# Mojave Desert Air Quality Management District

Final 

# Staff Report Proposed Amendment of Rule 1165 – Glass Melting Furnaces

Amended on August 25, 2008

14306 P ARK 

### A VE 

### , V ICTORVILLE 

### , CA 92392-2310 P HONE 

### : (760) 245-1661

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### : (760) 245-2699This page intentionally left blank.MDAQMD Rule 1165 TC-1 Final Staff Report, 11/03/2008 

### FINAL STAFF REPORT TABLE OF CONTENTS Rule 1165 – Glass Melting Furnaces

I. PURPOSE OF STAFF REPORT ............................................................................................ 1 II. EXECUTIVE SUMMARY..................................................................................................... 1 III. STAFF RECOMMENDATION ............................................................................................. 1 IV. LEGAL REQUIREMENTS CHECKLIST ............................................................................ 2 V. DISCUSSION OF LEGAL REQUIREMENTS..................................................................... 3 A. REQUIRED ELEMENTS/FINDINGS............................................................................... 3 1. State Findings Required for A doption of Rules & Regulations ..................................... 3 a. Necessity................................................................................................................... .. 3 b. Authority................................................................................................................... .. 3 c. Clarity ..................................................................................................................... .... 3 d. Consistency................................................................................................................. 3 e. Non-duplication .......................................................................................................... 3 f. Reference ................................................................................................................... . 4 g. Public Notice & Comment, Public Hearing................................................................ 4 2. Federal Elements (SIP Submittals, Other Federal Submittals)....................................... 4 a. Satisfaction of Underlyi ng Federal Requirements...................................................... 4 b. Public Notice and Comment ....................................................................................... 5 c. Availability of Document ........................................................................................... 5 d. Notice to Specified Entities ........................................................................................ 5 e. Public Hearing ............................................................................................................ 5 f. Legal Authority to Adopt and Implement................................................................... 5 g. Applicable State Laws and Regulations Were Followed............................................ 5 B. WRITTEN ANALYSIS OF EXISTING REQUIREMENTS ............................................ 5 C. ECONOMIC ANALYSIS .................................................................................................. 6 1. General..................................................................................................................... ....... 6 2. Incremental Cost Effectiveness....................................................................................... 6 D. ENVIRONMENTAL ANALYSIS (CEQA)....................................................................... 6 E. SUPPLEMENTAL ENVIRONMENTAL ANALYSIS..................................................... 7 1. Potential Environmental Impacts.................................................................................... 7 2. Mitigation of Impacts...................................................................................................... 7 3. Alternative Methods of Compliance............................................................................... 7 F. PUBLIC REVIEW.............................................................................................................. 7 VI. TECHNICAL DISCUSSION ................................................................................................ 7 A. SOURCE DESCRIPTION.................................................................................................. 7 B. EMISSIONS ................................................................................................................... .... 7 C. CONTROL REQUIREMENTS.......................................................................................... 7 D. PROPOSED RULE SUMMARY....................................................................................... 8 E. SIP HISTORY ................................................................................................................. ... 9 1. SIP History................................................................................................................ ..... 9 a. SIP in the San Bernardino County Portion of MDAQMD ......................................... 9 b. SIP in the Riverside County Portion of the MDAQMD............................................. 9TC-2 MDAQMD Rule 1165 Final Staff Report, 11/03/2008 2. SIP Analysis................................................................................................................ .. 10 Appendix A - Iterated Version.................................................................................................. .. A-1 Appendix B - Public Notice Documents..................................................................................... B-1 Appendix C - Public Comments and Responses......................................................................... C-1 Appendix D - California Environmenta l Quality Act Documentation ....................................... D-1 Appendix E - Bibliography...................................................................................................... ....E-1MDAQMD Rule 1165 1 Final Staff Report, 11/03/2008 

### FINAL STAFF REPORT Rule 1165 – Glass Melting Furnaces

I. PURPOSE OF STAFF REPORT

A staff report serves several disc rete purposes. Its primary purpos e is to provide a summary and background material to the members of the Govern ing Board. This allows the members of the Governing Board to be fully informed before ma king any required decision. It also provides the documentation necessary for the Governing Boar d to make any findings, which are required by law to be made prior to the approval or adopt ion of a document. In addition, a staff report ensures that the correct pro cedures and proper documentation for approval or adoption of a document have been performed. Finally, the sta ff report provides evidence for defense against legal challenges regarding th e propriety of the approval or adoption of the document.

II. EXECUTIVE SUMMARY

The Mojave Desert Air Quality Management District (MDAQMD) has the authority pursuant to California Health and Safety Code (H & S C ode) §40702 to adopt, amend or repeal rules and regulations.

The MDAQMD originally adopted Rule 1165 – Glass Melting Furnaces on August 27, 2007 to satisfy a commitment made in the 8-Hour Reasonably Available Control Technology State Implementation Plan Analysis ( RACT SIP Analysis ) and as required by the Federal Clean Air Act (FCAA). The MDAQMD amended Rule 1165 – Glass Melting Furnaces on January 20, 2008 to include changes in response to substantive verbal comments from USEPA that were not included in the original rule adoption. The MDAQMD ha s received further (non-substantive) comments from both CARB and USEPA that are being addre ssed in this subsequent rule amendment.

III. STAFF RECOMMENDATION

Staff recommends that the Governing Board of the Mojave Desert Air Quality Management District (District) adopt the pr oposed amendments to Rule 1165 – Glass Melting Furnaces and approve the appropriate CEQA documentation. Th is action is necessary to address CARB and USEPA comments, and to co rrect a rule citation.

The Governing Board of the Mojave Desert Ai r Quality Management District adopted the amendments to Rule 1165 – Glass Melting Furnaces on August 25, 2008.2 MDAQMD Rule 1165 Final Staff Report, 11/03/2008 IV. LEGAL REQUIREMENTS CHECKLIST

The findings and analysis as indicated below ar e required for the proce durally correct proposed amendment of Rule 1165 – Glass Melting Furnaces . Each item is discussed, if applicable, in Section V. Copies of related documents ar e included in the appropriate appendices.

FINDINGS REQUIRED FOR RULES & REGULATIONS:

X Necessity

X Authority

X Clarity

X Consistency

X Non-duplication

X Reference

X Public Notice & Comment

X Public Hearing

REQUIREMENTS FOR STATE IMPLEMENTATION PLAN SUBMISSION (SIP):

X Public Notice & Comment

X Availability of Document

X Notice to Specified Entities (State, Air Districts, USEPA, Other States)

X Public Hearing

X Legal Authority to adopt and implement the document.

