Cement Production

SEPA

Subpart H, Greenhouse Gas Reporting Program

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Under the Greenhouse Gas Reporting Program (GHGRP), owners or operators of facilities that contain
cement production processes (as defined below) must report emissions from cement production processes
and all other source categories located at the facility for which methods are defined in 40 CFR Part 98.
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 of 40 CFR Part 98 Subpart H - Cement Production.

How Is This Source Category Defined?

The cement production source category consists of each kiln and each in-line kiln/raw mill at any portland
cement manufacturing facility, including alkali bypasses and kilns and in-line kilns/raw mills that burn
hazardous waste.

What Greenhouse Gases Must Be Reported?

Cement production facilities must report the following emissions:

•	Carbon dioxide (CO2) process emissions from calcination in each kiln.

•	CO2 combustion emissions from each kiln.

•	Nitrous oxide (N2O) and methane (CH4) combustion emissions from each kiln. Report these
emissions under 40 CFR part 98 subpart C (General Stationary Fuel Combustion Sources). The
information sheet on General Stationary Fuel Combustion Sources summarizes the rule
requirements for calculating and reporting emissions from these units.

•	CO2, N2O, and CH4 emissions from each stationary combustion unit other than kilns. Report these
emissions under 40 CFR part 98 subpart C (General Stationary Fuel Combustion Sources).

How Must Greenhouse Gas Emissions Be Calculated?

Cement production facilities must calculate and report CO2 emissions from each kiln using one of the
following two methods:

•	For kilns that meet the requirements in 40 CFR 98.33(b)(4)(ii) or (b)(4)(iii) for continuous
emission monitoring systems (CEMS), the owner or operator must calculate and report the
combined CO2 emissions from calcination and fuel combustion by operating and maintaining a
CEMS to measure CO2 emissions in accordance with the Tier 4 calculation methodology of 40
CFR part 98 subpart C.

•	For other kilns, owners or operators can elect to either:

o Install and operate a CEMS to measure combined calcination and fuel combustion CO2

emissions according to the Tier 4 methodology specified in 40 CFR 98 subpart C, or
o Calculate and report annual process CO2 emissions as the sum of annual clinker
emissions and annual raw material emissions:

¦ Annual clinker emissions from each kiln are calculated using:

•	Monthly clinker production (measurement required).

•	A monthly kiln-specific clinker emission factor calculated from the
monthly carbonate and noncarbonate content of the clinker
(measurement required).

•	Quarterly cement kiln dust (CKD) not recycled, i.e., discarded
(measurement required).

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•	A quarterly kiln-specific CKD emission factor for CKD not recycled to
the kiln (measurement or default values).

¦ Annual raw material emissions are calculated using:

•	The annual consumption of raw materials or raw kiln feed.

•	The organic carbon content of the raw material or raw kiln feed (or a
default value of 0.2 percent of total raw material weight may be used).

A checklist for data that must be monitored is available at:
https://www.epa.gov/ghgreporting/subpart-h-checklist

Any portland cement manufacturing facility meeting the criteria 40 CFR 98.2(a)(1) through (3) in 2010 or
any calendar year thereafter must begin monitoring and reporting GHG emissions in accordance with the
methods specified in subpart H.

What Information Must Be Reported?

In addition to the information required by the General Provisions at 40 CFR 98.3(c), each portland cement
manufacturing facility must report the following information:

If a CEMS is used to measure CO2 emissions, report under this subpart the relevant information required
by 40 CFR 98.36 for the Tier 4 calculation methodology and the following information:

•	Monthly clinker production from each kiln.

•	Annual cement production from each kiln.

•	Number of kilns and number of operating kilns.

If a CEMS is not used to measure CO2 emissions, report the following information for each kiln:

•	Kiln identification number

•	Annual cement production.

•	Number of kilns and number of operating kilns.

•	Method used to determine non-calcined CaO and non-calcined MgO in clinker.

•	Method used to determine non-calcined CaO and non-calcined MgO in CKD.

•	Quarterly kiln-specific CKD CO2 emission factors (metric tons C02/metric ton CKD produced).

•	Name of raw kiln feed or raw material.

•	Number of times missing data procedures were used to determine the following information:

o Clinker production (number of months),
o Carbonate contents of clinker (number of months),
o Non-calcined content of clinker (number of months),
o CKD not recycled to kiln (number of quarters),
o Non-calcined content of CKD (number of quarters),
o Organic carbon contents of raw materials (number of times),
o Raw material consumption (number of months).

•	Method used to determine the monthly clinker production from each kiln.

•	Annual clinker production (metric tons)

•	Annual average clinker CO2 emission factor for the facility, averaged across all kilns (metric tons
C02/metric ton clinker produced).

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• Annual average CKD CO2 emission factor for the facility, averaged across all kilns (metric tons
CCh/metric ton CKD produced).

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 c-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 H, visit the Subpart H 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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