Q718. Will EPA approve the use of Subpart W Best Available Monitoring Methods (BAMM) relating to the measurement of isolation valves at compressors in the shut down depressurized mode that are to be measured at least once every three calendar years? The Rule appears to require facilities under certain circumstances to shut down solely for this measurement purpose.

A718. The totality of the circumstances related to conducting isolation valve measurement on compressors in shutdown depressurized mode 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.

BAMM requests are due on June 30 of the year prior to the reporting year for which use of BAMM is sought. Facilities seeking to use BAMM for isolation valve measurement on compressors in shutdown depressurized mode 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.