0 Technical Support Document for EPA’s Notice of Proposed Rulemaking on revisions

to the California State Implementation
Plan as submitted

by the State of California, Air Resources Board for the South Coast Air Quality Management District EPA’s Analysis
of South Coast Air Quality Management District’s Rule 1175, Control
of Emissions From the Manufacturing

of Polymeric Cellular (Foam) Products United States Environmental Protection Agency, Region IX Air Division June 30, 2009 Prepared
by: Jennifer Blonn Reviewed
by: Andrew SteckelSouthCoastAirQualityManagementDistrict(SCAQMD)Rule1175,ControlofEmissionsfromtheManufacturingofPolymericCellular(Foam)ProductsChronoIoiyofRuleAdoption,SubmittalandEPAActionAugust25,1994EPAapprovedapriorversionofRule1175intotheCaliforniaStateImplementationPlan(SIP);see59FederalRegister43751.September7,2007TheSCAQMDGoverningBoardadoptedruleamendments.March7,2008TheCaliforniaAirResourcesBoard(CARB)submittedrevisedRule1175toEPAasarevisiontotheSIP.April17,2008EPAfoundCARB’ssubmittalofRule1175complete.RuleSummaryRule1175wasdesignedtoreducevolatileorganiccompound(VOC),chlorofluorocarbon(CFC),andmethyleneclorideemissionsfromexpandedpolystyrene(EPS)foammolders,directinjectionpolystyrenefoamextrusion,polyurethane,isocyanurateandphenolicfoammanufacturingoperations.SCAQMD’sStaffReportexplainsthatRule1175wasamendedprimarilytoprovideEPSmoldingoperationswithamorecost-effectivecomplianceoption.ChangestotheRuleThemajorrevisionstoRule1175adoptedonSeptember7,2007aresummarizedbelow.Seepages4and5ofSCAQMD’sstaffreportforadditionalinformation.•Thedefinitioninparagraph(b)(1)(B)of“approvedemissioncontrolsystem”wasrevisedtorequirecollectionofstorageemissions.•Definitionswereaddedtosection(b)for“certificateofanalysis”,“lowpentanebead”,“midpentanebead”and“storageemissions”.•Acomplianceoptionwasaddedtoinparagraph(c)(4)(B)(iii)toallowEPSblockmoldingoperationstocollectandreducemanufacturingemissionsbyatleast93%,ifatleast60%ofbeadsarelow-pentaneandtheremainderaremid-pentane.•The“methodsofanalysis”sectionwasamendedtoallowadditiontestmethodsiftheyareapprovedbySCAQMD,EPAandCARB,andareequivalenttothoselistedinSection(f).•ProceduresandmethodsfordeterminingcaptureefficiencyofemissioncontrolsystemsSCAQMD-RuleI175,ControlofEmissionsFromtheManufacturingofPolymericCellular(Foam)Products;TSD,6/092were added
to paragraph (f)(3)(A). • SCAQMD test method 25.3 was added
as an additional method that may be used to determine control device efficiency

in paragraph (f)(3)(B). Statutory Requirements

& EPA Guidance Generally, SIP rules must be enforceable (see CAA

§ 110(a)); must require Reasonably Available Control Technology (RACT) for major sources
in ozone nonattainment areas (see CAA §
1 82(a)(2)(A)); must not interfere with applicable requirements including those concerning attainment (see CAA §110(1)); and must not relax requirements

in effect prior to the 1990 CAA amendments
(see

§ 193). The SCAQMD regulates major foam manufacturing facilities

in a severe ozone nonattainment
area (see 40 CFR part 81), so Rule 1175 must fulfill RACT. Rule Evaluation The major change

to Rule 1175
is the addition
of paragraph (c)(4)(B)(iii),

to provide
an alternative compliance option for EPS block molding operations. The new option

is intended

to produce equivalent

or greater emission reductions compared

to the existing option defined

in section (c)(4)(B). The new option increases control of manufacturing emissions from 85.5%
to 93% and reduces control of storage emissions from 85.5%
to zero, among other requirements. Appendix

