Technical Support Document for the Lime
Manufacturing 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 the Lime Sector: Proposed Rule for Mandatory Reporting of Greenhouse Gases
CONTENTS
1. Source Description 1
2. Total Emissions 1
2.1 Process Emissions 1
2.2 Stationary Combustion 1
3. Review of Existing Programs and Methodologies 3
3.1 2006 IPCC Guidelines 3
3.2 2008 NLA Protocol 4
3.3 2008 U. S. Inventory of Greenhouse Gas Emissions and Sinks 4
3.4 WRI/WBCSD Protocol 4
3.5 EUETS 1st Reporting Period 5
3.6 EU ETS 2nd Reporting Period 5
3.7 The Climate Registry 5
3.8 Technical Guidelines Voluntary Reporting of Greenhouse Gases (1605(b))
Program 5
4. Options for Reporting Threshold 6
4.1 Options Considered 6
4.1.1 Emissions Thresholds 6
4.1.2 Capacity Thresholds 6
4.1.3 No Emissions Threshold 6
4.2 Emissions and Facilities Covered Per Option 6
4.2.1 Emissions Thresholds 6
4.2.2 Capacity Threshold 7
5. Options for Monitoring Methods 7
5.1 Option 1: Simplified Emissions Calculation 7
5.2 Option 2: Input-based Method 8
5.3 Option 3: Emissions Based on Lime Type (default factors) 8
5.4 Option 4: Emissions Based on Lime Type (NLA Method) 9
5.5 Option 5: Direct Measurement using Continuous Emission Monitoring Data
(CEMS) 9
6. Procedures for Estimating Missing Data 10
6.1 Procedures for Option 1: Simplified Emissions Calculation 10
6.2 Procedures for Option 2: Input Method 10
6.3 Procedures for Option 3: Emissions Based on Lime Type (default factors) 10
6.4 Procedures for Option 4: Emissions Based on Lime Type (NLA method) 10
6.5 Procedures for Option 5: CEMS 10
7. QA/QC Requirements 11
7.1 Stationary Emissions 11
7.2 Process Emissions 11
7.3 Data Management 12
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Technical Support Document for the Lime Sector: Proposed Rule for Mandatory Reporting of Greenhouse Gases
7.4 Calculation Checks 12
8. Types of Emission Information to be Reported 13
8.1 Types of Emissions to be Reported 13
8.1.1 Option 1: Simplified Emissions Calculation 13
8.1.2 Option 2: Input-based Approach 13
8.1.3 Option 3: Emissions Based on Lime Type (default factors) 13
8.1.4 Option 4: Emissions Based on Lime Type (NLA method) 13
8.1.5 Option 5: Direct Measurement using Continuous Emission Monitoring
Data(CEMS) 14
8.2 Other Information to be Reported 14
8.3 Additional Data to be Retained Onsite 14
9. References 15
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1. Source Description
As described in the Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990-2006 (EPA
2008b), lime is an important manufactured product with many industrial, chemical, and
environmental applications. Its major uses are in steel making, flue gas desulfurization (FGD)
systems at coal-fired electric power plants, construction, and water purification. In 2006, lime
was used for the following purposes: metallurgical uses (36%), environmental uses (29%),
chemical and industrial uses (21%), construction uses (13%), and to make dolomite refractories
(1%) (USGS 2007). For U.S. operations, the term "lime" actually refers to a variety of chemical
compounds. These compounds include calcium oxide (CaO), or high-calcium quicklime; calcium
hydroxide (Ca(OH)2), or hydrated lime; dolomitic quicklime ([CaOMgO]); and dolomitic
hydrate ([Ca(OH)2'MgO] or [Ca(OH)2ĞMg(OH)2]).
2. Total Emissions
Emissions from the lime industry were estimated to be 25.4 million metric tons of CC>2
equivalent (MMTCC^e) in 2004 (EPA 2006). These emissions include both process-related
emissions and on-site stationary combustion emissions from 89 lime manufacturing facilities
across the United States, including Puerto Rico. Process-related emissions account for 14.3
MMTCO26 l, or 56 percent of the total, while on-site stationary combustion emissions account
for the remaining 11.1 MMTCO2e (EPA 2006). The 89 facilities studied covers over 65% of the
National Lime Association facilities (44 out of 67 facility members) as well as several other
facilities which are not participating members of the NLA. The list of U.S. lime manufacturing is
presented in Table 1 as provided by EPA (2006).
2.1 Process Emissions
Lime production involves three main processes: stone preparation, calcination, and hydration.
