# 1 MEMORANDUM

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

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

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

DATE: September 16, 2011

SUBJECT: SUPPLEMENTAL DATA SUBMITTED ON BEST AVAI LABLE 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 receiv e prior approval from the Admini strator for use of BAMM in 2011.

The 2010 final rule for Subpart W of the Greenh ouse 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 containi ng petroleum and natural gas systems. The rule

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

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

emissions and other related data.

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

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

extending the time period during which owners or ope rators are permitted to us e BAMM without submitting a

request to the Administrator for approval, to December 31, 2011. EPA is also expa nding 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 owne rs or operators can request use of BAMM for

beyond 2011.

EPA received data from the American Exploratio n 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 fa ll 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 processingData 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 neededEmission SourceData Parameter40 C.F.R. BAMM CitationWhy more time beyond Sept. 2011 is neededAcid 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 eliminateambiguity between processing and production. Reporters have never tracked thisdata before and need to assess how to track and establish systems to collect thisdata.Dehydrator Vents Volumetric Flow Rate §98.233(e) §98.234(f)(3)(iii) The definition of "onshore natural gas processing" needs to berevised to eliminateambiguity between processing and production. Reporters have never tracked thisdata before and need to assess how to track and establish systems to collect thisdata.Dehydrator Vents Hours Operated §98.233(e) §98.234(f)(3)(i) The definition of "onshore natural gas processing" needs to be revisedto eliminateambiguity between processing and production. Reporters have never tracked thisdata before and need to assess how to track and establish systems to collect thisdata.Hours Vented §98.233(f) §98.234(f)(3)(i) Reporters have never tracked this data before and need to assess how to track andestablish data collection systems and conduct training before they can begin tocollect 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 andestablish data collection systems and conduct training before they can begin tocollect this data.Reduced Emissions Completion/WorkoverVolume to Sales§98.233(g) §98.234(f)(2)(i) Reporters have never tracked this data before and need to assess how to track andestablish systems to collect this data. In order to start tracking data, a datacollection system needs to be developed, then rolled out to the third party servicecompanies, the service companies need to approve the system, and contracts mayneed to be renegotiated to mandate the use of the new tracking systems. Only thencan 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 andestablish systems to collect this data. In order to start tracking data, a datacollection system needs to be developed, then rolled out to the third party servicecompanies, the service companies need to approve the system, and contracts mayneed to be renegotiated to mandate the use of the new tracking systems. Only thencan the third party service companies start collecting, uploading and tracking data.Metered Vent Gas Flow Rate forCompletion/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 andestablish data collection systems and conduct training before they can begin tocollect this data. Calculation Methodologies 1 and 2 both require determining theflow rate for one completion in each gas producing "field" and for one well workoverin each gas producing "field." Reporting on a field basis is an issue that has beenraised in several petitions for reconsideration. The term "field" is not sufficientlydefined to enable reporters to know know where to take the measurements yet, assome wells are not in defined fields. Reporters cannot comply with this requirementuntil this ambiguity is resolved.Gas Well Venting from Completions &Workovers w/ Hydraulic FractureRecovered Emissions into Sales PipelineDuring Completions/Workovers§98.233(g) §98.234(f)(2)(i) Reporters have never tracked this data before and need to assess how to track andestablish systems to collect this data. Although the rule allows the use of companyrecords, those records report production sales, but they do not provide informationon a per event basis. It is unclear what is meant by "recovered emissions" and howthese 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 processingData 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 neededEmission SourceData Parameter40 C.F.R. BAMM CitationWhy more time beyond Sept. 2011 is neededHours Vented During Completions/WorkoversPer 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 wellcompletion venting in a "field" during the reporting year. The term "field" is notsufficiently defined to enable reporters to know know where to take themeasurements