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Home My WebLink AboutAQ_F_0100237_20190119_CMPL_InspRpt NORTH CAROLINA DIVISION OF Winston-Salem Regional Office AIR QUALITY Owens-Brockway Glass Container Inc. NC Facility ID 2900106 Inspection Report County/FIPS:Davidson/057 Date: 01/19/2021 Facility Data Permit Data Owens-Brockway Glass Container Inc. Permit 01491 /T22 9698 Old US Highway 52 South Issued 3/21/2018 Lexington,NC 27295 Expires 2/28/2023 Lat: 35d 57.0167m Long: 80d 13.0667m Class/Status Title V SIC: 3221 /Glass Containers Permit Status Active NAICS: 327213/Glass Container Manufacturing Current Permit Application(s)TV-502(b)(10) Contact Data Program Applicability Facility Contact Authorized Contact Technical Contact SIP/Title V MACT Part 63: Subpart 6S, Subpart ZZZZ Greg Dellinger Dennis Benjamin Greg Dellinger NSPS: Subpart IIII EHS Manager Maintenance Plant EHS Manager (567)336-3906 Engineer (567)336-3906 (567)336-3930 Compliance Data Comments: Inspection Date 01/19/2021 Inspector's Name Jim Hafner Inspector's Signature: Operating Status Operating yy Compliance Status Violation-procedures a4. � Action Code FCE Date of Signature: Inspection Result Compliance Total Actual emissions in TONS/YEAR: TSP S02 NOX VOC CO PM10 *HAP 2019 101.89 242.50 598.92 25.55 3.40 97.62 2340.00 2018 78.75 288.74 435.27 13.75 4.30 76.55 3861.00 2017 80.27 286.60 431.40 10.30 3.73 78.10 2535.00 *Highest HAP Emitted inpounds)__ Five Year Violation History: Date Letter Type Rule Violated Violation Resolution Date 10/30/2020 NOV Permit Condition 12/04/2020 12/20/2019 NOV Part 63 -NESHAP/MACT Subpart ZZZZ Stationary 01/06/2020 Reciprocating Internal Combustion Engines 08/08/2019 NOV 2D .0516 Sulfur Dioxide Emissions from Combustion 08/26/2019 Sources Performed Stack Tests since last FCE: Date Test Results Test Method(s) Source(s)Tested 12/15/2020 Pending 01/16/2020 Compliance Method 202,Method 5,Method 6C,Method 7E GF-C.FURN Page 1 of 14 PERMITTED SOURCES Emissionmison Source; escri tion Control Control Device i Source ID Vo. Duce TD No.' Description _._......_....__.._..... _.....w......................."......,......................_.....,........_. ...._......._......................_............................._........._..,......._.........."..... ................ _,._........,........... one natural gas-fired furnace(170 tons per day maximum glass pull rate and 35.4 million Btu per hour maximum heat GF-A.FURN n/a n/a input)consisting of a melter with electric boost and regenerative checkers a natural gas-fired molten glass refiner(3.2 million Btu per GF-A.RF hour maximum heat input rate)and a natural gas-fired n/a n/a forehearth(3.2 million Btu per hour maximum heat input) ........ ...._....................,... ................................... _.W W._._.......... ............_.... ............._.._........_.. GF-B.FURN one natural gas-fired furnace(175 tons per day maximum MACT glass pull rate and 36.45 million Btu per hour maximum heat n/a n/a Subpart input)consisting of a melter with electric boost and SSSSSS : regenerative checkers ..................._................................................._.._......................................................................................................................................._.................................................................................................. �...................................................................................:............ 1 a natural gas-fired molten glass refiner(2.8 million Btu per GF-B.RF hour maximum heat input)and a natural gas-fired forehearth n/a n/a (2.8 million Btu per hour maximum heat input) one natural gas-fired furnace(300 tons per day maximum glass pull rate and 57.3 million Btu per hour maximum heat GF-C.FURN I n/a n/a input)consisting of a melter with electric boost and regenerative checkers a natural gas-fired molten glass refiner(5.2 million Btu per GF-C.RF ' hour)and two natural gas-fired forehearths(5.2 million Btu n/a 1 n/a per hour maximum heat input total) ES-BH batch house fugitive sources [ n/a n/a ES-SS1 and two sand silos(20,900 cubic feet and 9.345 cubic feet CD-SSFF one bagfilter(68 square feet ES-SS2 i capacity) of filter area) ;m one bagfilter(68 square feet ES-MBE ' one mix batch elevator CD-MBEFF of filter area) ......:.:.:.. ........:...... one bagfilter(68 square feet ( ES-MBAE 1 east mix batch bin for furnace A(550 cubic feet capacity) CD-MAEFF of filter area) ....................................................................€ ............................................ ....... .................. ........................................................................................................................................................................................................................................................................................................................................ ............ ...................... .. ............................................. ES-MBAW west mix batch bin for furnace A(550 cubic feet capacity) CD-MBAWFF one bagfilter(68 square feet of filter area) ES-MBBE east mix batch bin for furnace B(550 cubic feet capacity) . one bagfilter(68 square feet CD-MBBEFF � of filter area) ..�...�....�...._._�..��,..�.._w�._.�.� .�.�.�....�_�...W��..V..._w�.��...w.._.w.�_.�..�..�._w.._.�...�.�.._..�..ww�...�..��.�.____w.,_._._....�....�..�..�.....w..�.�...W......W..........__.._._M...........�.........V..�._._.w_._�.._.._._�.�_.,�.._wu_._�:_w..�.._..W.W�...Y.....w_.___..��._._��... ES-MBBW I west mix batch bin for furnace B(550 cubic feet capacity) CD-MBBWFF one bagfilter(68 square feet of filter area) ES-MBCE and j east and west mix batch bin for furnace C CD-MBCFF one bagfilter(68 square feet ES-MBCW (1,100 cubic feet capacity each) of filter area) ES-HST one surface treatment system n/a nh/ one filter cartridge dust ES-08 I one grit blaster CD-08FF collector(486 square feet of filter area) ES-09 one grit blaster CD-09FF one bagfilter(80 square feet of filter area) .......................................:............................................................................................................................................................................................................................................................................ ........................................................................................ ......................................................................................................................... ES-ML mold lubrication n/a n/a ................................................................................................................................................................................................................................................................................................................ Page 2 of 14 Emission _ __.. - Control Control Deice Source IDNa. Emissxan S'aurce Descr�pt�on Device ID No. D scrYptlon one bagfilter(41 square feet :_,.......:.................... _.......... ...... ........ _... .......... ........ . .................................. . .............................. ........ ...:..................................................._... ES-RME Raw material elevator CD-RMEFF of filter area) INSIGNIFICANT/EXEMPT SOURCES emission Source YD Emission Source D'escriptionW _...: ..__.. .::..m_........m........ ......_....::....._..._..._..........................._............................................_.................................._........................................._............................_.........._...................__.._...._.........................:................_.............................._..._.......:...._............