Subpart I BAMM Request Form_12

Electronics Manufacturing (Subpart I)

Mandatory Reporting of Greenhouse Gases (40 CFR Part 98)

Optional Form For Requesting an Extension Use of Best Available Monitoring Methods

OMB Control No. XXXX-XXXX

Approval Expires XX/XX/XXXX

The public reporting and recordkeeping burden for this collection of information is estimated to average 30 minutes per response (the burden was already included in ICR 2060-new). This is an optional application form. Send comments on the Agency's need for this information, the accuracy of the provided burden estimates, and any suggested methods for minimizing respondent burden, including through the use of automated collection techniques to the Director, Collection Strategies Division, U.S. Environmental Protection Agency (2822T), 1200 Pennsylvania Ave. NW, Washington, D.C. 20460. Include the OMB control number in any correspondence. Do NOT send the completed form to this address.

General Information: If you are an owner or operator subject to subpart I of 40 CFR Part 98, you may use Best Available Monitoring Methods (BAMM) to estimate emissions that occur through June 30, 2011 for any parameter for which it is not reasonably feasible to achieve the following by January 1, 2011:

1. Acquire, install, or operate a required piece of monitoring equipment; or

2. Procure necessary measurement services.

You do not need to submit a request to EPA to use BAMM unless you are planning to use BAMM to estimate emissions that occur beyond June 30, 2011. You may use this optional form to request to use BAMM to estimate emissions that occur from July 1, 2011 through December 31, 2011 for any parameter.

To obtain approval, the request must demonstrate to the EPA Administrator’s satisfaction that it is not reasonably feasible to acquire, install, or operate the required piece of monitoring equipment, or procure necessary measurement services to comply with subpart I.

For parameters other than recipe-specific utilization and by-product formation rates for the plasma etching process type under §98.93(a)(2)(ii)(A), you must submit your request by February 28, 2011. For recipe-specific utilization and by-product formation rates for the plasma etching process type under §98.93(a)(2)(ii)(A), you must submit your request by June 30, 2011.

Requests to use BAMM to estimate emissions that occur beyond December 31, 2011 may be submitted for unique and extreme circumstances, which include safety, technical infeasibility, or inconsistency with other local, State or Federal regulations. You must submit your request by June 30, 2011. You may also use this form if you find it necessary to submit a request for an extension of the use of BAMM past December 31, 2011, under subpart I of 40 CFR Part 98 (40 CFR 98.94(a)(4)). Please see Part II of this form.

The following table summarizes the important dates for subpart I BAMM requests:

Important Dates for Subpart I BAMM Requests

To use BAMM to estimate emissions that occur between July 1, 2011 and December 31, 2011 for the following parameters:	Demonstrate that it is not reasonably feasible to comply with the monitoring requirements of subpart I before:	Submit BAMM request no later than:
Parameters other than recipe-specific utilization and by-product formation rates for the plasma etching process type	July 1, 2011	February 28, 2011
Recipe-specific utilization and by-product formation rates for the plasma etching process type	December 31, 2011	June 30, 2011
To use BAMM to estimate emissions that occur after December 31, 2011 for the following parameters:	Demonstrate that, due to extreme and unique circumstances, it is not reasonably feasible to comply with the monitoring requirements of subpart I before:	Submit BAMM request no later than:
Parameters other than recipe-specific utilization and by-product formation rates for the plasma etching process type	December 31, 2011	June 30, 2011
Recipe-specific utilization and by-product formation rates for the plasma etching process type	December 31, 2012	June 30, 2011

Please see §98.94(a) for the full set of requirements regarding the use of BAMM for subpart I.

This form can be submitted electronically (preferred) to [email protected]. Please include “Subpart I BAMM Request” in the subject line.

As an alternative, the form can be printed and mailed. (Please do not send duplicative forms by multiple delivery modes, for example, by email, overnight mail, and fax.) For US mail use the following postal address:

Carole Cook

Climate Change Division

Office of Atmospheric Programs (MC– 6207J)

Environmental Protection Agency

1200 Pennsylvania Ave. NW.

Washington, DC 20460

USA

For submissions using a private mail carrier (e.g., DHL, FEDEX) use the following address:

Carole Cook

U.S. EPA

1310 L Street NW (802E)

Washington, DC 20005-4113

USA

Tel.: (202) 343-9334

Upon receipt, the request will be recorded in the EPA tracking system, and the requester will be notified that EPA has received the request and is evaluating the request. EPA will evaluate your request to confirm that it is consistent with §98.94(a). The agency will then notify you to confirm approval or denial of the application. As a general matter, EPA will base its decision on the information provided in the timely extension request and does not intend to negotiate on specific issues or necessarily follow-up with the requester regarding missing data. As time allows, EPA may follow up on extension requests with additional questions. The requester must discontinue using best available monitoring methods and begin following all applicable monitoring and QA/QC requirements of subpart I and part 98 no later than the applicable date (July 1, 2011, for parameters other than recipe-specific utilization and by-product formation rates for the plasma etching process type, and December 31, 2011, for recipe-specific utilization and by-product formation rates for the plasma etching process type) unless EPA approves an extension request before that date.