During the calcination process, lime is sufficiently heated to generate process-related CC>2 as a
by-product. For example, the calcination of pure limestone is as follows:
CaCO3 + heat -> CaO + CO2
In certain applications, lime reabsorbs CC>2 during use. For example, sugar refineries use lime to
remove impurities from the raw cane juice, and then remove excess lime through carbonation
(IPCC 2006).
2.2 Stationary Combustion
Stationary combustion emissions occur when fossil fuels are combusted to provide energy for
manufacturing equipment, as well as to provide heat for the manufacturing process. This heat is
used in the previously discussed calcination process to produce pure lime (CaO). Coal, natural
gas, distillate fuel oil, and residual fuel oil are all possible fuel inputs, though the actual mix of
fuels will be site-specific.
1 The U.S. Inventory (EPA 2008b) reports 15.8 Tg CO2 Eq. of process emissions from lime manufacturing in 2006.
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Technical Support Document for the Lime Sector: Proposed Rule for Mandatory Reporting of Greenhouse Gases
Table 1. U.S. Lime Manufacturing Facilities (2004)
Company
Carmeuse Lime
Chemical Lime Co.
Chemical Lime Co.
Chemical Lime Co.
Cheney Lime & Cement Co.
Southern Lime Co.
Chemical Lime Co.
Chemical Lime Co.
U.S. Lime and Minerals, Inc.
Arkansas Lime Co.
Chemical Lime Co.
Spreckels Sugar Co.-C
Spreckels Sugar Co.-C
Western Sugar Co.-C
Western Sugar Co.-C
Amalgamated Sugar Co. LLC-C
Amalgamated Sugar Co. LLC-C
Amalgamated Sugar Co. LLC-C
Carmeuse Lime
Carmeuse Lime
Ispat Inland, Inc.-C (NOW, Mittal
Steel)
Linwood Mining & Minerals
Corp.
Carmeuse Lime
Carmeuse Lime
Old Castle Industrial Minerals,
Inc.
Specialty Minerals, Inc. (C&S)
Carmeuse Lime
Michigan Sugar Co.-C
Michigan Sugar Co.-C
Michigan Sugar Co.-C
Michigan Sugar Co.-C
Monitor Sugar Co.-C
American Crystal Sugar Co.-C
American Crystal Sugar Co.-C
Plant Location
Saginaw, AL
Alabaster, AL
Montevallo, AL
Calera, AL
Siluria, AL
Calera, AL
Douglas, AZ
Nelson, AZ
Batesville, AR
Salinas, CA
Mendota, CA
Brawley, CA
Fort Morgan, CO
Greeley, CO
Nampa, ID
Paul, ID
Twin Falls, ID
South Chicago, IL
Buffington, IN
Indiana Harbor, IN
Linwood, IA
Carntown, KY
Maysville, KY
Lee, MA
Adams, MA
River Rouge, Ml
Sebewaing, Ml
Carollton, Ml
Croswell, Ml
Carrolton, Ml
Bay City, Ml
Moorhead, MN
Crookston, MN
Company
Martin Marietta Magnesia
Specialties LLC-C&S
National Lime & Stone Co.6
U.S. Lime Co. -St. Clair7
Amalgamated Sugar Co.-C
Ash Grove Cement Co.
Carmeuse Lime
Graymont (PA) Inc.
Graymont (PA) Inc.
LWB Refractories Co. -C&S
Mercer Lime and Stone Co.
Florida Lime Corp.
Pete Lien & Sons Inc.
Bowater Southern Paper Corp.-
C
O-N Minerals Tenn Luttrell
Operation
Austin White Lime Co.
Chemical Lime Co.
Chemical Lime Co.
Chemical Lime Co.
U.S. Lime and Minerals Inc.
Texas Lime Co.
Chemical Lime Co.
Graymont Western U.S. Inc.
Chemical Lime Co.
O-N Minerals Chemstone
Operation
O-N Minerals Chemstone
Operation
Graymont Western U.S. Inc.
Tacoma Lime Division (C&S)
Greer Lime Co.
Cutler-Magner Corp.
Rockwell Lime Co.
Western Lime Corp.
Western Lime Corp.
Western Sugar Co.-C
Western Sugar Co.-C
Wyoming Lime Producers
Plant Location
Woodville, OH
Carey, OH
Marble City, OK
Nyssa, OR
Portland, OR
Annville, PA
Pleasant Gap, PA
Bellefonte, PA
York, PA
Branchton, PA
Ponce, PR
Rapid City, SD
Calhoun, TN
Luttrell, TN
McNeil, TX
Clifton, TX
Marble Falls, TX
New Braunfels, TX
Cleburne, TX
Grantsville, UT
Delta, UT
Kimbalton, VA
Strasburg, VA
Clear Brook, VA
Tacoma, WA
Riverton, WV
Superior, Wl
Manitowoc, Wl
Green Bay, Wl
Eden, Wl
Torrington, WY
Lovell, WY
Frannie, WY
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Technical Support Document for the Lime Sector: Proposed Rule for Mandatory Reporting of Greenhouse Gases
Company
American Crystal Sugar Co.-C
Southern Minnesota Sugar
Corp.-C
Chemical Lime Co.
