ENVIRON 

October II, 2007 

Texas Commission on Environmental Quality 

Air Pennits Initial Review Team, MC 161 

12100 Park 35 Circle 

~~d'IIJII\li!&l: 

APMRT 

OCT 15 2007 

Building C, 3'd Floor AIR PERMITS DI\IISION 

Austin, Texas 78753 

Re: Standard Permit Registration 

PPG Industries, Inc., Wichita Falls Plant 

Account No. WH-0040-R 

To Whom It May Concern: 

OCT 1 5 2007 

On behalf of PPG Industries, h1c., ENVIRON is sending you (enclosed) one copy of a standard 

permit registration for oxy-fuel conversion of Melting Furnace No. I at the PPG Wichita Falls 

Plant (TCEQ Account No. WH-040-R). This project was discussed with Ms. Am1e hunan, Rule 

Registrations Section Manager, and members of her staff Ms. Molly Wentworth a11d Mr. Marc 

Oliver on October znd of this year. Based on discussions during that meeting, it is our 

understanding that Mr. Oliver will be taking the lead in performing the review of this registration. 

Confidential information is being submitted with this registration. It is included in the enclosed 

and separate envelope marked "CONFIDENTIAL." 

Please note that the $900 registration fee has been paid via ePay. The ePay receipt is included, 

Attachment F to the registration package. 

If you have any questions, feel free to contact me at your convenience. I can be reached by 

telephone at 713.470.6657 or by email at sramsey(tll.environcom.com 

Sincerely, 

ENVIRON International Corporation 

Principal Consultant 

Enclosure 

cc: Ms. Winona Henry, TCEQ Region 3 Director, w/ Enclosure 

Ms. Pat Pride, PPG, w/ Enclosure (2 copies) 

Mr. Scott Johnson, PPG, w/ Enclosure 

Ms. Laura LaValle, Beveridge & Diamond PC, w/ Enclosure 

APMRT 

lli,j 15 2007 

www.environcorp.com 10333 Richmond Avenue, Suite 910, Houston, Texas 77042 Tel: 713.470.6546 Fax: 713.470.6547 
Standard Permit Registration 

PPG Industries, Inc. 

Wichita Falls Plant 

Line 1 Melting Furnace Oxy-Fuel 

Conversion 

TCEQ Account No. WH-0040-R 

Prepared for: 

PPG Industries, Inc. 

Wichita Falls, Texas 

Prepared by: 

ENVIRON International Corporation 

Steven H. Ramsey, P.E., BCEE 

Alessandra R. Carreon 

October 2007 

Project No. 26-17400A 

10333 Richmond Avenue, Suite 910, Houston TX 77042 

E:NVIRON 

AIR PERMITS DIVISION 

OCT 1 5 2001 

APIRT 

UL.H 15 2007 

Tel: 713.470.6546 
CONTENTS 

Page 

LIST OF TABLES .......................................................................................................................... ii 

LIST OF FIGURES ........................................................................................................................ ii 

LIST OF ATTACHMENTS ........................................................................................................... ii 

1. INTRODUCTION ...................................................................................................................... 1 

1.1 Purpose of Standard Permit Registration Application ..................................................... 1 

1.2 Permit History .................................................................................................................. 1 

1.3 Limitations ....................................................................................................................... 1 

2. EXISTING CONDITIONS ......................................................................................................... 2 

2.1 Site Description ................................................................................................................ 2 

2.2 Description of Existing Operations .................................................................................. 2 

2.3 Baseline Air Emissions ................................................................................................... .4 

3. OXY-FUEL CONVERSION PROJECT .................................................................................. 10 

3.1 Project Scope ................................................................................................................. 1 0 

3.2 Federal New Source Review Requirements .................................................................. 10 

3.3 Air Emissions ................................................................................................................. 11 

3.4 Authorization ................................................................................................................. 12 

3.5 TCEQ Forms .................................................................................................................. 12 

