1 

MEMORANDUM 

DATE: September 2014 

TO: Docket EPA-HQ-OAR-2010-0929 

FROM: Lisa Grogan-McCulloch

SUBJECT: Final Evaluation of Competitive Harm from Disclosure of “Inputs to 

Equations” Data Elements 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 53057) (hereafter referred to as “‘inputs 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). 

The EPA documented the results 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 27 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. 

The 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 structures such that the release of the data could 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, the 

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 could result in competitive harm, an evaluation 

of each individual “inputs to equations” data elements 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 proceeded to evaluate each individual “inputs 

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 sections 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 cause 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 Importance 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 individual firms have over the prices they obtain for their 

products. 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 price 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 competitors’ 

operations. Markets with a relatively small 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 their level of 

concentration. 

3.0 Process 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 include 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 = Σisi

2 , where si = the market share of the ith firm. 

Potential values of the HHI range from near zero (if each of the top 50 firms has one-50th of 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 identify markets where there are potential anti-trust 

concerns. 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. The 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 

decisions for specific products or services. While identifying a concentrated or moderately 

concentrated NAICS is sufficient to identify subparts in which facilities are aware of their 

competitors, and thus subparts for which revealing sensitive information would 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. Some sectors 

(defined at the 6-digit NAICS code level) that are not concentrated 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, some NAICS may include multiple industry 

sectors, only one of which is 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 may 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 the 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 determined whether a majority of the facilities reported 

concentrated or moderately concentrated NAICS. 

3. If all the national NAICS associated with a subpart are unconcentrated, or a majority of 

facilities report under unconcentrated NAICS, the EPA determined whether: 

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

b. The 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 market 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 “inputs to equations” 

data elements for the subpart would be minimal. If the EPA found that any of the above criteria 

is true for a subpart, the EPA determined that the market is concentrated, such that the firms 

subject to the subpart are likely able to identify their competitors. For each such subpart, the EPA 

proceeded to evaluate each “inputs to equations” data element within the 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 assessed, 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 sectors that did not have manufacturing NAICS codes, subparts W (Petroleum and Natural 

Gas Systems) and CC (Soda Ash), 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 sector NAICS codes, 

for which HHI information is compiled by the Census Bureau. Subparts CC and W5 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 non-manufacturing Sectors (i.e., subparts W and CC). 

4.1 Analysis of Concentration at the National Sector (NAICS-Code) Level 

To begin its assessment of the potential for the release of the “inputs 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 identified each NAICS. This information allowed the EPA to identify which NAICS 

codes within a subpart represent the majority of reporting facilities.6 

 At the subpart level, the EPA considered a subpart to be associated with concentrated or 

moderately concentrated markets if a majority of the firms reporting under that subpart identified 

themselves with NAICS codes that are concentrated or moderately concentrated. Recognizing 

that it is actually the market or the sector that is concentrated, for convenience throughout the 

rest of this document, the EPA refers 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 occur. Refer to the Part 2 of this 

memorandum for this evaluation. 

4.2 Analysis of Concentration 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 analysis. The 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 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. 
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 

Other Basic Inorganic Chemical Manufacturing. This is a very broad NAICS code, 

encompassing production of many different inorganic chemicals; adipic acid production is a 

small subset of the overall NAICS. Thus, the EPA examined adipic acid producers specifically, 

rather than relying on a NAICS-level assessment. Three facilities reported under subpart E for 

reporting year 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 further evaluated the “inputs to equations” data elements in subpart 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 firms. In previous analyses supporting the EPA rulemaking, 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 example, this analysis identified 20 regional markets for gray 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’ 

identity 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 market results in an HHI of 3,267 (3 x 332

