March 30, 2015

United States Environmental Protection Agency

1200 Pennsylvania Avenue NW

Washington, D.C. 20460

Submitted via www.regulations.gov

Attention: Docket ID No. EPA –HQ–OAR–2014–0738

Re: Receipt of Approval Requests for the Operation of Pressure-Assisted Multi-Point Ground Flare 

Technology, Request for Comments (80 Fed. Reg. 8023, February 13, 2015)

Dear Docket Clerk:

The Texas Oil & Gas Association (“TXOGA”) is a non-profit corporation representing the interests of the 

oil and gas industry in the State of Texas. Founded in 1919, TXOGA is the largest and oldest petroleum 

organization in Texas, representing more than 5,000 members. The membership of TXOGA produces in 

excess of 90 percent of Texas’s crude oil and natural gas, operates nearly 100 percent of the state’s refining 

capacity, and is responsible for the vast majority of the state’s pipelines. In 2013, the oil and gas industry 

employed 389,000 Texans, providing wages and salaries of over $44 billion in Texas alone. In addition, 

large associated capital investments by the oil and gas industry generate significant secondary economic 

benefits for Texas. TXOGA member companies produce a quarter of the nation’s oil, a third of its natural 

gas, and account for one-fourth of the country’s refining capacity. Nationally, our member companies 

produce more than a third of the nation’s oil, almost a third of its natural gas and accounts for one-fourth 

of the U.S. refining capacity.

TXOGA member companies will be directly affected by the approval of the proposed Alternative Means 

of Emissions Limitation (AMEL) for the Operation of Pressure-Assisted Multi-Point Ground Flare (MPGF) 

Technology. Several major expansion projects by TXOGA members include plans to utilize MPGF

technology. These large projects provide significant positive impacts on jobs and the local and state

economy.

TXOGA supports the approval of the AMEL and supports the comments filed jointly by the American 

Chemistry Council (ACC), American Fuel and petrochemical Manufacturers (AFPM) and American 

Petroleum Institute (API). We specifically support flexibility to enable the use of the final AMEL by 

companies, as appropriate, in addition to Dow and ExxonMobil. Approving the requested AMEL and 

allowing broader industry utilization will facilitate the use of an alternative control technology that can 

promote significant environmental benefits while fully realizing the goals and purposes of the New Source 

Performance Standards (NSPS), 40 C.F.R. § 60.18, and National Emission Standards for Hazardous Air 

Pollutants (NESHAP), 40 C.F.R. § 63.11.
As described in the ACC/AFPM/API comments, MPGF technology is well-proven with many world-wide 

applications. While low pressure flares remain a proven emission control technology, there can be 

applications where a pressure-assisted flare may provide an advantage over low pressure flares. MPGFs 

operate with combustion and destruction efficiencies that are at least as equivalent to, and generally greater, 

than low pressure flares. Greater combustion and destruction efficiencies from this type of emissions 

control translates into public benefits such as lower post-combustion emission rates for hydrocarbons. 

Smokeless operation is achieved over the entire operating range without any assist medium. With no assist 

medium, energy usage and its related emissions are minimized and there is no potential for steam/air overassist. 

We appreciate EPA’s attention to this issue which has the potential to further a technology with significant 

environmental, business and public benefits. Should you have any questions, please contact me at 

cpomeroy@txoga.org or by phone at (512) 478-6631.

Sincerely, 

Cory Pomeroy

Vice President and General Counsel