4. STANDARD PERMIT COMPLIANCE DEMONSTRATION ............................................... 14 

4.1 Compliance with General Requirements ....................................................................... 14 

4.2 Compliance with Specific Requirements ....................................................................... 23 

PPG Standard Pennit Registration 

TCBQ Account No. WH-0040-R 

-iENVIRON 
Table 2-1 

Table 2-2 

Table 2-3 

Table 2-4 

Table 2-5 

Table 3-1 

Table 3-2 

LIST OF TABLES 

Page 

Actual Emission Rates for Current Operations ..................................................................... .4 

Baseline NOx, S02, CO and VOC Emissions for Melting Furnace No. 1 ............................. 5 

Meadville Line 2 Furnace PM Emissions ............................................................................... 6 

Comparison of Meadville aud Wichita Falls PM Emissions .................................................. 7 

Baseline PM Emissions for Melting Furnace No. 1 ............................................................... 8 

PSD Analysis for Melting Furnace No. 1 ............................................................................. 11 

Melting Furnace No. 1 Emission Rates ................................................................................ 13 

LIST OF FIGURES 

Page 

Figure 2-1 Process Flow Diagram for Existing Operations ..................................................................... 2 

Figure 2-2 Meadville Line 2 Furnace PM Emissions ............................................................................... 6 

Figure 2-3 Wichita Falls Melting Furnace No. 1 PM Emissions Trend Line .......................................... 8 

Figure 3-1 Process Flow Diagram for Oxy-Fue1 Operations ................................................................. 1 0 

LIST OF ATTACHMENTS 

30 TAC §116.617 (Effective Date of February 1, 2006) 

Aerial Images of PPG Wichita Falls Plant 

PPG Wichita Falls Plaut Plot Plan 

Registration for Air Standard Permit Form PI-1S 

Table 1(a) Emission Point Summary 

Attachment A 

Attachment B 

Attachment C 

Attachment D 

Attachment E 

Attachment F 

Attachment G 

Air Quality Standard Permits, State Pollution Control Project Requirements Checklist 

TCEQ ePay Voucher Receipt 

PPG Standard Permit Registration 

TCEQ Account No. WH~0040~R 

-iiENVIRON 
1. INTRODUCTION 

1.1 Purpose of Standard Permit Registration Application 

PPG Industries, Inc. ("PPG") submits this registration to authorize the implementation of low-NOx. oxyfuel injection technology on Melting Furnace No. 1 at PPG's flat glass manufacturing facility in Wichita 

Falls, Texas, pursuant to the state pollution control project standard permit in 30 TAC §116.617. The 

project will result in a significant reduction of NOx emissions, and will reduce emissions of C02, a 

greenhouse gas. No increase in the emission of any air contaminant currently emitted, or emission of any 

air contaminant currently not emitted, will result. The conversion, in and of itself, will not result in any 

change in production capacity, heat input, products produced or raw materials used. The oxy-fuel 

conversion will be accomplished during an upcoming cold-tank repair on Melting Furnace No. I. As 

explained in this application, this environmentally-beneficial project qualifies for authorization under the 

state pollution control project standard permit. 

This registration is submitted as required by 30 TAC §116.617(d). A copy of the current version of 30 

TAC § 116.617 is included as Attachment A. 

1.2 Permit History 

PPG's Wichita Falls flat glass manufacturing plant operations are authorized pursuant to New Source 

Review ("NSR") Permit No. 898, which was recently renewed and amended. No facilities at the site are 

currently authorized by standard permit. The Wichita Falls Plant is a major source under the Title V 

federal operating permits program, pursuant to which Title V Permit No. 01113 was issued on April 24, 

2006. Melting Furnace No. 1 is identified as Emission Point Number ("EPN") 22 in these authorizations. 

Applicable TCEQ identification numbers are as follows. 

PPG Industries, Inc., TCEQ Customer Number ...................................................................... CN600124614 

Wichita Falls Plant TCEQ Regulated Entity Number ............................................................. RN102522950 

Wichita Falls Plant TCEQ Air Quality Account Number: .......................................................... WH-0040-R 

1.3 Limitations 

In this registration application, certain information regarding the PPG Wichita Falls Plant and the existing 

glass manufacturing process are provided for reference purposes only. Per 30 TAC §ll6.116(a), only 

those representations directly relating to construction plans and operational procedures associated with the 

subject oxy-fuel conversion pollution control project are enforceable representations as conditions upon 

which the permit registration is issued. 

