Technical Support Document for the Silicon
Carbide Production Sector: Proposed Rule for
   Mandatory Reporting of Greenhouse Gases
                                Office of Air and Radiation
                          U.S. Environmental Protection Agency
                                     January 22, 2009

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   Technical Support Document for Silicon Carbide: Proposed Rule for Mandatory Reporting of Greenhouse Gases
                                      CONTENTS
1.      Industry Description	2

2.      Total Emissions	2
       2.1    Process Emissions	2
       2.2    Stationary Combustion	2
3.      Review of Existing Programs and Methodologies	3
4.      Options for Reporting Threshold	3
       4.1    Emissions Thresholds	3
       4.2    Capacity Thresholds	5
       4.3    No Emissions Threshold	5
5.      Options for Monitoring Methods	6
       5.1    Option 1:  Simplified Emission Calculation	6
       5.2    Option 2:  Input-Based Method	7
       5.3    Option 3:  Direct Measurement	8
6.      Procedures  for Estimating Missing Data	9
       6.1    Procedures for Option 1: Simplified Emissions Calculation	9
       6.2    Procedures for Option 2: Input-Based Method	9
       6.3    Procedures for Option 3: Direct Measurement (Annual Reporting)	9

             6.3.1  Continuous Emission Monitoring Data (CEMS)	9
             6.3.2  Stack Testing Data	10
7.      QA/QC Requirements	11
       7.1    Stationary Emissions	11
       7.2    Process Emissions	11
             7.2.1  Continuous Emission Monitoring System (CEMS)	11
             7.2.2  Stack Test Data	11
       7.3    Data Management	12
8.      Types of Emission Information to be Reported	13
       8.1    Other Information to be Reported	13
       8.2    Additional Data to be Retained Onsite	13
9.      References	14

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   Technical Support Document for Silicon Carbide: Proposed Rule for Mandatory Reporting of Greenhouse Gases


1.     Industry Description

Silicon carbide is primarily an industrial abrasive manufactured from silica sand or quartz and
petroleum coke (USGS 2006).  Applications of silicon carbide include semiconductors, body
armor, and the manufacture of Moissanite, a diamond substitute.  The silicon carbide sector
discussed in this Technical Support Document is limited to the  production of "abrasive-grade"
silicon carbide. Approximately 35,000 metric tons of "abrasive-grade" silicon carbide valued at
24.3 million dollars was produced by a single facility in Illinois in 2006.  Similarly, 35,000
metric tons of "metallurgical-grade" silicon carbide was produced in 2006 at the same facility
(USGS 2006). A small manufacturer in Kentucky is known to  produce non-abrasive grade
silicon carbide for "heat-resistant products" though the quantity produced is unknown (USGS
2006).

                         Table 1. U.S. Producers of Silicon Carbide
Company
Exolon Corp.
2006 Silicon Carbide Production
(metric tons)
35,000
2006 Silicon Carbide Production
(million $)
24.3
Source: USGS Minerals Yearbook 2006 (http://minerals.usgs.gov/minerals/pubs/commoditv/abrasives/mvb1-2006-
abras.pdf)

Silicon carbide is produced through the following reaction:

                             SiO2 + 3C -» SiC + 2CO (+ O2 -^2CO2)

2.     Total Emissions
Silicon carbide process emissions (U.S EPA 2008) totaled 100,226 mtCO2e in 2006.  Of the
total, process-related CO2 emissions accounted for 91% (91,700 mtCO2e) and CJLt emissions
accounted for 9% (8,526 mtCO2e).  On-site stationary combustion emissions from silicon carbide
production amounted to 9,045 mtCO2e (less than one percent of the total emissions).

2.1    Process Emissions
As shown above, carbon dioxide (CO2) and methane (CH4) are emitted during the production of
silicon carbide. Petroleum coke is utilized as the carbon source during silicon carbide
production.  Approximately 35% of the carbon is retained within the silicon carbide, and the
remaining carbon is converted to CO2 and CH4. The presence of hydrogen-containing volatile
compounds in the petroleum coke may cause formation and emission to the atmosphere of CH4
(IPCC2006).  .

