SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

FINAL STAFF REPORT

September 16, 2010

Proposed Amendments to Rule 4354 (Glass Melting Furnaces)

Prepared by: Joven R. Nazareno, Senior Air Quality Engineer Sandra Lowe-Leseth, Ai r Quality Engineer

Reviewed by: George Heinen, Super vising Air Quality Engineer Errol Villegas, Manager, Strategy and Incentives Samir Sheikh, Director, Strategy and Incentives

I. SUMMARY

A. Reasons for Rule Development and Implementation

The District Governing Board adopted amendments to Rule 4354 at the October 2008 Public Hearing that established more stri ngent emissions limitations for glass melting furnaces. During that heari ng, there was significant discussion regarding concerns raised by affected sources about the informati on used by the District to evaluate the potential cost impacts and cost -effectiveness of the proposed rule amendments. As a result, the Governing Board pr ovided additional direction to staff to re -evaluate the impact of the rule amendments and report ba ck to the Board within 18 months of adoption to accommodate additional cost informa tion provided by affected businesses.

Based on staff’s re-evaluation of the adopted rule amendments and recommendations made at the April 15, 2010 Public Hearing, the Board directed staff to develop and propose future rule amendments to Rule 4354 incorporating short-term emission limitation flexibility for flat glass manufacturing facilitie s committed to achieving more stringent long-term emissions limitations earlier than would otherwise be required by the rule. This direction was based on new information submitted by Pilkington North America with regard to meeting the interim Tier 3 oxides of nitrogen (NOx) emission limits for flat glass manufacturers by t he January 2011 compliance date in the rule.

The Tier 3 and the Tier 4 NOx emission limi ts will require installation of advanced and expensive emission control systems and would necessitate major changes to existing furnaces. District staff agrees with the gla ss manufacturers that the most appropriate time to make changes to the furnace in order to install emission control equipment is when the furnace is down for periodic repairs to the furnace’s insulating refractory. This periodic maintenance is commonly known in the industry as “cold repair” or “rebuild”. Flat glass furnaces can operate for 15 y ears or more between rebuilds and operateSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Final Staff Report: Rule 4354 (Glass Melting Fur naces) September 16, 2010

continuously between rebuilds. Therefore, the window of opportunity for cost-effective installation of emission control equipment is very narrow. Installing emission control systems prior to the scheduled fu rnace rebuild would incur additional significant costs

due to lost revenue because the furnace is not producing any glass products during the installation of the required controls and s ubsequent start-up periods which normally take

several months.

As an additional factor for consideration, no one could have antici pated the depth or the length of the current economic recession. G enerally, the two main consumers of flat glass are the building trades (windows fo r homes and buildings) and the automotive market (windows and windshields for cars and trucks). Both of t hese market sectors have been particularly hard-hit by the recessi on and the slowdown in these markets has affected their suppliers, includi ng flat glass manufacturers.

Since October 2008 when the last amendments were adopted for the rule, Pilkington has experienced a significant economic downt urn that forced a del ay in their planned

furnace rebuild and the associated installa tion of emission controls. As a result, Pilkington’s current facilit y cannot meet the Tier 3 NO x limit by the 2011 deadline

without installation of additional emission control equipment in conjunction with a furnace rebuild. The Tier 3 NOx limit provides no real transition period because there is no intermediate technology that will allow Pilki ngton’s furnace to achieve the Tier 3 NOx limit, other than the technol ogy required to achieve the lower Tier 4 limit.

To address this concern, the District pr oposes to incorporate short-term emission limitation flexibility for flat glass manufacturing facilitie s committed to achieving more stringent long-term emissions limitations earlier than would otherwise be required by the rule. This ”Tier 4 early enhanced” option would achieve additional early reductions by complying with "Tier 4 enhanced" emissions lim itations four year s earlier than would otherwise be required by the rule in return fo r flexibility in meeti ng the interim Tier 3

emissions limitation.

There are three flat glass manufacturers in t he Valley. Besides Pilkington, the other two facilities are currently meeti ng the Tier 3 NOx emission limit and have permit conditions that would prevent them from increasing their NOx emissions ab ove the Tier 3 limit if it

were to be removed from the Oct ober 2008 version of the rule.

Staff finds that removing the Tier 3 limit and requiring the lowest NOx limit four years earlier for a single flat glass furnace will not affe ct the District's attain ment date. In order

to be considered in attainment of an ai r quality standard, the District must have no

violations of the standard at its official monitoring site for thr ee years. In the Tier 4 early enhanced option, the lower emissions from th is facility come just ahead of the PM2.5 attainment year of 2014 rather than afterwards, as would be expected if Pilkington opted for the Tier 4 enhanced option. By implem enting the Tier 4 early enhanced option at Pilkington, Valley residents would reap t he benefits of nearly 33 tons per year of

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Final Staff Report: Rule 4354 (Glass Melting Fur naces) September 16, 2010

additional NOx reductions beginning in 2014, rather than in 2018, and the emission

reductions would continue for the length of the furnace campaign.

B. Description of the Project

District staff would amend Rule 4354 in orde r provide flexibility for flat glass manufacturers to defer meeting the Tier 3 emission limitation in January 1, 2011 provided they meet the “Tier 4 enhanced” emission limits four year earlier than otherwise required, namely by January 2014 rather than by January 2018. The proposed compliance option would achieve addi tional long-term emission reduction by complying with “Tier 4 enhanced” emissions lim itations four year s earlier than would otherwise be required by the rule in return for eliminating the Tier 3 emissions limitation. The proposed amendments would not change or affect the existing emission limits and requirements for container glass manufacturi ng and fiberglass manufacturing facilities.

