1

MEMORANDUM 

FROM: Akachi Imegwu, U.S. EPA, Climate Change Division 

TO: Docket EPA-HQ-OAR-2011-0417, Mandatory Reporting of Greenhouse Gases: Petroleum and 

Natural Gas Systems (Subpart W): Revisions to Best Available Monitoring Method Provisions 

DATE: September 16, 2011 

SUBJECT: SUPPLEMENTAL DATA SUBMITTED ON BEST AVAILABLE MONITORING METHODS 

(BAMM) 

The purpose of this memorandum is to present the supplemental data received by the EPA in support of 

amending subpart W to allow all owners or operators of subpart W covered facilities to use BAMM in 2011 

without the requirement to receive prior approval from the Administrator for use of BAMM in 2011. 

The 2010 final rule for Subpart W of the Greenhouse Gas Reporting Rule (Subpart W) was signed by 

EPA Administrator Lisa Jackson on November 8, 2010 and published in the Federal Register on November 30, 

2010 (75 FR 74459, Tuesday, November 30, 2010). The 2010 final rule, which became effective on December 

31, 2010, included reporting of GHGs from facilities containing petroleum and natural gas systems. The rule 

does not require control of GHGs, rather it only requires that owners or operators of facilities containing 

petroleum and natural gas systems with emissions sources above certain threshold levels monitor and report 

emissions and other related data. 

 EPA finalized amendments to certain provisions related to the use of BAMM for the Petroleum 

and Natural Gas Systems source category of the Greenhouse Gas Reporting Rule. Specifically, EPA is 

extending the time period during which owners or operators are permitted to use BAMM without submitting a 

request to the Administrator for approval, to December 31, 2011. EPA is also expanding the list of types of 

emissions sources for which owners or operators are not required to submit a request to the Administrator to use 

BAMM during 2011, and extending the deadline by which owners or operators can request use of BAMM for 

beyond 2011. 

EPA received data from the American Exploration and Production Council and from the Chesapeake 

Energy Corporation on the need for BAMM delineated by emissions source (please see Table 1 and Table 2 

attached). These data demonstrate an expressed need for the availability of BAMM due to uncertainty in how 

to carry out specific monitoring methods outlined in the rule, thereby supporting the need for additional time in 

order to more properly position the facility for submitting the required data to the EPA. In addition, the need 

for BAMM demonstrated in this supplement covers emission sources that fall within the BAMM groupings 

outlined in 40 CFR 98.234(f)(2), (f)(3), (f)(4), and (f)(5)(iv). 

 
Table 1:

Onshore production and Onshore natural gas processing

Data parameters for which BAMM is permitted under 40 C.F.R. 98.234(f)(2), (3), (4)

Why more time for BAMM beyond Sept. 2011 is needed 

Emission Source Data Parameter 40 C.F.R. BAMM Citation Why more time beyond Sept. 2011 is needed

Acid Gas Removal (AGR) Vents Volumetric Flow Rate §98.233(d) §98.234(f)(3)(iii)

§98.234(f)(4)(iii)

The definition of "onshore natural gas processing" needs to be revised to eliminate ambiguity between processing and production. Reporters have never tracked this data before and need to assess how to track and establish systems to collect this data.

Dehydrator Vents Volumetric Flow Rate §98.233(e) §98.234(f)(3)(iii) The definition of "onshore natural gas processing" needs to be revised to eliminate 

ambiguity between processing and production. Reporters have never tracked this data before and need to assess how to track and establish systems to collect this data.

Dehydrator Vents Hours Operated §98.233(e) §98.234(f)(3)(i) The definition of "onshore natural gas processing" needs to be revised to eliminate 

ambiguity between processing and production. Reporters have never tracked this data before and need to assess how to track and establish systems to collect this data.

Hours Vented §98.233(f) §98.234(f)(3)(i) Reporters have never tracked this data before and need to assess how to track and 

establish data collection systems and conduct training before they can begin to collect this data.

Number of Events §98.233(f) §98.234(f)(3)(ii) Reporters have never tracked this data before and need to assess how to track and 

establish data collection systems and conduct training before they can begin to collect this data.