If you are interested in submitting a request for an extension of the use of BAMM to estimate emissions that occur during 2011, please complete Part I of the form below. If you are interested in submitting a request for an extension of the use of BAMM to estimate emissions that occur after 2011 under unique and extreme circumstances, as discussed in 40 CFR Part 98 (40 CFR 98.94(a)(4)), please also complete Part II.

Part I

General Information
1. Name of Person to Contact about the Request
2. Contact Person Address (include street address, city, state and zip code)
3. Contact Person Phone Number
4. Contact Person E-mail Address
5. Signature: “I certify under penalty of law that I have personally examined, and am familiar with, the statements and information submitted in this document and all its attachments. Based on my inquiry of those individuals with primary responsibility for obtaining the information, I certify that the statements and information are to the best of my knowledge and belief true, accurate, and complete. I am aware that there are significant penalties for submitting false statements and information or omitting required statements and information, including the possibility of fine or imprisonment.”
6. Date Signed
7. Date Submitted
Facility Information
8. Facility Name
9. Facility Physical Address (include street address, city, state and zip code)
Monitoring Equipment
10. Monitoring equipment for which the request is being made (e.g. scales))
11. Locations where each piece of monitoring instrumentation/equipment will be installed If you choose to include documentation (e.g., facility or process diagram) where each piece of monitoring instrumentation/equipment will be installed, then please indicate that such documentation is attached and include a list of files attached.
12. Specific parameter for which the request is being made (e.g., apportioning factors)
13. Rule citation for monitoring requirements for which the monitoring instrumentation/equipment is needed (e.g., §98.94(c)))
Measurement Service
14. Measurement services for which the request is being made (e.g. emissions measurement services)
15. Locations where each measurement service will be provided If you choose to include documentation (e.g., facility or process diagram) where each measurement service will be provided, then please indicate that such documentation is attached and include a list of files attached.
16. Specific parameter for which the request is being made (e.g., recipe-specific utilization and by-product formation rates)
17. Rule citation for monitoring requirements for which the measurement service is (e.g., §98.93(a)(2)(ii)(A))
Reason for the Extension Request
18. Please provide a description of the reasons why the needed equipment could not be obtained, installed, or operated or why the needed measurement services could not be provided before July 1, 2011*). *For BAMM extension requests for recipe-specific utilization and by-product formation rates for the plasma etching process type under §98.93(a)(2)(ii)(A) substitute the date December 31, 2011 for the date July 1, 2011.
19. Is the reason for the extension request that equipment cannot be purchased, delivered, or installed? If yes, then complete items 19a through 19e below, as appropriate, and include supporting documentation as attachments identifying them in the responses to which they are relevant.	 Yes  No
19a. Date the monitoring equipment was ordered.
19b. Information on alternative suppliers investigated, and the dates by which alternative vendors promised delivery or installation.
19c. Backorder notices or notices of unexpected delays.
19d. Descriptions of actions taken to expedite delivery or installation.
19e. The current expected date of delivery or installation.
20. Is the reason for the extension request that service providers were unable to provide necessary measurement services? If yes, then complete item 20a below and identify any necessary attachments.	 Yes  No
20a. Please include supporting documentation that measurement services could not be acquired before July 1, 2011*. This documentation must include written correspondence to and from at least three service providers stating that they will not be available to provide the necessary services before July 1, 2011*. *For BAMM extension requests for recipe-specific utilization and by-product formation rates for the plasma etching process type under §98.93(a)(2)(ii)(A) substitute the date December 31, 2011 for the date July 1, 2011.
Description of BAMM and Plans for Monitoring Requirement Compliance
21. Please provide a detailed description of the specific best available monitoring methods that you will use in place of the required methods.
22. Please describe the specific actions the owner or operator will take to comply with monitoring requirements by January 1, 2012?

Part II

General Information
1. Name of Person to Contact about the Request
2. Contact Person Address (include street address, city, state and zip code)
3. Contact Person Phone Number
4. Contact Person E-mail Address
5. Signature: “I certify under penalty of law that I have personally examined, and am familiar with, the statements and information submitted in this document and all its attachments. Based on my inquiry of those individuals with primary responsibility for obtaining the information, I certify that the statements and information are to the best of my knowledge and belief true, accurate, and complete. I am aware that there are significant penalties for submitting false statements and information or omitting required statements and information, including the possibility of fine or imprisonment.”
6. Date Signed
7. Date Submitted
Facility Information
8. Facility Name
9. Facility Physical Address (include street address, city, state and zip code)
Requests for Extension of BAMM beyond 2011
10. Specific parameter for which the request is being made. (The extension request beyond 2011 must be completed for each specific parameter for which an extension is desired.)
11. Please provide a description of the specific rule requirements that can not be met, including a detailed explanation as to why the requirements can not be met.
12. Please provide a detailed description of the unique circumstances necessitating the request for an extension, including specific data collection issues that do not meet safety regulations, technical infeasibility, or specific laws or regulations that conflict with data collection.
13. Please provide a detailed explanation and supporting documentation of how and when you will receive the required data and/or services to comply with the reporting requirements of subpart I in the future.
14. Please provide a detailed description of the specific best available monitoring methods that you will use in place of the required methods.

EPA Form TBD