A of SCAQMD’s staff report describes the EPS block testing program and provides

an example compliance demonstration. Table A-i compares VOC emissions under the new compliance option with emissions under the SIP approved option
in paragraph (c)(4)(B)(ii). Nine billets of molded polystyrene foam were analyzed and the new option resulted

in a calculated average emission reduction

of 24%. While this testing was limited, EPA
is relying on it as the basis to concur with SCAQMD’s determination
that the requirements established

by paragraph (c)(4)(B)(iii)

are unlikely

to interfere with attainment

of the ozone NAAQS

or other CAA requirements. Further, the rule does not appear
to relax existing SIP control requirements

in effect before November 1990. EPA previously determined that the existing SIP-approved version of Rule 1175 adequately implements RACT, partly because the emission limits
in Rule 1175 are generally

at least as stringent

as analogous requirements

in other areas. Since the revised rule does not relax the SIP- approved version and continues

to be generally

at least as stringent

as analogous requirements

in other areas, we believe that
it too adequately implements RACT. The rule largely contains recordkeeping,

test method and other provisions that are clear and sufficient

to ensure rule enforceability. However, adequate enforcement mechanisms required
by CAA

§ 110(a) are not defined for portions
of

1 175(c)(4),

as explained below. SCAQMD- Rule 1175, Control of Emissions From the Manufacturing

of Polymeric Cellular (Foam) Products; TSD, 6/09

3DeficienciesParagraph(c)(4)(iii)wasaddedtotheruletoprovideEPSblockmoldingoperationswithanalternativecomplianceoption.TheparagraphallowsEPSoperationsto,“...collectandreduce,throughacombinationofemissioncontrolsystemsandoperationaltechniques,asapprovedbytheExecutiveOfficer,manufacturingemissionsbyatleast93%overallbyweight...”However,theruledoesnotspecifyhowtheExecutiveOfficerwilldeterminethattheemissioncontrolsystemsandoperationaltechniquesachieve93%control.EPAunderstandsthatspecificoperatingparametersmaybenecessarytoachievethislevelofcontrol.Suchparametersmayinclude,butarenotlimitedto,establishingspecifictemperatureandpressurelimitsforanagingroom,establishingvolumetricflowratesintoacontroldevice,andrequiringaminimumoperatingtemperatureofacontroldevice.Further,EPArecognizesthatnecessaryparametersmayvarybyfacility,product,blowingagentcontentandmanufacturerofrawmaterials.Withoutasourcetest,SCAQMDinspectorsmaynothaveadequateinformationtodeterminewhetheroperationaltechniquesinplaceatafacilityaresufficienttocomplywithparagraph(c)(4)(iii).Tocorrectthisenforceabilitydeficiency:1.Therulemustrequiredemonstration,throughsourcetestingapprovedinwritingbytheExecutiveOfficer,thatthesystemsandtechniquesinplaceatafacilityachieve93%collectionandreductionofemissionsforsourcescomplyingwithparagraph(c)(4)(B)(iii).Inaddition,Rule1175doesnotensurecontinuedutilizationoftheapprovedoperationaltechniques.InspectorsmusthaveknowledgeofthespecificoperatingparametersthatwereapprovedbytheExecutiveOfficertoachieve93%control,andtheseparametersmustberequiredandenforceableonacontinuousbasis.Tocorrectthisenforceabilitydeficiency:2.Therulemustclarifythatalloperationaltechniquesandparametersneededtoachieve93%controltocomplywithparagraph(c)(4)(B)(iii)mustbeclearlydefmedandenforceablethroughafederallyenforceablepermitsuchasaTitleVoperatingpermit.Rule1175shouldalsoberevisedwherepossibletoidentifytheseparameters.Paragraphs(c)(4)(B)(i)and(ii)defineaSIP-approvedcomplianceoption.Thisoptionrequires90%captureand95%reductionofemissionsfrommanufacturingandstorage.Operationaltechniquesarealsonecessaryforfacilitiestoachievethiscontrollevel,justastheyareforthe93%controllevelasdescribedabove.Similarly,theruledoesnotensurecontinuedutilizationofoperationaltechniquesinthiscontext.Tocorrectthisenforceabilitydeficiency:3.Therulemustclarifythatalloperationaltechniquesandparametersneededtoachieve90%collectionand95%destructiontocomplywithparagraphs(c)(4)(B)(i)and(ii)mustbeclearlydefinedandenforceablethroughafederallyenforceablepermitsuchasaTitleVoperatingpermit.Rule1175shouldalsoberevisedwherepossibletoidentifytheseparameters.SCAQMD-Rule1175,ControlofEmissionsFromtheManufacturingofPolymericCellular(Foam)Products;TSD,6/094Additional Recommendations

