Q809. What are the current BAMM provisions for reporting year 2015?
A809. On November 25, 2014 the EPA finalized revisions to Subpart W of the GHGRP, including changes to various calculation methods, monitoring requirements, and data reporting provisions (http://www.gpo.gov/fdsys/pkg/FR-2014-11-25/pdf/2014-27681.pdf).Background
Who can use BAMM in 2015?
Reporters who are subject to the monitoring or measurement requirements for the data listed below by the recent revisions are eligible to request to use BAMM for 2015.
What are the dates associated with the new 2015 BAMM provisions?
Reporters have the option to use best available monitoring methods (BAMM) from January 1, 2015 to March 31, 2015 for the 2015 reporting year without prior approval from the EPA for monitoring or measurement of the data listed below. In order to use BAMM beyond March 31, 2015, a formal BAMM request must be submitted to the EPA by January 31, 2015 and subsequently approved by the EPA. BAMM requests should be submitted using the e-GGRT system, which has been updated to reflect the revised requirements. Otherwise, reporters who relied on BAMM through March 31st must begin following all applicable monitoring and quality assurance/quality control requirements as stated in Part 98 as of April 1, 2015.
How do I submit a request to use BAMM beyond March 31, 2015?
Instructions for how to submit a BAMM request can be retrieved through the eGGRT help website. http://www.ccdsupport.com/confluence/display/help/Subpart+W+BAMM+Request+Instructions
What types of data are covered under these new BAMM provisions?
| Industry Segment | Emission Source Type | Types of Data Covered |
|---|---|---|
| Onshore petroleum and natural gas production | Well Venting for Liquids Unloading | Vented natural gas flow rate for any well in a unique tubing diameter group and pressure group combination that has not previously been measured when using calculation method 1 as prescribed in 98.233(f)(1) if calculation method 1 was used in calendar year 2014 and will be used again in 2015 |
| Gas Well Venting during Completions and Workovers with Hydraulic Fracturing | If using Equation W-10A, initial and average flowback rates when using calculation method 1 in 98.233(g)(1)(i) or pressures upstream and downstream of the choke when using calculation method 2 in 98.233(g)(1)(ii) for any well in a well type combination that has not been previously measured | |
| Onshore natural gas processing | Reciprocating Compressors Centrifugal Compressors | Reciprocating Compressors As found measurements of manifolded emissions from groups of reciprocating compressor sources according to 98.233(p)(4) and (5). Centrifugal Compressors As found measurements of manifolded emissions from groups of centrifugal compressor sources according to 98.233(o)(4) and (5). |
| Onshore natural gas transmission compression | ||
| Underground natural gas storage | ||
| Liquefied natural gas (LNG) storage | ||
| LNG Import and Export Equipment |
What if I submitted a BAMM request for 2015 before the requirements were modified?
As the provisions covering which monitoring and measurement requirements are eligible for BAMM have changed substantially since the original 2015 BAMM requests were submitted, the EPA is requiring that any facility that wants to use BAMM beyond March 31, 2015 must reapply using the revised BAMM module in e-GGRT. The EPA will distribute official notifications to facilities who submitted a BAMM request under the previous set of requirements once the rule takes effect in January 2015.
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