SDAPCD RULE 67.10 KELP PROCESS.& BIO-POLYMER MFG.OPERATIONS               
LAST REVISED 06/15/94

               
               RULE 67.10.  KELP PROCESSING AND BIO-POLYMER MANUFACTURING
                            OPERATIONS  (Effective: 1/30/85;  Rev. Effective 
                            6/15/94)

               (a)  APPLICABILITY

                    (1)  Except as otherwise provided in Section (b), this
               rule is applicable to any kelp processing or bio-polymer
               manufacturing line, or associated pilot plant facility,
               where volatile organic compounds (VOC's) are used as
               reactants, dissolvers or extractants or used to separate or
               purify the products of kelp processing or bio-polymer
               manufacturing line operations.

                    (2)  Kelp processing and bio-polymer manufacturing
               operations subject to, or exempt from, this rule shall not
               be subject to Rule 66.

               (b)  EXEMPTIONS

               The provisions of Sections (d), (e), and (g) of this rule
          shall not apply to:

                    (1)  Any kelp processing or bio-polymer manufacturing
               line where emissions of  VOC's, at the maximum design
               capacity of the line, are no greater than 15 pounds in any
               one day, provided total emissions of VOC's from all kelp
               processing or bio-polymer manufacturing equipment located at
               a stationary source are no greater than 100 pounds in a day.
               It shall be the responsibility of a person claiming this
               exemption to maintain daily records necessary for the
               District to determine the applicability of such an
               exemption; and

                    (2)  Fuel oil; and

                    (3)  Laboratory facilities used exclusively for
               research and development provided that monthly records are
               kept of the usage of VOC-containing materials; and

                    (4)  Any low volatility organic compound which has a
               normal boiling point of 185C or greater.  Any person
               claiming this exemption shall maintain written records which
               substantiate the claim such as applicable manufacturer's
               specifications or, for pure compounds, standard reference
               texts.

                    (5)  Any temporary equipment installed in a pilot plant
               facility and resulting in an emissions increase not
               exceeding 10 pounds of VOC's per day.  It shall be the
               responsibility of a person claiming this exemption to
               maintain daily records necessary for the District to
               determine the applicability of such an exemption.

                    All records pursuant to Subsections (b)(1), (b)(3),
               (b)(4), and (b)(5) shall be retained on site for at least
               two years and shall be submitted to the District upon
               request.


               (c)  DEFINITIONS

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

                    (1)  "Approved Air Pollution Control Device" means a
               single piece of equipment or combination of pieces of
               equipment which is designed to reduce the emissions of air
               contaminants and which is approved, in writing, by the Air
               Pollution Control Officer.

                    (2)  "Bio-polymer Manufacturing Line" means one or more
               pieces of equipment linked by a process flow in which a bio-
               polymer or any of its precursors is dried, extracted,
               filtered, mixed or reacted with any VOC where the end
               product cannot be produced if any piece of equipment is
               removed or not functioning.

                    (3)  "Drier" means a device used to remove water and/or
               VOC's from a material by applying heat, by flowing
               unsaturated air, or by subjecting the material to vacuum, or
               any combination thereof.

                    (4)  "Exempt Compound" means any of the following
               compounds or classes of compounds:  1,1,1-trichloroethane,
               methylene chloride, trichlorofluoromethane (CFC-11),
               dichlorodifluoromethane (CFC-12), trifluoromethane (HFC-23),
               trichlorotrifluoroethane (CFC-113),
               dichlorotetrafluoroethane (CFC-114), chloropentafluoroethane
               (CFC-115), chlorodifluoromethane (HCFC-22),
               dichlorotrifluoroethane (HCFC-123), dichlorofluoroethane
               (HCFC-141b), 1,1,1,2-tetrafluoroethane (HFC-134a), 1,1,2,2-
               tetrafluoroethane (HFC-134), chlorodifluoroethane (HCFC-
               142b), 2-chloro-1,1,1,2-tetrafluoroethane (HCFC-124),
               pentafluoroethane (HFC-125), 1,1,1-trifluoroethane (HFC-
               143a), 1,1-difluoroethane (HFC-152a), and the following four
               classes of perfluorocarbon (PFC) compounds:

                         (i)  cyclic, branched, or linear, completely
                    fluorinated alkanes;

                         (ii) cyclic, branched, or linear, completely
                    fluorinated ethers with no unsaturations;

                         (iii)cyclic, branched, or linear, completely
                    fluorinated tertiary amines with no unsaturations; and

                         (iv) sulfur-containing perfluorocarbons with no
                    unsaturations and with sulfur bonds only to carbon and
                    fluorine.

