SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

RULE 4682 POLYSTYRENE, POLYETHYLENE, AND POLYPROPYLENE 

PRODUCTS MANUFACTURING

(Adopted May 21, 1992)(Amended December 17, 1992; June 16, 1994; September 20, 2007) 

1.0 Purpose 

 The purpose of this rule is to limit emissions of VOC and trichlorofluoromethane (CFC11) and dichlorofluoromethane (CFC-12) from manufacturing and processing of products 

composed of polystyrene, polyethylene, or polypropylene and from the storage of VOC 

blowing agents. 

2.0 Applicability 

 The provisions of this rule shall apply to any manufacturing, processing, and storage of 

products composed of polystyrene, polyethylene, or polypropylene. 

3.0 Definitions 

 For the purpose of this rule, the following definitions shall apply: 

3.1 APCO: as defined in Rule 1020 (Definitions). 

3.2 ARB: California Air Resource Board. 

3.3 Approved Emission Control System: any system used to reduce emissions and 

consists of a capture and a control device, which are approved, in writing, by the 

APCO. The control system must be maintained and operated in such a manner 

that meets the following requirements: 

3.3.1 The emission capture system shall collect at least 90 percent by weight of 

the emissions; and 

3.3.2 The control device shall reduce emissions from the emission capture 

system by at least 95 percent, by weight. 

3.4 Blowing Agent: any liquid, or gaseous material, including VOCs, that facilitates 

the formation of a cellular product from raw polymeric material. 

 3.5 Controllable VOC Emission Sources: fluff silos or bins, reclaim extruders, 

condenser devolatizer vents, styrene recovery unit vents, and reclaim die hood 

exhausts in which materials manufactured with a VOC blowing agent are 

processed, or are stored, and from which emissions are vented to the atmosphere. 

 3.6 Chlorofluorocarbon (CFC): any chlorinated fluorinated compound of carbon, 

excluding chlorodifluoromethane (HCFC-22), dichlorotrifluoromethane (HCFCSJVUAPCD 4682-1 9/20/2007 
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123), tetrafluoroethane (HFC-134a), dichlorofluoroethane (HCFC-141b), and 

chlorodifluoroethane (HCFC-142b). 

 3.7 EPA: United States Environmental Protection Agency. 

 3.8 Fluff Silo or Bin: a container utilized for the storage of ground polystyrene foam 

for recycling. 

3.9 Manufacturing Emissions: all emissions of VOC, CFC, or methylene chloride 

that occur during the manufacturing operation, quantified before any capture or 

control. 

3.10 Manufacturing Operation: a production line or lines consisting of all steps in the 

processing of a polymer or resin, from the receipt of raw polymeric material by 

the manufacturing facility through the final step prior to shipment of the finished 

product from the manufacturing facility, and that results in VOC emissions to the 

atmosphere. Individual steps include, but are not limited to: expandable bead 

storage, finished product storage/aging, extrusion, expansion, softening or 

annealing, intermediate (pre-puff) storage/aging, decomposition, molding, 

grinding, and forming. 

 3.11 Polyethylene (High and Low Density): linear thermoplastic polymers of ethylene 

with densities from 0.94 gram per cubic centimeter or higher. 

 3.12 Polymeric Material: a multi-molecular compound or mixture of compounds 

formed by polymerization and consisting essentially of repeating structural units. 

 3.13 Polypropylene: a high molecular weight thermoplastic crystalline polymer of 

propylene. 

 3.14 Polystyrene: a thermoplastic material which is a polymer of styrene. 

3.15 Raw Material: All polystyrene, polyethylene and polypropylene, and blowing 

agent used in the manufacturing operation, including virgin and recycled 

polymeric materials. 

3.16 Reclaim Die Hood Exhaust: an exhaust hood above reclaim extruder die 

intended to remove VOCs which escape from the extruder die. 

3.17 Reclaim Extruder: equipment used to reprocess ground polystyrene foam into 

polystyrene pellets. 

 3.18 Reclaim Extruder Vent: the vent or opening through which emissions are 

expelled from the reclaim extruder. 

 3.19 Volatile Organic Compound (VOC): defined in Rule 1020 (Definitions). 

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4.0 Exemptions 

 The provisions of Sections 5.1, 5.2, and 5.3 shall not apply to manufacturing and 

processing operations using polymeric materials containing less than 1 percent volatile 

organic compounds by weight, and not using a blowing agent in their process. 

