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Comment 19 for Proposed Amendments to the ATCM for Chromium Electroplating and Chromic Acid Anodizing Operations (chromeatcm2023) - 45 Day.

First NameJim
Last NameMeyer
SubjectToward Rule Improvement
As stated previously, the rule language itself could improve by...
1)	Recognizing that some chrome platers who do not use PFAS/PFOS,
are not located near schools, are not located near sensitive
receptors, have fully compliant HEPA systems and 1469 compliance,
are located in CalEnviroScore areas with no population and
therefore no CalEnviroScore, but perform vital work that supports
the national commercial aviation and DOD infrastructure (
should have a right to exist until a substitute technology can be
identified. Don't ban us before the replacing technology is
identified, ban us after the replacing technology is identified.
For us, the substitute technology won't be trivalent plating. Take
out the ban language associated with hard chrome platers - no one
can raise capital with that in there.
2)	Implementing AQMD 1469 statewide. That's it. No need for
anything else.
3)	Reducing the source test requirement to a frequency of five
4)	Allowing currently permitted facilities to add/change permits so
long as compliant to emissions regulations (i.e..1469).
5)	Allowing decorative platers a way to comply rather than a hard

Thank you for your consideration. 

Original File Name
Date and Time Comment Was Submitted 2022-12-19 16:13:06

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