_......................._:........................... � I-L1 one natural gas-fired annealing lehr(4.8 million Btu per hour maximum heat input)on A line I-L2 one natural as-fired annealing .0 million g g Lehr(4 Btu per hour maximum heat input)on B line I-L3 [natural gas-fired annealing lehr(4.0 million Btu per hour maximum heat input)on C east line .......... ............ .._........ ........:.................................................................. .._...__...._........ _.._.............._....................._._.............._...._.:__...._..._.................................._..._........................................................................... .................... ... I L4 natural gas ............ .fired annealing lehr(4.0 million Btu per hour maximum heat input)on C west line . � I-DE3 NESHAP ZZZZ,NSPS IIII�one diesel engine-fire pump(175 HP rated capacity) I-DE4 NESHAP ZZZZ one natural gas-fired engine-side wall cooling fan backup(46 HP rated capacity) m.. ._m..... _._.....::.. ..........._......:_.__....._......_...._..._.._.__................................._._......................_._......._......_.............._............._..................._...._......_................. ........... ....._..:...........__.........._........ ............ .... ................. _.... _.........__..._........._......... ............ ....... ........... ..... _....._...._...._............. _....... ..... ._.......................... . I-EG NESHAP ZZZZ lone diesel-fired emergency generator(125KW rated capacity) I-DES one diesel-fired emergency generator 363KW output/486 h input rated capacity) NESHAP ZZZZ,NSPS IIII g y g ( p p I-DE6 NESHAP ZZZZ,NSPS IIII one diesel-fired emergency generator(486 bhp input rated capacity) I-BC 1 one bottle coating operation consisting of ink jets :. . :. W _.......... ......_. .W. .,...__:__ .W. .;...; _ _ :._,.... . _.._ _........ . ......... w..:.. _ ......:.� I-PD non-halogenated solvent parts degreasers I-MR Imold repair dust system venting to CD-MRCF _.:............_......._....._:._....._......................._.........................................................................................................................................................................._............................................................................................................................................................................................................._................................................................................:.............. I WH one natural gas fired domestic hot water boiler(740,000 million Btu per hour maximum heat input) 1-16 cold end surface treatment 1 INTRODUCTION Per current DAQ policy,Jim Hafner,DAQ-WSRO Environmental Engineer,conducted an MS Teams meeting on January 19,2021 with Greg Dellinger,EHS Manager,and Walter Tamukong,North America Environmental Manager,of Owens-Brockway Glass Container Inc. The purpose of the teams meeting was to conduct the records review portion of the air quality compliance inspection. Mr.Hafner followed up with the site visit portion of the compliance inspection of plant on January 21,2021. The facility was targeted this year for a compliance inspection and has a facility classification of Title V. The facility received its last compliance inspection on December 4,2019 by Mr.Hafner and Matt Harper,former DAQ-WSRO Environmental Engineer. The inspection determined that the facility was in violation 40 CFR Part 63 Subpart ZZZZ as the fire pump engine(I-DE3)ran for more than 50 hours for nonemergency use. The facility was found to be in compliance with all other applicable Air Quality regulations at that time. Since the last inspection,there have been changes to the facility contacts. Mr.Dellinger replaced Vince DeGrava as EHS Manager and Matthew Boswell is no longer the Plant Manager. An update to the facility contact information was received on December 15,2020,and the appropriate changes were made in IBEAM. Currently,Mr.Dennis Benjamin,Plant Engineer is listed as the authorized contact. Mr. Dellinger stated that Steve Jenkins is the Interim Plant Manager. Owens-Brockway Glass Container, Inc.manufactures glass beverage bottles for companies such as MillerCoors,Yuengling,and Starbucks. The plant produces up to 3.5 million bottles per day. The facility operates 24 hours per day,7 days a week for 52 weeks per year. SAFETY When inspecting this facility,DAQ personnel are required to wear long sleeves,reflective vest,safety shoes,safety glasses,and hearing protection. The facility is now food grade certified and hair nets and beard nets are required in manufacturing areas and Page 3 of 14 jewelry is not allowed to be worn. Hard hats are required in the basement.Due to OSHA reducing the respirable silica dust exposure limit(PEL)by 50%in 2017,respirators are now required for anyone to enter or go on top of the batch house.General safety practices from the required HAZWOPER training should always be followed. LATITUDE/LONGITUDE VERIFICATION The latitude and longitude coordinates of the facility were verified and did not need to be updated by this inspector. APPLICABLE REGULATIONS The following Title 15A North Carolina Administrative Code(NCAC)air quality regulations apply to Owens-Brockway Glass Container,Inc.:2D .0515,2D.0516,2D.0521,2D.0530(u),2D.1100,2D.1111 (40 CFR Part 63, Subpart SSSSSS),2D .1806,and 2Q .0711.NSPS 40 CFR Part 60, Subpart IIII and NESHAP 40 CFR Part 63, Subpart ZZZZ apply to exempt sources. SOURCE TESTS On April 19,2017,the facility tested natural gas-fired furnace GF-B.FURN.EPA Methods 1,2,3A,4,5,6C,7E,29,and 202 were used to test for emissions of total(filterable+condensable)particulate matter(PM),sulfur dioxide(S02),nitrogen oxide(NOx),and chromium(Cr).The results will be used to demonstrate compliance with 15A NCAC 2D.0515,2D .1100,and 2D .1111 (40 CFR Part 63, Subpart SSSSSS).Rule 2D.0515 limits the total PM emissions per the allowable rates. The allowable rate(E)in lbs/hr can be calculated from the process rate(P)in tons/yr by the following equations: 1)E=4.10 x P 0.67,where P<30 or 2)E=55.0 x P 0-11 -40, where P>30.Rule 2D.1100 limits hexavalent chromium emissions to 2.261 lbs/yr.NESHAP Subpart 6S specifies that the"3-hour block average production-based PM mass emission rate must not exceed 0.1 g/kg(0.2 lbs/ton)glass produced"or"the 3-hour block average production-based metal HAP mass emission rate must not exceed 0.01 g/kg(0.02 lbs/ton)of glass produced." The test was performed by Montrose Air Quality Services(MAQS).The Protocol Submittal Form was received by this office on January 27,2017.The protocol was approved by the DAQ-SSCB on March 15,2017.The results of the test were received by the DAQ-WSRO on May 24,2017,and the test results were found to be acceptable on June 8,2018 by Gregg O'Neal of DAQ-SSCB. The results are shown in the table below. Glass Melting Furnace GF-B.FURN,April 19,2017 Test Results Glass EPA Production Method Pollutant Test Results Emissions Limit Standard Compliance 5 Filterable PM 4.44 lb/hr 0.66 lb/ton of glass 202 Condensable PM 0.85 lb/hr 0.13 lb/ton of glass 6.68 ton/hr 5.30 lb/hr (160.4 TPD) 5/202 Total PM 0.791b/ton of glass 15.6 lb/hr 15A NCAC 2D.0515 Indicated (92%of 6C S02 16.4 lb/hr 2.3 lb/MMBtu 15A NCAC 2D.0516 Indicated Maximum) 0.68 lb/MMBtu 7E NO, 22.4 lb/hr --- --- --- 3.36 lb/ton of glass 29 Total Cr 0.0091 lb/hr Metal HAP 63 Subpart SSSSSS Indicated 0.0014 lb/ton of glass 0.02 lb/ton of glass On June 28-29,2017,the facility tested natural gas-fired furnaces GF-C.FURN and GF-A.FURN.EPA Methods 1,2,3A,4, 5,6C, 7E,and 202 were used to test for emissions of total(filterable+condensable)particulate matter(PM),sulfur dioxide(S02),and nitrogen oxide(NOx).Only Furnace C was tested for sulfuric acid(H2SO4)using CTM-013.The results will be used to demonstrate compliance with 15A