BAY AREA AIR QUALITY MANAGEMENT DISTRICT 939 ELUS STREET SAN FRANCISCO, CA 94109 

### January 7, 1994

TO: CHAIRPERSON HILLIGOSS AND MEMBERS OFTHE BOARD OF DiRECTORS FROM: AIR POLLUTION CONTROL OFFICER SUBJECT: PROPOSED REGULATION 9, RULE 12: NITROGEN OXIDES FROM GLASS MELTING FURNACES

EXECUTIVE SUMMARY On 

### January 19, 1994, the Board ofDirectors will consider adoption ofproposed Regulation 9, Rule 12: Nitrogen Oxides From Glass Melting Furnaces. This proposed rule would implement Control Measure D6 ofthe Bay Area 1991 Clean Air Plan. The rule is one of a series of NOx control measures being developed by the District. NOx reacts with VOCs to form ozone in the lower atmosphere. When transported to downwind air basins, NOx contributes to downwind ozone. The District is required to adopt NOx controls by both the federal and state Clean Air Acts. Adoption ofthe proposed rule:

— Establishes an emission limit of 5.5 lbs NOx per ton ofglass produced.

— Affects three plants: Owens-Brockway Glass Containers in Oakland, Anchor Glass Container in Antioch, and Anchor Glass Container in Hayward.

— Requires the three plants to make percentage reductions in NOx emissions until they reach the 5.5 lb limit. Reduces overall NOx emissions from this industry by about 25%, although the Anchor plants have higher emissions and will make greater reductions.

— Minimizes the adverse economic impact of NOx control by allowing the industry to coordinate installation of control equipment with normal furnace rebuild schedules. AFFECTED PUNTS The affected glass plants all produce glass bottles, primarily forwine, beer, and soft drinks. These plants also play a significant role in the recycling of glass in the Bay Area. Each plant faces different problems in reducing NOx, and the rule is structured to allow each plant to install appropriate NOx reduction technology when furnaces are rebuilt in accordance with the plant’s normal rebuild schedule. 

## 01PROPOSED RULE The rule establishes a target emission level of5.5 lbs ofNOx perton of glass produced. To reach that target, plants are required to reduce current NOx emissions by 10% in 1997, by 25% in 1999, and by 45% in 2001. Ifthe 5.5 lb standard has not been achieved by 2001, the plants will have to make further reductions until the 5.5 lb standard is reached. Compliance with the rule will be monitored by source tests. The plants will be required to establish baseline emission levels for each furnace by performing sourcetests in accordance with District-approved specifications. Percentage reductions are then to be made from this baseline. To demonstrate thatthe mandated reductions have been achieved, the plants will a9ain perform source tests and submit results to the District. As always, the District may also conduct source tests to ensure the reliability ofthe data received. EMiSSiON REDUCTlONS The three plants affected by the proosed rule collectively emit about 5 tons of NOx per day. The rule will reduce NOx emissions by 1.2 tons perday. This represents a reduction of about 25% forthis industry. The Anchorfurnaces have significantly higher NOx emission levels than the Owens-Brockway furnaces, and will reduce emissions by about 45%. COMPLIANCE COSTS Costs ofcontrollin9 NOx will vary from plantto plant, depending upon the current level ofemissions. The costs to Owens-Brockway will be lowerbecause its furnaces already come close to meeting the proposed standard. Anchor, on the other hand, will have to install new technology, but can do so overtime, as NOx reductions are phased in. Anchor is also working on new NOx control technology that will enable it to reduce the cost ofreaching the 5.5 lb standard. Costs of control for the proposed rule range from $1800 to $2400 perton ofNOx reduced. In light ofthe importance ofthese plants to local recycling and the history of glass plant closures in the U.S., costs were carefully considered in connection with the proposed rule. The proposed rule will maximize environmental benefits by reducing NOx without threatening the existence ofthe Bay Area facilities. ASSOCIATED IMPACTS A socioeconomic analysis was performed for the proposed rule. This analysis concludes that the rule would not create significant economic impacts on the plants. According to the analysis, the plants could choose to make some minor staffreductions to recoup the costs of NOx control, but it is more likely that they will recoup costs with minor price increases. Staff performed a CEQA Initial Study to determine whether the proposed rule would have any impacts other than those analyzed in the Environmental Impact Report prepared for the Bay Area 1991 Clean Air Plan. The CAP EIR and staff’s Initial Study conclude that the proposed rule would have no significant adverse environmental impacts. 

