San Joaquin Valley 

AIR POLLUTION CONTROL DISTRICT HEALTHY AIR LIVING 

GOVERNING BOARD 

J. Steven Worthley, Chair 

Tulare Counr, 

Ann Johnston, Vice Chair 

Mayor, City of Stockton 

Tony Barba 

Supervises, Kings County 

DATE: December 15, 2011 

TO: SJVUAPCD Governing Board 

FROM: Seyed Sadredin, Executive Director/APCO 

Project Coordinator: Errol Villegas 

RE: ADOPT PROPOSED AMENDMENTS TO RULE 4625 

(WASTEWATER SEPARATORS) 

RECOMMENDATION: 

1 Adopt Proposed Amendments to Rule 4625 (Wastewater 

Separators). 

2 Authorize the Chair to sign the attached Resolution. 

BACKGROUND: 

In continuing efforts to reduce emissions from stationary sources in 

the Valley, your Board adopted amendments to Rule 4625 

(Wastewater Separators) in December 1992. The adopted 

amendments included stringent emissions limitations and design 

requirements that control volatile organic compound (VOC) emissions 

from wastewater separators. After adoption, the rule was submitted to 

the Environmental Protection Agency (EPA) for evaluation and 

inclusion into the State Implementation Plan (SIP). 

EPA evaluated the amended rule and determined that while the rule 

largely meets Clean Air Act requirements, several issues needed to be 

further evaluated to ensure the rule fully satisfies the requirements of 

the Act for reasonably available control technology or RACT. The 

District has conducted a thorough analysis and is proposing 

amendments that are expected to result in full EPA approval of Rule 

4625. Today's recommendations will increase vapor control efficiency 

from 90 to 95%, remove exemptions and outdated language, add 

definitions, and add recordkeeping and maintenance requirements. 

District staff have determined that the amendments will not achieve 

significant emissions reductions or have a significant impact on affected 

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Supervisor, Fresno County 

Bonn Doininici 

Supervisor. Madera County 

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Randy Miller 

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William O'Brien 

Supeiwsnr. Sunislaus County 

Leroy °miles 

Superviser, Sari Joaquin County 

Alexander C. Sherriffs, 

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Chris Vierra 

Mayor. City of Cores 

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Supetvittx. Merced County 

Raymond A. Watson 

Supervisor, Kein Cowl 

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Small City Repiesontative, Kings County 

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Large City Representative. Tulare County 

Seyed Sadredin 

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Northern Region °Ike 

4800 Enteiprise Way 

Modesto, CA 95355-6718 

f209 557 6490 • FAX 12091 557•6475 

Central Region Office 

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Fresno, CA 93726 , 0244 

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SJVUAPCD Governing Board 

ADOPT PROPOSED AMENDMENTS TO RULE 4625 (WASTEWATER SEPARATORS) 

December 15, 2011 

sources since the District has existing requirements in place that affect these sources. 

These existing requirements, including the existing rule, New Source Review permitting, 

and the District's risk management requirements, have already eliminated or reduced the 

majority of emissions from this source. Rather than looking at these requirements 

collectively as a demonstration that Valley sources meet Clean Air Act requirements, the 

Act still requires each rule to specifically contain the RACT limits. Although no significant 

reductions in actual emissions will be achieved, the proposed amendments will satisfy 

these administrative requirements. 

This rule addresses VOC emissions from a source category that is relatively small, with 

only 7 wastewater separators impacted by this rule. VOC emissions reductions are 

generally far less important to the Valley's long-term attainment goals than are oxides of 

nitrogen (N0x) emissions reductions. As such, the Valley's attainment strategies generally 

emphasize NOx reductions. The District will continue to seek as much VOC reductions as 

expeditiously practical, technologically feasible, and as economically reasonable as 

determined by the Governing Board. 

DISCUSSION: 

EPA finalized a limited approval of Rule 4625 on July 7, 2011. To demonstrate RACT, 

EPA suggested removing exemptions, increasing the required vapor control efficiency, 

and including requirements for recordkeeping and inspection. District staff evaluated 

existing standards and worked with affected sources to incorporate EPA's recommended 

changes as appropriate. The proposed rule was made available to the public 30 days 

prior to this public hearing. Based on further review, the District has made minor revisions 

to the proposed rule. The revised proposed language does not change the applicability, 

requirements or intent of the rule. 

Summary of Proposed Amendments to Rule 4625 

District staff is proposing increasing VOC control efficiency requirements from 90% to 

95% for units with vapor recovery systems. The revised proposed rule includes the 

removal of all exemptions from the rule, including exemptions for air floatation units, 

exemptions from New Source Review, and exemption for units that exceed a set ratio of 

sump surface area to oil vapor loss. The proposed amendments also include new 

requirements for recordkeeping and inspection. Additionally, the District proposes to 

add definitions to Section 3.0 of the rule to add rule clarity and address a concern from 

stakeholders during the rule development process regarding the definition of custody 

transfer. District staff is also proposing to remove the compliance section as requested 

by EPA comments and confirmed by affected sources to not be in use. 

