A B C D E F G H I J K L M N O P Q R S T U V W X Y
1 CommentID FacilityNeighbor InOregon InUS OutsideUS SupportsRule OpposesRule WantsMoreComplianceTimeOrFlexibility ConsiderEconomicAffectOnGlassArtists OtherSourcesPolluteToo DontShutDownGlassIndustry ILikeGlass GlassArtist SupportsStatewide SupportsLowOrNoThreshold SupportsIncludingMoreMetalsInList SupportsHigherCaptureEfficiency SupportsRevisedBenchmarks SupportsIncludingAllGlassManufacturers SupportsHealthBased MorePublicInvolvement DetailedComment Notes DuplicateOfPrevious TestComment
2 1 FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE TRUE is there visible emissions monitoring through another rule FALSE FALSE
3 2 TRUE FALSE FALSE FALSE FALSE FALSE TRUE TRUE TRUE FALSE FALSE TRUE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE   FALSE FALSE
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14 13 FALSE FALSE TRUE FALSE FALSE FALSE TRUE TRUE TRUE FALSE FALSE TRUE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE   FALSE FALSE
15 15 FALSE FALSE FALSE TRUE FALSE FALSE FALSE FALSE FALSE TRUE TRUE TRUE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE Additional document is picture of stained glass window. FALSE FALSE
16 16 FALSE FALSE TRUE FALSE FALSE FALSE TRUE TRUE FALSE TRUE TRUE TRUE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE   FALSE FALSE
17 17 FALSE FALSE TRUE FALSE FALSE FALSE TRUE TRUE FALSE TRUE FALSE TRUE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE   FALSE FALSE
18 18 FALSE FALSE TRUE FALSE FALSE TRUE FALSE TRUE FALSE FALSE FALSE TRUE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE   FALSE FALSE
19 19 FALSE FALSE TRUE FALSE FALSE FALSE TRUE TRUE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE Additional document is picture of glass art. FALSE FALSE
20 20 FALSE FALSE TRUE FALSE FALSE FALSE TRUE TRUE FALSE FALSE FALSE TRUE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE   FALSE FALSE
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36 38 FALSE FALSE FALSE TRUE FALSE FALSE FALSE TRUE FALSE FALSE FALSE TRUE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE   FALSE FALSE
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52 103 FALSE FALSE FALSE TRUE FALSE FALSE FALSE TRUE FALSE FALSE FALSE TRUE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE   FALSE FALSE
53 107 FALSE FALSE TRUE FALSE FALSE TRUE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE   FALSE FALSE
54 108 FALSE FALSE TRUE FALSE FALSE FALSE FALSE FALSE FALSE TRUE TRUE TRUE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE   FALSE FALSE
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58 115 FALSE FALSE TRUE FALSE FALSE FALSE FALSE TRUE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE   FALSE FALSE
59 116 FALSE FALSE TRUE FALSE FALSE FALSE FALSE TRUE FALSE FALSE FALSE TRUE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE   FALSE FALSE
60 117 FALSE FALSE TRUE FALSE FALSE FALSE FALSE FALSE FALSE TRUE FALSE TRUE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE   FALSE FALSE
61 119 FALSE FALSE TRUE FALSE FALSE FALSE FALSE FALSE FALSE FALSE TRUE TRUE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE   FALSE FALSE
62 120 FALSE FALSE TRUE FALSE TRUE FALSE FALSE FALSE FALSE FALSE FALSE TRUE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE   FALSE FALSE
63 121 FALSE FALSE TRUE FALSE FALSE FALSE FALSE TRUE FALSE FALSE FALSE TRUE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE   FALSE FALSE
64 155 FALSE FALSE TRUE FALSE FALSE FALSE FALSE FALSE FALSE FALSE TRUE TRUE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE   FALSE FALSE
65 189 FALSE FALSE TRUE FALSE FALSE FALSE FALSE FALSE FALSE FALSE TRUE TRUE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE   FALSE FALSE
66 194 TRUE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE TRUE TRUE TRUE FALSE FALSE TRUE FALSE TRUE FALSE   FALSE FALSE
67 199 TRUE TRUE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE TRUE TRUE TRUE FALSE FALSE TRUE FALSE FALSE FALSE   TRUE FALSE
68 200 TRUE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE TRUE TRUE TRUE FALSE FALSE TRUE TRUE FALSE FALSE   FALSE FALSE
69 204 TRUE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE   FALSE FALSE
70 205 TRUE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE TRUE TRUE TRUE FALSE FALSE FALSE FALSE FALSE FALSE   FALSE FALSE
71 206 FALSE TRUE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE TRUE TRUE FALSE FALSE TRUE TRUE FALSE FALSE   FALSE FALSE
72 209 FALSE FALSE TRUE FALSE FALSE FALSE TRUE FALSE FALSE TRUE FALSE TRUE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE   TRUE FALSE
73 212 FALSE TRUE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE TRUE FALSE TRUE FALSE FALSE TRUE FALSE TRUE FALSE   FALSE FALSE
74 215 TRUE FALSE FALSE FALSE TRUE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE 'filter all furnaces' FALSE FALSE
75 221 FALSE FALSE TRUE FALSE FALSE FALSE TRUE FALSE FALSE TRUE FALSE TRUE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE   FALSE FALSE
76 224 TRUE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE TRUE TRUE TRUE FALSE FALSE TRUE TRUE FALSE FALSE   FALSE FALSE
77 230 FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE   FALSE TRUE
78 231 TRUE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE wants 'highest, strongest' emissions standards. FALSE FALSE
79 235 TRUE TRUE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE TRUE Appears to be same as previous comment, with comment included as Word doc with some words highlighted. TRUE FALSE
80 236 TRUE TRUE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE TRUE Appears to be same as previous comment, with comment included as Word doc with some words highlighted. TRUE FALSE
81 237 FALSE TRUE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE TRUE TRUE TRUE FALSE FALSE FALSE FALSE FALSE FALSE   TRUE FALSE
82 238 FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE TRUE FALSE FALSE TRUE TRUE TRUE regulate cold shops too
require baghouse filters to be rated for 99.9% capture
precautionary principle		 FALSE FALSE
83 239 FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE TRUE   TRUE FALSE
84 240 FALSE TRUE FALSE FALSE TRUE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE don't rely only on NESHAP FALSE FALSE
85 241 FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE TRUE duplicate of previous TRUE FALSE
86 242 FALSE TRUE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE TRUE FALSE FALSE FALSE FALSE TRUE TRUE FALSE FALSE   FALSE FALSE
87 243 FALSE TRUE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE   FALSE FALSE
88 244 FALSE FALSE TRUE FALSE FALSE FALSE TRUE FALSE FALSE TRUE FALSE TRUE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE   TRUE FALSE
89 362 FALSE TRUE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE TRUE FALSE TRUE TRUE FALSE TRUE FALSE FALSE FALSE wants 99.9% capture rate
wants 'all glass factories', not just art glass		 FALSE FALSE
90 367 FALSE FALSE TRUE FALSE FALSE FALSE TRUE FALSE FALSE FALSE FALSE TRUE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE   FALSE FALSE
91 368 FALSE FALSE TRUE FALSE FALSE FALSE FALSE FALSE FALSE TRUE FALSE TRUE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE   FALSE FALSE
92 369 FALSE FALSE TRUE FALSE FALSE FALSE FALSE FALSE FALSE TRUE FALSE TRUE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE   FALSE FALSE
93 372 FALSE FALSE TRUE FALSE FALSE FALSE FALSE FALSE FALSE TRUE FALSE TRUE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE   FALSE FALSE
94 376 FALSE FALSE TRUE FALSE FALSE FALSE FALSE TRUE FALSE TRUE FALSE TRUE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE   TRUE FALSE
95 381 FALSE FALSE TRUE FALSE FALSE FALSE FALSE TRUE FALSE FALSE FALSE TRUE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE attachment is picture of glass art FALSE FALSE
96 382 FALSE FALSE TRUE FALSE FALSE FALSE FALSE TRUE FALSE FALSE FALSE TRUE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE   TRUE FALSE
97 383 TRUE FALSE FALSE FALSE TRUE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE   FALSE FALSE
98 385 FALSE FALSE TRUE FALSE FALSE FALSE FALSE FALSE FALSE TRUE FALSE TRUE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE   FALSE FALSE
99 387 TRUE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE TRUE TRUE TRUE FALSE FALSE TRUE TRUE TRUE FALSE   FALSE FALSE
100 388 TRUE FALSE FALSE FALSE TRUE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE   FALSE FALSE
101 389 FALSE TRUE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE TRUE TRUE TRUE TRUE TRUE TRUE FALSE TRUE TRUE revise benchmarks, revise rule to depend on new benchmarks
Apply to General Glass and Owens-Brockaway
wants 99.9% limit
video recording equipment for all public meetings		 FALSE FALSE
102 390 FALSE TRUE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE TRUE FALSE TRUE TRUE FALSE TRUE FALSE FALSE FALSE 99.9% capture rate
all glass factories, not just art glass		 FALSE FALSE
103 395 FALSE TRUE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE TRUE FALSE FALSE TRUE TRUE TRUE FALSE FALSE FALSE update health benchmarks
apply to all glass factories, not just art glass
99.9% capture rate		 FALSE FALSE
104 557 FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE TRUE FALSE TRUE TRUE FALSE TRUE FALSE FALSE FALSE 99.9% capture rate
revise health benchmarks
apply to all glass factories, not just art glass		 FALSE FALSE
105 558 FALSE FALSE TRUE FALSE FALSE FALSE FALSE TRUE FALSE TRUE FALSE TRUE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE   FALSE FALSE
106 561 FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE   TRUE FALSE
107 566 FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE TRUE FALSE TRUE TRUE TRUE TRUE FALSE FALSE FALSE 99.9% capture
update health benchmarks		 FALSE FALSE
108 590 FALSE FALSE TRUE FALSE FALSE FALSE TRUE TRUE FALSE TRUE FALSE TRUE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE TRUE "there is a simple fix to everything: close the loophole on the definition of batch production. Because that is basically what is happening here. The art glass industry has followed the rules, and like any logical entity, utilized the loophole to its advantage - so close the loophole." FALSE FALSE
109 593 FALSE TRUE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE TRUE TRUE wants more info about DEQ actions & hex chrome concentrations
translation for non-English speakers
make air emissions data publicly available
DEQ should have online searchable database of permits
diesel emissions		 FALSE FALSE
110 594 FALSE FALSE TRUE FALSE FALSE FALSE TRUE FALSE FALSE FALSE FALSE TRUE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE   FALSE FALSE
111 596 FALSE TRUE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE TRUE FALSE FALSE FALSE FALSE FALSE FALSE TRUE suggests 500 lb threshold TRUE FALSE
112 602 TRUE TRUE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE TRUE TRUE FALSE FALSE FALSE FALSE FALSE FALSE FALSE suggests 500 lb threshold instead of 10 tons TRUE FALSE
113 608 TRUE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE TRUE TRUE FALSE FALSE FALSE FALSE FALSE FALSE FALSE suggests 500 lb threshold instead of 10 tons FALSE FALSE
114 612 FALSE TRUE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE TRUE TRUE FALSE FALSE FALSE TRUE FALSE FALSE TRUE supports lower threshold calculated based on modeling and ambient benchmarks
and grain loading standard at 0.005 gr/dscf		 FALSE FALSE
115 616 FALSE TRUE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE TRUE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE regulate differently for making from raw materials vs those who re-melt. Any size manufacturer that is using raw materials should be regulated. FALSE FALSE
116 989 FALSE TRUE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE TRUE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE As a representative and resident of Southeast Portland, I am deeply concerned about the environmental and human health impacts of uncontrolled metal emissions. If we truly care about the health of all Oregonians, I encourage the DEQ and EQC to consider extending the permanent rule to art glass manufacturers statewide. The issue of industrial air toxics is not limited to the Portland Metro Area, and the proposed permanent rule may provide a competitive advantage to businesses in other regions of the state. I believe that all known sources of air pollution should be subject to the DEQ’s health-based regulations, regardless of geographic location. In broadening the scope of the permanent rule, we can better protect the health and wellbeing of all Oregon residents TRUE FALSE
117 1005 FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE As a representative and resident of Southeast Portland, I am deeply concerned about the environmental and human health impacts of uncontrolled metal emissions. If we truly care about the health of all Oregonians, I encourage the DEQ and EQC to consider extending the permanent rule to art glass manufacturers statewide. The issue of industrial air toxics is not limited to the Portland Metro Area, and the proposed permanent rule may provide a competitive advantage to businesses in other regions of the state. I believe that all known sources of air pollution should be subject to the DEQ’s health-based regulations, regardless of geographic location. In broadening the scope of the permanent rule, we can better protect the health and wellbeing of all Oregon residents. TRUE FALSE
118 1034 FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE As a representative and resident of Southeast Portland, I am deeply concerned about the environmental and human health impacts of uncontrolled metal emissions. If we truly care about the health of all Oregonians, I encourage the DEQ and EQC to consider extending the permanent rule to art glass manufacturers statewide. The issue of industrial air toxics is not limited to the Portland Metro Area, and the proposed permanent rule may provide a competitive advantage to businesses in other regions of the state. I believe that all known sources of air pollution should be subject to the DEQ’s health-based regulations, regardless of geographic location. In broadening the scope of the permanent rule, we can better protect the health and wellbeing of all Oregon residents TRUE FALSE
119 1062 FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE As a representative and resident of Southeast Portland, I am deeply concerned about the environmental and human health impacts of uncontrolled metal emissions. If we truly care about the health of all Oregonians, I encourage the DEQ and EQC to consider extending the permanent rule to art glass manufacturers statewide. The issue of industrial air toxics is not limited to the Portland Metro Area, and the proposed permanent rule may provide a competitive advantage to businesses in other regions of the state. I believe that all known sources of air pollution should be subject to the DEQ’s health-based regulations, regardless of geographic location. In broadening the scope of the permanent rule, we can better protect the health and wellbeing of all Oregon residents. TRUE FALSE
120 1063 FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE As a representative and resident of Southeast Portland, I am deeply concerned about the environmental and human health impacts of uncontrolled metal emissions. If we truly care about the health of all Oregonians, I encourage the DEQ and EQC to consider extending the permanent rule to art glass manufacturers statewide. The issue of industrial air toxics is not limited to the Portland Metro Area, and the proposed permanent rule may provide a competitive advantage to businesses in other regions of the state. I believe that all known sources of air pollution should be subject to the DEQ’s health-based regulations, regardless of geographic location. In broadening the scope of the permanent rule, we can better protect the health and wellbeing of all Oregon residents TRUE FALSE
121 1068 FALSE TRUE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE TRUE FALSE TRUE TRUE TRUE TRUE FALSE FALSE FALSE 99.9% control efficiency
apply to all glass manufacturers
revise health benchmarks		 FALSE FALSE
122 1080 FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE   TRUE FALSE
123 1081 FALSE TRUE FALSE FALSE TRUE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE   FALSE FALSE
124 1082 FALSE TRUE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE TRUE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE   FALSE FALSE
125 1084 FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE   TRUE FALSE
126 1086 FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE   TRUE FALSE
127 1094 FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE   FALSE TRUE
128 1095 FALSE FALSE FALSE TRUE FALSE FALSE FALSE TRUE FALSE TRUE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE   FALSE FALSE
129 1096 FALSE TRUE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE TRUE TRUE FALSE FALSE FALSE TRUE 99.9% capture
revise Cr6 benchmark to 0.08 ng/m3 (and use that as daily acceptable source impact level in 340-244-9040)		 FALSE FALSE
130 1097 FALSE TRUE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE TRUE FALSE TRUE TRUE TRUE TRUE FALSE FALSE FALSE 99.9% capture
include all glass factories
revise health benchmarks		 FALSE FALSE
131 1099 FALSE TRUE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE TRUE TRUE FALSE FALSE FALSE TRUE 99.9% capture
revise Cr6 benchmark to 0.08 ng/m3 (and use that as daily acceptable source impact level in 340-244-9040)		 FALSE FALSE
132 1101 FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE   TRUE FALSE
133 1103 FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE   TRUE FALSE
134 1345 FALSE FALSE TRUE FALSE FALSE FALSE FALSE FALSE FALSE TRUE FALSE TRUE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE   FALSE FALSE
135 1348 FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE TRUE FALSE TRUE TRUE TRUE TRUE FALSE FALSE FALSE 99.9% capture rate
apply to all glass factories, not just art glass		 FALSE FALSE
136 1349 FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE TRUE FALSE TRUE TRUE TRUE TRUE FALSE FALSE FALSE 99.9% capture rate
apply to all glass factories, not just art glass		 FALSE FALSE
137 1350 FALSE TRUE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE TRUE For Tier 2 chrome usage limits, suggests testing for total Cr at outlet of baghouse (Method 29) and assuming all of it is Cr6.
suggests 0.2 lb/ton emission rate rather than 99% control efficiency		 FALSE FALSE
138 1351 FALSE TRUE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE TRUE TRUE TRUE FALSE FALSE TRUE TRUE TRUE TRUE ensure public notice and comment instead of locking the public out of DEQ decisions
health-based standards		 FALSE FALSE
139 1358 FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE   TRUE FALSE
140 1366 FALSE TRUE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE TRUE FALSE TRUE TRUE TRUE TRUE TRUE FALSE FALSE benchmarks should be the most conservative
99.9% capture rate
all glass manufacturers, not just art glass		 FALSE FALSE
141 1367 FALSE TRUE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE TRUE FALSE TRUE FALSE FALSE FALSE FALSE FALSE TRUE include all sources of metal emissions
some of comment is a duplicate of their previous entry.		 FALSE FALSE
142 1368 FALSE FALSE FALSE TRUE FALSE FALSE TRUE TRUE TRUE TRUE FALSE TRUE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE   FALSE FALSE
143 1483 FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE   TRUE FALSE
144 1611 TRUE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE TRUE TRUE TRUE FALSE FALSE TRUE FALSE FALSE FALSE   FALSE FALSE
145 1616 FALSE FALSE TRUE FALSE FALSE TRUE FALSE FALSE TRUE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE Based on wind data and the ratio between different heavy metals, believes the metal emissions measured near Bullseye are from fly ash used at Lehigh Cement. FALSE FALSE
146 1617 FALSE TRUE FALSE FALSE FALSE FALSE TRUE FALSE TRUE FALSE FALSE TRUE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE   FALSE FALSE
147 1651 FALSE FALSE TRUE FALSE FALSE TRUE FALSE FALSE TRUE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE believes the metals are mostly coming from Lehigh Cement, based on his read of the wind data. FALSE FALSE
148 1652 FALSE TRUE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE TRUE FALSE FALSE FALSE TRUE 5 ng/m3 benchmark for Cr6, to replace current 36 ng/m3 in the rule. FALSE FALSE
149 1653 FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE   TRUE FALSE
150 1654 FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE   TRUE FALSE
151 1655 FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE   TRUE FALSE
152 1656 FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE   TRUE FALSE
153 1657 FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE   TRUE FALSE
154 1874 FALSE TRUE FALSE FALSE FALSE FALSE FALSE FALSE TRUE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE   FALSE FALSE
155 1875 FALSE TRUE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE TRUE TRUE TRUE TRUE FALSE TRUE TRUE TRUE FALSE control filterable and condensable at 99.9%
apply to all glass manufacturers
more public notice and comment
health-based standards		 FALSE FALSE
156 1876 FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE   TRUE FALSE
157 1925 FALSE FALSE TRUE FALSE FALSE FALSE FALSE FALSE TRUE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE   FALSE FALSE
158 1945 FALSE FALSE TRUE FALSE FALSE FALSE FALSE FALSE TRUE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE 'no wind data was collected or analyzed'
believes lead is from Lehigh Cement, not from Bullseye		 FALSE FALSE
159 1946 FALSE TRUE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE TRUE TRUE TRUE FALSE FALSE TRUE TRUE FALSE FALSE wants health-based standards
all glass manufacturers not just CAGM		 FALSE FALSE
160 1947 FALSE TRUE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE TRUE TRUE TRUE TRUE TRUE FALSE TRUE TRUE TRUE wants health-based not technology based
500 lb/year threshold not 10 tpy
legal requirement to consider effect on EJ communities [asked Paul to draft response]
rule should only apply to furnaces to which NESHAP 6S does not apply
no emissions before DEQ permit issued
public participation in details of permit app, etc
99.9% control efficiency
source test should include condensables
clarify that Tier 2 can't use metal HAP in uncontrolled furnace 9040(2)
revise Cr6 limit 36 ng/m3		 FALSE FALSE
161 1948 TRUE TRUE FALSE FALSE TRUE FALSE FALSE FALSE FALSE FALSE FALSE FALSE TRUE TRUE TRUE TRUE FALSE TRUE FALSE TRUE FALSE   TRUE FALSE
162 1949 FALSE TRUE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE TRUE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE revise baghouse source test method to reduce cost FALSE FALSE
163 1952 FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE   TRUE FALSE
164 1954 TRUE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE TRUE TRUE TRUE TRUE FALSE TRUE TRUE TRUE FALSE health-based standards
99.9% capture
filterable and condensable		 FALSE FALSE
165 1957 FALSE TRUE FALSE FALSE TRUE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE   FALSE FALSE
166 1963 FALSE FALSE TRUE FALSE FALSE FALSE FALSE FALSE TRUE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE   FALSE FALSE
167 1964 FALSE TRUE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE TRUE TRUE FALSE FALSE FALSE FALSE FALSE FALSE FALSE   TRUE FALSE
168 1968 FALSE TRUE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE TRUE TRUE FALSE FALSE FALSE FALSE FALSE FALSE TRUE suggests baghouse outlet grain loading limit of 0.01 gr/dscf or 0.001 gr/dscf as a replacement for 99% standard
500 lbs/year threshold instead of 10 tpy
add cadmium to list of metals (currently Cr6) that tier 1s can't use in uncontrolled furnace
keep Tier 1 permits below $2-4,000/year		 FALSE FALSE
169 1969 FALSE TRUE FALSE FALSE FALSE FALSE FALSE FALSE TRUE FALSE FALSE FALSE TRUE TRUE FALSE FALSE FALSE TRUE FALSE FALSE FALSE supports change from 99% control efficiency to grain loading FALSE FALSE
170 1972 FALSE TRUE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE TRUE FALSE TRUE TRUE FALSE FALSE FALSE FALSE FALSE filterable and condensable 99.9% FALSE FALSE
171 1973 FALSE TRUE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE TRUE TRUE TRUE FALSE FALSE TRUE TRUE TRUE FALSE health-based standards FALSE FALSE
172 1975 FALSE TRUE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE TRUE suggests change to 99% source test "revise the rule to specify that a source test of the control
device is required under 9070(2)(h), but specify that it is an EPA Method 5 test with run time
capped at 2 hours or 31.8 dscf sampling volume, whichever is shorter. If that length of test run
does not generate enough particulate on the filter to be measurable, then the control device has
clearly been demonstrated to be performing its job."		 FALSE FALSE
173 1977 TRUE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE TRUE TRUE TRUE TRUE FALSE TRUE FALSE TRUE FALSE filterable and condensable 99.9%
all HAPs		 FALSE FALSE
174 1980 FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE   TRUE FALSE
175 1982 FALSE TRUE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE TRUE FALSE TRUE TRUE FALSE FALSE FALSE FALSE FALSE filterable and condensable FALSE FALSE
176 1984 FALSE FALSE TRUE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE replace 99.0% with an outlet grain loading standard of 0.005 gr/dscf.
Bag leak detection systems
Cr6 should be tested at baghouse outlet, not inlet.		 FALSE FALSE
177 1988 FALSE TRUE FALSE FALSE FALSE TRUE FALSE FALSE TRUE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE   FALSE FALSE
178 1989 FALSE TRUE FALSE FALSE FALSE TRUE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE suggests that DEQ not finalize art glass rules until the CAO regulation is complete.
Requested details on when DEQ / OHA would step in under 340-244-9090		 FALSE FALSE
179 1990 FALSE TRUE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE TRUE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE   FALSE FALSE
180 1996 FALSE TRUE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE TRUE TRUE TRUE FALSE TRUE FALSE TRUE FALSE FALSE don't allow Cr use in uncontrolled furnaces
reduce 10 tpy threshold
do fuel-fired furnaces really emit more than electrically fired (enough to merit use in criteria between Tier 1 / Tier 2)?
Use 0.35 ng/m3 as 24-hr limit for Cr6 (from Ontario)		 FALSE FALSE
181 1999 FALSE FALSE TRUE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE TRUE TRUE FALSE FALSE TRUE FALSE FALSE FALSE TRUE "thermal oxidizers"
no metals in uncontrolled furnaces
no chromium in any form should be allowed
require regular monitoring of emissions
revise ambient benchmarks		 FALSE FALSE
182 2004 FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE   TRUE FALSE
183 2005 FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE   TRUE FALSE
184 2006 FALSE TRUE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE TRUE TRUE TRUE FALSE TRUE TRUE TRUE TRUE TRUE TRUE 99.9% control efficiency
'close loopholes that allow emissions from uncontrolled furnaces'
include condensable particulate matter
consider fugitive emissions
et		 FALSE FALSE
185 2007 TRUE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE TRUE FALSE TRUE FALSE FALSE TRUE TRUE TRUE FALSE submitted copy of CRAG Law Center's comments during the temporary rule rulemaking. Points Katharine emphasized:
the rule is not health-based,
should not allow emissions from any uncontrolled furnaces, and
is too narrow (should apply statewide and to all metal HAPs emitted by these facilities).
Facilities should not be able to emit HAPs until DEQ issues the permit.
Public involvement in detailed decisions about design of the control device, source testing etc.
Baghouse leak detection devices.		 FALSE FALSE
186 2008 FALSE TRUE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE TRUE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE TRUE believes current definition of 'molten glass' and 'melt' need revision
don't include colored glass in definition of raw material		 FALSE FALSE
187 2358 TRUE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE TRUE FALSE TRUE TRUE TRUE TRUE FALSE FALSE FALSE 99.9% capture efficiency
all glass factories, not just CAGM
update health benchmarks		 FALSE FALSE
188 2359 FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE TRUE FALSE TRUE TRUE TRUE TRUE FALSE FALSE FALSE 99.9% capture efficiency
all glass factories, not just CAGM
update health benchmarks		 FALSE FALSE
189 2360 FALSE TRUE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE TRUE TRUE FALSE FALSE FALSE FALSE FALSE FALSE FALSE   FALSE FALSE
190 0 FALSE TRUE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE TRUE TRUE FALSE FALSE FALSE FALSE FALSE FALSE TRUE grain loading standard
cadmium volatilizes, it should be more regulated		 FALSE FALSE
191 2362 FALSE TRUE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE TRUE TRUE TRUE FALSE   FALSE FALSE
192 2361 FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE FALSE TRUE   FALSE FALSE

  A B C D E F G H
1 ID FirstName LastName EmailAddress Organization State Comment AdditionalDocument
2 1 Shawn Dolqan sdolan50@msn.com Sustainable Skys I read the monitoring for the control device installed annually but I do not read the monitoring of the visible emissions for the facilities. Is this rule subject to another rule that regulates visible emissions from the furnaces?
3 2 Melody Roth mroth97@msn.com OR I am a full-time health professional and part-time glass artist from Portland, OR. I work in a studio that is owned by a sole proprietor who provides classes, open studio time, equipment and that produces architectural glass pieces for sale to retailers across the U.S.

I have been interested in glass for many years, but it took a health scare experience for me to really begin creating with glass. I ground myself with focus on the color, the feel and the activity. It is a wonderful stress reducer and an opportunity to help by giving gifts of glass to support others during their difficult times. If the studio that I work in is unable to survive, I and many others will have no place to work.

I live in SE Portland, OR where Bullseye has been under scrutiny for emitting heavy metals from their exhaust stacks during glass production. In an industrial area where there is an intermodal train yard and diesel truck exhaust, a cement company and many other industries tucked in between neighborhoods, we would expect to see these metals. Uroboros, another Portland-based glass producer is in an industrial area between two freeways that carry a high load of truck traffic, is close to train tracks and a switching yard. Did you know that diesel exhaust produces chromium, manganese, mercury, selenium, arsenic, cadmium, lead, nickel and many more chemicals that are dangerous to our health?

The Governor of Oregon issued a Cease & Desist order twice to Bullseye without specifically identifying the source of emission. DEQ, Oregon Health Authority, EPA and our elected officials across the country seem to be pointing to the production at Bullseye as the definitive culprit. Fused art glass is limited in production in the US to 6 small manufacturers. Many are in industrial areas where they belong. However, this does make it challenging to identify the real sources of toxins to more accurately deal with the air quality issue.

We all want cleaner air. We all want a thriving economy and jobs. While Bullseye employs about 125 people, many thousands of people depend on their success worldwide to support their families and to pay taxes. They export about 35% of their production. They are a strong contributor to our community both in special projects and income. Bullseye attracts tourism revenue in many of our service sectors due to classes, tours and retail sales of products.

Bullseye is at present adding baghouses to their furnaces that will allow them to produce glass with 99.9% filtration rate. It is difficult to meet the deadlines for installation when nearly 80% of production had been shut down for a period of time, and at present are strictly limited, with limited impact on air quality.

