Comment submitted by B. Lane

i. The attached applicability determination has been pending for almost 2 years. The regulation should be clear in how to calculate an emission increase at a flare making this type of applicability determination un-necessary. The commenter requests a response to the applicability determination in the promulgated BID. This comment applies to J and Ja. ii. In addition, it should be clear that adding a new line to the flare does not increase the capacity of the flare and should not trigger Subpart J or Ja iii. Since most streams routed to the flare occur during SSM events, it should be clear how these SSM events trigger a modification, i.e. do you include these emissions in the baseline emissions prior to the modification. This comment applies to J and Ja. iv. This comment applies to J and Ja. The affected facility should be well defined. Is a knockout drum and flare gas compressor part of the affected facility? It doesn't make sense for replacing a knockout drum to trigger NSPS on a flare. Is the pilot gas system part of the affected facility. v. It should be clear that flare tip replacements are considered routine maintenance and repair and should be exempt from triggering a modification for J and/or Ja. This should be true even if the flare tip is replaced with a flare tip of a different geometry (potentially larger diameter) to reduce noise. vi. There is an exemption for triggering a modification for an increase in production rate of an existing facility, if that increase can be accomplished without a capital expenditure on that facility? Does this exemption apply to flares? What is the production rate for a flare, is it flare flow? vii. Are turbines, cogens, welding machines, and IC engines fuel gas combustion devices? viii. The 50 ppm FCCU SO2 emission standard should be an option for Subpart J even if there is no control device.