10/01/86
Guideline S-26 - Enforcement of the Arsenic NESHAP for Glass
Manufacturing Plants ( 40 CFR Part 60 Subpart N )
OCT - 1 1986
MEMORANDUM
SUBJECT: Guideline S-26 - Enforcement of the Arsenic NESHAP
for Glass Manufacturing Plants ( 40 CFR Part 60 Subpart N )
FROM: Director
Stationary Source Compliance Division
Office of Air Quality Planning and Standards
TO: Air and Waste Management Division Director
Region II
Air Management Division Directors
Regions I, III, V and IX
Air, Pesticides, and Toxics Management Division Directors
Regions IV and VI
Air and Toxics Division Directors
Regions VII
The attached guideline is being forwarded to you to assist you in the
implementation and enforcement of the arsenic National Emission Standards
for Hazardous Air Pollutants ( NASHAPS ) for glass manufacturing plants
( Subpart N ).
If you have any questions or comments on this guideline, please
contact Doreen Cantor in the Stationary Source Compliance Division at FTS
382-2874.
Edward E. Reich
Attachment
cc: Michael Alushin Stan Cuffe
Bob Ajax Ron Myers
George Walsh Jan Myers
Jim Engel
S-26 - GUIDELINE FOR THE ENFORCEMENT OF THE
ARSENIC NESHAP REGULATIONS
FOR GLASS MANUFACTURING PLANTS
This guideline is being issued to assist the Regional Offices in the
enforcement of one of the NESHAP regulations for the control of arsenic
emissions. Three types of facilities are required to be controlled by
these regulations: (1) glass manufacturing plants, (2) primary copper
smelters, and (3) arsenic trioxide and metallic arsenic production
facilities. This guideline addresses glass manufacturing plants only.
Arsenic was declared a hazardous air pollutant on June 5, 1980.
Regulations were proposed for the control of arsenic under Section 112 of
the Clean Air Act, National Emission Standards for Hazardous Air
Pollutants ( NESHAPS ) 40 FR 59532, on August 22, 1983. These regulations
were promulgated on August 4, 1986. Since this regulatory framework has
been previously utilized for the control of asbestos, beryllium, mercury,
vinyl chloride, and benzene, additional helpful information is available
in Guidelines S-17 thru S-30, which offer some general guidance relative
to the procedural requirements of the NESHAP program.
Summary of Requirements
The standard covers each glass melting furnace that uses commercial
arsenic as a raw material, except that pot furnaces ( refractory vessels in
which glass is melted by indirect heating and where the openings are
covered with refractory stoppers during melting ) are exempted. Each owner
or operator must either 1) vent all inorganic arsenic emissions from each
glass melting furnace to a control device and reduce emissions by at least
85%, the level of reduction achievable by an electrostatic precipitator or
fabric filter ( Section 61.162(a)(2) and (b)(2) ), or 2) maintain
uncontrolled (i.e. preceeding an add-on control device) arsenic emissions
at 2.5 Mg/year (2.75 TPY) or less for existing plants ( Section
61.162(a)(1) ), or at 0.4 Mg/year (0.44 TPY) or less for new plants
( Section 61.162(b)(1) ).
If the owner or operator intends to meet the standard by using a
control device, s/he is required to continuously monitor opacity and
temperature, and to submit semiannual reports of excess opacity. An owner
or operator may bypass the control device for a limited period of time for
designated purposes such as maintenance of the control device, upon prior
approval from the Regional Office.
- 2 -
If the owner or operator intends to meet the standard by limiting
uncontrolled arsenic emissions, s/he is required to calculate the
uncontrolled arsenic emissions semiannually, and to report if the emission
rate is above the applicable limit.
