Q829. What are the Subpart W BAMM provisions for reporting year 2016?

A829. Background

On October 22, 2015 (80 FR 64262), the EPA finalized revisions to Subpart W of the Greenhouse Gas Reporting Program (GHGRP), including adding reporting requirements for the Onshore Petroleum and Natural Gas Gathering and Boosting segment, the Onshore Natural Gas Transmission Pipeline segment, and oil well completions and workovers with hydraulic fracturing and well identification numbers for the existing Onshore Petroleum and Natural Gas Production segment (https://www.gpo.gov/fdsys/pkg/FR-2015-10-22/pdf/2015-25840.pdf).

What is BAMM?

The best available monitoring method (BAMM) is a method used by a GHGRP reporter for monitoring emissions or process operating parameters as an alternative to using a monitoring or measurement method specified by the GHGRP. BAMM can include any of the following methods:

• Monitoring methods currently used by a facility that do not meet the specifications of the GHGRP.
• Supplier data (i.e., data available through third parties).
• Engineering calculations.
• Other company records.

Note that BAMM applies to monitoring or measurement methods. Reporters that use BAMM must still use the calculation methodologies and equations in 40 CFR 98.233 “Calculating GHG Emissions.”

Who can use BAMM in 2016 and what sources are covered?

For reporting year 2016 only, EPA is allowing the use of BAMM on a short-term transitional basis for facilities that must report a newly added Subpart W industry segment or emission source. BAMM can be used for parameters that must otherwise be monitored or measured for the following industry segments and sources:

• Oil well completions and workovers with hydraulic fracturing (new emission source in the Onshore Petroleum and Natural Gas Production segment)
• Onshore Petroleum and Natural Gas Gathering and Boosting (new industry segment; see the final section of this FAQ for specific parameters and source types)
• Onshore Natural Gas Transmission Pipeline (new industry segment)

Reporters are allowed to use BAMM for inputs to emission equations for the sources above for which Subpart W requires monitoring or measurement. This is only for cases where these inputs cannot reasonably be monitored or measured according to the monitoring and QA/QC requirements of Subpart W beginning on January 1, 2016.

Note that BAMM may not be used for the new requirement to report well identification numbers in the Onshore Petroleum and Natural Gas Production segment, because the well identification number is not a parameter that meets the requirements of BAMM use.

No other segments or sources other than those listed above and/or in the final section of this FAQ are permitted to use BAMM for reporting year 2016.

What are the dates associated with the new 2016 BAMM provisions?

Eligible reporters have the option of using BAMM from January 1, 2016 to December 31, 2016.

Do I need to submit a request to use BAMM in 2016?

No. For reporting year 2016, BAMM is automatically approved for eligible sources and reporters. Since the EPA is providing automatic transitional BAMM for the identified industry sources and segments for the entire 2016 reporting year, a facility does not need to submit a request to use BAMM.

What if I have an existing facility that was not previously subject to Subpart W but becomes newly subject to Subpart W in 2016? Can I use BAMM for sources at that facility that are not specified above?

No. However, 40 CFR 98.235(e) provides 6 months of reporting flexibility for these sources. For example, if you have an Onshore Petroleum and Natural Gas Production facility that becomes subject to Subpart W for the first time in 2016 due to the addition of emissions from oil well completions and workovers with hydraulic fracturing, you can only use BAMM for appropriate parameters in the oil well completions and workovers with hydraulic fracturing emissions source. However, you could use the provisions of 40 CFR 98.235(e) for the other emission sources at your newly subject facility, if needed.

Similarly, 40 CFR 98.235(f) provides 6 months of reporting flexibility for facilities that are currently subject to subpart W that acquire new sources that were not previously subject to subpart W for any data related to the newly acquired sources.

What are the specific parameters and sources in the Onshore Petroleum and Natural Gas Gathering and Boosting industry segment for which BAMM can be used?

The amended regulatory text specifically allows the use of BAMM for the following parameters in the Onshore Petroleum and Natural Gas Gathering and Boosting segment:

• Measurement data for the following parameters that are used in calculation of emissions for acid gas removal units:
• Volume of vent gas (§98.233(d)(2))
• Volumetric fraction of CO₂ content in vent gas flowing out of the acid gas removal unit (§98.233(d)(2))
• Volume of natural gas flow into and out of the acid gas removal unit (§98.233(d)(3))
• Volumetric fraction of CO₂ content in natural gas flowing into and out of the acid gas removal unit (§98.233(d)(3))
• Dehydrator vent operating time (§98.233(e)(1)(ix))
• Wet natural gas composition for dehydrators (volume input) (§98.233(e)(1)(xi))
• Number of blowdowns (§98.233(i)(2)(i))
• Separator or non-separator equipment oil composition (volume input) (§98.233(j)(1)(vi))
• Separator oil composition at separator pressure and temperature (§98.233(j)(2)(i) and (j)(5))
• Gas/liquid ratio for non-separator equipment (volume input) (§98.233(j)(2)(iii) (B))
• Liquid and gas composition for non-separator equipment upstream of a storage tank (volume input) (§98.233(j)(2)(iii)(A) and (B))
• Separator flash gas volume (§98.233(j)(5))
• Volume of gas sent to a flare (§98.233(n)(5))
• Mole fraction of specific GHG in the natural gas for desiccant dehydrators, gas sent to flares, and fuel sent to combustion units (volume of fuel used) (§98.233(u)(2)(i))
• Cumulative volume of fuel used (§98.233(z)(2)(i))
• Volume of gas sent to combustion unit (§98.233(z)(2)(iii))
• Annual volume of the fuel combusted ((§98.233(z)(2)(vi))

For some parameters, the rule already allows for the use of estimates based on best available data:

• Hours of operation for natural gas pneumatic device venting and natural gas pneumatic pump venting (§98.233(a) and (c)(1))
• Count of natural gas pneumatic devices in the first 2 years (§98.233(a))
• Type of natural gas pneumatic device (§98.233(a)(3))
• Parameters needed for standard simulation software packages for dehydrator vents and storage tanks (§98.233(e)(1)(i)-(viii), (e)(1)(x), and (j)(1)(i)-(vi))
• Adjustment of emissions for dehydrators and storage tanks with vapor recovery (§98.233(e)(5) and (j)(4))
• Dehydrator vent gas composition (§98.233(e)(6)(i))
• Physical volumes for blowdowns (§98.233(i)(1))
• Total time a separator dump valve is not closing properly (§98.233(j)(6))
• Volumetric flow rate for flares (§98.233(n)(1))
• Fraction of feed sent to an unlit flare (§98.233(n)(5))
• Average estimated time that each emission source type associated with equipment leak emissions was operational in the calendar year (§98.233(r))
• Actual temperature and pressure for acid gas removal vents, flare stacks, and combustion units (§98.233(t)) and for emergency blowdowns (§98.233(i)(2)(i))

For parameters that are considered activity data other than those specifically listed in §98.234(g)(6), such as counts and miles of gathering pipeline, BAMM may not be used because these parameters do not require monitoring or measurements. However, the EPA does note that there are missing data provisions (40 CFR 98.235(g)) that may be used if activity data such as counts are not collected.