## 1 

# MEMORANDUM

DATE: August 2013

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

FROM: Lisa Grogan-McCulloch

SUBJECT: 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 re ferred 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 comp etitive harm if made publicly available. The EPA outlined a four-step pr ocess 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 purpose of this memorandum is to describe th e review undertaken for the second step of this evaluation process: the EPA’s analysis of the competitive harm that would likely result from reporting of “inputs to equations” data elements . This review was undertaken for 27 of the 28 subparts of the Greenhouse Gas Reporting Prog ram (GHGRP) with “inputs to equations.” 1



# This analysis of competitive harm includes:

 Part One: An evaluation of the current market structures for sector s required to report “inputs to equations” data elements, to dete rmine whether conditions exist within the market structures such that the release of th e data could result in competitive harm, and

 Part Two: For those sectors for which the ma rket structure analysis determined that reporting of the “inputs to equations” data elements could result in competitive harm, an evaluation of each individual “inputs to equati ons” data elements to determine whether its release would be likely to cause competitive harm.

1 

### The review was not conducted for 2015 data inputs in subpart I because reporting of the “inputs to equations” data elements fo r that subpart was addressed in a separate proposed action [see 77 FR 63538]. Additionally, the evaluation of the subpart C “inputs to equations” in this memorandum encompasses the one subpa rt A “input to equation” data element. As a result, the one subpart A “input to equation” is not listed explicitly in this memorandum.

## 2 

# The EPA’s evaluation of current market structures is presented in Part One of this memorandum. For all sectors in which the market structure anal ysis summarized in Part One determined that the conditions exist within the ma rket such that firms could us e released “inputs to equations” data elements to gain a competitive advantage, the EPA proceeded to evaluate each individual “inputs to equations” data element. Part Two of this memorandum presents an evaluation of each individual “inputs to equations” data elemen t to determine whether potential release would be likely to cause substantial competitive harm.

## 3 

# Part 1: Evaluation of Market Structures

1.0 Introduction

The following section describes the overall process used to assess th e 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 ma rket such that competitive harm could occur should “inputs to equations” data elements be re leased to the public. Section 2.0 summarizes the connection between market structure and the po tential 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 price they obtain for their product. The market, in turn, is defined in term s of the commodity marketed and the geographic scope of the market.

Competitive markets are characte rized by many suppliers and produc ts that are identical or nearly identical, in terms of produc t characteristics that users value. In such markets, firms are “price takers”; that is, they are unable to infl uence the market price, and must determine their profit-maximizing production level as a function of the price set by the mark et. In such markets, strategic behavior is not possible because th ere are too many competitors, making it impossible for them to make decisions based on their competit ors’ 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 nu mber 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 Structu res and Potential for Competitive Harm

Economists assess market concentration using measur es that characterize th e share of the market served by the largest firms. Specific tools used include the Herfindahl-Hirschman Index (HHI).

## 4 

# For a given market, the HHI is calculated by squari ng the market share of each firm competing in the market, then summing the squared shares.

HHI =  i 

# s i 2 

# , where s i 

# = the market share of the i th 

# firm.

Potential values of the HHI range from near zer o (if each of the top 50 firms has one-50th if the output of the group (50*(1/50^2)), to 10,000, if one firm has 100 percent 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 sm aller 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 

# use the HHI to identify markets where there are potential anti-trust concerns. They consider markets with an HHI below 1,000 to be unconcentrated; markets with HHI between 1,000 and 1,800 are c onsidered 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. 3



# Economists define markets at the product or pr ocess level because customers make purchasing decisions for specific products or services. While identifying a concentrated or moderately concentrated NAICS is sufficient to identify s ubparts in which facilities are aware of their competitors, and thus subparts for which revealing sensitive information would have the potential to lead to competitiv e harm, it is not the only indicator that a market may have the potential to lead to competitive harm should se nsitive 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 pr oducing the product that they are aware of each other’s operations and may behave stra tegically. In these cases, publication of some data could result in ei ther reduced competition or competitive harm. Similarly, some products are traded in regional, ra ther than national markets; for these, even if the sector does not appear concentrated or mode rately 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 addi tion, 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 re sult, 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:

2 Department of Justice. Use of HHI. http://www.justice.gov/atr/pu blic/divisionmanual.html , and Federal Trade Commission (FTC), 2004. The Petroleum Industry: Mergers, Struct ural Change, and Antitrust Enforcement

. http://www.ftc.gov/opa/ 2004/08/oilmergersrpt.shtm 3 Census Bureau. Economic Cens us, Concentration Ratios, 2007. http://www.census.gov/econ/concentration.html

## 5 

# 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. If multiple NAICS are associated with a s ubpart, and not all NAICS are in the same concentration category, the EPA determined whet her 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 unc oncentrated NAICS, the EPA determined whether:

a. The markets for the goods produced by firm s 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 ma rkets 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-specif ic) to determine if it is concentrated or moderately c oncentrated. 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 resu lting 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 th e market is concentrated, such that the firms subject to the subpart are likely ab le to identify their competitors. For each such subpart, the EPA proceeded to evaluate each “inputs to equations” da ta elements 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 (Combusti on), II (Industrial Wastewater Treatment), and TT (Industrial Landfills), the subparts represent a proc ess that may take place at facilities in a number of industry sectors. Anot her subpart, subpart U (Miscellane ous Uses of Carbonates), also includes a variety of industry sectors. The mark ets in which these facilities compete, and for which concentration must be assessed, are the ma rkets for the goods or services they produce. To evaluate the concentration in th ese markets, therefore, the EP A identified the NAICS codes for the industry sectors reported by these facilities, and exam ined their concentration.

