Comment Log Display

October 30, 2023
On October 16, 2023. the California Air Resources Board released
the Chrome Plating ATCM Third Notice of Public Availability of
Modified Text. Amendments to the Airborne Toxic Control Measure for
Chromium Electroplating and Chromic Acid Anodizing Operations. We
support the proposed amendments and commend the staff for the
integrity of this work.
This correspondence provides comments on the document. As
mentioned, in previous correspondence we were encouraged by the
Board's approval of the ATCM Amendments. Greg Harris and his staff
modified the language to correct grammatical errors and more
importantly to clarify the language in the document.
Florence Gharibian, Chair of the Del Amo Action Committee served as
a Branch Chief in Department of Toxic Substances Control
Enforcement Program for several years. Ambiguous language
diminishes the ability of inspectors to do the important work of
ensuring regulatory requirements are met. It can also make
compliance more difficult.
As example of clarification of the ATCM Amendments staff removed
the word "only" and removed the phrase "except for the requirements
set in 93102.4" to clarify the applicability requirements for
facilities that have enclosed hexavalent chromium plating tank(s).
This modification was necessary and strengthens the ASTM. The
modification makes it clear that chromium plating tanks are subject
to that section's requirements for facilities that use hexavalent
chromium. Clearly the enclosure of hexavalent chromium plating
tank(s) is necessary and significantly reduces air emissions of
this dangerous chemical.
Thank You for providing an opportunity to comment,
Florence Gharibian, Chair Board of Directors
Del Amo Action Committee
Cynthia Babich, Director
Del Amo Action Committee