ALLEGHENY COUNTY HEALTH DEPARTMENT AIR QUALITY PROGRAM. January 28, 2013

Transcription

1 ALLEGHENY COUNTY HEALTH DEPARTMENT AIR QUALITY PROGRAM January 28, 2013 SUBJECT: TO: FROM: Review Renewal Application Title V Operating Permit Guardian Industries Corp. Floreffe 1000 Glasshouse Road Jefferson Hills, PA Allegheny County ACHD Operating Permit File No Sandra L. Etzel Chief Engineer Melissa Jativa Air Pollution Control Engineer FACILITY DESCRIPTION: The Guardian Industries Corp. (Guardian) facility is a float glass manufacturing plant located at 1000 Glass House Road in Jefferson Hills, PA. It primarily manufactures glass for the automobile industry. The facility currently produces several types of glass with various types of tinting, depending on customer orders. The plant is composed of a melting furnace capable of producing 350 tons of glass per day. The raw materials are fed into the furnace after being unloaded, stored and weighed in the Batch House. The raw materials are transported on site via railroad and truck from various locations. After weighing and blending, the raw materials, including cullet, are conveyed to the furnace for melting, where a continuous ribbon of glass is pulled through the furnace on a layer of molten tin. A computer-controlled cutting system cuts the glass into the desired sizes as dictated by customer orders. The glass is then inspected, packaged, and shipped off-site via truck. The facility is classified as a major source of nitrogen oxides (NO X ) and sulfur dioxide (SO2). It is a minor source of particulate matter less than 10 microns in diameter (PM10), carbon monoxide (CO), volatile organic compounds (VOCs) emissions and hazardous air pollutants (HAPs),. The facility currently consists of the following emission units: 1. Glass Melting Furnace: capable of producing between tons of flat glass per day; fired with natural gas, and supplemented with oxy-fuel firing. Nitrogen bubbling and electric boost are also used. 2. Virgin Lime Silo: supplies the hydrated lime for use in the lime injection scrubber; capable of handling up to 750 pounds of lime per hour. 3. Used Lime Silo: handles the spent lime for re-use in the scrubber; capable of handling 750 pounds of lime per hour. 4. Glass and Roll Coating: used to coat the rollers and glass with sulfur dioxide gas in order to prevent the tin from sticking to the glass and rollers. 5. Float Glass Cutting: odorless mineral spirits are used to lubricate the glass cutters. 1

2 6. Emergency Back-up Generators: Three (3) diesel fuel powered generators (2,000 KW, 900 KW, 500 KW) for use as emergency back-up electricity generation in the event of a power failure at the facility. 7. Cullet Return: Cullet is returned to the furnace for re-melting and as part of the glass batch recipe; the maximum throughput is 127,750 tons of crushed/broken glass per year. 8. Cullet Pads Storage Pile: Cullet is stored in a three-sided containment for holding prior to re-use in the melting furnace. The maximum storage pile area is 150,000 square feet, with a maximum of 50,000 tons of cullet transfers per year. 9. Vehicular Traffic: The facility contains 0.4 miles of paved roads, and 0.2 miles of unpaved roads utilized by a variety of vehicles resulting in 7251 miles/year for LDGV, 104 miles/year for HDGV, and 4824 miles/year for HDDV. Emission Unit Data: 1. Emission Unit: Facility ID: Manufacturer: Max. Throughput: Primary Fuel: Secondary Fuel: Restrictions: Control Device(s): Glass Melting Furnace S-001 Unknown 350 tons of glass per day Natural gas (supplemented with oxy-fuel firing) None Limited to 350 tons/day of glass pulled; natural gas with oxy-fuel firing only Dry lime injection scrubber followed by a three-field electrostatic precipitator 2. Emission Unit: Facility ID: Capacity: Throughput: Control device: Virgin Lime Silo S cubic feet (10.9 ft diameter x 23.0 ft height) 750 pounds of lime per hour Baghouse 3. Emission Unit: Facility ID: Capacity: Max. Throughput: Control device: Used Lime Silo S cubic feet (5.9 ft diameter x 23.0 ft height) 750 pounds of lime per hour Baghouse 4. Emission Unit: Facility ID: Raw Materials: Max. Usage: Control Device: Glass and Roll Coating F-001 Sulfur Dioxide 60,000 pounds per year (30.0 tons per year) None 2