- 3 -
A. Source Notification
The Regional Offices should notify all potentially affected sources
immediately following the promulgation of the arsenic NESHAP regulations,
or immediately upon identification of affected sources anytime after
promulgation ( see guideline S-17 for example notification ). A list of all
know glass manufacturing plants using arsenic as a raw material is
attached ( Table 1 ). This list includes 75 furnaces at 27 plants, and
includes both controlled and uncontrolled furnaces, and furnaces emitting
arsenic at levels both above and below the threshold of 2.5 Mg/Yr. This
regulation would require two of these furnaces to install additional
controls or reduce arsenic usage, and would require at least six furnaces
to maintain their present controls. However, this list may not be
exhaustive, and it includes many emission estimates. Since new plants may
have been constructed, additional plants may have begun using arsenic as a
raw material, and some plants may be unidentified as of yet, additional
investigation should be made to complete the list. Also, a number of
companies are investigating the possibility of reducing or eliminating
arsenic in soda-lime batch formulations, which may reduce the number of
affected facilities. Preferably, all glass plants should be notified of
the regulations, because they will become subject if they begin using
arsenic as a raw material in the future. All affected sources should be
coded into CDS.
- 4 -
B. Determination of Compliance ( 40 CFR 61.164 )
1. Initial Report ( 40 CFR 61.10 )
The owner or operator of each existing source is required to submit an
initial report to the Administrator by November 2, 1986. This initial
report should include:
-name and address of the owner or operator,
-source location,
-brief description of the nature, size, design, and method of
operation ( including capacity and emission points ),
-the average weight of arsenic processed per month over the
previous 12 months as determined by direct measure of
materials balance,
-a description of the existing control equipment ( including
efficiency ), and
-a statement of the feasibility of complying with the
standard by November 2, 1986.
If the owner or operator is unable to comply with the standard within the
90-day period, s/he may apply for a waiver of compliance ( See Guideline
S-19). Sources which need to install control equipment may be granted a
waiver for up to two years if the time is needed for purchase and
installation. Reasonable compliance schedules for installing fabric
filters and ESP's are attached ( Table 2 ).
For any source for which a performance test is required, the owner or
operator must notify EPA at least 30 days before the test and must submit
the results to EPA within 60 days of the test, as indicated in the next
section.
For any source which can demonstrate compliance by means of an
emission calculation alone, the owner or operator must submit to EPA by
September 18, 1986 ( or within 45 days of start-up or modification ) a
written report of the calculated estimates of arsenic emissions. ( NOTE:
In the proposal, this report was required to be submitted within 90,
rather than 45, days. Sources may be unprepared for this change and may
require more time. )
- 5 -
For new and modified sources ( for which construction or modification
commenced after July 20, 1983, including any existing furnace which begins
to use arsenic - see following discussion ), the owner or operator must
apply for approval to construct or modify ( required by Section 61.07 ) and
provide process and emission data so that EPA may determine if the source
will be able to comply with the standard. After approval, the owner or
operator is required to notify EPA of the anticipated and actual start-up
dates as indicated in Section 61.90.
- 6 -
Determination of Whether a Source is "Modified" based on Arsenic Usage
Background Information
"Modification" is defined in the General Provisions, 40 CFR Section
61.02 as "any physical change or change in the method of operation . . .
which increases the amount of any hazardous air pollutant . . . or which
results in the emission of any hazardous air pollutant not previously
emitted, except that . . . an increase of the production rate, if such
increase does not exceed the operating design capacity . . . ( or ) an
increase in hours of operation . . . ( shall not be considered a change in
the method of operation )".
"New source" is defined as "any stationary source, the construction or
modification of which is commenced after ( proposal )".
The preamble to the promulgated standards ( Federal Register Vol. 51,
No. 149, August 4, 1986, p. 27997 ) states "(s)ince proposal, the use of
arsenic in some glass melting furnaces has been eliminated and the Agency
believes that this trend is likely to continue. The companies that
operate these furnaces have indicated that they do not plan to resume
using arsenic. The cutoff applied to new or modified glass melting
furnaces is based on consideration of cost and economic factors and has
been retained in the promulgated standard to discourage reintroduction of
arsenic in furnaces that have recently eliminated its use and to
discourage future use. The Agency believes that this is appropriate to
prevent risks from increasing near those furnaces that have recently
eliminated arsenic use and because reasonable alternatives to exceeding
this cutoff level are available at these facilities. These include the
use of low-arsenic glass recipes and the use of controlled furnaces for
production of those glass types which would result in uncontrolled
emissions of arsenic of more than 0.4 Mg ( 0.44 ton ) per year.
