March 30, 2015

U nited 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 billio n 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 accoun t 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 b e 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 impact s 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), Ameri can 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 a nd 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 emis sion 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,

tha n 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 oper ating 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 over

assist.

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 Gener al Counsel