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

-------
Technical Support Document for the Ferroalloy Production Sector: Proposed Rule for Mandatory Reporting of
Greenhouse Gases
CONTENTS
1.	Industry Description	1
2.	Total Emissions	3
2.1	Combustion Emissions	3
2.2	Process Emissions	4
3.	Review of Existing Programs and Methodologies	5
3.1	2006 IPCC Guidelines	5
3.1.1	Process-related CO2 Emissions	5
3.1.2	Process-related CH4 Emissions	8
3.2	U.S. EPA's Inventory of U.S. Greenhouse Gas Emissions and Sinks	9
3.3	Australian National Government's Greenhouse and Energy Reporting Program	9
3.4	Canadian Mandatory Greenhouse Gas Reporting Program	9
4.	Options for Reporting Threshold	10
4.1	Options Considered	10
4.2	Emissions and Facilities Covered Per Option	10
4.2.1	Combustion Emissions	10
4.2.2	Process Emissions	10
4.2.3	Emissions Thresholds	11
5.	Options for Monitoring Methods	12
5.1	Option 1: Simplified Emission Calculation	12
5.2	Option 2: Facility-Specific Carbon Balance Calculation	12
5.3	Option 3: Facility-Specific Emission Factor Using Stack Test Data	12
5.4	Option 4: Direct Measurement Using CEMS	14
6.	Procedures for Estimating Missing Data	15
6.1	Procedures for Option 1: Simplified Emission Calculation	15
6.2	Procedures for Option 2: Facility-Specific Carbon Balance Calculation	15
6.3	Procedures for Option 3: Facility-Specific Emission Factor Using Stack Test Data	15
6.4	Procedures for Option 4: Direct Measurement Using CEMS	15
7.	QA/QC Requirements	16
7.1	Combustion Emissions	16
7.2	Process Emissions	16
7.3	Methods Using Stack Test Data	16
7.4	Methods Using CEMS	16
7.5	Data Management	17
8.	Types of Emission Information to be Reported	18
8.1	Types of Emissions to be Reported	18
8.2	Additional Data to be Retained Onsite	18
9.	References	19

-------
Technical Support Document for the Ferroalloy Production Sector: Proposed Rule for Mandatory Reporting of
Greenhouse Gases
1. Industry Description
A ferroalloy is an alloy of iron with at least one other metal such as chromium, silicon,
molybdenum, manganese, or titanium. The ferroalloy production source category is defined to
consist of facilities that produce either ferroalloys or silicon metal. Ferroalloys are used
extensively in the iron and steel industry to impart distinctive qualities to stainless and other
specialty steels, and serve important functions during iron and steel production cycles. Silicon
metal is included in the ferroalloy metals category due to the similarities between its production
process and that of ferrosilicon. Silicon metal is used in alloys of aluminum and in the chemical
industry as a raw material in silicon-based chemical manufacturing.
The basic process used at U.S. ferroalloy production facilities is a batch process in which a
measured mixture of metals, carbonaceous reducing agents, and slag forming materials are
melted and reduced in an electric arc furnace (EAF). Molten alloy tapped from the EAF is casted
into solid alloy slabs which are further mechanically processed for sale as product. The molten
slag is tapped from the EAF, and then either further processed for sale as a product or disposed
in landfill.
The carbonaceous material used to reduce the ore in the EAF is generally coal or coke. However,
other carbon containing materials such as charcoal and wood can be used as primary or
secondary carbon sources. These carbon materials are charged into the EAF together with the
raw ore. While the submerged-arc open-top EAF is most commonly used to produce ferroalloys,
this furnace can also be closed or semi-open (IPCC 2006). The open-top consists of a cup-shaped
steel shell below a hood, which acts to collect fumes from the process and is approximately 1
meter above the bottom shell (Sjardin 2003). To heat the contents of the furnace, usually three
prebaked graphite electrodes or consumable Soderberg electrodes are suspended in the charge
material in the bottom shell, and electric currents are passed from one electrode to another.
Electricity passes between electrodes through electric arcs. Heat is generated through both the
electrodes and resistance from the charge materials. As the charge materials are heated, the coke
(or other carbon reducing agents) and the electrodes are consumed and the metallic oxides are
reduced.
There are approximately 14 U.S. ferroalloy production facilities (Table 1). Nine U.S. facilities
produce ferrosilicon, silicon metal, ferrochromium, ferromanganese, or silicomanganese alloys.
The U.S. production of ferrosilicon (25%-55% Si, and 56% 95% Si), and silicon metal alloys in
2006 totaled 400,700 metric tons (mt). Of this total, ferrosilicon (25%-55% Si) accounted for
164,000 mt, ferrosilicon (56% 95% Si) for 88,700 mt, and silicon metal for 148,000 mt (U.S.
EPA 2008). Four companies contributed to this production with a total of six plants operating in
the United States. In 2006, an additional three facilities produced ferrochromium,
ferromanganese, or silicomanganese. Finally, five additional facilities produce ferromolybdenum
and ferrotitanium. No production capacity information was available for these 5 facilities.
1

