SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

FINAL STAFF REPORT

Revised Proposed Amendments to Rule 4682 (Polystyrene Foam, Polyethy lene & Polypropylene Manufacturing)

Prepared by: George Heinen, Supervising Air Quality Engineer Manuel Salinas, Air Quality Engineer Reviewed by: Joven R. Nazareno, Senior Air Quality Engineer Ellyce Baldwin, Supervisi ng Air Quality Inspector Mark Schonhoff, Senior Air Quality Engineer

September 20, 2007

I. REASONS FOR RULE DEVELOPMENT AND IMPLEMENTATION

A. District Attainment Status of National Ambient Air Quality Standards

In the San Joaquin Valley Air Basin (SJ VAB), monitored levels of ozone exceed National Ambient Air Quality Standards (NAAQS), which are set at levels that protect public health and welfare. Consequently, the U.S. Environmental Protection Agency (EPA) has classified the SJVAB’s air quality as serious for its nonattainment designation for the federal eight-hour ozone NAAQS. Under the now revoked federal one-hour ozone standard, the SJVAB was classi fied as extreme nonattainment.

The federal Clean Air Act (CAA) requires air districts in nonattainment areas to prepare plans that are designed to achieve and mainta in the NAAQS by the earliest practicable date, and no later than attainment deadlines given in the CAA. The San Joaquin Valley

Unified Air Pollution Control District (District) adopted the Extreme Ozone Attainment

Demonstration Plan ( EOADP ) on October 8, 2004. The EOADP calls for a reduction in volatile organic compound (VOC) emi ssions by 2010 by amending Rule 4682 (Polystyrene Foam, Polyethylene & Polyprop ylene Manufacturing) to further reduce VOC emissions by introducin g more stringent limits.

Although EPA has revoked the federal 1-hr ozone NAAQS the VOC emission reduction

commitment from Rule 4682 Amendment must still be met. EPA’s final Phase 1 rule implementing the 8- hr ozone NAAQS (69 FR 23858 and 70 FR 30592) identifies a number of federal CAA requirem ents that applied to an area by virtue of its 1-hr ozone

nonattainment classification and that conti nue to apply after revocation of the 1-hr ozone NAAQS [40 CFR 51.900(f)]. Because the SJVAB was classified as extreme nonattainment, and because an attainment demonstration (as defined by 40 CFR

Final Staff Report with Appendices for Revised Proposed Amendments to Rule 4682SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Final Staff Report: Rule 4682 September 20, 2007

2 Final Staff Report with Appendices for Revised Proposed Amendments to Rule 4682 51.905) is one of the requirements, the EOADP becomes one of the requirements that still apply to the SJVAB by vi rtue of its former cl assification under the now-revoked 1-hr
ozone NAAQS. The EOADP uses the VOC emissions reductions from the Rule 4682 Amendment to project attain ment. Without the reducti ons from the Rule 4682 Amendment, the EOADP does not project attainment a nd therefore does not meet the requirements of 40 CFR 51.905. Thus t he District must pr oceed with Rule 4682 emission reductions even though the standard was revoked.

This rulemaking project is part of the Distric t’s ozone attainment strategies. As such, this project is subject to the fo llowing state and federal requirements:

• Ozone attainment plans need to implement control measures as expeditiously as practicable, and provide for attainment. Clean Air Act (CAA) Section 172(c)(1)

• Ozone attainment plans should provide for best available retrofit control technology (BARCT) for existing permitted sources. California Heal th & Safety Code (H&SC) Section 40919(a)(3)

• Ozone attainment plans should include “all feasible control measures.” H&SC Section 40914(a)(2)

The California Air Resource Board (ARB) inte rprets “every feasible control measure to mean that, at a minimum, a district consi der regulations that have been successfully implemented elsewhere. They should also consider going beyond what has already been accomplished by evaluation of new tec hnologies and innovative approaches that may offer potential emission reductions. Fu rther, districts should consider not only technological factors, but also social , environmental, economic (e.g., cost effectiveness), and energy factors which prev ail in the District, along with the resources realistically available to the district to adopt, implement, and enf orce the measures.”

To satisfy the attainment goals of the oz one plan, District staff would amend Rule 4682 to implement the emission control measure in the District’s ozone attainment plan. The

draft amendments to Rule 4682 will seek to obtain as much reduction of VOC emissions from existing polystyrene foam, polyethyle ne, and polypropylene product manufacturing operations as expeditiously as practicable, technologically feasible, and economically reasonable, as determined by the District’s Go verning Board. The draft amendments to Rule 4682 achieve emissions reduction by requiring either compliance with a VOC

emission limit or the operation of a VOC capture and control system to reduce the emissions from the manufacturing and st orage of polystyrene, polyethylene, and polypropylene products. This rulemaking proj ect is also intended to satisfy the state and federal requirements identified above.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Final Staff Report: Rule 4682 September 20, 2007

3 Final Staff Report with Appendices for Revised Proposed Amendments to Rule 4682 B. Description of the Project

This category was listed in the Ozone Rate of Progress Plan as an all feasible measure suggested by the EPA. Amending Rule 4682 is intended to reduce VOC emissions from manufacturing polymeri c foam and foam products by specifying VOC emission limits or emission control devices. The two major categories of processes in this category are extruded foam products and mo lded foam products. Although there are key differences between the two processes, each process employs a blowing agent to create spaces in the plastic structure to pr oduce a strong, but lightweight material with good thermal insolating properties that is inert to water and grease.

