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
7	3	other facilities	The pollution measured around Bullseye may be coming from other sources. DEQ should have collected more wind direction and velocity data. If DEQ does collect that data, it is likely that metals pollution near Bullseye is actually coming from fly ash used in making cement at the Lehigh Cement facility. There may be other point sources and mobile sources of these pollutants.	ask Brian Boling		Brian Boling
9	5	500 lb/year	DEQ should lower the applicability threshold of the rule so that all facilities making at least 500 lbs per year of HAP-containing glass are regulated.
10	6	all metals	The rule should regulate all heavy metals or all hazardous air pollutants (HAP), not just arsenic, cadmium, chromium, lead, manganese and nickel.		adding cobalt and selenium. Add uranium too?
20	16	health-based applicability	DEQ should base the applicability threshold on the amount of metals used (lbs/year) and their relative health risks, rather than on the amount of glass. Some glass contains concentrated HAP and other recipes are very dilute. Also, some HAP like hexavalent chromium are more dangerous than others.		Al Hooton
21	17	don't apply to glass users	Because of the way that 'melt' and 'furnace' are used in the rule, it may apply to some art glass users that are remelting glass rather than making it from powdered raw materials.		Chris Mini
22	18	EJ	DEQ is required by to do demographic analysis to make sure that it does not have disproportionate adverse impacts on communities of color.		CRAG	Paul
23	19	BLDS	DEQ should require baghouse leak detection		EPA
27	23	no metals in uncontrolled furnaces	CAGMs should not be allowed to use any metals in uncontrolled furnaces	?
31	24	baghouses not effective	In the Bullseye source test, the capture efficiency for chromium was less than for particulate matter. Baghouses are not effective if pollution is in a gas state or in very small particles.	The boiling point for chromium is 4,841°F. Baghouses operate at a much lower temperature than that, so chromium would not be in vapor form when passing through the baghouse. The Bullseye source test referenced in the comment only included one test run, so it's unknown whether that one data point is accurate under all circumstances. It's possible that chromium is being emitted at a very small particle size that is difficult for the baghouse to filter out. In any case, under the revised rule Tier 2 facilities are required to test their outlet emissions using EPA Method 29, which includes all emissions (filterable and condensable) and set production limits to keep chromium emissions below health benchmarks. That further data will measure actual chromium emissions and limit them to keep the air safe to breathe.			need review