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Appendix B: Emission and Emission Reductions Augus t 21, 2008

B-1 Final Draft Staff Report with Appendices

for Proposed Amendments to Rule 4354 

# APPENDIX B

BASELINE EMISSIONS AND EMISSION REDUCTION

ANALYSIS FORPROPOSED AMENDMENTS TO RULE 4354 (GLASS MELTING FURNACES)

August 19, 2010SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

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## Baseline Emissions and Emission Reduction Analysis for

Proposed Amendments to Rule 4354

I. SUMMARY

The purpose of this analysis is to estimate the oxi des of nitrogen (NOx), oxides of sulfur (SOx), and particulate matter with aerodynamic diam eter of 10 micrometers or less (PM10) emission reductions for the proposed amendme nts Rule 4354 (Glass Melting Furnaces) and to outline the methodologies used to calculate the emission reductions. This analysis also includes the assumptions made fo r the calculations. Because the

2008 version of the rule was not submitted to the U S environmental Protection Agency as a California State Implementation Plan (SIP) rev ision, the emission reductions from those amendments could not be counted as part of th e District’s attainment strategy. If approved by the Governing Board, District staff wil l submit the proposed rule as a SIP

revision and therefore the emission reductions were calculated as the difference between the proposed emission limits and the 2006 b aseline inventory.

Table 1 summarizes the estimated emission reduction s from each of these pollutants compared to the 2006 version of the rule. The calc ulation methodology is outlined in Section II of this appendix. When fully implemente d, the proposed amendments are estimated to have a total of about 3.3 tons per day (tpd) of NOx emission reductions,

which is about a 41% reduction to the current emiss ion baseline of 8.0 tons NOx per day. SOx emission reduction is estimated at 1.1 tp d (about 36% of baseline emission inventory) and PM10 would be reduced by about 0.11 tpd (about 10% of baseline emission inventory).

For the proposed change in the compliance schedule, District staff estimates that Pilkington would reduce their NOx emissions an addi tional 0.09 tons per day by committing to the Tier 4 early enhanced option rath er than the Tier 4 standard option. This additional emission reduction brings the NO em ission reductions for flat glass manufacturers to 2.2 tons per day and the total NOx reductions to 3.37 tons per day.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

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for Proposed Amendments to Rule 4354 Table 1 – Summary of Emissions and Estimated Emissi on Reductions

Pollutant Claimed 2008 Current Emissions tpd Claimed Emission Reduction tpd

NOx

Container 2.66 1.16
Fiberglass 0.53 0.01

Flat Glass 4.80 2.11

Additional reductions Tier 4 early enhanced Not applicable 0.09

Total NOx 7.99 3.37

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

II. EMISSIONS AND EMISSION REDUCTION METHODOLOGY

This section of the report outlines the procedures used to calculate the current

emissions and the estimated emission reductions ass ociated with the proposed amendments to Rule 4354 (Glass Melting Furnaces). Each pollutant is addressed separately.

A. NOx Emissions and Emission Reduction Methodology

District staff used the results of 2006 source test s to calculate the current NOx emissions from glass melting furnaces. Source test emissions were reported in pounds per hour. It was assumed that the emission rate du ring the source test was typical of the operation on a 24-hour basis.

Current Emissions = (2006 Source Test Results in lb /hr * 24 hrs/day) / 2,000 lb/ton

For two flat glass furnaces, their source test emis sions are above the Tier 2 NOx limits. The emission reductions associated with the change from Tier 1 to Tier 2 NOx limits have already been claimed in a previous rule develo pment project. The currentSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

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for Proposed Amendments to Rule 4354 emissions were calculated by using the 30-day Tier 2 NOx limit and multiplying by the either the source test pull rate or 80% of the glas s production capacity depending on whether the source test report included the pull ra te during source testing.