For sectors that did not have manufacturing NAICS codes, subparts W (Petroleum and Natural Gas Systems) and CC (Soda Ash), HHI values we re 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 co des 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 thes e 296, 200 are manufacturing sector NAICS codes,

## 6 

# for which HHI information is compiled by the Census Bureau. Subparts CC and W 4 

# did not have 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 concentr ation 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 re lease of the “inputs to eq uations” 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 subpar t are likely are aware of each other’s actions. The EPA focused its as sessment on the 200 manufacturing sector NAICS codes associated with GHG reporting facilities.

Appendix A lists concentration ratios for the 6-dig it NAICS codes cited by facilities, as well as values of the Herfindahl-Hirschman Index ( HHI) published by the U.S. Census Bureau for affected manufacturing NAICS codes. In additi on, 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. 5



# At the subpart level, the EPA considered a s ubpart 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 concentr ated or moderately c oncentrated. Recognizing that it is actually the market or the sector that is concentrat ed, for convenience throughout the rest of this document, the EPA refers to su ch subparts as concentrated or moderately concentrated. Using this crit erion, the EPA found that the fo llowing 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 

### Three of the 1,549 fa cilities reporting under subpart W in 2011 reporte d manufacturing NAICS code s. See section 4.4 for further discussion. 5 

### Some facilitiesreported multiple NAICS; t hus, facilities may be counted several times within a subpart, and the sum of NAICS cited by facilities within a subpa rt may exceed the number of fac ilities reporting under that subpart.

## 7 

# 4.2 Analysis of Concentration at the Regional, Product, or Process Level

For sectors for which the Census Bureau data indicates HHI in the unconcentrated range, the EPA undertook further analysis. The markets fo r 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 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; th is is a very broad NAICS code, encompassing production of many different inorgani c chemicals. Adipic acid production is a small subset of the overall NAICS. Thus, the EPA examined adipic ac id producers specifically, rather than relying on a NAICS-level assessment. Three facilities re ported under subpart E for Reporting Year 2011. Even without firm-level data, the HHI is useful because with only three pl ants, the lowest value the HHI could have is 3,267. 6 

# Because this source category does not have a threshold for applicability, all ad ipic acid producers in the U.S. ar e 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 equati ons” data elements in Subpart E by examining individual data elements to determine if harm woul d 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 Cens us. In addition, Appendix 1 shows that the NAICS codes reported by GHGRP f acilities in 2011 are unconcentr ated. Therefore, the EPA proceeded to assess whether regi onal markets are concentrated.

High cement transportation cost rela tive to product value leads to regional cement markets with a small number of competing firms. In previous analyses supporting the EPA rule making, the cement industry has been modeled as re gional, and imperfectly competitive. 7 

# That is, market concentration within a re gional market is sufficiently high that firms are aware of competitors. For example, this analysis identified 20 regiona l markets for gray cement (a subset of this sector), with the number of plants in each market ranging from one to nine 6 

# ; 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 ba sed on their knowledge of other (competing) producers’ behavior. In additi on, they would be aware of their competitors’ identity and interested in pr oduction and market information a bout their competitors. It is

6 

### Assuming each firm has an equal one-third share of the market results in an HHI of 3,267 (3 x 33 2 

### ). In fact,the threshold of 1,000 for moderately concentrated markets tr anslates to a minimum of 10 firms. 7 

### See EPA’s Regulatory Impact Analysis: Amendments to the National Emissions Standards for Hazardous Air Pollutants and New Source Performance Standards for the Portland Cement Industry, August 2010, Section 2.3. http://www.epa.gov/ttnecas1/regdat a/RIAs/portlandcementfinalria.pdf , EPA-HQ-OAR-2002-0051-3477.

## 8 

# important to note that faciliti es in the cement industry may pr oduce a variety of cement products. Some cement products are homogeneous (e.g. gray cem ent) and are traded in regional markets; others such as white, Type III and Type V repres ent niche products with different markets, with few firms but possibly servi ng a larger geographic area. 8



# As a result of these assessments, the EPA concl uded that the structure of the markets that exist within this source catego ry warrant further evaluation of the “inputs to equations” data elements in subpart H. Therefore, the EPA further evalua ted 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. Business 9 

# , there are 19 firms nationwide that produce ferroall oys. 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 ad dition, if a sector that has 19 firms nationwide includes a few firms with relatively large market sh are (as opposed to a sector where all firms are similar size, and each has roughly 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 fu rther 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 woul d 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, genera lly for captive use. Because th ese sectors are considered at least moderately concentrated (see discussion fo r subpart Y, below), we concluded that the structure of the markets that exist within this source category warrant fu rther 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 Bur eau and other information. Steel production is generally characterized by economie s 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

8 EPA’s Regulatory Impact Anal ysis: National Emissions Standards for Hazar dous Air Pollutants from the Portland Cement Industry, April 2009, shows that only 4 plants nationwide produ ced white cement in 2005. See Appendix A of the 2009 RIA for list of plants in each cement market in 2005. http://www.epa.gov/ttnecas1/regdata/ RIAs/portlandcementria_4-20-09.pdf

.

9 

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

## 9 

# 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 th eir knowledge of other (competing) producers’ behavior. Nationally, the majority of facilities reporting under this source category had a NAICS code that was unconcentrated. , for the reasons mentioned abov e, the national NAICS-level assessment may be misleading. Some steel products ar e homogeneous and are traded in regional markets; others represent niche products w ith relatively few firms, serving di fferent markets ( possibly different geographic dimensions). Both regional markets a nd niche markets have relatively small numbers of producers, indicating at least moderate market concentration.

