1175

(Adopted November 3, 1989)(Amended January 5, 1990)
(Amended May 13, 1994)

RULE 1175. CONTROL OF EMISSIONS FROM THE MANUFACTURE OF
POLYMERIC CELLULAR (FOAM) PRODUCTS

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

(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) Definitions
(1) APPROVED EMISSION CONTROL SYSTEM means any system used
to reduce manufacturing emissions and consists of a collection and a
control device, which are approved, in writing, by the Executive Officer.
The control system must be operated subject to the following provisions:
(A) The emission collection system shall collect at least a 90 percent
by weight of the manufacturing emissions; and
(B) 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) CHLOROFLUOROCARBON (CFC) is any chlorinated fluorinated
compound of carbon, excluding;
chlorodifluoromethane (HCFC-22),
dichlorotrifluoroethane (HCFC-123),
tetrafluoroethane (HFC-134a),
dichlorofluoroethane (HCFC-141b),
chlorodifluoroethane (HCFC-142b)
2-chloro-1,1,1,2-tetrafluoroethane (HCFC-124),

(4) EXEMPT COMPOUNDS are any of the following compounds:
(A) Group I (General)
trifluoromethane (HFC-23)
pentafluoroethane (HFC-125)
1,1,2,2-tetrafluoroethane (HFC-134)
tetrafluoroethane (HFC-134a)
1,1,1-trifluoroethane (HFC-143a)
1,1-difluoroethane (HFC-152a)
chlorodifluoromethane (HCFC-22)
dichlorotrifluoroethane (HCFC-123)
2-chloro-1,1,1,2-tetrafluoroethane (HCFC-124)
dichlorofluoroethane (HCFC-141b)
chlorodifluoroethane (HCFC-142b)
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
sulfur-containing perfluorocarbons with no unsaturations and with
sulfur bonds only to carbon and fluorine
(B) Group II
methylene chloride
1,1,1-trichloroethane (methyl chloroform)
trifluoromethane (FC-23)
trichlorotrifluoroethane (CFC-113)
dichlorodifluoromethane (CFC-12)
trichlorofluoromethane (CFC-11)
dichlorotetrafluoroethane (CFC-114)
chloropentafluoroethane (CFC-115)
The use of Group II compounds and/or carbon tetrachloride may be
restricted in the future because they are toxic, potentially toxic, upperatmosphere
ozone depleters, or cause other environmental impacts. By
January 1, 1996, chlorofluorocarbons (CFC), 1,1,1,-trichloroethane
(methyl chloroform), and carbon tetrachloride will be phased out in
accordance with the Code of Federal Regulations Title 40, Part 82
(December 10, 1993).

(5) 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.

(6) MANUFACTURING EMISSIONS are any emissions of VOC, CFC, or
methylene chloride that occur during the manufacturing operation.

(7) 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.

(8) RAW MATERIAL means all polystyrene beads, polyurethane, and
blowing agent used in the manufacture of polymeric cellular products.

(9) RIGID POLYURETHANE is a closed cell polyurethane, primarily
manufactured as rigid slabstock, laminated boardstock, field spray foam or
pour-in-place foam.

(10) VOLATILE ORGANIC COMPOUND (VOC) is any volatile compound
of carbon, excluding methane, carbon monoxide, carbon dioxide, carbonic
acid, metallic carbides or carbonates, and exempt compounds.

(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 subparagraph (c)(1) or (c)(2), shall submit a
plan to the District subject to approval by the Executive Officer's
designee, that will demonstrate compliance with subparagraph (c)(1) or
(c)(2).


(4) The owner or operator of any polymeric cellular manufacturing operation
that has not achieved the requirements specified in subparagraphs (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 12 months of failing to meet the requirements of
subparagraph (c)(1), (c)(2), or (c)(3), the following provisions
must be satisfied:
(i) An approved emission control system is installed and
operating with all sources of manufacturing emissions
vented only to the approved emission control system; and
(ii) Emissions from the final manufactured product are vented
only to the approved emission control system 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.

(d) Exemptions

(1) The provisions of paragraph (c) shall not apply to any:
(A) Expandable polystyrene operation that processes less tha. 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 subparagraph (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 the District and subject to
approval 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
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 a District
representative 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) Test Methods

(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) United States Environmental Protection Agency (USEPA)
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 paragraph (c), only when
manufacturers specify which individual compounds are used in
the coating formulation:
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 test methods
approved and used by the United States Environmental Protection
Agency, California Air Resources Board, and the District 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 SCAQMD "Laboratory
Methods of Analysis for Enforcement Samples" manual.

(3) Determination of Efficiency of Emission Control System
(A) The efficiency of the collection device of the emission control
system required in paragraph (c)(4) shall be determined by the
USEPA method cited in 55 Federal Register 26865 (June 29,
1990), or any other method approved by the United States
Environmental Protection Agency, the California Air Resources
Board, and the District.
(B) The efficiency of the control device of the emission control system
required in paragraph (c)(4) and the VOC content in the control
device exhaust gases, measured and calculated as carbon, shall be
determined by USEPA Test Methods 25, 25A, or SCAQMD
Method 25.1 (Determination of Total Gaseous Non-Methane
Organic Emissions as Carbon) as applicable. USEPA 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.