Art Glass Permanent Rulemaking
Comments summary (beginning of day 7/29/2016)
1. Consider economic impact on glass artists, don’t shut down CAGMs, give them more time or flexibility [glass artists]
2. Include all metal HAPs or all HAPs in rule [EPAC members]
a. “Close loopholes that would allow for emissions of heavy metals from uncontrolled furnaces”
3. Make rule apply statewide [EPAC members]
4. Update health benchmarks [EPAC members]
5. Include all glass manufacturers (include General Glass and Owens-Brockway, not just art glass) [EPAC members]
6. Replace 99.0% baghouse source test standard
a. Use 99.9% [EPAC members]
b. 0.005 gr/dscf [Glass Alchemy]
c. 0.2 lbs/ton of glass produced [Bullseye]
7. More transparency
a. Online video of all public meetings
b. Online searchable database of air permits or emissions info
c. “ensure public notice and comment instead of locking the public out of DEQ decisions”
8. Replace 10 tpy applicability threshold
a. Everybody that melts glass should have to report, define threshold lbs/year usage rate for each metal. All above that threshold are subject to the other parts of the rule. [Glass Alchemy]
b. Use 1 lb/year [EPAC]
9. Replace Cr6 benchmark in rule
a. Use 0.08 ng/m3 as 24 hr limit. Mentions ASTDR 2-week number. (EPAC)
10. Tier 2 chrome usage rates
a. allow testing for total Cr at outlet of baghouse (Method 29) and assuming all of it is Cr6. [Bullseye]
11. What about non-filterable emissions? [EPAC]
Joe Westersund, 2016-07-29T10:11:00Z
Add cobalt and selenium
Joe Westersund, 2016-07-29T10:26:00Z
Not sure
Are there CAGMs outside Portland that would be subject?
Other option is to amend to be statewide as part of CAO next year.
Joe Westersund, 2016-07-29T10:29:00Z
Test on outlet for all metals
Joe Westersund, 2016-07-29T10:40:00Z
If we require Method 29, does that include non-filterable emissions?
Once we have Method 29 exit emissions data, what do we do with that?
Require Tier 2s to do source testing + modeling for all metals not just Cr?