COMMONWEALTH OF PENNSYLVANIA Department of Environmental Protection Southwest Regional Office

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Background

Air Quality File SOOP-63-0~1 ~ 0 ~

Barbara R. Hatch, PE ~ ~ Environmental Engineer ~nager Air Quality

Mark A. Wayner, PE ~"'JY Regional Program Managel' 1 VI Air Quality

November 6, 2012

Review of Application for State Only Operating Permit World Kitchen, LLC (Formerly Coming Consumer Products Company) Charleroi Plant, Washington County

OFFIGW. FILE COPY

MEMO

World Kitchen, LLC (WK) makes Pressed and Blown glass in the "Other than Borosilicate, Soda-Lime, and Lead Recipe" category under Standard Industrial Code 3229at this facility located in Charleroi, Washington County. Company currently operates one melting tank (Source 107, aka Tank 61 or 11), a tunnel kiln (rated at 17.71 mmbtu/hr), approximately 25 other smaller ( <5 mmbtu/hr) combustion sources, material handling operations and a chrome plating line in support of their operation. Dry raw materials are mixed together in prescribed formulas called "batch" . Batch is fed into the furnace where it melts and then flows to the furnace forehearth. Various ingredients are added to the molten glass to refine it, eliminate bubbles, and correct the chemistry. Molten glass flows to the mold machine area where it is formed into tableware. Products may be tempered in the tunnel kiln to relieve interior stresses. Additional processing may include polishing, decoration and packaging.

This facility has been in operation since the 1940s, but Departmental records for the site start in 1984. Earliest records for Source 107 indicate a design capacity of 108 tons glass pulled per day. Over the years, Coming has increased the throughput rate of the source through various changes, such as conversion to 1 00% gas-oxygen firing and installation of increased electric boost but emissions have not increased.

Plan Approval PA-63-00110H was issued on April19, 2010 to authorize the installation of additional electric boost capacity on Source 107, to establish Source 107 NOx emissions at less than 50 tpy, to establish the entire facility as a Synthetic Minor, and to approve the generation of Emission Reduction Credits generated from the shutdown of Source 105. Reductions in NOx emissions were achieved by resuming the use of sodium sulfate as a fining agent and discontinuing the use of sodium nitrate. During a routine rebricking operation, Coming increased the electric boost system (increasing boost from 1650 kWH or 39,600 kilowatts per day to 1900 kWH or 45 ,600 kilowatts per day). The melt tank area was not increased, the forehearth cross section was not changed, and no emission increases resulting from this project were approved.

On August 2, 2010, DEP received from WK a request to modify Plan Approval to authorize the installation on Source 107 of two burners, each rated at 2.0 mmbtu/hr. The position of these new burners provided better heat distribution on Source 107.

World Kitchen SOOP-63-00110 Review Memo ll /2012

On March 4, 2011 DEP received from WK. a request to extend the Plan Approval and to modify the Plan Approval to authorize an increase in the allowable SOx emissions from Source 107, and facility-wide . Original SOx limits established in PA-63-00 11 OH were 13 .7 lb per hour and 60 tons per year, with a facility-wide limit of 65 tons SOx per year. Applicant requested that SOx limits from Source 107 be increased to 20.5 pounds per hour and 90 tons per year, with a facility-wide limit of 95 tons SOx per year. Except for a SOx limit of 500 ppm established in accordance with PA Code Title 25 § 123.21 , the facility has never had a limit established for SOx emissions. Company reported SOx emissions in excess of200 tons per year during the time period 1990 through 1995, so clearly they have always had the capability of using sodium sulfite. Since this change does not constitute a modification or reconstruction, the issuance of a new Plan Approval to authorize this increase is not warranted.

