e-Ggrt Webinar Subpart W NOI and BAMM

Greenhouse Gas Reporting Program 

Subpart W: Petroleum and Natural Gas 

Systems 

Best Available Monitoring Methods (BAMM) 

November 17, 2011 

Jerome Blackman, Kong Chiu, US EPA 

This training is provided solely for informational purposes. It does not 

provide legal advice, have legally binding effect, or expressly or 

implicitly create, expand, or limit any legal rights, obligations, 

responsibilities, expectations, or benefits in regard to any person.

Outline 

• Subpart W Overview 

• Best Available Monitoring Methods (BAMM) 

provisions of Subpart W 

• How to apply for BAMM for 2012, if needed 

• How to register facilities and Designated 

Representatives in the Electronic Greenhouse Gas 

Reporting Tool (e-GGRT) 

2

Subpart W Overview 

Subpart W requires petroleum and natural gas 

facilities that emit 25,000 metric tons or more of CO 2e 

per year to report: 

– offshore petroleum and natural gas production 

– onshore petroleum and natural gas production 

– onshore natural gas processing 

– onshore natural gas transmission compression 

– underground natural gas storage 

– liquefied natural gas (LNG) storage 

– LNG import and export equipment 

– natural gas distribution 

3

Background to Subpart W 

BAMM 

• November 2010 –Subpart W Published in FR 

• January 1, 2011 – Data Collection Began for W Reporters. 

Reports Due September 2012. 

• June 2011 – Proposed rule to allow automatic BAMM for all 

sources for 2011 

• September 2011 - Finalized rule granting automatic BAMM 

for 2011, and in future years allowing use of BAMM in cases 

of unique or unusual circumstances, upon EPA approval 

4

Background to Subpart W 


• Final BAMM Rule (76 FR 59533) 

– Permits use of BAMM for all measurements for calendar 

year 2011 without being required to submit a request for 

approval from the Administrator 

– Gives owners and operators additional time to request to 

use BAMM beyond 2011 

5

How Do I Use BAMM? 

• Reporters MUST estimate emissions using 

applicable equations in rule 

• Reporters MAY use approved BAMM for 

estimating equation inputs 

6

What Methods Qualify as 

BAMM? 

BAMM could include the following: 

– Monitoring methods currently used by your facility that 

do not meet the specifications of a relevant subpart 

(including use of industry accepted or company used 

emission factors, e.g., the API Compendium) 

– Supplier data 

– Engineering calculations 

– Other company records 

7

To What Sources does BAMM 

apply? 

• If a parameter cannot reasonably be measured: 

– 98.234(f)(2): Well-related emissions 

– 98.234(f)(3): Specified activity data 

– 98.234(f)(4): Leak detection and measurement 

– 98.234(f)(5)(iv): All sources not listed above 

8

2011 – BAMM Automatic 

• In 2011, option to use BAMM is granted automatically 

• No need for notice of intent (NOI) submission or BAMM 

request submission 

• Use of BAMM does not impact reporting obligations- you 

must still follow the reporting requirements in 98.236, but 

your report will reflect the methods you used for BAMM. 

9

Requests to use BAMM in 

2012 

• EPA does not anticipate a need for BAMM in 2012 

• EPA will only approve BAMM if and applicant demonstrates unique or unusual 

circumstances according to 98.234(f)(8)(iii). 

• Two Step Process – NOI must be submitted by 12/31/11 and BAMM Request must be 

submitted by 3/30/12 

– A reporter must submit both NOI & BAMM requests by the respective deadlines 

– Each reporter must specify in every facility’s BAMM application the amount of time 

BAMM is needed, and a description of unique and unusual circumstances. In order to 

give compliance assurance, EPA will automatically grant BAMM through June 30, 

2012 for every BAMM application submitted by March 30, 2102. 

– Between March 30 and June 30, 2012 EPA will evaluate every BAMM application. EPA 

will only approve BAMM beyond June 30, 2012 if an application clearly demonstrates 

unique or unusual circumstances. EPA will send notification of rejected BAMM 

applications by June 2012. 

10

Requests to use BAMM for 2012 

• Owners or operators that submit an NOI but do not 

follow up with the BAMM request by March 30, 

2012 cannot use BAMM in 2012. 

