United States Environmental Protection Agency, Region 9 

Air Division 

Technical Support Document 

for 

EPA’s Notice of Rulemaking 

for the 

California State Implementation Plan 

Mojave Desert Air Quality Management District’s 

Rule 1165, Glass Melting Furnaces 

Prepared by: Idalia Perez 

January 2012 
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Mojave Desert Air Quality Management District (MDAQMD) 

Submitted Rule 

MDAQMD Rule 1165, Glass Melting Furnaces: 

§ Adopted: August 12, 2008 

§ Submitted: December 23, 2008 

§ Determined complete: April 20, 2009 

Previous Rule Submittals 

A previous version of Rule 1165 was adopted on August 27, 2007 and submitted to EPA 

on March 7, 2008. This interim submittal was superseded by the December 23, 2008 

submittal which is discussed in this Technical Support Document (TSD). Although we 

can only act on the most recent version of the submitted rule, we have reviewed 

previously submitted versions. 

SIP-Approved Rule 

There is currently no SIP-approved version of Rule 1165. 

Rule Summary 

Rule 1165 limits emission of nitrogen oxides (NOx), carbon monoxide (CO), volatile 

organic compounds (VOCs) and sulfur oxides (SOx) from glass melting furnaces that 

produce at least 5 tons of glass per day. 

Emission limits are as follows (Section (C)(1)). 

Type of 

Furnace 

Combustion 

Type 

NOx CO VOC 

Container 

Glass or 

Fiberglass

100% AirFuel Fired 4.0 lb/ton of glass pulled on a 

24-hour block average 

300 ppmv 20 ppmv 

Oxygen 

Assisted 

Combustion 

4.0 lb/ton of glass pulled on a 

24-hour block average 

1.0 lb/ton of 

glass pulled 

0.25 lb/ton of 

glass pulled 

Flat Glass 100% AirFuel Fired 9.2 lb/ton of glass pulled on a 

24-hour block average 

and 

7.0 lb/ton of glass pulled on a 

rolling 30-day average 

300 ppmv 20 ppmv 

Oxygen 

Assisted 

Combustion 

9.2 lb/ton of glass pulled on a 

24-hour block average 

and 

7.0 lb/ton of glass pulled on a 

rolling 30-day average 

0.9 lb/ton of 

glass pulled 

0.1 lb/ton of 

glass pulled 

SOx is controlled by requiring units to fire on PUC-quality natural gas. Liquid fuels are 

allowed as backup fuels if they contain no more than 15 ppm of sulfur and the unit firing 

them has a SOx emission control system with a control efficiency of 50% or greater. 
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Section (C)(3) indicates the startup requirements, section (C)(4) has the shutdown 

requirement and Section (C)(5) has the idling requirements. 

Section (D) has monitoring and recordkeeping requirements. 

Section (E) has compliance procedures and tests methods. 

Section (F) indicates what constitutes a violation of the rule. 

Effects on Emissions 

Supporting information that was included in the SIP-submittal indicates that no emission 

reduction will result from implementation of Rule 1165 because the District’s only 

facility subject to this Rule has permit conditions more stringent that the Rule. In 

addition, this facility ceased operations in 2008. 

Rule Evaluation Criteria 

We have primarily used the following three criteria to evaluate Rule 1159: 

Rule Stringency Section 172(c)(1) of the Clean Air Act (CAA) requires 

nonattainment areas to implement all reasonably available control measures 

(RACM), including such reductions in emissions from existing sources in the area 

as may be obtained through the adoption, at a minimum, of reasonably available 

control technology (RACT), as expeditiously as practicable. Ozone nonattainment 

areas classified as moderate or above must require RACT for all major sources of 

NOx. CAA § 182(b)(2) & (f). In addition, SIP rules must implement Reasonably 

Available Control Measures (RACM), including Reasonably Available Control 

Technology (RACT), in moderate PM-10 nonattainment areas (see CAA sections 

189(a)(1)) The MDAQMD regulates an ozone nonattainment area classified as 

Severe-17 for the 1-hour ozone standard and classified as moderate for the 8-hour 

ozone standard (see 40 CFR part 81), thus Rule 1159 must fulfill RACT 

requirements for NOx. The MDAQMD also regulates a moderate PM-10 

nonattainment area, and is therefore subject to the requirement under sections 

189(a)(1)(C) and 189(e) of the Act to implement RACM for control of PM-10 

and PM-10 precursor emissions. 

Enforceability CAA section 110(a)(2)(A) requires that regulations submitted to 

EPA for approval into a State Implementation Plan (SIP) must be clear and 

legally enforceable. 

SIP Revisions CAA section 110(l) prohibits EPA from approving any SIP 

revision that would interfere with any applicable requirement concerning 

attainment and reasonable further progress (RFP) or any other applicable 

requirement of the CAA. In addition, CAA section 193 prohibits the modification 

of any SIP-approved control requirement in effect before November 15, 1990, in a 

nonattainment area.
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Guidance and policy documents that we used to define specific enforceability, RACT and 

RACM requirements include the following: 

• Issues Relating to VOC Regulation, Cutpoints, Deficiencies, and Deviations (the 

“Blue Book”), US EPA, OAQPS (May 25, 1988). 