2.2    Stationary Combustion
Combustion emissions of GHGs from the production of silicon carbide are limited to the fuel
inputs used for equipment necessary to the manufacturing process.  The existing silicon carbide
plant uses natural gas as the fuel for the product dryer and uses electric furnaces.

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   Technical Support Document for Silicon Carbide: Proposed Rule for Mandatory Reporting of Greenhouse Gases
3.     Review of Existing Programs and Methodologies
Emissions monitoring from the silicon carbide sector are addressed in both the U.S. Inventory
(U.S. EPA 2008) and 2006IPCC Guidelines for National Greenhouse Gas Inventories (IPCC
2006).  The U.S. Inventory relies upon standard emission factors from the IPCC to report CC>2
emissions for the silicon carbide sector whereas the IPCC itself offers three tiers including a
reporting method that utilizes facility-specific petroleum coke consumption data (Tier 3). No
additional protocols were identified from emission trading schemes, voluntary programs or
industry trade groups.

4.     Options for Reporting Threshold
4.1    Emissions Thresholds
Four emissions threshold levels were considered for the silicon carbide manufacturing sector
based on actual emissions. These thresholds, 100,000, 25,000, 10,000, and 1,000  mtCO2e per
year, were analyzed. All threshold levels were found to incorporate all silicon carbide
manufacturing facilities included in this Technical Support Document. Table 2  provides the
threshold analysis for the silicon carbide sector. The threshold analysis estimated total emissions
for the silicon carbide sector at 109,271 tons CC>2.  This total was the additive sum of process
emissions (100,226 mtCC^e) and combustion emissions (9,045 mtCC^e). The single facility with
known production that has been identified would surpass the 100,000 tons CC>2  reporting
threshold.
             Table 2.  Emissions Threshold Analysis for Silicon Carbide Production
Threshold
Level
(Metric
Tons)
100,000
25,000
10,000
1,000
Process
Emissions
(Metric
Tons
CO2e/yr)
100,226
100,226
100,226
100,226
CO2
Emissions
(Metric
Tons/yr)
9,045
9,045
9,045
9,045
Total
National
Emissions
(Metric
Tons
CO2e)
109,271
109,271
109,271
109,271
Number
of
Entities
1
1
1
1
Emissions Covered
Tons
CO2e/yr
109,271
109,271
109,271
109,271
Percent
100%
100%
100%
100%
Entities Covered
Number
1
1
1
1
Percent
100%
100%
100%
100%

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   Technical Support Document for Silicon Carbide: Proposed Rule for Mandatory Reporting of Greenhouse Gases


Process emissions were calculated using default emission factors for both CC>2 and CH4 per
metric ton of silicon carbide produced. The amount of silicon carbide produced is limited, in this
analysis, to "abrasive-grade" silicon carbide.  The factors, 2.62 metric tons of CC>2 per metric ton
of raw material used and 11.6 kg of CH/t per metric ton of carbide produced, were published by
the IPCC and are equivalent to a Tier 1 estimation method (IPCC 2006). Calculations of process
emissions followed the equation:

       EC02 = [(EFC02 * AD) + (EFCH4 * AD*21)]


Where:
       Eco2      = Emissions of CC>2 and CH/t, (mtCC^e)
       EFCo2     = Emissions factor for CC>2
       EFCH4     = Emissions factor for CH4
       AD       = Silicon carbide production, (metric tons)
       21        = Global warming potential for CH/t, (mt CCVmt CH/t)
Combustion emissions were estimated through data collected from a Title V permit that listed the
number, type, and fuel consumption rate of stationary emission sources at the known silicon
carbide production facility.  Assuming that each emission unit within the facility operated
continuously (24-hours a day, 365 days  a year) at 90% capacity, emissions were estimated for a
solution heater that ran on natural gas and consumed  2.5 MMBtu/hr, and a rotary dryer that ran
on natural gas and consumed 19.1 MMBtu/hr (Illinois EPA 2004).