The most common blowing agent used is in the Valley is pentane, but chlorofluorocarbons (CFC) and carbon dioxi de, (CO2) have also been used in other locations. Pentane is a VOC that is a prec ursor to ozone and therefore a pollutant of interest to the District. CFC are ozone-deplet ing chemicals, which can rise to the upper atmosphere and impact the stratospheric-ozone layer, so they are not typically found in

modern facilities. Non-VOC blowing agents, such as carbon dioxide, CO2, may be used in some cases, but CO 2 systems require specifica lly constructed equipment and are not suitable making for all products, due to the affect on the foam characteristics compared to pentane. One Valley facility uses 10% CO2 in conjunction with a VOC blowing agent.

Extruded Foam Product Manufacturing Overview

Extruded foam products begin with plastic beads that typically contain little or no VOC

content. The beads are delivered in bulk an d pneumatically transferred to storage silos until needed. Basic steps in the manufacturing process include: the mixing and extrusion of the foam sheet; storing or aging of the sheet s, thermoforming the sheets into the desired shapes using heat and vacuum; and packaging and storage of the finished products. Excess material that is trimmed off during manufacturing is recovered and recycled either on-site or of f-site at the bead manufacturing facility.

The extrusion process consists of moving the beads from the stor age silos and heating the beads with a VOC-containing blowing agent, under pressure in an auger. As the materials mix, the blowing agent expands and forms bubbles in the plastic which is then extruded through a forming die to form a conti nuous foam sheet of a desired thickness. The sheet of foam is cooled, cut to the needed width, and moved to a storage area for aging. At this point, the concentration of th e entrained blowing agent in the foam is too high for manufacturing purposes and a period of off-gassing or aging is required.

After aging, which can take several days, the foam sheets are moved to the thermoforming machines. These machines us e a combination of heat and pressure to which produce a variety of products includi ng food-grade trays and packaging for sales and service. The completed products are then packaged and sent to storage areas toSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Final Staff Report: Rule 4682 September 20, 2007

4 Final Staff Report with Appendices for Revised Proposed Amendments to Rule 4682 continue the off-gassing of blowing agents and to await shipping. After manufacturing, the completed product can still retain 50% or more of the original blowing agent introduced during the extrusion process.

The recovery and recycling of excess or trimmed material includes shredding or grinding the material until it is small enoug h to be reintroduced to the extruder. The recycled material still contains some percent of blowing agent from the original foam manufacturing process, but mo re blowing agent can be added dur ing extrusion, to make up for the amount lost during manufacturing.

The primary points of VOC em issions are the extrusion and sheet forming process; aging of the rolls; thermoforming; and finished goods storage, but the products continue to release VOC from the residual blowing agent contained in the ai r pockets. As will be discussed later, the existing operations ma y have VOC capture and control equipment to reduce some or all of the manufacturing emissions.

Most extruders produce long sheets of foam fo r thermal molding or other purposes, but some extruders can also produce smaller products such as loose fill material which is used as packing material to cushion items dur ing shipping. There are currently no loose fill manufacturers in the Valley.

Molded Foam Product Manufacturing Overview

Molded foam products use pre-expanded beads and direct-injected molds, rather than

extruded foam sheets and thermo forming machines. The raw material for molded foam typically contains the needed blowing agent w hen it is received at the facility. The material handling and storage containers must t herefore have VOC emission controls to

reduce emissions from the raw materials.

Prior to molding, the beads are pre-expanded using heat to slightly expand the blowing agent and puff the beads. The beads are then cooled and stored in emission-controlled containers for intermediate aging and stabilization. Molding involves filling the mold with puffed beads; heating the beads to complete their expansion; and releasing the molded product. Depending on the product, a negative pressure or vacuum may be used to better fill the mold and produce a uni form contact with the mold surface.

Finished products may require trimming to reduce flashing or seam material that escapes at mold joints or pour points. An y waste materials are collected for recycling. Finished materials, which can retain signif icant portions of the blowing agents, are packaged and moved to st orage until shipping.

The primary points of VOC emissions are the raw material and storage systems, preexpansion and puff bead storage, molding; and finished goods storage, but the products

continue to release VOC from the residual bl owing agent contained in the air pockets.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Final Staff Report: Rule 4682 September 20, 2007

5 Final Staff Report with Appendices for Revised Proposed Amendments to Rule 4682 As will be discussed later, the existing oper ations may have VOC capture and control equipment to reduce some or all of the manufacturing emissions.

There are three major types of molding: blocks, cups , and shapes. Block molders produce large blocks of foam which are cut into sheets such as building insulation, or other desired shapes after molding. Cup mo lders make cups, bowls and other similar containers. Shape molders make custom f oam shapes such as grape shipping boxes or to packing inserts to protect electronic equipment during shipment.