X Applicable State laws and regulations were followed. ELEMENTS OF A FEDERAL SUBMISSION:

X Elements as set forth in applicable federal law or regulations.

CALIFORNIA ENVIRONMENTAL QUALITY ACT REQUIREMENTS (CEQA):

N/A Ministerial Action

X Exemption

N/A Negative Declaration

N/A Environmental Impact Report

X Appropriate findings, if necessary.

X Public Notice & Comment

SUPPLEMENTAL ENVIRONMENTAL ANALYSIS (RULES & REGULATIONS ONLY):

X Environmental impacts of compliance.

N/A Mitigation of impacts.

N/A Alternative methods of compliance.

OTHER:

X Written analysis of existing air pollution control requirements

X Economic Analysis

X Public ReviewMDAQMD Rule 1165 3 Final Staff Report, 11/03/2008 V. DISCUSSION OF LEGAL REQUIREMENTS

A. REQUIRED ELEMENTS/FINDINGS

This section discusses the Stat e of California statutory requ irements that apply to the amendments to Rule 1165. These are actio ns that need to be performed and/or information that must be provided in order to amend the rule in a procedurally correct

manner.
1. State Findings Required for A doption of Rules & Regulations

Before adopting, amending, or repealing a rule or regula tion, the District Governing Board is required to make findings of necessity, authority, clarity, consistency, non-duplication, and refere nce based upon relevant information presented at the hearing. The information be low is provided to assist the Board in making these findings.

a. Necessity

The amendments to Rule 1165 are necessary to address (nonsubstantive) comments from both CARB and USEPA, and to correct a rule citation.

b. Authority

The District has the authority purs uant to California Health and Safety Code (H & S Code) §40702 to adopt, amend or repeal rules and regulations.

c. Clarity

The amendments to Rule 1165 are clear in that the rule is written so that the persons subject to the rule can easily understand the meaning.

d. Consistency

The amendments to Rule 1165 are in harmony with, and not in conflict with or contradictory to any state law or regulation, federal law or regulation, or court decisions.

e. Non-duplication

The amendments to Rule 1165 do not impose the same requirements as any existing stat e or federal law or regulation because the amendments are admini strative in nature in that two unused references to “furnace battery” are removed, several4 MDAQMD Rule 1165 Final Staff Report, 11/03/2008 sections are clarified in respons e to USEPA comments, and a rule citation is corrected.

f. Reference

The District has the authority pur suant to H & S Co de §40702 to adopt, amend or repeal rules and regulations.

g. Public Notice & Comment, Public Hearing

Notice for the public hearing for the proposed amendments to Rule 1165 was published 07/25/08. See Appendix “B” for a copy of the public notice. See Appendix “C” for copies of commen ts, if any, and District responses.

2. Federal Elements (SIP Submittals, Other Federal Submittals)

Submittals to the USEPA are required to include various elements depending upon the type of document submitted and the underlying federal law that requires the submittal. The information below indicates which elements are required for the amendments to Rule 1165 and how they were satisfied.

a. Satisfaction of Underlyi ng Federal Requirements

The amendments to Rule 1165 are s ubject to all the requirements for a SIP submittal because Rule 1165 will be included in the MDAQMD SIP. The FCAA re quires areas designated nonattainment and classified modera te and above to implement RACT for sources subject to CTG documents issued by USEPA for “major sources” of VOCs and NO X that are ozone precursors. Because the District has a “maj or source” in this category, the District committed to adopting a RACT rule for glass melting furnaces as part of the recently adopted RACT SIP Analysis

. USEPA proposed approval of Sa n Joaquin Valley Air Pollution Control District (SJVAPCD) Rule 4354 – Glass Melting Furnaces

as a RACT rule on 04/24/02 (67 FR 20078) and approved this rule on 12/06/02 (67 FR 72573). SJVAPCD Rule 4354 was used as the basis for Rule 1165 – Glass Melting Furnaces . The MDAQMD is now proposing to amend Rule 1165 – Glass Melting Furnaces to include changes in response to (non-substantive) comments from both CARB and USEPA. The proposed amendments will remove two unused references to “furnace battery,” clarify several sections, and correct a rule citati on. This most recent amendment is expected to be the version submitted for inclusion in the SIP.MDAQMD Rule 1165 5 Final Staff Report, 11/03/2008 b. Public Notice and Comment

Notice for the public hearing for the proposed adoption of Rule 1165 was published 07/25/08. See Appendix “B” for a copy of the public notice. See Appendix “C” fo r copies of comments, if any, and District responses.

c. Availability of Document

Copies of the proposed amendments to Rule 1165 and the accompanying draft staff report were made available to the public on 07/15/08.

d. Notice to Specified Entities

Copies of the proposed adoption of Rule 1165 and the accompanying draft staff report were se nt to all affected agencies. The proposed rule was sent to CARB and USEPA on 07/15/08.

e. Public Hearing

A public hearing to consider the proposed amendments to Rule 1165 was set for 08/25/08.

f. Legal Authority to Adopt and Implement

The District has the authority pursuant to H&S Code §40702 to adopt, amend, or repeal rules and re gulations and to do such acts as may be necessary or proper to execute the duties imposed upon the District.

g. Applicable State Laws and Regulations were Followed

Public notice and hearing pro cedures pursuant to H&S Code §§40725 - 40728 have been followe d. See Section (V)(A)(1) above for compliance with state findings required pursuant to H&S Code §40727. See Section (V)(B) below for compliance with the required analysis of existing requ irements pursuant to H&S Code §40727.2. See Section (V)(C) for compliance with economic analysis requirements pursuant to H&S Code §40920.6. See Section (V)(D) below for complia nce with provisions of the California Environmental Quality Act (CEQA).

B. WRITTEN ANALYSIS OF EXISTING REQUIREMENTS

H & S Code §40727.2 requires air districts to pr epare a written analysis of all existing federal air pollution control requirements that apply to the same equipment or source type as the rule proposed for modi fication by the District.6 MDAQMD Rule 1165 Final Staff Report, 11/03/2008 The FCAA requires areas designated non-attainme nt for ozone and classified moderate and above to adopt and maintain RACT rule s to control the emissions of VOCs and NO X for categories which the USEPA has adopted a Control Technology Guideline (CTG) or Alternative Control Technology (ACT) and for all categories where there are major stationary sources of air pollution (42 U.S.C. §7511a(b)(2), FCAA 182(b)(2)). For purposes of the FCAA, portions of the Distri ct have been designated non-attainment for ozone and classified severe-17.

