SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Emission and Emission Reductions August 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, 2010 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Emission and Emission Reductions August 21, 2008 

B-2 Final Draft Staff Report with Appendices 

for Proposed Amendments to Rule 4354 

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SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Emission and Emission Reductions August 21, 2008 

B-3 Final Draft Staff Report with Appendices 

for Proposed Amendments to Rule 4354 

Baseline Emissions and Emission Reduction Analysis for 

Proposed Amendments to Rule 4354 

I. SUMMARY 

The purpose of this analysis is to estimate the oxides of nitrogen (NOx), oxides of sulfur 

(SOx), and particulate matter with aerodynamic diameter of 10 micrometers or less 

(PM10) emission reductions for the proposed amendments Rule 4354 (Glass Melting 

Furnaces) and to outline the methodologies used to calculate the emission reductions. 

This analysis also includes the assumptions made for the calculations. Because the 

2008 version of the rule was not submitted to the US environmental Protection Agency 

as a California State Implementation Plan (SIP) revision, the emission reductions from 

those amendments could not be counted as part of the District’s attainment strategy. If 

approved by the Governing Board, District staff will 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 baseline inventory. 

Table 1 summarizes the estimated emission reductions from each of these pollutants 

compared to the 2006 version of the rule. The calculation methodology is outlined in 

Section II of this appendix. When fully implemented, 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 emission baseline of 8.0 tons NOx per 

day. SOx emission reduction is estimated at 1.1 tpd (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 additional 0.09 tons per day by 

committing to the Tier 4 early enhanced option rather than the Tier 4 standard option. 

This additional emission reduction brings the NO emission 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 DISTRICT

Appendix B: Emission and Emission Reductions August 21, 2008 

B-4 Final Draft Staff Report with Appendices 

for Proposed Amendments to Rule 4354 

Table 1 – Summary of Emissions and Estimated Emission 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 associated 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 tests 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 during 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 emissions 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 development project. The current 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Emission and Emission Reductions August 21, 2008 

B-5 Final Draft Staff Report with Appendices 

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 glass production capacity depending on 

whether the source test report included the pull rate during source testing. 

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

District staff assumed that the furnaces would be operated, on average, at 80% of 

permitted glass production capacity. For the facility that has heat input as the limiting 

permit condition, District staff assumed that the maximum glass production 

corresponding to the highest heat input is 1,800 tons 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/ton 

Claimed emission reductions are the difference between the current emissions claimed 

for this rule project minus the emissions after rule implementation. 

Claimed Emission Reduction = Current Emissions – After Implementation Emissions 

B. SOx Emissions and Emission Reduction Methodology

The calculations for SOx emissions are similar to the NOx emissions calculations 

above. District staff used results of recent source 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 during the source test was typical of 

the operation on a 24-hour basis. Emissions from glass melting furnaces after 

implementation were calculated by multiplying the proposed emission limit by the 

assumed average production rate of 80% of the permitted glass production capacity. 

For the facility that has heat input as the limiting 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 were calculated as the difference 

between the current emissions and the emissions after rule implementation. See the 

equations in Section II.A above for the form used for SOx emissions. 

C. PM10 Emissions and Emission Reduction Methodology 

Particulate matter source test results were reported as PM, PM10, or both. For those 

source test results with PM only, District staff assumed 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 results in calculating current emissions. 

Emissions from glass melting furnaces after implementation were calculated by 

multiplying the emission limit by the assumed average production rate of 80% of the 

permitted glass production capacity. For the facility that has heat input as the limiting 

permit condition, District staff assumed that the maximum glass production 

corresponding to the highest heat input is 1,800 tons glass produced per day. PM10 

emission reductions were calculated by taking the difference between the current 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Emission and Emission Reductions August 21, 2008 

B-6 Final Draft Staff Report with Appendices 

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 ANALYSIS 

Table 1 above summarizes the results of using the methodology outlined in Section II. 

The following paragraphs discuss the results of applying the methodology to the 

individual glass melting furnaces subject to this rule. It is important to note that the 

emission reductions claimed in this appendix are different than those used to calculate 

cost effectiveness in Appendix C of this staff report. One container glass furnace and 

one flat glass furnace have emission reductions that District staff is claiming for 

emission inventory purposes. These emissions, however, 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 related to this rule project. 

A. NOx Emissions and Claimed NOx Emission Reductions 

There are three furnaces whose NOx emission calculation is different than outlined in 

Section II. Two of those furnaces are flat glass furnaces. These furnaces did not meet 

the Tier 2 NOx emission limit during their 2006 source test. The emission reduction for 

these furnaces going from Tier 1 to Tier 2 limits have already been claimed on the 2002 

rule amendment project. For purposes of the current proposed amendments, the 

current emissions from these furnaces are assumed to be the 30-day Tier 2 NOx 

emission limit of 7.0 pounds per ton glass pulled and the glass production rate is 

assumed to be 80% of the furnaces permitted glass production 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 emissions from the furnace were at the 

highest level allowed by the furnace’s permit. There is one container glass facility with 

source test results that are below the proposed Tier 3 NOx limit. Emission reduction 

from this facility is, therefore, zero. 