For associated emissions after the Tier 3 NOx emiss ion limits are fully implemented,

District staff assumed that the furnaces would be o perated, on average, at 80% of permitted glass production capacity. For the facil ity that has heat input as the limiting permit condition, District staff assumed that the m aximum glass production corresponding to the highest heat input is 1,800 to ns glass produced per day.

After Implementation Emissions = (Proposed limit in lb/ton glass * 80% * permitted glass production capacity in tons glass/day) / 2,000 lb/t on

Claimed emission reductions are the difference betw een the current emissions claimed for this rule project minus the emissions after rul e implementation.

Claimed Emission Reduction = Current Emissions – Af ter Implementation Emissions

B. SOx Emissions and Emission Reduction Methodology

The calculations for SOx emissions are similar to t he NOx emissions calculations

above. District staff used results of recent sourc e tests to calculate the current SOx emissions from glass melting furnaces. Source test emissions were reported in pounds per hour. It was assumed that the emission rate du ring the source test was typical of the operation on a 24-hour basis. Emissions from g lass melting furnaces after implementation were calculated by multiplying the p roposed emission limit by the assumed average production rate of 80% of the permi tted glass production capacity. For the facility that has heat input as the limitin g permit condition, District staff assumed that the maximum glass production corresponding to the highest heat input is 1,800 tons glass produced per day. Emission reductions w ere calculated as the difference

between the current emissions and the emissions aft er rule implementation. See the equations in Section II.A above for the form used f or SOx emissions.

C. PM10 Emissions and Emission Reduction Methodolog y

Particulate matter source test results were reporte d as PM, PM10, or both. For those source test results with PM only, District staff as sumed that all PM is PM10 when

calculated the current PM10 emissions. For sources reporting PM and PM10 emissions, District staff used only the PM10 test r esults in calculating current emissions. Emissions from glass melting furnaces after impleme ntation were calculated by multiplying the emission limit by the assumed avera ge production rate of 80% of the permitted glass production capacity. For the facil ity that has heat input as the limiting permit condition, District staff assumed that the m aximum glass production corresponding to the highest heat input is 1,800 to ns glass produced per day. PM10 emission reductions were calculated by taking the d ifference between the currentSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

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for Proposed Amendments to Rule 4354 emissions and the after-implementation emissions. See the equations in Section II.A

above for the form used for PM10 emissions.

III. BASELINE EMISSIONS AND EMISSION REDUCTION ANAL YSIS

Table 1 above summarizes the results of using the m ethodology outlined in Section II. The following paragraphs discuss the results of app lying the methodology to the individual glass melting furnaces subject to this r ule. It is important to note that the emission reductions claimed in this appendix are di fferent than those used to calculate cost effectiveness in Appendix C of this staff repo rt. One container glass furnace and one flat glass furnace have emission reductions tha t District staff is claiming for emission inventory purposes. These emissions, howe ver, have no compliance costs that can be linked to this rule project because the operators are making the changes to their furnaces in response to requirements not rela ted to this rule project.

A. NOx Emissions and Claimed NOx Emission Reduction s

There are three furnaces whose NOx emission calcula tion is different than outlined in Section II. Two of those furnaces are flat glass f urnaces. These furnaces did not meet the Tier 2 NOx emission limit during their 2006 sou rce test. The emission reduction for these furnaces going from Tier 1 to Tier 2 limits h ave already been claimed on the 2002 rule amendment project. For purposes of the curren t proposed amendments, the

current emissions from these furnaces are assumed t o be the 30-day Tier 2 NOx emission limit of 7.0 pounds per ton glass pulled a nd the glass production rate is assumed to be 80% of the furnaces permitted glass p roduction capacity. This evaluation was performed to not count the emission reductions already associated with a previous rule project in the current rule project

.

One fiberglass furnace is not currently required to source test for NOx or SOx. For this facility, District staff assumed that the current e missions from the furnace were at the highest level allowed by the furnace’s permit. The re is one container glass facility with source test results that are below the proposed Tie r 3 NOx limit. Emission reduction from this facility is, therefore, zero.