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   Technical Support Document for Silicon Carbide: Proposed Rule for Mandatory Reporting of Greenhouse Gases


4.2    Capacity Thresholds
Four capacity threshold levels were considered for the silicon carbide manufacturing sector
based on facility capacity. These thresholds, 35,000, 25,000,  10,000, and 1,000 metric tons
silicon carbide produced per year, were analyzed.

Table 3 provides the capacity threshold analysis for the silicon carbide sector. Four reporting
threshold levels were considered for the silicon carbide production sector.  These thresholds were
35,000, 25,000, 10,000, and 1,000 metric tons of silicon carbide produced per year.  The single
facility with known production that has been identified would surpass the 35,000 metric tons
reporting threshold.
              Table 3. Capacity threshold Analysis for Silicon Carbide Production
Capacity Threshold
(metric tons silicon
carbide produced
per year)
35,000
25,000
10,000
1,000
Process
Emissions
(Metric Tons
CO2e/yr)
111,362
111,362
111,362
111,362
Number
of
Entities
1
1
1
1
Emissions Covered
Metric Tons
CO2e/yr
111,362
111,362
111,362
111,362
Percent
100%
100%
100%
100%
Entities Covered
Number
1
1
1
1
Percent
100%
100%
100%
100%
4.3    No Emissions Threshold
The no emissions threshold includes all silicon carbide manufacturing facilities included in this
Technical Support Document regardless of their emissions or capacity.

The option of regulating all silicon carbide manufacturing facilities regardless of their emissions
profile is similar to the emissions threshold option when only the known facility is considered
because at each threshold level the known facility would be regulated. When the possibility of
new facilities is considered, the no emissions threshold option becomes more inclusive since it is
likely that an emissions threshold option would not include smaller facilities at certain emission
thresholds.

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   Technical Support Document for Silicon Carbide: Proposed Rule for Mandatory Reporting of Greenhouse Gases


5.     Options for Monitoring Methods
Three separate monitoring methods were considered for this technical support document: a
simplified emission calculation (Option 1), a hybrid method (Option 2), and direct measurement
(Option 3). All of these options require annual reporting.

5.1    Option  1: Simplified Emission Calculation

Option 1 follows the IPCC's Tier 1 protocol. The Tier 1 monitoring method requires raw
material input or output to be known in addition to a standard emission factor. Table 4 gives the
standard emission factors for Tier 1. According to the 2006 IPCC Guidelines, the default CO2
emission factors are relatively uncertain because industrial-scale carbide production processes
differ from the stoichiometry of theoretical chemical reactions (IPCC 2006).  The guidelines
recommend assuming general uncertainty of ±10% for the CO2 and CFLt emission factors.

The equation for calculating emissions is:

       CO2 Emissions = AD * EF

Where:
       CO2 Emissions = process emissions of CO2
       AD = Petroleum coke input or  silicon carbide output
       EF = Standard emission factor.

                            Table 4. Standard emission factors
Carbide Type
Silicon Carbide
CO2 Emission Factor
(ton/ton product)
2.62
CH4 Emission Factor (ton/ton
product)
0.0116
 Source: 2006 IPCC Guidelines for National Greenhouse Gas Inventories

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   Technical Support Document for Silicon Carbide: Proposed Rule for Mandatory Reporting of Greenhouse Gases

5.2    Option 2: Input-Based Method

Option 2 follows the IPCC's Tier 3 protocol.  The Tier 3 monitoring method requires raw
material input data to be known and for plant-specific carbon content factors to be determined.
The equation for calculating emissions is:
       CO2 Emissions = AD * EFco2
Where:
       CO2 Emissions = Emissions of CO2
       AD = Petroleum coke activity data
       EFCo2 = Emissions factor

The emissions factor is calculated using the formula:
       EFC02 = 0.65 * CCF * COF * (44/12)
Where:
       EFCo2     = Emissions factor
       0.65      = Adjustment factor for amount of carbon in silicon carbide product
                    (assuming 35 percent of carbon input is in the carbide product)
       CCF      = Carbon content factor (assumed 90-95 percent if plant data is not available)
       COF      = Carbon oxidation factor (assumed to be 1 if plant data is not available)
       44/12     = Ratio of molecular weights, CO2 to carbon.