As recent air monitoring data has shown, there has been little change in air quality since Bullseye has been limited in their production. That points to a stronger likelihood of other bigger contributors in the neighborhood. Please use objective scientific methods and data and consult with glass professionals for advice in making sound decisions when developing pollution control solutions for the glass art industry. Please be fair in application of rules to art glass manufacturers. Please consider the impact on jobs, tax revenues, and the limited win on pollution control when applying subjective and stringent rules on the glass industry with short notification in relationship to the environments they operate in. This effort has a huge financial impact and may well cause production to shift overseas. Sending production to China will not clean our air. It will not support the Oregonians who work in the art glass industry, nor any of those across our continent and the rest of the world. It will not provide any tax revenues.

Thank you for your time. Please consider using scientific data to have a real impact on our health and air quality, on art and our economy as changes are made in environmental regulations.

Sincerely,
Melody Roth
4 3 Susan Zarit slzarit@msn.com Mind and Soul Art Washington Mr. Westersund,

You had asked for people to comment about the fiscal impact of the permanent ruling on the glass industry. However, it has come to my attention that, perhaps, you may be disregarding those of us that are outside the State of Oregon. I do hope I am misinformed. As I had stated in my previous comment, Bullseye Glass Co. is not an island unto itself. It is an integral part of a much larger community...a community of thousands of people to be somewhat exact. Therefore, the decisions you, the DEQ and the EPA, make have a very far reaching effect. Therefore, Mr. Westersund, statements from people outside of Oregon are just as valid as those from within because Oregon is not an island unto itself either.

Now, having said all of that, I am the owner of Mind and Soul Art. I do not make money as I donate my art work to various charities for auctions and other fundraisers. Actually, I helped Eugene's Relay for Life. They have been the largest fundraiser's for that organization. Did you know that? I also help organizations within my own State of Washington: Mosaic, The Answer for Youth, My choices, local animal shelters, etc. I help nation/international organizations: American Foundation for Suicide Prevention, Walk in My Shoes, American Cancer Society, Autism Speaks, etc. My point in listing some these organizations is to point out that the financial impact is not only about making a living, supporting a family, supporting employees. It is all of those and more.

If you would like some examples of how "out-of-Staters" have a more direct fiscal impact in this matter, please allow me to give you a few examples. I was just recently in Portland for a 5-day education class at Bullseye. Now, I came down a day early, so that's 6 days at a hotel. I stayed at the Oxford Inn & Suites at Jantzen Beach because I thoroughly enjoyed my stay there from the last time I was in town for a Bullseye education class. While in town, I had to purchase food. I also needed to purchase other items I forgot to pack. like a good pair of sturdy shoes. Now, my family joined me during my stay. While I was in class, they were out sightseeing and spending tourism dollars. Now, I was not the only "out-of-Stater" at this class. Bullseye has a large selection of education classes. This draws in many people who spend money in your State.

Please consider all sides of this discussion when making your decision. We all want clean air. I don't want to see what happened to Spectrum Glass (Woodinville,WA) happen to Bullseye or any other glass company.
5 4 Leora Druckman leorad@aol.com Michigan *Why closing Bullseye could mean the death of an international industry.*

I make glass art, not for a living, but simply because I love it. But, I respect the many tens of thousands of people around the globe who depend on art glass for their living. This includes talented artists who make beautiful works of art by cutting, melting, shaping, casting and blowing this amazing material. It includes the galleries that sell these works of art; the many wholesale and retail businesses that sell glass tools and materials; the instructors who make their living teaching this ancient craft; the manufacturers of kilns, glass tools, enamels and other additives; and, of course, those who make art glass - the specialty glass required for almost all of today's modern glass crafts. Bullseye is, by far, the primary producer of art glass in the world. Without Bullseye, the art glass industry may cease to exist.

But how can a single producer in an industry this large have such a huge impact? Aren't there other colored glass producers in the world?

Yes, other companies produce colored glass, but only a few produce colored glass that can actually be used in creating art glass. There are a few producers of colored glass who make glass primarily used to create stained glass, but the glass they make can not be used when creating blown, kiln melted, lampworked or cast glass art. All of which combine multiple colors of glass under high heat and constitute the vast majority of glass art today.

There are only a few companies that make glass that can be used in this way. The largest and most experienced is Bullseye. Bullseye is the only major producer of a full color range of 90 COE (coefficient of expansion) glass. Most glass artists use either 90 COE or 96 COE glass. In fact, many restrict their studios to one or the other. Why? While two pieces of colored art glass may look exactly alike, when pieces of COE 90 and COE 96 are combined though heat, hours or even months of work can be destroyed. Glasses with different COEs pull away from each other in heat, causing cracks, warping, breaking and often, one big mess.

Bullseye created and perfected the manufacturing processes and technology for producing glass that is COE compatible across an entire product line. Before Bullseye did this, most of the magnificent glass art you see today would not have been possible. Because of their vast selection, rigorous 90 COE testing, high quality and excellent (and very generous) production of educational materials, most in the art glass business primarily stock and use Bullseye glass. The only other major competition comes from producers of COE 96 colored art glass. COE 96 glass is produced almost exclusively by two businesses, Spectrum glass (which just announced that they are going out of business) and Uroboros. The 90 COE and 96 COE glass manufacturers have provided healthy competition with each other in an industry with few competitors. The majority of the rest of the glass produced in the world is of uncertain and/or inconsistent COE and therefore unusable for making most art glass.

Usually, businesses do not rely primarily on one supplier for their business needs. Because of the difficulty of producing quality, COE compatible glass, the art glass industry is different. Bullseye is the only major producer of COE 90 compatible glass. Even if everyone in the art glass business attempted to switch to COE 96 glass, many businesses would go under due to the cost of switching all their glass and supporting materials. The art glass industry (like many businesses) is still recovering from the recent recession. Also, due to the death of Spectrum, it is unlikely that enough COE 96 glass in the needed range of colors will be available as soon as it would be needed. And, if Uroboros receives the same treatment as Bullseye, it may end up out of business like its sister Spectrum.

Please consider this unique and valuable international industry when making decisions involving Bullseye. Clearly, the company is showing a willingness to improve their impact on the environment as they have already started implementing filtering systems and have offered a plan for reduced emissions. Consider giving time for the company to adjust so it can continue to survive while making these important decisions. And, be very, very sure that the data you are using to make these decisions is accurate and actually leads to any conclusions you decide to make before you destroy a entire industry.
6 5 Bonnie Sparlin sparlin1059@charter.net Glass Artist Oregon Glass art has been an important part of culture for 100's of years. Please work with our glass companies to keep to find a solution so we can keep this art form alive.
7 6 Debbie Harary Debbieharary@gmail.com Harary Glass Studio. Owner Massachusetts As a working glass artist. I support myself and my family in this manner. The glass i ise is only american made to keep business within our own country viable. Bullseye glass company is my source for my medium. Without this i would no longer be able to create my art and sustain a lifestyle. Please consider the implications to all glass artists across the nation if our source for quality glass is not available
8 7 Janet Davis janetd010100@gmail.com LA Art glass manufacturers, plus their suppliers and customers, are important to the economy everywhere. Give them regulations to follow and time to meet them. We do not want to lose MORE glass manufacturing to China.
9 8 Bobbi Lolby Bobb1e@aol.com Montana I have been using stained glass and fusing glass now for 40 years. The joy I personly get from a finished item is so satisfying. Yes I believe we need to save our planet but make the goals of better filters or reducing what goes into the air liveable for the manufactures. They can complie but in what time frame? Putting people out of work does no good. From the plants that produce the glass right down to the little guy artists. I am retired and when possible I buy beautiful colored glass. And the products from China do not compare to what is made here in the USA. Please make sure this manufacturing if colored glass remains here in the USA.
10 9 Celie Mayer csmayer46@gmail.com Arkansas Fused glass is a family affair for 3 generations of my family. I would appreciate it if you would find a way to help control the pollution rather than shutting factories down. The loss of a USA manufacturer would probably cause the price of glass to rise forcing hobbiest out of their hobby.
11 10 MM Walter mm.newleaf@gmail.com from Ella Ross GA Good afternoon, I am writing to let you know how important my ability to obtain the beautiful glass of Bullseye is to my business. I have a small but nice fused glass business in Atlanta, GA. I do not know how my business can continue if the glass Bullseye produces is discontinued. I do believe we should not taint the air we breathe and sincerely hope all the parties involved will seek a reasonable and mutually beneficial solution so that I can continue in my business. Thanks, M
12 11 Donna Coffin redheron@aol.com Red Heron Handprints and Glass art Florida Glass art is very important to me. I am an artist and use this media to make a living and express my views on life around me. My work has been sold all around the world.
13 12 Carol Rasmussen Theglasscat@comcast.net Illinois I hope you will give the glass manufacturers time to comply with the new rules and restrictions. It would severely hurt my passion and livelihood if the manufacturing of colored art glass left the USA.
I have been creating glass art for the last 30 years.
14 13 Terri Johanson Terrijohanson@terrijohansonartglass.com Terri Johanson Art Glass, member of the Oregon Glass Guild Gorge Chapter Washington I am a glass artist in the Columbia River Gorge and although I currently live in Washington I was a long-time Oregon resident. I have experience with state rule-making and I understand the pressures exerted by the passions of diverse stakeholders. I urge that the process resist rules responding to hypothetical and/or "what if" ideas that may be presented; but rather that the standards be set to align with scientific evidence of toxicity levels and the rules should include procedures for continued monitoring and response processes.

I have extensive experience working with the 2 glass manufacturers in Portland. I know them to be responsible and responsive business people. In addition to their desire to produce the glass products that we use for our art and to make a reasonable profit, they are also people who want to be sure that they are keeping their employees, customers and communities safe and healthy. The rule-making that is currently in process MUST place equal responsibility on those who monitor and regulate the environmental impacts of manufacturing as on the manufacturers. The rules must require consistent and immediate communication with manufacturers to initiate a collaborative problem-solving process to address any real or perceived problem. Also reasonable time frames must be established for initiating or installing any equipment or process to resolve such problems. Without a positive and reasonable regulatory and monitoring process in place both industry (not just the glass industry) and the regulatory agencies that carry public responsibility for setting and monitoring the standards are vulnerable to media generated hysteria that can result in unreasoned and unfair responses. Industry cannot respond to issues that emerge beyond the existing requirements and/or without appropriate notification and problem-solving efforts between the regulators and the industry representatives. Public fear is a dynamic and powerful force which can cause undo harm to all concerned...to people who are, or imagine that they are, or may be, harmed; to regulators caught without appropriate standards grounded in real science; and to the industries impacted by the rules and the standards. The rules must set not only standards, but also a proactive ongoing process that supports a healthy environment for both the population and the industries impacted.

It is highly unlikely that the recent environmental uproar in Portland was due to emissions from just the glass manufactures but also to others in the complex industrial environment that exists in the urban area. Therefore whatever rules emerge from this effort must be applied across the industrial entities that may be using the chemicals involved in these rules...and that the rules govern responsible operations of both the industry and the regulatory agencies involved.

The rules must also include requirements for regular review and amendments of the rules to respond to ungoing research and analysis of the environmental impacts of issues governed by the rules. Science has consistently shown that what is known or thought to be known is often revealed to be erroneous and/or misguided in light of new research and emerging knowledge.

This rule-making effort is serious business. The impacts are far-reaching. There are significant economic impacts not just on the glass industry and on the art world and artists who depend on its products, but also on the employees of the industry, the retailers who serve the art community and the economy of the communities involved.

The health impacts of these rules must also be evaluated in light of grounded research of the potential for and/or existing demonstration of harm. Fear, supposition and imagined or media hyped harm should not influence or guide the rule making process.
15 15 Claudia Sportelli CLAUDY25189@HOTMAIL.IT ITALY I truly believe that if we leave that the art glass dissapear we are going just to lose all the purity in the world. Glass art is a way to bring people to their purity which got lost when we start to live as adult. Please, don't leave the world to became an unbright place... https://data.oregon.gov/views/54i7-gnrh/files/75b056f0-c939-4dff-875d-01895ebaa78d?filename=IMG_1321.JPG&content_type=image%2Fjpe
16 16 William Punch bill.punch@gmail.com Hobby Glassblower MI I was very lucky to have realized my life's dream when a glassblower set up shop in my small Michigan town (Williamston, Fireworks Glass). I have been taking classes ever since. Now, I cannot participate in my hobby due to the lack of glass. I had promised my son I would create glass for his wedding day on May 20th 2017 but that looks like it might not happen.

Please allow these good people to maintain their art. It is important to me, and many other people, not just because it is my hobby but because it brings so much beauty into the world.

-- Bill Punch
17 17 Karen Sharbo Karensharbo@me.com Hilltop Studio Texas This is like asking do we really need French Horrns. Glass isn't a new creation. It dates back thousands of years....maybe more. Colored glass is an intragal part of art just as each musical instrument, eg. French Horns, are used to complete a musical score. Right now, worldwide, thousands of artists are earning a livings using colored glass in hot, warm and cold applications to earnings a living. Colored glass is the heart and soul of everything from church windows to the space industry. It adorns skyscrapers, dinner tables and fashionistas. It is significant in religious symbols and prescription eye wear. Don't throw out the baby witht the bathroom water. Right now Oregon has the finest manufactured colored glass in the world. You have an industry that feeds your locals as well as many in the world. Take a global view, please
18 18 Karen Price karenjprice@gmail.com Missouri I am a glass artist who relies on fusible art glass made by Bullseye glass. I would not be able to continue as a glass artist if Bullseye was not able to continue making affordable fusible glass. Please know that glass artists like myself have invested a large amount of money in kilns, tools and supplies. Because my tools are specific to stained glass and warm glass, it would not be possible to reuse my tools in another capacity. Also, the companies which produce kilns and glass tools will also feel the repercussions of a negative decision. Please trust Bullseye Glass to produce fusible glass in a safe and responsible manner without adding additional restrictions that would decimate the industry.
19 19 Trisa Swerdlow trisa_s@yahoo.com Trisa Swerdlow Studio California I depend on American made Art Glass for my business. I am an environmentalist. I believe the glass companies can and will update their systems if you give them the time (and maybe some tax credit help) to do so. https://data.oregon.gov/views/54i7-gnrh/files/c38cd5d3-00d4-4338-951c-dd9323576057?filename=Trisa+Placer+Image.jpg&content_type=image%2Fjpeg
20 20 Peggy Orosz-Boslar Orosz789@gmail.com Boslar Jewelry Mi My husband and I are glass artists. My husband, a glass artist for over 40 years is a native of Portland OR and has worked exclusively with Bullseye Glass. I have been a glass artist for 20 years and also use Bullseye Glass exclusively.
We sell our work at art shows and galleries.
This is how we pay our bills.
The art shows bring visitors and create an influx of money into the various communities. The same with the galleries. These businesses have employees, pay local taxes and contribute to their communities.
If art glass is no longer produced, not only would my husband and I stand to lose our income, but the trickle down effect will cost jobs. No need for salespeople, no need for food servers, fewer places to eat out, less local taxes being paid, less money spent on family needs, school clothes, books, fewer parents involved in schools. The list goes on and on.
I live in Mi and have witnessed this many times through out the years. Local communities still have empty store fronts and children are left with fewer opportunities .
Please keep in mind that art glass is not just a hobby for people. It leads to the creation of jobs and yes, beauty.
Respectfully
Peggy Orosz-Bosla
21 22 Angela Cottingham angiecottingham@hotmail.com Texas It is important that we have glass suppliers like bullseye for many different reasons. I got into glass as a major hobby after my father unexpected passed away. It is a hobby that has since then allowed me to have an escape/stress reliever ever since. There are not many glass suppliers that are able to supply quality glass. Or this particular COE that is used for fusing. There are other glass suppliers but mostly for lampworking or for stained glass. Stained glass does not need a COE rating in order to use since you are not heating it. But bullseye provides quality glass with true stable colors that allow fusing to be possible. Fusing and other uses for Bullseye glass are very important for a lot of people, some their lively hoods relay on it. For me my sanity and relieving of stress relies on it. Without Art glass I do not know what I would do. Glass is beautiful and there are so many different thing you can do with it. Even your mistakes can be refired and turned beautiful.
22 23 Jan Simpson Janatkoru@Gmail.com Koru arts United kingdom Without the extremely specialist coloured glass produced by American companies such as Bullseye, Uroboros etc, myself, my employees and countless other UK based small businesses would be unable to continue in business. This would have a huge knock on effect to kiln suppliers, mold manufacturers, lighting companies, interior designers, religious institutions, who would be unable to sell their specialist products or obtain their architectural installations. The industry is much larger then is visible and many people have spent many years developing their scientific methods and techniques. Without the materials to continue this development a lot of families would have lost huge investment - in my case 17 years, in many other people's cases, a great deal more.
23 24 Barbara Domsky domskyglass@aol.com Domsky Glass nevada My husband and I have been professional glass workers since 1990. We have built, and continue to build our livelihood on the art we create from fused and hot glass. This is a craft we have passed down to a new generation of emerging glass artists. to illuminate the production of the medium we require would be to remove my very ability to support myself and my family. Please we beg that you consider those who require the very glass that we have built our lives upon. and consider the devastating results of elimination.
24 25 Charity Heroux Gotdichro@yahoo.com SOURGiRL glass art California Hello,

I have been working with glass for the last fifteen years. Wow, to see it in print like that is amazing. I feel so fortunate to have found the art form that makes me whole. From the minute I saw dichroic glass, I was hooked. I have been madly in love ever since.

I started out small, making things for myself and gifts for others, but with hard work and sacrifice (so much sacrifice) I have built a business and a name I am very proud of. I was born to make this art, and I cannot do it without companies like Bullseye and Uroboros.

Over the last several months the Art Glass industry has been under fire for emissions that the companies were unaware of. As soon as they found out they were emitting the toxins they voluntarily stopped production and manufacturing using any of the compounds in question until they are able to install filtration on their furnaces. The Office of the Governor and the DEQ have made it very difficult for these companies to continue working while they try to come up to code with the new and swiftly changing regulations, but Bullseye and Uroboros have worked very hard to comply. The Cease and Desist issued by the Governor all but crippled Bullseye, prohibiting them from raising any capital to meet the new filtration requirements. But still, they have persevered.
They believe in this industry. They believe that this art form must survive.

I believe Bullseye glass when they say they want to comply with the new standards. I have known and worked with these people for fifteen years, they are truly GOOD people. I believe they want to make their facility as clean as they possibly can. They just need your help to do it.

What I am asking for is your help to keep this American industry alive. There are no known facilities that produce the glass these companies make outside of the USA. This does not just affect fused glass but stained, flameworked, and blown glass as well. The agrument here is not against the new regs, it is against the timeline and restrictions in which the EPA and DEQ are requiring changes. Bullseye cannot stay afloat if they can't come up for air.

In order for these companies to survive they need time to install the new baghouses. They need time to raise money (by making glass to sell) to be able to afford these baghouses, as they are all family owned companies. America was built on the sweat of small companies like these.

So please, we need to help this amazing artform stay alive in the USA. Their closure will impact the glass art movement world wide if this industry does not survive. This is an international industry primarily made up of American companies supplying the entire world of Glass Artists. We cannot do this without you.


Help us keep American jobs in America!


Thank you so much for your time,

Charity Ann Heroux

SOURGiRL glass artÂ
25 26 Jill Mooney Jillmoon4655@gmail.com Texas Having recently retired I had assumed I would be having much more time to teach fused glass. Fused glass is an art and we all recognize the arts are not being taught in schools anymore so we must provide this service. Don't take this art away from the kids.
26 27 Carolyn Sturdivant cps47@bellsouth.net Old House Glass Works MS I am the artist/owner of the above stated business in the State of Mississippi. I am absolutely dependent of American glass manufacturers to keep my business viable. Bullseye Glass and other Washington State glass manufacturers are under Federal pressure that has and still may force other glass businesses to close their doors. If it continues, I will also be forced to close my business. The artists that work in glass are proud that our art work is solely produced in the United States and we strongly urge you to see that this does NOT change.
27 28 Kathleen White glassclass101@gmail.com Glass Class Art California i am a fused glass artist and teacher who relies on the availability of compatible glasses for my work. As I'm sure you are aware, Bullseye is part of a very small group of manufacturers of this comodity, and the loss of Bullseye or Uroboros would send this industry overseas, likely to China, where there is little oversight of the environment or the quality of the end product. Please do all that is possible to work with the industry to keep it in the US, and to make it as clean an operation as is possible. The history of American Art glass is long and proud, don't let it end here!
28 30 Robin Houck houck@consolidated.net Artsajoy! Texas I am an artist that works exclusively with fusible glass, making art glass cabochons for jewelry. I also have several jewelry makers that would be very disappointed if I was not able to supply them anymore!
29 31 Marina Vrouvlianis mvrouv@hotmail.com Mrs. MA while growing up, I always had a yearning to collect glass art! And one day I was blessed with the opportunity to actually make this kind of art! The joy and fulfillment have been overwhelming. I would be crushed it this was lost....
30 32 Gayle Bamber Clanbamber@aol.com California I have been a registered nurse for almost 50 years and am still working full time. This is a demanding and offer high pressure job. I started fusing glass seventeen or eighteen years ago and hove found the creative outlet to be invaluable to my mental health. In addition to giving me a creative outlet it has given me a positive connection with many of my patients, often bringing light, color and joy to their lives. My world and theirs would be much darker without this outlet.
31 33 Professor Sandra Feder sandy_feder@hotmail.com Sacramento City College California I am a college professor in California. I have been making art glass for 40 years. Colored glass is critical to what I make. These companies MUST continue to make colored glass for this art form to survive. The entire world uses colored glass created in Oregon. Don't stop production of colored glass in Oregon
32 34 Dawn LaBonte dawnl23644@gmail.com MA I am very concerned as a glass artist about the situation the glass manufacturing industry is in. I am certain they want to comply with any and all regulations put forth for safe operation. It can not be done overnight. If these companies are put out of business because they cannot comply within a reasonable time frame, my livelihood and passion will be denied to me. Please allow these companies to remain open and operating till the changes are made. My future as a glass artist will be in jeopardy if the American glass industry is put out of business.
33 35 Dennis Brady brady@debrady.com Victrian Art Glass BC I spent 35 years and raised my family with glass art. My 2 sons have taken over the business I created and expect to raise their family reliant on it. Loss of some glass makers will seriously harm us - BUT the bigger issue is one of environmental ethics. If a glass maker can nt make glass without distributing toxins into the environment, they should be shut down. No exception. No exemption. Clean it up or shut it down.
34 36 Carol Korfin Carol@glassgiraffe.com California These companies have been following all prescribed procedures and are being treated unfairly. Do not throw the baby out with the bath water. Give them a fair shake. They are willing to compromise,y
35 37 Rebecca Dunbar Dunbarrj@aol.com Illinois Art glass manufacturers are the foundation of numerous small businesses and craftmen alike. The long legacy of this industry in the U.S. in one that is world renowned. To put these factories, artsts and small businesses at risk combined with sending another American I did try to SE Asia is not what this country deserves. Please consider the depth of the impact of your decision. Please keep the glass manufacturing here in America.
36 38 Vicki McPhail vickimcphail55@gmail.com The Glass Diva Cambridge Ontario I would like to say that the demands being put on the glass manufacturers are making it very hard for the whole glass community. I make my living from my glass work. If I am unable to keep purchasing art glass then that means you have just put me out of business and taken away my livelyhood. Please consider the impact you will be having on not just the USA but world wide for those who buy American made art glass
37 39 James Wright vvrjim@yahoo.com Recycled Iron and Glass Calif We supplement our retirement making things from Bullseye glass. We have invested heavily in glass equipment in the last two years tp loose our glass supplier would kill our small Bis
38 40 Sherry Salito-Forsen Glassicsart@gmail.com Glassics CA I am a fused glass artist. I have been making my living creating glass art since 1976. I rely solely on the sheet glass that Bullseye Glass makes. If they were to go under, so would I. Please consider that there are thousands of artist who rely on their glass. Please allow them enough time to comply with requirements.
Thank you
Sherry Salito-Forsen
www.glassicsart.com
39 41 Carol Gault cgault@rof.net Aspen Light Imaging Colorado I am a strong advocate for the improvement of the quality of air and water. Bullseye glass had been asked to change their production to lessen their impact on the environment around them by Oregon. It is my understanding that they are trying to put these changes in place. So, I am confused as to why they are being penalized for not having it done in a time frame that is impossible to meet. They may to close down their production. Bullseye glass makes a product that is important to me and my company. I am new to glass fusing but have planned different products that I want to sell using Bullseye glass and other products they make. If their glass is no longer available, it will set me back many months as I try new glass for my product development. Also, I will have to source glass from out of the country at greater expense and time waiting for delivery. Also, ordering from overseas can cause more damage to the environment with shipping fuels expended and no guarantees that that company doesn't pollute their country with its production. Thank you for your consideration. Carol Gaul
40 43 Kim Smith abednego.smith@gmail.com Creative adventures caravan Canada I teach fused art glass to children through out the Edmonton,Alberta area. I teach close to 4000 children each year allowing them to explore the scientific and creative potential found in art glass. I exclusively use Bullseye art glass and have created this business on my own for the past six years. As a single mom this is the only income I have to raise my children. Glass art is my life.
41 45 Donna McClaren jenalib@me.com PA With regards to the current issues on plate glass makers - please do not forget that Nullseye and other manufacturers have already been working to resolve environmental impacts.

Please remember that shutting down American industries will continue to allow foreign companies who are not as concerned with environmental issues to fill those gaps - often with substandard product.

Please remember that layoffs due to closing those American manufacturers will affect your community by straining resources in an already difficult economy.

Please remember that it will affect those who may not live in Oregon as well. As a single mother, my artwork supplements my income just enough that I do not have to use public assistance programs. By closing down these manufacturers, you are now actively choosing to affect more than just Oregon.

