Q750. Will EPA approve the use of Subpart W Best Available Monitoring Methods (BAMM) relating to the measurement of compressor vents routed to flare? Some reporters interpret 40 CFR § 98.233(o) to require facilities which cannot isolate a compressor from the flare header to shut down and depressurize the entire facility to safely install ports or meters to enable measurement.

A750. The totality of the circumstances related to conducting measurement on compressors vents routed to flare systems if fully explained in a proper Best Available Monitoring Methods (BAMM) request may be considered by EPA to constitute unique or unusual circumstances justifying the use of BAMM. While requests to use BAMM for the 2013 Reporting Year were due on September 30, 2012, EPA reserves the right to review and approve requests submitted after that deadline which demonstrate unique or unusual circumstances pursuant to 40 CFR § 98.234(f)(1). Facilities seeking to use BAMM for measurement on compressor vents routed to flare which have not yet submitted a request should do so as swiftly as possible.

Facilities approved to use BAMM are still required to use the calculation methodologies and equations in § 98.233, and must comply with the reporting requirements in § 98.236.

For further information on how to submit a BAMM request, see: http://www.ccdsupport.com/confluence/display/help/Subpart+W+BAMM+Request+Instructions