Valley Foam Product Operations

District staff identified twelve manufacturers of various located within the District. The majority of manufacturers in the District are manufacturing polyst yrene foam products. Three manufacturers produce products fr om extruded polystyrene (XPS) while the majority of the operators us e expanded polystyrene (EPS) to mold foam products. Molders include one foam cup manufacturer, several grape box manufacturers and a few specialty products manufacturers. Currently, there are no block molding manufacturers operating in the District so rule amendments will not address this industry. Any new facility would undergo the New Source Review, which include a Best Available Control Technology (BACT) deter mination process, so Rule 4682 will not attempt to set BACT fo r new operations.

C. Rule Development Process

As part of the rule development process, District staff conducted a public scoping meeting in July 2006, the first workshop in April 2007, a technical working group meeting in June 2007, and a final workshop in July 2007. At the scoping me eting and workshop District

staff solicited comments fr om interested par ties, affected industry operators, and

stakeholders. Affect ed source operators, consultants, vendors and manufacturers of control technologies, and trade associations were also requested to provide technical feasibility and compli ance cost information which woul d be useful in developing the

amended rule. The information ob tained from the public meetin gs may be used to develop the proposed amendments to th e rule and staff report.

Pursuant to state law, Dist rict staff are required to perform a socioeconomic impact analysis prior to the adoption, amendment, or repeal of a rule that has significant air quality benefits or that will strengt hen emission limitations. As par t of the District socioeconomic analysis process, District sta ff sought a limited number of re presentatives from interested groups to participate as members of a Focu s Group. The Focus Group was to assist District staff in determining the appropriate method of gathering information on regulatory compliance costs and business impacts resulting from comp liance with the rule. The

results of the socioeconomic an alysis were publishe d in a report along with the refined version of the proposed rule to th e public and inte rested parties.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Final Staff Report: Rule 4682 September 20, 2007

6 Final Staff Report with Appendices for Revised Proposed Amendments to Rule 4682 D. Summary of Revised Proposed Amendments to Rule 4682

Following are the major changes proposed for Rule 4682. In establishing proposed VOC emission limits, District staff consi dered the limits that have been achieved in practice, as well as limits achievable by f easible control technolog ies. District staff evaluated BACT determinations established by t he District, other California air districts, other states, including those that are recommended by control technology manufacturers and stakeholders. These changes are based on similar rules from other

California air districts and BAC T determinations with the District.

Affected operators would have to comply wit h one of four emission control options:

1. Demonstrate that they emit no mo re than 2.4 lb of VOC for each 100 pounds of total material processed, or 2. Use a non-VOC blowing agent, or 3. Control all manufacturing emission s with an approved emission control system and store the finis hed product in a controlled warehouse for 24 or 48 hours, or 4. Demonstrate that they release no more emissions than would have occurred if complying with option 3.

Operators had commented that the demonstration opti on (number 4 above) needed clarification. Rule language was added to outline an option that would be considered equivalent to the demonstrati on. Definitions and rule language was added or modified to clarify and strengthen rule compliance. Recordkeeping, testing and compliance dates for the new requir ements were updated or added.

II. CURRENT AND PROPO SED REGULATIONS

Rule 4682 currently limits emissions fr om polystyrene foam, polyethylene, and polypropylene manufacturing, but only for selected operations and equipment within the process. Those selected operations are curr ently defined as controllable VOC emission sources. This rule would be expanded to include VOC emission reduction or control from all manufacturing processes including product curing areas and general product storage areas, similar to those employed by several of the existing sources.

A. Existing Rule 4682

Rule 4682 was adopted on May 21, 1992, and subsequently amended on December 17, 1992, and June 16, 1994. The purpose of Rule 4682 is to limit VOC and chlorofluorocarbon (CFC) emissions from m anufacturing and processing of polystyrene foam, polyethylene, and polypropylene and fr om the storage of VOC blowing agents.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Final Staff Report: Rule 4682 September 20, 2007

7 Final Staff Report with Appendices for Revised Proposed Amendments to Rule 4682 The rule applies to any polystyrene foam, polyethylene, and polypropylene manufacturing and processi ng operations.

Certain provisions of the current rule do not apply to manufacturing and processing operations using polymeric materials cont aining less than 1 percent volatile organic compounds by weight, and not using a blowing agent in their process.

The rule requirements contain options for compliance. The options include using non VOC or CFC blowing agents, operating with a collection system and control which abates the captured emissions, or controllin g VOC emissions with an alternative method that achieves emission reductions equiva lent to the collection system and thermal oxidizer. The rule also requires emi ssion control systems for VOC blowing agent storage and contains provisions for recordkeeping.

B. Requirements in Other California Air Districts

District staff considered the standards/requirem ents in the rules of other California air

districts for similar manufactu ring operations. In particular, District staff evaluated the Bay Area Air Quality Management Distr ict (BAAQMD) Rule 52 (Polystyrene, Polypropylene, and Polyethyle ne Foam Product Manufacturing Operations) and the South Coast Air Quality Management Distr ict (SCAQMD) Rule 1175 (Control of

Emissions from the Manufacture of Polymeric Cellular Foam Products).