yet as some wells are not in defined fields. Reporters cannotcomply with this requirement until this ambiguity is resolved. Reporters have nevertracked this data before and need to assess how to track and establish systems tocollect this data. In order to start tracking data, an data collection system needs tobe developed, then rolled out to the third party service companies, the servicecompanies need to approve the system, and contracts may need to be renegotiatedto mandate the use of the new tracking systems. Only then can the third partyservice companies start collecting, uploading and tracking data.Volume of CO2or N2Injected DuringCompletions/Workovers w/ Frac Jobs§98.233(g) §98.234(f)(2)(i) Data available**GHG mole fraction (CH4 and CO2) inproduced natural gas§98.233(g) §98.234(f)(2)(i) Reporters have never tracked this data before and need to assess how to track andestablish systems to collect this data. In order to start tracking data, a datacollection system needs to be developed, then rolled out to the third party servicecompanies, the service companies need to approve the system, and contracts mayneed to be renegotiated to mandate the use of the new tracking systems. Only thencan 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 howto track andestablish systems to collect this data. In order to start tracking data, a datacollection system needs to be developed, then rolled out to the third party servicecompanies, the service companies need to approve the system, and contracts mayneed to be renegotiated to mandate the use of the new tracking systems. Only thencan 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 totrack andestablish systems to collect this data. In order to start tracking data, a datacollection system needs to be developed, then rolled out to the third party servicecompanies, the service companies need to approve the system, and contracts mayneed to be renegotiated to mandate the use of the new tracking systems. Only thencan 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 andestablish systems to collect this data. In order to start tracking data, a datacollection system needs to be developed, then rolled out to the third party servicecompanies, the service companies need to approve the system, and contracts mayneed to be renegotiated to mandate the use of the new tracking systems. Only thencan 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 wellcompletion venting in a "field" during the reporting year. The term "field" is notsufficiently defined to enable reporters to know know where to take themeasurements yet as some wells are not in defined fields. Reporters cannotcomply with this requirement until this ambiguity is resolved. Reporters have nevertracked this data before and need to assess how to track and establish systems tocollect 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 servicecompanies need to approve the system, contracts may need to be renegotiated tomandate the use of the new tracking systems, and then the third party servicecompanies 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 processingData 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 neededEmission SourceData Parameter40 C.F.R. BAMM CitationWhy more time beyond Sept. 2011 is neededNumber of Events §98.233(h) §98.234(f)(3)(ii) Reporters must determine the number of workovers per field not involving hydraulicfracturing 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 toconduct these counts as some wells are not in defined fields. Reporters cannotcomply with this requirement until this ambiguity is resolved. Reporters have nevertracked this data before and need to assess how to track and establish systems tocollect 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 servicecompanies need to approve the system, contracts may need to be renegotiated tomandate the use of the new tracking systems, and then the third party servicecompanies 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 eliminateambiguity between processing and production. Reporters have never tracked thisdata before and need to assess how to track and establish systems to collect thisdata.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 mustbe revised to clearly distinguish well testing emissions from completion emissions toenable 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 mustbe revised to clearly distinguish well testing emissions from completion emissions toenable 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 mustbe revised to clearly distinguish well testing emissions from completion emissions toenable 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 mustbe revised to clearly distinguish well testing emissions from completion emissions toenable reporter to know what data to collect. No guidance is available regardingwhether 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 mustbe revised to clearly distinguish well testing emissions from completion emissions toenable reporter to know what data to collect. No guidance is available regardingwhether or how to calibrate pressure gauges.GHG mole fraction (CH4 and CO2) inproduced 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 mustbe revised to clearly distinguish well testing emissions from completion