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Comment 4 for Proposed Amendments to the ATCM for Chromium Electroplating and Chromic Acid Anodizing Operations (chromeatcm2023) - 15-3.

First NameJim
Last NameMeyer
Email Addressjmeyer@aviation-repair.com
Affiliation
SubjectWhat 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). 

Attachment
Original File Name
Date and Time Comment Was Submitted 2023-10-27 07:52:54

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