Owners and operators may request the use of best available monitoring methods (BAMM) for certain parameters that cannot reasonably be measured according to the monitoring and QA/QC requirements of Subpart W. The owner or operator must use the calculation methodologies and equations in 98.233 but may request the use of BAMM for certain parameters for which it is not reasonably feasible to acquire, install, and operate a required piece of monitoring equipment. Best available monitoring methods means any of the following methods including: monitoring methods currently used by the facility that do not meet the specifications of the relevant portion of Subpart W, supplier data, engineering calculations, or other company records.
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). BAMM requirements, including the eligible emission sources have changed for Reporting Year 2015. Reporters who are subject to the monitoring or measurement requirements that were amended in this final rule have the option to use BAMM from January 1, 2015 to March 31, 2015 for the 2015 reporting year without prior approval from the EPA. 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. These formal BAMM requests MUST be submitted through eGGRT as explained below.
This help content reflects the requirements for Reporting Year 2015. For additional information on the specific sources and data for which BAMM are applicable please review FAQ 809.
This page provides step-by-step instructions on how to enter and edit a Subpart W BAMM request submissions including:
- Creating a BAMM Request Submission
- Adding Industry Segments and Source Types
- Uploading Supporting Documentation
- Submitting and Certifying a BAMM Submission
Instructions on the use of these e-GGRT features follows:
Step 1: Creating a BAMM Request Submission
In e-GGRT, select the facility you wish to submit a BAMM request for from the Facility Management page. Next, access the e-GGRT Subpart W BAMM submission page for the selected facility by selecting "Subpart W: Petroleum and Natural Gas Systems Best Available Monitoring Method Request" at the bottom.
To add a BAMM submission, click the link titled "ADD a BAMM Submission."
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For a new BAMM Request Submission, select the Reporting Year from the dropdown list and click CONTINUE.
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If a BAMM Request Submission for the selected reporting year has already been created but has not yet been submitted and 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 delete or certify the previous version.
To later edit information you have entered for a BAMM submission, click the link (e.g., 2015v1) in the Submission column of the BAMM PETITION SUBMISSIONS table on the Subpart W 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 Submission, click the red “x” in the last column of the BAMM PETITION SUBMISSIONS table.
Step 2: Add an Industry Segment
To add an industry segment, click the “ADD an Industry Segment” link.
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On the Industry Segment page, select from the list and click CONTINUE. After an industry segment is added, specify the source types for which you are requesting BAMM.
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To make changes to the source types selected for an existing industry segment, click the link in the Industry Segment column of the INDUSTRY SEGMENTS table on the BAMM Request Submission page.
To remove an industry segment, click the red “x” in the Delete column of the INDUSTRY SEGMENTS table.
Step 3: Add a Source Type to an Industry Segment
Under ADD A SOURCE TYPE, select a source type from the dropdown list and click ADD. Note that only the Source Types applicable to your Industry Segment are included in the Source Type drop down list.
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Step 4: Define the Source Types
For each source type, enter the following required information:
- Parameters for which BAMM is requested
- Description of reasons that the needed equipment could not be obtained and installed before April 1, 2015.
- 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.
When you are finished entering information for the source type, click SAVE. Then continue adding source types if needed. If one of the supporting information text fields (parameters, circumstances, and compliance plan) for a source type are left empty, then you will receive a screen error after clicking SAVE. In order to avoid this, information must be provided in all text fields (unless the checkbox is clicked). If you are uploading an attachment with the necessary supporting information, enter a statement such as "See attachment" in order to avoid screen errors.
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Step 5: Repeat Steps 2-4
Continue adding and defining Industry Segments and Source Types until all information for your facility has been entered. When you are finished, click the BAMM Request Submission button to return to the BAMM Request Submission page.
Step 6: Upload Supporting Documentation
If you have supporting documents to upload, they must be in one of the following formats: .zip, .pdf, .doc, .docx.
To upload a file, click Browse, select the file, and then click UPLOAD.
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Step 7: Submit and Certify BAMM Submission
Please ensure that the correct source types are selected for each industry segment and that supporting information (i.e., parameters, unique and unusual circumstances, and compliance plan) for each source type is provided in text on the Industry Segment and Source Type page, or as an attachment.
When you are ready to submit the BAMM Request, click the CERTIFY and SIGN button. Enter your password and click SUBMIT, then answer the challenge question and click SUBMIT again.
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The page will display confirmation of submission.
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