Technical Support Document for the Nitric Acid
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 Nitric Acid: Proposed Rule for Mandatory Reporting of Greenhouse Gases
CONTENTS
1. Industry Description 1
2. Total Emissions 3
3. Review of Existing Programs and Methodologies 10
3.1 2006IPCC Guidelines for National Greenhouse Gas Inventories 10
3.2 WRI/WBCSD The Greenhouse Gas Protocol - A corporate reporting and
accounting standard 11
3.3 United States Department of Energy's Technical Guidelines Voluntary Reporting
of Greenhouse Gases (1605(b)) Program 11
3.4 The Climate Registry 12
3.5 Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990-2006 (EPA 2008)
12
3.6 European Union's 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 12
3.7 United Kingdom's Guidelines for the Measurement and Reporting of Emissions
by Direct Participants in the UK Emissions Trading Scheme 12
3.8 Australia's Technical Guidelines for the Estimation of Greenhouse Emissions and
Energy at Facility Level: Energy, Industrial Process and Waste Sectors in
A ustralia 12
3.9 Greenhouse Gas Inventory Report of Japan 12
3.10 Environment Canada's Technical Guidance on Reporting Greenhouse Gas
Emissions 12
4. Options for Reporting Threshold 13
4.1 Emissions Thresholds 13
4.2 Capacity Thresholds 13
4.3 No Emissions Threshold 14
5. Options for Monitoring Methods 14
5.1 Option 1: Simplified Emissions Calculation 14
5.2 Option 2: Hybrid (Facility Specific Emission Factor Using Stack Test) 15
5.3 Option 3: Direct Measurement 16
5.3.1. Stack Test Data 16
5.3.2. New Source Performance Standard Approach 17
5.3.3. Continuous Emissions Monitoring Systems 17
6. Options for Estimating Missing Data 17
6.1 Procedures for Option 1: Simplified Emission Calculation Method 18
6.2 Procedures for Option 2: Facility Specific Emission Factor Using Stack Test 18
6.3 Procedures for Option 3: Direct Measurement 18
6.3.1 Continuous Emission Monitoring Data 18
6.3.2 Stack Test Data 19
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Technical Support Document for Nitric Acid: Proposed Rule for Mandatory Reporting of Greenhouse Gases
1. QA/QC Requirements 19
7.1 Stationary Emissions 19
7.2 Process Emissions 19
7.3 Data Management 20
8. Types of Emission Information to be Reported 20
8.1 Types of Emissions to be Reported 21
8.1.1 Option 1: Simplified Emission Calculation 21
8.1.2 Option2: Facility Specific Emission Factor Using Stack Test 21
8.1.3 Option 3: Direct Measurement 21
8.1.3.1 CEMS 21
8.1.3.2 Stack Testing 22
8.2 Other Information to be Reported 22
8.3 Additional Data to be Retained Onsite 22
9. References 22
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Technical Support Document for Nitric Acid: Proposed Rule for Mandatory Reporting of Greenhouse Gases
1. Industry Description
Nitric acid is an inorganic chemical that is used in the manufacture of nitrogen-based fertilizers,
adipic acid, and explosives. Nitric acid is also used for metal etching and processing of ferrous
metals. Production levels for 2006 have been estimated at 6.6 million metric tons of nitric acid
and indicate an estimated 17.7 million metric tons of nitrous oxide (N2O) emissions [in units of
metric tons of carbon dioxide (mtCO2) equivalent emissions].
The production process begins with the stepwise catalytic oxidation of ammonia (NH3) through
nitric oxide (NO) to nitrogen dioxide (NO2) at high temperatures. Then the nitrogen dioxide is
absorbed in and reacted with water (H2O) to form nitric acid (HNO3). The steps in the process
are shown below.
4NH3 + 5O2 -> 4NO + 6H2O (Reaction 1)
2NO + O2 -> 2NO2 (Reaction 2)
3NO2 + H2O -> 2HNO3 + NO (Reaction 3)
The main greenhouse gas (GHG) emitted during this process is N2O, which has a global
warming potential of 310 metric tons of CO2 equivalent emissions (MMTCO2e) per metric ton of
N2O. Nitric acid production is the main source of N2O emissions in the chemical industry
(IPCC, 2006). Nitrous oxide is formed through side reactions during the oxidation of ammonia,
as shown in Reactions 4, 5, and 6. The amount formed depends on pressure, temperature,
catalyst composition, catalyst age, and burner design (EFMA, 2000). EPA estimates that
approximately 15.6 million MMTCO2e, accounting for about 5 percent of all GHG emissions
from stationary industrial sources (excluding utilities) and less than 1 percent of the total U.S.
GHG inventory (USGHG, 2008). The N2O originates in the absorption tower and is emitted
with the tail gas into the atmosphere.
2NH3 + 2O2 -> N2O + 3H2O (Reaction 4)
2NH3 + 8NO -> 5N2O + 3H2O (Reaction 5)
4NH3 + 4NO + 3O2 -> 4N2O + 6H2O (Reaction 6)
In the United States, nitric acid is produced in two different types of plants due to differences in
the three reactions. Reaction 1 is more efficient at lower pressures and higher temperatures
while Reactions 2 and 3 are more efficient at higher pressures and lower temperatures. In single
pressure plants, the oxidation and absorption take place at essentially the same pressure, and in
dual pressure plants absorption takes place at a higher pressure than oxidation. Figure 1 contains
a simplified block diagram for single pressure plants (BCS, 2008).
There are a few technologies that control N2O and NOx (i.e., nitrogen oxides, NO and NO2)
emissions. These abatement technologies include extended absorption, and catalytic reduction.
