SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix B: Rule Consistency Analysis December 15, 2011 

Final Staff Report with Appendices for 

Revised Proposed Amendments to Rule 4682 

B - 1

APPENDIX B 

Rule Consistency Analysis for 

Revised Proposed Amendments to Rule 4682 (Polystyrene, 

Polyethylene, and Polypropylene Products Manufacturing) 

December 15, 2011 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix B: Rule Consistency Analysis December 15, 2011 

Final Staff Report with Appendices for 

 Revised Proposed Amendments to Rule 4682 

B - 2

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SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix B: Rule Consistency Analysis December 15, 2011 

Final Staff Report with Appendices for 

 Revised Proposed Amendments to Rule 4682 

B - 3

RULE CONSISTENCY ANALYSIS FOR REVISED PROPOSED AMENDMENTS TO 

RULE 4682 

I. Requirements of Rule Consistency Analysis 

Pursuant to Section 40727.2 of the CH&SC, prior to adopting, amending, or repealing a 

rule or regulation, the District is required to perform a written analysis that identifies and 

compares the air pollution control elements of the rule or regulation with corresponding 

elements of existing or proposed District and United States Environmental Protection 

Agency (EPA) rules, regulations, and guidelines that apply to the same source category. 

The elements analyzed are emission standards, monitoring and testing, and 

recordkeeping and reporting requirements. The analysis is discussed below and a 

summary is presented in the Rule Consistency Table.

II. Results of Analysis

A. District Rules 

Rule 4682 applies to manufacturers of polystyrene, polyethylene, and polypropylene 

products. No other rule in the District covers the same source category. 

B. Federal Rules, Regulations, and Policies 

1. 40 CFR 60 Subpart DDD (Standards of Performance for Volatile Organic 

Compound (VOC) Emissions from the Polymer Manufacturing Industry) 

40 CFR 60 Subpart DDD establishes requirements for facilities involved in the 

manufacture of polypropylene, polyethylene, polystyrene, and polyethylene 

terephthalate, as defined in Section 60.561. The standards cover all equipment used in 

the manufacture of these polymers, beginning with raw materials preparation and 

ending with product storage, and cover all emissions. This subpart also covers control 

equipment used such as incinerators, flares, boilers, absorbers, and condensers. 

The facilities covered by Rule 4682 use these resins as raw materials in their 

manufacturing process, but do no manufacture such material on-site. 

2. Alternative Control Techniques (ACT) Document – Control of VOC Emissions 

From Polystyrene Foam Manufacturing, dated August 1990 

The ACT presents technical information on estimating and controlling VOC emissions 

from the manufacture of polystyrene foam. The ACT addresses the expandable 

polystyrene bead industry, and the extruded polystyrene foam and sheet industries. 

The ACT contains cost effectiveness estimates for different control techniques. 

However, the ACT does not prescribe the specific emission limits that should be used in 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix B: Rule Consistency Analysis December 15, 2011 

Final Staff Report with Appendices for 

 Revised Proposed Amendments to Rule 4682 

B - 4

developing a regulation to control VOC emissions from polystyrene foam manufacturing. 

Rule 4682 contains specific VOC emissions limits and control system requirements to 

reduce emissions from the manufacture of polystyrene foam. The exact control 

technique is chosen by the operator to meet their manufacturing needs, but choices 

represent the ATC's suggestions. 

3. EPA “Control Techniques Guideline (CTG) Document 

The CTG applicable to SJVUAPCD Rule 4682 is entitled, “Control of Volatile Organic 

Compound Emissions from Manufacture of High-Density Polyethylene, Polypropylene, 

and Polystyrene Resins'' (EPA-450/3-83-008). This CTG addresses what would be 

representative of Reasonably Available Control Technology (RACT) for the manufacture 

of polypropylene, high-density polyethylene, and polystyrene. The CTG contains 

emission control techniques, emission control costs, and emission control analysis. 

The facilities covered by Rule 4682 use these resins as raw materials in their 

manufacturing process, but do no manufacture such material on-site. 

4. EPA Policy on Recordkeeping 

The recordkeeping requirement in Section 6.1 of Rule 4682 is consistent with EPA’s 

policy to keep and maintain records for at least five years. 

III. Conclusion 

Based on the above analysis, District staff concludes that revised proposed 

amendments to Rule 4682 are consistent with other District rules and are not in conflict 

with these rules. Further, the revised proposed rule is consistent with EPA rules, 

regulations, and guidelines that apply to the same source category.
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix B: Rule Consistency Analysis 

Final Staff Rep

 Revised Proposed Ame

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Summary of Rule Consistency Analysis for Rule 4682 

Requirements Rule 4682 Federal Rules, Regulations, and Policies 

40 CFR 60 Subpart DDD CTG EPA-450/3-83-008 AC

Applicability The provisions of this rule apply to 

any manufacturing, processing, and storage of products composed of polystyrene, polyethylene, or polypropylene 

Manufacture of polypropylene, polyethylene, polystyrene, or poly (ethylene terephthalate). 

Control of Volatile Organic Compound Emissions from Manufacture of High-Density Polyethylene, Polypropylene, and Polystyrene Resins 

Expandable pbead industryextruded polysand sheet ind

Emission Limits 1. 2.4 lb of VOC for each 100 

pounds of total material processed, calculated monthly, and/or 2. 3.4 lb of VOC for each 100 pounds of total material processed, calculated daily, or 3. Use a non-VOC blowing agent, or 4. Control all manufacturing emissions with an approved system and store the finished product in a controlled warehouse for 24 or 48 hours, or 5. Control the manufacturing emissions to obtain an equivalent reduction to that achieved by option 4 

1. Reduce emissions of total organic compounds (minus methane and ethane) (TOC) by 98% wt. or to 20 ppmv, corrected to 3% O2, whichever is less stringent. 2. Polystyrene: TOC not to be > than 0.0072 lb TOC/ton product; or not allow outlet gas stream temperature from each final condenser to exceed –25 oC. 

1. Polypropylene plants using liquid phase processes: 98% wt. reduction or reduction to 20 ppm VOC (reaction, mat’l recovery, and finishing sections). 2. High-density polyethylene plants using liquid phase slurry processes: 98% wt. reduction or reduction to 20 ppm VOC (mat’l recovery section). 3. Polystyrene plants using continuous processes: 0.12 kg VOC/1,000 kg product (mat’l recovery section). 

None 

Exemptions 1. Sections 5.1 and 5.2 shall not 

apply to manufacturing and processing operations using polymeric materials containing less than 1% VOC by weight and not using a blowing agent. 

1. Facilities with a design capacity to produce < 1,102 ton/year 2. Certain facilities under a maximum uncontrolled threshold. 3. Facilities with an existing control device. 4. Emergency vent streams. 

None None 

Emission measurement Calculated over a 30-day rolling 

period and/or 24-hour period. 

Performance test data. None None 

Monitoring and Testing Demonstrate continuous operation 

and compliance of the emission control device by maintaining daily records of key system operating and maintenance procedures. 

1. Temperature monitoring device. 2. Flame monitoring device. 3. Flow monitoring indicator. 4. Organic monitoring device. 

None None 

Recordkeeping and reporting 

Maintain records for five years. Maintain records for two years None None 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix B: Rule Consistency Analysis December 15, 2011 

 

 Final Staff Report with Appendices for 

Revised Proposed Amendments to Rule 4682 

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