Mississippi Lime Co.-S&C
Mississippi Lime Co.-S&C
Vessell Mineral Products Co.
Graymont Western U.S. Inc.
Sidney Sugars Inc.-C
Western Sugar Co.-C
Western Sugar Co.-C
Chemical Lime Co.
American Crystal Sugar Co.-C
American Crystal Sugar Co.-C
Minn-Dak Farmers Coop.-C
Carmeuse Lime
Carmeuse Lime
Carmeuse Lime
Graymont Dolime (OH) Inc.
Huron Lime Co.
Plant Location
East Grand Forks,
MN
Renville, MN
Ste. Genevieve, MO
Ste. Genevieve, MO
Springfield, MO
Bonne Terre, MO
Townsend, MT
Sidney, MT
Billings, MT
Scottsbluff, NE
North Las Vegas, NV
Drayton, ND
Hillsboro, ND
Wahpeton, ND
Millersville, OH
Maple Grove, OH
Grand River, OH
Genoa, OH
Huron, OH
Company
Wyoming Sugar Co. LLC-C
Carmeuse Lime
Riverton Corp.-C
Western Lime Corp.
Western Lime Corp.
Western Sugar Co.-C
Western Sugar Co.-C
Wyoming Lime Producers
Wyoming Sugar Co. LLC-C
Carmeuse Lime
Riverton Corp.-C
Wyoming Lime Producers
Wyoming Sugar Co. LLC-C
Carmeuse Lime
Riverton Corp.-C
Carmeuse Lime
Riverton Corp.-C
Plant Location
Worland, WY
Hanover, PA
VA
Green Bay, Wl
Eden, Wl
Torrington, WY
Lovell, WY
Frannie, WY
Worland, WY
Hanover, PA
VA
Frannie, WY
Worland, WY
Hanover, PA
VA
Hanover, PA
VA
Source: EPA DRAFT Lime Plant Database (2006)
3. Review of Existing Programs and Methodologies
Protocols and guidance reviewed for this analysis include the 2006IPCC Guidelines., U.S.
Inventory, the World Resource Institute and World Business Council for Sustainable
Development's Greenhouse Gas Protocol, the EU ETS (both the first and second reporting
periods), the Technical Guidelines for the Voluntary Reporting of Greenhouse Gases (1605(b))
Program, the National Lime Association, and The Climate Registry. These methodologies
coalesce around two different approaches, based on measuring either the input or output of the
production process. In general, the output method is less certain, as it involves multiplying
production data by emission factors and correction factors for lime kiln dust and hydrated lime
that are default values based on purity (i.e. percentage of input that is a carbonate) assumptions.
In contrast, the input method is more certain as it generally involves measuring the consumption
and the carbonate content of each process input and calculating the carbonate weight ratio of
inputs. The existing programs and methodologies are discussed in more detail below.
3.1 2006 IPCC Guidelines
The IPCC considers three tiers of emission estimation methodologies that use either an output-
based approach (Tier 1 and 2) or an input-based approach (Tier 3). The Tier 1 method applies a
default emission factor to lime production. For Tier 1, the only site-specific input that is needed
for the emission estimate is the lime production in the year of interest.
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Technical Support Document for the Lime Sector: Proposed Rule for Mandatory Reporting of Greenhouse Gases
The Tier 2 method expands upon the Tier 1 method by including production by lime type and a
correction factor for lime kiln dust (LKD) production and hydrated lime consumption. These
correction factors are implemented to account for CC>2 emitted from LKD (which contains
uncalcined carbonates) and hydrated lime (which uses alternative emission factors); neither of
these factors are used in the Tier 1 methodology. For Tier 2, information on the mass of lime
production (by type, including byproducts/waste products, such as lime kiln dust) is the only site-
specific data necessary.
IPCC also considers a Tier 3 method, which is based upon facility-specific data. This approach
requires facilities to calculate their calcination fractions and determine the weight fraction of
their carbonate inputs. The fractions are applied to their carbonate consumption and LKD
production using stoichiometric emission factors. The Tier 3 method requires site-specific
information on the mass and fraction of calcination achieved for both carbonate process inputs
and LKD production.
