Ideas for changes to the art glass rule:

•  Demonstrating 99% control efficiency may be very difficult for facilities that don’t have a lot of PM coming into their baghouse.

◦  Allow them to show compliance with a baghouse / bag design spec (designed for 99.5% capture?)

◦  Or, create an alternate standard based on grain loading at the outlet?

◦  Or, could a surrogate PM be injected for testing purposes?

•  Clarifications:

◦  Clarify that facilities can operate between permit application and permit issuance?

◦  Is furnace a 'controlled furnace' as soon as baghouse is installed, or does it have to wait until the source test has been performed (or source test results received?)

•  for Tier 1 facilities, treat cadmium like chrome VI and don't allow use of it in uncontrolled furnaces? Cd has a low melting point so only 20% ends up in the final product, presumably 80% goes up the stack. (Abe Fleishman, Northstar 5/17/2016 phone call)

•  Allow use of a mass balance approach to estimate emissions (measure amount in final product + amount in raw materials, assume the rest is emitted?) (Abe Fleishman, Northstar 5/17/2016 phone call)

•  Lower the threshold for rule applicability, to capture facilities making glass in their garages? Apparently there are two garage glassmaking operations in Eugene. (Abe Fleishman, Northstar 5/17/2016 phone call)