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(Adopted November 3, 1989)(Amended January 5, 1990)

(Amended May 13, 1994)(Amended September 7, 2007) 

(Amended November 5, 2010) 

RULE 1175. CONTROL OF EMISSIONS FROM THE MANUFACTURE 

OF POLYMERIC CELLULAR (FOAM) PRODUCTS 

(a) Applicability 

This rule shall apply to polymeric cellular products manufacturing operations 

including but not limited to expandable polystyrene, extruded polystyrene, 

polyurethane, isocyanurate and phenolic foam operations. All steps of the 

manufacturing operation and the storage of the final product for a maximum of 48 

hours are subject to the requirements of this rule.

(b) Definitions 

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

(1) APPROVED EMISSION CONTROL SYSTEM means any system used 

to reduce manufacturing and storage emissions and consists of an emission 

collection system and a control device, which are approved, in writing, by 

the Executive Officer, that has been demonstrated to perform and operate 

according to the following provisions: 

(A) The emission collection system shall collect at least 90 percent by 

weight of the manufacturing emissions; and 

(B) The emission collection system shall collect at least 90 percent by 

weight of the storage emissions; and 

(C) The control device shall reduce emissions from the emission 

collection system by at least 95 percent, by weight. 

(2) BLOWING AGENT means a liquid, gaseous or solid material that 

facilitates the formation of a cellular product from raw polymeric material. 

(3) CERTIFICATE OF ANALYSIS is a written document that cites the range 

of pentanes in expandable polystyrene bead, expressed as the percentage 

by weight of a manufactured bead-lot, prior to shipment from the 

manufacturer. It also contains the name of the manufacturer, a bead-lot 

number, and grade and type identifiers, along with a signature of an officer 

or an officer’s designee of the bead-lot manufacturer. 

(4) CHLOROFLUOROCARBON (CFC) is any chlorinated fluorinated 

compound of carbon. 
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(5) EXEMPT COMPOUNDS (see Rule 102 - Definition of Terms) 

(6) EXPANDABLE POLYSTYRENE (EPS) MOLDING OPERATIONS

consist of a series of processes, where polystyrene beads and blowing 

agent are expanded by exposure to steam or any other expansion agent and 

processed through cup, block or shape molding into low-density, closed 

cell, cellular products. EPS products include but are not limited to 

drinking cups, insulation board, packaging material, and ice chests. 

(7) EXTRUDED POLYSTYRENE (XPS) FOAM OPERATIONS consist of a 

series of processes, where a blowing agent is injected into molten 

polystyrene and upon exit of the extrusion die the blowing agent vaporizes 

thus expanding the molten resin into foam, where it expands in both 

thickness and width, and includes directly associated processes that 

incorporate reprocessed material into XPS products. XPS products 

include but are not limited to food containers and insulation foams used in 

the construction of structures for both residential and commercial 

buildings, such as under concrete slabs, roofing, decks, steel and wood 

framed wall sheathing. 

(8) LOW-PENTANE BEAD is an expandable polystyrene bead containing 

pentane as a blowing agent with an upper limit less than 4.0 percent by 

weight, prior to shipment, as certified upon delivery by an accompanying 

bead lot manufacturer’s Certificate of Analysis. 

(9) MANUFACTURING EMISSIONS are any emissions of VOC, CFC, or 

methylene chloride that occur during the manufacturing operation. 

(10) MANUFACTURING OPERATION means every step of the processing of 

a polymeric material from the delivery of the raw material, until the 

storage of the final cellular product. 

(11) MID PENTANE BEAD is an expandable polystyrene bead containing 

pentane as a blowing agent within the range of 4.0 to 5.2 percent by 

weight, prior to shipment, as certified upon delivery with an 

accompanying bead lot manufacturer’s Certificate of Analysis. 

(12) RAW MATERIAL means all polystyrene beads, polyurethane, 

reprocessed material and blowing agent used in the manufacture of 

polymeric cellular products. 

(13) REPROCESSED MATERIAL means all regrind trim, scrap or recycled 

material. 
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(14) RIGID POLYURETHANE is a closed cell polyurethane, primarily 

manufactured as rigid slabstock, laminated boardstock, field spray foam or 

pour-in-place foam. 

(15) STORAGE EMISSIONS are VOC emissions occurring for a maximum of 

48 hours after the polymeric cellular foam product is manufactured. 

