A	B	C	D	E	F	G
1	DEQ art glass permanent rulemaking 2016
2	Public comment points to respond to
4	Point ID	short summary	Summary of Comment	DEQ response	Notes	Assigned to	Response Status
15	11	health-based	This rule's requirements are technology-based, but the rule restrictions should be health-based	DEQ has begun the Cleaner Air Oregon rulemaking process to develop a statewide risk-based air toxics permitting program that will cover many industry types. There will be many opportunities for public input and participation in that process. The approach proposed in the art glass rule is a combination of risk and technology based approaches. It requires emission control devices to reduce the rate at which CAGMs emit metals, which is a technology-based requirement. It also incorporates elements of a risk-based program by establishing health based acceptable source impact levels for chromium usage at Tier 2 facilities. For rules to be only health based may be ideal, but the availability of emission control technology and its ability to control emissions must also be taken into account.			draft