The MDAQMD adopted a RACT rule on 08/27/07 for glass melting furnaces as part of the recently adopted RACT SIP Analysis to provide a backstop rule for this source. This rule was amended 01/28/08 to include cha nges in response to substantive verbal comments from USEPA that were not include d in the original rule adoption. The MDAQMD proposed to amend Rule 1165 – Glass Melting Furnaces to include changes in response to CARB Review Comments to re move two unused references to “furnace battery”. The amendment will al so clarify several sections in response to non-substantive USEPA comments, and co rrect a rule citation.

C. ECONOMIC ANALYSIS

1. General

No economic impacts are anticipated from the adoption of the amendments to Rule 1165. The amendments are admini strative in nature and address CARB Review Comments to remove two unused refe rences to “furnace battery,” clarify several sections in response to non-substantive USEPA comments, and correct a rule citation.

2. Incremental Cost Effectiveness

Pursuant to H&S Code §40920.6, incremental cost effectiveness calculations are required for rules and regulations which are adopted or amended to meet the California Clean Air Act requirements for Best Available Retrofit Control Technology (BARCT) or “all f easible measures” to c ontrol volatile compounds, oxides of nitrogen or oxides of sulfur. The amendments to Rule 1165 are not subject to incremental cost effectivene ss calculations because they do not involve BARCT or “all feasible measures”.

D. ENVIRONMENTAL ANALYSIS (CEQA)

Through the process described below the appr opriate CEQA process for the amendments to Rule 1165 was determined.

1. The amendments to Rule 1165 meet the CEQA definition of “project”. They are not “ministerial” actions.

2. The amendments to Rule 1165 are exempt from CEQA review because they will not create any adverse impacts on the environment. Because there is not potential that the amendments might cause the release of additional airMDAQMD Rule 1165 7 Final Staff Report, 11/03/2008 contaminants or create any adverse envi ronmental impacts, a Class 8 categorical exemption (14 Cal. Code Reg. §15308) applie s. Copies of the documents relating to CEQA can be found in Appendix “D”.

E. SUPPLEMENTAL ENVIRONMENTAL ANALYSIS

1. Potential Environmental Impacts

There are no potential adverse environm ental impacts of compliance with the amendments to Rule 1165. The amendments are administrative in nature in that they remove two unused references to “f urnace battery,” clarify several sections in response to non-substantive USEPA co mments, and correct a rule citation.

2. Mitigation of Impacts

N/A

3. Alternative Methods of Compliance

N/A

F. PUBLIC REVIEW

See Staff Report Section (V)(A)(1)(g) and (V )(A)(2)(b), as well as Appendix “B”

VI. TECHNICAL DISCUSSION

A. SOURCE DESCRIPTION

The amendments are administrative in natu re in that they to remove two unused references to “furnace battery,” clarify seve ral sections in response to non-substantive USEPA comments, and co rrect a rule citation.

B. EMISSIONS

The amendments to Rule 1165 – Glass Melting Furnaces do not cause the release of additional air contaminants or create any e nvironmental impacts because they remove to remove two unused references to “furnace batter y,” clarify several sect ions in response to non-substantive USEPA comments, and correct a rule citation.

C. CONTROL REQUIREMENTS

Please see section (C) of the rule (A ppendix A) for control requirements.

The amendments to Rule 1165 – Glass Melting Furnaces do not cause the release of additional air contaminants or create a ny environmental impacts because two unused references to “furnace battery” are removed, se veral sections are clar ified in response to USEPA comments, and a rule citation is corrected.8 MDAQMD Rule 1165 Final Staff Report, 11/03/2008 D. PROPOSED RULE SUMMARY

This section gives a brief overview of th e amendments to Rule 1165. Readers are encouraged to examine the [bracketed and italicized] notations contained in the iterated version of the rule contained in Appendi x A for notations regarding movement and modification of specific s ections and subsections.

1. Subsection (C)(4)(a) rule citation (B)(11) has been corrected to (B)(10).

2. Reference to “furnace battery” in subsection (C)(7) has been removed.

3. Reference to “furnace battery” in su bsection (D)(5)(a) has been removed.

4. Section (C)(5)(b) has been clarified by removi ng the phrase “pounds per day.”

5. Section (D)(1)(a) has been clarifie d to require that the maximum daily glass production limit and maximum heat input limits are specified in each furnace’s permit to operate.

6. Typographical error corrected in sect ion (E)(1)(f)(ii) from “expressed and SO 2 ” to “expressed as SO 2 .”

7. Reference to Rule 218 in section (E)(2)(vi) has been removed as Rule 218 is not a SIP rule and rule refe rence is not necessary in rule.

8. Typographical error corrected in se ction (E)(3)(c) of “(A)(3)(c)” to “(A)(3)(d).”

9. Section (E)(4)(b)(i) has been cl arified by removing the phrase “after exemption is lost.”

10. Section (E)(5)(a) has been generalized for all polluta nts, rather than just NO X .MDAQMD Rule 1165 9 Final Staff Report, 11/03/2008 E. SIP HISTORY

1. SIP History

a. SIP in the San Bernardino County Portion of MDAQMD

The 08/27/07 version of Rule 1165 – Glass Melting Furnaces and the 01/28/08 amendment have been submitted as a SIP revisions, but due to the closen ess of the submission of these amendments, the District expects the current amendment will supersede the previous submission.

b. SIP in the Riverside County (Blythe/Palo Verde Valley) Portion of the MDAQMD

One of the provisions of the le gislations that created the MDAQMD allowed areas contiguous to the MDAQMD boundaries and within the same air basin to leave their current air district and become a part of the MDAQMD. On 07/01/94 the area commonly known as the Palo Verde Valley in Riverside County, including the City of Blythe , left SCAQMD and joined the MDAQMD. Since USEPA adopts SI P revisions in California as effective within the jurisdictional boundaries of local air districts, when the local boundaries change the SIP as approved by USEPA for that area up to the date of the change remains as the SIP in that particular area. Upon annexation of the Blythe/Palo Verde Valley the MDAQMD acquired the SIP prior to 07/01/94 that was effective in the Blythe/Palo Verde Valley. Therefore, the SIP history for the Blythe/Palo Verd e Valley portion of the MDAQMD is based upon the rules adopted a nd approved for that portion of Riverside County by SCAQMD.