In early 2001 , WK. met with the Department to discuss upcoming plans for the Charleroi facility. At that time, they were discussing the possibility of increasing the design capacity of Source 107 to 230 tons per day. They anticipated an increase in particulate emissions from Source 107. On this basis, DEP notified WK. that an increase in particulate matter would trigger the applicability of 40 CFR 60, Subpart CC- Standards of Performance for Glass Manufacturing Plants, and require the installation of an opacity CEM in accordance with 40 CFR § 60.293(c).

WK. included the Opacity CEM in their capital budget and had it installed and certified. However, the proposed project that included an increase in particulate matter never transpired, and there has been no increase in particulate matter. On March 31 , 2010, as part of a rebricking initiative, WK. tore down Stack 107, and disabled the existing Opacity CEM. On January 31 , 2011 , the Department received a letter from World Kitchen requesting that they no longer be required to participate in the CEMS Program. World Kitchen does not have a regulatory obligation to keep an Opacity Monitor certified in the CEMS program. The installation, operation and maintenance of an Opacity CEM have never been included in a Plan Approval or an Operating Permit. The Department agreed to WK. 's request that the Opacity Monitor no longer be included in the CEMs Program.

Regulatory Analysis

The potential applicability of the 40 CFR 60 Subpart CC-Standards of Performance for Glass Manufacturing Plants has been evaluated. Per 40 CFR 60.290, a glass melting furnace that commences construction or modification after June 15, 1979 is subject to the requirements of the regulation. The regulation deals only with allowable particulate emissions. Per 40 CFR 60.2 , "modification means any physical change in, or change in the method of operation of, an existing facility which increases the amount of any air pollutant (to which a standard applies) emitted to the atmosphere by that facility." Since the NSPS sets standards for particulate, an increase in particulate emission rate would make the furnace subject to the NSPS. In 1987, Corning approached the Department about increasing the allowable throughput for Source I 07 from 120 tons glass pulled per day to 170 tons glass pulled per day. At that time they committed to an allowable PM emission rate as would be calculated using the factors and equation found at Title 25 PA Code 123 .13(b )(2). This set an allowable limit of 8.94 lb/hour. Allowable throughput was increased from 170 to 200 tons glass pulled per day. At that time, a PM emission rate of 6.0 lbs/hour was established. In WK.'s SOOP, DEP has carried over an allowable emission rate of 6.0 lbs PM/hr for Source 107. WK./Corning has been able to increase these throughputs through the addition of electric boost and 100% gas/oxygen firing. Even though the charge rate has gone up over the years, the use of electric boost and 100% gas/oxygen firing has effectively reduced the volume and velocity of exhaust gases, allowing them to meet these restricted particulate matter emission limits. Electric boost is used to partially replace the use of natural gas and is not intended to increase material throughput. Since WK. has not modified (as defined at 40 CFR 60.14) their facility since June 15, 1979, the requirements of 40 CFR 60 - Subpart CC are not applicable to this facility.

The potential applicability of 40 CFR 61 , Subpart N- National Emission Standard for Inorganic Arsenic Emissions From Glass Manufacturing Plants has been evaluated. This NESHAP applies to glass melting furnaces that use commercial arsenic as a raw material in any amount. No minimum glass production threshold is established. Arsenic that is a naturally occurring trace constituent of another substance is not considered

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World Kitchen SOOP-63-00110 Review Memo 11 /2012

"commercial arsenic". This rule was promulgated on August 4, 1986. At that time WK notified DEP and EPA that they were no longer going to use commercial arsenic as a raw material. WK does not currently and does not plan to use commercial arsenic as a raw material in Source 107 melting furnace. Therefore this NESHAP is not an applicable requirement for this facility.

