## 1



## MEMORANDUM

DATE: September 201 4

TO: Docket EPA

- HQ

- OAR

- 2010

- 0929

FROM: Lisa Grogan

- McCulloch

SUBJECT: Final Evaluation of Competitive Harm f rom Disclosure of “ Inputs to Equations ” Data Elemen ts Deferred to March 31, 2015

Introduction and Purpose of Analysis

In the August 25, 2011

, final rule deferring reporting of certain inputs to emission equations under 40 CFR part 98 (76 FR 530 57) (hereafter referred to as “‘i nputs to equations ’ data elements”) until March 31, 2015

, the EPA expressed its intent to further evaluate the “inputs to equations” data elements to determine which, if any, could result in competitive harm if made publicly available. The EPA outlined a four

- step process for this evaluation in the final rule and in a supporting memorandum entitled “Process for Evaluating and Potentially Amending Part 98 Inputs to Emission Equations” (docket EPA

- HQ

- OAR

- 2010

- 0929).

T he EPA docum en ted the res ults of the review undertaken for the second step of this evaluation

process (i.e., the EPA’s analysis of the competitive harm that would likely result from reporting of “inputs to equations” data elements ) in its memorandum “ Evaluation of Competitive Harm
from Disclosure of ‘ Inputs to Equations ’ Data Elements Deferred to March 31, 2015 ,” August 2013, in support of the proposed September 11, 2013 rulemaking amending Part 98 to address this competitive harm ( 78 FR 55994 )

. This review was undertaken for 2 7 of the 28 subparts of the Greenhouse Gas Reporting Program (GHGRP) with “inputs to equations.” 1 

## This
memorandum is the final memorandum

, which takes into consideration public comments
submitted on the September 11, 2013 proposed rulemaking.

Th e evaluation of competitive harm includes :

 Part 1 : An evaluation of the current market structures for sectors required to report “inputs to equations” data elements

, to determine whether conditions exist within the market structure s such that the release of the data c ould result in competitive harm, and

1 

### The review was not conducted for 2015 data inputs in subpart I because reporting of the “ inputs to equations ” data elements for that subpart was addressed in a separate proposed action [see 78 FR 68162 , November 13, 2013 ]. Additionally, t he evaluation of the subpart C “inputs to equations” in this memorandum encompasses the one subpart A “input to equation” data element. As a result, the one subpart A “input to equation” is not listed explicitly in this memorandum.

## 2



##  Part 2 : For those sectors for which the market structure analysis determined that reporting of the “inputs to equations” data elements c ould result in competitive harm, a n e valuati on of each individual “inpu ts to equations” data element s to determine whether its release would be likely to cause competitive harm.

The EPA’s evaluation of current market structures is presented in Part 1 of this memorandum

. For all sectors in which the market structure analysis summarized in Part 1 determined that the
conditions exist within the market such that firms could use released “inputs to equations” data
elements to gain a competitive advantage, the EPA proce e ded to evaluate each individual “input s to equations” data element. Part 2 of this memorandum presents an evaluation of each individual “inputs to equations” data element to determine whether potential release would be likely to

cause substantial competitive harm.

## 3



## Part 1: Evaluation of Market Structures

1.0 Introduction

The following section s describes the overall process used to assess the market structures that exist within the different subparts of 40 CFR part 98 with “ inputs to equations” data elements , to
determine whether conditions exist within the market such that competitive harm could occur
should “inputs to equations” data elements be released to the public. Section 2 .0 summarizes the connection between market structure and the potential for information to caus e competitive
harm. Section 3.0 presents the process used for the assessment. Section 4.0 presents the results of
the market structure assessment for each subpart evaluated

. Section 5.0 presents a summary of the overall results of this analysis.

2 .0 Import ance of Market Structure

Market structure affects firms’ ability to use information about other firms in their market. Market structure is defined in terms of the number of firms supplying a commodity in the market, and the degree of control that individua l firms have over the price s they obtain for their product s . The market, in turn, is defined in terms of the commodity marketed and the geographic scope of the market.

Competitive markets are characterized by many suppliers and products that are identical or nearly identical, in terms of product characteristics that users value. In such markets, firms are “price takers”; that is, they are unable to influence the market price, and must determine their profit

- maximizing production level as a function of the p rice set by the market. In such markets, strategic behavior is not possible because there are too many competitors, making it impossible for them to make decisions based on their competitors’ actions and thereby affect market price.

Thus, for firms to be able to use information either to cause competitive harm or to coordinate their pricing with competitors, the number of firms in the market must be small enough that firms can identify their competitors and identify critical information about their competi tors’ operations. Markets with a relatively sm all number of firms are termed “ concentrated

. ”

In the following section, we describe methods for assessing whether markets are concentrated. We then examine several sectors covered by the GHGRP, to determine t h eir level of
concentration.

3 .0 Proce ss for Assessing Market Structures and Potential for Competitive Harm

Economists assess market concentration using measures that characterize the share of the market served by the largest firms. Specific tools used inc lude the Herfindahl

- Hirschman Index (HHI). For a given market, the HHI is calculated by squaring the market share of each firm competing in the market, then summing the squared shares.

## 4 

## HHI =  i 

## s i 2 

## , where s i 

## = the market share of the i th 

## firm.

Potential va lues of the HHI range from near zero (if each of the top 50 firms has one

- 50th o f the output of the group (50*(1/50^2)), to 10,000, if one firm has 100 % of the value (100^2=10,000).
The HHI reflects both the number of firms in the market and the relative size of the firms, and assumes larger values (1) the smaller the number of firms in the market and (2) the greater the disparity in size between the firms. The U.S. Department of Justice (DOJ) and the Federal Trade Commission (FTC) 2 , 3 

## use the HHI to identi fy markets where there are potential anti

- trust

concern s. They consider markets with HHI below 1,000 to be unconcentrated; markets with HHI between 1,000 and 1,800 to be moderately concentrated, and markets with HHI above 1,800 to be highly concentrated. T he Census Bureau computes and publishes HHI for the manufacturing sectors, defined using North American Industry Classification System codes or NAICS codes. 4



## Economists define markets at the product or process level because customers make purchasing
decis ions for specific products or services. While identifying a concentrated or moderately concentrated NAICS is sufficient to identify subpart s in which facilities are aware of their competitors

, and thus subparts for which revealing sensitive information wou ld have the potential to lead to competitive harm, it is not the only indicator that a market may have the potential to lead to competitive harm should sensitive information be released

. S ome sectors (defined at the 6

- digit NAICS code level) that are not c oncentrated at the national sector level

may produce some products for which there are sufficiently few firms producing the product that they are aware of each other’s operations and may behave strategically. In these cases, publication of some data could result in either reduced competition or competitive harm. Similarly, some products are traded in regional, rather than national markets; for these, even if the sector does not appear concentrated or moderately concentrated at the national level based upon its HHI , regional markets, which have fewer firms on the supply side compared to the
national sector , may be concentrated. In addition, s ome NAICS may include multiple industry sectors, only one of which i s covered by a subpart . If this is the case, the industry sector may have concentrated or moderately concentrated markets even if the overall NAICS is not concentrated or moderately concentrated. As a result , for subparts for which the national

- level
NAICS assessment indicates that the sector m ay be unconcentrated, the EPA performed
additional assessments.

Thus, the EPA’s analysis followed a tiered approach:

1. For each subpart, the EPA examined associated NAICS codes to determine if the entire NAICS is concentrated or moderately concentrated at th e national level.

2 Department of Justice. 2014. Use of HHI. Antitrust Division Manual. http://www.justice.gov/atr/public/divisionmanual/index.html 3 Federal Trade Commission

. 2004. The Petroleum Industry: Mergers, Structural Change, and Antitrust Enforcement

. http://www.ftc.gov/reports/petroleum

- industry

- mergers

- structural

- change

- antitrust

- enforcement

- report

- staff

- federal

. 4 Census Bureau. 2007. Economic Census : Concentration Ratios. http://www.census.gov/econ/concentration.html



## .

## 5



## 2. If multiple NAICS are associated with a subpart, and not all NAICS are in the same concentration category, the EPA determine d whether a majority of the facilities report ed concentrated or moderately concentrated NAICS.

3. If all the nationa l NAICS associated with a subpart are unconcentrated, or a majority of
facilities report under unconcentrated NAICS, the EPA determine d whether:

a. T he markets for the goods produced by firms in the subpart are regional, or

b. T he NAICS is broader than the affected market, or there are sub

- sector markets within a sector, such as markets for specialty products.

If the EPA found that either of the criteria under the third tier above is true for a subpart

, the
EPA examined the mark et itself (either regional or sub

- sector/product

- specific) to determine if it is concentrated or moderately concentrated. If the EPA found that none of the above criteria is true for a subpart, the EPA determined that the market is unconcentrated, and that the risk of competitive harm or diminished competition resulting from the release of “ input s to equations ”
data elements for th e subpart would be minimal

. If the EPA found that any of the above criteria
is true for a subpart, the EPA determined that t he market is concentrated, such that the firms subject to the subpart are likely able to identify their competitors . For each such subpart, the EPA proceed ed to evaluate each “ inputs to equations ” data element within th e subpart to determine if
its release would be likely to cause competitive harm . Refer to Part 2 of this memorandum for this analysis.

For three of the subparts, subparts C (Combustion), II (Industrial Wastewater Treatment)

, and TT (Industrial Landfills), the subparts represent a process that may take place at facilities in a number of industry sectors. Another subpart, subpart U (Miscellaneous Uses of Carbonates), also includes a variety of industry sectors. The markets in which these facilities compete, and for
which concentration must be as sessed, are the markets for the goods or services they produce. To evaluate the concentration in these markets, therefore, the EPA identified the NAICS codes for the industry sectors reported by these facilities, and examined their concentration.

For sect ors that did not have manufacturing NAICS codes, subparts W (Petr ol eum and Natural
Gas Systems ) and CC ( S oda A sh), HHI values were not available. As a result, the EPA
conducted a qualitative analysis of the market structure.

4 .0 Results of Analysis

The EPA calculated HHI values using NAICS codes reported by facilities for reporting year
2011. For the 27 subparts for which this analysis was conducted, the EPA identified 296 unique NAICS codes that facilities reported. Of these 296, 200 are manufacturing s ector NAICS codes, for which HHI information is compiled by the Census Bureau. Subparts CC and W 5 

## did not have

5 

### Three of the 1,549 facilities reporting under subpart W in 2011 reported manufacturing NAICS codes. See Section 4.4 for further discussion.

## 6



## manufacturing NAICS reported , and thus HHI values were not available. As a result, for these subparts, the EPA conducted a qualitative analysis.

Section 4 .1 presents the results of the analysis of concentration at the national sector (NAICS code) level. Section 4 .2 presents the results of the analysis of concentration at the regional, product, or process level. Section 4 .3 presents the results of the analysis of subparts representing processes from many Sectors (i.e., subparts C, U, II, and TT). Section 4 .4 presents the results of the analysis of n on

- m anufacturing Sectors (i.e., subparts W and CC).

4 .1 Analysis of C oncentration at the National Sect or (NAICS

- C ode) L evel
To begin its assessment of the potential for the release of the “ input s to equations” data elements to lead to reduced competition or competitive harm, the EPA determined the level of sector
concentration at the national NAICS code level. If the EPA determined that the NAICS code identified by a majority of firms in a subpart is concentrated or moderately concentrated at the national NAICS code level, the EPA concluded that the firms in the subpart are likely are aware
of each other ’ s actions. The EPA focused its assessment on the 200 manufacturing sector NAICS codes associated with GHG reporting facilities.

Appendix A lists concentration ratios for the 6

- digit NAICS codes cited by facilities , as well as
values of the HHI published by the U.S. Census Bureau for affected manufacturing NAICS
codes

. In addition, Appendix A presents information about the number of reporting facilities in a subpart that identif

ied each NAICS. This information allowed the EPA to identify which NA ICS codes within a subpart represent the majority of reporting facilities. 6



## At the subpart level, the EPA consider ed a subpart to be associated with concentrated or moderately concentrated markets if a majority of the firms reporting under that subpart identif ied themselves with NAICS codes that are concentrated or moderately concentrated. Recognizing
that it is actuall y the market or the sector that is concentrated, for convenience throughout the rest of this document, the EPA refer s to such subparts as concentrated or moderately concentrated. Using this criterion, the EPA found that the following subparts are at least moderately concentrated based on the NAICS codes associated with them: subparts F, G, L, N, O, S, V, Z, AA, BB, and EE. As a result, the EPA further evaluated these subparts by examining individual data elements to determine if harm would be likely to occu r. Refer to the Part 2 of this
memorandum for this evaluation.

4 .2 Analysis of Concentrat ion at the Regional, Product, or Process Level

For sectors for which the Census Bureau data indicate HHI in the unconcentrated range, the EPA undertook further analys is. T he markets for the goods they produce were examined to determine if the markets for some or all of the goods are concentrated within a particular NAICS , or if the

6 

### Some facilities reported multipl e NAICS; thus, facilities may be counted several times within a subpart, and the sum of NAICS cited by facilities within a subpart may exceed the number of facilities reporting under that subpart.

## 7



## goods are traded in regional markets, which would have fewer firms than the national markets
and thus are more likely to be concentrated ; see the analysis below.

Subpart E : Adipic Acid Producers . Production of adipic acid falls under NAICS 325199, All
Oth er Basic Inorganic Chemical Manufacturing . T his is a very broad NAICS code, encompassing production of many different inorganic chemicals ; a dipic acid production is a small subset of the overall NAICS. Thus, the EPA examine d adipic acid producers specifica lly

, rather than relying on a NAICS

- level assessment. Three facilities reported under subpart E for

r eporting y ear 2011. Even without firm

- level data, the HHI is useful because with only three plants , the lowest value the HHI could have is 3,267. 7 

## Because this source category does not have a threshold for applicability, all adipic acid producers in the U

. S

. are reporting under the
GHGRP

. Thus, the EPA concluded that the market for adipic acid is concentrated at the national
level. As a result, the EPA furth er evaluated the “ inputs to equations ” data elements in s ubpart E by examining individual data elements to determine if harm would be likely to occur. Refer to
Part 2 of this memorandum for this evaluation.

Subpart H: Portland Cement Sector

. Subpart H is the Portland cement industry. Nationally, the HHI for the cement industry is 609.9; the four largest firms produce 40.8% of value of shipments, according to the 2007 Economic Census. In addition, Appendix 1 shows that the NAICS codes reported by GHGRP facilities in 2011 are unconcentrated. Therefore, the EPA proceeded to assess whether regional markets are concentrated.

High cement transportation cost relative to product value leads to regional cement markets with a small number of competing fi rms. In previous analyses supporting the EPA rule making, the cement industry has been modeled as regional, and imperfectly competitive. 8 

## That is, market concentration within a regional market is sufficiently high that firms are aware of competitors.

For ex ample, this analysis identified 20 regional markets for gr a y cement (a subset of this

sector ) , with the number of plants in each market ranging from one to nine ; 9 

## such markets are clearly concentrated at the regional level.

In such markets, firms may have the ability to influence market prices by their production choices. In addition, firms are more likely to behave strategically based on their knowledge of other (competing) producers’ behavior. In addition, they would be aware of their competitors’
identit y and interested in production and market information about their competitors. It is important to note that facilities in the cement industry may produce a variety of cement products. Some cement products are homogeneous (e.g.

, gray cement) and are traded in regional markets;

7 

### Assuming each firm has an equal one

- third share of the m arket results in an HHI of 3,267 (3 x 33 2 

### ). In fact, the threshold of 1,000 for moderately concentrated markets translates to a minimum of 10 firms.
8 

### U.S. Environmental Protection Agency. 2010. Section 2.3. In Regulatory Impact Analysis: Amendments to the National Emissions Standards for Hazardous Air Pollutants and New Source Performance Standards for the Portland Cement Industry . EPA

- HQ

- OAR

- 2002

- 0051

- 3477. http://www.epa .gov/ttnecas1/regdata/RIAs/portlandcementfinalria.pdf

. 9 

### Some facilities reported multiple NAICS; thus, facilities may be counted several times within a subpart, and the sum of NAICS cited by facilities within a subpart may exceed the number of facilities reporting under that subpart.

## 8



## others such as white, Type III

, and Type V represent niche products with different markets, with
few firms but possibly serving a larger geographic area. 10



## As a result of these assessments, the EPA concluded that the structure of the m arkets that exist within this source category warrant s further evaluation of the “inputs to equations” data elements in subpart H. Therefore, the EPA further evaluated the “inputs to equations” data elements by examining each individual data element to determine if harm would be likely to occur. Refer to
Part 2 of this memorandum for this evaluation.

Subpart K

: Ferroalloys

. According to the 20 10 Statistics of U.S. Business es, 11 

## t here are 19 firms nationwide that produce ferroalloys. Of the 10 firms report ing under subpart K, nine selected NAICS 331112, for which no HHI information is available from the Census

. As a result, we conducted a qualitative assessment of the market structure. Firms in an industry with only 19 firms would be aware of their competit ors. In addition, if a sector that has 19 firms nationwide includes a few firms with relatively large market share (as opposed to a sector where all firms are
similar in size, and each has roughly a 1/19 share of the market ), the sector is likely to be

con centrated

. As a result, the EPA concluded that the structure of the market that exist s within this source category warrant s further evaluation of the “inputs to equations” in subpart K. Therefore, the EPA further evaluated the “inputs to equations” data elements by examining each individual data element to determine if harm would be likely to occur. Refer to Part 2 of this
memorandum for this evaluation.

Subpart P: Hydrogen Production

. M ost hydrogen is produced at petroleum refineries and ammonia producti on facilities, generally for captive use. Because these sectors are considered at least moderately concentrated (see discus sion for subpart Y, below), we concluded that the structure of the markets that exist within this source category warrant s further ev aluation of the “inputs to equations” data elements in subpart P. Therefore, the EPA further evaluated the “inputs to equations” data elements by examining each individual data element to determine if harm would be likely to occur. Refer to Part 2 of this memorandum for this evaluation.

Subpart Q: Iron and Steel Sector

. The EPA assessed the market structure of the iron and steel sector, using HHI data from the Census Bureau and other information

. Steel production is generally characterized by economies of s cale, resulting in markets dominated by a few large
firms. Economies of scale favor large furnaces (high capital investment costs) and pose entry barriers. High transportation cost relative to product value is associate d with regional steel
markets with a small number of competing firms. As a result, firms may have the ability to influence market prices by their production choices. In addition, firms are more likely to behave strategically based on their knowledge of other (competing) producers’ behavior. N ationally, the

10 EPA’s Regulatory Impact Analysis: National Emissions Standards for Hazardous Air Pollutants from the Portland Cement Industry ( April 2009, http://www.epa.gov/ttnecas1/regdata/RIAs/portlandcementria_4

- 20

- 09.pdf ) shows that only four plants nationwide produced white cement in 2005. See Appendix A of the 2009 RIA for list of plants in each cement market in 2005.
11 

### U.S. Census Bureau. 2010. Statistics of U.S. businesses, 2010. http://www.census.gov/econ/susb/ . Accessed March 5, 2013.

## 9



## majority of facilities reporting under this source category had unconcentrated NAICS code s. F or the reasons mentioned above, the national NAICS

- level assessment may be misleading. Some steel products are homogeneous and are traded in regiona l markets; others represent niche products with relatively few firms, serving different markets (possibly different geographic dimensions). Both regional markets and niche markets have relatively small numbers of producers, indicating at least moderate market concentration.

The EPA computed HHI at the process, region, and parent company level s , using data from the
American Iron and Steel Institute. The American Iron and Steel Institute provides limited steel production and process data

, available on its website

. 12 

## The data show a total of almost 124 million tons of steel produced, 73 million tons in EAFs and 50 million tons in basic oxyg en furnaces (BOFs). The EPA constructed HHI values using th ese production data, disaggregati ng by state, parent company, and process. The results indicated that there are 116 facilities located in 31 states, and production is not concentrated nationally, as indicated by relatively low HHI
values. However, when data are grouped by state or parent company

, the HHI values show at least moderate concentration, with the exception of EAFs

, which are unconcentrated even at the
state level. As a result, when the EPA accounted for the distinctions of region, parent company ownership, and steelmaking process

, the EPA concluded that the structure of the markets that
exist s within this source category warrant s further evaluation of the “inputs to equations” data
elements in subpart Q. Therefore, the EPA further evaluated the “inputs to equations” data elements by examining each individual data element to determine if harm would be likely to
occur. Refer to Part 2 of this memorandum for this evaluation.

Subparts R (Lead Smelting) and GG (Zinc Smelting). The EPA determined that markets served by firms reporting under subparts R and GG are concentrated at the national level. Both subpart R (lead smelting) and subpart GG (zinc smelting) fall under NAICS 331410, Nonferrous Metal (except Aluminum) Smelting and Ref ining. In addition to lead and zinc, many other nonferrous metals are included under NAICS 331410. Thus, the EPA examined the markets for lead and zinc individually. For subpart R, there is only one primary lead smelter, and seven firms with 14 secondary s melters nationwide (USGS, 2010a). For subpart GG, there is only one primary zinc
smelter and two secondary smelters nationwide (USGS, 2010b). Thus, firms in both of these subparts produce commodities whose markets are concentrated nationally. As a result, the EPA concluded that the structure of the markets that exist within these source categories warrant s further evaluation of the “inputs to equations” data elements . Therefore, the EPA further evaluated the “inputs to equations” data elements by examining each individual data element to determine if harm would be likely to occur. Refer to Part 2 of this memorandum for this
evaluation.

Subpart X: Petrochemicals

. In 2011, 64 petrochemical manufacturing facilities identified 14 NAICS codes. Of these, two NAICS , identified by 19 facilities, are concentrated based on their

12 

### http://ww w.steel.org/en/Making%20Steel/Where%20Its%20Made.aspx

## 10



## HHI values. Facilities within this subpart produce one of six products: carbon black, methane, acrylonitrile, ethylene, ethylene oxide, and ethylene dichloride. The EPA examined the markets
for these products, and found that none of them had more than 17 firms, and most had 10 or fewer. 13 

## As a result, the EPA concluded that the structure of the markets that exist within this
source category warrant s further evaluation of the “inpu ts to equations” data elements in subpart

X. Therefore, the EPA further evaluated the “inputs to equations” data elements by examining
each individual data element to determine if harm would be likely to occur. Refer to Part 2 of
this memorandum for this e valuation.

Subpart Y: Petroleum Refinery Sector

. There are two types of barriers to entry facing firms wanting to enter the refining industry. First, there are significant economies of scale in refinery operations, so firms would need to start a fairly lar ge

- scale operation or they w ould face higher
unit costs than their competitors . Second, legal barriers may also present obstacles (e.g., patented

processes )

. Nationally, the HHI for the refinery industry is 807; the four largest firms produce 47.5% of the value of shipments, according to the 2007 Economic Census. While 807 is not considered concentrated, the industry has become more concentrated over time, even when considered
nation

- wide ( the HHI in 1996 was 412, in 2000 the HHI was 611, and in 2007 it wa s 807). Concentration has occurred through mergers, which has reduced the number of refinery companies in the U.S. Examining HHIs by the five PADDs (Petroleum Administrative Districts
for Defense

, ” 14 

## the Federal Trade Commission 15 

## found that PADD V (the West Coast including Alaska and Hawaii) was moderately concentrated (HHI=1,246 in 2003).

Individual petroleum products are relatively homogeneous, although different firms produce a different mix of products, and some produce specialty products for which there are few other producers. The U.S. Department of Energy collects data on refiner ies in a petroleum supply

survey , which is published as an annual Petroleum Capacity Report. 16 

## The EPA reviewed the latest data (2012) containing 31 separate products and proces ses at 95 different facilities owned by 63 different firms. To better characterize the petroleum market, the EPA analyzed th ese data at the product/process level, applying the HHI measure to test for market concentration. The result of calculating the HHI at the product/process level for petroleum refineries shows that activity for several key products/process es is at least moderately concentrated. The data include capacity data for three thermal cracking processes (visbreaking, fluid coking, other)

, and together there are only nine facilities nationwide with this capability (HHI = 5,568, 2,463, and 10,000 respectively). Similarly, desulfurization and catalytic hydrocracking are processes where there is

13 

### U.S. Environmental Protection Agency. 2008. Technical Support Document for the Petrochemical Production Sector: Proposed Rule for Mandatory Reporting of Greenhouse Gases. http://www.epa.gov/ghgreporting/documents/pdf/archived/tsd/TSD%20PetroChem_EPA_09

- 09

- 08.pdf

. 14 

### http://www.eia.gov/oog/ info/twip/padddef.html
15 

### Federal Trade Commission

. 2004. The Petroleum Industry: Mergers, Structural Change, and Antitrust Enforcement

. http://www.ftc.gov/reports/petroleum

- industry

- mergers

- structural

- change

- antitrust

- enforcement

- report

- staff

- federal

. 16 

### http://www.eia.gov/petroleum/refinerycapacity/

## 11



## at least moderate concentration (HHI 1,023 and 5 ,109

, respectively). Additionally, production of isooctane (isomerization) is concentrated with a HHI of 7,813. Overall, of the 31 prod u cts/processes captured in the DOE data, seven are at least moderately concentrated.

Because the petroleum refinery indu stry is moderately concentrated in PADD V and because the markets for some petroleum products were at least moderately concentrated, the EPA concluded that the structure of the markets that exist within this source category warrant s further evaluation
of t he “i nputs to equations” data elements in subpart Y . Therefore, the EPA further evaluated the “inputs to equations” data elements by examining each individual data element to determine if harm would be likely to occur. Refer to Part 2 of this memorandum fo r this evaluation.

4 .3 Analysis of Subparts Representing Processes f rom Many Sectors
Subparts C, II, TT, and U have reporters from a large number of sectors. As opposed to many of
the other source categories reporting under the GHGRP , these s ource categories are not defined by the types of products manufactured, or produced, at the facility. Instead, these subparts are defined by production processes or waste management processes (C, II, and TT) or inputs used (U). As a result

, it is not possi ble to make a determination based on the subpart as a whole. Instead, whether information related to these source categories has the potential to cause competitive harm depends on the concentration of the markets in which the facilities sell their products rather than on the total number of facilities reporting under each source category. Thus,
the EPA determined that it would be necessary to identify the markets affected and examine their
market structure.

For these subparts, the EPA was able to conduct th e first step of the evaluation, to examine the
national

- level HHI for the NAICS codes reported by facilities. However, for the NAICS codes
where the national level 6

- digit NAICS indicated unconcentrated HHIs, EPA did not proceed with evaluating each of the NAICS codes to determine whether regional or product

- specific
concentration occurred. Because these facilities come from a wide variety of sectors for which
the EPA does not have specific information beyond th e 6

- digit NAICS code provided

, and
because man y of the NAICS reported for these sectors are not manufacturing NAICS codes,
further analysis of each of these sectors would be resource

- intensive , and would be likely to have a large uncertainty without obtaining additional information from the facilities on the specific markets in which these facilities operate.

A summary of the results for the HHIs compute d for these subparts is provide d , by subpart, in
Table 1 . Refer to Appendix A for a complete list of the HHIs for NAICS codes reported by these
facilities. The EPA’s analysis of HHIs for manufacturing NAICS codes listed by facilities in these subparts show s that some of the affected markets for goods produced by facilities in each of these subpar ts are concentrated or moderately concentrated. For these facilities, therefore, publishing the information contained in the “inputs to equations” data elements could potentially cause competitive harm or reduce competition. Due to the limitations of the m arket structu re analysis for these subparts

, and because the results of the analysis demonstrate that some of the

## 12



## facilities that report under these subparts are in sectors that are at least moderately concentrated at the national level, the EPA proceeded to evaluat e the individual data elements to determine if harm would likely occur (refer to Part 2 of this memorandum)

.

Table 1. Summary of National

- Level Herfindahl

- Hirschman Index ( HHI) for the Industry Sectors Subject to Subparts C, II, TT, and U

Subpart # of NAICS

Reported # of Reporters # of Facility

R eports of
NAICS with
HHIs a , b 

## # of F acility

R eports of
NAICS with A t
L east
M oderately
C oncentrated
HHIs a



## Subpart C 295 5,780 2,382 985

Subpart II 24 155 181 39

Subpart TT 52 173 196 117

Subpart U 13 18 20 8

a 

### The number of facility reports may exceed the number of facilities, because some facilities report multiple NAICS codes.

b 

### Includes only facility reports of NAICS codes with non

- missing HHI values.



## 4

. 4 A nalysis of Non

- Manufacturing Sectors

As shown in Appendix A, HHIs were not available for subpart W 17 

## (Petroleum and Natural Gas) and subpart CC (soda ash manufacturing). As a result, a qualitative analysis of the market structures that exist within these source categories was conducted.

Subp art W

: Petr oleum and Natural Gas. Subpart W includes facilities operating in eight related segments of the petroleum and natural gas sector. Because subpart W is not a manufacturing sector, HHIs were not available for the vast majority of facilities. As a result, the EPA conducted

a qualitative analysis of the segments within this sector.

For each segment, the EPA examined the market structure to determine if revelation of “inputs to equations” data elements by firms in that segment had the potential to cause competitive harm or reduce competition. For source categories that are in the manufacturing sector, as shown in
Sections 4 .1 and 4 .2 of this memorandum, the EPA examined concentration at the national level,

17 

### Of the 1,549 facilities that reported under subpart W in 2011, three facilities reported manufacturing NAICS codes for which HHIs are available and were moderately concentrated. Of these, one facility with a NAICS of 325181 (alkalies and chlorine manufacturing) reported a small amount of emissions under LNG storage. EPA determined that this LNG storage process is separable from the remainder of the facilit y and is unrelated to the alkalies and chlorine manufacturing market. EPA believes that the NAICS for the remaining two facilities were reported in error.

## 13



## as well as at the r egional, p roduct, or p rocess l evel. Because of the unique nature of the subpart W source category with a relatively large number of producers selling a relatively homogeneous product

, the EPA determined that it would not be appropriate to assess the market structure at the product or process level. As a result, the EPA considered the market structure of each segment as well as the types of information that are collected through this source category

. The EPA’s findings for each subpart W segment are reported below.

Onshore Petroleum and Natural Gas Production 

## The onshore petroleum and natural gas production segment covers emissions related to onshore production wellheads. The market structure for petroleum and natural gas was considered separately for this segment. Onshore petroleum production is a regionally concentrated market, with wells located in fixed geological formations. Decisions on where to drill wells may be based on proprietary information during the early deve lopment of a formation when lease prices have not stabilized and operators are taking risks by drilling explorations wells in formations that do not have proven production records. After several wells have been drilled in an area, information about product ion becomes publically available and the advantage incurred by the operator drilling exploration wells is lost. However, once a well has been drilled, decisions to produce are based on market prices and the ability to control flow from the well. Although t his could pose a potential data sensitivity with respect to exploration wells, for most exploratory wells this issue is addressed by the fact that onshore production data is reported at a sub

- basin level, as defined by county boundaries, and which is a lar ge enough scale that disclosure of the data collected under subpart W would not reveal any proprietary information about the facility or cost to do
business

. However, for two specific types of exploratory wells, delineation wells and wi ldcat wells, in specific cases discussed below, early public disclosure of six “ inputs to equations ”
data elements could reveal the productivity of the wells and therefore result in loss of
investment value. The six “ inputs to equations ” data elements are:

 For gas well completions or workovers with hydraulic fracturing, the measured flow rate of backflow during well completion (40 CFR 98.236(c)(6)(i)(B));

 For gas well completions or workovers with hydraulic fracturing, the measured flow rate of backflow during well work over (40 CFR 98.236 (c)(6)(i)(D));

 For gas well completions or workovers with hydraulic fracturing, the total number of days of backflow from all wells during completions (40 CFR 98.236 (c)(6)(i)(E));

 For gas well completions or workovers with hydraulic f racturing, the total number of days of backflow from all wells during workovers (40 CFR 98.236 (c)(6)(i)(F));

 For onshore production storage tanks, the total volume of oil from all wellhead separators sent to tank(s) in barrels per year (40 CFR 98.236(c)(8 )(i)(F)); and

## 14



##  For onshore production storage tanks, the total volume of sales oil from all wells in barrels per year (40 CFR 98.236(c)(8)(ii)(A)).

