# REVISED PROPOSED December 15, 2011

4682-1 Revised Proposed

Amendments to Rule 4682 RULE 4682 POLYSTYRENE, POLYETHYLENE, AND POLYPROPYL ENE PRODUCTS

MANUFACTURING (Adopted May 21, 1992; Amended Decemb er 17, 1992; Amended June 16, 1994; Amended September 20, 2007; Amended [ Rule Adoption Date ])

1.0 Purpose

The purpose of this rule is to limit emissions of VOC and trichlorofluoromethane (CFC-11) and dichlorofluoromethane (CFC-12) from ma nufacturing and processing of products composed of polystyrene, polyethylene, or polypropylene and from the storage of VOC blowing agents.

2.0 Applicability

The provisions of this rule shall apply to any man ufacturing, processing, and storage of products composed of polystyrene, polyethylene, or polypropylene.

3.0 Definitions

For the purpose of this rule, the following defini tions shall apply:

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

3.2 ARB: California Air Resource Board.

3.3 Approved Emission Control System: any system u sed to reduce emissions and consists of a capture and a control device, which a re approved, in writing, by the APCO. The control system must be maintained an d operated in such a manner that meets the following requirements:

3.3.1 The emission capture system shall collect at least 90 percent by weight of the emissions; and

3.3.2 The control device shall reduce emissions fro m the emission capture system by at least 95 percent, by weight.

3.4 Blowing Agent: any liquid, or gaseous material , including VOCs, that facilitates the formation of a cellular product fro m raw polymeric material.

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

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

exhausts in which materials manufactured with a VOC blowing agent are processed, or are stored, and from which emissions are vented to the atmosphere.

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Amendments to Rule 4682 3.6 Chlorofluorocarbon (CFC): any chlorinated flu orinated compound of carbon,

excluding chlorodifluoromethane (HCFC-22), dichloro trifluoromethane (HCFC123), tetrafluoroethane (HFC-134a), dichlorofluoroe thane (HCFC-141b), and chlorodifluoroethane (HCFC-142b).

3.7 EPA: United States Environmental Protection A gency.

3.8 Expandable Polystyrene Molding: a series of pro cesses where expandable polystyrene beads, which are polystyrene resin part icles impregnated with blowing agent, undergo expansion, aging and then cu p, shape or block molding to form a low-density foam product. During expansio n, the beads are expanded to the appropriate desired density by exposure to s team or hot air in a preexpander. During aging, the expanded beads (or pre- puff) are transferred to storage silos or mesh bags to stabilize and dry. Du ring molding, the aged prepuff is exposed to heat in a closed mold that cause s the beads to soften, reexpand, and fuse together to form the shaped produc t.

3.9 Extrusion: the process in which a plastic res in is melted in an extruder and

continuously forced through a die opening shaped li ke the finished product. As it leaves the die opening, the extruded plastic mel t partially expands and is then drawn by a puller through forming equipment that si zes, cools, and cuts the product to length or winds it into a roll. With ext ruded foam products, blowing agent is injected under pressure directly into the extruder where it mixes with the plastic melt.

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

foam for recycling.

3.119 Manufacturing Emissions: all emissions of VO C, CFC, or methylene chloride that occur during the manufacturing operation, quan tified before any capture or

control.

3.1210 Manufacturing Operation: a production line or lines consisting of all steps in the processing of a polymer or resin, from the rece ipt of raw polymeric material by the manufacturing facility through the final ste p prior to shipment of the finished product from the manufacturing facility, a nd that results in VOC emissions to the atmosphere. Individual steps incl ude, but are not limited to: expandable bead storage, finished product storage/a ging, extrusion, expansion, softening or annealing, intermediate (pre-puff) sto rage/aging, decomposition, molding, grinding, and forming.

3.13 Operator: includes but is not limited to any p erson who owns, leases, supervises, or operates a facility and/or equipment

.

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Amendments to Rule 4682 3.1411 Polyethylene (High and Low Density): linear thermoplastic polymers of ethylene

with densities from 0.94 gram per cubic centimeter or higher.

3.1512 Polymeric Material: a multi-molecular compo und or mixture of compounds

formed by polymerization and consisting essentially of repeating structural units.

3.1613 Polypropylene: a high molecular weight the rmoplastic crystalline polymer of

propylene.

3.1714 Polystyrene: a thermoplastic material whic h is a polymer of styrene.

3.1815 Raw Material: all polystyrene, polyethylene and polypropylene, and blowing agent used in the manufacturing operation, includin g virgin and recycled polymeric materials.

3.1916 Reclaim Die Hood Exhaust: an exhaust hood a bove reclaim extruder die intended to remove VOCs which escape from the extru der die.

3.2017 Reclaim Extruder: equipment used to reproce ss ground polystyrene foam into polystyrene pellets.

3.2118 Reclaim Extruder Vent: the vent or opening through which emissions are expelled from the reclaim extruder.

3.22 Total Product Emissions: includes emissions from the manufacturing operation, after controls, plus the residual blowing agent in the finished product.