PPG Standard Permit Registration 

TCEQ Account No. WH-0040-R 

.]. 

ENVIRON 
2. EXISTING CONDITIONS 

2.1 Site Description 

PPG owns and operates a flat glass manufacturing facility located at 7400 Central Freeway North in the 

City of Wichita Falls, Wichita County, Texas. Aerial images of the facility and surrounding area are 

included as Attachment B to this application. The map includes the site orientation, the scale, and the 

plant boundary. A scaled plot plan showing the PPG property boundary and the location of on-site 

structures is included as Attachment C. 

2.2 Description of Existing Operations 

PPG produces flat glass on two production lines at the Wichita Falls Plant, each with a single furnace. 

The process flow diagram in Figure 2.1 illustrates the existing glassmaking operations. 

Various Raw 

Materials 

Raw Material 

Delivery and 

Handling 

-

Natural 

Air Gas 

j 

Glass Melijng ~ Glass 

Furnace Surface 

Treatment 

Recycle 

Cutting, 

1----> Packaging :--

and Finishing 

-~ 

Figure 2-1. Process Flow Diagram for Existing Operations 

The following is a brief overview of the Wichita Falls Plant glassmaking operations. 

2.2.1 Raw Material Receiving and Handling 

Glass Products 

Sand, soda ash, limestone, salt cake, dolomite and caustic soda constitute the primary raw materials 

processed at the plant. These materials are delivered to the site by railcar or truck. Minor quantities are 

typically delivered in super sacks or small containers. The raw materials, except for the caustic soda, are 

loaded into underground hoppers where conveyors and bucket elevators transport the materials into one of 

several storage silos. The caustic soda is loaded in aboveground storage tanks. These operations occur 

inside the material unloading building. 

The raw materials are weighed and mixed in either the west or east batch mixers prior to transfer to the 

main building. Covered conveyor belts are used to transport the hatched materials to the furnace feed 

hopper. Recycled cullet from the cullet processing area is added to the materials through the conveyor 

belts. 

PPG Standard Permit Registration 

TCEQ Accounl No. Wl-1~0040-R 

-2-

ENVIRON 
2.2.2 Glass Melting Furnaces 

Raw material that has undergone preparation for production is sent to one of two glass melting furnaces 

(Line 1 or Line 2) through a feeder. The two furnace units are fired with natural gas as the primary fuel, 

though both have the capability to fire fuel oil. As the raw material melts, it passes to the front of the 

furnace and flows into a refiner and tin bath. The molten glass contacts the surface of liquid tin and 

flattens into glass sheets as it cools. The glass is further cooled in the annealing lehr where glass 

properties may be modified by controlling the rate of cooling. General information regarding Melting 

Furnace No. 1 follows. 

Line 1 Glass Production Capacity: .............................................................. Approximately 700 tons per day 

Line 1 Furnace Maximum Rated Heat Input: .................................... Approximately 215 MMBTU per hour 

Operating Schedule: .......................................... : .......................................................................... Continuous 

2.2.3 Glass Surface Treatment 

A portion of the colored glass produced may be covered with a reflective surface coating known as 

Solarcool®. Solarcool® is made by applying a solution of acetylacetonate metals to one side of the 

colored glass. When not producing Solarcool®, S02 may be applied to the glass as a lubricant to prevent 

surface damage from the conveyor rollers. 

2.2.4 Cutting, Packaging and Finishing Procedures 

An acetic acid and water solution is sprayed onto the bottom of the glass for cleaning purposes as it 

proceeds down the conveyor. A final water spray rinse is performed to remove acetic acid from the glass 

surface and the glass is then blown dry with air knives. Handling of the glass is performed by vacuum 

transfer machines that utilize suction cups and a vacuum to transport the glass sections. 

After cleaning, the glass is inspected for defects and "W" interleaving is employed. "W" interleaving is 

an application of aqueous ammonium adipate used to prevent glass staining during handling and storage. 

Finished glass product is cut from the continuously formed glass. Large glass sections are sent to final 

cutting and trimming in any one of several final packaging sites. "L" interleaving is also applied to the 

top surface of the glass as a means of protection. The polymeric powder beads of "L" interleaving allow 

for separation of the packed sheets and also offer some stain resistance. 