3 5. Emission Unit: Facility ID: Raw Materials: Max. Usage: Control Device: Float Glass Cutting F-003 Odorless mineral spirits (naphtha, heavy alkylate) 7000 gallons per year None 6. Emission Unit: Emergency Back-up Generators Facility ID: Power Output: Primary Fuel: Secondary Fuel: Restrictions: S-020, S-021, and S KW, 900 KW, and 500 KW Diesel None Limited to 500 hours of operation per year; only diesel fuel as a fuel 7. Emission Unit: Facility ID: Capacity: Raw Materials: Control Device: Cullet Return S ,750 tons per year Cullet Cyclone (Torit DownFlow Model 2DF16) 8. Emission Unit: Facility ID: Size: Control Device: Restrictions: Cullet Pads Storage Piles N/A 150,000 square feet total area None Total transfers limited to 127,750 tons per year 9. Emission Unit: Parking Lots: Paved Roads: Unpaved Roads: Vehicle Types: VMT: Restrictions: Vehicular Traffic 37,200 square feet 0.4 miles 0.2 miles Gasoline powered automobiles; two (2) five-ton dump trucks, and pay loader with two-yard bucket LDGV=7251 miles/year; HDGV=104 miles/year; HDDV=4824 miles/year 10 mph speed limit; watering of roadways 3

4 Emission Units of Minor Significance: The following table summarizes the processes and/or activities conducted at the Guardian Industries facility that were determined to be of minor significance: I.D. S002 S003 F005 F006 F008-F020 F021 F024 F002 D001, D002, D003 D004 TABLE 1 Emission Sources of Minor Significance SOURCE BASIS FOR EXEMPTION DESCRIPTION Cullet Hopper Sand Silo Check Scale Cullet Conveyor Raw Material Bins Raw Material Elevator Batch house basement Tin Bath Sealing Baghouse exhausts indoors; PTE less than 0.1 tpy Baghouse exhausts indoors; PTE less than 0.1 tpy Baghouse exhausts indoors; PTE less than 0.1 tpy Baghouse exhausts indoors; PTE less than 0.1 tpy Baghouses exhaust indoors; PTE less than 0.1 tpy Baghouse exhausts indoors; PTE less than 0.1 tpy Baghouse exhausts indoors; PTE less than 0.1 tpy De minimus VOC/HAP emissions 4 RESTRICTIONS Doors, windows and other openings to enclosure shall be kept closed at all times during operation Doors, windows and other openings to enclosure shall be kept closed at all times during operation Doors, windows and other openings to enclosure shall be kept closed at all times during operation Doors, windows and other openings to enclosure shall be kept closed at all times during operation Doors, windows and other openings to enclosure shall be kept closed at all times during operation Doors, windows and other openings to enclosure shall be kept closed at all times during operation Doors, windows and other openings to enclosure shall be kept closed at all times during operation Use less than 1500 pounds per year of RTV sealant 275-Gallon Storage Tanks Diesel fuel storage Diesel fuel storage only 300-Gallon Waste Oil Storage Tank 275-Gallon Oil-Water Discharge Tank No hazardous components/low volatility No hazardous components/low volatility Non-hazardous and low-voc material storage only Non-hazardous and low-voc material storage only D Gallon Storage Tank Diesel fuel storage Diesel fuel storage only D Gallon Storage Tank Diesel fuel storage Diesel fuel storage only D Gallon Storage Tank Diesel fuel storage Diesel fuel storage only N/A N/A N/A Tin Bath Chlorination N.G. Warehouse Space Heaters Checker Burn Sulfate Maintenance Removal Less than 5 pounds chlorine/yr De minimus emissions De minimus emissions None Natural Gas as fuel only None N/A N.G. Hot Water Heaters De minimus emissions Natural Gas as fuel only

5 PROCESS DESCRIPTIONS: 1. Glass Melting Furnace The existing melting furnace is a side-port continuous regenerative furnace with the capacity to produce 350 tons of glass per day. The batch mixture is fed into the furnace using a computer-controlled charger that controls the batch mixture feed rate. The mixture is heated in the furnace to 2900ºF to 3000ºF, which melts the mixture to form a homogeneous bath of molten glass. The molten glass flows by gravity and displacement out of the opposite end of the furnace into the molten tin float bath, and then to the annealing lehr, and finally out to the cutting and packaging operations. Emissions from this process result from the combustion of natural gas, as well as the melting of the raw materials used in making the glass itself. Selenium, along with other compounds, is used in the batches in order to produce a specialty colored (tint) glass product used in the automotive industry. Due to its relatively low melting, boiling, and vaporization points, selenium will readily volatilize into a vapor when introduced into the molten glass bath. The selenium vapor cools and acts as fine particulate once it exits the stack. A dry lime injection scrubber and electrostatic precipitator (ESP) control system controls the selenium and particulate matter, and as a result of the interaction of the gas stream contents with the lime, sulfur dioxide as well. Monitoring Methodology: In order to demonstrate compliance, the permittee shall monitor the following parameters: 1) The primary and secondary voltage (in volts) and primary and secondary current (in amps) at each transformer on the electrostatic precipitator; 2) The spark rate (in sparks per minute) in each section of the electrostatic precipitator; 3) The feed rate of lime into the scrubber (in pounds per hour); 4) The nitrogen bubbling rate; 5) The level of electric boost (kw) for each zone ; 6) The amount of oxy-fuel combusted; 7) The opacity of visible emissions from the ESP Stack (S001); and 8) NOx emissions from the NOx analyzer. 5