### Ok; 

# ()The rule is also not expected to significantly affect BAAQMD staffing needs since compliance will be monitored primarily by source tests conducted by the plants. RULE DEVELOPMENT HISTORY

- June 23, 1993. Workshop draft ofrule completed. Draft rule proposed a standard similar to South Coast Air Quality Management District (SCAQMD) standard.

- July 30, 1993. Public workshop attended by representatives from Anchor and Owens-Brockway, along with two consultants for the Glass Packaging Institute. Major topics of discussion at workshop 

### were: (1) difficulties in applying various existing NOx control technologies to container glass furnaces, (2) new NOx control technologies, (3) differences between SCAQMD and BAAQMD furnaces and markets, (4) economic impacts of control, and (5) alternative rule provisions proposed by industry.

- August 1993. Staff researched NOx control efforts in the SCAQMD and outside California. Staff discussed issues with furnace engineers for most of the major producers of container glass nationwide.

- September 1993. Staff revised the rule proposal following determination that proposed standard would probably lead to plant closures.

— October 1, 1993. Staff mailed revised draft of rule to affected parties. Staff received written comments from both Anchor and Owens-Brockway. These comments resulted in minor changes to the rule and staffreport. October 22, 1993. Final proposed rule completed, public hearing notice mailed. CONCLUSION A copy of Regulation 9, Rule 12: Nitrogen Oxides From Glass Melting Furnaces, along with copies of the staff report, the socioeconomic impact analysis, and the CEQA analysis are attached for your review. Staff recommends adoption-of the proposed rule.



# oj

# 0

.0STAFF REPORT PROPOSED REGULATION 9, RULE 12 NITROGEN OXIDES FROM GLASS MELTING FURNACES

EXECUTiVE SUMMARY Proposed Regulation 9, Rule 12 is a

### retrojit rule designed to reduce 

### nitrogen oxides (NOx) emissions from glass melting furnaces. The rule would implement Control Measure D6 ofthe BayAiea 1991 CleanAirPlan. The proposed rule would affectthree BayArea containerglass plants operating atotal offive furnaces, and would require specified percentage reductions in NOx emissions from a baseline established foreach furnacethrough source testin9. No furtherreductions would be required afterattainment ofatarget emission limit of5.5 lbs of NOx perton ofglass pulled from the furnace. The rule specifres a 10% reduction from baseline NOx emissions effectiveJanuary 1, 1997, a 25% reduction from baseline effectiveJanuary 1, 1999. and a 45% reduction effective January 1, 2001. The estimated cost ofcomplying with the proposed rule varies, depending on the current emission level ofthe plant. TWo plants have emissions in the 9.0- 10.0 lb range, and have significantly fartherto go than thethird plant, which has emissions in the 5.0-6.0 lb range. Forthe plants with higheremissions, the cost ofcomplying with the 10% reduction requirement and the 25% reduction requirement is approximately $2000 perton ofNOxreduced. Forthese plants to reach the 5.5 lb standard, emissions would have to be reduced by 45%, at a cost ofapproximately $4000 per ton ofNOx reduced. The plantwith lower emissions can meetthe 5.5 lb standard with a 10% reduction in emissions, at a cost ofapproximately $2400 perton orless. Whetherthe District should mandate reductions to 5.5 lbs orbelow, and by when, were the central issues ofthis rulemaking effort. The current South Coast Air Quality Management District (SCAQMD) limit dropped to 4.0 lbs on January 1, 1993 under a rule adopted in 1983. The Bay Area CAP and the workshop draft ofthis rule proposed this same limit, effective January 1, 1997. Atthe workshop and in numerous contacts afterthe workshop, industrypresented considerable technical and financial information which adequately demonstrated to 

### staffthe following:

— The Bay Areafurnaces differ in importantdesign respects from most of the South Coast furnaces, making some relatively low capital cost NOx reduction techniques used on the South Coastfurnaces unavailable here. The South Coast plants have been able to complywith the 4.0 lb standard by usin9 these low-cost techniques in conjunction with a production technique called electric boosting. Electric boosting can be used eitherto replace some gas firing, thereby reducing NOx. or. supplement gas firing, thereby increasing production.