Please remember these things when making your decision.
42 46 Dee Janssen dee@deejanssenglass.com Dee Janssen GlassWorks GA I'm a glass artist whose livelihood depends on there being materials to create my work. I sell wholesale and retail. While I agree that the glass companies - as well as all the other manufacturing companies in Portland - need to be in compliance, I do find it troublesome that you seem to be singling out only one specific industry. These are not major corporations with deep pockets, these are small companies who need time to purchase, install and test the needed filtering equipment.
43 47 Kristin Young bulblet@hotmail.com Short Fuse Glass Alaska the pressure you have put on Bullseye has already caused the one Alaska distributor of Bullseye glass to go out of business. Your cease and desist order has already therefore severely impacted my business as I no longer have a local supplier of bullseye glass. If you continue to prevent Bullseye from operating, in spite of their good faith efforts to come into compliance, you will put me out of business as well. I know a certain state governor whose opponent in the next election will receive a donation from me.
44 48 Kenneth Cowan ansilatoms@comcast.net Self-employed artist Washington By being reactive and draconian, you could easily sink a large part of the economy, and negatively impact thousands of people all over the country and World...even destroying their way of life and way of making a living. Please don't do that THINKING you're saving the planet. Actually do your research before making any sweeping declarations, and shutting down thriving and vital businesses
45 49 Jennifer Francis Mommyfrancis2004@yahoo.com AZ I am a glass artist in AZ I order on average 10k worth of glass from Bullseye Glass every year. I have invested so much of my life into my art and love making beautiful art projects that I sell at art shows all over the west. This is my life! Please consider the people who are affected and work with the glass producers and not against them . This is an ancient art form that has been around for thousands of years and it will be China I buy my glass from if the glass makers go out of business here in the US. I like things made in America �
46 50 Julie Sparks spjule@gmail.com Fused glass artist Alberta Canada As a glass artist, Bullseye has the best and safest product on the market. I have been to the area many times and believe there are many other industries that should be targeted for the same compliances. Artists like myself rely on their quality to produce a safe and superior project.
47 51 Clarann Bjers glasselegancems@gmail.com CA I am a glass artist in California. Im deeply concerned with the challenges and changes taking place in regards to colored glass production and availability. Not only will this effect my income but my passion. The availability of glass within the USA is crucial to this form of art. Why would the government not work with the companies, communities etc to come to a workable solution. I teach teens and children this art form. Many have said how they dont have many options in the art world...now what will the future look like to our upcoming generations if the red tape of bureaucracy force closures of our glass manufacturers? it will be a sad prospect to loose this art form because of the government s ruling......what happened to "of the people for the people".....a concept lost, freedom jeopardized for political gain.
48 52 Danny Beinsberger danny.beinsberger@telenet.be Glass artist Belgium If production of this specialtyglass stops, it will mean that the artists all over the world will loose the colours they need to create the art objects they wanted to make...what a loss of culture...
49 53 Tanya Veit info@aaeglass.com AAE Glass LLC Florida I have built a successful family glass art business in a relatively short amount of time. This I am proud of. What I am more proud of however is the amount of glass artists around the world I have been able to assist in building their businesses as well. Many have been able to leave their day jobs to pursue their passion as a glass artist. There are only a handful of colored glass manufacturers in the world and they are all in our beautiful United States, most being in your state of Oregon and the city of Portland. I truly hope that the decisions that are being made by the deq are fair, honest and based on facts, rather than guided by ulterior motives. There is a way to allow a business such as Bullseye glass to operate in a safe manner while improving air quality. Bullseye initiated immediate action to address the problem and has made it clear that they intend to be the most "clean" glass manufacturer in the world. Please allow them to conduct business under set and clear guidelines so we can assure the residents of Portland that their health is safe and we can continue to produce beautiful glass art that has been around for centuries. Thank you.
50 76 Vi Laux Dvkj@msn.com Craftsmanship Guild of Pittsburgh Pa Save American Glass, there are thousands of lives effected by the loose of glass. Not only in manufacturing of glass, thousands of artists and glass purchasers. Keeping the price and quality affordable is extremely important. So that we can afford to create and customers can afford to purchase.
51 89 Kate Lindley lindleykk@aol.com wa Glass fusing is important to me. As a veterinarian I spend my days in service to others and I center myself to prevent burn out in my studio.
52 103 TJ Miller urbanglowartglass@live.com Urban Glow Art Glass Alberta, Canada Although I personally do not YET use the COE of glass that Bullseye produces, I know and have interacted with many glass artists that rely on it. Decisions made with you are far-reaching, way beyond Oregon and the US. Please keep this in mind when formulating your opinions and final decisions. Thank you.
53 107 Cheryl Forsman irishhick@gmail.com American Citizen Washington Leave them alone. They supply beauty, and we need more of that.
54 108 Marla Montgomery mmngrace@msn.com Kiss My Glass Artist Florida I move to Mt. Dora Florida when I retired three years ago, having lived in Portland Oregon for 47yrs. I was self-employed and worked in my Day Spa 6 day a wk. 10-12hr. days. I told myself that one day, when I could retire I wanted to work with glass as a Kiln formed glass artist. Well I finally got my chance, spent lots of money learning practicing and now that I'm finally able to do art, my love of glass is Bulls eye Glass, from my home state. It is the very best glass, I love knowing that the money I spend on my glass goes to such an incredible company, both ethically, creatively and the way they treat their employees. It is very important to me that Bullseye is able to continue to not only do business in my beautiful Portland, but to thrive. When they thrive, their employees thrive and I get to also thrive. It is a wonderful company. I researched all my products thoroughly when I had my spa, for these very same reasons and that is why I chose Bullseye. Please do what you can to allow them to continue to do their work and their craft. Thank you. Marla Montgomer
55 113 Theresa Bour t@bour.org Ar Please help us save our American made glass makers. I am sure there is enough of a demand that China will start making it. Do we want that?
56 114 Gayle Potter pottergayle305@gmail.com Arizona I am writing to express my concern about the recent restrictions on the manufacturing of art glass, specifically Bullseye Glass. The availability of their glass is crucial to many artists in Arizona.
57 115 Gayle Potter pottergayle305@gmail.com Arizona I am deeply concerned about the possibility of losing Bullseye glass. Many artists in Sedona are dependent on glass in order to produce a quality product.
58 116 Lenore Hemingway lenhem@msn.com Mosaic Madness ARIZONA I want to emphasize the criticality of the impact to the small glass artist, as well as the overall glass community of suppliers and consumers who rely on being able to purchase glass at a reasonable cost. Significantly higher costs to the consumer will put many small businesses out of business very quickly--not what our nation needs right now.
59 117 Beth Gershovich bbgartistry@gmail.com BBG Artistry NE Please don't shut down the Art Glass Suppliers. The medium of Art Glass is vast, and done with these techniques: blown, cast, fused, mosaic and Lampwork (done over a torch. You already forced a large and wonderful glass supplier, Spectrum, which many of us glass artists used religiously.
Many people around the world purchase glass art in the various mediums I listed above. Please work with the glass suppliers instead of shutting down the entire medium of Art Glass.
Sincerely,
Beth Gershovich
Glass Artist
60 119 Gloria Fuller rgfuller@tds.net Lancaster High School WI Glass is extremely important in the art classroom. I teach over 300 students a year, times 26 years of art education, so far. We use glass constantly for clay projects, etching, fusing & stained glass. I can't begin to think about inspiring our youth without it.
61 120 Jack DeNina jjack9485@yahoo.com Fused glass artist Texas keep our air clean !!
62 121 Glenda Melton gsm32423@live.com Fl I buy the majority of my glass from bullseye. Many small business glass owners depend upon the glass manufactures for the supplies we need to make our products. to us american made still means something
63 155 Marina Vrouvlianis mvrouv@hotmail.com Mrs. MA while growing up, I always had a yearning to collect glass art! And one day I was blessed with the opportunity to actually make this kind of art! The joy and fulfillment have been overwhelming. I would be crushed it this was lost....
64 194 Jessica Applegate applegatebrown@msn.com EPAC/Concerned citizen and neighbor of Bullseye OR Regard for the public health should be utmost in the decision making process and expedite emission controls installation. My family has been subjected to unfiltered emissions from Bullseye for decades. Knowing what we know now, it would seem the most protective of public health to consider the following when making these rules permanent. 1) Close loopholes that would allow for emissions of heavy metals from uncontrolled furnaces;
2) Apply state-wide;
3) Apply to all glass manufacturers;
4) Apply to all heavy metals;
5) Would ensure public notice and comment instead of locking the public out of DEQ decisions
65 199 Barbara Peters barbaraannpeters@gmail.com Oregon As a resident of Portland who has suffered long-term exposure to toxic wood smoke and other air pollutants, I’m appalled that the art glass industry has been given a pass for so many years to poison people who live and work in our community. No one should be involuntarily exposed to known carcinogens and air toxics. It’s your responsibility to act now to close every loophole that might allow continued uncontrolled heavy metal emissions. All furnaces of every glass manufacturer along with any industry that produces heavy metals should be controlled or shut down. Health-based regulations must be enacted on a statewide basis for ALL known sources of air pollution.
66 200 Barbara Peters barbaraannpeters@gmail.com Oregon As a resident of Portland who has suffered long-term exposure to toxic wood smoke and other air pollutants, I’m appalled that the art glass industry has been given a pass for so many years. No one should be involuntarily exposed to known carcinogens and air toxics. It’s your responsibility to act now to close every loophole that might allow continued uncontrolled heavy metal emissions. All furnaces of every glass manufacturer along with any industry that produces heavy metals should be controlled or shut down. Health-based regulations must be enacted on a statewide basis for ALL known sources of air pollution.
67 204 April St. John aprilstjohn@gmail.com Oregon I live 5 blocks from bullseye glass with my husband and 3 young children (3months, 3 years and 6 years). This is our home and we deserve to breath clean air. The DEQ has failed to keep us safe in the past please don't fail us again. Public health should always come before private profits!
68 205 James Ofsink james@ofsink.today Oregon As a resident of SE Portland my chief concern is for the health of my neighbors, friends, family, and community members. Like many Oregonians I was disturbed to learn about the high levels of heavy metals and other toxins discovered recently in our air. The primary goal of art glass regulation (and other industrial manufacturing regulation) should be to protect the wellbeing of workers, neighbors, and the environment around industrial sites. Resultantly I urge you to develop strong regulations with health-based standards to keep our neighborhood safe. These regulations should be mandatory and apply statewide to large and small manufacturers to make it possible for all Oregonians to breathe clean air. Additionally the health based standards should cover all heavy metals and hazardous air pollutants and take into account cumulative/interactive effects instead of pretending that people are exposed to a single pollutant in isolation. Finally, there must be sufficient monitoring and enforcement of the regulations. As we have seen, rules with largely self-monitoring and inadequate enforcement is not enough to stop toxic pollution. Monitoring should be conducted strategically at undisclosed times and should include fenceline monitoring as well as more general assessment. The air we breathe, the water we drink, and the soil that enriches our gardens belongs to all of us and not just industry. I urge you in the development of these rules to consider the levels of hexavalent chromium, cobalt, mercury, and lead you would be comfortable with your children breathing, consuming, and playing in. Thank you for doing everything you can to keep our community healthy and safe
69 206 Elizabeth Breitenstein Brei7588@pacificu.edu Oregon As a life long Oregon resident I strongly support strong regulations to protect the health of all Oregonians. I hope to see DEQ close loopholes that would allow for emissions of all heavy metals. I think these rules should apply to all glass manufacturers not just those that produce 10 tons per.
It is critical that we have true HEALTH BASED STANDARDS when determining concentration levels that are protective of human health
70 209 Judith Kiriazis judy@heartofstonestudio.com Arizona My name is Judith Kiriazis. Please see my attached testimony. Please contact me at judy@heartofstonestudio.com if you do not receive it. Thank you. https://data.oregon.gov/views/54i7-gnrh/files/6a32a9ac-5f03-4f39-9e5d-bbd21b7ca948?filename=testimony+to+State+of+Oregon.txt&content_type=text%2Fplain
71 212 Brittney Bieberich brittneymathews@gmail.com Oregon Loopholes that would allow for emissions of heavy metals from uncontrolled furnaces need to be closed. This needs to be applied state-wide to all glass manufacturers. Additionally, this needs to be applied to all heavy metals by September 1st.
The clean up process needs to be open to the public and open for public comment.
We are tired of getting poisoned and need to hold DEQ accountable.
72 215 Paulette Marchand yellowgardenhouse@yahoo.com SE portland resident please close the loop holes. Put peoples health first. Filter all furnaces .we will never have all the the answers regarding past exposure, but lets go forward knowing our neighborhood parks, schools ,homes are safe places to breath. we have no other choice.
73 221 Judith Kiriazis judy@heartofstonestudio.com Arizona My name is Judith Kiriazis. Please see my attached testimony. Please contact me at judy@heartofstonestudio.com if you do not receive it. Thank you.

[text pasted in below]
Testimony of Judith Kiriazis on Glass Art Rulemaking 2016

My name is Judith Kiriazis and I am a PhD in biology as well as a glass artist. In the past, I've run an environmental organization called Lake Michigan Federation in Chicago, a citizens environmental group charged with protecting the water quality in the 68,000 square-mile drainage basin of Lake Michigan. As you know, this is one of the Great Lakes, so I have extensive experience working on water quality issues on the local, city, state, interstate, federal, and international levels.

I know from experience that the most effective way to effect change to protect the environment is to work in concert with government agencies, businesses, citizens groups, and individuals. In my tenure as an environmental activist, I have specialized in fostering communication and cooperation among these sometimes varying interests. It might not be the quickest way to get things done, but it is the most long-lasting.

Therefore, I understand the quandary involved in developing a resolution to the issue of air pollution in city areas caused by industrial uses. You have to balance the health needs and concerns of residents with the economic viability of the industries involved.

I have personally dealt with some of the biggest polluters in the United States-- companies who dumped tons and tons of PCBs into Waukegan Harbor, companies who nearly killed an entire river in Northwest Indiana with outflows from steel mills and oil refineries, and midnight dumpers who poisoned waterways with toxic waste from 55-gallon drums. I worked hand-in-hand with the EPA, state agencies, and a consortium of concerned steelworkers and local citizens to clean up and protect as much as we could of these areas. I have personally snuck into steel mill property to photograph the headwaters of a river to prove that, contrary to the mill's assertion, the river did NOT originate in one of its outfall pipes.

So I feel qualified to say that I know polluters. I know what a company looks like when it is trying to skirt the law, or trying to weaken regulations to suit its bottom line. I know what a company looks like who will sap the resources of an area and leave it devastated and unusable, just to line its pockets with cash.

I'm here to tell you today, that Bullseye Glass is not one of those companies. I've been a Bullseye customer for more than 20 years. I've been to the Portland production site several times, including a tour of the facility. I've met many of the staff and employees, and I've taken classes at this facility.

I think that it's fair to say that this whole problem with emissions arose, not because Bullseye was attempting to defy or skirt regulations, but because the regulations were set up to catch big fish (big production), and the holes in the net were simply too big for smaller companies like Bullseye to get noticed.

Unfortunately, the citizen uproar sounded on incomplete evidence and shaky science. While it is absolutely important for the citizens of Portland to know that their air quality is being protected, a knee-jerk reaction that might drive Bullseye and other glass companies out of business is both unfair and unprofessional.

It is my understanding that Bullseye has done its utmost to come into compliance, and as a long-term customer, I know that these continuing improvements are going to be costly, so I am prepared for increased glass prices because I know that these changes are for the best. I am guessing that most other Bullseye customers feel similarly. What is not acceptable is an unreasonable compliance schedule or vindictive lawsuits that will drive a good company out of business, rob dozens of dedicated employees of their jobs, and leave tens of thousands of glass users around the world without a source of quality art glass.

I recently attended a conference where I learned about the versatility and environmental aspects of glass: It is the one material in common use that can be infinitely recycled. Researchers have developed glass with enormous strength; paper-thin glass that can be folded; and glass with uses we have yet to dream of. And all of this glass, as well as all of the glass that was ever made, can be recycled for new uses. I am confident that in the near future, glass will replace plastic in many applications, freeing our oceans and landfills from the glut of plastic waste.

As such, I urge you to think long-term and expand your stance in order to work in partnership with glass companies such as Bullseye. They are the good guys, but they need your guidance. I urge you to dialogue with them to set long-term goals: They need to be encouraged to develop efficient and safe production methods that are both cost-effective and environmentally responsible. A clean, successful company in your state that benefits many people on many levels is something you can be proud of, as opposed to a company needlessly driven out of business. Please help glass companies achieve the former.

Thank you for your consideration.		 https://data.oregon.gov/views/54i7-gnrh/files/eef647cd-1d66-42ac-af8a-fc9fd75ece1e?filename=testimony+to+State+of+Oregon.txt&content_type=text%2Fplain
74 224 Barbara Peters barbaraannpeters@gmail.com Oregon As a resident of Portland who has suffered long-term exposure to toxic wood smoke and other air pollutants, I'm appalled that the art glass industry has been given a pass for so many years. No one should be involuntarily exposed to known carcinogens and air toxics. It's your responsibility to close every loophole that might allow continued uncontrolled heavy metal emissions. All furnaces of every glass manufacturer along with any industry that produces heavy metals should be controlled or shut down based upon health-based regulations enacted on a statewide basis.
75 229 Vivian Christensen vivianchristensen@earthlink.net Oregon As you know, residents of Portland have been breathing unhealthy air for many years. The EPA estimates that Portland’s air is capable of causing between 26 and 86 extra cancers per 1 million people. In six census tracts near the city center, this cancer rate is worse than 99 percent of the country. As you are aware, Oregon lags behind California and Washington in enforceable air quality standards. I urge the DEQ to implement art glass regulations that will result in the state meeting meaningful air quality benchmarks. I also urge the DEQ to require all glass manufacturers to demonstrate on an annual basis that they are using the best available technology to limit toxic emissions from their facilities. Residents living and working near these facilities should not have to shoulder the burden of poor environmental regulatory oversight. It is also imperative that the DEQ foster transparency of the amount and types of toxins that industry is emitting throughout Oregon. In order to win back the public’s trust, the DEQ must enable the public to view pollution permits as well as the pollution regulations that facilities are required to implement. I urge the Oregon DEQ to become a national leader in creating meaningful pollution regulations aimed at protecting human health and the environment.
76 230 Joe Westersund westersund.joe@deq.state.or.us DEQ Oregon test comment
77 231 Alicia Cohen cohenalicia@gmail.com Oregon I have lived in Portland most of my adult life and since 2002 I have been in contact with the DEQ trying to figure out what was going on with the air in Portland. At first I could *smell* that something was awry. I called the DEQ many times over the years desperate for answers. The smells were awful, toxic and different all through the city. The DEQ never once gave me any substantive information about air toxics. They would tell me they had no idea what could possibly be causing that awful odor! They would even come out and sniff the air in my neighborhood a say to me personally "I don't smell anything." So much for science. I was baffled by their seeming concern but utter lack of knowledge about the airshed. It was only years later that the USA Today article "The Smokestack Effect" came out that I understoond why the air in Portland was so foul smelling. Portland air stinks because it is some of the dirtiest air in the United States. My neighborhood in Northeast ranked in the bottom 11% for toxic air from sitting Title V factories. I was about to move to SE 24th and Division and the air there ranked in the bottom 2%. Then, all these years later, the Forest Service came out with even more detailed findings: there is cadmium and arsenic in the air at incedibly dangerous levels and it comes from Bullseye. This arsenic and cadmium doesn't even facotr in the measurements that give the same airshed the bottom 2% rankings for Title V polluters nor all the dirty diesel we are breathing due to Oregon's weak diesel laws. We get bad air coming and going in Portland and in the neighborhood around Bullseye is like a war zone. Journalists have revealed documents that show the DEQ even encouraged Bullseye to skirt EPA health measurements and guidelines. Now the governor of Oregon has demanded that the DEQ and Bullseye start following EPA rules and write permits in adherence to health standards. Finally, some sanity will guide the DEQ's permit rules. Sure, I love colored glass as much as anybody. I love art. But if we can send a man to the moon, then we can make colored glass that does not poison children. There is no economic reason to permit Bullseye to emit any toxics into our airshed. The cost in terms of lost of health for the community vastly outweighs any economic benefit that comes from jobs and tax revenue. We, the neighbors and employees of Bullseye have already paid in pain and suffering and death for the long years that Bullseye has emitted toxics into the airshed without limit, We demand the highest, strongest emssions standards for Bullseye. The citizens of Portland will no longer tolerate the DEQ's weak enforcement and permits. And we don't want the air to get "better" we want Oregon to begin to set the gold standard for urban air quality nation-wide.
78 235 Alicia Cohen cohenalicia@gmail.com Oregon I have lived in Portland most of my adult life and since 2002 I have been in contact with the DEQ trying to figure out what was going on with the air in Portland. At first I could *smell* that something was awry. I called the DEQ many times over the years desperate for answers. The smells were awful, toxic and different all through the city. The DEQ never once gave me any substantive information about air toxics. They would tell me they had no idea what could possibly be causing that awful odor! They would even come out and sniff the air in my neighborhood a say to me personally "I don't smell anything." So much for science. I was baffled by their seeming concern but utter lack of knowledge about the airshed. It was only years later that the USA Today article "The Smokestack Effect" came out that I understoond why the air in Portland was so foul smelling. Portland air stinks because it is some of the dirtiest air in the United States. My neighborhood in Northeast ranked in the bottom 11% for toxic air from sitting Title V factories. I was about to move to SE 24th and Division and the air there ranked in the bottom 2%. Then, all these years later, the Forest Service came out with even more detailed findings: there is cadmium and arsenic in the air at incedibly dangerous levels and it comes from Bullseye. This arsenic and cadmium doesn't even facotr in the measurements that give the same airshed the bottom 2% rankings for Title V polluters nor all the dirty diesel we are breathing due to Oregon's weak diesel laws. We get bad air coming and going in Portland and in the neighborhood around Bullseye is like a war zone. Journalists have revealed documents that show the DEQ even encouraged Bullseye to skirt EPA health measurements and guidelines. Now the governor of Oregon has demanded that the DEQ and Bullseye start following EPA rules and write permits in adherence to health standards. Finally, some sanity will guide the DEQ's permit rules. Sure, I love colored glass as much as anybody. I love art. But if we can send a man to the moon, then we can make colored glass that does not poison children. There is no economic reason to permit Bullseye to emit any toxics into our airshed. The cost in terms of lost of health for the community vastly outweighs any economic benefit that comes from jobs and tax revenue. We, the neighbors and employees of Bullseye have already paid in pain and suffering and death for the long years that Bullseye has emitted toxics into the airshed without limit, We demand the highest, strongest emssions standards for Bullseye. The citizens of Portland will no longer tolerate the DEQ's weak enforcement and permits. And we don't want the air to get "better" we want Oregon to begin to set the gold standard for urban air quality nation-wide.
 https://data.oregon.gov/views/54i7-gnrh/files/295df75f-fc04-4416-806d-008387a1be67?filename=I+have+lived+in+Portland+most+of+my+adult+life+and+since+2002+I+have+been+in+contact+with+the%C2%A0DEQ%C2%A0trying+to+figure+out+what+was+going+on+with+the+air+in+Portland.docx&content_type=application%2Fvnd.openxmlformats-officedocument.wordprocessingml.document
79 236 Alicia Cohen cohenalicia@gmail.com Oregon I have lived in Portland most of my adult life and since 2002 I have been in contact with the DEQ trying to figure out what was going on with the air in Portland. At first I could *smell* that something was awry. I called the DEQ many times over the years desperate for answers. The smells were awful, toxic and different all through the city. The DEQ never once gave me any substantive information about air toxics. They would tell me they had no idea what could possibly be causing that awful odor! They would even come out and sniff the air in my neighborhood a say to me personally "I don't smell anything." So much for science. I was baffled by their seeming concern but utter lack of knowledge about the airshed. It was only years later that the USA Today article "The Smokestack Effect" came out that I understoond why the air in Portland was so foul smelling. Portland air stinks because it is some of the dirtiest air in the United States. My neighborhood in Northeast ranked in the bottom 11% for toxic air from sitting Title V factories. I was about to move to SE 24th and Division and the air there ranked in the bottom 2%. Then, all these years later, the Forest Service came out with even more detailed findings: there is cadmium and arsenic in the air at incedibly dangerous levels and it comes from Bullseye. This arsenic and cadmium doesn't even facotr in the measurements that give the same airshed the bottom 2% rankings for Title V polluters nor all the dirty diesel we are breathing due to Oregon's weak diesel laws. We get bad air coming and going in Portland and in the neighborhood around Bullseye is like a war zone. Journalists have revealed documents that show the DEQ even encouraged Bullseye to skirt EPA health measurements and guidelines. Now the governor of Oregon has demanded that the DEQ and Bullseye start following EPA rules and write permits in adherence to health standards. Finally, some sanity will guide the DEQ's permit rules. Sure, I love colored glass as much as anybody. I love art. But if we can send a man to the moon, then we can make colored glass that does not poison children. There is no economic reason to permit Bullseye to emit any toxics into our airshed. The cost in terms of lost of health for the community vastly outweighs any economic benefit that comes from jobs and tax revenue. We, the neighbors and employees of Bullseye have already paid in pain and suffering and death for the long years that Bullseye has emitted toxics into the airshed without limit, We demand the highest, strongest emssions standards for Bullseye. The citizens of Portland will no longer tolerate the DEQ's weak enforcement and permits. And we don't want the air to get "better" we want Oregon to begin to set the gold standard for urban air quality nation-wide. https://data.oregon.gov/views/54i7-gnrh/files/36a137e5-9dd4-4126-9f4c-a676c17355d7?filename=I+have+lived+in+Portland+most+of+my+adult+life+and+since+2002+I+have+been+in+contact+with+the%C2%A0DEQ%C2%A0trying+to+figure+out+what+was+going+on+with+the+air+in+Portland.docx&content_type=d2l%2Funknowntype
80 237 Barbara Peters barbaraAnnPeters@gmail.com Oregon [Submitted by Joe Westersund on behalf of Barbara Peters]
As a resident of Portland who has suffered long-term exposure to toxic wood smoke and other air pollutants, I’m appalled that the art glass industry has been given a pass for so many years. No one should be involuntarily exposed to known carcinogens and air toxics. It’s your responsibility to act now to close every loophole that might allow continued uncontrolled heavy metal emissions. All furnaces of every glass manufacturer along with any industry that produces heavy metals should be controlled or shut down based on health-based regulations enacted on a statewide basis.
81 238 Shawn Ingersoll shawnwingersoll@gmail.com [emailed to Joe Westersund by Shawn Ingersoll on 7/21/2016]

Received an error message when trying to submit, my comment is below:

- Health based regulation that incorporate the Precautionary Principle.
- Clause to allow for the future addition of other materials from glass manufacturing if found to exceed either short and/or long term health standards for air shed quality.
- Choose limits based on those most at risk, not normal average healthy adults (i.e., children, elders, and those with medical issues). Many of the facilities are near schools and parks, so there are large populations of children that cannot tolerate the same level of pollution as a full grown adult.
- Assume the EPA view that all Cr III converts to Cr 6 in glass production.
- Require filters that are rated to remove 99.9% of emissions.
- Require all furnaces to have said filters if they use HAP.
- Create facility limits, not furnace limits. If you limit based on furnaces, there is the likelihood that the accumulative pollution for all furnaces would be above health based standards.
- Heavy fines for violations and a plan for repeat offenders. The ability to shut facility down if it poses an immediate risk to the public and environment.
- Incorporate full health and environmental costs into account. Both long and short term.
- Health before profits. The cost of pollution will always outweigh any benefits a facility brings to the economy. We can get new jobs, develop new ways to make glass, yet we can't prevent the damage that has already been done to our bodies. Damage that may take years to surface.
- Ensure their coldshops (where they cut the glass) and resulting wastewater are safe. Incorporate direction/regulation/fines to ensure their coldshops do not result in environmental damage (i.e., fine glass particulates making their way into the water system).
- Incorporate direction/regulation/fines related to the fine glass particulates that have the ability to become airborne, as well as the glass fragments that litter the perimeter of their facility (particularly near their scrap collection bins).
- Incorporate an accumulative pollution approach to permitting (multiple industrial polluters in a small vicinity). There may be health based limits, but if two polluters are hitting both of their limits in a small geographical area, it will double the health/environmental impact of said pollutant and cause damage to people and the environment. In addition look at how pollution interacts, for example there was a study that showed higher rates of autism when a population was exposed to both styrene and chromium.
- Do not delay implementation beyond the defined timeline.
- Continue to involve the public in the process with transparent decision making and public input.
- Continue to monitor the air quality near these facilities.
Beyond just these rules:
- A public notification system for the permitting process (new and renewals). DEQ has a responsibility to ensure homeowners, businesses, and schools are aware of the pollution that is being permitted in their area. Currently there is no system in place that provides transparent and easy to access information for the public. We have a right to know who permits what, and we have a right to as a community, refuse to allow a polluter into our neighborhoods if they cannot do business responsibly or if their business puts the public or environment at unnecessary risk. We need in-person mailers to all homes, businesses, and schools within a determined radius of the facility (i.e., a mile) with information on the permit, other polluters nearby (so we can have an understanding of the addition of pollution being made to the area). In addition, an accessible online mapping system that identifies all facilities, all hazardous materials used/on site, the health effects (long and short) on the specific materials, permitting allowances for their facility, when a permit ends/begins, and air/water/soil monitoring data etc.
- DEQ needs to start collecting all info on all hazardous materials used on all sites, not just a lump sum of pollution.
- DEQ needs to advocate for funding. Show the public why you need it and what it is for. The DEQ is severely underfunded.
- DEQ should have informed the public of the high levels of cadmium when they first knew. DEQ needs to start notifying the public immediately to instances such as these.
- DEQ needs source and ambient air monitoring. The ability for DEQ to do source testing needs to be included in all permits moving forward.
- DEQ needs to do statewide moss sampling.
- Realize that for all the out of state glass artists that Bullseye has recruited to contribute their comments, their numbers pale in comparison to the affected families around these facilities. Be aware that many working families that are impacted by this pollution do not have the luxury to comment on these rules; be it time, access to the internet, or even being aware of this issue.
Our air, water, and soil is community based. We all need it to be clean and healthy for generations to come. A facility does not have the right to put others at risk simply by paying a small fee and all the while the public is none the wiser. Bullseye is the catalyst. It is my sincere hope that DEQ does not stop here because the public sure won't.
Thank you,
Shawn		 https://data.oregon.gov/views/54i7-gnrh/files/3f4a3def-eb55-4f66-8e3f-a8523344af5f?filename=E%3A%5CJoe%27s+Documents%5CAir+Toxics+Rulemaking+2016%5Ctemp+to+permanent%5C4%29+public+comments%5Cerror+reports%5Ccomments+that+need+to+be+manually+included%5CSha
82 239 Shawn Ingersoll shawnwingersoll@gmail.com "[posted by Joe Westersund for Shawn Ingersoll]
- Health based regulation that incorporate the Precautionary Principle.
- Clause to allow for the future addition of other materials from glass manufacturing if found to exceed either short and/or long term health standards for air shed quality.
- Choose limits based on those most at risk, not normal average healthy adults (i.e., children, elders, and those with medical issues). Many of the facilities are near schools and parks, so there are large populations of children that cannot tolerate the same level of pollution as a full grown adult.
- Assume the EPA view that all Cr III converts to Cr 6 in glass production.
- Require filters that are rated to remove 99.9% of emissions.
- Require all furnaces to have said filters if they use HAP.
- Create facility limits, not furnace limits. If you limit based on furnaces, their is the likelihood that the accumulative pollution for all furnaces would be above health based standards.
- Heavy fines for violations and a plan for repeat offenders. The ability to shut facility down if it poses an immediate risk to the public and environment.
- Incorporate full health and environmental costs into account. Both long and short term.
- Health before profits. The cost of pollution will always outweigh any benefits a facility brings to the economy. We can get new jobs, develop new ways to make glass, yet we can't prevent the damage that has already been done to our bodies. Damage that may take years to surface.
- Ensure their coldshops (where they cut the glass) and resulting wastewater are safe. Incorporate direction/regulation/fines to ensure their coldshops do not result in environmental damage (i.e., fine glass particulates making their way into the water system).
- Incorporate direction/regulation/fines related to the fine glass particulates that have the ability to become airborne, as well as the glass fragments that litter the perimeter of their facility (particularly near their scrap collection bins).
- Incorporate an accumulative pollution approach to permitting (multiple industrial polluters in a small vicinity). There may be health based limits, but if two polluters are hitting both of their limits in a small geographical area, it will double the health/environmental impact of said pollutant and cause damage to people and the environment. In addition look at how pollution interacts, for example there was a study that showed higher rates of autism when a population was exposed to both styrene and chromium.
- Do not delay implementation beyond the defined timeline.
- Continue to involve the public in the process with transparent decision making and public input.
- Continue to monitor the air quality near these facilities.
Beyond just these rules:
- A public notification system for the permitting process (new and renewals). DEQ has a responsibility to ensure homeowners, businesses, and schools are aware of the pollution that is being permitted in their area. Currently there is no system in place that provides transparent and easy to access information for the public. We have a right to know who permits what, and we have a right to as a community, refuse to allow a polluter into our neighborhoods if they cannot do business responsibly or if their business puts the public or environment at unnecessary risk. We need in-person mailers to all homes, businesses, and schools within a determined radius of the facility (i.e., a mile) with information on the permit, other polluters nearby (so we can have an understanding of the addition of pollution being made to the area). In addition, an accessible online mapping system that identifies all facilities, all hazardous materials used/on site, the health effects (long and short) on the specific materials, permitting allowances for their facility, when a permit ends/begins, and air/water/soil monitoring data etc.... [see attachment for full text]"		 https://data.oregon.gov/views/54i7-gnrh/files/f74dd231-dc70-46c9-a04f-c0905fb0ae51?filename=E%3A%5CJoe%27s+Documents%5CAir+Toxics+Rulemaking+2016%5Ctemp+to+permanent%5C4%29+public+comments%5Cerror+reports%5Ccomments+that+need+to+be+manually+included%5CSha
83 240 Kevin Kaufman kevinkaufman@comcast.net Oregon Oregon can no longer afford to ignore the negative health impacts glass making facilities are having on the surrounding communities. Health-based regulations must be put in place that favor human health over profit. Relying on the Clean Air Act’s Emissions Standards for Hazard Air Pollutants (NESHAPS), which regulates point sources of air toxics (including heavy metals) only when a single industrial source has total annual emissions exceeding 10 tons of each air toxin (or 25 tons per year of aggregated toxic emissions) from a single source does not protect the public from the harmful effects of toxins that are emitted into neighboring communities from industrial polluters. I urge the DEQ to close these loopholes.
84 241 Shawn Ingersoll shawnwingersoll@gmail.com [posted by Joe Westersund for Shawn Ingersoll]
...- DEQ needs to start collecting all info on all hazardous materials used on all sites, not just a lump sum of