• Guidance Document for Correcting Common VOC and Other Rule Deficiencies, 

EPA Region IX (August 21, 2001, the “Little Bluebook”). 

• State Implementation Plans; General Preamble for the Implementation of Title I 

of the Clean Air Act Amendments of 1990, 57 FR 13498 (April 16, 1992); 57 FR 

18070 (April 28, 1992). 

• State Implementation Plans for Serious PM-10 Nonattainment Areas, and 

Attainment Date Waivers for PM-10 Nonattainment Areas Generally; Addendum 

to the General Preamble for the Implementation of Title I of the Clean Air Act 

Amendments of 1990, 59 FR 41998 (August 16, 1994). 

• PM-10 Guideline Document, US EPA 452/R-93-008 (April 1993). 

• Interim White Paper - Midwest RPO Candidate Control Measure: Glass 

Manufacturing, Lake Michigan Air Directors Consortium (December 12, 2005) 

http://www.ladco.org/reports/control/white_papers/glass_fiberglass_manufacturin

g_plants.pdf

• Alternative Control Techniques Document-- NOx Emissions from Glass 

Manufacturing, US EPA 453/R-94-037 (June 1994). 

http://www.epa.gov/ttn/catc/dir1/glassact.pdf

• Integrated Pollution Prevention and Control (IPPC) Reference Document on Best 

Available Techniques in the Glass Manufacturing Industry, European 

Commission (December 2001). 

http://www.epa.ie/downloads/advice/brefs/glass.pdf 

Evaluation of Rule Stringency 

Due to the high temperatures in glass furnaces (up to 1650°C – 2000°C in the flame), the 

dominant source of NOx is thermally generated NOx. According to the ACT, 

uncontrolled NOx emissions from glass manufacturing facilities are typically (see Table 

2-1 in the ACT): 

Type of glass produced Uncontrolled NOx Emissions (lb/T) 

Container 1.8 – 21.6 

Flat 8.8 – 23.6 

The wide range in emissions reflects the effects of furnace type, age and combustion 

characteristics on NOx emissions. Various technologies, including combustion 

modifications, process modifications and post-combustion modifications, are available to 

control NOx emissions from glass manufacturing facilities with control efficiencies 

ranging between 10 and 85% (see Table 2-2, ACT). The effects of these techniques are 

not additive; therefore, a 10% reduction due to one technique cannot simply be added to 

10% from a different technique. Control efficiencies generally decrease with furnace age. 

The most effective technique discussed in the ACT is oxy-firing, in which combustion is 

done in an oxygen rich environment and requires a source of O2. Many of the techniques 

can only be effectively installed during a furnace rebuild and some of them have not been 
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shown to be applicable to the manufacturing of all types of glass. Some considerations 

that may hinder the installment of control techniques include space requirements and 

concerns of glass quality due to redox changes. Additionally, some of these control 

techniques can increase emissions of other pollutants (e.g. increased SO2 emissions from 

some combustion modifications techniques due to an atmosphere with a larger reducing 

capacity). The percentages in reduction in Table 2-2 of the ACT assume uncontrolled 

NOx emissions of 15.8 lb/T for flat glass. Using these emission values and Table 2-2 of 

the ACT, we can calculate a best case scenario for controlled NOx emissions from flat 

glass furnaces to be 2.37 lb/T. This calculated best case scenario value does not represent 

an emission that has been achieved in practice. We are only focusing on flat glass 

because the only existing source at MDAQMD subject to this rule produces flat glass, 

AGC Flat Glass North America located in Victorville. 

The following are NOx emissions limits in permits obtained from the RBLC: 

RBLC ID Year Permit Issued Type NOx (lb/T) 

OH-0319 2008 Flat 7.4 

WA-0320 2008 Flat 7.0 

The following table contains NOx emission limits for different types of glass 

manufacturing facilities in prohibitory rules throughout the US: 

Area Type of Glass NOx Emission Limit (lb/T) 

BAAQMD (Rule 9-12, 1994) All 5.5 (3 hour period) 

SJVUAPCD (Rule 4354, Tier 

2, compliance date of 3/31/08) 

Flat 9.2 (24-hour block average) & 

7.0 (30-day rolling average) 

SJVUAPCD (Rule 4354, 

compliance date of 1/1/11) 

Flat 5.5 (24-hour block average) & 

5.0 (30-day rolling average) 

SJVUAPCD (Rule 4354, 

compliance date of 1/1/14) 

Flat 3.7 (24-hour block average) & 

3.2 (30-day rolling average) 

SJVUAPCD (Rule 4354, 

compliance date of 1/1/16) 

Flat 3.4 (24-hour block average) & 

2.9 (30-day rolling average) 

