Ideas for changes to the art glass rule:

•  Demonstrating 99% control efficiency may be very difficult for facilities that don’t have a lot of PM coming into their baghouse.

◦  Allow them to show compliance with a baghouse / bag design spec (designed for 99.5% capture?)

◦  Or, create an alternate standard based on grain loading at the outlet?

◦  Or, could a surrogate PM be injected for testing purposes?

◦  “other test as approved by DEQ”

◦  Allow grain loading for Tier 1 and for Tier 2

◦  Require baghouse leak detection system for Tier 2s?

•   9040(3)(a)(B) allow Tier 2s to measure for chrome conversion at outlet of control device, don’t need to measure at inlet of control device.

•  Clarifications:

◦  Clarify that facilities can operate between permit application and permit issuance?

▪  Intent is that existing facility must apply by deadline, can operate until DEQ issues permit. Did not decide whether rule language change to clarify this is needed.

◦  Is furnace a 'controlled furnace' as soon as baghouse is installed, or does it have to wait until the source test has been performed (or source test results received?)

▪  Intent is that it is ‘controlled’, can be operated until source test results available. Did not decide whether rule language change to clarify this is needed.

•  for Tier 1 facilities, treat cadmium like chrome VI and don't allow use of it in uncontrolled furnaces? Cd has a low melting point so only 20% ends up in the final product, presumably 80% goes up the stack. (Abe Fleishman, Northstar 5/17/2016 phone call)

◦  This may be a moot point. No Tier 1s are planning to go the uncontrolled + modeling route.

•  Allow use of a mass balance approach to estimate emissions (measure amount in final product + amount in raw materials, assume the rest is emitted?) (Abe Fleishman, Northstar 5/17/2016 phone call)

•  Lower the threshold for rule applicability, to capture facilities making glass in their garages? Apparently there are two garage glassmaking operations in Eugene. (Abe Fleishman, Northstar 5/17/2016 phone call)

◦  Maybe smaller garage facilities could be regulated by zoning or handled by the bigger rulemaking. Keep at 10 tons.

•  Should the rule apply statewide? (Suggested by the 5 CAGMs subject to the rule, as part of a fiscal advisory committee meeting.)

◦  Are there any facilities outside PDX that would be subject?

◦  Leave this as PDX-only, could be replaced or extended statewide when the bigger risk-based permitting rule moves forward.

•  Change the 24-hr benchmark for hex chrome, if/when OHA has a revised number? (It’s incorporated at OAR 340-244-9040(3) and (4).