SAN JOAQUIN VALLEY AIR POLLUTION CONTROL DISTRICT 

Appendix A: Comments and Responses December 15, 2011 

A - 1 Final Staff Report with Appendices for 

 Revised Proposed Amendments to Rule 4625 

APPENDIX A 

Summary of Comments on Responses 

For Revised Proposed Amendments to Rule 4625 

December 15, 2011 
SAN JOAQUIN VALLEY AIR POLLUTION CONTROL DISTRICT 

Appendix A: Comments and Responses December 15, 2011 

A - 2 Final Staff Report with Appendices for 

 Revised Proposed Amendments to Rule 4625 

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SAN JOAQUIN VALLEY AIR POLLUTION CONTROL DISTRICT 

Appendix A: Comments and Responses December 15, 2011 

A - 3 Final Staff Report with Appendices for 

 Revised Proposed Amendments to Rule 4625 

SUMMARY OF SIGNIFICANT COMMENTS FOR 

RULE 4625 (WASTEWATER SEPARATORS) 

FOR THE PUBLIC HEARING 

EPA REGION IX STAFF COMMENTS 

 No comments were received from EPA. 

ARB STAFF COMMENTS 

 No comments were received from ARB. 

STAKEHOLDER COMMENTS 

 No comments were received from stakeholders. 
SAN JOAQUIN VALLEY AIR POLLUTION CONTROL DISTRICT 

Appendix A: Comments and Responses December 15, 2011 

A - 4 Final Staff Report with Appendices for 

 Revised Proposed Amendments to Rule 4625 

 

SUMMARY OF SIGNIFICANT COMMENTS FOR 

RULE 4625 (WASTEWATER SEPARATORS) 

EPA REGION IX STAFF COMMENTS 

 No comments were received from EPA. 

ARB STAFF COMMENTS 

 No comments were received from EPA. 

STAKEHOLDER COMMENTS 

Association of Irritated Residents (AIR) 

Insight Environmental Consultants (IEC) 

Kern Oil and Refining Company (KORC) 

1. COMMENT: The current standard of 90% capture and control and the proposed 

standard of 95% are far too low. The required capture and control percentage 

should be 98% because emissions in the San Joaquin Valley are of greater 

proportion here than in the South Coast region. Oil companies should also be 

mandated to achieve 98% recovery. (AIR)

RESPONSE: The purpose of this rule-amending project is to address RACT 

deficiencies as identified by EPA in the Federal Register. RACT is the lowest level 

of control requires for non-attainment areas. Currently there are no other regulations 

that require 98% capture and control. The rule requires the best possible controls 

and now includes requirements for inspection and maintenance. 

2. COMMENT: In order for the rule to retain consistent APCD formatting, the District 

should keep section 4.0, and label it “[Reserved]”. This would bump regulatory 

requirements back to Section 5.0 of the Rule and Administrative requirements et. al. 

back to 6.0. (IEC)

RESPONSE: District staff agrees with this comment and will retain Section 4.0.

3. COMMENT: The District should include a clear definition of “custody transfer” to 

avoid confusion and ambiguity of which parties to whom the rule applies. If the 

definition is not added in this rule, then the District should improve the clarity of 
SAN JOAQUIN VALLEY AIR POLLUTION CONTROL DISTRICT 

Appendix A: Comments and Responses December 15, 2011 

A - 5 Final Staff Report with Appendices for 

 Revised Proposed Amendments to Rule 4625 

Section 2.0, add the definition to the Definition Rule 1020, or reference the 

appropriate District rule where the phrase is defined. KORC’s understanding of the 

rule is that the District meant to apply it to the oil/water separators at non-oil 

production sites (i.e. refineries or other manufacturing locations). (IEC, KORC)

RESPONSE: District staff reviewed this comment and recommends adding a 

definition of custody transfer to Rule 4625. Please see page 3 of the staff report for 

more details. 

4. COMMENT: Section 4.4 requires that recovered oil or tar must be routed to a 

process unit or a 90% controlled storage unit. However, Rule 4623 already covers 

the requirements for the storing of organic liquids, including specific allowances for 

the storage of organic liquids with TVP < 0.5 without vapor control. Section 4.4 

should be amended to include provisions for storage or recovered oils in otherwise 

Rule 4623-compliant tanks.

KORC recommends the new section read similar to: 

Skimmed oil or tar removed from wastewater separating devices shall be either 

charged to process units with feed or transferred to a container with a control system 

with at least 90% control efficiency by weight or otherwise in conformance with Rule 

4623 “Storage of Organic Liquids.” A control device must be under District permit. 

(KORC) 

RESPONSE: Incorporating the proposed changes into the rule would make the rule 

less stringent. The District is prohibited from backsliding and therefore this issue will 

not be addressed at this time.

5. COMMENT: Section 5.5 is unclear and leaves the regulated party confused as to 

how the inspection criteria apply. Clear inspection criteria should be developed for 

separators that use control option 5.1.1, 5.1.2, or 5.1.3. The manner in which the 

current draft is written specifies inspections are required for all operators subject to 

the rule requirements, but goes on to describe inspection procedures that apply to 

floating roof devices. It is unclear how this inspection would be performed by 

operators meeting control requirements in Sections 5.1.1 or 5.1.3 in lieu of 5.1.2. If 

no inspections are required for operators using methods described in Section 5.1.1 

and 5.1.3, such should be explicitly stated in Section 5.5. Inspection requirements 

for the storage of organic liquids are covered by Rule 4623; therefore, the 

requirements for this type of inspection should only be included as reference. 

(KORC)

RESPONSE: District staff reviewed this comment and will add inspection 

requirements specific for each different compliance option. 
SAN JOAQUIN VALLEY AIR POLLUTION CONTROL DISTRICT 

Appendix A: Comments and Responses December 15, 2011 

A - 6 Final Staff Report with Appendices for 

 Revised Proposed Amendments to Rule 4625 

6. COMMENT: Draft Rule 4625 will place an enormous economic burden on facilities 

that do not meet the 95% control efficiency. The District should perform an in depth 

analysis of the economic impact to capture these emissions. The actual reductions 

available seem insignificant when compared to other available sources of emission 

reductions in the San Joaquin Valley. (KORC)

RESPONSE: District staff reviewed permit conditions and directly contacted all 

affected operators directly to discuss this change. All facilities that currently comply 

with the rule by venting emission to a vapor control system are already achieving 

95% control efficiency. Therefore, the District does not anticipate facilities incurring 

significant costs. 

7. COMMENT: The District timeline request for feedback was not sufficient for proper 

engineering or operational costs analysis. KORC respectfully requests that at 

minimum, a 30 day notice be given for District requests, rather than the 14 day 

notice given for this rule. (KORC)

RESPONSE: It is the District’s mission to provide excellent customer service and 

allow for ample opportunity for stakeholder input. The 14-day notice was necessary 

to meet the expedited schedule for this rule project. However, the District will ensure 

stakeholders have adequate time to submit comments. In fact, stakeholders will 

have additional opportunities to comment on this rule after posting (11/15/11), and at 

the public hearing (12/15/11).