UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IX AIR DIVISION

Technical Support Document

for

EPA ’ s Notice of Direct Final Rulemaking

for the

California State Implementation Plan

Yolo

- Solano Air Quality Management District

R ule 2.41

, Expandable Polystyrene Manufacturing Operations

Ju ly 28 , 2011

Prepared by Mae Wang2

Agency: Yolo

- Solano Air Quality Management District ( YS AQM D)

SIP Approved Rule:

none

Previously Submitted Versions:

none

Su bject of this Technical Support Document : YSAQMD Rule 2.41, Expandable Polystyrene Manufacturing Operations

A dopted on Septemb er 10 , 20 08 , submitted on December 23, 20 08

Rule Summary

Rule 2.41 was designed to control emissions of volatile organic compounds (VOC ) from

the ma nufacturing of expand able polystyrene (EPS) products. The rule requires all manufacturing emissions to be controlled by an emission control system with a capture efficiency of at least 90% and a destruction efficiency of at least 95%. The rule also requi res all EPS products to be manufactured with either low

- pentane or mid

- pentane beads. Compliance with these requirements is verified through yearly source testing and daily records of raw material usage, emissions control system operating parameters, and finished product specifications. Currently, there is only one EPS product manufacturing facility in YSAQMD.

EPA Evaluation

Generally, SIP rules must be enforceable (see section 110(a) of the Clean Air Act (CAA) ), must require Reasonably Available Co ntrol Technology (RACT) for major sources in nonattainment areas (see section 182(a)(2)(A) of the CAA ), must not relax existing requirements.

T he YS AQMD regulates a severe ozone nonattainment area (40 CFR 81) , so Rule 2.41 must
fulfill RACT as well as CAA section 110(l) requirements

.

Guidance and policy documents that we used to evaluate the submitted rule include the following:

1. Issues Relating to VOC Regulation Cutpoints, Deficiencies, and Deviations , EPA, May 25, 1988 ( The Bluebook ).

2. Guidance Document for Correcting Common VOC & Other Rule Deficiencies, EPA Region 9, August 21, 2001 ( the Little Bluebook ).3

3

. “Control of VOC Emissions from Polystyrene Foam Manufacturing ” (EPA

- 450/3

- 90

- 020

, September 1990 )

.

4

. SIP Relaxation

- Where previous v ersions of rules have been SIP approved, new submittals must comply with CAA §110(l) and §193 regarding SIP relaxations. We

evaluate SIP revision s to determine whether they would interfere with any applicable requirement concerning attainment and reasona ble further progress (RFP) or any other applicable requirement of the CAA ( see CAA section 110(l)) or modify, in a nonattainment area, any SIP

- approved control requirement in effect bef ore November 15, 1990 (see CAA section 193).

YSAQMD Rule 2.41 fulfill s the relevant criteria summarized above. This rule improves the SIP by regulating a source category for which no previous SIP rule exists. The rule is generally clear and contains appropriate monitoring, reporting, and recordkeeping requirements

to ensu re the emission limits are adequately enforceable. The rule does not interfere with any applicable requirement concerning attainment and RFP or any other applicable requirement of the CAA ( see section 110(l) of the CAA). The rule requirements are general ly consistent with the recommendations contained in EPA’s control technology documents and other district rules regulating the same category of sources. We are not aware of any more stringent controls demonstrated to be reasonably available for this indus try.

Additional Recommendations

The following suggested revisions are not currently the basis for rule disapproval, but are

recommended for the next time the rule is amended.

Because of the high quantities of emissions from the storage ar eas in these types of facilities, we recommend that the YSAQMD requir e controls during the storage and aging processes. Since there is only one facility in the YSAQMD, it would be possible to evaluate this situation on a

case

- by

- case basis. Some faciliti es in other districts have installed control systems for the storage areas, and South Coast AQMD Rule 1175 contains language establishing requirements

for these areas. We are aware that the control of emissions from these large warehouses may require buil ding alterations and may initially be viewed as cost

- prohibitive, but in some facilities the changes and installation of controls was determined to be technically and economically

feasible.

EPA Action

YS AQM D Rule 2.41 strengthens the SIP and fulfills the relevant Clean Air Act §110 and Part D requirements

. EPA staff recommends approval of Rule 2.41 pursuant to CAA §110(k)(3).