3.2 2008 NLA Protocol
The National Lime Association (NLA) has developed a protocol for calculating CC>2 emissions
called, "CC>2 Emissions Calculation Protocol for the Lime Industry English Units Version",
February 5, 2008 Revision. The NLA protocol improves the IPCC Tier 2 method. NLA
emission calculations are based on metric tons of each type of lime and calcined
byproducts/wastes (such as LKD) produced at the kiln. Emissions are calculated by multiplying
amounts of quicklime and calcined byproducts/wastes by an emission factor. Facilities multiply
the amount of lime produced at each kiln and the amount of calcined byproducts/wastes at the
kiln by an emission factor. The protocol requires measurements of the quantity of each type of
lime produced and each type of calcined byproduct/waste product produced at the kiln, and
chemical analysis of the composition of the lime and calcined byproduct/waste. To assess the
composition of the lime and calcined byproduct/waste product, facilities would send samples to
an off-site laboratory for analysis by ASTM C25-06, "Standard Test Methods for Chemical
Analysis of Limestone, Quicklime, and Hydrated Lime" coupled with the procedures in the
written protocol. The NLA protocol is a common business practice within the industry and NLA
has prepared a document containing a spreadsheet with built in calculations and instructions for
using the protocol.
3.3 2008 U.S. Inventory of Greenhouse Gas Emissions and Sinks
The U.S. inventory follows the IPCC Tier 2 approach, including any default value
recommendations.
3.4 WRI/WBCSD Protocol
The World Resource Institute and World Business Council for Sustainable Development's
Greenhouse Gas Protocol provides two approaches to calculating emissions from lime
production which are similar to IPCC's Tier 2 and Tier 3 methods. Approach 1 estimates
emissions based on lime production data and is calculated with the same values as IPCC's Tier 2.
This method encourages more plant-specific data than IPCC's method, although default values
are presented in the protocol and are identical to the IPCC default values for Tier 2. Approach 2
estimates emissions based on carbonate consumption. This method requires the same data and
calculations as IPCC's Tier 3 and offers identical default values.
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Technical Support Document for the Lime Sector: Proposed Rule for Mandatory Reporting of Greenhouse Gases
3.5 EU ETS 1st Reporting Period
European Union Emission Trading System (EU ETS) guidelines from the first reporting period
offers two calculation approaches for reporting GHG emissions from this sector. Approach A is
based on carbonate input and output data. In other words, the amounts of carbonates entering
and exiting the process are used to determine the amount of carbonates consumed. This
consumption value is then multiplied by the appropriate emissions factor and a conversion factor
to account for the amount of carbon not converted to CC>2. Default emission factors are given but
can be calculated with plant-specific data as well.
Calculation approach B requires data on the amount of magnesium and calcium oxides in the
lime produced. The calculation involves multiplying the amount of magnesium and calcium
oxides by an emission factor and a conversion factor. If plant-specific data are not available,
default factors may be used for this method.
Both approaches offer two Tiers based on the amount of uncertainty allowed in measuring the
perspective activity data (i.e. carbonate weights or magnesium and calcium oxide weights). EU
ETS considers the two approaches to be equivalent.
3.6 EU ETS 2nd Reporting Period
EU ETS guidelines from the second reporting period are similar to the 1st reporting period.
Approach A, based on carbonate input to the kiln, does not require measurement of carbonates
leaving the kiln. In addition, this report's guidelines offer a 3 Tier option for approach A. The
additional tier allows more uncertainty in the activity data. For Approach B based on
magnesium and calcium oxide measurement, the same tiers are allowed.
3.7 The Climate Registry
The Climate Registry (General Reporting Protocol for the Voluntary Reporting Program)
outlines four emission calculation approaches: (1) Mass balance based on carbonate inputs,
(2) Mass balance based on production, (3) Mass balance based on carbonate inputs with default
values, and (4) Mass balance based on production with default values. These methods are
essentially IPCC's Tier 2 and 3 methods with options for using plant-specific factors or the use
of default values.
3.8 Technical Guidelines Voluntary Reporting of Greenhouse Gases (1605(b)) Program
The Technical Guidelines 1605(b) Program uses NLA's approach to calculating emissions. In
addition, they offer the default emission factor values from IPCC's Tier 2 method for use when
plant-specific values cannot be determined. Default values are considered to be of a lower rating
(higher uncertainty) than using plant-specific values.
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Technical Support Document for the Lime Sector: Proposed Rule for Mandatory Reporting of Greenhouse Gases
4. Options for Reporting Threshold
4.1 Options Considered
4.1.1 Emissions Thresholds
Four emission threshold levels were considered for the lime manufacturing sector based on
actual facility emissions. These thresholds, 100,000, 25,000, 10,000, and 1,000 mtCO2e per year,
were analyzed.