Reduced Emissions Completion/Workover Volume to Sales

§98.233(g) §98.234(f)(2)(i) Reporters have never tracked this data before and need to assess how to track and 

establish systems to collect this data. In order to start tracking data, a data collection system needs to be developed, then rolled out to the third party service companies, the service companies need to approve the system, and contracts may need to be renegotiated to mandate the use of the new tracking systems. Only then can the third party service companies start collecting, uploading and tracking data.

Gas to Flare During Completions/Workovers §98.233(g) §98.234(f)(2)(i) Reporters have never tracked this data before and need to assess how to track and 

establish systems to collect this data. In order to start tracking data, a data collection system needs to be developed, then rolled out to the third party service companies, the service companies need to approve the system, and contracts may need to be renegotiated to mandate the use of the new tracking systems. Only then can the third party service companies start collecting, uploading and tracking data.

Metered Vent Gas Flow Rate for Completion/Workover Per Field

§98.233(g) §98.234(f)(2)(i) Reporters have never tracked this data before and need to assess how to track and 

establish data collection systems and conduct training before they can begin to collect this data. Calculation Methodologies 1 and 2 both require determining the flow rate for one completion in each gas producing "field" and for one well workover in each gas producing "field." Reporting on a field basis is an issue that has been raised in several petitions for reconsideration. The term "field" is not sufficiently defined to enable reporters to know know where to take the measurements yet, as some wells are not in defined fields. Reporters cannot comply with this requirement until this ambiguity is resolved.

Gas Well Venting from Completions & Workovers w/ Hydraulic Fracture

Recovered Emissions into Sales Pipeline During Completions/Workovers

§98.233(g) §98.234(f)(2)(i) Reporters have never tracked this data before and need to assess how to track and 

establish systems to collect this data. Although the rule allows the use of company records, those records report production sales, but they do not provide information on a per event basis. It is unclear what is meant by "recovered emissions" and how these emissions are distinguishable from sales production.

Well Venting for Liquids UnloadingGas Well Venting from Completions & Workovers w/ Hydraulic Fracture

**BAMM is allowed for this parameter but may not be necessary for all reporters.
Table 1:

Onshore production and Onshore natural gas processing

Data parameters for which BAMM is permitted under 40 C.F.R. 98.234(f)(2), (3), (4)

Why more time for BAMM beyond Sept. 2011 is needed 

Emission Source Data Parameter 40 C.F.R. BAMM Citation Why more time beyond Sept. 2011 is needed

Hours Vented During Completions/Workovers Per Field

§98.233(g) §98.234(f)(2)(i)

§98.234(f)(3)(i)

The calculations require knowing the cumulative amount of time in hours of all well completion venting in a "field" during the reporting year. The term "field" is not sufficiently defined to enable reporters to know know where to take the measurements yet as some wells are not in defined fields. Reporters cannot comply with this requirement until this ambiguity is resolved. Reporters have never tracked this data before and need to assess how to track and establish systems to collect this data. In order to start tracking data, an data collection system needs to be developed, then rolled out to the third party service companies, the service companies need to approve the system, and contracts may need to be renegotiated to mandate the use of the new tracking systems. Only then can the third party service companies start collecting, uploading and tracking data.

Volume of CO2 or N2 Injected During 

Completions/Workovers w/ Frac Jobs

§98.233(g) §98.234(f)(2)(i) Data available**

GHG mole fraction (CH4 and CO2) in produced natural gas 

§98.233(g) §98.234(f)(2)(i) Reporters have never tracked this data before and need to assess how to track and 

establish systems to collect this data. In order to start tracking data, a data collection system needs to be developed, then rolled out to the third party service companies, the service companies need to approve the system, and contracts may need to be renegotiated to mandate the use of the new tracking systems. Only then can the third party service companies start collecting, uploading and tracking data.

Temperature at Actual Conditions §98.233(g) §98.234(f)(2)(i) Reporters have never tracked this data before and need to assess how to track and 

establish systems to collect this data. In order to start tracking data, a data collection system needs to be developed, then rolled out to the third party service companies, the service companies need to approve the system, and contracts may need to be renegotiated to mandate the use of the new tracking systems. Only then can the third party service companies start collecting, uploading and tracking data. No guidance is available regarding whether or how to calibrate temperature gauges.

