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Now that we can see the corrected emission inventory...

On page 37 of this presentation here
(https://ww2.arb.ca.gov/sites/default/files/2022-06/Chrome%20Public%20Workshop%206.9.22_9.30am.pdf)
CARB defined large functional platers as "hard chrome platers W/
Add-On Controls".

On page 38, they show that Large functional platers (defined above)
have a cancer risk of 213 in a million.

In the posted appendix F, Table F.14(b) CARB shows that a cancer
risk of 213 in a million is derived from a facility assumed to be 0
meters from a receptor with throughput of 120,000,000 amp hours and
an emission rate at the ATCM limit of 0.0015. The emission rate of
0.0015 is not the emission rate of a facility with Add-On Controls.
Large chrome platers in California have HEPA systems as required by
the Air Districts. There is no such facility in California with
120,000,000 amp / hours located 0 meters from a residential
receptor, without a HEPA system. Zero.

The highest risk facility has a throughput of 116,500,000, is
located 40 meters from a residential receptor, and has a HEPA
system. The HEPA system efficiency of that facility is unknown by
this writer but CARB's posted materials contain two statements
about HEPA control efficiency. Table 1 of the emission inventory
states 0.0000588, and Table 2 of the emission inventory states
0.000588. Using these values, we can calculate that facility has a
cancer risk between 6 in a million (Table 1 HEPA efficiency) or 60
in a 
million (Table 2 HEPA efficiency). (As an aside, yes it would be
helpful if CARB would correct this previously identified
discrepancy between the two HEPA efficiency numbers in their posted
materials).

Page 39 of the presentation is highly inaccurate in several
respects as we can now determine from review of the emission
inventory just released by CARB. Yet this seems to be the basis for
statements in the ISOR and SRIA and made to the board on January
27.

The presentation referenced above was made to a public workshop on
June 9, 2022 and was (I am sure) troubling to the public and
environmental justice communities who viewed it. They were
misinformed. 
The advocates for this rule have been misinformed. The media have
been misinformed. An industry has been damaged. Large chrome
platers with HEPA controls have been damaged.

CARB. What is your response?