Magnetic sputter vacuum deposition ("MSVD") is used as a solar control metallic reflective coating for a 

portion of the flat glass. The flat glass is first loaded into a vacuum chamber, then conveyed to the spray 

coating booth where an aqueous solution of polyvinyl alcohol is applied. In some circumstances, some of 

the metal coating may be mechanically buffed from the glass edges. Particulates generated during buffing 

are controlled by dust collectors with HEPA filters. 

2.2.5 Gullet Processing 

A sizeable quantity of scrap glass results from the glass trimming process. This scrap glass is crushed and 

recycled back to the process prior to the furnace feed hopper. Cullet that exits the crushers drops onto one 

PPG Standard Permit Registration 

TCEQ Account No. WH-0040-R 

-3-

ENVIRON 
of two main conveyor belts that direct the collet to the collet storage building. Some collet is stored 

outside. Front-end loaders are utilized to load the resulting collet on the collet recycle loop conveyor 

system which may be added to the delivery of raw materials to the furnaces. 

2.3 Baseline Air Emissions 

PPG has conducted two sets of emission tests on Melting Furnace No. 1. These tests were conducted in 

April 1995 and April 2007. The testing results are presented in Table 2-1. The 1995 and 2007 values 

each represent the average of three 1-hour runs. 

Table 2-1. Actual Emission Rates for Current Operations 

NOx(as N02) 26.270 16.666 

so2 0.468 1.276 

co 0.043 0.029 

VOC (non-CH4) N.A. 0.021 

PM 1.129 0.816 

PMw N.A. 0.566 

The higher of the two measured emission rates presented in Table 2-1 is used along with glass production 

rates to estimate emissions of NOx, S02, CO and VOC for each of the past 10 years. These estimated 

baseline emissions are presented in Table 2-2. As shown in Table 2-2, the two highest consecutive years 

of emissions during the past 10 years occurred during 1999 and 2000 (yellow highlights). Baseline 

emissions are the average of emissions during these two years and are as follows for NOx. S02, CO and 

VOC emissions. 

NOx = 2,889.84 tons/year 

so2 = 140.37 tons/year 

co = 4.73 tons/year 

voc = 2.31 tons/year 

Based upon measurements of PM emissions over time, PPG has found that the baseline emissions 

analysis for PM requires a different approach. Following re-bricking (or initial construction if a new 

furnace), a glass melting furnace will be operated continuously until such time as the refractory bricks 

begin to disintegrate. Then and only then (excluding any unforeseen and extraordinary situations) will the 

furnace be taken off-line and drained of all residual heat. This "campaign" will typically last between 10 

and 12 years. The exact length of the campaign is determined by the condition of the refractory brick. 

PPG Standard Pennit Registl'ation 

TCEQ Account No. WH~0040~R 

-4-

ENVIRON 
Table 2-2. Baseline NOx, S02, CO and VOC Emissions for Melting Furnace No. 1 

1997 216,664 1998 165,959 1999 222,506 

2000 217,516 2001 214,737 

2002 205,163 2003 178,140 2004 204,140 2005 194,047 2006 205,053 

PPG Standard Pennit Registration 

TCEQ Account No. WH-0040-R 

26.270 2,845.88 26.270 2,179.87 26.270 2,922.62 26.270 2,857.07 26.270 2,820.57 26.270 2,694.82 26.270 2,339.87 26.270 2,681.38 26.270 2,548.81 26.270 2,693.37 

··-··-··· ........•. 

1.276 138.23 0.043 1.276 105.88 0.043 1.276 141.96 0.043 1.276 138.78 0.043 1.276 137.00 0.043 1.276 130.89 0.043 1.276 113.65 0.043 1.276 130.24 0.043 1.276 123.80 0.043 1.276 130.82 0.043 

-5-

---- --· -------

4.66 

3.57 

4.78 

4.68 

4.62 

4.41 

3.83 

4.39 

4.17 

4.41 
PPG has determined through testing performed at the Wichita Falls Plant as well as a furnace of nearly 

identical design at its Meadville, Pennsylvania plant, that measured emissions of PM are not constant 

throughout a campaign. Rather, PM emissions decline over time during the course of a campaign. While 

the specific reason or reasons for this documented trend are not known, PPG believes that one reason is 

the increasing amount of PM that settles in the furnace's heat recovery regenerators - also known as 

"checkers"- during the course of a campaign. 