Extended absorption reduces NOx emissions by increasing the efficiency of the absorption tower
or incorporating an additional absorption tower.
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Technical Support Document for Nitric Acid: Proposed Rule for Mandatory Reporting of Greenhouse Gases
Figure 1 - Simplified Single Pressure Block Diagram
Air Input
Ammonia Feedstock
Power
Cooling Water
Heat
Boiler Water
Cooling Water
Cooling Water
Process Water
1
Filtration (1)
V
Compression (2)
^
Heating (3)
(optional)
^
Filtration (4)
^
Mixing (7)
^
Catalytic Reaction (8)
> C
^
^
Heat Recovery
(ii)
*
ooler Condenser
(12)
"T
Absorption (13) ^^
I
1
^
Filtration (6)
.^ Steam Turbine
~~^ (10)
iTail
Gas
4k
7
_T. .... 1 1 Tail Gas to
Nitric Acid 1 1
^- *
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Technical Support Document for Nitric Acid: Proposed Rule for Mandatory Reporting of Greenhouse Gases
and adipic acid production facilities and possibly other chemical source categories. The three
types of facilities are related because ammonia is used to produce nitric acid and nitric acid is
used to produce adipic acid. Co-location can influence the GHG emissions from the overall
facility but should not influence the assessment of emissions from the production of nitric acid.
Each co-located facility should be assessed individually for N2O emissions from nitric acid
production and reported as indicated by the other appropriate process-specific source categories.
2. Total Emissions
Production levels for 2006 have been estimated at 6.6 million metric tons of nitric acid and
indicate an estimated 17.7 MMTCO2e from nitric acid production processes. According to the
facility-level (bottom-up) inventory, there are 45 nitric acid production plants operating in 25
states with a total of 65 process units. There are 9 small businesses which own a total of 18
nitric acid facilities. Table 1 contains a list of all nitric acid facilities. As shown in Table 1,17
percent of the processes use SCR, 5 percent of the processes use NSCR, and 58 percent of the
processes use continuous emission monitoring systems (CEMS) to measure NOx emissions.
Table 2 shows the estimated amount of N2O emissions from the nitric acid facilities.
Nitric Acid process emissions were estimated by the Inventory of U.S. Greenhouse Gas
Emissions and Sinks: 1990-2006 at 15.4 MMTCO2e in 2006 or 0.2 percent of total U.S.
greenhouse gas emissions. The main reason for the difference in estimates is that the
methodology of the Greenhouse Gas Inventory assumed 20 percent of the nitric acid facilities
were using nonselective catalytic reduction (NSCR) as an N2O abatement technology. The
facility-level analysis showed that only five percent of the nitric acid facilities are using NSCR.
The estimate above includes only process-related GHG emissions. Combustion emissions (CO2,
CH4, and N2O) from nitric acid production plants result from the combustion of natural gas and
fuel oil. Combustion sources include turbine steam generators and boilers. Although other fuels
may be combusted for energy, MECS data for NAICS code 325311, "Nitrogenous Fertilizers"
which includes nitric acid production, indicates 98 percent of the total fuel energy consumption
(i.e., excluding purchased electricity) is natural gas. For more information on reporting options
for stationary combustion refer to EPA-HQ-OAR-2008-0508-004.
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Technical Support Document for Nitric Acid: Proposed Rule for Mandatory Reporting of Greenhouse Gases
Table 1. U.S. Producers of Nitric Acid (metric tons per year)
Facility Name
Agrium US
Agrium US
Agrium US
Agrium US
Air Products
Angus
Chemical
Apache
Nitrogen
Products
CF Industries
Dyno Nobel
Dyno Nobel
Dyno Nobel
Coffeyville
Resources
DuPont
DuPont
Dyno Nobel
City
Beatrice
Kennewick
North Bend
West
Sacramento
Pasadena
Sterlington
Benson
Donaldsonville
Battle Mountain
Cheyenne
St. Helens
Coffeyville
Orange
Victoria
Donora
State
NE
WA
OH
CA
TX
LA
AZ
LA
NV
WY
OR
KS
TX
TX
PA
Number of
nitric acid
processes
1
1
1
1
2
1
2
3
1
3
1
1
1
1
1
Abatement
Technology
SCR
SCR
extended
absorption and
SCR
NSCR
SCR
Co-location
ammonia
production
ammonia
production
ammonia
production
ammonia
production
adipic acid
production
adipic acid
production
Monitoring
NOxCEMS
NOxCEMS
NOxCEMS
2006
Nameplate
Capacity
(metric tons
HNO3 per
year) [100%
Acid Basis]
145,000
285,000
85,000
70,000
110,000
65,000
140,000
680,000
250,000
100,000
20,000
170,000
170,000
300,000
115,000
Estimated
2006 HNO3
Production
(metric tons
HNO3)
101,248
199,005
59,352
48,878
76,809
45,387
132,489
474,820
174,566
69,826
13,023
118,705
118,705
209,479
80,300
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Technical Support Document for Nitric Acid: Proposed Rule for Mandatory Reporting of Greenhouse Gases
Facility Name
Dyno Nobel
