San Joaquin Valley Unified Air Pollution Control District April 16, 2009

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Rule 4354 – Glass Melting Furnaces 

Emissions Inventory:

Tons per day  summer season 

Pollutant 2005 2008 2011 2012 2014 2017 2020 2023 

NOx 9.38 8.02 8.56 8.73 9.08 9.64 10.12 10.65 

VOC 0.337 0.39 0.415 0.423 0.440 0.469 0.49 0.515 

(Source: District 2007 Ozone Plan) 

District Rule 4354 Description

This rule controls NOx, SOx, VOC, and CO emissions from any glass-melting furnace 

located at facilities that have the total potential to emit of at least ten tons per year of 

NOx or at least ten tons per year of VOC. The emission limits depend on type of glass 

produced, furnace firing technology and emission averaging period. NOx emission 

limits range from 4.0 to 9.2 pounds NOx per ton of glass pulled (lb/ton glass); CO limits 

are 300 ppmv or 0.9 to 1.0 lbs/ton glass; and VOC emission limits are 20 ppmv or range 

from 0.1 to 0.25 lbs/ton glass. 

Operators of multiple furnaces have the option to average emissions across the 

furnaces in order to comply with the emission limits. Operators who select this option 

are required to meet emission limits that are 10% lower than if they had controlled each 

furnace individually. 

Operators meet current emission limits through a selection of furnace firing technology 

and glass raw materials. There are a range of NOx control strategies to achieve the 

current emission limits. These strategies go beyond low-NOx or ultra-low-NOx burners 

and electric boost to advanced controls like oxygen-enriched air staging (OEAS), 

replacement of combustion air with pure oxygen (oxy-fuel firing), and fuel re-burn 

technology (the proprietary 3-R process). One source is in the process of converting to 

selective catalytic reduction (SCR) for NOx control. This SCR system will be the first in 

the US on a glass furnace. 

How does District Rule 4354 compare with federal rules and regulations?

A. EPA – Control Technique Guidelines (CTG) 

There is no CTG for this source category. 

B. EPA – Alternative Control Technology (ACT) 

EPA-453/R-94-037 Alternative Control Techniques Document – NOx Emissions from 

Glass Manufacturing 
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This document outlines the available control techniques for three types of glass melting 

furnaces  container glass, flat glass and pressed-and-blown glass. The document lists 

no specific NOx emission limit, although it does suggest estimated percent NOx 

reduction from uncontrolled levels. In not having a specific NOx limit for any of the 

subject furnaces, the document does not define RACT for the three types of glass. 

There is no ACT for glass melting furnaces at either wool fiberglass or strand fiberglass 

manufacturing facilities. 

C. Standards of Performance for New Stationary Sources (NSPS)

40 CFR 60 Subpart CC – Standards of Performance for Glass Manufacturing Plants; 

and 40 CFR Subpart PPP – Standards of Performance for Wool Fiberglass 

Insulation Plants 

These NSPSs target the control of particulate matter from the specified glass 

manufacturing processes. As such, neither NSPS defines applicable RACT for these 

sources. There is no NSPS for fiberglass strand furnaces. 

D. National Emission Standards for Hazardous Air Pollutants (NESHAPs) and 

Maximum Achievable Control Technologies (MACTs) 

There is one NESHAP that could apply to glass melting furnaces  40 CFR 61 Subpart 

N (National Emission Standard for Inorganic Arsenic Emissions from Glass 

Manufacturing Plants). An arsenic-containing compound could be used in the glass 

recipe to improve glass quality, although no glass manufacturer subject to the District 

rule uses the arsenic compound in their operations. The NESHAP specifically targets 

inorganic arsenic emissions, and therefore, does not apply to NOx or VOC emission 

limits. The NESHAP does not define applicable RACT for this source category. 

There are two MACT standards that apply to glass melting furnaces  40 CFR 63 

Subpart NNN (National Emission Standards for Hazardous Air Pollutants for Wool 

Fiberglass Manufacturing Plants) and 40 CFR 63 Subpart SSSSSS (National Emission 

Standards for Hazardous Air Pollutants for Glass Manufacturing Area Sources). The 

portions of both MACTs that apply to the glass melting furnaces are particulate emission 

limits and subsequent recordkeeping. As such, they do not regulate NOx or VOC for 

this source category; therefore the MACT standard does not define applicable RACT for 

this source category. 