C. Rule Development Process

District staff conducted a public workshop in June 2010 in order to present and receive

comments on draft amendments to Rule 435 4. Comments received from affected source operators, consultants, vendors and m anufacturers of control technologies, the California Air Resources Board (ARB) and t he United States Envir onmental Protection Agency (EPA) have been evaluated and, if appropriate, incorpor ated into proposed rule provisions.

The proposed rule and final draft staff report will be published and mailed to affected sources and interested parties prior to a public hearing to consider the adoption of proposed amendments to Rule 4354 by the Dis trict Governing Board in September

2010.

II. CLIMATE CHANGE

The California Global Warming Solutions Ac t of 2006 (AB 32) created a comprehensive, multi-year program to reduc e greenhouse gas (GHG) emissions in California, with the goal of restoring emissions to 1990 levels by 2020. In the coming years, the ARB and the Legislature will be developing policies and programs to implement Assembly Bill 32 (AB 32). There are many win-win stra tegies that can reduce both GHG and criteria/toxic pollutant emissions. However, the District’s primary mission remains to achieve attainment with air quality standards to protect public health. Therefore, when

situations that involve tradeoffs between GHG and criteria or toxic pollutants arise, the District will give precedence to reducing criteria or toxic pollutant emissions due to the more immediate public health concerns associated with such pollutants.

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Final Staff Report: Rule 4354 (Glass Melting Fur naces) September 16, 2010

III. BACKGROUND

Since the proposed amendments only affect the emission limits and requirements for flat glass furnaces, District staff will not di scuss the existing Rule 4354 requirements for container glass furnaces and fiberglass furnaces.

Prior to the October 2008 Rule 4354 amend ments, glass melting furnaces were required to meet Tier 2 oxid es of nitrogen (NOx) limits. Under the 2008 amended rule, flat glass furnaces are required to meet an interim Tier 3 NOx limit by January 2011 as well as stringent sulfur oxides (SOx) and parti culate matter (PM) limits. The Tier 4 NOx limit for flat glass furnaces has a co mpliance date as soon as January 2014 for the standard option and as late as January 2018 for the enhanced option. Table 1 summarizes the NOx limits and comp liance dates for flat glass.

Table 1 – Flat Glass NOx Limits of Existing Rule 4354 NOx limit Lb/ton glass produced
Tier 2 limit – prior to Jan 2011 7.0 Tier 3 limit – begi nning Jan 2011 5.0 Select one of the following: Tier 4 standard option by Jan 2014 3.2 Tier 4 enhanced option by Jan 2018 2.9

The Tier 3 and the Tier 4 NOx emission limi ts will require installation of advanced and expensive emission control systems and would necessitate major changes to existing furnaces. District staff agrees with the gla ss manufacturers that the most appropriate time to make changes to the furnace in order to install emission control equipment is when the furnace is down for periodic repairs to the furnace’s insulating refractory. This periodic maintenance is commonly known in the industry as “cold repair” or “rebuild”. Flat glass furnaces can operate for 15 y ears or more between rebuilds and operate continuously between rebuilds. Therefore, the window of opportunity for cost-effective installation of emission control equipment is very narrow. Installing emission control systems prior to the scheduled fu rnace rebuild would incur additional significant costs

due to lost revenue because the furnace is not producing any glass products during the installation of the required controls and s ubsequent start-up periods which normally take

several months.

As an additional factor for consideration, no one could have antici pated the depth or the length of the current economic recession. G enerally, the two main consumers of flat glass are the building trades (windows fo r homes and buildings) and the automotive market (windows and windshields for cars and trucks). Both of t hese market sectors have been particularly hard hit by the recessi on and the slowdown in these markets has affected their suppliers, includi ng flat glass manufacturers.

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Final Staff Report: Rule 4354 (Glass Melting Fur naces) September 16, 2010

Since October 2008, Pilkington has experienced a significant economic downturn that forced a delay in their planned furnace rebuild and the associated installation of emission controls. As a result, Pilkington ’s current facility c annot meet the Tier 3 emission standards by the 2011 deadline without installation of additional emission control equipment in conjuncti on with a furnace rebuild. The interim Tier 3 NOx limit provides no real transition period because there is no intermediate technology that will allow Pilkington’s furnace to achieve the Tier 3 limit, othe r than the technology required to achieve the lower Tier 4 limit. As pr eviously stated, Pilkington requested an adjustment to the complianc e schedule in order to allow continued operation of the Lathrop facility with the 100 associated jobs.

IV. CURRENT RULE 435 4 AND PROPOSED AMENDMENTS

A. Current Rule 4354

Rule 4354 was adopted in September 1994, a nd it was amended in April 1998, February 2002, August 2006, and October 2008. The rule applies to any glass melting furnace. The rule exempts electric glass furnaces, glas s furnaces that are lo cated at a stationary source with a total potential to em it, for all processes, of at less than ten tons per year of NOx or less than ten tons per year of vo latile organic compounds (VOC). The current rule limits emission of NOx, VOC, car bon monoxide (CO), and SOx. The emission limits depend on type of glass produced, fu rnace firing technology and emission averaging period. The current Tier 2 NOx emission limits range from 4.0 to 9.2 pounds NOx per ton of glass pulled (lb/ton glass); CO limits are 300 ppmv or 0.9 to 1.0 lbs/ton glass; and VOC emission limits are 20 ppmv or range from 0.1 to 0.25 lbs/ton glass. Operators meet current emissi on limits through a selection of furnace firing technology and glass raw materials. The future emission limits that will take effect beginning 2011 through 2018 range from 1.5 to 3.2 lbs NOx/t on glass, depending on the type of glass furnace and the compliance option chosen by the operator. The PM 10 limit which will take effect in 2011 is 0.5 lb/ton glass for all types of glass furnaces . The SOx limits that will take effect in 2011 range from 0.9 to 1. 7 lb/ton glass, depending on the type of glass furnace and firing technology. For detailed r equirements, please refe r to current Rule 4354, which is available on the Distri ct’s website at www.valleyair.org.