). 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 markets that exist 

within this source category warrants 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 2010 Statistics of U.S. Businesses,11 there are 19 firms 

nationwide that produce ferroalloys. Of the 10 firms reporting 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 competitors. 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 

concentrated. As a result, the EPA concluded that the structure of the market that exists within 

this source category warrants 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. Most hydrogen is produced at petroleum refineries and 

ammonia production facilities, generally for captive use. Because these sectors are considered at 

least moderately concentrated (see discussion for subpart Y, below), we concluded that the 

structure of the markets that exist within this source category warrants further evaluation 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 scale, 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 associated 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. Nationally, 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 codes. For 

the reasons mentioned above, the national NAICS-level assessment may be misleading. Some 

steel products are homogeneous and are traded in regional 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 levels, 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 oxygen 

furnaces (BOFs). The EPA constructed HHI values using these production data, disaggregating 

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 

exists within this source category warrants 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 Refining. 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 smelters 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 warrants 

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://www.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 warrants further evaluation of the “inputs 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 evaluation. 

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 large-scale operation or they would 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 was 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 Commission15 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 refineries 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 processes at 95 different facilities owned 

by 63 different firms. To better characterize the petroleum market, the EPA analyzed these 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/processes 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 

products/processes captured in the DOE data, seven are at least moderately concentrated. 

Because the petroleum refinery industry 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 warrants further evaluation 

of the “inputs 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 for this evaluation.

4.3 Analysis of Subparts Representing Processes from 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 source 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 possible 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 the 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 the 6-digit NAICS code provided, and 

because many 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 computed for these subparts is provided, 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 shows that some of the affected markets for goods produced by facilities in each 

of these subparts 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 market structure 

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 evaluate 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 

Reports of 

NAICS with 

HHIsa,b

# of Facility 

Reports of 

NAICS with At 

Least 

Moderately 

Concentrated 

HHIsa

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 

aThe 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 Analysis of Non-Manufacturing Sectors 

As shown in Appendix A, HHIs were not available for subpart W17 (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. 

Subpart W: Petroleum 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 facility 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 regional, product, or process level. 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 development 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 production 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 this 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 large 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 wildcat 

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 workover (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 fracturing, 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 

represent volumes of wildcat wells and/or exploratory wells exclusively, which could 

reveal information on the productivity of the well.

Delaying reporting of these data for two reporting years would be sufficient time for 

reporters to thoroughly conduct an assessment 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, disclosure 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 earlier, 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 

delivered 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 information 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 roughly 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 equation” 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 

pipeline 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 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. 

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 regulated, 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 segment, 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 regional; 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 in 

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 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. 

Liquefied Natural Gas Storage 

Liquefied natural gas (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 

upstream 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 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 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 import terminals located along the Gulf and East Coasts. 

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 import/export is identical to the product generated in 

onshore and offshore natural gas production. Functionally, import and export terminals may 

be considered as a large producer or consumer of natural gas. Import and export 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 market 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 of the industry segments within subpart 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 markets in 

which the affected firms operate are structured in ways that disclosure of “inputs to equations” 

data elements would not be likely to cause competitive harm. For the wildcat wells and 

delineation wells, in the specific cases described above, early public disclosure of seven “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 information, 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 subpart W. 

Subpart CC: Soda Ash. The four facilities reporting under subpart CC in 2011 identified 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 with relatively large market share (as opposed 

to a sector where all firms are similar in size, and each has roughly 1/18 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 warrants 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 structure such that release of 

these data could result in competitive harm. The EPA 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 reporting under subpart 

W. For the “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 this memorandum for this evaluation. 
19 

Part Two: Evaluation of Individual Data Elements 

1.0 Introduction 

As discussed in Part 1 of this memorandum, the EPA 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. The EPA further evaluated the remaining “inputs to equations” data elements in 

26 subparts by examining individual data elements to determine if harm would be likely to occur. 

2.0 Evaluation of Harm 

Based on the EPA’s previous 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 identified 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 operation, 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, would 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 element 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 results of the analysis for each of the 493 data elements. 

2.1 Quantity and Composition of Raw Materials or Products 

The EPA has 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 these previous actions, the EPA finalized CBI determinations for such data 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, disclosing a 

facility’s production or throughput data would 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 insight into 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 locations; and 

• Disclosing 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 strategies, or 

reveal a firm’s suppliers and sourcing strategies. 