The potential applicability of 40 CFR 63 Subpart SSSSSS-National Emission Standards for Hazardous Air Pollutants for Glass Manufacturing Area Sources has been evaluated. Subpart SSSSSS applies only to glass manufacturing plants that operate continuous furnaces and use one or more of the glass manufacturing metal Hazardous Air Pollutants, which are Arsenic, Cadmium, Chromium, Lead, Manganese and Nickel, as raw materials. Furthermore, per the Federal RegisterNol. 72, No. 246/Wednesday, December 26, 2007/Rules and Regulations pg. 73187 (Definition of Affected Source): "Glass furnace stacks generally exhaust emissions from the furnace melter, which is the part of the furnace where raw materials are charged and melted. Although furnace stacks may also exhaust emissions from other parts of, or appendages to the furnace, it was our intent to regulate emissions from the furnace melter." WK adds nickel bonded oxide to the forehearth which is downstream of Source 107 melt furnace. The forehearth has its own vents and does not vent through Source 1 07 melt tank exhaust system. Therefore, Subpart SSSSSS does not apply to WK Charleroi for the following reasons: (1) forehearth is an appendage to the Source 1 07 melt furnace, and (2) forehearth does not contribute emissions to the furnace stack. Because WK does not believe that they are subject to this NESHAP, they are required to meet the recordkeeping requirements of 40 CFR §63 .1 (b)(3) and 40 CFR § 63 .1 O(b)(3) relating to an applicability determination. Regulations found in 40 CFR 63 , Subpart SSSSS are not applicable requirements for this facility.

The applicabi lity the Greenhouse Gas Mandatory Reporting Rule found at 40 CFR 98, Subpart N- Glass Production has been evaluated. Facilities that contain glass production processes and that emit 25 ,000 metric tons or more of greenhouse gases (GHG) per year (expressed as carbon dioxide equivalents or C02e) from glass production processes, stationary combustion, miscellaneous use of carbonates, and other source categories must report emissions from all source categories located at the facility for which emission calculation methods are defined in the rule. The glass production source category consists of facility that manufactures glass (including flat, container, or pressed and blown glass) or wool fiberglass using one or more continuous glass melting furnaces . WK reviewed operational data from 2006-2008 was reviewed to would exceed the applicability threshold for reporting and therefore be subject to the rule.

However, public comments to the Greenhouse Gas Mandatory Reporting Rule (GHG MRR) questioned whether the requirements of this ru le met current definitions of " applicable requirement" as that term is defined at 40 CFR 70.2 and 71.2. The commenters requested that USEPA confirm their interpretation ofthe regulations. The EPA provided the following response: "As currently written, the definition of " applicable requirement" in 40 CFR 70.2 and 71.2 does not include a monitoring rule such as today' s action, which is promulgated under CAA sections 114(a)(1) and 208." The preamble of the final version ofthe GHG MRR, located at 74 Fed Reg 209, pp. 56287-56288, states that the GHG MRR is not considered an "applicable requirement" under the Title V Operating Permit program. Therefore, 40 CFR 98 Subpart N- Glass Production, while an obligation for WK, is not considered an applicable condition for this State Only Operating Permit.

The applicability of Pa. Code 25 §§ 129.301-129.310- Continuous Emissions Monitoring Requirements for the Control ofNOx from Glass Melting Furnaces has been evaluated. Pa. Code 25 § 129.302 (relating to applicability) specifies that the rulemaking 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. Plan Approval PA-63-00 11 OH established a cap on NOx emissions from Source 107 of 47.5 Tons per Year (TPY), therefore the requirements ofPa. Code 25 §§ 129.301-129.310 are not applicable to this facility.

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World Kitchen SOOP-63-00110 Review Memo 11 /2012

Emissions and Control Equipment

Short-term emission limitations for Source 107 were established in PA-63-00 110 H shown in TABLE 1, below. Stack testing conducted on January 6, 2011 demonstrated that Source 107 was operating in compliance with these emission limitations. The State Only Operating Permit requires that stack testing of Source 107 be repeated once every five years.

TABLE 1 SOURCE 107 EMISSION LIMITATIONS (POUNDS/HOUR)

co NOx PM10 sox voc 2.0 19.0 6.0 20.5 2.0

TABLE 2, below, shows the allowable Source 107 emission limitations, and actual emission and production data since 1990. It is evident that WK. has historically been able to increase their glass production while lowering emissions.