B. Proposed Amendments to Rule 4354

The main objective of this rule project is a llow flat glass manufacturers to eliminate the Tier 3 NOx emission limits provided they meet the early enhanced emission limits by January 2014. The current rule also require s that the flat gla ss manufacturers would

meet low SOx and PM2.5 limits by January 2011. For flat glass manufacturers that choose the Tier 4 early enhanced option, co mpliance with the SOx and PM limits would be deferred until January 2014, which is the same date as the Ti er 4 early enhanced option compliance date. Revisions were made throughout the rule to accommodate the inclusion of the flat glass early enhanced compliance option. These changes include

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Final Staff Report: Rule 4354 (Glass Melting Fur naces) September 16, 2010

language modifications in the m onitoring and recordkeeping sections to match the Tier 4 early enhanced option compliance date.

1. Section 5.1 NOx Emission Limits

The table in Section 5.1 of the rule would be revised to include the flat glass Tier 4 “early enhanced” NOx lim its as shown below.

Table 2 - NOx Emission Limits in pounds NOx per ton glass produced

Type of Glass

Produced Tier 2 NOx

limit Tier 3 NOx limit Tier 4 NOx limit Standard Option Tier 4 NOx limit

Enhanced

Option

Container Glass 4.0 A 1.5 B not available not available

Fiberglass 4.0 A 1.3 A, C

3.0 A, D not available not available

Flat Glass Standard Option 9.2 A

7.0 B 5.5 A

5.0 B 3.7 A

3.2 B 3.4 A

2.9 B

Flat Glass Enhanced Option 9.2 A

7.0 B 5.5 A

5.0 B 3.4 A

2.9 B

Flat Glass Early Enhanced Option 9.2 A

7.0 B not available 3.4 A

2.9 B

A

Block 24-hour average

B Rolling 30-day average

C Not subject to California Public Resources Code Section 19511

D Subject to California Public Resources Code Section 19511

2. New Section 5.1.4

This new provision would require a flat gla ss operator who commits to meet the Tier 4 early enhanced option NOx limits to demonstrate complianc e with the limits according to the deadlines specified in new Section 7.2.2 (i .e., by January 1, 2014). After January 1, 2011, an operator who commits to meet t he flat glass early enhanced NOx limits schedule is not eligible to choose a di fferent compliance option and applicable

deadlines.

3. Section 5.3.2 (SOx Requirements)

The existing language in Section 5.3.2 perta ining to SOx emission requirements would

be reworded to make them consistent wit h the existing language on NOx requirements

in current Section 5.1.1. Because this sect ion would also indicate that the SOx limit compliance deadlines are specified in Section 7.0, Table 3 (SOx emission Limits) would be modified to remove the compliance date in the table.

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Final Staff Report: Rule 4354 (Glass Melting Fur naces) September 16, 2010

4. Section 5.4.1 (PM10 Requirements)

The existing language in Section 5.4.1 perta ining to PM10 emission requirements would

be reworded to make them consistent wit h the existing language on NOx requirements

in current Section 5.1.1. Because this sect ion would also indicate that the SOx limit compliance deadlines are specified in Sect ion 7.0, Table 4 (P M10 Emission Limits)

would be modified to remove the compliance date in the table.

5. Section 5.9.3 (SOx Monitoring) and Section 5.9.4 (PM Monitoring)

Language would be added so that flat glass manufacturers that opt for the Tier 4 early enhanced option would not be subject to moni toring for SOx and PM until they become subject to the specific emission limits.

6. Section 6.1 (Permitted Glass Produc tion Capacity and Fuel Use Capacity)

Section 6.1 would have an outdated provis ion and compliance date removed. The provision to allow fuel-use capacity as a permit condition was retired in 2009 and fuel use capacity was removed fr om the section title.

7 New Section 7.2.1

This new section would indicate that a flat glass operator, who does not commit to the Tier 4 early enhanced option in Section 5. 1 Table 1 would need to comply with the existing compliance deadlines specified in renumbered Sections 7.2.1.1 through 7.2.1.6 to meet flat glass Table 1 Tier 3, Tier 4 standard opt ion, and Tier 4 enhanced option
NOx limits.

8. New Section 7.2.2

This new section would specif y the following requirements and compliance schedules for a flat glass operator who commits to the m eet Section 5.1 Table 1 Tier 4 early enhanced option limits.

• By November 1, 2010, oper ators would need to subm it a letter signed by a responsible official, which contains spec ific information specified in Sections 7.2.2.1.1 through 7.2.2.1. 4 of the proposed rule.

• By June 1, 2012, operators would need to submit a completed application for Authority-to-Construct for any flat glass furnace modifications to comply with the applicable NOx, SOx and PM10 emission limits.

• Full compliance with the Tier 4 early enhanced NOx limit, SOx limit; and PM10 limit by January 1, 2014 or by the next fu rnace rebuild, whichever is earlier.