Results of annual testing of PM emissions from the Line 2 furnace at the Meadville Plant are shown in 

Table 2-3. 

Table 2-3. Meadville Line 2 Furnace PM emissions 

4 28.0 20.0 1.40 

5 23.9 19.8 1.21 

6 19.0 19.9 0.95 

7 22.9 19.8 1.15 

8 15.6 20.0 0.78 

9 11.0 20.4 0.54 

10 15.4 20.4 0.75 

1

Emissions were not tested duri~g the first three years of the campaign. 

A graphic representation of this data with a best-fit trend line is presented as Figure 2-2. As shown, the 

equation (y = rnx + b) that best represents the trend line is: 

(Equation 1) PM (lb/ton glass produced)= -0.1236 x (Year of Campaign)+ 1.8336 

The coefficient of determination, R2

, is 0.785. 1 

] 2.00 

1.80 

::l 

"8 1.60 

.. 1.40 0.. 

m 

1.20 

(!j 1.00 

c 0.80 

{!. 0.60 '-

:; 0.40 

0.. 0.20 :f! 0.00 

0 

PPG Standard Permit Registralion 

TCEQ Account No. WH-0040-R 

2 4 6 8 10 

Year of Campaign 

Figure 2-2. Meadville Line 2 Furnace PM Emissions 

-6-

12 

APGRT 

E~IR~~0U 
Emissions testing data demonstrate that the Wichita Falls Plant Melting Furnace No. 1 PM emissions 

behave similarly to those at Meadville: declining over the course of a campaign. PM emission factors 

calculated using Equation 1 (Meadville Line 2 Furnace only) are shown in Table 2-4. Emission rates 

determined by source testing on Wichita Falls Melting Furnace No. 1 are presented for comparison 

purposes. As shown, measured emissions are close to predicted values. 

Table 2-4. Comparison of Meadville and Wichita Falls PM Emissions 

1 1.71 

2 1.59 

3 1.46 

4 1.34 

5 1.22 

6 1.09 1.13 

7 0.97 

8 0.84 

9 0.72 

10 0.60 0.82 

Comparison of tested PM emissions at the Wichita Falls Melting Furnace No. 1 and the Meadville Line 2 

Furnace is appropriate given that these furnaces are of nearly identical design. Specifically, they both 

utilize air-fired technology in the same operational configuration, but have different capacities. Wichita 

Falls Melting Furnace No. 1 has a glass production capacity of approximately 700 tons per day, and the 

Meadville Line 2 Furnace has a capacity of approximately 600 tons per day. Accordingly, it makes sense 

from a technical standpoint, and is therefore not surprising, that both furnaces have the same declining 

PM emissions trend. 

To most accurately predict PM emissions for Wichita Falls Melting Furnace No. 1, PPG used the same 

trend line created using Meadville Plant data and adjusted the trend line using 1995 Wichita Falls source 

testing data. Wichita Falls 2007 source testing data was not used because the furnace was not operating 

near capacity during the test and, based upon experience, PPG believes that the PM emissions were biased 

slightly higher as a result. Figure 2-3 shows the adjusted trend line for Wichita Falls Melting Furnace No. 

1. 

PPG Standard Pennit Registration 

TCEQ Account No. WH-0040MR 

-7-

ENVIRON 
2.00 

§ 1.80 

1.60 

~ 1.40 

M 

1.20 

~ 1.00 

~ 0.80 

.... 0.60 

~ 0.40 

:9 0.20 

0.00 

0 2 4 6 8 10 12 

Year of Campaign 

Figure 2-3. Wichita Falls Melting Furnace No. 1 PM Emissions Trend Line 

The equation (y = mx +b) that best represents the trend line is: 

(Equation 2) PM (lb/ton glass produced)= -0.1278 x (Year of Campaign)+ 1.8967 

Equation 2 is used to estimate PM emissions from the Wichita Falls Melting Furnace No. 1. For purposes 

of establishing a baseline, PM10 is estimated assuming that the ratio of PM10 to PM determined during 

April2007 testing (0.566/0.816 = 0.694 or 69.4%) remains constant throughout the campaign. 