6 Maximum Potential Emissions Summary: Table 2 Emissions Limitation for the Glass Melting Furnace HOURLY EMISSION ANNUAL EMISSION POLLUTANT LIMIT (lb/hr) LIMIT (tons/year)a PM 6.57b / 12.1c 28.8b / 53.0 c PM b / 12.1c 28.8b / 53.0c NOX SO CO CO 2 12,600 55,188 VOCs Se Compounds Total HAPs a a year is defined as any consecutive 12-month period. b as determined by usepa method 5 and the ACHD Source Testing Manual c as determined by USEPA Methods 1-5, Method 202, and the ACHD Source Testing Manual EMISSION CALCULATIONS: Since NSPS Subpart CC, Standards of Performance for Glass Manufacturing Plants applies to the facility, the emission standard from Installation Permit No I002 of grams of particulate matter per kilogram of glass produced was used to determine the short-term emission rate for the furnace: PM/PM10 limit = (0.225g/kg) x (1.0 kg/2.2 lb) x (1.0 lb/454 g) x (2000 lb/ton) x (350 tons/day of glass) x (1.0 day/24 hr) = 6.57 lb/hr PM/PM10 annual emission limit = (6.58 lb/hr) x (8760 hr/yr) x (1 ton/2000 lb) = 28.8 ton/yr The above NSPS limit is lower than the limit that would be calculated using the equation below from Article XXI c.24 Allowable PM emissions (lb/hr) = 0.76 x (50 x tons of glass/fill charged per hour) Therefore, by complying with the NSPS limit the source also meets the Article XXI requirement. The sulfur dioxide limit was calculated assuming a control device efficiency of 50%, and using the stack test results from September 2000 that indicated an average precontrol sulfur dioxide emission rate of lb/hr at a Priva-Guard glass production rate of 327 tons/day. Adding an additional 10% to allow for testing variation and scaling up to 350 tons/day yields the following result: SO2 hourly limit = (41.27 lb/hr) x (1.1) x (0.5) x (350/327) = 24.3 lb/hr 6

7 SO2 annual limit = (24.3 lb/hr) x (8760 hr/yr) x (1 ton/2000 lb) = ton/yr The selenium limit was set according to the ESP manufacturer guarantee of 2.2 lbs/hr. The annual limit was calculated assuming continuous operation, i.e., 8760 hours per year. The annual limit was calculated at 9.5 tons/yr of selenium. The limit for total HAPs was calculated using the September 2000 stack test results for trace metals analysis, which indicated a maximum hourly rate of lb/hr of chromium, and lb/hr for cobalt, in addition to the selenium. Using these maximum amounts, and adding an additional 10% to allow for testing variation, yields an hourly additional HAPs rate of: (0.161 lb/hr lb/hr) x 1.1 = lb/hr Adding this to the selenium limit of 2.17 lb/hr yields a total HAP limit of 2.35 lb/hr. Based on continuous operation, the annual limit would be 10.3 tons/yr. In addition to the above PM and HAP limits, the permittee shall comply with Title 40 CFR Part 63, Subpart SSSSSS by meeting one of the following emission limits: 9) The 3-hour block average production-based PM mass emission rate shall not exceed 0.1 gram per kilogram (g/kg) (0.2 pound per ton (lb/ton)) of glass produced; OR 10) The 3-hour block average production-based metal HAP mass emission rate shall not exceed 0.01 g/kg (0.02 lb/ton) of glass produced. The limits for nitrogen oxides were based on the Alternative NOx Compliance Schedule approved by the Department in accordance with Title , which allows emissions of 250 lbs/hr of NOx averaged over a calendar day. NOx = 250 lbs/hr; based on continuous operation, the annual limit = 1095 tons/yr The CO and VOCs limits were based on estimates and factors from Guardian. 2. Virgin Lime Silo Guardian utilizes a storage silo to store the hydrated lime needed for the scrubber system. To control particulate emissions from the transfers of lime to this silo, a dedicated dust collector (baghouse) was installed. Monitoring Methodology: In order to demonstrate compliance, the permittee shall monitor the opacity of visible emissions of the Virgin Lime Silo dust collector on a daily basis. 7

