EPA alleged that Owens-Brockway violated, at its glass melting furnace (Furnace H), Illinois SIP rule 35 IAC 212.321(a) and corresponding Title V permit Condition 7.3.3.c limiting PM emissions from process units during any one hour period to rates of less than those computed by the relationship E = A(P)B; where E is the allowable emission rate; P is the process weight rate; and A and B are constants. These violations were revealed by EPA during a review of information submitted by Owens-Brockway in response to a Section 114 information request.
On March 13, 2007, EPA issued to Owens-Brockway a Notice of Violation and Finding of Violation alleging that the company violated the aforementioned conditions of its Title V permit and Illinois SIP. Owens-Brockway representatives met with EPA on April 17, 2007, to discuss the alleged violations and actions that the company would take to achieve and maintain compliance with the Illinois SIP and its operating permit limitations. Owens-Brockway subsequently proposed utilizing electric boost to reduce PM emissions from the furnace to within the allowable PM limits. Electric boost is a known method of reducing glass furnace PM emissions, if it is used to offset natural gas combustion and not to increase glass production.
EPA required that Owens-Brockway demonstrate the effectiveness of the proposed electric boost-production rate schedule by conducting a number of stack tests at varying production rates and electric boost rates.