El Dorado
Nitrogen
El Dorado
Nitrogen
El Dorado
Nitrogen
First Chemical
Geneva
Nitrogen
Hercules
JR Simplot
JR Simplot
Koch Nitrogen
Koch Nitrogen
Koch Nitrogen
Koch Nitrogen
LSB Industries
Lyondell
Chemical
Bayer
Corporation
City
Louisiana
Baytown
Cherokee
El Dorado
Pascagoula
Orem
Parlin
Helm
Pocatello
Beatrice
Dodge City
Enid
Fort Dodge
Crystal City
Lake Charles
Baytown
State
MO
TX
AL
AR
MS
UT
NJ
CA
ID
NE
KS
OK
IA
MO
LA
TX
Number of
nitric acid
processes
1
1
1
5
1
2
1
1
1
1
1
1
1
1
1
1
Abatement
Technology
SCR
SCR
SCR
SCR
NSCR
SCR
Co-location
ammonia
production
ammonia
production
ammonia
production
ammonia
production
ammonia
production
Monitoring
NOxCEMS
NOxCEMS
NOxCEMS
NOxCEMS
NOxCEMS
NOxCEMS
NOxCEMS
2006
Nameplate
Capacity
(metric tons
HNO3 per
year) [100%
Acid Basis]
270,000
445,000
270,000
425,000
75,000
80,000
80,000
80,000
20,000
55,000
70,000
40,000
165,000
180,000
170,000
45,000
2006 HNO3
Production
(metric tons
HNO3)
188,531
310,728
188,531
296,762
52,370
74,230
55,861
50,973
13,965
38,405
48,878
27,931
115,214
125,688
118,705
31,422
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Technical Support Document for Nitric Acid: Proposed Rule for Mandatory Reporting of Greenhouse Gases
Facility Name
Bayer
Corporation
Nitrochem
Orica
Orica
PCS Nitrogen
PCS Nitrogen
PCS Nitrogen
Rentech
Energy
Midwest
Corporation
Solutia
Terra
International
Terra
International
Terra
International
Terra
International
TradeMark
Nitrogen
TOTALS
City
New Martinsville
Newell
Joplin
Morris
Augusta
Geismar
Lima
East Dubuque
Pensacola
Port Neal
Verdigris
Woodward
Yazoo City
Tampa
45
State
WV
PA
MO
IL
GA
LA
OH
IL
FL
IA
OK
OK
MS
FL
Number of
nitric acid
processes
1
1
1
1
2
4
1
2
1
2
1
1
4
1
65
Abatement
Technology
SCR
SCR
extended
absorption and
SCR
SCR
SCR
extended
absorption and
SCR
extended
absorption
Co-location
ammonia
production
ammonia
production
ammonia
production
ammonia
production
ammonia
production
ammonia
production
ammonia
production
ammonia
production
17
Monitoring
NOxCEMS
NOxCEMS
NOxCEMS
NOxCEMS
NOxCEMS
NOxCEMS
NOxCEMS
NOxCEMS
NOxCEMS
NOxCEMS
20
2006
Nameplate
Capacity
(metric tons
HNO3 per
year) [100%
Acid Basis]
90,000
75,000
160,000
160,000
475,000
825,000
105,000
110,000
365,000
255,000
630,000
90,000
955,000
35,000
9,505,000
2006 HNO3
Production
(metric tons
HNO3)
62,844
52,370
111,722
111,722
331,675
576,068
73,318
76,809
254,866
178,057
439,906
62,844
614,822
24,439
6,632,249
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Technical Support Document for Nitric Acid: Proposed Rule for Mandatory Reporting of Greenhouse Gases
Table 2. U.S. Estimated CO2e Emissions from Producers of Nitric Acid (metric tons CO2e per year)
Facility Name
Facility 1
Facility 2
Facility 3
Facility 4
Facility 5
Facility 6
Facility 7
Facility 8
Facility 9
Facility 10
Facility 11
Facility 12
Facility 13
Facility 14
Facility 15
Facility 16
Facility 17
Facility 18
Facility 19
Total N2<3 Emissions from
HMOs production
(metric tons CO2e)
282,483
165,593
107,149
496,780
68,185
925,374
555,225
311,705
204,556
331,187
175,334
146,112
350,241
1,095,751
487,039
194,816
8,074
331,187
331,187
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Technical Support Document for Nitric Acid: Proposed Rule for Mandatory Reporting of Greenhouse Gases
Facility Name
Facility 20
Facility 21
Facility 22
Facility 23
Facility 24
Facility 25
Facility 26
Facility 27
Facility 28
Facility 29
Facility 30
Facility 31
Facility 32
Facility 33
Facility 34
Facility 35
Facility 36
Total N2O Emissions
from HNO3 production
(metric tons CO2e)
584,447
224,038
526,002
866,930
526,002
827,967
146,112
153,232
155,853
142,215
38,963
136,371
17,317
321,446
350,668
175,334
311,705
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Technical Support Document for Nitric Acid: Proposed Rule for Mandatory Reporting of Greenhouse Gases
Facility Name
Facility 37
Facility 38
Facility 39
Facility 40
Facility 41
Facility 42
Facility 43
Facility 44
Facility 45
TOTALS
Total N2O Emissions
from HNO3 production
(metric tons CO2e)
1,607,229
214,297
1,227,339
1,334,163
214,297
711,077
87,667
136,371
126,630
17,731,650
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Technical Support Document for Nitric Acid: Proposed Rule for Mandatory Reporting of Greenhouse Gases
3. Review of Existing Programs and Methodologies
In evaluating monitoring options for nitric acid production, multiple GHG emissions reporting
guidance documents were consulted. These include documents developed by the U.S.
Environmental Protection Agency (EPA, 2008), the Intergovernmental Panel on Climate Change
(IPCC, 2006), The Climate Registry (CR, 2007), the European Union (EU, 2007), the United
Kingdom (DEFRA, 2003), Australia (NGER, 2007), Japan (Japan, 2006), the World Resources
Institute/World Business Council for Sustainable Development (WRI/WBCSD, 2001), the U.S.