- 7 -
Discussion
Many furnaces subject to the arsenic NESHAP will typically melt a
variety of glasses with different arsenic contents and emission factors.
It is necessary to determine whether furnaces will become modified
sources, and thus subject to the more stringent emission limit, on the
basis of these changes in the method of operation.
The above information indicates that if a furnace has never used
arsenic and starts arsenic use any time after proposal, that furnace
should be considered a modified source.
If a furnace has used arsenic in the past, but has ceased its use, it
becomes a modified source at any point after proposal that it resumes the
use of arsenic. Because arsenic usage is to be calculated as a rolling
12-month average every 6 months, if a furnace does not use arsenic during
any such 12-month period, ( starting from the 12-month period immediately
preceeding proposal ) that furnace should be considered a non-arsenic
furnace, and any addition of arsenic in the future will cause this furnace
to become subject to the more stringent standard for new and modified
furnaces.
If a furnace has continuously used arsenic since the 12-month period
before proposal, it would be a modified source if arsenic emissions
increase above previous levels. Operating records should be reviewed to
determine if there has been any 12-month rolling average where arsenic
emissions were higher than a previous 12-month period. If so, the source
should be considered modified. If not, the semiannual rolling averages
calculated by the source should routinely be monitored to see that
emissions do not increase in the future. If emissions do increase, the
source is modified and is required to either install controls or change
operation in some way so that uncontrolled emissions will be limited to
0.4 Mg/Yr arsenic.
There are several exceptions to this:
(1) A source may argue that this period of lowest arsenic emissions
is not representative of the typical operation of that furnace. These
claims should be evaluated on a case-by-case basis. However, if the
reason for the low arsenic emissions was that the furnace was successfully
using a substitute for arsenic, then the lower emission rate should be
considered representative operation.
- 8 -
(2) If the increase in arsenic emissions is due solely to an increase
in production, then the furnace should not be considered "modified".
However, this refers to the production rate and hours of operation of the
furnace, not for the individual glass types. Therefore, if a furnace has
increased production of a big-arsenic glass but at the same time has
decreased production of a low-arsenic or non-arsenic glass such that
overall arsenic emissions increase but total production remains constant,
then the furnace should be considered modified.
In summary, for all furnaces which choose to demonstrate compliance
with the 2.5 Mg/Yr uncontrolled arsenic emission standard for existing
sources, their operating records for the period from August 22, 1982 ( 12
months before proposal ) to the present, as well as all future semiannual
calculations of uncontrolled arsenic emissions, should be reviewed to
determine whether the furnace has been modified because of these changes
in operation.
- 9 -
2. Emission Test ( 40 CFR 61.164 )
By November 2, 1986 (or within 90 days of startup for a new source),
the owner or operator must test emissions from the source unless a waiver
of emission testing is obtained under Section 61.13 ( See Guideline S-20 ).
The owner of operator must provide the Regional Office at least 30
days prior notice of the emission test and demonstration of the opacity
monitoring system, if applicable.
Emission tests are to be conducted while the source is operating under
conditions that are representative of those from which the maximum arsenic
emissions will result, as may be specified by the Regional Office.
Usually, this will be under conditions representative of the expected
maximum ( allowable ) production rate. However, for sources melting more
than one type of glass, or for sources with multiple furnaces emitting to
a single control device, the emission test should be conducted while the
source is operating at the expected maximum production rates for the glass
types generating the greatest amounts of arsenic. Furnaces producing non-
arsenic glass should also be operating during the emission test, as would
be representative of a source's usual operation. Another test may be
required later if source operation changes so that the original testing
operating conditions are no longer representative of "worst case"
operation.
The owner or operator must furnish the Regional Office with a written
report of the emission test results and associated calculations within 60
days of the test, and must retain records of emission test results and
other data needed to determine emissions for two years.
- 10 -
Furnaces with Uncontrolled Arsenic Emissions Above
2.5 Mg/yr ( existing ) or 0.4 Mg/yr ( new or modified )
( Section 61.164(e) )
Unless an alternative test method is approved ( refer to Guideline S-18
for procedure ), the owner or operator of each furnace must demonstrate
compliance with the 85% arsenic reduction requirement in Section
61.162(a)(2) or (b)(2) by using Method 108 to determine the concentration
of arsenic in the inlet and outlet has streams to the control device.
