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Comment 72 for Proposed Amendments to the ATCM for Chromium Electroplating and Chromic Acid Anodizing Operations (chromeatcm2023) - 45 Day.

First NameWesley
Last NameTurnbow
AffiliationEME, Inc.
SubjectPollution Controls Work! They stop hexavalent chrome in its tracks.
Hello CARB Members:

I wanted to send you proof of the effectiveness of source controls
when it comes to hexavalent chromium emissions. I have attached the
Excel version to make it easy for your team to check formulas.

The South Coast AQMD monitored our facility fence line to fence
line for 9 months. The attached data was pulled from their website.
The fence line monitors where within 20 feet of our buildings, and
our chromic acid anodize tank and spray booths were directly in
between, as the prevailing winds blow. And the winds off of the
ocean are fairly predictable. EME, Inc. was one of the first, if
not the first, to place pollution controls on our chromic acid
tank. That tank and the paint booths are fitted with HEPA

Note that the difference between the monitors is 0.00 nanograms
when the one significantly test result is thrown out (it is less
than a quarter of a nanogram even with that anomaly). The fact that
there are low amounts of hexavalent chromium in the monitors at
most times is because the Alameda Train Corridor and Alameda Ave (a
large thoroughfare) are just downwind from our facility.

Bans are not the way to go! When it comes to hexavalent chromium,
source controls have done the job effectively for years.  

Best regards,

Wesley Turnbow
E. M. E., Inc. 
431 E. Oaks Street
Compton, CA 90221
(323) 717-7871 mobile

Original File NameEME Hexavalent Chromium Monitoring 2017-2018.pdf
Date and Time Comment Was Submitted 2023-01-17 16:57:35

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