The MDAQMD inherited a glass melting furnace rule from SCAQMD that is contained in th e SIP for the Blythe/Palo Verde Valley portion of the MDAQMD. This rule is SCAQMD Rule 1117 – Emissions of Oxides of Nitrogen from Glass Melting Furnaces . SCAQMD Rule 1117 was originally adopted on 02/05/82 and subsequently amended on 01/06/84. The 01/06/84 version was submitted as SIP revision on 12/03/84 and approved at 40 CFR 52.220(c)(159)(v)(D ) - 07/12/90 55 FR 28624

. Thus, the 01/06/84 version of Rule 1117 is in the SIP for the Blythe/Palo Verde Valley upon separation from SCAQMD in July of 1994. The SCAQMD has not subsequently amended this version of Rule 1117. This version of Rule 1165 is more stringent than the SCAQMD rule in the SIP.10 MDAQMD Rule 1165 Final Staff Report, 11/03/2008 The 08/27/07 version of Rule 1165 – Glass Melting Furnaces and the 01/28/08 amendment have been submitted as a SIP revisions for the Blythe/Palo Verde Valley po rtion of Riverside County, but due to the closeness of the subm ission of these amendments, the District expects the current amendment will supersede the previous submission.

2. SIP Analysis

The District will request CARB to su bmit the amendments to Rule 1165 for inclusion in the SIP for the MDAQMD and the Blythe/Palo Verde Valley portion of Riverside County. The 08/27/07 version of MDAQMD Rule 1165 – Glass Melting Furnaces and the 01/28/08 amendment have been submitted as a SIP revisions, but due to the cl oseness of the submission of these amendments, the District expects that the current am endment will supersede the previous submission.

Rule 1165 is a RACT rule because the Dist rict based the rule on an existing glass melting furnace rule that has been de emed to meet RACT by USEPA (San Joaquin Valley Air Pollution Contro l District (SJVAPCD) Rule 4354 – Glass Melting Furnaces ).MDAQMD Rule 1165 A-1 Final Staff Report, 11/03/2008 

### Appendix “A” Rule 1165 - Glass Melting Furnaces Iterated Version

The iterated version is provided so that the changes to an existi ng rule may be easily found. The manner of differentiating text is as follows:

1. Underlined text identifies new or revised language.

2. Lined out text identifies language wh ich is being deleted.

3. Normal text identifies the current language of the rule which will remain unchanged by the adoption of the proposed rule.

4. [Bracketed italicized text] is explanatory material that is not part of the proposed language. It is removed once th e proposed rule is adopted.A-2 MDAQMD Rule 1165 Final Staff Report, 11/03/2008 This page intentionally left blank.(Adopted: 08/27/07; Amended: 01/28/08; Amended: mm/dd/yy)

MDAQMD Rule 1165 1165-1 Glass Melting Furnaces, d2 08/12/08 

## Rule 1165 Glass Melting Furnaces

(A) General

(1) Purpose

(a) The purpose of this rule is to limit the emissions of oxides of nitrogen (NO X ), carbon monoxide (CO), volatil e organic compounds (VOCs), and oxides of sulfur (SO X ) from glass melting furnaces.

(2) Applicability

(a) This rule shall apply to any glass melting furnace.

(3) Exemptions

The provisions of this rule shall not apply to:

(a) Except for section (D)(2)(a), the provisi ons of this rule shall not apply to electric glass melting furnaces where all the heat is supplied by an electric current from electrodes submerged in the molten glass, except that other fuels for startup may supply heat when the furnace contains no molten glass.

(b) Except for section (D)(2)(a), the provisi ons of this rule shall not apply to any glass melting furnace that is de signed to produce less than 4.55 Mg (5 tons) of glass per day.

(c) The provisions of this rule shall not apply to hand glass melting furnaces.

(d) The emission limits in Section (C)(1 ) Table 1 shall not apply during periods of startup, shutdown, or idling, provided the owner/operator complies with the applicable require ments of Section (C)(3), (C)(4), (C)(5), and (E)(3).


### (B) Definitions

For the purpose of this rule the following definitions shall apply:

(1) Air-Fuel Firing – Operation of a glass melti ng furnace where greater than 50 percent of the oxidant for the fuel come s from ambient air. 100 percent air-fuel1165-2 MDAQMD Rule 1165 Glass Melting Furnaces, d2 08/12/08 fired means operation of a glass melting fu rnace where the oxidant is exclusively ambient air.

(2) Block 24-hour Average – The arithmetic average of the hourly NO X emission rates of a furnace as measured over 24 one-hour periods, daily, from 12:00 a.m. to 11:59 p.m., excluding periods of system calibration.

(3) California Air Resources Board (CARB) – The California Air Resources Board, the powers and duties of which are descri bed in Part 2 of Division 26 of the California Health & Safety Code (commencing with section 39500).

(4) Container Glass – Any glass manufactured by pressing, blowing in molds, drawing, rolling, or casting which is used as a container as listed in Standard Industrial Classifica tion 3221 (SIC 3221).

(5) Fiberglass – Material consisting of fine filame nts of glass that are combined in yarn and woven or spun into fabrics, or that are used as reinforcement in other materials or in masses as thermal or acoustical insulating products for the construction industry.

(6) Flat Glass – Any continuous flat glass sheets pr oduced by the float, sheet, rolled, or plate glass process, which is used in windows, windshields, tabletops, or similar products listed in SIC 3211.

(7) Furnace Rebuild – A cold repair that is commenced after the end of a furnace campaign period or expected life cycle of a furnace.

(8) Glass Melting Furnace – A unit comprising a refr actory vessel in which raw materials are charged, melted at high temp erature, refined, and conditioned to produce molten glass. The unit includ es foundations, superstructures and retaining walls, raw material charger systems, heat exchangers, melter cooling system, exhaust system, refractory brick work, fuel supply and electrical boosting equipment, integral control systems and instrumentation, and appendages for conditioning and distributing molten glass to forming apparatuses. The forming apparatuses, including the float bath used in flat glass manufacturing and flow channels in fiberglass manufacturing, are not considered part of the glass melting furnace.