11

Subpart W BAMM Process 

2011 

Automatic 

2012 

Through 

June 30 

Automatic if: 

� Notice of Intent 


� BAMM application 


2012 

Beyond 

June 30 

Considered by EPA 

for unique or unusual 

circumstances: 

•Notice of Intent 

submitted by 

12/31/11 

•BAMM applicaiton 

submitted by 

3/30/12 

2013 

and beyond 

Considered by EPA for 

unique or unusual 

circumstances: 

� BAMM application 

submitted by 9/30 of 

previous year 

12

BAMM Request Process for 2012 

Facility registers Designated Representative and facility 

through e-GGRT in 2011 prior to submitting Notice of Intent 

Facility submits Notice of Intent by December 31, 2011 

Facility submits BAMM request by March 30, 2012 

If both documents are submitted by respective deadlines, AUTOMATIC BAMM through June 30, 2012 

Use of BAMM between June 30 - December 31, 2012 is subject to EPA approval 

13

BAMM Request Process for 2013 

and Beyond 

Facility registered in e-GGRT (completed) 

Facility submits BAMM request by September 30 of PRECEDING year for which BAMM is sought 

BAMM extensions are subject to receiving EPA approval by December 31. NO AUTOMATIC BAMM. 

Each BAMM request will be approved for a maximum of one calendar year ending on 

the date requested or by December 31, whichever is earlier. 

14

How do I submit NOI and 

BAMM requests? 

• NOI and BAMM requests must be submitted 

through e-GGRT 

• EPA now modifying e-GGRT to accept both NOIs 

and BAMM requests. 

– e-GGRT will be able to accept NOIs by November 2011 (to 

meet the December 31, 2011 deadline for submission of 

NOIs). 

– e-GGRT will be able to accept the full BAMM request 

before the March 30, 2012 deadline. 

15

How do I submit NOI and 

BAMM requests? (cont’d) 

• Facilities reporting under subpart W that also 

reported for the 2010 data collection year (e.g., 

under another subpart) are already registered with 

e-GGRT 

• For facilities reporting for the first time in 2011, 

you must register the facility and Designated 

Representative in 2011 prior to submitting an NOI. 

• If you do not plan to use BAMM in 2012, then the 

registration deadline is July 30, 2012. 

16

Who can submit the NOI and 

BAMM request? 

• Each NOI and BAMM request must be submitted by 

the Designated Representative, or an alternate 

designated representative, or agent. 

• A single Designated Representative may represent 

multiple facilities. 

• An association cannot submit NOI or BAMM 

requests for multiple facilities. 

17

NOI’s and BAMM Requests 

• An NOI or BAMM request submitted prior to 

the effective date of the final BAMM rule 

revision (76 FR 59533, September 30, 2011) 

is not valid. 

• Reporters must submit an NOI due by 

December 31, 2011 and BAMM application 

due by March 30, 2012 for use of BAMM 

during 2012. 

18

BAMM Requests for 2012 and 

Beyond 

• See 76 FR 59533, section 98.234(f)(8)(ii) for 

requirements for content of BAMM request 

– List of industry segments and parameters for which 

BAMM is requested 

– Description of unique and unusual circumstances 

justifying BAMM 

– Explanation of how and when the facility will comply 

with all Subpart W reporting requirements 

19

For More Information 

• Subpart W Information 

http://www.epa.gov/ghgreporting/reporters/subpart/w.html 

• GHG Reporting Program Information: 

http://www.epa.gov/ghgreporting/reporters/index.html 

• Questions on the rule 

http://www.epa.gov/ghgreporting/contactus.html 

• Email 

GHGreporting@epa.gov 

20

For a copy of these slides, visit: 

www.epa.gov/ghgreporting/reporters/training/index.html 

21

Electronic Greenhouse Gas 

Reporting Tool (e-GGRT) 

22

E-GGRT Overview 

• Purpose of this portion of the webinar 

• About e-GGRT 

• e-GGRT & NOI / BAMM 

• e-GGRT user registration 

• e-GGRT facility/supplier registration 

• Registering Designated Representatives (DR), 

Alternate Designated Representatives (ADR) and 

Agents 

• Questions & Answers 

23

About e-GGRT 

https://ghgreporting.epa.gov 

• Web-based system 

– Will guide reporters through data entry and submission 

– Built-in calculations 

• Reporters may choose to format their annual GHG report according 

to the e-GGRT XML schema 

– These reporters must meet the same registration and submission 

deadlines as all other reporters 

24

About e-GGRT 

• System Requirements 

– Internet Explorer 7+ or Firefox 3+ 

– Javascript enabled in the browser 

– Transport Layer Security (TLS) 

enabled in the browser 

– PDF reader (e.g. Adobe Reader) 

– Access to printer (for Electronic 

Signature Agreement) 

– Access to the Internet 

– Personal (private) email account 

• E-GGRT performs a browser test and 

will redirect to these pages if you fail 

• E-GGRT enforces a ten-minute 

inactivity timeout. 