3.2319 Volatile Organic Compound (VOC): defined in Rule 1020 (Definitions).

4.0 Exemptions

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

processing operations using polymeric materials con taining less than 1 percent volatile organic compounds by weight, and not using a blowin g agent in their process.

5.0 Requirements

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

date.

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

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Amendments to Rule 4682 5.1 No person shall operate controllable VOC emiss ion sources at a polystyrene

foam, polyethylene, or polypropylene manufacturing or processing operation unless one of the following VOC emission reduction methods is provided:

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

or dichlorodifluoromethane (CFC-12) is exclusively used; or

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

and a thermal oxidizer which abates captured VOC em issions by at least 95 percent by weight; or

5.1.3 VOC emissions are controlled by a method wh ich achieves an emission

reduction equivalent to Section 5.1.2 and which doe s not include the use of trichlorofluoromethane (CFC-11) or dichlorodiflu oromethane (CFC12), and is approved by the APCO.

5.12 No person operator shall place, hold, or stor e any VOC blowing agent in any

stationary tank, reservoir or container having a ca pacity greater than 200 gallons unless one (1) of the following emission control sy stems is provided:

5.12.1 The container is a pressure vessel maintai ning a working pressure at all

times sufficient to prevent release of VOC emission s to the atmosphere under normal operating conditions; or

5.12.2 The container is equipped with an emission control device or system which collects and disposes of VOC emissions, and w hich achieves and maintains a vapor recovery/control efficiency of at least 95 percent by weight.

5.23 The operator shall not conduct any manufacturi ng operations, as defined in Section 3.0, unless one of the following emission r eduction methods is met:

5.23.1 Effective until December 31, 2012, Tthe oper ator demonstrates, to the satisfaction of the APCO, that the total product em issions do not exceed 2.4 pounds of VOC per 100 pounds of total material processed, calculated over a monthly period. The total produc t emissions include emissions from the manufacturing operation, after c ontrols, plus the residual blowing agent in the finished product.

5.2.2 Effective on and after January 1, 2013, the o perator of an extrusion facility shall demonstrate, to the satisfaction of the APCO, that the total product emissions do not exceed 2.4 pounds of VOC p er 100 pounds of total material processed, calculated over a monthly period.

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Amendments to Rule 4682 5.2.3 Effective on and after January 1, 2013, the operator of an expandable

polystyrene molding facility shall demonstrate, to the satisfaction of the APCO, that the total product emissions do not excee d the following:

5.2.3.1 3.4 pounds of VOC per 100 pounds of total m aterial processed, calculated daily, and

5.2.3.2 2.4 pounds of VOC per 100 pounds of total m aterial processed, calculated over a monthly period.

5.2.4 5.3.2 A blowing agent other than a VOC or tri chlorofluoromethane (CFC11) or dichlorofluoromethane (CFC-12) is exclusivel y used.

5.2.5 5.3.3 An approved emission control system is installed and operating with manufacturing emissions vented only to the app roved emission control system; and emissions from the final manufa ctured product are to be vented only to the approved emission control sys tem for at least:

5.2.5.1 5.3.3.1 48 hours, in the case of expandabl e polystyrene molding operations that process more than 800,000 p ounds per calendar year of raw material; or

5.2.5.2 5.3.3.2 24 hours, in the case of all other manufacturing operations.

5.2.5.3 5.3.3.3 The provision of Section 5.2.5.1 5. 3.3.1 or 5.2.5.2 5.3.3.2 are not required for any facility that only manufacturers polystyrene products and the highest concentration of the blowing agent in the product is 1.8 percent or less by weight, within 15 minutes after the completion of the final processing step, prior to any finished product storage. Verif ication of the concentration shall be demonstrated annually, pursu ant to a protocol submitted to the District and subject to a pproval by the

APCO.

5.2.6 5.3.4 The operator demonstrates to the satis faction of the APCO that the manufacturing emissions are no greater than the fac ility emissions which would occur under Section 5.2.5 5.3.3, as calculate d according to Section 5.45, and which does not include the use of trichlorofluoromethane (CFC-11) or dichlorodifluoro methane (CFC-12).

5.2.7 5.3.5 A control system that meets all of the following requirements shall be deemed as meeting the requirements of Section 5. 2.6 5.3.4, unless the APCO determines that additional controls are requir ed.

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Amendments to Rule 4682 5.2.7.1 5.3.5.1 The beads used in manufacturing hav e an annual-average VOC content of less than 4.2% per weight; and

5.2.7.2 5.3.5.2 The manufacturing emissions (not in cluding finished product storage emissions) are controlled with an o verall capture and control efficiency of at least 93% by w eight.

