1

Law, Nicole

From: Sheraz Gill <Sheraz.Gill@valleyair.org>

Sent: Wednesday, April 27, 2016 2:28 PM

To: Steckel, Andrew

Cc: Law, Nicole

Subject: RE: Additional SJV info

Attachments: AO engine Retrofit analysis email from Sheraz Gill.pdf

Hello Andy, 

The District provided EPA with a comprehensive evaluation on June 25, 2015 (attached) 

demonstrating that there were major technological feasibility issues in retrofitting existing ag engines 

which is why there is no cost-effective analysis performed for those engines. For the Rich-burn 

replacement category, there is essentially only one control technology (3-way catalysts) to lower 

emissions and that technology would bring emissions directly down to 25ppmv, therefore, the cost 

effectiveness would be the same for both 25ppmv and 65ppmv. For the Lean-burn replacement 

engine category, there is essentially only one control technology (SCR) to lower emissions from 

engines below 65ppmv and that technology would bring emissions directly down to 11ppmv, 

therefore, the cost effectiveness would be the same for both 11ppmv and 25ppmv. Per our 

discussion, I am also including, below, the emissions inventory which breaks down the emissions 

specifically from diesel and natural gas ag engines. 

Emissions Inventory - Ag Engines (tonsNOx/day) 2012 2013 2014 2015 2016 2017 2018 

Diesel 10.40 10.20 9.94 6.85 4.88 4.50 4.26 

Natural Gas 0.39 0.39 0.38 0.38 0.38 0.38 0.37 

In regards to your questions regarding boilers > 75MMBtu/hr subject to the limits for Category B.a 

(Standard Schedule, 7 ppmv), Table 1 of Rule 4320. There are 66 boilers subject to that limit. 2 

boilers are paying a fee instead of the limit. All of these boilers are operated on natural gas fuel and 

using low-NOx or ultra-low NOx burners. Many of these boilers also have SCR. 

In regards to glass plants, District Rule 4354 is far more stringent than SCAQMD Rule 1117. District 

Rule 4354 requires a NOx limit of 1.5 lbs per ton of glass produced for container glass plants, while 

SCAQMD Rule 1117 requires a NOx limit of 4.0 lbs per ton of glass produced. Even though the 

District limit is at 1.5 lbs per ton of glass produced, the majority of glass plants in the Valley produce 

emissions much lower than the Rule limit. Furthermore, the achievable NOx emissions level for glass 

furnaces is affected by factors other than the emission control device used. These other factors 

include the stability of the glass pull rate over an extended period of time, and the condition and age 

of the refractories and furnace insulation. When the operator adjusts the pull rate of the furnace in 

response to the market need, additional NOx emissions may occur during the transition time while the 

low-NOx oxy-fuel burners adjust to accommodate the new pull rate. In addition, to maintain high 

temperature levels, glass furnaces require high levels of heat input which is independent from the 

level of glass pulled each day but is specific to each glass furnace. In addition to this “baseline” heat 

input, additional energy is necessary to melt glass. This variable heat input required to melt glass 

fluctuates according to the quantity of glass pulled and is added to the “baseline” heat input. As a 

result, the total heat input necessary to melt a ton of glass varies according to the overall quantity of 
2

glass melted in conjunction with the intersect characteristics of the glass furnace. Consequently, the 

lb-NOx/ton varies in similar ways and is impacted by the glass pull rate. 

The container glass furnaces within the San Joaquin Valley manufacture a large variety of sizes and 

shapes of still and sparkling wine glass bottles, requiring the operators to utilize their furnaces in a 

fashion that results in a less stable pull rate in far greater conditions than facilities located in the 

South Coast which are mainly producing beer bottles . Due to the less stable pull rate, additional 

NOx emissions are expected during the change in the fire rate of the burners as explained 

above. Additionally, in response to business demands on the wine industry, SJV facilities must 

operate furnaces with a high degree of flexibility and variable operational conditions causing constant 

changes in the furnace pull rate and variations in NOx emissions. 

Finally, as furnaces age, the refractory is not as effective at retaining heat in the furnace. Therefore, 

under such conditions, the burner fire rate must be increased over time to maintain the same overall 

furnace and glass temperature and NOx on a lb/ton basis is expected to increase accordingly. The 

combination of these factors result in a situation where the NOx emission rate varies significantly over 

production conditions, campaign, and furnace life. Therefore, a simple comparison cannot be made 

between glass plants and their associated emissions limits and a thorough evaluation assessing all 

the multiple factors must be taken into consideration. 

Please call me if you have any questions. Thanks 

Sheraz Gill 

Director of Strategies and Incentives

San Joaquin Valley APCD

Phone: (559) 230-5908

Fax: (559) 230-6061

sheraz.gill@valleyair.org

From: Steckel, Andrew [mailto:Steckel.Andrew@epa.gov] 

Sent: Thursday, April 14, 2016 11:33 AM 

To: Sheraz Gill 

Cc: Law, Nicole; Perez, Idalia; Drake, Kerry; Samir Sheikh 

Subject: Additional SJV info 

Sheraz, 

Thanks for your voicemail and for working on our request regarding boilers. 

Regarding engines, I think your voicemail was referring to pages 132-139 in Appendix C and to your supplemental engine 

analysis, both attached. We believe these provide cost effectiveness analysis for retrofitting/replacing ag engines as 
3

summarized in the table below from our TSD associated with our recent approval of SJV Rule 4702. We’re asking for 

additional information for items in the table listed as “no analysis.” 

Table B: Cost Effectiveness ($/ton NOx reduced) for Spark Ignited AO Engines[1]

Emission limits Rich-Burn Lean-Burn 

Retrofit Replacement Retrofit Replacement 

11 ppmv No analysis 59,754 55,118 76,209 

25 ppmv No analysis 69,521 No analysis No analysis 

65 ppmv No analysis No analysis No analysis 42,146 

I also mentioned on voicemail that we’re hoping to get additional information regarding glass plants. Specifically, 

EarthJustice’s comment on our proposed approval of SJV’s PM2.5 plan asserts that EPA has not adequately explained 

why lower NOx emissions from South Coast’s container glass facility are not feasible for SJV container facilities. South 

Coast shared CEMs data indicating that their Owens-Brockway container glass facility consistently emits below 0.72 lb 

NOx/ton of glass pulled using oxyfuel to control NOx. For all the container glass furnaces in the SJV, can you explain why 

similar limits are not technically and economically available? Additionally, can you tell us what NOx control technologies 

these facilities currently use? 

Again, I’m sorry about the short turn-around, but we need this information by April 22. 

 

Thanks, Andy 

[1] Appendix C: BACM and MSM for Stationary and Area Sources 2015 Plan for the 1997 PM2.5 Standard Section C.17, 

SJVUAPCD, April 16, 2015.