The EPA computed HHI at the pr ocess, region, and parent compa ny level, 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 10 

# . 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 this production data, disaggregating by state, parent company, and proce ss. The results indicated that th ere 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 stat e or parent company, th e HHI values show at least moderate concentration, w ith 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 concl uded that the structure of the markets that exists within this source category warrant furt her evaluation of the “inputs to equations” data elements in subpart Q. Therefore, the EPA fu rther 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 con centrated at the national level. Both subpart R (lead smelting) and subpart GG (zinc sme lting) fall under NAICS 331410, Nonferrous Metal (except Aluminum) Smelting and Refining. In add ition to lead and zinc, many other nonferrous metals are included under NAICS 331410. Thus, th e EPA examined the markets for lead and zinc individually. For subpart R, there is only on e primary lead smelter, and seven firms with 14 secondary smelters nationwide (USGS, 2010a). Fo r subpart GG, there is only one primary zinc smelter and two secondary smelters nationwide (USGS, 2010b). Thus, firms in both of these subparts produce commodities whose markets are concentrated nationally. As a result, the EPA concluded that the structure of the markets that exist within these source categories warrant 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

10 

### http://www.steel.org/ en/Making%20St eel/Where%20Its%20Made.aspx

## 10 

# 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 manuf acturing facilities identified 14 NAICS codes. Of these, two NAICS, identified by 19 facilities, are concentrated based on their HHI values. Facilities within this subpart produce one of si x 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 ten or fewer. 11 

# As a result, the EPA concluded that the structure of the markets that exist within this source category warrant further ev aluation of the “inputs to equati ons” data elements in subpart X. Therefore, the EPA further evaluated the “i nputs 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 ba rriers to entry facing firms wanting to enter the refining industry. First, ther e 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 ba rriers 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 value of shipments, according to the 2007 Ec onomic Census. While 807 is not considered concentrated, the industry has become more c oncentrated over time, even when considered nation-wide (HHI in 1996 was 412, in 2000 th e 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” 12 

# , the Federal Trade Commission (FTC, 2004) found that PADD V (the West Coast including Alaska and Hawaii) was mode rately concentrated (HHI=1,246 in 2003).

Individual petroleum products are relatively homogeneous, although different firms produce a different mix of products, and some produce spec ialty products for which there are few other producers. The U.S. Department of Energy collec ts data on refineries in a petroleum supply survey which is published as an annual Petroleum Capacity Report. 13 

# The EPA reviewed the latest data (2012) containing 31 se parate products and processes at 95 different facilities owned by 63 different firms. To better characterize the pe troleum market, the EPA analyzed this data at the product/process level, applying the HHI measure to test for market concentration. The result of calculating the HHI at the pr oduct/process level for petroleum refineries shows that activity for several key products/processes is at least moderately concen trated. The data includes

11 

### U.S. Environmental Protection Agency. Te chnical Support Document for the Petroc hemical Production Sector: Proposed Rule for Mandatory Reporting of Greenhouse Gases. September 9, 2008. http://www.epa.gov/ghgreporting/documents/pdf /archived/tsd/TSD%20PetroChem_EPA_09-09-08.pdf 12 

### http://www.eia.gov/oog/in fo/twip/padddef.html 13 

### http://www.eia.gov/petrol eum/refinerycapacity/

## 11 

# capacity data for 3 thermal cracking processes (v isbreaking, fluid cokin g, other) and together there are only 9 facilitie s nationwide with this cap ability (HHI = 5,568, 2,463, and 10,000 respectively). Similarly, desulf urization and catalytic hydrocracki ng are processes where there is at least moderate concentration (HHI 1,023, 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, 7 of them are at least moderately concentrated.

Because the petroleum refinery industry is mode rately 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 market s that exist within this source category warrant further evaluation of the “inputs to equations” data elements in subp art 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 Pa rt 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 repo rting under the Greenhouse Gas Reporting Program, these source categories are not defined by the types of products manufactured, or produced, at the facility. Instead, these subparts are define d by production processes or wa ste 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 informati on related to these sour ce categories has the potential to cause competitive harm depends on the concentration of the markets in which the facilities sell their produc ts rather than on the total number of facilities repo rting under each source category. Thus, the EPA determined that it would be necessary to identify the markets affected, and examine their market structure.

For these subparts, the EPA was able to conduct th e first step of the evaluation, to examine the national-level HHI for the NAICS codes reported by facilities. However, for the NAICS codes where the national level 6-digi t 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 th ese 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 li st of the HHIs for NAICS codes reported by these facilities. The EPA’s analysis of HHIs for ma nufacturing 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,

## 12 

# publishing the information contained in the “input s to equations” data elements could potentially cause competitive harm or reduce competition. Du e to the limitations of the market structure analysis for these subparts, and because the result s of the analysis demonstrate that some of the facilities that report under these subparts are in sectors that ar e at least moderately concentrated at the national level, the EPA proceeded to evalua te the individual data elements to determine if harm would likely occur (refer to Part Two of this memorandum).

Table 1. Summary of National Level Herfin dahl-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 HHIs, 1,2 

# # of Facility Reports of NAICS with at Least Moderately Concentrated HHIs 1



# 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

1 

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

2 

### Includes only facility reports of NAI CS codes with non-missing HHI values.



# 4.4 Analysis of Non-Manufacturing Sectors

As shown in Appendix A, HHIs were not available for subpart W 14 

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

Subpart W: Petroleum and Natural Gas.

