Comment submitted by Michel Weiss, Fleet Readiness Center Southeast (FRC-SE), Navy Department

Sec. 63.11490(f)(5) requires one to "[m]inimize or reduce heating during tank operation and when tanks are not in use." It must be noted that unless a tank is down for an extended period of time, it may not be practical to adjust the bath temperature as this could affect stability of the particular process and/or the bath chemistry. For example, nickel plating bath temperatures must be stabilized at proper settings to ensure boric acid levels are optimally maintained. It takes significant time for temperatures to stabilize, considering the large bath volumes. Therefore, it is impractical to require any general bath temperature adjustments. It is suggested that the proposed regulation be rewritten to state, "[w]here practical, minimize or reduce heating during tank operation and when tanks are not in use."