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1 of 3 RE: South Coast Oil Production Sumps Victor Juan Victor Juan, Nicole Law 08/28/2012 11:46 AM Cc: Stanley Tong Hide Details From: Victor Juan <vjuanaqmd.gov> To: Victor Juan <vjuan@aqmd.gov>, Nicole Law/R9/USEPA!US@EPA, Cc: Stanley Tong/R9/USEPAIUSEPA History: This messagehas been replied to. On aside note,in the Earth Justice document,

I believe Nike misunderstood

mystatement about the use of WEMCOs

orclarifiers. Those devices areused nottomeetthe
5 mg/i (which again
is aRule 1176 exemption threshold), but rather tomeetlimits set by municipal sewersand 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 youremail. With regard
tothe document, specifically item #1: “1. Some oil production facilities sample right after the first wash tank/knock outtank. At this point, the oil and water pumped outof the ground

is just gravity separated,
nochemicals

ormechanical agitation has occurred yettoenhance the oil/water separation.” The sampling
of the inlet side of the wastewater separation

is an attempt
tomeetthe requirements

of the Rule 1176 exemption.

It is not
aroutine sample taken. However,

if changes aremade tothe wastewater streamor production drastically changes then another sample maybe requested. Item #3: “3. Some facilities just pumptheir waterinto the wastewater (municipal sewer) systemfor disposal and therefore
do nothave tomeetthe
5 mg/L limit.” Going into the municipal sewerdoes not necessarily have

arelation
tothe
5 mg/I. Going to sanitary sewer only meansthat the facility chose that avenue
if it happens
tobe the cost-effective solution
to dealing with the wastewater. The facility neverhas tomeetthe
5 mg/l, unless they chose tohave open sumps,clarifiers and the like. Again, the

5 mg/i is the threshold

to qualify for the Rule 1176 exemption, and notaroutine test. Sorry for the mix up. file://C :\Users\nlawO2\AppData\Local\Temp\notes5524D

1 \—web 1573 .htm 8/30/2012Page2of3 Victor From: Nicole Law fmailto: Law. Nicole@lepamail.eDa
.ciovl Sent: Thursday, August 23, 2012 12:51 PM To: Victor Juan Cc: Stanley Tong Subject: Fw: South Coast Oil Production Sumps 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 file://C:\Users\nlawO2\AppData\Local\Temp\notes5524D

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