Baseline PM emissions are presented in Table 2-5. 

Table 2-5. Baseline PM Emissions for Melting Furnace No. 1 

1998 

1999 

2000 

2002 

2003 

2004 

2005 

2006 

PPG Standard Permit Regisu·ation 

TCEQ Account No, WH-0040-R 

2 

3 

4 

6 

7 

8 

9 

-8-

ENVIRON 
As shown in Table 2-5, the two highest consecutive years of emissions during the past 10 years occurred 

during 1999 and 2000 (yellow highlights). Baseline PM emissions are the average of emissions during 

these two years and are as follows. 

PM = 

PM10 = 

173.59 tons/year 

120.41 tons/year 

PPG Standard Permit Registration 

TCEQ Account No. WH~0040-R 

ENVIRON 

-9-
3. OXY-FUEL CONVERSION PROJECT 

3.1 Project Scope 

As discussed in the Introduction, PPG is submitting this registration application for authorization to 

implement low-NOx oxy-fuel injection technology on Melting Furnace No. 1. In addition to certain 

furnace structural changes necessary for the conversion, the project will require the installation of an onsite air separation plant to produce the oxygen required by the process. The air separation plant will be 

owned and operated by a third-party on land leased from PPG. The third-party owner will be responsible 

for authorization of any associated air emissions. 

As noted in the Introduction, the project will not change the furnace maximum production rate, maximum 

rated heat input capacity, operating schedule, raw materials used or products produced. However, a large 

reduction in NOx emissions will be realized. The emissions following implementation of the project are 

discussed in Section 3.3. 

A process flow diagram for the facility following the oxy-fuel conversion is shown in Figure 3-1. 

Various Raw 

Materials 

Raw Material 

Delivery and 

Handling 

Air Separation 

Plant 

j 

o, 

Natural 

Gas 

Glass Melting 

Furnace 

Glass 

Surface 

Treatment 

Recycle 

Cutting, 

Packaging 

and Finishing 

Figure 3-1. Process Flow Diagram for Oxy-Fuel Operations 

3.2 Federal New Source Review Requirements 

Glass Products 

The first step in the process of evaluating permitting requirements is to determine if federal NSR 

permitting is triggered. Since the Wichita Falls area is in attainment of (or unclassified for) all national 

ambient air quality standards, only the applicability of Prevention of Significant Deterioration ("PSD") 

permitting (not nonattainment NSR permitting) needs to be considered. 

TCEQ's PSD permitting rules define "major modification" as "[a]ny physical change in, or change in the 

method of operation of a major stationary source that causes a significant project emissions increase and a 

significant net emissions increase for any federally regulated new source review pollutant. At a stationary 

PPG Standard Pennit Registration 

TCEQ Account No. WH-0040-R 

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ENVIRON 
source that is not major prior to the increase, the increase by itself must equal or exceed that specified for 

a major source .... The major source and significant thresholds for prevention of significant deterioration 

pollutants are identified in 40 Code of Federal Regulations §51.166(b)(1) and (23), respectively." [30 

TAC §116.12(18)] 

For purposes of this federal NSR analysis, PPG conservatively assumed that conversion of Melting 

Furnace No. 1 from air to oxy-fuel constitutes a physical change and/or a change in the method of 

operation. Therefore, PPG evaluated the net emissions increase associated with the conversion to 

determine if PSD review is triggered. The net emissions increase is determined by comparing allowable 

emissions or projected actual emissions to baseline actual emissions for Melting Furnace No. 1. As 

shown in Table 3-1, with the exception of VOC, the difference between the baseline and the current 

permit allowable emissions is greater than the PSD significance threshold. To avoid triggering PSD 

review, the allowable emission limits will need to be lowered so that the difference between the permit 

allowable and the baseline actual emissions is less than the PSD significance threshold. 