 

5.0 Requirements 

Section 5.1 shall be effective until September 20, 2010 and shall not apply after that date. 

Sections 5.3 through 5.5 shall be effective on and after September 20, 2010. 

 5.1 No person shall operate controllable VOC emission sources at a polystyrene 

foam, polyethylene, or polypropylene manufacturing or processing operation 

unless one of the following VOC emission reduction methods is provided: 

 5.1.1 A blowing agent other than a VOC or trichlorofluoromethane (CFC-11) or 

dichlorodifluoromethane (CFC-12) is exclusively used; or 

 5.1.2 A system designed to achieve at least 90 percent VOC capture efficiency, 

and a thermal oxidizer which abates captured VOC emissions by at least 

95 percent by weight; or 

 5.1.3 VOC emissions are controlled by a method which achieves an emission 

reduction equivalent to Section 5.1.2 and which does not include the use 

of trichlorofluoromethane (CFC-11) or dichlorodifluoromethane (CFC12), and is approved by the APCO. 

 5.2 No person shall place, hold or store any VOC blowing agent in any stationary 

tank, reservoir or container having a capacity greater than 200 gallons unless one 

(1) of the following emission control systems is provided: 

 5.2.1 The container is a pressure vessel maintaining a working pressure at all 

times sufficient to prevent release of VOC emissions to the atmosphere 

under normal operating conditions; or 

 5.2.2 The container is equipped with an emission control device or system 

which collects and disposes of VOC emissions, and which achieves and 

maintains a vapor recovery/control efficiency of at least 95 percent by 

weight. 

5.3 The operator shall not conduct any manufacturing operations, as defined in 

Section 3.0, unless one of the following emission reduction methods is met: 

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5.3.1 The operator demonstrates, to the satisfaction of the APCO, that the total 

product emissions do not exceed 2.4 pounds of VOC per 100 pounds of 

total material processed, calculated over a monthly period. The total 

product emissions include emissions from the manufacturing operation, 

after controls, plus the residual blowing agent in the finished product. 

5.3.2 A blowing agent other than a VOC or trichlorofluoromethane (CFC-11) or 

dichlorofluoromethane (CFC-12) is exclusively used. 

5.3.3 An approved emission control system is installed and operating with 

manufacturing emissions vented only to the approved emission control 

system; and emissions from the final manufactured product are to be 

vented only to the approved emission control system for at least: 

5.3.3.1 48 hours, in the case of expandable polystyrene molding 

operations that process more than 800,000 pounds per calendar 

year of raw material; or 

5.3.3.2 24 hours, in the case of all other manufacturing operations. 

5.3.3.3 The provision of Section 5.3.3.1 or 5.3.3.2 are not required for 

any facility that only manufacturers polystyrene products and the 

highest concentration of the blowing agent in the product is 1.8 

percent or less by weight, within 15 minutes after the completion 

of the final processing step, prior to any finished product storage. 

 Verification of the concentration shall be demonstrated 

annually, pursuant to a protocol submitted to the District and 

subject to approval by the APCO. 

5.3.4 The operator demonstrates to the satisfaction of the APCO that the 

manufacturing emissions are no greater than the facility emissions which 

would occur under Section 5.3.3, as calculated according to Section 5.5, 

and which does not include the use of trichlorofluoromethane (CFC-11) or 

dichlorodifluoromethane (CFC-12). 

5.3.5 A control system that meets all of the following requirements shall be 

deemed as meeting the requirements of Section 5.3.4, unless the APCO 

determines that additional controls are required. 

5.3.5.1 The beads used in manufacturing have an annual-average VOC 

content of less than 4.2% per weight; and 

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5.3.5.2 The manufacturing emissions (not including finished product 

storage emissions) are controlled with an overall capture and 

control efficiency of at least 93% by weight. 

5.4 Operators subject to the provisions of Section 5.3.1, who exceed the limit based 

on the monthly calculation, shall be considered to have been in violation for each 

day of that monthly period. 

5.5 Facility emissions that would occur under 5.3.3 shall be calculated using the 

following formula, or other formula approved by the APCO and EPA: 

FE = [1- (0.90 x 0.95)] x [(P1+AS - P2) + (P2 - P3)] 

where 

FE = Facility Emissions for Section 5.3.3 

P1 = Amount of VOC in the received material 

AS = Amount of VOC added to the material 

P2 = Amount of VOC in the finished product, measured within 15 

minutes after the final processing step, prior to finished product 

storage. 

