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

-------
                                     CONTENTS
1.      Industry Description	1
2.      Total Emissions	2
       2.1    Process Emissions	2
       2.2    Stationary Combustion	2
3.      Review of Existing Programs and Methodologies	2
       3.1    2006 IPCC Guidelines	3
       3.2    2008 U. S. Inventory of Greenhouse Gas Emissions and Sinks	3
       3.3    Government of Canada's Greenhouse Gas Reporting program	3
       3.4    Australian National Greenhouse and Energy Reporting System	3
       3.5    Technical Guidelines Voluntary Reporting of Greenhouse Gases (1605(b))
             Program	3
4.      Options Considered for Reporting Threshold	4
       4.1    Emissions Thresholds	4
       4.2    Capacity Thresholds	6
       4.3    No Emissions Threshold	6
5.      Options for  Monitoring Methods	7
       5.1    Option 1: Default Emission Calculation	7
       5.2    Option 2: Stack Testing	7
       5.3    Option 3: Direct Measurement	8
6.      Procedures for Estimating Missing Data	8
       6.1    Procedures for Option 1: Default Emission Calculation	8
       6.2    Procedures for Option 2: Stack Testing	9
       6.3    Procedures for Option 3: Direct Measurement	9
7.      QA/QC Requirements	9
       7.1    Stationary Emissions	9
       7.2    Process Emissions	9
             7.2.1  Continuous Emission Monitoring System (CEMS)	9
             7.2.2  Stack Test Data	9
       7.3    Data Management	10
8.      Types of Emission Information to be Reported	10
       8.1    Other Information to be Reported	11
       8.2    Additional Data to be Retained Onsite	11
9.      References	12
January 22, 2009

-------
1.     Industry Description
Soda ash (sodium carbonate, Na2COs) is a raw material utilized in numerous industries including
glass manufacturing, pulp and paper production, and soap manufacturing. Soda ash production in
2006 amounted to 11 million metric tons, an amount consistent with 2005 and 500,000 metric
tons (mt) more than was produced in 2002. Owing to a glut of soda ash on the market in 2006
approximately 17 percent of the soda ash industry's nameplate capacity was idled (USGS 2007).

The majority of the  11 million metric tons of soda ash produced is used for glass manufacturing
(USGS 2007). In the United States, trona ore, the raw material from which most American soda
ash is produced, is mined exclusively in Wyoming. Wyoming is home to five of the seven United
States soda ash  manufacturing facilities (Table 1). Nameplate capacity at the five Wyoming
facilities analyzed in this document is included in Table  1. The nameplate capacity of the
Wyoming units totals 12.3 million metric tons of soda ash per year.

The facility located  in California extracts soda ash from  sodium carbonate-bearing brines that are
carbonated. The CO2 utilized in the carbonating process is recycled and only results in small
fugitive emissions. Therefore, the CC>2 emissions are assumed to be zero, and thus, the California
facility is not accounted for in the threshold analysis.

The facility located  in Parachute, Colorado, was closed in September 2004 and no plans to restart
soda ash manufacturing have been reported. USGS reports that previously closed facilities are
being brought back  online (USGS 2007). No confirmation that the Parachute, CO facility will be
brought back on-line in the near future has been received. Therefore, the plant is not accounted
for in the threshold analysis.

                            Table 1. U.S. Producers of Soda Ash
Company
FMC Wyoming Corp.
FMC Wyoming Corp.
General Chemical Partners
OCI Chemical Corp.
Solvay Chemicals, Inc.
Total
Plant Location
Granger, WY
Green River, WY
Green River, WY
Green River, WY
Green River, WY

Nameplate Capacity
(million mt per year)
1.18
3.22
2.54
2.81
2.54
12.3
Source of Sodium Carbonate
Underground Trona Ore
Underground Trona Ore
Underground Trona Ore
Underground Trona Ore
Underground Trona Ore

Source: USGS Minerals Yearbook 2006 (http://minerals.usgs.gov/minerals/pubs/commoditv/soda_ash/mvb1-2006-
  sodaa.pdf)
January 22, 2009

-------
2.     Total Emissions
Emissions from natural soda ash facilities for 2006 were approximately 3,121,438 MMTCO2e.
These emissions were closely divided between process emissions of approximately 1.6 million
MMTCO26 and stationary combustion emissions of approximately 1.5 million MMTCO2e.