(9) Hand Glass Melting Furnace – A glass melting furnace where the molten glass is removed from the furnace by a glassworker using a blowpipe or a pontil.

(10) Idling – The operation of a furnace at less than 25 percent of the permitted glass production capacity or fuel use capacity as stated on the District permit.

(11) Liquefied Petroleum Gas (LPG) –A general term for any of the following gasses: commercial propane, commercial butane, propane-butane (PB) mixtures, and special duty propane.MDAQMD Rule 1165 1165-3 Glass Melting Furnaces, d2 08/12/08 (12) Oxygen-Assisted Combustion – Operation of a glass melting furnace where the oxidant is greater than th e oxygen content in the ambien t air or greater than 20.9 percent oxygen.

(13) Oxy-Fuel Fired – Operation of a glass melting furnace where greater than 50 percent of the oxidant for the fuel is provided from enriched oxygen streams.

(14) Permitted Glass Production Capacity – The maximum pull rate as stated in the District permit.

(15) Primary Furnace Combustion System – The burners in a furnace that are used during the production of glass.

(16) PUC-Quality Natural Gas – A gaseous fuel that meets the requirements specified in California Public Utilities Commis sion (PUC) General Order 58-A. PUCquality natural gas also means that the su lfur content is no mo re than one-fourth grain of hydrogen sulfide per 100 standard c ubic feet and no more than five grains total sulfur per 100 standard cubic feet.

(17) Pull Rate – The amount of glass coming out of a glass melting furnace, expressed in short tons per day.

(18) Rolling 30-day Average – The arithmetic average of the daily emission rates of a furnace over a contiguous 30-day period, excluding periods of system calibration.

(19) Shutdown – The period of time during which a glass melting furnace is taken from operational to non-operationa l status by allowing it to cool down from its operating temperature to a cold or ambient temperature as the fuel supply is turned off.

(20) Startup – The period of time, after initial c onstruction or a furnace rebuild, during which a glass melting furnace is heated to operating temperature by the primary furnace combustion system, and systems and instrumentation are brought to stabilization.

(21) United States Environmental Protection Agency (USEPA) – The United States Environmental Protection Agency, the Admi nistrator of the US EPA and his or her authorized representative.

(22) Volatile Organic Compound (VOC) – Any volatile compound of carbon, excluding methane, carbon monoxide, carbon dioxide, carbonic acid, metallic carbides or carbonates, ammonium car bonate, and those compounds listed in 40 CFR 51.100(s)(1).1165-4 MDAQMD Rule 1165 Glass Melting Furnaces, d2 08/12/08 

### (C) Requirements

(1) Except as specified in section (A)(3)( d), the owner/operator of any glass melting furnace shall not operate a furnace in such a manner that results in NO X , CO, or VOC emissions exceeding the limits in Table 1.

Table 1 NO X , CO, and VOC Emission Limits

Type of Furnace Combustion Type NO X CO VOC

100% AirFuel Fired 4.0 lb/ton of glass pulled on a block 24-hour average 300 ppmv 20 ppmv

Container Glass or Fiberglass Oxygen Assisted Combustion 4.0 lb/ton of glass pulled on a block 24-hour average 1.0 lb/ton of glass pulled 0.25 lb/ton of glass pulled

100% AirFuel Fired 9.2 lb/ton of glass pulled on a block 24 hour average and 7.0 lb/ton of glass pulled on

a rolling 30-day average 300 ppmv 20 ppmv

Flat Glass

Oxygen Assisted Combustion 9.2 lb/ton of glass pulled on a block 24 hour 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

(2) All glass melting furnaces subject to Table 1 emission limits shall limit SO X by:

(a) Firing PUC-quality natural gas, propane, or LPG.

(b) Liquid fuel may be used as a backup fuel or standby fuel provided the liquid fuel contains no more than 15 ppm sulfur and the furnace exhaust is controlled by a SO X emission control system with a control efficiency of 50 percent or greater.

(3) Startup Requirements

(a) The owner/operator shall submit a reque st for a startup exemption to the APCO, CARB, and the USEPA in conjunc tion with or in advance of anMDAQMD Rule 1165 1165-5 Glass Melting Furnaces, d2 08/12/08 application for Authority to Construc t (ATC) associated with a furnace rebuild.

(b) The owner/operator shall submit to the APCO, CARB, and the USEPA any information deemed necessary by the APCO, CARB, or the USEPA to determine the appropriate lengt h of startup exemption. This information shall include, but is not limited to:

(i) A detailed list of activities to be performed during startup, and a reasonable explanation for the length of time needed to complete each activity; and (ii) A description of the material proc ess flow rates, system operating parameters, etc., that the owner/ operator plans to evaluate during the process of optimization; and (iii) Clearly identified control techno logies or strategies to be employed; and (iv) Explicit description of what physical conditions prevail during startup periods that prevent the co ntrols from being effective; and (v) Reasonably precise estimate as to when physical conditions will have reached a state that allows for the effective control of emissions.

(c) Startup exemptions shall begin upon activation of the primary combustion system.

(d) The actual length of the startup exem ption shall be determined by the APCO, CARB and USEPA at the time of the Authority to Construct (ATC) issuance, but in any case, it shall not exceed the amount of time specified in Table 2. The approval fo r the startup exemption shall be in writing from each agency.

Table 2 Maximum Startup Time

Column I Column II

Type of Furnace Maximum Startup NO X control system

that meets section (C)(3)(d)(i) provisions Maximum Startup NO X control system

that does not meet section (C)(3)(d)(i) provisions

Container glass 100 days 70 days

Fiber glass 105 days 40 days

Flat glass 208 days 104 days1165-6 MDAQMD Rule 1165 Glass Melting Furnaces, d2 08/12/08 (i) Maximum startup time for Tabl e 2, Column I, must have a NO X control system that meets one or more of the following conditions:

a. Is innovative, b. Is not in common use,

c. Is not readily available from a commercial supplier, d. Is funded as original rese arch by a public agency.

(ii) Maximum startup time for those furnaces with NO X controls that do not meet any of the conditions in section (C)(3)(d)(i) shall comply with startup times in Table 2, Column II.

(e) During the startup period, the stoichio metric ratio of the primary furnace combustion system shall not exceed five percent excess oxygen, as calculated from the actual fuel and oxidant flow measurements for combustion in the glass melting furnace.

(f) The emission control system sha ll be in operation as soon as technologically feasib le during startup to minimize emissions.

