UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION III 1650 Arch Street Philadelphia, Pennsylvania 19103
DATE: May

5, 2011 SUBJECT: Technical Support Document

– Commonwealth of Pennsylvania

– Control o f

Nitrogen Oxides from Glass M elting Furnaces /s/ FROM: Rose Quinto, Environmental Engineer

Office of Air Program Planning TO: File /s/ THRU: Cristina Fernandez , Associate Director

Office of Air Program Planning
A. BACKGROUND On July 23, 2010 , the Pennsylvania Department of Environmental Protection (PADEP) submitted a State Implementation Plan (SI P) revision pertaining to the control of nitrogen oxides (NOx) emissions from glass melting furnaces. The manufacturing process requires raw materials, such as sand, limestone, soda ash, scrap, and recycled glass, to be fed into a furnace where a temperature is maintained in the 2700° to 3100° Fahrenheit range. The raw materials then chemically

react creating a molten material

– glass. The reaction of nitrogen and oxygen in the furnace creates NOx emissions, of which NOx is a precursor of ozone. This SI P revision is based on the Ozone Transport Commission (OTC) control measure to reduce NOx emissions from glass melting furnaces. The OTC members include Pennsy lvania, Connecticut, Delaware, Main e, Maryland, Massachusetts, New Hampshire, New Jersey , New York, Rhode I sland, Vermont, Virginia, and the District of Columbia. The OTC was created under section 184 of the Clean Air Act (CAA) to establish regulatory programs to reduce ozone precursor emi ssions, which includes the reduction of NOx emissions from glass melting furnaces.
B. STATE SUBMITTAL The SI P revision adds definitions and terms to Title 25 of the Pennsylvania Code (25 Pa. Code) Chapter 121.1, relating to definitions , used in the s ubstantive provisions of this SI P revision. The SI P revision adds a new regulation pertaining to the NOx emission standards in 25 Pa. Code Chapter 129, Standards of Sources, Sections 129.301 through 129.310, Control of NOx Emissions from Glass Melting Fur naces . The SI P revision applies to an owner or operator of a glass melting furnace that emits or has the potential to emit NOx at a rate greater than 50 tons per2

ye ar in the Commonwealth of Pennsylvania, including the local air pollution control agencies in Philadelphia and Allegheny Counties. The purpose of the SI P revision is to annually limit the emissions of NOx from glass melting furnaces. T he following definitions and terms were added in 25 Pa. Code Section 121.1 : Blown glass

– Glassware shaped by blowing air into a molten glass gather. Cold shutdown

– A cold repair or replacement of damaged or worn refractory parts of a glass melting furnace while the furnace does not contain molte n glass. Container glass

– Glass manufactured by pressing, blow ing in molds, drawing, rolling or casting which is used as a container. Fiberglass

– Material consisting of fine filaments of glass that are combined into yarn and woven or spun into fabrics, or that are used as reinforcement in other materials or in mass es as thermal or as acoustical insulating product. Flat glass

– Glass produces by the float, sheet, rolled or plate glass process which is used in windows, windshields, tabletops or similar products. Glass melting furnace

– A unit comprising a refractory
- lined vessel in which raw materials are charged and melted at high temperature to produce molten glass. Idling

– The operation of a glass furnace at less than 25% of the permitted production capacity or fuel use capacity

as stated in the plan approval or operating permit. Permitted production capacity

– The maximum pull rate as stated in the plan approval, oper ating permit or Title V permit. P ressed glass

– Glassware formed by placing a blob of molten glass in a metal mold, then pressing it with a metal plunger or follower to form the inside shape. The resultant piece, termed “ mold
- pressed,” has an interior f orm independent of the exterior, in contrast to mold
- blown glass, whose interior corresponds to the outer form. P rimary furnace combustion system

– The burners in a glass melting furnace that are used during production of glass. P ull rate

– The amount of glass withdrawn from a glass melting furnace, expressed in short tons per day
. S hutdown