Use the above equations with the default CH4 emissions factor to estimate CFLi emissions.

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   Technical Support Document for Silicon Carbide: Proposed Rule for Mandatory Reporting of Greenhouse Gases
5.3    Option 3: Direct Measurement

For industrial source categories for which the process emissions and/or combustion GHG
emissions are contained within a stack or vent, direct measurement constitutes either
measurements of the GHG concentration in the stack gas and the flow rate of the stack gas using
a CEMS, or periodic measurement of the GHG concentration in the stack gas and the flow rate of
the stack gas using periodic stack testing.  In the case of silicon carbide, process and combustion
GHG emissions are not emitted from the same stack. Process emissions from the product
furnaces are emitted from four separate  stacks and combustion emissions from the  product dryer
are emitted from a fifth stack.

Elements of a CEMS include a platform and sample probe within the stack to withdraw a sample
of the stack gas, an analyzer to measure the concentration of the GHG (e.g., CO?) in the stack
gas, and a flow meter within the stack to measure the flow rate of the stack gas. The emissions
are calculated from the concentration of GHGs in the stack gas and the flow rate of the stack gas.
A CEMS continuously withdraws  and analyzes a sample of the stack gas and continuously
measures the GHG concentration and flow rate of the stack gas.

For direct measurement using stack testing, sampling equipment would be periodically brought
to the site and installed temporarily in the stack to withdraw a sample of the stack gas  and
measure the flow rate of the stack  gas. Similar to CEMS, for stack testing the emissions are
calculated from the concentration of GHGs in the stack gas and the flow rate of the stack gas.
The difference between stack testing and continuous monitoring is that the CEMS data provide a
continuous measurement of the emissions, while a stack test provides a periodic measurement of
the emissions.  A method using periodic, short-term stack testing would be appropriate for those
facilities where process inputs (e.g., carbonaceous reducing agents such as petroleum coke) and
process operating parameters remain relatively consistent over time.  In cases where there is the
potential for significant variations  in the process input characteristics or operating conditions,
continuous measurements would be needed to accurately record changes in the  actual  GHG
emissions from the sources  resulting from any process variations.

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   Technical Support Document for Silicon Carbide: Proposed Rule for Mandatory Reporting of Greenhouse Gases


6.     Procedures for Estimating Missing Data
Options and considerations for missing data vary will vary depending on the proposed
monitoring method. Each option would require a complete record of all measured parameters as
well as parameters determined from company records that are used in the GHG emissions
calculations (e.g., carbon contents, monthly fuel consumption,  etc.).

6.1    Procedures for Option 1: Simplified Emissions Calculation
For process sources that use a simplified emission calculation no missing data procedures would
apply because the emission calculation is derived from default emission factors and activity data.
Businesses closely track activity data such as purchase and use of production inputs, therefore
therefore, 100 percent data availability would be expected.

6.2    Procedures for Option 2: Input-Based Method
For process sources that use a site-specific emission factor no missing data procedures would
apply because the site-specific emission factor is derived from an initial carbon content analysis
from the petroleum coke supplier (carbon content analysis test) and used in each calculation.
The  same factor would be multiplied by the production rate or process input rate, which are
readily available.  Therefore, 100 percent data availability would be required.

