SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Emis sion and Emission Reduct ions September 16, 2010



## APPENDIX B

BASELINE EMISSIONS AND EMIS SION REDUCTION ANALYSIS FOR

PROPOSED AMENDMENTS TO RULE 4354 (GLASS MELTING FURNACES)

September 16, 2010

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

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Appendix B: Emis sion and Emission Reduct ions September 16, 2010



## Appendix B 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 aerodynami c diameter of 10 mi crometers or less (PM10) emission reductions for the propos ed 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 Implement ation Plan (SIP) revision, t he emission reductions from those amendments could not be counted as part of the District’s atta inment strategy.

Because these amendments hav e been approved by the Governing Board, District staff is submitting the proposed rule as a SIP revi sion and therefore the emission reductions

were calculated as the difference between t he 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 im plemented, 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 curr ent 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 thei r NOx emissions an additional 0.09 tons per day by committing to the Tier 4 early enhanced option rather than t he 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.

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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 r eductions associated with the proposed amendments to Rule 4354 (Glass Melting Furnaces). Each pollutant is addressed separately.

A. NOx Emissions and Emi ssion Reduction Methodology

District staff used the results of 2006 sour ce tests to calculate the current NOx emissions from glass melting furnaces. S ource 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 Resu lts in lb/hr * 24 hrs/day) / 2,000 lb/ton

For two flat glass furnaces, t heir 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 ru le development proj ect. The current

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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 pr oduction capacity depending on whether the source test report included t he pull rate during source testing.

For associated emissions after the Tier 3 NO x 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 fa cility that has heat input as the limiting permit condition, District staff assum ed that the maximum glass production corresponding to the highest heat input is 1,800 tons glass produced per day.

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

Claimed emission reductions are the differenc e between the current emissions claimed for this rule project minus the emi ssions after rule implementation.

Claimed Emission Reduction = Current Emis sions – After Implem entation Emissions

B. SOx Emissions and Emi ssion Reduction Methodology

The calculations for SOx emissions are si milar to the NOx emi ssions calculations

above. District staff used results of recent source tests to calculate the current SOx emissions from glass melting furnaces. Sour ce 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 multip lying the proposed emi ssion limit by the assumed average production rate of 80% of the permitted glass production capacity. For the facility that has heat input as the lim iting permit condition, Di strict staff assumed that the maximum glass production corres ponding to the highest heat input is 1,800 tons glass produced per day. Emission reduct ions were calculated as the difference

between the current emissions and the emissions after rule implementation. See the equations in Section II.A above for t he form used for SOx emissions.

C. PM10 Emissions and Em ission Reduction Methodology

Particulate matter source test results were reported as PM, PM10, or both. For those source test results with PM only, Distric t staff assumed that all PM is PM10 when

calculated the current PM 10 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 assu med average production rate of 80% of the permitted glass production capacity. For the fa cility that has heat input as the limiting permit condition, District staff assum ed 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

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Appendix B: Emis sion and Emission Reduct ions September 16, 2010

emissions and the after-implem entation 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 us ing the methodology outlined in Section II. The following paragraphs discuss the result s 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 t han 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 emi ssions, however, have no compliance costs that can be linked to this rule project bec ause the operators are making the changes to their furnaces in response to requirements not related to this rule project.

A. NOx Emissions and Clai med NOx Emission Reductions

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

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

the Tier 2 NOx emissi on limit during their 2006 source tes t. 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 t he 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 pe rmitted glass production capacity. This evaluation was performed to not count the emission reducti ons 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 curr ent emissions from the furnace were at the highest level allowed by the fu rnace’s permit. There is one c ontainer glass facility with source test results that are below the pr oposed 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 re ductions 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 fur nace will operate at 80% of it maximum glass

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B-7 Final Staff Report with Appendices for Proposed Amendments to Rule 4354 production capacity, District staff estimates t hat an additional 32.8 tons per year of NOx emission reductions or about 0.09 tons per day.

C. SOx Emissions and Clai med SOx Emission Reductions

Seven of the nine container glass furnac es have SOx emissions above the proposed emission limit – the fiberglass fu rnaces either meet the proposed limit or emit very little SOx. As noted in Table 1, emission reducti on from container furnaces will total about 0.38 tpd and fiberglass will have no emission reducti ons. 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-bri cking. However, the claimed SOx emission

reductions from this furnac e will not be used for calculating cost effectiveness in Appendix C of this staff repor t, since there are no costs that can be related to the proposed rule amendments. T he 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 Claime d PM10 Emission Reductions

One container glass furnace and two flat glass furnaces currently emit above the proposed PM10 limit. It is ex pected that emission reducti ons 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-b ricking and the PM10 emission reductions from the container glass furnace that source test ed 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 r eport, 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 DISTRICTAppendix B: Emission and Emission Reductions September16,2010B-8Final Staff Report with AppendicesFor Proposed Amendments to Rule 4354Table 2 – Details of Emission Reduction CalculationPollutantClaimed CurrentEmissions tpdEstimated Emissions AfterImplementation tpdClaimed EmissionReduction tpdClaimed EmissionReduction tpyNOxContainer2.661.501.16424.1Fiberglass0.530.520.014.1Flat Glass4.802.692.11770.4Additional reductionsTier 4 early enhancedNot applicableNot applicable0.0932.7Totals for NOx7.994.703.281198.7SOxContainer1.541.150.38138.8Fiberglass0.020.020.0010.3Flat Glass1.570.840.74268.5Totals for SOx3.132.011.12407.5PM10Container0.380.370.026.9Fiberglass0.0070.0050.0020.6Flat Glass0.590.500.0830.3Totals for PM100.980.870.1140.2SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Baseline Emissions and Em ission Reductions September 16, 2010

IV. EMISSION REDUCTION IMPLICAT IONS 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 t he 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 co mply 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 c onditions, 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 Pilkingt on’s will be considered for this

assessment.

Table 3 shows the estimated annual NOx em issions 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 ov er 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 cu rrent rule options and offers lower NOx emissions 4 years sooner than the Tier 4 enhanced option.

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Table 3 – 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

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

B. SOx Emissions

Although District staff was unable to quantify t he 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 alr eady 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 woul d reduce their SOx emi ssions by about 0.11 tons per day or 36.4 tons per year. By mo ving the compliance date, this rule project

would have 145.5 tons of SOx emissions. Be cause SOx is not an ozone precursor in the District’s air basin, the change in complianc e 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 strate gy, there is no detrime ntal effect on the District’s progress toward attainment of the PM2.5 standard. The additional SOx reductions may allow cleaner air sooner in cert ain areas of the Distr ict, but the total

amount of SOx reductions from glass melting furnaces would not be enough to affect the District’s estimated attainment year of 20 17. For this reason, District staff believes that moving the compliance date for SOx fo r the Tier 4 early enhanced from 2011 to

2014 would not affect the Distr ict’s attainment status.

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C. Directly-Emitted PM Emissions

The 2008 rule project did have some PM em ission reductions, but the reductions were not quantified for the glass melting furnac es control measure in the District’s 2008

PM2.5 Plan. The bulk of the claimed flat glass PM emissi on 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 manuf acturers). The fuel change emission reductions have already been realiz ed 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 expec ted to affect the District’s attainment strategy for the PM2. 5 air quality standard.

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