Refer to the preamble to the proposed CBI determinations (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 attributes 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 requirement to report the quantity or composition of raw 

materials or 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 has determined that data related to process 

design, process performance and operation, and cost to do business would reveal the following 

information: 

• Disclosing process design information could be detrimental to a firm’s competitiveness 

by revealing the design efficiency of the unit, providing insight into the firm’s 

operational strengths and weaknesses (e.g., disclosing the ratio of the maximum rate heat 

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 process performance and operation information could be detrimental to a 

firm’s competitiveness by revealing process efficiency, providing insight into a firm’s 
21 

operational strengths and weaknesses (e.g., disclosing an aluminum production facility’s 

cell performance would disclose current production efficiency);and 

• Disclosing information related to the cost to do business could be detrimental to a firm’s 

competitiveness by providing insight into a firm’s operational strengths and weaknesses 

(e.g., disclosing an HCFC production facility’s loss factor, which accounts for the loss 

of HCFC-22 upstream of a measurement, would reveal the amount of product that is 

lost). 

Data elements determined to include a requirement to report the type of information described 

above are identified in Appendix B. 

2.3 Other Data That Would Likely Reveal the Types of Data Specified Above If 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 materials 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 N2O 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 proprietary information in this way are 

identified in Appendix B. 

For any such data elements identified, the EPA also determined if such harm could be avoided 

by removing the reporting requirement for certain additional data elements. For example, if the 

abatement utilization factor were reported (as required under §98.56(h)), together with annual 

N2O 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 results of Part 1 and Part 2 of this memorandum, the EPA proceeded to Step 3 of 

the evaluation for 2519 of the 27 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 moderately 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 from 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 fuelfired 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. 

 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 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 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 fuelfired 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 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 at least one 

combustion unit 

connected to a fuelfired 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 continuously 

monitor CO2 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 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 

memorandum. 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 than 1 

megawatt (MW) 

electric output and 

containing at least one 

combustion unit 

connected to a fuelfired 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)(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, C1b, C-8, C-8a, 

C-8b; C-2a, C2b, 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 fuelfired 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)(C) High heat values used in the 

CO2 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 

average value for the month. 

C-2a, C-2b, C9a 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 fuelfired 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: 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 information 

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 fuelfired 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 fuelfired 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 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 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. 
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 fuelfired 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 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 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 fuelfired 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 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, indicates 

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 fuelfired 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. 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 fuelfired 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 (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 fuelfired 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 CO2 is determined 

according to §98.33(e)(2), 

report the carbon-based Ffactor 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 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 fuelfired 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 CO2 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; 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. 
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 fuelfired 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 CO2 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 produce 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 fuelfired 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 performance, design, and 

operation; cost to do business; raw 

material usage; or production. Sitespecific fuel characteristics for 

these units do not vary significantly 

from publicly-known average 

values. For facilities with these 

combustion units, certain fuel use 

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 customers. 
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 fuelfired 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 facility or 

process performance, design, and 

operation; cost to do business; raw 

material usage; or production. Sitespecific fuel characteristics for 

these units 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 fuelfired 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 continuously 

monitor CO2 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 each 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. Sitespecific fuel characteristics do not 

vary significantly from publiclyknown 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 fuelfired 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)(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, C1b, C-8, C-8a, 

C-8b; C-2a, C2b, 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 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 total generator 

capacity greater than 1 

megawatt (MW) 

electric output and 

containing at least one 

combustion unit 

connected to a fuelfired 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)(C) High heat values used in the 

CO2 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 

average value for the month. 