Subpart W includes facilities operating in eight re lated segments of the petroleum and natural gas sector. Because subpart W is not a manufacturing sector, HHIs were not available for the vast

14 

### Of the 1,549 facilities that reported under subpart W in 2011, th ree facilities reported manufacturing NAICS codes for which HHIs are available and were moderately concentrated. Of thes e, 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 

# majority of facilities. As a result, the EPA conducted a qualita tive analysis of the segments within this sector.

For each segment, the EPA examined the market st ructure to determine if revelation of “inputs to equations” data elements by firms in that segmen t had the potential to cause competitive harm or reduce competition. For source categories that ar e in the manufacturing sector, as shown in Sections 4.1 and 4.2 of this memorandum, the EPA examined concentration at the national level, as well as at the regional, product, or process le vel. 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 a ssess the market structure at the product or process level. As a resu lt, the EPA considered the market structure of each segment as well as the types of information that are co llected 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 producti on segment covers emissions related to onshore production wellheads. The market stru cture 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 in formation during the ea rly development of a formation when lease prices have not stabi lized 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, in formation about production becomes publically available and the advantage incurred by the ope rator drilling exploration wells is lost. However, once a well has been drilled, decision s to produce are based on market prices and the ability to control flow from the well. Alt hough this could pose a potential data sensitivity with respect to exploration wells, this issue is addressed by the fact that onshore production data is reported at a sub-basi n level, as defined by county boundaries, and which is a large enough scale that disclosure of the data co llected under subpart W 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 collect ed for this segment, the EPA did not proceed to evaluate each “input to equation” data element in this segment.

The onshore natural gas production market overlap s many of the geological formations of petroleum production. Furthermore, the market it self is structured the same, with a large number of operators within each formation. Li ke onshore oil production, disclosure of data for onshore natural gas production at the sub- basin level would al so not reveal any proprietary information about the facility or cost to do business. As the likelihood of harm can be characterized for all information collect ed for this segment, the EPA did not proceed to evaluate each “input to equation” data element in this segment.

## 14 Offshore Petroleum and Natural Gas Production 

# Offshore petroleum and natural gas production includes emissions from offshore production platforms and does not include emissions from dr illing and exploration th at is not associated with production platforms. The products cr eated 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 is specific to a latitude and l ongitude as identified by the facility but the data reported in offshore production does not include information specific to the formations from which hydrocarbons are being extracted and only information concerning the operations of the platform are reported. The operational information does not include information that the operator will find proprietary to the well and as a result, the information reported under offshore petroleum and natural gas producti on 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 equati on” data element in this segment.

Natural Gas Processing 

# Natural gas processors are regionally located cl ose to production wellheads. The market itself is large, with roughly 500 firms. These firms ar e located in close proximity to given natural gas plays. However, we do not believe that this regional concentr ation would pose data sensitivity issues because the “inputs to equati ons” data elements in this segment would not reveal any proprietary information about the f acility, cost of natural gas, or cost to do business. As the likelihood of harm can be char acterized for all information collected for this segment, the EPA did not proceed to evaluate e ach “input to equation” data element in this segment.

Natural Gas Transmission Compression 

# Natural gas transmission compression operators tr ansport natural gas from processors to end users. Firms are regionally concentrated, havi ng control over particul ar 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 relate d to pipeline construction an d natural gas transmission; technological innovation is mainly in the area of pipeline secur ity; (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 fo r this segment, the EPA did not proceed to evaluate each “input to equation” da ta element in this segment.

## 15 Natural Gas Distribution 

# Natural gas distributers own and operate the distribution mains and services and function as the middle man between transmission lines and e nd-users. This market is regionally located with distributers having exclusive access to spec ific cities and other localities. Both publiclyand privately-owned companies are highly regulat ed, unable to charge market based rates for service. The regulation by government and th e monopoly rights distributors hold over given regions prevents competitors’ use of the data fo r strategic purposes. As a result, the “inputs to equations” data elements in this segment woul d not reveal any proprietary information about the facility or cost to do business. As the li kelihood 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.

Underground Natural Gas Storage 

# Underground natural gas storage is used to sm ooth out volatility in c onsumption and use of natural gas. The market is regional; facilities ar e located either near major distribution centers or near oil and gas fields. Even with the regi onal market structure, competitors are not known to engage in strategic competition in building st orage facilities. First, facilities are built in response to other upstream factors, such as in creased gas supply coming to distributors, not to undermine other competitors. Second, storag e firms are constrained by the geographical and geological requirements needed for underg round storage, preventing firms from moving in and increasing their market share. Finall y, 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 char acterized for all information collected for this segment, the EPA did not proceed to evaluate e ach “input to equation” data element in this segment.

Liquefied Natural Gas Storage 

# Liquefied Natural Gas (LNG) storage operate s 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 possibi lities for disruptive competitive undercutting; however, there we determined that this is un likely for the following two reasons. First, LNG storage is primarily owned by highly regulated distributors, preventing competitive firms from undercutting the market. Second, LNG stor age 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 elemen ts 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 collect ed for this segment, the EPA did not proceed to evaluate each “input to equation” data element in this segment.