pollution.
- DEQ needs to advocate for funding. Show the public why you need it and what it is for. The DEQ is severely

underfunded.
- DEQ should have informed the public of the high levels of cadmium when they first knew. DEQ needs to start

notifying the public immediately to instances such as these.
- DEQ needs source and ambient air monitoring. The ability for DEQ to do source testing needs to be included in

all permits moving forward.
- DEQ needs to do statewide moss sampling.
- Realize that for all the out of state glass artists that Bullseye has recruited to contribute their comments,

their numbers pale in comparison to the affected families around these facilities. Be aware that many working

families that are impacted by this pollution do not have the luxury to comment on these rules; be it time, access

to the internet, or even being aware of this issue.
Our air, water, and soil is community based. We all need it to be clean and healthy for generations to come. A

facility does not have the right to put others at risk simply by paying a small fee and all the while the public

is none the wiser. Bullseye is the catalyst. It is my sincere hope that DEQ does not stop here because the public

sure won't.
Thank you,
Shaw
85 242 Owen Kaufman owenkaufman1@gmail.com Oregon As a resident of Portland, I urge the DEQ to implement health-based regulations for ALL industrial facilities that emit toxins into our environment as soon as possible.
86 243 Nancy Brown Nancyla23@aol.com OR Please give careful consideration to the proposed air regulations, especially considering the proximity to neighborhoods, etc.
87 244 Judith Kiriazis judy@heartofstonestudio.com Arizona My name is Judith Kiriazis and I am a PhD in biology as well as a glass artist. In the past, I've run an environmental organization to protect Lake Michigan’s water quality. I know from experience that the most effective way to effect change to protect the environment is to work in concert with government agencies, scientists, businesses, citizens groups, and individuals. As an environmental activist, I have fostered communication and cooperation among these sometimes varying interests. It might not be the quickest method, but it is the most long-lasting. I know it’s a challenge to balance the health needs of city residents with the economic viability of local industries. I also know what a company looks like when it is trying to skirt the law, and I'm here to tell you today that Bullseye Glass is not one of those companies. I've been a Bullseye customer for more than 20 years. I've been to the BE Portland several times, toured the facility, met many of the staff, and taken classes there. I think that it's fair to say that this whole problem with emissions arose, not because Bullseye was attempting to defy or skirt regulations, but because the regulatory “holes in the net� were simply too big for smaller companies like Bullseye to get noticed. I believe the citizen uproar resulted from fear and concern, but was based on incomplete evidence and shaky science. It’s vital for the citizens of Portland to know that their air quality is being protected, but a knee-jerk reaction that might drive Bullseye and other glass companies out of business is both unfair and unprofessional. Bullseye has done its utmost to come into compliance, and as a long-term customer, I know that these continuing improvements are going to be costly, so I and my fellow customers are prepared for increased glass prices because I know that these changes are for the best. What is not acceptable is an unreasonable compliance schedule or vindictive lawsuits that will drive a good company out of business, rob dozens of dedicated employees of their jobs, and leave tens of thousands of glass users around the world without a source of quality art glass. Glass is a material that can be infinitely recycled. I predict that in the near future, glass will replace plastic in many applications, freeing our oceans from the glut of plastic waste. As such, I urge you to think long-term and expand your stance in order to work in partnership with glass companies such as Bullseye. They are the good guys, but they need your guidance. I urge you to dialogue with them to set long-term goals: They need to be encouraged to develop production methods that are both cost-effective and environmentally responsible. A clean, successful company in your state that benefits many people on many levels is something you can be proud of, as opposed to a company needlessly driven out of business. Please help glass companies achieve the former. Thank you.
88 362 Karin Wagner portlandrolfer@gmail.com Rolfing Portland OR Thank you for working to make our air and our soil safer. I would appreciate the following changes:

1. Include ALL heavy metals and hazardous emissions (not just the 6 Federally regulated ones).
2. Cover the whole state of Oregon
3. All glass factories, not just art glass
4. 99.9% capture rate on emissions control devices.

Thank you!
89 367 Helen Cowart helen@elemental.name Helen Cowart WA I have been a glass-focused artist since 2009 and I have had the pleasure of becoming acquainted with Bullseye Glass, many of the small businesses who sell art glass, and artists who work with art glass. This network and community of people is far reaching. I personally know glass artists in Australia, the United Kingdom, Israel, and France, and I am acquainted with many artists in New Zealand, Argentina, Denmark, Canada, Costa Rica, and Switzerland. I know and know of many, many glass artists across the United States

I personally know several of the employees of Bullseye, and I know through them that the owners are just as concerned about the city they live in. All parties desire the same thing - clean air in their homes and neighborhoods. The only request that is being made by Bullseye and their supporters is to find solutions that are based on valid scientific data, facts, open & rational communication, and reasonable response tims.

It is my understanding that there are other companies and manufacturers who are producing as much or more toxic emissions that have not been investigated at all. Professionally unacceptable, in my opinion. Either the laws apply to all or they apply to none.

Please understand that Bullseye is not seeking to be exempt, only that they are given the time to install appropriate emission controls properly. In Lani McGregor's (co-owner of Bullseye) own words "But all of us here are going to do the right thing, and we're going to do the right thing if it kills us."
Make INFORMED decisions. Make sure the new laws, rules, and regulations are developed in a sound, scientific manner, researching and studying all the data that is available. And then apply those laws, rules, and regulations equally and fairly to all.

After all, we want the same clean air to breathe and safe soil to live .

Thank your for your time and efforts
90 368 Barbara Boals mojoglassworks@gmail.com Glassmakers Idaho It does not appear that the chemical findings warrant a closure of Bullseye glass. Please consider the livelihoods of the many glass artists. I depend on Bullseye for my living. Thank you....
91 369 Debbie Baudin dion1@suddenlink.net D's Designs, LLC Louisiana This is an already dieing art! Most of us do this because we love it and only make enough to be able to buy more glass! It is a way of life for us! We live and dream this colored glass art form! Please please please work with these USA companies to keep colored glass production live and well. Without them, we cannot repair these century old windows nor make new ones for generations to love.
92 372 Michelle Raine bzgirl2006@yahoo.com California I have taken four semesters of classes in glass fusing and just purchased my own kiln. If the supply of glass is unavailable it will be devastating and I know that I am not alone in this. There are so many artists who create the most beautiful items and the glass industry is important to many glass artists in this country. Please set reasonable goals to let the industry continue and make any necessary changes for public safety in a reasonable amount of time.
93 376 Beth Ulrich bu626@yahoo.com Chester County Art Glass PA the glass business is my livelihood - it is how I make my money to survive. taking away glass or causing a high charge to fix the air would pass down to little people like me for who people will not buy anything if I have to put my prices higher due to the increased price of glass.
94 381 Beth Ulrich bu626@yahoo.com Chester County Art Glass PA the glass business is my livelihood - it is how I make my money to survive. taking away glass or causing a high charge to fix the air would pass down to little people like me for who people will not buy anything if I have to put my prices higher due to the increased price of glass. https://data.oregon.gov/views/54i7-gnrh/files/300988bb-6674-44bf-90dc-88c409f2d1de?filename=20160721_121201.jpg&content_type=image%2Fjpeg
95 382 Beth Ulrich bu626@yahoo.com Chester County Art Glass PA the glass business is my livelihood - it is how I make my money to survive. taking away glass or causing a high charge to fix the air would pass down to little people like me for who people will not buy anything if I have to put my prices higher due to the increased price of glass. https://data.oregon.gov/views/54i7-gnrh/files/cd7528b5-93ed-4c63-9931-04dc07f9f75c?filename=20160721_121201.jpg&content_type=image%2Fjpeg
96 383 Julia Young julesteryoung@gmail.com OR Dear DEQ, I request that you protect neighbors from dangerous emissions from the Bullseye Glass Co. Please have regulations that protect Portlanders even if they hurt businesses. Stricter regulations are needed and I hope DEQ will update its rules to tighten regulations for glass manufacturers as well as other businesses in the city like Precision Castparts. Thank you for your consideration. - Julie Young, a concerned neighbor and parent
97 385 KATHLEEN Meadors kathymeadors@charter.net Self Montana I am 73 And I found my joy in glass for years ago after my husband passed away. Please do not shut down Bullseye it will have severe ramifications for the glass industry Nationwide. Keep glass in the USA not China. Thank you
98 387 Michael Aiello redbarn.studio@live.com Aiello Fine Art OR I Live .4 miles from Bullseye for the past 9 years. Me my wife Amy and my 6 year old daughter each have High levels of Lead, Barium, Arsenic, Nickel and Cadmium. My daughter has high levels of Arsenic and Cadmium. We are not eating out of our garden this year, being unable to afford hauling in fresh soil or the cost of building raised beds. In fact, we have already spent about $700 on various tests for our bodies and are being advised by our Naturopath to undergo chelation over this year. The costs of that will likely go into the thousands. I am joining Erin Brokovitz's lawfirms lawsuit and if I am able I will advocate for the DEQ also being accountable.

These are the actions that the DEQ needs to enact to be a trusted agency in my eyes, otherwise regardless of the excuses, DEQ will continue to be a disappointment to me, my family and community.

1. PLEASE, close loopholes that would allow for emissions of heavy metals in uncontrolled furnaces.
2. PLEASE, apply these state wide.
3. PLEASE, apply these to all glass manufacturers, not just those producing 10 tons per year.
4. PLEASE, apply to all heavy metal by September 1st.
5. PLEASE, ensure public notice and comment instead of locking us out of DEQ decisions.
6. PLEASE, create and enforce rules that will cover all heavy metals.
7. PLEASE, create and enforce true HEALTH BASED STANDARDS.

Since moving into this neighborhood, I have had respiratory issues, peripheral neuropathy and hyper pigmentation. My daughter was born with a heart murmur, has a history of bladder issues and has demineralization of her bones. Our toxicologist says all these symptoms are consistent with the synergistic effects of toxic environmental exposure. PLEASE DO ALL YOU CAN TO ENSURE THE HEALTH OF ALL OREGON CHILDREN AND FAMILIES. We cannot afford to sell our home and relocate, please change our family's prognosis to a much healthier one and do more than ever before to make Bullseye and all other Oregon polluters safe neighbors. Thank you, Michael Aiello
99 388 Michael Aiello redbarn.studio@live.com Portland, Oregon I already wrote with my recommendations. Me and my family live .4 miles from Bullseye and are the victims of their 42 years of non stop unregulated heavy metal pollution. Aside from my respiratory issues and my daughters demineralization and high metals levels, our immediate neighbors include 2 non genetic cancer victims and another woman who has 3 autoimmune diseases. The only difference between us and them is that we've only been here for 9 years and they all have been here the entire time that Bullseye has been polluting. This message is to all the people who are asking not to affect the art glass industry, YOU FOLKS DON"T REALIZE THAT INNOCENT CHILDREN ARE THE VICTIMS OF YOU ART GLASS!! It is selfish to advocate for Bullseye when local neighbors here are currently suffering health issues directly related to their polluting. BULLSEYE DOESN'T NEED TO GO OUT OF BUSINESS, THEY NEED TO BE PROPERLY REGULATED AND TRANSFORMED INTO A RESPONSIBLE ENVIRONMENTLALLY SAFE INDUSTRY INSTEAD OF A LYING CLASS A LOCAL POLLUTER!

What would YOU FOLKS FROM DISTANT PLACES DO if tour child was sick from Bullseye's unfiltered toxic polution???
100 389 Katharine Salzmann katharinesalzmann@gmail.com Eastside Portland Air Coalition (EPAC) Oregon I would like to request the following changes to the Temporary Rules for Art Glass Manufacturers:

1. Please include ALL heavy metals and potentially toxic substances used and emitted in the glassmaking process. Selenium, for example, is not included and our neighborhood was recently exposed to a spike in this Hazardous Air Pollutant because it is still unregulated. ALL toxic and potentially toxic substances used and emitted during the glassmaking process should be included and controlled.
2. Please revisit the short-term and long-term benchmarks established in the Temporary Rules. I realize this document was made in extreme haste. In anticipation of the Cleaner Air Oregon regulatory overhaul, now is an opportune time to apply the most protective benchmarks available. I am sure you have staff who have been researching this. Please change the Temporary Rules to reflect the MOST HEALTH PROTECTIVE benchmarks possible.
3. Please expand this rule to cover the entire State of Oregon. It is my understanding that a search was done for other art glass manufacturers statewide and none were found. I am in no position to confirm this, but in anticipation of new businesses springing up, and to protect residents outside the Portland Air Quality Maintenance Area, these rules should be applied statewide.
Also, omitted from the Rules are two large Portland glass recyclers, General Glass Company and Owens-Brockway, which sit in two arsenic hot spots identified by the USFS Moss Study. Why?
4. The Rules should be amended to apply to all glass factories, not just art glass manufacturers and not just those that produce 10 tons per year. Please explore ways to include those two Portland glass recyclers and methods for preventing pollution from any glassmaker handling hazardous materials, not just art glassmakers.
5. Section 340-244-9070 of the Temporary Rules currently requires emissions control device that meets 99.0 percent or more removal efficiency for particulate matter. At a recent DEQ meeting allowing public comment on making the Temporary Rules permanent, the DEQ rule-writer repeatedly referred to the control requirement as 99.9 percent. That is not what it says in the Temporary Rules, but that is what it SHOULD SAY: 99.9 percent removal efficiency.

We have born a terrible burden in SE Portland for 42 years. Imagining the data from the October air monitoring extrapolated daily for decades, and watching what has occurred in the local airshed even with the Temporary Rules in place has been at once terrifying and utterly dismaying. Given that modern technology exists to filter up to 99.9% of HAPs, there is simply no reason to allow uncontrolled and unregulated emissions of any kind to continue to occur anywhere ever again.

And finally, I would once again like to ask that the DEQ be brought into the 21st century by employing modern video recording equipment for ALL PUBLIC MEETINGS, making those available online and through social media, so that discussion and information are more readily available for working people who would like to participate and stay informed. The Oregon Attorney General's recent ruling that prohibits DEQ from charging the public for access to public documents denotes a real sea change for agency transparency. The public cannot support you or advocate for you with our legislators, nor can we make substantive commentary unless we understand the ways you are striving to protect us and our environment from hazardous pollution. We must have meaningful access to these essential public proceedings.
101 390 Karin Wagner portlandrolfer@gmail.com OR Thank you for working to make our air and our soil safer. I would appreciate the following changes:

1. Include ALL heavy metals and hazardous emissions (not just the 6 Federally regulated ones).
2. Cover the whole state of Oregon
3. All glass factories, not just art glass
4. 99.9% capture rate on emissions control devices.

Thank you!
102 395 Ruth Gundle ruth.gundle@icloud.com The Eighth Mountain Press OR 1. Include ALL heavy metals and hazardous emissions for regulation, not just the 6 Federally regulated ones.
2. Make sure the health safety benchmarks are the most protective of human health they can be
3. Expand this rule to cover the whole state of Oregon
4. Apply the rules to all glass factories, not just art glass manufacturers
5. Require 99.9% capture rate on emissions control devices.
103 557 Julia Gaddis julia@jlgaddis.com   Please make permanent the "Temporary Rules for Art Glass."

For our citizens and our children and future, please:
Ask the DEQ to:

1. Include ALL heavy metals and hazardous emissions for regulation, not just the 6 Federally regulated ones.
2. Make sure the health safety benchmarks are the most protective of human health they can be
3. Expand this rule to cover the whole state of Oregon
4. Apply the rules to all glass factories, not just art glass manufacturers
5. Require 99.9% capture rate on emissions control devices.

This is vital to our health and well-being, for the environment in which we live and breathe.

Sincere regards,

Julia Gaddi
104 558 Debbie James starfishdj@aol.com Artist Texas Please do not keep the these companies from making the same colors. The new ones are just not the same brilliance that artist like I need and it will make my craft more expensive to produce. It is ridiculous that even after they comply with your new rules it's still not good enough. I don't want to have to pay a lot of money to get the same glass as before in another country. I have to do this with flash glass and I have a hard time selling those pieces made with it because of the price.
105 561 Debbie James     Texas Please do not keep the these companies from making the same colors. The new ones are just not the same brilliance that artist like I need and it will make my craft more expensive to produce. It is ridiculous that even after they comply with your new rules it's still not good enough. I don't want to have to pay a lot of money to get the same glass as before in another country. I have to do this with flash glass and I have a hard time selling those pieces made with it because of the price.
106 566 Robert Thompson salalscape@yahoo.com Dear DEQ,

When considering the glass rules please:

1. Include ALL heavy metals and hazardous emissions for regulation, not just the 6 Federally regulated ones.
2. Make sure the health safety benchmarks are the most protective of human health they can be 3. Expand this rule to cover the whole state of Oregon 4. Apply the rules to all glass factories, not just art glass manufacturers 5. Require 99.9% capture rate on emissions control devices.

Thank you,
Robert Thompson
107 590 Josephine Geiger jageiger.studio@comcast.net J A GEIGER STUDIO, LLC MN As a professional glass, I am all for the safe production of my raw materials. With that said, Bullseye, Uroboros, and the half dozen other art glass manufacturers across the country seem to be unfairly targeted by this witch-hunt. I call it a witch-hunt because even with extremely limited production for the last six months, the emissions monitoring during that time show little to no change in air quality. This definitely suggests that the problem is likely coming from another source. Please use accurate and fair data to make your assessments and rule definitions. And be fair in the application of these regulations: if this were Exxon polluting the air, water and soil, would they be given the same treatment? It seems that the small independent businesses are footing the bill in lost production for rules and regulations that are being changed and eliminated overnight. While the biggest companies are given years to implement new regulatory controls, how is that fair? Please, please use actual scientific data (not some blogger's hysteria) to determine the new regulations. And, as another commenter pointed out, there is a simple fix to everything: close the loophole on the definition of batch production. Because that is basically what is happening here. The art glass industry has followed the rules, and like any logical entity, utilized the loophole to its advantage - so close the loophole.
As for economic impact, this is huge. I make my living as a glass artist. If the new regulations cause more art glass manufacturers to go out of business, like Spectrum Art Glass did as a direct result of this, the art glass world may very well collapse. Having Spectrum already out of business has already impacted my business, as well as countless others. I bought as much stock as I could afford to buy, using up my entire emergency fund, which means I actually have no money for an actual emergency. This is because Spectrum makes a few types of glass completely unique which I use in much of my artwork, and not having any more will have a huge impact on my business and is consequently forcing a change in my artistic style.
Bullseye and Uroboros are two of my primary material suppliers, especially for fusible/compatible glass. I have had to reduce my own production and limit my artwork because so much glass are unavailable, and still is not back into production, which means my sales have declined and my commissions have been delayed. This all adds up to less income. Multiply this by the hundreds of thousands of other artists and glass professionals, and this is a HUGE economic wheel. Not to mention that every single manufacture has increased prices by at least 10%, sometimes as much as %15. Since sheet glass is 80% of my yearly material expenses each year that will be a huge impact upon my bottom line.
Please, please consider the impact on all jobs, tax revenues, not just those in Portland. The limited win on pollution control when applying subjective and stringent rules on the glass industry with virtually no notification creates direct hardships that these small industries can barely weather. This effort has a huge financial impact and may well cause production to shift overseas. Sending production to China will not clean our air. It will not support the Oregonians who work in the art glass industry, nor any of those across our continent and the rest of the world. It will not provide any tax revenues.
Thank you for your time. Please consider using to have a real impact on our health and air quality, on art and our economy as changes are made in environmental regulations.
108 593 Isa Dean isad@multcolib.org Humboldt Neighborhood Association Oregon Hello,

As a member of the Humboldt Neighborhood Association board, I am writing in support of the letter submitted by NE Coalition of Neighborhoods which requests:

Ensuring leadership that prioritizes health-based standards. It is important to hire a DEQ Director who understands how to make health-based decisions on permitting and regulation. Any new Environmental Quality Commission board members should also understand the importance protecting human health.

Ongoing information and comprehensive air emissions data, concentration maps, locations, producers (known and unknown), and associated emissions health risks. Comprehensive information surrounding air toxics emissions taking place throughout the City of Portland is lacking. We recognize that regulatory actions have been taken to identify and inspect facilities, collect data, and increase air-monitoring capabilities. We are asking that DEQ and associated organizations provide the public with all the most up-to-date and comprehensive information that is ongoing, clear, and accessible to all.

Hexavalent chromium levels in the air need to be addressed. As indicated in the available data, there are currently many unknowns, one of which is of huge concern for the community: levels of hexavalent chromium. Hexavalent chromium is a known carcinogen, yet the Department currently lacks information regarding hexavalent chromium users and levels. The little information that is available does not differentiate between hexavalent chromium and other chromium.


Provide continuous information for the community that is translated for non-English speakers. We ask the DEQ and associated agencies to conduct additional information/community forums, provide translation for all materials released regarding the situation, and conduct culturally-specific outreach to non-English speakers, communities of color, and low-income communities.


Make air emissions permits publicly available, not just through public record release requests. Permits provided by the DEQ are public records, and any member of the public should be able to access these records without going through the lengthy and costly process of submitting a public records release request. The simplest way to rectify this is to provide permits online, through DEQ's website. Ideally, permits would be available in a searchable database.

Provide clarification regarding the timeline released by the DEQ and associated entities, as this situation seems to have gone on for some time without informing the public at large formally. The press release on February 3, 2016 references this situation as a rapidly evolving one, even though this appears to have originated as far back as 2003. For example, in 2009 monitoring of the Harriet Tubman School in NE Portland revealed that Uroboros was noted as a potential source of cadmium emissions.

Focus on diesel particulates. One of the most serious current threats to public health from air pollution comes from the burning of diesel fuel. Oregon has become a dumping ground for dirty diesel and should develop an aggressive approach to these health threats.

Thank you,

Isa Dean
Humboldt Neighborhood Board Member
Portland, Oregon 97217
109 594 Eric Suevel suevelstudios@gmail.com Suevel Studios, Inc. Illinois What happened to working with business to help them meet current standards instead of the knee jerk reactions? Your narrow view of the impact of shutting down the glass business is very dangerous. These companies supply glass at an international level, so the impact is global, not just little Portland. I would ask if the companies were billion dollar businesses and were contributing money to the Governor of Oregon, would they be treated in the same manner you are currently treating them? From everything I can see the companies are willing to comply, but the dates given are rather ridiculous at best. Stop the panic and help the businesses!
110 596 Cindy Young rocknrollschool@msn.com EPAC Oregon The rules as of now only apply to producers of 10 tons or more.The rule should be modified to apply to all sources of hazardous air pollutants (HAPs), ideally, regardless of the amount produced. However, if a threshold is needed, we suggest that the rule apply to manufacturers of greater than 500 pounds of colored art glass per year. This would prevent smaller, unregulated, colored art glass manufacturers from starting up in lieu of the larger, tiered regulated manufacturers. This modification would be consistent with the goal of reducing the amount of HAPs being discharged to the atmosphere.
111 602 Cindy Young rocknrollschool@msn.com EPAC Oregon As a long term resident living less than a half mile from Bullseye and a member of EPAC I have followed the rule making process and these are my concerns.
Concerns that were also shared by all participants of the fiscal committee.
The rule is to regulate companies that make over 10 tons of glass containing the 6 metal haps (cadmium,lead, nickel, chrome, manganese and arsenic). After looking at the rule for the smaller glass producers I think each tier 1 manufacture makes less than 10 tons of glass containing the metals haps in question so that would leave all tier 1 manufactures exempt of the whole temp rule and possibly the permanent rules as well. This is a very big concern. Again deq leaving loopholes for companies to do what they want.
The rule should be modified to apply to all sources of hazardous air pollutants (HAPs), ideally, regardless of the amount produced. However, if a threshold is needed, we suggest that the rule apply to manufacturers of greater than 500 pounds of colored art glass per year. This would prevent smaller, unregulated, colored art glass manufacturers from starting up in lieu of the larger, tiered regulated manufacturers. This modification would be consistent with the goal of reducing the amount of HAPs being discharged to the atmosphere.
I would also like to add that the rules need to be applied to the whole state of Oregon not just Portland.
As the rules sit now you could move your facility out of the Portland area and continue business as usual.
The State of Oregon is ranked 3rd worst air quality in the country. It's time to clean up Oregon.
Oregon's lack of health based regulation on Industry needs to change. Our air, water, soil and most importantly our lives depend on it.
112 608 Cindy Young rocknrollschool@msn.com Oregon [submitted by email]
As a long term resident living less than a half mile from Bullseye and a member of EPAC I have followed the rule making process and these are my concerns.
Concerns that were also shared by all participants of the fiscal committee.
The rule is to regulate companies that make over 10 tons of glass containing the 6 metal haps (cadmium,lead, nickel, chrome, manganese and arsenic). After looking at the rule for the smaller glass producers I think each tier 1 manufacture makes less than 10 tons of glass containing the metals haps in question so that would leave all tier 1 manufactures exempt of the whole temp rule and possibly the permanent rules as well. This is a very big concern. Again deq leaving loopholes for companies to do what they want.
The rule should be modified to apply to all sources of hazardous air pollutants (HAPs), ideally, regardless of the amount produced. However, if a threshold is needed, we suggest that the rule apply to manufacturers of greater than 500 pounds of colored art glass per year. This would prevent smaller, unregulated, colored art glass manufacturers from starting up in lieu of the larger, tiered regulated manufacturers. This modification would be consistent with the goal of reducing the amount of HAPs being discharged to the atmosphere.
I would also like to add that the rules need to be applied to the whole state of Oregon not just Portland.
As the rules sit now you could move your facility out of the Portland area and continue business as usual.
The State of Oregon is ranked 3rd worst air quality in the country. It's time to clean up Oregon.
Oregon's lack of health based regulation on Industry needs to change. Our air, water, soil and most importantly our lives depend on it.

Thank you,
Cindy Young
113 612 Al Hooton al@glassalchemy.com Glass Alchemy Oregon Please see attached comments document. https://data.oregon.gov/views/54i7-gnrh/files/fe330805-5c36-48a6-a17a-6466414f641e?filename=permanent+rule+public+comments+FINAL.pdf&content_type=application%2Fpd
114 616 K Hamill voiceofathena@yahoo.com Oregon [submitted by email, see attachment]

K. Hamill
voiceofathena@yahoo.com
Oregon

As a lifelong Portlander, I have a stake in the quality of our air. I also highly value art and all the positives the local glass community has brought to our city. That puts me in the middle of the current polarization between clean air advocates and glass supporters. There does NOT need to be sides. Urban pollution is complex, every man made product and convenience creates it. We need to first and foremost recognize we each contribute to the pollution problem and we each and every one of us need to work together toward reducing our environmental impact. Should CAGM’s take steps to reduce their emissions? Absolutely. And they are. And it’s up to DEQ and everyone who wants cleaner air to support those efforts – reduction of emissions from all sources.

If DEQ has determined the use of raw materials (Metal HAPS in their raw, non-vitrified state) used in glass making in an unfiltered furnace is a risk to public health – then it logically follows that risk is not geographically unique. If the rules are necessary, based on science, and fairly written. Then they should no doubt apply to all of ODEQ’s jurisdiction equally, not just Portland.

As for the threshold of tonnage produced, previously the two larger manufactures in Portland did not fall under EPA NESHAP since they use less raw metals than those rules limit as emissions. Simply, they were too small to matter. Apparently now, that was not sufficient and there is concern. DEQ is now proposing just creating a different bar, with exceptions again. In another decade will we back where we are now with insufficient rules? If making permanent rules, carefully consider the long term.