Each emission test is to consist of three 60-minute test runs, each
consisting of simultaneous testing of the inlet and outlet gas streams.
The gas streams must contain all of the gas exhausted from the gas melting
furnace.
The percent reduction for each run will be computed as follows:
D = ( Cb - Ca ) x 100
_______________
Cb
D = percent emission reduction
Cb = arsenic concentration in stack gas entering the
control device, as measured by Method 108
Ca = arsenic concentration in stack gas exiting the
control device, as measured by Method 108
The average percent reduction is equal to the arithmetic mean of the
results for the three runs, and must be equal to or greater than 85% for
the source to be in compliance.
- 11 -
Furnaces with Uncontrolled Arsenic Emissions Under
2.5 Mg/yr ( existing ) or 0.4 Mg/yr ( new or modified )
( Section 61.164(c) and (d) )
If less than 8.0 Mg arsenic/year ( 8.8 TPY ) is added to an existing
furnace, or less than 1.0 Mg arsenic/year ( 1.1 TPY ) is added to a new or
modified furnace, the owner or operator will usually be able to
demonstrate compliance with the uncontrolled emission limits by an
emission calculation only. A theoretical arsenic emission factor should
be calculated for each type of glass produced ruing the 12-month period,
as follows:
Ti = ( Abi x Wbi ) + ( Aci x Wci ) - Agi
Ti = theoretical uncontrolled arsenic emission factor
(g/kg) for each glass type (i)
Abi = fraction by weight of arsenic in fresh batch for
each glass type (i)
Wbi = weight (g) of fresh batch melted per kg of glass
produced for each glass type (i)
Aci = fraction by weight of arsenic in cullet for each
glass type (i)
Wci = weight (g) of cullet melted per kg of glass produced
for each glass type (i)
Agi = weight (g) of arsenic per kg glass produced for
each glass type (i)
The theoretical uncontrolled arsenic emissions for the 12-month period is
estimated as follows:
Yi = ( Ti x Gi )
_________
106
Yi = theoretical uncontrolled arsenic emission estimate
for the 12-month period for each glass type ( Mg/yr )
Ti = theoretical uncontrolled arsenic emission factor
for each type of glass produced during the 12-month
period (as calculated above)
Gi = kg of each arsenic-containing glass type (i)
produced during the 12-month period
- 12 -
The total theoretical uncontrolled arsenic emissions for each 12-month
period is equal to the sum of these emission estimates ( Yi ) for each glass
type produced. If this is equal to or less than 2.5 Mg for existing
plants, or 0.4 Mg for new plants, the source is in compliance and no
emission testing is required. If the total is above these limits, then
the source is required to test as described below.
The following procedure is required for existing sources using more
than 8.0 Mg arsenic/year, new sources using more than 1.0 Mg arsenic/year,
and for sources using less than these amounts but which are unable to
demonstrate compliance solely by the calculation procedure above. The
theoretical uncontrolled arsenic emission factors ( Ti ) and estimates (Yi)
should again be calculated for each glass type produced during the 12-
month period as described above. Emission testing, using Method 108, must
then be conducted during production of the glass type with the highest
theoretical uncontrolled arsenic emissions. The actual uncontrolled
arsenic emission factor should be computed as follows:
Ra = Ea
__
P
Ra = actual uncontrolled arsenic emission factor ( g/kg )
Ea = actual uncontrolled arsenic emission rate, from
Method 108 ( g/h )
P = rate of glass production ( kg/h ), determined by
dividing the weight of glass pulled from the furnace
during the emission test by the number of hours taken
to perform the test
A furnace correction factor (F) to relate the theoretical and actual
uncontrolled arsenic emission factors should be calculated as follows ( Ra
and Ti should be the same glass type ):
F = Ra
__
Ti
- 13 -
The total uncontrolled arsenic emission rate for the 12-month period
should be computed by applying this furnace correction factor to all of
the theoretical emission factors, as follows:
U = ( Summation of n where i = 1 )* ( T sub i x F x G sub i )/106th power
U = total uncontrolled arsenic emission rate ( Mg/year )
n = number of arsenic-containing glass types produced
during the 12-month period
If the total uncontrolled arsenic emission rate is less than 2.5 Mg/yr for
an existing furnace, or 0.4 Mg/yr for a new furnace, the source is in
compliance. If the total is above these values, then the source is in
violation and must install controls. However, the source may opt to
conduct Method 108 tests on the remaining glass types compute type
specific correction factors, and attempt to demonstrate compliance in that
way.