-------
Technical Support Document for the Ferroalloy Production Sector: Proposed Rule for Mandatory Reporting of
Greenhouse Gases
Table 1. U.S. Ferroalloy Production Facilities
Facility
Ferroalloy
Produced
Production Capacity
(metric tons per year)
Plant 1
Ferrosilicon
10,000
Silicon metal
29,000
Plant 2
Ferrosilicon
38,500
Silicon metal
38,500
Plant 3
Silicon metal
28,500a
Plant 4
Ferrosilicon
102,100 a
Plant 5
Ferrosilicon
102,100 a
Plant 6
Silicon metal
52,000
Plant 7
Ferrochromium
20,000
Plant 8
Ferromanganese
100,000
Silicomanganese
100,000
Plant 9
Silicomanganese
150,000
Plant 10
Ferromolybdenum or
ferrotitanium
(b)
Plant 11
Ferromolybdenum or
ferrotitanium
(b)
Plant 12
Ferromolybdenum or
ferrotitanium
(b)
Plant 13
Ferromolybdenum or
ferrotitanium
(b)
Plant 14
Ferromolybdenum or
ferrotitanium
(b)
a Production capacity estimated.
b Production information not available.
Source: USGS 2005, USGS 2006, and personal communication with USGS Commodity
Specialists.
2

-------
Technical Support Document for the Ferroalloy Production Sector: Proposed Rule for Mandatory Reporting of
Greenhouse Gases
2. Total Emissions
Ferroalloy production results in both combustion and process-related GHG emissions. The major
source of GHG emissions from a ferroalloy production facility are the process-related emissions
from the EAF operations. These GHG emissions, which consist primarily of carbon dioxide
(CO2) with smaller amounts of methane (CH4), result from the reduction of the metallic oxides
and the consumption of the graphite (carbon) electrodes during the process (discussed further in
Section 4.2).
Total nationwide GHG emissions from ferroalloy production in the United States for the year
2006 were estimated to be approximately 2,343,990 metric tons CO2 equivalent (metric tons
CC>2e). This total GHG emissions estimate includes both the process-related emissions (CO2 and
CH4) resulting from EAF operations at these facilities and the additional combustion emissions
(CO2, CH4) from stationary combustion units at the facilities. Process-related GHG emissions
were 2,025,836 metric tons CC>2e(86 percent of the total emissions). The remaining 318,153
metric tons C02e emissions (14 percent of the total emissions) were combustion GHG emissions.
2.1 Combustion Emissions
For some equipment used at ferroalloy production facilities to prepare material for charging to
the EAF and to process the molten metal tapped from the EAF, the only source of carbon is the
natural gas or another fuel the burned in the unit to produce heat for drying, melting, or casting
operations. These types of stationary combustion units can include furnaces (other than EAFs
and induction furnaces which use electricity to produce heat for melting), rotary kilns, casting
machines, boilers, and space heaters. Ferroalloy production facility owners and operators would
report annual CO2, CH4, and N2O emissions from these combustion sources using one the GHG
reporting methods discussed in the Technical Support Document (TSD) for Stationary
Combustion Sources (refer to EPA-HQ-OAR-2008-0508-004).
3

-------
Technical Support Document for the Ferroalloy Production Sector: Proposed Rule for Mandatory Reporting of
Greenhouse Gases
2.2 Process Emissions
The production of all ferroalloys results in carbon monoxide (CO) emissions and, for ferrosilicon
and silicon metal production, CH4 emissions. The basic steps to produce ferroalloys involve
mixing raw ore, carbonaceous reducing agents, and slag forming materials in a furnace that heats
them to high temperatures for reduction and smelting. As the carbon contained in the electrodes
is consumed, it captures oxygen from the metal oxides and forms carbon CO emissions. The
metal oxides, having lost their oxygen, are reduced to molten base metals and combine to form
an alloy. The following is a representative reaction equation for the production of 50%
ferrosilicon (FeSi) (U.S. EPA 2008):
Fe203 + 2 Si02 + 7C -> 2FeSi + 7CO
In a closed-top EAF, the CO is either recovered and used for energy production, or it is flared,
both of which end as in-plant CO2 emissions (while these CO2 emissions may end as energy
emissions, they are attributed to process emissions because the primary reason for their
production was the creation of the alloy, not for the energy) (IPCC 2006; Sjardin 2003). In
semi-open or open-top EAFs, this CO burns between the charge surface and the hood through
infiltration of air, and produces CO2 (Sjardin 2003). This basic process results in CO2 emissions
for all ferroalloy production. In addition, when semi-open or open-top EAFs are used to produce
both ferrosilicon and silicon metal, the same process produces CH4 and N2O emissions.
4

