Comment Log Display

Here is the comment you selected to display.

Comment 25 for Proposed Amendments to the ATCM for Chromium Electroplating and Chromic Acid Anodizing Operations (chromeatcm2023) - 45 Day.

First NameArt
Last NameHolman
Email Addressart@shermsplating.com
AffiliationSherm's Custom Plating
Subject2022 Chrome emissions
Comment
I would like for the board to look at decorative platers emissions
and clearly state why we are being targeted for elimination in
California when we are already highly regulated and have zero
threat to public safety when operating under current ATCM.

I will publicly post my emissions for the 2022 year with data to
prove that shops like mine are not the problem and should not be
required to transition to trivalent or close down operations.

2022 I used 31,322 amp/hrs at a source test rating of 0.00032
The math is 31,322 x 0.00032 = 10.02304 milligrams for all of
2022.
To put this in perspective a paperclip = 1 gram.  

It would take my facility 100 years at these rates to produce 1
gram of chrome, a paperclip worth! Can you see how ridiculous this
is? you have the ability to look at true data on emissions in the
industry and the facts speak for themselves.

Before any decision on a new ATCM is reached the board really needs
to look at facts, the overwhelming majority of platers all have
amp/hr meters and source test documentation that proves the chrome
plating industry as a whole is not the problem with hexavalent
chrome emissions. 

Ships, Rail, Concrete, and mobile sources are huge contributors,
and this new rule will do nothing to change that it will only drive
chrome platers out of state where they are not regulated as tightly
as here in California.



Attachment
Original File Name
Date and Time Comment Was Submitted 2022-12-30 07:03:25

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


Board Comments Home