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Comment 24 for Proposed Amendments to the ATCM for Chromium Electroplating and Chromic Acid Anodizing Operations (chromeatcm2023) - 45 Day.

First NameBobbi
Last NameBurns
SubjectAmendment to Chrome ATCM
For those reading public comments that may not be aware, Hexavalent
Chromium can be found in many places in our everyday lives. Besides
nature and plating shops, Hexavalent Chromium is found within
industries of aerospace, ground transportation, concrete, welding,
leather tanning, wood preserving, fireworks (there goes
Disneyland), cosmetics, cleaning agents and tobacco. Some everyday
items include products in our home like electronics, fixtures,
hardware, furniture and keys. The Chromium finishes are essential
to automobiles including electric cars, aerospace, industrial
machinery, dies and molds; metal finishing adds a variety of
protection, wear resistance, and in some cases restoration.

Permits, inspections, testing and fees are the standard for any
Chromium plating facility in California. Regulations here in
California are the most stringent in the USA. California sets the
standard and is the leader of environmental innovations in the
Country. The proposed ban on Decorative Chrome in the upcoming
amendment to the ATCM simply doesn't make sense.
Banning the Decorative Chrome process here does not make the demand
for the finish go away. There are countless manufacturing and
restoration companies here in this State that will have to close or
ship parts to other States, other States that have little to no
control on the process, creating a new wave of problems. The
technology used today to prevent pollution is superior to what was
used decades ago.

"In 2007, to further protect the public, CARB adopted additional
amendments to the Chrome Plating ATCM, resulting in the most
stringent and health protective emission standards applicable to
chrome plating operations in the nation." This sentence was plucked
straight from CARB's website. 

Since 2007 there has been a significant reduction in CrVI emissions
from plating facilities. We account for less than 1% of the total
CrVI emissions in the entire State. My point is that we are not a
failed regulated industry. The proposed amendment should create an
emission base rule for all covered process equally. The Decorative,
Functional and Chromic Acid Anodize have the same chemistry so why
ban just one?  The amendment should be an emission based rule for
any hexavalent chromium process. The Decorative Chrome process
averages 10k to 40K amp-hrs annually but the Hard or Functional
Chrome and Chromic Acid Anodize process can run-up to and over a
million amp-hrs annually. It is discrimination. 

Proposing alternatives such as Tri-Chrome for decorative finishes
should be an alternative, not the only choice. If a Decorative
Chrome facility is meeting the emission standard, under the
threshold  or non-detect for CrVI emissions then why shut it down?
The ATCM Amendment should be based on science and data, not
emotions. Imposing a discriminatory ban on this process sets a bad
precedent for California. 

I strongly urge CARB to stand by the side of California businesses
that have maintained compliance and continue to invest in better
technologies so that we can continue our craft and be of service to
not only the large manufacturers but the hobbyist and enthusiasts
that rely on our finishes. The stationary source of this hexavalent
chromium is under control of not only the Operators, who are
certified by CARB's program but also by the local Air Districts. 
I am a second generation metal finisher for over thirty years. I am
in good health. My long-time employees are in good health. If I
thought I was endangering my family or community we wouldn't be in
business. Thank you for reading my comments.

Biological fun facts: Ingested Cr(VI) is efficiently reduced to the
Cr(III) by the gastric juices [De Flora, Badolati et al. 1987].
Cr(VI) can also be reduced to the Cr(III) in the epithelial lining
fluid of the lungs by ascorbate and glutathione (Petrilli, Rossi et
al. 1986; Suzuki and Fukuda 1990).
Once absorbed into the bloodstream, Cr(VI) is rapidly taken up by
erythrocytes after absorption and reduced to Cr(III) inside the red
blood cells. In contrast, Cr(III) does not readily cross red blood
cell membranes, but binds directly to transferrin , an
iron-transporting protein in the plasma (made by the liver) EPA
1998; ATSDR 2000; Dayan and Paine 2001].

Original File Name
Date and Time Comment Was Submitted 2022-12-29 13:13:44

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

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