Rule Language Related to BAMM Requests for Reporters Newly Subject to the GHGRP

Per 98.3(l)(1), from January 1, 2015 to March 31, 2015, owners or operators subject to 98.3 (l) may use best available monitoring methods for any parameter (e.g., fuel use, feedstock rates) that cannot reasonably be measured according to the monitoring and QA/QC requirements of a relevant subpart. The owner or operator must use the calculation methodologies and equations in the ‘‘Calculating GHG Emissions’’ sections of each relevant subpart, but may use the best available monitoring method for any parameter for which it is not reasonably feasible to acquire, install, and operate a required piece of monitoring equipment by January 1, 2015. Starting no later than April 1, 2015 the owner or operator must discontinue using best available methods and begin following all applicable monitoring and QA/QC requirements of this part, except as provided in 98.3 (l)(2). Best available monitoring methods means any of the following methods:

• Monitoring methods currently used by the facility that do not meet the specifications of a relevant subpart.
• Supplier data.
• Engineering calculations.
• Other company records.

The owner or operator may submit a request to the Administrator to use one or more best available monitoring methods beyond March 31, 2015.

The extension request must be submitted to EPA no later than January 31, 2015.

The request must contain the following information:

• A list of specific items of monitoring instrumentation for which the request is being made and the locations where each piece of monitoring instrumentation will be installed.
• Identification of the specific rule requirements (by rule subpart, section, and paragraph numbers) for which the instrumentation is needed.
• A description of the reasons that the needed equipment could not be obtained and installed before April 1, 2015.
• If the reason for the extension is that the equipment cannot be purchased and delivered by April 1, 2015, include supporting documentation such as the date the monitoring equipment was ordered, investigation of alternative suppliers and the dates by which alternative vendors promised delivery, backorder notices or unexpected delays, descriptions of actions taken to expedite delivery, and the current expected date of delivery.
• If the reason for the extension is that the equipment cannot be installed without a process unit shutdown, include supporting documentation demonstrating that it is not practicable to isolate the equipment and install the monitoring instrument without a full process unit shutdown. Include the date of the most recent process unit shutdown, the frequency of shutdowns for this process unit, and the date of the next planned shutdown during which the monitoring equipment can be installed. If there has been a shutdown or if there is a planned process unit shutdown between November 29, 2014 and April 1, 2015, include a justification of why the equipment could not be obtained and installed during that shutdown.
• A description of the specific actions the facility will take to obtain and install the equipment as soon as reasonably feasible and the expected date by which the equipment will be installed and operating.

To obtain approval, the owner or operator must demonstrate to the Administrator’s satisfaction that it is not reasonably feasible to acquire, install, and operate a required piece of monitoring equipment by April 1, 2015. The use of best available methods under 98.3 (l) will not be approved beyond December 31, 2015.