8 Maximum Potential Emissions Summary: POLLUTANT Table 3 Emissions Limitation for the Virgin Lime Silo HOURLY (lb/hr) 8 ANNUAL (tons/year)* PM/PM * A year is defined as any consecutive 12-month period. EMISSION CALCULATIONS: The emission limits were calculated assuming an outlet grain loading limit of 0.01 gr/dscf. The exhaust flow rate of 1000 scfm was not corrected for moisture or temperature since the unit will operate at ambient conditions. All particulate matter was assumed to be PM10. The Department considers that a no observable visible emissions requirement (Method 22) will reasonably demonstrate compliance with the emission limitation. PM/PM10 = (0.01 gr/ft3) x (1.0 lb/7000 gr) x (1000 ft3/min) x (60 min/hr) = 0.09 lb/hr. All long-term limitations were calculated using the hourly limits multiplied by 8760 hours per year. PM/PM10 = (0.09 lb/hr) x (8760 hr/yr) x (1.0 ton/2000 lb) = 0.39 ton/yr. 3. Used Lime Silo Guardian utilizes a storage silo in order to store the hydrated lime that is exhausted from the scrubber. This material is packaged and shipped off site for disposal. To control particulate emissions from the transfers of lime to this silo, a dedicated dust collector (baghouse) was installed. The Department considers that a no observable visible emissions requirement (Method 22) will reasonably demonstrate compliance with the emission limitation. Monitoring Methodology: In order to demonstrate compliance, the permittee shall monitor the opacity of visible emissions of the Used Lime Silo dust collector on a daily basis. Maximum Potential Emissions Summary: POLLUTANT Table 4 Emissions Limitation for the Recycled Lime Silo HOURLY (lb/hr) ANNUAL (tons/year)* PM/PM * A year is defined as any consecutive 12-month period.

9 EMISSION CALCULATIONS: The emission limits were calculated assuming the BACT outlet grain loading limit of 0.01 gr/dscf. The exhaust flow rate of 100 acfm was corrected for moisture and temperature to scfm. All particulate matter was assumed to be PM10. PM/PM10 = (0.01 gr/ft 3 ) x (1.0 lb/7000 gr) x (55.21 ft 3 /min) x (60 min/hr) = 0.01 lb/hr. All long-term limitations were calculated using the hourly limits multiplied by 8760 hours per year. PM/PM10 = (0.01 lb/hr) x (8760 hr/yr) x (1.0 ton/2000 lb) = 0.05 ton/yr. 4. Glass and Roll Coating To prevent the molten tin from adhering to the rollers and to the glass itself, Guardian coats the glass and rollers with sulfur dioxide from pressurized cylinders. The sulfur dioxide is emitted as a fugitive emission at the facility. Monitoring Methodology: In order to demonstrate compliance, the permittee shall monitor the amount of sulfur dioxide used (in pounds) of the Glass and Roll Coating process on a monthly and 12-month rolling total basis. Maximum Potential Emissions Summary: POLLUTANT Table 5 Emissions Limitation for the Glass and Roll Coating HOURLY (lb/hr) ANNUAL (tons/year)* SO * A year is defined as any consecutive 12-month period. EMISSION CALCULATIONS: Based on a continuous operation and estimates from Guardian, the process requires a maximum of 60,000 pounds of sulfur dioxide per 12-month period. This value was rounded up from 45,900 pounds of actual usage reflected in the permit application to allow for production increases above the 327 tons per day of glass (i.e., the maximum furnace pull rate of 350 tons per day). Assuming 8,760 hours per year, the hourly and annual limits would be: 60,000 lbs/yr x 1 ton/2000 lbs = 30.0 tons/yr (assuming all is emitted) 60,000 lbs/yr x 1 yr/8760 hr = 6.9 lbs/hr 5. Flat Glass Cutting Guardian uses low-odor mineral spirits, which are essentially naphtha and heavy alkylates, as a cutting oil to lubricate the glass cutters. Monitoring Methodology: 9

