Mojave Desert 

Air Quality Management District 

Final 

Staff Report 

Proposed Amendment of 

Rule 1165 – Glass Melting Furnaces 

Amended on 

August 25, 2008 

14306 PARK AVE, VICTORVILLE, CA 92392-2310 

PHONE: (760) 245-1661 

FAX: (760) 245-2699 
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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 Adoption 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 Underlying 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............................................. 9 
TC-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 Environmental Quality Act Documentation ....................................... D-1 

Appendix E - Bibliography..........................................................................................................E-1 
MDAQMD 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 discrete purposes. Its primary purpose is to provide a summary and 

background material to the members of the Governing Board. This allows the members of the 

Governing Board to be fully informed before making any required decision. It also provides the 

documentation necessary for the Governing Board to make any findings, which are required by 

law to be made prior to the approval or adoption of a document. In addition, a staff report 

ensures that the correct procedures and proper documentation for approval or adoption of a 

document have been performed. Finally, the staff report provides evidence for defense against 

legal challenges regarding the 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 Code) §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 has received further (non-substantive) comments 

from both CARB and USEPA that are being addressed 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 proposed amendments to Rule 1165 – Glass Melting Furnaces and 

approve the appropriate CEQA documentation. This action is necessary to address CARB and 

USEPA comments, and to correct a rule citation. 

The Governing Board of the Mojave Desert Air 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 are required for the procedurally correct proposed 

amendment of Rule 1165 – Glass Melting Furnaces. Each item is discussed, if applicable, in 

Section V. Copies of related documents are 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 Review 
MDAQMD Rule 1165 3

Final Staff Report, 11/03/2008 

V. DISCUSSION OF LEGAL REQUIREMENTS 

A. REQUIRED ELEMENTS/FINDINGS 

This section discusses the State of California statutory requirements that apply to the 

amendments to Rule 1165. These are actions 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 Adoption of Rules & Regulations 

Before adopting, amending, or repealing a rule or regulation, the District 

Governing Board is required to make findings of necessity, authority, clarity, 

consistency, non-duplication, and reference based upon relevant information 

presented at the hearing. The information below 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 pursuant 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 state or federal law or regulation 

because the amendments are administrative in nature in that two 

unused references to “furnace battery” are removed, several 
4 MDAQMD Rule 1165 

Final Staff Report, 11/03/2008 

sections are clarified in response to USEPA comments, and a rule 

citation is corrected. 

f. Reference 

The District has the authority pursuant to H & S Code §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 comments, 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 Underlying Federal Requirements 

The amendments to Rule 1165 are subject to all the requirements 

for a SIP submittal because Rule 1165 will be included in the 

MDAQMD SIP. The FCAA requires areas designated nonattainment and classified moderate and above to implement RACT 

for sources subject to CTG documents issued by USEPA for 

“major sources” of VOCs and NOX that are ozone precursors. 

Because the District has a “major 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 San 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 citation. 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” for 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 sent 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 regulations 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 procedures pursuant to H&S Code 

§§40725 - 40728 have been followed. 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 requirements 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 compliance with provisions of the 

California Environmental Quality Act (CEQA). 

B. WRITTEN ANALYSIS OF EXISTING REQUIREMENTS 

H & S Code §40727.2 requires air districts to prepare 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 modification by the District. 
6 MDAQMD Rule 1165 

Final Staff Report, 11/03/2008 

The FCAA requires areas designated non-attainment for ozone and classified moderate 

and above to adopt and maintain RACT rules to control the emissions of VOCs and NOX

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 District 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 changes in response to substantive verbal 

comments from USEPA that were not included 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 remove two unused references to “furnace 

battery”. The amendment will also clarify several sections in response to non-substantive 

USEPA comments, and correct 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 administrative in nature and address CARB 

Review Comments to remove two unused references 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 feasible measures” to control volatile compounds, 

oxides of nitrogen or oxides of sulfur. The amendments to Rule 1165 are not 

subject to incremental cost effectiveness calculations because they do not involve 

BARCT or “all feasible measures”.

D. ENVIRONMENTAL ANALYSIS (CEQA) 

Through the process described below the appropriate 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 air 
MDAQMD Rule 1165 7

Final Staff Report, 11/03/2008 

contaminants or create any adverse environmental impacts, a Class 8 categorical 

exemption (14 Cal. Code Reg. §15308) applies. 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 environmental impacts of compliance with the 

amendments to Rule 1165. The amendments are administrative in nature in that 

they remove two unused references to “furnace battery,” clarify several sections 

in response to non-substantive USEPA comments, 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 nature in that they to remove two unused 

references to “furnace battery,” clarify several sections in response to non-substantive 

USEPA comments, and correct 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 environmental impacts because they remove to 

remove two unused references to “furnace battery,” clarify several sections in response to 

non-substantive USEPA comments, and correct a rule citation.

