Anonymous comment

The following areas need to be clarified: 1. Does the monitoring of valves for 2 successive months following a leak include the reading that demonstrated that the leak was fixed? 2. The calculation of % leakers need to be consistent with the CAR (40 CFR Part 65). The calculation of the percentage leaking components should explicity handle the following situations: ? Out of service valves (temporary or permanent) ? Difficult to Monitor valves ? Unsafe to Monitor valves ? Heavy Liquid, non-VOC, and vacuum service valves ? Valves on Delay of Repair ? AVO potential leaks that were either repaired or confirmed below leak definition ? Duplicate leak determinations on the same valve (within the monitoring period) 3. The list in 40 CFR 60.486(e)(2)(ii) does not need to be signed by an operator. A designated tag in the database should be sufficient.