2.1    Process Emissions
As discussed above, the production of soda ash from mined trona ore emits CO2. Trona-based
production methods are collectively referred to as "natural production" methods. "Natural
production"  emits CO2 by calcining trona ore based on the following reaction:

       2Na2CO3.NaHCO3.2H2O (Trona) -> 3Na2CO3 (Soda Ash) + 5H2O + CO2

Calcining involves placing crushed trona ore into a kiln to convert sodium bicarbonate into crude
sodium carbonate that will later be filtered into pure soda ash. Following the formula, one mt
CO2 process emissions is produced for every 10.27 mt of trona consumed (IPCC 2006).

2.2    Stationary Combustion
Stationary combustion emissions of greenhouse gases from the production of soda ash are
limited to the fuel inputs used to fire ore crushers, coal  crushers, trona ore driers, industrial
boilers and other necessary equipment of the manufacturing process.  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.
3.     Review of Existing Programs and Methodologies
Emissions monitoring from the soda ash manufacturing sector are addressed in numerous
protocols and reporting programs.  Many programs and guidance documents, such as the U.S.
Greenhouse Gas Inventory (EPA 2008) and DOE's 1605(b) Reporting Program, contain specific
monitoring methods rather than use generic emissions factors and stoichiometric calculations.
The 2006 IPCC Guidelines for National Greenhouse Gas Inventories (IPCC 2006) presents three
methods (tiers) for addressing GHG emissions at soda ash manufacturing facilities classified
according to the extent of plant-level data that are available. Tier 1 methodology is based on
default values and national statistics, Tier 2 methodology is a facility-specific method that
utilizes either trona ore input or soda ash output as well as a facility-specific emissions factor,
and Tier 3 uses monitoring and direct measurement of CO2 emissions. The IPCC guidelines,
Australian Government's National Mandatory Greenhouse and Energy Reporting System,
Government of Canada's Greenhouse Gas Reporting program, U.S. Greenhouse Gas Inventory,
and DOE's 1605(b) Reporting Program are discussed in more detail below.
January 22, 2009

-------
3.1    2006 IPCC Guidelines
The IPCC considers two different methods for calculating process-related emissions from soda
ash manufacturing (IPCC 2006). The fractional purity of trona or soda ash is defined as the level
of inorganic carbon present in trona or soda ash. The Tier 1 method uses a default emission
factor per unit of output (either 0.0974 ton CCVton of trona ore consumed or 0.138 ton CCVton
natural soda ash produced) multiplied by production activity data (i.e., trona ore used in
production, or amount of natural soda ash produced). The default emission factor assumes  that
the fractional purity of each material is 100%. The Tier 2 method calculates process emissions
through facility-level  data collection (i.e., site-specific CO2 emission factor, site-specific trona
ore usage or soda ash production data, and measured fractional purity of the trona or soda ash).
The Tier 3 method uses CO2 data obtained through direct measurement (i.e., CEMS).

The IPCC Tier 1  method (utilizing the 0.0974 ton CCVton of trona ore consumed emission
factor) was used to determine process-related CO2 emissions from the facilities presented in
Table 2.

3.2    2008 U.S. Inventory of Greenhouse Gas Emissions and Sinks
The U.S. Greenhouse Gas Inventory system requires reporting of CC>2 emissions from soda ash
manufacturing. This program is not an industry reporting program but instead utilizes a
stoichiometric CC>2 emission factor (0.0974 tons CO2/ton of trona ore consumed) and annual
activity data (trona ore consumption) at the national level. The input data source used to calculate
emissions are stoichiometric CC>2 emission factor and trona ore consumed (both taken from
USGS 2006).

3.3    Government  of Canada's Greenhouse Gas Reporting program
The Government of Canada's Greenhouse Gas Reporting Program uses a similar approach  to the
2006 IPCC guidelines.