for the Next Rule Revision- The following revisions
are not currently the basis for rule disapproval,
but are recommended

for the next time the rule is amended. 1. While Rule 1175 applies

to polystyrene foam extrusion operations,

it does not explicitly reference these operations

as it does polystyrene molding and block making operations. Future revisions should clarify which requirements
also apply
to polystyrene foam extrusion. 2. Please revise paragraph (c)(2)
to clarify whether polystyrene foam extrusion may include reprocessed material when demonstrating compliance with the limit of 2.4 lbs VOC per 100 lbs raw material processed. 3. Note two potential typographical errors
in the introductory paragraph

of section (f). The first sentence references paragraphs
(f)( 1) through (f)(6), although the rule ends with (f)(4). The last sentence reads, “...provided

the approved alternative method

is equivalent

to those listed above,” but we find no methods listed above. 4. In developing
the additional compliance option
in paragraph (c)(4)(iii), SCAQMD relied on data generated using procedures designed

to measure emissions from highway vehicles.

In June 2005, EPA supported

an EPS block molding facility’s plan to complete these tests for
a separate purpose, and EPA did not expect that the results would be used to support this rule amendment.

As &result, we strongly recommend that SCAQMD reevaluate
the compliance option
in light of: (a) the small number
of polystyrene block tests that form the technical basis for t1e compliance option; and (b)
a report released

in March 2009 by the Alliance
of Foam Packaging Recyclers and EPS Manufacturers Association, entitled “Pentane Emissions Profile for Expanded Polystyrene Foam Manufacturing Industry”, which suggests considerably higher emissions during block storage. Impact
on Emissions Changes made to Rule 1175 provide EPS molding operations with an additional compliance option, which SCAQMD believes will achieve more emission reductions than an existing SIP approved compliance option. To ensure that emissions

do not increase

as a result of these rule revisions, requirements must be fully enforceable

as discussed above. EPA Action As
a result of the deficiencies discussed above, EPA staff recommend disapproving Rule 1175 pursuant

to CAA §1l0(k)(3) and §301(a). This would have the effect of maintaining
the existing SIP-approved version
of the rule (approved August 25, 1994) in the SIP. There are no CAA §179 sanction

or §1l0(c)(1) FTP implications

of this action
as this is not

a required CAA submittal. SCAQMD- Rule

I 175, Control
of Emissions From the Manufacturing

of Polymeric Cellular (Foam) Products; TSD, 6/09

5Attachments 1. SCAQMD, Rule 1175- Control of Emissions From the Manufacturing

of Polymeric Cellular (Foam) Products, adopted September

7, 2007. Change copy. 2. SCAQMD, Rule 1175- Control
of Emissions From the Manufacturing

of Polymeric Cellular (Foam) Products, adopted September

7, 2007. 3. “Final Staff Report for Proposed Amendments

to Rule 1175- Control of Emissions From the Manufacturing

of Polymeric Cellular (Foam) Products,” South Coast Air Quality Management District, September

