EPA Currently Taking Comments on Proposed U & O FIP

The following overview of proposed Federal Implementation Plan is from a slideshow at www.epa.gov

The following types of control technologies would apply in varying
degrees to certain O&NG sources operating on or proposing to
locate on the U&O Reservation:
◦ Routing of emissions from tanks to a combustor
◦ Routing of emissions from dehydrators to a combustor
◦ Routing of emissions from pneumatic pumps to a combustor
 Certain existing sources would require installation of a combustor and retrofitting tanks,
dehydrators and pneumatic pumps to route emissions to the combustor.
◦ Installation of low-bleed pneumatic controllers
Certain existing sources would require conversion of existing high-bleed
pneumatic controllers to low-bleed pneumatic controllers
◦ Equipping all combustion devices with auto igniters
 Certain existing combustion devices would require retrofit
◦ Implementation of a leak detection and repair program using OGI equipment
(e.g., IR camera)

The full text of the Proposed Rule is here. Comments will be accepted through March 23 but will have best opportunity for review if submitted by Feb 20. Rule should be finalized in July. Submit comments here.

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