Example 1:
If the glass type produced during the Method 108 test is the only
glass type to be produced for the initial 12-month period, then
the actual arsenic emission factor can simply be multiplied by the
amount of glass produced to calculate total yearly arsenic
emissions. ( If less than 8.0 Mg (or 1.0 Mg) arsenic/year were
added to the furnace, a Method 108 test would be unnecessary. )
Ea = .045 lb/hr ( from Method 108 )
P = 900 lb/hr
Ra = Ea = .045 = .1 lb As/ton glass
__ ____
P 900
Total yearly arsenic emissions = (Ra) (annual
production) = (.1 lb/ton)(4000 ton/yr)= .2 TPY As
- 14 -
Example 2:
If two or more glass types are produced, a theoretical arsenic
emission factor, based on a materials balance, should be calculated for
every type of glass that will be produced. This should be multiplied by
the correction factor to calculate an actual arsenic emission factor for
each type of glass. Each actual arsenic emission factor should then be
multiplied by the amount of that glass that will be produced to calculate
yearly arsenic emissions for each glass type, and the results summed to
calculate total yearly arsenic emissions.
Assume 3 types of glass (A,B,C) are produced in one
furnace
For Glass A, from above, Ra(A)= .1 lb As/ton glass
Annual production of Glass A = 3000 TPY
Theoretical arsenic emission factor (TA) =
.08 lb As/ton glass
Correction factor = .1 = 1.25
__
.08
For Glass B, TB = .075 lb/ton
Ra(B)= (.075)(1.25) = .09 lb/ton
Annual production of Glass B = 500 TPY
For Glass C, TC = .4 lb/ton
Ra(C) = (.4)(1.25) = .5 lb/ton
Annual production of Glass C = 750 TPY
Total yearly arsenic emissions
= (Ra(A))(A's annual production) + (RaB))(B's
annual production) + (Ra(C))(C's annual
production)
= (.1 lb/ton)(3000 TPY) + (.09 lb/ton)(500 TPY)
+ (.5 lb/ton)(750 TPY)
= .15 TPY + .021 TPY + .19 TPY = .36 TPY
- 15 -
The Test Methods in Appendix B of Part 61 are to be used unless an
alternative method has been approved by the Director of the Emission
Standards and Engineering Division. If the results obtained by an
alternative method are thought to be inaccurate, the Regional Office may
require the use of a reference method. If the results obtained by the
reference method do not agree with those of the alternative method, the
results obtained by the reference method will prevail.
- 16 -
C. Emission Monitoring ( 40 CFR 61.163 )
An owner or operator complying with Section 61.162(a)(2) or (b)(2)
must install, calibrate, maintain, and operate
1) a continuous monitoring system for measuring opacity of
the exhaust gas and
2) a monitoring device for the continuous measurement of the
temperature of the gas entering the control device.
These should be installed, and their operational status verified, prior to
the emissions test. A report of the CEM evaluation should be furnished to
the Regional Office within 60 days of the evaluation. The purpose of the
transmissometer will be to indicate when the control device may not be
operating properly and emissions may be exceeding the applicable limit.
The reference method used to demonstrate compliance with the emission
limitation remains Method 108. As described in the following discussion,
a source specific opacity limit is to be derived for each individual
facility, which will be based on the opacity during an emissions test
demonstrating compliance. This level would be viewed as indicative of a
properly operated and maintained control device.
Opacity should be monitored during each of the three runs of the
emission test. During the emission test, process and control equipment
should be operated so that opacity is minimized, as may be specified by
the Regional Office. Monitoring results should be reduced to 6-minute
averages, and a source-specific opacity limit corresponding to the 97.5%
upper confidence level of a normal or lognormal ( whichever is more
representative ) distribution of the average opacity values should be
determined. Temperature of the gas entering the control device should
also be monitored during each test run, and 15-minute temperature averages
should be determined. An owner or operator may redetermine both these
values if this procedure is repeated during each test run of an emission
test demonstrating compliance.