(16) VOLATILE ORGANIC COMPOUND (VOC) is as defined in Rule 102. 

(c) Emission Control Requirements 

(1) Manufacturing Operations, Excluding Expandable Polystyrene Molding 

Operations and Extruded Polystyrene Foam Operations

(A) No polyurethane operation subject to this rule shall use any VOCs. 

(B) Each manufacturing operation, excluding rigid polyurethane 

operations shall reduce yearly emissions from its 1988 emissions 

baseline, based on Rule 301 emission fees filing, by 100 percent, 

beginning calendar year 1994. 

(2) Expandable Polystyrene Molding and Extruded Polystyrene Foam 

Operations 

The owner or operator of an expandable polystyrene molding operation or 

an extruded polystyrene foam operation shall demonstrate, to the 

satisfaction of the Executive Officer, manufacturing emissions and postmanufacturing emissions, assuming all the blowing agent is released from 

the product, are less than 2.4 lbs per 100 lbs of raw material processed. 

(3) The owner or operator of any polymeric cellular manufacturing operation, 

subject to the requirements of paragraphs (c)(1) or (c)(2), shall submit a 

plan to be approved by the Executive Officer, that demonstrates 

compliance with paragraph (c)(1) or (c)(2). 

(4) The owner or operator of any polymeric cellular manufacturing operation 

that has not achieved the requirements specified in paragraph (c)(1), 

(c)(2), or (c)(3) shall: 

(A) Submit permit applications for the installation of an emission 

control system within four months of the date that compliance with 

such requirement was not achieved; and 

(B) Within twelve months of failing to meet the requirements of 

paragraph (c)(1), (c)(2), or (c)(3), the following provisions must be 

satisfied: 
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(i) An approved emission control system is installed and 

operated with all sources of manufacturing emissions 

collected and reduced according to subparagraphs (b)(1)(A) 

and (b)(1)(C); this system, including any critical 

operational techniques and parameters (e.g., minimum 

temperature and time in aging/curing areas venting to the 

control system, if applicable), must be incorporated in a 

federally enforceable permit, such as a Title V operating 

permit, as approved by the Executive Officer; and 

(ii) All sources of storage emissions from the final 

manufactured product are collected and reduced according 

to subparagraphs (b)(1)(B) and (b)(1)(C) for at least: 

(I) 48 hours, in the case of expandable polystyrene

molding operations that process more than 800,000 

pounds per calendar year of raw material; or 

(II) 24 hours, in the case of all other manufacturing 

operations. 

(5) Expanded polystyrene block molding operations may, in lieu of complying 

with the specific control requirements of clauses (c)(4)(B)(i) and 

(c)(4)B)(ii), collect and reduce, manufacturing emissions by at least 93 

percent overall by weight (the product of capture and control device 

efficiencies), provided, at least 60 percent of the annual expanded 

polystyrene block throughput is manufactured with low-pentane bead and 

the remainder with mid-pentane bead. Any owner or operator of a facility 

who elects to comply using this alternate compliance method shall 

demonstrate the requisite 93 percent reduction through a source test 

approved in writing by the Executive Officer. Facilities with a Title V 

permit shall repeat such demonstration every five (5) years. This alternate 

compliance method, including any critical operational techniques and 

parameters (e.g., minimum temperature and time in aging/curing areas 

venting to the control system, if applicable), must be incorporated in a 

federally enforceable permit, such as a Title V operating permit, as 

approved by the Executive Officer. 

(6) The owner or operator of a facility utilizing an approved emission control 

system shall conduct source testing, to be approved in writing by the 

Executive Officer, to demonstrate compliance with paragraphs (c)(2) or 
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(c)(4). Facilities with a Title V permit shall repeat such demonstration 

every five (5) years. 

(d) Prohibition of Use 

 No polymeric cellular product operation subject to this rule shall use methylene 

chloride, or any CFC, unless specifically approved as an acceptable alternative 

under 40 CFR Part 82 Subpart G – Significant New Alternatives Policy Program. 

(e) Exemptions 

(1) The provisions of paragraph (c) shall not apply to any: 

(A) Expandable polystyrene operation that processes less than 200 

pounds per day of raw material. 

(B) Rigid polyurethane operation that processes less than 1,000 pounds 

per day of raw material. 