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Final Staff Report: Rule 4354 (Glass Melting Fur naces) September 16, 2010

VI. BASELINE EMISSIONS AND ESTIMATED EMISSION REDUCTIONS

District staff has considered the potential effects on other flat glass manufacturers as well as whether the proposal affects the Distr ict’s ability to meet the attainment dates committed to by the Board in the 2007 8- Hour Ozone Plan and the 2008 PM2.5 Plan. Additionally, whether the proposal has a net benefit to Valley residents would also be a part of the assessment.

A. Baseline Emissions and Es timated Emission Reductions

Although the rule was amended in 2008, as dire cted by the District’s Governing Board,

the rule was not submitted to EPA for inclus ion into the California State Implementation Plan (SIP). Because the amended rule was not submitted into the SIP, the reductions associated with the 2008 rule project have not been claimed for attainment demonstration purposes. Since this version of the rule will be submitted to EPA, the

District will claim the reductions from the 20 08 rule amendments as part of this rule project. Table 3 below summarizes t he estimated emissions and the estimated

emission reductions associated with the 2008 rule project. Details of the emission

calculations are included in Appendix B of t he staff report.

Table 3 – Estimated Emissions and Emission Reductions from 2008 Final Staff Report

Pollutant Claimed 2008 Baseline Emissions, tpd Claimed Emission Reduction, tpd

NOx

Container 2.66 1.16 Fiberglass 0.53 0.01

Flat Glass 4.80 2.11

Total NOx 7.99 3.28

SOx

Container 1.54 0.38 Fiberglass 0.02 0.00

Flat Glass 1.57 0.74

Total SOx 3.13 1.12

PM10

Container 0.38 0.02 Fiberglass 0.007 0.002

Flat Glass 0.59 0.08

Total PM10 0.98 0.11

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Final Staff Report: Rule 4354 (Glass Melting Fur naces) September 16, 2010

B. Impact of Proposed Amendments on Emissions from Other Flat Glass

Manufacturers

District staff considered the impact of the proposed amendments on flat glass

manufacturers other than Pilk ington, including any potentia l competitive disadvantage caused by the proposed amendments. There are two flat glass manufacturers besides Pilkington located in the District. One plant already meets the Ti er 4 NOx, SOx and

PM10 limits because of a rebuild in 2008. T he second facility is already meeting the

Tier 3 NOx and the 2011 SOx and PM 10 limits. It is not know at this time whether the second facility’s management will choose the Tier 4 standard or the Tier 4 enhanced option, however, at the time of the 2008 rule development project, they were leaning toward the Tier 4 enhanced optio n due to the furnace refractory being in good shape at mid-campaign. For these reas ons, the other flat glass m anufacturers are not expected to be affected by the proposed amendments to Rule 4354.

C. Impact of Proposed Amendments on District Attainment Strategies

NOx emission reductions are part of the control strategy fo r attaining the 8-hour ozone

standard and the PM2.5 standard. The following paragraphs describe the impact of changing the flat glass compliance dates from 2011 to 2014.

1. 2007 8-hour Ozone Attainment Plan

Computer modeling of the San Joaquin Air Basin for oz one ambient air quality standard
violations has determined that NOx emissi on reductions are far better at reducing ambient ozone levels than any other ozone prec ursor. Because glass melting furnaces operate 24 hours per day everyday of the year and combust a lot of fuel while the furnace operates at very high temperatures , they are a significant portion of the District’s stationary source NOx emission in ventory. The expected emission reductions from the ozone plan’s Rule 4354 control measure represent the second largest source
of NOx reductions for the plan, behind open burning. The glass furnace control measure estimated that beginning in 2008, 1. 2 tons per day of NOx would be reduced, climbing to 1.6 tons per day in 2012 and growing to 2.0 tons per day in 2023. Based on the information gathered during the 2008 Rule 4354 amendments project, the estimated
NOx emission reductions would be 1.2 tons per day beginning in 2008, which includes a flat glass plant and one furnace of a contai ner glass plant that underwent cold repair and came back into production mode in 2008.

Pilkington has pledged to rebuild in late 2013 and early 2014 to meet the Tier 4 early enhanced NOx limit, rather t han waiting until 2018. In accommodating Pilkington’s request, it is estimated that the NOx reductions from thei r furnace would be about 1.2 tons per day. This compares to the oz one plan control measure which estimates an additional 0.4 tons per day beginning in 2012.

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Final Staff Report: Rule 4354 (Glass Melting Fur naces) September 16, 2010

In the 2008 amendments to Rule 4354, Distric t staff estimated that there will be a reduction of 0.4 tons per day from a container glass facilit y in addition to the Pilkington reductions. The 0.4 tons per day of reductions are in additi on to the estimated 1.2 tons per day of reductions associ ated with a Pilkington rebuild.

The 2007 Ozone Plan predicts attainment in 2023, if the District implements all of its

control measures and finds additional NO x reductions. Amending Rule 4354 to accommodate Pilkington’s reque st would not change the Distr ict’s attainment date for

the 8-hour ozone standard.

2. 2008 PM2.5 Attainment Plan

For attainment of the PM2.5 standard, reductions in direct ly-emitted PM2.5 as well as the PM2.5 precursors of NO x and SOx are needed for the Distr ict to reach attainment. The plan did not estimate PM 2.5 or SOx reductions from the glass melting furnaces control measure. However, the NOx reductions and timing we re similar to the 8-hour ozone plan control measure. For comparing the NOx reductions for the PM2.5 control

measure and the rule amendment project, the discussi on from the PM2.5 plan is the same as outlined in the 8-hour ozone plan above.