-------
Technical Support Document for the Ferroalloy Production Sector: Proposed Rule for Mandatory Reporting of
Greenhouse Gases
3. Review of Existing Programs and Methodologies
Four existing GHG emissions reporting programs and methodologies were identified for
calculating GHG emissions from ferroalloy production: the 2006 Intergovernmental Panel on
Climate Change (IPCC) Guidelines for National Greenhouse Gas Inventories, the U.S. EPA's
Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990-2006, the Australian National
Greenhouse Gas Reporting Program, and the Canadian Mandatory Greenhouse Gas Reporting
Program.
3.1 2006 IPCC Guidelines
The 2006 IPCC Guidelines present three different methods (identified as "Tiers") for calculating
process-related CO2 and CH4 emissions from ferroalloy production (IPCC 2006).
3.1.1 Process-related CO2 Emissions
The IPCC Tier 1 method for process-related CO2 emissions is to multiply the applicable default
emission factor listed in Table 2 by ferroalloy product type times the total quantity of ferroalloy
product produced. The equation is as follows:
Eco2 = (MP, x EFf)
Where:
Eco2 = CO2 emissions, metric ton
MP, = Production of ferroalloy type z, metric ton
EF, = Default emission factor for ferroalloy type z, mtCCVmt specific ferroalloy
product (Table 2).
Table 2. IPCC Tier 1 C02 Emission Factors for Ferroalloy Production
Ferroalloy
Emission Factor
(mt CO2/ mt ferroalloy product)
Ferrosilicon 45% Si
2.5
Ferrosilicon 65% Si
3.6
Ferrosilicon 75% Si
4.0
Ferrosilicon 90% Si
4.8
Ferromanganese (7% C)
1.3
Ferromanganese (1% C)
1.5
Silicomanganese
1.4
Silicon metal
5.0
Ferrochromium
1.3
(1.6 with a sinter plant)
Note: Only those emission factors applicable to this analysis are presented.
Source: IPCC 2006
5

-------
Technical Support Document for the Ferroalloy Production Sector: Proposed Rule for Mandatory Reporting of
Greenhouse Gases
The IPCC Tier 2 method for estimating process-related CO2 emissions is considered more
accurate than the IPCC Tier 1 method and is based upon production and default emission factors
for carbonaceous reducing agents listed in Table 3. The equation is as follows:
E(X>2 — (Mreducing agent, i EF reducing agent, i) 2ft(More, ^ X CContentore, h) x (44/12)
~l~ (M slag forming material, / ^ CContent slag forming material,/) x (44/12)
-	Z/(M product./: CContCtlt product. /:) ^ (44/12)
-	(M non-product outgoing stream, / ^ CContent non-product outgoing stream, /) ^ (44/12)
Where:
Eco2 = CO2 emissions from ferroalloy production, metric ton
Mreducing agent,« = Mass of reducing agent z, metric ton
EFreducing agent, / = Emission factor of reducing agent z, mtC02/mt reducing agent
M 0re, h = mass of ore /z, metric ton
CContent ore, a = Carbon content in ore /z, mt C/mt ore
M slag forming material,/ = Mass of slag forming material /, metric ton
CContent siag forming material,/ = Carbon content in slag forming material /, mt C/mt material j
M product, /: = Mass of product k, metric ton
CContent product, = Carbon content in product k, mt C/ mt product k
M non-product outgoing stream, i = Mass of non-product outgoing stream /, metric ton
CContent non-product outgoing stream, / = Carbon content in non-product outgoing stream /, mt C/
mt non-product outgoing stream /
Table 3. IPCC Tier 2 C02 Emission Factors for Ferroalloy Production
Reducing Agent (usage)
Emission Factor
(mt CO2/ mt ferroalloy product)
Coal (for FeSi and Si metal)
3.1
Coal (for other ferroalloys)
(a)
Coke (for Si and FeSi)
3.3-3.4
Coke (for other ferroalloys)
(a)
Prebaked electrodes
3.54
Electrode Paste
3.4
Petroleum Coke
3.5
a IPCC Guidelines note that inventory compilers are encouraged to use
producer-specific values based on average blend of coal and/or coke for
each ferroalloy producer.
Source: IPCC 2006
6

-------
Technical Support Document for the Ferroalloy Production Sector: Proposed Rule for Mandatory Reporting of
Greenhouse Gases
The IPCC Tier 3 method estimates process related CO2 emissions based on facility-specific
emission factors for each carbonaceous agent and its mass. The equation is as follows:
E(X>2 — (M reducing agent, i * CContent reducing agent, i) * (44/12)
+ (M ore, h x CContent ore, h) x (44/12)
~l~ (M slag forming material, y X CContCtlt slag forming material. /) X (44/12)
-	(M product, k x eContent product, fe) x (44/12)
-	(M non-product outgoing stream, / X CContent non-product outgoing stream, /) X (44/12)
Where:
Eco2= CO2 emissions from ferroalloy production, metric ton
M reducing agent,«= Mass of reducing agent z, metric ton
CContent reducing agent,«= carbon content in reducing agent /, mt C/mt reducing agent
M ore, h = Mass of ore /z, metric ton
CContent ore, h = Carbon content in ore /z, mt C/mt ore
M slag forming material,/ = Mass of slag forming material j, metric ton
CContent siag forming material,/ = Carbon content in slag forming material j, mt C/mt material /
M product, k = Mass of product k, metric ton
CContent product, = Carbon content in product k, mt C/ mt product k
M non-product outgoing stream, /= Mass of non-product outgoing stream /, mt
CContent non-product outgoing stream, / = Carbon content in non-product outgoing stream /, mt C/ mt
44/12 = Constant for mass of CO2 emitted for each mass unit of total carbon used.
For the Tier 3 method, emission estimates are based on carbon contents of the reducing agents
actually used at the facility for the production processes. However, IPCC guidelines suggest that
the analysis be based on percentage of ash and volatiles where:
Fix C% = 100% - % Ash - % Volatiles
In this case, carbon contents of the reducing agents are calculated by the following equation:
CContent reducing agent, / F FixC, / Fvolatiles, / X Cv
Where:
CContent reducing agent, i = Carbon content in reducing agent z, mt C/mt reducing agent
F Fixe,« = Mass fraction of Fix C in reducing agent z',mt C/mt reducing agent
Fvoiatiies,« = Mass fraction of volatiles in reducing agent z, mt volatiles/mt reducing agent
Cv = Carbon content in volatiles, mt C/mt volatiles.
7