10 In order to demonstrate compliance, the permittee shall monitor the amount (in gallons) and the VOC content (in pounds per gallon) of the mineral spirits used in the Flat Glass Cutting process on a monthly and 12-month rolling total basis. Maximum Potential Emissions Summary: Table 6 Emissions Limitation for Flat Glass Cutting POLLUTANT HOURLY (lb/hr) 10 ANNUAL (tons/year)* VOCs * A year is defined as any consecutive 12-month period. EMISSION CALCULATIONS: Based on estimates from Guardian, the maximum cutting oil usage per 12-month period would be 7,000 gallons. This value is rounded up from the 3,751 gallons of actual usage reflected in the permit application to allow for increased production up to 350 tons per day of glass. One gallon of the mineral spirits weighs 6.24 pounds, and contains 100% VOCs. Using this data, and assuming all VOCs are emitted as fugitives, the following emission limits were calculated: 7,000 gal/yr x 6.5 lbs VOCs/gal = 45,500 lbs/yr = tons VOCs/yr 45,500 lbs/yr x 1 yr/8760 hr = 5.2 lb VOCs/hr 6. Cullet Return Guardian uses cullet to supplement the glass batches. The cullet is essentially the trimmings and defective glass that is broken up and returned to the batches. The cullet is stored in six (6) three-sided open containments. A dedicated cyclone control device controls the emissions of particulate matter from the transfer points into the batches. Monitoring Methodology: In order to demonstrate compliance, the permittee shall monitor the opacity of visible emissions of the Cullet Return dust collector on a daily basis. Maximum Potential Emissions Summary: POLLUTANT Table 7 Emissions Limitation for the Cullet Return HOURLY (lb/hr) ANNUAL (tons/year)* PM * A year is defined as any consecutive 12-month period.

11 EMISSION CALCULATIONS: Assuming an outlet grain loading of 0.01 gr/dscfm, an exhaust flow rate of 7232 acfm, ambient conditions, and continuous operation, the PM emission limits were calculated. Since the unit operates at ambient conditions, the difference between acfm and dscfm is minimal; therefore, for calculation purposes, the 7,232 ft 3 /min maximum flow was assumed: The Department considers that a no observable visible emissions requirement (Method 22) will reasonably demonstrate compliance with the emission limitation. PM = (7232 ft 3 /min) x (60 min/hr) x (1.0 lb/7000 gr) x (0.01 gr/ft 3 ) = 0.62 lb/hr PM = (0.62 lb/hr) x (8760 hr/yr) x (1 ton/2000 lb) = 2.7 ton/yr 7. Cullet Pads Storage Pile The cullet is stored in six (6) three-sided open-top containments. PM emissions due to wind erosion will be insignificant. PM emissions will essentially occur from the transfers of cullet. The Department considers that a no observable visible emissions requirement (Method 22) will reasonably demonstrate compliance with the emission limitation. Monitoring Methodology: In order to demonstrate compliance, the permittee shall monitor the amount (in tons) of cullet transferred in the Cullet Storage Process on a monthly and annual basis. Maximum Potential Emissions Summary: Table 8 Emissions Limitation for the Cullet Pads Storage Pile ANNUAL POLLUTANT (tons/year)* PM 0.9 * A year is defined as any consecutive 12-month period. EMISSION CALCULATIONS: Calculations were performed as per AP-42, , Aggregate Handling and Storage Piles. Since no moisture content data is available for cullet, a conservative moisture content of 1.0% was assumed. E = k x (0.0032) x {[(U/5) 1.3 ]/[(M/2) 1.4 ] = lb/ton of PM, where k=0.74, U=9 mph, and M = 1.0% E = 0.74 x (0.0032) x {[(9/5) 1.3 ]/[(1/2) 1.4 ] = lb/ton of PM Since a maximum of 127,750 tons are transferred per 12-month period, the annual PM limit would be: (0.014 lb/ton) x (127,750 tons/yr) = 0.9 tons/yr 11