3.4    Australian National Greenhouse and Energy Reporting System
The Australian Government's National Greenhouse and Energy Reporting System requires
reporting of CC>2 emissions from soda ash manufacturing. Registration and reporting under  this
system is required for corporations if: they control facilities that emit at least 25,000 MMTCC^e,
or produce or consume at least 100 terajoules of energy; or their corporate group  emits at least
125,000 MMTCO26, or it produces or consumes at least 500 terajoules  of energy (Australian
DCC 2007). The methods for estimating emissions from soda ash manufacturing follow the
IPCC procedures.

3.5    Technical Guidelines Voluntary Reporting of Greenhouse Gases (1605(b)) Program
The DOE's 1605(b) Reporting Program is a voluntary inventory and emission reduction program
reporting of CC>2 emissions from soda ash manufacturing. The DOE's 1605(b) program
considers two different approaches for calculating process-related emissions from soda ash
manufacturing. The first approach uses a default emission factor per unit of output (either 0.0974
ton CO2/ton of trona ore consumed multiplied by activity data (trona ore used in production).
The second approach  calculates process emissions through facility-level data collection (i.e.,
direct emissions measurement).
January 22, 2009

-------
4.     Options Considered for Reporting Threshold
4.1    Emissions Thresholds
For the reporting of process CC>2 emissions from soda ash manufacturing, threshold options
considered included emissions-based thresholds of 100,000, 25,000, 10,000, and 1,000
MMTCO26 for combined combustion and process emissions. The results of the threshold
analysis are summarized in Table 2.

All production-based emission threshold levels were found to incorporate the entire soda ash
manufacturing sector. Table 2 provides the production-based emissions threshold analysis for the
soda ash manufacturing sector.

          Table 2. Production-Based Threshold Analysis for Soda Ash Manufacturing
Threshold
Level
(metric
tons
CO2e/yr)
100,000
25,000
10,000
1,000
Process
Emissions
(metric
tons
CO2e/yr)
1,626,095
1,626,095
1,626,095
1,626,095
Combustion
CO2
Emissions
(metric tons
CO2e/yr)
1,495,343
1,495,343
1,495,343
1,495,343
Total
National
Emissions
(metric tons
CO2e/yr)
3,121,438
3,121,438
3,121,438
3,121,438
Number
of
Entities
5
5
5
5
Emissions Covered
Metric
tons
CO2e/yr
3,121,438
3,121,438
3,121,438
3,121,438
Percent
100%
100%
100%
100%
Entities Covered
Number
5
5
5
5
Percent
100%
100%
100%
100%
This analysis estimated total emissions for the soda ash manufacturing sector of 3.1 MMTCC^e.
This total was the sum of process emissions of 1.6 MMTCC^e and combustion emissions that
totaled -1.5 MMTCC^e. All five facilities that have been identified surpass the 100,000
MMTCO26 reporting threshold.  The option of regulating all soda ash manufacturing facilities
regardless of their emissions profile is similar to the emissions threshold option because at each
threshold level all soda ash facilities would be regulated.
January 22, 2009

-------
Process emissions for this document were calculated using a stoichiometric emissions factor of
0.0974 metric tons CC>2 per ton of trona ore consumed (U.S. EPA 2008). The 16.7 million metric
tons of trona ore mined in Wyoming in 2006 (USGS 2007) were estimated to produce
approximately 1,626,095 MMTCC^e based on the following formula:
Where:
CC>2 Emissions = EF x AD



CC>2 Emissions = Emissions of CC>2 (metric tons)
EF = Emissions factor of 0.0974 metric tons CC>2 per ton trona ore mined
AD = Amount of trona ore mined (metric tons)
Stationary combustion CC>2 emissions for this document were calculated using fuel input data
from the National Renewable Energy Laboratory (NREL) Life-Cycle Analysis database (NREL
2007). Each fuel input estimate was multiplied by the amount of soda ash produced using the
trona-based method. Trona-based soda ash manufacturing was apportioned from total soda ash
production using nameplate capacity as a surrogate for facility production. By dividing the
nameplate capacity of non-trona-based production facilities (2.45 million short tons) by the total
nameplate capacity (16 million short tons) it was determined that 15 percent of total U.S. soda
ash production was non-trona-based. Therefore 85 percent (9.35 million mt) of total U.S. soda
ash production was trona-based. NREL Life-Cycle Analysis  fuel input estimates for bituminous
coal, distillate fuel oil, residual fuel oil, and natural gas are listed in Table 4 (i.e., the quantity of
fuel required for providing one short ton of soda ash).

