| Comment | The previous appendix B Table 2 on Line 3 "Hard with Add-On" showed
the computation of the average source test value used in Table 1 of
Appendix B above it. The calculation included results from seven
tested facilities. The values were:
As shown previously
Test 1 0.00045
Test 2 0.00011
Test 3 0.001
Test 4 0.00034
Test 5 0.00063
Test 6 0.0002875
Test 7 0.0013
Average 0.000588214
Now, I don't know if the facility source test values you used above
are correct or not but I do know math and the math appears to be a
correct computation of the average of the values shown.
In your now corrected emission inventory put out this morning, your
team is using a value of 0.0000588214 as the source test value for
hard chrome. I know that you know that 0.000588214 is a magnitude
of 10 times greater than the 0.0000588214. So, what changed? Your
team has not included a revised Table 2 with the data release from
this morning. Therefore the 0.0000588214 is an unsupported value
since it does not correspond to the yet to be corrected Table 2 of
Appendix B. The official record supporting a hex chrome emission
rule contains this critical 10X uncorrected error which is a
building block of the current emissions of the industry.
I recommend CARB introduce a quality assurance function. Those of
us who are in the aviation safety business (until 2039) have found
value in having a second set of eyes inspect work before it goes
out.
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