Table 3-1. PSD Analysis for Melting Furnace No. 1 

NOx 40 2,929.84 3,236.82 

SOz 140.37 40 180.37 350.40 

co 4.73 100 104.73 700.80 

voc 2.31 40 42.31 5.08 

PM 173.59 25 198.59 310.98 

PMw 120.41 15 135.41 310.98 

3.3 Air Emissions 

PPG anticipates a large reduction in NOx emissions as a result of the oxy-fuel conversion project. Based 

upon experience at other facilities, PPG anticipates that, on annual average, emissions will be less than 

7.0 lbs NOx per ton of glass produced. Using this value, annual emissions are estimated as follows: 

NOx = (7.0 lbs NOx/ton glass) x (700 tons glass/day) x (365 days/year) x (1 ton/2000 lbs) 

NOx = 894.25 tons/year 

This represents a reduction of approximately 1,996 tons per year when compared to baseline NOx 

emissions. 

To address potential variability in emissions during normal operation and emissions associated with 

scheduled maintenance, startup and shutdown (MSS) activities, PPG intends to retain the current shortterm NOx emission limit of 739 lbs/hour. The primary planned and scheduled MSS activities are startup 

of the furnace at the beginning of the campaign and shutdown of the furnace at the end of the campaign. 

PPG Standard Permit Registration 

TCEQ Account No. WH-0040-R 

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ENVIRON 
PPG does not shut down furnaces before the end of a campaign. During startup or shutdown, NOx 

emissions could be as high as they are for an air-fired furnace. Therefore, it is appropriate to retain the 

current permitted short-term NOx emission rate to authorize emissions from normal operation and MSS 

activities. With respect to S02, CO, PM and PM10, PPG proposes setting the annual permit allowable 

emission limits at just below the levels that would trigger PSD review (see Table 3.1). Using S02 as an 

example: 

S02 = Baseline Emissions + PSD Threshold - 0.10 ton/year 

so2 = 140.37 tons/year+ 40 tons/year- 0.10 ton/year 

so2 = 180.27 tons/year 

Current hourly permit limits for S02, CO, PM and PM10 will be retained to address variability in 

emissions during normal operation and those emissions associated with scheduled and planned MSS 

activities. Current annual and short-term emission limits will be retained for VOC and non-criteria 

pollutants. 

Table 3-2 summarizes the proposed emission rates following implementation of low-NOx oxy-fuel 

injection technology on Melting Furnace No. 1. 

3.4 Authorization 

The subject oxy-fuel conversion project qualifies for authorization under the State Pollution Control 

Project Standard Permit in 30 TAC §116.617. As discussed in detail in Section 4 of this application, the 

project meets all of the requirements for authorization under the referenced standard permit. 

3.5 TCEQ Fonns 

The following TCEQ forms are included as attachments to this document: 

• Registration for Air Standard Permit, Form PI-IS (included as Attachment D) 

• Table l(a) Emission Point Summary (included as Attachment E) 

• Air Quality Standard Permits, State Pollution Control Project Requirements Checklist (included 

as Attachment F) 

No Core Data Form information has changed; therefore, one is not submitted with this registration. 

PPG Standard Permit Registration 

TCEQ Account No. WH-0040-R 

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APIRT 

E )'(j)\! t ~ ~NlOOI 
Table 3-2. Proposed Melting Furnace No. 1 Emission Rates 

180.27 

--

104.63 -596.17 1

-

-

5.08 0.00 

--

-

198.49 -112.49 7

-

-

135.31 -175.67 7

-

-

1.00 0.00 

-

31.00 0.00 4

-

Ni1 I 0.10 I -- I 

0.061 -- I -- I 

82.00 

0.06 

I I -- I 0.10 

_

Si1 

Ce1 I 40.00 I -- I -- I 40.00 I o.oo 

Ti1 I 8.80 I -- I -- I 8.80 I o.oo 

1 Combined emissions from Melting Furnace No. I (EPN 22) and Melting Furnace No. 2 (EPN 23). These pollutants are not subject to 

actual and proposed net emission increases are not provided. 

PPG Standard Permit Registration 

TCEQ Account No. WH-0040-R 

-13-

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