SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

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 (Polystyre ne,

Polyethylene, and Polypropylene Products Manufactur ing)

December 15, 2011SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix B: Rule Consistency Analysis December 15, 2011

Final Staff Report with Appendices for

Revised Pro posed Amendments to Rule 4682 B - 2 This page intentionally blank.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix B: Rule Consistency Analysis December 15, 2011

Final Staff Report with Appendices for

Revised Pro posed Amendments to Rule 4682 B - 3 RULE CONSISTENCY ANALYSIS FOR REVISED PROPOSED AMEN DMENTS 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 per form 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 Unite d States Environmental Protection

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

The elements analyzed are emission standards, monit oring and testing, and

recordkeeping and reporting requirements. The anal ysis 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 Manufactu ring Industry)

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

manufacture of polypropylene, polyethylene, polysty rene, and polyethylene

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

the manufacture of these polymers, beginning with r aw materials preparation and

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

equipment used such as incinerators, flares, boiler s, absorbers, and condensers.

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

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

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

From Polystyrene Foam Manufacturing, dated August 1 990

The ACT presents technical information on estimatin g and controlling VOC emissions

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

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

The ACT contains cost effectiveness estimates for d ifferent control techniques.

However, the ACT does not prescribe the specific em ission limits that should be used inSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix B: Rule Consistency Analysis December 15, 2011

Final Staff Report with Appendices for

Revised Pro posed Amendments to Rule 4682 B - 4 developing a regulation to control VOC emissions fr om polystyrene foam manufacturing.

Rule 4682 contains specific VOC emissions limits an d control system requirements to

reduce emissions from the manufacture of polystyren e foam. The exact control

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

represent the ATC's suggestions.

3. EPA “Control Techniques Guideline (CTG) Document

The CTG applicable to SJVUAPCD Rule 4682 is entitle d, “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 Tech nology (RACT) for the manufacture

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

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

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

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

4. EPA Policy on Recordkeeping

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

policy to keep and maintain records for at least fi ve years.

III. Conclusion

Based on the above analysis, District staff conclud es that revised proposed

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

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

regulations, and guidelines that apply to the same source category.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICTAppendix B: Rule Consistency AnalysisDecember 15, 2011Final Staff Report with Appendices forRevised Proposed Amendments to Rule 4682B - 5Summary of Rule Consistency Analysis for Rule 4682Requirements Rule 4682Federal Rules, Regulations, and Policies40 CFR 60 Subpart DDD CTG EPA-450/3-83-008 ACT US PolicyApplicability The provisions of this rule apply toany manufacturing, processing, andstorage of products composed ofpolystyrene, polyethylene, orpolypropyleneManufacture of polypropylene,polyethylene, polystyrene, or poly(ethylene terephthalate).Control of Volatile OrganicCompound Emissions fromManufacture of High-DensityPolyethylene, Polypropylene, andPolystyrene ResinsExpandable polystyrenebead industry, and theextruded polystyrene foamand sheet industriesNoneEmission Limits 1. 2.4 lb of VOC for each 100pounds of total material processed,calculated monthly, and/or2. 3.4 lb of VOC for each 100 poundsof total material processed,calculated daily, or3. Use a non-VOC blowing agent, or4. Control all manufacturingemissions with an approved systemand store the finished product in acontrolled warehouse for 24 or 48hours, or5. Control the manufacturingemissions to obtain an equivalentreduction to that achieved by option 41. Reduce emissions of totalorganic compounds (minusmethane and ethane) (TOC) by98% wt. or to 20 ppmv, correctedto 3% O2, whichever is lessstringent.2. Polystyrene: TOC not to be >than 0.0072 lb TOC/ton product; ornot allow outlet gas streamtemperature from each finalcondenser to exceed –25 oC.1. Polypropylene plants using liquidphase processes: 98% wt. reductionor reduction to 20 ppm VOC(reaction, mat’l recovery, andfinishing sections).2. High-density polyethylene plantsusing liquid phase slurry processes:98% wt. reduction or reduction to 20ppm VOC (mat’l recovery section).3. Polystyrene plants usingcontinuous processes: 0.12 kgVOC/1,000 kg product (mat’lrecovery section).None NoneExemptions 1. Sections 5.1 and 5.2 shall notapply to manufacturing andprocessing operations usingpolymeric materials containing lessthan 1% VOC by weight and notusing a blowing agent.1. Facilities with a design capacityto produce < 1,102 ton/year2. Certain facilities under amaximum uncontrolled threshold.3. Facilities with an existingcontrol device.4. Emergency vent streams.None None NoneEmission measurement Calculated over a 30-day rollingperiod and/or 24-hour period.Performance test data. None None NoneMonitoring and Testing Demonstrate continuous operationand compliance of the emissioncontrol device by maintaining dailyrecords of key system operating andmaintenance procedures.1. Temperature monitoring device.2. Flame monitoring device.3. Flow monitoring indicator.4. Organic monitoring device.None None NoneRecordkeeping andreportingMaintain records for five years. Maintain recordsfor two years None None Maintain records forfive years.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix B: Rule Consistency Analysis December 15 , 2011

Final Staff Report with Appendices for

Revised Proposed Amendments to Rule 4682 B - 6 This page intentionally blank.