TO: Docket EPA-HQ-OAR-2011-0417

FROM: Akachi Imegwu, U.S. EPA 

DATE: April 24, 2013

SUBJECT: Mandatory Greenhouse Gas Reporting: Revision to Best Available Monitoring 

Method Request Submission Deadline for Petroleum and Natural Gas Systems 

Source Category – Estimated Changes to Burden Estimates 

On November 30, 2010 (75 FR 74459) the EPA finalized the Petroleum and Natural Gas 

Systems source category, Subpart W, of the Greenhouse Gas Reporting Rule. As part of that 

rule, the EPA finalized detailed provisions in 40 CFR 98.234(f), allowing for owners or 

operators to use best available monitoring methods for specified parameters in 40 CFR 98.233 

where additional time is needed to comply with the monitoring and quality assurance/quality

control (QA/QC) requirements as outlined in the rule. In these cases, owners or operators are 

given the flexibility, upon approval, to estimate parameters for equations in 40 CFR 98.233 by

using either monitoring methods currently used by the facility that do not meet the specifications 

of a relevant Subpart, supplier data, engineering calculations, or other company records. 

Owners or operators desiring to use best available monitoring methods for reporting years 

2012 and beyond are required to submit a request by September 30 of the year prior to the 

reporting year for which use of best available monitoring methods are being sought. 

This final rule amends one provision related to best available monitoring methods 

required in 40 CFR 98.234(f)(8)(i). This action amends the date by which owners or operators 

must submit a request to use best available monitoring methods for future reporting years from 

September 30 to June 30 of each year prior to the reporting year for which use of best available 

monitoring methods is sought. This amendment does not change any other best available 

monitoring method requirements as outlined in 40 CFR 98.234(f). 

This amendment is expected to have minimal adverse impact on owners or operators 

requesting to use best available monitoring methods. First, this action does not impose any new 

information collection burden. Secondly, this amendment only affects the date that best 

available monitoring method requests must be submitted and does not affect what is being 

submitted in those requests or any associated burden with submitting those request. 

REVISION TO BEST AVAILABLE MONITORING METHOD PROVISION

EPA is revising one provision in subpart W related to the submission of best available 

monitoring requests as shown in redline strike-out text below. 
Revision to 40 CFR 98.234(f)(8)(i) Timing of Request. 

EPA does not anticipate a need for best available monitoring methods beyond 2011, but 

for all reporting years after 2011, best available monitoring methods will be considered 

for unique or unusual circumstances which include data collection methods that do not 

meet safety regulations, technical infeasibility, or counter to other local, State, or Federal 

regulations. For use of best available monitoring methods in 2012, an initial notice of 

intent to request best available monitoring methods must be submitted by December 31, 

2011. Any notice of intent submitted prior to the effective date of this rule cannot be used 

to meet this December 31, 2011 deadline; a new notice of intent must be signed and 

submitted by the designated representative. In addition to the initial notification of intent, 

owners or operators must also submit an extension request containing the information 

specified in 98.234(f)(8)(ii) by March 30, 2012. Any best available monitoring methods 

request submitted prior to the effective date of this rule cannot be used to meet the March 

30, 2012 deadline; a new best available monitoring methods request must be signed and 

submitted by the designated representative. Owners or operators that submit both a timely

notice of intent and extension request consistent with 98.234(f)(8)(ii) can automatically

use best available monitoring method through June 30, 2012, for the specific parameters 

identified in their notification of intent and best available monitoring methods request 

regardless of whether the best available monitoring methods request is ultimately

approved. Owners or operators that submit a notice of intent but do not follow up with a 

best available monitoring methods request by March 30, 2012 cannot use best available 

monitoring methods in 2012. For 2012, when an owner or operator has submitted a notice 

of intent and a subsequent best available monitoring method extension request, use of 

best available monitoring methods will be valid, upon approval by the Administrator, 

until the date indicated in the approval or until December 31, 2012, whichever is earlier. 

For reporting years after 2012, a new request to use best available monitoring methods 

must be submitted by June 30th of the year prior to the reporting year for which use of 

best available monitoring methods is sought.