Pressure at Actual Conditions §98.233(g) §98.234(f)(2)(i) Reporters have never tracked this data before and need to assess how to track and 

establish systems to collect this data. In order to start tracking data, a data collection system needs to be developed, then rolled out to the third party service companies, the service companies need to approve the system, and contracts may need to be renegotiated to mandate the use of the new tracking systems. Only then can the third party service companies start collecting, uploading and tracking data. No guidance is available regarding whether or how to calibrate pressure gauges.

Number of Events §98.233(g) §98.234(f)(3)(ii) Reporters have never tracked this data before and need to assess how to track and 

establish systems to collect this data. In order to start tracking data, a data collection system needs to be developed, then rolled out to the third party service companies, the service companies need to approve the system, and contracts may need to be renegotiated to mandate the use of the new tracking systems. Only then can the third party service companies start collecting, uploading and tracking data.

Number of Events §98.233(h) §98.234(f)(3)(i) The calculations require knowing the cumulative amount of time in hours of all well 

completion venting in a "field" during the reporting year. The term "field" is not sufficiently defined to enable reporters to know know where to take the measurements yet as some wells are not in defined fields. Reporters cannot comply with this requirement until this ambiguity is resolved. Reporters have never tracked this data before and need to assess how to track and establish systems to collect this data. In order to start tracking data, a data collection system needs to be

developed, then rolled out to the third party service companies, the service companies need to approve the system, contracts may need to be renegotiated to mandate the use of the new tracking systems, and then the third party service companies can start uploading and tracking data.

Gas Well Venting from Completions & Workovers w/o Hydraulic FractureGas Well Venting from Completions & Workovers w/ Hydraulic Fracture

**BAMM is allowed for this parameter but may not be necessary for all reporters.
Table 1:

Onshore production and Onshore natural gas processing

Data parameters for which BAMM is permitted under 40 C.F.R. 98.234(f)(2), (3), (4)

Why more time for BAMM beyond Sept. 2011 is needed 

Emission Source Data Parameter 40 C.F.R. BAMM Citation Why more time beyond Sept. 2011 is needed

Number of Events §98.233(h) §98.234(f)(3)(ii) Reporters must determine the number of workovers per field not involving hydraulic 

fracturing and the number of well completions without hydraulic fracturing in a field. The term field is not sufficiently defined to enable reporters to know know how to conduct these counts as some wells are not in defined fields. Reporters cannot comply with this requirement until this ambiguity is resolved. Reporters have never tracked this data before and need to assess how to track and establish systems to collect this data. In order to start tracking data, a data collection system needs to bedeveloped, then rolled out to the third party service companies, the service companies need to approve the system, contracts may need to be renegotiated to mandate the use of the new tracking systems, and then the third party service companies can start uploading and tracking data.

Blowdown Vent Stacks Number of Events §98.233(i) §98.234(f)(3)(ii) The definition of "onshore natural gas processing" needs to be revised to eliminate 

ambiguity between processing and production. Reporters have never tracked this data before and need to assess how to track and establish systems to collect this data.

Storage Tanks Volumetric Flow Rate §98.233(j) §98.234(f)(3)(iii) Data available**

Gas to Oil Ratio §98.233(l) §98.234(f)(2)(ii) The final rule did not provide a definition for the term "well testing." The rule must 

be revised to clearly distinguish well testing emissions from completion emissions to enable reporter to know what data to collect.

Flow Rate for Tested Well §98.233(l) §98.234(f)(2)(ii)

§98.234(f)(3)(iii)

The final rule did not provide a definition for the term "well testing." The rule must be revised to clearly distinguish well testing emissions from completion emissions to enable reporter to know what data to collect.

Days Tested §98.233(l) §98.234(f)(2)(ii)

§98.234(f)(3)(i)

The final rule did not provide a definition for the term "well testing." The rule must be revised to clearly distinguish well testing emissions from completion emissions to enable reporter to know what data to collect.

Temperature at Actual Conditions §98.233(l) §98.234(f)(2)(ii) The final rule did not provide a definition for the term "well testing." The rule must 

be revised to clearly distinguish well testing emissions from completion emissions to enable reporter to know what data to collect. No guidance is available regarding whether or how to calibrate temperature gauges.

Pressure at Actual Conditions §98.233(l) §98.234(f)(2)(ii) The final rule did not provide a definition for the term "well testing." The rule must 

be revised to clearly distinguish well testing emissions from completion emissions to enable reporter to know what data to collect. No guidance is available regarding whether or how to calibrate pressure gauges.

