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Comment 13 for Proposed Amendments to the ATCM for Chromium Electroplating and Chromic Acid Anodizing Operations (chromeatcm2023) - 15-1.

First NameTracey
Last NameCoss
Email Addresstraceycoss@scpci.com
Affiliation
SubjectATCM for hex chrome
Comment
I urge the California Air Resources Board [CARB] to NOT move
forward with the proposed amendment to the Airborne Toxic Control
Measure for Chromium Electroplating and Chromic Acid Anodizing
Operations [CrVI ATCM], and instead to revise the ATCM to provide
emission control measures that will be effective in further
reducing the negligible amount of air emissions of hexavalent
chromium from metal finishing facilities, recognize the extremely
negative consequences of proposed bans, and provide a reasoned,
science-based approach and emission-based rule moving forward.

The proposed ban on CrVI plating fails to acknowledge the
importance of this segment of manufacturing in California, the
significant emission reductions the industry has achieved to date
and can obtain through further emission reduction efforts, and the
increase in emissions (from commercial trucks transporting products
for CrVI plating) that will result from plating operations moving
to other states and countries with less, if any, emission
requirements. Further, bans will leak significant businesses and
associated jobs away from California!

CrVI plating facility emissions have been significantly reduced
over the years to the extent that chrome metal finishing comprises
significantly less than 1% of total annual CrVI emissions for the
entire state. No other state or country has CrVI emission limits
anywhere near the level of protections already established in
California. CARB should acknowledge that protection of the
environment is best achieved in California by working WITH
industry.

I urge CARB to remove the ban, correct the data, SAVE JOBS, and
prevent business from closing down and/or leaving the state.

Attachment
Original File Name
Date and Time Comment Was Submitted 2023-04-10 13:58:41

If you have any questions or comments please contact Clerk of the Board at (916) 322-5594.


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