Q718. Will EPA approve the use of 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?


A718. Pursuant to a May 2013 final rule, Subpart W BAMM requests are due by June 30 of the year prior to the year in which reports are due (the “reporting year”) and for which BAMM is sought.  As June 30, 2013 falls on a weekend, BAMM requests for the 2014 reporting year are due by July 1, 2013.  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.

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.


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