## 16 Liquefied Natural Gas Import/Export 

# Currently the U.S. has only twelve LNG im port terminals and one LNG export terminal. There are nine onshore import terminals a nd three offshore import terminals. LNG technology is not proprietary. Th e technology is relatively simp le 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 la rger natural gas supply sector that is a much larger market. The product delivered or cons umed by LNG Import/Export is identical to the product generated in onshore and offshore natu ral gas production. Functionally, Import and Export terminals may be considered as a large producer or consumer of natural gas. Import and Export terminals are generally located in regions of supply restrictions or excess to maximize price margins. However, the trading pr ices of natural gas is publically available and the building of new import and export terminals is limited by capital and permitting, not by market structure. Therefor e, release of information a bout 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, the EPA determined that, for all of the industry segments with in Subpart W, either the data are reported at a le vel of geographical aggregati on that protects individual well information, or the markets in which the affected firms operate are stru ctured in ways that disclosure of “inputs to equations” data elements would not be likely to cause competitive harm. As a result, the EPA did not further evaluate th e “inputs to equations” data elements in Subpart
W.

Subpart CC, Soda Ash . The four facilities re porting 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. 15 

# If a sector that has 18 firms nationwide includes a few firm s with relatively large market share (as opposed to a sector where all firms are similar size, and each has roughly 1/18 shar e of the market), it is likely to be concentrated. As a result, the EPA c oncluded that the structure of the markets that exist within this source category warrant furthe r evaluation of the “inputs to equations” data elements in subpart CC. Therefore, the EPA fu rther evaluated the “inpu ts 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

15 

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

## 17 

# In this part, the EPA examined the market structures for subparts with “inputs to equations” data elements to determine whether conditions exist with in the market structure such that release of these data could result in competitive harm. Th e EPA determined that such conditions exist within the market structures fo r all of the subparts examined ex cept for facilitie s reporting under subpart W. As a result, the EPA did not further evaluate competitive harm for facilities reporting under subpart W. For the “inputs to equations” da ta elements in the remaining 26 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.

## 18 

# Part Two: Evaluation of Individu al Data Elements

1.0 Introduction

As discussed in Part One of this memorandum, th e 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 subpa rts examined in this memorandum except for facilities reporting under subpart W. As a result, no further evaluati on of competitive harm was conducted for this source category. The remaining “inputs to equations ” data elements in 26 subparts were further evaluated by examining individual da ta elements to determine if ha rm 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 th e Call for Information (75 FR 81366, December 27, 2010), the EPA identified certain types of data th at 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 a nd operation, and cost to do business.

Additionally, the EPA determined that many othe r “inputs to equations” data elements, which alone would not reveal informati on that could cause competitive ha rm, would reveal the types of data specified above if known together with ce rtain 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 furthe r discussed below. In all, 525 “inputs to equations” data elemen ts (excluding “inputs to equations ” for facilities subject to subpart W) were reviewed according to the proce ss described in this section. Refer to Appendix B for results of the analysis for each of the 525 data elements.

2.1 Quantity and Composition of Raw Materials or Products

The EPA has determined in previous GHGRP acti ons that publicly releasing facility-specific data on the quantity or composition of raw mate rials 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., producti on rates that are currently colle cted under Part 98, but not used to calculate GHG emissions). As further di scussed 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 in formation and operational and mark eting strategies, as follows:

## 19 

#  Annual production quantities, used in conjunction with othe r 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 th roughput quantities and product compositions could give competitors insight into a firm’s local and regional market conditions and expansion plans, enabling competitors to devi se strategies to prevent expansion and to steal market share in specific locations; and

 Disclosing a facility’s feed stock quantities and compositi on and reactants fed into particular processes at a facility could pr ovide 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 identifi ed 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 da ta 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 prev iously proposed CBI determinati ons). 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 requireme nt to report the quantity or composition of raw materials or products are id entified 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 busi ness would reveal the following information:

 Disclosing process design information could be detrimental to a firm’s competitiveness by revealing design efficiency of the unit, providing insight to a firm’s operational strengths and weaknesses (e.g., disclosing the ratio of the maximum rate heat input capacity to the design rated steam output capac ity 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 to a firm’s operational strengths and wea knesses (e.g., disclosing an aluminum production facility’s cell performance would disclose current production efficiency);and

## 20 

#  Disclosing information related to the cost to do business could be detrimental to a firm’s competitiveness by providing insight to 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, w ould reveal the amount of product that is lost).

Data elements determined to include a requireme nt 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 pro ducts (see section 2.1), in combination with currently reported data el ements and other “inputs to equations” data elements could be used to back-calculate the ty pes of data specified in sections 2.1 and 2.2 (e.g., production quantity, cost to do business). For exampl e, for a nitric acid production facility, the abatement technology destruction e fficiency, if reported alone, woul d not reveal any information that would likely cause harm; however, if reported together with the abatement utilization factor, emission factor, and reported N 2 

# O emissions, it could be used to back-calculate an estimate of the mass of nitric acid produced, which is the type of data id entified in section 2.1 of this memorandum. Data elements determined to rev eal proprietary information in this way are identified in Appendix B.

For any such data elements identified, the EPA al so 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 (a s required under §98.226(j)), together with annual
N 2 

# O emissions from nitric acid production (in §98.3(c)(4)), the emission factor (in §98.226(m)(1)), and the destruction e fficiency (in §98.226(i)), these da ta together could be used to calculate the mass of nitric ac id produced. However, if repor ting of the emission factor were removed, the abatement utilization factor coul d be reported without revealing proprietary information about nitric acid production. Any su ch “inputs to equations” data elements are identified in Appendix B.

3.0 Summary

Based on the results of Part One and Part two of this memorandum, the EPA proceeded to Step 3 of the evaluation for 25 of the 27 subparts evaluated in this memo randum. The EPA did not proceed to Step 3 of the evaluation for subpart W (Petroleum and Natural Gas Systems) and Subpart II (Industrial Wastewater Treatment).