– The period of time during which g lass melting furnace is taken f r o m an operational to a non - operational statu s by allowing it to cool down f r o m its operating temper ature to a cold or3

ambient temperature as the fuel supply is turned off. S tart
- up
– The period of time, after initial construction, shutdown or cold shutdown, during a glass melting furnace is heated to stable operating temperature by the primary

furnace combustion sy stem, and sy stems and instrumentation are brought to stabilization. Summary of the SIP Revision The SI P revision adds a new regulation in 25 Pa. Code Chapter 129, Control of NOx Emissions from Glass Melting Furnaces, Sections 129.301

– 12 9.310. Section 129.301, relating to the purpose of the new regulation, annually limits the emissions of NOx from glass melting furnaces. Section 129.302, relating to the applicability , specifies that the regulation applies to an owner or operator of a gl ass melting furnace that emits or has the potential to emit NOx at a rate greater than 50 tons per y ear. Section 129.303 provides that the emission requirements do not apply during periods of start
- up, shutdown, or idling if the owner or operator complies with the start - up, shutdown, and idling requirements . (See start
- up, shutdown, and idli ng requirements in the PADEP SI P revision submittal

– s ections 129.305, 129.306, and 129.307, and page 5 of the attachment of EPA’s Start
- up, Shutdown and Malfunction ( SSM ) Policy

– Memorandum of Steven A. Herman and Robert Percias epe, Policy of Excess Emissions During Malfunctions, Start

- up and Shutdown , September 20, 1999). Owners and ope rators claiming the exemption sha ll notify PADEP or the local air pollution control agency within 24 hours after initiation of the operation for which the exemption is claimed. Additionally , the owner or operator of a glass melting furnace that is granted an exemption sha ll maintain operating records or documentation, or both necessa ry to support the claim for the exemption. Section 129.304 provides that the own er of a glass melting furnace shall determine allowable NOx emissions by

multiplying the tons of glass pulled by each of the furnace by : 4.0 pounds of NOx per ton of glass pu ll ed for container glass furnaces; 7.0 pounds of NOx per ton of glass pulled for pressed or blown glass furnaces; 4.0 pounds of NOx per ton of glass pulled for fiberglass furnaces; 7.0 pounds of NOx per ton of glass pulled for flat glass furnaces ; and 6.0 pounds of NOx per ton of glass pulled for all other glass melting furnaces. Furthermore, the owner or operat or of a glass melting furnace sha ll comply with the allowable NOx emissions by

January 1, 2012, unless a petition for an alternative emission limit ation or compliance schedule is submitted, in writing, to PADEP or the local air pollution control agency by January 1, 2012 and also approved in writing by PADEP or the local air pollution control agency .4

The SI P revision also provides a petition process for an alternative NOx emission limitation to the owner or operator of a glass melting furnace that demonstrates to PADEP’s satisfaction that it is economically

or technologically

infeasible to meet the established emission limitations in this SI P revisio n. An alternative NOx emission limitation approved by PADEP must be included in either a plan approval or an operating permit issued by PADEP or a permit issued by the loca l air pollution control agency
. Inaddition, the SI P revision includes a petition process for an alternative compliance schedule if an owner or operator of a glass melting furnace demonstrates that compliance cannot be achieved by the January

1, 2012 compliance date. Section 129.305, relating to start
- up requirements, requires the owne r or oper ator of a gl ass melting furnace to submit specific information requested by PADEP or the local air pollution control agencies information to assure proper operation of the furnace. The owner or operator of a glass melting furnace may submit a req

uest for a start
- up exemption in conjunction with the approval application, if required. The length of the start
- up exemption should not exceed a finite number of day s depending on the ty pe of the furnace. PADEP or the local air pollution control agency sha ll approve start
- up exemptions to the extent that the request identifies the control technologies or strategies to be used. Additi onally , the owner or operator sha ll place the emission control sy stem in operation as soon as technologically feasible dur ing start
- up to minimize emissions. Section 129.306, relating to shutdown requirements, provides that the duration of glass melting furnace shutdown, as measured from the time the furnace operations drops below 25% of the permitted production capacity or fuel use capacity , to when all emissions f r o m the furnace cease, should not exceed 20 day s. The owner or operat or of a glass melting furnace sha ll operate the emission control sy stem whenever technically feasibl e, as approved by

