This document was developed for the Proposed Mandatory GHG Reporting Rule.
For the final document, please visit the final Mandatory Reporting of
Greenhouse Gases Rule.
Phosphoric Acid Production
United Slates
Proposed Rule: Mandatory Reporting of Greenhouse Gases Environmental Protection
Under the proposed Mandatory Reporting of Greenhouse Gases (GHGs) rule, owners or
operators of facilities that contain phosphoric acid production (as defined below) would report
emissions from wet-process phosphoric acid production processes and all other source
categories located at the facility for which methods are defined in the rule. Owners or operators
would collect emission data; calculate GHG emissions; and follow the specified procedures for
quality assurance, missing data, recordkeeping, and reporting.
How Is This Source Category Defined?
Under the proposal, the phosphoric acid production source category consists of facilities that use a wet-
process phosphoric acid process to produce phosphoric acid. A wet-process phosphoric acid process line
is any system that manufactures phosphoric acid by reacting phosphate rock and acid.
What GHGs Would Be Reported?
The proposal calls for each phosphoric acid production facility to report carbon dioxide (CO2) emissions
from each wet-process phosphoric acid process line.
In addition, each facility would report GHG emissions for other source categories for which calculation
methods are provided in the rule. For example, facilities would report carbon dioxide (CO2), nitrous oxide
(N2O), and methane (CFL^ emissions from each stationary combustion unit on site by following the
requirements of 40 CFRpart 98, subpart C (General Stationary Fuel Combustion Sources). Please refer to
the relevant information sheet for a summary of the proposal for calculating and reporting emissions from
any other source categories at the facility.
How Would GHG Emissions Be Calculated?
Under the proposal, owners or operators of phosphoric acid production facilities would calculate
emissions of CO2 using one of two methods, as appropriate:
• Facilities with certain types of continuous emissions monitors (CEMS) in place would report
using the CEMS and follow the methodology of 40 CFR part 98, subpart C to report total CO2
emissions from calcination and fuel combustion. At other facilities, the use of CEMS would be
optional.
• Facilities without CEMS would calculate CO2 emissions based on monthly measurements of the
mass of phosphate rock consumed and measurements of the inorganic carbon content of each
batch of phosphate rock.
What Information Would Be Reported?
In addition to the information required by the General Provisions at 40 CFR 98.3(c), the proposal calls for
each annual report to include the following information for each phosphoric acid production line:
March 2009 1 EPA-430-F-09-030
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This document was developed for the Proposed Mandatory GHG Reporting Rule.
For the final document, please visit the final Mandatory Reporting of
Greenhouse Gases Rule.
• Annual phosphoric acid production by origin of the phosphate rock (metric tons).
• Annual phosphoric acid production by concentration of phosphoric acid produced (metric tons).
• Annual phosphoric acid production capacity.
• Annual arithmetic average of the inorganic carbon in phosphate rock from batch records
(percent).
• Annual average phosphate rock consumption from monthly measurement records (metric tons).
For More Information
This series of information sheets is intended to assist reporting facilities/owners in understanding key
provisions of the proposed rule. However, these information sheets are not intended to be a substitution
for the rule. Visit EPA's Web site (www.epa.gov/climatechange/emissions/ghgrulemaking.html) for more
information, including the proposed preamble and rule and additional information sheets on specific
industries, or go to to access the rulemaking docket (EPA-HQ OAR-2008-0508).
For questions that cannot be answered through the Web site or docket, call 1-877-GHG-l 188.
March 2009 2 EPA-430-F-09-030
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