The specific cases for which early public disclosure of these six “inputs to equations” data
elements could reveal the productivity of the wells and result in loss of investment value are
as follows:

 For gas well completions or workovers with hydraulic fracturing, where wildcat wells and/or delineation wells are the only wells in a sub

- basin that can be used for the

measurement

. These measurements require the use of “representative” wells. If wildcat and/or delineation wells are the only wells that can be used for measurement of these data, then the inputs could reveal information on the productivity of the well.

 For onshore production storage tanks, where wildcat wells and/or delineation wells are the only wells in a sub

- basin

. If wildcat wells and/or delineation wells are the only
wells in a sub

- basin, then the volumes reported for these data elements would

rep resent volumes of wildcat wells and/or exploratory wells exclusively, which could reveal information on the productivity of the well.

D elay ing reporting of these data for two reporting years would be sufficient time for reporters to thoroughly conduct an a ssessment of the well

, after which the data could be reported and made publicly available. Besides the need for a two

- year delay for the six data elements associated with exploratory wells in the specific cases described above

, the likelihood of harm can be characterized for all information collected for this segment, and the EPA did not proceed to evaluate each “input to equation” data element in this segment.

The onshore natural gas production market overlaps many of the geological formations of petroleum production. Furthermore, the market itself is structured the same, with a large number of operators within each formation. Like onshore oil production, disclo sure of data for onshore natural gas production at the sub

- basin level would also not reveal any proprietary information about the facility or cost to do business , except for the specific case
described earlier

. Aside from the specific case described earli er, the likelihood of harm can be characterized for all information collected for this segment

, and the EPA did not proceed to evaluate each “input to equation” data element in this segment.

Offshore Petroleum and Natural Gas Production 

## Offshore petroleum and natural gas production includes emissions from offshore production platforms and does not include emissions from drilling and exploration that is not associated with production platforms. The products created on offshore production platforms are
deliv ered into the same market as onshore petroleum and natural gas production, which is a competitive market. The reported data are specific to a latitude and longitude as identified by the facility

, but the data reported in offshore production do not include information specific to the formations from which hydrocarbons are being extracted and only information

## 15



## concerning the operations of the platform is reported. The operational information does not include information that the operator will find proprietary to the well ; as a result, the information reported under offshore petroleum and natural gas production would not reveal any proprietary information about the facility or cost to do business

. As the likelihood of
harm can be characterized for all informatio n collected for this segment, the EPA did not proceed to evaluate each “input to equation” data element in this segment.

Natural Gas Processing 

## Natural gas processors are regionally located close to production wellheads. The market itself is large, with r oughly 500 firms. These firms are located in close proximity to given natural gas plays. However, we do not believe that this regional concentration would pose data sensitivity issues because the “inputs to equations” data elements in this segment would not reveal any proprietary information about the facility, cost of natural gas, or cost to do
business

. As the likelihood of harm can be characterized for all information collected for this
segment, the EPA did not proceed to evaluate each “input to equati on” data element in this
segment.

Natural Gas Transmission Compression 

## Natural gas transmission compression operators transport natural gas from processors to end users. Firms are regionally concentrated, having control over particular segments of the pip eline infrastructure. Although the number of firms and the regional concentration could pose data sensitivity issues, we do not believe this is an issue for three reasons: (1) there are few technological secrets related to pipeline construction and natural gas transmission , and technological innovation is mainly in the area of pipeline security; (2) the rate charged for transport is highly regulated, preventing use of the data for strategic price competition; and (3) once pipeline and compression are built in a given corridor, there is little incentive for a competitor to build additional pipeline and compression along the same route. As a result, the “inputs to equations” data elements in this segment would not reveal any proprietary
information about the f

acility or cost to do business

. As the likelihood of harm can be characterized for all information collected for this segment, the EPA did not proceed to evaluate each “input to equation” data element in this segment.

Natural Gas Distribution 

## Natural gas distributers own and operate the distribution mains and services and function as
the middle man between transmission lines and end

- users. This market is regionally located

, with distributers having exclusive access to specific cities and other localities. Both publicly and privately owned companies are highly reg ulated, unable to charge market

- based rates for service. The regulation by government and the monopoly rights distributors hold over given regions prevent competitors’ use of the data for strategic purposes. As a result, the “inputs to equations” data elements in this segment would not reveal any proprietary information about the facility or cost to do business

. As the likelihood of harm can be characterized for all

## 16



## information collected for this seg ment, the EPA did not proceed to evaluate each “input to equation” data element in this segment.

Underground Natural Gas Storage 

## Underground natural gas storage is used to smooth out volatility in consumption and use of natural gas. The market is regiona l; facilities are located either near major distribution centers or near oil and gas fields. Even with the regional market structure, competitors are not known to engage in strategic competition in building storage facilities. First, facilities are built i n response to other upstream factors, such as increased gas supply coming to distributors, not to undermine other competitors. Second, storage firms are constrained by the geographical and geological requirements needed for underground storage, preventing firms from moving in and increasing their market share. Finally, storage technology is widely known and not used to garner a competitive advantage. As a result, the “inputs to equations” data elements in this segment would not reveal any proprietary inform ation about the facility or cost to do
business

. As the likelihood of harm can be characterized for all information collected for this
segment, the EPA did not proceed to evaluate each “input to equation” data element in this
segment.

Liquefied Natural Ga s Storage 

## Liquefied n atural g as (LNG) storage operates much the same as underground natural gas storage, with storage used to smooth volatility related to consumption. The small size of the LNG storage market could create the possibilities for disruptive competitive undercutting; however, we determined that this is unlikely for the following two reasons. First, LNG storage is primarily owned by highly regulated distributors, preventing competitive firms from undercutting the market. Second, LNG storage occurs in response to increase supply

ups tream or decreased demand downstream, and is not responsive to cost advantages. As a result, the “inputs to equations” data elements in this segment would not reveal any proprietary information about the facility or cost to do business

. As the likelihood o f harm can be characterized for all information collected for this segment, the EPA did not proceed to evaluate each “input to equation” data element in this segment.

Liquefied Natural Gas Import/Export 

## Currently the U

. S

. has only 12 LNG import terminals and one LNG export terminal. There are nine onshore import terminals and three offshore import terminals. LNG technology is not proprietary. The technology is relatively simple and has been around for many years. The market is regional and small

, with impo rt terminals located along the Gulf and East C oasts. Although there are a small number of facilities that import and/or export LNG, they may be viewed as a part of the larger natural gas supply sector that is a much larger market. The product delivered or consumed by LNG i mport/ e xport is identical to the product generated in onshore and offshore natural gas production. Functionally, i mport and e xport terminals may be considered as a large producer or consumer of natural gas. Import and e xport terminals are

## 17



## generally located in regions of supply restrictions or excess to maximize price margins. However, the trading prices of natural gas are publically available and the building of new import and export terminals is limited by capital and permitting, not by ma rket structure. Therefore, release of information about import/export terminals would not change the operations of other firms in the market . As a result, the “inputs to equations” data elements in this segment would not reveal any proprietary information about the facility or cost to do
business

. As the likelihood of harm can be characterized for all information collected for this
segment, the EPA did not proceed to evaluate each “input to equation” data element in this
segment.

In summary

, for all o f the industry segments within s ubpart W , with the exception of the specific cases described above for wildcat wells and delineation wells, either the data are reported at a level of geographical aggregation that protects individual well information, or the mar kets in which the affected firms operate are structured in ways that disclosure of “inputs to equations”
data elements would not be l ikely to cause competitive harm. For the wildcat wells and delineation wells, in the specific cases described above , early public disclosure of s even “ inputs to equations ” data elements could reveal the productivity of the wells and result in loss of
investment value. In those cases, reporting of these data for two reporting years would be adequate to safeguard sensitive infor mation, after which the data could be reported and made publicly available. As a result, the EPA did not further evaluate the “inputs to equations” data
elements in s ubpart W.

Subpart CC : Soda Ash . The four facilities reporting under subpart CC in 2011 ide ntified NAICS 212391, Potash, Soda, and Borate Mineral Mining. This is not a manufacturing NAICS, so HHI is not published for it. However, there are only 18 firms in this sector nationwide

. 18 

## If a sector
that has 18 firms nationwide includes a few firms wit h relatively large market share (as opposed
to a sector where all firms are similar in size, and each has roughly 1/1 8 share of the market ) , it is likely to be concentrated. As a result, the EPA concluded that the structure of the markets that
exist within this source category warrant s further evaluation of the “inputs to equations” data
elements in subpart CC. Therefore, the EPA further evaluated the “inputs to equations” data elements by examining each individual data element to determine if harm would be likely to
occur. Refer to Part 2 of this memorandum for this evaluation.

5.0 Summary

In this part, the EPA examined the market structures for subparts with “ inputs to equations” data
elements to determine whether conditions exist within the market structu re such that release of
these data could result in competitive harm. The E PA determined that such conditions exist within the market structures for all of the subparts examined except for subpart W, for which there are specific cases described in Section 4 .0 of this document where early public disclosure

18 

### U.S. Census Bureau. 2010. Statistics of U.S. businesses, 2010. NAICS 212391. http://www.census.gov/econ/susb/

.

## 18



## of six “inputs to equations” data elements could reveal the productivity of wildcat wells and
delineation wells and result in loss of investment value. In those cases, delaying reporting of
these data for two reporting years would be adequate to safeguard sensitive information, after which the data could be reported and made publicly available without disclosure concerns. As a result, the EPA did not further evaluate competitive harm for facilities reportin g under subpart
W. For th e “inputs to equations” data elements in the remaining 27 subparts examined, the EPA further evaluated the data elements by examining each individual data element to determine if harm would be likely to occur. Refer to Part 2 of th is memorandum for this evaluation.

## 19



## Part Two: Evaluation of Individual Data Elements

1.0 Introduction

As discussed in Part 1 of this memorandum, the E PA determined that conditions exist within the market structures such that competitive harm could occur should certain types of information be released for all of the subparts examined in this memorandum except for facilities reporting under subpart W. As a result, no further evaluation of competitive harm was conducted for this source category. Th e EPA further evaluated the remaining “inputs to equations” data elements in

2 6 subparts by examining individual data elements to determine if harm would be likel y to occur.

2.0 Evaluation of Harm

Based on the EPA ’s prev ious consideration of competitive harm (see proposed CBI rule, 75 FR
39115

– 39116, July 7, 2010), the EPA’s previous consideration of comments received on the proposed CBI rule (see final CBI rule, 76 FR 30806, May 26, 2011), and the EPA’s more recent consideration of comments received on the Call for Information ( 75 FR 81366, December 27, 2010)

, the EPA i dentified certain types of data that would reveal information that likely cause competitive harm, if reported and publicly released. These data include:

 The quantity or composition of raw materials or products ; or

 Process design, process performance and op eration, and cost to do business

.
Additionally, the EPA determined that many other “inputs to equations” data elements, which
alone would not reveal information that could cause competitive harm, w ould reveal the types of data specified above if known together with certain additional data elements (i.e., multiple reported “inputs to equations” data elements would be needed to back

- calculate the types of data specified above)

. Under this evaluation, each individual “inputs to equations” data elemen t was evaluated to determine whether it includes any of these types of data, as further discussed below

. In all, 493 “inputs to equations” data elements (excluding “inputs to equations” for facilities subject to subpart W) were reviewed according to the process described in this section. Refer to Appendix

B for result s of the analysis for each of the 493 data elements.

2.1 Quantity and Composition of Raw Materials or Products

The EPA ha s determined in previous GHGRP actions that publicly releasing facility

- specific data on the quantity or composition of raw materials or products would likely cause competitive
harm. In t hese previous actions

, the EPA finalized CBI determinations for such d ata currently reported under Part 98 (e.g., production rates that are currently collected under Part 98, but not used to calculate GHG emissions). As further discussed in the proposed CBI rule, d isclosing a facility’s production or throughput data w ould be detrimental to a firm’s competitiveness by revealing confidential process information and operational and marketing strategies, as follows :

## 20



##  Annual production quantities, used in conjunction with other publicly available data related to capacity, provide i nsight in to a firm’s operational strengths and weaknesses. Competitors could determine at what percent capacity a firm is operating, which can reveal information on the financial and competitive strength of the firm ;

 Disclosing a facility’s production or throughput quantities and product compositions could give competitors insight into a firm’s local and regional market conditions and expansion plans, enabling competitors to devise strategies to prevent expansion and to steal market share in specific locat ions ; and

 D isclos ing a facility’s feedstock quantities and composition and reactants fed into particular processes at a facility could provide insight into a facility’s operational strengths and weaknesses, expose a firm’s competitive and marketing strate gies, or reveal a firm’s suppliers and sourcing strategies.

Refer to t he preamble to the proposed CBI determi nations (75 FR 39115

– 39116, July 7, 2010)
for a more detailed discussion on why reporting production and raw material information would be likely to cause competitive harm.

Under this evaluation, we identified all “inputs to equations” data elements that require reporting
of data related to the quantity or composition of raw materials or products. We evaluated these
data elements to identify any at tributes in the data elements that would distinguish them as less likely to cause competitive harm if released than those data elements previously determined to be
CBI (see reference above to previously proposed CBI determinations). We concluded that all such data elements identified under this analysis would be as likely to cause competitive harm as those previously identified.

Data elements determined to include a require ment to report the quantity or composition of raw
materials o r products are identified in Appendix B

.

2.2 Data Related to Process Design, Process Performance and Operation, and Cost to
Do Business

Based on a review of comments on the Call for Information (75 FR 81366, December 27, 2010 )
and on previous actions under the GHGRP

, the EPA h as determined that d ata r elated to p rocess d esign, p rocess p erformance and o peration, and c ost to d o b usiness would reveal the following
information:

 Disclosing p rocess design information could be detrimental to a firm’s competitiveness by revealing the design efficiency of the unit, providing insight in to the firm’s operational strengths and weaknesses (e.g., d isclosing the r atio of the maximum rate he at input capacity to the design

- rated steam output capacity of a combustion unit, not connected to the electric power grid

, would disclose the design efficiency of the unit ) ;

 Disclosing p rocess performance and operation information could be detrimental to a firm’s competitiveness by reveal ing process efficiency , providing insight in to a firm’s

## 21



## operational strengths and weaknesses (e.g., d isclosing an aluminum production fa cility’s cell performance would disclose current production efficiency ) ; and

 Disclosing information related to the c ost to d o business could be detrimental to a firm’s competitiveness by providing insight in to a firm’s operational strengths and weaknesses (e.g., d isclosing a n HCFC production facility’s loss factor , which a ccount s for the loss of HCFC

- 22 upstream of a measuremen t
, would reveal the amount of product that is lost ).

Data elements determined to include a require ment to report the type of information described above are identified in Appendix B

.

2.3 Other Data T hat Would Likely Reveal the Types of Data Specified Above I f Certain
Additional Data Are Also Known

An additional evaluation was conducted to determine whether each “inputs to equations” data
element not related to the quantity or composition of raw mater ials or products (see section 2.1)

, in combination with currently reported data elements and other “inputs to equations” data
elements

, could be used to back

- calculate the types of data specified in sections 2.1 and 2.2 (e.g., production quantity, cost to do business)

. For example, for an adipic acid production facility, the abatement technology destruction efficiency , if reported alone, would not reveal any information
that would likely cause harm; however, if reported together with the abatement utilization factor

, emission factor and reported N 2 

## O emissions, it could be used to back

- calculate an estimate of the
mass of adipic acid produced, which is the type of data identified in section 2.1 of this memorandum. Data elements determined to reveal p roprietary information in this way are identified in Appendix B.

For any such data elements identified

, the EPA also determined if such harm c ould be avoided by removing the reporting requirement for certain additional data elements

. For example, if the
ab atement utilization factor were reported (as required under §98.56(h)), together with annual

N 2 

## O emissions from nitric acid production (in §98.3(c)(4)) and the emission factor (in §98.56(j)(1)), and the destruction efficiency (in §98.56(g)), these data together could be used to calculate the mass of adipic acid produced. However, if reporting of the emission factor were removed, the abatement utilization factor could be reported without revealing proprietary information about nitric acid production. Any such “ inputs to equations ” data elements are identified in Appendix B

.

3.0 Summary

Based on the r esults of Part 1 and Part 2 of this memorandum, the EPA proceeded to Step 3 of
the evaluation for 2 5 19 

## of the 2 7 subparts evaluated in this memorandum

. The EPA did not

19 

### Note that “inputs to equations” data elements for subparts A and C are combined in Appendix B Table B

- 1.

## 22



## proceed to Step 3 of the evaluation for subpart W ( Petroleum and Natural Gas Systems ) and Subpart II (Industrial Wastewater Treatment)

.

