West Paterson, NJ
Strategic program approach, audit for 40 CFR Part 98 readiness
Keywords: GHG emissions reporting, data collection
Marc Karell and CCES performed an audit of the initial steps taken by Cytec to prepare for the federal Mandatory GHG Reporting Rule (40 CFR Part 98). Cytec’s self-evaluation was that only two operating plants were impacted by the rule. CCES reviewed Cytec’s initial baseline GHG emissions inventory prepared for USEPA Climate Leaders, and focusing only on the part of the inventory relevant to Part 98 concurred that the two plants were Part 98 applicable, and that a third plant was right below the threshold and that Cytec should prepare for its eventual entry into the program. CCES also reviewed the two facilities’ program for collecting relevant data to meet Part 98 GHG emission calculation and reporting requirements. CCES made several recommendations to upgrade their internal collection methodology to both improve the quality of the data collected (necessary to meet rule requirements) and to save resources, as well. CCES developed a Monitoring Plan and methodology for Cytec’s largest manufacturing plant to effectively collect data, calculate GHG emissions meeting requirements of two different subparts of the rule, and develop annual reports. Finally, CCES prepared a comprehensive executive-level report summarizing the rule and needed steps and methodology to comply and detailing other potential GHG rules that may impact the company, such as the USEPA’s “Endangerment Finding” and “Tailoring Rule” and the Western Climate Initiative.