emissions toenable 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 mustbe revised to clearly distinguish well testing emissions from completion emissions toenable 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 mustbe revised to clearly enable reporters to know what constitutes "associated gasventing and flaring emissions not in conjunction with well testing." Without definingthese 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 andestablish data collection systems and conduct training before they can begin tocollect this data.Hours Operated Per Mode and Fraction ofTime 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 eliminateambiguity between processing and production. Reporters have never tracked thisdata before and need to assess how to track and establish systems to collect thisdata. 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 anddry seal compressors). Reporters have previously tracked total runtime, but nevertime in each operating mode. Reporters need to establish systems to collect thisdata.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 processingData 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 neededEmission SourceData Parameter40 C.F.R. BAMM CitationWhy more time beyond Sept. 2011 is neededMetered Volumetric Flow Rate §98.233(o) §98.234(f)(4)(ii) The definition of "onshore natural gas processing" needs to be revised to eliminateambiguity between processing and production. Reporters have never tracked thisdata before and need to assess how to track and establish systems to collect thisdata. The rule requires measuring emissions from all vents, including thosemanifolded to common vents. EPA needs to clarify whether vents must bemeasured individually and, if so, how to do so safely. Reporters may need toestablish systems to collect this data and conduct training to ensure data iscollected in a safe manner.Hours Operated Per Mode and Fraction ofTime 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 eliminateambiguity between processing and production. Reporters have never tracked thisdata before and need to assess how to track and establish systems to collect thisdata. 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 anddry seal compressors). Reporters have previously tracked total runtime, but nevertime in each operating mode. Reporters need to establish systems to collect thisdata.Metered Volumetric Flow Rate §98.233(p) §98.234(f)(4)(i) The definition of "onshore natural gas processing" needs to be revised toeliminateambiguity between processing and production. Reporters have never tracked thisdata before and need to assess how to track and establish systems to collect thisdata. The rule requires measuring emissions from all vents, including thosemanifolded to common vents. EPA needs to clarify whether vents must bemeasured individually and, if so, how to do so safely. Reporters may need toestablish systems to collect this data and conduct training to ensure data iscollected 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 eliminateambiguity between processing and production. Reporters have never tracked thisdata before and need to assess how to track and establish systems to collect thisdata. Reporters have never tracked the time the components (i.e., valves,connectors, open ended lines, pressure relief valves, and meters) were leaking andoperational before. Reporters need to assess how to track and establish systems tocollect this data.Equipment Leaks Leak Detection §98.233(q) §98.234(f)(4)(iv) The definition of "onshore natural gas processing" needs to be revisedto eliminateambiguity between processing and production. Reporters have never tracked thisdata before and need to assess how to track and establish systems to collect thisdata.Enhanced Oil Recovery Injection PumpBlowdownNumber of Events §98.233(w) §98.234(f)(3)(ii) Reporters have never tracked this data before and need to assess how to track andestablish data collection systems and conduct training before they can begin tocollect this data.Enhanced Oil Recovery HydrocarbonDissolved CO2Volumetric 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 andestablish data collection systems and conduct training before they can begin tocollect 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 processingData parameters for which BAMM is not permitted in the final ruleWhy BAMM is needed for these additional data parameters for these emission sourcesEmission Source Data Parameter 40 C.F.R. Why BAMM is needed for these data parametersPneumatic Devices Gas Composition § 98.233(a) For onshore petroleum and natural gas production facilities, no method is provided by whichto obtain the concentration of GHGs. Not all streams have continuous gas samplers. Ifsampling is allowed to be conducted on a "field" basis, the term "field" is not sufficientlydefined to enable reporters to know where to collect samples because some wells are not indefined fields. Reporters cannot comply with this requirement until this ambiguity is resolved.The distinction between source categories needs to be resolved through revisions to the finalrule before reporters know at which locations gas composition data is needed. Once this isdetermined, additional time is required to install safe sampling ports (where