TULSA, Okla. (Dec. 17, 2014) - The Gas Processors Association (GPA) today filed comments with the U.S. Environmental Protection Agency (EPA), recommending the agency withdraw its proposed changes to section 13.5 of AP-42, Compilation of Air Pollutant Emission Factors. GPA member companies own facilities using the AP-42 emission factors and would be subject to increased regulatory burdens under the agency’s proposed substantial increase in the emission factor for nitrogen oxides emitted from industrial flares.
“Finalizing the proposed emission factors will cause uncertainty to both regulators and the regulated community alike; there are no benefits,” said GPA President and CEO Mark Sutton. “In addition, the midstream sector of the natural gas industry across the United States will be substantially harmed if performance testing or other methods must be used as alternatives to the current published emission factor for industrial flares.”
The GPA comments expressed concern regarding the sample size used to develop the new emission factors, which was based on only five new data points, with one value from a facility “orders of magnitude higher than the average of the other four.”
GPA also noted that emission factors apply to different facility types within oil and gas operations, as well as other industry sectors, and EPA has based its proposed factors on flare data from one type of flare, from only one type of facility, and in one industry sector - petroleum refineries - plus a test facility.
“Refineries are large sources of air emissions and typically fall into major source categories. The majority of midstream facilities with flares are minor sources and use flares as control devices and stay below major source thresholds,” Sutton explained. “Increasing the NOx emission factor by a factor of 42 as proposed could result in hundreds of midstream facilities becoming inappropriately categorized as major sources. The increase in permit applications alone could result in a significant regulatory burden on both the regulatory authorities and the regulated community.”
The association recommended that EPA withdraw all proposed changes to AP-42 Section 13.5, keep the existing factors and instead determine new industrial flare emission factors using data from multiple industry segments. In addition, GPA asked the agency to consider determining separate factors for different flare types, feed composition and industrial applications prior to making any changes to the emission factors.