## 23 

## Appendix A

Subpart Sector Concentration Assessment, National NAICS Code Level

## 24

Table A

- 1 . Subpart Sector Concentration Assessment, National NAICS Code Level

Subpart NAICS Number of Subpart C Facilities Affected by 2015 Deferral 1 

### HHI,

VOS 2 

### HHI,

VA 2 

### Finding

C Combustion 111419 1 N/A N/A N/A

C Combustion 111930 1 N/A N/A N/A

C Combustion 112340 1 N/A N/A N/A

C Combustion 113310 1 N/A N/A N/A

C Combustion 115114 3 N/A N/A N/A

C Combustion 211111 453 N/A N/A N/A

C Combustion 211112 232 N/A N/A N/A

C Combustion 212111 6 N/A N/A N/A

C Combustion 212112 28 N/A N/A N/A

C Combustion 212113 2 N/A N/A N/A

C Combustion 212210 8 N/A N/A N/A

C Combustion 212221 5 N/A N/A N/A

C Combustion 212222 1 N/A N/A N/A

C Combustion 212231 2 N/A N/A N/A

C Combustion 212234 5 N/A N/A N/A

C Combustion 212311 1 N/A N/A N/A

C Combustion 212312 7 N/A N/A N/A

C Combustion 212313 1 N/A N/A N/A

C Combustion 212322 2 N/A N/A N/A

C Combustion 212324 14 N/A N/A N/A

C Combustion 212325 9 N/A N/A N/A

C Combustion 212391 10 N/A N/A N/A

C Combustion 212392 2 N/A N/A N/A

C Combustion 212399 8 N/A N/A N/A

C Combustion 213112 81 N/A N/A N/A

C Combustion 213113 1 N/A N/A N/A

C Combustion 213115 1 N/A N/A N/A

C Combustion 221111 2 N/A N/A N/A

C Combustion 221112 1008 N/A N/A N/A

C Combustion 221113 3 N/A N/A N/A

C Combustion 221119 37 N/A N/A N/A

C Combustion 221121 1 N/A N/A N/A

C Combustion 221122 11 N/A N/A N/A

C Combustion 221210 222 N/A N/A N/A

C Combustion 221310 9 N/A N/A N/A

C Combustion 221320 7 N/A N/A N/A

## 25

Subpart NAICS Number of Subpart C Facilities Affected by 2015 Deferral 1 

### HHI,

VOS 2 

### HHI,

VA 2 

### Finding

C Combustion 221330 72 N/A N/A N/A

C Combustion 237120 2 N/A N/A N/A

C Combustion 311119 6 285.4 290.2 Unconcentrated

C Combustion 311213 6 N/A N/A N/A

C Combustion 311221 23 2,338.2 2,291.2 Concentrated

C Combustion 311222 41 1,930.8 2,496.1 Concentrated

C Combustion 311223 3 2,752.7 2,221.5 Concentrated

C Combustion 311225 11 1,030.3 950.2 Moderately Concentrated

C Combustion 311230 10 2,425.5 2,909.0 Concentrated

C Combustion 311311 2 N/A N/A N/A

C Combustion 311312 5 N/A N/A N/A

C Combustion 311313 22 N/A N/A N/A

C Combustion 311330 1 1,547.6 1,730.0 Moderately Concentrated

C Combustion 311411 23 586.6 648.1 Unconcentrated

C Combustion 311421 22 254.8 295.2 Unconcentrated

C Combustion 311422 7 2,885.1 D Concentrated

C Combustion 311423 4 486.3 500.3 Unconcentrated

C Combustion 311511 3 1,075.3 1,265.7 Moderately Concentrated

C Combustion 311512 2 2,283.3 2,170.1 Concentrated

C Combustion 311513 6 379.3 308.2 Unconcentrated

C Combustion 311514 13 651.8 1,548.8 Moderately Concentrated

C Combustion 311611 33 1,046.5 644.0 Moderately Concentrated

C Combustion 311612 13 258.1 330.3 Unconcentrated

C Combustion 311613 39 645.6 800.5 Unconcentrated

C Combustion 311615 18 737.6 937.0 Unconcentrated

C Combustion 311711 1 1,254.9 1,107.8 Moderately Concentrated

C Combustion 311821 1 1,607.2 1,987.3 Concentrated

C Combustion 311911 1 413.4 716.1 Unconcentrated

C Combustion 311919 7 D D N/A

C Combustion 311920 3 763.1 939.2 Unconcentrated

C Combustion 311942 9 479.5 701.5 Unconcentrated

C Combustion 311991 1 273.0 257.4 Unconcentrated

C Combustion 311999 7 168.2 161.7 Unconcentrated

C Combustion 312120 19 D D N/A

C Combustion 312130 1 584.0 595.1 Unconcentrated

C Combustion 312140 8 1,519.4 2,373.6 Concentrated

C Combustion 312221 2 N/A N/A N/A

C Combustion 312229 1 2,744.6 D Concentrated

## 26

Subpart NAICS Number of Subpart C Facilities Affected by 2015 Deferral 1 

### HHI,

VOS 2 

### HHI,

VA 2 

### Finding

C Combustion 313210 1 253.9 259.0 Unconcentrated

C Combustion 313230 1 778.2 1,043.9 Moderately Concentrated

C Combustion 313311 5 209.5 247.3 Unconcentrated

C Combustion 313312 3 277.2 292.9 Unconcentrated

C Combustion 314110 5 1,649.7 1,728.5 Moderately Concentrated

C Combustion 315191 1 537.5 633.9 Unconcentrated

C Combustion 316110 2 560.3 466.8 Unconcentrated

C Combustion 321113 9 98.3 59.8 Unconcentrated

C Combustion 321114 1 385.7 293.7 Unconcentrated

C Combustion 321211 2 415.1 311.8 Unconcentrated

C Combustion 321212 3 1,233.3 1,408.3 Moderately Concentrated

C Combustion 321219 13 345.0 322.8 Unconcentrated

C Combustion 321999 1 65.1 90.1 Unconcentrated

C Combustion 322110 58 1,023.5 1,235.7 Moderately Concentrated

C Combustion 322121 122 758.9 1,036.2 Moderately Concentrated

C Combustion 322122 9 X X N/A

C Combustion 322130 69 713.1 768.6 Unconcentrated

C Combustion 322213 1 696.2 527.7 Unconcentrated

C Combustion 322222 3 630.1 1,274.5 Moderately Concentrated

C Combustion 322224 1 1,043.0 1,117.7 Moderately Concentrated

C Combustion 322291 7 1,317.8 1,789.4 Moderately Concentrated

C Combustion 322299 1 187.7 256.3 Unconcentrated

C Combustion 323110 3 96.6 86.6 Unconcentrated

C Combustion 323111 3 1,359.5 1,430.7 Moderately Concentrated

C Combustion 324110 146 806.5 811.6 Unconcentrated

C Combustion 324121 2 188.4 206.4 Unconcentrated

C Combustion 324191 4 794.5 1,902.5 Concentrated

C Combustion 324199 31 739.8 617.1 Unconcentrated

C Combustion 325110 45 2,535.2 D Concentrated

C Combustion 325120 37 1,415.2 1,377.8 Moderately Concentrated

C Combustion 325131 7 1,265.0 1,293.6 Moderately Concentrated

C Combustion 325132 3 837.6 803.9 Unconcentrated

C Combustion 325181 13 2,391.7 2,428.2 Concentrated

C Combustion 325182 16 N/A N/A N/A

C Combustion 325188 63 223.5 303.4 Unconcentrated

C Combustion 325191 6 2,389.8 D Concentrated

C Combustion 325192 19 2,328.9 D Concentrated

C Combustion 325193 172 275.1 298.0 Unconcentrated

## 27

Subpart NAICS Number of Subpart C Facilities Affected by 2015 Deferral 1 

### HHI,

VOS 2 

### HHI,

VA 2 

### Finding

C Combustion 325199 111 360.5 289.0 Unconcentrated

C Combustion 325211 96 400.4 546.4 Unconcentrated

C Combustion 325212 10 727.8 717.4 Unconcentrated

C Combustion 325221 2 N/A N/A N/A

C Combustion 325222 12 2,071.1 2,246.5 Concentrated

C Combustion 325311 36 1,135.6 1,214.9 Moderately Concentrated

C Combustion 325312 17 D 2,777.2 Concentrated

C Combustion 325320 9 1,109.1 1,632.2 Moderately Concentrated

C Combustion 325411 12 1,423.7 1,299.9 Moderately Concentrated

C Combustion 325412 26 456.8 532.6 Unconcentrated

C Combustion 325413 2 759.9 792.3 Unconcentrated

C Combustion 325414 9 946.9 890.5 Unconcentrated

C Combustion 325510 4 539.8 504.9 Unconcentrated

C Combustion 325520 2 234.8 276.6 Unconcentrated

C Combustion 325611 6 2,025.3 2,362.8 Concentrated

C Combustion 325612 3 1,164.4 1,346.0 Moderately Concentrated

C Combustion 325613 8 2,353.1 859.5 Concentrated

C Combustion 325620 1 1,220.6 751.2 Moderately Concentrated

C Combustion 325910 1 906.0 1,188.8 Moderately Concentrated

C Combustion 325920 2 920.7 1,037.2 Moderately Concentrated

C Combustion 325991 2 290.0 313.0 Unconcentrated

C Combustion 325992 3 1,888.0 2,202.9 Concentrated

C Combustion 325998 19 158.4 212.6 Unconcentrated

C Combustion 326113 8 185.7 228.4 Unconcentrated

C Combustion 326121 3 333.3 409.6 Unconcentrated

C Combustion 326130 1 485.9 666.1 Unconcentrated

C Combustion 326140 3 783.5 667.2 Unconcentrated

C Combustion 326191 1 356.8 320.3 Unconcentrated

C Combustion 326199 2 26.3 26.7 Unconcentrated

C Combustion 326211 19 1,734.7 1,893.2 Concentrated

C Combustion 326291 1 274.5 254.6 Unconcentrated

C Combustion 326299 1 292.8 89.4 Unconcentrated

C Combustion 327111 2 D D N/A

C Combustion 327121 2 616.0 681.5 Unconcentrated

C Combustion 327122 6 1,542.2 1,824.0 Concentrated

C Combustion 327125 2 819.2 932.7 Unconcentrated

C Combustion 327211 27 N/A N/A N/A

C Combustion 327212 23 516.8 582.6 Unconcentrated

## 28

Subpart NAICS Number of Subpart C Facilities Affected by 2015 Deferral 1 

### HHI,

VOS 2 

### HHI,

VA 2 

### Finding

C Combustion 327213 44 2,506.6 2,468.8 Concentrated

C Combustion 327215 5 332.0 341.6 Unconcentrated

C Combustion 327310 81 609.9 651.3 Unconcentrated

C Combustion 327390 1 127.7 140.7 Unconcentrated

C Combustion 327410 49 1,424.1 1,394.2 Moderately Concentrated

C Combustion 327420 43 1,553.6 1,492.1 Moderately Concentrated

C Combustion 327910 3 1,662.4 2,197.7 Concentrated

C Combustion 327992 10 615.8 648.0 Unconcentrated

C Combustion 327993 22 936.4 1,031.9 Moderately Concentrated

C Combustion 327999 5 651.8 666.0 Unconcentrated

C Combustion 331111 117 785.6 906.8 Unconcentrated

C Combustion 331112 11 N/A N/A N/A

C Combustion 331210 8 435.6 741.5 Unconcentrated

C Combustion 331221 13 402.1 441.8 Unconcentrated

C Combustion 331222 2 296.9 312.4 Unconcentrated

C Combustion 331311 6 N/A N/A N/A

C Combustion 331312 11 2,250.3 D Concentrated

C Combustion 331314 22 930.8 2,019.9 Concentrated

C Combustion 331315 14 1,995.3 1,852.0 Concentrated

C Combustion 331316 6 433.3 394.7 Unconcentrated

C Combustion 331319 2 1,119.8 1,391.6 Moderately Concentrated

C Combustion 331411 4 N/A N/A N/A

C Combustion 331419 9 598.6 1,080.3 Moderately Concentrated

C Combustion 331421 3 1,134.3 910.9 Moderately Concentrated

C Combustion 331423 2 1,217.4 1,849.4 Concentrated

C Combustion 331491 4 818.3 727.7 Unconcentrated

C Combustion 331492 21 344.0 345.6 Unconcentrated

C Combustion 331511 28 337.5 324.7 Unconcentrated

C Combustion 331513 3 458.1 542.1 Unconcentrated

C Combustion 331521 7 371.7 364.5 Unconcentrated

C Combustion 331522 2 366.2 417.3 Unconcentrated

C Combustion 331524 5 288.8 306.4 Unconcentrated

C Combustion 331528 2 624.4 763.8 Unconcentrated

C Combustion 332111 7 203.0 194.2 Unconcentrated

C Combustion 332112 4 888.4 1,034.3 Moderately Concentrated

C Combustion 332211 1 1,373.0 1,571.5 Moderately Concentrated

C Combustion 332323 1 93.1 70.5 Unconcentrated

C Combustion 332618 1 65.6 57.9 Unconcentrated

## 29

Subpart NAICS Number of Subpart C Facilities Affected by 2015 Deferral 1 

### HHI,

VOS 2 

### HHI,

VA 2 

### Finding

C Combustion 332811 2 264.5 186.8 Unconcentrated

C Combustion 332812 5 181.9 140.0 Unconcentrated

C Combustion 332813 2 61.0 19.6 Unconcentrated

C Combustion 332913 1 1,532.2 1,810.9 Concentrated

C Combustion 332991 1 1,834.1 1,893.2 Concentrated

C Combustion 332992 2 2,446.7 D Concentrated

C Combustion 332993 1 2,015.9 2,220.3 Concentrated

C Combustion 332996 1 215.5 197.2 Unconcentrated

C Combustion 332998 1 1,312.0 1,611.5 Moderately Concentrated

C Combustion 332999 2 25.3 23.9 Unconcentrated

C Combustion 333111 2 1,828.5 2,371.9 Concentrated

C Combustion 333120 4 1,143.3 1,076.5 Moderately Concentrated

C Combustion 333131 2 546.1 624.3 Unconcentrated

C Combustion 333315 1 1,831.1 1,873.4 Concentrated

C Combustion 333415 1 510.7 527.4 Unconcentrated

C Combustion 333511 1 21.0 17.9 Unconcentrated

C Combustion 333514 1 53.1 34.2 Unconcentrated

C Combustion 333516 2 1,139.4 1,066.8 Moderately Concentrated

C Combustion 333611 1 1,937.0 1,464.6 Concentrated

C Combustion 333612 2 352.0 347.9 Unconcentrated

C Combustion 333618 6 1,022.1 1,089.4 Moderately Concentrated

C Combustion 333992 1 1,051.7 1,127.5 Moderately Concentrated

C Combustion 334411 3 1,402.1 1,535.7 Moderately Concentrated

C Combustion 334413 49 1,283.6 1,929.1 Concentrated

C Combustion 334515 1 544.5 623.3 Unconcentrated

C Combustion 335224 2 N/A N/A N/A

C Combustion 335313 3 718.8 693.8 Unconcentrated

C Combustion 335929 1 479.8 423.3 Unconcentrated

C Combustion 335991 2 620.6 650.3 Unconcentrated

C Combustion 336111 18 1,448.8 1,548.7 Moderately Concentrated

C Combustion 336112 19 2,679.5 D Concentrated

C Combustion 336211 1 243.0 202.1 Unconcentrated

C Combustion 336312 3 931.4 712.4 Unconcentrated

C Combustion 336330 2 541.1 626.3 Unconcentrated

C Combustion 336350 7 554.3 560.7 Unconcentrated

C Combustion 336360 1 1,369.8 864.2 Moderately Concentrated

C Combustion 336370 4 385.8 456.6 Unconcentrated

C Combustion 336399 4 80.9 71.2 Unconcentrated

## 30

Subpart NAICS Number of Subpart C Facilities Affected by 2015 Deferral 1 

### HHI,

VOS 2 

### HHI,

VA 2 

### Finding

C Combustion 336411 11 D D N/A

C Combustion 336412 6 2,421.8 2,304.8 Concentrated

C Combustion 336413 5 674.4 752.7 Unconcentrated

C Combustion 336414 1 N/A N/A N/A

C Combustion 336415 3 N/A N/A N/A

C Combustion 336510 3 951.6 1,177.7 Moderately Concentrated

C Combustion 336611 2 1,545.7 1,838.9 Concentrated

C Combustion 336992 4 2,477.1 2,575.9 Concentrated

C Combustion 337211 1 550.7 565.8 Unconcentrated

C Combustion 337214 1 1,285.2 1,442.8 Moderately Concentrated

C Combustion 339112 1 245.2 267.4 Unconcentrated

C Combustion 339999 4 274.5 386.1 Unconcentrated

C Combustion 423110 2 N/A N/A N/A

C Combustion 423120 1 N/A N/A N/A

C Combustion 423320 1 N/A N/A N/A

C Combustion 423720 1 N/A N/A N/A

C Combustion 423990 1 N/A N/A N/A

C Combustion 424690 2 N/A N/A N/A

C Combustion 424710 5 N/A N/A N/A

C Combustion 424910 1 N/A N/A N/A

C Combustion 481111 2 N/A N/A N/A

C Combustion 484220 1 N/A N/A N/A

C Combustion 486110 5 N/A N/A N/A

C Combustion 486210 504 N/A N/A N/A

C Combustion 486990 3 N/A N/A N/A

C Combustion 488119 4 N/A N/A N/A

C Combustion 488190 2 N/A N/A N/A

C Combustion 488210 1 N/A N/A N/A

C Combustion 488310 1 N/A N/A N/A

C Combustion 493110 1 N/A N/A N/A

C Combustion 493190 2 N/A N/A N/A

C Combustion 525920 1 N/A N/A N/A

C Combustion 531110 2 N/A N/A N/A

C Combustion 531120 1 N/A N/A N/A

C Combustion 541380 3 N/A N/A N/A

C Combustion 541611 1 N/A N/A N/A

C Combustion 541711 6 N/A N/A N/A

C Combustion 541712 15 N/A N/A N/A

## 31

Subpart NAICS Number of Subpart C Facilities Affected by 2015 Deferral 1 

### HHI,

VOS 2 

### HHI,

VA 2 

### Finding

C Combustion 541940 1 N/A N/A N/A

C Combustion 541990 1 N/A N/A N/A

C Combustion 551114 1 N/A N/A N/A

C Combustion 561210 4 N/A N/A N/A

C Combustion 561990 1 N/A N/A N/A

C Combustion 562111 1 N/A N/A N/A

C Combustion 562211 6 N/A N/A N/A

C Combustion 562212 595 N/A N/A N/A

C Combustion 562213 74 N/A N/A N/A

C Combustion 562910 2 N/A N/A N/A

C Combustion 562920 3 N/A N/A N/A

C Combustion 562998 1 N/A N/A N/A

C Combustion 611310 113 N/A N/A N/A

C Combustion 611610 1 N/A N/A N/A

C Combustion 621111 1 N/A N/A N/A

C Combustion 622110 25 N/A N/A N/A

C Combustion 713110 1 N/A N/A N/A

C Combustion 721120 4 N/A N/A N/A

C Combustion 722110 1 N/A N/A N/A

C Combustion 811111 2 N/A N/A N/A

C Combustion 812921 1 N/A N/A N/A

C Combustion 813990 2 N/A N/A N/A

C Combustion 921120 2 N/A N/A N/A

C Combustion 921150 1 N/A N/A N/A

C Combustion 921190 3 N/A N/A N/A

C Combustion 922140 3 N/A N/A N/A

C Combustion 923110 3 N/A N/A N/A

C Combustion 924110 1 N/A N/A N/A

C Combustion 926130 1 N/A N/A N/A

C Combustion 926140 1 N/A N/A N/A

C Combustion 928110 50 N/A N/A N/A E Adipic Acid 325120 1 1,415.2 1,377.8 Moderately Concentrated E Adipic Acid 325199 3 360.5 289.0 Unconcentrated E Adipic Acid 325211 1 400.4 546.4 Unconcentrated E Adipic Acid 325311 1 1,135.6 1,214.9 Moderately Concentrated

F Aluminum 221112 1 N/A N/A N/A
F Aluminum 331312 11 2,250.3 D Concentrated

F Aluminum 331314 1 930.8 2,019.9 Concentrated

## 32

Subpart NAICS Number of Subpart C Facilities Affected by 2015 Deferral 1 

### HHI,

VOS 2 

### HHI,

VA 2 

### Finding

F Aluminum 331316 1 433.3 394.7 Unconcentrated

F Aluminum 331319 1 1,119.8 1,391.6 Moderately Concentrated

G Ammonia 221210 1 N/A N/A N/A

G Ammonia 221330 1 N/A N/A N/A
G Ammonia 325120 1 1,415.2 1,377.8 Moderately Concentrated
G Ammonia 325188 1 223.5 303.4 Unconcentrated
G Ammonia 325199 1 360.5 289.0 Unconcentrated

G Ammonia 325311 20 1,135.6 1,214.9 Moderately Concentrated

G Ammonia 325312 1 D 2,777.2 Concentrated

H Cement 212312 3 N/A N/A N/A

H Cement 327310 96 609.9 651.3 Unconcentrated

H Cement 327999 1 651.8 666.0 Unconcentrated

H Cement 562211 2 274.5 386.1 Unconcentrated

K Ferroalloy 325120 1 N/A N/A N/A K Ferroalloy 325199 1 360.5 289.0 Unconcentrated K Ferroalloy 331112 9 N/A N/A N/A
L Fluorinated Gas 325110 1 2,535.2 D Concentrated
L Fluorinated Gas 325120 12 1,415.2 1,377.8 Moderately Concentrated
L Fluorinated Gas 325188 3 223.5 303.4 Unconcentrated

L Fluorinated Gas 325199 1 360.5 289.0 Unconcentrated

L Fluorinated Gas 325211 7 400.4 546.4 Unconcentrated

L Fluorinated Gas 325222 1 2,071.1 2,246.5 Concentrated
L Fluorinated Gas 325613 2 2,353.1 859.5 Concentrated
L Fluorinated Gas 325998 4 158.4 212.6 Unconcentrated
L Fluorinated Gas 326113 1 185.7 228.4 Unconcentrated

L Fluorinated Gas 326121 1 333.3 409.6 Unconcentrated

L Fluorinated Gas 327910 1 1,662.4 2,197.7 Concentrated

L Fluorinated Gas 562211 1 N/A N/A N/A
N Glass 325613 1 2,353.1 859.5 Concentrated
N Glass 325998 1 158.4 212.6 Unconcentrated
N Glass 326113 2 185.7 228.4 Unconcentrated

N Glass 326121 1 333.3 409.6 Unconcentrated

N Glass 326299 1 292.8 89.4 Unconcentrated

N Glass 327111 1 D D N/A
N Glass 327211 27 N/A N/A N/A
N Glass 327212 23 516.8 582.6 Unconcentrated
N Glass 327213 44 2,506.6 2,468.8 Concentrated

N Glass 327215 1 332.0 341.6 Unconcentrated

## 33

Subpart NAICS Number of Subpart C Facilities Affected by 2015 Deferral 1 

### HHI,

VOS 2 

### HHI,

VA 2 

### Finding

N Glass 327910 1 1,662.4 2,197.7 Concentrated

N Glass 327993 15 936.4 1,031.9 Moderately Concentrated

N Glass 331511 1 337.5 324.7 Unconcentrated

N Glass 332913 1 1,532.2 1,810.9 Concentrated
N Glass 332998 1 1,312.0 1,611.5 Moderately Concentrated
N Glass 333618 1 1,022.1 1,089.4 Moderately Concentrated
N Glass 562211 1 N/A N/A N/A

O HCFR

- 22, HCFC

- 23 325110 1 2,535.2 D Concentrated

O HCFR

- 22, HCFC

- 23 325120 5 1,415.2 1,377.8 Moderately Concentrated

O HCFR

- 22, HCFC

- 23 325188 2 223.5 303.4 Unconcentrated

O HCFR

- 22, HCFC

- 23 325211 3 400.4 546.4 Unconcentrated

O HCFR

- 22, HCFC

- 23 325222 1 2,071.1 2,246.5 Concentrated

O HCFR

- 22, HCFC

- 23 325998 1 158.4 212.6 Unconcentrated P Hydrogen 324110 57 806.5 811.6 Unconcentrated P Hydrogen 324191 1 794.5 1,902.5 Concentrated P Hydrogen 324199 1 739.8 617.1 Unconcentrated P Hydrogen 325110 2 2,535.2 D Concentrated P Hydrogen 325120 45 1,415.2 1,377.8 Moderately Concentrated P Hydrogen 325188 1 223.5 303.4 Unconcentrated P Hydrogen 325199 4 360.5 289.0 Unconcentrated P Hydrogen 325211 1 400.4 546.4 Unconcentrated

P Hydrogen 325311 1 1,135.6 1,214.9 Moderately Concentrated P Hydrogen 325613 1 2,353.1 859.5 Concentrated P Hydrogen 325998 1 158.4 212.6 Unconcentrated P Hydrogen 424710 1 N/A N/A N/A Q Iron &Steel 212210 8 N/A N/A N/A Q Iron &Steel 324199 12 739.8 617.1 Unconcentrated Q Iron &Steel 331111 102 785.6 906.8 Unconcentrated Q Iron &Steel 331112 1 N/A N/A N/A Q Iron &Steel 331221 7 402.1 441.8 Unconcentrated Q Iron &Steel 331222 2 296.9 312.4 Unconcentrated Q Iron &Steel 331419 1 598.6 1,080.3 Moderately Concentrated Q Iron &Steel 331511 1 337.5 324.7 Unconcentrated Q Iron &Steel 332618 1 65.6 57.9 Unconcentrated Q Iron &Steel 333516 2 1,139.4 1,066.8 Moderately Concentrated Q Iron &Steel 336611 1 1,545.7 1,838.9 Concentrated

R Lead 331419 1 598.6 1,080.3 Moderately Concentrated

R Lead 331492 12 344.0 345.6 Unconcentrated

## 34

Subpart NAICS Number of Subpart C Facilities Affected by 2015 Deferral 1 

### HHI,

VOS 2 

### HHI,

VA 2 

### Finding

S Lime 212312 4 N/A N/A N/A

S Lime 212391 1 N/A N/A N/A

S Lime 311313 21 N/A N/A N/A

S Lime 327125 1 819.2 932.7 Unconcentrated
S Lime 327410 49 1,424.1 1,394.2 Moderately Concentrated
S Lime 331111 1 785.6 906.8 Unconcentrated
U Carbonate 212392 1 N/A N/A N/A

U Carbonate 212399 1 N/A N/A N/A

U Carbonate 221112 1 N/A N/A N/A

U Carbonate 325181 1 2,391.7 2,428.2 Concentrated
U Carbonate 325188 5 223.5 303.4 Unconcentrated
U Carbonate 325199 2 360.5 289.0 Unconcentrated
U Carbonate 325311 3 1,135.6 1,214.9 Moderately Concentrated

U Carbonate 325312 2 D 2,777.2 Concentrated

U Carbonate 327211 3 N/A N/A N/A

U Carbonate 327213 2 2,506.6 2,468.8 Concentrated
U Carbonate 331511 2 337.5 324.7 Unconcentrated
U Carbonate 331524 1 288.8 306.4 Unconcentrated
U Carbonate 333612 1 352.0 347.9 Unconcentrated

V Nitric Acid 325110 1 2,535.2 D Concentrated

V Nitric Acid 325120 1 1,415.2 1,377.8 Moderately Concentrated

V Nitric Acid 325188 1 223.5 303.4 Unconcentrated

V Nitric Acid 325192 1 2,328.9 D Concentrated

V Nitric Acid 325199 4 360.5 289.0 Unconcentrated

V Nitric Acid 325211 1 400.4 546.4 Unconcentrated

V Nitric Acid 325311 30 1,135.6 1,214.9 Moderately Concentrated

V Nitric Acid 325920 1 920.7 1,037.2 Moderately Concentrated

V Nitric Acid 424690 1 N/A N/A N/A
V Nitric Acid 424910 1 N/A N/A N/A
W Petroleum & Natural Gas 211111 689 N/A N/A N/A
W Petroleum & Natural Gas 211112 201 N/A N/A N/A

W Petroleum & Natural Gas 213112 21 N/A N/A N/A

W Petroleum & Natural Gas 221111 1 N/A N/A N/A

W Petroleum & Natural Gas 221112 6 N/A N/A N/A
W Petroleum & Natural Gas 221121 3 N/A N/A N/A
W Petroleum & Natural Gas 221122 5 N/A N/A N/A

W Petroleum & Natural Gas 221210 193 N/A N/A N/A

W Petroleum & Natural Gas 237120 1 N/A N/A N/A

## 35

Subpart NAICS Number of Subpart C Facilities Affected by 2015 Deferral 1 

### HHI,

VOS 2 

### HHI,

VA 2 

### Finding

W Petroleum & Natural Gas 325110 2 2,535.2 D Concentrated

W Petroleum & Natural Gas 325181 1 2,391.7 2,428.2 Concentrated

W Petroleum & Natural Gas 486210 471 N/A N/A N/A

X Petrochem 221112 3 N/A N/A N/A
X Petrochem 221330 1 N/A N/A N/A
X Petrochem 324110 5 806.5 811.6 Unconcentrated

X Petrochem 324191 1 794.5 1,902.5 Concentrated

X Petrochem 325110 21 2,535.2 D Concentrated

X Petrochem 325120 2 1,415.2 1,377.8 Moderately Concentrated

X Petrochem 325181 7 2,391.7 2,428.2 Concentrated

X Petrochem 325182 16 N/A N/A N/A
X Petrochem 325188 4 223.5 303.4 Unconcentrated

X Petrochem 325199 25 360.5 289.0 Unconcentrated

X Petrochem 325211 13 400.4 546.4 Unconcentrated

X Petrochem 325212 1 727.8 717.4 Unconcentrated

X Petrochem 325998 1 158.4 212.6 Unconcentrated

X Petrochem 424710 1 N/A N/A N/A
Y Petroleum Refineries 211111 2 N/A N/A N/A
Y Petroleum Refineries 237120 1 N/A N/A N/A

Y Petroleum Refineries 324110 143 806.5 811.6 Unconcentrated

Y Petroleum Refineries 324121 2 188.4 206.4 Unconcentrated

Y Petroleum Refineries 324191 2 794.5 1,902.5 Concentrated

Y Petroleum Refineries 324199 2 739.8 617.1 Unconcentrated

Y Petroleum Refineries 325110 6 2,535.2 D Concentrated

Y Petroleum Refineries 325120 1 1,415.2 1,377.8 Moderately Concentrated

Y Petroleum Refineries 325212 1 727.8 717.4 Unconcentrated

Y Petroleum Refineries 424710 3 N/A N/A N/A

Y Petroleum Refineries 561210 1 N/A N/A N/A Z Phosphoric Acid 311119 1 285.4 290.2 Unconcentrated Z Phosphoric Acid 325188 1 223.5 303.4 Unconcentrated Z Phosphoric Acid 325311 2 1,135.6 1,214.9 Moderately Concentrated Z Phosphoric Acid 325312 12 D 2,777.2 Concentrated AA Pulp & Paper 321113 1 98.3 59.8 Unconcentrated AA Pulp & Paper 321999 1 65.1 90.1 Unconcentrated AA Pulp & Paper 322110 52 1,023.5 1,235.7 Moderately Concentrated AA Pulp & Paper 322121 53 758.9 1,036.2 Moderately Concentrated AA Pulp & Paper 322122 4 N/A N/A N/A AA Pulp & Paper 322130 36 713.1 768.6 Unconcentrated

## 36

Subpart NAICS Number of Subpart C Facilities Affected by 2015 Deferral 1 

### HHI,

VOS 2 

### HHI,

VA 2 

### Finding AA Pulp & Paper 322222 1 630.1 1,274.5 Moderately Concentrated AA Pulp & Paper 325191 1 2,389.8 D Concentrated AA Pulp & Paper 325998 1 158.4 212.6 Unconcentrated AA Pulp & Paper 423990 1 274.5 386.1 Unconcentrated
BB Silicon Carbide 327910 1 1,662.4 2,197.7 Concentrated
CC Soda Ash 212391 4 N/A N/A N/A
EE Titanium Dioxide 325131 6 1,265.0 1,293.6 Moderately Concentrated

EE Titanium Dioxide 325188 1 223.5 303.4 Unconcentrated

GG Zinc 331492 6 344.0 345.6 Unconcentrated HH Municipal Landfills 221112 1 N/A N/A N/A HH Municipal Landfills 221119 2 N/A N/A N/A HH Municipal Landfills 562111 6 N/A N/A N/A HH Municipal Landfills 562211 2 N/A N/A N/A HH Municipal Landfills 562212 1194 N/A N/A N/A HH Municipal Landfills 562213 4 N/A N/A N/A HH Municipal Landfills 562920 2 N/A N/A N/A HH Municipal Landfills 921190 1 N/A N/A N/A HH Municipal Landfills 924110 2 N/A N/A N/A HH Municipal Landfills 928110 6 N/A N/A N/A

II Industrial Wastewater 112340 1 N/A N/A N/A

II Industrial Wastewater 221112 1 N/A N/A N/A

II Industrial Wastewater 311119 1 285.4 290.2 Unconcentrated
II Industrial Wastewater 311221 8 2,338.2 2,291.2 Concentrated
II Industrial Wastewater 311222 1 1,930.8 2,496.1 Concentrated

II Industrial Wastewater 311225 1 1,030.3 950.2 Moderately Concentrated

II Industrial Wastewater 311411 7 586.6 648.1 Unconcentrated

II Industrial Wastewater 311421 2 254.8 295.2 Unconcentrated

II Industrial Wastewater 311422 1 2,885.1 D Concentrated

II Industrial Wastewater 311611 21 1,046.5 644.0 Moderately Concentrated
II Industrial Wastewater 311612 5 258.1 330.3 Unconcentrated
II Industrial Wastewater 311613 17 645.6 800.5 Unconcentrated

II Industrial Wastewater 311615 14 737.6 937.0 Unconcentrated

II Industrial Wastewater 311919 1 N/A N/A N/A

II Industrial Wastewater 312120 1 N/A N/A N/A
II Industrial Wastewater 312140 2 1,519.4 2,373.6 Concentrated
II Industrial Wastewater 316110 1 560.3 466.8 Unconcentrated

II Industrial Wastewater 322110 2 1,023.5 1,235.7 Moderately Concentrated

II Industrial Wastewater 322121 2 758.9 1,036.2 Moderately Concentrated

## 37

Subpart NAICS Number of Subpart C Facilities Affected by 2015 Deferral 1 

### HHI,

VOS 2 

### HHI,

VA 2 

### Finding

II Industrial Wastewater 322130 8 713.1 768.6 Unconcentrated

II Industrial Wastewater 325191 1 2,389.8 D Concentrated

II Industrial Wastewater 325193 87 275.1 298.0 Unconcentrated

II Industrial Wastewater 562219 2 N/A N/A N/A
II Industrial Wastewater 811111 1 N/A N/A N/A
TT Industrial Landfills 111930 1 N/A N/A N/A
TT Industrial Landfills 212234 1 N/A N/A N/A

TT Industrial Landfills 221112 6 N/A N/A N/A

TT Industrial Landfills 221113 1 N/A N/A N/A

TT Industrial Landfills 311221 2 2,338.2 2,291.2 Concentrated

TT Industrial Landfills 311223 1 2,752.7 2,221.5 Concentrated

TT Industrial Landfills 311311 1 N/A N/A N/A
TT Industrial Landfills 311313 9 N/A N/A N/A

TT Industrial Landfills 321113 1 98.3 59.8 Unconcentrated

TT Industrial Landfills 321212 1 1,233.3 1,408.3 Moderately Concentrated

TT Industrial Landfills 321219 2 345.0 322.8 Unconcentrated

TT Industrial Landfills 321999 1 65.1 90.1 Unconcentrated

TT Industrial Landfills 322110 38 1,023.5 1,235.7 Moderately Concentrated

TT Industrial Landfills 322121 51 758.9 1,036.2 Moderately Concentrated

TT Industrial Landfills 322122 4 N/A N/A N/A

TT Industrial Landfills 322130 30 713.1 768.6 Unconcentrated

TT Industrial Landfills 322222 1 630.1 1,274.5 Moderately Concentrated

TT Industrial Landfills 322291 2 1,317.8 1,789.4 Moderately Concentrated

TT Industrial Landfills 324110 4 806.5 811.6 Unconcentrated

TT Industrial Landfills 325110 3 2,535.2 D Concentrated

TT Industrial Landfills 325120 2 1,415.2 1,377.8 Moderately Concentrated

TT Industrial Landfills 325181 1 2,391.7 2,428.2 Concentrated

TT Industrial Landfills 325188 1 223.5 303.4 Unconcentrated

TT Industrial Landfills 325191 1 2,389.8 D Concentrated

TT Industrial Landfills 325192 1 2,328.9 D Concentrated

TT Industrial Landfills 325193 1 275.1 298.0 Unconcentrated

TT Industrial Landfills 325199 11 360.5 289.0 Unconcentrated

TT Industrial Landfills 325211 9 400.4 546.4 Unconcentrated

TT Industrial Landfills 325221 1 N/A N/A N/A
TT Industrial Landfills 325311 1 1,135.6 1,214.9 Moderately Concentrated

TT Industrial Landfills 325320 1 1,109.1 1,632.2 Moderately Concentrated

TT Industrial Landfills 325412 1 456.8 532.6 Unconcentrated

TT Industrial Landfills 325998 3 158.4 212.6 Unconcentrated

## 38

Subpart NAICS Number of Subpart C Facilities Affected by 2015 Deferral 1 

### HHI,

VOS 2 

### HHI,

VA 2 

### Finding

TT Industrial Landfills 327111 1 D D N/A

TT Industrial Landfills 331111 5 785.6 906.8 Unconcentrated

TT Industrial Landfills 331311 1 N/A N/A Concentrated

TT Industrial Landfills 331312 3 2,250.3 D Concentrated

TT Industrial Landfills 331314 2 930.8 2,019.9 Unconcentrated

TT Industrial Landfills 331316 1 433.3 394.7 Moderately Concentrated

TT Industrial Landfills 331319 1 1,119.8 1,391.6 Moderately Concentrated

TT Industrial Landfills 331411 1 N/A N/A N/A

TT Industrial Landfills 331511 5 337.5 324.7 Unconcentrated

TT Industrial Landfills 331513 1 458.1 542.1 Unconcentrated

TT Industrial Landfills 331521 1 371.7 364.5 Unconcentrated

TT Industrial Landfills 331524 1 288.8 306.4 Unconcentrated

TT Industrial Landfills 332112 1 888.4 1,034.3 Moderately Concentrated

TT Industrial Landfills 332913 1 1,532.2 1,810.9 Concentrated

TT Industrial Landfills 332998 1 1,312.0 1,611.5 Moderately Concentrated

TT Industrial Landfills 333315 1 1,831.1 1,873.4 Concentrated

TT Industrial Landfills 333618 1 1,022.1 1,089.4 Moderately Concentrated

TT Industrial Landfills 562212 16 N/A N/A N/A
TT Industrial Landfills 562910 1 N/A N/A N/A

1 

### Facilities may report more than one NAICS code; thus, the sum of the number of NAICS codes reported by facilities in a subpart may exceed the total number of facilities reporting under that subpart.

2 

### HHI: Herfindahl

- Hirschman index This index is calculated by summing the squares of the individual company percentages for the 50 largest companies or the universe, whichever is lower. Values less than 1000 are considered unconcentrated, values between 1000 and 1800 are considered moderat ely concentrated, and values over 1800 are considered concentrated. VOS is Value of Shipments; VA is Value Added.

## 39 

## Appendix B

Results of the Evaluation of Competitive Harm f rom Disclosure of Data Elements Deferred to March 31, 2015

## 40



## Table B

- 1. Final Results of the Evaluation of Competitive Harm from Disclosure of Data Elements Deferred to March 31, 2015

Subpart 

### Rule Citation in 40

CFR Part 98 Data Element Description Data Element is used as Input to Equation . . . Analysis Results
C (Stationary fuel combustion sources excluding those located at a facility with total generator capacity greater than 1 megawatt (MW) electric output and containing at least one combustion unit connected to a fuel

fired electric generator owned or operated by an entity that is subject to regulation of customer billing rates by the public utility commission (excluding generators connected to combustion units subject to 40 CFR part 98, subpart D)) 

### §98.3(d)(3)(v) For any facility who submitted an abbreviated

e missions report under §98.3(d)(3)(v), any facility operating data or process information used for the GHG emission calculations. Provides data related to process design; process performance, and operation; and/or cost to do business, as described in sect ion 2.2 of Part Two of this memorandum. Specifically, indicates the quantity of fuel used in the process, which could reveal information about the cost to produce products. For specialty fuels that are byproducts of the production process, information about fuel characteristics indicates the com position of the process byproduct, which could reveal information about process efficiency and cost to produce a product.

C (Stationary fuel combustion sources excluding those located at a facility with total generator capacity greater than 1 megawatt (M W) electric output and containing at least one combustion unit connected to a fuel

fired electric generator owned or operated by an entity that is subject to regulation of customer billing rates by the public utility commission (excluding generators

connec ted to combustion units subject to 40 CFR part 98, subpart D)) 

### §98.36(b)(9)(iii) Estimate of the heat input from each type of fuel listed in Table C

- 2 that was combusted in the unit during the report year. C

- 10 Provides data related to process design; process performance, and operation; and/or cost to do business, as described in section 2.2 of Part Two of this memorandum. Specifically, for specialty fuels that are byproducts of the production process, indicates the composition of the process byproduct, which could reveal information about process efficiency and cost to produce a product.

## 41 Subpart 

### Rule Citation in 40

CFR Part 98 Data Element Description Data Element is used as Input to Equation . . . Analysis Results C (Stationary fuel combustion sources excluding those located at a facility with total generator capacity greater than 1 megawatt (MW) electric output and containing a t least one combustion unit connected to a fuel

fired electric generator owned or operated by an entity that is subject to regulation of customer billing rates by the public utility commission (excluding generators connected to combustion units subject to 40 CFR part 98, subpart D)) 

### §98.36(c)(2)(ix) The flue gases from two or more stationary fuel combustion units at a facility are combined together and discharged through a common stack or duct before exiting to the atmosphere and if CEMS are used to continu ously monitor CO 2 mass emissions at the common stack or duct according to the Tier 4 Calculation Methodology, you may report the combined emissions from the units sharing the common stack or duct, in lieu of separately reporting the GHG emissions from the individual units. This monitoring and reporting alternative may also be used when process off

- gases or a mixture of combustion products and process gases are combined together in a common stack or duct before exiting to the atmosphere. An estimate of the h eat input from each type of fuel listed in Table C

- 2 combusted during the reporting year. C

- 10 Provides data related to process design; process performance, and operation; and/or cost to do business, as described in section 2.2 of Part Two of this

memora ndum. Specifically, indicates the quantity of fuel used in the process, which could reveal information about the cost to produce products.

C (Stationary fuel combustion sources excluding those located at a facility with total generator capacity greater th an 1 megawatt (MW) electric output and containing at least one combustion unit connected to a fuel

fired electric generator owned or operated by an entity that is subject to regulation of customer billing rates by the public utility commission (excluding g enerators connected to combustion units subject to 40 CFR part 98, subpart D)) 

### §98.36(e)(2)(i);

§98.36(e)(2)(ii)(A); §98.36(e)(2)(iv)(A) Total quantity of each type of fuel combusted in each unit or group of aggregated units (as applicable). C

- 1, C

- 1a, C

1b, C

- 8, C

- 8a, C

- 8b; C

- 2a, C

2b, C

- 9a; C

- 3 (to calculate annual fuel quantity) and C

- 2b (method cited in Eq C

- 3 to calculate annual average carbon content), C

- 4( to calculate annual fuel quantity) and C

- 2b (method cited in Eq C

- 4 to calculate annual average carbon content), C

- 5( to calculate annual fuel quantity) and C

- 2b (method cited in Eq C

- 5 to calculate annual average carbon content), C

- 8, C

- 13 In certain cases provides

production or raw material data described in section 2.1 of Part
Two of this memorandum. Also, in certain cases provides data related to process design; process performance, and operation; and/or cost to do business, as described in section 2.2 of Part Two of this memorandum. Specifically, could reveal information about the cost to produce products.