In addition to the NOx reductions, District staff analyzed whether there were benefits associated with the timing of the Pilkington’s reductions. Table 4 shows the estimated emissions from the Pilkington facility if it were to be oper ated at 80% of its maximum glass-producing capacity under three scenarios: the current rule (Tier 4 standard and Tier 4 enhanced) and as proposed by Pilki ngton (Tier 4 early enhanced). Computer modeling for the 2008 PM2.5 At tainment Plan predicts t hat attainment can be demonstrated by 2014. In order to demonstrat e attainment, the District’s official air quality monitors must show no vi olations for three years prio r to the attainment date. The added NOx reductions from the proposed Tier 4 early enhanced occur just ahead of the PM2.5 attainment year of 2014 rather than afterwards, as would be expected if Pilkington opted for the Tier 4 enhanced option.

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Final Staff Report: Rule 4354 (Glass Melting Fur naces) September 16, 2010

Table 4 – Pilkington Annual NOx Emissi ons at 80% of Maximum Glass Capacity

Current Rule Pilkington Calendar Year Tier 3 plus

Tier 4 standard Tier 3 plus

Tier 4 enhanced No Tier 3 plus Tier 4 early enhanced

2010 (Tier 2 – base) 766.5 766.5 766.5

2011 547.5 547.5 766.5

2012 547.5 547.5 766.5

2013 547.5 547.5 766.5

2014 350.4 547.5 317.6

2015 350.4 547.5 317.6

2016 350.4 547.5 317.6

2017 350.4 547.5 317.6

2018 350.4 317.6 317.6

Total NOx Emissions (2011 – 2018), tpy 3,394.5 4,150.1 3,887.3

During the 2008 rule amendment pr oject, District staff estima ted that the bulk of the

SOx emission reductions would be from a furnace that had undergone rebuild during the rule project and that those reductions w ould be about 0.63 tons per day. Pilkington and container glass furnaces would contri bute another 0.28 tons per day of SOx reductions. If the complianc e date for meeting the SOx and PM2.5 limits were revised for flat glass furnace, moving the date from 2011 to 2014, the calculated attainment date for the PM2.5 standard would not be affected. The expected 0.4 tons per day of NOx

emission reductions is less than 0.3% of t he total cumulative emissions for the 2012 milestone year. Based on the small fraction of additional NOx reductions from glass furnaces of the total emission reductions, it is not expected that the PM2.5 air quality

standard attainment date w ould be affected.

3. Reasonable Further Progress Dem onstration of the 2008 PM2.5 Plan

The federal Clean Air Act (Act) requires that attainment plans m eet reasonable further progress (RFP) by achieving incremental emi ssion reductions to ensure attainment of
the National Ambient Air Qua lity Standards by the attainm ent date. The Act does not identify specific emission reduction benchmar ks that must be met for PM attainment plans. EPA has interpreted the Act’s RFP r equirement using the concept of achieving (generally) linear progress toward the st andard. The District’s 2008 PM2.5 Plan

contains an RFP demonstrati on. For the PM2.5 attainm ent strategy, glass melting
furnace emission reductions from SOx and di rectly-emitted PM2.5 were not quantified and therefore not part of t he reductions in the RFP. The proposed delay in implementing the SOx and direct ly-emitted PM2.5 from glass melting furnaces will have no effect on the RFP. However, the ru le amendments will increase the cumulative

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Final Staff Report: Rule 4354 (Glass Melting Fur naces) September 16, 2010

emission reductions achieved in the milestone years by including emission reductions beyond what was estimated at the time of the 2008 PM2.5 plan’s adoption.

The flat glass Tier 3 NOx im plementation date for the curr ent rule is January 2011 with Tier 4 NOx standard option having a J anuary 2014 compliance date and Tier 4 enhanced option having a January 2018 compli ance date. Removing the Tier 3 NOx reductions from the Pilkingt on furnace would affect only the milestone year of 2012 because the Tier 4 early enhanced option wo uld require that the furnace be in compliance by January 1, 2014 and as a result, the emission reductions would occur the milestone year of 2014. The control measure for glass melting furnaces in the

PM2.5 Plan states that about 0.4 tons per day of NOx woul d come from furnaces that are not at the lowest app licable NOx limit an d that the lowest limit would be implemented starting in 2012. The expect ed 0.4 tons per day of NOx emission

reductions is less than 0.3% of the total cumulative emissions for the 2012 milestone year. Based on the small fracti on of the total emission reducti ons from glass furnaces, it is not expected that t he RFP would be affected.

4. Impact of Proposed Amendments on Attainment of Ambient Air Quality

Standards

Based on the analysis above, District staff fi nds that the change in compliance dates for a single flat glass furnace will not affect the District’s attainment date of either the ozone

standard or the PM2.5 standard. As a benef it, the initial Tier 4 early enhanced reductions would take place during ke y years of demonstrating attainment.

VII. EMISSION CONTROL TECHNIQUES

Operators can control air emi ssions either by controlling i nputs to the process or by treating the exhaust from the process. Pr ocess inputs for glass melting furnaces include raw materials, fuel, and combustion air. Post-combustion control techniques depend on the pollutant to be controlled. The following paragraphs outline potential ways that operators of glass me lting furnaces can reduce fu rnace exhaust emissions of NOx, SOx, and PM.