C-2a, C-2b, C9a Would not reveal any proprietary 

information about facility or 

process performance, design, and 

operation; cost to do business; raw 

material usage; or production. Sitespecific fuel characteristics do not 

vary significantly from publiclyknown 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. 
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 fuelfired 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 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 typically 

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 fuelfired 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: 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 manufacturers 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 

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 fuelfired 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)(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-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 total generator 

capacity greater than 1 

megawatt (MW) 

electric output and 

containing at least one 

combustion unit 

connected to a fuelfired 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)(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 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. 
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 fuelfired 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 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) 

Would not reveal any proprietary 

information about facility or 

process performance, design, and 

operation; cost to do business; raw 

material usage; or production. Sitespecific fuel characteristics do not 

vary significantly from publiclyknown 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 fuelfired 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) 

Would not reveal any proprietary 

information about facility or 

process performance, design, and 

operation; cost to do business; raw 

material usage; or production. Sitespecific fuel characteristics do not 

vary significantly from publiclyknown 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. 
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 least one 

combustion unit 

connected to a fuelfired 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 

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. Sitespecific fuel characteristics do not 

vary significantly from publiclyknown 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 fuelfired 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 CO2 is determined 

according to §98.33(e)(2), 

report the carbon-based Ffactor 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 

material usage; or production. Sitespecific fuel characteristics do not 

vary significantly from publiclyknown 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 fuelfired 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 CO2 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 

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 

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. Sitespecific fuel characteristics do not 

vary significantly from publiclyknown 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 fuelfired 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 CO2 is determined 

according to §98.33(e)(2), 

report the total 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 

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. Sitespecific fuel characteristics do not 

vary significantly from publiclyknown 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” 

(Pz ). 

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 
55 

Subpart 

Rule Citation in 40 

CFR Part 98 Data Element Description 

Data Element 

is used as 

Input to 

Equation . . . Analysis Results 

2.1 of Part Two of this 

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 N2O 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 proprietary 

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 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(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 

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 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. 
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 reported 

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 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(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 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 

(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 factor 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 

under 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) N2O 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 

production. 
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 

concentration 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 any 

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 

concentration 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 

(percent of total emissions 

from the production unit that 

are sent to the abatement 

technology) if equation E-3c 

is used. (FCN) 

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), 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 
60 

Subpart 

Rule Citation in 40 

CFR Part 98 Data Element Description 

Data Element 

is used as 

Input to 

Equation . . . Analysis Results 

operation; cost to do business; raw 

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 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) 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 reported 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 

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 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 

emissions (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 aluminum 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 performance, 

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 

memorandum. 

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 noncalcined 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 noncalcined MgO in clinker. H-3 Provides production or raw 

material data described in section 
64 

Subpart 

Rule Citation in 40 

CFR Part 98 Data Element Description 

Data Element 

is used as 

Input to 

Equation . . . Analysis Results 

2.1 of Part Two of this 

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 noncalcined 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 noncalcined 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 

CO2 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 

CO2 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 kilnspecific 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 about 

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 business; 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 

CO2 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 

CO2 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 

CO2 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 

CO2 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 

CO2 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 

CO2 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 

CO2 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 

CO2 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 

CO2 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 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 

CO2 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) Annual average of the carbon 

content determinations for 

each material included for the 

calculation of annual process 

CO2 emissions (No CEMS): 

Cnon-product outgoingl= 

Carbon content in nonproduct outgoing material l 

(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. 
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, 

expressed 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 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-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 

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
69 

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 each fluorinecontaining 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 fluorinecontaining 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 fluorinecontaining 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 fluorinecontaining 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 fluorinecontaining reactant that is 

removed from the process and 

fed into the destruction 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 fluorinecontaining 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 

memorandum 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(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. 

(FEP) 

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 byproduct (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 consists of each 

fluorine-containing byproduct. (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 byproduct. (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, processvent-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 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, processvent-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, processvent-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, processvent-specific emission 

factor(s) for each process vent 

(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 to 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, processvent-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, processvent-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 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, processvent-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, processvent-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 to 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) and (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 

memorandum 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 Part 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 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). 

(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 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

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 described 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 destruction 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. (RED) 

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 into 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 carbonatebased 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 

carbonate-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, 

indicates 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 (G23 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 (S23 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 

(OD23 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 I23, 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 I23, 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 O9). 

