Q164. A third party measures the quantity of a petroleum product I receive with equipment that is not located on my 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.

You are responsible for retaining records to support quantities reported to EPA under this subpart, including but not limited to the standard method or industry standard practice used to determine quantity, the date of initial calibration of measurement equipment, the frequency of measurement equipment recalibration, other records normally maintained in the course of business to document product and feedstock flows, and anything else listed in 98.3(g) that applies. As specified in 98.3(g), records must be kept in an electronic or hard-copy format (as appropriate) and may be retained off site if they are readily available for expeditious inspection and review.

The designated representative or any alternate designated representative of the facility or supplier must sign and submit the annual GHG report and certify that the information is true, accurate, and complete. It is the facility's responsibility to ensure that all quantity measurements and standards or methods are accurately reported.