Form B 102810 BAMM # 5900-219-clean

Form B 102810 BAMM # 5900-219-clean.docx

Regulation to Establish Mandatory Reporting of Greenhouse Gases (Change Worksheet for Petroleum and Natural Gas, Subpart W)

Form B 102810 BAMM # 5900-219-clean

OMB: 2060-0651

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Petroleum and Natural Gas Systems (Subpart W) of the Greenhouse Gas Reporting Rule

Optional Facility Form for Requesting Extension of Best Available Monitoring Methods (BAMM) for Specified Activity Data



Form B Part I – Request for BAMM Extension thru December 31, 2011

For Sources Identified in 98.234(f)(3)



OMB Control No. 2060-0651

Approval expires 12/31/2013


The public reporting and recordkeeping burden for this collection of information is estimated to average 60 minutes per response (the burden was already included in ICR 2376.02). 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 W of 40 CFR Part 98 and have sources eligible for BAMM under 98.234(f)(3), you may use best available monitoring methods through June 30, 2011 for specified activity data that cannot reasonably be measured according to the monitoring and QA/QC requirements of Subpart W. You do not need to submit a Form B BAMM request to EPA unless you are planning to use BAMM beyond June 30, 2011 for the sources identified in 98.234(f)(3) for which measurements cannot be duplicated after June 30, 2011. You may use this optional form to request to use BAMM to estimate emissions that occur beyond July 1, 2011 through December 31, 2011 for sources identified in 98.234(f)(3). You must submit your request by April 30, 2011.


To obtain approval, the request must demonstrate to the EPA Administrator’s satisfaction that it is not feasible to implement the data collection for the sources described in 98.234(f)(3) according to the methods outlined in subpart W.


For requests to use BAMM to estimate emissions that occur beyond December 31, 2011 for sources listed in 98.234(f)(8) due to unique and extreme circumstances which include safety, technical infeasibility, or inconsistency with local, State, or Federal regulations, you must submit your request by September 30, 2011. You may use Part II of 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 W of 40 CFR part 98 (40 CFR part 98.234(f)(8)).


The following table summarizes the important dates for subpart W BAMM requests for sources identified in 98.234(f)(3).


Important Dates for Subpart W BAMM Requests For Sources Identified in 98.234(f)(3)



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 W after:

Submit BAMM request no later than:

Cumulative hours of venting, days or time of operation in 98.233(e),(f), (g), (h), (l), (o), (p), (q), and (r).


Number of blowdowns, completions, workovers, or other events in 98.233(f), (g), (h), (i), and (w).


Cumulative volume produced, volume input or output, or volume of fuel used in paragraphs 98.233(d), (e), (j), (k), (l), (m), (n), (x), (y), and (z).

June 30, 2011

April 30, 2011

To use BAMM to estimate emissions that occur beyond 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 W after:

Submit BAMM request no later than:

For sources listed in 98.234(f)(8).

December 31, 2011

September 30, 2011



This form can be submitted electronically (preferred) to [email protected]. Please include “Subpart W 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

1310 L Street NW (802E)

Washington, DC 20005-4113

Phone: 202-343-9334

USA



Upon receipt, the request will be recorded in the EPA tracking system, and the requester will be notified that EPA has received and is evaluating the request. EPA will evaluate your request to confirm that it is consistent with §98.234(f). 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 extension request and does not intend to negotiate on specific issues. 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 W and part 98 no later than July 1, 2011 unless EPA approves an extension request before that date.



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. Contact person date signed


7. Contact person date submitted


Facility and Segment Information 40 CFR §98.230(a)

8. Facility name


9. Facility segment:


Please enter appropriate rule segment, for example, Processing would be 98.232 (a)(3)



10. Facility physical address (include street address, city, state and zip code) for where each emissions source is located


For onshore production sources, please report the AAPG basin name.



Emission Source Type, Applicability, and Monitoring Equipment

40 CFR §98.234(f)(7)(ii)(A)

11. Include a list of specific source types for which data collection could not be implemented. Please attach additional documentation as necessary.


12. Please indicate the BAMM chosen in place of the rule requirements such as company records, other engineering estimates, available data, etc. If the BAMM chosen differs by emission source category, please identify the BAMM chosen for each category choice.

Identification of Specific Rule Requirements

40 CFR §98.234(f)(7)(ii)(B)

13. Identify the specific rule requirements – by subpart, section, and paragraph number – for which the instrumentation, contract modification, or monitoring service is needed. (Include citations from 98.233 as applicable) Please attach additional documentation as needed.


Description of Data Collection Methodologies

40 CFR §98.234(f)(7)(ii)(C)

14. Include a description of the data collection methodologies that do not meet safety regulations, technical infeasibility, or specific laws or regulations that conflict with each specific source for which an owner or operator is requesting use of best available monitoring methodologies for which data collection could not be implemented in the 2011 calendar year.


















If you are interested in submitting a request for an extension of the use of Best Available Monitoring Methods past December 31, 2011 for sources in 98.234 (f)(8), under Subpart W of 40 CFR Part 98 (40 CFR 98.234(f)) to the EPA Administrator, you have the option of using this form. You must submit your request by September 30, 2011. The EPA will only consider requests for BAMM extension beyond 2012 under extreme and unique circumstances for granting a further extension beyond 2012.




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. Contact person date signed


7. Contact person date submitted


Facility and Segment Information

8. Facility name


9. Industry segment:


Please enter appropriate rule segment, from §98.230 of 40 CFR part 98



10. Facility location (please enter location address of facility. For onshore petroleum and natural gas production facilities, please provide AAPG basin name as appropriate).



Listing of Specific Sources for BAMM

40 CFR §98.234(f)(8)(iii)

11. Please list the specific source categories and parameters for which BAMM is being requested. Please attach documentation as necessary.


Reason for BAMM Request

40 CFR §98.234(f)(8)(iv)

12. Include a description of the data collection methodologies that do not meet safety regulations, technical infeasibility, or specific laws or regulations that conflict with each specific source for which an owner or operator is requesting use of BAMM. Please attach additional documentation as necessary.


13. Please indicate the BAMM chosen in place of the rule requirements such as company records, other engineering estimates, available data, etc. If the BAMM chosen differs by emission source category, please identify the BAMM chosen for each category choice.


Specific Actions to Comply with Subpart W

§98.234(f)(8)(v)

14. Include a detailed explanation and supporting documentation of how and when the owner or operator will receive the services or equipment to comply with all of this subpart W reporting requirements. Indicate the time period for which BAMM is being requested. Please attach additional documentation as necessary.




EPA Form 5900-219 Page 5 of 7


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