12 8. Vehicular Traffic The facility contains 0.5total miles of paved roads, 0.1 miles of unpaved roads, and a total of 37,200 square feet of parking lots. Guardian estimates the annual light-duty gasoline vehicle miles traveled (VMT) at 7251 miles, the heavy-duty gasoline VMT traveled at 0miles per year, and the heavy-duty diesel VMT at 4927 miles per year. The road dust emissions were estimated using the factors and methodology in AP-42, Emission controls will include speed limit restrictions of 10 mph or less, and the watering of roadways and parking lots, where applicable. Maximum Potential Emissions Summary: Table 9 Emissions Limitation for Vehicular Traffic POLLUTANT ANNUAL (tons/year)* PM 5.2 * A year is defined as any consecutive 12-month period. The emission calculations performed in Title V Operating Permit Application No were reviewed and edited where applicable to adjust for allowable short-term and long-term emission limitations, using the best data and engineering judgment available, i.e., AP-42 factors, stack tests, batch data, emission factors, etc. TITLE V OPERATING PERMIT APPLICATION COMPONENTS: 1. Installation Permit Application No I002, received December BACT correspondence from Guardian to the Department dated February 23, 2001 and May 3, Operating Permit Application No. 0023, dated November 24, Operating Permit Application No. 0023, Title V Application Update, dated October 16, Installation Permit No I002 Application Amendment, received March 1, Operating Permit Renewal Application No. 0023, received April 9, Installation Permit Application No.0023-I003, received June 17, Compliance Assurance Monitoring (CAM) Plan, received January 19, Installation Permit Application No.0023-I004, received July 15, METHOD OF DEMONSTRATING COMPLIANCE: Compliance with the emission standards set in this permit will be demonstrated by the Compliance Assurance Monitoring (CAM) Plan. The facility is subject to the CAM Rule with regards to particulate matter, sulfur dioxide, and selenium. The CAM Plan is discussed in more detail in the applicable regulations section of this document. Compliance will also be demonstrated by the proper operation, calibration and maintenance of the processes and associated control devices according to manufacturers= recommendations and good engineering judgment. In addition, periodic stack testing of the process for nitrogen oxides (NOX), sulfur dioxide (SO2), particulate matter less than 10 microns in diameter (PM10), hazardous air pollutants (HAPs), carbon monoxide (CO) and volatile 12

13 organic compounds (VOCs) is required. Records of all material throughput will be kept on a daily, monthly and annual basis, where applicable. All pertinent operating parameters of the processes and associated control devices shall also be monitored and recorded on a continuous basis. In addition, a Continuous Emission Monitor (CEM) for NOx has been installed and will be used to demonstrate compliance with emission limitations. All instances of non-compliance will be reported to the Department on a semi-annual basis. See also Compliance Assurance Monitoring below. See Title V Operating Permit #0023 for specific conditions. TESTING REQUIREMENTS: Stack testing is in accordance with e, i, , and 40 CFR 60.8, and will be performed every other year for sulfur oxides and nitrogen oxides. Stack testing for particulate matter, selenium and other hazardous metals emissions shall be performed once every four years. The test report shall indicate the operating parameters of the process and control equipment during the stack test in order to demonstrate compliance with the emission limitations in this permit. The next stack test shall be performed in October See Title V Operating Permit #0023 for specific conditions. APPLICABLE REGULATIONS: Virgin Lime Silo, Used Lime Silo BACT: Fabric filters provide the most effective technically feasible means of controlling particulate emissions from material handling operations. The outlet grain loading limit of 0.01 grains per dry standard cubic feet of airflow, and the proper operation and maintenance of the aforementioned control device constitutes BACT for the Virgin Lime Storage and Recycled Lime Silos. Glass Melting Furnace RACT: The Glass Melting Furnace is subject to Reasonably Available Control Technology (RACT) provisions for NOX emissions. The Plan Approval Order and Agreement No. 242 states that at no time shall Guardian exceed a limit of 40.0 pounds of NO X emissions per ton of glass produced. It also requires that Guardian perform emissions testing for NO X emissions every two (2) years, and that records of fuel use, operating hours, maintenance, inspections, repairs, calibration and/or replacement of fuel-burning equipment be kept. Daily batch and furnace operation logs are also required. NSPS: Since Guardian commenced modifications to their process at the end of 1998 (prior to installation of controls) that resulted in an emissions increase of particulate matter that meets the applicability conditions of 60.14, the facility is subject to the New Source Performance Standards (NSPS), Subpart CC, Standards of Performance for Glass Manufacturing Plants. To determine applicability, Appendix C of Part 60 was used, and stack test data from 1996 and 2000: Before/after emission rates of particulate matter: Ea = ( )) 3 = 12.6 lb/hr average (1996) Eb = ( )) 3 = lb/hr average (2000) 13