4.1.2 Capacity Thresholds
Four capacity threshold levels were considered for the lime manufacturing sector based on
facility capacity. These thresholds, 1,000,000, 500,000, 250,000, 80,000, and 40,000 metric tons
of lime produced per year, were analyzed.
4.1.3 No Emissions Threshold
The no emissions threshold includes all lime manufacturing facilities included in this Technical
Support Document regardless of their emissions or capacity.
4.2 Emissions and Facilities Covered Per Option
4.2.1 Emissions Thresholds
A summary of the emissions and facilities covered per option is presented in Table 2. Emission
estimates were provided using EPA's lime plant database (EPA 2006).
Table 2. Emissions-based Threshold Analysis for Lime Manufacturing
Threshold
Level
(Metric
Tons)
100,000
25,000
10,000
1,000
Process
Emissions
(Metric
Tons
CO2e/yr)
14,338,898
14,338,898
14,338,898
14,338,898
Stationary
Combustion
Emissions
(Metric
Tons
CO2e/yr)
11,082,146
11,082,146
11,082,146
11,082,146
Total
National
Emissions
(Metric
Tons
C02e)
25,421,043
25,421,043
25,421,043
25,421,043
Number
of
Facilities
89
89
89
89
Emissions Covered
Metric
Tons
CO2e/yr
23,833,273
25,371,254
25,396,036
25,421,043
Percent
93.7%
99.8%
99.9%
100%
Facilities Covered
Number
52
85
86
89
Percent
58.4%
95.5%
96.6%
100%
Calculated based on reported production or production capacity values from listed facilities.
Under the less restrictive thresholds (i.e. 25,000 mtCC^e and less), the majority (greater than 95
percent) of relevant facilities would be required to report and the majority (greater then 95
percent) of emissions would be reported. This reporting coverage is in marked contrast to the
highest threshold, which would cover 94 percent of emissions but only 58 percent of facilities.
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Technical Support Document for the Lime Sector: Proposed Rule for Mandatory Reporting of Greenhouse Gases
4.2.2 Capacity Threshold
A summary of the capacity-based emissions and facilities covered per option is presented in
Table 3. Emission estimates were provided using EPA's lime plant database (EPA 2006). Five
reporting threshold levels were considered for the lime production sector. These thresholds were
1,000,000, 500,000, 250,000, 80,000, and 40,000 metric tons of lime produced per year.
Table 3. Capacity-based Threshold Analysis for Lime Manufacturing
Capacity
Threshold
(metric tons
lime
produced per
year)
1,000,000
500,000
250,000
80,000
40,000
Process CO2
Emissions**
(mtCO2e/yr)
15,954,608
15,954,608
15,954,608
15,954,608
15,954,608
Number
of
Facilities
89
89
89
89
89
Process CO2 Emissions
Covered
mtCO2e/yr
3,163,839
7,031,718
11,599,349
15,830,776
15,954,608
%
19.83%
44.07%
72.70%
99.22%
100.00%
Facilities Covered
Number
3
10
28
86
89
%
3.4%
11.2%
31.5%
96.6%
100.0%
Calculated based on production capacity values from reporting facilities.
The capacity-based threshold analysis exhibits the range of lime production facility sizes. Again,
under the less restrictive thresholds (i.e. 80,000 metric tons and less), the majority (greater than
95 percent) of relevant facilities would be required to report and the majority (greater then 95
percent) of emissions would be reported. At the highest thresholds (i.e. 500,000 metric tons and
more), less than 50 percent of emissions are covered and only 11 percent of facilities would be
required to report. A threshold of zero (requiring all facilities to report) is thus consistent with
these less restrictive thresholds.
5. Options for Monitoring Methods
Five separate monitoring methods were considered for this technical support document: a
simplified emission calculation (Option 1), an input-based method (Option 2), a method
calculating emissions by lime type (using default factors) (Option 3), a method calculating
emissions by lime type (using NLA's facility-level data method) (Option 4), and direct
measurement (Option 5). All of these options could be carried out on an annual basis.
5.1 Option 1: Simplified Emissions Calculation
A simplified emissions calculation is based upon the IPCC Tier 1 methodology (IPCC 2006).
The Tier 1 method is an output-based approach applying an emission factor to the total quantity
of lime produced. This approach uses country specific data on the ratio of lime types produced.