A. NOx Emission Control Techniques

On the inlet side of the glass furnace, NOx is generated from nitrogen-containing materials entering the furnace. The nitrogen (N 2 ) and oxygen (O 2 ) in ambient air can combine to form NOx at the high temper ature. This phenomenon is called “thermal NOx.” Since high temperatures are required to melt raw materials to form glass, thermal NOx in the exhaust of glass melting furnaces is expected. There are several combustion practices that form less therma l NOx. Operators may also choose to

control NOx on the outlet side of the process, i.e., run the glass furnace to optimize the product, and then deal with the generated NOx in the furnac e’s exhaust stream.

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Final Staff Report: Rule 4354 (Glass Melting Fur naces) September 16, 2010

1. Raw Materials

One of the ingredients in glass is a refining agent. The purpose of a refining agent is to remove bubbles of gas, known as seeds, from the glass melt. Niter (sodium nitrate,

chemical formula Na 2 NO 3 ) is a commonly used refining agen t. A little over half of niter

converts to NOx and leaves the furnace in t he exhaust gas. Therefore, the use of niter as a refining agent is balanced against the melting furnace’s total NOx emissions allowed by permit. Operators may substitute a different re fining agent, called saltcake (sodium sulfate, chemical formula Na 2 SO 4 ), to reduce NOx emissions. The replacement is not without its own set of c hallenges. The operator may not be able to exchange saltcake for niter wit hout substantially changing the glass recipe. Adding to

the consideration is the fact t hat at least some of the saltca ke leaves the molten glass to
become SOx emissions.

2. Control of the Combustion Process

Commercial natural gas is very low in ni trogen-containing material and all active furnaces in the District are firing on commerc ial natural gas as a primary fuel. This means that nitrogen contained in the fuel is not a significant source for NOx.

Operators can modify the com bustion process either by c hanging the configuration of the burner to reduce peak flame temperature or change the composition of the

combustion air to reduce t he amount of nitrogen gas (N 2 ) available for conversion to NOx. Thermal NOx formation increases exp onentially as a function of a burner’s peak flame temperature. Therefor e, lowering the peak flame temperature can significantly

reduce NOx formation. Burner manufactu rers have designed low-NOx burners that increase the zone where combustion takes plac e, thereby lowering the temperature of the flame at any given point. Lower fl ame temperatures means less thermal NOx created per unit of fuel burned. Besides low-NOx burners, operators can use electrodes submerged in the molten glass to “boost” t he amount of heat added to the materials. The electric boosters generate no additional NO x, since they do not come in contact with air. However, District operators consider heat from elec tricity expensive relative to heat generated by burning fossil fuels, so the use of electrodes within the District is perceived as cost-prohibitive.

Ambient air (the air around us) is about 79% nitrogen (N 2 ) and 21% oxygen (O 2 ). If the operator changes the proportion of N 2 in the air used for fuel burning (combustion air) by increasing the concentration of O 2 , the amount of NOx that could form would be

reduced because there is less N 2 available to react. A partial replacement of N 2 with O 2 is called “oxygen-assisted” firi ng – total replacement is “oxy-f uel” firing. Replacing some

or all of the N 2 in combustion air with O 2 is not without cost. Most operators who convert to their furnaces to oxy- fuel or oxygen-enhanced firing have an O 2 -generating gas plant built on their property to support th e needs of the glass-melting furnace. On the other hand, oxy-fuel furnaces don’t heat the inert nitrogen found in ambient air, and therefore, the process uses so mewhat less fuel to melt the same amount of glass as air-

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fuel furnaces. This means that operator s can partially offset the cost of O 2 -generation through more efficient fuel usage.

3. Post-Combustion Techniques

Post-combustion control is the final place where operators can redu ce NOx emissions. Add-on controls increase the complexity of the process by virtue of being another system that the operator must monitor and maintain. Glass manufacturers face challenges with post-combustion controls. Si nce the furnace exhaust temperature is high, special care must be taken to design an appropriate control system.

Controlling NOx thr ough add-on controls offers one im portant advantage to operators. With add-on controls, the operator can c hoose the raw materials and furnace firing technology that make the most sense for the operations yet still meet low emission limits. Post-combustion control, however, does carry one main disadvantage – extra costs. These costs are significant one-ti me capital costs and on-going additional operating expenses. Since add-on controls are a separate system from the glassmaking portion of the process, maintenance of the emission cont rol system can add complexity to overall manufacturing operati ons. Also, add-on controls may have some indirect effects on the glass-making process. Some examples of these indirect effects

are that the furnace exhaust temperature or certain raw materials may have to be

different in order to run t he add-on control efficiently.

Selective catalytic reduction (SCR) is one type of post-combustion emission control

used in other industries to control NOx em issions on combustion exhaust streams. SCR works by passing the post-combustion exhaust stream through a catalyst bed. The catalyst promotes the reaction of NOx back to N 2 and O 2 . The catalyst is effective only in a narrow temperature r ange, and the exhaust stream mu st be relatively free from particulates and sulfur-containing compound s before the stream passes through the catalyst. To date, the use of SCR has been established at glass-making facilities in Europe and Asia, but it has not been used he re in the United States. One District facility has recently installed a SCR on its glass-melting furnace, but has operated the unit only a few months.

Selective non-catalytic reduction (SNCR) is a second type of post-combustion emission

control used in other industries. The use of SNCR is not a widely adopted practice in the glass industry and it is not expected that operat ors within the District would use this technology to control NOx emissions.

