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

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

BAMM Form D 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 Use of or Extension of Best Available Monitoring Methods for All Other Sources (Not included in Forms A, B or C)


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

For all Other Sources (See 98.234(f)(5)(iv))




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 that are not eligible for BAMM under 98.234(f)(2),(3) or (4), you may still request to use Best Available Monitoring Methods through December 31, 2011 for all other sources not included in BAMM forms A, B and C, subject to requirements identified in 98.234(f)(5)(iv). You must submit your request by April 30, 2011. Please see §98.234(f) regarding the use of Best Available Monitoring Methods in 2011.


You may use optional BAMM Form D to request use of BAMM for all other sources. The basis for requesting the use of Best Available Monitoring Methods may include, but are not limited to, inability to secure relevant equipment vendors or service providers, and accessibility or safety concerns related to installing necessary equipment or gathering necessary data. To obtain approval, the request must demonstrate to the EPA Administrator’s satisfaction that site-specific circumstances do not enable you to reasonably acquire, install and operate the necessary equipment.



If you are interested in submitting a request for an extension of the use of Best Available Monitoring Methods past December 31, 201 1 for all other sources not included in BAMM forms A, B and C, subject to requirements identified in 98.234(f)(5)(iv), 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 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. 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 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 (include area code)


4. Contact person e-mail address


5. Contact person date signed


6. Contact person date submitted


7. Indicate if this is an initial BAMM request or an extension

Initial BAMM request:

Extension BAMM request:

Facility and Segment Information

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, please report the AAPG basin name and the EIA field name.


Source Category, Applicability and Monitoring Equipment

11. Indicate type of emissions Source category or parameters for which the owner/operator is requesting the use of BAMM. Please cite the specific emissions source by name and rule citation.


(Example)


  1. 98.232 (d) (4): Blowdown Vent Stacks

  2. 98.232 (d) (5): Dehydrator Vent Stacks


12. Total number of sources at the facility included in this application

Report number of sources requesting BAMM for each emissions source above






13. For each emissions source category identified, describe the reason why BAMM is being requested (safety regulations, technical infeasibility, shutdown required, etc. If more space is required, please include supporting documentation separately. Indicate here that you are providing additional documentation and note the document number for identification.


14. Please indicate if documentation (e.g., fuel flow diagram) for the emissions sources being requested.


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


This information is required for monitoring or measurement equipment which would be installed. For other equipment the reporter may include a facility flow diagram and indication of source locations if this information would provide additional support for the BAMM request.



15. Type of eligible BAMM chosen by the owner/operator (e.g., other monitoring methods, supplier data, engineering calculations, emissions factors, other owner or operator records).


For each requested emissions source category, please indicate the eligible BAMM chosen. If the BAMM chosen is different for different emissions sources, please identify the BAMM chosen for each emissions source.




.

Documentation of Plans to Comply

16. Please provide a detailed explanation and supporting documentation of how and when the owner or operator will receive the services or equipment, or otherwise be prepared to comply with all Subpart W reporting requirements.


Provide information for each emissions source that BAMM is being requested.






Planned Equipment Installation

17. What are the specific actions the facility will take to obtain and install the equipment as soon as reasonably feasible?



18. What is the planned installation date?



Length of Initial BAMM Request


19. When will you start applying the full monitoring methods in the rule (no later than January 1, 2012, unless the EPA grants an extension)?











Requests for Extension of BAMM beyond 2011

1. Please list the specific emissions 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.)


2. 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.



3. 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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