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 O9). 

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 HFC23 fed into the destruction 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 deferred 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 destruction 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 
77 

Subpart 

Rule Citation in 40 

CFR Part 98 Data Element Description 

Data Element 

is used as 

Input to 

Equation . . . Analysis Results 

operation; cost to do business; raw 

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 HCFC22 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, this 

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 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): 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 Two 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. 
78 

Subpart 

Rule Citation in 40 

CFR Part 98 Data Element Description 

Data Element 

is used as 

Input to 

Equation . . . Analysis Results 

P §98.166(b)(6) Monthly analyses of the 

molecular weight of gaseous 

fuels and feedstocks. 

P-1 Provides production or raw 

material data described in section 

2.1 of Part Two of this 

memorandum. 

Q §98.176(b) Annual production quantity 

(in metric tons) for taconite 

pellets, coke, sinter, iron, and 

raw steel 

Calculation 

method 

specified in 

98.173(b)(2)(iv

) for the sitespecific 

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 CO2 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 CO2 emissions (No 

CEMS) -gaseous fuel 

combusted(Cgf). 

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 CO2 emissions (No 

CEMS)- liquid fuel 

combusted (Clf). 

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 CO2 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 CO2 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 CO2 emissions (No 

CEMS)- Iron (Ciron) 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 CO2 emissions (No 

CEMS)- Scrap (Cscrap). 

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 CO2 emissions (No 

CEMS)- Flux (Cflux). 

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 

Q §98.176(e)(1) Carbon content of each 

process input used to 

determine CO2 emissions (No 

CEMS)- Carbonaceous 

material (Ccarbon). 

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 CO2 emissions (No 

CEMS) - Steel produced 

(Csteel). 

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 CO2 emissions (No 

CEMS) - Slag produced 

(Cslag). 

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 CO2 emissions (No 

CEMS) - Air pollution 

control residue collected (CR) 

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 CO2 emissions (No 

CEMS)- Coal charged to coke 

battery (Ccoal) 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 CO2 emissions (No 

CEMS) - Coke produced by 

coke battery (Ccoke). 

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 CO2 emissions (No 

CEMS) - Air pollution 

control residue collected from 

coke battery (CR) 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)(1) Carbon content of each 

process input used to 

determine CO2 emissions (No 

CEMS)- Gaseous fuel 

combusted in the sinter 

process (Cgf). 

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 CO2 emissions (No 

CEMS) - sinter feed (CFeed) 

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 CO2 emissions (No 

CEMS) - sinter (CSinter). 

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 CO2 emissions (No 

CEMS) - Air pollution 

control residue collected from 

sinter process (CR) and other 

process outputs. 

Q-4 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 

Q §98.176(e)(1) Carbon content of each 

process input used to 

determine CO2 emissions (No 

CEMS)- Gaseous fuel 

(Cgf).and Iron (Ciron) 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 CO2 emissions (No 

CEMS)- Scrap (Cscrap) 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 CO2 emissions (No 

CEMS)- Flux (Cflux) 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 CO2 emissions (No 

CEMS)- Carbonaceous 

material (Ccarbon) 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 CO2 emissions (No 

CEMS)- Electrode consumed 

in EAF (Celectrode) 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 CO2 emissions (No 

CEMS) - Steel produced 

(Csteel) 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 CO2 emissions (No 

CEMS) - Slag produced 

(Cslag) 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 CO2 emissions (No 

CEMS) - Air pollution 

control residue collected (CR) 

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 CO2 emissions (No 

CEMS) - molten steel before 

decarburization (Ctsteelin) 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 CO2 emissions (No 

CEMS) - molten steel after 

decarburization (Csteelout) 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 CO2 emissions (No 

CEMS) - Air pollution 

control residue collected (CR) 

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 CO2 emissions (No 

CEMS) - Gaseous fuel 

combusted in the direct 

reduction furnace (Fg) . 