The NOx emission reductions claimed for this rule p roject are 1.16 tons NOx per day for container glass; 0.01 tpd for fiberglass; and 2.11 tpd for flat glass furnaces yielding total estimated NOx emission reductions of 3.28 tons per day. These results are shown in

Table 2 below.

B. Additional NOx Reductions from Tier 4 Early Enha nced Option

District staff estimated additional emission reduct ions that would occur when Pilkington elects to comply with the Tier 4 early enhanced opt ion rather than the Tier 4 standard option. Using the assumption that the furnace will operate at 80% of it maximum glassSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

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for Proposed Amendments to Rule 4354 production capacity, District staff estimates that an additional 32.8 tons per year of NOx emission reductions or about 0.09 tons per day.

C. SOx Emissions and Claimed SOx Emission Reduction s

Seven of the nine container glass furnaces have SOx emissions above the proposed emission limit – the fiberglass furnaces either mee t the proposed limit or emit very little SOx. As noted in Table 1, emission reduction from container furnaces will total about 0.38 tpd and fiberglass will have no emission reduc tions. District staff estimates that the flat glass furnaces will reduce SOx emissions by ab out 0.74 tons per day. A summary

of the calculations is shown in Table 2 below.

For emission inventory purposes, the District is cl aiming SOx emission reductions from one flat glass facility that is down for re-brickin g. However, the claimed SOx emission

reductions from this furnace will not be used for c alculating cost effectiveness in Appendix C of this staff report, since there are no costs that can be related to the proposed rule amendments. The SOx emission reducti ons used in Appendix C are 0.38 tpd for container glass and 0.11 tpd for flat glass

.

D. PM10 Emissions and Claimed PM10 Emission Reducti ons

One container glass furnace and two flat glass furn aces currently emit above the proposed PM10 limit. It is expected that emission reductions from implementing the proposed emission limit will total 0.10 tons PM10 p er day, with 80% of emission reduction coming from the flat glass furnaces and 2 0% coming from container and fiberglass furnaces. See Table 2 for details.

For emission inventory purposes, the District is cl aiming PM10 emission reductions from one flat glass facility that is down for re-brickin g and the PM10 emission reductions from the container glass furnace that source tested befo re its recent re-bricking. However,

the claimed PM10 emission reductions from these fac ilities will not be used for calculating cost effectiveness in Appendix C of thi s staff report, since there are no costs to these operations related to the current rule pro ject. For cost effectiveness calculations, District staff will use emission redu ctions of 0.0015 tpd for fiberglass and 0.02 tpd for flat glass. The container glass facil ities are already in compliance with the proposed limit as shown by source testing, therefor e, operators of container glass furnaces will not incur any costs due the proposed rule amendments.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICTAppendix B: Emission and Emission ReductionsAugust 21, 2008B-8Final Draft Staff Report with AppendicesFor Proposed Amendments to Rule 4354Table 2 – Details of Emission Reduction CalculationPollutantClaimed CurrentEmissions tpdEstimated Emissions AfterImplementation tpdClaimed EmissionReduction tpdClaimed EmissionReduction tpyNOxContainer 2.661.501.16424.1Fiberglass 0.530.520.014.1Flat Glass 4.802.692.11770.4Additional reductionsTier 4 early enhancedNot applicableNot applicable0.0932.7Totals for NOx7.994.703.281198.7SOxContainer 1.541.150.38138.8Fiberglass 0.020.020.0010.3Flat Glass 1.570.840.74268.5Totals for SOx3.132.011.12407.5PM10Container 0.380.370.026.9Fiberglass 0.0070.0050.0020.6Flat Glass 0.590.500.0830.3Totals for PM100.980.870.1140.2SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

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B-9 Final Draft Staff Report with Appendices

for Proposed Amendments to Rule 4354 IV. EMISSION REDUCTION IMPLICATIONS FOR TIER 4 EARL Y ENHANCED

COMPLIANCE OPTION

Although the 2008 version of the rule was not submi tted to EPA as a SIP revision, it is important to determine the effect of the proposed c hanges in compared to the 2008 version of the rule. Since the proposed rule amend ments only affect flat glass furnaces, only emissions from flat glass furnaces will be con sidered in this evaluation.

