UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION III

	1650 Arch Street

	Philadelphia, Pennsylvania  19103

DATE:	May 5, 2011

SUBJECT:	Technical Support Document – Commonwealth of Pennsylvania –
Control of Nitrogen Oxides from Glass Melting Furnaces

			/s/

FROM:	Rose Quinto, Environmental Engineer

		Office of Air Program Planning

TO:		File

			/s/

THRU: 	Cristina Fernandez, Associate Director

Office of Air Program Planning

A.  BACKGROUND

On July 23, 2010, the Pennsylvania Department of Environmental
Protection (PADEP) submitted a State Implementation Plan (SIP) revision
pertaining to the control of nitrogen oxides (NOx) emissions from glass
melting furnaces.  The manufacturing process requires raw materials,
such as sand, limestone, soda ash, scrap, and recycled glass, to be fed
into a furnace where a temperature is maintained in the 2700° to 3100°
Fahrenheit range.  The raw materials then chemically react creating a
molten material – glass.  The reaction of nitrogen and oxygen in the
furnace creates NOx emissions, of which NOx is a precursor of ozone. 
This SIP revision is based on the Ozone Transport Commission (OTC)
control measure to reduce NOx emissions from glass melting furnaces. 
The OTC members include Pennsylvania, Connecticut, Delaware, Maine,
Maryland, Massachusetts, New Hampshire, New Jersey, New York, Rhode
Island, Vermont, Virginia, and the District of Columbia.  The OTC was
created under section 184 of the Clean Air Act (CAA) to establish
regulatory programs to reduce ozone precursor emissions, which includes
the reduction of NOx emissions from glass melting furnaces.  

B.  STATE SUBMITTAL

The SIP revision adds definitions and terms to Title 25 of the
Pennsylvania Code (25 Pa. Code) Chapter 121.1, relating to definitions,
used in the substantive provisions of this SIP revision.  The SIP
revision adds a new regulation pertaining to the NOx emission standards
in 25 Pa. Code Chapter 129, Standards of Sources, Sections 129.301
through 129.310, Control of NOx Emissions from Glass Melting Furnaces. 
The SIP revision applies to an owner or operator of a glass melting
furnace that emits or has the potential to emit NOx at a rate greater
than 50 tons per year in the Commonwealth of Pennsylvania, including the
local air pollution control agencies in Philadelphia and Allegheny
Counties.  The purpose of the SIP revision is to annually limit the
emissions of NOx from glass melting furnaces.

The following definitions and terms were added in 25 Pa. Code Section
121.1:  

Blown glass – Glassware shaped by blowing air into a molten glass
gather.

Cold shutdown – A cold repair or replacement of damaged or worn
refractory parts of a glass melting furnace while the furnace does not
contain molten glass.

Container glass – Glass manufactured by pressing, blowing in molds,
drawing, rolling or casting which is used as a container.

Fiberglass – Material consisting of fine filaments of glass that are
combined into yarn and woven or spun into fabrics, or that are used as
reinforcement in other materials or in masses as thermal or as
acoustical insulating product.

Flat glass – Glass produces by the float, sheet, rolled or plate glass
process which is used in windows, windshields, tabletops or similar
products.

Glass melting furnace – A unit comprising a refractory-lined vessel in
which raw materials are charged and melted at high temperature to
produce molten glass.

Idling – The operation of a glass furnace at less than 25% of the
permitted production capacity or fuel use capacity as stated in the plan
approval or operating permit.                                           
                                                                        
                              

Permitted production capacity – The maximum pull rate as stated in the
plan approval, operating permit or Title V permit. 

Pressed glass – Glassware formed by placing a blob of molten glass in
a metal mold, then pressing it with a metal plunger or follower to form
the inside shape.  The resultant piece, termed “mold-pressed,” has
an interior form independent of the exterior, in contrast to mold-blown
glass, whose interior corresponds to the outer form.

Primary furnace combustion system – The burners in a glass melting
furnace that are used during production of glass.

Pull rate – The amount of glass withdrawn from a glass melting
furnace, expressed in short tons per day.