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 CO2 emissions (No 

CEMS) - iron ore or iron ore 

pellets fed into the direct 

reduction furnace (Core) . 

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 CO2 emissions (No 

CEMS)- Carbonaceous 

material (Ccarbon) 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 CO2 emissions (No 

CEMS) - Other materials 

charged to the direct 

reduction furnace (Cother). 

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 CO2 emissions (No 

CEMS) - Iron produced from 

direct reduction furnace 

(Ciron). 

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 CO2 emissions (No 

CEMS) - Non-metallic 

materials produced from 

direct reduction furnace (CNM) 

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 CO2 emissions (No 

CEMS) - Air pollution 

control residue collected (CR) 

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 

memorandum. 

Q §98.176(e)(3) Annual volume of each type 

of gaseous fuel used to 

determine CO2 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 CO2 emissions 

(reported separately for each 

type in gallons) (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 mass (in metric tons) 

of each process input used to 

determine CO2 emissions (No 

CEMS)- Annual mass of 

greenball (taconite) pellets 

fed into the furnace (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 CO2 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 CO2 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 CO2 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 each process input used to 

determine CO2 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 CO2 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 

memorandum. 

Q §98.176(e)(3) Annual mass (in metric tons) 

of each process input used to 

determine CO2 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 CO2 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 CO2 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 CO2 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 CO2 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 CO2 emissions (No 

CEMS)- Coal charged to 

battery (Coal) and other 

process 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 CO2 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 CO2 emissions (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 CO2 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 CO2 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 Two of this 

memorandum. 

Q §98.176(e)(3) Annual mass (in metric tons) 

of each process input used to 

determine CO2 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 CO2 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 CO2 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 CO2 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 CO2 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 process input used to 

determine CO2 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 CO2 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 CO2 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 CO2 emissions (No 

CEMS) - Annual mass of air 

pollution control residue 

collected (Residue) from EAF 

and other process outputs; 

and annual volume of each 

type of gaseous fuel used to 

determine CO2 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 CO2 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 CO2 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 CO2 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 CO2 emissions (No 

CEMS)- Annual mass of iron 

ore or iron ore pellets charged 

to the direct reduction furnace 

(Ore). 

Q-7 Provides production 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 CO2 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 CO2 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 

memorandum. 

Q §98.176(e)(3) Annual mass (in metric tons) 

of each process input used to 

determine CO2 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 CO2 emissions (No 

CEMS)- Annual mass of nonmetallic 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 CO2 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 CO2

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), for 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 CO2

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(f)(4) Annual production rate used 

to estimate annual CO2

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 - 

Used 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 CO2 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 CO2 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 CO2 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 CO2 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 CO2 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 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 

CO2 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 §98.186(b)(7) Annual average of the carbon 

content determinations for 

each material used for the 

calculation of annual process 

CO2 emissions (No CEMS). 

(CScrap= Carbon content of 

the lead scrap, 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 §98.186(b)(7) Annual average of the carbon 

content determinations for 

each material used for the 

calculation of annual process 

CO2 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 §98.186(b)(7) Annual average of the carbon 

content determinations for 

each material used for the 

calculation of annual process 

CO2 emissions (No CEMS). 

(CCarbon= Carbon content of 

the carbonaceous 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 §98.186(b)(7) Annual average of the carbon 

content determinations for 

each material used for the 

calculation of annual process 

CO2 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 

available) 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 carbonate, 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 N2O 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 

memorandum. 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 determine 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 efficiencies 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 conditions 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 

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-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 

operational 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 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)(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) N2O 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 used 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) Number 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 § 98.246(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" 

((Fgf)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" ((Pgf)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 

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) 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 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 liquid feedstock i 

for month "n" ((Flf)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" ((Plp)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" ((Flf)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" ((Plp)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 

feedstock i for month "n" 

((CClf)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 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 mass values (used in 

Equations X-1 to X-3) - Mass 

of solid feedstock i for month 

"n" ((Fsf)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" ((Psp)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" ((CClf)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 Equation Y-1b: 

report the carbon mole 

number of each carbon 

containing compound other 

than CO2 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 combustion 

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)(10) 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 reported 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 catalytic 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 consumption) if the N2O 

emissions (as currently reported 
97 

Subpart 

Rule Citation in 40 

CFR Part 98 Data Element Description 

Data Element 

is used as 

Input to 

Equation . . . Analysis Results 

under 40 CFR 98.252(e) and made 

publicly available)1

 are also known. 