A. NOx Emissions

In determining the emission reductions in the Secti on III analysis, District staff assumed that each flat glass manufacturer would comply with the rule at the Tier 4 standard option NOx emission level and compliance date. Fla t glass furnace operators are not required to notify the District of which compliance option they will implement until January 2011. Based on the current permit conditio ns, District staff believes that the furnace operator currently permitted at Tier 3 will choose the Tier 4 early enhanced option and therefore, no emissions other than Pilki ngton’s will be considered for this

assessment.

Table 3 shows the estimated annual NOx emissions fr om Pilkington’s furnace from 2010 through 2018. The table assumes that the furn ace operates at 80% of its maximum capacity for the entire year. The estimate d NOx emissions from the Tier 3 plus Tier 4 standard option are the lowest over the time period 2011 through 2018 and highest for the Tier 3 plus Tier 4 enhanced option. The proposed change (no-Tier3 and Tier 4 early enhanced) is between the two current r ule options and offers lower NOx emissions 4 years sooner than the Tier 4 enhanced o ption.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

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for Proposed Amendments to Rule 4354 Table 3 – Pilkington Annual NOx Emissions 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

Based on the table above, District staff concludes that the proposed NOx compliance option would not significantly affect NOx emissions in the calendar years 2011 through 2018 compared to the NOx compliance options offered in the 2008 version of the rule.

B. SOx Emissions

Although District staff was unable to quantify the SOx emission reductions for the control measure for this source category in the 200 8 PM2.5 Plan, the rule project did

have some SOx emission reductions. The bulk of the claimed flat glass SOx emission

reductions came from a furnace that converted from fuel oil-fired to natural gas-fired. The fuel change emission reductions have already be en realized and are not part of the evaluation for the proposed rule. The other flat g lass furnace operator is already in compliance with the rule’s 2011 SOx limit.

District staff estimated that Pilkington would redu ce their SOx emissions by about 0.11 tons per day or 36.4 tons per year. By moving the compliance date, this rule project

would have 145.5 tons of SOx emissions. Because SO x is not an ozone precursor in the District’s air basin, the change in compliance date does not affect the District’s 2007 8-hour Ozone attainment strategy. Further, since t he SOx emissions were not included in the District’s 2008 PM2.5 attainment strategy, t here is no detrimental effect on the District’s progress toward attainment of the PM2.5 standard. The additional SOx reductions may allow cleaner air sooner in certain areas of the District, but the total amount of SOx reductions from glass melting furnace s would not be enough to affect the District’s estimated attainment year of 2017. For this reason, District staff believes that moving the compliance date for SOx for the Tie r 4 early enhanced from 2011 to

2014 would not affect the District’s attainment sta tus.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

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B-11 Final Draft Staff Report with Appendices

for Proposed Amendments to Rule 4354 C. Directly-Emitted PM Emissions

The 2008 rule project did have some PM emission red uctions, but the reductions were not quantified for the glass melting furnaces contr ol measure in the District’s 2008 PM2.5 Plan. The bulk of the claimed flat glass PM emission reductions came from a

furnace that converted from fuel oil-fired to natur al gas-fired (about 0.6 tons per day out of the total of 0.8 tons per day from all flat glas s manufacturers). The fuel change emission reductions have already been realized and are not part of the evaluation for the proposed rule. The remaining flat glass furnac e is already in compliance with the

PM10 limit.

Since the PM reductions are so small, the proposed change to the compliance date for the Tier 4 early enhanced option is not expected to affect the District’s attainment strategy for the PM2.5 air quality standard.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

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