Also, what is a “glass manufacturer”? There is a significant and clear difference between mixing raw materials in a furnace until they vitrify – to create glass - and the many studios and artisans that re-melt and form glass (sheet, cullet etc.) to create finished goods. Failure to define this difference could be more damaging than the question of the threshold amount. With that in mind, it seems any size manufacture (combining raw materials sand, soda, metal oxides etc., to create glass) that handles metal HAPS in their raw form should be regulated to some extent as to the safe handling of those materials and reducing potential furnace emissions.

DEQ needs to carefully and clearly craft its rule making language – much of the controversy in the initial rulemaking was due to the EPA’s failure to properly define a co-opted industry term, which to some created a “loophole” in the 2005 NESHAP rules. The terms “continuous” and “periodic” in the industry deal with the type of furnace and its ability to continuously output glass, the EPA has now recently redefined their use of the term to refer to the continuous firing of the fuel source, not the furnace construction or production. This poor use of regulation language has caused confusion and contention for all sides. For a simplistic explanation of the difference between continuous and periodic furnaces refer to this, page 6: http://www.lehigh.edu/imi/teched/GlassProcess/Lectures/Lecture03_Hubert_industglassmeltfurnaces.pdf

According to DEQ’s own PATS findings the metal air emissions in question that these temporary rules are supposedly addressing, are primarily emitted by other sources such as Diesel and mobile combustion, wood smoke, metal manufacture, and for some metals they are just naturally high in our area. Yet, a significant amount of DEQ resources is being squandered to address small glass manufactures, the two largest of which have already begun the process of installing filtration and will be soon brought under the EPA NESHAP Title V standards. In the interest of public health, why is DEQ using a majority of resources addressing a small fraction of the air quality problem? Again, the filtration currently being installed by CAGMs is absolutely necessary and important, but the continual focus on ‘just’ glassmakers is not addressing the big picture. Why not tackle limiting metal emissions from ALL sources in the permanent rules? Stop pointing fingers and get the job done.		 https://data.oregon.gov/views/54i7-gnrh/files/159a9290-9d5b-4704-b6d0-8fdd3e74314e?filename=E%3A%5CJoe%27s+Documents%5CAir+Toxics+Rulemaking+2016%5Ctemp+to+permanent%5C4%29+public+comments%5Cerror+reports%5Ccomments+that+need+to+be+manually+included%5CK+H
115 1068 Sage Cohen sage@sagecohen.com Sage Communications OR I would like you to: 1. Include ALL heavy metals and hazardous emissions for regulation, not just the 6 Federally regulated ones.
2. Make sure the health safety benchmarks are the most protective of human health they can be
3. Expand this rule to cover the whole state of Oregon
4. Apply the rules to all glass factories, not just art glass manufacturers
5. Require 99.9% capture rate on emissions control devices
116 1080 K Hamill voiceofathena@yahoo.com Oregon [submitted by email, see attachment] https://data.oregon.gov/views/54i7-gnrh/files/159a9290-9d5b-4704-b6d0-8fdd3e74314e?filename=E%3A%5CJoe%27s+Documents%5CAir+Toxics+Rulemaking+2016%5Ctemp+to+permanent%5C4%29+public+comments%5Cerror+reports%5Ccomments+that+need+to+be+manually+included%5CK+H
117 1081 Brian Jones bsj2312@hotmail.com OR Your temporary rules make a great deal of sense and have been scientifically scrutinized. Despite what individuals in the glass industry believe, the health of a population is much more important than jobs and the visual appeal of color translucent panels. Anyone who says the art glass industry will dry up and disappear because of these regulations is a fool and has been misled. I hope all these businesses opposing this rule post such on the fronts of their doors, so we all know who is responsible for destroying the health and lives of Portland's residents.
118 1082 Rob Nosse rep.robnosse@state.or.us State Representative Oregon As a representative and resident of Southeast Portland, I am deeply concerned about the environmental and human health impacts of uncontrolled metal emissions. If we truly care about the health of all Oregonians, I encourage the DEQ and EQC to consider extending the permanent rule to art glass manufacturers statewide. The issue of industrial air toxics is not limited to the Portland Metro Area, and the proposed permanent rule may provide a competitive advantage to businesses in other regions of the state. I believe that all known sources of air pollution should be subject to the DEQ's health-based regulations, regardless of geographic location. In broadening the scope of the permanent rule, we can better protect the health and wellbeing of all Oregon residents.
119 1094 Gregor Richardson gregor.richardson@socrata.com Socrata Washington This is a test from Socrata support
120 1095 Karen Roussos fireflyglass.creations@gmail.com Glass artist Australia Please don't hold up the production of glass
This is my lively hood I have three shops and 9 staff that need to keep there jobs
Kind regards Karen
121 1096 Katharine Salzmann katharinesalzmann@gmail.com EPAC Oregon In light of recent revelations in the DEQ report on Bullseye's April test results that chromium emits almost entirely in the carcinogenic hexavalent form AND that their bag house had only about a 65% capture rate for Cr+6 , the DEQ must make provisions in the Temporary (Permanent) Rules for 99.9% capture of condensable particulate matter. I would also like to suggest that 0.08 ng/m3 be set as both the annual and the daily acceptable source impact level for Cr+6. Section 340-244-9040 sets the daily acceptable source impact level for Cr+6 concentration at 36 ng/m3. THIS MUST BE SIGNIFICANTLY LOWERED. This is NOT ACCEPTABLE to the public and insufficient to protect public health. Even the CDC's ASTDR starts their annual minimum risk level for hex chrome at TWO WEEKS OR MORE EXPOSURE. Please, make provisions in the Temporary (Permanent) Rules for 99.9% capture of condensable particulate matter and lower the daily acceptable source impact level for hexavalent chromium to 0.08 ng/m3
122 1097 Cynthia Eckersley cynthia.eckersley@gmail.com EPAC Oregon Please consider doing the following when rewriting the rules: 1. Include ALL heavy metals and hazardous emissions for regulation, not just the 6 Federally regulated ones.
2. Make sure the health safety benchmarks are the most protective of human health they can be
3. Expand this rule to cover the whole state of Oregon
4. Apply the rules to all glass factories, not just art glass manufacturers
5. Require 99.9% capture rate on emissions control devices.
Thank you, this is so important!
Cynthia Eckersley
123 1099 Cindy Young rocknrollschool@msn.com EPAC Oregon Bullseye's April test results show that chromium emits almost entirely in the carcinogenic hexavalent form AND that their bag house had only about a 65% capture rate for Cr+6 , the DEQ must make provisions in the Temporary (Permanent) Rules for 99.9% capture of condensable particulate matter. 0.08 ng/m3 be set as both the annual and the daily acceptable source impact level for Cr+6. Section 340-244-9040 sets the daily acceptable source impact level for Cr+6 concentration at 36 ng/m3. THIS MUST BE SIGNIFICANTLY LOWERED. This is NOT ACCEPTABLE to the public and insufficient to protect public health. Even the CDC's ASTDR starts their annual minimum risk level for hex chrome at TWO WEEKS OR MORE EXPOSURE. Please, make provisions in the Temporary (Permanent) Rules for 99.9% capture of condensable particulate matter and lower the daily acceptable source impact level for hexavalent chromium to 0.08 ng/m3. http://www.oregon.gov/…/Pages/2016/Rartglass2016.asp
124 1345 Cheryl Dillon cd.coupon@yahoo.com student at AAE Glass Fl By making those rules permanent you would limit the ability of many people who enjoy working in glass fussing . I have read the proposed statue and do not feel it is based on current facts concerning people being ill at this time but something that could possibly happen in the future. I am a nurse and I feel this rule is overwhelming in scope based on the reports currently on file with the DEQ.
125 1348 Robert Thompson salalscape@yahoo.com Dear DEQ,
Thank you for implementing temporary rules to protect my family from toxic glass work pollution. As you consider making permanent rules I ask that you:

1. Include ALL heavy metals and hazardous emissions for regulation, not just the 6 Federally regulated ones.
2. Make sure the health safety benchmarks are the most protective of human health they can be 3. Expand this rule to cover the whole state of Oregon 4. Apply the rules to all glass factories, not just art glass manufacturers 5. Require 99.9% capture rate on emissions control devices.

Thank you,
Robert Thompson
126 1349 Surah Hirsch drshirsch@aol.com   PLEASE:


1. Include ALL heavy metals and hazardous emissions for regulation, not just the 6 Federally regulated ones.
2. Make sure the health safety benchmarks are the most protective of human health they can be
3. Expand this rule to cover the whole state of Oregon
4. Apply the rules to all glass factories, not just art glass manufacturers
5. Require 99.9% capture rate on emissions control devices.

Thank you,
Dr. Surah Hirsch, D.C.
127 1350 Jeffrey Hunter jhunter@perkinscoie.com Perkins Coie LLP Oregon See attached comments on proposed permanent rule. https://data.oregon.gov/views/54i7-gnrh/files/25366391-9592-47a4-833a-d6a84b8c8b5e?filename=Comments+for+Art+Glass+Permanent+Rulemaking+--+Signed.pdf&content_type=application%2Fpdf
128 1351 Kerry Ryan kerrysilvaryan@gmail.com Oregon I suport the efforts of my neighbors' requests for the permanent glass rules. In particular, please... Close loopholes that would allow for emissions of heavy metals from uncontrolled furnaces, apply rules state-wide; apply to all glass manufacturers, not just those that produce 10 tons per year; apply to all heavy metals by September 1st; ensure public notice and comment instead of locking the public out of DEQ decisions; cover all heavy metals and HAPS; hold DEQ accountable; have true HEALTH BASED STANDARDS when determining concentration levels that are protective of human health. Thank you
129 1358 Kerry Ryan kerrysilvaryan@gmail.com Oregon I suport the efforts of my neighbors' requests for the permanent glass rules. In particular, please... Close loopholes that would allow for emissions of heavy metals from uncontrolled furnaces, apply rules state-wide; apply to all glass manufacturers, not just those that produce 10 tons per year; apply to all heavy metals by September 1st; ensure public notice and comment instead of locking the public out of DEQ decisions; cover all heavy metals and HAPS; hold DEQ accountable; have true HEALTH BASED STANDARDS when determining concentration levels that are protective of human health. Thank you.
130 1366 Robert Clapp Profigliano1@yahoo.com Citizen OR 1. All heavy metals can be hazardous/poisonous/neurotoxic/teratogenic, etc. They should all be regulated, not just the six proposed.

2. Rule should cover all of Oregon, not just PDX.

3. The benchmarks should be the safest/highest known to science--and if that means there is no safe level for a metal, then it should not be emitted at all.

4. Capture rates should be 99.9%

5. ALL glass manufacturers should be covered, not just art glass.

6. Health based standards, not risk based standards.

7. Standards should not be set by the industry being regulated--nor should they be the ones policing compliance.
131 1368 Mitch Hosford fcbr01@hotmail.com Mitch Hosford Glass UK [see attached comment, submitted by email]

Hello,
I am a glass artist in the UK and rely on Bullseye glass for my work. In the UK we only get 3 types of fusible glass imported - Bullseye, Spectrum (now Uroboros) and float-compatable. Most people here work with either Bullseye or Spectrum (which is closing with Uroboros taking up the slack) so without these manufacturers many artists and hobyists will have to stop their glass fusing. Without hobyists there will be less oportunity for artists to supplement their income by teaching.
In my own case, I was made redundant after long-term illness. Having now recovered enough to do some work I have found getting a suitable job where my on-going health problems are tolerated is nigh on impossible. I have now invested my money in setting up my own glass business.
Much of my existing equipment is made in the USA and due to all the uncertainty surrounding the continued production of US fusing compatable glass I have just put off buying a larger kiln (Paragon which is a US company), a lap-grinder (Glastar which is a US company) and ring saw (Gemini Saw Co which is a US company). Replacement grinding discs and blades are also imported from the USA. I have been lucky enough to take classes with some US-based instructors. As you can see the loss of the US art glass industry will have an economic impact in the USA beyond the glass manufacturers. In my own case, without compatible fusing glass I will have lost the money I have already invested and have to go on welfare.
Bullseye was in compliance with the old code. We all want Portland to have clean air (the glass manufacturers and their employees live there afterall). Even so, when notified of any problem Bullseye initiated action to address it, from voluntarily suspending using certain metals to arranging baghouses to be installed. However, in the case of Bullseye, the Cease and Desist issued by the Governor meant they had to decrease their glass production by some 80%, making it very difficult to raise the money by selling glass to install the baghouses. Even with sufficient capital, these adjustments can't be made overnight as these baghouses are custom-built.
Please make any decisions based on facts rather than being media-led.For example it is still being reported that Bullseye is releasing harmful chromium, but the report stating that 5,498 pounds of raw hexavalent chromium compounds on site at Bulleye was an error based on an error in the Fire Marshal's HSIS. Apparently "chromite" (Cr3) autocorrects to "chromate" (Cr6).
Re the Bullseye baghouse and chromium batch test result, the firm that did the testing said in their report that the test results were not consistent and that no conclusions could be made based on those results. There are concerns regarding how the test was conducted and results (which DEQ acknowledge) which on at least one occassion showed more Cr6 in the test results than CR3 going into the furnace.
While Bullseye could certainly have been emitting some amount of metals from unfiltered furnaces and it's important they addressed their patch (which they immediately and continue to do so) From a basic chemistry standpoint look at the boiling temperature point of a compound and its decomposition temperature. Most colorants are going to have boiling points under the glass melting point and just go into solution and be trapped within the glass. Most of the concerns are with the dust of the colorants getting loose from the crucible in the thermal updraft of the furnace before the glass melts, and before the colorant can be trapped in solution. Baghouses will address this.
It should also be noted that The USFS moss study did not sample around the Brooklyn railyard. (Nor can it account for wind direction.) Uroboros is also near a train yard. Particulate matter is created during the incomplete combustion of diesel fuel. Its composition can include hundreds of chemical elements, including sulfates, ammonium, nitrates, elemental carbon, condensed organic compounds, and and heavy metals such as arsenic, selenium, cadmium and zinc.
The daycare is literally surrounded on three sides by the rail yard. Across the street is Lehigh Southwest Cement. Mention CR6 and everyone immediately thinks of high temperature industrial processes. All the cement across the street is a product of high temperature industrial processes - it's just not processed across the street. Same thing with the fly ash that contains all the heavy metals*- it was produced elsewhere. There is a rail car shed there. The shed allows for rail cars to have a roof overhead when they unload. It is also not protected like the truck transfer facility with baghouse filtration etc. The shed is open on both ends. When the wind blows it will blow through the shed picking up any concrete or fly ash that has been spilled.
In summary, please give the glass companies clear and set guidelines and allow them time to make alterations. Allow them to stay in business. Please consult with a glass scientist to find out what can and can't happen in a kiln. Measure wind direction. For the sake of the people of Portland also investigate beyond the glass industry and put any pre-conceptions aside. Thank you

* (depends upon the specific coal bed makeup, but may include one or more of the following substances in quantities from trace amounts to several percent: arsenic, beryllium, boron, cadmium, chromium, chromium VI, cobalt, lead, manganese, mercury, molybdenum, selenium, strontium, thallium, and vanadium, along with dioxins and PAH compounds.)		 https://data.oregon.gov/views/54i7-gnrh/files/beaf495f-8a77-4491-b53b-3935948a83d8?filename=E%3A%5CJoe%27s+Documents%5CAir+Toxics+Rulemaking+2016%5Ctemp+to+permanent%5C4%29+public+comments%5Cerror+reports%5Ccomments+that+need+to+be+manually+included%5CMi
132 1483 Shawn Ingersoll shawnwingersoll@gmail.com [emailed to Joe Westersund by Shawn Ingersoll on 7/21/2016] https://data.oregon.gov/views/54i7-gnrh/files/3f4a3def-eb55-4f66-8e3f-a8523344af5f?filename=E%3A%5CJoe%27s+Documents%5CAir+Toxics+Rulemaking+2016%5Ctemp+to+permanent%5C4%29+public+comments%5Cerror+reports%5Ccomments+that+need+to+be+manually+included%5CSha
133 1611 Amanda Jarman amanda@amandajarman.net Eastside Portland Air Coalition Oregon Please pass the strongest rules you can to protect air quality.

These rules should include all glass art manufacturers by lowering the production threshold to 1 pound of glass produced per year.

These rules should also apply statewide. Nobody, regardless of where they live, should have to face the health risks my neighbors and I face due to glass manufacturing.

The rules should cover all heavy metals that are known to cause human health problems.

Thank you for your action on this issue.
134 1616 Craig Merriman camerriman@gmail.com Washington It's important to use fundamental scientific methods to describe the problem around the Fred Meyer Daycare. There is some serious flaws to the methodology used to document the heavy metals detected in the air. The biggest problem with the Wide Area Sampling Plan is that the DEQ failed to collect wind data. Without wind data, it is speculation as the the source of the heavy metals around the daycare. DEQ needs to start over with the plan or include wind direction & velocity data with the plan. Because wind data wasn't collected, the DEQ has put theory ahead of facts - this leads to trying to get the facts to fit the theory. It's supposed to be the other way around - do experiments to collect data - then form your theory based on the results. As it is, when you do compare wind direction & velocity data - it's pretty apparent that over 90% of the sample data was taken when Bullseye Glass was downwind or abeam the air quality monitoring station. When you look at the data to see where the heavy metals are coming from - it points across the street to the Lehigh Southwest Cement. The highest lead levels detected at Fred Meyer were when the monitoring station was directly downwind of Lehigh. Lehigh Cement was upwind of the monitoring station for 51 days out of 104 - This means that the data that the DEQ is referring to to make decisions is based mostly on the heavy metals from Lehigh Cement. The problem is that the Lehigh Cement is adding fly ash to the concrete. Fly ash is coal ash. If you look at the air sample data, you will see the same ratio in heavy metals in fly ash as whit is detected. The data also shows that particulate is being lofted into the atmosphere via the same physical processes as dust storms - higher the wind velocity, higher the concentration of particulate. The air sampling data is consistent with cement dust being kicked up by the wind. The data is not consistent with chimney emissions. When is the DEQ going to do some *real* science to solve this problem? When is the DEQ going to tell the parents of the kids at the daycare that their kids daycare is across the street from a hazardous waste treatment facility. Concrete is just one method to encapsulate contaminants - it's just in process across the street until water and aggregate is added to solidify it. The fly ash is just as hazardous as the fly ash that is regulated at the generator - probably explains the heavy metals in north Portland at CalPortland Cement. When id the DEQ going to tell people about the hazardous waste that is being treated in Portland. When is the State going to regulate the safe handling & transportation of fly ash? https://data.oregon.gov/views/54i7-gnrh/files/cd3696dc-b2d9-400c-bcfc-f2279424eed8?filename=wind-by-degrees.png&content_type=image%2Fpng
135 1617 Michelle Galli Galli.michelle@att.net Oregon I am a glass artist and have been following the news regarding air quality in the Portland area specifically relating to the glass factories. I am concerned about environmental health issues and support fair rules that allow these companies to continue to produce glass while decreasing harmful emissions. However, I am troubled by the focus solely on the glass industries when many nearby businesses are contributing and possibly are primary sources of these harmful emissions. I have been to Bullseye and Uroborus factories and they are both located in Industrial areas. Science should dictate the rules and not emotions. Wind direction on test days should be factored in the equation. I urge you to allow adequate time and to work with the glass companies to enable them to continue to produce this wonderful glass so many worldwide artists depend on as their medium to create beautiful art.
136 1651 Craig Merriman camerriman@gmail.com Washington There is really no way to proceed without all the facts about the air quality. Without wind direction & velocity data, you cannot effectively identify or rule out the sources of heavy metals detected at the daycare. DEQ needs to start over - DEQ needs to collect wind data at the same location and times the air sampling is done. DEQ also needs to understand that ambient air monitoring in an error - ambient air monitoring is typically employed in buildings with closed environments. For outside, wind data is imperative as the atmosphere is dynamic. When wind direction & velocity data is compared to the air sampling data - it indicates that the highest heavy metal concentrations detected at the daycare came from nearly 40 degrees south of Bullseye Glass - the location of Lehigh Southwest Cement. Lehigh is within 100' feet of the monitoring station with a huge footprint - meaning that anytime the wind is from 285 through 325, the air monitoring station is downwind. Wind direction and velocity data indicate that the air monitoring station was downwind of Lehigh for 51 out of 104 days sampled - about 6 days it was downwind of Bullseye Glass.

Similar pattern Powell Park & 22nd - Monitoring station is only downwind for a few days out of 104.

The detected levels are quite different between the two stations. All things being equal, then the detected levels should be similar or closer than they are. The reason for the discrepancy is that Powell Park monitoring station is farther away from Lehigh.

It's not possible to engage in rulemaking without *all* the facts. The proposed rules will do nothing to reduce the heavy metals being lofted into the atmosphere at Lehigh. The infants & children under 5 will still be in harms way. This IS the reason why wind direction & velocity data is critical. The health & safety of children is at stake. DEQ must get it right the first time. STOP - START OVER COLLECT WIND DATA.		 https://data.oregon.gov/views/54i7-gnrh/files/465aa1ac-6426-4a7a-9699-56dfe7ac4bdc?filename=daycare-cement.jpg&content_type=image%2Fjpeg
137 1652 Jere High jere.high@state.or.us Oregon Health Authority Oregon [received by email]
[contents of attachment pasted in]

Joe Westersund
811 SW Sixth Avenue
July 29, 2016
Dear Mr. Westersund,

The Oregon Health Authority (OHA) has partnered with DEQ throughout the rule-writing process and is supportive of the approach that DEQ is taking with art glass manufacturers. As DEQ knows, OHA has initiated a process to review and revise the 24-hour screening levels for multiple air toxics, including hexavalent chromium, with more scientific, external peer review and opportunity for public input. As DEQ used the existing 24-hour screening level for hexavalent chromium as the daily acceptable source impact level in the art glass manufacturing rule, this revision process may be relevant to this rule.

Unfortunately, OHA will not be able to complete this 24-hour screening level review process before DEQ proposes new art glass rules to the Environmental Quality Commission. However, hexavalent chromium is one of the metals that OHA is particularly concerned about in terms of the existing 24-hour screening level. In order to ensure that the daily acceptable source impact level in the permanent rule is protective of health, OHA recommends that sections 2, 3(b)(C)(ii), and 4 of rule 340-244-9040 be modified such that the daily acceptable source impact level is revised from 36 nanograms per cubic meter (ng/m3) to 5 ng/m3. This value of 5 ng/m3 is the intermediate minimal risk level (MRL) established by the Agency for Toxic Substances and Disease Registry (ATSDR) (http://www.atsdr.cdc.gov/toxprofiles/tp.asp ?id=62&tid=17).

Intermediate MRLs are designed for exposures that are longer than two weeks, but less than one year. This intermediate MRL is based on a study in which workers were occupationally exposed to hexavalent chromium in the form of chromic acid aerosol mists. At concentrations 400 times higher (2,000 ng/m3) than the proposed 5 ng/m3, observed health effects included nasal irritation, mucosal atrophy, and decreased measures of lung function. While the shortest duration exposures included in the study were 0.1 years (-36 days), it was not clear in the study whether the health effects observed began when the workers first started working there or whether it took the full 36 days for the health effects to occur. Therefore, applying a 24-hour averaging time to this intermediate MRL is reasonable and health protective. The short-term toxicity of chromic acid aerosol mists is much greater than the short-term toxicity of other forms of hexavalent chromium, such as sodium dichromate particulates. ATSDR's intermediate MRL for sodium dichromate is 300 ng/m3. Because there is uncertainty about which form of hexavalent chromium is present in ambient air surrounding art glass manufacturing facilities, OHA is recommending the MRL for the more toxic form out of an abundance of caution. This effectively assumes that 100% of the hexavalent chromium contributed to ambient air by art glass manufacturers is in the form of the more toxic chromic acid aerosol mist.

Because of these layers of conservativism/health protectiveness, a 24-hour ambient monitoring sample result higher than 5 ng/m3 of hexavalent chromium should not automatically be construed to mean that acute or immediate health effects are imminent or expected. ATSDR's stated use ofthis number is for exposures that last longer than two weeks, but less than one year.

As OHA's process to review and revise 24-hour screening levels for multiple contaminants, including hexavalent chromium, progresses, it may be possible that a different 24-hour screening level for hexavalent chromium will be published. It is very unlikely that the final value would be any less than the 5 ng/m3 recommended here for the purposes of this rule.

Sincerely,
Jere High, ND
Administrator, Center for Health Protection
Public Health Division		 \\deqhq1\rule_development\Currrent Plan\AQ-Art Glass 2016 - Westersund\5-Public comment and testimony\comment attachments\OHA.pdf
138 1653 Thomas Wood   Stoel Rives Oregon received in hard copy \\deqhq1\rule_development\Currrent Plan\AQ-Art Glass 2016 - Westersund\5-Public comment and testimony\comment attachments\Stoel Rives.pdf
139 1654 Chris Winter chris@crag.org CRAG Law Center Oregon received by email \\deqhq1\rule_development\Currrent Plan\AQ-Art Glass 2016 - Westersund\5-Public comment and testimony\comment attachments\CRAG law center.pdf
140 1655 Cecilia Youngs cyoungs@yoakum.com CECILIA Y. YOUNGS, ATTORNEY AT LAW Washington received by email \\deqhq1\rule_development\Currrent Plan\AQ-Art Glass 2016 - Westersund\5-Public comment and testimony\comment attachments\Cecilia Youngs.pdf
141 1656 Donald Dossett   US EPA Washington received by email \\deqhq1\rule_development\Currrent Plan\AQ-Art Glass 2016 - Westersund\5-Public comment and testimony\comment attachments\EPA.pdf
142 1657 Joanne Fuller   Multnomah County Oregon received by email \\deqhq1\rule_development\Currrent Plan\AQ-Art Glass 2016 - Westersund\5-Public comment and testimony\comment attachments\Multnomah County.pdf
143 1874 Jim Scheller jim@jimscheller.com Self Oregon I encourage you to look carefully at the research done for you by Craig Merriman where he overlays wind data to the data you are collecting at the Day Care. He has sent it to you. This science indicates a likely source of continued high levels of CrVI.

It has become to easy for you to use Bullseye to move all eyes away from the poor job you are doing and keeping the pubilc hate going by headlining Bullseye. This political inspired move will backfire on your boss, appointed Governor Kate Brown, come November.

Oh, and what have you done lately on the other hotspots you got from the Forest Service moss data you demanded? You have been silent on that.
144 1875 Sarah Wilkinson Snkonk@pdx.edu Parents of SE Portland Oregon. MY DAUGHTER'S HEALTH!!! THE HEALTH OF FUTURE GENERATIONS IN PORTLAND.

- Close loopholes that would allow for emissions of heavy metals from uncontrolled furnaces
- Apply to all heavy metals by September 1st.
- Both filterable and condensable hazardous emissions must be controlled at 99.9% capture
- Apply state-wide
- Apply to all glass manufacturers not just those that produce 10 tons per year.
- Would ensure public notice and comment instead of locking the public out of DEQ decisions.
- Rules would cover all heavy metals and HAPS.
- We are tired of getting poisoned and need to hold DEQ accountable.
- Have true HEALTH BASED STANDARDS when determining concentration levels
145 1876 Joanne Fuller joanne.fuller@multco.us Multnomah County Health Dept Oregon see attached-not clear if document is being attached https://data.oregon.gov/views/54i7-gnrh/files/c1253850-8130-421a-8d42-244f08140cfc?filename=Comments+on+Manufacturer+RulesMultcoFinal.pdf&content_type=application%2Fpdf
146 1925 Craig Merriman camerriman@gmail.com Washington Graphical depiction of wind direction data from May 8, 9, 10. Wind direction & velocity data do not support the DEQ folk theory about the sources of heavy metals in SE Portland. Today, Flint reminds us why is it critically important to use sound scientific methods when dealing with lead exposure.

Who is responsible for this? There needs to be some accountability at the DEQ. How can the State govern effectively without all the facts? 		https://data.oregon.gov/views/54i7-gnrh/files/a5bdedc1-a026-485a-8858-22275c16cc61?filename=wind-dir+copy.png&content_type=image%2Fpng
147 1945 Craig Merriman camerriman@gmail.com Washington This is the info graphic I intended to include in previous comments.

When wind data is compared to the air sampling data, it shows for example, the winds on 5/9/2016 were from 299 from 8 to 25 mph. The day preceding, 314, the day after 308. Wind direction and velocity data indicate that the source of lead detected near the daycare was from Lehigh Southwest. Encapsulating toxins in concrete is one method of hazardous waste treatment. Fly ash is added to improve performance. Sampling data detected a similar rate of occurrence of heavy metals.

Because no wind data was collected or analyzed, this has led to the perpetuation of folk theory as fact. DEQ needs to get all the facts first. This is why it is necessary to STOP & START OVER.

No wind data is a HUGE error. How can you say for sure where things are coming from when you have this daycare that is jutting into industrial zoned land - or, a target rich environment. It's imperative that the DEQ either identify or rule out sources in this environment.

Impossible to engage in rulemaking with shoddy science.		 https://data.oregon.gov/views/54i7-gnrh/files/182a2f9c-dd79-4d80-b6e9-0f2b94a4fd27?filename=wind-by-degrees.jpg&content_type=image%2Fjpe
148 1946 Jody Bleyle bleyle@gmail.com Eastside Portland Air Coalition OR Please create standards that are protective of human health. Health-based standards. Not tech-based or risk-based, but health-based.