Y § 98.256(f)(11) Units of measure for the unitspecific CH4 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 

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(f)(12) Units of measure for the unitspecific N2O 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. Y12, 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. Y12, 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. Y12, 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 recovery 

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 

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 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 dust 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 
99 

Subpart 

Rule Citation in 40 

CFR Part 98 Data Element Description 

Data Element 

is used as 

Input to 

Equation . . . Analysis Results 

2.1 of Part Two of this 

memorandum. 

Y §98.256(i)(7) For coke calcining: The unitspecific CH4 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 currently 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 

CH4 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(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 

memorandum. 

Y §98.256(i)(8) For coke calcining: If a unitspecific 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) CO2 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 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)(6) CH4 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 Equation 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 CO2 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: CH4

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 
101 

Subpart 

Rule Citation in 40 

CFR Part 98 Data Element Description 

Data Element 

is used as 

Input to 

Equation . . . Analysis Results 

CFR 98.252(f) and made publicly 

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. Specifically, 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 the design 

and operation of the coking unit. 

Y §98.256(k)(3) For delayed coking units: 

Annual number of cokecutting 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 

available. 

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 delayed 

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 design 

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 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 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 coking 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 currently 

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 cumulative 

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): CH4 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 Y21 (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 in 

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 facility 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 

production 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 gas (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 tankspecific 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 CH4

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 CH4 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)(vi). 

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)(vi). 

Y §98.256(p)(2) For loading operations: 

Quantity of materials loaded 

by vessel type that have an 

equilibrium vapor-phase 

concentration of CH4 of 0.5 

volume percent or greater. 

Used in 

methods 

specified in AP42, 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 CO2 (ton CO2/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 
106 

Subpart 

Rule Citation in 40 

CFR Part 98 Data Element Description 

Data Element 

is used as 

Input to 

Equation . . . Analysis Results 

2.1 of Part Two of this 

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 combustion 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 combusted. 

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 

CO2 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 

CH4 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 

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 
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; raw 

material usage; or production. 

AA §98.276(e) Default emission factor for 

N2O 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 

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(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 
108 

Subpart 

Rule Citation in 40 

CFR Part 98 Data Element Description 

Data Element 

is used as 

Input to 

Equation . . . Analysis Results 

2.1 of Part Two of this 

memorandum. 

AA §98.276(g) Annual quantities of fossil 

fuels used in pulp mill lime 

kilns. 

C-8a 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-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 CaCO3

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 Na2CO3

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 emissions 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. 

CC §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 
109 

Subpart 

Rule Citation in 40 

CFR Part 98 Data Element Description 

Data Element 

is used as 

Input to 

Equation . . . Analysis Results 

operation; cost to do business; raw 

material usage; or production. 

CC §98.296(b)(10)(ii) Hourly CO2 concentration 

during performance test 

(percent CO2) 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 any 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) CO2 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; raw 

material usage; or production) that 

would reveal information that could 

cause competitive harm. 

CC §98.296(b)(10)(iv) CO2 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 production 

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 carboncontaining 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 carboncontaining 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 carboncontaining 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 carboncontaining 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 carboncontaining 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 carboncontaining 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 

material data described in section 

2.1 of Part Two of this 

memorandum. 

GG §98.336(b)(7) Carbon content of carboncontaining 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 

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 fraction) (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 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)(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 both 

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)(iii)) 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 

reported 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 that 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,” which 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."