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Comment 57 for Proposed Amendments to the ATCM for Chromium Electroplating and Chromic Acid Anodizing Operations (chromeatcm2023) - 45 Day.

First NameJim
Last NameMeyer
SubjectSource Test Frequency
The requirement to source test pollution control systems very two
years is unnecessary and extremely costly. It is unnecessary
because ongoing compliance with Rule 1469 requires ongoing
monitoring of control system parameters such as pressure drops and
slot velocities and documented maintenance practices. District
enforcement of these rule elements assures there is not a need for
source testing frequency greater than every ten years.  CARB's
requirement to test every two years is unreasonable. 

If there is data that supports the need for testing frequency less
than 10 years, CARB should present it. Even the current SC AQMD
requirement is too frequent. 

Original File Name
Date and Time Comment Was Submitted 2023-01-17 07:52:12

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