                    (5)  "Fugitive Liquid Leak" means a visible leak of
               liquid, containing greater than 10 percent by weight VOC, at
               a rate in excess of three drops per minute, or a visible
               mist.  For the purposes of this rule, a liquid leak dropping
               into a capture system which is connected to an air pollution
               control device shall not be considered a fugitive liquid
               leak.

                    (6)  "Incorporator" means a device in which a solid and
               a VOC introduced into the device are mixed, where it is not
               intended that the VOC chemically modify the solid.

                    (7)  "In-Process Tank" means  a tank, which is part of
               a kelp processing or bio-polymer manufacturing line or pilot
               plant facility and which is used to handle or transfer VOC-
               containing material.  In-process tanks include spent pots,
               but exclude stationary storage tanks.

                    (8)  "Kelp Processing Line" means one or more pieces of
               equipment linked by a process flow in which kelp or any of
               its derivatives is dried, extracted, filtered, mixed, or
               reacted with any VOC where the end product cannot be
               produced if any piece of equipment is removed or not
               functioning.

                    (9)  "Laboratory Facility" means a facility which uses
               bench-scale or small-scale equipment for the purpose of
               conducting studies or tests for the research, development or
               evaluation of a product, process, or service.

                    (10) "Pilot Plant Facility" means a facility which uses
               small-scale or intermediate-scale process equipment.

                    (11) "Press" means a mechanical device for separating
               liquids from solids.

                    (12) "Reactor" means a device in which a chemical
               reaction takes place between two or more materials
               introduced into the device, where a VOC chemically modifies
               one or more materials.

                    (13) "Research and Development" means bench-scale or
               small-scale kelp and/or bio-polymer processing operations,
               including operations performed for purposes of testing and
               quality control, which are not used for production purposes
               to produce a salable product or service, other than the
               first-article product or service.

                    (14) "Spent Pot" means the container where VOC-
               containing liquid is collected immediately after being
               discharged from a press.

                    (15) "Stationary Source" means the same as is defined
               in Rule 20.1.

                    (16) "Stationary Storage Tank" means any tank,
               reservoir, or other container used to store, but not
               transport, VOC.  Stationary storage tanks do not include
               tanks used to separate solids from process streams or spent
               pots.

                    (17) "Still" means a device designed to separate, in
               whole or in part, the constituents of a mixture of miscible
               liquids by heating the liquid mixture and preferentially
               condensing and collecting the vapors.

                    (18) "Temporary Equipment", for the purposes of the
               exemption in Subsection (b)(5), means equipment located at a
               pilot plant facility for a period not exceeding 90 days in
               any consecutive twelve-month period.

                    (19) "Volatile Organic Compound (VOC)" means any
               volatile compound containing at least one atom of carbon
               excluding methane, carbon monoxide, carbon dioxide, carbonic
               acid, metallic carbides or carbonates, ammonium carbonates,
               and exempt compounds which may be emitted to the atmosphere
               during operations subject to any provision of this rule.

               (d)  STANDARDS

                    (1)  A person shall not operate any kelp processing or
               bio-polymer manufacturing line unless all aboveground
               stationary storage tanks, having capacities greater than
               20,000 gallons, containing VOC used in conjunction with the
               line are equipped with pressure-vacuum relief valves which
               have minimum relief settings of 5 oz/sq. in. (pressure) and
               0.5 oz/sq. in. (vacuum).  Tanks with capacities greater than
               50,000 gallons shall have minimum relief settings of 0.5
               oz/sq. in. (pressure) and 0.5 oz/sq. in. (vacuum).

                    (2)  A person shall not operate any kelp processing or
               bio-polymer manufacturing line or pilot plant facility
               unless all piping, valves, fittings, tanks, stills, process
               equipment and other devices used to transport, store, react
               or process VOC or materials containing VOC are free of
               fugitive liquid leaks.  A fugitive liquid leak from
               incorporators shall only be considered a violation of this
               rule if the liquid contains more than 50 percent by weight
               of VOC.

                    Repair of a fugitive liquid leak may be delayed until
               the leaking equipment is next scheduled to be off-line, or a
               production cycle is completed, or within 72 hours of
               detection, whichever occurs first, provided:

                         (i)  The time, date and location of the leak are
                    recorded promptly following detection;

                         (ii) All practicable steps to minimize the
                    magnitude of the leak are taken as soon as possible
                    following detection; and

                         (iii)The record required by Subsection (d)(2)(i)
                    is made available to the Air Pollution Control Officer
                    upon request.

                    An unrecorded leak shall be considered a violation of
               this rule.  The provisions of this subsection shall become
               effective June 15, 1997 for presses in a kelp processing
               manufacturing line.

