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Comment 18 for Proposed Amendments to the ATCM for Chromium Electroplating and Chromic Acid Anodizing Operations (chromeatcm2023) - 45 Day.

First NameJim
Last NameMeyer
SubjectAppendix B (The Emissions Inventory) is not correct

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. 

Original File Name
Date and Time Comment Was Submitted 2022-12-19 14:26:35

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