Department of Energy (U.S.DOE, 2007), and Environment Canada (EC, 2006). The main
monitoring methods from each of these reporting programs are reviewed below.
3.1 2006 IPCC Guidelines for National Greenhouse Gas Inventories
The Tier 1 methodology estimates emissions using the total production of nitric acid and the
appropriate default emission factor from Table 3. The Tier 1 method should be applied assuming
no abatement of N2O emissions and the use of the highest default emission factor based on
technology type. The Tier 2 methodology estimates emissions using facility-specific
information, including the production rate of nitric acid, the appropriate emission factor from
Table 3, the destruction factor for abatement technology, and the utilization factor of the
abatement system (if applicable). The equation is shown below. The Tier 3 methodology
estimates emissions using plant level production data and plant level emission factors that are
obtained from direct measurement of emissions. These may be derived from irregular sampling
of N2O or monitoring of N2O over a period that reflects the usual pattern of operation of the
plant.
EF{ * NAPt * (l - DFj * ASUFj ))
vhere:
EN20 = emissions of N2O, kg
EF; = N2O emission factor for technology type i, kg N2O/metric ton nitric acid
produced
NAP; = nitric acid production from technology type i, metric ton
DFj = destruction factor for abatement technology type j, fraction
ASUFj = abatement system utilization factor for abatement technology type j,
fraction.
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Technical Support Document for Nitric Acid: Proposed Rule for Mandatory Reporting of Greenhouse Gases
Table 3. Default N2O Emission Factors from Nitric Acid Production
Production Process
Plants with NSCR
Plants with process-
integrated ortailgas N2O
destruction
Atmospheric pressure
plants (low pressure)
Medium pressure plants
High pressure plants
Approximate
Pressure (atm)
1
4-8
8-14
N2O Emission Factor
(kg N20/
metric ton nitric acid)
Low
1.9
2.25
4.5
5.6
5.4
Average
2
2.5
5
7
9
High
2.1
2.75
5.5
8.4
12.6
N2O Emission Factor
(metric ton N2O/
metric ton nitric acid)
Low
0.0019
0.00225
0.0045
0.0056
0.0054
Average
0.002
0.0025
0.005
0.007
0.009
High
0.0021
0.00275
0.0055
0.0084
0.0126
3.2 WRI/WBCSD The Greenhouse Gas Protocol - A corporate reporting and accounting
standard
Approach 1 involved precise direct monitoring of N2O emissions, with measurements at both the
exit stream and the uncontrolled stream. Data quality is satisfactory when measurement data are
only available for the exit stream. Approach 2 involves site-specific N2O emission factors. This
approach is based on the IPCC Tier 2 methodology. Approach 3 involves the use of default
emission factors for N2O emissions. This approach is based on the IPCC Tier 1 methodology.
3.3 United States Department of Energy's Technical Guidelines Voluntary Reporting of
Greenhouse Gases (1605(b)) Program
The "A" rated approach involves continuous emission monitoring (CEM) from confined and
uncontrolled streams. If pollutant information is not available for uncontrolled streams,
monitoring of confined streams only is acceptable. If CEM is not possible, emissions can be
estimated using an emission factor based on direct, periodic measurements of plant emissions
during a stack test. Emission factors must account for emission rates and abatement system
efficacy and frequency of use of abatement technologies. The "B" rated approach involves the
use of default IPCC emission factors and production if plant-level emission information is not
available. The "C" rated approach involves the use of estimates based on "other published
default values."
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Technical Support Document for Nitric Acid: Proposed Rule for Mandatory Reporting of Greenhouse Gases
3.4 The Climate Registry
The Tier Al methodology is specified as direct measurement. The Tier A2 methodology is a
mass balance approach based on plant-specific factors for destruction and utilization factors for
an abatement technology and N2O emission factor based on direct measurements. The Tier B
methodology is a mass balance approach based on default N2O emission factors by technology
type. This methodology is consistent with Tier 2 methodology from IPCC.
3.5 Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990-2006 (EPA 2008)
The Tier 1 methodology includes the use of an emission factor for estimating N2O emissions
from total national production of nitric acid. The emission factor was determined as a weighted
average of 2 kilograms (kg) N2O per metric ton HNOs for 28 plants using NSCR systems and 9
kg N2O per metric ton HNOs for plants not equipped with NSCR (IPCC, 2006). In the process
of destroying NOx, NSCR systems destroy 80 to 90 percent of the N2O, which is accounted for
in the emission factor of 2 kg N2O per metric ton HNOs. An estimated 20 percent of HNOs
plants in the United States are equipped with NSCR (Choe et al. 1993). Hence, the emission
factor is equal to (9 x 0.80) + (2 x 0.20) = 7.6 kg N2O per metric ton HNO3 (USGHG, 2008).
Emissions are calculated by multiplying this emission factor by national production of nitric
acid.
3.6 European Union's 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
This report has no specific guidance for nitric acid production and generally follows IPCC
guidelines.
3.7 United Kingdom's Guidelines for the Measurement and Reporting of Emissions by
Direct Participants in the UK Emissions Trading Scheme
The method outlined for nitric acid production is specific to one company and is not
recommended for all nitric acid production facilities. Other companies are required to submit
their own protocols for approval by DEFRA.
3.8 Australia's Technical Guidelines for the Estimation of Greenhouse Emissions and
Energy at Facility Level: Energy, Industrial Process and Waste Sectors in Australia
The default method follows the Tier 2 methodology of the IPCC.
3.9 Greenhouse Gas Inventory Report of Japan
Emissions data in Japan are considered confidential, so nitric acid production volume and
emission factors were set for Japan's total production. The method is based on IPCC Tier 1 and
Tier 2 methodologies.