The 3R process, developed by Pilkington Glass Limited, is a proprie tary, low-NOx firing technology. The process injects various hy drocarbon fuels into the furnace waste gas stream as the agent to reduce NOx to nitr ogen and water vapor. Since the control of NOx occurs within the furnace’s regenerator s (checker packs), the 3R process can be considered a hybrid between combustion control and add-on cont rol. The treatment is after combustion, since the fuel is inject ed into the furnace exhaust. However, the

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reaction does not take place in a separate unit, so the 3R proce ss is not, technically speaking, an add-on control. While flat gl ass furnace operators can expect to rebuild checker packs at the same rate as the gla ss melting furnace (every 15 years or so), some facilities utilizing the 3R process have ex perienced early failure of the refractory (insulation) within the checker packs, forcin g rebuilds of the checker pack much sooner than the melting furnace.

B. SOx Emission Control Techniques

Within the glass-making process, there are th ree sources of SOx. The sources are fuel, raw material, especially a refining agent ca lled saltcake (sodium sulfate, chemical

formula Na 2 SO 4 ), and gaseous SO 2 used in the annealing oven (lehr). As noted below,

the sulfur that becomes SOx emissions enter s a glass-melting furnace with either the

fuel or the raw materials.

1. Fuel and Raw Materials

Natural gas is a low-sulfur fuel, therefore fuel is not a significant source of sulfur in the

furnace exhaust. For furnaces fired on natur al gas, controlling sulfur emissions on the input side of the process means controlling the use of saltcake. Replacing all or part of saltcake with alternative refining agent can create as many challenges as it solves. Arsenic trioxide is, by far, the best refining ag ent. However, it is seldom used in largescale glass making because of the inherent to xicity of compounds containing arsenic. Sodium nitrate (niter) is another commonly used refining agent. Niter must be stored and handled appropriately for safety considerati ons; niter is not as good as saltcake at stabilizing colorant ions for certain gla ss chemistries; and, at glass melting temperatures, niter dissociates to form NOx. All these facts, ta ken as a whole, mean that replacing saltcake as a raw material is not a straightforward substitution.

2. Annealing Oven (Lehr)

A third source of SOx emissions is within the anneali ng section of the flat-glass production. Sulfur dioxide gas (SO 2 , one form of SOx) may be pumped into the annealing oven (lehr), either to prevent surf ace staining of the glass or to form a protective coat on the rollers that pull the glass through the process. The portion of SO 2 that does not adhere to the glass surface or roller surface exits the process with the lehr’s exhaust gas. The lehr does not melt materials to make glass, and, therefore, is not directly subject to Rule 4354. Howeve r, the design of the glass manufacturing line may be such that the lehr exhaust gases go through the glass-melting furnace and exit the process with the furnace exh aust. If the lehr in a glass -making process for flat glass is designed to exhaust into the glass-melt ing furnace, the lehr exhaust becomes a source of SOx to the glass-melting furnace. To reduce SOx emissions in the furnace by controlling the SO 2 level in the lehr can be problematic. The SO 2 concentration in the lehr is optimized for best glass proce ssing, and making large changes in the SO 2

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concentration to meet emission limits may be detrimental to maintaining glass quality and processing efficiency.

3. Post Combustion Control

If an operator determines that inlet-side contro l technique is not feasible or that the changes are not practical, there are control devices for removing SO x from the exhaust side of the process such as scrubbers. Scru bbers are air pollution control devices that use an absorbent to remove aerosol and gaseous pollutants from an air stream. The gases are removed either by absorption or chemical reaction. There are two types of scrubbing suitable for glass manufa cturers: dry and semi-dry (in other industries, this type of scrubber is sometimes called semi-wet). The reaction principles are the same for both types of scrubbers. A reactive material (the absorbent) is introduced to and dispersed in the exhaust stream. The absorbent reacts with the SO x species to form a solid, which has to be removed from the exhaus t stream by a bag filter system or an electrostatic precipitator ( EP). It makes economic sense for some glass manufacturers to reuse a portion the collected dust as a raw material, rather than disposing of it. The collected EP dust is high in sulfates, so the recycled dust may replace at least some of the purchased saltcake in the glass recipe.

C. Particulate Matter (PM) Emission Control Techniques

The airflow through a glass melting furnac e can be on the order of 30,000 standard cubic feet per minute. With airflow this high, un-melted raw material in the furnace can

be lifted off the surface of t he molten glass to go directly into the furnace’s exhaust stream. Operators can infl uence the rate at which raw materials become directly emitted PM through raw materials specification, control of the raw material moisture at the point the material is delivered to the fu rnace, and design of the furnace’s material charging system. There are also end-of -pipe particulate control techniques.

1. Material Selection and Moisture Control

In selecting raw materials, operators take in to account the particle size of glass raw materials. Small particles are more easily li fted by airflow than larger particles, but are more easily melted. Material moisture also plays into how much material bypasses the melting process. It is best if material c ontains “enough” moisture to keep the material from being airborne, but not so wet as to affect glass production. In addition, the amount of recycled glass (cullet) in the reci pe plays a role. Cullet generally melts at a lower temperature than glass raw material and is more likely to have a larger particle size. The use of cullet may be limited by th e end-use quality requirements for the glass. For container glass and certain types of fiber glass, minimum cullet use is specified in the California Public Resources Code. Oper ators would balance all three elements to minimize directly emitted particula te through raw material selection.

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2. Furnace Material Charging System

Given that most glass melting furnaces are designed to produce hundreds of tons of glass per day, making sure that enough raw ma terials are fed into the furnace is an important consideration in fu rnace design. Particulate control through raw material

selection and moisture content could be moot if the furnace’s material charging system facilitates the material becoming airborne. The design of the material charging system is constrained by engineering principl es and production requirements.