Based on this stationary combustion CC>2 emissions were estimated to produce approximately
1,495,343 metric tons or 1.5 MMTCO2e.

                    Table 3. NREL Life-Cycle Analysis Fuel Input Estimates
Input
Coal
Distillate fuel oil
Residual fuel oil
Natural gas
Fuels Consumed per
Short Ton of Soda Ash Production
107.6 pounds
0.067 gallons
0.185 gallons
797.5 cubic feet
                      Source: NREL Life-Cycle Analysis (http://www.nrel.gov/lci/databaseA
January 22, 2009

-------
4.2    Capacity Thresholds
Three capacity threshold levels were considered for the soda ash manufacturing sector.  Capacity
is the largest amount of soda ash that a facility can produce on an annual basis. These thresholds
were 3, 2, and 1 million metric tons of soda ash produced per year.  The results of the capacity
threshold analysis are shown in Table 4.

              Table 4. Capacity Threshold Analysis for Soda Ash Manufacturing
Capacity
Threshold
Level
(metric
tons soda
ash/yr)
3,000,000
2,000,000
1,000,000
Process
Emissions
(metric tons
TCO2e/yr)
1,696,373
1,696,373
1,696,373
Number
of
Entities
5
5
5
Emissions Covered
Metric
tons
CO2e/yr
444,437
1,533,622
1,696,373
Percent
27%
94%
100%
Entities Covered
Number
1
4
5
Percent
20%
80%
100%
A threshold of 1,000,000 metric tons captures all facilities in the inventory. A threshold of
2,000,000 metric tons captures 94 percent of emissions, 80 percent of the facilities. A threshold
of 3,000,000 metric tons captures 27 percent of emissions, 20 percent of the facilities. Process
emissions for this document were calculated using a stoichiometric emissions factor of 0.138
metric tons CC>2 per ton of soda ash produced (IPCC). The 12.3 million metric tons of soda ash
production capacity in Wyoming in 2006 (USGS 2007) were estimated to produce approximately
1,696,373 MMTCO26 based on the following formula:
Where:
CC>2 Emissions = EF x AD



CC>2 Emissions = Emissions of CC>2 (metric tons)
EF = Emissions factor of 0.138 metric tons CC>2 per ton of soda ash produced
AD = Total nameplate capacity of soda ash produced (metric tons)
Combustion emissions for this analysis were considered to be the same as those used in the
production-based threshold analysis.

4.3    No Emissions Threshold
The no emissions threshold includes all soda ash manufacturing facilities regardless of their
emissions or capacity.
January 22, 2009

-------
5.     Options for Monitoring Methods
Three separate monitoring methods were considered for this technical support document: a
default emission calculation (Option 1), and direct measurement (Option 3 and Option 4).  All of
these options require annual reporting.

Options 3 and 4 would measure both process and combustion related CO2 emissions from soda
ash production.


5.1    Option 1: Default Emission Calculation
Option 1 follows the IPCC's Tier 2 protocol. The Tier 2 monitoring method offers the choice of
two options. The emissions can be  determined through knowledge of the trona ore input or the
soda ash output. To use either method, the quantity of material, the fractional purity of the
material and the default emission factor must be known. The equation for calculating emissions
is:

       CO2 Emissions = AD x FP x EF

Where:

       CO2 Emissions = process emissions of CO2 (metric tons)
       AD = Quantity of either trona ore input or soda ash output
       FP = Fractional purity of either trona ore input or soda ash output (as determined by the
                    inorganic carbon content)
       EF = Default emission factor per unit of trona ore input or soda ash output

The default emission factor per unit of trona ore input is 0.0974 mtCO2/mt of trona ore mined.
The default emission factor per unit of soda ash output in 0.138 mtCO2/mt soda ash produced
(IPCC 2006).

The IPCC Tier 2 protocol is the foundation for numerous other programs and guidance
documents around the world; both  Canada's Greenhouse Gas Reporting program and Australia's
National Greenhouse Gas Energy Reporting System refer to the IPCC's guidance.

