To: Victor Juan <vjuan@aqmd.gov>, Nicole Law/R9/USEPA!US@EPA,

Cc: Stanley Tong/R9/USEPAIUSEPA History: This message has been replied to.

On a side note, in the Earth Justice document, I believe Nike misunderstood my statement about the use of WEMCOs or clarifiers. Those devices are used not to meet the 5 mg/i (which again is a Rule 1176 exemption threshold), but rather to meet limits set by municipal sewers and DOGR water quality requirements for reinj ection.

-Victor

From: Victor Juan

Sent: Tuesday, August 28, 2012 11:36 AM

To: ‘Nicole Law’Cc: Stanley Tong

Subject: RE: South Coast Oil Production Sumps

Hello Nicole,Sorry I dropped the ball and missed your email.

With regard to the document, specifically item #1:

“1. Some oil production facilities sample right after the first wash tank/knock out tank. At this point, the oil and water pumped out ofthe ground is just gravity separated, no chemicals or mechanical agitation has occurred yet to enhance the oil/water separation.”

The sampling ofthe inlet side ofthe wastewater separation is an attempt to meet the requirements of the Rule 1176 exemption. It is not a routine sample taken. However, if changes are made to the wastewater stream or production drastically changes then another sample maybe requested.

Item #3:

“3. Some facilities just pump their water into the wastewater (municipal sewer) system for disposal and therefore do not have to meet the 5 mg/L limit.”

Going into the municipal sewer does not necessarily have a relation to the 5 mg/I. Going to sanitary sewer only means that the facility chose that avenue ifit happens to be the cost-effective solution to dealing with the wastewater. The facility never has to meet the 5 mg/l, unless they chose to have open sumps, clarifiers and the like. Again, the 5 mg/i is the threshold to qualify for the Rule 1176 exemption, and not a routine test.

Sorry for the mix up.

file://C:\Users\nlawO2\AppData\Local\Temp\notes5524D 1 \—web 1573 .htm 8/30/2012
Hi Victor,

I am emailing because I haven’t heard back from you about the below email. Maybe the email just got lost? I did

some review of my notes of our conversation with you and revised the record of communication. Do you mind taking a look at it to make sure it’s accurate? Please let me know if you have suggested revisions or if it looks fine. Thank you!

Nicole

Nicole Law

Rulemaking Office, Air Division

U.S. Environmental Protection Agency

75 Hawthorne Street

San Francisco, 94105

Office: (415) 947-4126

Fax: (415) 947-3579

Forwarded by Nicole Law/R9/USEPAIUS on 08/23/2012 12:48 PM -—

From: Nicole Law/R9/USEPAIUS

To: vluan(apmd.pov, eteszler(apmd.pov,

Cc: Stanley TongIR9/USEPAIUS@EPA

Date: 08/17/2012 11:51 AM

Subject: South Coast Oil Production Sumps

Hi Victor and Eugen,

Thank you so much for speaking with Stan and me a couple weeks ago. We plan to use the information you shared with us in an upcoming rulemaking notice, so I thought I would send you a draft copies of the records of communication. Do you mind going through it to make sure we have accurately captured our conversations?

Please let me know if I should make any changes to the attached records of communication. Thank you.

Eugen, can you please also run this by Dairo? In addition to the record of communication, I would like to know if he has additional comments about the comment made my Earthjustice. “SCAQMD found these wastewater

treatment options met the SCAQMD’s standards of cost-effectiveness in 1989.” Thanks again.

Nicole

Nicole Law

Rulemaking Office, Air Division

U.S. Environmental Protection Agency 75 Hawthorne Street

San Francisco, 94105

Office: (415) 947-4126

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