C. CONTROL REQUIREMENTS 

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

The amendments to Rule 1165 – Glass Melting Furnaces do not cause the release of 

additional air contaminants or create any environmental impacts because two unused 

references to “furnace battery” are removed, several sections are clarified 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 the amendments to Rule 1165. Readers are 

encouraged to examine the [bracketed and italicized] notations contained in the iterated 

version of the rule contained in Appendix A for notations regarding movement and 

modification of specific sections 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 subsection (D)(5)(a) has been removed. 

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

day.” 

5. 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. 

6. Typographical error corrected in section (E)(1)(f)(ii) from “expressed and 

SO2” to “expressed as SO2.” 

7. Reference to Rule 218 in section (E)(2)(vi) has been removed as Rule 218 

is not a SIP rule and rule reference is not necessary in rule. 

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

“(A)(3)(d).” 

9. Section (E)(4)(b)(i) has been clarified by removing the phrase “after 

exemption is lost.” 

10. Section (E)(5)(a) has been generalized for all pollutants, rather than just 

NOX. 
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 closeness 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 legislations 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 SIP 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 Verde Valley portion of the MDAQMD 

is based upon the rules adopted and approved for that portion of 

Riverside County by SCAQMD. 

The MDAQMD inherited a glass melting furnace rule from 

SCAQMD that is contained in the 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 portion of Riverside County, but 

due to the closeness of the submission of these amendments, the 

District expects the current amendment will supersede the previous 

submission. 

2. SIP Analysis 

The District will request CARB to submit 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 closeness of the submission of these amendments, the 

District expects that the current amendment will supersede the previous 

submission. 

Rule 1165 is a RACT rule because the District based the rule on an existing glass 

melting furnace rule that has been deemed to meet RACT by USEPA (San 

Joaquin Valley Air Pollution Control 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 existing 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 which 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 the proposed rule is adopted. 
A-2 MDAQMD Rule 1165 

Final Staff Report, 11/03/2008 

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 (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 

(NOX), carbon monoxide (CO), volatile organic compounds (VOCs), and 

oxides of sulfur (SOX) 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 provisions 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 provisions of this rule shall not apply to 

any glass melting furnace that is designed 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 requirements 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 melting furnace where greater than 50 

percent of the oxidant for the fuel comes from ambient air. 100 percent air-fuel 
1165-2 MDAQMD Rule 1165 

Glass Melting Furnaces, d2 08/12/08 

fired means operation of a glass melting furnace where the oxidant is exclusively 

ambient air. 

(2) Block 24-hour Average – The arithmetic average of the hourly NOX 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 described 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 Classification 3221 (SIC 3221). 

(5) Fiberglass – Material consisting of fine filaments 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 produced 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 refractory vessel in which raw 

materials are charged, melted at high temperature, refined, and conditioned to 

produce molten glass. The unit includes 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 the oxygen content in the ambient 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 Commission (PUC) General Order 58-A. PUCquality natural gas also means that the sulfur content is no more than one-fourth 

grain of hydrogen sulfide per 100 standard cubic 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-operational 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 construction 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 Administrator of the USEPA 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 carbonate, 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 NOX, CO, or 

VOC emissions exceeding the limits in Table 1. 

Table 1 

NOX, CO, and VOC Emission Limits

Type of Furnace Combustion 

Type NOX 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 SOX 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 SOX emission control system with a control efficiency of 

50 percent or greater. 

(3) Startup Requirements 

(a) The owner/operator shall submit a request for a startup exemption to the 

APCO, CARB, and the USEPA in conjunction with or in advance of an 
MDAQMD Rule 1165 1165-5

Glass Melting Furnaces, d2 08/12/08 

application for Authority to Construct (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 length 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 process flow rates, system operating 

parameters, etc., that the owner/operator plans to evaluate during 

the process of optimization; and 

(iii) Clearly identified control technologies or strategies to be 

employed; and 

(iv) Explicit description of what physical conditions prevail during 

startup periods that prevent the controls 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 exemption 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 for the startup exemption shall be in 

writing from each agency. 

Table 2 

Maximum Startup Time

Column I Column II 

Type of Furnace Maximum Startup 

NOX control system 

that meets section 

(C)(3)(d)(i) provisions 

Maximum Startup 

NOX 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 days 
1165-6 MDAQMD Rule 1165 

Glass Melting Furnaces, d2 08/12/08 

(i) Maximum startup time for Table 2, Column I, must have a NOX

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 research by a public agency. 

(ii) Maximum startup time for those furnaces with NOX 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 stoichiometric 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 shall be in operation as soon as 

technologically feasible 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 threshold as specified in section (B)(1110) 

to when all emissions from the furnace cease, shall not exceed 20 days. 

[correcting reference citation]

(i) The emission control system shall be in operation whenever 

technologically feasible 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 shall be in operation whenever 

technologically feasible during idling to minimize emissions. 