GHG mole fraction (CH4 and CO2) in produced natural gas 

§98.233(l) §98.234(f)(2)(ii) The final rule did not provide a definition for the term "well testing." The rule must 

be revised to clearly distinguish well testing emissions from completion emissions to enable reporter to know what data to collect.

Gas to Flare §98.233(l) §98.234(f)(2)(ii) The final rule did not provide a definition for the term "well testing." The rule must 

be revised to clearly distinguish well testing emissions from completion emissions to enable reporter to know what data to collect.

Associated Gas Venting Volumetric Flow Rate §98.233(m) §98.234(f)(3)(iii) The final rule did not provide a definition for the term "well testing." The rule must 

be revised to clearly enable reporters to know what constitutes "associated gas venting and flaring emissions not in conjunction with well testing." Without defining these terms, it is unclear what data to collect.

Flare Stacks Volumetric Flow Rate §98.233(n) §98.234(f)(3)(iii) Reporters have never tracked this data before and need to assess how to track and 

establish data collection systems and conduct training before they can begin to collect this data.

Hours Operated Per Mode and Fraction of Time Gas to Sales vs. VRU

§98.233(o) §98.234(f)(3)(i) The definition of "onshore natural gas processing" needs to be revised to eliminate 

ambiguity between processing and production. Reporters have never tracked this data before and need to assess how to track and establish systems to collect this data. The rule requires knowing the number of hours operated in each mode (e.g., operating mode, blowdown valve leakage through the blowdown vent, wet seal and dry seal compressors). Reporters have previously tracked total runtime, but never time in each operating mode. Reporters need to establish systems to collect this data.

Well Testing VentingCentrifugal Compressor Venting

**BAMM is allowed for this parameter but may not be necessary for all reporters.
Table 1:

Onshore production and Onshore natural gas processing

Data parameters for which BAMM is permitted under 40 C.F.R. 98.234(f)(2), (3), (4)

Why more time for BAMM beyond Sept. 2011 is needed 

Emission Source Data Parameter 40 C.F.R. BAMM Citation Why more time beyond Sept. 2011 is needed

Metered Volumetric Flow Rate §98.233(o) §98.234(f)(4)(ii) The definition of "onshore natural gas processing" needs to be revised to eliminate 

ambiguity between processing and production. Reporters have never tracked this data before and need to assess how to track and establish systems to collect this data. The rule requires measuring emissions from all vents, including those manifolded to common vents. EPA needs to clarify whether vents must be measured individually and, if so, how to do so safely. Reporters may need to establish systems to collect this data and conduct training to ensure data is collected in a safe manner. 

Hours Operated Per Mode and Fraction of Time Gas to Sales vs. VRU

§98.233(p) §98.234(f)(3)(i) The definition of "onshore natural gas processing" needs to be revised to eliminate 

ambiguity between processing and production. Reporters have never tracked this data before and need to assess how to track and establish systems to collect this data. The rule requires knowing the number of hours operated in each mode (e.g., operating mode, blowdown valve leakage through the blowdown vent, wet seal and dry seal compressors). Reporters have previously tracked total runtime, but never time in each operating mode. Reporters need to establish systems to collect this data.

Metered Volumetric Flow Rate §98.233(p) §98.234(f)(4)(i) The definition of "onshore natural gas processing" needs to be revised to eliminate 

ambiguity between processing and production. Reporters have never tracked this data before and need to assess how to track and establish systems to collect this data. The rule requires measuring emissions from all vents, including those manifolded to common vents. EPA needs to clarify whether vents must be measured individually and, if so, how to do so safely. Reporters may need to establish systems to collect this data and conduct training to ensure data is collected in a safe manner. 

Equipment Leaks Hours Operated §98.233(q) §98.234(f)(3)(i) The definition of "onshore natural gas processing" needs to be revised to eliminate 

ambiguity between processing and production. Reporters have never tracked this data before and need to assess how to track and establish systems to collect this data. Reporters have never tracked the time the components (i.e., valves, connectors, open ended lines, pressure relief valves, and meters) were leaking and operational before. Reporters need to assess how to track and establish systems to

collect this data.

Equipment Leaks Leak Detection §98.233(q) §98.234(f)(4)(iv) The definition of "onshore natural gas processing" needs to be revised to eliminate 

ambiguity between processing and production. Reporters have never tracked this data before and need to assess how to track and establish systems to collect this data.