## 21 

# Appendix A

Subpart Sector Concentration Assessm ent, National NAICS Code Level

## 22 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

## 23 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

## 24 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

## 25 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

## 26 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

## 27 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

## 28 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

## 29 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

## 30 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

## 31 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

## 32 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

## 33 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

## 34 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

## 35 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

## 36 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 ma y 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, wh ichever 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.

## 37 

# Appendix B

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

## 38 

# Table B-1. Results of the Evaluation of Co mpetitive 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 at industrial

sources, excluding stationary fuel combustion

sources connected to certain electric generators connected to the local or regional power grid) 1 §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 at industrial

sources, excluding stationary fuel combustion

sources connected to certain electric generators connected to the local or regional power grid) 1 §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.

C (Stationary fuel combustion
sources at industrial

sources, excluding stationary fuel combustion

sources connected to certain electric generators connected to the local or regional power grid) 1 §98.36(c)(2)(ix) The flue gases from two or more stationary fuel combustion units at a facility are combined together and discharged through a common stack or duct before exiting to the atmosphere and if CEMS are used to continuously monitor CO 2 mass emissions at the common stack or duct according to the Tier 4 Calculation Methodology, you may report the combined emissions from the units sharing the common stack or duct, in lieu of separately reporting the GHG emissions from the individual units. This monitoring and reporting alternative may also be used when process off-gases or a mixture of combustion products and process gases are combined together in a common stack or duct before exiting to the atmosphere. An estimate of the heat input from 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.

## 39 Subpart Rule Citation in 40 CFR Part 98 Data Element Description Data Element is used as Input to Equation . . . Analysis Results each type of fuel listed in Table C-2 combusted during the reporting year.

C (Stationary fuel combustion
sources at industrial

sources, excluding stationary fuel combustion

sources connected to certain electric generators connected to the local or regional power grid) 1 §98.36(e)(2)(i)§98.36(e)(2)(ii)(A) §98.36(e)(2)(iv)(A) Total quantity of each type of fuel combusted in each unit or group of aggregated units (as applicable). C-1,C-1a,C-1b,C8,C-2b,C-13,C3,C-4,C-5,C-8,C8a,C-8b 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.

C (Stationary fuel combustion
sources at industrial

sources, excluding stationary fuel combustion

sources connected to certain electric generators connected to the local or regional power grid) 1 §98.36(e)(2)(ii)(C) High heat values used in the CO 2 emissions calculations for each fuel combusted during the reporting year. Report a HHV value for each calendar month in which HHV determination is required. If multiple values are obtained in a given month, report the arithmetic average value for the month. C-2b 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.

## 40 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 at industrial

sources, excluding stationary fuel combustion

sources connected to certain electric generators connected to the local or regional power grid) 1 §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 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 at industrial

sources, excluding stationary fuel combustion

sources connected to certain electric generators connected to the local or regional power grid) 1 §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 Provo 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 energy generated from MSW or solid fuel, which could reveal information about the cost to produce energy for the process.

C (Stationary fuel combustion
sources at industrial

sources, excluding stationary fuel combustion

sources connected to certain electric generators connected to the local or regional power grid) 1 §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-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.

C (Stationary fuel combustion
sources at industrial

sources, excluding stationary fuel combustion

sources connected to certain electric generators connected to the local or regional power grid) 1 §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-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.

## 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 at industrial

sources, excluding stationary fuel combustion

sources connected to certain electric generators connected to the local or regional power grid) 1 §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-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 at industrial

sources, excluding stationary fuel combustion

sources connected to certain electric generators connected to the local or regional power grid) 1 §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-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 at industrial

sources, excluding stationary fuel combustion

sources connected to certain electric generators connected to the local or regional power grid) 1 §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.

C (Stationary fuel combustion
sources at industrial

sources, excluding stationary fuel combustion

sources connected to certain electric generators connected to the local or regional power grid) 1 §98.36(e)(2)(ix)(D) For units that combust both fossil fuel and biomass, when biogenic CO 2 is determined according to §98.33(e)(2),report the carbon-based 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.

## 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 at industrial

sources, excluding stationary fuel combustion

sources connected to certain electric generators connected to the local or regional power grid) 1 §98.36(e)(2)(ix)(E) For units that combust both fossil fuel and biomass, when biogenic CO 2 is determined according to §98.33(e)(2), report the annual average HHV value used in Equation C-13 of this subpart. C-13 Provides data related to process design; process performance, and operation; 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 at industrial

sources, excluding stationary fuel combustion

sources connected to certain electric generators connected to the local or regional power grid) 1 §98.36(e)(2)(ix)(F) For units that combust both fossil fuel and biomass, when biogenic CO 2 is determined according to §98.33(e)(2), report the total quantity of fossil fuel combusted during the reporting year. C-13 Provides data related to process design; process performance, and operation; and/or cost to do business, as described in section 2.2 of Part Two of this memorandum. Specifically, indicates the quantity of fuel used in the process, which, in certain cases, could reveal information about the cost to produce products.

C (Stationary fuel combustion

sources connected to certain electric generators connected to the local or regional power grid) 1 §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 materialusage; or production. Sitespecific fuel characteristics for these units do not varysignificantly from publiclyknown 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.