6.3    Procedures for Option 3: Direct Measurement (Annual Reporting)
6.3.1  Continuous Emission Monitoring Data (CEMS)
For options involving direct measurement of CC>2 emissions using CEMS, Part 75 establishes
procedures for the management of missing data. Specifically, the procedures for managing
missing CC>2 concentration data are specified in §75.35. In general, missing data from the
operation of the CEMS may be replaced with substitute data to determine the CC>2 emissions
during the period for which CEMS data are missing.  Section 75.35(a) requires the owner or
operator of a unit with a CC>2 CEMS to substitute for missing CC>2 pollutant concentration data
using the procedures specified in paragraphs (b) and (d) of §75.35;  paragraph (b) covers
operation of the system during the first 720 quality-assured operation hours for the CEMS, and
paragraph (d) covers operation of the system after the first 720 quality-assured operating hours
are completed.

During the first 720 quality-assured monitor operating hours following  initial certification at a
particular unit or stack location, the owner or operator would be required to  substitute CC>2
pollutant concentration data according to the procedures in §75.3 l(b). That is, if prior quality-
assured data exist, the owner or operator would be required to substitute for each hour of missing
data, the average of the data recorded by a certified monitor for the operating hour immediately
preceding and immediately following the hour for which data are missing. If there are no prior
quality-assured data, the owner or operator would have to substitute the maximum potential CC>2
concentration for the missing data.

Following the first 720 quality-assured monitor operating hours, the owner or operator would
have to follow the same  missing data procedures for SC>2 specified  in §75.33(b).  The specific
methods used to estimate missing data would depend on the monitor data availability and the
duration of the missing data period.

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   Technical Support Document for Silicon Carbide: Proposed Rule for Mandatory Reporting of Greenhouse Gases


6.3.2  Stack Testing Data
For options involving direct measurement of CC>2 flow rates or direct measurement of CC>2
emissions using stack testing, "missing data" is not generally anticipated.  Stack testing
conducted for the purposes of compliance determination is subject to quality assurance
guidelines and data quality objectives established by the U.S. EPA, including the Clean Air Act
National Stack  Testing Guidance published in 2005 (EPA 2005).  The 2005 EPA Guidance
Document indicates that stack tests should be conducted in accordance with a pre-approved site-
specific test plan to ensure that a complete and representative test is conducted. Results of stack
tests that do not meet pre-established quality assurance guidelines and data quality objectives
would generally not be acceptable for use in emissions reporting, and any such stack test would
need to be re-conducted to obtain acceptable data.

The U.S. EPA regulations for performance testing under 40 CFR § 63.7(c)(2)(i) state that before
conducting a required performance test, the owner/operator is required to develop a site-specific
test plan and, if required,  submit the test plan for approval. The test plan is required to include "a
test program summary, the test schedule, data quality objectives, and both an internal and
external quality assurance (QA) program" to be  applied to the stack test. Data  quality objectives
are defined under 40 CFR § 63.7(c)(2)(i) as "the pre-test expectations of precision, accuracy, and
completeness of data." Under 40 CFR § 63.7(c)(2)(ii), the internal QA program is required to
include, "at a minimum, the activities planned by routine operators and analysts to provide an
assessment of test data precision; an example of internal QA is the sampling and analysis of
replicate samples." Under 40 CFR § 63.7(c)(2)(iii) the external QA program is required to
include, "at a minimum, application of plans for a test method performance audit (PA) during the
performance test." In addition, according to the  2005 Guidance Document, a site-specific test
plan should generally include chain of custody documentation from sample collection through
laboratory analysis including transport, and should recognize special sample transport, handling,
and analysis instructions necessary for each set of field samples (EPA 2005).