TABLE 1 SOURCE 107 LIMITS (TPY)

co I NOx PMlO PM2.5 sox voc PRODUCTION

8.8 1 47.5 26.3 N/A 90.0 8.8 73,000 SOURCE 107 ACTUALS (TPY)

2011 1.98 35.0 10.8 9.79 81.4 2.0 54,321 2010 0.6 7.1 10.0 9.1 35.3 1.6 68,112 2009 0.7 8.4 12 10.9 42 .1 1.9 64,711 2008 0.7 8.4 12 10.9 42.2 1.9 64,937 2007 0.3 85.7 15 13.6 21.8 1.2 61 ,751 2006 0.1 120.2 15.7 14.3 10.3 0.8 57,244 2005 0.1 134.4 17.6 17.6 11.8 0.9 64,007 2004 0.1 101.9 17.2 17.2 11.5 0.8 62,428 2003 0.1 88.5 17.2 17.2 11.6 0.8 62,571 2002 0.1 86.2 15.5 N/A 10.4 0.8 56,277 2001 3.8 115.5 22.0 N/A 33.0 1.1 55,000 2000 4.4 131.0 25.0 N/A 38.0 1.2 62,600 1999 0.1 106.0 19.0 N/A 28.0 0.4 64,100 1998 0.1 106.0 19.0 N/A 28.0 0.4 54,700 1997 0.1 99.0 18.0 N/A 26.2 0.4 49,600 1996 5.5 44.0 0.0 N/A 3.8 2.5 55,300 1995 3.3 141.5 0 N/A 144.9 5.0 33,300 1994 5.2 399.7 16.2 N/A 227.0 7.9 52,172 1993 4.9 207.4 0 N/A 212.3 7.3 48,791 1992 5.5 558.0 N/A N/A 237.4 8.2 54,578 1991 4.4 444.8 N/A N/A 189.2 6.5 43,500 1990 4.5 193.2 0 N/A 197.7 6.8 45 ,455

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World Kitchen SOOP-63-00110 Review Memo 11 /2012

Facility -wide emission limitations are established as shown in TABLE 3, below.

TABLE 3 FACILITY-WIDE PERMIT LIMITS (TPY)

co NOx PM10 sox voc 25 65 35 95 10

Company submitted application for 42.9 tons ofNOx ERCs created by the permanent shutdown Source 105 (aka Tank 11 and Tank 61) in 2002. In order for ERCs to be generated, they must meet the criteria ofPA Code Title 25 § 127.207. That is, they must meet the creditability requirements in that they are Surplus, Permanent, Quantified and Enforceable.

The ERCs are surplus, because they were included in the inventory during the years 2000 and 200I , and have not been used to meet past or current SIP, attainment demonstration, RFP, emissions limitation or compliance plans. These ERCs are based on post-RACT operations, so it is not necessary to discount the decreases for RACT.

The ERCs are permanent, because they result from the permanent, in-place disablement of Source 105. If WK ever wants to reactivate Source 105, it will be treated as a new source, and be required to go through the Plan Approval process.

The emissions from Source I 05 have been quantified using stack test results and operational records. Applicant has used the Source I 05 actual emissions reported in 2000 and 200 I as their baseline years.

Since the reductions met all of the requirements ofPA Code Title 25 § I27 .207, the generation of 42 tons ofNOx ERCs were made enforceable by inclusion in Plan Approval PA-63-00IIOH, and have been carried over to this State Only Operating Permit.

Conclusions and Recommendations

Notice of DEP' s intent to issue this SOOP was published in the Pa. Bulletin on December 17, 20 II . Company provided minor comments to reconcile the SOOP with the application. I recommend that a State Only Operating Permit be issued with a five year term.

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