SCAQMD (Rule 1117, 1984) All 4.0 

New Jersey State Dept of 

Environmental Protection 

(7:27-19, 2008) 

Various 4.0 

New Jersey State Dept of 

Environmental Protection 

(7:27-19, 2008) 

Flat, 

PTE > 10 T/year 

9.2 

Massachusetts Department of 

Environmental Protection (310 

CMR 7.19(11)) 

All Types, max 

production rate > 14 

T/day 

5.3 

New York Department of 

Environmental Conservation (6 

NYCRR Part 220-2) 

Flat 9.2 (24-hour block average), or 

7.0 (30-day rolling average) 
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Rule 1165 implements RACT for NOx in Mojave Desert AQMD at the time of rule 

submittal to EPA for reasons including: 

- South Coast AQMD Rule 1117 and Bay Area AQMD Rule 9-12 have more 

stringent limits for flat glass manufacturing facilities but there are no facilities 

of this type in the South Coast or Bay Area District thus the limits have not 

been shown to be reasonable available in practice. 

- At the time of rule adoption, MDAQMD’s Rule 1165 was as stringent San 

Joaquin Valley Unified APCD’s Rule 4354 which was approved into the SIP 

in 2007 (72 FR 41894). SJVUAPCD has subsequently amended the rule and 

added more stringent NOx emission limits with compliance deadlines ranging 

from January 2011 to January 2016. 

- The 1994 ACT document mentioned above provide technical information 

including control techniques and achievable controlled NOx emission levels 

from glass melting furnaces. Rule 1165 requirements are consistent with data 

in the ACT. 

- The combination of daily and monthly limits complement each other by 

minimizing large spikes in emissions due to short-term variations as well as 

ensuring lower emissions are achieved over longer timeframes. Taken 

together, these limits are consistent with available the technology as well as 

the operational and emission characteristics of glass manufacturing facilities 

which have short-term fluctuations due to minor process adjustments as well 

as longer term fluctuations due to changes in production output driven by 

varying market conditions. 

Since no CTG has been issued for this activity, we do not have clear national guidance 

defining presumptive RACT. However, we believe the analysis summarized above 

sufficiently demonstrates that Rule 1165 implements RACT at the time of rule adoption 

for NOx emitted from glass furnaces in Mojave Desert. 

CAA §172(c)(1) requires nonattainment areas to implement all reasonably available 

control measures, including such reductions in emissions from existing sources in the 

area as may be obtained through the adoption, at a minimum, of RACT, as expeditiously 

as practicable. Glass furnaces can emit direct PM, as well as SOx, which is a precursor to 

PM, and NOx, which is a precursor to both PM and ozone. Therefore, MDAQMD must 

implement RACM for glass furnaces if those measures will advance attainment of the 

National Ambient Air Quality Standard (NAAQS) for PM10 or ozone, when considered 

collectively with other reasonable measures. Additional control measures may be 

required pursuant to CAA §172(c)(1) if both: (1) additional measures are reasonably 

available; and (2) these additional reasonably available measures will advance attainment 

in the area when considered collectively. In separate rulemakings, EPA will take action 

on the State’s RACM demonstration for ozone based on an evaluation of the control 

measures submitted as a whole and their overall potential to advance the applicable 

attainment dates in the District. See 40 CFR §§ 51.1010, 51.912(d). 

Evaluation of Enforceability and SIP Revision Criteria 
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Recordkeeping and other compliance provisions in the rule ensure that the requirements 

are adequately enforceable. 

The submitted rule is a new addition to the SIP, strengthening the requirements of the 

SIP. Therefore, we propose to determine that an approval of the submittal would comply 

with CAA sections 110(l) and 193 because (1) the proposed SIP revision would not 

interfere with the on-going process for ensuring that requirements for RFP and attainment 

of the NAAQS are met, and (2) the submitted SIP revision is more stringent than the 

existing SIP requirements. 

Suggested Rule Improvements 

Although not currently basis for rule disapproval, EPA recommends that the MDAQMD 

make the following improvements in the next revision of Rule 1165: 

1. An equation on how to calculate control efficiency, which is referred to in Section 

(C)(2)(B), should be added to the Rule. 

2. A definition of the terms “innovative” and “common use”, used in Section 

(C)(3)(d)(i) should be added to the Rule. 

3. Section (C)(7) should also require a CO CEMS. 

4. The District should consider adopting the NOx, SOx and PM emission limits in 

San Joaquin Valley Rule 4354, amended on May 19, 2011. 

5. The District should evaluate if long-term averaging (longer than 24 hours) is still 

needed given changes in available technology and is consistent with attaining and 

maintaining the NAAQS as well as with meeting RFP/ROP. 

Recommendation 

EPA staff recommends approval of submitted Rule 1165 for incorporation into the 

California Applicable SIP. 

Other References 

1. Submitted Rule 1165 

2. Staff Report 

3. RBLC permit information (OH-0319, WA-0320)