However, in the absence of country specific values, a facility may assume a production of 85
percent high calcium lime (quicklime) and 15 percent production of dolomitic lime. The Tier 1
equation is as follows:
ECo2 = ML EFL
Where:
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Technical Support Document for the Lime Sector: Proposed Rule for Mandatory Reporting of Greenhouse Gases
Eco2 = process emissions of CC>2 (metric tons)
ML = mass of lime produced (metric tons)
EFiime = emission factor for lime (metric tons CC>2 / metric tons lime)
This method also relies upon the emission factors to calculate an overall lime production
emissions factor. The default emissions factor is calculated below:
J^r lime U. o J _t/r quicklime ~r U. 1J lir dolomitic lime
= 0.85*0.75+0.15*0.77a
= 0.75 metric tons CCVmetric ton of lime produced
5.2 Option 2: Input-based Method
This approach is based upon the IPCC Tier 3 method, which is an input-based approach. This
approach requires facilities to calculate their calcination fractions and determine the weight
fraction of their carbonate inputs, and then apply this information to their carbonate consumption
and lime kiln dust production using stoichiometric emission factors. In other words:
EC02 = Si (EFi' Mi' Fi) - Md Cd (1 - Fd) EFd
Where:
Eco2 = process emissions of CC>2 (metric tons)
EF; = emission factor for carbonate / (metric tons CC>2 / metric tons carbonate)
M; = mass of carbonate /' consumed (metric tons)
F; = fraction calcination achieved for carbonate /', fraction
Md = mass of lime kiln dust (LKD) (metric tons)
Cd = fraction of original carbonate in the LKD (fraction)
Fd = fraction calcination achieved for the LKD (fraction)
EFd = emission factor for the uncalcined carbonate in the lime kiln dust (metric tons
CC>2 / metric tons carbonate)
The 2006 IPCC Guidelines contain emission factors for common carbonates, which are
presented in Table 4. Calcite (limestone) and dolomite are the only two carbonates used to
produce lime in the United States. (Miller 2008).
Table 4. CO2 Emission Factors for Common Carbonates
Mineral Name - Carbonate
Calcite/aragonite - CaCOs
Dolomite - CaMg(CO3)2
CO2 Emission Factor
(metric tons CO2/ metric tons carbonate)
0.43971
0.47732
Source: IPCC (2006) 2006 IPCC Guidelines for National Greenhouse Gas Inventories
5.3 Option 3: Emissions Based on Lime Type (default factors)
IPCC's Tier 2 method offers an output based calculation based on production by lime type.
Default factors are used for the calcium oxide and magnesium oxide content in calculating the
emission factors. The Tier 2 equation is as follows:
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Technical Support Document for the Lime Sector: Proposed Rule for Mandatory Reporting of Greenhouse Gases
n *Mk>n *CFlkcUn)*0.9?)
2000
2205
n=l
Where:
Ek = Annual CO2 emissions from lime production at kiln k (metric tons/year)
EFk,n = Emission factor for lime in calendar month n (tons CO2/tons carbonate)
Mk,n = Weight or mass of lime calendar month n (tons/calendar month)
CFikd,k,n = Correction factor for LKD in calendar month n
0.97 = Default correction factor for the proportion of hydrated lime (Assuming 90
percent of hydrated lime produced is high-calcium lime with a water
content of 28 percent)
2000/2205 = Conversion factor for tons to metric tons
i = Each of the specific lime types
p = Months per year.
5.4 Option 4: Emissions Based on Lime Type (NLA Method)
The NLA's proposed method for calculating CO2 emissions from lime manufacturing is similar
to IPCC's Tier 2, but differs in that it uses facility-level data to calculate emission factors as
opposed to default emission factors. Calcium oxide and magnesium oxide content of the lime
products including byproducts and waste products (such as LKD) are required at the facility-
level. The emission factors are calculated as follows:
, = (SRCa0 CaO) + (SRMg0 -MgO)
Where:
EFiime,; = Emission factor for lime type i, metric tons CO2/ metric tons lime
SRcao = Stoichiometric ratio of CO2 and CaO (See Table 1 of §98. 199), metric ton
CO2/ metric ton CaO
SRMgo = Stoichiometric ratio of CO2 and MgO (See Table 1 of §98. 199), metric ton
CO2/ metric ton MgO
CaO = CaO content (percent total CaO), metric tons CaO/ metric tons lime
MgO = MgO content (percent total MgO), metric tons MgO/ metric tons lime.
5.5 Option 5: Direct Measurement using Continuous Emission Monitoring Data
(CEMS)
Direct measurement constitutes measurements of the GHG concentration in the stack gas and the
flow rate of the stack gas using a CEMS. Under a CEMS approach, the emissions measurement
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Technical Support Document for the Lime Sector: Proposed Rule for Mandatory Reporting of Greenhouse Gases
data could be reported annually and would account for both combustion and process-related
emissions. Currently, the lime industry does not use CEMS for CC>2 monitoring, although there
are few plants which do have CEMS for NOx and CO monitoring.