All continuous monitoring systems should be in continuous operation as
described in Section 61.163(f). All opacity data should be reduced to 6-
minute averages, not including data from periods of breakdowns, repairs,
calibration checks, and zero and span adjustments. Fifteen-minute
averages of temperature should also be calculated.
The Regional Office may approve, after receipt and consideration of
written application, an alternative continuous monitoring system
( parameter-based, etc. ) to replace the CEM.
- 17 -
D. Recordkeeping ( 40 CFR 61.165 )
All owners or operators of glass melting furnaces using arsenic as a
raw material are subject to recordkeeping and reporting requirements.
Each owner or operator must retain for a minimum of two years the
following information:
. 1) all measurements, including continuous monitoring for
opacity and temperature,
. 2) all calculations used for emission estimates and all
records of emission test data,
. 3) all monitoring system performance evaluations, including
calibration checks and adjustment,
. 4) occurrence and duration of all startups, shutdowns or
malfunctions of furnace,
. 5) all malfunctions of air pollution control system,
. 6) all periods when any continuous monitoring system or
device is inoperative,
. 7) all maintenance and repairs made to each air pollution
control system, continuous monitoring system, or
monitoring device, and
. 8) if permission to bypass the control device is obtained,
the dates the control device is bypassed and steps taken
to minimize arsenic emissions during that period.
Additionally, each owner or operator of a glass plant complying with
Section 61.162(a)(1) or (b)(1) must determine and record every six months:
1) the uncontrolled arsenic emission rate for the preceeding
12-month period ( or 6-month period, for the first determination )
using measured or calculated arsenic emission factors ( as
applicable ) multiplied by each respective glass production rate,
and
- 18 -
2) an estimate of the uncontrolled arsenic emission rate
for the forthcoming 12-month period, taking into
consideration anticipated changes in production rates,
glass types, and other factors.
For these semiannual determinations, it would not be necessary to conduct
a Method 108 test again. The initial correction factor could be applied
again to calculate the measured arsenic emission factor for each glass
type.
- 19 -
E. Reporting ( 40 CFR 61.165 )
Each owner or operator complying with Section 61.165(a)(2) or (b)(2)
must submit written reports to the Administrator semiannually if excess
opacity occurred during the proceeding six-month period. An occurrence of
excess opacity is any 6-minute period where the average opacity exceeded
the source-specific opacity level. Excess opacity reports would not be
used to cite a source in violation, but would alert enforcement personnel
that the control device may not be operated and maintained properly and to
indicate that an inspection and/or emission test may be appropriate. All
semiannual reports should include:
1) magnitude of excess opacity, conversion factors used,
dates and times of each occurrence,
2) specific identification of excess opacity occurring
during start-ups, shutdowns, and malfunctions, and
3) dates and times of each period when the continuous
monitoring system was inoperative ( except for zero and
span checks ) and the nature of repairs or adjustments.
These reports must be postmarked by the 30th day following the end of the
six-month period.
An owner or operator may apply to the Regional Administrator for
approval to bypass the control device for limited periods, as described
previously. This application must be submitted at least 60 days before
the bypass period is to begin, and should include:
. 1) name and address of owner or operator,
. 2) location of source,
. 3) description of nature, size, design, and operation of source,
. 4) the reason it is necessary to bypass the control device,
. 5) the length of time needed to bypass the control device,
- 20 -
. 6) steps that will be taken to minimize arsenic emissions
during the bypass,
. 7) the quantity of emissions that would be released if no
steps were taken to reduce emissions,
. 8) the expected reduction in emissions due to steps taken
during the bypass to minimize emissions, and
. 9) the type of glass to be produced during the bypass and an
explanation of why non-arsenic or lower-arsenic glass
could not be melted during the bypass period.
If an owner or operator of a source complying with the 85% arsenic
reduction requirement wishes to reduce arsenic usage and comply with the
uncontrolled arsenic emission limitation instead, s/he should notify the
Regional Office of this change and include the necessary calculations and
emission test data to demonstrate that uncontrolled emissions will remain
below 2.5 (pr 0.4) Mg/year.
