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EPA finalized a rule (78 FR 71904) that became effective on January 1, 2014 that amended Part 98 to implement corrections, revisions and other amendments including amendments to the global warming potential (GWP) values for certain greenhouse gases (GHGs). For more detailed information on the changes to the GWPs and other changes finalized in this rule, please refer to the rule factsheet. As a result of the changes to the GWP values, EPA anticipates that several facilities would become subject to the GHGRP for the first time.

98.3(l) of this rule provides special provisions for the use of best available monitoring methods (BAMM) in reporting year 2014 applies to owners or operators of facilities or suppliers that first become subject to any subpart of part 98 due to an amendment to Table A-1.

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Rule Language Related to BAMM Requests for Reporters Newly Subject to the GHGRP

Per 98.3(l)(1) from January 1, 2014 to March 31, 2014, owners or operators subject to this paragraph (l) may use best available monitoring methods for any parameter (e.g., fuel use, feedstock rates) that cannot reasonably be measured according to the monitoring and QA/QC requirements of a relevant subpart. The owner or operator must use the calculation methodologies and equations in the “Calculating GHG Emissions” sections of each relevant subpart, but may use the best available monitoring method for any parameter for which it is not reasonably feasible to acquire, install, and operate a required piece of monitoring equipment by January 1, 2014. Starting no later than April 1, 2014, the owner or operator must discontinue using best available methods and begin following all applicable monitoring and QA/QC requirements of this part, except as provided in paragraph (l)(2) of this section. Best available monitoring methods means any of the following methods:
(i) Monitoring methods currently used by the facility that do not meet the specifications of a relevant subpart.
(ii) Supplier data.
(iii) Engineering calculations.
(iv) Other company records.
Per 98.3(l)(2) facilities may requests extension of the use of best available monitoring methods. The owner or operator may submit a request to the Administrator to use one or more best available monitoring methods beyond March 31, 2014 no later than January 31, 2014.

Requests must contain the following information:
(A) A list of specific items of monitoring instrumentation for which the request is being made and the locations where each piece of monitoring instrumentation will be installed.
(B) Identification of the specific rule requirements (by rule subpart, section, and paragraph numbers) for which the instrumentation is needed.
(C) A description of the reasons that the needed equipment could not be obtained and installed before April 1, 2014.
(D) If the reason for the extension is that the equipment cannot be purchased and delivered by April 1, 2014, supporting documentation such as the date the monitoring equipment was ordered, investigation of alternative suppliers and the dates by which alternative vendors promised delivery, backorder notices or unexpected delays, descriptions of actions taken to expedite delivery, and the current expected date of delivery.
(E) If the reason for the extension is that the equipment cannot be installed without a process unit shutdown, include supporting documentation demonstrating that it is not practicable to isolate the equipment and install the monitoring instrument without a full process unit shutdown. Include the date of the most recent process unit shutdown, the frequency of shutdowns for this process unit, and the date of the next planned shutdown during which the monitoring equipment can be installed. If there has been a shutdown or if there is a planned process unit shutdown between November 29, 2013 and April 1, 2014, include a justification of why the equipment could not be obtained and installed during that shutdown.
(F) A description of the specific actions the facility will take to obtain and install the equipment as soon as reasonably feasible and the expected date by which the equipment will be installed and operating.

To obtain approval, the owner or operator must demonstrate to the Administrator's satisfaction that it is not reasonably feasible to acquire, install, and operate a required piece of monitoring equipment by April 1, 2014. The use of best available methods under this paragraph (l) will not be approved beyond December 31, 2014.

This page provides step-by-step instructions on how to enter and edit BAMM request submissions including:

  • Creating a BAMM request submission
  • Identify the monitoring instrumentation for which the request is being made and their anticipated locations
  • Add subpart and rule requirements for which BAMM is requested
  • Identify reason for the extension request
  • Upload supporting documentation
  • Provide planned actions

Instructions on the use of these e-GGRT features follows:

Step 1: Add a BAMM Request Submission

In e-GGRT, you can access the BAMM submission modules on the Facility Management Tab. If you have more than one facility you must first select the facility to open the Facility Summary page. Then access  BAMM submission page for this facility by clicking "Best Available Monitoring Method Request for Reporters Newly Subject to the GHGRP".

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Clicking on the "Best Available Monitoring Method Request for Reporters Newly Subject to the GHGRP" link opens the BAMM overview page as shown below. For a new BAMM Request Submission, click Add a BAMM Submission. To edit and existing BAMM submission, click on the BAMM submission of you wish to edit.

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If a BAMM Request Submission has already been created but has not yet been certified, you will receive an error message if you try to add a new BAMM submission. To create another BAMM Request Submission for the selected reporting year, you must first certify or delete the previous version.

To later edit information you have entered for a BAMM submission, click the link (e.g., 2014v1) in the Submission column of the BAMM Request SUBMISSIONS table on the Overview page. Once a submission has been certified, however, it cannot be edited. A new submission must be created if edits are necessary. Please note that when creating a new BAMM submission within the same reporting year, all information from the previous certified BAMM submission for that reporting year will be auto-populated into the new submission. From this point, only the necessary revisions will need to be made.

To delete a BAMM Request which has not yet been submitted, click the red “x” in the last column of the BAMM REQUEST SUBMISSIONS table.

Once you select the BAMM Submission you want to work on the following BAMM data entry page will appear:

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Step 2: Identify the monitoring instrumentation for which the request is being made and their anticipated locations

List the specific items of monitoring instrumentation for which the request is being made and the locations where each piece of monitoring instrumentation will be installed.
The list of instrumentation and locations is entered into a single text box with a maximum of 4000 characters.

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Step 3: Add Subpart and Rule Requirements for which BAMM is requested

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Step 4: Identify Reason for the Extension Request

You must select at least one reason for the extension request. If you select "Other" you must provide a textual explanation.

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Step 5: Upload Supporting Documentation

To upload a file, click Browse, select the file, and then click UPLOAD.

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If you have supporting documents to upload, they must be in one of the following formats: .zip, .pdf, .doc, .docx.

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Step 6: Provide planned actions

In the Planned Actions section please enter the description of the specific actions the facility will take to obtain and install the equipment as soon as reasonably possible and the expected data by which the equipment will be installed and operating.

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Step 7: Submit and Certify BAMM Submission

Once you have ensured that the correct monitoring instrumentation, subpart and rule requirements, reason for the extension request, supporting documentation and planned actions have been entered you are ready to submit your BAMM Request.

To initiate the submission click the SUBMIT and CERTIFY button. You will be prompted for you password and then asked to answer the challenge question. Once you have entered the response to the challenge question click SUBMIT.

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After a successful submission the confirmation of submission report will be displayed. You may print this report.

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