(g) Notifications shall be performed and records shall be kept in accordance with section (D)(2).

(4) Shutdown Requirements

(a) The duration of shutdown, as measured from the time the furnace operations drop below the idle thresh old as specified in section (B)( 11 10 ) to when all emissions from the furnace cease, shall not exceed 20 days. [correcting reference citation]

(i) The emission control system sh all be in operation whenever technologically feasib le during shutdown to minimize emissions. (ii) Notifications shall be performed and records kept in accordance with section (D)(2).

(5) Idling Requirements

(a) The emission control system sh all be in operation whenever technologically feas ible during idling to minimize emissions.

(b) The NO X , CO, and VOC emission during idling shall not exceed the amount calculated by multiplying the applicable pounds per day emission limit of NO X , VOC, or CO in pounds per ton of glass produced by the furnace permitted production capacity in tons of glass produced per day. [clarification of subsection pursuant to USEPA recommendation]

(c) Notifications shall be performed an d records kept in accordance with section (D)(2).MDAQMD Rule 1165 1165-7 Glass Melting Furnaces, d2 08/12/08 (6) Compliance Determination

(a) The emissions measured for compliance with NO X , CO, and VOC limits shall be averaged over a three hou r period in accordance with the applicable test methods in section (E)(1), or, if a Continuous Emission Monitoring System (CEMS) or an alternate emission monitoring method is used, the applicable requirements of sections (E)(2)(a) or (E)(2)(b), respectively.

(b) Any source testing result, CEMS, or alternate emission monitoring method averaged value exceeding the a pplicable emission limits in section (C)(1) shall constitute a violation of the rule. Any rolling 30-day averaged value from CEMS or altern ate emission monitoring method that exceeds the applicable emission limit in (C)(1) shall constitute a violation of the rule for each day of the averaged period. [language derived from SJVAPCD draft Rule 4354 §5.7.2 added for clarification pursuant to USEPA recommendation]

(7) The owner/operator of any gla ss melting furnace shall implement a NO X CEMS or a NO X alternative emissions monitoring met hod on each furnace, that is approved in writing by the APCO, CARB, and USEPA, and that meets the requirements of section (E)(2). For a furnace battery, a single CEMS or alternate emissions monitoring method may be used to determine the total NO X emissions from all the furnaces provided the emission measurements are made at the common stack. [removing reference to furnace battery in response to CARB Review Comment]


### (D) Monitoring and Records

(1) Administrative Requirements

(a) Permitted Glass Production Capacity and Fuel Use Capacity

Each permit to operate for a glass melting furnace shall comply with specify a maximum daily glass production li mit (units of tons of glass pulled per day) and maximum furnace heat input limit (MMBtu/hr) consistent with compliance with this rule. [clarification of subsection pursuant to USEPA recommendation]

(2) Operations Records

(a) The owner/operator of any glass melti ng furnace subject to section (C) or claiming exemption under section (A)(3) of this rule shall maintain an operating log for each furnace that includes, on a daily basis:

(i) Total hours of operation; (ii) Type of fuel used in each furnace; (iii) Quantity of fuel used by each furnace, and the quantity of glass pulled by each furnace;1165-8 MDAQMD Rule 1165 Glass Melting Furnaces, d2 08/12/08 (iv) NO X emission rate in lb/ton of glass pulled.

(3) The Owner/Operator shall maintain records of source te sts and operating parameters established during initial source test, maintenance, repair, and malfunction.

(4) The Owner/Operator shall maintain all r ecords required by this rule for five-years, and shall produce those records for inspect ion by the APCO or his designee upon request.
(5) Compliance Source Testing

(a) Each glass melting furnace or furnace battery shall be source tested at least once every calendar year, but no t more than once every 18 months and not sooner than every six months to demonstrate compliance with the applicable requirements of section (C). [removing reference to furnace battery in response to CARB Review Comment]

(b) Source test conditions shall be repr esentative of normal operations, but not less than 60 percent of either the maximum glass production capacity or the furnace’s maximum fuel use capacity for each furnace, whichever limit is stated in the PTO.

(c) For source testing performed in accord ance with section (D)(5)(a), the arithmetic average of three 30-consecu tive-minute test runs shall apply. If two of the three runs individuall y demonstrate emissions above the applicable limit, the test cannot be used to demonstrate compliance for the furnace, even if the averaged emissions of all three test runs is less than the applicable limit.


### (E) Compliance Procedures and Test methods

(1) Test Methods

(a) Oxides of Nitrogen – EPA Method 7E, EPA Method 19, or CARB Method 100.

(b) Carbon monoxide (ppmv) – EP A Method 10, or CARB Method 100

(c) Volatile Organic Compound (ppmv) – EPA Method 25A expressed in terms of carbon. EPA Test Method 18 or CARB Method 422 shall be used to determine emissions of exempt compounds.

(d) Stack gas oxygen, carbon dioxide, excess air, and dry molecular weight – EPA Method 3 or 3A, or CARB Method 100.

(e) Stack gas velocity and volumetric flow rate – EPA Method 2.MDAQMD Rule 1165 1165-9 Glass Melting Furnaces, d2 08/12/08 (f) The SO X emission control system efficiency shall be determined using the following:

(i) EPA Method 2 for measuring flow rates; and (ii) EPA Method 6C or EPA Method 8 for measuring total SO X (expressed and as SO 2 ) concentrations at the inlet and outlet of the control device. [correction of typographical error]

(g) Alternative Test Methods

(i) Other test methods demonstrat ed to provide results that are acceptable for purposes of determining compliance with any provisions of this rule may also be used after review and approval in writing by the District, CARB and USEPA.

(2) Emissions Monitoring Systems

(a) An approved CEMS shall comply with the most recently adopted version of all of the following requirements:

(i) 40 CFR Part 51; (ii) 40 CFR Part 60.7; (iii) 40 CFR Part 60.13; (iv) 40 CFR Part 60 Appendix B (Performance specifications); (v) 40 CFR Part 60 Appendix F (Quality Assurance Procedures; and (vi) Applicable sections of Rule 218 (Stack Mon itoring) [Rule 218 is not contained in SIP and should not be referenced in a SIP rule pursuant to USEPA recommendation]

(b) Any approved alternate emission s monitoring method pursuant to the provisions of (E)(2)(a) above shall be capable of determining the furnace emissions on an hourly basis and sh all comply with the following requirements: [correction of typographical error]

(i) 42 40 CFR 54900 64 (Compliance Assurance Monitoring); and [correction of typographical error pursuant to USEPA recommendation] (ii) 40 CFR 60.13 (Monitoring Requirements).

