# analysis

Notes:
is there visible emissions monitoring through another rule?


Notes:
Additional document is picture of stained glass window.


Notes:
Additional document is picture of glass art.


Notes:
wants 'highest, strongest' emissions standards.


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


Notes:
regulate cold shops too
require baghouse filters to be rated for 99.9% capture
precautionary principle


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


Notes:
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


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


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


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


Notes:
"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."


Notes:
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


Notes:
suggests 500 lb threshold instead of 10 tons


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


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


Notes:
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.


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


Notes:
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


Notes:
99.9% capture rate
apply to all glass factories, not just art glass


Notes:
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


Notes:
ensure public notice and comment instead of locking the public out of DEQ decisions
health-based standards


Notes:
benchmarks should be the most conservative
99.9% capture rate
all glass manufacturers, not just art glass


Notes:
include all sources of metal emissions
some of comment is a duplicate of their previous entry.


Notes:
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.


Notes:
believes the metals are mostly coming from Lehigh Cement, based on his read of the wind data.


Notes:
5 ng/m3 benchmark for Cr6, to replace current 36 ng/m3 in the rule.


Notes:
control filterable and condensable at 99.9%
apply to all glass manufacturers
more public notice and comment
health-based standards


Notes:
'no wind data was collected or analyzed'
believes lead is from Lehigh Cement, not from Bullseye


Notes:
wants health-based standards
all glass manufacturers not just CAGM


Notes:
wants health-based not technology based
500 lb/year threshold not 10 tpy
legal requirement to consider effect on EJ communities
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


Notes:
revise baghouse source test method to reduce cost


Notes:
health-based standards
99.9% capture
filterable and condensable


Notes:
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


Notes:
supports change from 99% control efficiency to grain loading


Notes:
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."


Notes:
filterable and condensable 99.9%
all HAPs


Notes:
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.


Notes:
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


Notes:
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)


Notes:
"thermal oxidizers"
no metals in uncontrolled furnaces
no chromium in any form should be allowed
require regular monitoring of emissions
revise ambient benchmarks


Notes:
99.9% control efficiency
'close loopholes that allow emissions from uncontrolled furnaces'
include condensable particulate matter
consider fugitive emissions
etc


Notes:
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.


Notes:
believes current definition of 'molten glass' and 'melt' need revision
don't include colored glass in definition of raw material


Notes:
99.9% capture efficiency
all glass factories, not just CAGM
update health benchmarks


Notes:
grain loading standard
cadmium volatilizes, it should be more regulated


# responses

DEQresponse:
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.


DEQresponse:
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.