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;
both stationary and process emissions are captured and calculated. The CEMS continuously
withdraws and analyzes a sample of the stack gas and continuously measures the GHG
concentration and flow rate of the stack gas.
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, fuel consumption, etc.).
6.1 Procedures for Option 1: Simplified Emissions Calculation
For process sources in the lime manufacturing category that use Option 1, facility-specific
production data is required. Because the likelihood for missing data is low because businesses
closely track production, 100 percent data availability could be required.
6.2 Procedures for Option 2: Input Method
For process sources in the lime manufacturing category that use Option 2, the data requirements
include the mass, carbonate content, and fraction of calcination achieved for lime kiln dust and
each process input. It is assumed that a facility will be able to supply facility-specific data.
6.3 Procedures for Option 3: Emissions Based on Lime Type (default factors)
For process sources in the lime manufacturing category that use Option 3, only lime production
data is required. It is assumed that a facility will be able to supply facility-specific production
data. Since the likelihood for missing data is low because businesses closely track production,
100 percent data availability could be required.
6.4 Procedures for Option 4: Emissions Based on Lime Type (NLA method)
For process sources in the lime manufacturing category that use Option 4 the calcium oxide
and/or magnesium oxide content are required. If a chemical is lost or missing, the analysis
would have to be repeated. It is assumed that a facility will be able to supply facility-specific
production data. Since the likelihood for missing data is low because businesses closely track
production, 100 percent data availability could be required. The NLA protocol does not provide
any recommendations for periods of missing data; however, it does recommend monthly
sampling of calcium and magnesium oxide measurements to use in annual calculations.
6.5 Procedures for Option 5: CEMS
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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.
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 might be required 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 potential QA/QC procedures that might be required are listed below.
7.1 Stationary Emissions
Facilities should refer to the Stationary Fuel Combustion TSD (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 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.
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7.3 Data Management
Data management procedures could be included in the QA/QC Plan. Elements of the data
management procedures plan could include:
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.
o A monitoring error is probable if differences between annual data cannot be
explained by:
Changes in activity levels,
Changes concerning fuels or input material,
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.
7.4 Calculation Checks
Checks could be performed for all reported calculations. Elements of calculation checks include:
Perform calculation checks by creating a representative sample of emissions calculations or
building in automated checks such as computational checks:
Check whether emission units, parameters, and conversion factors are appropriately
labeled
Check if units are properly labeled and correctly carried through from beginning to end of
calculations
Check that conversion factors are correct
Check the data processing steps (e.g., equations) in the spreadsheets
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Technical Support Document for the Lime Sector: Proposed Rule for Mandatory Reporting of Greenhouse Gases
Check that spreadsheet input data and calculated data are clearly differentiated
Check a representative sample of calculations, by hand or electronically
Check some calculations with abbreviated calculations (i.e., back of the envelope checks)
Check the aggregation of data across source categories, business units, etc.
When methods or data have changed, check consistency of time series inputs and
calculations (EPA 2007).
8. Types of Emission Information to be Reported
8.1 Types of Emissions to be Reported
Based on the review of existing programs and the emission sources at lime manufacturing
facilities, GHG reporting is limited to process-related CO2 produced from the facility. There are
potentially other sources of GHG emissions at facilities that manufacture lime. The data to be
reported would depend on the threshold implemented. For reporting options for stationary fuel
combustion (CO2, CH4, and N2O),, refer to EPA-HQ-OAR-2008-0508-004. In some cases, such
as with CEMs, a reporting option may estimate process CO2 emissions and combustion related
CO2 emissions.
8.1.1 Option 1: Simplified Emissions Calculation
For the simplified emissions calculation, the facility would report its lime production in addition
to GHG emissions.
8.1.2 Option 2: Input-based Approach
For the input method, in addition to GHG emissions the facility would report its carbonate
consumption, lime kiln dust production, and the fraction of calcination achieved for each
carbonate input and lime kiln dust in addition to calculated GHG emissions.
8.1.3 Option 3: Emissions Based on Lime Type (default factors)
The default output-based method would require reoporting of: annualjime production by lime
type, default emission factors, total annual CO2 process emissions from all kilns, number of
kilns, total lime production for each kiln (by type), total calcined byproducts/wastes produced by
each kiln, correction factor for byproducts/waste products for each kiln, chemical composition
analyses (by lime type) and the number of operating hours in the calendar year, in addition to
calculated GHG emissions. These information could be collected on a weekly, monthly, or
quarterly basis.
