Do You Need to Check Your TSCA Report?

By John Beath

Sep 03

JBE has developed a process for checking the information a facility/company puts together for its report which may prove useful to detect and head off reporting problems before the September 30, 2016 EPA reporting deadline.

Our method for evaluating your TSCA CDR report (as described further below) investigates estimated intermediate stream production volumes using our checker process, as well as checking produced final products estimated (e.g., the sum of all product gasoline blend stocks) as compared to your EPA GHG Subpart MM production reporting results (or other sales data for facilities other than refineries).

Several key areas that could result in under-reporting or incomplete reporting are:

  • The process by which constituents present in imported chemicals were investigated and aggregated;
  • The identification and proper quantification of reportable process intermediate streams;
  • The selection of intermediate streams for Part III reporting (versus being excluded from this); and
  • Spreadsheet mechanical errors that incorrectly assemble the numbers or even streams (especially if pivot tables are used).

By performing a unit-by-unit volume input/output comparison, the facility may be able to determine where intermediate streams that contribute substantially may have been left out, as well as where meter data results in obvious inconsistencies (e.g., a unit producing twice as many barrels as the sum of its documented feeds).  Organizing your data with a focus on input into CDX just does not give you this important unit-by-unit perspective.

Here is a visual representation of the checker process we use:

TSCA

Please contact us if you would like further information or if we can help you perform a review of your data.

About the Author

Read John's full bio here: http://www.beath.us/john-beath/

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