(3) Notifications and Records for Startup, Shutdown, and Idling

(a) The owner/operator of any glass melting furnace claiming an exemption under section (A)(3)(c) sh all notify the APCO by telephone at least 24 hours before initiating idli ng, shutdown, or startup. This notification shall include:

(i) Date and time of the start of the exempt operation; and (ii) Reason for performing the operation; and1165-10 MDAQMD Rule 1165 Glass Melting Furnaces, d2 08/12/08 (iii) An estimated completion date.

(b) The owner/operator shall notify the APCO by telephone within 24 hours after completion of the idling, shutdown, or startup.

(c) The owner/operator claiming exemption under section (A)(3)( c d ) shall maintain all operating records and support documentation necessary to support claim of exemption, and shall meet the following requirements: [correction of typographical error pursuant to USEPA recommendation]

(i) The records and support documentati on shall be retained on-site for five years; and (ii) The records and support documentati on shall be made available to the APCO, CARB, or USEPA dur ing normal business hours; and (iii) The records and support documentation shall be submitted to the APCO, CARB, or USEPA upon request.

(4) Records for Exempt Furnaces

(a) An owner/operator claiming exempti on under section (A)(3 )(a) or section (A)(3)(b) shall maintain records a nd documentation necessary to support claim of exemption.

(b) Records and support documentation speci fied in section (E)(4)(a) shall meet the following requirements:

(i) The records and support documentati on shall be retained on-site for five years after exemption is lost ; and [removal clarifies rule pursuant to USEPA recommendation] (ii) The records and support documentati on shall be made available to the APCO, CARB, or USEPA dur ing normal business hours; and (iii) The records and support documentation shall be submitted to the APCO, CARB, or USEPA upon request.

(5) Calculation Methods

(a) The NO X pollutant emission rate in ppmv shall be converted to lb/hr by using the appropriate conversion equations in ARB Method 100, EPA Method 19, or an equivalent conv ersion method approved, in writing, by the APCO, CARB, and the USEPA. The NO X mass emission rate in lb/hr shall be converted to lb NO X / / ton of glass pulled according to the following equation: [clarification of subsect ion pursuant to USEPA recommendation]

in tons/hr rate pull NOx of lb/hr pulled glass of ton NOx lbs =MDAQMD Rule 1165 1165-11 Glass Melting Furnaces, d2 08/12/08 in tons/hr rate pull pollutant of lb/hr pulled glass of ton pollutant of lbs =

(b) 100 percent air-fuel fired furnaces that have concentration limits in ppmv values shall be subject to the CO and VOC emission limits specified in section (C)(1). These limits are refere nced at dry stack gas conditions and 8.0 percent by volume of stack oxygen. The CO and VOC emission concentrations shall be corrected to 8.0 percent oxygen by using the equation below, or an equivalent co rrection method that is approved, in writing, by the APCO, CARB, and the USEPA.


## ( ) ( ) ( ) CO ppmv x O % % 9

. 20 % 9

. 12 CO ppmv measured measured corrected
2 − =



## ( ) ( ) ( ) VOC ppmv x O % % 9

. 20 % 9

. 12 VOC ppmv measured measured corrected
2 − =

(c) The owner/operator of a oxy-fuel fired furnace, oxygen-assisted combustion furnace, or a furnace utilizing any fuel oxidants other than 100 percent ambient air, shall subm it to the APCO, CARB, and USEPA for approval any methodologi es and data that will be used to calculate emission rates for NO X , CO, and VOC if the methods are different than specified in section (E)(5)(a) or (E )(5)(b). Unless the owner/operator received prior written approval fr om the APCO, CARB, and USEPA of all the calculation methods to be used that are different than specified in (E)(5)(a) or (E)(5)(b), compliance with the emission limits cannot be fully demonstrated, and it shall be deemed to be a violation of this rule.


### (F) Violations

(1) Failure to comply with any provision of this rule shall constitute a violation of the rule.

(2) A violation of the limits contained in this rule as determined by any one of these test methods shall constitute a violation of this rule.

(3) When one or more test method or set of te st methods are specified for any testing, a violation of any requirement of this ru le established by any one of the specified test methods or set of test methods shall constitute a violation of the rule.

[SIP: Submitted as amended 08/25/08 on mm/dd/yy]1165-12 MDAQMD Rule 1165 Glass Melting Furnaces, d2 08/12/08 This page intentionally left blank.MDAQMD Rule 1165 B-1 Final Staff Report, 11/03/2008 

### Appendix “B” Public Notice Documents

1. Proof of Publication – Daily Press, 07/25/08 2. Proof of Publication – Riverside Press Enterprise, 07/25/08B-2 MDAQMD Rule 1165 Final Staff Report, 11/03/2008 This page intentionally left blank.MDAQMD Rule 1165 B-3 Final Staff Report, 11/03/2008B-4 MDAQMD Rule 1165 Final Staff Report, 11/03/2008MDAQMD Rule 1165 C-1 Final Staff Report, 11/03/2008 

### Appendix “C” Public Comments and Responses

1. CARB Review Comments, 06/24/08 2. CARB Review Comments, 07/31/08 3. EPA Rule Review Comments, 08/07/08C-2 MDAQMD Rule 1165 Final Staff Report, 11/03/2008 This page intentionally left blank.MDAQMD Rule 1165 C-3 Final Staff Report, 11/03/2008 

## STATE OF CALIFORNIA
ENVIRONMENTAL PROTECTION AGENCY 

# AIR RESOURCES BOARD

P. O. Box 2815 Sacramento, California 95812

June 24, 2008

Transmittal of ARB Staff Rule Review Comments

To: Mr. Eldon Heaston, Executive Director Mojave Desert Air Quality Management District Telephone Number: (661) 723-8070 e-mail: eheaston@mdaqmd.ca.gov

From: Dave Brown, (916) 324-1129 e-mail: dabrown@arb.ca.gov

The following rule, which was amended at a publ ic hearing held by your District Board on January 28, 2008, was received by us on April 11, 2008, for our review:

1165 Glass Melting Furnaces (amended)

We have reviewed the rule and have the comments on the following page.

Based on our discussion with Ms. Tracy Walter s of your staff we understand that you plan to revise Rule 1165 to incorporate our comments at the ne xt available board hearing.