The U.S. EPA anticipates that test plans for stack tests that are expected to be used to obtain data
for the purposes of emissions reporting would be made available to EPA prior  to the stack test
and that the results of the stack test would be reviewed against the test plan prior to the data
being deemed acceptable  for the purposes of emissions reporting.
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7.     QA/QC Requirements
Facilities should conduct quality assurance and quality control of the production and
consumption data, supplier information (e.g., carbon contents), and emission estimates reported.
Facilities are encouraged to prepare an in-depth quality assurance and quality control plan which
would include checks on production data, the carbon content information received from the
supplier and from the lab analysis, and calculations performed to estimate GHG emissions.
Several examples of QA/QC procedures are listed below.

7.1    Stationary Emissions
Facilities should follow the guidelines given by the Stationary Combustion Source Section of
this TSD.

7.2    Process Emissions
Options and considerations for QA/QC will vary depending on the proposed monitoring method.
Each option would require unique QA/QC measures appropriate to the particular methodology
employed to ensure  proper emission monitoring and reporting.

7.2.1   Continuous Emission Monitoring System (CEMS)
For units using CEMS to measure CC>2 emissions, the equipment should be tested for accuracy
and calibrated as necessary by a certified third party vendor.  These procedures should be
consistent in stringency and data reporting and documentation adequacy with the QA/QC
procedures for CEMS described in Part 75 of the Acid Rain Program.

7.2.2   Stack Test Data
U.S. EPA regulations for performance testing under 40 CFR § 63.7(c)(2)(i)  state that before
conducting a required performance test, the owner/operator is required to develop a site-specific
test plan and, if required, submit the test plan for approval. The test plan is required to include "a
test program summary, the test schedule, data quality objectives, and both an internal and
external quality assurance  (QA) program" to be applied to the stack test.  Data quality objectives
are defined under 40 CFR  § 63.7(c)(2)(i) as "the pre-test expectations of precision, accuracy, and
completeness of data."  Under 40 CFR § 63.7(c)(2)(ii), the internal QA program is required to
include, "at a minimum, the activities planned by routine operators and analysts to provide an
assessment of test data precision; an example of internal QA is the sampling and analysis of
replicate samples." Under 40 CFR § 63.7(c)(2)(iii) the external QA program is required to
include, "at a minimum, application of plans for a test method performance  audit (PA) during the
performance test." In addition, according to the 2005 Guidance Document, a site-specific test
plan should generally include chain of custody documentation from sample  collection through
laboratory analysis including transport, and should recognize  special sample transport, handling,
and analysis instructions necessary for each set of field samples (US EPA 2005).
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   Technical Support Document for Silicon Carbide: Proposed Rule for Mandatory Reporting of Greenhouse Gases


7.3    Data Management
Data management procedures should be included in the QA/QC Plan.  Elements of the data
management procedures plan are as follows:

    •  For measurements of carbonate content, assess representativeness of the carbonate
       content measurement by comparing values received from supplier and/or laboratory
       analysis with IPCC default values.
    •  Check for temporal consistency in production data, carbonate content data, and emission
       estimate. If outliers exist, they should be explained by changes in the facility's
       operations or other factors. A monitoring error is probable if differences between annual
       data cannot be explained by:
         o  Changes in activity levels,
         o  Changes concerning fuels or input material,
         o  Changes concerning the emitting process (e.g. energy efficiency improvements)
            (European Commission 2007).

    •  Determine the "reasonableness" of the emission estimate by comparing it to previous
       year's estimates and relative to national emission estimate for the industry:
         o  Comparison of data on fuel or input material consumed by specific sources with
            fuel or input material purchasing data and data on stock changes,
         o  Comparison of fuel or input material consumption data with fuel or input material
            purchasing data and data on stock changes,
         o  Comparison of emission factors that have been calculated or obtained from the fuel
            or input material supplier, to national or international reference emission factors of
            comparable fuels or input materials
         o  Comparison of emission factors based on fuel analyses to national or international
            reference emission factors of comparable fuels, or input materials,
         o  Comparison of measured and calculated emissions (European Commission 2007).

