By Overnight Mail and Email (crangan@ph.lacounty.gov)
December 2, 2016
Cyrus Rangan M.D., P.P.H
Deputy Health Officer
Los Angeles County Department of Public Health
3530 Wilshire Blvd.
Suite 1110
Los Angeles, CA 90010
Re: Public Health Directive to Aerocraft Heat Treating Company, Inc.
Dear Dr. Rangan:
Acrocraft Heat Treating Company, Inc. (“Aerocraft”) is in receipt of your December 1, 2016
letter directing the company to take all necessary actions to ensure that we are not endangering
public health and provide you with alist of actions, implemented and anticipated, to accomplish
that objective. This letter is in response to that directive.
I want to personally assure you that we are taking all necessary actions to ensure that we are not
endangering public health. Aerocraft has been a part of the Paramount, CA community since
1959. The facility employs approximately 50 skilled employees, the majority of whom live
within 10 miles of the facility. We care about the health of our employees and our neighbors.
We have worked cooperatively with South Coast Air Quality Management District
(“SCAQMD") over the past few weeks since they first alerted us that the facility could be a
source of airborne hexavalent chromium. Just yesterday (December 1), we met with SCAQMD
program staff for over two and one-half hours to discuss our findings regarding possible
chromium sources and our action plan for minimizing Aerocraft’s contribution to the
neighborhood’s hexavalent chromium concentrations. The air district noted at our meeting that
Acrocraft is not the only potential source of hexavalent chromium in the community. However,
that is no reason for us to diminish our response in any way. We are well into the process of
evaluating and addressing possible source of hexavalent chromium from our operations. Based
on our meeting yesterday, [ understand that the air district is supportive of the actions we areCyrus Rangan M.D., P.P.H
December 2, 2016
Page 2
taking and believes we are proceeding appropriately. Rest assured we will persist until we are
confident of the effectiveness of our response.
Acrocraft has already implemented multiple measures to minimize our potential to emit
hexavalent chromium. The following is a list of actions taken and planned. This list reflects the
action plan discussed with the air district in yesterday’s meeting.
‘Action Timing
Discontinue use of compressed air for | Complete
cleaning purposes
Discontinue use of dry sweeping Complete
Implement enhanced maintenance Complete
procedures to minimize fugitive dust
including daily use of wet sweeper
Daily vacuuming with HEPA vacuum in| Complete
areas not accessible to wet sweeper
Discontinue operation of plasma torch | Complete
cutting until a collection efficiency
assessment is completed
Confirm absence of chromium in Reviewed SDSs to confirm absence of chromium
refractory brick
Confirm absence of chromium in ceramic | Reviewed SDSs to confirm absence of chromium
coatings
Confirm absence of chromium in oil in | Testing complete showing no detectable chromium
oil quench tanks (total or hexavalent)
Clean water quench tanks and replace
water
‘One tank complete. Two tanks in process. No
water quench tank will be used until cleaned and
tested
Perform employee exposure monitoring
In process (pending availability of industrial
hygiene monitoring professionals)
Perform all grinding operations in a fully | To be completed by 12/3,
enclosed room with dust routed to fabric
filtration unit
Upgrade grind room fabric filter to Engineering in process
include HEPA secondary filtration
Coat heat treat racks with ceramic Starting Monday 12/5
coating to reduce scaleCyrus Rangan M.D., P.P.H
December 2, 2016
Page 3
‘Action Timing
Continue to work closely with South | Ongoing
Coast AQMD to assess benefits from
measures taken to date
As you can see, Aerocraft has implemented multiple actions to minimize our potential to emit
hexavalent chromium. Our ongoing effort is well under way. We will provide you and the air
istrict with routine updates to inform you of our progress implementing the measures above and
to inform you of any additional measures.
‘Thank you for your interest in Aerocraft’s action plan. I hope that you are satisfied that we have
adopted an aggressive approach to minimize our emissions. If you have any questions, do not
hesitate to call me.
Very truly yours,
Greg Stonick
General Manager