(2) The provisions of clause (c)(4)(B)(ii) shall not apply to any facility that 

only manufactures: 

(A) Rigid polyurethane foam; or 

(B) Expanded polystyrene foam and the highest concentration of the 

blowing agent in the cellular product is 1.8 percent or less by 

weight within 15 minutes of completion of the manufacturing 

operation. Verification of the concentration shall be demonstrated 

annually, pursuant to a written protocol submitted to and approved 

by the Executive Officer. 

(f) Recordkeeping 

(1) Any owner or operator subject to this rule or claiming an exemption under 

subdivision (e) shall maintain a daily record of operations, including but 

not limited to the amount of raw material processed, the equipment used, 

and the type of blowing agent used. Such records shall be retained in the 

operator's files for a period of five (5) years and be made available to the 

Executive Officer upon request. 

(2) Owners and/or operators using any emission control system as a means of 

complying with this rule shall maintain daily records of the operation and 

maintenance of the emission control system. These records shall include 

key system operating parameters such as temperatures, pressures, 

flowrates, and other measures needed to demonstrate compliance with 

paragraphs (c)(4), (c)(5) and (c)(6). Such records shall be retained in the 
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operator's files for a period of five (5) years and be made available to the 

Executive Officer upon request. 

(g) Methods of Analysis 

All applicable methods of analysis shall be as cited in paragraphs (g)(1) through 

(g)(4) below, or any other applicable method approved by the Executive Officer, 

the United States Environmental Protection Agency (U.S. EPA), and the 

California Air Resources Board (CARB), provided the approved alternative 

method is equivalent to those listed below. 

(1) Determination of VOC Content 

The VOC content of materials subject to the provisions of this rule shall 

be determined by the following methods: 

(A) U.S. EPA Reference Method 24 (Code of Federal Regulations 

Title 40 Part 60, Appendix A). The exempt solvent content shall 

be determined by SCAQMD Method 303 (Determination of 

Exempt Compounds) contained in the SCAQMD "Laboratory 

Methods of Analysis for Enforcement Samples" manual; or, 

(B) SCAQMD Method 304 [Determination of Volatile Organic 

Compounds (VOCs) in Various Materials] contained in the 

SCAQMD "Laboratory Methods of Analysis for Enforcement 

Samples" manual. 

(C) Exempt Perfluorocarbon Compounds 

The following classes of compounds will be analyzed as exempt 

compounds for compliance with subdivision (c), only when 

manufacturers specify which individual compounds are used in the 

manufacture of polymeric cellular products: 

cyclic, branched, or linear, completely fluorinated alkanes; 

cyclic, branched, or linear, completely fluorinated ethers with no 

unsaturations; 

cyclic, branched, or linear, completely fluorinated tertiary amines 

with no unsaturations; and 

sulfur-containing perfluorocarbons with no unsaturations and with 

sulfur bonds only to carbon and fluorine. 

In addition, the manufacturers must identify the U.S. EPA, CARB, 

and SCAQMD approved test methods used to quantify the amount 

of each exempt compound. 
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(2) Determination of Pentanes in Expandable Styrene Polymers 

The weight percent pentane in expandable polystyrene polymer shall be 

determined by SCAQMD Method 306 (Analysis of Pentanes in 

Expandable Styrene Polymers) contained in the SCAQMD "Laboratory 

Methods of Analysis for Enforcement Samples" manual. 

(3) Determination of Efficiency of Emission Control System 

(A) Capture efficiency specified in paragraph (b)(1) or paragraph (c)(5) 

shall be determined by the procedures presented in the U.S. EPA 

technical guidance document “Guidelines for Determining Capture 

Efficiency, January 9, 1995”, or U.S. EPA Methods 204 A-F. 

(B) The efficiency of the control device of the emission control system 

specified in paragraph (b)(1) or paragraph (c)(5) and the VOC 

content in the control device exhaust gases, measured and 

calculated as carbon, shall be determined by U.S. EPA Test 

Methods 25, 25A, SCAQMD Method 25.1 (Determination of Total 

Gaseous Non-Methane Organic Emissions as Carbon), or 

SCAQMD Method 25.3 (Determination of Low Concentration of 

Non-Methane Non-Ethane Organic Compound Emissions from 

Clean Fueled Combustion Sources) as applicable. U.S. EPA Test 

Method 18, or ARB Method 422 shall be used to determine 

emissions of exempt compounds. 

(4) Multiple Test Methods 

When more than one test method or set of test methods are 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 the rule.