P3 = Amount of VOC in the finished product after warehousing for 48 

hours (for facilities subject to Section 5.3.3.1.1) or 24 hrs (for all 

others). (P2 - P3) = 0 for products with residual VOC amounts of 

1.8 percent or less by weight. 

5.6 Compliance Plan 

No later than March 20, 2009, operators complying with Section 5.3.1, 5.3.4, or 

5.3.5 shall submit to the APCO a Compliance Plan which includes all necessary 

information to show the proposed method of compliance with the applicable 

section. Such information shall include, but not be limited to: 

5.6.1 Potential VOC emissions, 

5.6.2 Overall VOC capture and control efficiency of VOC emission control 

system, 

5.6.3 Material VOC content at relevant manufacturing points. The amount of 

VOC in the material shall be determined using the test method in Section 

6.2.4, or other method approved by the APCO and EPA. 

5.6.4 VOC emission calculation formula which will be used to show 

compliance, and 

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5.6.5 Operational characteristics of the VOC emission control systems which 

will be monitored to show continued compliance with the applicable 

limits. 

5.6.6 Any operational or equipment limitations that are necessary to make the 

demonstration enforceable and which will be included as a condition on 

the appropriate Permit to Operate. 

6.0 Administrative Requirements 

 6.1 Recordkeeping 

 6.1.1 Any person subject to the provisions of this rule, including exempt 

facilities, shall maintain records of operation, including but not limited to 

the amount of material processed, the equipment used, and the type of the 

blowing agent used. Records shall be maintained with a minimum 

monthly totals with the ability to calculate daily averages in any given 

month. 

 6.1.2 Any person using an emissions control system as a means of complying 

with this rule, shall maintain daily records of key system operating and 

maintenance procedures which will demonstrate continuous operation and 

compliance of the emission control device. Key system operating 

parameters are those necessary to ensure compliance with VOC emission 

requirements such as temperature, pressures, and flowrates. 

6.1.3 Operators complying with Section 5.3.1 shall maintain records necessary 

to show compliance with that section and shall, once every month, 

calculate the daily average VOC emissions, based on the records for the 

preceding monthly period, according to the approved VOC emission 

calculation formula. 

6.1.4 Effective on and after September 20, 2007, the operator shall keep in the 

facility all records required to demonstrate compliance with the 

requirements of this rule for a minimum of five years. The records shall 

be made available at the facility during normal business hours to the 

APCO, ARB, or EPA. The records shall be submitted to the APCO, ARB, 

or EPA upon request. 

 6.2 Test Methods 

Alternative test methods, that are equivalent to those specified in Sections 6.2.1 

through 6.2.4, may be used, provided that those test methods have been approved 

in writing by the APCO and EPA. 

 6.2.1 The control efficiency of the emission control system shall be determined 

using EPA Methods 2, 2A, or 2D for measuring flow rates, and EPA 

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Methods 25, 25A, or 25B for measuring total gaseous organic 

concentrations at the inlet and outlet of the control device. 

6.2.2 The capture efficiency of an emission capture control system shall be 

determined according to EPA’s “Guidelines for Determining Capture 

Efficiency,” January 9, 1995 and 40 CFR 51, Appendix M, Methods 204-

204F, as applicable. 

 6.2.3 EPA Method 18 or ARB Test Method 422 for determination of exempt 

compounds and halogenated blowing agents. 

6.2.4 The VOC blowing agent contained in polymeric materials shall be 

determined using South Coast Air Quality Management District 

(SCAQMD) Method 306 (Analysis of Pentanes in Expandable Styrene 

Polymers) or Bay Area Air Quality Management District (BAAQMD) 

Method 45 (Determination of Butanes and Pentanes in Polymeric 

Materials). 

6.2.5 When more than one test method or set of test methods is specified for any 

testing, a violation of any requirement of this rule established by any one 

of the specified test methods or set of test methods shall constitute a 

violation of this rule. 

7.0 Compliance Schedule 

 

On and after September 20, 2010, operators shall be in compliance with the applicable 

provisions of Sections 5.3 through 5.5, unless otherwise noted. 

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