needed),establish sampling protocols and schedules, and perform the appropriate analyzercalibrations (some analyzers will require a shutdown to calibrate).Pneumatic Devices Actual and estimatedcounts of high, low,and intermittent bleeddevices§ 98.233(a) The rule requires conducting a population count and using an emission factor based onwhether the pneumatic device has a high or low continuous bleed rate. However, the ruledoes not provide a method by which to determine whether bleed rates are "high" or "low".Some source categories may use estimates for 2 yrs per the rule, but cannot begin countingsuch 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. Not all streams havecontinuous gas samplers. If sampling is allowed to be conducted on a "field" basis, the term"field" is not sufficiently defined to enable reporters to know where to collect samples becausesome wells are not in defined fields. Reporters cannot comply with this requirement until thisambiguity is resolved. The distinction between source categories needs to be resolvedthrough revisions to the final rule before reporters know at which locations gas compositiondata is needed. Once this is determined, additional time is required to install safe samplingports (where needed), establish sampling protocols and schedules, and perform theappropriate analyzer calibrations (some analyzers will require a shutdown to calibrate).Pneumatic Pumps Count of natural gasdriven pneumaticpumps§ 98.233(c) Reporters have a large number of pneumatic pumps. Those that use instrument air ratherthan natural gas do not have GHG emissions and therefore need to be excluded from thepopulation count.Acid Gas Removal(AGR) VentsAll Input Parameters §98.233(d) The definition of "onshore natural gas processing" needs to be revised to eliminate ambiguitybetween processing and production. It is currently unclear what facilities need to collect dataregarding AGR vents. Additional time is needed for gas composition sampling and to fulfillappropriate calibration requirements. The distinction between source categories needs to beresolved through revisions to the final rule before reporters know at which locations gascomposition data is needed.Table 2:Onshore production and Onshore natural gas processingData parameters for which BAMM is not permitted in the final ruleWhy BAMM is needed for these additional data parameters for these emission sourcesEmission Source Data Parameter 40 C.F.R. Why BAMM is needed for these data parametersDehydrator Vents All Input Parameters §98.233(e) The definition of "onshore natural gas processing" needs to be revised to eliminate ambiguitybetween processing and production. It is currently unclear what facilities need to collect dataregarding dehydrator vents. Once the distinction between onshore production and gasprocessing is clear, data collection systems must be devised and implemented to gatherinformation 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 pressure gauges.Dehydrator Vents Gas Composition §98.233(e) Calculation Methodology 1 calls for the wet natural gas composition. Reporters may use themost recent gas composition based on available sample analysis for the "field." The term"field" is not sufficiently defined to enable reporters to know know where to collect samplesbecause some wells are not in defined fields. The distinction between source categoriesneeds to be resolved through revisions to the final rule before reporters know at whichlocations gas composition data is needed. Reporters cannot comply with this requirementuntil these ambiguities are resolved. Once this is determined, additional time is required toinstall safe sampling ports (where needed), establish sampling protocols and schedules, andperform the appropriate analyzer calibrations (some analyzers will require a shutdown tocalibrate).Well Venting forLiquids UnloadingMeteredMeasurement§98.233(f)(1) Calculation Methodology 1 calls for direct measurement by installing a flow meter on the ventline that vents gas from the well. Some companies might prefer to do direct measurementrather than conducting a calculation for each individual well with liquids unloading events;however, there are no meters that can directly meter the highly acidic, corrosive material thatcontains clay, sand, and rock. Therefore, companies will need to install sand separators,install a separate line and then meter the gas. Companies will need to engage vendors thatcan supply this equipment. Demand for the separators is expected to outpace supply. Theequations provided in calculation Methodologies 2 and 3 have errors and need to be revised.Count of wells ventedto the atmosphere forliquids unloading§ 98.233(f) Reporters have never tracked this data before and need to assess how to track and establishsystems to collect this data, regardless of whether calculation Methodology 1, 2, or 3 is used.Temperature § 98.233(f) No guidance is available regarding whether or how to calibrate temperature gauges.Pressure § 98.233(f) No guidance is available regarding whether or how to calibrate pressure gauges.Temperature § 98.233(h) No guidance is available regarding whether or how to calibrate temperature gauges.Pressure § 98.233(h) No guidance is available regarding whether or how to calibrate pressure gauges.Liquid