Enhanced Oil Recovery Injection Pump Blowdown

Number of Events §98.233(w) §98.234(f)(3)(ii) Reporters have never tracked this data before and need to assess how to track and 

establish data collection systems and conduct training before they can begin to collect this data.

Enhanced Oil Recovery Hydrocarbon Dissolved CO2

Volumetric Flow Rate §98.233(x) §98.234(f)(3)(iii) Data available**

Onshore Combustion Volumetric Flow Rate §98.233(z) §98.234(f)(3)(iii) Reporters have never tracked this data before and need to assess how to track and 

establish data collection systems and conduct training before they can begin to collect this data.

Reciprocating Compressor Venting

**BAMM is allowed for this parameter but may not be necessary for all reporters.
Table 2:

Onshore production and Onshore natural gas processing

Data parameters for which BAMM is not permitted in the final rule

Why BAMM is needed for these additional data parameters for these emission sources

Emission Source Data Parameter 40 C.F.R. Why BAMM is needed for these data paramete

Pneumatic Devices Gas Composition § 98.233(a) For onshore petroleum and natural gas production facilities, no method 

to obtain the concentration of GHGs. Not all streams have continuous sampling is allowed to be conducted on a "field" basis, the term "field" idefined to enable reporters to know where to collect samples because defined fields. Reporters cannot comply with this requirement until this The distinction between source categories needs to be resolved througrule before reporters know at which locations gas composition data is ndetermined, additional time is required to install safe sampling ports (westablish sampling protocols and schedules, and perform the appropricalibrations (some analyzers will require a shutdown to calibrate).

Pneumatic Devices Actual and estimated 

counts of high, low, and intermittent bleed devices

§ 98.233(a) The rule requires conducting a population count and using an emission 

whether the pneumatic device has a high or low continuous bleed rate. does not provide a method by which to determine whether bleed rates Some source categories may use estimates for 2 yrs per the rule, but csuch devices until a methodology is provided in the final revised rule. 

Pneumatic Pumps Gas Composition § 98.233(c) No method is provided by which to obtain the concentration of GHGs. 

continuous gas samplers. If sampling is allowed to be conducted on a "field" is not sufficiently defined to enable reporters to know where to cosome wells are not in defined fields. Reporters cannot comply with this ambiguity is resolved. The distinction between source categories needthrough revisions to the final rule before reporters know at which locatiodata is needed. Once this is determined, additional time is required to ports (where needed), establish sampling protocols and schedules, anappropriate analyzer calibrations (some analyzers will require a shutdo

Pneumatic Pumps Count of natural gas 

driven pneumatic pumps

§ 98.233(c) Reporters have a large number of pneumatic pumps. Those that use in

than natural gas do not have GHG emissions and therefore need to be population count.

Acid Gas Removal (AGR) Vents

All Input Parameters §98.233(d) The definition of "onshore natural gas processing" needs to be revised 

between processing and production. It is currently unclear what facilitieregarding AGR vents. Additional time is needed for gas composition saappropriate calibration requirements. The distinction between source cresolved through revisions to the final rule before reporters know at whcomposition data is needed.
Table 2:

Onshore production and Onshore natural gas processing

Data parameters for which BAMM is not permitted in the final rule

Why BAMM is needed for these additional data parameters for these emission sources

Emission Source Data Parameter 40 C.F.R. Why BAMM is needed for these data paramete

Dehydrator Vents All Input Parameters §98.233(e) The definition of "onshore natural gas processing" needs to be revised 

between processing and production. It is currently unclear what facilitieregarding dehydrator vents. Once the distinction between onshore proprocessing is clear, data collection systems must be devised and impleinformation for each dehydrator (one company alone has over 200).

Dehydrator Vents Pressure §98.233(e) No guidance is available regarding whether or how to calibrate pressurDehydrator Vents Gas Composition §98.233(e) Calculation Methodology 1 calls for the wet natural gas composition. R

most recent gas composition based on available sample analysis for th"field" is not sufficiently defined to enable reporters to know know wherbecause some wells are not in defined fields. The distinction between needs to be resolved through revisions to the final rule before reporters locations gas composition data is needed. Reporters cannot comply wuntil these ambiguities are resolved. Once this is determined, additionainstall safe sampling ports (where needed), establish sampling protocoperform the appropriate analyzer calibrations (some analyzers will requcalibrate).