BAAQMD Rule 52 :

BAAQMD Rule 52 requires control of emis sions from foam product manufacturing operations by complying with specific VOC emissions limits depending on the product type or by installing and operating an approved VOC emission control system.

• “Manufacturing operations” are defined as: a production line or lines consisting of all steps in the processing of a polym er or resin, from the receipt of raw polymeric material by the manufacturing facility through the final step prior to shipment of the finished foam produc t that results in a change in the form, chemical composition, or any chemical or physical property of the material, and

that results in VOC emissions to the at mosphere. Individual steps include, but are not limited to, expandab le bead storage, finished product storage/aging, extrusion, expansion, softening or annealing, intermediate (pre-puff) storage/aging, decomposition, molding, grinding, and forming. This definition covers a broader range of processes than the definition on District 4682.

• Polyethylene and polypropylene foam product manufacturing operations must have collection systems (85% efficien cy) and a control system (98%).SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Final Staff Report: Rule 4682 September 20, 2007

8 Final Staff Report with Appendices for Revised Proposed Amendments to Rule 4682 • Polystyrene Foam manufacturers must meet emission limits, depending on the product line. These limits are

o 2.4 lb VOC/100 lb of raw material for block molders and loose fill;

o 2.7 lb VOC/100 lb of raw ma terial for shape molders; and

o 2.89 lb VOC/100 lb of raw material for cup molders.

SCAQMD Rule 1175 :

SCAQMD Rule 1175 basically prohibits a VOC blowing agent for any operation except expandable polystyrene (EPS) molding operations.

• For EPS molding operations, Rule 1175 r equires that manufacturing emissions and residual blowing agent total to le ss than 2.4 pounds per 100 pounds of raw material processed.

• Operators who could not achieve the above standards are required to install and operate an approved VOC emission cont rol system. SCAQMD also final manufactured products to be stored in a controlled warehouse for 48 hours for EPS operations processing more than 400 tons per year and 24 hours for all other operations.

• Rule 1175 defines manufacturing operati ons as: every step of the processing of a polymeric material from delivery of t he raw material, include the first 48 hours of storage of the final product.

SCAQMD Rule 1175 is currently open for amendment. Based on the draft language, the amended rule would allow block molding m anufacturers to employ a cost-effective compliance alternative that still produces equi valent emission reductions. According to the June 2007 Preliminary Dr aft Staff Report, SCAQMD staff will propose allowing a

block manufacturer to ov er-control manufacturing emissions and use beads with less blowing agent instead of controlling warehouse emissions. The proposed overall control efficiency of the manufacturing emi ssions is 93 percent. Preliminary analysis indicates that South Coast’s proposal is equivalent to the District’s proposed Compliance Option 3 as it applied to block manufacturers. Although the District has no block manufacturers, this option can apply to other types of foam manufacturing. The proposed rule language inclu des adequate language to require additional controls, if necessary, to demonstrate equivalence. T he VOC emission standard of 2.4 lb per 100 lb of raw material has not been proposed to be amended and is considered achieved in practice. The SCAQMD proposed rule and SCAQMD June 2007 prelim inary draft staff report are included in this report as Appendix F.

C. Affected Sources and Control Technology

Rule 4682 was implemented to reduce emissions of VOC from this source category. Manufacturers within the District are still utilizing VOC, prim arily pentane and butane, as a blowing agent. Possible controls incl ude switching to an al ternative, non-VOCSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Final Staff Report: Rule 4682 September 20, 2007

9 Final Staff Report with Appendices for Revised Proposed Amendments to Rule 4682 blowing agent, employing capture and c ontrol systems for t he VOC emissions, modifying the manufacturing process, and usi ng materials with lowe r VOC contents.

Currently in the District t here are sources that have c hanged to lower VOC-containing blowing agents and utilize regenerative thermal oxidizers or boilers for control of VOC emissions. The requirements in the rule provide options for compliance for those sources that cannot change bl owing agents. There are operators in the District achieving control of manufacturing em issions including wa rehouse areas and/or meeting the VOC emissions standar ds added into the current dra ft of the rule. There is also a facility, subject to the rule, that c hose to collect and control the emissions by operating with a permanent total enclosu re on their manufacturing operation.

General information on available control technologies follows:

Adsorption Vapor Recovery :

Adsorption vapor recovery is accomplis hed by passing the VOC-laden gas through beds containing adsorbents that have a high su rface area to weight ratio. Typical adsorbents are activated carbon, zeolite, or organic polymers. As the gas stream passes through the bed, organic compounds adsorb weakly onto the adsorbent’s surface. Adsorption of the hydrocarbon mo lecules proceeds until the available surface

area is filled or saturated with VOC molecu les. The VOC molecules are retained until the regeneration step, or disposal of the spent adsorbent.