Shutdown – The period of time during which glass melting furnace is
taken from an operational to a non-operational status by allowing it to
cool down from its operating temperature to a cold or ambient
temperature as the fuel supply is turned off.

Start-up – The period of time, after initial construction, shutdown or
cold shutdown, during a glass melting furnace is heated to stable
operating temperature by the primary furnace combustion system, and
systems and instrumentation are brought to stabilization.  

Summary of the SIP Revision

The SIP revision adds a new regulation in 25 Pa. Code Chapter 129,
Control of NOx Emissions from Glass Melting Furnaces, Sections 129.301
– 129.310.

Section 129.301, relating to the purpose of the new regulation, annually
limits the emissions of NOx from glass melting furnaces.

Section 129.302, relating to the applicability, specifies that the
regulation applies to an owner or operator of a glass melting furnace
that emits or has the potential to emit NOx at a rate greater than 50
tons per year.

Section 129.303 provides that the emission requirements do not apply
during periods of start-up, shutdown, or idling if the owner or operator
complies with the start-up, shutdown, and idling requirements.  (See
start-up, shutdown, and idling requirements in the PADEP SIP revision
submittal – sections 129.305, 129.306, and 129.307, and page 5 of the
attachment of EPA’s Start-up, Shutdown and Malfunction (SSM) Policy
– Memorandum of Steven A. Herman and Robert Perciasepe, Policy of
Excess Emissions During Malfunctions, Start-up and Shutdown, September
20, 1999).  Owners and operators claiming the exemption shall notify
PADEP or the local air pollution control agency within 24 hours after
initiation of the operation for which the exemption is claimed. 
Additionally, the owner or operator of a glass melting furnace that is
granted an exemption shall maintain operating records or documentation,
or both necessary to support the claim for the exemption.

Section 129.304 provides that the owner of a glass melting furnace shall
determine allowable NOx emissions by multiplying the tons of glass
pulled by each of the furnace by:  4.0 pounds of NOx per ton of glass
pulled for container glass furnaces; 7.0 pounds of NOx per ton of glass
pulled for pressed or blown glass furnaces; 4.0 pounds of NOx per ton of
glass pulled for fiberglass furnaces; 7.0 pounds of NOx per ton of glass
pulled for flat glass furnaces; and 6.0 pounds of NOx per ton of glass
pulled for all other glass melting furnaces.

Furthermore, the owner or operator of a glass melting furnace shall
comply with the allowable NOx emissions by January 1, 2012, unless a
petition for an alternative emission limitation or compliance schedule
is submitted, in writing, to PADEP or the local air pollution control
agency by January 1, 2012 and also approved in writing by PADEP or the
local air pollution control agency.

The SIP revision also provides a petition process for an alternative NOx
emission limitation to the owner or operator of a glass melting furnace
that demonstrates to PADEP’s satisfaction that it is economically or
technologically infeasible to meet the established emission limitations
in this SIP revision.  An alternative NOx emission limitation approved
by PADEP must be included in either a plan approval or an operating
permit issued by PADEP or a permit issued by the local air pollution
control agency.  In addition, the SIP revision includes a petition
process for an alternative compliance schedule if an owner or operator
of a glass melting furnace demonstrates that compliance cannot be
achieved by the January 1, 2012 compliance date.

Section 129.305, relating to start-up requirements, requires the owner
or operator of a glass melting furnace to submit specific information
requested by PADEP or the local air pollution control agencies
information to assure proper operation of the furnace.  The owner or
operator of a glass melting furnace may submit a request for a start-up
exemption in conjunction with the approval application, if required. 
The length of the start-up exemption should not exceed a finite number
of days depending on the type of the furnace.  PADEP or the local air
pollution control agency shall approve start-up exemptions to the extent
that the request identifies the control technologies or strategies to be
used.  Additionally, the owner or operator shall place the emission
control system in operation as soon as technologically feasible during
start-up to minimize emissions.

Section 129.306, relating to shutdown requirements, provides that the
duration of glass melting furnace shutdown, as measured from the time
the furnace operations drops below 25% of the permitted production
capacity or fuel use capacity, to when all emissions from the furnace
cease, should not exceed 20 days.  The owner or operator of a glass
melting furnace shall operate the emission control system whenever
technically feasible, as approved by PADEP or the local air pollution
control agency, during shutdown to minimize emissions.