5.34 Operators subject to the provisions of Section 5.2.1 5.3.1, 5.2.2, or 5.2.3 who exceed the limit based on the monthly calculation, shall be considered to have been in violation for each day of that monthly peri od.

5.45 Facility emissions that would occur under 5.2. 5 5.3.3 shall be calculated using the following formula, or other formula approved by the APCO and EPA:

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

where FE = Facility Emissions for Section 5.2.5 5.3.3

P1 = Amount of VOC in the received material

AS = Amount of VOC added to the material P2 = Amount of VOC in the finished product, measure d within 15 minutes after the final processing step, prior to f inished product

storage. P3 = Amount of VOC in the finished product after wa rehousing for 48 hours (for facilities subject to Section 5.2.5.1 5.3.3.1) or 24 hours (for all others). (P2 - P3) = 0 for products with residual VOC amounts of 1.8 percent or less by weight.

5.56 Compliance Plan

No later than March 20, 2009, operators complying w ith Section 5.2.1 5.3.1, 5.2.2, 5.2.6 5.3.4, or 5.2.7 5.3.5 shall submit to the APCO a Compliance Plan which includes all necessary information to show th e proposed method of compliance with the applicable section. No later t han January 1, 2013, operators complying with Section 5.2.3 shall submit to the APCO a Compliance Plan which includes all necessary information to sh ow the proposed method of compliance with the applicable section. Such infor mation shall include, but not

be limited to:

5.56.1 Potential VOC emissions,

5.56.2 Overall VOC capture and control efficiency o f VOC emission control

system,

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Amendments to Rule 4682 5.56.3 Material VOC content at relevant manufacturi ng points. The amount of VOC in the material shall be determined using the t est method in Section 6.2.4, or other method approved by the APCO and EPA

.

5.56.4 VOC emission calculation formula which will be used to show compliance, and

5.56.5 Operational characteristics of the VOC emiss ion control systems which will be monitored to show continued compliance with the applicable

limits.

5.56.6 Any operational or equipment limitations tha t are necessary to make the

demonstration enforceable and which will be include d as a condition on the appropriate Permit to Operate.

6.0 Administrative Requirements

6.1 Recordkeeping

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

facilities, shall maintain records of operation, in cluding but not limited to the amount of material processed, the equipment use d, and the type of the blowing agent used. Records shall be maintaine d with a minimum monthly totals with the ability to calculate daily averages in any given

month.

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

with this rule, shall maintain daily records of key system operating and maintenance procedures which will demonstrate conti nuous operation and compliance of the emission control device. Key system operating parameters are those necessary to ensure compliance with VOC emission requirements such as temperature, pressures, and fl owrates.

6.1.3 Operators complying with Section 5.2.1, 5.3.1 5.2.2, or 5.2.3 shall maintain records necessary to show compliance with that section and shall, once every month, calculate the daily averag e VOC emissions, based on the records for the preceding monthly peri od, according to the approved VOC emission calculation formula.

6.1.4 Operators complying with Section 5.2.3 shall maintain records necessary to show compliance with that section and shall, onc e every day, calculate the daily VOC emissions, according to the approved VOC emission

calculation formula.

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Amendments to Rule 4682 6.1.54 Effective on and after September 20, 2007, t The operator shall keep in the facility all records required to demonstrate co mpliance with the requirements of this rule for a minimum of five yea rs. The records shall be made available at the facility during normal bus iness hours to the APCO, ARB, or EPA. The records shall be submitted to the APCO, ARB, or EPA upon request.

6.2 Test Methods

Alternative test methods, that are equivalent to th ose specified in Sections 6.2.1 through 6.2.4, may be used, provided that those tes t methods have been approved in writing by the APCO and EPA.

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

using EPA Methods 2, 2A, or 2D for measuring flow r ates, and EPA Methods 25, 25A, or 25B for measuring total gaseous organic

concentrations at the inlet and outlet of the contr ol device.

6.2.2 The capture efficiency of an emission capture control system shall be determined according to EPA’s “Guidelines for Deter mining Capture Efficiency,” January 9, 1995 and 40 CFR 51, Appendi x M, Methods 204-204F, as applicable.

6.2.3 EPA Method 18 or ARB Test Method 422 for de termination of exempt

compounds and halogenated blowing agents.

6.2.4 The VOC blowing agent contained in polymeric materials shall be determined using South Coast Air Quality Management District (SCAQMD) Method 306 (Analysis of Pentanes in Expand able Styrene Polymers) or Bay Area Air Quality Management Distri ct (BAAQMD) Method 45 (Determination of Butanes and Pentanes in Polymeric Materials).

6.2.5 When more than one test method or set of test methods is specified for any testing, a violation of any requirement of this rule established by any one of the specified test methods or set of test me thods shall constitute a

violation of this rule.

7.0 Compliance Schedule

On and after September 20, 2010, operators shall be in compliance with the applicable provisions of Sections 5.3 through 5.5, unless othe rwise noted.