NCAC 2D.0515 and 2D.0530(u). Rule 2D.0530(u)applies only to GF-C.FURN and permit Condition 2.1.A.6.d lists the projected actual emissions for nitrogen oxides(NOx),sulfur dioxide(S02),particulate matter(PM),PMio and PM2,5. The test was to establish emission factors for total PM,PMio,PM2,5, S02,NOx,and sulfuric acid(H2SO4)to verify the assumptions used in the projected actual emissions calculations. Page 4 of 14 The test was performed by MAQS.The Protocol Submittal Form was received by this office on January 27,2017.The protocol was approved by the DAQ-SSCB on March 15,2017. The results of the test were received by the DAQ-WSRO on July 31,2017, and the test results were found to be acceptable on June 8,2018 by Gregg O'Neal of DAQ-SSCB. The results are shown in the tables below. Glass Melting Furnace GF-A.FURN,June 29,2017 Test Results Glass Production EPA Method Pollutant Test Results Emissions Limit Standard Compliance 091b/hr 5 Filterable PM 4. --- --- --- 0.63 lb/ton of glass 202 Condensable PM 0.43 lb/hr ___ --- --- 6.51 ton/hr 0.07 lb/ton of glass (159.2 TPD) 4.53 lb/hr 5/202 Total PM 0.701b/ton of glass 15.3 lb/hr 15A NCAC 2D.0515 Indicated (94%of Maximum) 6C SO2 20.8 lb/hr 2.3 lb/MMBtu 15A NCAC 2D.0516 Indicated 0.58 1b/MMBtu 7E NOX 39.6 lb/hr 6.091b/ton of glass Glass Meltin Furnace GF-C.FURN,June 29,2017 Test Results Glass Production EPA Method Pollutant Test Results Emissions Limit Standard Compliance 5 Filterable PM 12.0 lb/hr 1.16 lb/ton of glass 202 Condensable PM 0.61 lb/hr 0.061b/ton of glass 10:27 ton/hr 12.6 lb/hr (246.5 TPD) 5/202 Total PM 1.22 lb/ton of glass 20.8 lb/hr 15A NCAC 2D .0515 Indicated (82%of 6C SO2 25.0 lb/hr 2.3 lb/MMBtu 15A NCAC 2D .0516 Indicated Maximum) 0.27 lb/MMBtu 7E NOX 84.5 lb/hr 8.23 lb/ton of glass CTM-013 H2SO4 0.867 lb/hr 0.084 lb/ton of glass On January 15,2020,the facility tested natural gas-fired furnace GF-C.FURN.EPA Methods 1,2,3A,4,5,6C,7E,and 202 were used test for emissions of total(filterable+condensable)particulate matter(PM),sulfur dioxide(SO2),and nitrogen oxide(NOx).The results will be used to demonstrate compliance with 15A NCAC 2D.0515 and 2D.0530(u). Rule 2D.0515 limits the total PM emissions per the allowable rates.The allowable rate(E)in lbs/hr can be calculated from the process rate(P)in tons/yr by the following equations: 1)E=4.10 X P 1.61,where P<30 or 2)E=55.0 x P 0-1 -40,where P>30.Rule 2D .1100 limits hexavalent chromium emissions to 2.261 lbs/yr. This test was performed at the request of the facility,as they do not consider the test result of 8.23 lb/NOx/ton glass from the June 2017 test to be representative. The test was performed by MAQS and was based on the protocol used for the June 2017 test.The results of the test were received by the DAQ-WSRO on February 25,2020,and the test results were found to be acceptable on August 10,2020 by Gregg O'Neal of DAQ-SSCB. The results are shown in the table below. Glass Melting Furnace GF-C.FURN,Janu ry 15& 16,2020 Test Results Glass EPA Production Method Pollutant Test Results Emissions Limit Standard Compliance 6.68 ton/hr 5 Filterable PM 5.11 lb/hr (279.02 0.44 lb/ton of glass TPD) 202 Condensable PM 1.29 lb/hr O11 lb/ton of glass Page 5 of 14 (93%of 5/202 Total PM 6.40 lb/hr 23.1 lb/hr 15A NCAC 2D.0515 Indicated Maximum) 0.55 lb/ton of glass 6C S02 19.0 lb/hr 2.3 lb/MMBtu 15A NCAC 2D.0516 Indicated 0.0.40 lb/MMBtu 7E NOX 53.8 lb/hr 4.63 lb/ton of glass On December 15,2020 the facility tested natural gas-fired furnace GF-A.FURN.EPA Methods 1,2,3A,4,and 29.The results will be used to demonstrate compliance with 40 CFR 63, Subpart SSSSSS,"National Emission Standards for Hazardous Air Pollutants for Glass Manufacturing Area Sources. The test was performed by MAQS. The Protocol Submittal Form was received by this office on October 28,2020. The testing was done without prior approval of the protocol. As of the time of this report,the protocol has not been approved by SSCB. It appears that it was an oversight by SSCB that protocol was not approved. The facility conducted three 2-hour runs of EPA Method 29 for total chromium emissions from Furnace A. Methods 1-4 were performed in conjunction with the metals train.Testing was performed to demonstrate compliance with 40 CFR 63, Subpart SSSSSS,"National Emission Standards for Hazardous Air Pollutants for Glass Manufacturing Area Sources."As described in permit condition 2.1.A.4.k.i,the facility is required to limit the production-based metal HAPs(Cr)mass emission rate to 0.02 lb/ton of glass produced.As noted in the stack observation report dated December 15,2020,the facility was required to conduct the testing as they began producing"emerald green"glass in furnace A on October 5,2020. As such, the facility will be required to submit an initial notification to the WSRO-D,AQ by February 2,2021.The facility will also be required to submit a notification of compliance status including the test results within 60 days of the test completion(February 23,2021). The stack test report was received on January 22,2021. The stack test result of 0.01 lb/ton indicated compliance. However,final approval is needed by DAQ-SSCB. DISCUSSION The facility has three furnaces(GF-A.FURN,GF-B.FURN,and GF-C.FURN)for manufacturing glass that are referred to as A,B,and C. Furnaces A and B are older units primarily used to produce amber glass that are charged on the sides. As noted above,the facility started production of emerald glass on October 5,2020 in Furnace A. Previously,only Furnace B was used to produce emerald glass. Furnaces A and B are natural gas-fired and consist of a melter with electric boost and regenerative checkers,a refiner,and a forehearth (GF-A.RF and GF-B.RF). Furnace C is different as it produces flint(clear)glass and is charged at the rear of the unit. It is natural gas-fired and consists of a melter with electric boost and regenerative checkers,a refiner,and two forehearths(GF-C.RF).For all furnaces,the melters exhaust outdoors via stacks,while the refiners and forehearths exhaust fugitively indoors. Furnace A experienced a malfunction and was shut down on August 30,2019. Overtime glass built-up on the top of the furnace, referred to as the crown. The furnace required a rebuild. Furnace A was re-started on March 16,2020 after completion of the rebuild. On January 10,2020,a 502(b)(10)notification form was received for the rebuild. The facility considered this a routine rebuild. The rebuild included a reduction in the melter area from 48.84 square feet to 48.04 square feet. The glass depth was reduced from 65 inches to 53 inches. The obsolete screw-type batch chargers were replaced with oscillating type chargers. The two old transformers, each rated at 667kVA were replaced with a new 1400 KVa transformer. The refiner increased from 6.28 square meters to 7.12 square meters. The total heat input of the refiner changed to 1.6 mmBTu/hr and the forehearth total heat input changed to 2.4 mmBtu/hr. Also,the forehearth is 6 inches shorter after the rebuild. On January 21,2021,Furnace A,Furnace B and C were operating with glass pull rates of 155.4, 155.3,and 259.2 tons per day, respectively. No detectable visible emissions were observed being emitted from the melter stacks of Furnace A and B. Furnace C appeared to be emitting between 0—5%opacity when observed. However,the conditions were not favorable for visible emissions observations as the sky was overcast. The facility's batch house(ES-BH)is used to make batches for feed to the furnaces. As noted in a previous inspection report,it takes 7 to 10 minutes to deliver a batch to a furnace. The batch house contains various raw material silos(limestone,soda ash,etc.)with internally exhausting bagfilters.The two sand silos(ES-SS 1 and ES-SS2)are located at the top of the batch house and are controlled by bagfilter CD-SSFF that is located and