    •  Maintain data documentation,  including comprehensive documentation of data received
       through personal communication:
         o  Check that changes in data or methodology are documented
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   Technical Support Document for Silicon Carbide: Proposed Rule for Mandatory Reporting of Greenhouse Gases
8.     Types of Emission Information to be Reported
Silicon carbide facilities should report both process (CO2) and combustion related (CC>2, CH4,
and N2O) greenhouse gas emissions.  The data to be reported may vary depending on monitoring
options selected. However, all nitric acid production facilities should report the number of nitric
acid production lines, annual nitric acid production (on a 100% acid basis),  annual nitric acid
production capacity (on a 100% acid basis), electricity usage (kilowatt-hours), emission factor(s)
used, type of nitric acid production process(es) used, abatement technology used (if applicable),
abatement utilization factor (percent of time that abatement system is operating), abatement
technology efficiency, and annual operating hours.  For reporting options for stationary
combustion refer to EPA-HQ-OAR-2008-0508-004.

8.1    Other Information to be Reported
The facility should report its annual CC>2 and CFLi emissions from silicon carbide production
process (in metric tons); annual production of silicon carbide (in metric tons); annual capacity of
silicon carbide production (in metric tons); annual operating hours; annual consumption of
petroleum coke (in metric tons); carbon content of petroleum coke consumed for each calendar
quarter; facility-specific emission factors; and annual electricity usage, KWhr/yr for each silicon
carbide manufacturing facility.

8.2    Additional Data to be Retained Onsite
Facilities should be required to retain data concerning monitoring of GHG emissions onsite for a
period of at least five years from the reporting year. For CEMS these data would include CEMS
monitoring system data including continuous-monitored GHG concentrations and stack gas flow
rates, calibration and quality assurance records. For stack testing these data would include stack
test reports and associated sampling and chemical analytical data for the stack test. Process data
including petroleum coke consumption and feed rates and petroleum coke carbon contents
should also be retained on site for a period of at least five years from the reporting year. EPA
could use such data to conduct trend analyses and potentially to develop process or activity-
specific emission factors for the process.
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9.     References

(EU 2007) Official Journal of the European Union, August 31, 2007. Commission Decision of
18 July 2007, "Establishing guidelines for the monitoring and reporting of greenhouse gas
emissions pursuant to Directive 2003/87/EC of the European Parliament and of the Council.
Available at http://eur-
lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2007:229:0001:0085:EN:PDF.

Illinois EPA (2004). Final "Revised" Title V- Clean Air Act Permit Program (CAAPP) Permit
and Title I Permit. State of Illinois Environmental Protection Agency, Springfield, Illinois.

IPCC (2006) 2006IPCC Guidelines for National Greenhouse Gas Inventories. The National
Greenhouse Gas Inventories Programme, The Intergovernmental Panel on Climate Change, H.S.
Eggleston, L. Buenida, K. Miwa, T Ngara, and K. Tanabe (eds.). Hayama, Kanagawa, Japan.

U.S. EPA (200?,) Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990-2006. U.S.
Environmental Protection Agency, Washington D.C. USEPA #430-R-08-005.

U.S. EPA (2007) Climate Leaders, Inventory Guidance, Design Principles Guidance, Chapter 7
"Managing Inventory Quality".  Available at
http://www.epa.gov/climateleaders/documents/resources/design_princ_ch7.pdf

U.S. EPA (2005) Clean Air Act National Stack Testing Guidance, U.S. Environmental Protection
Agency Office of Enforcement and Compliance Assurance, September 30, 2005.
www.epa.gov/compliance/resources/policies/monitoring/caa/stacktesting.pdf

U.S. EPA (2003) Part 75, Appendix Bl, Available at
http ://www. epa. gov/airmarkt/spm/rule/001OOOOOOB. htm.

USGS (2006) Minerals Yearbook: Manufactured Abrasives Annual Report. U.S. Geological
Survey, Reston, VA.  Available online at:
http://minerals.usgs.gov/minerals/pubs/commoditv/abrasives/mybl-2006-abras.pdf
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