First Name | Florence |
---|---|
Last Name | Gharibian |
Email Address | florencegharibian@yahoo.com |
Affiliation | Del Amo Action Committee |
Subject | ATCM Amendments |
Comment | 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 |
Attachment | www.arb.ca.gov/lists/com-attach/458-chromeatcm2023-B2FVP10zVHVQMwRq.pdf |
Original File Name | FlorenceHexChrome10302023 (9).pdf |
Date and Time Comment Was Submitted | 2023-10-31 15:57:54 |
If you have any questions or comments please contact Clerk of the Board at (916) 322-5594.