First Name | Jim |
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Last Name | Meyer |
Email Address | jmeyer@aviation-repair.com |
Affiliation | |
Subject | What is the specific logic CARB used to bypass the Health and Safety Code? |
Comment | What is the specific logic path CARB used to reject enclosed hexavalent chrome tanks and HEPA ? 1) Is a "phaseout" (or ban) a "more effective control method"? If yes, what is the control? 2) Did the CARB perform an assessment of risk? When was it accomplished? Where are the results of it? Does CARB assert it is appendix F? 3) Relative to an alternative level of emission reduction, how was "adequacy" of HEPA and enclosed tank rejected? What analysis was performed? When was the analysis performed? When did the rejection decision occur? Was the public or any working group able to provide feedback to CARB about the analysis data and methods? 4) Relative to an alternate level of emission reduction, how was "necessity" established? Was there an analysis performed? What were the criteria used to determine necessity? When was the analysis performed? When was the decision made? 5) What is the logic that makes it a necessity to ban enclosed hexavalent chrome tanks and chrome tanks with HEPA controls but makes it not a necessity to ban welding, thermal spray, machining, heat treating, cement making, cement destruction, forging, recycling, refineries, driving cars and trucks (including electric) with brakes, etc., many of which do not require even HEPA? Please provide a response in the public record (FSOR). |
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Date and Time Comment Was Submitted | 2023-10-27 07:52:54 |
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