Comment Log Display

Here is the comment you selected to display.

Comment 20 for Proposed Amendments to the ATCM for Chromium Electroplating and Chromic Acid Anodizing Operations (chromeatcm2023) - 45 Day.

First NameJim
Last NameMeyer
SubjectComputing the Cancer Risk for my facility
Let's look at the risk from our facility using the data that CARB
provides on pages 173 to 175 of the ISOR. CARB breaks the risk up
into two pieces, the risk to residents, and the risk to off-site
workers in the area. 

We are located in an industrial zone in the 90813 zip code area.
There are no residential buildings within 500 meters. According to
figure V.1 that means that our cancer risk to residents is ZERO. 

Yes, zero risk to residents. But, let's go on and look at offsite
worker risks. At the bottom of page 175, CARB states, and I quote,

"For the 2019 baseline, the estimated potential cancer risks range
approximately from less than one in a million to 17 chances per
million, depending on the level of plating operations at the
So, we can use this to compute the cancer risk. Even though 17 in a
million is the worst case, and even though it would be better for
my illustration to use one in a million, we will use the higher
number; even though we are a smaller facility. How many offsite
workers are there around us? We don't know for sure but we can make
a useful estimate. 
The 90813 zip code is one of the densest in the state (#31 as a
matter of fact) and has a density of 18,175 people per square mile.
If we draw a circle around our facility at a radius of 500 meters,
the area is 0.3 square miles. Applying a little arithmetic, we can
compute an estimate of 5,452 workers within that circle if the work
force is dispersed at a similar density to residents. But maybe it
is not, so let's make an extreme assumption about the number of
workers within 500 meters of us and say it is 25,000. Our
assumption is between 5,000 and 25,000 people work within 500
meters of us. Using the highest figure, we can compute that 0.425
offsite workers (25,000 X 0.000017 = 0.425) might get cancer. Let
me repeat that number 0.425.

And looking at a previous sentence CARB states that, and I quote: 
"The guidelines assume that a worker at a nearby worksite is
exposed to the emissions for 25 years, 250 days per year, and 8
hours per day."
So, in order to get 0.425 cases of cancer, we need 25,000 people to
stay within 500 meters of this facility for 8 hours a day, 250 days
per year, for 25 years!

There it is, for my facility, using CARB's numbers and conservative
assumptions, we get less than 1/2 of one cancer case. I hope you
get the point.

So why after more than three years of engagement in this ATCM
process with CARB and the preceding rule 1469 process with AQMD and
CARB is this small business dealing with the existential threat of
a ban? Who is in charge? Is anyone at CARB capable of making a
decision to stop this madness? Is this what AB 617 hath wrought? We
are being damaged.

Original File Name
Date and Time Comment Was Submitted 2022-12-21 15:23:31

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

Board Comments Home