(b) The NOX, CO, and VOC emission during idling shall not exceed the 

amount calculated by multiplying the applicable pounds per day emission 

limit of NOX, 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 and 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 NOX, CO, and VOC limits 

shall be averaged over a three hour 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 applicable emission limits in section 

(C)(1) shall constitute a violation of the rule. Any rolling 30-day 

averaged value from CEMS or alternate 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 glass melting furnace shall implement a NOX CEMS or 

a NOX alternative emissions monitoring method 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 NOX 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 

withspecify a maximum daily glass production limit (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 melting 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) NOX emission rate in lb/ton of glass pulled. 

(3) The Owner/Operator shall maintain records of source tests and operating 

parameters established during initial source test, maintenance, repair, and 

malfunction. 

(4) The Owner/Operator shall maintain all records required by this rule for five-years, 

and shall produce those records for inspection 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 not 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 representative 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 accordance with section (D)(5)(a), the 

arithmetic average of three 30-consecutive-minute test runs shall apply. If 

two of the three runs individually 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) – EPA 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 SOX 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 SOX

(expressed and as SO2) concentrations at the inlet and outlet of the 

control device. [correction of typographical error]

(g) Alternative Test Methods 

(i) Other test methods demonstrated 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 Monitoring) [Rule 218 is not 

contained in SIP and should not be referenced in a SIP rule

pursuant to USEPA recommendation]

(b) Any approved alternate emissions monitoring method pursuant to the 

provisions of (E)(2)(a) above shall be capable of determining the furnace 

emissions on an hourly basis and shall 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) shall notify the APCO by telephone at least 24 

hours before initiating idling, 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; and 
1165-10 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)(cd) 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 documentation shall be retained on-site 

for five years; and 

(ii) The records and support documentation shall be made available to 

the APCO, CARB, or USEPA during 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 exemption under section (A)(3)(a) or section 

(A)(3)(b) shall maintain records and documentation necessary to support 

claim of exemption. 

(b) Records and support documentation specified in section (E)(4)(a) shall 

meet the following requirements: 

(i) The records and support documentation 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 documentation shall be made available to 

the APCO, CARB, or USEPA during 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 NOX 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 conversion method approved, in writing, by 

the APCO, CARB, and the USEPA. The NOX mass emission rate in lb/hr 

shall be converted to lb NOX//ton of glass pulled according to the 

following equation: [clarification of subsection pursuant to USEPA 

recommendation]

pull rate in tons/hr

lb/hr of NOx lbs NOx ton of glass pulled =
MDAQMD Rule 1165 1165-11

Glass Melting Furnaces, d2 08/12/08 

pull rate in tons/hr

lb/hr of pollutant lbs of pollutant ton of glass pulled =

(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 referenced 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 correction method that is approved, in 

writing, by the APCO, CARB, and the USEPA. 

( ) ( ) x ( ) ppmvCO

20.9% %O

12.9%

ppmvCO measured

measured

corrected − 2

=

( ) ( ) x ( ) ppmv VOC

20.9% %O

12.9%

ppmv VOC 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 submit to the APCO, CARB, and USEPA 

for approval any methodologies and data that will be used to calculate 

emission rates for NOX, 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 from 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 test methods are specified for any testing, 

a violation of any requirement of this rule 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] 
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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, 07/25/08 
B-2 MDAQMD Rule 1165 

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MDAQMD Rule 1165 B-3

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B-4 MDAQMD Rule 1165 

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MDAQMD 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, 08/07/08 
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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 public 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 Walters of your staff we understand that you 

plan to revise Rule 1165 to incorporate our comments at the next available board 

hearing. 

If you have any questions, please contact me by e-mail or at the telephone number 

above. 

If you have any questions about our comments, please contact Mr. Dave Mehl, 

Manager of the Energy Section, Project Assessment Branch, Stationary Source 

Division, at (916) 323-1491. 

Rule review comments are on the following page 
C-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 recommends that the last sentence of Section 

(C)(7) be removed as the District is removing 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 “or furnace battery” be removed from this 

section as the District is removing all reference 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 subsection (C)(7) has been removed. 

2. Reference to “furnace battery” in subsection (D)(5)(a) has been removed. 
C-6 MDAQMD Rule 1165 

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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: Enforcement, Monitoring and Laboratory, and Stationary 

Source. 

If you have any questions, please contact me by e-mail or at the telephone number 

above. 
C-8 MDAQMD Rule 1165 

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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. 
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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 section (E)(1)(f)(ii) from “expressed and SO2” to 

“expressed as SO2.” 

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 been clarified by removing the phrase “after exemption is lost.” 

7. Section (E)(5)(a) has been generalized for all pollutants, rather than just NOX. 
C-12 MDAQMD Rule 1165 

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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 Exemption 
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MDAQMD Rule 1165 D-3

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D-4 MDAQMD Rule 1165 

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MDAQMD 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, 2008 
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