## 42 Subpart 

### Rule Citation in 40

CFR Part 98 Data Element Description Data Element is used as Input to Equation . . . Analysis Results C (Stationary fuel combustion sources excluding those located at a facility with total generator capacity greater than 1 megawatt (MW) electric output and containing at least one combustion unit connected to a fuel

fired electri c generator owned or operated by an entity that is subject to regulation of customer billing rates by the public utility commission (excluding generators connected to combustion units subject to 40 CFR part 98, subpart D)) 

### §98.36(e)(2)(ii)(C) High heat va lues used in the CO 2 emissions calculations for each fuel combusted during the reporting year. Report a HHV value for each calendar month in which HHV determination is required. If multiple values are obtained in a given month, report the arithmetic

averag e value for the month. C

- 2a, C

- 2b, C

9a Provides data related to process

design; process performance, and operation; and/or cost to do business, as described in section 2.2 of Part Two of this memorandum. Specifically, for specialty fuels that are byproducts of the production process, indicates the composition of the process byproduct, which could reveal information about process efficiency and cost to produce a product.

C (Stationary fuel combustion sources excluding those located at a facility with total generator capacity greater than 1 megawatt (MW) electric output and containing at least one combustion unit connected to a fuel

fired electric generator owned or operated by an entity that is subject to regulation of customer billing rates by th e public utility commission (excluding generators connected to combustion units subject to 40 CFR part 98, subpart D)) 

### §98.36(e)(2)(ii)(D) If Eq. C

- 2c is used: Ratio of the maximum rate heat input capacity to the design rated steam output capacity of the unit. C

- 2c, C

- 9b Provides data related to process design; process performance, and operation; and/or cost to do business, as described in section 2.2 of Part Two of this memorandum. Specifically, indicates the efficiency of the unit, which could reveal in formation about the cost to produce the

steam.

## 43 Subpart 

### Rule Citation in 40

CFR Part 98 Data Element Description Data Element is used as Input to Equation . . . Analysis Results C (Stationary fuel combustion sources excluding those located at a facility with total generator capacity greater than 1 megawatt (MW) electric output and containing at least one combustion unit connected to a fuel

fired electric generator owned or operated by an entity that is subject to regulation of customer billing rates by the public utility commission (excluding generators connected to combustion units subject to 40 CFR part 98, subpart D)) 

### §98.36(e)(2)( ii)(D) If Eq. C

- 2c is used: Total quantity (i.e., pounds) of steam produced from MSW or solid fuel combustion during each month of the reporting year. C

- 2c, C

- 9b Provides data related to process design; process performance, and operation; and/or cost to do business, as described in section 2.2 of Part Two of this memorandum. Specifically, indicates the efficiency of the unit, which could reveal information about the cost to produce the

steam.

C (Stationary fuel combustion sources excluding those located at a facility with total generator capacity greater than 1 megawatt (MW) electric output and containing at least one combustion unit connected to a fuel

fired electric generator owned or operated by an entity that is subject to regulation of customer billi ng rates by the public utility commission (excluding generators connected to combustion units subject to 40 CFR part 98, subpart D)) 

### §98.36(e)(2)(iv)(C) The carbon content used in the emission calculations (including both valid and substitute data values) . For each calendar month of the reporting year in which carbon content and, if applicable, molecular weight determination is required, report a value of each parameter. If multiple values of a parameter are obtained in a given month, report the arithmetic average value for the month. (CC). C

- 2b (method cited in Eq C

- 3 to calculate annual average carbon content, an input to Eq C

- 3) Provides data related to process

design; process performance, and operation; and/or cost to do business, as described in sectio n 2.2 of Part Two of this memorandum. Specifically, for specialty fuels that are byproducts of the production process, indicates the composition of the process byproduct, which could reveal information about process efficiency and cost to produce a product

.

## 44 Subpart 

### Rule Citation in 40

CFR Part 98 Data Element Description Data Element is used as Input to Equation . . . Analysis Results C (Stationary fuel combustion sources excluding those located at a facility with total generator capacity greater than 1 megawatt (MW) electric output and containing at least one combustion unit connected to a fuel

fired electric generator owned or oper ated by an entity that is subject to regulation of customer billing rates by the public utility commission (excluding generators connected to combustion units subject to 40 CFR part 98, subpart D)) 

### §98.36(e)(2)(iv)(C) The carbon content used in the emission calculations (including both valid and substitute data values). For each calendar month of the reporting year in which carbon content and, if applicable, molecular weight determination is required, report a value of each parameter. If multiple val ues of a parameter are obtained in a given month, report the arithmetic average value for the month. (CC). C

- 2b (method cited in Eq C

- 4 to calculate annual average carbon content, an input to Eq C

- 4) Provides data related to process

design; process perform ance, and operation; and/or cost to do business, as described in section 2.2 of Part Two of this memorandum. Specifically, for specialty fuels that are byproducts of the production process, indicates the composition of the process byproduct, which could re veal information about process efficiency and cost to produce a product.

C (Stationary fuel combustion sources excluding those located at a facility with total generator capacity greater than 1 megawatt (MW) electric output and containing at least one

com bustion unit connected to a fuel

fired electric generator owned or operated by an entity that is subject to regulation of customer billing rates by the public utility commission (excluding generators connected to combustion units subject to 40 CFR part 98, subpart D)) 

### §98.36(e)(2)(iv)(C) The carbon content used in the emission calculations (including both valid and substitute data values). For each calendar month of the reporting year in which carbon content and, if applicable, molecular weight determinati on is required, report a value of each parameter. If multiple values of a parameter are obtained in a given month, report the arithmetic average value for the month. (CC). C

- 2b (method cited in Eq C

- 5 to calculate annual average carbon content, an input to Eq C

- 5) Provides data related to process

design; process performance, and operation; and/or cost to do business, as described in section 2.2 of Part Two of this memorandum. Specifically, for specialty fuels that are byproducts of the production process, i ndicates the composition of the process byproduct, which could reveal information about process efficiency and cost to produce a product.

## 45 Subpart 

### Rule Citation in 40

CFR Part 98 Data Element Description Data Element is used as Input to Equation . . . Analysis Results C (Stationary fuel combustion sources excluding those located at a facility with total generator capacity greater than 1 megawatt (MW) electric output and containing at least one combustion unit connected to a fuel

fired electric generator owned or operated by an entity that is subject to regulation of customer billing rates by the public utility commission (excluding generators connected to combustion units subject to 40 CFR part 98, subpart D)) 

### §98.36(e)(2)(iv)(C) Gas molecular weight values used in the emission calculations (including both valid and substitute data values). For each calendar month of the reporting year in which carbon content and, if applicable, molecular weight determination is required, report a value of each parameter. If multiple values of a parameter are obtained in a given month, report the arithmetic average value for the month. C

- 2b (method cited in Eq C

- 5 to calculate annual average carbon content, an input to Eq C

- 5) Provides data related to process

design; process performance, and operation; and/or cost to do business, as described in section 2.2 of Part Two of this memorandum. Specifical ly, for specialty fuels that are byproducts of the production process, indicates the composition of the process byproduct, which could reveal information about process efficiency and cost to produce a product.

C (Stationary fuel combustion sources excludi ng those located at a facility with total generator capacity greater than 1 megawatt (MW) electric output and containing at least one combustion unit connected to a fuel

fired electric generator owned or operated by an entity that is subject to regulation of customer billing rates by the public utility commission (excluding generators connected to combustion units subject to 40 CFR part 98, subpart D)) 

### §98.36(e)(2)(iv)(F) The annual average HHV, when measured HHV data, rather than a default HHV from Table C

- 1 of this subpart, are used to calculate CH4 and N2O emissions for a Tier 3 unit, in accordance with §98.33(c)(1). C

- 8 Provides data related to process design; process performance, and operation; and/or cost to do business, as described in section 2.2 of Part Two of this memorandum. Specifically, for specialty fuels that are byproducts of the production process, indicates the composition of the process byproduct, which could reveal information about process efficiency and cost to produce a product.

## 46 Subpart 

### Rule Citation in 40

CFR Part 98 Data Element Description Data Element is used as Input to Equation . . . Analysis Results C (St ationary fuel combustion sources excluding those located at a facility with total generator capacity greater than 1 megawatt (MW) electric output and containing at least one combustion unit connected to a fuel

fired electric generator owned or operated by an entity that is subject to regulation of customer billing rates by the public utility commission (excluding generators connected to combustion units subject to 40 CFR part 98, subpart D)) 

### §98.36(e)(2)(ix)(D) For units that combust both fossil fuel and b iomass, when biogenic CO 2 is determined according to §98.33(e)(2), report the carbon

- based F

factor used in Equation C

- 13 of this subpart. C

- 13 Provides data related to process design; process performance, and operation; and/or cost to do business, as desc ribed in section 2.2 of Part Two of this memorandum. Specifically, for specialty fuels that are byproducts of the production process, indicates the composition of the process byproduct, which could reveal information about process efficiency and cost to pr oduce a product.

C (Stationary fuel combustion sources excluding those located at a facility with total generator capacity greater than 1 megawatt (MW) electric output and containing at least one combustion unit connected to a fuel

fired electric generator owned or operated by an entity that is subject to regulation of customer billing rates by the public utility commission (excluding generators connected to combustion units subject to 40 CFR part 98, subpart D)) 

### §98.36(e)(2)(ix)(E) For units that combust both fossil fuel and biomass, when biogenic CO 2 is determined according to §98.33(e)(2), report the annual average HHV value used in Equation C

- 13 of this subpart. C

- 13 Provides data related to process design; process performance, and operation; a nd/or cost to do business, as described in section 2.2 of Part Two of this memorandum. Specifically, for specialty fuels that are byproducts of the production process, indicates the composition of the process byproduct, which could reveal information about process efficiency and cost to produce a product.

## 47 Subpart 

### Rule Citation in 40

CFR Part 98 Data Element Description Data Element is used as Input to Equation . . . Analysis Results C (Stationary fuel combustion sources excluding those located at a facility with total generator capacity greater than 1 megawatt (MW) electric output and containing at least one combustion unit connected to a fuel

fired electric generator owned or operated by an entity that is subject to regulation of customer billing rates by the public utility commission (excluding generators connected to combustion units subject to 40 CFR part 98, subpart D)) 

### §98.36(e) (2)(ix)(F) For units that combust both fossil fuel and biomass, when biogenic CO 2 is determined according to §98.33(e)(2), report the total quantity of fossil fuel combusted during the reporting year. C

- 13 Provides data related to process design; process performance, and operation; and/or cost to do business, as described in section 2.2 of Part Two of this memorandum. Specifically, indicates the quantity of fuel used in the process, which, in certain cases, could reveal information about the cost to produc e products.

C (Stationary fuel combustion sources containing at least one combustion unit located at a facility with total generator capacity greater than 1 megawatt (MW) electric output and containing at least one combustion unit connected to a fuel

fired electric generator owned or operated by an entity that is subject to regulation of customer billing rates by the public utility commission (excluding generators connected to combustion units subject to 40 CFR part 98, subpart D)) §98.3(d)(3)(v) For any facility who submitted an abbreviated emissions report under §98.3(d)(3)(v), any facility operating data or process information used for the GHG emission calculations. Would not reveal any proprietary information about facility or process perform ance, design, and operation; cost to do business; raw material usage; or production. Site

specific fuel characteristics for these units do not vary significantly from publicly

- known average values. For facilities with these combustion units, certain fuel u se and fuel characterization data for the units are reported and publicly released via the EIA. Additionally for the electric utilities, this sector has experienced a high level of transparency due to the practice of passing fuel costs through to paying cu stomers.

## 48 Subpart 

### Rule Citation in 40

CFR Part 98 Data Element Description Data Element is used as Input to Equation . . . Analysis Results C (Stationary fuel combustion sources containing at least one combustion unit located at a facility with total generator capacity greater than 1 megawatt (MW) electric output and containing at least one combustion unit connected to a fuel

fired electric generator owned or operated by an entity that is subject to regulation of customer billing rates by the public utility commission (excluding generators connected to combustion units subject to 40 CFR part 98, subpart D)) §98.36(b)(9)(iii) Estimate of the heat input from each type of fuel listed in Table C

- 2 that was combusted in the unit during the report year. C

- 10 For facilities with these types of combustion units, facility

- level heat input from each type of fuel is publicly available because it can be calculated based on other data reported and publicly released via EIA. As required to be reported under Part 98, an estimate of the heat input from each type of fuel for the combustion unit(s) would not reveal any proprietary information about faci lity or process performance, design, and operation; cost to do business; raw material usage; or production. Site

specific fuel characteristics for these units do not vary significantly from publicly

- known average values. Additionally for the electric utili ties, this sector has experienced a high level of transparency due to the practice of passing fuel costs through to paying customers.

C (Stationary fuel combustion sources containing at least one combustion unit located at a facility with total generator capacity greater than 1 megawatt (MW) electric output and containing at least one combustion unit connected to a fuel

fired electric generator owned or operated by an entity that is subject to regulation of customer billing rates by the public utility comm ission (excluding generators connected to combustion units subject to 40 CFR part 98, subpart D)) §98.36(c)(2)(ix) The flue gases from two or more stationary fuel combustion units at a facility are combined together and discharged through a common stack or duct before exiting to the atmosphere and if CEMS are used to continuously monitor CO 2 mass emissions at the common stack or duct according to the Tier 4 Calculation Methodology, you may report the combined emissions from the units sharing the common stack or duct, in lieu of separately reporting the GHG emissions from the individual units. This monitoring and reporting alternative may also be used when process off

- gases or a mixture of combustion products and process gases are combined together in a common stack or duct before exiting to the atmosphere. An estimate of the heat input from ea ch type of fuel listed in Table C

- 2 combusted during the reporting year. C

- 10 Would not reveal any proprietary information about facility or process performance, design, and operation; cost to do business; raw material usage; or production. Site

specific fuel characteristics do not vary significantly from publicly

known average values. Additionally for the electric utilities, this sector has experienced a high level of transparency due to the practice of passing fuel costs through to paying customers.

## 49 Subpart 

### Rule Citation in 40

CFR Part 98 Data Element Description Data Element is used as Input to Equation . . . Analysis Results
C (Stationary fuel combustion sources containing at least one combustion unit located at a facility with total generator capacity greater than 1 megawatt (MW) electric output and containing at least one combustion unit connected to a fuel

fired electric gene rator owned or operated by an entity that is subject to regulation of customer billing rates by the public utility commission (excluding generators connected to combustion units subject to 40 CFR part 98, subpart D)) §98.36(e)(2)(i); §98.36(e)(2)(ii)(A); § 98.36(e)(2)(iv)(A) Total quantity of each type of fuel combusted in each unit or group of aggregated units (as applicable). C

- 1, C

- 1a, C

1b, C

- 8, C

- 8a, C

- 8b; C

- 2a, C

2b, C

- 9a; C

- 3 (to calculate annual fuel quantity) and C

- 2b (method cited in Eq C

- 3 to calculate annual average carbon content), C

- 4( to calculate annual fuel quantity) and C

- 2b (method cited in Eq C

- 4 to calculate annual average carbon content), C

- 5( to calculate annual fuel quantity) and C

- 2b (method cited in Eq C

- 5 to calculate annual average carbon content), C

- 8, C

- 13 For facilities with these types of

combustion units, facility

- level quantity of each type of fu el combusted is publicly released by EIA. As required to be reported under Part 98, quantity of each type of fuel combusted for the combustion unit(s) would not reveal any proprietary information about facility or process performance, design, and operation ; cost to do business; raw material usage; or production. Additionally for the electric utilities, this sector has experienced a high level of transparency due to the practice of passing fuel costs through to paying customers.

C (Stationary fuel combusti on sources containing at least one combustion unit located at a facility with total generator capacity greater than 1 megawatt (MW) electric output and containing at least one combustion unit connected to a fuel

fired electric generator owned or operated b y an entity that is subject to regulation of customer billing rates by the public utility commission (excluding generators connected to combustion units subject to 40 CFR part 98, subpart D)) §98.36(e)(2)(ii)(C) High heat values used in the CO 2 emissions c alculations for each fuel combusted during the reporting year. Report a HHV value for each calendar month in which HHV determination is required. If multiple values are obtained in a given month, report the arithmetic average value for the month. C

- 2a, C

- 2b, C

9a Would not reveal any proprietary

information about facility or process performance, design, and operation; cost to do business; raw material usage; or production. Site

specific fuel characteristics do not vary significantly from publicly

known ave rage values. Additionally for the electric utilities, this sector has experienced a high level of transparency due to the practice of passing fuel costs through to paying customers.

## 50 Subpart 

### Rule Citation in 40

CFR Part 98 Data Element Description Data Element is used as Input to Equation . . . Analysis Results C (Stationary fuel combustion sources containing at least one combustion unit located at a facility with total generator capacity greater than 1 megawatt (MW) electric output and containing at least one combustion unit connected to a fuel

fired electric generator owned or operated by an entity that is subject to regulation of customer billing rates by the public utility commission (excluding generators connected to combustion units subject to 40 CFR part 98, subpart D)) §98.36(e)(2)(ii)(D) If Eq. C

- 2c is used: Total quantity (i.e., pounds) of steam produced from MSW or solid fu el combustion during each month of the reporting year. C

- 2c, C

- 9b Would not reveal any proprietary information about facility or process performance, design, and operation; cost to do business; raw material usage; or production. MSW combustors are typicall y operated by municipalities. Additionally for the electric utilities, this sector has experienced a high level of transparency due to the practice of passing fuel costs through to paying customers.

C (Stationary fuel combustion sources containing at least one combustion unit located at a facility with total generator capacity greater than 1 megawatt (MW) electric output and containing at least one combustion unit connected to a fuel

fired electric generator owned or operated by an entity that is subje ct to regulation of customer billing rates by the public utility commission (excluding generators connected to combustion units subject to 40 CFR part 98, subpart D)) §98.36(e)(2)(ii)(D) If Eq. C

- 2c is used: Ratio of the maximum rate heat input capacity to the design rated steam output capacity of the unit. C

- 2c, C

- 9b Would not reveal any proprietary information about facility or process performance, design, and operation; cost to do business; raw material usage; or production. Can be determined from equipment model information that is publicly available from manufactur ers of the electricity generating equipment. Additionally for the electric utilities, this sector has experienced a high level of transparency due to the practice of passing fuel costs through to paying customers.

## 51 Subpart 

### Rule Citation in 40

CFR Part 98 Data Element Description Data Element is used as Input to Equation . . . Analysis Results C (Stationary fuel combustion sources

co ntaining at least one combustion unit located at a facility with total generator capacity greater than 1 megawatt (MW) electric output and containing at least one combustion unit connected to a fuel

fired electric generator owned or operated by an entity t hat is subject to regulation of customer billing rates by the public utility commission (excluding generators connected to combustion units subject to 40 CFR part 98, subpart D)) §98.36(e)(2)(iv)(A) Quantity of each type of fuel combusted in the unit or

gr oup of units (as applicable) during each month of the reporting year (Fuel). C

- 13 For facilities with these types of combustion units, facility

- level quantity of each type of fuel combusted is publicly released by EIA. As required to be reported under Part 98, quantity of each type of fuel combusted for the combustion unit(s) would not reveal any proprietary information about facility or process performance, design, and operation; cost to do business; raw material usage; or production. Additionally for the electric utilities, this sector has experienced a high level of transparency due to the practice of passing fuel costs through to paying customers.

C (Stationary fuel combustion sources containing at least one combustion unit located at a facility with t otal generator capacity greater than 1 megawatt (MW) electric output and containing at least one combustion unit connected to a fuel

fired electric generator owned or operated by an entity that is subject to regulation of customer billing rates by the publ ic utility commission (excluding generators connected to combustion units subject to 40 CFR part 98, subpart D)) §98.36(e)(2)(iv)(A) Quantity of each type of fuel combusted in the unit or group of units (as applicable) during each month of the reporting year (Fuel). C

- 3 (to calculate annual fuel quantity) and C

- 2b (method cited in Eq C

- 3 to calculate annual average carbon content) For facilities with these types of

combustion units, facility

- level quantity of each type of fuel combusted is publicly releas ed by EIA. As required to be reported under Part 98, quantity of each type of fuel combusted for the combustion unit(s) would not reveal any proprietary information about facility or process performance, design, and operation; cost to do business; raw

mate rial usage; or production. Additionally for the electric utilities, this sector has experienced a high level of transparency due to the practice of passing fuel costs through to paying customers.

## 52 Subpart 

### Rule Citation in 40

CFR Part 98 Data Element Description Data Element is used as Input to Equation . . . Analysis Results C (Stationary fuel combustion sources containing at least one combustion unit located at a facility with total generator capacity greater than 1 megawatt (MW) electric output and containing at least one combustion unit connected to a fuel

fired electric generator owned or operated by an entity that is subject to regulation of customer billing rates by the public utility commission (excluding generators connected to combustion units subject to 40 CFR part 98, subpart D)) §98.36(e)(2)(iv)(C) The carbon content used in the emission calculations (including both valid and substitute data values). For each calendar month of the reporting year in which carbon content and, if applicable, molecular weight determination is required, report a value of each parameter. If multiple values of a parameter are obtained in a given m onth, report the arithmetic average value for the month. (CC) C

- 2b (method cited in Eq C

- 5 to calculate annual average carbon content, an input to Eq C

- 5) Would not reveal any proprietary

information about facility or process performance, design, and

opera tion; cost to do business; raw material usage; or production. Site

specific fuel characteristics do not vary significantly from publicly

known average values. Additionally for the electric utilities, this sector has experienced a high level of transparency due to the practice of passing fuel costs through to paying customers.

C (Stationary fuel combustion sources containing at least one combustion unit located at a facility with total generator capacity greater than 1 megawatt (MW) electric output and containing at least one combustion unit connected to a fuel

fired electric generator owned or operated by an entity that is subject to regulation of custom er billing rates by the public utility c ommission (excluding generators connected to combustion units subject to 40 CFR part 98, subpart D)) §98.36(e)(2)(iv)(C) Gas molecular weight values used in the emission calculations (including both valid and substit ute data values). For each calendar month of the reporting year in which carbon content and, if applicable, molecular weight determination is required, report a value of each parameter. If multiple values of a parameter are obtained in a given month, repor t the arithmetic average value for the month. C

- 2b (method cited in Eq C

- 5 to calculate annual average carbon content, an input to Eq C

- 5) Would not reveal any proprietary

information about facility or process performance, design, and operation; cost to d o business; raw material usage; or production. Site

specific fuel characteristics do not vary significantly from publicly

known average values. Additionally for the electric utilities, this sector has experienced a high level of transparency due to the pra ctice of passing fuel costs through to paying customers.

## 53 Subpart 

### Rule Citation in 40

CFR Part 98 Data Element Description Data Element is used as Input to Equation . . . Analysis Results C (Stationary fuel combustion sources containing at least one combustion unit located at a facility with total generator capacity greater than 1 megawatt (MW) electric output and containing at leas t one combustion unit connected to a fuel

fired electric generator owned or operated by an entity that is subject to regulation of customer billing rates by the public utility commission (excluding generators connected to combustion units subject to 40 CFR part 98, subpart D)) §98.36(e)(2)(iv)(F) The annual average HHV, when measured HHV data, rather than a default HHV from Table C

- 1 of this subpart, are used to calculate CH4 and N2O emissions for a Tier 3 unit, in accordance with §98.33(c)(1). C

- 8 For facilities with these types of combustion units, facility

- level HHV data are publicly available because they can be calculated based on other data reported and publicly released via EIA. As required to be reported under Part 98, the HHV data for the combus tion unit(s) would not reveal any proprietary information about facility or process performance, design, and operation; cost to do business; raw material usage; or production. Site

specific fuel characteristics do not vary significantly from publicly

known average values. Additionally for the electric utilities, this sector has experienced a high level of transparency due to the practice of passing fuel costs through to paying customers.

C (Stationary fuel combustion sources containing at least one combus tion unit located at a facility with total generator capacity greater than 1 megawatt (MW) electric output and containing at least one combustion unit connected to a fuel

fired electric generator owned or operated by an entity that is subject to regulation of customer billing rates by the public utility commission (excluding generators connected to combustion units subject to 40 CFR part 98, subpart D)) §98.36(e)(2)(ix)(D) For units that combust both fossil fuel and biomass, when biogenic CO 2 is determined according to §98.33(e)(2), report the carbon

- based F

factor used in Equation C

- 13 of this subpart. C

- 13 Would not reveal any proprietary information about facility or process performance, design, and operation; cost to do business; raw

mater ial usage; or production. Site

specific fuel characteristics do not vary significantly from publicly

known average values. Additionally for the electric utilities, this sector has experienced a high level of transparency due to the practice of passing fuel costs through to paying customers.

## 54 Subpart 

### Rule Citation in 40

CFR Part 98 Data Element Description Data Element is used as Input to Equation . . . Analysis Results C (Stationary fuel combustion sources containing at least one combustion unit located at a facility with total generator capacity greater than 1 megawatt (MW) electric output and containing at least one combustion unit connected to a fuel

fired electric generator owned or operated by an entity that is subject to regulation of customer billing rates by the public utility commission (excluding generators connected to combustion units subject to 40 CFR part 98, subpart D)) §98.36(e)(2)(ix)(E) For units that combust both fossil fuel and biomass, when biogenic CO 2 is determined according to §98.33(e)(2), report the annual average HHV value used in Equation C

- 13 of this subpart. C

- 13 For facilities with these types of combusti on units, facility

- level HHV data are publicly available because they can be calculated based on other data reported and publicly released via EIA. As required to be reported under Part 98, the HHV data for the combustion unit(s) would not reveal any propr ietary information about facility or process performance, design, and operation; cost to do business; raw material usage; or production. Site

specific fuel characteristics do not vary significantly from publicly

known average values. Additionally for the e lectric utilities, this sector has experienced a high level of transparency due to the practice of passing fuel costs through to paying customers.

C (Stationary fuel combustion sources containing at least one combustion unit located at a facility with to tal generator capacity greater than 1 megawatt (MW) electric output and containing at least one combustion unit connected to a fuel

fired electric generator owned or operated by an entity that is subject to regulation of customer billing rates by the publi c utility commission (excluding generators connected to combustion units subject to 40 CFR part 98, subpart D)) §98.36(e)(2)(ix)(F) For units that combust both fossil fuel and biomass, when biogenic CO 2 is determined according to §98.33(e)(2), report the t otal quantity of fossil fuel combusted during the reporting year. C

- 13 For facilities with these types of combustion units, facility

- level HHV data are publicly available because they can be calculated based on other data reported and publicly released via EIA. As required to be reported under Part 98, the HHV data for the

co mbustion unit(s) would not reveal any proprietary information about facility or process performance, design, and operation; cost to do business; raw material usage; or production. Site

specific fuel characteristics do not vary significantly from publicly

k nown average values. Additionally for the electric utilities, this sector has experienced a high level of transparency due to the practice of passing fuel costs through to paying customers.

E 

### §98.56(b) Total annual adipic acid production from unit “z” (P z ). E

- 2 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.
E 

### §98.56(b) Total annual adipic acid production from unit “z” (Pz). E

- 3a Provides production or raw
material data described in section
2.1 of Part Two of this
memorandum.

E 

### §98.56(b) Total annual adipic acid production from unit “z” (Pz ). E

- 3b Provides production or raw
material data described in section
2.1 of Part Two of this

## 55 Subpart 

### Rule Citation in 40

CFR Part 98 Data Element Description Data Element is used as Input to Equation . . . Analysis Results

memorandum.

E 

### §98.56(b) Total annual adipic acid production from unit “z” (Pz). E

- 3c Provides production or raw
material data described in section
2.1 of Part Two of this
memorandum.

E 

### §98.56(b) Total annual adipic acid production from unit “z” (Pz ) E

- 3d Provides production or raw
material data described in section
2.1 of Part Two of this
memorandum.

E 

### §98.56(c) Annual adipic acid production during which N 2 O abatement technology (located after the test point) is operating (Pz,N). E

- 2 Provides production or raw
material data described in section
2.1 of Part Two of this
memorandum.

E §98.56(g) Abatement technology destruction efficiency for each abatement technology (DF). E

- 3a Provides data described in section 2.3 in Part Two of this memorandum that could be used to calculate the mass of adipic acid produced if all of the following data are also known: annual N2O mass emissions from adipic acid production (as currently reported under 40 CFR 98.3(c)(4) and made publicly available) 1 , EFs (40 CFR 98.56(j)(1), for which reporting was deferred to 2015), and AF (40 CFR 98.56(h), for which reporting was deferred to 2015). However, if the EFs were not reported, would not reveal any proprietary information about facility or process performance, design, and operation; cost to do business; raw material usage; or production.

E §98.56(g) Abatement technology destruction efficiency for each abatement technology (DF). E

- 3b Provides data described in section 2.3 in Part Two of this memorandum that could be used to calculate the mass of adipic acid produced if all of the following data are also known: annual N2O mass emissions from adipic acid production (as currently reported under 40 CFR 98.3(c)(4) and made publicly available) 1 , EFs (40 CFR 98.56(j)(1), for which reporting was deferred to 2015), and AF (40 CFR 98.56(h), for which reporting was deferred to 2015). However, if the EFs were not reported, would not reveal any pro prietary information about facility or process performance, design, and operation; cost to do business; raw material usage; or production.

## 56 Subpart 

### Rule Citation in 40

CFR Part 98 Data Element Description Data Element is used as Input to Equation . . . Analysis Results

E §98.56(g) Abatement technology destruction efficiency for each abatement technology (DF). E

- 3c Provides data described in section 2.3 in Part Two of this memorandum that could be used to calculate the mass of adipic acid produced if all of the following data are also known: annual N2O mass emissions from adipic acid production (as currently reported under 40 CFR 98.3(c)(4) and made publicly available) 1 , EFs (40 CFR 98.56(j)(1), for which reporting was deferred to 2015), the AF (40 CFR 98.56(h), for which reporting was deferred to 2015), and the fraction control factor (40 CFR 98.56(l), for which rep orting was deferred to 2015). However, if the EFs were not reported, would not reveal any proprietary information about facility or process performance, design, and operation; cost to do business; raw material usage; or production.
E §98.56(h) Abatement utilization factor for each abatement technology (AF). E

- 3a Provides data described in section 2.3 in Part Two of this memorandum that could be used to calculate the mass of adipic acid produced if all of the following data are also known: annual N2O

mass emissions from adipic acid production (as currently reported under 40 CFR 98.3(c)(4) and made publicly available) 1 , EFs (40 CFR 98.56(j)(1), for which reporting was deferred to 2015), and the DF (40 CFR 98.56(g), for which reporting was deferred to 2015). However, if the DF were not reported, would not reveal any proprietary information about facility or process performance, design, and operation; cost to do business; raw material usage; or production.
E §98.56(h) Abatement utilization factor for each abatement technology. (AF) E

- 3b Provides data described in section 2.3 in Part Two of this memorandum that could be used to calculate the mass of adipic acid produced if all of the following data are also known: annual N2O mass emissions from adipic acid

p roduction (as currently reported under 40 CFR 98.3(c)(4) and made publicly available) 1 , EFs (40 CFR 98.56(j)(1), for which reporting was deferred to 2015), and the DF (40 CFR 98.56(g), for which reporting was deferred to 2015). However, if the EFs were no t reported, would not reveal any proprietary information about facility or process performance, design, and operation; cost to do business; raw material usage; or production.

