July 2, 2015
On June 18, the Gas Processors Association (GPA) filed comments on the proposed rule from the U.S. Environmental Protection Agency (EPA) that would require the owner/operator responsible official to electronically submit specified reports required under 40 CFR part 60 to the EPA’s Central Data Exchange rather than submitting them in paper format.
GPA member companies subject to New Source Performance Standards (NSPS) pertaining to the natural gas industry include subparts A, Ka, Kb, GG, LLL, IIII, JJJJ, KKKK and OOOO. None of the reports required under subpart KKK contain air emissions data that the EPA is requesting be submitted under this proposal. EPA, however, may require electronic submittal of these reports at a later time.
GPA supports using electronic test data in pursuing emissions factor development improvements. GPA is also in agreement that test data reported electronically would greatly aid in the development of emission factors of higher quality and representative of the whole industry sector. However, GPA has a number of concerns regarding the EPA’s proposed Electronic Reporting and Recordkeeping Requirements for New Source Performance Standards. Specifically:
- The proposed rule does not give any exception to submitting the required reports via the electronic reporting system.
- EPA needs to clarify when electronic reports are required, EPA should allow companies more time to prepare for compliance.
- Additional flexibility is needed for the user roles within the Compliance and Emissions Data Reporting Interface.
- EPA should not eliminate the exemption in air agency delegation agreements allowing sources to refrain from submitting reports to EPA.
- EPA cannot require data elements not required to be reported under a subpart.\
- The costs associated with the rule compliance are erroneous.
What this means to you
The Gas Processors Association has filed comments in six specific areas of EPA’s New Source Performance Standards requirement for electronic reporting. Spark Ignition (Subpart JJJJ) and Compression Ignition (Subpart IIII) engines are affected under 40 CFR part 60.
MIRATECH can help
Contact MIRATECH to learn more about emissions solutions for SI and CI stationary engines.