The NOx emission reductions claimed for this rule project 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 Enhanced Option 

District staff estimated additional emission reductions that would occur when Pilkington 

elects to comply with the Tier 4 early enhanced option rather than the Tier 4 standard 

option. Using the assumption that the furnace will operate at 80% of it maximum glass 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Emission and Emission Reductions August 21, 2008 

B-7 Final Draft Staff Report with Appendices 

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 Reductions 

Seven of the nine container glass furnaces have SOx emissions above the proposed 

emission limit – the fiberglass furnaces either meet 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 reductions. District staff estimates that the 

flat glass furnaces will reduce SOx emissions by about 0.74 tons per day. A summary 

of the calculations is shown in Table 2 below. 

For emission inventory purposes, the District is claiming SOx emission reductions from 

one flat glass facility that is down for re-bricking. However, the claimed SOx emission 

reductions from this furnace will not be used for calculating 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 reductions 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 Reductions 

One container glass furnace and two flat glass furnaces 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 per day, with 80% of emission 

reduction coming from the flat glass furnaces and 20% coming from container and 

fiberglass furnaces. See Table 2 for details. 

For emission inventory purposes, the District is claiming PM10 emission reductions from 

one flat glass facility that is down for re-bricking and the PM10 emission reductions from 

the container glass furnace that source tested before its recent re-bricking. However, 

the claimed PM10 emission reductions from these facilities will not be used for 

calculating cost effectiveness in Appendix C of this staff report, since there are no costs 

to these operations related to the current rule project. For cost effectiveness 

calculations, District staff will use emission reductions of 0.0015 tpd for fiberglass and 

0.02 tpd for flat glass. The container glass facilities are already in compliance with the 

proposed limit as shown by source testing, therefore, operators of container glass 

furnaces will not incur any costs due the proposed rule amendments. 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Emission and Emission Reductions August 21, 2008 

B-8 Final Draft Staff Report with Appendices 

For Proposed Amendments to Rule 4354 

Table 2 – Details of Emission Reduction Calculation

Pollutant 

Claimed Current 

Emissions tpd 

Estimated Emissions After 

Implementation tpd 

Claimed Emission 

Reduction tpd 

Claimed Emission 

Reduction tpy 

NOx Container 2.66 1.50 1.16 424.1Fiberglass 0.53 0.52 0.01 4.1Flat Glass 4.80 2.69 2.11 770.4

Additional reductions 

Tier 4 early enhanced Not applicable Not applicable 0.09 32.7

Totals for NOx 7.99 4.70 3.28 1198.7

SOx Container 1.54 1.15 0.38 138.8Fiberglass 0.02 0.02 0.001 0.3Flat Glass 1.57 0.84 0.74 268.5

Totals for SOx 3.13 2.01 1.12 407.5

PM10 Container 0.38 0.37 0.02 6.9Fiberglass 0.007 0.005 0.002 0.6Flat Glass 0.59 0.50 0.08 30.3

Totals for PM10 0.98 0.87 0.11 40.2
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Baseline Emissions and Emission Reductions August 19, 2010 

B-9 Final Draft Staff Report with Appendices 

for Proposed Amendments to Rule 4354 

IV. EMISSION REDUCTION IMPLICATIONS FOR TIER 4 EARLY ENHANCED 

COMPLIANCE OPTION 

Although the 2008 version of the rule was not submitted to EPA as a SIP revision, it is 

important to determine the effect of the proposed changes in compared to the 2008 

version of the rule. Since the proposed rule amendments only affect flat glass furnaces, 

only emissions from flat glass furnaces will be considered in this evaluation. 

A. NOx Emissions 

In determining the emission reductions in the Section 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. Flat 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 conditions, 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 Pilkington’s will be considered for this 

assessment. 

Table 3 shows the estimated annual NOx emissions from Pilkington’s furnace from 

2010 through 2018. The table assumes that the furnace operates at 80% of its 

maximum capacity for the entire year. The estimated 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 rule options and offers lower NOx 

emissions 4 years sooner than the Tier 4 enhanced option. 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Baseline Emissions and Emission Reductions August 19, 2010 

B-10 Final Draft Staff Report with Appendices 

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 2008 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 been realized and are not part of the 

evaluation for the proposed rule. The other flat glass furnace operator is already in 

compliance with the rule’s 2011 SOx limit. 

District staff estimated that Pilkington would reduce 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 SOx 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 the SOx emissions were not included 

in the District’s 2008 PM2.5 attainment strategy, there 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 furnaces 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 Tier 4 early enhanced from 2011 to 

2014 would not affect the District’s attainment status. 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Baseline Emissions and Emission Reductions August 19, 2010 

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 reductions, but the reductions were 

not quantified for the glass melting furnaces control 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 natural gas-fired (about 0.6 tons per day out 

of the total of 0.8 tons per day from all flat glass 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 furnace 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 DISTRICT

Appendix B: Baseline Emissions and Emission Reductions August 19, 2010 

B-12 Final Draft Staff Report with Appendices 

for Proposed Amendments to Rule 4354 

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