Q751. Will EPA approve the use of Subpart W Best Available Monitoring Methods (BAMM) relating to the measurement of individual compressor vents routed a common manifold? Some reporters interpret 40 CFR § 98.233(o) and (p) to require facilities which cannot isolate an individual compressor vent from a common manifold to shut down and depressurize the entire facility to safely install ports or meters to enable measurement.

A751. The totality of the circumstances related to conducting measurement on compressors vents routed to a common manifold, 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. Due to June 30, 2013 falling on a weekend, BAMM requests for the 2014 reporting year are due by July 1, 2013. Facilities seeking to use BAMM measurement on compressor vents routed to a common manifold 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