## 57 Subpart 

### Rule Citation in 40

CFR Part 98 Data Element Description Data Element is used as Input to Equation . . . Analysis Results

E §98.56(h) Abatement utilization factor for each abatement technology (AF). E

- 3c Provides data described in section 2.3 in Part Two of this memorandum that could be used to calculate the mass of adipic acid produced if all of the following data are also known: annual N2O mass emissions from adipic acid production (as currently rep orted under 98.3(c)(4) and made publicly available) 1 , EFs (40 CFR 98.56(j)(1), for which reporting was deferred to 2015), the DF (40 CFR 98.56(g), for which reporting was deferred to 2015), and the fraction control factor (40 CFR 98.56(l), for which repor ting was deferred to 2015). However, if the EFs were not reported, would not reveal any proprietary information about facility or process performance, design, and operation; cost to do business; raw material usage; or production.
E 

### §98.56(j)(1) Emission factor for each unit (EFN2Oz). E

- 3a Provides data described in section 2.3 in Part Two of this memorandum that could be used to calculate the mass of adipic acid produced if all of the following data are also known: annual N2O mass emissions from adipic acid production (as currently reported under 40 CFR 98.3(c)(4) and made publicly available) 1 , DF (40 CFR 98.56(g), for which reporting was deferred to 2015), and AF (40 CFR 98.56(h), for which reporting was deferred to 2015). However, if the DF or AF wer e not reported, would not reveal any proprietary information about facility or process performance, design, and operation; cost to do business; raw material usage; or production.
E 

### §98.56(j)(1) Emission factor for each unit (EFN2O ). E

- 3b Provides data described in section 2.3 in Part Two of this memorandum that could be used to calculate the mass of adipic acid produced if all of the following data are also known: annual N2O mass emissions from adipic acid production (as currently reported under 40 CFR 98.3(c)(4) and made publicly available) 1

, DF (40 CFR 98.56(g), for which reporting was deferred to 2015), and AF (40 CFR 98.56(h), for which reporting was deferred to 2015). However, if the DFN or AF were not reported, would not reveal any proprietary information about facility or process performance, design, and operation; cost to do business; raw material usage; or production.

## 58 Subpart 

### Rule Citation in 40

CFR Part 98 Data Element Description Data Element is used as Input to Equation . . . Analysis Results

E 

### §98.56(j)(1) Emission factor for each unit (EFN2O). E

- 3c Provides data described in section 2.3 in Part Two of this memorandum that could be used to calculate the mass of adipic acid produced if all of the following data are also known: annual N2O mass emissions from adipic acid production (as currently reported under 40 CFR 98.3(c)(4) and made publicly available) 1 , DFN (40 CFR 98.56(g), for which reporting was deferred to 2015), AF (40 CFR 98.56(h), for which reporting was deferred to 2015), and fraction control factor (40 CFR 98.56(l) , for which reporting was deferred to 2015). However, if the DF or AF were not reported, would not reveal any proprietary information about facility or process performance, design, and operation; cost to do business; raw material usage; or production.
E 

### §98.56(j)(1) Emission fa ctor for each unit (EFN2O). E

- 3d Provides data described in section 2.3 in Part Two of this memorandum that could be used to calculate the mass of adipic acid produced if the annual N2O mass emissions from adipic acid production (as currently reported und er 40 CFR 98.3(c)(4) and made publicly available) 1 is also known.
E 

### §98.56(j)(3) Production rate per test run during performance test for each unit (P). E

- 1 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.
E §98.56(j)(4) N 2 O concentration per test run during performance test for each unit (CN2O). E

- 1 Provides data described in section 2.3 in Part Two of this memorandum that could be used to calculate the mass of adipic acid produced if all of the following data are also known: EFs (40 CFR 98.56(j)(1), for which reporting was deferred to 2015),volumetric flow rate of effluent gas during the performance test (40 CFR 98.56(j)(5), for which reporting was deferred to 2015), and number of test runs ( 40 CFR 98.56(j)(6), for which reporting was deferred to 2015). However, if the EFs were not reported, would not reveal any proprietary information about facility or process performance, design, and operation; cost to do business; raw material usage; or

pro duction.

## 59 Subpart 

### Rule Citation in 40

CFR Part 98 Data Element Description Data Element is used as Input to Equation . . . Analysis Results

E §98.56(j)(5) Volumetric flow rate per test run during performance test for each unit (Q). E

- 1 Provides data described in section 2.3 in Part Two of this memorandum that could be used to calculate the mass of adipic acid produced if all of the following data are also known: EFs (40 CFR 98.56(j)(1), for which reporting was deferred to 2015), N2O

conc entration per test run during performance test (40 CFR 98.56(j)(4), for which reporting was deferred to 2015), and number of test runs (40 CFR 98.56(j)(6), for which reporting was deferred to 2015). However, if the EFs were not reported, would not reveal a ny proprietary information about facility or process performance, design, and operation; cost to do business; raw material usage; or production.
E §98.56(j)(6) Number of test runs for each unit (n). E

- 1 Provides data described in section 2.3 in Part Two of this memorandum that could be used to calculate the mass of adipic acid produced if all of the following data are also known: EFs (40 CFR 98.56(j)(1), for which reporting was deferred to 2015),N2O

conce ntration per test run during performance test (40 CFR 98.56(j)(4), for which reporting was deferred to 2015), and volumetric flow rate per test run during performance test (40 CFR 98.56(j)(5), for which reporting was deferred to 2015). However, if the EFs were not reported, would not reveal any proprietary information about facility or process performance, design, and operation; cost to do business; raw material usage; or production.
E §98.56(l) Fraction control factor for each abatement technology (perc ent of total emissions from the production unit that are sent to the abatement technology) if equation E

- 3c is used. (FC N ) E

- 3c Provides data described in section 2.3 in Part Two of this memorandum that could be used to calculate the mass of adipic acid

pr oduced if all of the following data are also known: annual N2O mass emissions from adipic acid production (as currently reported under 40 CFR 98.3(c)(4) and made publicly available) 1

, EFs (40 CFR 98.56(j)(1), for which reporting was deferred to 2015), DFN (40 CFR 98.56, for which reporting was deferred to 2015), and the abatement utilization factor (40 CFR 98.56(h), for which reporting was deferred to 2015). However, if the EFs were not reported, would not reveal any proprietary information about facility or process performance, design, and operation; cost to do business; raw

## 60 Subpart 

### Rule Citation in 40

CFR Part 98 Data Element Description Data Element is used as Input to Equation . . . Analysis Results

material usage; or production.

F 

### §98.66(a) Annual aluminum production. (MP) F

- 5 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.
F 

### §98.66(a) Annual aluminum production. (MP) F

- 6 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.
F 

### §98.66(c)(2) Anode effect minutes per cell

- day. (AEM) F

- 2 Could reveal information about the process efficiency. Also, provides data described in section 2.3 of Part Two of this memorandum that could be used to calculate the mass of aluminum produced if both the slope coefficient (40 CFR 98.66(c)(3), for which re porting was deferred to 2015) or using a default value provided in Table F

- 1 and reported GHG emissions (as currently reported under 40 CFR 98.3(c)(4) and made publicly available) 1 are also known.
F 

### §98.66(c)(2) Anode effect overvoltage factor. (EFCF4) F

- 3 Provides data described in section 2.3 of Part Two of this memorandum that could be used to calculate the mass of aluminum produced if reported GHG emissions (as currently reported under 40 CFR 98.3(c)(4) and made publicly available) 1 are also known.
F 

### §98.66(c)(2 ) Anode effect frequency. Used to calculate AEM and the slope coefficients used as an input in Eq. F

- 2 Provides data related to process

efficiency, as described in section 2.2 of Part Two of this memorandum. Also, provides data described in section 2.3 of Part Two of this memorandum that could be used to calculate the mass of aluminum produced if both the slope coefficient (40 CFR 98.66(c)(3), for which reporting was deferred to 2015) or using a default value provided in Table F

- 1 and report ed GHG emissions (as currently reported under 40 CFR 98.3(c)(4) and made publicly available) 1 are also known.

## 61 Subpart 

### Rule Citation in 40

CFR Part 98 Data Element Description Data Element is used as Input to Equation . . . Analysis Results

F 

### §98.66(c)(2) Anode effect duration. Used to calculate AEM and the slope coefficients used as an input in Eq. F

- 2 Provides data related to process

efficiency, as described in section 2.2 of Part Two of this memorandum. Also, provides data described in section 2.3 of Part Two of this memorandum that could be used to calculate the mass of aluminum produced if the both

t he slope coefficient (40 CFR 98.66(c)(3), for which reporting was deferred to 2015) or using a default value provided in Table F

- 1 and reported GHG emissions (as currently reported under 40 CFR 98.3(c)(4) and made publicly available) 1 are also known.
F 

### §98.66(c)(2) Potline overvoltage. Used to calculate the overvoltage factor used as an input in Eq.
F

- 3 Provides data described in section

2.3 of Part Two of this memorandum that could be used to calculate the mass of aluminum produced if reported GHG emis sions (as currently reported under 40 CFR 98.3(c)(4) and made publicly available) 1 are also known.
F 

### §98.66(c)(2) Current efficiency. Used to calculate the overvoltage factor used as an input in Eq.
F

- 3 Provides data related to process

design; process performance, and operation; and/or cost to do business, as described in section 2.2 of Part Two of this memorandum. Specifically, could provide some indication of cell performance and production efficiency.
F 

### §98.66(c)(3) Smelter

- specific slope coefficients. (SCF4) F

- 2 Provides data related to process efficiency, as described in section 2.2 of Part Two of this memorandum. Also, provides data described in section 2.3 of Part Two of this memorandum that could be used to calculate the mass of alumin um produced if both the AEM (40 CFR 98.66(c)(2), for which reporting was deferred to 2015) and reported GHG emissions (as currently reported under 40 CFR 98.3(c)(4) and made publicly available) 1 are also known.
F 

### §98.66(c)(3) Overvoltage emission factors. (EFCF4) F

- 3 Provides data described in section 2.3 of Part Two of this memorandum that could be used to calculate the mass of aluminum produced if reported GHG emissions (as currently reported under 40 CFR98.3(c)(4) and made publicly available) 1 are also known.
F 

### §98.66(e)(1) Annual anode consumption if not using the method in § 98.63(g).. (No CEMS) (NAC) F

- 5 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.
F 

### §98.66(f)(1) Annual paste consumption if not using the method in § 98.63(g).. (No CEMS) (PC ) F

- 6 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

## 62 Subpart 

### Rule Citation in 40

CFR Part 98 Data Element Description Data Element is used as Input to Equation . . . Analysis Results

F 

### §98.66(g) Sulfur content in baked anode (percent weight). (Sa) F

- 5 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.
F 

### §98.66(g) Ash content in baked anode (percent weight). (Asha) F

- 5 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.
F 

### §98.66(g) Binder content of paste (percent weight). (BC ) F

- 6 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.
F 

### §98.66(g) Sulfur content of pitch (percent weight). (Sp) F

- 6 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.
F 

### §98.66(g) Ash content of pitch (percent weight). (Ashp) F

- 6 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.
F 

### §98.66(g) Hydrogen content of pitch (percent weight). (Hp) F

- 6 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.
F 

### §98.66(g) Sulfur content in calcined coke (percent weight). (Sc) F

- 6 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.
F 

### §98.66(g) Ash content in calcined coke (percent weight). (Ashc) F

- 6 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.
F 

### §98.66(g) Carbon in skimmed dust from Soderberg cells (metric ton C/metric ton Al) (CD). F

- 6 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.
F 

### §98.66(g) Initial weight of green anodes (metric tons) (GA). F

- 7 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.
F 

### §98.66(g) Annual hydrogen content in green anodes (metric tons) (Hw). F

- 7 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.
F 

### §98.66(g) Annual baked anode production (metric tons) (BA). F

- 7 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.
F 

### §98.66(g) Annual waste tar collected (metric tons) (WT). F

- 7 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.
F 

### §98.66(g) Annual packing coke consumption (metric tons/metric ton baked anode) (PCC). F

- 8 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.
F 

### §98.66(g) Annual baked anode production (metric tons) (BA). F

- 8 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.
F 

### §98.66(g) Sulfur content in packing coke (percent weight) (SPc). F

- 8 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

## 63 Subpart 

### Rule Citation in 40

CFR Part 98 Data Element Description Data Element is used as Input to Equation . . . Analysis Results

F 

### §98.66(g) Ash content in packing coke (percent weight) (Ashpc). F

- 8 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.
G 

### §98.76(b)(2) Monthly quantity of each type of feedstock consumed for ammonia manufacturing

- Gaseous Feedstock. G

- 1 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.
G 

### §98.76(b)(2) Monthly quantity of each type of feedstock consumed for ammonia manufacturing

- Liquid Feedstock. G

- 2 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.
G 

### §98.76(b)(2) Monthly quantity of each type of feedstock consumed for ammonia manufacturing

- Solid Feedstock. G

- 3 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.
G 

### §98.76(b)(7) Carbon content of the gaseous feedstock. G

- 1 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.
G 

### §98.76(b)(8) Molecular weight of the gaseous feedstock. G

- 1 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.
G 

### § 98.76(b)(9) Molar volume conversion factor of the gaseous feedstock. G

- 1 Is a constant value widely known within the industry and publicly available. Otherwise, does not include, and could not be used to calculate, data or information about facility or process perfo rmance, design, and operation; cost to do business; raw material usage; or production.
G 

### §98.76(b)(10) Carbon content of the liquid feedstock, for month n. G

- 2 Provides production or raw material data described in section 2.1 of Part Two of this memorand um. G 

### §98.76(b)(11) Carbon content of the solid feedstock, for month n. G

- 3 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.
H 

### §98.86(b)(2) Monthly clinker production for each kiln (No CEMS). H

- 2 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.
H 

### §98.86(b)(5) Quarterly quantity of CKD not recycled to the kiln. H

- 2 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.
H 

### §98.86(b)(6) Monthly fraction of total CaO in clinker. H

- 3 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.
H 

### §98.86(b)(6) Monthly fraction of total MgO in clinker. H

- 3 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.
H 

### §98.86(b)(6) Monthly fraction of non

calcined CaO in clinker. H

- 3 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.
H 

### §98.86(b)(6) Monthly fraction of non

calcined MgO in clinker. H

- 3 Provides production or raw material data described in section 2.1 of Part Two of this

## 64 Subpart 

### Rule Citation in 40

CFR Part 98 Data Element Description Data Element is used as Input to Equation . . . Analysis Results

memorandum.

H 

### §98.86(b)(8) Quarterly fraction of total CaO in CKD not recycled to the kiln. H

- 4 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.
H 

### §98.86(b)(8) Quarterly fraction of total MgO in CKD not recycled to the kiln. H

- 4 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.
H 

### §98.86(b)(8) Quarterly fraction of non

calcined CaO in CKD not recycled to the kiln. H

- 4 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.
H 

### §98.86(b)(8) Quarterly fraction of non

calcined MgO in CKD not recycled to the kiln. H

- 4 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.
H 

### §98.86(b)(10) Monthly kiln

- specific clinker CO 2 emission factors for each kiln. H

- 2 Provides data described in section 2.3 of Part Two of this memorandum that could be used to calculate the mass of clinker produced if reported GHG emissions (as currently reported under 40 CFR §98.3(c)(4) and made publicly available) 1

, are also known.
H §98.86(b)(11) Quarterly kiln

- specific CKD CO 2 emission factors for each kiln. H

- 2 Provides data described in section 2.3 in Part Two of this memorandum that could be used to calculate the mass of clinker produced if all of the following data are also known : CKD not recycled to the kiln (40 CFR 98.86(b)(5), for which reporting was deferred to 2015), CO2 emissions (as currently reported under 40 CFR 98.3(c)(4) and made publicly available) 1 , kiln

- specific clinker emission factor (40 CFR 98.86(b)(10), for which reporting was deferred to 2015), and kiln

specific CKD emission factor (40 CFR 98.86(b)(11), for which reporting was deferred to 2015). The CKD emission factor represents a minor portion of reported emissions and would reveal minimal information abou t total process output. However, if the kiln

- specific clinker emission factor or kiln

- specific CKD emission factor were not reported, would not reveal any proprietary information about facility or process performance, design, and operation; cost to do busi ness; raw material usage; or production.
H 

### §98.86(b)(12) Annual organic carbon content of each raw kiln feed or annual organic carbon content of each raw material. H

- 5 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.
H 

### §98.86(b)(13) Annual consumption of each raw kiln feed or annual H

- 5 Provides production or raw material data described in section

## 65 Subpart 

### Rule Citation in 40

CFR Part 98 Data Element Description Data Element is used as Input to Equation . . . Analysis Results consumption of each raw material. 2.1 of Part Two of this memorandum.

H §98.86(b)(13) Name of raw kiln feed or raw material. Would not reveal any proprietary information about facility or process performance, design, and operation; cost to do business; raw material usage; or production.
H 

### §98.86(b)(15) Monthly kiln

- specific raw kiln feed to clinker produced factors (if used) for each kiln. Used to calculate clinker production by facilities using the method in 40 CFR 98.84(d) (i.e., kiln

- specific clinker

- to

- feed factors) Provides data related to process

design; process performance, and operation; and/or cost to do business, as described in section 2.2 of Part Two of this memorandum. Specifically, indicates the design efficiency of the unit.

K 

### §98.116(b) Annual production by product from each EAF (tons) (used as input to Eq K

- 1): Mproductk= Annual mass of alloy product k tapped from EAF (tons). K

- 1 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

K 

### §98.116(b) Annual production by product from each EAF (tons) (used as input to Eq K

- 3). K

- 3 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.
K 

### §98.116(e)(4) Annual material quantity for each material included for the calculation of annual process CO 2 emissions (No CEMS): Mreducing agenti= Annual mass of reducing agent i fed, charged, or otherwise introduced into the EAF (tons). K

- 1 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

K 

### §98.116(e)(4) Annual material quantity for each material included for the calculation of annual process CO 2 emissions (No CEMS): Melectrodem= Annual mass of carbon electrode m consumed in the EAF (tons). K

- 1 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

K 

### §98.116(e)(4) Annual material quantity for each material included for the calculation of annual process CO 2 emissions (No CEMS): Moreh= Annual mass of ore h charged to the EAF (tons). K

- 1 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

K 

### §98.116(e)(4) Annual material quantity for each material included for the calculation of annual process CO 2 emissions (No CEMS): Mfluxj= Annual mass of flux material j fed, charged, or otherwise introduced into the EAF to facilitate slag formation (tons). K

- 1 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

## 66 Subpart 

### Rule Citation in 40

CFR Part 98 Data Element Description Data Element is used as Input to Equation . . . Analysis Results

K 

### §98.116(e)(4) Annual material quantity for each material included for the calculation of annual process CO 2 emissions (No CEMS): Mnon

- product outgoingl= Annual mass of non

- product outgoing material l removed from EAF (tons). K

- 1 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

K 

### §98.116(e)(5) Annual average of the carbon content determinations for each material included for the calculation of annual process CO 2 emissions (No CEMS): Creducing agenti= Carbon content in reducing agent i (percent by weight, expressed as a decimal fraction). K

- 1 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

K 

### §98.116(e)(5) Annual average of the carbon content determinations for each material included for the calculation of annual process CO 2 emissions (No CEMS): Celectrodem= Carbon content of the carbon electrode m (percent by weight, expressed as a decimal fraction). K

- 1 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

K 

### §98.116(e)(5) Annual average of the carbon content determinations for each material included for the calculation of annual process CO 2 emissions (No CEMS): Coreh= Carbon content in ore h (percent by weight, expressed as a decimal fraction). K

- 1 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

K 

### §98.116(e)(5) Annual average of the carbon content determinations for each material included for the calculation of annual process CO 2 emissions (No CEMS): Cfluxj= Carbon content in flux material j (percent by weight, expressed as a decimal fraction). K

- 1 Provides production or raw material data described in section 2.1 of P art Two of this memorandum.

K 

### §98.116(e)(5) Annual average of the carbon content determinations for each material included for the calculation of annual process CO 2 emissions (No CEMS): Cproductoutgoingk = Carbon content in alloy product k . (percent by weight, expressed as a decimal fraction). K

- 1 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

K 

### §98.116(e)(5) Annu al average of the carbon content determinations for each material included for the calculation of annual process CO 2 emissions (No CEMS): Cnon

- product outgoingl= Carbon content in non

product outgoing material l (percent by weight, expressed as a decimal f

raction). K

- 1 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

## 67 Subpart 

### Rule Citation in 40

CFR Part 98 Data Element Description Data Element is used as Input to Equation . . . Analysis Results

L §98.126(b)(1) Elements of the sum (a, b, c, etc.) (e.g., measured variables in the sum). L

- 1 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.
L §98.126(b)(1) eSA (absolute error of the sum, expressed as one half of a 95 percent confidence interval). Note that where eSA = the overall absolute error calculated for the process emissions you report under §98.126(a)(2), this data element was not deferred in the inputs deferral rule (76 FR 53057, August 25, 2011), and would be required to be reported. L

- 1 Does not include, and could not be used to calculate, data or information about facility or process performance, design, and operation; cost to do business; raw material usage; or production. 2

L §98.126(b)(1) ea, eb, ec = Relative error of a, b, or c, respectively, expressed as one half of a 95 percent confidence interval. L

- 1 Does not include, and could not be used to calculate, data or information about facility or process performance, design, and operation; cost to do business; raw material usage; or production. 2

L §98.126(b)(1) Elements of the sum (a, b, c, etc.) (e.g., measured variables in the sum). L

- 2 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.
L §98.126(b)(1) a+b+c = Sum of the variables measured. L

- 2 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.
L §98.126(b)(1) eSR (relative error of the sum, expressed as one half of a 95 percent confidence interval). Note that where eSR = the overall relative error calculated for the process emissions you report under §§98.126(a)(2), this data element was not deferred in the inputs deferral rule (76 FR 53057, August 25, 2011), and would be required to be reported. L

- 2 Does not include, and could not be used to calculate, data or information about facility or process performance, design, and operation; cost to do business; raw material usage; or production. 2

L §98.126(b)(1) eSA (absolute error of the sum, expressed as one half of a 95 percent confidence interval). Note that where eSA = the overall absolute error calculated for the process emissions you report under §98.126(a)(2), this data element was not deferred in the inputs deferral rule (76 FR 53057, August 25, 2011) , and would be required to be reported. L

- 2 Does not include, and could not be used to calculate, data or information about facility or process performance, design, and operation; cost to do business; raw material usage; or production . 2

L §98.126(b)(1) Elements of the sum (a, b, c, etc.) (e.g., measured variables in the sum). L

- 3 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

## 68 Subpart 

### Rule Citation in 40

CFR Part 98 Data Element Description Data Element is used as Input to Equation . . . Analysis Results

L §98.126(b)(1) ea, eb, ec = Relative error of a, b, or c, respectively,

expre ssed as one half of a 95 percent confidence interval. L

- 3 Does not include, and could not be used to calculate, data or information (about facility or process performance, design, and operation; cost to do business; raw material usage; or production) that would reveal information that could cause competitive harm. 2

L §98.126(b)(1) ePA (absolute error of the product, expressed as one half of a 95 percent confidence interval). Note that where ePA = the overall absolute error calculated for the process emiss ions you report under §98.126(a)(2), this data element was not deferred in the inputs deferral rule (76 FR 53057, August 25, 2011) , and would be required to be reported. L

- 3 Does not include, and could not be used to calculate, data or information about facility or process performance, design, and operation; cost to do business; raw material usage; or production. 2

L §98.126(b)(1) a*b*c = Product of the variables measured. L

- 3 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.
L §98.126(b)(1) Measured variables of the product (a, b, c, etc.). L

- 4 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.
L §98.126(b)(1) a*b*c = Product of the variables measured. L

- 4 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.
L §98.126(b)(1) ePR (relative error of the product, expressed as one half of a 95 percent confidence interval). Note that where ePR = the overall relative error calculated for the process emissions you report under §98.126(a)(2), this data element was not deferred in the inputs deferral rule (76 FR 53057, August 25, 2011) , and would be required to be reported. L

- 4 Does not include, and could not be used to calculate, data or information about facility or process performance, design, and operation; cost to do business; raw material usage; or production. 2

L §98.126(b)(1) ePA (absolute error of the product, expressed as one half of a 95 percent confidence interval). Note that where ePA = the overall absolute error calculated for the process emissions you report under §98.126(a)(2), this data element was not deferred in the inputs deferral rule (76 FR 53057, August 25, 2011) , and would be required to be

rep orted. L

- 4 Does not include, and could not be used to calculate, data or information about facility or process performance, design, and operation; cost to do business; raw material usage; or production. 2

## 6 9 Subpart 

### Rule Citation in 40

CFR Part 98 Data Element Description Data Element is used as Input to Equation . . . Analysis Results

L §98.126(b)(2) The balanced chemical equation that describes the reaction used to manufacture the fluorinated GHG product and each fluorinated GHG transformation product. Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

L §98.126(b)(6) The mass of e ach fluorine

containing reactant that is fed into the process. (Rd) L

- 6 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.
L §98.126(b)(7) The mass of each fluorine

containing product produced by the process. (P) L

- 6 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.
L §98.126(b)(8)(i) The mass of each fluorine

containing product that is removed from the process and fed into the destruction device (metric tons). (Pj) L

- 7 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

L §98.126(b)(8)(ii) The mass of each fluorine

containing by

- product that is removed from the process and fed into the destruction device (metric tons). (Bkj) L

- 7 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

L §98.126(b)(8)(iii) The mass of each fluorine

containing reactant that is removed from the process and fed into the destruc tion device (metric tons). (Rdj) L

- 7 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

L §98.126(b)(8)(iv) The mass of each fluorine

containing by

- product that is removed from the process and recaptured (metric tons). (Bkl) L

- 7 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

L §98.126(b)(8)(v) The demonstrated destruction efficiency of the destruction device for each fluorinated GHG fed into the device from the process in greater than trace concentrations (fraction). (DEFGHGf= Destruction efficiency of the device that has been demonstrated for fluorinated GHG f in stream j (fraction).) L

- 8 Provides data described in section 2.3 of Part Two of this

memora ndum that could be used to calculate the amount of fluorinated GHG in a waste stream removed from the process and sent to a destruction device, if the following information is also known: (1) annual emissions of each fluorinated GHG (as required to be

repo rted under 40 CFR 98.126(a)(2)); and (2) that the emissions consist exclusively of post

- destruction device emissions (information that a competitor knowledgeable of some aspects of the facility and/or of fluorine chemistry might deduce). 2

L §98.126(b)(9)(i) The mass of fluorine in each stream that is fed into the destruction device (metric tons). (cTFj * Sj) L

- 17 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

L §98.126(b)(9)(ii) The mass of fluorine that is recaptured (metric tons). (cTFl * Sl) L

- 17 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

## 70 Subpart 

### Rule Citation in 40

CFR Part 98 Data Element Description Data Element is used as Input to Equation . . . Analysis Results

L §98.126(b)(9)(iii) The weighted average destruction efficiency of the destruction device calculated for each stream under §98.123(b)(16). (DEavgj) L

- 17 Provides data described in section 2.3 of Part Two of this memorandum that could be used to calculate the concentration of fluorine

- containing reactants, products or byproducts in waste

streams if the following information is also known: (1) annual emissions of each fluorinated GHG (as required to be reported under 40 CFR 98.126(a)(2)); (2) that only one stream with only one fluorine compound is sent to the destruction device; (information that a competitor knowledgeable of some aspects of the facility and/or of fluorine chemistry might deduce). 2

L §98.126(b)(10) The fraction of the mass emitted that consists of each fluorine

- containing reactant (FERd). L

- 11 This data element is not addressed because this is a reported emissions value, which is addressed in a separate action related to subpart L of part 98.
L §98.126(b)(10) The fraction of the mass emitted that consists of each fluorine

- containing reactant. (FERd). L

- 12 This data element is not addressed because this is a reported emissions value, which is addressed in a separate action related to subpart L of part 98.
L §98.126(b)(10) The fraction of the mass emitted that consists of each fluorine

- containing reactant (FERd). L

- 13 This data element is not addressed because this is a reported emissions value, which is addressed in a separate action related to subpart L of part 98.
L §98.126(b)(11) The fraction of the mass emitted that consists of the fluorine

- containing product (FEP). L

- 11 This data element is not addressed because this is a reported emissions value, which is addressed in a separate action related to subpart L of part 98.
L §98.126(b)(11) The fraction of the mass emitted that consists of the fluorine

- containing product. (F EP) L

- 12 This data element is not addressed because this is a reported emissions value, which is addressed in a separate action related to subpart L of part 98.
L §98.126(b)(11) The fraction of the mass emitted that consists of the fluorine

- containing product. (FEP). L

- 13 This data element is not addressed because this is a reported emissions value, which is addressed in a separate action related to subpart L of part 98.
L §98.126(b)(12) The fraction of the mass emitted that consists of each fluorine

- containing by

product (FEBk). L

- 11 This data element is not addressed because this is a reported emissions value, which is addressed in a separate action related to subpart L of part 98.
L §98.126(b)(12) The fraction of the mass emitted that con sists of each fluorine

- containing by

product. (FEBk) L

- 12 This data element is not addressed because this is a reported emissions value, which is addressed in a separate action related to subpart L of part 98.
L §98.126(b)(12) The fraction of the mass emitted that consists of each fluorine

- containing by

product. (FEBk) L

- 13 This data element is not addressed because this is a reported emissions value, which is addressed in a separate action related to subpart L of part 98.