3. Raw Material Volatilization

Raw materials can be made gaseous at the high temperatures associated with glass melting furnaces. These volatilized mate rials can condense on surfaces or form particulate and exit the fur nace with the exhaust gases. Operators can control raw material volatilization by covering the molt en glass with un-melted raw material and by minimizing the furnace temperature.

4. Post Combustion Control

Post-combustion particulate control is of two types: filters and electr ostatic precipitators (EPs). Filters used for high airflow situatio ns are grouped together into what is called a baghouse. In most cases, glass melting furnace operators opt for EPs, since the temperature of the furnace exhaust is too high for most filter materials.

VIII. COSTS AND COST EF FECTIVENESS ANALYSIS

The California Health and Safety Code 40920.6 (a) requires District staff to conduct a cost effectiveness analysis of available emis sion control options prior to adopting each Best Available Retrofit Control Technology (BARCT) rule. Since the proposed rule modifies certain compliance dates and does not change existing emission limits, the requirement to perform a cost e ffectiveness analysis does not apply.

IX. SOCIOECONOMIC IMPACT ANALYSIS

Pursuant to state law, District staff is required to perform a socioeconomic impact analysis prior to adoption, amendment, or repeal of a rule that has significant impacts on air quality or that will str engthen emission limitations. The proposed amendments to Rule 4354 are only intended to provide flat glass manufacturers with an option to defer compliance with the Tier 3 emission limits pr ovided they comply with the early enhanced emission limits four years sooner than woul d have been required to comply with the enhanced option emission limits. Because of this, the requirement to perform a socioeconomic impact analysis does not apply.

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X. ENVIRONMENTAL IMPACTS

Global Climate Change (GCC), which is no w generally accepted by the scientific community to be caused by GHGs, is a widely discussed scientific, economic, and political issue in the United States. Briefly stated, GCC is the cumulative change in the average weather of the earth that may be measured by changes in temperature, precipitation, storms , and wind. Gases t hat trap heat in the atmosphere are called greenhouse gases; they act in the atmosphere in a manner analogous to the way a greenhouse retains heat. Common GHG include wa ter vapor, carbon dioxide, methane, nitrous oxides, chlorofluorocarbons, hydr ofluorocarbons, perfluorocarbons, sulfur hexafluoride, ozone, and aerosols. Some greenhouse gases such as water vapor occur naturally and are emitted to the atmosphere th rough natural processes as well as through human activities, such as electricity production, vehicle use, etc. The most common GHG that results from human activity is carbon dioxide, followed by methane

and nitrous oxide.

The proposed amendments to Rule 4354 only move the compliance date of final implementation for one facility. The propos ed rule amendments will not affect the meaning, scope of, or prohibitions contained in current rule language. The District’s analysis demonstrates that implementing the proposed amendments would not affect the existing emission limits that have been in place since 2008. Furthermore the analysis demonstrates that t he project has the potential to reduce criteria pollutant emissions, thus having a positive impact on air quality. There is no evidence before the District that indicates that the projec t would result in increased greenhouse gas emissions. Thus, the District concludes that the project would not have a cumulatively significant impact on global climate change.

Based on the lack of evidence to the contra ry, District staff has concluded that the proposed amendments to the rule s will not have any signific ant adverse effects on the environment. The proposed amendments to Rule 4354 have undergone environmental review in accordance with the requirement s CEQA. A proposed negative declaration has been issued by the District and made ava ilable for public review and comment. Upon approval of this project, a Negative Declarati on will be filed.

XI. RULE CONSISTENCY ANALYSIS

Prior to adopting, amending, or repealing a ru le or regulation, California Health and Safety Code Section 40727.2 requires a writt en analysis that identifies and compares requirements of the proposed rule with corr esponding, existing and proposed District rules and corresponding United St ates Environmental Protection Agency (EPA) rules, regulations, and guidelines. Based on the anal ysis, District staff concludes that the proposed amendments to Rule 4354 are consistent with other District rule s and are not in conflict with these rules. Further, the propo sed rule amendments are consistent with EPA

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rules, regulations, and guidelines that apply to the same source category. Th e analysis is presented in Appendix C of th e Final Draft Staff Report.

**XII. REASONABLY AVAILABLE CO NTROL TECHNIQUES (RACT) ANALYSIS** 

The Clean Air Act (CAA) Section 182(b)(2) states that ozone attainment plans shall

assure that RACT for volati le organic compounds (VOC) is applied at certain sources. Section 182(f) extends federal RACT requirements to NOx rules and major NOx

sources. NOx emission reductions are included in the District’s 2007 Ozone Plan for

Rule 4354 and were included in the 2008 vers ion of the rule. The 2008 NOx emission limits are among the most stri ngent limits for this source category. As such, they constitute a level above “reasonably available” control technology.

XIII. REFERENCES

1. Final Draft Staff Report, “Re-evaluat ion of the October 2008 Amendments to Rule 4354”, April 15, 2008.

2. Governing Board Memorandum, “Revie w Report on Re-Evaluation of October

2008 Amendments to Rule 4354 (Glass Meting Furnaces) and Authorize the APCO to Develop Future Rule Amendments”, April 15, 2010

3. SJVUAPCD Rule 4354 (Glass Melti ng Furnaces), Amended October 16, 2008.

4. Pilkington North America’s Comm ent Letter on SJVUAPCD Rule 4354 ReEvaluation, January 7, 2010.

5. District Project No. CEQA 20080357 (Ini tial Study and Negative Declaration for

Draft Amendments to Rule 4354), August 18, 2008.

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