How does District Rule 4354 compare to rules in other air districts?

District staff compared NOx limits, optional control requirements, and work practice 

standards in District Rule 4354 to comparable requirements in rules from the following 

California nonattainment areas: 
San Joaquin Valley Unified Air Pollution Control District April 16, 2009

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South Coast AQMD Rule 1117, as amended January 1984 

Bay Area AQMD Regulation 9 Rule 12, as adopted January 1994 

Ventura County APCD and Sacramento Metro AQMD do not have a specific 

prohibitory rule for this source category. 

A. South Coast AQMD Rule 1117 (Emissions of Oxides of Nitrogen from Glass 

Melting Furnaces) 

South Coast AQMD Rule 1117 has a single NOx limit of 4.0 pounds per ton glass 

pulled, however the limit does not apply to tableware glass, flat glass, or fiberglass 

furnaces  these are specifically exempt under Rule 1117. This means that Rule 1117 

applies only to container glass furnaces. Alternative emission control plans are allowed 

which let emissions to be averaged over more than one furnace as long as the total 

emissions are no greater than if each furnace was individually meeting the emission 

limit. Recent amendments to District Rule 4354 have reduced NOx limits for container 

glass which are lower than South Coast Rule 1117. The District rule also goes beyond 

the South Coast AQMD rule to limit NOx emissions from flat glass and fiberglass 

furnaces. Additionally, the alternative emission control plan in District Rule 4354 

requires a 10% reduction in total emissions for the averaged group of furnaces over 

controlling the furnaces individually. 

B. Bay Area AQMD Regulation 9 Rule 12 (Nitrogen Oxide Emissions from Glass 

Melting Furnaces) 

Bay Area AQMD Regulation 9 Rule 12 has a single NOx emission limit of 5.5 pounds 

NOx per ton glass pulled, which is lower than current District Rule 4354 NOx emission 

limits for flat glass. However, there are no flat glass furnaces within Bay Area AQMD, 

meaning the emission limit has not been achieved in practice in the Bay Area AQMD for 

flat glass furnaces. On April 3, 2009, Mr. Weyman Lee of BAAQMD has verified that 

there are no flat glass furnaces within the BAAQMD. With the most recent amendments 

to District Rule 4354, the NOx emission limit for every category of glass is more 

stringent than the NOx limit in Bay Area AQMD Regulation 9 Rule 12. 

Are additional cost-effective controls available?

As noted above, the current furnaces are already utilizing advanced control 

technologies for NOx. Table 2 below details the NOx control technologies being used 

within the District. All 14 glass melting furnaces in the District are using low-NOx or 

ultralow NOx burners in conjunction with the advanced NOx controls. The estimated 

emission reductions are taken from EPAs ACT fro glass furnaces. Cost effectiveness 

was taken from the recent rule amendment project where only SCR and oxy-fuel firing 

were considered sufficient to meet the new NOx limits. While SCR is new to US glass 

furnaces, it has been in use in Europe for several years. 
San Joaquin Valley Unified Air Pollution Control District April 16, 2009

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Table 2  NOx Control Strategies, Cost Effectiveness, and Actual Technology Utilization 

NOx Control 

Technology 

Estimated Emission 

Reduction over 

Uncontrolled 

Furnaces 

Estimated Cost 

Effectiveness 

($/ton reduced) 

Number District 

Furnaces Currently 

Using This 

Technology 

Low-NOx or Ultra-low 

NOx burners 

30% to 40% --- 14 

Electric Boost 10% to 30% --- 

Unable to tell from 

individual permits 

Oxygen Enriched Air 

Staging (OEAS) 30% to 75% --- 3 

Oxygen Fuel (oxyfuel) Firing 

75% to 85% $51,700 6 

Fuel Re-burn (3-R) 50% to 65% --- 1 

Selective Catalytic 

Reduction (SCR) 75% to 90% $2,180 $10,800 1 

Were relevant public comments received recently about Rule 4354?

Relevant public comments received during the public process for adopting the Districts 

2008 Ozone Plan have been addressed in Appendix L of the plan. 

Conclusion

After careful evaluation of federal rules and regulations as well as prohibitory rules in 

other California nonattainment areas, District staff concludes that District Rule 4354 

satisfies RACT for glass melting furnaces.