## 71 Subpart 

### Rule Citation in 40

CFR Part 98 Data Element Description Data Element is used as Input to Equation . . . Analysis Results

L §98.126(c)(1) The quantity of the process activity used to estimate emissions (e.g., tons of product produced or tons of reactant consumed). (ActivityC or ActivityU) L

- 21 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

L §98.126(c)(1) The quantity of the process activity used to estimate emissions (e.g., tons of product produced or tons of reactant consumed). (ActivityC or ActivityU) L

- 22 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

L §98.126(c)(1) The quantity of the process activity used to estimate emissions (e.g., tons of product produced or tons of reactant consumed). (Activity) L

- 26 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

L §98.126(c)(1) The quantity of the process activity used to estimate emissions (e.g., tons of product produced or tons of reactant consumed). (ActivityU or ActivityC) L

- 27 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

L §98.126(c)(2) The site

- specific, process

vent

- specific emission factor(s) for each process vent (EFPV). L

- 20 Provides data described in section 2.3 of Part Two of this memorandum that could be used to calculate the pr ocess feed rate, production process rate, or other process activity rate if the mass of fluorinated GHG emitted from the process vent (as required to be reported in 40 CFR 98.126(c)(3)) is also known. 2

L §98.126(c)(2) The site

- specific, process

vent

- specific emission factor(s) for each process vent (EFPV

– C). L

- 21 Provides data described in section 2.3 of Part Two of this memorandum that could be used to calculate the process feed rate, production process rate, or other process activity rate if the mass of fluorinated GHG emitted from the process vent (as required to be reported in 40 CFR 98.126(c)(3)) is also known. 2

L §98.126(c)(2) The site

- specific, process

vent

- specific emission calculation factor for each process vent. (ECFPV

- U). L

- 21 Provides data described in section 2.3 of Part Two of this memorandum that could be used to calculate the process feed rate, production process rate, or other process activity rate if the mass of fluorinated GHG emitted from the process vent (as required to be reported in 40 CFR 98.126(c)(3)) is also known. 2

L §98.126(c)(2) The site

- specific, process

vent

- specific emission factor(s) for each process ven t (EFPV

– U). L

- 22 Provides data described in section 2.3 of Part Two of this memorandum that could be used to calculate the process feed rate, production process rate, or other process activity rate if the mass of fluorinated GHG emitted from the process vent (as required t o be reported in 40 CFR 98.126(c)(3)) is also known. 2

## 72 Subpart 

### Rule Citation in 40

CFR Part 98 Data Element Description Data Element is used as Input to Equation . . . Analysis Results

L §98.126(c)(2) The site

- specific, process

vent

- specific emission factor(s) for each process

vent. (EFPV) L

- 23 Provides data described in section 2.3 of Part Two of this memorandum that could be used to calculate the process feed rate, production process rate, or other process activity rate if the mass of fluorinated GHG emitted from the process vent (as required to be reported in 40 CFR 98.126(c)(3)) is also known. 2

L §98.126(c)(2) The site

- specific, process

vent

- specific emission calculation factor for each process vent. (ECFPV). L

- 25 Provides data described in section 2.3 of Part Two of this memorandum that could be used to calculate the process feed rate, production process rate, or o ther process activity rate if the mass of fluorinated GHG emitted from the process vent (as required to be reported in 40 CFR 98.126(c)(3)) is also known. 2

L §98.126(c)(2) The site

- specific, process

vent

- specific emission calculation factor for each process vent (ECFPV). L

- 26 Provides data described in section 2.3 of Part Two of this memorandum that could be used to calculate the process feed rate, production process rate, or other process activity rate if the mass of fluorinated GHG emitted from the process vent (as required to be reported in 40 CFR 98.126(c)(3)) is also known. 2

L §98.126(c)(2) The site

- specific, process

vent

- specific emission calculation factor for each process vent. (ECFPV). L

- 27 Provides data described in section 2.3 of Part Two of this memorandum that could be used to calculate the process feed rate, production process rate, or other process activity rate if the mass of fluorinated GHG emitted from the process vent (as required t o be reported in 40 CFR 98.126(c)(3)) is also known. 2

L §98.126(d) Where missing data have been estimated pursuant to §98.125 report, estimate of the missing data. Varies Provides data (missing data could include the data specified in 40 CFR 98.126(b) an d (c)), which could be used (as specified for those citations in this table) to calculate the process feed rate, production process rate, or other process activity rate; or the mass of fluorinated GHG entering the destruction device. 2

## 73 Subpart 

### Rule Citation in 40

CFR Part 98 Data Element Description Data Element is used as Input to Equation . . . Analysis Results

L §98.126(f)(1) Destruction efficiency (DE) of each destruction device for each fluorinated GHG whose destruction the facility reflects in §98.123, in accordance with §98.124(g)(1)(i) through (iv). (DEFGHGf) L

- 8 Provides data described in section 2.3 of Part Two of this

m emorandum that could be used to calculate the amount of fluorinated GHG in a waste stream removed from the process and sent to a destruction device, if the following information is also known: (1) annual emissions of each fluorinated GHG (as required to be reported under 40 CFR 98.126(a)(2)); and (2) that the emissions consist exclusively of post

- destruction device emissions (information that a competitor knowledgeable of some aspects of the facility and/or of fluorine chemistry might deduce). 2

L §98.126(f)(1) Destruction efficiency (DE) of each destruction device for each fluorinated GHG whose destruction the facility reflects in §98.123, in accordance with §98.124(g)(1)(i) through (iv). (DEFGHGf) L

- 18 Provides data described in section 2.3 of Par t Two of this memorandum that could be used to calculate the amount of fluorinated GHG in a destroyed stream removed from the process and sent to a destruction device, if the following information is also known: (1) annual emissions of each fluorinated GHG (as required to be reported under 40 CFR 98.126(a)(2); (2) that only one stream with only one fluorine compound is sent to the destruction device (information that a competitor knowledgeable of some aspects of the facility and/or of fluorine chemistry mig ht deduce). 2

L §98.126(f)(1) Destruction efficiency (DE) of each destruction device for each fluorinated GHG whose destruction the facility reflects in §98.123, in accordance with §98.124(g)(1)(i) through (iv). (DE ) L

- 22 Provides data described in section 2.3 of Part Two of this memorandum that could be used to calculate the process feed rate, production process rate, or other process activity rate if the emission factor for fluorinated GHG emitted from process vents (as required to be reported in 4 0 CFR 98.126(c)(2)) and the mass of fluorinated GHG emitted from the process vents (as required to be reported in 40 CFR 98.126(c)(3)) are also known. 2

L §98.126(f)(1) Destruction efficiency (DE) of each destruction device for each fluorinated GHG whose destruction the facility reflects in §98.123, in accordance with §98.124(g)(1)(i) through (iv) (DE). L

- 27 Provides data described in section 2.3 of Part Two of this memorandum that could be used to calculate the process feed rate, production process rate, or other process activity rate if the emission factor for fluorinated GHG emitted from process vents (as required to be reported in 40 CFR 98.126(c)(2)) and the mass of fluorinated GHG emitted from the process vents (as required to be reported in 40 CFR 98 .126(c)(3)) are also known. 2

## 74 Subpart 

### Rule Citation in 40

CFR Part 98 Data Element Description Data Element is used as Input to Equation . . . Analysis Results

L §98.126(f)(1) Destruction efficiency (DE) of each destruction device for each fluorinated GHG whose destruction the facility reflects in §98.123, in accordance with §98.124(g)(1)(i) through (iv) (DE). L

- 31 Provides data desc ribed in section 2.3 of Part Two of this memorandum that could be used to calculate the mass of fluorinated GHGs that were previously produced (and that are fed annually into the destruction device) if the mass of fluorinated GHGs emitted annually from des truction of fluorinated GHGs that were previously produced (as required to be reported in 40 CFR 98.126(g)(2)) is also known. 2

L §98.126(g)(1) The mass of the fluorinated GHG fed into the destruction device. (RE D ) L

- 31 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.
L §98.126(h)(2) If applicable, the heel factor calculated for each container size and type. (hfj) L

- 34 Provides data described in section 2.3 of Part Two of this memorandum that could be used to calculate the number of tanks processed if the emissions from each type of container (as required to be reported in 40 CFR 98.126(h)(1 )) are also known. The number of each type of tank processed and the size of the tanks could provide insight i nto product sales. 2

N 

### §98.146(b)(2) Annual quantity of carbonate based

- raw material charged to each continuous glass melting furnace (No CEMS). N

- 1 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.
N 

### §98.146(b)(4) Carbonate

- based mineral mass fraction of carbonate

based raw material charged to a furnace. N

- 1 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.
N 

### §98.146(b)(6) Fraction of calcination for carbonate

- based raw material. N

- 1 Provides data described in section 2.3 of Part Two of this memorandum that could be used to calculate the recipe for the glass produced (i.e., the product of the annual average mass fraction of carbonate

- based mineral in

c arbonate

- based raw material and the annual mass of carbonate

- based raw material) if the CO2 emissions (as currently reported under 40 CFR 98.3(c)(4) and made publicly available) 1 are also known.
O 

### §98.156(a)(2) Loss Factor used to account for the loss of HCFC

– 22 upstream of the measurement (LF used in equation O

- 3). O

- 3 Provides data related to process design; process performance, and operation; and/or cost to do business, as described in section 2.2 of Part Two of this memorandum. Specifically, indica tes process performance and efficiency, as well as cost to do business (i.e., how much of a facility’s product is lost).
O 

### §98.156(a)(7) Annual mass of the HFC

- 23 generated (G 23 in Eq. O

- 4). O

- 4 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

## 75 Subpart 

### Rule Citation in 40

CFR Part 98 Data Element Description Data Element is used as Input to Equation . . . Analysis Results
O 

### §98.156(a)(8) Annual mass of any HFC

- 23 sent off site for sale (S 23 in Eq. O

- 4). O

- 4 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.
O 

### §98.156(a)(9) Annual mass of any HFC

- 23 sent off site for destruction (OD 23 used in Eq. O

- 4). O

- 4 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.
O 

### §98.156(a)(10) Mass of HFC

- 23 in storage at the beginning of the year (used to calculate I 23 , which is used in Eq. O

- 4). O

- 4 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.
O 

### §98.156(a)(10) Mass of HFC

- 23 in storage at the end of the year (used to calculate I 23 , which is used in Eq. O

- 4). O

- 4 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.
O 

### §98.156(b)(1) Annual mass of HFC

- 23 fed into the destruction device (FD used in Eq. O

- 8 and O

9). O

- 8 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.
O 

### §98.156(b)(1) Annual mass of HFC

- 23 fed into the destruction device (FD used in Eq. O

- 8 and O

9). O

- 9 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.
O 

### §98.156(b)(2) Annual mass of HFC

- 23 destroyed (D23 used in Eq. O

- 8). O

- 8 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.
O 

### §98.156(d)(1) If the HFC

- 23 concentration measured pursuant to §98.154(l) is greater than that measured during the performance test that is the basis for the destruction efficiency (DE), report flow rate of HFC

- 23 being fed into the destruction device in kg/hr. Calculation method specified in either § 98.154(l)(1) or § 98.154(l)(2) Provides data related to process

design; process performance, and operation; and/or cost to do business, as described in section 2.2 of Part Two of this memorandum. Specifically, if the facility produces HCFC

- 22 onsite, information about the HCFC

- 23 production rate reveals information about process efficiency, revealing information about the HCFC

- 22 production rate.
O §98.156(d)(2) If the HFC

- 23 concentration measured pursuant to §98.154(l) is greater than that measured during the performance test that is the basis for the destruction efficiency (DE), report concentration (mass fraction) of HFC

- 23 at the outlet of the destruction device. No Equation

- Used to calculate Destruction Efficiency Provides data described in section

2.3 of Part Two of this memorandum that could be used to estimate HCFC

- 23 production if the following data are also known: flow rate of HFC

- 23 being fed into the destruction device (40 CFR 98.156(d)(1), for which reporting was deferred to 2015); and flow

rate at the outlet of the destruction device (40 CFR 98.156(d)(3),or emission rate as required to be reported in 40 CFR 98.156(d)(4), for which reporting of each was deferred to 2015). If the facility produces HCFC

- 22 onsite, this HCFC

- 23 production rate reveals information about process efficiency, revealing information about the HCFC

- 22 production rate. However, if the destruction efficiency (and flow rate of HFC

23 fed into the destru ction device, which is used to calculate the destruction efficiency) were not

## 76 Subpart 

### Rule Citation in 40

CFR Part 98 Data Element Description Data Element is used as Input to Equation . . . Analysis Results

reported, would not reveal any proprietary information about facility or process performance, design, and operation; cost to do business; raw material usage; or production.

O §98.156(d)(3) If the HFC

- 23 concentration measured pursuant to §98.154(l) is greater than that measured during the performance test that is the basis for the destruction efficiency (DE), report flow rate at the outlet of the destruction device in kg/hr. No Equation

- Used to calculate Destruction Efficiency Provides data described in section

2.3 of Part Two of this memorandum that could be used to estimate HCFC

- 23 production if the destruction efficiency (40 CFR 98.156(d)(5), for which reporting was deferre d to 2015) is also known. If the facility produces HCFC

- 22 onsite, this HCFC

- 23 production rate reveals information about process efficiency, revealing information about the HCFC

- 22 production rate. However, if the destruction efficiency (and flow rate of HFC

- 23 fed into the destruction device, which is used to calculate the destruction efficiency), were not reported, would not reveal any proprietary information about facility or process performance, design, and operation; cost to do business; raw material usage; or production.
O §98.156(d)(4) If the HFC

- 23 concentration measured pursuant to §98.154(l) is greater than that measured during the performance test that is the basis for the destruction efficiency (DE), report emission rate (in kg/hour) calculated from the paragraphs (d)(2) and (d)(3) of this section. No Equation

- Used to calculate Destruction Efficiency Provides data described in section

2.3 of Part Two of this memorandum that could be used to estimate HCFC

- 23 production if the destruct ion efficiency (40 CFR 98.156(d)(5), for which reporting was deferred to 2015) is also known. In this case, if the facility produces HCFC

- 22 onsite, this HCFC

- 23 production rate reveals information about process efficiency, revealing information about the HCFC

- 22 production rate. However, if the destruction efficiency were not reported, would not reveal any proprietary information about facility or process performance, design, and operation; cost to do business; raw

## 77 Subpart 

### Rule Citation in 40

CFR Part 98 Data Element Description Data Element is used as Input to Equation . . . Analysis Results

material usage; or production.

O 

### §98.156(d)(5) If the HFC

- 23 concentration measured pursuant to §98.154(l) is greater than that measured during the performance test that is the basis for the destruction efficiency (DE), report the destruction efficiency (DE) calculated from paragraphs (d )(1) and (d)(4) of this section. Calculation method specified in either § 98.154(l)(1) or § 98.154(l)(2) Provides information about process

efficiency, revealing information about the HCFC

- 22 production rate, if the facility produces HCFC

22 onsite. Also, provides data described in section 2.3 of Part Two of this memorandum that could be used to estimate HCFC

- 23 production if the HCFC

- 23 production rate is known.

O 

### §98.156(e)(1) (One time report) Destruction efficiency (DE) (by March 31, 2011 or within 60 days of commencing HFC

- 23 destruction). O

- 9 Provides data described in section 2.3 of Part Two of this memorandum that could be used to estimate HCFC

- 23 production if the HCFC

- 23 production rate can be estimated. If the facility produces HCFC

- 22 onsite, th is HCFC

- 23 production rate reveals information about process efficiency, revealing information about the HCFC

- 22 production

rate.
P 

### §98.166(b)(2) Monthly consumption of each fuel and feedstock by type used for hydrogen production (No CEMS): gaseous. P

- 1 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.
P 

### §98.166(b)(2) Monthly consumption of each fuel and feedstock by type used for hydrogen production (No CEMS) (Fdstkn): Liquid. P

- 2 Provides production or r aw material data described in section 2.1 of Part Two of this memorandum.
P 

### §98.166(b)(2) Monthly consumption of each fuel and feedstock by type used for hydrogen production (No CEMS) (Fdstkn): solid. P

- 3 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.
P 

### §98.166(b)(5) Monthly analyses of carbon content for each fuel and feedstock used in hydrogen production: Gaseous. P

- 1 Provides production or raw material data described in section 2.1 of Part Tw o of this memorandum.
P 

### §98.166(b)(5) Monthly analyses of carbon content for each fuel and feedstock used in hydrogen production: Liquid. P

- 2 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.
P 

### §98.166(b)(5) Monthly analyses of carbon content for each fuel and feedstock used in hydrogen production: Solid. P

- 3 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.
P 

### §98.166(b)(6) Monthly analyses of the molecular weight of gaseous P

- 1 Provides production or raw material data described in section

## 78 Subpart 

### Rule Citation in 40

CFR Part 98 Data Element Description Data Element is used as Input to Equation . . . Analysis Results
fuels and feedstocks. 2.1 of Part Two of this memorandum.

Q 

### §98.176(b) Annual production quantity (in metric tons) for taconite pellets, coke, sinter, iron, a nd raw steel Calculation method specified in 98.173(b)(2)(iv ) for the site

specific emission factor method and calculation methods in 98.173(b)(1) for the mass balance method Provides production or raw

material data described in section 2.1 of Part Two of this memorandum.

Q 

### §98.176(e)(1) Carbon content of each process input used to determine CO 2 emissions (No CEMS)

- solid fuel combusted (Csf). Q

- 1 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

Q 

### §98.176(e)(1) Carbon content of each process input used to determine CO 2 emissions (No CEMS)

- gaseous fuel combusted(C gf

). Q

- 1 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

Q 

### §98.176(e)(1) Carbon content of each process input used to determine CO 2 emissions (No CEMS)

- liquid fuel combusted (C lf

). Q

- 1 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

Q 

### §98.176(e)(1) Carbon content of each process inp ut used to determine CO 2 emissions (No CEMS)

- greenball pellets produced (Co) and other process inputs. Q

- 1 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

Q 

### §98.176(e)(1) Carbon content of each

process output used to determine CO2 emissions (No CEMS)

- Fired pellets produced (Cp). Q

- 1 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

Q 

### §98.176(e)(1) Carbon content of each process output used to determine CO 2 emissions (No CEMS)

- air pollution control residue collected (Cr) and other process outputs. Q

- 1 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

Q 

### §98.176(e)(1) Carbon content of each process input used to determine CO 2 emissions (No CEMS)

- Iron (C iron ) and other process inputs. Q

- 2 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

Q 

### §98.176(e)(1) Carbon content of each process input used to determine CO 2 emissions (No CEMS)

- Scrap (C scrap ). Q

- 2 Provides production or raw material data described in section 2.1 of Part Two of this memorandum. Q 

### §98.176(e)(1) Carbon content of each process input used to determine CO 2 emissions (No CEMS)

- Flux (C flux ). Q

- 2 Provides production or raw material data described in section 2.1 of Part Two of this memorandum. Q 

### §98.176(e)(1) Carbon content of each process input used to determine CO 2 emissions (No CEMS)

- Carbonaceous Q

- 2 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

## 79 Subpart 

### Rule Citation in 40

CFR Part 98 Data Element Description Data Element is used as Input to Equation . . . Analysis Results material (C carbon ).

Q 

### §98.176(e)(1) Carbon content of each process output used to determine CO 2 emissions (No CEMS)

- Steel produced (C steel ). Q

- 2 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

Q 

### §98.176(e)(1) Carbon content of each process output used to determine CO 2 emissions (No CEMS)

- Slag produced (C slag ). Q

- 2 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

Q 

### §98.176(e)(1) Carbon content of each process output used to determine CO 2 emissions (No CEMS)

- Air pollution control residue collected (C R ) and other process outputs. Q

- 2 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

Q 

### §98.176(e)(1) Carbon content of each process input used to determine CO 2 emissions (No CEMS)

- Coal charged to coke battery (C coal ) and other process inputs. Q

- 3 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

Q 

### §98.176(e)(1) Carbon content of each process output used to determine CO 2 emissions (No CEMS)

- Coke produced by coke battery (C coke ). Q

- 3 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

Q 

### §98.176(e)(1) Carbon content of each process output used to determine CO 2 emissions (No CEMS)

- Air pollution control residue collected from coke battery (C R ) and other process outputs. Q

- 3 Provides productio n or raw material data described in section 2.1 of Part Two of this memorandum.

Q 

### §98.176(e)(1) Carbon content of each process input used to determine CO 2 emissions (No CEMS)

- Gaseous fuel combusted in the sinter process (C gf

). Q

- 4 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

Q 

### §98.176(e)(1) Carbon content of each process input used to determine CO 2 emissions (No CEMS)

- sinter feed (C Feed ) and other process inputs. Q

- 4 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

Q 

### §98.176(e)(1) Carbon content of each process output used to determine CO 2 emissions (No CEMS)

- sinter (C Sinter ). Q

- 4 Provides production or raw material data described in section 2.1 of Part Two of this memorandum. Q 

### §98.176(e)(1) Carbon content of each process output used to determine CO 2 emissions (No CEMS)

- Air pollution control residue collected from sinter process (C R ) and other process outputs. Q

- 4 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

Q 

### §98.176(e)(1) Carbon content of each process input used to determine CO 2 emissions (No CEMS)

- Gaseous fuel Q

- 5 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

## 80 Subpart 

### Rule Citation in 40

CFR Part 98 Data Element Description Data Element is used as Input to Equation . . . Analysis Results (C gf ).and Iron (C iron ) used in EAF.

Q 

### §98.176(e)(1) Carbon content of each process input used to determine CO 2 emissions (No CEMS)

- Scrap (C scrap ) used in EAF. Q

- 5 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

Q 

### §98.176(e)(1) Carbon content of each process input used to determine CO 2 emissions (No CEMS)

- Flux (C flux ) used in EAF. Q

- 5 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

Q 

### §98.176(e)(1) Carbon content of each process input used to determine CO 2 emissions (No CEMS)

- Carbonaceous material (C carbon ) used in EAF. Q

- 5 Provides production or raw material data described in section 2.1 of Part Two of this

memora ndum.

Q 

### §98.176(e)(1) Carbon content of each process input used to determine CO 2 emissions (No CEMS)

- Electrode consumed in EAF (C electrode ) and other process inputs. Q

- 5 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

Q 

### §98.176(e)(1) Carbon content of each process output used to determine CO 2 emissions (No CEMS)

- Steel produced (C steel ) in EAF. Q

- 5 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

Q 

### §98.176(e)(1) Carbon content of each process output used to determine CO 2 emissions (No CEMS)

- Slag produced (C slag ) in EAF. Q

- 5 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

Q 

### §98.176(e)(1) Carbon con tent of each process output used to determine CO 2 emissions (No CEMS)

- Air pollution control residue collected (C R ) for EAF and other process outputs. Q

- 5 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

Q 

### §98.176(e)(1) Carbon content of each process input used to determine CO 2 emissions (No CEMS)

- molten steel before decarburization (C tsteel in ) in EAF and other process inputs. Q

- 6 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

Q 

### §98.176(e)(1) Carbon content of each process output used to determine CO 2 emissions (No CEMS)

- molten steel after decarburization (C steelout ) in EAF. Q

- 6 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

Q 

### §98.176(e)(1) Carbon content of each process output used to determine CO 2 emissions (No CEMS)

- Air pollution control residue collected (C R ) for EAF and other process outputs. Q

- 6 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

## 81 Subpart 

### Rule Citation in 40

CFR Part 98 Data Element Description Data Element is used as Input to Equation . . . Analysis Results Q 

### §98.176(e)(1) Carbon content of each process input used to determine CO 2 emissions (No CEMS)

- Gaseous fuel combusted in the direct reduction furnace (F g ) . Q

- 7 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

Q 

### §98.176(e)(1) Carbon content of each process input used to determine CO 2 emissions (No CEMS)

- iron ore or iron ore pellets fed into the direct reduction furnace (C
ore ) . Q

- 7 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

Q 

### §98.176(e)(1) Carbon content of each process input used to determine CO 2 emissions (No CEMS)

- Carbonaceous material (C carbon ) used in the direct reduction furnace . Q

- 7 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

Q 

### §98.176(e)(1) Carbon content of each process input used to determine CO 2 emissions (No CEMS)

- Other materials charged to the direct reduct ion furnace (C other ). Q

- 7 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

Q 

### §98.176(e)(1) Carbon content of each process output used to determine CO 2 emissions (No CEMS)

- Iron produced from direct reduction furnace (C iron ). Q

- 7 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

Q 

### §98.176(e)(1) Carbon content of each process output used to determine CO 2 emissions (No CEMS)

- Non

- metallic materials produced from direct reduction furnace (C NM ) and other process inputs. Q

- 7 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

Q 

### §98.176(e)(1) Carbon content of each process output used to determine CO 2 emissions (No CEMS)

- Air pollution control residue collected (C R ) for direct reduction furnace and other process outputs. Q

- 7 Provides production or raw material data described in section 2.1 of Part Two of this

m emorandum.

Q 

### §98.176(e)(3) Annual volume of each type of gaseous fuel used to determine CO 2 emissions (reported separately for each type in standard cubic feet) (No CEMS)

- Taconite Indurating Furnace. Q

- 1 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

Q 

### §98.176(e)(3) Annual volume of each type of liquid fuel used to determine CO 2 emissions (reported separately for each type in gallons) (No CEMS)

- Taconite Indurating Furnace. Q

- 1 Provides produc tion or raw material data described in section 2.1 of Part Two of this memorandum.

Q 

### §98.176(e)(3) Annual mass (in metric tons) of each process input used to determine CO 2 emissions (No CEMS)

- Annual mass of greenball (taconite) pellets fed into the furn ace (O) and other process inputs. Q

- 1 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

## 82 Subpart 

### Rule Citation in 40

CFR Part 98 Data Element Description Data Element is used as Input to Equation . . . Analysis Results Q 

### §98.176(e)(3) Annual mass (in metric tons) of each process input used to determine CO 2 emissions (No CEMS)

- Annual mass of solid fuel combusted (Fs). Q

- 1 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

Q 

### §98.176(e)(3) Annual mass (in metric tons) of each process output used to determine CO 2 emissions (No CEMS)

- Annual mass of air pollution control residue (R) and other process outputs. Q

- 1 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

Q 

### §98.176(e)(3) Annual mass (in metric tons) of each process output used to determine CO 2 emissions (No CEMS)

- Annual mass of fired pellets produced (P). Q

- 1 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

Q 

### §98.176(e)(3) Annual mass (in metric tons) of e ach process input used to determine CO 2 emissions (No CEMS)

- Annual mass of molten iron charged to furnace (Iron) and other process inputs. Q

- 2 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

Q 

### §98.176(e)(3) Annual mass (in metric tons) of each process input used to determine CO 2 emissions (No CEMS)

- Annual mass of scrap charged to the furnace (Scrap). Q

- 2 Provides production or raw material data described in section 2.1 of Part Two of this

memor andum.

Q 

### §98.176(e)(3) Annual mass (in metric tons) of each process input used to determine CO 2 emissions (No CEMS)

- Annual mass of flux charged to the furnace (Flux). Q

- 2 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

Q 

### §98.176(e)(3) Annual mass (in metric tons) of each process input used to determine CO 2 emissions (No CEMS)

- Annual mass of carbon (e.g., coal, coke) charged to furnace (Carbon). Q

- 2 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

Q 

### §98.176(e)(3) Annual mass (in metric tons) of each process output used to determine CO 2 emissions (No CEMS)

- Annual mass of steel produced (Steel). Q

- 2 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

Q 

### §98.176(e)(3) Annual mass (in metric tons) of each process output used to determine CO 2 emissions (No CEMS)

- Annual mass of slag produced (Slag). Q

- 2 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

Q 

### §98.176(e)(3) Annual mass (in metric tons) of each process output used to determine CO 2 emissions (No CEMS)

- Annual mass of air pollution control residue collected (Residue) and other process outputs. Q

- 2 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

Q 

### §98.176(e)(3) Annual mass (in metric tons) of each process input used to determine CO 2 emissions (No CEMS)

- Coal charged to battery (Coal) and other

proce ss inputs. Q

- 3 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

## 83 Subpart 

### Rule Citation in 40

CFR Part 98 Data Element Description Data Element is used as Input to Equation . . . Analysis Results Q 

### §98.176(e)(3) Annual mass (in metric tons) of each process output used to determine CO 2 emissions (No CEMS)

- Annual mass of coke produced (Coke). Q

- 3 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

Q 

### §98.176(e)(3) Annual mass (in metric tons) of each process output used to determine CO 2 em issions (No CEMS)

- Annual mass of air pollution control residue collected from battery (R) and other process outputs. Q

- 3 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

Q 

### §98.176(e)(3) Annual volume of each type of gaseous fuel used to determine CO 2 emissions (reported separately for each type in standard cubic feet) (No CEMS)

- Sinter process (Fg). Q

- 4 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

Q 

### §98.176(e)(3) Annual mass (in metric tons) of each process input used to determine CO 2 emissions (No CEMS)

- Annual mass of sinter feed material (Feed) and other process inputs. Q

- 4 Provides production or raw material data described in section 2.1 of Part T wo of this memorandum.

Q 

### §98.176(e)(3) Annual mass (in metric tons) of each process input used to determine CO 2 emissions (No CEMS)

- Annual mass of sinter Produced (Sinter). Q

- 4 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

Q 

### §98.176(e)(3) Annual mass (in metric tons) of each process output used to determine CO 2 emissions (No CEMS)

- Annual mass of air pollution control residue collected from sinter process (R) and other process outputs. Q

- 4 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

Q 

### §98.176(e)(3) Annual mass (in metric tons) of each process input used to determine CO 2 emissions (No CEMS)

- Annual mass of direct reduced iron charged to the EAF (Iron). Q

- 5 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

Q 

### §98.176(e)(3) Annual mass (in metric tons) of each process input used to determine CO 2 emissions (No CEMS)

- Annual mass of Scrap charged to the EAF(Scrap). Q

- 5 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

Q 

### §98.176(e)(3) Annual mass (in metric tons) of each process input used to determine CO 2 emissions (No CEMS)

- Annual mass of flux charged to the EAF(Flux). Q

- 5 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

Q 

### §98.176(e)(3) Annual mass (in metric tons) of each proc ess input used to determine CO 2 emissions (No CEMS)

- Annual mass of carbon electrode consumed in the EAF(Electrode) and other process inputs. Q

- 5 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

## 84 Subpart 

### Rule Citation in 40

CFR Part 98 Data Element Description Data Element is used as Input to Equation . . . Analysis Results Q 

### §98.176(e)(3) Annual mass (in metric tons) of each process input used to determine CO2 emissions (No CEMS)

- Annual mass of carbonaceous (coal or coke) material charged to the EAF(Carbon). Q

- 5 Provides production or raw material data described in section 2. 1 of Part Two of this memorandum.

Q 

### §98.176(e)(3) Annual mass (in metric tons) of each process output used to determine CO 2 emissions (No CEMS)

- Annual mass of steel produced (Steel) in EAF. Q

- 5 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

Q 

### §98.176(e)(3) Annual mass (in metric tons) of each process output used to determine CO 2 emissions (No CEMS)

- Annual mass of slag produced (Slag) in EAF. Q

- 5 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

Q 

### §98.176(e)(3) Annual mass (in metric tons) of each process output used to determine CO 2 emissions (No CEMS)

- Annual mass of air pollution control residue collected (Residue) from EAF and other process ou tputs; and annual volume of each type of gaseous fuel used to determine CO 2 emissions (reported separately for each type in standard cubic feet) (No CEMS)

– each furnace (Fg).. Q

- 5 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

Q 

### §98.176(e)(3) Annual mass (in metric tons) of each process input used to determine CO 2 emissions (No CEMS)

- Annual mass of steel charged to the decarburization vessel (Steel) and other process inputs. Q

- 6 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

Q 

### §98.176(e)(3) Annual mass (in metric tons) of each process output used to determine CO 2 emissions (No CEMS)

- Annual mass of air pollution control residue collected (Residue) from the decarburization vessel and other process outputs. Q

- 6 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

Q 

### §98 .176(e)(3) Annual volume of each type of gaseous fuel used to determine CO 2 emissions (reported separately for each type in standard cubic feet) (No CEMS)

- direct reduction furnaces (Fg). Q

- 7 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

Q 

### §98.176(e)(3) Annual mass (in metric tons) of each process input used to determine CO 2 emissions (No CEMS)

- Annual mass of iron ore or iron ore pellets charged to the direct reduction furnace (Ore). Q

- 7 Provides prod uction or raw material data described in section 2.1 of Part Two of this memorandum.

## 85 Subpart 

### Rule Citation in 40

CFR Part 98 Data Element Description Data Element is used as Input to Equation . . . Analysis Results Q 

### §98.176(e)(3) Annual mass (in metric tons) of each process input used to determine CO 2 emissions (No CEMS)

- Annual mass of carbonaceous (coal or coke) material charged to the direct reduction furnace (Carbon). Q

- 7 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

Q 

### §98.176(e)(3) Annual mass (in metric tons) of each process input used to determine CO 2 emissions (No CEMS)

- Annual mass of other material charged to the direct reduction furnace (Other). Q

- 7 Provides production or raw material data described in section 2.1 of Part Two of this

memor andum.

