# analysis

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Additional document is picture of stained glass window.


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Additional document is picture of glass art.


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wants info about emissions and permit conditions.


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wants 'highest, strongest' emissions standards.


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Appears to be same as previous comment, with comment included as Word doc with some words highlighted.


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wants 99.9% capture rate
wants 'all glass factories', not just art glass


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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


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99.9% capture rate
all glass factories, not just art glass


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update health benchmarks
apply to all glass factories, not just art glass
99.9% capture rate


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99.9% capture rate
revise health benchmarks
apply to all glass factories, not just art glass


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"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."


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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


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suggests 500 lb threshold instead of 10 tons


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supports lower threshold calculated based on modeling and ambient benchmarks
and grain loading standard at 0.005 gr/dscf


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regulate differently for making from raw materials vs those who re-melt. Any size manufacturer that is using raw materials should be regulated.


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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.


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99.9% control efficiency
apply to all glass manufacturers
revise health benchmarks


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99.9% capture
revise Cr6 benchmark to 0.08 ng/m3 (and use that as daily acceptable source impact level in 340-244-9040)


Notes:
99.9% capture
include all glass factories
revise health benchmarks