3.10 Environment Canada's Technical Guidance on Reporting Greenhouse Gas Emissions
The guidance for mandatory reporting in Canada primarily references the IPCC guidelines.
There is no specific guidance on nitric acid production.
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Technical Support Document for Nitric Acid: Proposed Rule for Mandatory Reporting of Greenhouse Gases
4. Options for Reporting Threshold
4.1 Emissions Thresholds
For the reporting of process CC>2 emissions from nitric acid production, EPA considered
emissions-based thresholds of 1,000, 10,000, 25,000, and 100,000 mtCO2e for process-related
emissions only. Data were not available to incorporate combustion-related emissions. The
results of the threshold analysis incorporating these four threshold options are summarized in
Table 4. The IPCC Tier 2 method was used to determine process CC>2 emissions from the
facilities presented in Table 1. The types of abatement equipment used for N2O control were
available from permits and in many cases, facility-level production data were also available.
When facility-level production data were not known, capacity data were used along with a
utilization factor of 70 percent. The utilization factor is based on total 2006 nitric acid
production (USCB 2007) and capacity estimates (ICIS 2005) (Innovation Group 2002).
The IPCC Tier 3 method could not be used because facility-specific emission factors have not
been determined.
Table 4. Threshold Analysis for Nitric Acid
Threshold
Level (mtCO2e)
100,000
25,000
10,000
1,000
Process N2O
Emissions
(mtCO2e/yr)
17,731,650
17,731,650
17,731,650
17,731,650
Process N2O Emissions
Covered
mtCO2e
17,511,444
17,706,259
17,723,576
17,731,650
%
98.8
99.9
99.95
100
Facilities Covered
Number
40
43
44
45
%
88.9
95.6
97.8
100
A threshold of 1,000 mtCC^e captures all facilities in the inventory. A threshold of 10,000
mtCO2e captures 99.95 percent of emissions and 97.8 percent of the facilities. A threshold of
25,000 mtCO2e captures 99.9 percent of emissions and 95.6 percent of the facilities. A
threshold of 100,000 mtCC^e captures 98.8 percent of emissions and 88.9 percent of the
facilities.
4.2 Capacity Thresholds
For the capacity thresholds analysis for nitric acid production, EPA considered six different
capacities of nitric acid production. Capacity is the largest amount of nitric acid that a facility
can produce on an annual basis. The thresholds considered were 500,000, 250,000, 150,000,
100,000, 50,000, and 20,000 metric tons of nitric acid produced per year. The results of the
capacity threshold analysis are shown in Table 5. A threshold of 20,000 metric tons captures all
facilities in the inventory. A threshold of 50,000 metric tons captures 98.8 percent of emissions,
and 91.1 percent of the facilities. A threshold of 100,000 metric tons captures 87.9 percent of
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Technical Support Document for Nitric Acid: Proposed Rule for Mandatory Reporting of Greenhouse Gases
emissions and 62.2 percent of the facilities. A threshold of 150,000 metric tons captures 78.5
percent of emissions and 46.7 percent of the facilities. A threshold of 200,000 metric tons
captures 65.7 percent of emissions and 31.1 percent of the facilities. Athreshold of 500,000
metric tons captures 29.4 percent of emissions and 8.9 percent of the facilities.
Table 5. Capacity Threshold Analysis for Nitric Acid Production
Capacity
Threshold
(metric tons
nitric acid
produced per
year)
500,000
200,000
150,000
100,000
50,000
20,000
Process N2O
Emissions
(mtCO2e/yr)
17,731,650
17,731,650
17,731,650
17,731,650
17,731,650
17,731,650
Process N2O Emissions
Covered
mtCO2e
5,212,385
11,654,838
13,921,270
15,592,792
17,526,379
17,731,650
%
29.4
65.7
78.5
87.9
98.8
100
Facilities Covered
Number
4
14
21
28
41
45
%
8.9
31.1
46.7
62.2
91.1
100
4.3 No Emissions Threshold
The no emissions threshold includes all nitric acid production facilities regardless of their
emissions or capacity.
5. Options for Monitoring Methods
5.1 Option 1: Simplified Emissions Calculation
A simplified emissions calculation option would use the default emission factors established by
the Intergovernmental Panel on Climate Change (IPCC, 2006). Two different approaches could
be used.
Approach 1. Use the default emission factors using total national production of nitric acid using
the Tier 1 approach established by the IPCC. The emissions are calculated using the total
production of nitric acid, assumes no abatement of N2O emissions, and uses the highest default
emission factor based on technology type.
This is consistent with the Tier 1 methodology from the U.S. Greenhouse Gas Inventory, the Tier
1 methodology from IPCC, the first approach from Japan's guidance document, Approach 3
from the World Business Council for Sustainable Development (WBCSD), and the "B" rated
approach from the United States Department of Energy (USDOE).
Approach 2. Use the default emission factors on a site-specific basis using the Tier 2 approach
established by the IPCC. These emission factors are dependent on the type of nitric acid process
used, the type of abatement technology used, and the production activity. The amount of N2O
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Technical Support Document for Nitric Acid: Proposed Rule for Mandatory Reporting of Greenhouse Gases
emissions are determined by multiplying the emission factor by the production level of nitric
acid (on a 100 percent acid basis).
This is consistent with the Tier 2 methodology from IPCC, the Tier B methodology from The
Climate Registry, the default method from Australia's guidance document, the second approach
from Japan's guidance document, Approach 2 from WBCSD, and the "B" rated approach from
USDOE.
