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Appendix “C” 

Public Comments and Responses 

1. USEPA comments on preliminary draft, April 23, 2014 

2. Searles Valley Minerals comment, 04/09/2014 

3. USEPA “No Comment” letter, May 30, 2014 

4. CARB “No Comment” letter, June 6, 2014 
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Comment 1 – USEPA, April 23, 2014 
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District Response to comment letter 1 

1. The reference to custody transfer as referenced in SJVUAPCD Rule 4625 §2.0 in has not 

been included as the District has no oil producers, and custody transfer references the physical 

and contractual ownership transfer of produced fluids from an oil producer to another entity 

(SJVUAPCD Rule 4625 §3.4). 

2. Leak detection limit has been lowered to 500 ppm in definition (B)(9) and Section 

(C)(3)(a).. 

3. Updated definition of oil-water separator includes “Any device or piece of equipment, 

which utilizes the difference in density between oil or petroleum products and water to remove 

the oil or associated chemicals from the water, or any device, such as a flocculation tank, 

clarifier, etc. that removes petroleum-derived compounds from wastewater.” The applicability 

was also amended to include air flotation units. 

4. Thank you for comment. No response necessary. 

5. Leak detection limit has been lowered to 500 ppm in definition (B)(9) and Section 

(C)(3)(a). 

6. Exemption was revised for clarity. This exemption was the prior applicability. 

7. Thank you for comment. No response necessary. 

8. Thank you for comment. No response necessary. 

 
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Comment 2 – SVM, May 13, 2014 

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District Response to comment letter 2 

1. As suggested, proposed section (D)(1)(b) has been modified to address the volume 

portion of the exemption, with the RVP reference being moved to new section (D)(1)(c). 

2. As suggested, proposed section (D)(1)(c) has been added to address RVP separately. 

The previous applicability exempted structures or systems collecting process effluent, recovering 

more than 760 liters per day, and collecting petroleum products with a RVP of 25 mm Hg or 

more. The way the exemption was proposed in the preliminary draft of the rule, it exclusively 

exempted systems collecting less than 760 liters with a RVP of 25 mm Hg or more. This 

proposed exemption, simply meant to restructure the previous applicability, actually excluded a 

large portion of the exemption that was intended to be included. Splitting the volume and RVP 

into separate sections presents the exemption as intended. 

 
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Comment 3 – USEPA, May 13, 2014 
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District Response to comment letter 3 

No response required. 

 
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Comment 4 – CARB, June 6, 2014 
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District Response to comment letter 4 

No response required.