-------
Technical Support Document for the Ferroalloy Production Sector: Proposed Rule for Mandatory Reporting of
Greenhouse Gases
3.1.2 Process-related CH4 Emissions
The IPCC Tier 1 method for process-related CH4 emissions uses the same equation as the Tier 1
CO2 emission calculation with the default emission factors shown in Table 4. Emission factors
are available for only a smaller group of ferroalloy products.
EcH4 = £/ (MP/ X EFf)
Where:
Ech4 = CH4 emissions, metric ton
MP, = Production of ferroalloy type z, metric ton
EF, = Default emission factor for ferroalloy type z, mtCH4/mt specific ferroalloy
product (Table 4)
Table 4. IPCC Emission Factors for Tier 1 CH4 Emission Estimates
Ferroalloy Type
Emission Factor
(mt CH4/ mt ferroalloy product)
Si-metal
1.2
FeSi 90
1.1
FeSi 75
1.0
FeSi 65
1.0
Source: IPCC 2006
The IPCC Tier 2 method for process-related CH4 emissions estimates uses the same equation as
the IPCC Tier 1 method only using the default emission factors specific to the facility's EAF
operations as presented in Table 5.
Table 5. IPCC Emission Factors for Tier 2 CH4 Emission Estimates
Ferroalloy Type
Emission Factor
(mt CH4/ mt ferroalloy product)
Batch-charging
Sprinkle-Charging
Sprinkle-Charging
and > 750°C
Si-metal
1.5
1.2
0.7
FeSi 90
1.4
1.1
0.6
FeSi 75
1.3
1.0
0.5
FeSi 65
1.3
1.0
0.5
Source: IPCC 2006
The IPCC Tier 3 method for CH4 emissions estimates recommends taking physical
measurements of emissions.
8

-------
Technical Support Document for the Ferroalloy Production Sector: Proposed Rule for Mandatory Reporting of
Greenhouse Gases
3.2	U.S. EPA's Inventory of U.S. Greenhouse Gas Emissions and Sinks
The protocol used for the U.S. EPA's Inventory of U.S. Greenhouse Gas Emissions and Sinks
(US EPA 2008) to estimate GHG emissions from U.S. ferroalloy production facilities was the
IPCC Tier 1 method (described in Section 3.1).
3.3	Australian National Government's Greenhouse and Energy Reporting Program
The Australian National Government's Greenhouse and Energy Reporting Program requires
reporting of CO2 emissions from ferroalloy production facilities that emit at least
25,000 mtC02e, or produce or consume at least 100 terajoules of energy; or their corporate group
emits at least 125,000 mtCC^e, or it produces or consumes at least 500 terajoules of energy
(Australian DCC 2007). The method used for estimating emissions is based on the National
Greenhouse Account (NGA) default method, which calculates emissions based on the following
equation:
Ei = £Ac x ECc xEFc / 1000
Where:
Ei = Emissions of CO2 from the production of the metal, metric tons
Ac = Quantity of each carbon reductant used, metric tons
ECc = Energy content of the reductant, gigajoules per metric ton
EFC = Emission factor of each carbon reductant used, kilograms of C02e per
gigajoule
Facilities may use the default emission factor presented in Table 6, but the higher-order method
would be to develop facility-specific emission factors from the carbon content of the reducing
agent. This higher order method is similar in protocol to IPCC's Tier 3 method.
Table 6. Australian National Greenhouse Account Default Emission Factors
Carbonaceous
Agent
Energy
Content
(gross) Gj/Mt
Emission Factors3
(KgC02-e/Gj)
C02
ch4
Metallurgical coke
30
90
0.02
Coke oven coke
27
117.1
0.03
a Only those given emission factors that apply to this analysis are presented.
Source: Australia National Greenhouse and Energy Reporting System 2007)
3.4 Canadian Mandatory Greenhouse Gas Reporting Program
The Canadian Mandatory Greenhouse Gas Reporting Program requires reporting of CO2
emissions from ferroalloy producing facilities if they emit 100,000 mtCC^e or more. While an
equation is not provided, it is suggested that estimation methods be consistent with IPCC Tier
methods (EPA 2008; Environment Canada 2006).
9