UnloadingTable 2:Onshore production and Onshore natural gas processingData parameters for which BAMM is not permitted in the final ruleWhy BAMM is needed for these additional data parameters for these emission sourcesEmission Source Data Parameter 40 C.F.R. Why BAMM is needed for these data parametersAll Input Parameters §98.233(i) The definition of "onshore natural gas processing" needs to be revised to eliminate ambiguitybetween processing and production. It is unclear which facilities need to collect dataregarding blowdown stack vents. The distinction between source categories needs to beresolved through revisions to the final rule before reporters know at which locations gascomposition data is needed. Once this is determined, additional time is required to installsafe sampling ports (where needed), establish sampling protocols and schedules, andperform the appropriate analyzer calibrations (some analyzers will require a shutdown tocalibrate).Pressure §98.233(i) No guidance is available regarding whether or how to calibrate pressure gauges.Gas Composition §98.233(j) Reporters must use the most recent gas composition based on available sample analysis forthe field. The term "field" is not sufficiently defined to enable reporters to know know where tocollect samples because some wells are not in defined fields. Reporters cannot comply withthis requirement until this ambiguity is resolved.Pressure §98.233(j) No guidance is available regarding whether or how to calibrate pressure gauges.Storage Tanks All Input Parametersand reportingrequirements for dataparameters inEquation W-16§98.233(j) The rule requires establishing the number of hours a dump valve to a separator or tank isstuck open during the year. If no maintenance or operations records are available, thereporter must assume the valve was stuck open for the entire portion of the year until thevalve was discovered open and then was closed. Significant time is needed to implement asystem to begin monitoring and recording when the last time the valve was known to beclosed. Companies have a lot of onshore separators and tanks. One company has over6,000 onshore separators and over 16,000 tanks. Reviewing paper records for every dumpvalve on an annual basis will be too burdensome to be manageable; therefore, electronictools will need to be developed.Storage Tanks Gas Composition §98.233(k) The distinction between source categories needs to be resolved through revisions to the finalrule before reporters know at which locations gas composition data is needed. Once this isdetermined, additional time is required to install safe sampling ports (where needed),establish sampling protocols and schedules, and perform the appropriate analyzercalibrations (some analyzers will require a shutdown to calibrate).Associated GasVentingAll Input Parameters §98.233(m) The final rule did not provide a definition for the term "well testing." The rule must be revisedto clearly enable reporters to know what constitutes "associated gas venting and flaringemissions not in conjunction with well testing." Without defining these terms, it is unclearwhat data to collect.HHV for N2OCalculation§98.233(n) It is not clear how to determine the higher heating value (HHV) for this calculation. It isunclear whether the default factor provided in 98.233(z)(6)(ii) should be used because thedefinitiion of "process vent" provided in Subpart A excludes gases to the flare. If98.233(z)(6)(iii) methodology must be used, reporters may need to establish systems tocollect data and conduct training to ensure data is collected in a safe manner.Storage TanksBlowdown VentStacksFlare StacksTable 2:Onshore production and Onshore natural gas processingData parameters for which BAMM is not permitted in the final ruleWhy BAMM is needed for these additional data parameters for these emission sourcesEmission Source Data Parameter 40 C.F.R. Why BAMM is needed for these data parametersGas Composition §98.233(n) For onshore natural gas production, if no continuous gas composition analyzer is available,reporters must use the most recent gas composition based on available sample analysis forthe field. The term "field" is not sufficiently defined to enable reporters to know know where tocollect samples because some wells are not in defined fields. The distinction between sourcecategories needs to be resolved through revisions to the final rule before reporters know atwhich locations gas composition data is needed. Reporters cannot comply with thisrequirement until these ambiguities are resolved. Once this is determined, additional time isrequired to install safe sampling ports (where needed), establish sampling protocols andschedules, and perform the appropriate analyzer calibrations (some analyzers will require ashutdown to calibrate).Temperature §98.233(n) No guidance is available regarding whether or how to calibrate temperature gauges.Pressure §98.233(n) No guidance is available regarding whether or how to calibrate pressure gauges.CentrifugalCompressor VentingGas Composition §98.233(o) Reporters must use the most recent gas composition based on available sample analysis forthe field. The term "field" is not sufficiently defined to enable reporters to know know where tocollect samples because some wells are