exhausts on the roof. The batch elevator(ES-MBE)delivers the raw materials to the batch bins for the furnaces. It is controlled by bagfilter CD-MBEFF located on the side of the batch house and exhausts outdoors. The raw material elevator(ES-RME)delivers the raw materials to the batch bins to the furnaces and is controlled by bagfilter CD-RMEFF located on the side of the batch house and exhaust outdoors. It should be noted that due to DAQ-respirator requirements for the batch Page 6 of 14 house,CD-SSFF on the batch house roof cannot be observed by DAQ inspectors. CD-MBEFF can be observed from the roof of the furnace building. Each furnace has an east and a west mix batch bin(ES-MBAE,ES-MBAW,ES-MBBE, ES-MBBW,ES-MBCE,ES-MBCW).Each batch bin for Furnaces A and B has a dedicated bagfilter(CD-MAEFF,CD-MBAWFF,CD-MBBEFF, CD-MBBWFF)located on the roof above the furnaces. The two batch bins for Furnace C are controlled by one bagfilter(CD-MBCFF). On January 21,2021,all bagfilters were observed with no evidence of visible emissions occurring. Glass from the furnaces is cut into slugs,which are diverted into bottle forming molds.Air is injected into the molds to form the bottles.The molds are lubricated(ES-ML)to allow for easy release of the bottles. This lubricant is hand applied from a tank that is closed with a lid when not in use.After forming,the bottles are sprayed with a surface treatment(ES-HST)under hoods on the"hot end"before entering the annealing lehrs.The ductwork from the hoods converge into one stack that exhausts indoors. There are four annealing lehrs,one each for Furnaces A and B(I-L 1 and I-L2)and two for Furnace C(I-L3 and I-L4).The annealing lehrs are natural gas-fired and exhaust fugitively indoors. The Furnace A,B and C lehrs were in operation during the inspection. After exiting the annealing lehrs,the bottles are sprayed with a"cold end"surface treatment(I-16).This wax coating is sprayed on the bottom and sides of the bottles to prevent them from sticking or scratching.There are five ink jet printers making up the bottle coating operation(I-BC 1)that prints a code on the bottles before final packaging and shipment. The facility has two grit blasters(ES-08 and ES-09)for cleaning molds that are controlled by a cartridge filter(CD-08FF)and bagfilter(CD-09FF)that exhaust out the side of the furnace building.The facility also has a mold repair shop(I-MR)that is controlled by a cartridge filter(CD-MRCF).The grit blasters and mold repair shop were not in operation on January 21,2021. The facility uses two non-halogenated solvent parts degreasers(I-PD)for cleaning the molds. These are covered when not in use. The facility has a natural gas-fired domestic hot water boiler(I-WH),and the facility recycles its own cullet. There are five engines located at the facility including one diesel fire pump engine(I-DE3), one natural gas backup engine for the side wall cooling fan(I-DE4),three diesel emergency generators(I-DEG,I-DE5 and I-DE6). None of the engines were in operation during the inspection. The emergency generator(I-DEG)is no longer operational and the natural gas backup engine for the side wall cooling fan(I-DE4)has been removed during the Furnace A rebuild. The hour meter readings are summarized in the "NSPS/NESHAP/112(r)Applicability"section of this report. PERMIT CONDITIONS Section 2—Specific Limitations and Conditions 2.1—Emission Source(s)and Control Device(s)Specific Limitations and Conditions A Control Control Emission Source Emission ce Saurce Descr�ptrarx Devace Dei ID No.H Aescrptran one natural gas-fired furnace(170 tons per day maximum glass pull rate and 35.4 GF-A.FURN million Btu per hour maximum heat input)consisting of a melter with electric boost n/a n/a and regenerative checkers a natural gas-fired molten glass refiner(3.2 million Btu per hour maximum heat input) n/a n/a GF-A.RF and a natural gas-fired forehearth(3.2 million Btu per hour maximum heat input) 3 µ:..��.�..�....�..�:,�....�..�... (..175 tons per day M:..:.�.,m�..�:�. .�..._�..._�._.�.:_.,_._....__.::..,.�m..:..:._.,:..:.__..._.... �..M__..,.._..._:..k._.r.._M.....�:_,_.......r.m.�...... GF-B.FURN one natural gas-fired furnace maximum glass pull rate and 36.45 MACT Subpart ! million Btu per hour maximum heat input)consisting of a melter with electric boost n/a n/a SSSSSS and regenerative checkers GF-B.RF a natural gas-fired molten glass refiner(2.8 million Btu per hour maximum heat input) n/a n/a and a natural gas-fired forehearth(2.8 million Btu per hour maximum heat input) Page 7 of 14 Control �ontr.'ol Emission Souxce Emission Source Description Device DevYce ID No. Description one natural gas-fired furnace(300 tons per day maximum glass pull rate and 57.3 GF-C.FUIZN million Btu per hour maximum heat input)consisting of a melter with electric boost n/a n/a and regenerative checkers f....................................................,............::................._...,......._.,_............,_,.....................:..............,....._....,.........,,............_.......,......_....................,..,,_.......,_.,......_......._.,. .._...............,......,._.._............._...._........,._.......,._...... ,,...,........_....,............._....,.. ......._......._............,..,_......_._........ GF-C.RF a natural gas-fired molten glass refiner(5.2 million Btu per hour)and two natural gas- n/a n/a fired forehearths(5.2 million Btu per hour maximum heat input,total) Condition 2.1.A.1—This contains the requirements for 2D.0515 which requires the facility to limit the particulate matter emissions from miscellaneous industrial processes according to the allowable rates.The allowable rate(E)in pounds per hour can be calculated from the process rate(P)in tons per year by the following equations: 1)E=4.10 X P 0.67,where P<30,or 2)E=55.0 X P 0.11-40, where P>30.Liquid and gaseous fuels and combustion air are not considered as part of the process rate. The facility is required to maintain the following records for each furnace: • the date and approval status of the most recent source test conducted; • the production rate at which the source test was conducted;and • the maximum production rate achieved since the most recent source test conducted. The June 2017 stack testing results demonstrated compliance with 2D.0515 for furnace A.The April 2017 stack testing results demonstrated compliance with 2D.0515 for Furnace B.The January 2020 stack testing results demonstrated compliance with 2D :0515 for furnace C. The facility calculates the actual production rate for each furnace on a daily basis. The facility appears to be in compliance with 2D.0515. Condition 2.1.A.2—This contains the requirements for 2D.0516 which requires the facility to limit sulfur dioxide emissions from combustion sources,such as the A,B,and C furnaces.The sulfur dioxide emissions are not to exceed 2.3 pounds per million Btu input. The facility is required to calculate the average SO2 emissions on a pounds per million BTU heat input basis for each batch formulation and maintain the result in a logbook. The facility must submit a summary report of the monitoring and recordkeeping activities postmarked on or before January 30 of each calendar year for the preceding six-month period between July and December, and July 30 of each calendar year for the preceding six-month period between January and June. The report must include the maximum calculated average SO2 emissions on a pounds per million Btu heat input basis that occurred during the reporting period along with supporting calculations. Mr.Tamukong indicated that they only have three batch formulations—amber,flint and emerald green and the sulfur content of each batch stays consistent unless there is a formulation change. Currently,the facility determines SO2 emissions, in lbs/mmBtu for each furnace daily. This condition