25

e-GGRT RSS RSS Feed Feed 

• RSS web feed/syndication format 

• e-GGRT specific updates, may include 

– e-GGRT outages, system status 

– e-GGRT software tips, bugs & work-arounds 

– e-GGRT FAQs 

– Other important announcements 

• Subscribe: 

– http://www.ccdsupport.com/confluence/createrssfeed.action?types=blogpos 

t&spaces=eggrtrss&title=e- 

GGRT&labelString%3D&excludedSpaceKeys%3D&sort=modified&maxResult 

s=10&timeSpan=10&showContent=true&showDiff=true&confirm=Create+R 

SS+Feed 

• Read the Blog: 

– http://www.ccdsupport.com/confluence/display/help/e-GGRT+RSS 

• e-GGRT Help: 

– www.ccdsupport.com 

26

Using e-GGRT for NOI and 

BAMM: Overview 

Log-In to 

e-GGRT 

Go To 

FAC 

MANAGEMENT 

TAB 

Note: Screenshots on the following 

Pages include “DRAFT” content that 

may differ slightly from the final 

Subpart W NOI and BAMM screens that 

users will see. 

Find & Open a 

Facility 

Click 

Subpart W 

Link 

(NOI / BAMM) 


Review & Complete 

BAMM Web-Form 

Upload 

Document(s) 

SUBMIT & CERTIFY 

NOI 

Review & Complete 

NOI Web-Form 

27

e-GGRT Home Screen 

Access your 

Facilities HERE or 

Click the FACILITY 

MANAGEMENT 

Tab (above) 

28

Facility Summary Screen 

Click HERE to begin 

The Subpart W 

NOI and BAMM 

Process for this 

Facility 

29

Subpart W Overview 

Click HERE to add a 

NOI 

Submission 

Click HERE to add a 


Submission 

30

NOI / BAMM Web-Form(s) 

Review Text on 

Page 

Complete information, 

as needed. 

Click HERE to begin the 

Official Submission & 

Certification process.. 

31

BAMM File Upload 

For BAMM submission 

only you will need to 

UPLOAD a file containing 

.your document(s) 

When you have 

Successfully 

Attached your file 

Click here to Submit 

32

Sign/Certify/Submit 

“subway” map shows 

you the steps in the 

process and where 

you are. 

Review Certification 

Statement(s) 

As appropriate 

then 

enter your Password 

to begin CROMERR 

Submission 

33

User Registration: Getting 

Started 

• Video Tutorials available at: 

– http://www.ccdsupport.com/confluence/display/help/ 

Tutorials 

• Information you will need includes: 

– Name 

– Mailing address 

– Email address 

• If you are an EPA Central Data Exchange (CDX) 

user: CDX User Name and Password 

34

Registration: Overview 

1 

New 

e-GGRT 

Users 

USER REGISTRATION 

Enter Basic Info to 

Become an 

e-GGRT 

USER 

EPA APPROVES 

Electronic Signature 

Agreement (ESA) 

2 

FACILITY AND 

SUPPLIER 

REGISTRATION 

3 

APPOINT 

DESIGNATED 

REPRESENTATIVE (DR) 

4 

SET UP 

AGENT(S) 

3 B 

SIGN AND SUBMIT 

Certificate of 

Representation (COR) 

4 B 

SIGN AND SUBMIT 

Notice of 

Delegation (NOD) 

35

User Registration: Login Page 

Context sensitive help on 

every page 

As a new e-GGRT user you will start 

at the e-GGRT login page: 

https://ghgreporting.epa.gov 

If you have a CDX 

account then log in 

with your CDX 

credentials here 

Otherwise, click the 

green NEW USER 

REGISTRATION button 

36

User Registration: On-Screen 

Directions 

On-screen directions will guide you 

through the user registration process. 

� Most e-GGRT pages allow you to 

freely navigate and come back later to 

complete them. New user 

registration, however, requires you to 

complete the four steps in one 

session. 

