Comment Log Display

Since we now have a new total hex chrome emission number we can
examine the proportionality between Metal Processors and Metal
Finishers in Paramount.  According to the March 27 modification of
the Emissions Inventory, the STATEWIDE hex chrome emissions of the
ENTIRE METAL FINISHING INDUSTRY in 2019 were 0.19 pounds. You can
verify this by referring to attachment 2, page 22, lower right cell
in the table.
It is helpful to contrast this with the hex chrome emissions
reported in Paramount, California in 2017 from just two sources;
Carlton Forge at 0.6 pounds and Press Forge at 0.3 pounds. That is
just in Paramount. You can verify this yourself by going to CARB's
website here
(https://www.arb.ca.gov/carbapps/pollution-map/?_ga=2.123164547.925282913.1680112885-1134180171.1680112885#)
and using the pollution mapping tool CARB provides. Please use the
filter criteria on the left and select pollutant = hexavalent
chromium, City = Paramount, and Year = 2017. 
Please keep this in mind when you hear CARB staff tell you fugitive
emissions from metal finishers were the problem in Paramount. The
emissions were observed from Metal Processors (See list here:
http://publichealth.lacounty.gov/eh/chromium6/directive.htm) of
which only two of the nine Metal Processors were Metal Finishers
(Anaplex and Lubeco).  
So, again, Carlton Forge and Press Forge reported emissions
totalling 0.9 pounds just a few blocks from the metal finishers
whose entire industry statewide emitted a fraction of that total.
CARB is making no attempt to ban hex chrome emissions from Carlton
Forge which is owned by Warren Buffet. But then, that might be a
bit more difficult for CARB.   
Please note that the modification of the Emissions Inventory
enabled this public comment and it is therefore pertinent for
inclusion in the board's considerations. I reserve the right to
modify this comment if CARB staff amend the emissions inventory for
a third time.