SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix A: Commen ts and Responses September 16, 2010



## APPENDIX A

COMMENTS AND RESPONSES TO JUNE 28, 2010 DRAFT VERSION OF RULE 4354

September 16, 2010

A-1 Final Staff Report with Appendices for Proposed Amendments to Rule 4354SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix A: Commen ts and Responses September 16, 2010

This page intentionally blank.

A-2 Final Staff Report with Appendices for Proposed Amendments to Rule 4354SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix A: Commen ts and Responses September 16, 2010



### Appendix A

SUMMARY OF SIGNIFICANT COMMENTS AND RESPONSES TO

DRAFT RULE 4354 DATED JUNE 28, 2010

EPA Region IX Staff Comments:

1. COMMENT: Please evaluate the effects of the delay in compliance on the reasonable further progress (RFP) dem onstration for the 2008 PM2.5 Plan.

RESPONSE: District staff has evaluated the e ffect of the proposed amendments

on the District’s RFP and found that there is no effect on the RFP. See the staff report for the results of the assessment.

2. COMMENT: Please evaluate further strengthening of the oxides of sulfur (SOx)

and Particulate matter 10 microns and sma ller (PM10) limits if compliance is delayed for the early enhanced flat glass scenario.

RESPONSE: District staff believe s that the most effici ent add-on control for NOx control on glass melting furnaces would be selective catalytic reduction (SCR), even though this technology is not in widespread use for glass furnaces. Based on the sensitivity of the SCR catalyst to sulfur poisoning and plugging from particulates, the operator must remove as much sulfur and dust from the stream as possible before the stream is exposed to the catalyst. In removing sulfur and dust, the glass furnace operator would most likely choose a semi-dry electrostatic precipitator (EP). The EP cools the air stream as the stream passes through the

unit. If the air stream is cooled too much as in the case of scrubbing the exhaust stream to be very low in SOx am PM , the temperature of the stream will fall below the working temperatur e of the NOx catalyst. In that case, the catalyst

would not remove NOx fr om the airstream.

Additionally, the District is relying on a NOx-reduction based strategy to attain both the 8-hour ozone and the PM2.5 air qu ality standards. Dis trict staff must balance SOx and PM10 control against the operator achieving very low NOx emissions per ton of glass pr oduced. If staff must choos e, then staff would lean toward having the very lowest NOx em issions and allowing slightly higher SOx

and PM10 emissions.

California Air Resources Bo ard (ARB) Staff Comments

The Air Resources Board staff has reviewed the rule and, based on the

information available to them at th is time, they have no comments.

A-3 Final Staff Report with Appendices for Proposed Amendments to Rule 4354SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix A: Commen ts and Responses September 16, 2010

Stakeholders submitting comments:

Pilkington North America, Inc. (PNA)

3. COMMENT: PNA strongly supports the suggest ed revisions to Rule 4354. In particular, PMA applauds the District’s decision to provide a more flexible implementation schedule that assures greater emission reductions. (PNA)

RESPONSE: District staff thanks co mmentor for their support.

4. COMMENT: At the June 28 workshop, District staff referenced another facility’s desire to amend the start-up, shutdown, and/ or idling provisions of Rule 4354. While we do not oppose the changes described during t he workshop, PNA opposes the inclusion of such changes in th is rulemaking if doing so could delay the timetable for revising the rule. (PNA)

RESPONSE: District staff has not incl uded the other facility’s startup/shutdown/idling concerns as part of this rule project.

5. COMMENT: Commenter suggests several language changes to improve rule clarity. (PNA)

RESPONSE: Changes have been incorporated as appropriate. See proposed rule for changes.

A-4 Final Staff Report with Appendices for Proposed Amendments to Rule 4354