Soda Ash Manufacturing
United States
Final Rule: Mandatory Reporting of Greenhouse Gases Aaencjmerrtal Pl°t9ction
Under the Mandatory Reporting of Greenhouse Gases (GHGs) rule, owners or operators of facilities that
contain soda ash manufacturing (as defined below) must report emissions from soda ash manufacturing
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?
A soda ash manufacturing facility is any facility that produces soda ash by calcining trona, calcining
sodium sesquicarbonate, or by using a liquid alkaline feedstock process that directly produces carbon
dioxide (CO2).
In the context of the soda ash manufacturing sector, "calcining" means the thermal/chemical conversion
of the bicarbonate fraction of the feedstock to sodium carbonate.
What GHGs Must Be Reported?
Soda ash manufacturing facilities must report the following emissions:
• CO2 process emissions from each soda ash manufacturing line.
• CO2 combustion emissions from each soda ash manufacturing line.
• Methane (CH4) and nitrous oxide (N2O) combustion emissions from each soda ash manufacturing
line. Calculate and report these emissions under 40 CFRpart 98, subpart C (General Stationary
Fuel Combustion Sources) by following the requirements of subpart C.
• CO2 CFI4, and N2O emissions from each stationary combustion unit other than soda ash
manufacturing lines. Calculate and report these emissions under 40 CFR 98, subpart C (General
Stationary Fuel Combustion Sources) by following the requirements of subpart C.
In addition, each facility must report GHG emissions for any other source categories for which calculation
methods are provided in other subparts of the rule.
How Must GHG Emissions Be Calculated?
For CO2 emissions from soda ash manufacturing lines, facilities must use one of the following methods,
as appropriate:
• Soda ash manufacturing lines with certain types of continuous emission monitoring systems
(CEMS) in place must report using the CEMS and follow the Tier 4 methodology of 40 CFR part
98, subpart C to report combined CO2 emissions from calcination and fuel combustion.
• For other soda ash manufacturing lines, reporters can elect to use one of the following:
o Install and operate a CEMS to measure combined process and combustion CO2 emissions
according to the requirements specified in 40 CFR part 98, subpart C
o Calculate CO2 process emissions using one of three alternative methods, as applicable:
• Trona input method. Calculate calcination emissions using the following
measurements:
o Monthly mass of trona input.
o The monthly inorganic carbon in the trona based on weekly composite analysis.
• Soda ash output method. Calculate calcination emissions using the following
measurements:
40 CFR 98, subpart CC 1 EPA-430-F-09-036R
September 2009
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o Monthly mass of soda ash produced.
o The monthly inorganic carbon in the soda ash.
• Site-specific emission factor method. Can only be used to calculate emissions from
the liquid alkaline feedstock process through an annual performance test using:
o Direct measurements of hourly CO2 concentration at process vents.
o Hourly stack gas volumetric flow rate from mine water stripper/evaporate.
A checklist for data that must be monitored is available at:
www.epa.gov/climatechange/emissions/downloads/checklists/sodaashmanufacturing.pdf
What Information Must Be Reported?
In addition to the information required by the General Provisions at 40 CFR 98.3(c), the following
information must be reported:
If a CEMS is used to measure CO2 emissions, then under this subpart the relevant information required
for the CEMS by subpart C (General Stationary Fuel Combustion Sources) and the following information
for each manufacturing line must be reported:
• Line identification number.
• Annual consumption of trona or liquid alkaline feedstock (metric tons).
• Annual production of soda ash (tons).
• Annual production capacity of soda ash (tons).
If a CEMS is not used to measure emissions, then the following information must be reported for each
manufacturing line:
• Line identification number.
• Annual process CO2 emissions (metric tons).
• Annual soda ash production (tons).
• Annual soda ash production capacity (tons).
• Monthly consumption of trona or liquid alkaline feedstock (tons).
• Monthly production of soda ash (metric tons).
• Inorganic carbon content factor of trona or soda ash (monthly percent by weight decimal
fraction).
• Method used to calculate CO2 emissions for each manufacturing line (trona input method, soda
ash output method, or site-specific emission factor method).
• Number of manufacturing lines used to produce soda ash.
• If producing soda ash using the liquid alkaline feedstock process and using the site-specific
emission factor method, report the relevant information listed under 40 CFR 98.296(b)(10).
• Number of times that missing data procedures were used for the parameters specified under 40
CFR98.296(b)(ll).
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 CC 2 EPA-430-F-09-036R
September 2009
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