SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix A: Comments 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 4354 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix A: Comments and Responses September 16, 2010 

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 A-2 Final Staff Report with Appendices 

for Proposed Amendments to Rule 4354 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix A: Comments 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) demonstration for the 2008 PM2.5 Plan. 

RESPONSE: District staff has evaluated the effect 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 smaller (PM10) limits if compliance is 

delayed for the early enhanced flat glass scenario. 

RESPONSE: District staff believes that the most efficient 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 temperature of the NOx catalyst. In that case, the catalyst 

would not remove NOx from 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 quality standards. District staff must 

balance SOx and PM10 control against the operator achieving very low NOx 

emissions per ton of glass produced. If staff must choose, then staff would lean 

toward having the very lowest NOx emissions and allowing slightly higher SOx 

and PM10 emissions. 

California Air Resources Board (ARB) Staff Comments 

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

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

 A-3 Final Staff Report with Appendices 

for Proposed Amendments to Rule 4354 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix A: Comments and Responses September 16, 2010 

Stakeholders submitting comments: 

Pilkington North America, Inc. (PNA) 

3. COMMENT: PNA strongly supports the suggested 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 commentor 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 the workshop, PNA 

opposes the inclusion of such changes in this rulemaking if doing so could delay 

the timetable for revising the rule. (PNA) 

RESPONSE: District staff has not included 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