Desorbing or removing captured VOCs r egenerates the adsorbent. There are three basic types of adsorption systems available to recover or remove hydrocarbon vapors

from an air stream. Two of these systems regenerate the ads orbent in-situ for reuse. The third system requires removal of the ads orbent to another site for regeneration.

The two systems that provide in-situ regeneration are: Pr essure Swing Regenerated Systems and Thermally Regener ated Systems. In the fi rst system, decreasing the pressure or providing a backpressure creates a relative vacuum that pulls the capture

VOC off the adsorbent. The se cond method involves increasi ng the temperature of the bed to evaporate off the captur ed VOC. In both syst ems, the released VOC would be vented it to a destruction system or chille r/condenser, depending on the value of the recovered VOC. These regenerative ads orption systems have the advantage of concentrating the collected VOC fo r either reuse or efficient oxidation, compared to a

thermal oxidize.

A third type of system, which requires remo val of the absorbent to another site for regeneration or disposal, is a once through si ngle use or canister system. Canister systems can usually be purchased directly fr om the manufacturer, but given the highSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Final Staff Report: Rule 4682 September 20, 2007

10 Final Staff Report with Appendices for Revised Proposed Amendments to Rule 4682 volume of the exhaust stream and the am ount of emissions to be controlled, nonregenerative systems would be less practical than on-site regeneration system.

Thermal Oxidation (Incineration) :

A thermal oxidizer (TO) destroys VOCs by the process of combustion. A basic TO system consists of a combustion chamber, bur ner, stack, and combustion controls. All hydrocarbons are oxidized to carbon diox ide and water vapor by the proper mix of temperature, residence time and turbulence wit hin the reactor chamber. Combustion of the contaminated gas stream occurs at high temperatures, normally 650 o C to 870 o C (1,200 o F to 1,600 o F) when treating low concentration streams. The relatively lowpressure, low-temperature of the TO does not favor NOx production so the amount of NOx produced by the combustion is typically much less than the VOC destroyed.

TO systems can be divided into recuperat ive or regenerative systems; based on methods used to increase operating efficiencies by capturing heat fr om the combustion process. Recuperative TO systems increase f uel efficiency by use of a gas pre-heating section and a heat recovery section to capture waste heat to preheat incoming air. Heat recovery can be as high as 70%, significant ly reducing the amount off fuel needed to

maintain the TO at its operating temperature.

Regenerative TO systems use a ceramic heat -exchange bed to preheat process air to

within 5% of the oxidation te mperature. A reg enerative TO system provides extremely high thermal-energy recovery; up to 95% of heat energy can be recovered. PM10 and VOC conversion efficiencies range from 97% to 99.9% for recuperative and 95% to 99% for regenerative TO systems.

Boilers :

Boilers can be an appropriate VOC cont rol technology at EPS foam product manufacturing facilities because they pr ovide necessary process steam for the operation and control VOC emi ssions. Boilers can be modified or designed to burn the collected vapors via direct combustion and dec rease the boiler’s fuel consumption. Boilers at these types of facilities have demonstrated VOC destruction efficiencies of at least 98% by weight.

Lower-VOC Beads and CO2 :

For some molding operations, it may be possi ble to reduce VOC emissions by starting

with beads that contain 2.4 to 4.0 percent blowing agent rather than beads with 4.0 to 6.5 percent blowing agent. The lower the initial amount of blowing agent, the fewer

emissions will be released durin g manufacturing and the lower t he residual quantity. As noted earlier, the SCAQMD is proposing to amend their rule to allow the use of 60%SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Final Staff Report: Rule 4682 September 20, 2007

11 Final Staff Report with Appendices for Revised Proposed Amendments to Rule 4682 low-pentane beads (less than 4% blowi ng agent) and 40% mid-pentane beads (less than 5.2 %blowing agent) as a control option for block manuf acturers, in conjunction with over controlling other operations. Such beads, however, may not be suitable for all processes and products since the blowing agent determines the characteristic of the final product.

As stated earlier, CO2 is sometimes used as a blowing agent, typically mixed with a traditional blowing agent, but it does not always produce acceptable results. The

exfiltration rate of the blowi ng agent affects the size of the small voids in the foam, which impact product qual ities. The exfiltration rate al so determines material strength during cooling process because if there is in sufficient blowing agent, the holes will sag, changing the physical proper ties of the foam.

Manufacturing Process Modifications :

For some operators, modifica tions to their manufacturing process can be made that will enhance their VOC capture and cont rol system. Many foam mo lders, for instance, use

VOC controls on their mold vacuum lines. This efficiently controls VOC during molding while minimizing the amount of air that would otherwise hav e to be controlled from a

traditional collection hood over the molding machinery.

According to the SCAQMD sta ff, a cup molder was able to modify their pre-expansion process to drive off more unneeded blowing agent into an existing control device and meet the 2.4 lb VOC limit. It is not possi ble to completely eliminate the blowing agent

which is need in the moldi ng stage, but the process modi fication eliminated, in a controlled manner, VOC emissions which would otherwise have been released during molding or as post-processing residual. No t every manufacturer will, however, be able

to make identical reductions due to operational, physical layout, and product quality

considerations.

