to be assigned Request for BAMM Extension thru December 31, 2011 For So

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

BAMM Form B 102810 CLEAN

Greenhouse Gas (GHG) Reporting Rule, Subpart W: Petroleum and Natural Gas Systems

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 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. XXXX-XXXX

Approval expires XX/XX/XXXX


The public reporting and recordkeeping burden for this collection of information is estimated to average XX minutes per response (the burden was already included in ICR XXXXXX-XXXX-XXX). 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 activity as defined in 98.234 (f)(3) that cannot reasonably be obtained according to the monitoring and QA/QC requirements of Subpart W. Therefore, you do not need to submit a Form B BAMM request if you will not need to use BAMM beyond June 30, 2011. You may use optional BAMM Form B to request an extension of BAMM for sources designated in 98.234(f)(3) if measurements cannot be duplicated after June 30, 2011 for those sources. The basis for requesting the extension of the use of Best Available Monitoring Methods may include, but are not limited to, inability to secure data from relevant equipment vendors or service providers, and accessibility concerns related to installing necessary equipment. To obtain approval, the request must demonstrate to the EPA Administrator’s satisfaction that site-specific circumstances do not enable you to reasonably acquire the specified activity data.


Owners or operators may request that the EPA Administrator allow the requestor to extend the use of Best Available Monitoring Methods through December 31, 2011 for sources in 98.234(f)(3). You must submit your request by April 30, 2011. Please see §98.234(f) regarding the use of Best Available Monitoring Methods in 2011.


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) (3), under Subpart W of 40 CFR Part 98 (40 CFR 98.234(f)) to the EPA Administrator, please see Part II of this form.

The EPA will only consider requests for BAMM extension beyond 2012 under extreme and unique circumstances for granting a further extension beyond 2012.


This form can be printed and submitted by mail or submitted electronically. Do not send duplicative forms by multiple delivery modes, for example, by email, overnight mail, and fax. While you may choose either method to submit your request to EPA, in order to expedite review of your BAMM request, please submit your application electronically to the following email address: MRRpetition@epa.gov with the email header “Subpart W BAMM Request”.



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

USA



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 §98.234(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.


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. Contact person date signed


6. Contact person date submitted


Facility and Segment Information

7. Facility name


8. Facility segment:


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



9. 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.



Activity Data and Emission Source Type Requested for using BAMM

10. Indicate type of emissions source for which the Owner/Operator is requesting the use of BAMM listed in §98.234(f)(3)(i)


For onshore sources, you must identify on this form all fields (using EIA field identification) within the basin for which BAMM is being requested.


Please check:


98.233 (e):

98.233 (f):

98.233 (g):

98.233 (h):

98.233 (l):

98.233 (o):

98.233(p):

98.233 (q):

98.233(r):


11. Indicate type of emissions source for which the owner/operator is requesting the use of BAMM listed in §98.234(f)(3)(ii).


You must identify on this form all fields (using EIA field identification) within the basin for which BAMM is being requested.


Please check:

98.233 (f):

98.233 (g):

98.233 (h):

98.233 (i):

98.233 (w):

12. Indicate type of emissions source for which the owner/operator is requesting the use of BAMM listed in §98.234(f)(3)(iii).


You must identify on this form all fields (using EIA field identification) within the basin for which BAMM is being requested.



Please check:

98.233 (d):

98.233 (e):

98.233 (j):

98.233 (k):

98.233 (l):

98.233 (m):

98.233(n):

98.233 (x):

98.233 (y):

98.233 (z):


13. Indicate the specific reason(s) for which BAMM extension is being requested. Provide 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.


14. Please indicate if documentation (e.g., fuel flow diagram, map) for the equipment is attached.


[Indicate whether you are including attachments and include a list of files attached]


For onshore related BAMM requests, the reporter may provide a list of individual fields within the basin which require the BAMM extension. Providing a map of the basin with fields identified would be acceptable if it would assist in explanation of the need for the BAMM extension.


15. Please indicate the eligible BAMM chosen. If the BAMM chosen is different for different emission source categories, please identify the BAMM chosen for each category source.


Documentation of Effort to Comply

16. Please verify and provide supporting documents that the owner or operator has attempted to obtain needed activity data, or services to obtain such data and why it could not be resolved by June 30, 2011.



Planned Actions and Timing to Comply:

17. What are the specific actions the facility will take to comply with monitoring requirements as soon as possible?



18. What is the planned installation date or date where all issues are resolved for compliance with monitoring requirements?



Length of Initial BAMM Request


19. When will you start applying the full monitoring methods in the rule? (If you may require BAMM beyond December 31, 2011, you must complete the bottom section of this form and re-submit by September 30, 2011)

















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)(3), 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. Contact person date signed


6. Contact person date submitted


Facility and Segment Information

7. Facility name


8. Facility segment:


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



9. 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.




Requests for Extension of BAMM beyond 2011

10. Please list the specific emission source categories and parameters for which BAMM is requested. (The extension request beyond 2011 must be completed for each specific source category for which an extension is desired.)


11. For each emissions source category requesting use of BAMM, please describe the reason for the BAMM request. This could be 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.



12. For each emissions source category requesting use of BAMM, please provide a detailed explanation and supporting documents of how and when the emissions source category will comply with Subpart W reporting requirements.



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