-------
Technical Support Document for the Ferroalloy Production Sector: Proposed Rule for Mandatory Reporting of
Greenhouse Gases
4. Options for Reporting Threshold
4.1	Options Considered
Options considered for reporting threshold include mandatory GHG reporting from ferroalloy
production facilities based on GHG emission thresholds of 1,000, 10,000, 25,000, and 100,000
mtC02e. For this analysis, process and combustion emissions were estimated for ferroalloy
production facilities as presented in Section 4.2.
4.2	Emissions and Facilities Covered Per Option
4.2.1 Combustion Emissions
Nationwide combustion GHG emissions from ferroalloy production facilities were estimated
using data provided by U.S. Energy Information Administration Manufacturing Energy
Consumption Survey (MECS) (U.S. DOE 2005). The CO2 emission factors for on-site fossil
fuel combustion were derived using heat content and carbon content data presented in the
Inventory of U.S. Greenhouse Gas Emissions and Sinks 1990-2006. The CH4 and N2O emission
factors were derived from the 2006 IPCC Guidelines for National Greenhouse Gas Inventories
(IPCC 2006). The MECS data provided for NAICS code 331112 are listed in Table 7 by fuel
type along with CO2 emission estimates for the industry sector and CO2 emission estimates per
establishment. The number of ferroalloy production facilities was obtained from the U.S. Census
Bureau (2002). Fuels burned at the facilities were distillate fuel oil, natural gas, liquefied
petroleum and natural gases, coal, and other. The representative stationary combustion GHG
emission estimate of 35,350 mtC02e was used for each ferroalloy production facility.
Table 7. Fuel Consumption and C02 Emission Estimates for Ferroalloy Production

Residual
Fuel Oil
Distillate
Fuel Oil
Natural
Gas
LPG
and
NGL
Coal
Coke
and
Breeze3
Other"
Total
Energy Consumption
(TBtu)
0.0
0.5*
7.0
0.5*
2.0
0.0
2.0
0.0
CO2 Emissions
(mtC02e)
0
15,016
152,092
12,793
77,053
0
61,199
318,153
C02
Emissions/Facility
(mtC02e)
0
1,668
16,899
1,421
8,561
0
6,800
35,350
a Value is 0.5, but is excluded because assumed to be captured as raw material
b Emission estimates for "Other" are based on the emission factor for "Other Liquid"
4.2.2 Process Emissions
Nine different ferroalloy types are identified in the USGS Minerals Yearbook: Ferroalloys:
ferrochromium, ferromanganese, ferromolybdenum, ferronickel, ferrosilicon, silicon metal,
ferrotitanium, ferrotungsten, ferrovanadium. However, for the purpose of this analysis, process-
related GHG emissions can only be estimated for those alloy types for which the IPCC provides
emission factors, and for which industry production capacity information could be obtained from
either the USGS Minerals Yearbooks or personal communications with commodity specialists at
the USGS. While the IPCC Guidelines discuss ferrosilicon and silicon metal as releasing process
10

-------
Technical Support Document for the Ferroalloy Production Sector: Proposed Rule for Mandatory Reporting of
Greenhouse Gases
emissions of N2O, the IPCC Guidelines do not provide emission factors for estimating these
emissions.
Nationwide process-related CO2 emissions from U.S. ferroalloy production facilities were
estimated using the IPCC Tier 1 method (see Section 3.1). Production capacity data for the nine
U.S. facilities that produce ferrosilicon, silicon metal, ferrochromium, ferromanganese, or
silicomanganese alloys as presented in Table 1 and default emission factors in Table 2, by
ferroalloy product type, were used.
4.2.3 Emissions Thresholds
Table 8 presents the estimated emissions and number of facilities that would be subject to GHG
emissions reporting, based upon emission estimates using production capacity data for a total of
nine U.S. facilities that produce ferrosilicon, silicon metal, ferrochromium, ferromanganese, or
silicomanganese alloys. The five additional facilities that produce ferromolybdenum and
ferrotitanium alloys were not included in the analysis because no production data were available
to be able to estimate emissions. Table 8 shows that eight of the nine facilities exceed a threshold
of 100,000 metric tons C02e/year. All nine facilities exceed a threshold of 25,000 metric tons
C02e/year.
Table 8. Threshold Analysis for Ferroalloy Production Facilities
Threshold
Level
(mtC02e/yr)
Nationwide Annual GHG Emissions
(mtC02e/yr)
Total
Number
of
Facilities
Subject to GHG Reporting
Process
Emissions
Combustion
Emissions
Total
GHG Emissions
Facilities
mtC02e/yr
Percent
Number
Percent
100,000
2,025,836
318,153
2,343,990
9
2,276,639
97%
8
89%
25,000
2,025,836
318,153
2,343,990
9
2,343,990
100%
9
100%
10,000
2,025,836
318,153
2,343,990
9
2,343,990
100%
9
100%
1,000
2,025,836
318,153
2,343,990
9
2,343,990
100%
9
100%
11