Q 

### §98.176(e)(3) Annual mass (in metric tons) of each process input used to determine CO 2 emissions (No CEMS)

- Annual mass of iron produced (Iron) in direct reduction furnace. Q

- 7 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

Q 

### §98.176(e)(3) Annual mass (in metric tons) of each process input used to determine CO 2 emissions (No CEMS)

- Annual mass of non

metallic materials produced (NM) in direct reduction furnace and other process inputs. Q

- 7 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

Q 

### §98.176(e)(3) Annual mass (in metric tons) of each process output used to determine CO 2 emissions (No CEMS)

- Annual mass of air pollution control residue collected (Residue) from the direct reduction furnace and other process outputs. Q

- 7 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

Q 

### §98.176(e)(4) Molecular weight of gaseous fuels (No CEMS)

- Taconite Indurating Furnace. Q

- 1 Provides production or raw material data described in section 2.1 of Part Two of this memorandum. Q 

### §98.176(e)(4) Molecular weight of gaseous fuels (No CEMS)

- Sinter Process or Electric Arc
Furnace. Q

- 4and Q

- 5 Provides production or raw material data described in section 2.1 of Part Two of this memorandum. Q 

### §98.176(e)(4) Molecular weight of gaseous fuels (No CEMS)

- Direct Reduction Furnace. Q

- 7 Provides production or raw material data described in section 2.1 of Part Two of this memorandum. Q §98.176(f)(1) Measured average hourly CO 2 emission rate during the test (No CEMS). No Equation

- Used as input to method described in §98.173(b)(2)(ii i). Provides data described in section

2.3 of Part Two of this memorandum that could be used to calculate iron and steel production rate if the EF (40 CFR 98.176(f)(3), for which reporting was deferred to 2015) is also known. However, if the EF were not reported, would not reveal any proprietary information about facility or

process performance, design, and operation; cost to do business; raw material usage; or production.

## 86 Subpart 

### Rule Citation in 40

CFR Part 98 Data Element Description Data Element is used as Input to Equation . . . Analysis Results Q 

### §98.176(f)(2) Average hourly feed rate during the test (No CEMS). No Equation

- Used as input in calc. method described in §98.173(b)(2)(ii i). Provides production or raw

material data described in section 2.1 of Part Two of this memorandum.

Q 

### §98.176(f)(2) Average hourly production rate during the test (No CEMS). No Equation

- Used as input in calc. method described in §98.173(b)(2)(ii i). Provides production or raw

material data described in section 2.1 of Part Two of this memorandum.

Q 

### §98.176(f)(3) Site

- specific emission factor (No CEMS). No Equation

- Used as input in calc. method described in §98.173(b)(2)(i v). Provides data described in section

2.3 of Part Two of this memorandum that could be used to calculate the iron and steel production if one of the following is also known: the measured average hourly CO2 emission rate during the test (40 CFR 98.176(f)(1), f

or which reporting was deferred to 2015); or CO2 mass emissions (as currently reported under 40 CFR 98.3(c)(4) and made publicly available) 1

. Q 

### §98.176(f)(4) Annual feed rate used to estimate annual CO 2 emissions (No CEMS). No Equation

- Used as input i n calc. method described in §98.173(b)(2)(i v). Provides production or raw

material data described in section 2.1 of Part Two of this memorandum.

Q 

### §98.176(f)(4) Annual production rate used to estimate annual CO 2 emissions (No CEMS). No Equation

- Used as input in calc. method described in §98.173(b)(2)(i v). Provides production or raw

material data described in section 2.1 of Part Two of this memorandum.

Q 

### §98.176(g) The annual amount of coal charged to the coke ovens (in metric tons). No Equation

- Use d as input in calc. method described in §98.173(c). Provides production or raw

material data described in section 2.1 of Part Two of this memorandum.

R 

### §98.186(b)(6) Annual material quantity used for the calculation of annual process CO 2 emissions (No CEMS) (Ore = Annual mass of lead ore charged to the smelting furnace (tons).) R

- 1 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

R 

### §98.186(b)(6) Annual material quantity used for the calculation of annual process CO 2 emissions (No CEMS) (Scrap = Annual mass of lead scrap charged to the smelting furnace (tons).) R

- 1 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

R 

### §98.186(b)(6) Annual material quantity used for the calculation of annual process CO 2 emissions (No CEMS) (Flux = Annual mass of flux materials (e.g., limestone, dolomite) charged to the smelting furnace (tons).) R

- 1 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

## 87 Subpart 

### Rule Citation in 40

CFR Part 98 Data Element Description Data Element is used as Input to Equation . . . Analysis Results

R 

### §98.186(b)(6) Annual material quantity used for the calculation of annual process CO 2 emissions (No CEMS) (Carbon = Annual mass of carbonaceous materials (e.g., coal, coke) charged to the smelting furnace (tons).) R

- 1 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

R 

### §98.186(b)(6) Annual material quantity used for the calculation of annual process CO 2 emissions (No CEMS) (Other = Annual mass of any other material containing carbon, other than fuel, fed, charged, or otherwise introduced into the smelting furnace (tons).) R

- 1 Provides produc tion or raw material data described in section 2.1 of Part Two of this memorandum.

R 

### §98.186(b)(7) Annual average of the carbon content determinations for each material used for the calculation of annual process CO 2 emissions (No CEMS) (COre= Carbon content of the lead ore, from the carbon analysis results (percent by weight, expressed as a decimal fraction).) R

- 1 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

R 

### §9 8.186(b)(7) Annual average of the carbon content determinations for each material used for the calculation of annual process CO 2 emissions (No CEMS). (CScrap= Carbon content of the lead scrap, from the carbon analysis (percent by weight, expressed as a dec imal fraction).) R

- 1 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

R 

### §98.186(b)(7) Annual average of the carbon content determinations for each material used for the calculation of annual process CO 2 emissions (No CEMS). (CFlux= Carbon content of the flux materials, from the carbon analysis (percent by weight, expressed as a decimal fraction).) R

- 1 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

R 

### §9 8.186(b)(7) Annual average of the carbon content determinations for each material used for the calculation of annual process CO 2 emissions (No CEMS). (CCarbon= Carbon content of the carbonaceous materials, from the carbon analysis (percent by weight, expre ssed as a decimal fraction).) R

- 1 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

R 

### §98.186(b)(7) Annual average of the carbon content determinations for each material used for the calculation of annual process CO 2 emissions (No CEMS). (COther= Carbon content of the other material from the carbon analysis results R

- 1 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

## 88 Subpart 

### Rule Citation in 40

CFR Part 98 Data Element Description Data Element is used as Input to Equation . . . Analysis Results (percent by weight, expressed as a decimal fraction).)

S 

### §98.196(b)(2) Monthly emission factors for each lime type produced. S

- 4 Provides data described in section 2.3 of Part Two of this memorandum that could be used to calculate the production rate for each lime product if annual CO2 process emissions (as currently reported under 40 CFR 98.3(c)(4) and made publicly available) 1 is known.
S 

### §98.196(b)(3) Monthly emission factors for each calcined byproduct/waste by lime type that is sold. (EFLKD,i,n) S

- 4 Provides data described in section 2.3 of Part Two of this memorandum that could be used to calculate the weight or mass of calcined byproducts/waste sold if annual CO2 process emissions (as currently reported under 40 CFR 98.3(c)(4) and made publicly avai lable) 1 is known.
S 

### §98.196(b)(5) Monthly results of chemical composition analysis of each type of lime product produced (CaOi,n and MgOi,n) (No CEMS). S

- 1 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

S 

### §98.196(b)(5) Monthly results of chemical composition analysis of each type of calcined lime byproduct/waste sold (CaOLKDi,n and MgOLKDi,n) (No CEMS). S

- 2 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

S 

### §98.196(b)(6) Annual results of chemical composition analysis of each type of lime byproduct/waste that is not sold ( CaOwastei,n and MgOwastei,n) (No CEMS). S

- 3 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

S 

### §98.196(b)(8) Monthly amount of lime product sold, by type (No CEMS). Calculation method described in §98.194(a) Provides production or raw

material data described in section 2.1 of Part Two of this memorandum.
S 

### §98.196(b)(10) Monthly amount of calcined lime byproduct/waste sold, by type (MLKDi,n) (No CEMS). S

- 4 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.
S 

### §98.196(b)(11) Annual amount of calcined lime byproduct/waste that is not sold, by type (Mwastei) (No CEMS). S

- 3 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.
S 

### §98.196(b)(12) Monthly weight or mass of each lime type produced (MLIMEi,n) (No CEMS). S

- 4 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.
U 

### §98.216(b) Annual carbonate consumption by carbonate type. U

- 1 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

## 89 Subpart 

### Rule Citation in 40

CFR Part 98 Data Element Description Data Element is used as Input to Equation . . . Analysis Results

U 

### §98.216(b) Annual carbonate input by carbonate type. U

- 2 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.
U 

### §98.216(e)(1) Annual carbonate consumption by carbonate type. U

- 1 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.
U 

### §98.216(e)(2) Annual calcination fractions used in calculations. U

- 1 Provides data described in section 2.3 of Part Two of this memorandum that could, if facility uses only one carb onate, be used to calculate the annual mass of each carbonate type consumed if the CO2 emissions (as currently reported under 40 CFR 98.3(c)(4) and made publicly available) 1 are also known.
U 

### §98.216(f)(1) Annual carbonate input by carbonate type. U

- 2 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.
U 

### §98.216(f)(2) Annual carbonate output by carbonate type. U

- 2 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.
V 

### §98.226(c) Annual nitric acid production from each nitric acid train (tons, 100% acid basis) (Pt). V

- 2 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.
V 

### §98.226(c) Annual nitric acid production from each nitric acid train (tons, 100% acid basis) (Pt). V

- 3a Provides production or raw material data described in section 2.1 of Part Two of this memorandum.
V 

### §98.226(c) Annual nitric acid production from each nitric acid train (tons, 100% acid basis) (Pt). V

- 3b Provides production or raw material data described in section 2.1 of Part Two of this memorandum.
V 

### §98.226(c) Annual nitric acid production from each nitric acid train (tons, 100% acid basis) (Pt). V

- 3c Provides production or raw material data described in section 2.1 of Part Two of this memorandum.
V 

### §98.226(c) Annual nitric acid production from each nitric acid train (tons, 100% acid basis) (Pt). V

- 3d Provides production or raw material data described in section 2.1 of Part Two of this memorandum.
V 

### §98.226(d) Annual nitric acid production during which N 2 O abatement technology is operating (tons, 100% acid basis). V

- 2 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.
V 

### §98.226(m)(1) Emission factor calculated for each nitric acid train (EFN2Ot). V

- 3a In certain cases provides data related to process design; process performance, and operation; and/or cost to do business, as described in section 2.2 of Part Two of this

me morandum. Specifically, could indicate process performance, and operational efficiencies that could be used to determine train

- specific operational conditions at the facility.

## 90 Subpart 

### Rule Citation in 40

CFR Part 98 Data Element Description Data Element is used as Input to Equation . . . Analysis Results

V 

### §98.226(i) Abatement technology destruction efficiency (DF). V

- 3a Provides data related to process design; process performance, and operation; and/or cost to do business, as described in section 2.2 of Part Two of this memorandum. Specifically, indicates process performance, and operational efficiencies that could be used to dete rmine train

- specific operational conditions at the facility.
V 

### §98.226(j) Abatement utilization factor (AF). V

- 3a Provides data described in section 2.3 in Part Two of this memorandum that could be used to calculate the mass of nitric acid produced if all of the following data are also known: annual N2O mass emissions from nitric acid production (as currently reported under 40 CFR 98.3(c)(4) and made publicly available) 1 , EFs (40 CFR 98.226(m)(1), for which reporting was deferred to 2015), and the destruction efficiency (40 CFR 98.226(i), for which reporting was deferred to 2015). However, if the EFs were not reported , would not reveal any proprietary information about facility or process performance, design, and operation; cost to do business; raw material usage; or production.
V 

### §98.226(m)(1) Emission factor calculated for each nitric acid train (EFN2Ot). V

- 3b In certain cases provides data related to process design; process performance, and operation; and/or cost to do business, as described in section 2.2 of Part Two of this memorandum. Specifically, could indicate process performance, and operational efficiencie s that could be used to determine train

- specific operational conditions at the facility.
V 

### §98.226(i) Abatement technology destruction efficiency (DF). V

- 3b Provides data related to process design; process performance, and operation; and/or cost to do business, as described in section 2.2 of Part Two of this memorandum. Specifically, indicates process performance, and operational efficiencies that could be used to determine train

- specific operational conditions at the facility.
V 

### §98.226(j) Abatement utilization factor (AF). V

- 3b Provides data related to process design; process performance, and operation; and/or cost to do business, as described in section 2.2 of Part Two of this memorandum. Specifically, indicates process performance, and operational efficiencies that could be used to determine train

- specific operational conditions at the facility.

## 91 Subpart 

### Rule Citation in 40

CFR Part 98 Data Element Description Data Element is used as Input to Equation . . . Analysis Results

V 

### §98.226(m)(1) Emission factor calculated for each nitric acid train (EFN2Ot). V

- 3c In certain cases provides data related to process design; process performance, and operation; and/or cost to do business, as described in section 2.2 of Part Two of this memorandum. Specifically, could indicate process performance, and operational efficiencies that could be used to determine train

- specific operational co nditions at the facility.
V 

### §98.226(i) Abatement technology destruction efficiency (DF). V

- 3c Provides data related to process design; process performance, and operation; and/or cost to do business, as described in section 2.2 of Part Two of this

memoran dum. Specifically, indicates process performance, and operational efficiencies that could be used to determine train

- specific operational conditions at the facility.
V 

### §98.226(j) Abatement utilization factor (AF). V

- 3c Provides data related to process design; process performance, and operation; and/or cost to do business, as described in section 2.2 of Part Two of this memorandum. Specifically, indicates process performance, and operational efficiencies that could be used to determine train

- specific

ope rational conditions at the facility.
V 

### §98.226(p) Fraction control factor for each abatement technology (percent of total emissions from the production unit that are sent to the abatement technology) if equation V

- 3c is used. V

- 3c Provides data related t o process design; process performance, and operation; and/or cost to do business, as described in section 2.2 of Part Two of this memorandum. Specifically, indicates process performance, and operational efficiencies that could be used to determine train

- sp ecific operational conditions at the facility.
V 

### §98.226(m)(1) Emission factor calculated for each nitric acid train (EFN2Ot). V

- 3d In certain cases provides data related to process design; process performance, and operation; and/or cost to do business, as described in section 2.2 of Part Two of this memorandum. Specifically, could indicate process performance, and operational efficiencies that could be used to determine train

- specific operational conditions at the facility.
V 

### §98.226(m)(3) Production rate per test run during performance test for each train. V

- 1 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

## 92 Subpart 

### Rule Citation in 40

CFR Part 98 Data Element Description Data Element is used as Input to Equation . . . Analysis Results

V 

### §98.226(m)(4) N 2 O concentration per test run during performance test for each train. V

- 1 Provides data related to process design; process performance, and operation; and/or cost to do business, as described in section 2.2 of Part Two of this memorandum. Specifically, indicates process performance, and operational efficiencies that could be use d to determine train

- specific operational conditions at the facility.
V 

### §98.226(m)(5) Volumetric flow rate per test run during performance test each train V

- 1 Provides data related to process design; process performance, and operation; and/or cost to do business, as described in section 2.2 of Part Two of this memorandum. Specifically, indicates process performance, and operational efficiencies that could be used to determine train

- specific operational conditions at the facility.
V 

### § 98.226(m)(6) Numb er of test runs during performance test each train. V

- 1 Provides data described in section 2.3 in Part Two of this memorandum that could be used to calculate the production rate of nitric acid if all of the following data are also known: EFs (40 CFR 98.226(m)(1), for which reporting was deferred to 2015), N2O concentration per test run during performance test (40 CFR 98.226(m)(4), for which reporting was deferred to 2015), and volumetric flow rate per test run during performance test (40 CFR 98.226(m) (5), for which reporting was deferred to 2015). However, if the EFs were not reported, would not reveal any proprietary information about facility or process performance, design, and operation; cost to do business; raw material usage; or production.
X 

### § 9 8.246(a)(4) Indicate whether you used the alternative to sampling and analysis specified in § 98.243(c)(4). X

- 1 Provides data related to production/raw materials, process design; process performance, and operation; and/or cost to do business, as described in sections 2.1 and 2.2 of Part Two of this memorandum. Specifically, indicates whether the concentration of a specific compound in a feedstock, byproduct, or product of a petrochemical process is greater than 99.5%.
X 

### §98.246(a)(4) Monthly volume values (used in Equations X

- 1 to X

- 3)

- Volume of gaseous feedstock i introduced in month "n" ((F gf ) n). X

- 1 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

X 

### §98.246(a)(4) Monthly volume values (used in Equations X

- 1 to X

- 3)

- Volume of gaseous product i produced in month "n" ((P gf ) n) X

- 1 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

## 93 Subpart 

### Rule Citation in 40

CFR Part 98 Data Element Description Data Element is used as Input to Equation . . . Analysis Results

X 

### §98.246(a)(4) Monthly carbon content values (used in Equations X

- 1
to X

- 3)

- Average carbon content of the gaseous feedstock i for month "n" ((CCgf)n). X

- 1 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

X 

### §98.246(a)(4) Monthly carbon content values (used in Equations X

- 1 to X

- 3)

- Average carbon content of the gaseous product i for month "n" ((CCgp)n). X

- 1 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

X 

### §98.246(a)(4) Molecular weights for gaseous feedstocks (used in Equ ation X

- 1). X

- 1 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.
X 

### §98.246(a)(4) Molecular weights for gaseous products (used in Equation X

- 1). X

- 1 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.
X 

### §98.246(a)(4) Indicate whether you used the alternative to sampling and analysis specified in § 98.243(c)(4). X

- 2 Provides data related to production/raw materials, process design; process performance, and operation; and/or cost to do business, as described in sections 2.1 and 2.2 of Part Two of this memorandum. Specifically, indicates whether the concentration of a specific compound in a feedstock, byproduct, or prod uct of a petrochemical process is greater than 99.5%.
X 

### §98.246(a)(4) Monthly volume values (used in Equations X

- 1 to X

- 3)

- Volume of liquid feedstock i for month "n" ((F lf

)
n ). X

- 2 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.
X 

### §98.246(a)(4) Monthly volume values (used in Equations X

- 1 to X

- 3)

- Volume of liquid product i for month "n" ((P lp )
n ) . X

- 2 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.
X 

### §98.246(a)(4) Monthly mass values (used in Equations X

- 1 to X

- 3)

- Mass of liquid feedstock i for month "n" ((F lf

)
n ). X

- 2 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.
X 

### §98.246(a)(4) Monthly mass values (used in Equations X

- 1 to X

- 3)

- Mass of liquid product i for month "n" ((P lp )
n ). X

- 2 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.
X 

### §98.246(a)(4) Monthly carbon content values (used in Equation s X

- 1
to X

- 3)

- Average carbon content of the liquid feedstock i for month "n" ((CC lf )n). X

- 2 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

X 

### §98.246(a)(4) Monthly carbon content values (used in Equations X

- 1
to X

- 3)

- Average carbon content of the liquid product i for month "n" ((CClp)n). X

- 2 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

## 94 Subpart 

### Rule Citation in 40

CFR Part 98 Data Element Description Data Element is used as Input to Equation . . . Analysis Results

X 

### § 98.246(a)(4) Indicate whether you used the alternative to sampling and analysis specified in § 98.243(c)(4). X

- 3 Provides data related to production/raw materials, process design; process performance, and operation; and/or cost to do business, as described in sections 2.1 and 2.2 of Part Two of thi s memorandum. Specifically, indicates whether the concentration of a specific compound in a feedstock, byproduct, or product of a petrochemical process is greater than 99.5%.
X 

### §98.246(a)(4) Monthly mass values (used in Equations X

- 1 to X

- 3)

- Mass of solid feedstock i for month "n" ((F sf )
n ). X

- 3 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.
X 

### §98.246(a)(4) Monthly mass values (used in Equations X

- 1 to X

- 3)

- Mass of solid product i for month "n" ((P sp )
n ). X

- 3 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.
X 

### §98.246(a)(4) Monthly carbon content values (used in Equations X

- 1 to X

- 3)

- Average carbon content of the solid feedstock i for month "n" ((CC lf

)n). X

- 3 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

X 

### §98.246(a)(4) Monthly carbon content values (used in Equations X

- 1
to X

- 3)

- Average carbon content of the solid product i for month "n" ((CClp)n). X

- 3 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

X 

### §98.246(b)(5)(iii) Quantity of each type of fuel used in equation C

- 8 in §98.33(c) for each stationary combustion unit or group of units (as applicable) during the reporting year, expressed in short tons for solid fuels, gallons for liquid fuels, and scf for gaseous fuels. C

- 8 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

X 

### §98.246(b)(5)( iv ) The HHV (either default or annual average from measured data) used in equation C

- 8 in §98.33(C) for each stationary combustion unit or group of units (as applicable). C

- 8 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

Y 

### § 98.256(e)(6) If using Equation Y

- 1a: report the molar volume conversion factor (in scf/g

- mole) for each flare. Y

- 1a Would not reveal any proprietary information about facility or process performance, design, and operation; cost to do business; raw material usage; or production. Is a constant value widely known within the industry and publicly available.
Y 

### § 98.256(e)(7) If using Equation Y

- 1b: report molar volume conversion factor for each flare. Y

- 1b Would not reveal any proprietary information about facility or process performance, design, and operation; cost to do business; raw material usage; or production. Is a constant value widely known within the industry and publicly available.

## 95 Subpart 

### Rule Citation in 40

CFR Part 98 Data Element Description Data Element is used as Input to Equation . . . Analysis Results

Y 

### §98.256(e)(7)(ii) If using Equati on Y

- 1b: report the carbon mole number of each carbon containing compound other than CO 2 in the flare gas stream for each flare. Y

- 1b Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

Y 

### §98.256(e)(9) Annual volume of flare gas combusted during normal operations. Y

- 3 Provides data described in section 2.3 in Part Two of this memorandum that could be used to calculate the volume of gas flared during an SSM event if the following additional data are also known: the higher heating value, molecular weight, and carbon content of the flare gas (40 CFR 98.256(e)(9), for which reporting was deferred to 2015). This information could reveal information on the performance and operation of process units.
Y 

### §98.256(e)(9) Annual average higher heating value of the flare gas (normal). Y

- 3 Provides data described in section 2.3 in Part Two of this memorandum that could be used to calculate the amount of gas flared during an SSM event if the following additional data are also known: the volume of gas flared during normal operations, carbon content, and molecular weight of the flare gas ( 40 CFR 98.256(e)(9), for which reporting was deferred to 2015). This information could reveal information on the performance and operation of process units.
Y 

### §98.256(e)(9) Volume of gas flared during each SSM event exceeding 500,000 scf/day. Y

- 3 Provides data related to process design; process performance, and operation; and/or cost to do business, as described in section 2.2 of Part Two of this memorandum. Specifically, reveals information about amount of waste gas sent to the flare for combustio n during an SSM event, which could reveal information on the performance and operation of process units.
Y 

### §98.256(e)(9) Average molecular weight of gas flared during each SSM event exceeding 500,000 scf/day. Y

- 3 Provides data described in section 2.3 in Part Two of this memorandum that could be used to calculate the amount of gas flared during an SSM event if the following additional data are also known: the volume of gas flared during normal operations, the higher heating value, and the carbon content of the flare gas (40 CFR 98.256(e)(9), for which reporting was deferred to 2015).

## 96 Subpart 

### Rule Citation in 40

CFR Part 98 Data Element Description Data Element is used as Input to Equation . . . Analysis Results

Y 

### §98.256(e)(9) Carbon content of the flare gas during each SSM event exceeding 500,000 scf/day. Y

- 3 Provides data described in section 2.3 in Part Two of this memorandum that could be used to calculate the volume of gas flared during an SSM event if the following additional data are also known: the amount of gas flared during normal operations, the higher heating value, and the molecular weight of the flare gas (40 CFR 98. 256(e)(9) , for which reporting was deferred to 2015).
Y 

### §98.256(e)(9) If using Equation Y

- 3: report the molar volume conversion factor for each flare. Y

- 3 Would not reveal any proprietary information about facility or process performance, design, and operation; cost to do business; raw material usage; or production. Is a constant value widely known within the industry and publicly available.
Y 

### §98.256(e)(10) Fraction of carbon in the flare gas contributed by methane (used in Equation Y

- 4). Y

- 4 Would not reveal any proprietary information about facility or process performance, design, and operation; cost to do business; raw material usage; or production. Is a default value provided in 40 CFR 98.256(b)(2), a measured value, or an engineering estimate.
Y 

### § 98.256(f)(7) If using Equation Y

- 6: report the molar volume conversion factor. Y

- 6 Would not reveal any proprietary information about facility or process performance, design, and operation; cost to do business; raw material usage; or production. Is a constant value widely known within the industry and publicly available.
Y 

### §98.256(f)(1 0) Coke burn

- off factor. Y

- 8 Provides data described in section 2.3 of Part Two of this memorandum that could be used to calculate the annual production from catalytic cracking unit regenerators and fluid coking units if CO2 mass emissions (as currently re ported under 40 CFR 98.252(b) and made publicly available) 1 , are also known.
Y 

### §98.256(f)(10) Annual throughput of unit. Y

- 8 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.
Y 

### §98.256(f)(10) Average carbon content of coke. Y

- 8 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.
Y 

### §98.256(f)(11) If you use a unit

- specific emission factor for CH4: report the unit

- specific emission factor for CH4 for each ca talytic cracking unit, traditional fluid coking unit, and catalytic reforming unit. Used in method specified in §98.253(c)(4) Provides data described in section

2.3 of Part Two of this memorandum that could be used to calculate either production or raw material consumption (depending on whether the facility uses an emission factor based on production throughput or raw material co nsumption) if the N2O emissions (as currently reported under 40 CFR 98.252(e) and made

## 97 Subpart 

### Rule Citation in 40

CFR Part 98 Data Element Description Data Element is used as Input to Equation . . . Analysis Results

publicly available) 1 are also known.

Y 

### § 98.256(f)(11) Units of measure for the unit

specific CH 4 emission factor. Used in method specified in §98.253(c)(4) Would not reveal any proprietary

information about facility or process performance, design, and operation; cost to do business; raw material usage; or production. Provides only the units of measure for the emission factor.
Y 

### §98.256(f)(11) Activity data for calculating emissions (input). Used in method specified in §98.253(c)(4) Provides production or raw

material data described in section 2.1 of Part Two of this memorandum.
Y 

### §98.256(f)(11) Activity data for calculating emissions (product). Used in method specified in §98.253(c)(4) Provides production or raw

material data described in section 2.1 of Part Two of this memorandum.
Y 

### §98.256(f)(12) Activity data for calculating emissions (input). Used in method specified in §98.253(c)(5) Provides production or raw

material data described in section 2.1 of Part Two of this memorandum.
Y 

### §98.256(f)(12) Activity data for calculating emissions (production). Used in method specified in §98.253(c)(5) Provides production or raw

material data described in section 2 .1 of Part Two of this memorandum.
Y 

### §98.256(f)(12) If a unit

- specific emission factor for N2O was used: report the unit

- specific emission factor for N2O each catalytic cracking units, traditional fluid coking units, and catalytic reforming units. Used in method specified in §98.253(c)(5) Provides data described in section

2.3 of Part Two of this memorandum that could be used to calculate either production or raw material consumption (depending on whether the facility uses an emission factor based on produ ction throughput or raw material consumption) if the N2O emissions (as currently reported under 40 CFR §98.252(e) and made publicly available) 1 are also known.
Y 

### § 98.256(f)(12) Units of measure for the unit

specific N 2 O emission factor. Used in method specified in 9§8.253(c)(5) Would not reveal any proprietary

information about facility or process performance, design, and operation; cost to do business; raw material usage; or production. Provides only the units of measure for the emission factor.
Y 

### §98.256(f)(13) Average carbon content of coke. Y

- 11 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.
Y 

### § 98.256(h)(4) If Equation Y

- 12 is used: report the molar volume conversion factor.(onsite and offsite) Y

- 12 Would not reveal any proprietary information about facility or process performance, design, and operation; cost to do business; raw material usage; or production. Is a constant value widely known within the industry and publicly available.

## 98 Subpart 

### Rule Citation in 40

CFR Part 98 Data Element Description Data Element is used as Input to Equation . . . Analysis Results

Y 

### §98.256(h)(4) If Equation Y

- 12 is used: Annual volumetric flow to the sulfur recovery plant. (onsite and offsite) Y

- 12 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.
Y 

### §98.256(h)(4) If Equation Y

- 12 is used: Annual average mole fraction of carbon in the sour gas (on or offsite).(onsite and offsite) Y

- 12 Provides production or raw material data described in section 2.1 of Part Two of this memorandum
Y 

### §98.256(h)(5) Annual volume of recycled tail gas (onsite only, if used to calculate recycling correction factor). If a correction for CO2 emissions in the tail gas was used in Eq. Y

12, used in method specified in §98.253(f)(5) Provides production or raw

material data described in section 2.1 of Part Two of this memorandum.

Y 

### §98.256(h)(5) Annual average mole fraction of carbon in the tail gas (onsite only, if used to calculate recycling correction factor). If a correction for CO2 emissions in the tail gas was used in Eq. Y

12, used in method specified in §98.253(f)(5) Provides production or raw

material data described in section 2.1 of Part Two of this memorandum.

Y §98.256(h)(5) Value of the correction. If a correction for CO2 emissions in the tail gas was used in Eq. Y

12, used in method specified in §98.253(f)(5) Would not reveal any proprietary

information about facility or process performance, design, and operation; cost to do business; raw material usage; or production. Provides only information about quantity of carbon in tail gas recycled to the sulfur recover y plant.
Y 

### §98.256(i)(5) If you use Eq. Y

- 13, report the annual mass of green coke fed to each coke calcining unit Y

- 13 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.
Y 

### §98.256(i)(5) If you use Eq. Y

- 13, report the carbon content of green coke fed to each coke calcining unit. Y

- 13 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.
Y 

### §98.256(i)(5) If you use Eq. Y

- 13, report the annual mass of marketabl e coke produced for each coke calcining unit. Y

- 13 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.
Y 

### §98.256(i)(5) If you use Eq. Y

- 13, report the carbon content of marketable coke produced for each coke calcining unit. Y

- 13 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.
Y 

### §98.256(i)(5) If Equation Y

- 13 used for coke calcining units: report the annual mass of coke dust removed from the process through du st collection systems. Y

- 13 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

Y 

### §98.256(i)(7) For coke calcining: Activity data for calculating emissions (input data). Used in method specified in §98.253(c)(4) Provides production or raw

material data described in section 2.1 of Part Two of this memorandum.
Y 

### §98.256(i)(7) For coke calcining: Activity data for calculating emissions (production data). Used in method specified in §98.253(c)(4) Provides production or raw

material data described in section 2.1 of Part Two of this

## 99 Subpart 

### Rule Citation in 40

CFR Part 98 Data Element Description Data Element is used as Input to Equation . . . Analysis Results

memorandum.