                    This subsection shall not apply to liquid losses
               occurring during maintenance, repair or back flushing of
               process and storage equipment.

                    (3)  A person shall not operate any kelp processing or
               bio-polymer manufacturing line or pilot plant facility
               unless each in-process tank for material containing VOC is
               equipped with an apparatus or cover which completely covers
               the tank but not necessarily provides a vapor tight seal,
               and which is closed or in place at all times except as
               necessary to meet operating requirements or for maintenance.

                    (4)  A person shall not operate any bio-polymer
               manufacturing line unless the total emissions of VOC's to
               the atmosphere from all driers used in conjunction with all
               lines are reduced by at least 95 percent by weight by means
               of an approved air pollution control device.  This
               requirement shall not apply to driers whose exhaust contains
               VOC at an average concentration of 200 ppmv or less over a
               complete batch or cycle.  Emissions of VOC occurring during
               the transfer of materials containing VOC into or out of a
               drier shall be included when determining emissions from that
               drier.

                    (5)  A person shall not operate a kelp processing line
               unless the total emissions of VOC to the atmosphere from all
               driers and reactors used in conjunction with all affected
               lines are reduced by means of an approved air pollution
               control device as follows:

                         (i)  For kelp processing lines or portions of
                    lines where the primary VOC being emitted is not a
                    process reactant or byproduct of a process reaction, by
                    at least 95 percent by weight.

                         (ii) For kelp processing lines or portions of
                    lines where the primary VOC being emitted is a process
                    reactant or byproduct of a process reaction, by at
                    least 80 percent by weight.

                    Emissions of VOC occurring during the transfer of
               materials containing VOC into or out of a drier or reactor
               shall be included when determining emissions from the drier
               or reactor.

                    (6)  A person shall not operate any pilot plant
               facility unless the total emissions of VOC's to the
               atmosphere from all driers used in conjunction with all
               lines are reduced by at least 95 percent by weight by means
               of an approved air pollution control device.  This
               requirement shall not apply to driers whose exhaust contains
               VOC at an average concentration of 200 ppmv or less over a
               complete batch or cycle.  Emissions of VOC occurring during
               the pneumatic transfer of materials containing VOC into or
               out of a drier shall be included when determining emissions
               from that drier.  Emissions of VOC occurring during manual
               transfer of materials containing VOC into or out of a drier
               shall not be included when determining emissions from that
               drier, provided the containers used to transfer the
               materials are covered after filling and prior to discharge.

                    (7)  Equipment, devices and systems in use to transport
               and control VOC emissions pursuant to Subsections (d)(4),
               (d)(5) and (d)(6) shall be maintained so as to be free of
               visible holes, breaks, openings or separations between
               adjoining components, that are not consistent with their
               design and intended operating function, from which fugitive
               VOC vapors would be emitted to the atmosphere.

                    (8)  An operation and maintenance program shall be
               submitted to the Air Pollution Control Officer for approval
               for new equipment required by Subsections (d)(4), (d)(5),
               (d)(6) and (d)(11).  An existing operation and maintenance
               program that has been approved by the Air Pollution Control
               Officer need not be resubmitted for approval as a result of
               amendments to this rule unless such approved operation and
               maintenance program is revised.  Each program shall be
               implemented and maintained on approval of the Air Pollution
               Control Officer.

                    Each operation and maintenance program submitted for
          approval shall:

                         (i)  Maintain the VOC emission reduction
                    efficiency required under Subsections (d)(4), (d)(5),
                    (d)(6) and (d)(11); and

                         (ii) Identify and maintain all key system
                    operating parameters.  Key system operating parameters
                    are those parameters, such as temperature, pressure,
                    and/or flow rate, necessary to maintain the VOC
                    emission reduction efficiency required under
                    Subsections (d)(4), (d)(5), (d)(6) and (d)(11); and

                         (iii)Include proposed inspection schedules,
                    anticipated ongoing maintenance steps and proposed
                    daily recordkeeping practices regarding the key system
                    operating parameters.

                    Each program will apply only to the equipment necessary
               to meet the requirements of Subsections (d)(4), (d)(5),
               (d)(6) and (d)(11) and need not include inspection, mainte-
               nance or recordkeeping relevant to compliance with
               Subsection (d)(7).

                    (9)  Compliance with Subsections (d)(4), (d)(5),
               (d)(6), and (d)(11) shall be determined based upon tests or
               observations of the process equipment and air pollution
               control system during a period of at least 16 hours, but not
               more than 24 hours.  Affirmative determination of compliance
               may be demonstrated through tests or observations for a
               shorter period of time provided such period of time has been
               determined appropriate in writing by the Air Pollution
               Control Officer.  Such a shorter test period shall not be
               the basis for determining non-compliance.

