# 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)


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99.9% capture
include all glass factories
revise health benchmarks


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


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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


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


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


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


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


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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.


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


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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.


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


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


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


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wants health-based standards
all glass manufacturers not just CAGM


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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


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revise baghouse source test method to reduce cost


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health-based standards
99.9% capture
filterable and condensable


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supports change from 99% control efficiency to grain loading


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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


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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."


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filterable and condensable 99.9%
all HAPs


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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.


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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


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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)


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