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SJVUAPCD Governing Board 

ADOPT PROPOSED AMENDMENTS TO RULE 4625 (WASTEWATER SEPARATORS) 

December 15, 2011 

Emission Reduction Analysis 

Emission reductions from the proposed amendments are not anticipated since most 

facilities are already complying with the proposed VOC emission limits or can make 

minor operating changes to be in compliance. 

Cost Effectiveness Analysis 

Pursuant to California Health & Safety Code Section (CH&SC) 40920.6(a), the District is 

required to analyze the cost effectiveness of new rules or rule amendments that 

implement Best Available Retrofit Control Technology (BARCT) or planning 

requirements to incorporate all feasible measures. The proposed amendments to this 

rule would only add federal RACT requirements but not BARCT or all feasible 

measures, and are therefore not subject to the cost effectiveness analysis mandate. 

Given that operators are generally complying with the increased control efficiency 

requirements currently and there are no significant emission reductions or compliance 

costs expected from these rule changes, a cost effectiveness analysis has not been 

performed. 

Socioeconomic Analysis 

Pursuant to CH&SC 40728.5(a), "Whenever a district intends to propose the adoption, 

amendment, or repeal of a rule or regulation that will significantly affect air quality or 

emissions limitations, that agency shall, to the extent data are available, perform an 

assessment of the socioeconomic impacts of the adoption, amendment, or repeal of the 

rule or regulation. This section does not apply to the adoption, amendment, or repeal of 

any rule or regulation that results in any less restrictive emissions limit if the action does 

not interfere with the district's adopted plan to attain ambient air quality standards, or 

does not result in any significant increase in emissions." 

The proposed amendments do not significantly affect air quality and no significant 

emission reductions are expected or claimed. The proposed amendments are primarily 

administrative changes such as the addition of inspection and recordkeeping. Affected 

sources could be impacted by increasing the required the control efficiency of vapor 

control systems from 90% to 95%. However, District staff has determined that all 

sources subject to Rule 4625 that utilize vapor recovery as the sole means of complying 

with the rule already achieve 95% control efficiency. Based on discussions with 

operators, the changes do not create a significant change to their operations or 

economic situation since they are already using compliant materials or do not use the 

specialty materials that are being impacted. Therefore, staff concludes that there would 

be no significant socioeconomic impact from this rule. 

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SJVUAPCD Governing Board 

ADOPT PROPOSED AMENDMENTS TO RULE 4625 (WASTEWATER SEPARATORS) 

December 15, 2011 

Rule Consistency Analysis 

Pursuant to CH&SC §40727.2, District staff evaluated the elements of amendments with 

the corresponding elements of other District rules and federal regulations that apply to 

the same source category or type of equipment. District staff found that the proposed 

amendments and requirements of this rule would not conflict with federal rules, 

regulations, or policies covering similar stationary sources. 

Environmental Impacts 

Adoption of the proposed amendments would limit VOC emissions from wastewater 

separators. As discussed in this Staff Report, the District proposes to make several 

minor and administrative changes to further strengthen District Rule 4625. The District 

performed an environmental analysis of the reasonably foreseeable methods by which 

compliance with the amended rule will be achieved. The District concludes that 

implementation of the proposed amendments would not result in foreseeable changes 

in existing operating practices impacting environmental resources. Staff concludes that 

there is no substantial evidence in the whole record before the District that the proposed 

amendments would cause any adverse environmental effects. Thus, the District finds 

that the project is exempt per the general rule that California Environmental Quality Act 

(CEQA) applies only to projects which have the potential for causing a significant effect 

on the environment (CCR §15061(b)(3)). 

Rule Development Process 

As part of the rule development process, District staff hosted a stakeholder meeting in 

September 2011 and a public workshop in October 2011 to discuss potential rule 

amendments with stakeholders. Staff solicited comments from the public, affected 

sources, trade organizations, California Air Resources Board (ARB), and EPA. 

Comments received were evaluated and incorporated into the rule as appropriate. 

The notice of the public hearing for the proposed rule amendments was published in 

general circulation newspapers in each of the eight San Joaquin Valley counties, and 

will be made available for review on the District website prior to this public hearing. 

FISCAL IMPACTS: 

District staff expects no fiscal impact to the District to result from this action. 

Attachments: Attachment A: Resolution for Revised Proposed Amendments to Rule 4625— (4 pages) 

Attachment B: Revised Proposed Rule 4625 - (6 pages) 

Attachment C: Final Draft Staff Report with Appendices for Revised Proposed Rule 

4625 — (34 pages) 

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