does not have a requirement for a daily calculation. A review of the daily records indicates that the SO2 emissions stay fairly consistent(0.5 lb/mmBtu, 1.2 lb/mmBtu.and 1.65 lb/mmBtu,respectively). It was suggested to Mr.Dellinger and Mr. Tamukong that they should consider keeping records of the calculated SO2 emission rate for each batch formulation rather than calculating this for each furnace daily. The latest semiannual report was received via email on January 29,2021 and demonstrated compliance with 2D .0516 for each furnace. The facility is considered in compliance with 2D .0516 at the time of the inspection. Condition 2.1.A.3—This contains the requirements for 2D.0521 which requires the facility to control the visible emissions from any emission source that may be discharged from vents or stacks.The visible emissions from the melter stacks for Furnaces A,B,and C are not to exceed 20%opacity when averaged over a six-minute period. To comply,the facility is required to perform daily visible emissions observations.Three days of absent observations are allowed per semi-annual period. If the visible emissions observed are above normal,corrective action must be taken.The visible emissions observations are to be recorded and maintained in a logbook with dates,times,results, and any corrective action noted. Summary reports of the observations are due on a semi-annual basis. On January 21,2021,no detectable emissions were observed from the Furnace A and Furnace B melters while the opacity for Furnace C ranged from 0 to 5%. The daily observations were reviewed and were found to be complete.A visible emission observation is typically done on each shift,or three times per day. This ensures that if a visible emission observation is missed during one shift,then the daily observation requirement will be met if an observation is done during one of the other shifts. The latest semiannual report was received via email on January 29,2021 and indicated that the observations were completed and maintained. The facility appears in compliance with 2D.0521. Page 8 of 14 Condition 2.1.A.4—This contains the requirements for 2D.1111 which involves the National Emissions Standards for Hazardous Air Pollutants(NESHAP)federal regulations promulgated by the EPA.The facility is subject to 40 CFR Part 63, Subpart SSSSSS for "Glass Manufacturing Area Sources"due to the use of chromium(a metal HAP)in their batch formulation for emerald glass bottles. The facility first did a trial of emerald glass on September 28,2010 in Furnace B.Therefore,their compliance date was September 28, 2012(within two years of the date on which the glass production rate for the furnace increased to at least 50 tpy). However,the facility decided not to continue emerald glass production after the trial batch,so source testing was never conducted at that time. Then on January 27,2017,the facility notified the DAQ-WSRO that they would be resuming emerald glass production in Furnace B and would therefore need to conduct source testing. For Furnace B,the permit condition requires testing within 180 days upon reintroduction of the emerald glass containing chromium. The facility began their emerald glass batch on April 7,2017 and conducted source testing on April 19,2017. The results and a Notification of Compliance Status(NOCS)were due within 60 days of the test, June 18,2017.The results and NOCS were received on May 24,2017. Therefore,the facility met the performance test requirements within 180 days upon reintroduction of the emerald glass containing chromium on April 7,2017. No further testing is required even if there is another time lapse between emerald glass production. A start-up of emerald glass production does not constitute a reintroduction. To comply with 40 CFR 63, Subpart SSSSSS,the 3-hour block average production-based PM mass emission rate must not exceed 0.1 g/kg(0.21bs/ton)glass produced"or"the 3-hour block average production-based metal HAP mass emission rate must not exceed 0.01 g/kg(0.02 lbs/ton)of glass produced."The test results for Furnace B were approved by the SSCB on June 8,2018 and show that the 3-hour average chromium emission rate was equal to 0.0014 lbs/ton. Therefore,the only other requirement is to keep records of the notifications,records regarding startup,shutdown,and malfunctions of the furnace,records of production rate,and records of the batch formulations containing metal HAPs.All the production and batch formulation records are kept electronically. Productions records were reviewed and appeared to be complete. As previously discussed,production of emerald glass in Furnace A began on October 5,2020. Based on this date,the facility is required to submit an initial notification by February 2,2021 (within 120 days after becoming subject to the standard per 40 CFR 63.9(b)and 40 CFR 63.114560). The facility also is required to submit an NOCS,including the performance test results,before the close of business on the 60th day following the completion of the performance test,per 40 CFR 60.8 or 40 CFR 63.10(d)(2). The Furnace A stack test was conducted on December 15,2020.The NOCS and test results are due on February 13,2021 based on the date of the stack test. The initial notification,NOCS and stack test results were received on January 29,2021. The submittal was also sent to EPA Region IV as required. The;facility will need to comply with the 3-hour block average production-based PM mass emission rate must not exceed 0.1 g/kg(0.2 lbs/ton)glass produced"or"the 3-hour block average production-based metal HAP mass emission rate must not exceed 0.01 g/kg (0.02 lbs/ton)of glass produced. Per Mr.Tamukong,the preliminary stack test results show compliance. The test report was submitted to the WSRO on January 22,2021. The facility appears in compliance with 2D.1111 and NESHAP Subpart 6S. Condition 2.1.A.5—This contains the requirements of 2D.0530(u)which allows the facility to use projected actual emissions to avoid the applicability of Prevention of Significant Deterioration(PSD)requirements for the Furnace C rebuild project. To comply, the facility shall maintain records of the total PM,PM10,PM25,NOx,and S02 emissions in tons per year on a calendar year basis for five years following the resumption of regular operations.The facility was required to submit annual reports of the total PM,PMio, PM2.5,NOx,and S02 emissions to the DAQ within 60 days after the end of each calendar year for the five years required. If projected emissions are exceeded, an explanation to be included as to why the actual rates exceeded the projection. This condition also requires that a permit application be submitted if the results of the required stack testing indicate emission factors greater than the ones used in the projected actual emission calculations for application no.2900106.14A. The five-year period for this reporting requirement ended in CY 2020. The first report was submitted for CY 2015. The projected actuals for NOx,PM,PM10 and PM2.5 were exceeded in CY 2017,and the projected actuals for NOx and PM2.5 were exceeded in CY 2018. The actual emissions for both calendar years were based on the June 2017 stack test results.The annual reports for CY 2015 and CY 2016 were based on the emission factors submitted in the permit application,and both reports indicated compliance. It should be noted that the stack test results were approved on June 8,2018 which was after the due date for the 2017 CY report. Therefore,the requirement to submit a permit application was not necessary at the time of report submittal in CY 2017. However due to the submittal of 2018 CY report received on January 29,2019,a permit application should have been submitted as required by the permit condition. The facility has indicated that the 8.23 lb/ton NOx emission factor from the 2017 stack test is not