George’s intro to Q and A session

Good evening everyone. As Joe indicated, we’ll have a question and answer period before taking your comments. I’d like to make a few introductory remarks, and then we’ll begin the questions and answers.

In April of this year the Environmental Quality Commission adopted temporary rules for regulation of colored art glass manufacturing facilities in the Portland area.

Temporary rules can be in effect for up to 6 months; after that they expire. In order for the rules to remain in effect, a permanent version of the rules must be adopted. The temporary colored art glass manufacturing rules will expire on October 18 of this year.

Besides the fact that temporary rules can only be in effect for 6 months, the other major difference between temporary and permanent rules is that temporary rules can be adopted without public notice, while permanent rules must have full public notice, which includes a hearing and an opportunity to submit comments.

At this time, DEQ is proposing permanent rules to replace the temporary rules adopted in April.

•  The proposed permanent rules were placed on public notice at the end of June.

•  Tonight is the public hearing for the proposed rules, and verbal comments can be given tonight.

•  In addition, written comments will be accepted until 5 p.m. Friday, July 29, 2016. Information on how to submit written comments can be found in the public notice.

I’d like to briefly describe the major elements of the temporary colored art glass rules:

The rules apply to facilities that manufacture colored art glass, provided the facility manufactures 10 tons per year of colored art glass or more, and the facility is located in the Portland Air Quality Management Area, which is basically the greater Portland area.

The smaller colored art glass manufacturers are classified as Tier 1 facilities, while the larger facilities are classified as Tier 2. There are 3 Tier 1 facilities, and 2 Tier 2 facilities.

Beginning on September 1, the larger Tier 2 facilities may not use raw materials containing As, Cd, Cr, Pb, Mn or Ni except in glass-making furnaces that use an emission control device that meets the requirements of the rules.

The Tier 2 facilities also have other metal usage restrictions.

The smaller Tier 1 facilities have three options, which have to be met by October 1:

•  Option 1 is to install an emission control system that meets the requirements of the rules, and to only use raw materials containing As, Cd, Cr, Pb, Mn or Ni in glass-making furnaces that use the emission control device;

•  Option 2 is to perform emissions testing and dispersion modeling and show that their emissions have ambient impacts that are less than levels specified in the rules; and

•  Option 3 is to request permit limits that prohibit the use of one or more of the metals.

Finally, the rules include a requirement for both Tier 1 and Tier 2 facilities to test the emission control system and show that it has a particulate matter removal efficiency of 99.0 percent or more.

For the proposed permanent rules, DEQ has not proposed any changes from the original temporary rules.

However, DEQ did request input on whether other options should be considered. The options that DEQ requested input on are:

•  Should the rules be modified to apply to sources that make less than 10 tons per year of colored art glass? If so, what threshold would be appropriate?

•  Should the rule be modified to apply statewide, rather than only in the Portland AQMA?

•  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. Should the 99.0% capture efficiency standard be replaced with some other requirement?

That’s the end of my introductory remarks, and we’ll now open the floor for questions until 6:45.

WESTERSUND Joe, 2016-07-18T16:38:00Z
I think public comment started June 15^th. But you’re right that it didn’t get published in the Oregon Bulletin until the end of June.

WESTERSUND Joe, 2016-07-18T17:09:00Z
I’m planning to talk about the overall rulemaking process including this stuff in my intro but I think it’s also fine for you to repeat it here.

WESTERSUND Joe, 2016-07-18T17:07:00Z
What do you think about mentioning something about baghouses?

‘There are multiple kinds of emission control devices, but many CAGMs have told DEQ they intend to comply with the rule by installing one or more baghouses.’

WESTERSUND Joe, 2016-07-18T17:23:00Z
My suggestions here are an attempt to make this sound more conversational.