Well Venting for Liquids Unloading

Metered Measurement

§98.233(f)(1) Calculation Methodology 1 calls for direct measurement by installing a 

line that vents gas from the well. Some companies might prefer to do drather than conducting a calculation for each individual well with liquids however, there are no meters that can directly meter the highly acidic, contains clay, sand, and rock. Therefore, companies will need to instainstall a separate line and then meter the gas. Companies will need to can supply this equipment. Demand for the separators is expected to oequations provided in calculation Methodologies 2 and 3 have errors an

Count of wells vented to the atmosphere for liquids unloading

§ 98.233(f) Reporters have never tracked this data before and need to assess how 

systems to collect this data, regardless of whether calculation Methodo

Temperature § 98.233(f) No guidance is available regarding whether or how to calibrate temperaPressure § 98.233(f) No guidance is available regarding whether or how to calibrate pressurTemperature § 98.233(h) No guidance is available regarding whether or how to calibrate temperaPressure § 98.233(h) No guidance is available regarding whether or how to calibrate pressur

Liquid Unloading
Table 2:

Onshore production and Onshore natural gas processing

Data parameters for which BAMM is not permitted in the final rule

Why BAMM is needed for these additional data parameters for these emission sources

Emission Source Data Parameter 40 C.F.R. Why BAMM is needed for these data paramete

All Input Parameters §98.233(i) The definition of "onshore natural gas processing" needs to be revised 

between processing and production. It is unclear which facilities need regarding blowdown stack vents. The distinction between source categresolved through revisions to the final rule before reporters know at whcomposition data is needed. Once this is determined, additional time is safe sampling ports (where needed), establish sampling protocols and perform the appropriate analyzer calibrations (some analyzers will requcalibrate).

Pressure §98.233(i) No guidance is available regarding whether or how to calibrate pressurGas Composition §98.233(j) Reporters must use the most recent gas composition based on availab

the field. The term "field" is not sufficiently defined to enable reporters collect samples because some wells are not in defined fields. Reportethis requirement until this ambiguity is resolved.

Pressure §98.233(j) No guidance is available regarding whether or how to calibrate pressur

Storage Tanks All Input Parameters 

and reporting requirements for data parameters in Equation W-16

§98.233(j) The rule requires establishing the number of hours a dump valve to a s

stuck open during the year. If no maintenance or operations records areporter must assume the valve was stuck open for the entire portion ovalve was discovered open and then was closed. Significant time is nesystem to begin monitoring and recording when the last time the valve closed. Companies have a lot of onshore separators and tanks. One c6,000 onshore separators and over 16,000 tanks. Reviewing paper revalve on an annual basis will be too burdensome to be manageable; thtools will need to be developed.

Storage Tanks Gas Composition §98.233(k) The distinction between source categories needs to be resolved throug

rule before reporters know at which locations gas composition data is ndetermined, additional time is required to install safe sampling ports (westablish sampling protocols and schedules, and perform the appropricalibrations (some analyzers will require a shutdown to calibrate).

Associated Gas Venting

All Input Parameters §98.233(m) The final rule did not provide a definition for the term "well testing." The 

to clearly enable reporters to know what constitutes "associated gas veemissions not in conjunction with well testing." Without defining these what data to collect.

HHV for N2O Calculation

§98.233(n) It is not clear how to determine the higher heating value (HHV) for this 

unclear whether the default factor provided in 98.233(z)(6)(ii) should be definitiion of "process vent" provided in Subpart A excludes gases to th98.233(z)(6)(iii) methodology must be used, reporters may need to estacollect data and conduct training to ensure data is collected in a safe m

Storage TanksBlowdown Vent StacksFlare Stacks
Table 2:

Onshore production and Onshore natural gas processing

Data parameters for which BAMM is not permitted in the final rule

Why BAMM is needed for these additional data parameters for these emission sources

Emission Source Data Parameter 40 C.F.R. Why BAMM is needed for these data paramete

Gas Composition §98.233(n) For onshore natural gas production, if no continuous gas composition a

reporters must use the most recent gas composition based on available the field. The term "field" is not sufficiently defined to enable reporters collect samples because some wells are not in defined fields. The distcategories needs to be resolved through revisions to the final rule befowhich locations gas composition data is needed. Reporters cannot comrequirement until these ambiguities are resolved. Once this is determinrequired to install safe sampling ports (where needed), establish samplschedules, and perform the appropriate analyzer calibrations (some anshutdown to calibrate).