D. Revised Proposed Amendments

In developing the draft amendments to Ru le 4682, District staff evaluated the requirements of BAAQMD Rule 52 and SCAQMD Rule 1175 which staff believe as meeting the standards for BARCT and all Feasib le Control Measures. Based on staff’s evaluation, the following are the dr aft major amendments to Rule 4682:

1. Sections, 1.0 Purpose and 2.0 Applicability – Modified the language of these

sections to make them clearer.

2. Section 3.0 Definitions – Added nine new definitions for terms used in the proposed amendments: APCO, ARB, A pproved Emission Control System, Certificate of Analysis, EPA, Low- pentane Bead, Manufacturing Emissions, Manufacturing Operation, Mid-pentane Bead and Raw Material. TheseSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

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12 Final Staff Report with Appendices for Revised Proposed Amendments to Rule 4682 definitions were developed to reflect the most stringent rule in place. In particular, the definition fo r manufacturing emissions no w includes all processes, compared to the current rule which only included a short list of process points.

3. Section 4.1 (Exemption) – The existing language pertaining exempts facilities not using a blowing agent, either in th e raw material or added during the manufacturing process. It was s uggested that the language be changed to
exempt operators not using a blowing agent which contains VOC or CFC, but that change would be a relaxation of the current rule. Sect ion 5.3.2, however does recognize the exclusive use of su ch blowing agents to be an acceptable compliance option.

4. Section 5.0 Requirements – Section 5.3, which is effective 36 months after rule adoption, provides four met hods with which an operator c an comply with the rule. These options are based on the current SCAQMD rule. The options include

1. Demonstrate that they emit no mo re than 2.4 lb of VOC for each 100 pounds of total material processed, or 2. Use a non-VOC blowing agent, or 3. Control all manufacturing emissions with an approved syst em and store the finished product in a controlled warehouse for 24 or 48 hours, or 4. Demonstrate that they release no more emissions than would have occurred if complying with option 3. Based on stakeholder comments, operators using VOC-limited beads and controlling 93% of the processing emissions are assumed to be in compliance with option 4, unless the APCO determines additional controls are required.

Compliance Option 1: 2.4 lb VOC per 100 pounds raw material limit

The proposed 2.4 lb VOC limit includes all uncontrolled emissions released during manufacturing and the residual amount of blowing agent contained in the finished product. This standard is equivalent to the SCAQMD and is already being achieved by a SCAQMD cup molder and, on at least two new lines, of a Valley foam extruder. Staff's initial revi ew of the existing operating permits and residual VOC content information provided by the operators indicates that the limit may be already achieved by some Valley shape molding operations.

The difficulty with complying with this opt ion is the natural variability in the material received for molding operations . Extruders can closely control their VOC content during the extrusion process by metering in the desired amount for the raw material. Molders have to rely on the supplier, transportation conditions and time, as well as the prevailing tem perature and humidity conditions in the manufacturing plant. Since there is no c ontinuous, real-time method of verifying

the VOC content of both the raw materi al and the finished product, staff proposeSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Final Staff Report: Rule 4682 September 20, 2007

13 Final Staff Report with Appendices for Revised Proposed Amendments to Rule 4682 to use a 30-day average to calculate comp liance. That will help smooth out the naturally occurring variations on materi al VOC content. In keeping with EPA policy, the rule also states that any violation of t he 2.4 lb VOC standard represents a separate violat ion on each of the 30 days during that period. The SCAQMD does not require a calculation based on a 30-day average, just

that it be demonstrated that the limit is met. Therefore, the District rule is more stringent, even allowing for the equivalent limits. Further , the District requires the operator make a calculation every 30-days which demonstrates continued compliance with the standard based on operat ional data. Each demonstration must be pre-approved by the APCO and EPA. Permit conditions will be required to ensure enforceability of the demonstration.

The BAAQMD requires the limit be met "at a ll time", but it is not clear how that

would be demonstrated on a continuous base. Also, some of their limits are higher that those proposed by the District so on the whole, the Di strict's rule is considered to be at least as stringent. All three rules require monitoring and recordkeeping of control equipment operat ing parameters to ensure continued compliance with the assumption on which the VOC limit determination would be

based.

During the workshops, operators had or iginally requested a VOC emission standard, based on raw material throughput, for each process, similar to those of
the BAAQMD rule. To be assured of rule stringency, we are required to adopt the single South Coast standard, which is t he more stringent of the rules. Based on existing operations, the 2.4 lb VOC limit appears to have been achieved in practice.

Compliance Option 2: Use of a non-VOC blowing agent

The use of a non-VOC, non-CFC blowing agent is in the existing rule and recognizes that alternativ e blowing agents have been developed that can prevent VOC emissions without harming the stratosp heric-ozone layer. As previously mentioned, such alternatives are not necessa rily feasible for all products. Also, modifications to an existing facility to handle the alternative blowing agent could amount to a complete rebuild of the material handling systems, controls and safety systems. This option, is prov ided for those manufacturers, who may be

able to avail themselves of such materials.

