Soda Ash Manufacturing Subpart CC, Greenhouse Gas Reporting Program


Soda Ash Manufacturing
Subpart CC, Greenhouse Gas Reporting Program
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Under the Greenhouse Gas Reporting Program (GHGRP), owners or operators of facilities that contain
soda ash manufacturing (as defined below) must report emissions from soda ash manufacturing processes
and all other source categories located at the facility for which methods are defined in the rule. Owners
and operators are required to collect emission data; calculate GHG emissions; and follow the specified
procedures for quality assurance, missing data, recordkeeping, and reporting per the requirements o f 40
CFR 98 Subpart CC - Soda Ash Manufacturing.
How Is This Source Category Defined?
A soda ash manufacturing facility is any facility that produces soda ash by calcining trona, calcining
sodium sesquicarbonate, or by using a liquid alkaline feedstock process that directly produces carbon
dioxide (CO2).
In the context of the soda ash manufacturing sector, "calcining" means the thermal/chemical conversion
of the bicarbonate fraction of the feedstock to sodium carbonate.
What Greenhouse Gases Must Be Reported?
Soda ash manufacturing facilities must report CO2 process emissions from each soda ash manufacturing
line.
In addition, each facility must report GHG emissions for any other applicable source categories for which
calculation methods are provided in other subparts of the rule. For example, facilities must report CO2,
nitrous oxide (N2O), and methane (CH4) emissions from each stationary combustion unit on site by
following the requirements of 40 CFR part 98, subpart C (General Stationary Fuel Combustion Sources).
Please refer to the relevant information sheet for a summary of the rule requirements for calculating and
reporting emissions from any other applicable source categories located at the facility.
How Must Greenhouse Gas Emissions Be Calculated?
For CO2 emissions from soda ash manufacturing lines, facilities must use one of the following methods,
as appropriate:
•	Soda ash manufacturing lines that meet the conditions of § 98.33(b)(4)(ii) or § 98.33(b)(4)(iii)
must report using a continuous emission monitoring system (CEMS) and follow the Tier 4
methodology of 40 CFR part 98, subpart C to report combined CO2 emissions from calcination
and fuel combustion.
•	For other soda ash manufacturing lines, reporters can elect to use one of the following:
o Install and operate a CEMS to measure combined process and combustion CO2 emissions
according to the requirements specified in 40 CFR part 98, subpart C.
o Calculate CO2 process emissions using one of three alternative methods, as applicable:
• Trona input method. Calculate calcination emissions using the following
measurements:
o Monthly mass of trona input.
o The monthly inorganic carbon in the trona based on weekly composite analysis.
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• Soda ash output method. Calculate calcination emissions using the following
measurements:
o Monthly mass of soda ash produced,
o The monthly inorganic carbon in the soda ash.
• Site-specific emission factor method. Can only be used to calculate emissions from the
liquid alkaline feedstock process through an annual performance test using:
o Direct measurements of hourly CO2 concentration at process vents,
o Hourly stack gas volumetric flow rate from mine water stripper/evaporate.
A checklist for data that must be monitored is available at: https://www.cpa.gov/ghgrcporting/monitoring-
chccklist-subpart-cc-soda-ash-manufacturing.
What Information Must Be Reported?
In addition to the information required by the General Provisions at 40 CFR 98.3(c), each facility must
report the following information:
If a CEMS is used to measure CO2 emissions, then under this subpart the relevant information required
for the CEMS by subpart C (General Stationary Fuel Combustion Sources) and the following information
for each manufacturing line must be reported:
• Line identification number.
• Annual consumption of trona or liquid alkaline feedstock (metric tons).
• Annual production of soda ash (tons).
• Annual production capacity of soda ash (tons).
If a CEMS is not used to measure emissions, then the following information must be reported for each
manufacturing line:
• Line identification number.
• Annual process CO2 emissions (metric tons).
• Annual soda ash production (tons).
• Annual soda ash production capacity (tons).
• Method used to calculate CO2 emissions for each manufacturing line (trona input method, soda ash
output method, or site-specific emission factor method).
• Number of manufacturing lines used to produce soda ash.
• If producing soda ash using the liquid alkaline feedstock process and using the site-specific
emission factor method, report the following relevant information:
o Stack gas volumetric flow rate during performance test (dscfm).
o Hourly CO2 concentration during performance test (percent CO2).
o CO2 emission factor (metric tons CC^/metric tons of process vent flow from mine water
stripper/evaporator).
o CO2 mass emission rate during performance test (metric tons/hour),
o Average process vent flow from mine water stripper/evaporator during performance test
(pounds/hour).
o Annual process vent flow rate from mine water stripper/evaporator (thousand pounds/hour).
• Number of times that missing data procedures were used for the following parameters:
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o Trona or soda ash (number of months),
o Inorganic carbon contents of trona or soda ash (weeks).
o Process vent flow rate from mine water stripper/evaporator (number of months).
Facilities must enter required data into the electronic Greenhouse Gas Reporting Tool (e-GGRT) to be
reported in the annual report, and must also enter into e-GGRT" s Inputs Verifier Tool (IVT) the inputs to
emission equations for which reporting is not required. IVT uses these entered data to calculate the
equation results.
When and How Must Reports Be Submitted?
Annual reports must be submitted by March 31 of each year, unless the 31st is a Saturday, Sunday, or
federal holiday, in which case the reports are due on the next business day. Annual reports must be
submitted electronically using e-GGRT. the GHGRP's online reporting system. Additional information
on setting up user accounts, registering a facility and submitting annual reports is available at
https ://ccdsupport. com/ confluence/.
When Can a Facility Stop Reporting?
There are several scenarios under which a facility may discontinue reporting. These scenarios are
summarized in the Subpart A Information Sheet as well as in an FAQ.
For More Information
For additional information on Subpart CC, visit the Subpart CC Resources webpage. For additional
information on the Greenhouse Gas Reporting Program, visit the Greenhouse Gas Reporting Program
Website, which includes information sheets on other rule subparts, data previously reported to the
Greenhouse Gas Reporting Program, training materials, and links to frequently asked questions.
This document is provided solely for informational purposes. It does not provide legal advice, have
legally binding effect, or expressly or implicitly create, expand, or limit any legal rights, obligations,
responsibilities, expectations, or benefits in regard to any person. The series of information sheets is
intended to assist reporting facilities/owners in understanding key provisions of the Greenhouse Gas
Reporting Program.
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