Appendix B contains data errors, spreadsheet errors, calculation
errors, and assumption errors. To the extentt it is the source of
any allegations, conclusions, statements, or any logic basis in
support of the ISOR, SRIA, or the rule formulation, it should be
corrected.
The data shown for our facility shows incorrect emissions,
incorrect emission permit limits, and incorrect source test
emission rates. It is difficult to find any row of data in the
appendix that correctly represents any facility.
If CARB is able to identify the correct data and calculations to
support the rule making, we request a new 45 day comment period
following the release of a new appendix B. It is only fair.
A rule making like this, in which there is an opportunity to
decrease overall hexavalent chrome emissions in the state by 0.2%
and will eliminate thousands of jobs, damage the state economy, and
disrupt several industries deserves to be based on correct
data.
|