-------
Technical Support Document for the Ferroalloy Production Sector: Proposed Rule for Mandatory Reporting of
Greenhouse Gases
5. Options for Monitoring Methods
As described in Section 4, ferroalloy production facilities can release both combustion and
process-related GHG emissions. The major source of GHG emissions from a ferroalloy
production facility are the process-related CO2 emissions from the EAF operations. This section
describes monitoring method options for estimating process-related GHG emissions from the
ferroalloy production source category.
5.1	Option 1: Simplified Emission Calculation
This is a simplified emission calculation method using the IPCC Tier 1 method described in
Section 3.1 to estimate CO2 and CH4 emissions. The method requires multiplying the amount of
each ferroalloy product type produced by the appropriate default emission factors shown in
Tables 2 and 3. This method may not fully capture emissions from all ferroalloy production
types, because the IPCC Guidelines provide default emission factors for the most common, but
not all types of ferroalloy production.
5.2	Option 2: Facility-Specific Carbon Balance Calculation
The monitoring option requires performing a monthly carbon balance using measurements of the
carbon content of specific process inputs and process outputs and the amounts of these materials
consumed or produced during a specified reporting period. This option is applicable to
estimating only CO2 emissions from an EAF, and is the IPCC Tier 3 method and the higher order
methods in the Canadian and Australian reporting programs. Implementation of this method
requires you to determine the carbon contents of carbonaceous material inputs to and outputs
from the EAFs. Facilities determine carbon contents through analysis of representative samples
of the material or from information provided by the material suppliers. In addition, the quantities
of these materials consumed and produced during production would be measured and recorded.
To obtain the CO2 emission estimate, the average carbon content of each input and output
material is multiplied by the corresponding mass consumed and a conversion of carbon to CO2.
The difference between the calculated total carbon input and the total carbon output is the
estimated CO2 emissions to the atmosphere. This method assumes that all of the carbon is
converted during the process. For estimating the CH4 emissions from the EAF, selection of this
option for estimating CO2 emissions would still require using the Option 1 method of applying
default emission factors to estimate CH4 emissions.
For this method, the facility owner or operator would report in addition to GHG emissions, the
facility ferroalloy product produced, carbon content of reducing agents consumed, and quantity
of carbon recovered for downstream use, if any. In addition, each facility owner or operator
would be required to conduct quality assurance (QA) of supplier-provided information on the
carbon content of the input materials by collecting a composite sample of material and sending it
to a third-party, independent laboratory for chemical analysis to verify the supplier's
information. This QA procedure could be conducted on a periodic basis (e.g., annually).
5.3	Option 3: Facility-Specific Emission Factor Using Stack Test Data
This monitoring method is applicable to certain ferroalloy production facility sources for which
the GHG emissions are contained within a stack or vent. If a ferroalloy production facility uses
an open or semi-open EAF depending on the capture effectiveness of the overhead (i.e., a
12

-------
Technical Support Document for the Ferroalloy Production Sector: Proposed Rule for Mandatory Reporting of
Greenhouse Gases
significant portion of CO2 emissions escape captured by the overhead hood and subsequent
discharge to a stack or vent), then another GHG emission estimation method other than direct
measurement may need to be applied.
The monitoring method uses CO2 emissions data from a stack test performed using U.S. EPA
reference test methods to develop a site-specific process emissions factor which is then applied
to quantity measurement data of feed material or product for the specified reporting period. This
method can offer a higher level of accuracy than either Options 1 or 2 since actual stack test data
are used for each facility to obtain facility-specific GHG emission factors. The performing of a
stack test requires additional cost and time to implement the method compared to Options 1 and
2. However, the method may not be appropriate for all ferroalloy production facility sources
depending on the site-specific operations conducted at the facility. A method using periodic,
short-term stack testing would be appropriate for those facilities where process inputs (e.g., feed
materials, carbonaceous reducing agents) and process operating parameters remain relatively
consistent over time. In cases where there is the potential for significant variations in the process
input characteristics or operating conditions, continuous measurements would be needed to
accurately record changes in the actual GHG emissions from the sources resulting from any
process variations.
To implement this method, a CO2 emissions measurement stack test would be performed
concurrently with measuring the input material feed rate or product output rate during the test.
For stack testing, sampling equipment is installed temporarily in the stack to collect a sample of
the stack gas for analysis to determine the CO2 concentration in the gas stream. During the test,
the flow rate of the stack gas is also measured allowing the calculation of the CO2 mass emission
rate for the source. The total annual CO2 process emissions for the source is calculated by
multiplying the calculated site-specific CO2 emission factor by the total amount of the
appropriate input material or product quantity, as applicable to the emissions factor, recorded for
the operation of the source during the specified reporting period.
The facility-specific emission factor would be required to be redetermined on a periodic basis
(e.g., annually) by performing a new stack test and recalculating the facility-specific CO2
emission factor. In addition, a new stack test and facility-specific CO2 emission factor
determination would be required whether there is a significant change in the source's process
input characteristics or operating conditions (e.g., changing the type or proportions of the
carbonaceous reducing agents used). The facility owner or operator would report for each
completed stack test the measured GHG concentrations in the stack gas, the monitored stack gas
flow rate for each monitored emission point, and the time period during which the stack test was
conducted. The process operating conditions (e.g., input material types and feed rates) during the
time period when the test was conducted would also be reported.
13