Each owner or operator complying with Section 61.162 (a)(1) or (b)(1)
must report the uncontrolled arsenic emission rate if uncontrolled arsenic
emissions exceed 2.5 Mg/yr for existing plants, or 0.4 Mg/yr for new
plants. If estimates show that arsenic emissions have exceeded 2.5 (or
0.4) Mg/yr for the preceeding 12-month period (or 6-month period, in a
first report following the compliance demonstration), this is a violation
and must be reported within 10 days of the end of the 6-month reporting
period. If estimates show that arsenic emissions will exceed 2.5 (or 0.4)
Mg/yr, the owner or operator must comply with Section 61.162 (a)(2) or
(b)(2) and, within 10 days, notify the Regional Office of the anticipated
date of the emission test.
- 21 -
Table 1: Emission Control for Arsenic Using Glass Plants
Expected
Plant No. Name/Location Number of Compliance
Furnaces Method a,b
1 Corning, Martinsburg, WV 1 PRc .
2 Corning, Charleroi, PA 1 PR
Corning, Charleroi, PA 1 CU
3 Corning, Fall Brook, NY 2 PR
Corning, Fall Brook, NY 3 UEL .
4 Corning, State College, PA 1 PR
5 GTE-Sylvania, Central Falls, RI 1 PR
6 North American Phillips, Danville, KY 1 PR
7 Blenko Glass, Milton, WV 1 UEL .
8 Brooke Glass Co., Wellsburg, WV 2 UEL
9 Corning, Corning, NY 2 UEL
10 Davis-Lynch Glass, Start City, WV 1 UEL
11 Fenton Art Glass, Williamston, WV 4 UEL .
12 Fostoria Glass, Moundsville, WV 1 UEL
13 GTE, Versailles, KY 1 UEL
14 Indiana Glass, Dunkirk, IN 9 UEL
15 Jeanette Shade & Novelty, Jeanette, WV 3 UEL .
16 Nourot Glass, Benica, CA 2 UEL
17 Owens-Illinois, Shreveport, LA 3 UEL
18 Owens-Illinois, Mt. Pleasant, PA 1 UEL
19 Owens-Illinois, Pittston, PA 2 UEL .
20 Owens-Illinois, Toledo, OH 9 UEL
21 Paul Wissnach Glass, Paden City, WV 5 UEL
22 Peltier Glass Co., Ottawa, IL 6 UEL
23 RCA, Circleville, OH 2 UEL .
24 Scandia Glass Works, Kenava, WV 2 UEL
25 Shott Optical, Duryea, PA 3 UEL
26 Vandermark Merritt Glass, Flemington, NJ 1 UEL
27 Westmoreland Glass Co., Pittsburgh, PA 4 UEL .
a UEL = Uncontrolled Emission Limt (2.5 Mg/yr)
PR = Percent Reduction (85%)
CU = Cease Arsenic Use
b Some of the furnaces emitting under 2.5 Mg arsenic/year also
have control devices, and may comply using either method
c Needs to install controls
- 22 -
Plants that are believed to have removed arsenic after proposal and which
would be subject to 0.4 Mg arsenic/year emission limit if arsenic is
re-introduced into glass:
1. American Stemware Corp.
2. Anchor-Hocking, Lancaster, OH
3. Anchor-Hocking, Baltimore, MD
4. Anchor-Hocking, Baltimore, MD
5. Corning, Charleroi, PA ( Soda-Lime furnace only )
6. Harvey Industries, Clarksburg, WV
7. Wheaton Industries, Millsville, NJ
Plants known to have used arsenic, but which were closed at last report:
1. Seneca Glass Company, Morgantown, WV
2. Sloan Glass, Inc., Culloden, WV
- 23 -
TABLE 1: Compliance Schedules
Fabric Filter ESP
Time (days)
Contracts awarded or purchase
orders issued 60 60
Fabrication 270 360
Shipping 30 30
Installation 240 150 .
Start-up 40 40
Sampling, analysis, report 90 90
Total 730 730 .
Return to Enforcement Policies