Please close all loopholes that allow emissions of ALL heavy metals and HAPS from uncontrolled furnaces.

Please apply these rules statewide to all glass manufacturers, not just those that produce 10 tons a year.



149 1947 Chris Winter chris@crag.org CRAG Law Cener Oregon I have attached a set of group comments from fifteen social justice and environmental organizations. Thank you. https://data.oregon.gov/views/54i7-gnrh/files/64476b17-ebe2-433b-9b67-d570962f0e49?filename=7-29-16+Final+Group+Comments+on+CAGM+Rule.pdf&content_type=application%2Fpdf
150 1948 Laura Raymond karlaura@comcast.net Community member Oregon My family and I have lived less than a mile from Bullseye Glass for the past 10 years and our daughter and niece have spent 11 (combined) years attending Winterhaven and Cleveland, with a (combined) 6 years left at Cleveland) – every day breathing highly-polluted air. Since moving here, our family has experienced worsening health issues common in people exposed to the pollutants Bullseye Glass has used, completely unfiltered. Many community members have decades-longer exposures. There is no defensible reason that our family and community should be paying for a lack of proper filtration with our current and future health – particularly now that we are all aware of the magnitude of these exposures.

I urge DEQ to adopt the strongest possible emissions rules to put a halt to these exposures, from glass-makers, and all industries that release HAPs. We need true health-protective standards, created from the best-available data, with a foundation in the Precautionary Principle that requires polluters to eliminate or greatly minimize health risks (even probable risks) with best-available technology, and for the polluters to pay that cost – not the community. I urge DEQ to:

1) Close any and all loopholes that would allow for emissions of heavy metals from uncontrolled furnaces;
2) Apply the rules to ALL heavy metals and HAPs by September 1, 2016;
3) Require that both filterable and condensable hazardous emissions be controlled at 99.9% capture;
4) Apply the rules to all glass manufacturers, not just those that produce 10 tons per year;
5) Ensure consistent public notice and commenting, instead of locking the public out of DEQ decisions; and
6) Apply these new rules state-wide, not just in Portland and not just around the two glass companies these current rules are targeting. DEQ has state-wide jurisdiction; it does not make sense to adopt different rules for the Metro-area or specific neighborhoods, which has great potential to further fuel environmental injustice.

We are holding DEQ, our political leaders, and industry accountable for our health. Do the right thing, and do it now. Thank you.
151 1952 Cecilia Youngs cyoungs@yoakum.com Attorney at Law Washington  
152 1954 Robin Denburg denburg@riseup.net Richmond community Oregon I have high levels of heavy metals in my yard and air since I am 6 blocks from Bullseye glass. They have repeatedly shown they are not a good actor and I need DEQ's involvement to help protect my community's air and soil.

I would request you:
- Close loopholes that would allow for emissions of heavy metals from uncontrolled furnaces
- Apply this to all heavy metals by September 1st.
- Both filterable and condensable hazardous emissions must be controlled at 99.9% capture
- Importantly, the current rules only apply to a narrow geographic area - they should apply state-wide! Or if not then to all urban areas.
- The rules should apply to all glass manufacturers not just those that produce 10 tons per year. 9.9 tons is still a MASSIVE amount of emissions into the air of these toxic materials.
- Please also ensure public notice and comment instead of limiting the public out of DEQ decisions.
- I would like the rules to cover all heavy metals and HAPS.

- Have real health based standards when determining concentration levels that are protective of human health
- Use the precautionary principle.

Thank you. I would welcome the permit writers response to see if you feel these are reasonable. I very much hope they are all incorporated on this critical issue that is impacting many people's lives.
153 1957 Emily Von W Gilbert bigemily@gmail.com Or I want to state my support for ALL suggestions made by the East Portland Air Quality workgroup, that surely do not need to be restarted here. I look forward to hearing about your concrete steps in the right direction for the community as a whole instead of for the business minority.
154 1963 Craig Merriman camerriman@gmail.com Washington How does the DEQ reconcile the placement by the moss study of the hotspot around Uroboros Glass west of the glass factory considerably? Is there hazardous waste being treated by CalPortland cement along the Willamette? Wind direction & velocity data is needed to identify or rule out sources https://data.oregon.gov/views/54i7-gnrh/files/ad340430-85ac-4364-96b4-aed6158dc07e?filename=cal-portland-uroboros.jpg&content_type=image%2Fjpeg
155 1964 Brian Jacobs brianj@northstarglass.com Northstar Glassworks Oregon   https://data.oregon.gov/views/54i7-gnrh/files/8e28561a-3d9d-4fc0-b87d-f1c954fb5509?filename=160720_Resp_DEQ_Req_Other_Opt%28v06-text%29.docx&content_type=application%2Fvnd.openxmlformats-officedocument.wordprocessingml.document
156 1968 Abe Fleishman abef@northstarglass.com Northstar Glassworks Oregon see attachment [submitted by email]

Oregon Department of Environmental Quality
Attn: Joe Westersund
811 SW Sixth Avenue
Portland, OR 97204-1390

RE: Art Glass Permanent Rules 2016

Public Comment on DEQ’s Rulemaking Proposal

As it Pertains to Northstar Glassworks, Inc.

Dear Mr. Westersund:

Northstar Glassworks, Inc. (Northstar) presents this letter of comments to Oregon Department of Environmental Quality’s (DEQ’s) proposed Art Glass Permanent Rulemaking 2016.

Background
DEQ’s Questions are provided in italicized text, and Northstar’ responses are provided in regular text below:
1. Should the rule be modified to apply to sources that make less than 10 tons per year of colored art glass?
o Yes, the rule should be modified to apply to all sources of hazardous air pollutants (HAPs), ideally, regardless of the amount produced. However, if a threshold is needed, we suggest that the rule apply to manufacturers of greater than 500 pounds of colored art glass per year. This would prevent smaller, unregulated, colored art glass manufacturers from starting up in lieu of the larger, tiered regulated manufacturers. This modification would be consistent with the goal of reducing the amount of HAPs being discharged to the atmosphere.
o Northstar Glassworks has worked with activists. DEQ and the EPA to better understand what goes on in our manufacturing process. The reason for Northstar recommending a lower threshold for tons produced per year is that it leave a large loophole for smaller manufactures to pollute. The main reason of these rules is to lower air toxics in the air in Portland and hopefully reduce the health concerns to the public. Also by NOT lowering the threshold of glass produced it could give any manufacture the chance to just have smaller facilities for producing just enough to skirt the rules all together. It is DEQ’s executive responsibility to protect the health and environment we live in. Please do not leave loopholes that could affect companies and the health of the public.

2. Should the rule be modified to apply statewide, rather than only in the Portland AQMA?
o Yes, the rule should be modified to apply to colored art glass manufacturers throughout the State. Such an action will prevent tiered colored art glass manufacturers from relocating to unregulated areas of the State, to avoid the cost of complying with the rules. This action would be consistent with the goal of reducing the amount of HAPs being discharged to the atmosphere.

3. The temporary rule requires control devices be shown to capture at least 99.0% of incoming particulate matter. DEQ has received indications that, for some facilities, capturing enough particulate matter to show compliance with the 99.0% requirement may require an unmanageably long source test. DEQ seeks comment on whether replacing the 99.0% capture efficiency standard with an emissions standard at the control device outlet would be appropriate for Tier 1 or all facilities and if so, what emissions standard should be chosen.
DEQ is considering a control device outlet particulate matter emission standard between 0.001 and 0.01 gr/dscf (grains per dry standard cubic foot of air) based on a range of emissions standards in federal air toxics rules.

o Our estimates indicate that insufficient PM would be collected over a 24-hr test period to achieve DEQ’s Method Quantitation Limit (MQL) of 7 milligrams (mg). Working backward, we would need over 700 mg at the inlet (or 2.3 lbs/hr, assuming a 24 hr sample duration) to show 99.0% removal, as shown below:

1-0.99 x PM = 0.01 x PM = 7 mg; PM = 7 mg/0.01 = 700 mg,
assuming:
Typical sampling rate of 16L/min (1 m3/hr)
Sample volume = 1 m3/hr 24-hour test duration = 1
m3/hr x 24 hr = 24 m3
Total mass to accumulate over 24-hour sample duration
(700 mg)
An inlet concentration of 30 mg/m3 (700 mg collected
at a rate of 1 m3/hr)
Which is equivalent to 0.013 gr/dscf, assuming
0.015 grains/mg)
A stack flow of 20,000 cfm (566 m3/min)
Calculated necessary minimum emission rate
266 gr/min, or
15932 gr/hr, or
2.3 lbs/hr, assuming 7000 grains/lb
Northstar Glassworks is estimated to produce no more than 10 lbs PM per month, 0.33 lb/day, or 0.014 lb/hr [6,300 mg/hr]), the majority of which is from glass crushing operations. Thus, the inlet PM is approximately 0.6% of the mass needed to meet a 99% efficiency standard using DEQ’s Method 5 MQL of 7 mg.
Although the method quantification limit in inlet PM in EPA’s method is better (3 mg), the inlet PM is only approximately 1.4% of the mass
needed to meet a 99% efficiency standard.
o Given the low inlet mass at Northstar, it is impossible to conduct a PM efficiency test that is long enough duration to meet the MQL for DEQ’s Method 5 or EPA’s Method 5; however, the estimated costs to conduct these tests ranged between approximately $40,000 to over $80,000, and are nearly one week in duration. Running a longer duration test, e.g., over a month long period, would introduce greater potential for error, increase costs significantly ($300k to $400k), but still not guarantee a successful test. None of the laboratories will guarantee results. All of these options are cost-prohibitive for a Tier I manufacturer of colored art glass. Therefore, Northstar strongly supports replacing the 99.0% capture efficiency standard. The following replacement emissions standards, listed in descending order of preference, are proposed:
- A standard tied to the efficiency of the baghouse fitted with a particular set of filters, i.e. 99.0%. No efficiency testing is proposed. Rather, we will rely on factory efficiency test data and the fact that baghouses are a time-proven technology.
- A device outlet particulate standard of 0.01 gr/dscf. This could be achieved using either DEQ Method 5 or EPA Method 5, and it is normally done with three (3) one-hour test runs that can be completed in one day with a crew of two technicians.
- A device outlet particulate standard of 0.001 gr/dscf. This could be achieved using either DEQ Method 5 or EPA Method 5, and it is
normally done with three (3) two-hour test runs that can be completed in one day with a crew of two technicians.
Northstar also recommends that DEQ add Cadmium to the list of materials that cannot be used in unfiltered hoods/furnaces for tier 1
manufactures. Cadmium is very toxic and we believe that Cadmium volatizes at more than 75 percent. By DEQ adding cadmium to the list of raw materials this would help protect the public and also NOT leave a loophole that could cause potential health concerns in the future.
We also would like to have DEQ lower the costs involved with the discharge permits to tier 1 manufactures. The costs for tier 1 manufactures are almost more the tier 2 manufactures to comply with the regulations when we are much smaller. Tier 1 manufactures have never been noted as polluters and have not been inspected in that manner either. After dealing with the costs to comply with the new regulations Northstar believes that costs for the permit should be NO more than 2-4,000 per year.

Kind regards,

Paul M. Trone, R.G.
Principal Geologist, EVREN Northwest
Abraham Fleishman
President, Northstar Glassworks, Inc.		 https://data.oregon.gov/views/54i7-gnrh/files/fe46aa36-98c1-4341-959f-836f145851ec?filename=E%3A%5CJoe%27s+Documents%5CAir+Toxics+Rulemaking+2016%5Ctemp+to+permanent%5C4%29+public+comments%5Cerror+reports%5Ccomments+that+need+to+be+manually+included%5C160
157 1969 James Knox jamesk@northstarglass.com Northstar Glassworks Orgeon [text in attachment pasted into body]
In March of this year we learned that there was an active issue with air pollution in the city of Portland. Focus quickly centered on what is representative of a fraction of industry in the city, that being colored art glass manufacturing. While Northstar Glassworks, as a tier one manufacturer, does not currently use nickel, arsenic, lead or hexavalent chromium we do utilize cadmium. Despite operating
below the safety benchmark for this metal we decided to stop all cadmium glass production at that time. We do recognize the dangers related to elevated levels of cadmium in our environment and strongly suggest this metal be added to the list of regulated emissions. This was a proactive response towards a health based standard for industry and we immediately began the engineering for our
solution to this problem, ahead of any legislation or mandates issued by the city or state level. Since then we have been witness to temporary rules that are clearly industry based as well as a runaway system of rule making that fails to achieve the stated goal. In our estimation, these rules were written to get the issue off the front page news and to placate the public into thinking the issue of air pollution in Portland had been easily solved. It is obtuse for the DEQ to believe this issue properly handled while not taking into account other industry in Portland such as plating manufacturers, metal fabrication plants, diesel truck emissions, railroads or bottling manufacturers. In the least, establishing a protocol for discovery regarding the existing benchmark levels of pollution outside of colored art glass manufacturing is needed for the safety of public health.

An example of the industry based approach used by the DEQ is the creation of a limit by weight of totallbs. of glass produced before said regulation takes effect. This has been set to 10,000 tons regardless of the composition of the glasses produced. What we are most concerned with ;is how much toxic metals are in the air as an aggregate, not by just limiting the size of one manufacturer. It would be in my benefit, in this case as a glass manufacturer, to create a network of satellite production facilities which would handle all of our toxic metals and maintain the less than 10,000 tons a year threshold, effectively skirting the nature of these regulations. Colored art glass manufacturers, and for that matter, any facility releasing these metals into the air needs to b.e regulated to meet the true nature of health
based standards. The only difference for a "smaller" manufacturer would be the scale of the emission control device required.

There has been a significant amount of education for the regulatory, manufacturing and civic parties in this process. Learning to identify the present dangers as well as how to respond and regulate them have come so fast that some technical aspects of how to do this have been developed without enough information do so efficiently or correctly. This is present particularly in the source testing recommended by the DEQ to the EQC and written into the temporary rules. As it stands, Tier 1 manufacturers would be relegated to the "99% requirement" source test that is not only unsound but ineffective. Under the "99% requirement" testing method we will be collecting sample air on the inlet to our hoods as well as to the outlet of the emission control device and would take no less than 30 days to do so. In the procedure of this testing method Northstar Glassworks will be held accountable for the existing unsafe levels of pollution related to our neighboring industries (railyard, diesel shipping, plating manufacturers, metal fabrication shops and bottling manufacturers). A much simpler and effective "grain load" test which has been suggested by our environmental consultant as well as the manufacturers of the emission control device would measure the output of metals from our factory while yielding no margin of safety to the "99% requirement". In addition to holding the same benchmark for safety the "grain load" test would take less than one day and represent a much more effective and accurate method in which to safeguard the community in which we live and work.

I urge the DEQ and EQC to work with industry as well as the public, utililizing our combined experience and knowledge, to address this issue creating health based standards while implementing effective and timely resolutions to resolve the air pollution problem in our city.

Thank you for your consideration

James Knox
General Manager
Northstar Glassworks
8228 SE 261h Place
Building A
Portland, OR 97202
866-684-6986 Toll Free
503-684-6986 Phone
503-670-0978 Fax		 https://data.oregon.gov/views/54i7-gnrh/files/6a8588ac-d7f2-45f1-8ac6-3c001d4e2d89?filename=Jame%27s+DEQ+Commentary0001.pdf&content_type=application%2Fpdf
158 1972 Elizabeth LeDoux 26ledoux@gmail.com Oregon - Close loopholes that would allow for emissions of heavy metals from uncontrolled furnaces
- Apply to all heavy metals by September 1st.
- Both filterable and condensable hazardous emissions must be controlled at 99.9% capture
- Apply state-wide
- Apply
159 1973 Jennifer Jones Jennifer@eastsideportlandair.org Eastside Portland Air Coalition Oregon I hope the DEQ is panicking as much as neighbors over the recent realization that even filtered emissions are not trapping all the cr6 pouring into the SE neighborhood surrounding bullseye glass.

DEQ MUST close the loopholes that allow for emissions of heavy metals from controlled and uncontrolled furnaces.

These rules must apply state-wide and to all glass manufacturers not just those that produce 10 tons per year.

The rules must apply to all heavy metals and HAPS before September 1st and ensure public notice and comment instead of locking the public out of DEQ decisions.

The rules must have true HEALTH BASED STANDARDS when determining concentration levels that are protective of human health.
160 1975 Thomas Wood tom.wood@stoel.com Stoel Rives LLP Oregon Attached is letter dated 7/29/16 to ODEQ from Thomas R. Wood of Stoel Rives

July 29, 2016

VIA MESSENGER
Oregon DEQ
Attn: Joe Westersund
811 SW Sixth Avenue
Portland OR 97204-1390

Re: Art Glass Permanent Rulemaking 2016

Dear Mr. Westersund:

Thanks you for the opportunity to comment on the proposed permanent art glass rule. I am writing out of concern for the impact that the proposed language will have on small Tier 1 art glass manufacturers. Proposed OAR 340-244-9070(1) requires that emission control devices
used to meet this rule achieve minimum 99.0% removal efficiency for particulate matter as measured by EPA Method 5 or equivalent method approved by DEQ. This requirement in and of itself is reasonable as a fabric filter or cartridge filtration unit should be capable of meeting this requirement. However, proposed OAR 340-244-9070(2)(h) requires that a Tier 1 art glass manufacturer perform inlet and outlet testing on the control device using DEQ Method 5. This rule language poses several problems.

First, the control efficiency requirement is properly stated in 9070(1) relation to EPA Method 5 which evaluates filterable particulate. However, 9070(2)(h) states that testing must use DEQ Method 5. There is no basis for requiring testing under 9070(2)(h) using DEQ Method 5 which includes condensable particulate. 9070(2)(h) should require testing using EPA Method 5.

Second, the rule is not clear as to the point of the testing required by 9070(2)(h). If the test is intended to document the removal efficiency, then the rule needs to say so. If the point of the test is simply to generate data on what the pre- and post-control emissions are, then the rule should say that.

Third, if the point of the 9070(2)(h) test is to document the removal efficiency, then the requirement is unworkable. Many of the small Tier 1 art glass manufacturers emit very little particulate pre-control. Once that particulate is passed through a control device meeting 99.0+%
control efficiency, it will be reduced to nearly nothing. Obtaining the 7 mg minimum sample mass required under the Oregon Source Sampling Manual (Section 2.8.b) on the inlet, let alone the outlet, of the control device would require a length of test run that for all practical purposes is impossible.

For these reasons, we encourage DEQ to revise the rule to specify that a source test of the control device is required under 9070(2)(h), but specify that it is an EPA Method 5 test with run time capped at 2 hours or 31.8 dscf sampling volume, whichever is shorter. If that length of test run does not generate enough particulate on the filter to be measurable, then the control device has clearly been demonstrated to be performing its job.

Please contact me if you have any questions about this comment.

Sincerely,

Thomas R. Wood		 https://data.oregon.gov/views/54i7-gnrh/files/fc6352b4-bda6-466d-b1eb-0f601bd0aab5?filename=2016-07-29+Letter+from+Stoel+Rives+to+ODEQ+re+Art+Glass+Permanent+Rulemaking+2016.pdf&content_type=application%2Fpdf
161 1977 Laura Raymond karlaura@comcast.net Oregon My family and I have lived less than a mile from Bullseye Glass for the past 10 years and our daughter and niece have spent 11 (combined) years attending Winterhaven and Cleveland, with a (combined) 6 years left at Cleveland) every day breathing highly-polluted air. Since moving here, our family has experienced worsening health issues common in people exposed to the pollutants Bullseye Glass has used, completely unfiltered. Many community members have decades-longer exposures. There is no defensible reason that our family and community should be paying for a lack of proper filtration with our current and future health particularly now that we are all aware of the magnitude of these exposures.

I urge DEQ to adopt the strongest possible emissions rules to put a halt to these exposures, from glass-makers, and all industries that release HAPs. We need true health-protective standards, created from the best-available data, with a foundation in the Precautionary Principle that requires polluters to eliminate or greatly minimize health risks (even probable risks) with best-available technology, and for the polluters to pay that cost not the community. I urge DEQ to:

1) Close any and all loopholes that would allow for emissions of heavy metals from uncontrolled furnaces;
2) Apply the rules to ALL heavy metals and HAPs by September 1, 2016;
3) Require that both filterable and condensable hazardous emissions be controlled at 99.9% capture;
4) Apply the rules to all glass manufacturers, not just those that produce 10 tons per year;
5) Ensure consistent public notice and commenting, instead of locking the public out of DEQ decisions; and
6) Apply these new rules state-wide, not just in Portland and not just around the two glass companies these current rules are targeting. DEQ has state-wide jurisdiction; it does not make sense to adopt different rules for the Metro-area or specific neighborhoods, which has great potential to further fuel environmental injustice.

We are holding DEQ, our political leaders, and industry accountable for our health. Do the right thing, and do it now. Thank you.
162 1980 Joanne Fuller joanne.fuller@multco.us Multnomah County Health Dept Oregon see attached-not clear if document is being attached https://data.oregon.gov/views/54i7-gnrh/files/ada5d266-c035-4be9-bdd7-f0a226c7c9d7?filename=Comments+on+Manufacturer+RulesMultcoFinal.pdf&content_type=application%2Fpdf
163 1982 Jen Davis Weallneedbees@gmail.com Bee Friendly Portland OR - Close loopholes that would allow for emissions of heavy metals from uncontrolled furnaces
- Apply to all heavy metals by September 1st.
- Both filterable and condensable hazardous emissions must be controlled at 99.9% capture
- Apply state-wide
- Apply
164 1984 Madonna Narvaez narvaez.madonna@epa.gov USEPA, Region 10, Office of Air and Waste Washington These are Region 10's technical comments on the Art Glass Final Rule 2016. https://data.oregon.gov/views/54i7-gnrh/files/7cd93fc3-2ee2-42c3-a84d-eba2dab0796e?filename=EPA+Comments+on+OR+ART+Glass+Final+Rule+2016.pdf&content_type=application%2Fpdf
165 1988 Laurie Adams Laurieadams101@yahio.com Citizen Oregon I am concerned and frustrated that in the place of hard science and unbiased research, DEQ is more committed to exercising strong-arm techniques and pushing politics during an election year. At the beginning, you came out stating the fault was Bullseye Glass and dismissing any other sources. Little if any investigation was given to other industrial companies. Furthermore, you are blatantly discounting wind speed, direction and local excavation. I am truly appalled at the direction this agency and our state government have taken. This is an example of strong arm politics and political grandstanding.
166 1989 Kathryn VanNatta kathryn@nwpulpandpaper.org Northwest Pulp & Paper Assn. OR NWPPA comments are attached. Thank you for the opportunity to comments. https://data.oregon.gov/views/54i7-gnrh/files/4a17ae89-9aeb-4f85-aee9-b9e7fdbafd3a?filename=NWPPA+Comments+Art+Glass+AQ+Rules.pdf&content_type=application%2Fpdf
167 1996 Joanne Fuller joanne.fuller@multco.us Multnomah County Health Dept Oregon [text of attachment pasted in]

July 29, 2016
Interim Director Pete Shepherd
Oregon Department of Environmental Quality
811 SW 6th Avenue, Portland, OR 97204

RE: Comments on Colored Art Glass Manufacturer Rules

Temporary rules pertaining to colored art glass manufacturers (CAGMs) were enacted after USFS moss samples and subsequent ambient air monitoring found elevated levels of heavy metals near two glass manufacturing facilities in the Portland metropolitan area. These rules
were designed to address the immediate risk presented by the emissions from these facilities. At the time of the discovery, one of the facilities was operating completely within the scope of their permit, and the other was below the production threshold requiring a permit. This indicated a gap in the regulatory framework designed to protect our air, indicating the need for temporary rules to address the emissions.

These rules are set to become permanent following the close of the public comment period at 11:59 PM on 7/29/16. The following represents the County's input on these rules.

• The rules should cover the entire state
o Currently, these rules apply to facilities within the Portland Air Quality Maintenance Area. This solves the immediate problem locally, but leaves a gap in regulation until permanent rules are put forth through the Cleaner Air Oregon process. We understand that all major producers in the state (of more than 10 TPY) are located within the Portland AQMA, but urge DEQ to move quickly to address emissions from all CAGMs in the larger rulemaking process.

• Any glassmaking furnace charged with heavy metals should be equipped with pollution controls
o The proposed rules restrict the use of certain metals in larger facilities, which is intended to decrease risk from airborne exposure to nearby receptors. Specifically, the metals indicated cannot be used in uncontrolled furnaces. They include arsenic, cadmium and chromium(VI). (Lead, nickel, selenium, cobalt and manganese are also restricted at Bullseye, via the company's MAO with DEQ).
O DEQ's own testing indicate that the majority of chromium(lll) charged in a glassmaking furnace converts to chromium(VI) in the emissions profile. There should be no acceptable usage of chromium in any uncontrolled furnace, and furthermore, in any controlled furnace that has not demonstrated an adequate removal efficiency that would be protective of public health at the nearest receptor.
O We believe there should be a complete review of materials used by these and other glass facilities to ensure all potentially hazardous air toxics are being addressed through these rules.

• Chromium should not be permitted in any furnace, with or without pollution controls, until those controls have demonstrated to be effective
o The rules allow for DEQ to set a maximum allowable usage rate of chromium(lll) in uncontrolled furnaces.
O Existing (and new stack testing) data indicate that the majority of chromium(lll) charged in a glassmaking furnace converts to chromium(VI) in glassmaking emissions. There should be no acceptable usage of chromium in any uncontrolled furnace, and furthermore, in any controlled furnace that has not demonstrated an efficiency of removal at a level that would be protective to public health at the nearest receptor.

• Facilities producing less than 10 TPY should not be exempt
o CAGMs producing less than 10 TPY are under the threshold requirements for these rules.
O We understand the need to set a reasonable threshold for regulation, but 10 TPY seems like a production rate that could result in unacceptable HAP emissions. Given the proximity of some of these smaller facilities to neighborhoods and human receptors, it seems prudent to lower the threshold to ensure public health is protected. Moss data indicating the presence of heavy metals in the Cully
Neighborhood, in close proximity to Glass Alchemy, suggests that lower thresholds are needed. We urge DEQ to take a precautionary approach.

• Thresholds should be determined through stack emissions testing, not by fuel or furnace type
o An electronically fired furnace producing 100 TPY falls under the Tier I threshold, while a fuel fired furnace producing 10 TPY is subject to Tier II requirements. Electrically fired furnaces are understood to have lower "lost material" emission rates due to their flameless characteristic. However, are these emission reductions in an electronic furnace significant enough to warrant a facility producing 99.9 TPY being characterized a Tier 1, and a similar facility with a gas fired furnace producing 1 0 TPY being subject to Tier 2 requirements?
O We urge DEQ to lower the threshold for electronically fired furnaces to a level that would ensure emissions rates do not exceed levels that would be harmful to human health. At a minimum DEQ should verify that the 100 TPY threshold for electrically fired furnaces is consistent with emissions rates from a fuel fired furnace producing 10 TPY and share with the public the evidence used in reaching this conclusion.

• Close any regulatory gap presented by the applicability of federal NESHAP glass manufacturer rules that are less protective than proposed State rules
o All Tier II CAGMs will be subject to applying for Title V operating permits and adherence to NESHAP 6S requirements- which stipulate PCD's on continuous furnaces producing more than 50 TPY.
O Will this exemption be allowed in Oregon within Title V CAGM permits, or will emission controls be required on all furnaces within Title V facilities charged with HAPs, regardless of individual furnace output?
O We would again urge DEQ to not allow uncontrolled release of HAPs from any furnace.

• Specify permitting and operational requirements that will be applied to facilities that are under the applicability thresholds of the proposed CAGM rules
o It is unclear what kind of operating requirements will be promulgated as a component of the ACDP's issued to a// CAGMs not otherwise subject to a permitting requirement beginning September 1, 2016.
o We understand that these will be part of the rules promulgated under Cleaner Air Oregon, and expect them to be protective of public health.

• Emissions control devices should be required to conform with best available control technology standards
o The requirement outlined in OAR 340-244-9070 states that emissions control devices must meet an efficiency rating of 99% or higher. EPA contends that a properly designed, run and maintained bag house (an effective PCD for this type of operation) is capable of 99.9% and higher efficiency- this should be the standard required. Additionally, reports of stack testing at Bullseye indicate that though these devices are highly effective at capturing particulate, they may not be as capable of capturing HAPs such as chromium(VI) when in gas phase. The
language in the permanent rule should be amended to require PCDs to achieve maximum efficiency of removal of HAPs of concern, not just particulate efficiency ratings.
O DEQ should implement further restrictions on the use of chromium compounds if available PCDs are shown to be ineffective at limiting chromium(VI) emissions.

• Set protective, science based and peer reviewed screening values for chromium compounds
o There is significant question on whether the 24 hour screening value chosen is sufficiently protective of public health. Specifically, the 36 ng/m3 24 hour screening value and its derivation has been a point of contention for the public, who believe it's not protective enough. Of the levels that were surveyed, Ontario recommends a far lower non-cancer endpoint number of 0.35 ng/m3 for a 24 hour screening value. This will continue to be an issue until a definitive value is ratified and agreed upon by all health agencies, and there will need to have scientific backing for its derivation.
O In the face of uncertainty we would urge DEQ and OHA to take a precautionary approach and opt for the most conservative chromium Ill maximum allowable usage rate and most conservative 24 hour screening value until a higher level is justified through scientific review.

