Phosphoric Acid Production
United States
Final Rule: Mandatory Reporting of Greenhouse Gases ^aimrriental Prot9ction
Under the Mandatory Reporting of Greenhouse Gases (GHGs) rule, owners or operators of facilities that
produce phosphoric acid using the wet-process (as defined below) must report emissions from
phosphoric acid production processes and all other source categories located at the facility for which
methods are defined in the rule. Owners or operators are required to 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?
The phosphoric acid production source category consists of facilities that produce phosphoric acid using a
wet-process phosphoric acid process line in which phosphate rock is reacted with acid.
What GHGs Must Be Reported?
Phosphoric acid production facilities must report carbon dioxide (CO2) emissions from each wet-process
phosphoric acid process line.
In addition, each facility must report GHG emissions for other source categories for which calculation
methods are provided in the rule. For example, facilities must report carbon dioxide (CO2), nitrous oxide
(N2O), and methane (CFLO 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 rule requirements for calculating and reporting
emissions from any other source categories located at the facility.
How Must GHG Emissions Be Calculated?
Most owners or operators can elect to calculate and report process CO2 emissions by using one of two
methods:
• Installing and operating a continuous emission monitoring system (CEMS) that complies with the
Tier 4 Calculation Methodology specified in 40 CFR 98, subpart C.
• Calculating the process CO2 emissions using the following measurements:
o Monthly mass of phosphate rock consumed by each process line.
o Monthly inorganic carbon content of each grab sample of phosphate rock.
However, if process CO2 emissions from phosphoric acid production are emitted through the same stack
as a combustion unit or process equipment that uses a CEMS and follows Tier 4 methodology to report
CO2 emissions, then the CEMS must be used to measure and report combined CO2 emissions from that
stack. In such cases, the reporter cannot use the CO2 calculation methodology outlined in approach (2) in
the previous bullet.
A checklist for data that must be monitored is available at:
www.epa.gov/climatechange/emissions/downloads/checklists/phosphoricacidproduction.pdf
40 CFR 98, subpart Z 1 EPA-430-F-09-030R
September 2009
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What Information Must Be Reported?
In addition to the information required by the General Provisions at 40 CFR 98.3(c), each annual report
must include the following information for each phosphoric acid production line:
• If a CEMS is used to measure emissions, under this subpart the relevant information required by
40 CFR subpart C for the Tier 4 Calculation Methodology and the following information must be
reported:
o Identification number of each wet-process phosphoric acid process line.
o Annual phosphoric acid production by origin of the phosphate rock (tons).
o Annual phosphoric acid permitted production capacity (tons).
o Annual arithmetic average percent inorganic carbon in phosphate rock from monthly
records.
o The annual CO2 emissions from each wet-process phosphoric acid process line (metric
tons).
• If a CEMS is not used to measure emissions, then the following information must be reported:
o Identification number of each wet-process phosphoric acid process line.
o Annual CO2 emissions from each wet-process phosphoric acid process line (metric tons).
o Annual phosphoric acid production by origin of the phosphate rock (tons).
o Annual phosphoric acid permitted production capacity (tons).
o Annual arithmetic average percent inorganic carbon in phosphate rock from monthly
records.
o Annual phosphate rock consumption from monthly measurement records by origin
(tons).
o Method used to estimate any missing values of inorganic carbon content of phosphate
rock for each wet-process phosphoric acid process line.
o Monthly inorganic carbon content of phosphate rock for each wet-process phosphoric
acid process line (percent by weight, expressed as a decimal fraction).
o Monthly mass of phosphate rock consumed by origin in production for each wet-process
phosphoric acid process line (tons).
o Number of wet-process phosphoric acid process lines.
For More Information
This document is provided solely for informational purposes. It does not provide legal advice, have
legally binding effect, or expressly or implicitly create, expand, or limit any legal rights, obligations,
responsibilities, expectations, or benefits in regard to any person. The series of information sheets is
intended to assist reporting facilities/owners in understanding key provisions of the final rule.
Visit EPA's Web site (www.epa.gov/climatechange/emissions/ghgrulemaking.html) for more
information, including the final preamble and rule, additional information sheets on specific industries,
the schedule for training sessions, and other documents and tools. For questions that cannot be answered
through the Web site, please contact us at: ghgmrr@epa.gov.
40 CFR 98, subpart Z 2 EPA-430-F-09-030R
September 2009
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