representative and has argued the validity of the stack test. The facility re-tested Furnace C in January 2020. The CY 2019 reported indicated compliance with the projected actuals for each pollutant based on the results of the January 2020 stack test. However,the report should have used the emission factors from the 2017 stack test,which would have resulted in actual emissions above the projected actuals for NOx,PM,PM10,and PM2.5. Based on the 2017 stack test,the facility exceeded the PSD threshold for a major modification of 40 tpy for NOx in 2017 through 2019;and exceeded the PSD threshold for major modification of 10 tpy for PM2.5 in Page 9 of 14 2017 through 2019. A Notice of Violation letter was issued on October 30,2020 for failure to submit an air permit application per the terms of this permit condition. Per the NOV letter,the facility was required to submit a PSD permit application by December 15, 2020. A follow up email from Davis Murphy dated November 13,2020 stated that a revised PSD analysis would be an acceptable submission to the response to the NOV. A response to the NOV with the required PSD analysis was received on December 4,2020. Based on a review of the PSD analysis and the decision that the facility has not given a valid justification to the DAQ that the 2017 stack test is not representative,the facility appears to have triggered PSD permitting applicability. At the time of this report,the facility is considered in continuing violation of this permit condition and is required to submit a PSD permit application for NOx and PM2.5. A Notice of Continuing Violation letter will be issued requiring a PSD permit application. The facility will be considered in continuing violation of this permit condition until a PSD permit application is received. B. Emxss�on Control Emissia►n Source Description Control Device Descr�ptxan Source ZD No. Device ID Nn. ES-BH batch house fugitive sources F n/a n/a ES-SS 1 and two sand silos(20,900 cubic feet and 9.345 CD-SSFF one bagfilter(68 square feet of filter area) ES-SS2 cubic feet capacity) ......................................................................................................_ . ............................ ................................................................:........_.............................................................................:...:.....:.....:.:.... .... ES-MBE ; one mix batch elevator CD-MBEFF one bagfilter(68 square feet of filter area) ES-MBAE east mix batch bin for furnace A CD-MAEFF one bagfilter(68 square feet of filter area) (550 cubic feet capacity) .................................._ ......._.....�..................._..................................................................................... ES-MBAW CD-MBAWFF one bagfilter(68 square feet of filter area) west mix batch bin for furnace A (550 cubic feet capacity) ES-MBBE east mix batch bin for furnace B CD-MBBEFF one bagfilter(68 square feet of filter area) (550 cubic feet capacity) west mix batch bin for furnace B ES-MBBW CD-MBBWFF one bagfilter(68 square feet of filter area) (550 cubic feet capacity) ES-MBCE and east and west mix batch bin for furnace C CD-MBCFF one bagfilter(68 square feet of filter area) ES-MBCW (1,100 cubic feet capacity each) ES-08 : one rit blaster CD-08FF one filter cartridge dust collector (486 square feet of filter area) ...................................................... ........................................................ . .... ....: ...:...:.:... .....:........................................... ......... ........ ... ES-09 one grit blaster CD-09FF one bagfilter(80 square feet of filter area) ............................................................................................................................................................................................ ........................................................................................................................................................................................................................ ...... ...... ES-ML mold lubrication n/a n/a _ .... .._�. ES-RME ; raw material elevator `CD-RMEFF one bagfilter(41 square feet of filter area) Condition 2.1.B.1—This contains the requirements for 2D.0515 which requires the facility to limit the particulate matter emissions from miscellaneous industrial processes according to the allowable rates.The allowable rate(E)in pounds per hour can be calculated from the process rate(P)in tons per year by the following equations: 1)E=4.10 x P 1.61,where P<30 or 2)E=55.0 x P 1-11 -40, where P>30.The facility is required to control particulate matter emissions from the above-mentioned sources through the use of their respective control devices.Routine maintenance,monthly visual inspections,and annual internal inspections of the filters are required by this permit condition.The results of these inspections and maintenance are to be kept in a logbook with dates,times,and results noted. Summary reports of the results of the monitoring and recordkeeping is required on a semi-annual basis.The internal annual inspection for each bagfilters and cartridge filters were completed on June 30,2020. The monthly visual inspections were reviewed and were found to be complete. The latest semiannual report was received via email on January 29,2021 and indicated that the monthly and annual inspections were completed.The facility appears to be in compliance with 2D .0515. Condition 2.1.B.2—This contains the requirements for 2D.0521 which requires the facility to control the visible emissions from any emission source that may be discharged from vents or stacks.The above-mentioned sources were manufactured after July 1, 1971. Therefore,the visible emissions are not to exceed 20%opacity when averaged over a six-minute period. To comply,the facility shall perform monthly visible emissions observations.If the visible emissions observed are above normal,corrective action must be taken. The visible emissions observations shall be recorded and maintained in a logbook with dates,times,results,and any corrective action noted.The facility shall submit a summary report of the observations on a semi-annual basis. On January 21,2021,there were no Page 10 of 14 detectable visible emissions observed from the affect sources. The monthly visual emission observations were reviewed and were found to be complete.The latest semiannual report was received via email on January 29,2021 and indicated that the observations were completed and recorded.The facility appears in compliance with 2D.0521. C. One surface treatment system(ES-HST) Condition 2.1.C.I—This contains the requirements for 2D .0521 which requires the facility to control the visible emissions from any emission source that may be discharged from vents or stacks.Visible emissions are not to exceed 20%opacity when averaged over a six-minute period.No monitoring,recordkeeping,or reporting requirements currently apply.It should be noted that the stack for this source exhausts inside the building. 