The default emission factor values for nitric acid production are uncertain. First, N2O may be
generated in the gauze reactor section of nitric acid production as an unintended by-product
reaction. Second, the exhaust gas may or may not be treated for NOx control, and the NOx
abatement system may or may not reduce (or may even increase) the N2O concentration of the
treated gas. A properly maintained and calibrated monitoring system can determine emissions to
within ±5% at the 95% confidence level (IPCC 2006).
5.2 Option 2: Hybrid (Facility Specific Emission Factor Using Stack Test)
Follow the Tier 3 approach established by IPCC using non-continuous monitoring. Directly
monitor N2O emissions and determine the relationship between nitric acid production and the
amount of N2O emissions; i.e., develop a site-specific emissions factor. The site-specific
emissions factor and production rate (activity level) is used to calculate the emissions. Annual
testing of N2O emissions would also be required to verify the emission factor over time. Testing
should be conducted without using any NOx or N2O abatement technologies. Testing would also
be required whenever significant process changes are made. This approach is consistent with the
Tier 3 methodology from IPCC, the Tier Al methodology from the Climate Registry, and
Approach 1 from WBCSD.
This option uses non-continuous direct monitoring of N2O emissions to determine the
relationship between nitric acid production and the amount of N2O emissions. As the production
rate changes, a new N2O emission rate could be calculated. Annual testing of N2O emissions
would also be required to verify the emission factor over time. Testing would also be required
whenever significant process changes are made.
Emissions would be calculated according to the following equations.
The average site-specific emission factor for the process would be calculated according to the
following equation:
"CN20*l.UxlQ-7*Q
P
Where:
EFN2o = Average site-specific N2O emissions factor (Ib N2O/ton nitric acid
produced, 100 percent acid basis)
CN20 = N2O concentration during performance test (ppm N2O)
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Technical Support Document for Nitric Acid: Proposed Rule for Mandatory Reporting of Greenhouse Gases
1.14xlO"7 = Conversion factor (Ib/dscf-ppm N2O)
Q = Volumetric flow rate of effluent gas (dscf/hr)
P = Production rate during performance test (tons nitric acid produced per
hour (100 percent acid basis))
n = Number of test runs
The N2O emissions for the process are then calculated by multiplying the emission factor by the
total production, according to following equation:
_ EFN2D*Pa*(l-DFN)*AFN
2205
Where:
EN20 = N2O mass emissions per year (metric tons of N2O)
EFN2o = Site-specific N2O emission factor (Ib N2O/ton acid produced, 100 percent
acid basis)
Pa = Total production for the year (ton acid produced, 100 percent acid basis)
= Destruction factor of N2O abatement technology (percent of N2O removed
from air stream)
= Abatement factor of N2O abatement technology (percent of year that
abatement technology was used)
2205 = Conversion factor (Ib/metric ton).
The amount of N2O emitted varies based on production rate, equipment condition, and abatement
technology used. The emission factor is not expected to vary significantly on a day-to-day basis.
Annual testing should be sufficient to account for changes in equipment over time and repeat
testing should be sufficient to account for any reduction in emissions due to equipment
installation or shutdown. All other variables that could impact N2O emissions (changes in
production rate and abatement technologies) are accounted for in the equation.
5.3 Option 3: Direct Measurement
Process and combustion emissions resulting from nitric acid production can also be determined
through direction measurement. Two approaches could be used to comply with Option 3. Under
either a CEMS approach or a stack testing approach, the emissions measurement data would be
reported annually.
5.3.1. Stack Test Data
Direct measurement could also be carried out through stack testing, whereby 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,
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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. Two approaches could be used to
comply with Option 3.
5.3.2. New Source Performance Standard Approach
Direct measurement is required_by the Nitric Acid New Source Performance Standard (NSPS)
(40 CFR Part 60, subpart G). Under the NSPS approach, however, owners or operators must use
CEMS to directly measure NOx and use a site-specific emission rate factor to convert the NOx
measurement to N2O emissions per ton of acid produced. This option would require monitoring
NOx emissions on a continuous basis and measuring N2O emissions to establish an emission rate
factor and periodic monitoring (using a stack test) to verify the emission rate factor over time.
Testing should be conducted without using any NOx or N2O abatement technologies. Testing
would also be required whenever significant process changes are made. According to the
facility-level (bottom-up) inventory, 44 percent of facilities are currently using NOx CEMS.
This approach is consistent with the approach used by the Nitric Acid NSPS to determine NOx
emissions in units of the emissions limit, Ib NOx per ton of 100 percent nitric acid produced.
5.3.3. Continuous Emissions Monitoring Systems
Another applicable monitoring method to estimate N2O emissions from nitric acid production
facilities for which the process emissions and/or combustion GHG emissions are contained
within a stack or vent is direct measurement using a Continuous Emissions Monitoring System
(CEMS). Though available, CEMS for monitoring N2O emissions are not currently in use in the
industry and there is no existing EPA method for certifying N2O CEMS.
Direct measurements of the GHG (in this case N2O) concentration in the stack gas and the flow
rate of the stack gas can be made using a CEMS. 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., CO2) 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.
Because a CEMS would continuously measure actual N2O emissions at a given nitric acid
production facility when it is in operation, this method is the most accurate monitoring method
for determining GHG emissions from a specific source. This method would be consistent with
the Tier 3 approach established by IPCC, the Tier Al methodology from the Climate Registry,
Approach 1 from WBCSD, and the "A" rated approach from USDOE.
6. Options for Estimating Missing Data
Options and considerations for missing data 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.).
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6.1 Procedures for Option 1: Simplified Emission Calculation Method
If facility-specific production data are missing for one year, an average value using the
production data from the year prior and the year after the missing year may be calculated.
