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Q164.

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A

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third

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party

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measures

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the

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quantity

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of

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a

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petroleum

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product

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I

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receive

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with

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equipment

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that

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is

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not

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located

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on

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my

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site.  Who is responsible for retaining the associated records? Who is responsible for the accuracy of that measurement?

 

A164. If a second party or a third party (such as an independent inspector) determines the quantity of a petroleum product you produce or receive, you may use that data to report quantity in your annual GHG report. If you do, you must ascertain that the appropriate consensus-based standard or industry standard practice was followed to determine quantity as specified in 98.394(a) and 98.396. If equipment is used to determine quantity, you must ensure that the calibration requirements as specified in 98.394(b) are met even if the equipment is offsite and/or operated by a third party. This applies to refineries, importers, and exporters.

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Source: This question and answer was derived from a Legacy FAQ. Revised by David Jacobson, 1/22/2014 (Subpart MM FAQs_01-15-2014_DJ.docx).
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Approval / Publishing History: Version 1
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Expiration: None
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Relevant Subparts:  Subpart MM
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