7, 2007. Additional References 1. “Issues Relating

to VOC Regulation Cutpoints, Deficiencies,
and Deviations,” EPA, May 25, 1988 (the “Bluebook”). 2. “Guidance Document
for Correcting Common VOC and Other Rule Deficiencies” EPA Region

9, August 21, 2001 (the “Little Bluebook”). SCAQMD- Rule 1175, Contwl
of Emissions From the Manufacturing

of Polymeric Cellular (Foam) Products; TSD, 6/09

6SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT RULE 1175- CONTROL
OF EMISSIONS FROM THE MANUFACTURE

OF POLYMERIC CELLULAR (FOAM) PRODUCTS (A dopted November

3, 1989) (Amended January

5, 1990; May 13, 1994; September

7, 2007) (a) Applicability This rule shall apply
to polymeric cellular products manufacturing operations including but not limited

to expandable polystyrene, polystyrene foam extrusion, 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) Defmitions 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, excluding; chlorodifluoromethane (HCFC-22), dichiorotrifluoroethane (HCFC- 123), 1175-1

# ) Rule 1175 (Cont.)

(Amended September

7, 2007) tetrafluoroethane (HFC-

1 34a), dichiorofluoroethane (HCFC- 141 b), chiorodifluoroethane (HCFC-142b). 2-chioro- 1,1,1 ,2-tetrafluoroethane (HCFC- 124), (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) 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. (8) MANUFACTURING EMISSIONS

are any emissions

of VOC, CFC, or methylene chloride that occur during the manufacturing operation. (9) 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. (10) 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. (11) RAW MATERIAL means
all polystyrene beads, polyurethane,

and blowing agent used in the manufacture

of polymeric cellular products. (12) RIGID POLYURETHANE

is
a closed cell polyurethane, primarily manufactured

as rigid slabstock, laminated boardstock, field spray foam or pour-in-place foam. (13) STORAGE EMISSIONS

are VOC emissions occurring
for
a maximum

of 48 hours after the polymeric cellular foam product

is manufactured. (14) VOLATILE ORGANIC COMPOUND (VOC) (see Rule 102

- 

# Definition of Terms). 1175-2Rule 1175 (Mnt.)
(ACnded September

7, 2007) (c) Emission Control Requirements (1) Manufacturing Operations, Excluding Expandable Polystyrene (EPS) Molding Operations (A) By January

1, 1994, each polyurethane operation subject

to the rule shall discontinue

its use of CFCs, VOCs,

or methylene chloride. (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 (EPS) Molding Operations The owner
or operator
of an expandable polystyrene (EPS) molding operation shall demonstrate,

to the satisfaction

of the Executive Officer, that manufacturing emissions
and post-manufacturing 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)(l), (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: (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)

; 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: 1175-3

# Rule 1175 (Cont.)
(Amended September

7, 2007) (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;

or (iii) Expanded polystyrene (EPS) 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, through

a combination

of emission control systems and operational techniques,

as approved
by the Executive Officer, 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 EPS block throughput

is manufactured with low-pentane bead and the remainder with mid-pentane bead. (d) 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) EPS 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 protocol submitted

to and approved
by the Executive Officer. (e) Recordkeeping (1) Any owner
or operator subject
to this rule or claiming

an exemption under paragraph
(d) shall maintain

a daily record of operations, including but not 1175-4Rule 1175 (tOnt.)

A 2 ided September

7, 2007) 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 two years and be available

to the Executive Officer upon request. (2) Owners and/or operators using an 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

to demonstrate compliance with paragraph (c)(4). (f) Methods
of Analysis All applicable methods
of analysis shall be as cited in paragraphs (f)(l) through (f)(6) 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 above. (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; 1175-5

# Rule 1175 (Cont.)

(Amended September

7, 2007) 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. (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 SCAQMI) “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 phrase (c)(4)(B) (iii) 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)(l) or phrase (c)(4)(B) (iii) 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. 1175-6