2.2—Multiple Emission Source(s)Specific Limitations and Conditions A. Facility-wide sources Condition 2.2.A.1—This contains the requirements for 2D .1806 which requires the facility to control and prohibit odorous emissions.Upon inspection,there were not any objectionable odors encountered near the property boundary.A review of the facility file showed that no odor complaints have been received by this office.The facility appears to be in compliance with 2D.1806. Condition 2.2.A.2—This contains the requirements for 2D.1100 which requires the facility to limit practices that release toxic air pollutant(TAP)emissions.For the surface treatment operation(ES-HST),hydrochloric acid emissions are limited to 1.05 pounds per hour.For the glass melting furnaces(GF-A,GF-B,and GF-C),cadmium and chromium (IV)emissions are limited to 146.83 and 2.261 pounds per year,respectively. The facility is required to maintain records of production rates, chemical usage,and other process operational information necessary to determine compliance with the emission limits.The 2019 Emissions Inventory reported,ES-HST emitted 0.27 pounds per hour of hydrochloric acid(based on 8,736 hr/yr).The facility-wide cadmium was 35.71 pounds per year. The total chromium emissions were report as 78.9 lbs/yr. The reported emissions are based on the April 2017 stack test for Furnace B. In the 2019 EI,the total chromium emission factor(0.0014 lb/ton)was applied to total glass production(55,989 tons/yr). Chromium is only emitted during emerald green production. The facility indicated that of the total of 30,666 tons was emerald green production and 22'923 tons was amber glass production. Based on emerald green production,total chromium should have been reported as 42.9 lbs/yr. It should be noted that the total chromium emission factor is based on EPA Reference Method 29. This test is for total chromium emissions and it is not possible to determine the Chromium VI portion from this test. The facility would need to test using SW-846 Method 0061 to determine chromium VI emissions. The facility likely complies with 2D.1100. Also,since the MACT 6S applies to emerald green production,the facility could request to remove the 2D.1100 chromium VI limit. Section 3—General Conditions Condition 3.P—This contains the requirements of 2Q .0508(n)which requires the facility to submit an Annual Compliance Certification(ACC)to the DAQ and EPA postmarked on or before March 1 st.The ACC should be certified by the responsible official and address all federally enforceable terms and conditions in the permit,including emissions limitations,standards,or work practices. The DAQ-WSRO received the facility's CY2019 ACC report on February 28,2020. The facility reported deviations for failure to submit a semiannual report by July 30,2019;exceeding the projected actual emission limits of permit condition 2.1.A.5.d;and for exceeding limit of 50 hours for nonemergency use for fire pump engine(I-DE3)per 40 CFR Part 63 Subpart ZZZZ. The facility appears to be in compliance with 2D.0508(n). Condition 3.X—This contains the requirements of 2Q.0207 which requires the facility to submit an Emissions Inventory(EI)to the DAQ by June 30th each year.The EI must include each air pollutant listed in 2Q.0207(a)from each emission source within the facility during the previous calendar year and be certified by the responsible official.The DAQ-WSRO received the facility's CY2019 EI on June 25,2020. The facility was requested to revise the 2019 Emissions Inventory based on the June 2017 stack test results for Furnace C. The facility contends that the June 2017 stack test is not representative. However,the EI was revised and was approved on November 3,2020. The facility appears to be in compliance with 2Q .0207. Condition 3.MM—This contains the requirements for 2D .0540 which requires the facility to control any fugitive dust emissions that may travel beyond the property boundary and cause a complaint.Upon review of the facility file,no recent fugitive dust complaints have been received by this office. There was not any fugitive dust encountered on January 21,2021.The facility appears to be in compliance with 2D .0540. Page 11 of 14 NSPS/NESHAP/112(r)APPLICABILITY The facility is subject to 40 CFR Part 60, Subpart IIII for"Compression Ignition Internal Combustion Engines"due to the diesel fire pump(I-DE3),the diesel emergency generators(I-DE5 and I-DE6). The fire pump is a 2015 Clarke Power model certified to EPA family EJDXL06.8120.I-DE5 is a 2006 Caterpillar model certified to EPA family 5VPXL 12.1 ACB. I-DE6 is a 2015 Caterpillar model.The specification sheet for the engine indicated that it was certified to Tier 3 emissions levels.To comply,the facility must operate and maintain the engines according to manufacturer specifications.Diesel fuel used by the engines is limited to a maximum sulfur content of 15 ppm and a minimum cetane index of 40 or a maximum aromatic content of 35 volume percent.The engine must be fitted with a non-resettable hour meter.Operation for maintenance checks and readiness testing is limited to 100 hours per year. Operation in non-emergency situations is allowed up to 50 hours per year,but those 50 hours are counted towards the 100 hours per year provided for maintenance and testing. There is no time limit on the use of emergency stationary ICE in emergency situations.The facility is required to keep records of all notifications associated with the subpart and records of all maintenance conducted on the engine.The facility must also keep records of operation hours of the engine that is recorded through the non-resettable hour meter. During the inspection,I-DE3,I-DE5,and I-DE6 were not operating.The facility is maintaining records of notifications and maintenance.The facility uses ULSD(15 ppm sulfur)in all engines. The facility is also subject to 40 CFR Part 63, Subpart ZZZZ for"Stationary Reciprocating Internal Combustion Engines"due to diesel fire pump(I-DE3),natural gas backup engine(I-DE4),diesel emergency generator(I-DE5),diesel emergency generator(I-EG), and diesel emergency generator(I-DE6).Per this rule,engines are considered"existing"if construction commenced before June 12, 2006 and are considered"new"if construction commenced on or after this date.I-DE3,I-DE5 I-DE6 are new,so their only requirement is to comply with NSPS Subpart IIII.I-DE4 and I-EG are existing engines. I-DE4 was a 1991 Arrow Specialty Co. model. This engine was removed during the Furnace A rebuild. I-EG is a 1973 (approx.)Caterpillar model and is currently not in use. It is disconnected from power except during testing. The compliance date was May 3,2013.For the engines,the facility is required to do the following: • Emergency stationary RICE must change oil and filter every 500 hours of operation or annually,whichever comes first; inspect air cleaner or spark plugs every 1,000 hours of operation or annually,whichever comes first;and inspect all hoses and belts every 500 hours of operation or annually,whichever comes first,and replace as necessary.There are no other operating limitations,fuel requirements,or performance tests required. • The facility with an engine subject to the oil change requirements has the option of utilizing an oil analysis program in order to extend the specified oil change requirement,as described under§63.66250). • The stationary RICE must be operated and maintained according to the manufacturer's emission-related operation and maintenance instructions,or facilities must develop and follow their own maintenance plan which must provide to the extent practicable for the maintenance and operation of the engine in a manner consistent with good air pollution control practice for minimizing emissions. • The engine's time spent at idle during startup must be minimized.The facility must also minimize the engine's startup time to a period needed for appropriate and safe loading of the engine,not to exceed 30 minutes. • Operation of the engine for any reason other than emergency operation,maintenance and testing,and operation in non- emergency situations for up to 50 hours per year is prohibited. There is no time limit on the use of emergency stationary RICE in emergency situations. Operation for maintenance checks and readiness testing is limited to 100 hours per year. The 50 hours per year of operation in non-emergency situations are counted towards the 100 hours per year provided for maintenance and testing.The 50 hours per year for non-emergency situations cannot be used for peak shaving or to generate income for a facility. • The engine must be equipped with a non-resettable hour meter. The facility must keep records which would support that the 100 hour per year operating limit is not exceeded,and the facility must document why the engine was operated and maintain records to support that the work practices were followed. The readings of the non-resettable hour meters are summarized in the table below.The facility is maintaining records of notifications and maintenance. Page 12 of 14 Emissions � �� Hours Hours `� Change in �� Em rss><on Source Descr�pt><an Last.Annual PM ;Source ID Na. (12/4/2019) (1/19l2020) Hours I-EGl diesel-fired emergency generator(125 kW) 891 893 7-2 1/16/20 ! f j 1/20/21 .................................................................._............................................... .................................................................. 