The default stoichiometric emission factors for trona consumed or for soda ash produced are
applied either to the quantity of trona consumed or the amount  of soda ash produced and the
fractional purity of the trona or soda ash.  The fractional purity of trona or soda ash would be
determined by the level of the inorganic carbon present in trona using in-house total organic
carbon (TOC) analyzers or in soda ash using applicable test methods. Soda ash facilities are
conducting daily tests of fractional purity (Cole 2008).

5.2    Option 2: Stack Testing
For direct measurement using stack testing, sampling equipment would be periodically brought
to the site and installed temporarily in the stack to withdraw a sample of the stack gas and
January 22, 2009

-------
measure the flow rate of the stack gas.  Similar to CEMS, for stack testing the emissions are
calculated from the concentration of GHGs in the stack gas and the flow rate of the stack gas.
The difference between stack testing and continuous monitoring is that the CEMS data provide a
continuous measurement of the emissions while a stack test provides a periodic measurement of
the emissions.

Performing a stack test requires additional cost and time to implement the method compared to
Option 1.  However, the method may not be appropriate for all soda ash production facilities
depending on the site-specific operations at the facility. A method using periodic, short-term
stack testing would be appropriate for those facilities where process inputs (e.g., trona
composition and fuel types) and process operating parameters remain relatively consistent over
time.  In cases where significant variations in the process inputs characteristics or operating
conditions could occur, continuous measurements would be needed to accurately record changes
in the actual GHG emissions from the sources resulting from any process variations.

5.3    Option 3: Direct Measurement
Option 3 follows the IPCC's Tier 3 protocol. For industrial source categories for which the
process emissions and/or combustion GHG emissions are contained within a stack or vent, direct
measurement constitutes either measurements of the GHG concentration in the stack gas and the
flow rate of the stack gas using a Continuous Emissions Monitoring System (CEMS), or periodic
measurement of the GHG concentration in the stack gas and the flow rate of the stack gas using
periodic stack testing.  Under either a CEMS approach or a stack testing approach, the emissions
measurement data would be reported annually.

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.

6.     Procedures for Estimating Missing Data
Options and considerations for missing data under Option 2 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 (i.e., trona ore input, soda ash output, fractional purity analyses,
etc.).  Therefore, whenever a quality-assured value  of a required parameter is unavailable (e.g., if
a monitor or CEMS malfunctions during unit operation or if a required fuel input parameter is
not obtained), a substitute data value for the missing parameter must be used in the calculations.

6.1    Procedures for Option 1: Default Emission Calculation
For process sources that use a facility specific calculation no  missing data procedures would
apply because the emission calculation is derived from default emission factors and activity data.
Activity data such as production or consumption are readily available. Therefore, 100 percent
data availability would be required.
January 22, 2009

-------
6.2    Procedures for Option 2: Stack Testing
This monitoring method was not the chosen option under this rule and therefore no procedures
for estimating missing data are provided.

6.3    Procedures for Option 3: Direct Measurement
This monitoring method was not the chosen option under this rule and therefore no procedures
for estimating missing data are provided.

7.     QA/QC Requirements
Facilities should conduct quality assurance and quality control of the production and
consumption data, on-site fractional purity analyses, and emission estimates reported. Facilities
are encouraged to prepare an in-depth Quality Assurance Project Plan (QAPP) which would
include checks on production data, the carbon content information received from the supplier and
from the lab analysis, and calculations performed to estimate GHG emissions.  Several examples
of QA/QC procedures that can be included in the QAPP are listed below.

7.1    Stationary  Emissions
For QA/QC options for stationary combustion refer to EPA-HQ-OAR-2008-0508-004.

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

7.2.1   Continuous Emission Monitoring System (CEMS)
For units using CEMS to measure CO2 emissions, the equipment should be tested for accuracy
and calibrated as necessary by a certified third party vendor. These procedures should be
consistent in stringency and data reporting and documentation adequacy with the QA/QC
procedures for CEMS  described in Part 75 of the Acid Rain Program.