37

User Registration: Your User 

Profile 

Please note the following when 

filling out your profile: 

Profile information will be used on the 

Certificate of Representation 

(if you are a DR or ADR) 

or Notice of Delegation 

(if you are an Agent) 

38

User Registration: On-Screen 

Directions 

Throughout the 

registration process onscreen 

directions and 

validation messages will 

provide help 

The Secret Question and Answer 

are used if you need to reset 

your password. Store this 

information securely. 

39

User Registration: Challenge 

Questions 

E-GGRT will use 

Challenge Questions 

and Answers later to 

support Electronic 

Signatures so keep 

them stored 

securely. 

40

User Registration: Electronic 

Signature Agreement 

On this final page you can 

print out your Electronic 

Signature Agreement. 

You can also save a copy 

as a PDF file. 

41


Signature Agreement 

You MUST sign and 

date your ESA 

John Metropolis 

123 Industrial Way 

Beverley Hills, CA 

90210 

e-GGRT Help Desk 

8301 Greensboro 

Drive 

Mail Stop E-11-2 

McLean, VA 

22102 

Please allow time to mail 

your Electronic Signature 

Agreement to EPA 

42


Signature Agreement Approved! 

Notifications from e-GGRT will be sent to the 

email address in your user profile. 

Make sure your email accepts mail from 

eggrt@ccdsupport.com 

For questions about the GHG Reporting 

Program or e-GGRT, contact EPA at 

GHGReporting@epa.gov 

43

Registering A Facility 

Click “Register A 

Facility” from your e- 

GGRT Home Page 

If you are a CBS user 

and have linked your 

CBS and e-GGRT 

accounts, your CBS 

facilities will be 

listed here. 

Log-In to e-GGRT at: https://ghgreporting.epa.gov 

44

Facility Registration 

Facilities that have already 

been registered will be 

labeled “Claimed” 

A “subway map” will 

show you where you 

are in the Facility setup 

process 

e-GGRT will help you SEARCH 

through EPA’s Facility Registry 

System for your facility. 

45


List the owners and 

operators of the 

facility or supplier 

here. Click “ADD” 

to list more. 

46


Grey boxes in e-GGRT 

provide explanatory text. You 

may also click HELP at any 

time for more info. 

You can appoint yourself as DR or 

someone else. EPA will review all 

appointments 

The email will be used by e- 

GGRT to invite the DR 

appointee to accept their role. 

Enter the ADR’s info here, 

if applicable. An ADR can 

also be added at a later 

time but must be 

approved by the DR 

47

Appointments and 

Invitations: DR & ADR 

1 

APPOINT 

DR 

or ADR 

2 

EPA 

APPROVES & 

E-GGRT sends email 

3 

4 

APPOINTEE 

Receives email 

Uses CODE 

To ACCEPT Role 

APPOINTEE 

Signs 


(COR) 

48

Appointments and 

Invitations: Agent(s) 

1 2 

SET UP 

AGENT(S) 

EPA 

APPROVES & 

E-GGRT sends email 

3 

4 

5 

APPOINTEE 

RECEIVES email 

USES code 

To ACCEPT Role 

DELEGATOR 

RECEIVES email 

REVIEWS Agent 

Delegation 

DELEGATOR 

Signs 

Notice of Delegation 

49

Using an Invitation Code 

Home Page lists facilities 

and role 

After an APPOINTEE receives 

an email invitation for a 

ROLE, he or she can log into 

e-GGRT and paste the 

invitation code into this box. 

50

Accepting the Appointment 

ANYREPORTER 

123 Main Street 

ANYTOWN, USA, ANYZIP 

Uncle JOE 

202-123-4567 

Joe.Uncle@mail.com 

51


Carefully review the 

Certification Statements. 

These Certification 

Statements can also be 

found in Section 98.4 of 

the Rule 

52

e-GGRT Support 

• E-GGRT Help Desk will be able to answer 

questions and provide support to e-GGRT users 

• Telephone: 1-877-444-1188 

• Email: GHGREPORTING@epa.gov [e-GGRT] 

• URLs: www.ccdsupport.com [Help] 

https://ghgreporting.epa.gov [e-GGRT] 

53

e-GGRT Help Site 

www.ccdsupport.com 

54

For more information 

On the GHG Reporting Program: 

http://www.epa.gov/ghgreporting/reporters/index.html 

On the GHG Data System: 

http://www.ccdsupport.com 

Contact Us: 

http://www.epa.gov/ghgreporting/contactus.html 

On ‘Contact Us’ page select e- 

GGRT for data system questions 

55

Questions? 

56

e-Ggrt Webinar Subpart W NOI and BAMM

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