Comment submitted by B. Lane

I have two additional comments. EPA should clarify whether emissions from degassing and cleaning tanks are fuel gas if combusted in a IC engine or thermal oxidizer. Typically, the degassing only occurs for days or weeks and it seems that NSPS Subpart J or Ja should not apply to this temporary service. EPA should also allow fuel gas compressor preventative maintenance. If there is no exemption, compressors that gets a slug of water or other foreign material will run to failure, and it will take much longer to fix. Periodic vibration analysis may be done on compressors to indicate that a compressor is about to fail, and can be taken out of service and repaired much quicker, than if run to failure. Typically, flaring would occur during the entire duration of compressor outage.