Y 

### §98.256(i)(7) For coke calcining: The unit

specific CH 4 emission factor. Used in method specified in §98.253(c)(4) Provides data described in section

2.3 of Part Two of this memorandum that could be used to calculate either production or raw material consumption (depending on whether the facility uses an emission factor based on production throughput or raw material consumption) if the CH4 emissions (as cur rently reported under 40 CFR 98.252(e) and made publicly available) 1 are also known.
Y 

### § 98.256(i)(7) For coke calcining: Units of measure for the unit

- specific CH 4 emission factor. Used in method specified in §98.253(c)(4) Would not reveal any propriet ary

information about facility or process performance, design, and operation; cost to do business; raw material usage; or production. Provides only the units of measure for the emission factor.

Y 

### §98.256(i)(8) For coke calcining: If a unit specific emission factor was used for the N2O factor: report the activity data used for calculating emissions (input or production). Used in method specified in §98.253(c)(5) Provides production or raw

material data described in section 2.1 of Part Two of this

memo randum.

Y 

### §98.256(i)(8) For coke calcining: If a unit

specific emission factor for N2O was used, report the unit

- specific emission factor. Used in method specified in §98.253(c)(5) Provides data described in section

2.3 of Part Two of this memorandum that could be used to calculate either production or raw material consumption (depending on whether the facility uses an emission factor based on production throughput or raw material consumption) if the N2O emissions (as currently reported under 40 CFR 98.252 (e) and made publicly available) 1 are also known.
Y 

### §98.256(i)(8) For coke calcining: If a unit specific emission factor was used for the N2O factor: report the units of measure for the unit

- specific factor . Used in method specified in §98.253(c)(5) Would not reveal any proprietary

information about facility or process performance, design, and operation; cost to do business; raw material usage; or production. Provides only the units of measure for the emission factor.
Y 

### §98.256(j)(2) Quantity of asphalt blown for each asphalt blowing unit. Y

- 14 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.
Y 

### §98.256(j)(2) Quantity of asphalt blown for each asphalt blowing unit. Y

- 15 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.
Y 

### §98.256(j)(2) Quantity of asphalt blown for each asphalt blowing unit. Y

- 16a Provides production or raw material data described in section 2.1 of Part Two of this memorandum.
Y 

### §98.256(j)(2) Quantity of asphalt blown for each asphalt blowing unit. Y

- 16b Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

## 100 Subpart 

### Rule Citation in 40

CFR Part 98 Data Element Description Data Element is used as Input to Equation . . . Analysis Results

Y 

### §98.256(j)(2) Quantity of asphalt blown for each asphalt blowing unit. Y

- 17 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.
Y 

### §98.256(j)(5) CO 2 emission factor for each asphalt blowing unit. Y

- 14 Provides data described in section 2.3 of Part Two of this memorandum that could be u sed to calculate the annual asphalt production if the CO2 emissions (as currently reported under 40 CFR 98.252(f) and made publicly available) 1 are also known.
Y 

### §98.256(j)(6) CH 4 emission factor for each asphalt blowing unit. Y

- 15 Provides data described in section 2.3 of Part Two of this memorandum that could be used to calculate the annual asphalt production if the CH4 emissions (as currently reported under 40 CFR 98.252(f) and made publicly available) 1 are also known.
Y 

### §98.256(j)(7) If Equat ion Y

- 16 is used: report the carbon emission factor. Y

- 16a Provides data described in section 2.3 of Part Two of this memorandum that could be used to calculate the annual asphalt production if the CO2 emissions (as currently reported under 40 CFR 98.252(f) and made publicly available) 1 are also known.
Y 

### §98.256(j)(8) If Equation Y

- 16b is used: report the CO 2 emission factor used. Y

- 16b Provides data described in section 2.3 of Part Two of this memorandum that could be used to calculate the annual asphalt production if both the CO2 emissions (as currently reported under 40 CFR 98.252(f) and made publicly available) 1 and the carbon emission factor “CEFAB” (40 CFR 98.256(j)(8), for which reporting was deferred to 2015) are also known.
Y 

### §98.256(j)(8) If Equation Y

- 16b is used: report the carbon emission factor. Y

- 16b Provides data described in section 2.3 of Part Two of this memorandum that could be used to calculate the annual asphalt production if both the CO2 emissions (as currently reported under 40 CFR 98.252(f) and made publicly available) 1 and the CO2 emission factor “EFAB,CO2” (40 CFR 98.256(j)(8), for which reporting was deferred to 2015) are also known. Additionally, if the uncontrolled emissions represented by the CO2 emission factor “EFAB,CO2” are very low, could estimate annual asphalt production if only this carbon factor and the CO2 emissions are known.
Y 

### §98.256(j)(9) If you use Eq. Y

- 17: CH 4 emission factor. Y

- 17 Provides data described in section 2.3 of Part Two of this memorandum that could be used to calculate the annual asphalt production if the CO2 emissions (as currently reported under 40 CFR 98.252(f) and made publicly

## 101 Subpart 

### Rule Citation in 40

CFR Part 98 Data Element Description Data Element is used as Input to Equation . . . Analysis Results

available) 1 are also known.

Y 

### §98.256(k)(3) For delayed coking units: Dimensions of coke drum or vessel. Y

- 18 Provides data related to process design; process performance, and operation; and/or cost to do business, as described in section 2.2 of Part Two of this memorandum. Specifical ly, could reveal information about the design and operation of the coking unit.
Y 

### §98.256(k)(3) For delayed coking units: Typical gauge pressure of the coking drum when first vented to the atmosphere. Y

- 18 Provides data related to process design; process performance, and operation; and/or cost to do business, as described in section 2.2 of Part Two of this memorandum. Specifically, could reveal information about the design and operation of the coking unit.
Y 

### §98.256(k)(3) For delayed coking units: Typical void fraction of coke drum or vessel. Y

- 18 Provides data related to process design; process performance, and operation; and/or cost to do business, as described in section 2.2 of Part Two of this memorandum. Specifically, could reveal information about t he design and operation of the coking unit.
Y 

### §98.256(k)(3) For delayed coking units: Annual number of coke

cutting cycles of coke drum or vessel. Y

- 18 Provides data related to process design; process performance, and operation; and/or cost to do business, as described in section 2.2 of Part Two of this memorandum. Specifically, could reveal information about the design and operation of the coking unit.
Y 

### §98.256(k)(3) For delayed coking units: report the molar volume conversion factor for each coke drum or vessel. Y

- 18 Would not reveal any proprietary information about facility or process performance, design, and operation; cost to do business; raw material usage; or production. Is a constant value widely known within the industry and publicly

a vailable.
Y 

### §98.256(k)(4) For each set of coking drums that are the same dimensions: Height and diameter of the coke drums. Y

- 18 Provides data related to process design; process performance, and operation; and/or cost to do business, as described in section 2.2 of Part Two of this memorandum. Specifically, could reveal information about the design and operation of the coking unit.
Y 

### §98.256(k)(4) For each set of coking drums that are the same dimensions: Cumulative number of vessel openings for all d elayed coking drums in the set. Y

- 18 Provides data related to process design; process performance, and operation; and/or cost to do business, as described in section 2.2 of Part Two of this memorandum. Specifically, could reveal information about the desig n and operation of the coking unit.

## 102 Subpart 

### Rule Citation in 40

CFR Part 98 Data Element Description Data Element is used as Input to Equation . . . Analysis Results

Y 

### §98.256(k)(4) For each set of coking drums that are the same dimensions: Typical venting pressure. Y

- 18 Provides data related to process design; process performance, and operation; and/or cost to do business, as described in section 2.2 of Part Two of this memorandum. Specifically, could reveal information about the design and operation of the coking unit.
Y 

### §98.256(k)(4) For each set of coking drums that are the same dimensions: Void fraction. Y

- 18 Provides dat a related to process design; process performance, and operation; and/or cost to do business, as described in section 2.2 of Part Two of this memorandum. Specifically, could reveal information about the design and operation of the coking unit.
Y §98.256(k)(4) For delayed coking units: Mole fraction of methane in coking gas. Y

- 18 Provides data described in section 2.3 of Part Two of this memorandum that could be used to calculate various other data related to process design and operation of the cok ing units (e.g., typical void fraction of the coke drum, height and diameter of the coke vessel). For examples this data element could be used to calculate typical void fraction of the coke vessel if the following data are also known: CH4 emissions (as cur rently reported under 40 CFR 98.252(f) and made publicly available) 1

, cumulative number of vessel openings for all delayed coking drums in the set (40 CFR 98.256(k)(4), for which reporting was deferred to 2015), height and diameter of the coking vessel (40 CFR 98.256(k)(4), for which reporting was deferred to 2015), typical venting pressure (40 CFR 98.256(k)(4), for which reporting was deferred to 2015) and the void fraction (40 CFR 98.256(k)(4), for which reporting was deferred to 2015). However, if the cu mulative number of vessel openings for all delayed coking drums in the set were not reported, would not reveal any proprietary information about facility or process performance, design, and operation; cost to do business; raw material usage; or production.
Y 

### § 98.256(l)(5) For each process vent: Molar volume conversion factor. Y

- 19 Would not reveal any proprietary information about facility or process performance, design, and operation; cost to do business; raw material usage; or production. Is a

constant value widely known within the industry and publicly available.

## 103 Subpart 

### Rule Citation in 40

CFR Part 98 Data Element Description Data Element is used as Input to Equation . . . Analysis Results

Y 

### §98.256(m)(3) Uncontrolled blowdown systems reporting under §98.253 (k): CH 4 emission factor used. Y

- 20 Provides data described in section 2.3 of Part Two of this memorandum that could be used to calculate the quantity of crude oil and intermediate products received from offsite if the CO2 emissions (as currently reported under 40 CFR 98.252(g) and made publicly available) 1 are also known.
Y 

### § 98.256(m)(3) Uncontrolled blowdown systems reporting under §98.253 (k): Molar volume conversion factor. Y

- 20 Would not reveal any proprietary information about facility or process performance, design, and operation; cost to do business; raw material usage; or production. Is a constant value widely known within the industry and publicly available.
Y 

### §98.256(m)(3) Uncontrolled blowdown systems reporting under §98.253 (k): Total quantity of crude oil plus the quantity of intermediate products received from off

- site that are processed at the facility in the reporting year. Y

- 20 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

Y §98.256(n)(3) For equipment leaks: Number of each type of emission source listed in Equation Y

21 (if using Eq. Y

- 21). Y

- 21 Would not reveal any proprietary information about facility or process performance, design, and operation; cost to do business; raw material usage; or production. These data (e.g., types of units, number of units) are already generally publicly available i n permits and permit applications, such that these reported data would not reveal any additional information.
Y 

### §98.256(o)(2)(ii) Total quantity of crude oil plus the quantity of intermediate products received from off

- site that are processed at the fac ility in the reporting year. Y

- 22 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

Y 

### §98.256(o)(4)(ii) For storage tanks that process unstabilized crude oil: Quantity of unstabilized crude oil received during the calendar year. Y

- 23 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

Y 

### §98.256(o)(4)(iii) For storage tanks that process unstabilized crude oil: Average pressure differential. Y

- 23 Provides data related to process design; process performance, and operation; and/or cost to do business, as described in section 2.2 of Part Two of this memorandum. Specifically, could reveal the type of crude oil processed, which can provide information regarding the

p roduction process and business

costs. Additionally, provides data described in section 2.3 of Part Two of this memorandum that could be used to calculate the quantity of unstabilized crude oil received if both the average mole fraction of CH4 in the vent g as (40

## 104 Subpart 

### Rule Citation in 40

CFR Part 98 Data Element Description Data Element is used as Input to Equation . . . Analysis Results

CFR 98.252(g), for which reporting was deferred to 2015) and the tank

specific methane composition data (required to be reported under 40 CFR 98.256(o)(4)(vi)) are also known.

Y 

### § 98.256(o)(4)(iv) For storage tanks that process unstabilized crude oil: Molar volume conversion factor. Y

- 23 Would not reveal any proprietary information about facility or process performance, design, and operation; cost to do business; raw material usage; or production. Is a constant value widely known within the industry and publicly available.
Y 

### §98.256(o)(4)(v) For storage tanks that process unstabilized crude oil: Average Mole fraction of CH 4 in vent gas from the unstabilized crude oil storage tanks. Y

- 23 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

Y §98.256(o)(4)(vi) If you did not use Equation
Y

- 23: report the gas generation volume (scf/year) used to estimate cumulative CH4 emissions for storage tanks used to process unstabilized crude oil. Used in methods specified in §98.253(m)(2) Gas generation data in volume per

year would not reveal any proprietary information about facility or process performance, design, and operation; cost to do business; raw material usage; or production.
Y §98.256(o)(4)(vi) If you did not use Equation
Y

- 23: report the tank

- specific methane composition data used to estimate cumulative CH4 emissions for storage tanks used to process unstabilized crude oil. Used in methods specified in §98.253(m)(2) Would not reveal any proprietary

information about facility or process performance, design, and operation; cost to do business; raw material usage; or production.

Y §98.256(o)( 6 ) Mole fraction of CH 4 in vent gas from the unstabilized crude oil storage tank. Y

- 23 See analysis for 40 CFR 98.256(o)(4)(v).

Y §98.256(o)(6) Average pressure differential. Y

- 23 See analysis for 40 CFR 98.256(o)(4)( iii ).

Y §98.256(o)(6) Quantity of unstabilized crude oil received during the calendar year. Y

- 23 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

## 105 Subpart 

### Rule Citation in 40

CFR Part 98 Data Element Description Data Element is used as Input to Equation . . . Analysis Results

Y §98.256(o)( 7 ) Tank

- specific methane composition data. Used in methods specified in §98.253(m)(2) See analysis for 40 CFR

98.256(o)(4)(v i ).

Y §98.256(o)( 7 ) Gas generation rate data. Used in methods specified in §98.253(m)(2) See analysis for 40 CFR

98.256(o)(4)(v i ).

Y 

### §98.256(p)(2) For loading operations: Quantity of materials loaded by vessel type that have an equilibrium vapor

- phase concentration of CH 4 of 0.5 volume percent or greater. Used in methods specified in AP

42, Section 5.2 (referenced by §98.253(n)) Provides production or raw

material data described in section 2.1 of Part Two of this memorandum.

Z 

### §98.266(f)(5) Monthly inorganic carbon content of phosphate rock for each wet

- process phosphoric acid process line for which Equation Z

- 1a is used (percent by weight, expressed as decimal fraction) (No CEMS). Z

- 1a Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

Z 

### §98.266(f)(5) Monthly CO 2 (ton CO 2 /ton of phosphate rock) for which Equation Z

- 1b is used (No CEMS). Z

- 1b Provides data described in section 2.3 of Part Two of this memorandum that could be used to calculate the amount of phosphate rock consumed if the N2O emissions (as currently reported under 40 CFR 98.3(c)(4) and made publicly available) 1 are also known.
Z 

### §98.266(f)(6) Monthly mass of phosphate rock consumed by origin in production. Z

- 1a Provides production or raw material data described in section 2.1 of Part Two of this memorandum.
Z 

### §98.266(f)(6) Monthly mass of phosphate rock consumed by origin in production. Z

- 1b Provides production or raw material data described in section 2.1 of Part Two of this memorandum.
AA 

### §98.276(b) Annual quantities of fossil fuels used in chemical recovery furnaces. C

- 1 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.
AA 

### §98.276(b) Annual quantities of fossil fuels used in chemical recovery furnaces. C

- 1a Provides production or raw material data described in section 2.1 of Part Two of this memorandum.
AA 

### §98.276(b) Annual quantities of fossil fuels used in chemical recovery furnaces. C

- 1b Provides production or raw material data described in section 2.1 of Part Two of this memorandum.
AA 

### §98.276(b) Annual quantities of fossil fuels used in chemical recovery furnaces. C

- 2a Provides production or raw material data described in section 2.1 of Part Two of this memorandum.
AA 

### §98.276(b) Annual quantities of fossil fuels used in chemical recovery furnaces. C

- 3 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.
AA 

### §98.276(b) Annual quantities of fossil fuels used in chemical recovery combustion units. C

- 4 Provides production or raw material data described in section 2.1 of Part Two of this

## 106 Subpart 

### Rule Citation in 40

CFR Part 98 Data Element Description Data Element is used as Input to Equation . . . Analysis Results

memorandum.

AA 

### §98.276(b) Annual quantities of fossil fuels used in chemical recovery combustion units. C

- 5 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.
AA 

### §98.276(b) Annual quantities of fossil fuels used in chemical recovery combust ion units. C

- 8 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.
AA 

### §98.276(b) Annual quantities of fossil fuels used in chemical recovery combustion units. C

- 8a Provides production or raw material data described in section 2.1 of Part Two of this memorandum.
AA 

### §98.276(b) Annual quantities of fossil fuels used in chemical recovery combustion units. C

- 8b Provides production or raw material data described in section 2.1 of Part Two of this memorandum.
AA 

### §98.276(b) Annual quantities of fossil fuels used in chemical recovery combustion units. C

- 9a Provides production or raw material data described in section 2.1 of Part Two of this memorandum.
AA 

### §98.276(c) Annual mass of the spent liquor solids combus ted. AA

- 1 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.
AA 

### §98.276(c) Annual mass of the spent liquor solids combusted. AA

- 2 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.
AA 

### §98.276(d) High heat value (HHV) of the spent liquor solids used in Equation AA

- 1. AA

- 1 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.
AA §98.276(e) Default emission factor for CO 2 used in equation AA

- 1. AA

- 1 Provides data described in section 2.3 of Part Two of this memorandum that could be used to calculate the mass of spent liquor solids combusted if the following data are also known: CO2 emissions (as currently reported under 40 CFR 98.3(c)(4) and made publicly available) 1 and HHV (40 CFR 98.276(d), for which reporting was deferred to 2015). However, if the HHV were not reported, would not reveal any proprietary information about facility or process performance, design, and operation; cost to do business; raw material usage ; or production.
AA §98.276(e) Default emission factor for CH 4 used in equation AA

- 1. AA

- 1 Provides data described in section 2.3 of Part Two of this memorandum that could be used to calculate the mass of spent liquor solids combusted if the following data are also known: CH4 emissions (as currently reported under 40 CFR 98.3(c)(4) and made publ icly available) 1 and HHV (40 CFR 98.276(d), for which reporting was deferred to 2015). However, if the HHV were not reported, would not reveal any proprietary

## 107 Subpart 

### Rule Citation in 40

CFR Part 98 Data Element Description Data Element is used as Input to Equation . . . Analysis Results

information about facility or process performance, design, and operation; cost to do business; r aw material usage; or production.

AA §98.276(e) Default emission factor for
N 2 O used in equation AA

- 1. AA

- 1 Provides data described in section 2.3 of Part Two of this memorandum that could be used to calculate the mass of spent liquor solids combusted if the following data are also known: N2O emissions (as currently reported under 40 CFR 98.3(c)(4) and made publ icly available) 1 and HHV (40 CFR 98.276(d), for which reporting was deferred to 2015). However, if the HHV were not reported, would not reveal any proprietary information about facility or process performance, design, and operation; cost to do business; r aw material usage; or production.
AA 

### §98.276(f) Carbon content of the spent liquor solids used in Equation AA

- 2. AA

- 2 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.
AA 

### §98.276(g) Annual quantities of fossil fuels used in pulp mill lime kilns. C

- 1 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.
AA 

### §98.276(g) Annual quantities of fossil fuels used in pulp mill lime kilns. C

- 1a Provides production or raw material data described in section 2.1 of Part Two of this memorandum.
AA 

### §98.276(g) Annual quantities of fossil fuels used in pulp mill lime kilns. C

- 1b Provides production or raw material data described in section 2.1 of Part Two of this memorandum.
AA 

### §98.276(g) Annual quantities of fossil fuels used in pulp mill lime kilns. C

- 2a Provides production or raw material data described in section 2.1 of Part Two of this memorandum.
AA 

### §98.276(g) Annual quantities of fossil fuels used in pulp mill lime kilns. C

- 3 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.
AA 

### §98.276(g) Annual quantities of fossil fuels used in pulp mill lime kilns. C

- 4 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.
AA 

### §98.276(g) Annual quantities of fossil fuels used in pulp mill lime kilns. C

- 5 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.
AA 

### §98.276(g) Annual quantities of fossil fuels used in pulp mill lime kilns. C

- 8 Provides production or raw material data described in section 2.1 of Part Two of this

## 108 Subpart 

### Rule Citation in 40

CFR Part 98 Data Element Description Data Element is used as Input to Equation . . . Analysis Results

memorandum.

AA 

### §98.276(g) Annual quantities of fossil fuels used in pulp mill lime kilns. C

- 8a Provides production or r aw material data described in section 2.1 of Part Two of this memorandum.
AA 

### §98.276(g) Annual quantities of fossil fuels used in pulp mill lime kilns. C

- 8b Provides production or raw material data described in section 2.1 of Part Two of this memorandum.
AA 

### §98.276(g) Annual quantities of fossil fuels used in pulp mill lime kilns. C

- 9a Provides production or raw material data described in section 2.1 of Part Two of this memorandum.
AA 

### §98.276(h) Make

- up quantity of CaCO 3 used for the reporting year used in Equation AA

- 3. AA

- 3 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.
AA 

### §98.276(i) Make

- up quantity of Na 2 CO 3 used for the reporting year used in Equation AA

- 3. AA

- 3 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.
BB 

### §98.286(b)(1) Monthly consumption of petroleum coke (No CEMS). BB

- 2 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.
BB 

### §98.286(b)(4) Carbon content factor of petroleum coke from the supplier or as measured by the applicable method. BB

- 1 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.
BB 

### §98.286(b)(6) CO2 e missions factor for each month. BB

- 2 Provides data described in section 2.3 of Part Two of this memorandum that could be used to estimate the amount of petroleum coke consumed if the CO2 emissions (as currently reported under 40 CFR 98.3(c)(4) and made publicly available) 1 are also known.
C C 

### §98.296(b)(5) Monthly consumption of

trona or liquid alkaline feedstock for each manufacturing line (No CEMS) (for facilities using Equation CC

- 1). CC

- 1 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

CC 

### §98.296(b)(6) Monthly production of soda ash for each manufacturing line (tons) (for facilities using Equation CC

- 2). CC

- 2 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.
CC 

### §98.296(b)(7) Inorganic carbon content factor of soda ash. CC

- 2 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.
CC 

### §98.296(b)(7) Inorganic carbon content factor of trona . CC

- 1 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.
CC §98.296(b)(10)(i) Stack gas volumetric flow rate during performance test (dscfm) for each manufacturing line or stack. CC

- 3 Provides information about the exhaust gas flow rate during the performance test and would not reveal any proprietary information about facility or process performance, design, and operation; cost to do business; raw

## 109 Subpart 

### Rule Citation in 40

CFR Part 98 Data Element Description Data Element is used as Input to Equation . . . Analysis Results

material usage; or production.

CC §98 .296(b)(10)(ii) Hourly CO 2 concentration during performance test (percent CO 2 ) for each manufacturing line or stack. CC

- 3 Provides information about the CO2 concentration in exhaust gas stream measured during the performance test and §98.would not reveal a ny proprietary information about facility or process performance, design, and operation; cost to do business; raw material usage; or production.
CC §98.296(b)(10)(iii) CO 2 emission factor of process vent flow from mine water for each manufacturing line or stack. CC

- 5 Does not include, and could not be used to calculate, data or information (about facility or process performance, design, and operation; cost to do business; r aw material usage; or production) that would reveal information that could cause competitive harm.
CC §98.296(b)(10)(iv) CO 2 emission mass emission rate during performance test (metric tons/hour) for each manufacturing line or stack. CC

- 4 Would not reveal any proprietary information about facility or process performance, design, and operation; cost to do business; raw material usage; or production. Data cannot be used to calculate the annual production or raw material consumption since the production and raw material usage during the performance test is not reported.
CC §98.296(b)(10)(v) Average process vent flow from mine water stripper/evaporator during performance test for each manufacturing line or stack. CC

- 4 Would not reveal any proprietary information about facility or process performance, design, and operation; cost to do business; raw material usage; or production. Data cannot be used to calculate annual production or raw material consumption since the prod uction rate and raw material consumption during the performance test is not reported.
CC §98.296(b)(10)(vi) Annual process vent flow rate from mine stripper/evaporator for each manufacturing line or stack. CC

- 5 Would not reveal any proprietary information about facility or process performance, design, and operation; cost to do business; raw material usage; or production. Data cannot be used to calculate annual production or raw material consumption since the production rate and raw material consumption during the performance test is not reported.

EE 

### §98.316(b)(6) Monthly calcined petroleum coke consumption for each production line (No CEMS). EE

- 2 Provides production or raw material data described in section 2 .1 of Part Two of this memorandum.
EE 

### §98.316(b)(9) Monthly carbon content factor of petroleum coke (percent by weight expressed as a decimal fraction) (No CEMS). EE

- 2 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

## 110 Subpart 

### Rule Citation in 40

CFR Part 98 Data Element Description Data Element is used as Input to Equation . . . Analysis Results
GG 

### §98.336(b)(6) Annual mass of each carbon

containing input material charged to each kiln or furnace (No CEMS)

- Mass of zinc bearing material. GG

- 1 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

GG 

### §98.336(b)(6) Annual mass of each carbon

containing input material charged to each kiln or furnace (No CEMS)

- Annual mass of flux materials (e.g., limestone, dolomite) charged to kiln or furnace “k” (tons). GG

- 1 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

GG 

### §98.336(b)(6) Annual mass of each carbon

containing input material charged to each kiln or furnace (No CEMS)

- Annual mass of carbon electrode consumed in furnace “k”. GG

- 1 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

GG 

### §98.336(b)(6) Annual mass of each carbon

containing input material charged to each kiln or furnace (No CEMS)

- Annual mass of other carbonaceous material consumed in furnace “k”. GG

- 1 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

GG 

### §98.336(b)(7) Carbon content of carbon

containing input materials charged to kilns or furnace (including zinc bearing material, flux materials, and other carbonaceous materials) from the annual carbon analysis or from information provided by the material supplier) for each kiln or furnace (percent by weight, expressed as a decimal fraction) (No CEMS)

- zinc bearing material. GG

- 1 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

GG 

### §98.336(b)(7) Carbon content of carbon

containing input materials charged to kilns or furnace (including zinc bearing material, flux materials, and other carbonaceous materials) from the annual carbon analysis or from information provided by the material supplier) for each kiln or furnace (percent by weight, expressed as a decimal fraction) (No CEMS)

- flux materials. GG

- 1 Provides production or raw materia l data described in section 2.1 of Part Two of this memorandum.

GG 

### §98.336(b)(7) Carbon content of carbon

containing input materials charged to kilns or furnace (including zinc bearing material, flux materials, and other carbonaceous materials) from the a nnual carbon analysis or from information provided by the material supplier) for each kiln or furnace (percent by weight, expressed as a decimal GG

- 1 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

## 111 Subpart 

### Rule Citation in 40

CFR Part 98 Data Element Description Data Element is used as Input to Equation . . . Analysis Results fraction) (No CEMS)

- other carbonaceous materials.

GG 

### §98.336(b)(10) Carbon content of the carbon electrodes used in each furnace from the annual carbon analysis or from information provided by the material supplier) (percent by weight, expressed as a decimal fr action) (No CEMS). GG

- 1 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

II §98.356(d)(2) Cumulative volumetric biogas flow for each week that biogas is collected for destruction (if using weekly sampling). II

- 4 Would not reveal any proprietary information about facility or process performance, design, and operation; cost to do business; raw material usage; or production.
II §98.356(d)(3) Weekly average CH4 concentration for each week that biogas is collected for destruction (if using weekly sampling). II

- 4 Would not reveal any proprietary information about facility or process performance, design, and operation; cost to do business; raw material usage; or production.
II §98.356(d)(4) Weekly average temperature at which flow is measured for biogas collected for destruction (if using weekly sampling). II

- 4 Would not reveal any proprietary information about facility or process performance, design, and operation; cost to do business; raw material usage; or production.
II §98.356(d)(5) Weekly average moisture content for each week at which flow is measured fo r biogas collected for destruction (if using weekly sampling). II

- 4 Would not reveal any proprietary information about facility or process performance, design, and operation; cost to do business; raw material usage; or production.

II §98.356(d)(6) Weekly average pressure for each week at which flow is measured for biogas collected for destruction (if using weekly sampling). II

- 4 Would not reveal any proprietary information about facility or process performance, design, and operation; cost to do business; raw material usage; or production.
TT 

### §98.466(c)(3)(i) Total number of years (N) for which disposal and production data are b oth available. TT

- 2 Provides data described in section 2.3 of Part Two of this memorandum that could be used to estimate either production quantities or raw material consumption if both the quantity of waste disposed in the landfill (reported under 40 CFR 98.466(c)(3)(ii) and (d)(2)) and

average waste disposal factor ( reported under 40 CFR 98.466(c)(3)(i i i )) are also known.

## 112 Subpart 

### Rule Citation in 40

CFR Part 98 Data Element Description Data Element is used as Input to Equation . . . Analysis Results

TT 

### §98.466(c)(3)(ii) The waste disposal quantity for each year used in Equation TT

– 2 of this subpart to calculate the average waste disposal factor (WDF). TT

- 2 Would not reveal any proprietary information about facility or process performance, design, and operation; cost to do business; raw material usage; or production. The amount of waste disposed of in the landfill (40 CFR 98.466(d )(2), which is identical to this input, for which reporting was deferred to 2013) is reported and publicly released.
TT 

### §98.466(c)(3)(ii) Quantity of product produced or feedstock entering the process or facility in year from measurement data and/or other company records (production units). You must use the same basis for all years in the calculation (i.e., based on production or based on quantity of feedstock) TT

- 2 and TT

- 3 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

TT 

### §98.466(c)(3)(iii) Average waste disposal factor (WDF) calculated for the

waste stream. TT

- 3 Provides data described in section 2.3 of Part Two of this memorandum that could be used to estimate either production quantities or raw material consumption given that the amount of waste disposed of in the landfill (40 CFR 98.466(d)(2) ) is currently

repo rted and publicly available

. 1 In the May 26, 2011 final CBI determination notice ( 76 FR 30782 ) , EPA grouped the direct

- emitter data reporting elements into 11 data categories and assigned CBI determinations on either a category or individual data elements basis. One of the categories established was “Emissions,” which contains all data elements tha t are emission values required to be reported by direct emitters under Part 98 (e.g., annual CO2e emissions, emissions by GHG and source category, emissions by GHG pollutant). All data elements within this category were determined to be “emission data,” wh ich under CAA section 114(c) are not entitled to confidential treatment. As a result, data elements that have been assigned to the “Emissions” category (refer to the final CBI rulemakings: May 26, 2011, 76 FR 30782; August 13, 2012, 77 FR 48072; August 24, 2012, 77 FR 51477) are made publicly available on the Greenhouse Gas Reporting Program website."