8.1.4 Option 4: Emissions Based on Lime Type (NLA method)
The NLA output-based method requires reoporting of: annualjime production by lime type,
calculated emission factors, total annual CO2 process emissions from all kilns from monthly
averages, number of kilns, total lime production for each kiln (by type) by month, total calcined
byproducts/wastes produced by each kiln by month, correction factor for byproducts/waste
products for each kiln, chemical composition analyses by month, and the number of operating
hours in calendar year in addition to calculated GHG emissions.
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8.1.5 Option 5: Direct Measurement using Continuous Emission Monitoring Data
(CEMS)
For options based on direct measurement, using a CEMS, the GHG emissions are directly
measured at the point of emission.
For direct measurement using CEMS, the facility would report the GHG emissions measured by
the CEMS for each monitored emission point and should 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 might be required to 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);
Each type of raw material used and each type of product produced in the unit during the
report year;
The calculated CC>2, CH4, 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
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.
8.2 Other Information to be Reported
In order to check the reported GHG emissions for reasonableness and for other data quality
considerations, additional information about the emission sources is needed. It is recommended
that, in addition to CC>2 emissions, each reporting lime facility should also report lime generation
and, if applicable, CC>2 combustion annual quantities. Additionally, it is recommended that the
data pertaining to a specific option also be submitted with the annual report.
8.3 Additional Data to be Retained Onsite
Facilities should be required to retain data concerning monitoring of GHG emissions onsite for a
period of 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, calibration, and quality assurance records. Process data including process raw material and
product feed rates and carbonate contents could also be retained on site for a period of at least
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Technical Support Document for the Lime Sector: Proposed Rule for Mandatory Reporting of Greenhouse Gases
three 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.
9. References
Australian DCC (2007). National Greenhouse and Energy Reporting System: Technical
Guidelines for the Estimation of Greenhouse Emissions and Energy at Facility Level.
Commonwealth of Australia. Canberra, Australia.
http://www.climatechange.gov.au/reporting/guidelines/
Climate Registry (2007). General Reporting Protocol for the Voluntary Reporting Program. The
Climate Registry, Draft for Public Comment. October 29, 2007. Available online at
http://www.theclimateregistry.org/downloads/Draft_GRP.pdf
Environment Canada (2006). Facility Greenhouse Gas Emissions Reporting Program. Available
online at http://www.ec.gc.ca/pdb/ghg/guidance/calcu_pro_e.cfm. Accessed on April 30, 2008.
European Commission (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. European Commission, Official Journal of the
European Union. Brussels, Belgium.
European Commission (2004). Commission Decision of 29 January 2004 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. European Commission, Official Journal of the
European Union. Brussels, Belgium.
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.
Miller, M. Michael (2008). Personal Communication between M. Michael Miller of USGS and
Tristan Kessler of ICF International. May 13, 2008.
National Lime Association (2008). C02 Emissions Calculation Protocol for the Lime Industry.
Available online at http://www.climatevision.gov/sectors/lime/pdfs/lime_protocol.pdf
U.S. DOE (2007) Technical Guidelines Voluntary Reporting of Greenhouse Gases (1605(b))
Program. Available online at
http://www.pi.energy.gov/enhancingGHGregistry/documents/January2007_1605bTechnicalGuid
elines.pdf
U.S. EPA (2008a) Acid Rain Program Regulations: Part 75. Available online at
http://www.epa.gov/airmarkets/emissions/consolidated.html.
U.S. EPA (2008b) Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990-2006. U.S.
Environmental Protection Agency, Washington D.C. USEPA #430-R-08-005.
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U. S. EPA (2007). Climate Leaders Greenhouse Gas Inventory Protocol: Design Principles,
Chapter 7 "Managing Inventory Quality". Available online at
http://www.epa.gov/climateleaders/documents/resources/design_princ_ch7.pdf.
U.S. EPA (2006) Draft Version of the Lime Plant Database. U.S. Environmental Protection
Agency, Washington D.C.
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. Available
online at 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 (2007) Minerals Yearbook: Lime Annual Report. U.S. Geological Survey, Reston, VA.
Available at: http://minerals.usgs.gov/minerals/pubs/commodity/lime/mybl-2007-lime.pdf
WRI &WBCSD (2008) Calculating CO2 Emissions from the Production of Lime. Version 2.0.
World Resource Institute and World Business Council for Sustainable Development's
Greenhouse Gas Protocol. Available online at http://www.ghgprotocol.org/calculation-
tools/lime-sector
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