14 Sample Variance: S a 2 = [( ) 2 + ( ) 2 + ( ) 2 ]) 3 = Sb 2 = [( ) 2 + ( ) 2 + ( ) 2 ]) 3 = Pooled estimate: Sp = [(3-1) x (1.4901) + (3-1) x (0.0167) ) ( )] 0.5 = Test static: t = ( ) ) (0.868 x (1/3 + 1/3) 0.5 ) = From Table 1 in Appendix C, t= = The value of t from above is greater than t=, and therefore the difference between Ea and Eb is significant, which triggers NSPS requirements. The NSPS requirement for particulate matter as per Table CC-1, Emission Rates, is grams per kilogram of glass produced. This value corresponds to pounds per ton of glass produced. The short term and long term emission limits for particulate matter were based on a maximum of 350 tons per day of glass, which represents an average glass pull rate of tons per hour. On March 11, 2002, an installation permit was issued requiring installation of an electrostatic precipitator (ESP). This installation permit took into account all emissions increases that may have resulted from installation of electric boost, nitrogen bubbling, and oxy-fuel firing capabilities previously. Pursuant to (b), the facility is not subject to 40 CFR Part 60, subpart IIII because the emergency generators commenced construction before July 11, MACT/NESHAP: The facility is subject to 40 CFR 63 Subpart SSSSSS, Glass Manufacturing Area Sources as it meets all (3) conditions for an affected source under 40 CFR This standard requires that the permittee demonstrate compliance at all times with the following: 1) The 3-hour block average production-based PM mass emission rate shall not exceed 0.1 gram per kilogram (g/kg) (0.2 pound per ton (lb/ton)) of glass produced; or 2) The 3-hour block average production-based metal HAP mass emission rate shall not exceed 0.01 g/kg (0.02 lb/ton) of glass produced. The facility is subject to 40 CFR 63, Subpart ZZZZ National Emission Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines. The facility is subject to this subpart because it operates existing emergency generators at an area source of HAP. 14

15 COMPLIANCE ASSURANCE MONITORING (CAM): Provisions of 40 CFR Part 64 have been met by this facility. The renewal application for the Title V Operating Permit included a Compliance Assurance Monitoring Plan. Pre-control emission levels of particulate matter, sulfur dioxide, selenium, and nitrogen oxides exceed the major source thresholds of each respective pollutant. Although an NSPS applies to particulate matter, the final rule pre-dates the 1990 CAAA. The facility became subject to the CAM Rule upon the installation of the Lime Injection Scrubber and Electrostatic Precipitator control devices. 1. Particulate Matter: Guardian installed a three-field electrostatic precipitator to control the emissions of particulate matter from its Glass Melting Furnace. A continuous opacity monitoring system (COMS) was also installed and satisfies the provisions of 64.3(a)(1)-(2), Special criteria for the use of continuous emission, opacity or predictive monitoring systems. Monitoring the primary and secondary voltage at each transformer, primary and secondary current at each transformer, and the spark rate in each portion of the electrostatic precipitator will demonstrate compliance for the particulate matter emission limitations. The indicator range will be based on historical operation and stack test data. The primary voltage and current at each transformer will be manually monitored weekly and recorded in a log book. The secondary voltage and current at each transformer and the spark rate in each portion of the electrostatic precipitator will be monitored continuously and recorded electronically. 2. Selenium: Guardian installed a lime injection scrubber to control the emissions of selenium from the Glass Melting Furnace. The control device parameters will be monitored on a continuous basis in order to meet the emission limitations set in the permit below the threshold of a major source, i.e., 10 tons per year. The indicator range for the hydrated lime target feed rate to the lime injection scrubber will be 90 lbs/hour during normal operations. It will vary no more than three standard variations, plus or minus, from the average of the feed rates recorded during the most recent stack test which demonstrated compliance with permit emission limits. The lime injection feed rate and other applicable parameters established during initial compliance testing will be continuously monitored, average hourly and recorded electronically. 3. Sulfur dioxide: The lime injection scrubber will control the emissions of sulfur dioxide. As per the selenium description above, monitoring the scrubber reagent feed rate will demonstrate compliance for the sulfur dioxide emission limitations. The indicator range for the hydrated lime target feed rate to the lime injection scrubber will be 90 lbs/hour during normal operations. It will vary no more than three standard variations, plus or minus, from the average of the feed rates recorded during the most recent stack test which demonstrated compliance with permit emission limits. The lime injection feed rate will be continuously monitored, averaged hourly and recorded electronically. 4. Nitrogen Oxides: The oxy-fuel firing and electric boost systems of the Glass Melting Furnace will control the emissions of nitrogen oxides. These systems were designed and installed to make the process more fuel-efficient, i.e., to reduce the demand of natural gas. The parameters of these systems will be monitored and recorded in order to demonstrate compliance for this pollutant. The electric boost output in zone 1 and zone 2 will be monitored. The output of zone 1 will be maintained between 0 and 810 kw and the output of zone 2 will be maintained between 0 and 1890 kw. Zone 1 or zone 2 may be operated with or without the other zone in operation. The amount of kw used is determined by monitoring the furnace bottom temperature. A range between 1600 F and 2000 F is maintained. The electric boost system is shut down a minimum of twice per day for under furnace inspection. The electric boost system is monitored by a meter and recorded once every twelve hours and when a change to the set point occurs. The temperature of the furnace bottom is recorded continuously by a temperature sensor with a display in the control room. A continuous emission monitoring system for NOx measurement has been installed on the glass melting furnace. Results of the NOx analyzer are submitted to the Department quarterly to demonstrate compliance for this pollutant. 15