PADEP or the local air pol lution control agency , during shutdown to minimize emissions. Section129.307, relating to idling requirements, provides that the owner or operat or of a glass melting furnace sha ll operate the emission control sy stem whenever technically feasibl e, as appro ved by

PADEP or the local air pollution control agency , during idling to minimize emissions. The NOx emissions during idling may not exceed the amount calculated using the following equation: Pounds per day

emission limit of NOx = (applicable NOx emissio n limit specified in the emission requirements, expressed in pounds per ton of glass produced) x (furnace permitted production capacity

in tons of glass produced per day ). Section 129.308, relating to compliance determination, requires that the owner or o perator of a glass melting furnace sha ll install, operate and maintain continuous emissions monitoring sy stem (CEMS) for NOx and other monitoring sy stems to convert data to required reporting units in compliance with 25 Pa. Code Chapter 139, Subchapter C ( relating to requirements for source monitoring for stationary sources) and calculate actual emissions using the CEMS data reported5

to PADEP or the local air pollution control agency , no later than14 day s prior to the compliance date
. However, the owner or operator of a glass melting furnace may elect to install and operate an alternate NOx emissions monitoring sy stem or me thod approved , in writing, by PADEP or the local air pollution control agency
. Data invalidated under Chapter 139, Subchapter C will be substituted with other values if approved by PADEP or the local air pollution control agency
. Section 129.309, relating to compliance demonstration, provides that the owner or operat or of a glass melting furnace sha ll calculate and report to PADEP or the local air pollution control agencies on a quarterly

basis, no later than 30 day s after the end of the quarter, the CEMS data and glass production data used to show compliance with the allowable NOx emission limitations
. The glass production data must c on sist of the quantity of glass in tons pulled per day for each furnace. Compliance can be demonstrated on a furnace
- by
- furnace basis; facility
- wide emission averaging basis ; or a sy stem - wide emissions averaging basis among glass melting furnaces under comm on control of the same owner or operator in the Commonwealth. The owner or operator of a glas s melting furnace for which PADEP or the local air pollution control agency has granted approval to voluntarily

opt into a market
- based program may not demonstrat e compliance on an emissions averaging basis. Moreover, an emission reduction obtained by emissions averaging to demonstrate compliance with the emission requirements in this SI P revision will not be considered surplus for emission re duction credit purpos es. Section 129.310, relating to recordkeeping, provides that the owner or operat or of a glass melting furnace sha ll maintain records to demonstrate compliance. The records must include an operating log maintained for each glass melting furnace that incl udes, on a daily basis the following : the total hours of operation; the ty pe and quantity

of fuel used; and the quantity of glass pulled. Inaddition, the owner or operator of a glass melting furnace sha ll maintain records of the following : source tests and operating parameters established during the initial source test; and maintenance, repairs, malfunctions, idling, start
- up and shutdown. The records will be maintained onsite for 5 years and sha ll be made available o r submitted to PADEP or the local a ir pollution control agency

upon request.
C . EPA EVALUATION This regulation will reduce emissions of NOx from glass melting furnaces to reduce levels of ground
- level ozone and fine particulate matter (PM 2.5 )
. Ground
- level ozone is not directly emitted by

pollution sources, but is created as a result of a chemical reaction of NOx and volatile organic compounds (VOC) in the presence of light and heat. The reduction of NOx emissions will also help protect the public health and environment from high lev el s of PM 2.5 , of which NOx is a precursor component. The reduction of NOx emissions also reduces visibility impairment and acid deposition.6

D . CONCLUSION S AND RECOMMENDED AGENCY ACTION The regulation on the control of NOx emissions from glass melting furnaces adopted by the Commonwealth of Pennsylvania will result in the reduction of NOx emi ssions from glass melting furnaces and w ill help the Commonwealth in attaining compliance with the 8
- hour ozone and PM 2.5 national ambient air quality standards (N AAQS ) . EPA approval of the SI P revision is recommen de d
.