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.