                    (10) A person shall not operate any kelp processing or
               bio-polymer manufacturing line or pilot plant facility
               unless:

                         (i)  Pumps processing VOC-containing material are
                    equipped with dual mechanical seals, or equipped with
                    other leak-free technology that has been approved in
                    writing by the Air Pollution Control Officer and
                    provided that the equipment complies with Subsection
                    (d)(2); and
                         (ii) Liquid process mixtures containing VOC's are
                    maintained at a temperature not higher than 115F
                    (46C) before entering a press; and


                         (iii)Presses are equipped with sealing door
                    covers.

                    (11) A person shall not operate any kelp processing or
               bio-polymer manufacturing line or pilot plant facility
               unless:

                         (i)  The total uncontrolled emissions of VOC to
                    the atmosphere from presses, and spent pots are
                    captured by an emission collection system and the
                    captured emissions are transported to an air pollution
                    control device; and

                         (ii) The combined emissions capture and control
                    device efficiency is at least 75% by weight.

               (e)  RECORDKEEPING

               Any person subject to the requirements of Section (d) of
          this rule shall maintain the following records:

                    (1)  A current list of VOC's, subject to this rule that
               are in use, and

                    (2)  For air pollution control equipment, maintain
               records sufficient to document compliance, such as daily
               records of process and key system operating parameters and
               maintenance performed pursuant to Subsections (d)(4),
               (d)(5), (d)(6), (d)(8), and (d)(11) which will demonstrate
               continuous operation and compliance of the emission control
               device during periods of emission producing activities.

                    All records shall be retained on site for at least two
               years, and shall be made available to the District upon
               request.

               (f)  VOC TEST METHODS

                    (1)  The VOC content of fluids subject to Subsections
               (c)(5) and (d)(2) of this rule shall be determined in
               accordance with ASTM Standard Recommended Practices for
               General Gas Chromatography Procedures, E 260-73, General
               Techniques of Infrared Quantitative Analysis, E 168-67, or
               General Techniques of Ultraviolet Quantitative Analysis, E
               169-63.

                    (2)  The determination of the normal boiling point of
               an organic compound pursuant to Subsection (b)(4) shall be
               conducted in accordance with ASTM Standard Test Method for
               Distillation Range of Volatile Organic Liquids, D 1078-86
               or, for pure compounds, may be made from technical data
               contained in standard reference texts.

                    (3)  Measurements of VOC emissions subject to
               Subsections (d)(4), (d)(5), (d)(6), and (d)(11) of this rule
               shall be conducted in accordance with EPA Test Methods 18
               and 25 or 25A (40 CFR, Appendix A) as they exist on June 15,
               1994.  Test procedures shall be performed in accordance with
               a protocol approved by the Air Pollution Control Officer.
               An alternative method to EPA Test Method 18 may be used
               provided such method has been approved, in advance, by the
               Air Pollution Control Officer and U.S. Environmental
               Protection Agency for the specific processes being tested.
               Subsequent to the initial compliance demonstration period,
               appropriate parameters as determined by the Air Pollution
               Control Officer may be used as indicators of the performance
               of  the emission control system.


               (g)  COMPLIANCE SCHEDULE

                    (1)  Any person operating an existing bio-polymer
               manufacturing line or pilot plant facility which is subject
               to the provisions of Subsections (d)(6), (d)(10) and/or
               (d)(11) shall meet the following increments of progress:

                         (i)  By December 15, 1994, submit to the Air
                    Pollution Control Officer an application for Authority
                    to Construct and Permit to Operate the equipment
                    specified in Subsections (d)(6), (d)(10) and/or
                    (d)(11).

                         (ii) By June 15, 1995, demonstrate compliance with
                    Subsections (d)(6), (d)(10), and/or (d)(11).

                    (2)  Any person operating an existing kelp processing
               line which is subject to the provisions of Subsections
               (d)(10) and/or (d)(11) shall meet the following increments
               of progress:

                         (i)  By June 15, 1995, submit to the Air Pollution
                    Control Officer an application for Authority to
                    Construct and Permit to Operate the equipment specified
                    in Subsections (d)(10) and/or (d)(11).

                         (ii) By December 15, 1995, demonstrate compliance
                    with Subsection (d)(10).

                         (iii)By June 15, 1997, demonstrate compliance with
                    Subsection (d)(11).

                    (3)  Any person installing a new kelp processing or
               bio-polymer manufacturing line or pilot plant facility which
               is subject to the provisions of Section (d) shall have
               equipment necessary to comply with the provisions of Section
               (d) installed and operating upon startup of the line or
               facility  and shall demonstrate compliance within 180 days
               of startup.