Default emission factors are readily available through IPCC guidelines (IPCC 2006).
6.2 Procedures for Option 2: Facility Specific Emission Factor Using Stack Test
For process sources that use the hybrid approach, the following data would be needed: nitric
acid production rate, nitric acid production capacity, number of operating hours, emission rate
factor, and the type of abatement technology used and its utilization factor. In general, the
substitute data value could be the arithmetic average of the quality-assured values of that same
parameter immediately preceding and immediately following the missing data incident. If no
quality-assured data are available prior to the missing data incident, the substitute data value
would be the first quality-assured value obtained after the missing data period. For missing oil
or gas flow rates the standard missing data procedures in section 2.4.2 of appendix D to part 75
could be required.
6.3 Procedures for Option 3: Direct Measurement
6.3.1 Continuous Emission Monitoring Data
CEMS for monitoring N2O emissions are not currently in use in the industry and there is no
existing EPA method for certifying N2O CEMS. In general, the missing data procedures for CC>2
CEMS, listed below would be adequate.
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
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methods used to estimate missing data would depend on the monitor data availability and the
duration of the missing data period.
6.3.2 Stack Test Data
For options involving direct measurement of flow rates or 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 (USEPA 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.
7. QA/QC Requirements
Facilities could be required to conduct quality assurance and quality control of the reported
data. Specific QA/QC requirements would vary depending on the monitoring methods, but
facilities could be required to prepare an in-depth quality assurance and quality control plan
which would include checks on production data and calculations performed to estimate GHG
emissions.
7.1 Stationary Emissions
For more information on the QA/QC requirements associated with methods for estimating CC>2,
CH4, and N2O emissions from stationary combustions see the General Stationary Fuel
Combustion Technical Support Document at EPA-HQ-OAR-2008-0508-004.
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.
For facilities using CEMS to measure CC>2 emissions, the equipment could be tested for accuracy
and calibrated as necessary by a certified third party vendor. These procedures could be required
to be consistent in stringency and data reporting and documentation with the QA/QC procedures
for CEMS described in Part 75 of the Acid Rain Program.
For facilities using stack test data, U.S. EPA regulations for performance testing under 40 CFR §
63.7(c)(2)(i) could be required. These regulations 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
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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 (USEPA 2005).
7.3 Data Management
Data management procedures could be included in the QA/QC Plan. Elements of the data
management procedures plan are as follows:
• Check for temporal consistency in production data and emission estimates. If outliers
exist, they could be required to be explained by changes in the facility operations or other
factors. A monitoring error is probable if differences between annual data cannot be
explained by: changes in activity levels, changes concerning fuels or input material, or
changes concerning the emitting process (e.g. energy efficiency improvements) (EU
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 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 (EU 2007).
• Maintain data documentation, including comprehensive documentation of data received
through personal communication.
• Check that changes in data or methodology are documented.
8. Types of Emission Information to be Reported
Nitric acid facilities owner and operators should report both process (N2O) 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.
Combustion-related emissions would be reported consistent with the stationary fuel combustion
methods. The specific data to be reported, and any additional information to be reported to
support verification, depends on the calculation methodology implemented. For more
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Technical Support Document for Nitric Acid: Proposed Rule for Mandatory Reporting of Greenhouse Gases
information on reporting options for stationary combustion refer to EPA-HQ-OAR-2008-0508-
004.
8.1 Types of Emissions to be Reported
8.1.1 Option 1: Simplified Emission Calculation
For process sources that use a simplified emission calculation, the facility could report its
production data, fuel type, fuel consumption, carbon content of fuel, and emission factor
calculated.
8.1.2 Option 2: Facility Specific Emission Factor Using Stack Test
For the hybrid method, the facility could report its production data and site-specific emission
factor. They could also be required to report testing of N2O emissions that was conducted to
verify the emission factor over time. Information on the type and use of abatement technologies
could also be required. If significant process changes are made, and additional testing is carried
out, this information could also be reported.
8.1.3 Option 3: Direct Measurement
For options for which the monitoring method is based on direct measurement, either using a
CEMS or through stack testing, the GHG emissions are directly measured at the point of
emission.
8.1.3.1 CEMS
For direct measurement using CEMS, the facility could be required to report the GHG emissions
measured by the CEMS for each monitored emission point and could also report the monitored
GHG concentrations in the stack gas and the monitored stack gas flow rate for each monitored
emission point. These data would illustrate how the monitoring data were used to estimate the
GHG emissions.
The facility could report the following data for direct measurement of emissions using CEMS:
• The unit ID number (if applicable);
• A code representing the type of unit;
• Maximum product production rate and maximum raw material input rate (in units of
metric tons per hour [metric tons/hr]);
• Each type of raw material used and each type of product produced in the unit during the
report year;
• The calculated CC>2, CH/t, and N2O emissions for each type of raw material used and
product produced, expressed in metric tons of each gas and in metric tons of CC^e;
• A code representing the method used to calculate the CC>2 emissions for each type of raw
material used (e.g., part 75, Tier 1, Tier 2, etc.);
• If applicable, a code indicating which one of the monitoring and reporting methodologies
in part 75 of this chapter was used to quantify the CC>2 emissions;
• The calculated CC>2 emissions from sorbent (if any), expressed in metric tons; and
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• The total GHG emissions from the unit for the reporting year, i.e., the sum of the CC>2,
CH4, and N2O emissions across all raw material and product types, expressed in metric
tons of CO26.
