Comment Log Display

 Since the implementation of RCRA, which is the Resource
Conservation and Recovery Act of 1976.  I have provided Hazardous
Waste Management services to the commercial, industrial, and
military sectors of California since 1977.
 I have the honor to sit on the Board for the National Association
of Surface Finishers and the Metal Finishing Association of
Northern California. 
Over the last 46 years I have seen many changes in the continuing
effort of our regulatory community to eliminate Industrial growth
in the State of California. 
This ban will immediately and negatively impact operations for many
family-owned small businesses.  
This ban will present decorative and functional Chrome 6 plating
facilities with unreasonable choices.
•	Close their operations immediately.
•	Those costs will start at the low end of $375,000.00 to over 1
million dollars, depending on the size of the facility.
•	The current cost for disposal alone of a 1000 gal Chromic Acid
Bath is $7,500.00. This cost does not include the management of
surrounding support equipment of the process. 
•	When a facility is forced to close, it will cause these hard
working Americans to lose their jobs and their family's
livelihoods.
•	Or invest significant dollars over three years to comply with new
CARB emission rules, and ultimately close their operations on the
January 1, 2027 the proposed ban date. 
•	If a facility operator is not properly financially prepared for
such an event, the cost will then need to be absorbed into the
States Superfund budget. Another burden passed on to all our
hard-working California Americans.
•	Please don't think that this ban is going to stop Chrome Plating.
it will simply just go underground with no environmental controls.
This BAN is a painfully irresponsible idea, and your Staff should
be embarrassed to have even brought this flawed data before the
Board.