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Comment 39 for Proposed Amendments to the ATCM for Chromium Electroplating and Chromic Acid Anodizing Operations (chromeatcm2023) - 45 Day.

First NameJim
Last NameMeyer
SubjectHEPA 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

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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