8.1.3.2 Stack Testing
For direct measurement using stack testing, the facility could report the GHG emissions
measured during the stack test, the measured GHG concentrations in the stack gas, the monitored
stack gas flow rate fore each monitored emission point, and the time period during which the
stack test was conducted. The facility could also report the process operating conditions (e.g.,
raw material feed rates) during the time period during which the test was conducted.
8.2 Other Information to be Reported
Facility owners and operators could also submit the following data to understand the emissions
data and verify the reasonableness of the reported emissions. The data could include annual
nitric acid production capacity, annual nitric acid production, number of operating hours in the
calendar year, the emission rate factor used, abatement technology used (if applicable),
abatement technology efficiency, and abatement utilization factor.
Capacity, actual production, operating hours will be helpful in determining the potential for
growth in the nitric acid industry. A list of abatement technologies would be helpful in assessing
the widespread use of abatement is in the nitric acid source category, cataloging any new
technologies that are being used, and documenting the amount of time that the abatement
technologies are being used.
8.3 Additional Data to be Retained Onsite
Facilities could 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 could include CEMS
monitoring system data including continuous-monitored GHG concentrations and stack gas flow
rates, and calibration and quality assurance records. For stack testing these data could include
stack test reports and associated sampling and chemical analytical data for the stack test. Process
data including process raw material and product feed rates and carbonate contents should also be
retained on site for a period of at least five years from the reporting year. The EPA could use
such data to conduct trend analyses and potentially to develop process or activity-specific
emission factors for the process.
9. References
BCS (2008). Memorandum from Bill Choate, BCS, Inc. to R. Neulicht, RTI International.
Energy Associated With Nitric Acid Production. March 14, 2008.
Choe, J.S., P.J. Cook, and F.P. Petrocelli (1993). "Developing N2O Abatement Technology for
the Nitric Acid Industry." Prepared for presentation at the 1993 ANPSG Conference. Air
Products and Chemicals, Inc., Allentown, PA.
CEMS Cost Model. CEMS.XLS. Accessed on April 30, 2008. Available at:
http ://www. epa. gov/ttn/emc/cem. html.
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Cotton, F.A. and Wilkinson, G. (1988). Advanced Inorganic Chemistry, 5th Edition, ISBN 0-
471-84997-9. Wiley, New York, USA.
CR (2007). The Climate Registry. General Reporting Protocol for the Voluntary Reporting
Program.
DEFRA (2003) Guidelines for the Measurement and Reporting of Emissions by Direct
Participants in the UK Emissions Trading Scheme. Department for Environment, Food and Rural
Affairs. June 2003. Accessed on April 30, 2008. Available
at:http://www.defra.gov.uk/environment/climatechange/trading/uk/pdf/trading-reporting.pdf
EC (2006). Environment Canada. Technical Guidance on Reporting Greenhouse Gas
Emissions. 2006 Reporting Year.
EFMA (2000). European Fertilizer Manufacturers' Association. Best Available Techniques for
Pollution Prevention and Control in the European Fertilizer Industry: Production of Nitric Acid,
Booklet No. 2 of 8. European Fertilizer Manufacturers' Association. Brussels.
EPA (2003). Environmental Protection Agency. International Analysis of Methane and Nitrous
Oxide Abatement Opportunities: Report to Energy Modeling Forum., Working Group 21.
Appendices Nitrous Oxide Baselines. Washington, DC.: EPA. June 2003. Accessed on April 29,
2008. Available at http://www.epa.gov/methane/appendices.html.
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
EU (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. Accessed on April 30, 2008. Available at:
http://eurlex.europa.eu/LexUriServ/site/en/oj/2007/l_229/l_2292007083 Ien00010085.pdf
IPCC (2006). Intergovernmental Panel on Climate Change. 2006IPCC Guidelines for National
Greenhouse Gas Inventories.
Japan (2006) National Greenhouse Gas Inventory Report of Japan. Ministry of the Environment.
Japan. Greenhouse Gas Inventory Office of Japan, Center for
Global Environmental Research, National Institute for Environmental Studies. August 2006.
Accessed on April 30, 2008. Available at: http://www-cger.nies.go.jp/publication/I069/I069.pdf.
NGER (2007). National Greenhouse and Energy Reporting System. Technical Guidelines for
the Estimation of Greenhouse Emissions and Energy at Facility Level: Energy, Industrial
Process and Waste Sectors in Australia. December 2007.
SBA (2008). U. S. Small Business Administration. Table of Small Business Size Standards
Matched to North American Industry Classification System Codes. Effective March 11, 2008.
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Accessed on April 29, 2008. Available at:
http://www.sba.gov/idc/groups/public/documents/sba_homepage/serv_sstd_tablepdf.pdf.
USDOE (2007). Technical Guidelines Voluntary Reporting of Greenhouse Gases (1605(b))
Program. Office of Policy and International Affairs United States Department of Energy
(USDOE). January 2007. Accessed on April 30, 2008. Available at:
www.eia.doe.gov/oiaf/1605/January2007_l 605bTechnicalGuidelines.pdf
U.S. EPA (2003) Part 75, Appendix Bl, Available at
http ://www. epa. gov/airmarkt/spm/rule/001OOOOOOB. htm.
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
USGHG (2008). Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990-2006. April
2008. EPA Document Number 430-R-08-005. Accessed on May 7, 2008. Available at:
http://www.epa.gov/climatechange/emissions/usinventoryreport.html.
WBCSD (2001). World Business Council for Sustainable Development. The Greenhouse Gas
Protocol - A corporate reporting and accounting standard. September 1, 2001. Accessed on
April 30, 2008. Available at: http://www.wbcsd.org/web/publications/ghg-protocol.pdf
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