Comment Log Display

The staff presentation to the Board on January 27 contained two
slides which referred to a "213 in a million" cancer risk from
chrome platers. The "213" value comes from Table F.14(b) in
appendix F page 28. Table F.14(b) shows the cancer risk from large
hard chrome facilities without controls, and maps the cancer risk
using two variables, throughput, and proximity. 

Considering there are ZERO facilities in California with throughput
at 120,000,000, and likely ZERO hard chrome facilities operating
without HEPA controls, and ZERO facilities of anywhere close to
that size that are 5 meters from a residential source, CARB's
allegation of a "213 in a million" cancer risk from chrome plating
is a complete FALSEHOOD. Unfortunately, the LA Times picked it up
and has published it as a general description of the cancer risk
from large chrome facilities.

I challenge CARB to spend a few minutes and locate the facility
that has the highest cancer risk in the state using Table F.14(b)
(proximity and size) but also in consideration of the HEPA controls
that facility operates with, and tell the public what the real
truth is about the maximum cancer risk at the highest risk real
chrome plating facility in California. The answer will not be 213
in a million.

This comment is not about any modifications to the rule that were
published on March 27. It is about incorrect cancer risk contained
in CARB materials presented to the board on January 27 and which
influenced the board's feedback to the staff on that date. Page 24
of the presentation states "Controlled Tanks". Table F.14(b)
contains information about uncontrolled tanks.