Compliance Option 3: Control of the manufacturing emissions and warehouses

This option is included to fulfill the stat e requirement for All Feasible Control Measures. Like Compliance Option 1, it has been part of the SCAQMD rule for over a decade and is achieved by a Valley foam extruder. Stakeholders cite concerns with the mandatory 24/48 hour wa rehouse provision because it of theSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Final Staff Report: Rule 4682 September 20, 2007

14 Final Staff Report with Appendices for Revised Proposed Amendments to Rule 4682 cost of controls and construction, spac e requirements, delays in shipping, and safety concerns. These concerns are ra ised despite two Valley operators, which currently operate controlled warehouses. Based on the stakeholder comments, however, it is unlikely that other operat ors will choose this compliance option. Rule language has been added to show how the emissions equivalent to this option would be calculated. This info rmation would be necessary for operators who choose to comply with Compliance Option 4.

Compliance Option 4: Demonstrate an equivalent emission reduction as would be obtained under Compliance Option 3:

This provision is similar to the current rule Section 5. 1.3, but updated to meet the more stringent requirement of Option 3. This provides the operator the flexibility to use a variety of materials, as long as the emission reductions are equivalent to those that would be achieved by t he fully controlling manufacturing and warehousing. Instead of controlling a st orage warehouse, operators could either reduce those emissions earlier in the proc ess with low-VOC materials or further reduce emissions during manufacturing. Since this requires equivalent emission reductions as the Option 3, staff believes that the District's rule is just as stringent as the SCAQMD rule. Rule language has been added for enforceability of this demonstration, similar to that de scribed for Compliance Option 1.

The SCAQMD rule is currently open for amendment to allow block molders to show rule compliance by controlling 93% of process emissions. Based on stakeholder comments, staff propose to add similar language to Rule 4682. The APCO would still have the right to require additional controls, should emissions be greater than those generated under Comp liance Option 4. Because this option is not a mandatory compliance r equirement and no additional emissions would result, staff do not consider this to be a significant change.

1. Section 6.0 Recordkeeping – Section 6.1.3, which will be effective on and after (36 months from rule adoption date), requires that records be retained 5 years instead of 2 as currently required. Records are to be kept at the facili ty and be made available or submitted to the APCO, ARB, and EPA upon request. The change from the current two years to five years is based on a long-standing EPA policy and is being

added to District rules as they are amended.

2. Section 6.2 Test Methods – Provides fo r equivalent test methods to be used as approved by the APCO and EPA. Added Section 6.3 which lists the test method for collection device efficiency and Section 6. 4 which list the test method for VOC

content.

3. Section 7.0 Compliance Schedule – New Se ction 7.3 stipulates the date where all operators are to be in compliance with all provisions of the rule. The finalSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Final Staff Report: Rule 4682 September 20, 2007

15 Final Staff Report with Appendices for Revised Proposed Amendments to Rule 4682 compliance date will be 36 months from rule adoption date. This has proven to be a sufficient time in the past for operators to implement major changes that are need to comply with rule requirements.

Significant issue raised at the Sept ember 20, 2007 Governing Board Hearing.

During the public hearing for Rule 4682 an operat or requested of the board a change in the rule language concerning the calculated av eraging period. The oper ator specifically requested that the daily average VOC emissions be performed "monthly" or on a "calendar month" instead of a 30-day period. A monthly average would be in line with corporate practice and such a policy is cons istent with Section 6. 1.1 of the rule, is consistent with facility permit conditions, and would avoid the need to perform midmonth inventories. The Governing Board agreed that the request was reasonable and directed staff to make this change.

EPA has commented that an av eraging period greater than 24 hours would create an approvability issue unless certain conditions are met. EPA discusses these conditions in “Averaging Times for Compliance with VO C Emission Limits – SIP Revision Policy”, John O’Connor, US EPA – OAQPS Me morandum dated January 20, 1984.

District staff identified, in the O’Connor memo, a set of criteria that must be fulfilled in order to maintain the monthly average. The five conditions and the District’s

demonstrations are as follows.

1. The VOC limits specified in an enforc eable form with appropriate compliance

dates . Rule 4682 Section 5.0 Requirements, Section 5.3.1, cont ains a VOC limit of 2.4 lbs per 100 lbs of total material processed. A compliance deadline of September 20, 2010 is specified in Section 7.0 Comp liance Schedule.

2. A description of the affected processes and associated historical production and operating rates. The Final Staff Report for Rule 4682 addresses affected processes and a current emissions inv entory with reductions can be found in Appendix B.

3. A description of the control techniques to be applied to the affected processes

such as low solvent and waterborne c oating; technology and/or add-on controls

. The Final Staff Report for Rule 4682 in Section II C addresses control techniques.