7.2.2   Stack Test  Data
U.S. EPA regulations for performance testing under 40 CFR § 63.7(c)(2)(i) state that before
conducting a required performance test, the owner/operator is required to develop a site-specific
test plan and, if required, submit the test plan for approval. The test plan is required to include "a
test program summary, the test schedule, data quality objectives, and both an internal and
external quality assurance (QA) program" to be  applied to the stack test. Data quality objectives
are defined under 40 CFR § 63.7(c)(2)(i) as "the pre-test expectations of precision, accuracy,  and
completeness of data."  Under 40 CFR § 63.7(c)(2)(ii), the internal QA program is required to
include, "at a minimum, the activities planned by routine operators and analysts to provide an
assessment of test data precision;  an example of internal QA is the sampling and analysis of
replicate samples." Under 40 CFR § 63.7(c)(2)(iii) the external QA program is required to
include, "at a minimum, application of plans for a test method performance audit (PA) during the
performance test." In addition, according to the  2005 Guidance Document, a site-specific test
plan should generally include chain of custody documentation from sample collection through
January 22, 2009

-------
laboratory analysis including transport, and should recognize special sample transport, handling,
and analysis instructions necessary for each set of field samples (US EPA 2005).

7.3    Data Management
Data management procedures should be included in the QAPP.  Elements of the data
management procedures plan are as follows:

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

    •  Maintain data documentation, including comprehensive documentation of data received
       through personal communication:
        o  Check that changes in data or methodology are documented.

8.     Types of Emission Information to be Reported
Based on the existing programs and the emission sources at soda ash manufacturing facilities,
GHG reporting for these facilities is limited to CCh, CH4, and N2O.  Soda ash facilities should
report both process (CO2) and combustion related (CC>2, CH4, and N2O) greenhouse gas
emissions.  The data to be reported may very depending on monitoring options selected.
However,  a soda ash manufacturing facility should report its annual trona consumption, number
of soda ash manufacturing lines, fractional purity of trona consumed or soda ash produced,
annual soda ash manufacturing, annual soda ash production capacity, electricity usage (kilowatt-
January 22, 2009                                                                        10

-------
hours), and annual operating hours. For reporting options for stationary combustion refer to
EPA-HQ-OAR-2008-0508-004.

8.1    Other Information to be Reported
Each soda ash manufacturing facility should report the following:

    •  Total annual CC>2 process emissions from all soda ash manufacturing lines (metric tons);
    •  Number of soda ash manufacturing lines;
    •  Annual soda ash production (metric tons) and annual soda ash production capacity;
    •  Annual consumption of trona ore from monthly measurements (metric tons);
    •  Fractional purity (i.e., inorganic carbon content) of trona or soda ash (by daily
       measurements and by monthly average);
    •  Electricity usage (kWh/yr); and
    •  Number of operating hours in calendar year.

8.2    Additional Data to be Retained Onsite
Facilities should be required to retain data concerning monitoring of GHG emissions onsite for a
period of at least five years from the reporting year. EPA could use such data to conduct trend
analyses and potentially to develop process or activity-specific emission factors for the process.
Facilities should retain the following information:

    •  Monthly production of soda ash (metric tons);
    •  Monthly consumption of trona (metric tons);
    •  Daily analyses for inorganic carbon content of trona or soda ash (as fractional purity);
    •  QAPP and related QA/QC records;
    •  Electricity usage, kWh/yr; and
    •  Operating hours in calendar year
January 22, 2009                                                                        11

-------
9.     References
RTI (2008) Contact report.  Summary of information gathered by Jeff Cole in discussions with
representatives from OCI Chemical Corporation and FMC Wyoming Corporation. June 2008.

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

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.

NREL (2007) Life-Cycle Analysis Database. National Renewable Energy Laboratory, Golden,
CO. http://www.nrel.gov/lci/database/

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

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

U.S. EPA (2005) Clean Air Act National Stack Testing Guidance, U.S. Environmental Protection
Agency Office of Enforcement and Compliance Assurance, September 30, 2005, Page 11.
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: Soda Ash Annual Report. U.S. Geological Survey,  Reston,
VA. Available online at: http://minerals.usgs.gov/minerals/pubs/commodity/soda_ash/mybl-
2007-sodaa.pdf
January 22, 2009                                                                      12

-------