-------
Technical Support Document for the Ferroalloy Production Sector: Proposed Rule for Mandatory Reporting of
Greenhouse Gases
5.4 Option 4: Direct Measurement Using CEMS
Another monitoring method applicable to ferroalloy production facility sources for which the
GHG emissions are contained within a stack or vent is direct measurement using a continuous
emissions monitoring system (CEMS). Direct measurements of the GHG concentration in the
stack gas and the flow rate of the stack gas can be made using a CEMS. The difference between
this option and Option 3 is using a CEMS provides a continuous measurement of the emissions
while a stack test provides a periodic measurement of the emissions. Because a CEMS
continuously measures actual CO2 emissions from a given ferroalloy production facility source
when it is in operation, this method is the most accurate monitoring method for determining
GHG emissions from a specific source. The costs for installing and operating a CEMS for direct
measurements of GHG emissions from a given ferroalloy production facility would be higher
than for using one of the other monitoring method options.
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.
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. Under a CEMS approach, the
results of the recorded emissions measurement data would be reported annually.
14

-------
Technical Support Document for the Ferroalloy Production Sector: Proposed Rule for Mandatory Reporting of
Greenhouse Gases
6. Procedures for Estimating Missing Data
Procedures for estimating missing data vary depending on the monitoring method used for
determining annual GHG emissions from a source. Each of the options described in Section 5
would require a complete record of measured parameters as well as parameters determined from
company records that are used in the GHG emissions calculations (e.g., reducing agent carbon
contents). Therefore, whenever a quality-assured value of a required parameter is unavailable, a
substitute data value for the missing parameter must be used in the calculations.
6.1	Procedures for Option 1: Simplified Emission Calculation
If facility-specific production data is missing for one year, an average value using the production
data from the year prior the missing year may be calculated. Default emission factors are
available from the IPCC guidelines (IPCC 2006).
6.2	Procedures for Option 2: Facility-Specific Carbon Balance Calculation
When assuming a 100% conversion of C to CO2, no missing data procedures would apply
because this factor would be multiplied by the materials input, which are readily available. If the
amount of carbonaceous agent input is not available, a facility owner or operator would need to
extrapolate a value from previous years operating data taking into consideration any changes in
production or process.
6.3	Procedures for Option 3: Facility-Specific Emission Factor Using Stack Test Data
For a method requiring measurement of CO2 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 (US EPA 2005). The 2005
Guidance Document states 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. In
addition, according to the 2005 Guidance Document, a site-specific test plan would 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. The test plan for a stack test used to obtain
data for the purposes of emissions reporting would be made available for review prior to
performing the stack test, and the stack test results would be reviewed with respect to the test
plan prior to the data being deemed acceptable for the purposes of emissions reporting. 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.
6.4	Procedures for Option 4: Direct Measurement Using CEMS
For a method requiring direct measurement of CO2 emissions using CEMS, procedures for
management of missing data established by the U.S. EPA in 40 CFR Part 75 could be used.
These procedures for management of missing data are described in Part 75.35(a), (b), and (d). In
general, missing data from operation of the CEMS may be replaced with substitute data to
determine the CO2 flow rates or CO2 emissions during the period in which CEMS data are
missing.
15

-------
Technical Support Document for the Ferroalloy Production Sector: Proposed Rule for Mandatory Reporting of
Greenhouse Gases
7. QA/QC Requirements
Facility owners and operators could conduct quality assurance (QA) and quality control (QC) of
the information used for each GHG emissions determination including production and
consumption data, supplier information (e.g., carbon contents), and emission estimates
calculations performed. Facility owners and operators could be encouraged to prepare an in-
depth quality assurance and quality control plan which could include checks on production data,
the carbon content information received from the supplier and from the lab analysis, and
calculations performed to estimate GHG emissions. Several examples of QA/QC procedures are
described below.
7.1	Combustion Emissions
In general, for determining and reporting emissions (CO2, CH4, and N2O) from stationary
combustion sources operated at ferroalloy production facilities, facility owner and operators
would follow the guidelines described for the method options presented in the Stationary
Combustion Source TSD (refer to EPA-HQ-OAR-2008-0508-004). However, if a method
requiring measurement of CO2 emissions using either stack testing of a CEMS is selected for use
at ferroalloy production facilities to report GHG emissions from stationary combustion sources
that also release process-related GHG emissions, the reported GHG emissions will be the
combined combustion and process-related emissions. For these sources for which the CO2
emissions resulting from fuel combustion in the source are accounted for by the stack test or
CEMS data, the source would not need to be included with the other stationary combustion
sources at the ferroalloy production facility for which combustion CO2 emissions are addressed
according using one of the method options presented in the Stationary Combustion Source TSD.
7.2	Process Emissions
The QA/QC requirements vary depending on the monitoring method used for determining annual
GHG emissions from a source. Each use of each method option described in Section 5 requires
QA/QC measures appropriate to the particular methodology used to ensure proper emission
monitoring and reporting.
7.3	Methods Using Stack Test Data
For a method requiring measurement of CO2 emissions using stack testing (e.g., Option 3), the
stack test could be required to be performed according to the quality assurance guidelines and
data quality objectives established by the U.S. EPA, including the Clean Air Act National Stack
Testing Guidance (U.S. EPA 2005).
7.4	Methods Using CEMS
For a method requiring direct measurement of CO2 emissions using CEMS (Option 4), the
equipment could be tested for accuracy and calibrated as necessary by a certified third party
vendor. These procedures would 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 (EPA 2008a).
16

