In an action issued as part of the federal GHG reporting program, the EPA has revised the date by which owners and operators (O/Os) of petroleum and natural gas facilities (O&G) must submit a request to use best available monitoring methods (BAMM) instead of those monitoring methods required for the category under 40 CFR 98, Subpart W. 

Specifically, as of May 31, 2013, the previous deadline of September 30 is amended to June 30 of each year before the reporting year for which use of BAMM is sought.  The amendment does not change any other BAMM requirements as outlined in 40 CFR 98.234(f). 

Instructions at 40 CFR 98.233 specify monitoring equations and calculations.  Under approved BAMM, O/Os are given the flexibility to estimate inputs to equations by using supplier data, engineering calculations, other company records, or monitoring methods currently used in place of those specified.

Technical reviews

The GHG reporting regulations give the EPA the authority to review and finalize BAMM requests during the reporting year in which the use of BAMM is sought.  However, the Agency says that making this annual deadline earlier will create a more realistic schedule for processing BAMM requests and will improve EPA’s ability to inform O/Os of EPA’s final determination before the reporting year for which such methods are sought. 

The Agency has noted that in 2012, it received more requests than anticipated, many of which were quite technical.  Based on a review of those requests, the Agency determined that additional time is needed to carefully review requests and, if necessary, to request further information to resolve concerns. 

“The September 30 deadline does not provide a realistic time period to sufficiently review and process the requests and notify all owners or operators of final determinations,” states the EPA.

Streamlined submittals

Also, the EPA is of the opinion that the closer deadline should not be a problem for industry because the Agency has streamlined the submittal process.  Specifically, the EPA has developed a web form in the electronic GHG reporting tool (eGGRT) that allows submitters to enter information according to the rule requirements.  After an initial request has been submitted, eGGRT stores the information in that request, and the O/O can use the stored information as the basis for a new request in subsequent reporting years.

The EPA also has the authority the review a request received after the deadline.  If a reporter anticipates the need for BAMM and the situation is unresolved at the time of the deadline, a written request explaining “unique or unusual circumstances unforeseen at the time of the applicable best available monitoring method deadline” may be submitted by the June 30 deadline through the eGGRT system.