• Ensure that the final rules are protective of public health and the environment
o The Policy and Purpose section of these rules states, "It shall be the policy of the Commission that no person may cause, allow, or permit emissions into the ambient air of any hazardous substance in such quantity, concentration, or duration determined by the Commission to be injurious to public health or the environment."
o We believe this is justification for a strong, health based approach to rulemaking, where industry should be required to prove that its emissions will not negatively impact the health and wellbeing of the communities they operate within.

Joanne Fuller, Director
Multnomah County Health Department		 https://data.oregon.gov/views/54i7-gnrh/files/90cc97da-0eb1-4fc1-81c3-2ee74239be42?filename=Comments+on+Manufacturer+RulesMultcoFinal.pdf&content_type=application%2Fpd
168 1999 Cecilia Youngs cyoungs@yoakum.com Attorney at Law Washington My comment attached. https://data.oregon.gov/views/54i7-gnrh/files/f3993279-bb59-4051-b510-99df07d70ae7?filename=LTR+to+EQC+07292016.pdf&content_type=application%2Fpdf
169 2004 Joanne Fuller joanne.fuller@multco.us Multnomah County Health Dept Oregon see attached-not clear if document is being attached https://data.oregon.gov/views/54i7-gnrh/files/028e3d0d-4df0-4367-b8fb-35ce0680e8ab?filename=Comments+on+Manufacturer+RulesMultcoFinal.pdf&content_type=application%2Fpdf
170 2005 Cecilia Youngs cyoungs@yoakum.com Attorney at Law Washington My comment attached. https://data.oregon.gov/views/54i7-gnrh/files/e57cf849-4214-4bdc-9d9b-5cee04edc608?filename=LTR+to+EQC+07292016.pdf&content_type=application%2Fpdf
171 2006 Ted Whitney tr_whitney@yahoo.com Oregon I am a glass and multimedia artist residing in Portland, Oregon. I have used glass manufactured by Bullseye and Uroboros for many years. I have the following comments on the proposed rules for colored art glass manufacturers.
1) The DEQ should close any and all loopholes that allow emissions of heavy metals from uncontrolled furnaces. All furnaces that emit HAP must have filters that filter 99.9% of ALL emissions. This should include condensable particulate matter.
2) Rules regarding heavy metal air pollutants should be applied state wide, not just on two companies in Portland.
3) All rules regarding HAPs emitted by colored glass manufacturers would apply to ALL glass manufacturers, not just the companies that produce 10 tons of glass per year. The separation of glass manufacturers into Tier I and Tier II is should not exist and contradicts the health-based regulation that Governor Brown has demanded.
4) The rules should apply to all heavy metals emissions by September 1, 2016. Implementing these rules at a later date will cause further harm to human health.
5) DEQ should ensure that there is always public notice and comment on all rules and DEQ should never leave the public out of the decision making process. Adequate and immediate public notice should occur for any air quality permitting in any Oregon neighborhood.
6) All rules and standards should be health, not technology, based. The current temporary rules are technology based and should be revised to be health-based.
7) Health based standards for emissions should make sense. For example, hexavalent chromium emissions are set at 0.08 ng/m3 annual maximum but the daily maximum limit of 36 ng/m3, when averaged over a year would exceed the annual maximum on EVERY SINGLE DAY OF THE YEAR. This regulation does not make sense. Re-write it so that it protects human health.
8) Add a clause to allow for future additions of other materials from glass manufacturing if they are found to exceed short or long term health health thresholds.
9) Set health limits for exposure that are based standards for those most at risk (e.g. children, elderly, health impaired) and take into account the proximity to residential neighborhoods, schools, daycares, and hospitals.
10) Accept the EPA view that 100% of Cr(III) converts to Cr(VI) in glass production.
11) Use facility limits, not furnace limits.
12) Increase fines for violations and require immediate shutdown of repeat offenders.
13) Monitor and restrict fugitive emmissions.
14) Incorporate an accumulative pollution approach to permitting for multiple industrial polluters in a small geographical area.
15) Continue long term air monitoring near glass factories.
16) Collect and maintain a list of all hazardous materials kept on site and used in glass furnaces.
172 2007 Katharine Salzmann   EPAC Oregon [summary of oral comment at 7/19/2016 public hearing]
Should regulate all heavy metals used by CAGMs. Health benchmarks should be more protective. There should be no uncontrolled emissions of any HAPs in Oregon.

Also submitted attachment in hard copy at public hearing		 \\deqhq1\rule_development\Currrent Plan\AQ-Art Glass 2016 - Westersund\5-Public comment and testimony\comment attachments\CRAG law center letter submitted by Katharine Salzmann at 7-19-2016 hearing.pdf
173 2008 Christopher Mini   Tabby Glass Oregon [summary of oral comment at 7/19/2016 public hearing]
Existing definitions could unintentionally regulate glass artists who do kiln work or glassblowing. These facilities reheat pre-made glass and don’t emit metal HAPs. Need better definition of ‘melt’ and ‘furnace’, and to not use term ‘molten glass’.

Also submitted attachment in hard copy at 7/19/2016 public hearing		 \\deqhq1\rule_development\Currrent Plan\AQ-Art Glass 2016 - Westersund\5-Public comment and testimony\comment attachments\Christopher Mini written testimony at 7-19-2016 hearing.pdf
174 2358 Cynthia Eckersley cynthia.eckersley@gmail.com EPAC Oregon Hello,
I tried to submit my comments via you website, with out any luck. I would like to submit the following as essential to the rules being rewritten by DEQ. I am part of the EPAC (East Portland Air Coalition) and live within 1/2 mile of Bullseye Glass.

1. Include ALL heavy metals and hazardous emissions for regulation, not just the 6 Federally regulated ones.
2. Make sure the health safety benchmarks are the most protective of human health they can be
3. Expand this rule to cover the whole state of Oregon
4. Apply the rules to all glass factories, not just art glass manufacturers
5. Require 99.9% capture rate on emissions control devices.

Please consider these recommendations seriously when rewriting the rules. Thank you very much.

Sincerely,
Cynthia Eckersle
175 2359 Sage Cohen sage@sagecohen.com Hello. Your website comments function is not working.

I would like to request that you:

1. Include ALL heavy metals and hazardous emissions for regulation, not just the 6 Federally regulated ones.
2. Make sure the health safety benchmarks are the most protective of human health they can be
3. Expand this rule to cover the whole state of Oregon
4. Apply the rules to all glass factories, not just art glass manufacturers
5. Require 99.9% capture rate on emissions control devices.

Thank you very much,
Sage Cohen
176 2360 James Knox   Northstar Glassworks Oregon [summary of oral comment at 7/19/2016 public hearing]
Rule should apply to all CAGMs, not just ones producing 10 tons/year. Rules should apply statewide or nationwide. 99.0% baghouse capture efficiency standard should be changed to a grain loading standard.
177 2361 Abe Fleishman Northstar Glassworks Oregon [summary of oral comment at 7/19/2016 public hearing]
Rule should apply to all glass manufacturers using metal HAPs, not just ones producing 10 tons/year. Rules should apply statewide or nationwide. 99.0% baghouse capture efficiency standard would cost ~$350k and should be changed to a more cost-effective test that measures actual emissions, like a grain loading standard. 65 to 85% of cadmium used in a glass batch volatilizes and cadmium should be more regulated than in the temporary rule
178 2362 Greg Pourget   Portland Clean Air Oregon [summary of oral comment at 7/19/2016 public hearing]
DEQ should regulate diesel emissions, Bullseye glass, other glass manufacturers like Owens Brockaway Glass and General Glass. Regulation should be health-based. DEQ should be more responsive and transparent.
179 1367 K Hamill voiceofathena@yahoo.com Oregon [text pasted in from attachment]

1. Permanent Rules should apply to all of ODEQ’s jurisdiction, not just Portland.
2. Should apply to all manufactures using raw metal HAPS, not just art glass.
3. DEQ has an obligation to craft clear rule language, and be capable of educating businesses and guiding them on coming into compliance with reasonable timelines and offering their support and expertise. No one benefits from shutting down businesses.

As a lifelong Portlander, I have a stake in the quality of our air. I also highly value art and all the positives the local glass community has brought to our city. That puts me in the middle of the current polarization between clean air advocates and glass supporters. There does NOT need to be sides. Urban pollution is complex, every man made product and convenience creates it. We need to first and foremost recognize we each contribute to the pollution problem and we each and every one of us need to work together toward reducing our environmental impact. Should CAGM’s take steps to reduce their emissions? Absolutely. And they are. And it’s up to DEQ and everyone who wants cleaner air to support those efforts – reduction of emissions from all sources.

If DEQ has determined the use of raw materials (Metal HAPS in their raw, non-vitrified state) used in glass making in an unfiltered furnace is a risk to public health – then it logically follows that risk is not geographically unique. If the rules are necessary, based on science, and fairly written. Then they should no doubt apply to all of ODEQ’s jurisdiction equally, not just Portland and not just art glass.

As for the threshold of tonnage produced, previously the two larger manufactures of art glass in Portland did not fall under EPA NESHAP since they use less raw metals than those rules limit as emissions. Simply, they were too small to matter. Apparently now, that was not sufficient and there is concern. DEQ is now proposing just creating a different bar, with exceptions again. In another decade will we be back where we are now with insufficient rules? If making permanent rules, carefully consider the long term.

Also, what is a “glass manufacturer”? There is a significant and clear difference between mixing raw materials in a furnace until they vitrify – to create glass - and the many studios and artisans that re-melt and form glass (sheet, cullet etc.) to create finished goods. Failure to define this difference could be more damaging than the question of the threshold amount. With that in mind, it seems any size manufacture (combining raw materials sand, soda, metal oxides etc., to create glass) that handles metal HAPS in their raw form should be regulated to some extent as to the safe handling of those materials and reducing potential furnace emissions.

DEQ needs to carefully and clearly craft its rule making language – much of the controversy in the initial rulemaking was due to the EPA’s failure to properly define a co-opted industry term, which to some created a “loophole” in the 2005 NESHAP rules. The terms “continuous” and “periodic” in the industry deal with the type of furnace and its ability to continuously output glass, the EPA has now recently redefined their use of the term to refer to the continuous firing of the fuel source, not the furnace construction or production. This poor use of regulation language has caused confusion and contention for all sides. For a simplistic explanation of the difference between continuous and periodic furnaces refer to this, page 6: http://www.lehigh.edu/imi/teched/GlassProcess/Lectures/Lecture03_Hubert_industglassmeltfurnaces.pdf



According to DEQ’s own PATS findings the metal air emissions in question that these temporary rules are supposedly addressing, are primarily emitted by other sources such as Diesel and mobile combustion, wood smoke, metal manufacture, and for some metals they are just naturally high in our area. Yet, a significant amount of DEQ resources is being squandered to address small glass manufactures, the two largest of which have already begun the process of installing filtration and will be soon brought under the EPA NESHAP Title V standards. In the interest of public health, why is DEQ using a majority of resources addressing a small fraction of the air quality problem? Again, the filtration currently being installed by CAGMs is absolutely necessary and important, but the continual focus on ‘just’ glassmakers is not addressing the big picture. Why not tackle limiting metal emissions from ALL sources in the permanent rules? Stop pointing fingers and get the job done. Collect data, perform scientific analysis, write protective rules and regulations based on your factual findings, and remember - DEQ is also responsible for supporting businesses with successfully coming into compliance. Failed businesses are a reflection of failed regulation. DEQ should be the experts; they should be sharing that expertise with businesses and guiding them. It benefits everyone for industry to improve their production practices and reduce emissions while at the same time contributing to the local economy. We all need to work on these problems – together.		 https://data.oregon.gov/views/54i7-gnrh/files/7baa2f42-5c8e-453b-a502-93ceacfa9cb0?filename=GlassRulesComment.txt&content_type=text%2Fplain
180 1949 Paul Trautman colors@taglass.com Trautman Art Glass Oregon [contents of attachment]

To The DEQ,

Thank You for the opportunity to comment on the proposed rules for Colored Art Glass Manufacturers.

I’ve been in the colored art glass manufacturing business for over 30 years. Trautman Art Glass is one of 3 tier 1 manufacturers in the Portland area covered by the new DEQ rules. The other 2 are Northstar Glassworks, which I started in the 80’s, and Glass Alchemy, started by a Northstar employee.

Along with the two tier 2 manufacturers, Bullseye and Uroboros, Portland is unique in having such a concentration of colored glass companies. Together we provide hundreds of jobs in a growing market, and millions of dollars in tax revenue to the Portland area.

But not all colored art glass companies are the same. We vary in size radically, and utilize vastly different processes to make the glass. We at Trautman are probably the smallest of the smaller tier 1 manufacturers.

The colored art glass manufacturing temporary rules now being considered were done in haste and have presented glass manufacturers with some unintended negative consequences. Even the DEQ has admitted this. The rules were written and put into temporary law before the DEQ even asked what we do and how we do it.

The rule, as written today, is OK, with one HUGE exception: Testing of the pollution control device installed would be prohibitively expensive for the, very small, tier 1 manufacturers . This is mainly because we emit such a small amount that it would take up to a month of testing , or longer, for the very smallest of us. So the smaller you are, and less you emit, the MORE expensive it would be to do the testing. We have been quoted nightmarish numbers , like $300,000, to do the testing. In addition, the longer a test takes to run , the less accurate they actually become. So those of us least able to afford such expenses would be burdened with the highest costs. Absurd! This kind of expense could cause the smallest of us to go out of business along with all the jobs we provide. There must be a better alternative.

Additionally , the whole concept is flawed. It’s like if you bought $30,000 car, new off the lot, and the DEQ required you to pay for a $90,000 test to prove that the emission control system works as advertised….

The air filtration devices we are buying have been engineered and utilize hepa filters that are warranted to do what they advertise, just like the car emissions devices and airbags.

At the very least, if the DEQ insists on such an impractical test they should subsidize the cost. Isn’t this what they do for car emissions testing already? Or change the rule.

As far as the 10 ton rule and the State wide rule, I do not see that it would make much difference. Most of the small (less than 10 tons) “garage” color companies that would be affected are out of state anyway. Some companies may see this as a way to gain control over competition. It has nothing to do with air quality. Make the rules nationwide and THAT I would whole heartedly support. If the rules put one of us out of business, it would only boost sales for the others. So DEQ risks becoming a pawn in a competitive marketplace.

We face competition from China, India and the EU. Don’t make this another example of American jobs being sent overseas.

In conclusion, I want to be clear that I support clean air , water , soil and a safe workplace. I don’t mind spending money to assure the public (and DEQ) that no harm is being done. I have always been a safety conscious and an environmentally conscious glass maker. But please don’t harm what is becoming one of Portland’s most unique and growing industries by imposing unrealistic testing requirements.

Sincerely,

Paul Trautman, Jr.
President , Trautman Art Glass, Inc.		 https://data.oregon.gov/views/54i7-gnrh/files/97258207-fdc5-4cac-9f22-8da6af18c433?filename=To+The+DEQ+and+EQC.docx&content_type=application%2Fvnd.openxmlformats-officedocument.wordprocessingml.document
181 112 Beth Ulrich bu626@yahoo.com Chester County Art Glass PA This is MY BUSINESS - please do not take that away from me - Glass effects a lot of people
182 1063 Rob Nosse rep.robnosse@state.or.us State Representative OR   https://data.oregon.gov/views/54i7-gnrh/files/34e7b9a6-43e5-4d30-a403-9d2e6c6e6341?filename=Art+Glass+Comment.txt&content_type=text%2Fplain
183 1062 Rob Nosse rep.robnosse@state.or.us State Representative OR   https://data.oregon.gov/views/54i7-gnrh/files/7b6496d8-4499-48c2-b3b3-584220abf3ba?filename=Art+Glass+Comment.txt&content_type=text%2Fplain
184 1034 Rob Nosse rep.robnosse@state.or.us State Representative OR   https://data.oregon.gov/views/54i7-gnrh/files/6140efc0-699c-4365-b1fd-3565bc7a83c0?filename=Art+Glass+Comment.txt&content_type=text%2Fplain
185 1005 Rob Nosse rep.robnosse@state.or.us State Representative OR   https://data.oregon.gov/views/54i7-gnrh/files/83287f01-fa0e-4ac7-8ab8-cfc011285e9b?filename=Art+Glass+Comment.txt&content_type=text%2Fplain
186 989 Rob Nosse rep.robnosse@state.or.us State Representative OR   https://data.oregon.gov/views/54i7-gnrh/files/9055b98f-9c6e-4a41-9dca-8816ff8a895e?filename=Art+Glass+Comment.txt&content_type=text%2Fplain
187 1084 Rob Nosse rep.robnosse@state.or.us State Representative Oregon As a representative and resident of Southeast Portland, I am deeply concerned about the environmental and human health impacts of uncontrolled metal emissions.  If we truly care about the health of all Oregonians, I encourage the DEQ and EQC to consider extending the permanent rule to art glass manufacturers statewide. The issue of industrial air toxics is not limited to the Portland Metro Area, and the proposed permanent rule may provide a competitive advantage to businesses in other regions of the state. I believe that all known sources of air pollution should be subject to the DEQ’s health-based regulations, regardless of geographic location. In broadening the scope of the permanent rule, we can better protect the health and wellbeing of all Oregon residents
188 1086 Rob Nosse rep.robnosse@state.or.us State Representative OR As a representative and resident of Southeast Portland, I am deeply concerned about the environmental and human health impacts of uncontrolled metal emissions. If we truly care about the health of all Oregonians, I encourage the DEQ and EQC to consider extending the permanent rule to art glass manufacturers statewide. The issue of industrial air toxics is not limited to the Portland Metro Area, and the proposed permanent rule may provide a competitive advantage to businesses in other regions of the state. I believe that all known sources of air pollution should be subject to the DEQ’s health-based regulations, regardless of geographic location. In broadening the scope of the permanent rule, we can better protect the health and wellbeing of all Oregon residents.
189 1101 Rob Nosse rep.robnosse@state.or.us State Representative OR   https://data.oregon.gov/views/54i7-gnrh/files/8651ab7a-8bf1-47c8-b223-5d6dca5fe273?filename=Art+Glass+Comment.txt&content_type=text%2Fplain
190 1103 Rob Nosse rep.robnosse@state.or.us State Representative OR   https://data.oregon.gov/views/54i7-gnrh/files/31ddcd92-0185-4e33-9e16-fe8aea8bb2aa?filename=Art+Glass+Comment.txt&content_type=text%2Fplain
191 1990 Rob Nosse rep.robnosse@state.or.us State Representative OR As a representative and resident of Southeast Portland, I am deeply concerned about the environmental and human health impacts of uncontrolled metal emissions. If we truly care about the health of all Oregonians, I encourage the DEQ and EQC to consider extending the permanent rule to art glass manufacturers statewide. The issue of industrial air toxics is not limited to the Portland Metro Area, and the proposed permanent rule may provide a competitive advantage to businesses in other regions of the state. I believe that all known sources of air pollution should be subject to the DEQ's health-based regulations, regardless of geographic location. In broadening the scope of the permanent rule, we can better protect the health and wellbeing of all Oregon residents

  A B C
1 CommentID DEQresponse Notes
2 1 Visible emissions from colored art glass manufacturers are subject to another rule, Oregon Administrative Rule 340-208-0110. DEQ will include permit conditions to implement this rule in permits issued to CAGMs.
3 229    
4 2008
THIS RESPONSE NEEDS TO BE REVISED TO COMPORT WITH CHANGES TO THE RULE - GFD 8/18/16

DEQ understands the commenter’s concerns and agrees that it is not DEQ’s intent to regulate glassworking. DEQ’s intent is to regulate the process of making colored art glass using the raw material that contains specified HAPs. Thus, for a facility to possibly be regulated under the proposed rule, two criteria must be met:
1. The facility must make (manufacture) glass; and
2. The glass must be colored using raw material that contains specified HAPs.
DEQ’s understanding of these two criteria is explained below.

The facility must make (manufacture) glass.
To make (manufacture) glass is a broad concept, and in DEQ’s view it means to make a new glass product that is different from the starting materials. This can include starting with a mix of sand, soda and other materials and heating the mix to create glass. It can also include starting with two pre-made glasses and heating them together to create a new glass product that has a different appearance than the two starting glasses; DEQ considers that a glassworker could “make” glass in this way. It is the second criteria above that more narrowly limits the applicability of the proposed rules.

The glass must be colored using raw material that contains specified HAPs.
The terms “colored” and “specified HAPs” are unambiguous, and most of the definition of “raw material” is also unambiguous, with the possible exception of subsection (c), which is considered in more detail below.

For the proposed rules to be applicable to a facility that makes glass (as described above), that facility must make colored glass using raw material that contains the specified HAPs. Two examples are given below to explain this:

Example 1: A facility can start with a mix of sand, soda and other materials and heat the mix to create glass. If cadmium sulfide is added to the mix for the purpose of achieving a colored glass product, the cadmium sulfide is a raw material and the facility may be regulated under the rule if it produces more than the threshold amount of colored art glass.

Example 2: A facility can start with two pre-made glasses and heat them to create glass. If cadmium sulfide is added to the mix for the purpose of achieving a colored glass product, the cadmium sulfide is a raw material and the facility may be regulated under the rule if it produces more than the threshold amount of colored art glass.

It is conceivable that a glassworker could make colored art glass in the manner described in Example 2, above. If that glassworker made more than the threshold amount of colored art glass, then that glassworker would be subject to the proposed rules. However, if a glassworker made any amount glass but did not use raw material that contained the specified HAPs, then that glassworker would not be subject to the proposed rules.

With regard to subsection (c), DEQ agrees that further clarification will be helpful. Subsection (c) in the temporary rules reads as follows:

“Raw material includes glass materials that contain metal HAPs in amounts that materially affect the color of the finished product and that are used as coloring agents.”

In Examples 1 and 2 above, cadmium sulfide is added for the purpose of achieving a colored glass product, and the cadmium sulfide is a raw material. DEQ understands that cadmium sulfide may be obtained in powder form, or in a glassified or vitrified form to minimize worker exposure to toxic cadmium sulfide dust. In the glassified form, the cadmium sulfide is essentially encased in a glass or glass-like carrier, but it has the same purpose as cadmium sulfide powder. If a glass formulation calls for one pound of cadmium, then that pound can be added by using an amount of cadmium sulfide powder that contains one pound of cadmium, or it can be added by using an amount of glassified cadmium sulfide that contains one pound of cadmium. The powder form of cadmium sulfide is a raw material, and the glassified form of cadmium sulfide is also a raw material. Although cadmium sulfide is used in these examples, the same concept applies to all of the HAPs regulated under the proposed rules.

In the final analysis, it is making glass using raw materials that contain the specified HAPs that makes a facility potentially subject to the proposed rules.

DEQ appreciates the commenter’s suggestions but has determined that the suggested changes are unnecessary. However, in view of any confusion that may be caused by subsection (c) in the definition of raw material, DEQ is proposing to revise subsection (c) to read as follows:

Raw material includes glass materials that contain glass-making HAPs in amounts that materially affect the color of the finished product and that are used as coloring agents. For example, one pound of cadmium sulfide may be used in a glass formulation for the purpose of achieving a particular color throughout the final glass product. The pound of cadmium sulfide may be added in powder form, or in a glassified or vitrified form; all of these are raw materials.

Changes were made to the proposed rule based on this comment.
5 2361 DEQ does not agree that these rules should apply to any glass manufacturer using metal HAPs, but has proposed to lower the applicability threshold from 10 tons of colored glass per year to 5 tons of colored glass per year. DEQ understands the concern that very small glass manufacturing operations could emit uncontrolled glass-making HAPs, but DEQ also considers it inappropriate to regulate individual glass artists. To produce 5 tons per year would require producing 200 pounds per week for 50 weeks per year. DEQ considers it unlikely that an individual artist or small glass-working shop would produce this much colored glass, while this level of production is achievable by the smallest of the CAGMs that DEQ intended to regulate when the temporary rule was adopted in April, 2016.

DEQ agrees that these rules should apply statewide and has revised the proposed rules to do so. DEQ's authority is limited to within Oregon and cannot make them apply nationwide.

DEQ agrees that the testing required to show 99.0 percent baghouse capture efficiency would be cost-prohibitive and has revised the proposed rules to require that CAGMs either test to show that particulate matter emissions at the control device outlet do not exceed 0.005 grains per dry standard cubic foot, or install a bag leak detection system.

????????????????????????????????? Make sure this comports with the actual final proposed rule language

DEQ agrees in principle that HAPs should be effectively regulated statewide, including all HAPs emitted by colored art glass manufacturers; however, DEQ has not revised the proposed rule to do this for the following reasons:

First, DEQ is currently proceeding with development of rules that will broadly regulate air toxic emissions in Oregon. The future rules are intended to encompass a broad range of manufacturing operations and apply similar health-based standards to all regulated facilities. In contrast to the future air toxics rules, the temporary colored art glass rules were narrowly focused on reducing the elevated levels of air toxics that were associated with CAGMs in Portland, primarily by imposing emission control requirements. The temporary colored art glass rules were never intended to be the broader health-based air toxics rules, and DEQ is not proposing to change that.

Second, DEQ does not know and cannot anticipate what health-protective criteria will be establised in the future air toxics rules. Although the proposed art glass rules do include health-protective criteria for chromium VI, it is possible that the future air toxics rules will set different criteria which may require revision to the chromium criteria in the art glass rules. DEQ does not consider it appropriate to propose additional health-protective criteria in the proposed art glass rule that may similarly require revisions in the future.

DEQ revised the proposed rules based on this comment.

  A B C D E F G H
1 Point ID short summary Summary of Comment DEQ response Commenter Notes Response Status Assigned to
2 1 flexibility DEQ should give more compliance time and flexibility to CAGM DEQ is confident that the requirements and deadlines in the proposed rules are achievable by all affected facilities. DEQ is also committed to work with all affected companies to issue necessary emission control device approvals and test plan approvals as quickly as possible.

We have revised the rule to reduce source testing costs and uncertainties by replacing the 99% capture efficiency standard with a standard at the baghouse outlet. In addition, DEQ added a pathway for facilities to apply for an extension of time to comply in 340-244-9005		 draft  
3 2 don't shut down DEQ should consider the economic effect on glass artists. DEQ should not shut down the glass industry. The proposed permanent rules are intended to ensure that CAGMs operate in a way that is protective of human health and the environment. We are confident that facilities can meet these requirements while continuing to serve their customers. draft  
4 3 don't increase glass prices If compliance with the rule is expensive, glass will be too expensive for glass artists to buy. CAGMs must operate in a way that does not harm the health of their neighbors. DEQ believes the proposed rule requirements provide that protection to facility neighbors in a way that is also achievable for the affected facilities. draft  
5 4 other facilities The pollution measured around Bullseye may be coming from other sources. DEQ should have collected more wind direction and velocity 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. Data collected in late 2015 near Bullseye measured significant concentrations of metal HAPs in air. Subsequent air data showed very marked reductions in these HAPs once these materials were taken out of Bullseye’s production process and controls were installed. This demonstrates that Bullseye was clearly the source of these significant elevation in air data. DEQ’s work to identify and control remaining sources of air toxics around the Bullseye facility is ongoing. Both the Bullseye and Lehigh facility are completing new controls and management practices to address residual elevated hexavalent chromium detections in recent monitoring events. draft  
6 5 statewide DEQ should apply this rule statewide instead of only in the Portland area. Based on comments received, DEQ is proposing that the permanent rule apply statewide. While there are no known air quality problems related to CAGM operations outside the Portland area, applying the rule statewide gives all Oregonians protections from current and potential future CAGM emissions and helps provide a “level playing field” for CAGMs that install the controls necessary to comply draft  
7 6 500 lb/year DEQ should lower the applicability threshold of the rule so that all facilities making at least 500 lbs per year (or even a smaller amount) of HAP-containing glass are regulated. DEQ proposes to lower the applicability threshold from 10 tons per year of colored art glass to 5 tons per year of colored art glass.

DEQ proposes to lower the applicability threshold based on comments that suggest lowering the threshold, and because DEQ has received information that indicates that the three smaller colored art glass facilities in the Portland AQMA that DEQ intended to regulate under the temporary rules may actually fall below the current 10 ton per year threshold. However, in proposing to lower the threshold, DEQ also does not wish to make the threshold so low that the rule would encompass facilities whose primary purpose is the production of items made from colored glass, such as glass art pieces or other glass items, and that might make small quantities of glass for special purposes.

Five tons per year is 10,000 pounds per year, and DEQ assumes a typical working year is 50 weeks. To produce 10,000 pounds of glass in a year, a CAGM would have to produce an average of 200 pounds of glass per working week. Producing this much glass per week would require two small glass making furnaces, each making 50 pounds of glass two times per week. DEQ considers this level of production to reasonably represent a level that defines an art glass manufacturing operation, but is high enough to exclude facilities whose primary purpose is the production of items made from colored glass.