-------
Technical Support Document for the Ferroalloy Production Sector: Proposed Rule for Mandatory Reporting of
Greenhouse Gases
7.5 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 carbon content, assess representativeness of the carbon content
measurement by comparing values received from supplier and/or laboratory analysis with
IPCC default values.
•	Check for temporal consistency in the production data, carbon 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
17

-------
Technical Support Document for the Ferroalloy Production Sector: Proposed Rule for Mandatory Reporting of
Greenhouse Gases
8. Types of Emission Information to be Reported
Ferroalloy production facility owners and operators could report annual CO2, CH4, and N2O
emissions. Depending on the monitoring method selected (discussed in Section 5), additional
information could be reported to assist in the verification of the reported emissions. Such
information could include facility operation information routinely recorded at the facility such as
ferroalloy product production quantities, raw material quantities purchased and consumed, and
fossil fuel usage. In addition, facility owners and operators would report additional information
to assist in QA/QC of any site-specific GHG emissions data used for the reported emissions
determination.
8.1	Types of Emissions to be Reported
Ferroalloy production releases both process-related and combustion GHG emissions. The major
source of GHG emissions from a ferroalloy production facility are the process-related CO2
emissions and CH4 from the EAF operations.
8.2	Additional Data to be Retained Onsite
Owners and operators of facilities reporting GHG emissions could be required to retain certain
process configuration information and operating data used for their GHG emissions
determinations onsite for a period of at least three years from the reporting year. Process
configuration information to be reported includes combustion device types, numbers, and sizes,
and identification of process equipment using carbonenous input materials. Process operating
data to be reported includes process raw material feed rates and carbon contents, and ferroalloy
product production quantities. These data could be used to conduct trend analyses and potentially
to develop process or activity-specific emission factors for ferroalloy production facilities. For
method using stack testing, information and data to be reported include stack test reports and
associated sampling and chemical analytical data for the stack test. For method using emission
monitoring systems, information and data to be reported include measured GHG concentrations
and stack gas flow rates, calibration and quality assurance records.
18

-------
Technical Support Document for the Ferroalloy Production Sector: Proposed Rule for Mandatory Reporting of
Greenhouse Gases
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.
Environment Canada (2006). Facility Greenhouse Gas Emissions Reporting Program.
http://www.ec.gc.ca/pdb/ghg/guidance/calcu_pro_e.cfm. Accessed 4/30/2008
EPA (2008). Communication with EPA on alternative protocols. As cited in draft file: Metals
processes tables 040308for EPA.xls. Accessed 4/29/2008.
IPCC (2006) 2006 IPCC 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.
European Parliament (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.
Personal communication between ICF International's Charles Cebul and USGS Commodity
Specialist John Papp.
Personal communication between ICF International's Charles Cebul and USGS Commodity
Specialist Kim Shed.
Personal communication between ICF International's Charles Cebul and USGS Commodity
Specialist Lisa Corathers.
Personal communication between ICF International's Charles Cebul and USGS Commodity
Specialist Michael Magyar.
Sjardin, M. (2003) CO2 Emission Factors for Non-Energy Use in the Non-Ferrous Metal,
Ferroalloys and Inorganics Industry. Copernicus Institute. Utrecht, the Netherlands.
U.S. DOE (2005) 2002 Manufacturing Energy Consumption Survey. Prepared by Energy
Information Administration http://www.eia.doe.gov/emeu/mecs/mecs2002 24 Jan 2005.
Table3.2.
U.S. Census Bureau. 2002. 2002 NAICS Codes and Titles.
http://www.census.gov/epcd/naics02/naicod02.htm 23 Mar 2004.
US EPA (2003). Part 75, Appendix Bl, Available at
http ://www. epa. gov/ airmarkt/spm/rule/001000000B. htm.
19

-------
Technical Support Document for the Ferroalloy Production Sector: Proposed Rule for Mandatory Reporting of
Greenhouse Gases
U.S. EPA 2005. Clean Air Act National Stack Testing Guidance, U.S. Environmental Protection
Agency Office of Enforcement and Compliance Assurance, September 30, 2005,
www.epa.gov/compliance/resources/policies/monitoring/caa/stacktesting.pdf
U.S. EPA 2007. Climate Leaders, Inventory Guidance, Design Principles Guidance, Chapter 7
"Managing Inventory Quality". Available at
http://www.epa.gov/climateleaders/documents/resources/design_princ_ch7.pdf.
U.S. EPA (2008) Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990-2006. U.S.
Environmental Protection Agency, Washington D.C. USEPA #430-R-08-005.
USGS (2005) Minerals Yearbook: Ferroalloys Annual Report. U.S. Geological Survey, Reston,
VA. Available at:
http://minerals.usgs.gov/minerals/pubs/commoditv/ferroallovs/feallmvb05.pdf.
USGS (2006) Minerals Yearbook: Silicon Annual Report. U.S. Geological Survey, Reston, VA.
Available at: http://minerals.usgs.gov/minerals/pubs/commoditv/silicon/mvbl-2006-simet.pdf.
USGS (2006) Minerals Yearbook: Titanium Annual Report. U.S. Geological Survey, Reston,
VA. Available at: http://minerals.usgs.gov/minerals/pubs/commoditv/titanium/mvbl-2006-
titan.pdf.
20

-------