## 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 connected to certain electric generators connected to the local or regional power grid) 1 §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 typesof combustion units, facilitylevel 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 materialusage; or production. Sitespecific fuel characteristics for these units do not varysignificantly 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 connected to certain electric generators connected to the local or regional power grid) 1 §98.36(c)(2)(ix) The flue gases from two or more stationary fuel combustion units at a facility are combined together and discharged through a common stack or duct before exiting to the atmosphere and if CEMS are used to continuously monitor CO 2 mass emissions at the common stack or duct according to the Tier 4 Calculation Methodology, you may report the combined emissions from the units sharing the common stack or duct, in lieu of separately reporting the GHG emissions from the individual units. This monitoring and reporting alternative may also be used when process off-gases or a mixture of combustion products and process gases are combined together in a common stack or duct before exiting to the atmosphere. An estimate of the heat input from 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 materialusage; or production. Sitespecific fuel characteristics do not vary significantly from publicly-known average values. Additionally for the electric utilities, this sector has experienced a high level of transparency due to the practice of passing fuel costs through to paying customers.

## 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 connected to certain electric generators connected to the local or regional power grid) 1 §98.36(e)(2)(i) Total quantity of each type of fuel combusted in each unit or group of aggregated units (as applicable) during the reporting year, in short tons for solid fuels, gallons for liquid fuels and standard cubic feet for gaseous fuels, or, if applicable, therms or mmBtu for natural gas. C-1 For facilities with these typesof combustion units, facilitylevel 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 connected to certain electric generators connected to the local or regional power grid) 1 §98.36(e)(2)(i) Total quantity of each type of fuel combusted in each unit or group of aggregated units (as applicable) during the reporting year, in short tons for solid fuels, gallons for liquid fuels and standard cubic feet for gaseous fuels, or, if applicable, therms or mmBtu for natural gas. C-1a For facilities with these typesof combustion units, facilitylevel 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 connected to certain electric generators connected to the local or regional power grid) 1 §98.36(e)(2)(i) Total quantity of each type of fuel combusted in each unit or group of aggregated units (as applicable) during the reporting year, in short tons for solid fuels, gallons for liquid fuels and standard cubic feet for gaseous fuels, or, if applicable, therms or mmBtu for natural gas. C-1b For facilities with these typesof combustion units, facilitylevel 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.

## 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 connected to certain electric generators connected to the local or regional power grid) 1 §98.36(e)(2)(i) Total quantity of each type of fuel combusted in each unit or group of aggregated units (as applicable) during the reporting year, in short tons for solid fuels, gallons for liquid fuels and standard cubic feet for gaseous fuels, or, if applicable, therms or mmBtu for natural gas. C-8 For facilities with these typesof combustion units, facilitylevel 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 connected to certain electric generators connected to the local or regional power grid) 1 §98.36(e)(2)(ii)(A) For Tier 2: Total quantity of each type of fuel combusted in the unit or group of aggregated units (as applicable) during each month of the reporting year. Express the quantity of each fuel combusted during the measurement period in short tons for solid fuels, gallons for liquid fuels, and scf for gaseous fuels. C-2b For facilities with these typesof combustion units, facilitylevel 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 connected to certain electric generators connected to the local or regional power grid) 1 §98.36(e)(2)(ii)(C) High heat values used in the CO 2 emissions calculations for each fuel combusted during the reporting year. Report a HHV value for each calendar month in which HHV determination is required. If multiple values are obtained in a given month, report the arithmetic average value for the month. C-2b Would not reveal any proprietary information about facility or process performance, design, and operation; cost to do business; raw materialusage; or production. Sitespecific fuel characteristics do not vary significantly from publicly-known average values. Additionally for the electric utilities, this sector has experienced a high level of transparency due to the practice of passing fuel costs through to paying customers.

## 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 connected to certain electric generators connected to the local or regional power grid) 1 §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 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 connected to certain electric generators connected to the local or regional power grid) 1 §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 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. C (Stationary fuel combustion

sources connected to certain electric generators connected to the local or regional power grid) 1 §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 typesof combustion units, facilitylevel 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.

## 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 connected to certain electric generators connected to the local or regional power grid) 1 §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 For facilities with these typesof combustion units, facilitylevel 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 connected to certain electric generators connected to the local or regional power grid) 1 §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-4 For facilities with these typesof combustion units, facilitylevel 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 connected to certain electric generators connected to the local or regional power grid) 1 §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-5 For facilities with these typesof combustion units, facilitylevel 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.

## 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 connected to certain electric generators connected to the local or regional power grid) 1 §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-8 For facilities with these typesof combustion units, facilitylevel 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 connected to certain electric generators connected to the local or regional power grid) 1 §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-8a For facilities with these typesof combustion units, facilitylevel 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 connected to certain electric generators connected to the local or regional power grid) 1 §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-8b For facilities with these typesof combustion units, facilitylevel 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.

## 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 connected to certain electric generators connected to the local or regional power grid) 1 §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-3 Would not reveal any proprietary information about facility or process performance, design, and operation; cost to do business; raw materialusage; or production. Sitespecific fuel characteristics do not vary significantly from publicly-known average values. Additionally for the electric utilities, this sector has experienced a high level of transparency due to the practice of passing fuel costs through to paying customers. C (Stationary fuel combustion

sources connected to certain electric generators connected to the local or regional power grid) 1 §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-4 Would not reveal any proprietary information about facility or process performance, design, and operation; cost to do business; raw materialusage; or production. Sitespecific fuel characteristics do not vary significantly from publicly-known average values. Additionally for the electric utilities, this sector has experienced a high level of transparency due to the practice of passing fuel costs through to paying customers. C (Stationary fuel combustion

sources connected to certain electric generators connected to the local or regional power grid) 1 §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-5 Would not reveal any proprietary information about facility or process performance, design, and operation; cost to do business; raw materialusage; or production. Sitespecific fuel characteristics do not vary significantly from publicly-known average values. Additionally for the electric utilities, this sector has experienced a high level of transparency due to the practice of passing fuel costs through to paying customers. C (Stationary fuel combustion

sources connected to certain electric generators connected to the local or regional power grid) 1 §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-5 Would not reveal any proprietary information about facility or process performance, design, and operation; cost to do business; raw materialusage; or production. Sitespecific fuel characteristics do not vary significantly from publicly-known average values. Additionally for the electric utilities, this sector has experienced a high level of transparency due to the practice of passing fuel costs through to paying customers.