Temperature §98.233(n) No guidance is available regarding whether or how to calibrate temperaPressure §98.233(n) No guidance is available regarding whether or how to calibrate pressur

Centrifugal Compressor Venting

Gas Composition §98.233(o) Reporters must use the most recent gas composition based on availab

the field. The term "field" is not sufficiently defined to enable reporters collect samples because some wells are not in defined fields. Reportethis requirement until this ambiguity is resolved. Additional clarity is necalibration requirements for gas composition analyzers. The distinction categories needs to be resolved through revisions to the final rule befowhich locations gas composition data is needed. Once this is determinrequired to install safe sampling ports (where needed), establish samplschedules, and perform the appropriate analyzer calibrations (some anshutdown to calibrate).

Reciprocating Compressor Venting

Gas Composition §98.233(p) Reporters must use the most recent gas composition based on availab

the field. The term "field" is not sufficiently defined to enable reporters collect samples because some wells are not in defined fields. Reportethis requirement until this ambiguity is resolved. The distinction betweeneeds to be resolved through revisions to the final rule before reporters locations gas composition data is needed. Once this is determined, adrequired to install safe sampling ports (where needed), establish samplschedules, and perform the appropriate analyzer calibrations (some anshutdown to calibrate).
Table 2:

Onshore production and Onshore natural gas processing

Data parameters for which BAMM is not permitted in the final rule

Why BAMM is needed for these additional data parameters for these emission sources

Emission Source Data Parameter 40 C.F.R. Why BAMM is needed for these data paramete

Equipment Leaks Gas Composition §98.233(q) No method is provided by which to obtain the concentration of GHGs fo

processing facilities. Not all streams have continuous gas samplers. If be conducted on a "field" basis, the term "field" is not sufficiently defineto know know where to collect samples because some wells are not in distinction between source categories needs to be resolved through revbefore reporters know at which locations gas composition data is needcomply with this requirement until these ambiguities are resolved. Oncadditional time is required to install safe sampling ports (where neededprotocols and schedules, and perform the appropriate analyzer calibratwill require a shutdown to calibrate). 

Population Count and Emission Factors

Gas Composition §98.233(r) No method is provided by which to obtain the concentration of GHGs fo

processing facilities. Not all streams have continuous gas samplers. If be conducted on a "field" basis, the term "field" is not sufficiently defineto know know where to collect samples because some wells are not in distinction between source categories needs to be resolved through revbefore reporters know at which locations gas composition data is needcomply with this requirement until these ambiguities are resolved. Addto schedule the calibration of gas composition analyzers (e.g., some recalibrate).

Temperature §98.233(t) No guidance is available regarding whether or how to calibrate temperaPressure §98.233(t) No guidance is available regarding whether or how to calibrate pressur

GHG Volumetric Emissions

Gas Composition §98.233(u) If a continuous gas sampler is not available, onshore petroleum and na

reporters must use the most recent gas composition based on available the "field." The term "field" is not sufficiently defined to enable reporterto collect samples because some wells are not in defined fields. The dsource categories needs to be resolved through revisions to the final ruknow at which locations gas composition data is needed. Reporters carequirement until these ambiguities are resolved. Once this is determinrequired to install safe sampling ports (where needed), establish samplschedules, and perform the appropriate analyzer calibrations (some anshutdown to calibrate).

Volumetric Emissions
Table 2:

Onshore production and Onshore natural gas processing

Data parameters for which BAMM is not permitted in the final rule

Why BAMM is needed for these additional data parameters for these emission sources

Emission Source Data Parameter 40 C.F.R. Why BAMM is needed for these data paramete

Onshore Petroleum & Natural Gas Production and Natural Gas Distribution Combustion Emissions

Gas Composition §98.233(z) If a continuous gas sampler is not available, reporters must use the mo

composition based on available sample analysis for the "field." The tersufficiently defined to enable reporters to know know where to collect swells are not in defined fields. Reporters cannot comply with this requiambiguity is resolved.