Section129.307, relating to idling requirements, provides that the owner
or operator of a glass melting furnace shall operate the emission
control system whenever technically feasible, as approved by PADEP or
the local air pollution control agency, during idling to minimize
emissions.  The NOx emissions during idling may not exceed the amount
calculated using the following equation:

Pounds per day emission limit of NOx = (applicable NOx emission limit
specified in the emission requirements, expressed in pounds per ton of
glass produced) x (furnace permitted production capacity in tons of
glass produced per day).

Section 129.308, relating to compliance determination, requires that the
owner or operator of a glass melting furnace shall install, operate and
maintain continuous emissions monitoring system (CEMS) for NOx and other
monitoring systems to convert data to required reporting units in
compliance with 25 Pa. Code Chapter 139, Subchapter C (relating to
requirements for source monitoring for stationary sources) and calculate
actual emissions using the CEMS data reported to PADEP or the local air
pollution control agency, no later than14 days prior to the compliance
date.  However, the owner or operator of a glass melting furnace may
elect to install and operate an alternate NOx emissions monitoring
system or method approved, in writing, by PADEP or the local air
pollution control agency.  Data invalidated under Chapter 139,
Subchapter C will be substituted with other values if approved by PADEP
or the local air pollution control agency.

Section 129.309, relating to compliance demonstration, provides that the
owner or operator of a glass melting furnace shall calculate and report
to PADEP or the local air pollution control agencies on a quarterly
basis, no later than 30 days after the end of the quarter, the CEMS data
and glass production data used to show compliance with the allowable NOx
emission limitations.  The glass production data must consist of the
quantity of glass in tons pulled per day for each furnace.  Compliance
can be demonstrated on a furnace-by-furnace basis; facility-wide
emission averaging basis; or a system-wide emissions averaging basis
among glass melting furnaces under common control of the same owner or
operator in the Commonwealth.  The owner or operator of a glass melting
furnace for which PADEP or the local air pollution control agency has
granted approval to voluntarily opt into a market-based program may not
demonstrate compliance on an emissions averaging basis.  Moreover, an
emission reduction obtained by emissions averaging to demonstrate
compliance with the emission requirements in this SIP revision will not
be considered surplus for emission reduction credit purposes.

Section 129.310, relating to recordkeeping, provides that the owner or
operator of a glass melting furnace shall maintain records to
demonstrate compliance.  The records must include an operating log
maintained for each glass melting furnace that includes, on a daily
basis the following:  the total hours of operation; the type and
quantity of fuel used; and the quantity of glass pulled.  In addition,
the owner or operator of a glass melting furnace shall maintain records
of the following:  source tests and operating parameters established
during the initial source test; and maintenance, repairs, malfunctions,
idling, start-up and shutdown.  The records will be maintained onsite
for 5 years and shall be made available or submitted to PADEP or the
local air pollution control agency upon request.

C.  EPA EVALUATION

This regulation will reduce emissions of NOx from glass melting furnaces
to reduce levels of ground-level ozone and fine particulate matter
(PM2.5).  Ground-level ozone is not directly emitted by pollution
sources, but is created as a result of a chemical reaction of NOx and
volatile organic compounds (VOC) in the presence of light and heat.  The
reduction of NOx emissions will also help protect the public health and
environment from high levels of PM2.5, of which NOx is a precursor
component.  The reduction of NOx emissions also reduces visibility
impairment and acid deposition.

D.  CONCLUSIONS AND RECOMMENDED AGENCY ACTION

The regulation on the control of NOx emissions from glass melting
furnaces adopted by the Commonwealth of Pennsylvania will result in the
reduction of NOx emissions from glass melting furnaces and will help the
Commonwealth in attaining compliance with the 8-hour ozone and PM2.5 
national ambient air quality standards (NAAQS).  EPA approval of the SIP
revision is recommended.

 PAGE   

  PAGE   \* MERGEFORMAT  4 