### 10 1- The South Coast plants had 16 years 

### from the beginning ofthe SCAQMD rulemaking effort to the effective date ofthe 4.0 lb standard, which allowed the plants to structure production so that electric boostin9 reduced NOx. Bay Area plants used the technique to increase production and can no longer use itto reduce NOx.

- Othertechnologies, upon which rulemaking efforts byARB and SCAQMD werebased, have notworked for container glass furnaces and are not options forthe Bay Areafurnaces.

-, The onlytechnology currently avãflabletothe BayArea glassplants that gives significant NOx reductions with good glass quality and proven performance is a relatively newtechnology using 100% oxygen combustion.

-. To reach 5.5 lbs in the nearterm (4-6 years). two ofthe three BayArea plants would have to install oxygen-fuel technology. To reach 4.0 lbs in the nearterm, all three plants would have to installoxy-fuel technology.

- Because ofthe potentially high capital costs and high operating costs of this technology, some orall ofthe plants would have to dose ifrequired to buythe technology in the nearterm. Closure ofthe plants would not only havethe obvious economic and

• social costs, butItmight also have a netnegative environmental impact because ofthe significantrole In glass recyding played bythe plants. The low-costtechniques availableto the plants here will allow NOx reductions ofapproximately 25%.

— New technologies thatwill reduce the costofmeetinQ a 5.5 lb limit, and perhaps even lower fimits, will probably be 

### available in the next 5-7 years. Given these findings, staffchose to fundamentallyrestructurethe earlierdraft rule. The essential thrust ofthe current proposal is to require the BayArea plants to use the low-costtechnologies that are availableto them nowto begin reducing NOx emissions toward a 5.5 lb target. Bythetime uncertainties about oxy-fuel technology are resolved and other newertechnologies are available, the plants will be required to use these technologies to meetthe 5.5 lb target The plants have been willing to accept a requirementto meet a 5.5 lb target in 2001 thatthey could not afford to meetby 1997 because they are fairly certain that developing technologies will significantlyreduce the costofachieving the reduction by 2001. The proposed Board Resolution nevertheless indudes a requirementthat staff, by January 1, 2000, reevaluate the technical feasibility and cost ofmeeting the 45% reduction target Staffwould then bring any necessary changes in the rule to the Board priorto the effective date forthe reduction. BACKGROUND NOx emissions resultfrom the combustion offossil fuels in the presence ofair. wThermal NOxa emissions are produced by high temperature combination ofthe 

# 0 2

— 

### 1.1.

### nitrogen and oxygen in combustion air. It the fuel contains nitrogen compounds, some ofthe fuel nitrogen may combine with atmospheric oxygen to form fuel 

### NOx. Since Bay Area glass plants bum natural gas, which contains 

### almost no nitrogen, nrtually all NOx emissions from the plants are thermal NOx. NOx emissions combine with VOCs (volatile organic compounds) in the presence ofsunHghtto form ozone. Because NOx emissions contribute to ground-level ozone formation, both the federal Clean AirActAmendments of 1990 and the Cailfomia Clean AirAct indude certain mandates to control NOx. Section 182(1) ofthe federal Clean 