4. The nature of the emission control program whether a bubble, a regulation change, a compliance schedule, or some other form of alternative control

program . Rule 4682 amendments include a VOC limit, and provisions for equivalency and can be found in the ru le and the Final Staff Report.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Final Staff Report: Rule 4682 September 20, 2007

16 Final Staff Report with Appendices for Revised Proposed Amendments to Rule 4682 5. The method of record keeping and reporting to be employed to demonstrate compliance with the new emission limit requirement and to support the showing

that the emission limit is consist ent with RFP and the demonstration of

attainment . The recordkeeping requirement in Section 6.1 of Rule 4682 is consistent with EPA’s policy to keep and mainta in records for at l east five years. The rule also contains provisions for the maintenance of daily records of key operational characteristics to ensur e compliance with the VOC emission requirements such as temperature, pressure, and flowrates.

It is also important to note that violati on of limits will be calculat ed consistent with the compliance period in accordance with Sectio n 5.4. Due to operator concerns and variations in VOC content of the raw material based on supplier, temperature, and products manufactured, a monthly basis is justified.

III. CURRENT EMISSIONS AND EMISSIONS REDUCTION

As stated in the EOADP total VOC emissions from sources subject to Rule 4682 were estimated to be 0.3 tons per day in 2008. The plan also states that upon full implementation of this rule, less than 0. 1 tons per day of VOC reductions are anticipated. The draft amendmen ts to Rule 4682 seek to obtain as much reduction of VOC emissions from existing polystyrene foam, polyethylene, and polypropylene product manufacturing operations as expediti ously as practicable, technologically feasible, and economically reasonable, as determined by the District’s Governing

Board. Based on the refined calculations shown in Appendix B, the final calculated

emission reductions are 0.4 tons /day from a baseline of 1.4 tons per day. This 28%

reduction meets the EOADP co mmitment of 26%. The refi ned calculated baseline was based on permitted emissions and th roughputs and will be used to update the emissions inventory, as appropriate.

IV. COST EFFECTIVENESS ANALYSIS

District staff cond ucted a cost effectiveness analysis of the proposed rule in Appendix C.

The cost information varies and may not represent act ual costs, which will vary by facility depending on their existing control systems and chosen compliance meth od. Some facilities may be able to demonstrate comp liance based on th eir current opera tions. Some facilities may be able to switch to low-VOC ma terial at little or no additional cost. Some

facilities that have existing covered warehouse areas migh t need to install a VOC control system and the costs may be hi gher depending on th e size of the wa rehouse and the amount of stored finished pr oducts. Others that do not have an existing covered warehouse area, could incur a higher costs associated wi th building a warehouse and installing a VOC cont rol system. Based on the high cost of building and controlling warehouses, it is unlikely that the rule woul d drive operators to th at option unless someSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Final Staff Report: Rule 4682 September 20, 2007

17 Final Staff Report with Appendices for Revised Proposed Amendments to Rule 4682 other benefit would be derived fr om that option. Th e most likely option is believed to be

the use of low-VOC materials and/or addi ng addition VOC cont rols to selected manufacturing areas.

V. SOCIOECONOMIC ANALYSIS

Pursuant to state law, District staff is required to analyze the so cioeconomic impacts of any proposed rule or rule amen dment that significantly affects air quality or strengthens an emission limitation. During the workshop meet ing, District staff solic ited volunteers from

stakeholders and manufactu rers and vendo rs of control devices to participate as members of the socioeconomic focus group for this rule. District staff worked closely with the focus group to determine direct compliance costs of the proposed rule. The socioeconomic focus group met in conjunction with the sec ond workshop held in July 2007. The District’s independent consultant participated with the focus group to identi fy and analyze the socioeconomic impacts of the proposed rule. District staff used the socioeconomic analysis to further refine the rule. The socioeconomic report was published as an appendix to this staff report and may also be pres ented to the District Governing Board at the public hearing for ad opting the propos ed rule amendmen ts in order to disclose any expected economic impacts.

VI. ENVIRONMENTAL IMPACTS

Pursuant to the California Environmental Quality Act (CEQA), District staff investigated the possible environmental impacts of the proposed amendments to Rule 4682. District staff has concluded that the proposed rule w ill not have any significant adverse effect on

the environment. District staff recommends filing a Notice of Exemption under the provisions of Public Resource Code 15061 (b)(3).

VII. RULE CONSIS TENCY ANALYSIS

Pursuant to the state Health and Safety C ode, Section 40272.2, District staff has

determined that Draft Rule 4682 is in harmony with, and not in conflict with or contradictory to, existing statut es, court decisions, or state or federal regulations that apply to the same type of equipment or source category.

VIII. REFERENCES

1. ARB BACT Clearinghouse Database.

2. SJVUAPCD BACT Clear ing House Database.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Final Staff Report: Rule 4682 September 20, 2007

18 Final Staff Report with Appendices for Revised Proposed Amendments to Rule 4682 3. SJVUAPCD 1-hour Extreme Ozone Atta inment Demonstration Plan, Amended

October 2005. 4. BAAQMD Regulation 8, Rule 52 (Pol ystyrene, Polypropylene, and Polyethylene Foam Product Manufacturing Operations. 5. SCAQMD Rule 1175 (Contro l of Emissions from the Manufacture of Polymeric Cellular Foam Products)