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Comment 26 for Proposed Amendments to the ATCM for Chromium Electroplating and Chromic Acid Anodizing Operations (chromeatcm2023) - 45 Day.

First NameJim
Last NameMeyer
SubjectParamount (Dichromate Seal Tanks)
Air monitoring in Paramount revealed that dichromate seal tanks
were a source of hex chrome and that CARB and AQMD had NO RULE to
control dichromate seal tanks! The tanks were unregulated. An
uproar ensued. CARB and AQMD came under fire. How could they let
this happen? Blame had to be assessed. Round up the usual platers! A new rule was made. Media headlines
blamed platers but the firms with dichromate seal tanks were NOT
decorative chrome platers and were NOT hard chrome platers. CARB's
allegations about fugitive plating emissions from "uncontrolled
tanks" are based on this situation in Paramount and on another in
Newport Beach. But, again, the Newport Beach firm is NOT a
decorative chrome and NOT a hard chrome plater either. So why does
this rule target decorative and hard chrome plating? Why does it
justify action based on "fugitive plating emissions from
uncontrolled tanks" when hard and decorative platers don't have
dichromate seal tanks? How did CARB draw a line from Dichromate
seal tanks to hard chrome and decorative chrome platers?

Original File Name
Date and Time Comment Was Submitted 2022-12-30 12:22:49

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