16 STATE REGULATIONS Control of NOx Emissions from Glass Melting Facilities ( ) The requirements of Title 25 Chapter 129 Sections through , Control of NOx Emissions from Glass Melting Facilities, are incorporated by reference in the permit. These regulations will apply to the Glass Melting Furnace because this furnace emits, or has the potential to emit, 50 tons per year of NOx. Except as specified in , (c), , and , the owner or operator of a glass melting furnace may not operate the glass melting furnace in a manner that results in NOx emissions in excess of 7.0 lbs of NOx per ton of glass pulled or NOx emission limits contained in an installation or operating permit, whichever are lower. The permittee requested an Alternative Compliance Schedule for compliance with the Chapter 129 regulations.( (c)(2)).and the Department is including the requirements of the approved Alternate Compliance Schedule in order to make them federally enforceable.. The details of the Alternative NOx Compliance Schedule have been incorporated into this permit and include the following: 1. Best operating practices: a. Combustion Control- Flame surveys and waste gas analyses are done on a weekly basis. b. Temperature Control- The operation is dependent upon stable temperatures throughout the process. Temperatures are measured both by thermocouples placed strategically throughout the structure and by hand held optical pyrometers. Variations in furnace temperatures are potentially detrimental to the convection currents necessary for process stability. c. Furnace Structure and Integrity- Burners and burner blocks are inspected and cleaned on a weekly basis. d. Batch Stability- Both the composition and amount of material in the furnace are monitored to achieve stability. e. NOx Control- Flame survey s, waste gas analysis and burner adjustments are conducted on a weekly basis in order to maximize combustion efficiency as well as to ensure the emission limits are in specification. Checker Burns are done to increase the amount of possible airflow for better combustion. 2. Submittal of NOx CEM quarterly reports to include date, hour, lb NOx/hour and lb NOx/ton glass pulled. 3. A limit of 250 lbs/hr of NOx averaged over a calendar day. 4. The following schedule of interim measures and milestone dates: Phase Interim Measure Milestone Date I Continue using low NOx burners and electric boost with best Ongoing operating practices II Submit NOx CEM data to ACHD Send by 1/31/2012 III Initiate Cold Tank Repair (CTR) Discussions 12/31/2011 IV Obtain PTI for flat flame burner and oxygen lancing installation 12/31/2011 V Initiate Engineering and Vendor Discussions for SCR system 3/31/

17 VI Initial CTR Budget 3/31/2012 VII Submit CTR Permit Application (including SCR) 8/30/2013 VII Final CTR Budget 12/31/2013 IX Issue PO for SCR 3/31/2014 X Furnace Shutdown for CTR 1/31/2015 XI Start-up Furnace 5/31/2015 XII Performance Test and Compliance On or before 180 days after start-up NON-APPLICABLE REGULATIONS: The pollutants and emission levels associated with any installations at the facility do not trigger PSD or NSR since they represented a reduction in actual emissions, no new pollutants are emitted, and the source is an existing source. MACT regulations do not apply since this will be considered a synthetic minor source with respect to HAPs, and no area source categories have been promulgated for this type of source. Greenhouse Gas Reporting (40 CFR Part 98): There are no Title V applicable requirements for greenhouse gases. Furnace CO 2 emissions = (105,000 SCF/hr) x (120,000 lb/10 6 SCF) = 12,600 lb/hr Furnace CO 2 emissions= (12,600 lb/hr) x (8760 hr/year) x (1 ton/2000 lbs) = 55,188 tons/year RECOMMENDATION: Note: 120,000 lb CO2/ 10 6 SCF from AP-42 Table It is recommended that Title V Operating Permit No be renewed. Operating in accordance with the approved Alternate Compliance Schedule and proper operation and maintenance of the Hydrated Lime Injection scrubber and Electrostatic Precipitator insures the facility is in full compliance with all applicable regulations of Article XXI. 17