### MrActrequires that state implementation plans include NOx control measures for nonattainment areas, unless EPA determines that net air quality benefits are greater in the absence of such controls. Because Districtair quality modeling showed that NOx measures would notbenefit air qualitywithin the District, the District submitted a requestto be exempted from the NOxrequirements. In addition, the Districthas met EPA criteria forredesi9nation as an ozone attainment area, and has submitted a requestforredesignation. Until EPA grants eitherrequest, however, the federal NOx control requirements apply. The federal NOx requirements must be implemented by May 31, 1995. Even ifthe federal requirements were to disappear, the Districtremains a nonattainment areaforthe state ozone standard and is subjectto state mandates. The California Clean Air Actrequires ARB to identify airbasins that contribute to violations ofthe state ozone standard in downwind basins and to develop mitigation measures. UnderARB regulations implementing this requirement, the Bay Area must adopt NOx controls for source categories accounting for 75 percent ofthe District’s NOxinventory The glass plants thatwould be affected by this rule are currentlythe eleventh, fifteenth, and twenty-second largest NOx sources in the District and coflectivety emit about 5 tons ofNOx perday. The larger BayArea refineries and electric power generating plants each emit about 10 tons ofNOxper day. The total stationary source NOx inventory was estimated to be 158 tons per day for 1991. South Coast Rule The model forthe 1991 CAP control measure to be implemented bythis rule was South CoastAir Quality Management District (SCAQMD) Rule 1117. Rule 1117 is more stringentthan the proposed rule, and currently requires South Coast glass plants to meet a standard of4.0 lbs NOx perton ofglass pulled. After receiving significant industry input during the rule development process, it became clearthatthe South Coast standard is not an entirely appropriate model for this rule forthree reasons. First, the South Coast rulemaking process for Rule 1117 began in 1977. Bythe time the 4.0 lb standard took effect on January 1, 1993, glass plants had 16 years to prepare to meetthe standard and had been meeting an interim 5.5 lb standard for 6 years. Second, the furnaces in the Bay Area differ in significant design respects from those in the South Coast. Third, many ofthe technologies upon which the SCAQMD rule was premised have not proved viable for container furnaces.



### L2 3

### Glass Industry In the U.S., the last new container glass plantwas built in 1980. Since 1980, 4.3 ofthe 115 plants then in existencehave been peiTnanentlydosed. There are now 11 containerglass plants in California: five plants in the SCAQMD, three in the San Joaquin Valley Unified APCD, and three in the BMQMD (Glass International). In Californiathere have been a numberofplant dosures in recentyears. In the SCAQMD, there have been three closures since the passage ofRule 1117, with one occurring lastyear. In the BayArea, there have been two plarjt dosures in the lasttwo ye4rs: the Owens-Brockway south plant in Oakland in 1992, and theAnchor (formerly Latchford) plantin San Leanciro in .1991. Recycling The BayAreaplants currentlyproduce about 1200tons ofglass perday. Approximately 30% ofbatch material is recycled glass. This represents an annual consumption ofapproximately 130,000 tons ofrecycled glass. According to California Senate estimates, about40 milliontons ofmunicipal solid waste are generated each year in California. Glass represents about 10% ofthis total. Given thatthe Bay Area’s population Is about 18% ofthe state total, it Is assumed thatthe BayArea sends about 720,000tons ofglass to landfills peryear. 

### Recycled glass used bythe BayArea

### plants istherefore equal to 18% ofthe amount sentto BayArea landfills. AFFECTED FACIUTIES The proposed rule applies to lar9e glass melting furnaces. Three container glass plants currently operating in the Districtwould be subjectto the rule. Anchor Glass Container Corporation operates two plants: one InAntioch and one in Hayward. Each Anchor plant has one glass melting furnace capable of producing approximately 300tona ofcontainer glass perday. Owens-Brockway Glass Container operates aplant in Oakland with three furnaces, collectively capable ofproducing rou9hly 800 tons ofcontainer glass perday. These three plants are the only plants identified as subjectto the proposed rule.

- The rule contains two exemptions. The first exemption (Section 9-12.110.1) is for electric melting furnaces. Although electric melting furnaces may produce some NOx ifniter (sodium nitrate) is added to the glass batch, NOx emissions are generallyinsignificant The only large electric furnace in the District is operated by Owens-Coming Fiberglass in Santa Clara. This furnace would not be subjecttothe rule. FUrnaces producing 4550 kg (5 shorttons) ofglass per day or less are exempted (Section 9-12-110.2). Any furnaces this smallwould produce insignificantNOx emissions. Staffhas been unableto identify any specific furnaces thatwould be exempted by this provision, butthe exemption is intended to applyto small art glass or other handmade glass operations.



# 0 4 

### 13