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ANAPLEX

December
2,2016

R E F I N E DM E T A LP R O C E S S I N G

CyrusRangan,
M.D,,M.P.H.
DeputyHealthOfficer
LosAngelesCountyDepartment
of PublicHealth
3530WilshireBoulevard,
Suite1110
LosAngeles,
CA 90010

Re:

Anaplex Corporation - City of Paramount - Responseto Department


Correspondence
and Public Health DirectiveDated December1,20t6

DearDr. Rangan:
As directed,I write in responseto your letter datedDecember1,2016 and the
Public Health Directive issuedto Anaplex Corporation("Anaplex"). First off: I want to assure
the Departmentof Public Health that'Anaplexis committedto operatingin full compliancewith
all applicableenvironmentalrequirements,includingthe SouthCoastAir Quality Management
District's stringentregulationsand the Department'sPublic Health Directive. Sincewe began
operationsat the facility, we have worked closelywith the District engineeringand compliance
staff, and will continueto do so to addressthe complianceissuesraisedby the AQMD together
with the AQMD's proposedOrder for Abatement.
You requestedthat Anaplex provide "a list of actionsto be taken,and proposed
actions"with respectto this Public Health Directive, Our plan forward is dynamic,in that we
haveyet to meet and confer with AQMD legal and technicalstaff. As you may know, the Order
for Abatementmust include list of actionsand schedulewithin which all actionsaie to be
completed,Anaplex fully intendsto comply with the Order for Abatement. Our initial
investigationleadsus to believe there may be misunderstandings
in the information collectedby
AQMD or in the databeing assessed
by AQMD from perimetermonitoring operationsaround
Anaplex.
That said,we provide below a focusedsummaryof actionsthat Anaplex is taking
to addressthis issue:
1.

By Friday.December2:
'

Confirm whether all tanksreferencedby the District do or do not havethe


appropriatepermit authorityto operate.Action; Anaplex has confirmedbased
on its initial reviewthat Anaplex'sl7 AQMD permits are current' 7 of these
AQMD permits relate to plating operations. Relativeto itsplating operations,
as of December2, 2 106,Anaplex is only operatingtanks that are permitted by
AQMD or exemptfrom permitting under District Rule 219. Anaplex will

15547GarfieldAvenue . Paramount,CA 90723 . (562) 634-5700 . (714) 522-4481. fax (562) 634-2867

Dr. Cyrus Rangan


December2,2016
Page2
provide further information to the County and AQMD as its investigation
continuesnext week.
' Eliminate any spargingof chromic acid anodizing tanks when electroplating
is
not occurring. Action: completeas of November30, 2016.
' Eliminate spargingat Tank 33 (deoxidizer tank) and Tank 38 (sulfuric
acid
anodizetank. Action: completeas of November30, 2016.
'
Examine statusof Tank 42 andits usewithout control technology.Action
taken: Tank 42 removedand operationsdiscontinued.
' Examine the dischargeof hexavalentchromium, a known carcinogen,
based
on 17 perimetermonitoring resultsconductedbetweenNovember 5 and
November 20,2016 attachedto the AQMD Notice of Violation servedon
November29,2016. Action: Anaplexconducteda review of the AQMD
avqilable data and identified at least two days that show that someof the
highestreported chromiumemissionsoccurredon two monitoring dayswhen
Anaplex was either closed or when no chromiumplating/anodizing occurred.
Monitoring location I5 is locatedI0 feet from Anaplex's main operationson
Garfield Avenue. On Thursday,November17, 2016, when thefocility was in
full operation,the AQMD reportedambientconcentrationsof 2.3 ng/m3,
roughly three times (3x) lower than when the days on which thefacility had no
operations involving chromium or wos entirely closed. Further, on Sunday,
November20, 2016 whenAnaplexoperationswere closed,AQMD reports
monitoring location I5 ambientmonitoring data as I0 ng/m3. Finally, on
Saturday,November5, 2016, a day when there were no chromiumplating
operations were being conducted,the highest repor:tedconcentrationsfor site
l5 (andfor that matterfor all of the sites included in the AQMD notice of
violotion) was reported by AQMD as 26 ng/m3. As a result of this
preliminary analysis, it may bepremature to attribute all of the chromium
detectedto Anaplex. Anaplex is continuing its review of the data provided to
AQMD and has requestedfromAQMD permit application and other
documentsin anticipationof meetingwithAQMD next Thursday,DecemberB,

20r6.

2.

By Frida)' December9:
!

Meet and confer with District legal and technical staff to confirm the Order
for Abatementto developa refined compliancescheduleand list of actionsto
assurecompliancewith District regulations.We will provide this list to the
Public Health Departmentonceit is agreedto.

Dr. Cyrus Rangan


December
2,2016
Page3
3.
B)' Wednesda)'.December14
'

Appear before the District Hearing Board in support of the Order for
Abatement, and obtain Hearing Board's approval of the actions that will
support issuanceof the Order for Abatement.

As you requested,Anaplex will copy the District (specifically,Kirk Wiese,Esq.,


BarbaraBaird, Esq. and William B. Wong, Esq.)on all of our communicationswith your
Departmentgoing forward.
We are committed to working with the District and Department of Public Health
to assurethat Anaplex operationsare in full compliancewith District regulations and Los
AngelesCountyCode 11.02.190.

Car@n Campbell

Kirk Wiese,Esq.
BarbaraBaird,Esq.
WilliamB. Wong,Esq.

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