DEQ acknowledges that at this time there is no information available to quantify the metal HAP emissions from colored art glass manufacturing operations, and that the proposed 5 ton per year threshold is therefore somewhat arbitrary. However, the proposed threshold is consistent with the intent of the temporary CAGM rules, which was to rapidly require emission controls on CAGMs.		 draft  
8 7 all metals The rule should regulate all heavy metals or all hazardous air pollutants (HAP), not just arsenic, cadmium, chromium, lead, manganese and nickel. DEQ agrees that the proposed rules should apply to all HAPs likely to be emitted by CAGMs, and has expanded the list of HAPs regulated by the proposed rules to add selenium. Selenium has been detected in the air near Bullseye at concentrations close to health screening levels. The proposed rules prohibit the use of the listed HAPs in uncontrolled furnaces after the applicable compliance dates. draft  
9 8 99.9% The temporary rule requires CAGMs to show that their baghouses capture 99.0% of incoming particulate matter. Baghouses can capture more than that, and DEQ should require them to demonstrate that they are capturing 99.9%. DEQ agrees that baghouses are capable of capture efficiencies higher than the 99.0% standard in the temporary rule. DEQ has learned that there are practical problems with demonstrating capture efficiency with a source test, particularly for the smaller (Tier 1) facilities.

To show 99.0% (or 99.9%) capture efficiency with a source test, a facility needs to test the inlet and the outlet of the baghouse. The inlet concentration would need to be at least 100x (or 1,000x) of the outlet concentration. Chemical tests are not accurate below a certain threshold (the method reporting limit, MRL) and if a reading is below the MRL then the sample concentration is assumed to be the MRL.

To show 99.0% capture efficiency, the source test must be run until the inlet sample is at least 100x the MRL. Unfortunately that takes a very long time, especially at Tier 1 facilities (~ one week per test run), because their baghouse systems pull in a lot of air from the room and are very dilute. Long test runs are expensive and prone to error. One facility, Northstar, reported that they were quoted a cost of $350k for a source test, which may be more than the cost of buying and installing a baghouse.

DEQ is proposing a rule revision so that facilities will have to meet an emissions standard of 0.005 gr/dscf (grains of particulate per dry standard cubic foot of air) rather than a baghouse capture efficiency standard. This is a standard type of emissions testing for other facility types and will reduce source testing costs.		 If requiring baghouse leak detection or HEPA filter, mention that here. draft  
10 9 health benchmarks DEQ should modify the health benchmarks in the rule to make them more protective, especially the 36 ng/m3 daily average source impact level for hexavalent chromium. The 36 ng/m3 can't be exceeded without also exceeding the 0.08 ng/m3 annual limit. Health benchmarks should take into account sensitive populations. DEQ has partnered with the Oregon Health Authority (OHA) to rely on their expertise in estimating environmental risks and setting health benchmarks.

Because chronic exposure to pollutants can cause harm through different mechanisms than intense, acute exposures, OHA recommended that DEQ incorporate an annual and 24 hour limit on chromium emissions from Tier 2 facilities. Facilities are bound by both limits, so the most stringent is the one that matters.

DEQ is proposing to change the 36 ng/m3 limit based on new information submitted by OHA. OHA recommended that DEQ revise the 24 hour health benchmark for hexavalent chromium to 5 ng/m3. 5 ng/m3 is the intermediate minimal risk level (MRL) established by the Agency for Toxic Substances and Disease Registry (ATSDR).

The health based Ambient Benchmark Concentrations and the daily maximum ambient concentration limits recently developed by DEQ and OHA all include conservative assumptions that encompass the protection of sensitive populations such as children, the elderly, and people who are health-impaired. With respect to chromium VI, the rules also limit long-term exposure to sensitive human receptors located in places such as schools, daycare centers and hospitals, and limit short-term exposure at any location off of the facility’s property.

OHA is beginning a process to review and revise other health benchmarks. If OHA revises other benchmarks as part of that process, the updated data could be incorporated into the art glass rule in a future rulemaking		 Sue MacMillan reviewed the 2nd to last paragraph. draft  
11 10 all glass factories This rule should be changed to regulate all glass factories (such as Owens Brockaway and General Glass), not just CAGMs The purpose of the proposed rules is to regulate emissions of certain HAPs from colored art glass manufacturers. As noted in another response, it is making glass using raw materials that contain the specified HAPs that makes a facility potentially subject to the proposed rules.

DEQ has reviewed other glass making facilities and believes that currently there are five facilities that meet the proposed definition of colored art glass manufacturer (CAGM): Bullseye, Uroboros, Northstar, Troutman Art Glass and Glass Alchemy. DEQ is proposing to make this rule apply statewide, and other CAGMs may be identified in the future.

Owens Brockway makes container glass, some of which is colored brown or green, but does not deliberately use raw materials that contain the specified HAPs. The colors in the container glass are achieved using iron oxides, and iron is not a HAP. Owens Brockway is regulated under other rules and is required to have a Title V air permit, but does not meet the definition of CAGM and is not regulated under the proposed rule.

General Glass was also identified by commenters. General Glass manufactures glass products starting from sheet glass, but General Glass does not make glass in the sense of melting raw materials or cullet to produce glass and therefore does not meet the definition of CAGM and is not regulated under the proposed rule.		 draft  
12 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  
13 12 translate DEQ should provide translation for non-English speakers and specific outreach to communities of color and low-income communities. DEQ can provide language translation for meetings or written materials upon request. Please contact DEQ and let us know if there is a specific community or language group that wants to request this. draft  
14 13 air permits on website DEQ should make air emissions permits publicly available through its database Making air permit records accessible to the public via DEQ’s website is a good suggestion but outside the scope of this rulemaking process. draft  
15 14 NESHAP 6S This rule is less stringent than NESHAP 6S in some ways, so it should not apply to furnaces that are subject to NESHAP 6S The proposed rules are designed to apply even at furnaces that are subject to NESHAP 6S. At furnaces subject to both regulations, the restrictions of both regulations would apply and not just one or the other. draft  
16 15 can't operate until permit issued Facilities should not be able to operate until the public has had a chance to comment on the proposed permit and DEQ has issued it. Because the process of issuing a permit is long, it is DEQ’s policy that when a new rule is put in place, existing facilities can continue to operate during the period between submitting an application and when DEQ issues the permit. Facilities do not have to wait until the permit is issued to begin operating.
 draft  
17 16 more public comment The public should be able to comment at more steps in the process, including commenting on source test plans and pollutant dispersion modeling. Opportunities for public participation are a required and valuable part of DEQ’s rulemaking process. For this rulemaking DEQ convened a fiscal advisory committee, held a public hearing, and accepted public comment via our website as well as email.

The proposed rule requires all Tier 1 and Tier 2 CAGMs to obtain air permits. As part of DEQ’s process for issuing air permits the public has an opportunity to comment on whether DEQ has correctly applied the rules and statutes to the proposed permit. The public can also request a public hearing.

Soliciting and responding to public comment takes significant time and effort, and DEQ is not able to do that at all steps in the process.		 draft  
18 17 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. DEQ agrees that setting an applicability threshold based on health risks is a good idea; however this approach would add technical complexity that DEQ intends to address through the development of a health-based air toxics permitting rule (Cleaner Air Oregon) that may incorporate this concept. Al Hooton   draft  
19 18 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. It is not DEQ’s intent to regulate glassworking. DEQ’s intent is to regulate the HAP emissions from the process of making colored art glass using raw material that contains specified HAPs. The process of remelting pre-made glass would not be regulated under this rule, unless glassmaking HAPs are being added (in a form such as a powder or as a special concentrated frit). DEQ is proposing to change the definition of raw material to make this distinction clearer. Chris Mini George is working on the definition of raw material. Look at this again when that is complete. needs review George
20 19 EJ DEQ has a legal obligation to do a demographic analysis to make sure the proposed rule does not have disproportionate adverse impacts on communities of color. DEQ has considered whether the proposed rule would result in distinct adverse impacts on communities of color, and has concluded that it will not. The purpose of this rule is to reduce art glass manufacturers' emissions of metal HAPs to surrounding communities. With the proposed change to apply it statewide, the rule does not differentiate based on the location of the facilities, nor does it encourage or discourage the location of the facilities in any particular area. All communities that are impacted by this source category would also benefit from the protection of the rules.

Some commenters have suggested that the facilities regulated by this rule are in wealthy areas, and that the source category should be defined differently so that disadvantaged communities would benefit more. Several commenters mentioned Owens Brockway and General Glass as glass-related facilities that they felt should be regulated by the rule.

Owens Brockway makes container glass, some of which is colored brown or green, but does not deliberately use raw materials that contain the specified HAPs. The colors in the container glass are achieved using iron oxides, and iron is not a HAP. Owens Brockway is regulated under other rules and is required to have a Title V air permit, but does not meet the definition of CAGM and is not regulated under the proposed rule.

General Glass manufactures glass products starting from sheet glass, but does not make glass in the sense of melting raw materials or cullet to produce glass and therefore does not meet the definition of CAGM and is not regulated under the proposed rule		 CRAG Emailed Sue Langston, Stephanie Caldera, and Nina DeConcini for review on 8/30/2016. needs review
21 20 BLDS DEQ should require baghouse leak detection DEQ is proposing that, in addition to the grain loading test, Tier 2 facilities be required to either install baghouse leak detection systems (BLDS) or HEPA after-filters on each baghouse. DEQ feels that HEPA after-filters, like BLDS, provide added assurance that the baghouse remains effective over time.

Because emissions from Tier 1 facilities are more dilute, DEQ proposes that they can either perform the grain loading test, install a BLDS, or install a HEPA after-filter		 EPA   needs review
22 21 grain loading DEQ should replace the 99.0% capture efficiency test with a "grain loading" test at the baghouse outlet, with limit on filterable particulate matter set at 0.005 gr/dscf. DEQ is recommending this change. EPA   draft  
23 22 EPA Method 29 at outlet DEQ should allow Tier 2 facilities to use Method 29 to measure total chromium at the baghouse outlet and assume all of it is hexavalent chromium, instead of using Method 0061 to measure hexavalent chromium or measuring at the baghouse inlet and estimating the outlet emissions based on capture efficiency. DEQ agrees that this method is conservative (because it assumes the worst case, that all chromium is in the hexavalent form) and is proposing a change to the rule language to allow this.

DEQ is also proposing to
Bullseye, EPA draft  
24 23 0.2 lb/ton DEQ should allow facilities to meet the NESHAP 6S limit (0.2 lb of particulate emitted per ton of glass produced) instead of demonstrating 99.0% capture efficiency from the baghouse. DEQ is proposing a change to the rule to eliminate the capture efficiency standard and replace it with an outlet PM grain loading limit of 0.005 gr/dscf. (Tier 2 facilities would be required to perform the outlet grain loading source test. Tier 1 facilities could perform the grain loading test or install a baghouse leak detection system or HEPA after-filter.) The 0.2 lb/ton NESHAP limit would apply in addition to the grain loading standard at furnaces that are subject to NESHAP 6S. Bullseye   draft  
25 24 no metals in uncontrolled furnaces CAGMs should not be allowed to use any metals in uncontrolled furnaces Under the proposed rules Tier 2 CAGMs are not allowed to use glassmaking HAPs in an uncontrolled furnace. Tier 1 CAGMs would not be able to use glassmaking HAPs in an uncontrolled furnace unless they had done source testing and air dispersion modeling to show that doing so does not pose a risk to people nearby. Some glassmaking HAPs are newly added to the list in this proposal and have a later compliance date. draft  
26 25 thermal oxidizers CAGMs should be required to use better control devices such as thermal oxidizers Thermal oxidizers are not effective in reducing metal emissions. Fabric filters (baghouses) are effective against metal particulates and appear to be the control devices most facilities will use to comply with the rule requirements. draft  
27 26 no chromium CAGMs should not be allowed to use chromium in any form, because it transforms to hexavalent chromium. DEQ believes that control devices such as baghouses are highly effective and that, if following the proposed regulations, CAGMS can use glassmaking HAP including chromium without undue impact to human health and the environment. Tier 2s facilities are required to source test and set usage limits in order to keep their impact below health benchmarks. draft  
28 27 emissions monitoring DEQ should require monitoring of emissions rather than monitoring of the control device DEQ does not agree that this type of monitoring should be required. DEQ believes the testing required by the rule is sufficient to demonstrate the performance of the emission control devices draft  
29 28 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 temporary rules, adopted in April, 2016, required a test to determine how much chromium III was converted to chromium VI. To ensure that the test would give a valid result, which requires capturing a large enough sample, the rules required testing at a baghouse inlet, before the filters in the baghouse reduce the amount of pollutant in the exhaust gases.

The temporary rules included a provision for setting maximum chromium usage rates that would keep a Tier 2 CAGM’s ambient chromium VI impacts from exceeding the health-based levels specified in the rules. To do this, it was also necessary to learn the actual emission rate of chromium VI, which the amount of chromium VI coming out of the baghouse (i.e. from the baghouse outlet). At that time, DEQ assumed that baghouse control efficiency for chromium VI would be the same as the baghouse control efficiency for particulate matter since DEQ expected all chromium VI to be in particulate form. Therefore, the rules also required testing for particulate matter both at the baghouse inlet and outlet (i.e. before and after the filters). By testing before and after the filters, the particulate matter removal efficiency could be calculated, and this removal efficiency could then be used to calculate the chromium VI emission rate.

In June, Bullseye performed this testing and also took an extra sample of chromium at the baghouse outlet. Based on the inlet and outlet testing for chromium, the calculated efficiency for chromium removal was significantly less than 99.0 percent, whereas the removal efficiency for particulate matter was over 99.0 percent.

Since the test only gave one data point for chromium removal efficiency, DEQ does not consider this to definitively show that the removal efficiency of chromium VI is less than 99.0 percent because there may be an unknown error in that single test. Other possible explanations for this result are: some of the chromium particles are so small that the baghouse does not capture all of them, or some of the chromium is in a gaseous form and passes through the baghouse as condensable matter. DEQ does not consider the last explanation very likely, but regardless of why the chromium removal efficiency appears to be low, the test result calls into question the assumption that the chromium removal efficiency is the same as the particulate matter removal efficiency. DEQ has therefore taken a different approach in the proposed permanent rules.

Rather than relying on testing for chromium at the baghouse inlet and using removal efficiency to calculate the chromium emission rate, DEQ is now proposing that the chromium emission rate be measured directly at the baghouse outlet. This will provide the information needed to set maximum usage rates that will keep a Tier 2 CAGM’s ambient chromium VI impacts from exceeding the health-based levels specified in the rules. With this change in approach, testing for particulate matter removal efficiency is no longer necessary and the requirement to test for particulate matter removal efficiency has been replaced with a simpler test in the proposed rules.

Finally, although the June source test result suggests that the chromium control efficiency for a baghouse is less than 99.0 percent, it also suggests that the chromium emissions are controlled to a significant extent, and DEQ still considers baghouses to be appropriate emission control devices for CAGM emissions.
Can this be condensed? needs review
30 29 cumulative health effects Rule should take into account cumulative/interactive effects instead of pretending that people are exposed to a single pollutant in isolation The health benchmarks incorporated into the proposed rule were developed with the help of the Oregon Health Authority. OHA is beginning a process to revise those benchmarks and if revised, DEQ could incorporate those changes in a future update to the art glass rule. OHA may have better answer draft  
31 30 Self-reported data Self-monitoring is insufficient. DEQ should conduct ongoing inspections. The proposed rule would require all affected facilities to get a DEQ permit. DEQ performs inspections of permitted sources on a regular basis. draft  
32 31 Best Available Technology CAGMS should have to demonstrate on an annual basis that they are using the best available technology to limit toxic emissions from their facilities. DEQ believes that existing technology can reduce CAGM emissions to levels below health benchmarks. If improved technologies are developed in the future, DEQ could revisit this rule in a future rulemaking. draft  
33 32 future additions The rule should include a clause to allow for the future regulation of other materials from glass manufacturing if found to exceed either short and/or long term health standards for air shed quality. The proposed rules include OAR 340-244-9090, which allows DEQ to set a limit on a CAGM’s use of a glassmaking HAP if that HAP is determined to pose an unacceptable risk to human health in the area of a CAGM. However, the rule would not allow DEQ to add materials to the list of glassmaking HAPs without going through a new rulemaking process. If new information comes to light DEQ could revisit the rule, or in an emergency the Governor's office could order DEQ to take action.

With respect to other materials that may be emitted, DEQ is working on the development of a larger state-wide rule (the Cleaner Air Oregon rule) to regulate air toxics emissions from industrial emissions sources. This larger rule is expected to provide a uniform program for the regulation of air toxics emissions. The rule is being developed over 2016 and 2017, with significant information gathering and opportunity for public input.		 draft  
34 33 precautionary principle Where health impacts are uncertain, DEQ should err on the side of being more protective of health. Limits should reflect sensitive populations. The health benchmarks incorporated into the proposed rule were developed with the help of the Oregon Health Authority. OHA is beginning a process to revise those benchmarks and if revised, DEQ could incorporate those changes in a future update to the art glass rule. draft  
35 34 facility limits vs furnace limits Rule should set per-facility emission limits so that cumulative impact of multiple furnaces does not exceed health benchmarks. The emissions limits in the proposed rule (chromium usage limits for Tier 2 facilities and limits for Tier 1 facilities that choose the 'source test and model' compliance pathway) are on a facility-wide basis and not a per-furnace basis. draft  
36 35 Cr6 conversion Rule should assume that all trivalent chromium converts to the more dangerous hexavelent chromium form in glass production. Tier 2 facilities are required to set production limits to make sure that chromium emissions are below health benchmarks. To set those production limits, the proposed rules allow CAGMs two options: assume that 100 percent of chromium emitted is in the form of hexavelent chromium, or conduct testing to quantify the emissions of hexavalent chromium. The choice of which option to use is up to the individual CAGMs; however, all testing procedures must be approved by DEQ. draft  
37 36 enforcement There should be heavy fines for violations, a plan for repeat offenders, and the ability to shut facility down if it poses an immediate risk to the public and environment. DEQ follows established enforcement procedures in Oregon Administrative Rule Chapter 340, Division 12. Fines are based on the amounts and procedures specified in these rules, and include provisions for increasing fines for repeated violations.

In addition, under Oregon Revised Statute 468.115, if DEQ finds that air pollution presents imminent and substantial endangerment to the public health, at the Governor’s direction, DEQ can issue a cease and desist order against the person or persons responsible for the pollution. The order can be effective for no more than 10 days and may be renewed by order of the Governor		 needs review
38 37 cold shops Rule should regulate dust and wastewater from cutting and cold processing of glass Particulates from cutting and grinding operations are larger and heavier, and much less likely to be emitted to the outside of the facility. This rule does not regulate water emissions. Are there other regs for stormwater, wastewater to sewer, or fugitive emissions from waste / broken glass near dumpster? draft  
39 38 NESHAP DEQ should not rely on the NESHAP to protect neighbors This rule is in addition to and more stringent than the federal NESHAP Subpart SSSSSS. draft  
40 39 September 1st DEQ should apply the new rules by September 1st DEQ disagrees that the rules should apply to all heavy metals by September 1, 2016. When rules that require the installation of emission control devices are adopted, agencies must give the affected facilities time to design, obtain building permits, obtain the emission control device and install it. When the temporary rules were adopted, the Tier 2 CAGMs were given until September 1, 2016 to comply with the rules. The Tier 1 CAGMs were contacted sometime after the Tier 2 CAGMs, and had less warning that they would be regulated, so were given an extra month. If the rules become applicable statewide, as proposed, CAGMs outside the Portland AQMA will need time to comply and DEQ has proposed to give them until April 1, 2017.

In addition to the above considerations, only the Environmental Quality Commission has the authority to approve new rules. The EQC will meet on September 29th to consider DEQ's proposal and changes approved by the EQC would not take effect retroactively.
 draft  
41 40 video DEQ should get modern video recording equipment and broadcast and post all public meetings. DEQ has recorded and posted some recent meetings but currently does not have the equipment or staff expertise to produce high-quality video. DEQ is considering requesting funding for this. draft  
42 41 other facilities (2) Ambient concentrations didn't decrease after the temp rule was put in place, so the pollution must be coming from other sources. Concentrations have remained fairly consistent during this time, however Bullseye ceased using metal HAPs well in advance of the enactment of the temporary rules. Therefore, no specific reductions would have been expected. There was one spiking event in May, which again was clearly attributable to Bullseye, which resulted in the implementation of new restrictions above and beyond the temporary rules in order to protect public health. draft  
43 42 batch vs continuous furnace The only rule change needed is to 'close the loophole on the definition of batch production' so that furnaces that are kept hot are subject to NESHAP 6S. DEQ should not add other regulation. EPA's current interpretation of NESHAP Subpart SSSSSS is that furnaces that are kept hot meet the definition of 'continuous furnace' and are subject to 6S if all other applicability criteria are met. However, 6S applies only to individual furnaces that produce 50 tons per year of colored glass using any of 6 listed HAPs. Many of the HAP-emitting furnaces at CAGMs would not be subject to 6S. The proposed rule applies to all furnaces at Tier 1 and Tier 2 CAGMs that produce any amount of colored glass using any of a larger list of HAPs. draft  
44 43 visible emissions Are CAGMs subject to a limit on visible emissions Visible emissions from colored art glass manufacturers are subject to another rule, Oregon Administrative Rule 340-208-0110. DEQ will include permit conditions to implement this rule in permits issued to CAGMs. draft  
45 44 no rules without public comment DEQ should never propose rules without going through public comment The EQC has authority to adopt temporary rules without public notice when there is a need to act quickly, as there was in early 2016 for the temporary art glass rules. As a safeguard against abusing the temporary rulemaking authority, temporary rules are only effective for six months and then either expire or can be renewed/revised through the normal rulemaking process, which includes full public notice and opportunity to comment on the rules.
 draft  
46 45 public notice for permitting actions The public should be notified about any proposed permits. Public notice is given for all proposed air quality permits, with the public notice procedures varying depending on the type of permit. Public notice requirements are specified in Oregon Administrative Rule Chapter 340, Division 209, available on DEQ’s website or through the State of Oregon website. To receive email notification of public notices, please go to DEQ’s website at http://www.oregon.gov/DEQ/pages/index.aspx and click on “Public Notices” on the left side of the page, then click on the link “Sign up for email notifications when this page is updated” near the top of the page draft  
47 46 fugitive emissions The rule should monitor and restrict fugitive emissions. By their very nature, fugitive emissions are difficult to control. DEQ’s observations of gas-fired glass-making furnaces indicate little or no fugitive emissions during normal operation. Fugitive emissions may occur during charging of raw materials, which happens several times at the beginning of the glass-making process. However, it is an operational necessity that the furnace be opened during charging and the possibility of some fugitive emissions during that time is unavoidable. If DEQ determines that operational practices need to be limited to reduce fugitive emissions, DEQ already has the authority to establish such limits under OAR 340-226-0120 draft  
48 47 cumulative effects of multiple facilities The rule should account for the additive effects of emissions from multiple facilities affecting the same geographic area. In addition to this rulemaking that regulates CAGMs, DEQ is also working on a larger rulemaking to develop an air toxics program that will apply more broadly to air toxics emissions. While the larger air toxics program may be able to consider comments such as this, the CAGM rules have limited scope and applicability and are intended only to address only one industrial sector. draft  
49 48 ambient monitoring DEQ should continue long term ambient air monitoring near glass factories. DEQ has limited resources for air monitoring, and has a responsibility to monitor around the state, not just near the glass factories. DEQ is continuing to monitor near the glass factories at this time, but the monitors will eventually have to be relocated so that monitoring can be done at other locations. reviewed by Brian Boling draft  
50 49 recordkeeping The rule should require CAGMs to maintain a list of all hazardous materials kept on site and used in glass furnaces DEQ’s air quality program is concerned with emissions of pollutants into the atmosphere. As such, DEQ can require facilities to keep records of air emissions and of activities and materials that contribute to those emissions. The proposed rule requires Tier 2 CAGMs to keep daily records of all glass formulations produced. DEQ may include additional recordkeeping requirements when issuing permits to CAGMs.

Other hazardous materials that may be on site at a facility or that may be emitted to other media (e.g. water or landfill) would be regulated by other programs and are outside the scope of the air quality program		 draft  
51 50 allow uncontrolled furnaces if under grain loading standard Facillities should be able to operate without control devices if their emissions are below the grain loading standard listed in the rule. The proposed grain loading standard is only intended to ensure that control devices are working. The grain loading standard is not intended to show health protectiveness because grain loading does not measure the facility's HAP emissions. Further, this rule has been developed in advance of the risk-based rules that DEQ is currently working on. Without those rules in place, DEQ does not have a basis for establishing health-based criteria for all the glassmaking HAPs. Instead, DEQ has taken the protective approach of requiring emission control devices. draft  
52 51 address all HAP sources This rule should address all HAP sources This rule is specifically targeted to address CAGM emissions. The Cleaner Air Oregon rulemaking is underway and will more broadly address HAP emissions from other sources. draft  
53 52 permit fees DEQ should lower the costs for the permits Tier 1 facilities will be required to get so that they are no more than $2-4,000 per year. Permit fees for Air Contaminant Discharge Permits (ACDP), the type that Tier 1 facilities would be required to have, are set in rule across multiple facility types and are not specific to this proposed rule. The class of ACDP permit these facilities would be required to have currently has a $7,200 application fee and $4,608 annual fee per facility. Northstar   draft  
54 53 cadmium CAGMs shouldn't be able to use cadmium in an uncontrolled furnace Under the proposed rule (and earlier temporary rule) Tier 2 facilities are not allowed to use cadmium in an uncontrolled furnace. Tier 1 facilities would only be able to use cadmium in an uncontrolled furnace if they performed source testing and dispersion modeling to show that emissions would not exceed health benchmarks. Abe Fleishman draft  
55 54 EPA Method 5 The source test requirement at OAR 340-244-9070(2)(h) should require EPA Method 5, not DEQ Method 5. DEQ is proposing to replace the 99.0% baghouse capture efficiency standard with a grain loading standard of 0.005 gr/dscf (grains of particulate matter [PM] per dry standard cubic feet of air). Grain loading is based on filterable PM as measured using DEQ Method 5.

The grain loading standard is intended to check that the control device is working. Baghouses are a form of filter and can only control filterable emissions, so the grain loading standard is based on filterable PM. EPA Method 5 does not separate the filterable and condensable forms of PM		 Stoel Rives Did I get this right about DEQ Method 5 vs EPA Method 5? needs review
56 55 99% - limit run length The 99% capture efficiency test is unworkable. DEQ should set a limit for the run length and sampling volume, and specify that the facility passes if inlet PM is non-detect at that point. DEQ recognizes that determining compliance with the 99.0% capture efficiency standard can lead to unreasonably long and expensive source tests, particularly for Tier 1 facilities that have very dilute emissions streams. DEQ is proposing to replace the 99.0% capture efficiency standard with other means to ensure that the baghouse is working. Tier 2 facilities would be required to meet a grain loading standard of 0.005 gr/dscf at the outlet of the control device and install either a baghouse leak detection device or a HEPA filter. Tier 1 facilities would be required to either meet the grain loading standard or install a baghouse leak detection device or install a HEPA filter. draft  
57 56 wait until Cleaner Air Oregon DEQ should wait to propose a permanent rule until the Cleaner Air Oregon rulemaking finishes. Otherwise, the rule for art glass manufacturers may have different or incompatible requirements. The current, temporary rules on art glass manufacturers will expire on October 18th, 2016, and cannot be extended. DEQ is moving to regulate colored art glass manufacturers (CAGMs) in response to data that showed residents near CAGMs were exposed to unhealthy air, in some cases exceeding acute (24-hr) health benchmarks. DEQ feels that these permanent rules are needed now. It is not yet known whether the Cleaner Air Oregon rulemaking will supersede this rule or leave it in place. NW Pulp and Paper Association draft  
58 57 how does DEQ interpret 340-244-9090? The proposed 340-244-9090 says that DEQ "must set a limit on the CAGM’s use of the metal HAP of concern" if ambient concentrations pose an unacceptable risk. How would this work in detail? Doesn't this presuppose the result of the Cleaner Air Oregon rulemaking? The proposed language at OAR 340-244-9090 would give DEQ the authority to act if, despite the rule, DEQ determined that CAGM emissions were found to still be posing an unacceptable risk to people near them. Such a determination would be made in consultation with the Oregon Health Authority but the details are otherwise not specified. DEQ feels this discretion is appropriate because of the potentially actute risks posed by CAGM emissions. The Cleaner Air Oregon rulemaking may supersede this rule or leave it in place. needs review
59 58 fuel-fired furnaces The proposed rule treats electrically heated and fuel-fired furnaces differently in the thresholds between Tier 1 and Tier 2. Are emissions really that different? The 100 tpy threshold for a facility with only electrically fired furnaces to become Tier 2 should be lowered. DEQ is not aware of data comparing the relative emissions of fuel-fired and electrically heated furnaces. However, the physics of fuel-fired furnaces are likely to result in higher emission rates. DEQ is lowering the applicability threshold for the rule to 5 tpy but is not proposing to adjust the Tier 1 / Tier 2 threshold for electrically fired furnaces at this time. Multnomah County Heath Department needs review
60 59 facilities under threshold What requirements will apply to CAGMs that are under the threshold The proposed rule only applies to facilities that produce 5 or more tons per year (previously 10 tpy) of glass containing the specified HAPs. It does not impose requirements on CAGMs who are below that threshold. Multnomah County Heath Department draft  
61 60 measure actual emissions Facilities should be required to measure and report actual emissions. The rule requires facilities to measure parameters of their emission control devices to ensure that they are operating correctly. Source testing to measure actual emissions costs thousands of dollars, and doing so on an ongoing basis would be cost-prohibitive. Cecilia Youngs needs review