|Subject||HEPA Filtration not BACT anymore?|
This ATCM imposes a ban on hex chrome use for hard chrome plating even though there is not an alternative. Since the ban is imposed even though hard chrome platers do use state of the art HEPA filtration systems, CARB is establishing a precedent that HEPA filtration systems are inadequate for management of carcinogens. This has major implications for not only hex chrome, but for nearly all the other air toxics in California. CARB would be saying that HEPA filtration is no longer the Best Available Control Technology. A ban would now be the best available control technology. But HEPA filters are effective for control of hex chrome as evidenced by all the other CARB and district rules which require use of HEPA enclosures and booths and which have not been proposed to be revised. There is a long list. Is it CARB's strategy to start with platers to eliminate HEPA filtration as a control method? Are they using us as some sort of Machiavellian example to everyone else. Cull out all the small business platers, win a key case, and then move on to the bigger polluters that make up 99% of the hex chrome problem. Hmmm, very shrewd. It would be false for CARB to state that the ban is necessary due to fugitive (non-HEPA) emissions since CARB has not measured fugitives (or admitted to doing so) at hard chrome platers. Fugitive emissions observed in Paramount and Newport Beach were not from hard chrome plating.
|Original File Name|
|Date and Time Comment Was Submitted||2023-01-13 10:36:22|
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