Comment Log Display

The revised data posted on 4-26-23 refer to an average source test
value for hard chrome platers of 5.88E-04. The footnote 3 in table
1 points the reader to the source of that number which is Table 2.
Table 2 contains a line labeled Hard with Add-On that shows seven
values which do computationally average 5.88E-04. How did CARB
select those seven values as representative samples for the hard
chrome population? I am particularly curious how the values 0.001
and 0.0013 were selected as they do not appear to be consistent
with values that would be the result of HEPA Control System source
tests. If they were not from HEPA control systems, can CARB why
they have chosen to create an average from a sample in which 28% of
hard chrome platers do not have HEPA controls. Is that
representational. Why didn't CARB simply use actual source test
values from all the facilities? Does CARB have source test data
from all the facilities for which this rule is being proposed? If
not, why not? Has CARB asked the air districts for the data
necessary for this rule? Did the air districts comply with CARB's
requests? Has CARB chosen to omit some source test data which it
has in its' possession from the average? If CARB has omitted data
from any particular facility from the average, why? Since a key
element of this rule making is the analysis of BACT, how did CARB
reach a conclusion about BACT efficiency? Dos CARB understand the
efficiency of HEPA's? Clearly they have had some difficulty in
applying and communicating the efficiency in this proposed rule.
CARB staff proposes a ban, purportedly because emissions are too
high even with BACT, so they should have done some studying of BACT
efficiency. Observation of the emissions inventory and the changes
to the emissions data to this point suggest that CARB staff did not
understand BACT efficiency to this point in the process. What is
the rationale for a ban in light of the HEPA efficiencies of each
of the HEPA controlled facilities in California?  I submitted my
HEPA source test result to CARB at CARB's request prior to the rule
proposal. CARB has not used my source test result to show the
efficiency of my facility. Rather, it has used the much higher
"average" that it has arbitrarily computed. CARB did not use my
source test data to compute the average. My data has been ignored.
My data would have reduced the average. My system was source tested
in 2019. What was the time period of the source tests CARB used in
the average they show here? My system tested at 0.000023. The
average that CARB has used and applied to me and all the other hard
chrome facilities in this inventory is 25 TIMES HIGHER than my
actual test. Obviously, inclusion of my data would have affected
that average. So, what was the logic that CARB used to exclude my
data? Did the logic used have anything to do with CARB's objectives
for this rule making?