1/16/20 I-DE3 diesel-fired fire pump(175 HP) 387.1 471.3 ! 84.2 1/12/21 1 _ _W...__w..___�W.._�._.__�.�__..�.._....�......,.�...�_.w..___w..._W.�.W.�__.._.�_uw��....W�_.__.�_.�.�.__.W._�.........__._,.....�.._..�._..:..W..__._�.W.__.....__........�._�._W..�......w_..._�.�...�.�_..W�,��r_,._....___:�_._.....W�.._......_................................ ._........... ....._...__�....� I-DE42 natural gas-fired backup engine for side wall NA NA NA NA ' cooling fan(46 HP) I-DES diesel-fired emergency generator 94.0 110 16 1/16/20 _ _ __ _ (363 kW/486 BHP) 1/11/21 50.7 1/16/20 I-DE6 diesel-fired emergency generator 12.1 62.8 (480 BHP) 1 1/11/21 .............................................................._..__................_........................................................................................................................................_.............................................................._............................................................................................._......................._...__..............._...,._..-1. ................................................................-.................,.............. 1. I-EG is no longer used and is disconnected from the power grid. Power is only connected during annual PM. The hour meter is in poor condition and the actual hours are hard to read. 2. I-DE4 has been removed as part of the Furnace A rebuild. The facility is also subject to 40 CFR Part 63, Subpart SSSSSS for"Glass Manufacturing Area Sources"as discussed under Condition 2.1.A.5 above. The facility does not use,store,or manufacture any of the regulated substances in quantities above the thresholds for the Section 112(r)program involving Risk Management Practice(RMP)requirements.They are only subject to the General Duty requirements contained in the General Condition. FACILITY EMISSIONS The following table summarizes the facility wide actual emissions.The actual emissions from the CY2016 and CY2017 Emissions Inventories are compared with the percent change demonstrated. CY201$Actual Em><ssipns CY2Q�9 Actual Em><ssibns C µ.w __,. T 3 ' o Pollutant /a hange 3 tans/year tans/year _._................ ....... .............._...._.................................................................................:..........._........................-__........................................_.................................._..._.................._.................................................................................._.................................................................................................................................. .. PM 78.75 101.89 +37.6 __...._.....__...__..__.w _...._� _._....._......:..._... W..._.., ._....__ �.W_,.._ ._._. .. .....,... ___.W.... w _.w...... _..._ _'___r.............. _�....w, +29 4 PMIo q 76.55 76 55 PMa.s 76.55 76.55 +27.5 .............:................_..................._..:.........................................._..__..........................._................- 502......................_.................._............... .......... .... ....................... ............. ........ ... w.. NOx._......_._...._.. .w..............._........._.,.._..... .._ W. ._.._._....._..._........_.._..w......w..._.._._... _.:__ .. .... _.._...._...._....__._..._ w _.. ......._. _.........� _ (7{" 435.27 598 92 ` +37 6 ,,,,,,,,,,,,,,,,w,rx�„•.v.,mw",......,,,,,.w"v.,,�,�„m,,,,.,,r....,.,."u..x,.„u,x,.,,,,,,,,,,,,"„",,,,vnw,,,,,i.,,,,,,,,.,x,,.,,,,,,......,u„"•x,,,,,.,,,.n„x„x,,,,..,,..u,.,,,,,nw,,,,,x,,.,,,,.. ,,,,v,,,,.w,,.,•,ix..,,.,,,,....,,,,",u,.,ui,,,,,.,,,,.,,,....,,r,,.,,v,,,,,,..,.,,v .....u,v,",,.,..., .,,u„mi,,.v,,.,,. ,,."•,..,, ,,,.,,u,,,,,u xv..,,,,,,,,.,.u,,,,,,,,,..,v,,.,,,,,.,,...,,,,u,,,m,,,.,,n'� CO 4.30 3.40 -20.9 ... ........ .._............_....... _._........_.................................._...._...........:...........................I........................................................................._................................................................................._........:......_........................:............................._.........................................._... ................................................................................._................................._................... VOC 13.75 25.55 +85.8 w_._ __..... �.__. _... _.._._.._.._ ._ ...._.._..... _ _._:. ._....._.........._._.W...... _........._.... ... HAPTotal ,..._..._._........_... 3 46 2.42 -30.0 ..._.W_...__. ..._.. 1.17 -39A HAPHigh m(5l)6: 1 93 PERMIT CONSIDERATIONS As stated above,the facility will be required to submit a PSD permit application due to the 2014 CY Furnace C rebuild project. The facility also submitted a 502(b)(10)notification for the Furnace A rebuild that occurred in 2020 CY. Both issues will need to be addressed as part of the next permit application submittal. Page 13 of 14 COMPLIANCE HISTORY October 30,2020-A Notice of Violation was issued for failure to submit a permit application per Permit Condition 2.1.A.5.d. The purpose of the permit application is to determine if PSD was triggered for the Furnace C rebuild project. As stated above,the facility was allowed to submit a PSD Analysis in lieu of a permit application. The PSD Analysis was received on December 4,2020. Based on the submittal,DAQ determined that PSD was triggered,and the facility will be required to submit a permit application. December 20,2019-A Notice of Violation was issued for exceeding the limit of 50 hours for nonemergency use for fire pump engine (I-DE3)per 40 CFR Part 63 Subpart ZZZZ.A response to the NOV was received on January 6,2020. The response indicated that a furnace inspection revealed a critical issue with Furnace B. During the repairs,a back-up chiller and pump were utilized to support the recirculation of water. Both the backup chiller and pump failed,necessitating the use of the emergency fire pump to prevent a glass leak and serious health and safety risks to the employees. August 8,2019—A Notice of Violation was issued for a late report for the purpose of complying with 15A NCAC 2D.0516"Sulfur Dioxide from Combustion Sources." The report was received on August 15,2019. February 20,2018—The facility was issued a Notice of Deficiency for exceeding the allowable hours for readiness testing on engine I-DE3 and failing to perform annual maintenance on engines I-DE4 and I-EG in 2017 CY. April 12,2017—The facility was issued a Notice of Deficiency for failing to submit the annual report required by Condition 2.1.A.6 of Air Quality Permit 01491/T21 by the due date of March 1,2017.The delinquent report was received on April 13,2017. CONCLUSION Owens-Brockway Glass Container,Inc. is in continuing violation of 2D.0530,"Prevention of Significant Deterioration"due to the Furnace C rebuild project. However,the facility was found to be operating in compliance with all other appropriate regulations based upon the visual observations and the records reviewed at the time of this inspection. Page 14 of 14