If you have any questions, please contact me by e-mail or at t he telephone number above.

If you have any questions about our comments, please contact Mr. Dave Mehl, Manager of the Energy Section, Projec t Assessment Branch, Stationary Source Division, at (916) 323-1491.

Rule review comments are on the following pageC-4 MDAQMD Rule 1165 Final Staff Report, 11/03/2008 Date: June 24, 2008

Air Resources Board Staff Comments on Mojave Desert Air Quality Management District Rule 1165

Rule 1165 Glass Melting Furnaces (amended)

1. Section (C)(7) : The last sentence of this section refers to a furnace battery. Based on U.S. EPA comments, the District has removed the definition of “Furnace Battery” from Rule 1165. ARB staff reco mmends that the last sentence of Section (C)(7) be removed as the District is remo ving all reference to furnace batteries from Rule 1165.

2. Section (D)(5)(a) : The first line of this section makes reference to “or furnace battery.” ARB staff recommends that “o r furnace battery” be removed from this section as the District is removing all refer ence to furnace batteries from Rule 1165 based on U.S. EPA comments.MDAQMD Rule 1165 C-5 Final Staff Report, 11/03/2008 District Response to CARB Review Comments

1. Reference to “furnace battery” in su bsection (C)(7) has been removed.

2. Reference to “furnace battery” in subs ection (D)(5)(a) has been removed.C-6 MDAQMD Rule 1165 Final Staff Report, 11/03/2008 This page intentionally left blank.MDAQMD Rule 1165 C-7 Final Staff Report, 11/03/2008 

## STATE OF CALIFORNIA
ENVIRONMENTAL PROTECTION AGENCY 

# AIR RESOURCES BOARD

P. O. Box 2815 Sacramento, California 95812

July 31, 2008

Transmittal of ARB Staff Rule Review Comments

To: Ms. Tracy Walters, Air Quality Specialist Mojave Desert Air Quality Management District Telephone Number: (760) 245-1661 ext 6122 e-mail: twalters@mdaqmd.ca.gov

From: Patrick Au, (916) 322-3303 e-mail: pau@arb.ca.gov

The following proposed rule, which is scheduled for a public hearing to be held by your District Board on August 25, 2008, was received by us on July 15, 2008, for our review:

Rule 1165 Glass Melting Furnaces

The Air Resources Board (ARB) staff has reviewed the rule and, based on the information available to us at this time, we have no comment. The rule was examined by the following ARB divisions: Enforcem ent, Monitoring and Laboratory, and Stationary Source.

If you have any questions, please contact me by e-mail or at t he telephone number above.C-8 MDAQMD Rule 1165 Final Staff Report, 11/03/2008 This page intentionally left blank.MDAQMD Rule 1165 C-9 Final Staff Report, 11/03/2008 August 07, 2008

Transmittal of EPA Rule Review Comments

To: Eldon Heaston, Mojave Desert Air Quality Management District eheaston@mdaqmd.ca.gov

Mike Guzzetta, California Air Resources Board mguzzett@arb.ca.gov

From: Andrew Steckel, Rulemaking Office Chief steckel.andrew@epa.gov

Re: Draft Amended Rule 1165 (Glass Melting Furnaces), scheduled for amendment on August 25, 2008

We are providing comments based on our preliminary review of the draft rule identified above. Please direct any questions about our comments to me at (415) 947-4115 or to Francisco Donez at (213) 244-1834.

Comments 1. Section (C)(5)(b): The phrase "pounds per day" should be removed from the second line of this section.

2. Section (D)(1)(a) should require that the maximum daily glass production limit and the maximum heat input limits be specified in each furnace's permit to operate.

3. Section (E)(1)(f)(ii) has a typographical error. The phrase "expressed and SO2" should be "expressed as SO2."

4. Section (E)(2)(vi): MDAQMD Rule 218 has not been submitted as a SIP rule. Please advise as to whether the District intends to submit Rule 218, or whether this reference can be removed from draft Rule 1165.

5. Section (E)(3)(c) contains an incorrect reference to Section (A)(3)(c). The reference should be to Section (A)(3)(d).

6. Section (E)(4)(b)(i): The phrase "after exemption is lost" should be removed from this section.

7. Section (E)(5)(a) should be generalized to apply to all pollutants, rather than just NOx.C-10 MDAQMD Rule 1165 Final Staff Report, 11/03/2008 This page intentionally left blank.MDAQMD Rule 1165 C-11 Final Staff Report, 11/03/2008 District Response to USEPA Review Comments

1. Section (C)(5)(b) has been clarified by removing the phrase “pounds per day.”

2. Section (D)(1)(a) has been clarified to require that the maximum daily glass production limit and maximum heat input limits are specified in each furnace’s permit to operate.

3. Typographical error corrected in sect ion (E)(1)(f)(ii) from “expressed and SO 2 ” to “expressed as SO 2 .”

4. Reference to Rule 218 in section (E)(2)(vi) has been removed as Rule 218 is not a SIP rule.

5. Typographical error corrected in section (E)(3)(c) of “(A)(3)(c )” to “(A)(3)(d).”

6. Section (E)(4)(b)(i) has b een clarified by removing the phras e “after exemption is lost.”

7. Section (E)(5)(a) has been generalized for all pollutants, rather than just NO X .C-12 MDAQMD Rule 1165 Final Staff Report, 11/03/2008 This page intentionally left blank.MDAQMD Rule 1165 D-1 Final Staff Report, 11/03/2008 

### Appendix “D” California Environmental Quality Act Documentation

1. San Bernardino County Notice of Exemption 2. Riverside County Notice of ExemptionD-2 MDAQMD Rule 1165 Final Staff Report, 11/03/2008 This page intentionally left blank.MDAQMD Rule 1165 D-3 Final Staff Report, 11/03/2008D-4 MDAQMD Rule 1165 Final Staff Report, 11/03/2008MDAQMD Rule 1165 E-1 Final Staff Report, 11/03/2008 

### Appendix “E” Bibliography

The following documents were consulted in the preparation of this staff report.

1. SJVAPCD Rule 4354 – Glass Melting Furnaces , amended August 17, 2006 2. SJVAPCD Draft Rule 4354 – Glass Melting Furnaces , June 26, 2008E-2 MDAQMD Rule 1165 Final Staff Report, 11/03/2008 This page intentionally left blank