not in defined fields. Reporters cannot comply withthis requirement until this ambiguity is resolved. Additional clarity is needed regardingcalibration requirements for gas composition analyzers. The distinction between sourcecategories needs to be resolved through revisions to the final rule before reporters know atwhich locations gas composition data is needed. Once this is determined, additional time isrequired to install safe sampling ports (where needed), establish sampling protocols andschedules, and perform the appropriate analyzer calibrations (some analyzers will require ashutdown to calibrate).ReciprocatingCompressor VentingGas Composition §98.233(p) Reporters must use the most recent gas composition based on available sample analysis forthe field. The term "field" is not sufficiently defined to enable reporters to know know where tocollect samples because some wells are not in defined fields. Reporters cannot comply withthis requirement until this ambiguity is resolved. The distinction between source categoriesneeds to be resolved through revisions to the final rule before reporters know at whichlocations gas composition data is needed. Once this is determined, additional time isrequired to install safe sampling ports (where needed), establish sampling protocols andschedules, and perform the appropriate analyzer calibrations (some analyzers will require ashutdown to calibrate).Table 2:Onshore production and Onshore natural gas processingData parameters for which BAMM is not permitted in the final ruleWhy BAMM is needed for these additional data parameters for these emission sourcesEmission Source Data Parameter 40 C.F.R. Why BAMM is needed for these data parametersEquipment Leaks Gas Composition §98.233(q) No method is provided by which to obtain the concentration of GHGs for onshore naturalgasprocessing facilities. Not all streams have continuous gas samplers. If sampling is allowed tobe conducted on a "field" basis, the term "field" is not sufficiently defined to enable reportersto know know where to collect samples because some wells are not in defined fields. Thedistinction between source categories needs to be resolved through revisions to the final rulebefore reporters know at which locations gas composition data is needed. Reporters cannotcomply with this requirement until these ambiguities are resolved. Once this is determined,additional time is required to install safe sampling ports (where needed), establish samplingprotocols and schedules, and perform the appropriate analyzer calibrations (some analyzerswill require a shutdown to calibrate).Population Countand EmissionFactorsGas Composition §98.233(r) No method is provided by which to obtain the concentration of GHGs for onshore natural gasprocessing facilities. Not all streams have continuous gas samplers. If sampling is allowed tobe conducted on a "field" basis, the term "field" is not sufficiently defined to enable reportersto know know where to collect samples because some wells are not in defined fields. Thedistinction between source categories needs to be resolved through revisions to the final rulebefore reporters know at which locations gas composition data is needed. Reporters cannotcomply with this requirement until these ambiguities are resolved. Additional time is neededto schedule the calibration of gas composition analyzers (e.g., some require a shutdown tocalibrate).Temperature §98.233(t) No guidance is available regarding whether or how to calibrate temperature gauges.Pressure §98.233(t) No guidance is available regarding whether or how to calibrate pressure gauges.GHG VolumetricEmissionsGas Composition §98.233(u) If a continuous gas sampler is not available, onshore petroleum and natural gas productionreporters must use the most recent gas composition based on available sample analysis forthe "field." The term "field" is not sufficiently defined to enable reporters to know know whereto collect samples because some wells are not in defined fields. The distinction betweensource categories needs to be resolved through revisions to the final rule before reportersknow at which locations gas composition data is needed. Reporters cannot comply with thisrequirement until these ambiguities are resolved. Once this is determined, additional time isrequired to install safe sampling ports (where needed), establish sampling protocols andschedules, and perform the appropriate analyzer calibrations (some analyzers will require ashutdown to calibrate).VolumetricEmissionsTable 2:Onshore production and Onshore natural gas processingData parameters for which BAMM is not permitted in the final ruleWhy BAMM is needed for these additional data parameters for these emission sourcesEmission Source Data Parameter 40 C.F.R. Why BAMM is needed for these data parametersOnshore Petroleum& Natural GasProduction andNatural GasDistributionCombustionEmissionsGas Composition §98.233(z) If a continuous gas sampler is not available, reporters must use the most recent gascomposition based on available sample analysis for the "field." The term "field" is notsufficiently defined to enable reporters to know know where to collect samples because somewells are not in defined fields. Reporters cannot comply with this requirement until thisambiguity is resolved.