## 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 connected to certain electric generators connected to the local or regional power grid) 1 §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 typesof combustion units, facilitylevel 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 materialusage; or production. Sitespecific fuel characteristics do not vary significantly from publicly-known average values. Additionally for the electric utilities, this sector has experienced a high level of transparency due to the practice of passing fuel costs through to paying customers. C (Stationary fuel combustion

sources connected to certain electric generators connected to the local or regional power grid) 1 §98.36(e)(2)(ix)(D) For units that combust both fossil fuel and biomass, when biogenic CO 2 is determined according to §98.33(e)(2),report the carbon-based 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 materialusage; or production. Sitespecific fuel characteristics do not vary significantly from publicly-known average values. Additionally for the electric utilities, this sector has experienced a high level of transparency due to the practice of passing fuel costs through to paying customers. C (Stationary fuel combustion

sources connected to certain electric generators connected to the local or regional power grid) 1 §98.36(e)(2)(ix)(E) For units that combust both fossil fuel and biomass, when biogenic CO 2 is determined according to §98.33(e)(2), report the annual average HHV value used in Equation C-13 of this subpart. C-13 For facilities with these typesof combustion units, facilitylevel 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 materialusage; or production. Sitespecific fuel characteristics do not vary significantly from publicly-known average values. Additionally for the electric utilities, this sector has experienced a high level of transparency due to the practice of passing fuel costs through to paying customers.

## 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 connected to certain electric generators connected to the local or regional power grid) 1 §98.36(e)(2)(ix)(F) For units that combust both fossil fuel and biomass, when biogenic CO 2 is determined according to §98.33(e)(2), report the total quantity of fossil fuel combusted during the reporting year. C-13 For facilities with these typesof combustion units, facilitylevel 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 materialusage; or production. Sitespecific fuel characteristics do not vary significantly from publicly-known average values. Additionally for the electric utilities, this sector has experienced a high level of transparency due to the practice of passing fuel costs through to paying customers. 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 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 N 2 O abatement technology (located after the test point) is operating (Pz,N) . E-2 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

## 52 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-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) 5 , EFs (as required to be reported in 40 CFR 40 CFR 98.56(j)(1)), and AF (as required to be reported in 40 CFR 98.56(h)). 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) 5 , EFs (as required to be reported in 40 CFR 98.56(j)(1)), and AF (as required to be reported in 40 CFR 98.56(h)). 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.

## 53 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 N 2 O mass emissions from adipic acid production (as currently reported under 40 CFR 98.3(c)(4) and made publicly available) 5 , EFs (as required to be reported in 40 CFR 98.56(j)(1)), the AF (as required to be reported in 40 CFR 98.56(h)), and the fraction control factor (as required to be reported in 40 CFR 98.56(l). 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) 5 , EFs (as required to be reported in 40 CFR 98.56(j)(1)), and the DF (as required to be reported in 40 CFR 98.56(g)). 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.

## 54 Subpart Rule Citation in 40 CFR Part 98 Data Element Description Data Element is used as Input to Equation . . . Analysis Results E §98.56h 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) 5 , EFs (as required to be reported in 40 CFR 98.56(j)(1)), and the DF (as required to be reported in 40 CFR 98.56(g)). 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-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) 5 , EFs (as required to be reported in 40 CFR 98.56(j)(1)), the DF (as required to be reported in 40 CFR 98.56(g)), and the fraction control factor (as required to be reported in 40 CFR 98.56(l). 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.

## 55 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 (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 N 2 O mass emissions from adipic acid production (as currently reported under 40 CFR 98.3(c)(4) and made publicly available) 5 , DF (as required to be reported in 40 CFR 98.56(g)), and AF (as required to be reported in 40 CFR 98.56(h)). 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 N 2 O mass emissions from adipic acid production (as currently reported under 40 CFR 98.3(c)(4) and made publicly available) 5 , DF (as required to be reported in 40 CFR 98.56(g)), and AF (as required to be reported in 40 CFR 98.56(h)). 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.

## 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(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 N 2 O mass emissions from adipic acid production (as currently reported under 40 CFR 98.3(c)(4) and made publicly available) 5 , DFN (as required to be reported in 40 CFR 98.56(g)), AF (as required to be reported in 40 CFR 98.56(h)), and fraction control factor (as required to be reported in 40 CFR 98.56(l). 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 N 2 O mass emissions from adipic acid production (as currently reported under 40 CFR 98.3(c)(4) and made publicly available) 5 is also known. E §98.56(j)(3) Production rate per test run during performance test for each unit (P). E-1 Provides production or raw material data described in section 2.1 of Part Two of this memorandum. E §98.56(j)(4) N 2 O concentration per test run during performance test for each unit (CN2O). E-1 Provides data described in section 2.3 in Part Two of this memorandum that could be used to calculate the mass of adipic acid produced if all of the following data are also known: EFs (as required to be reported in 40 CFR 98.56(j)(1)), volumetric flow rate of effluent gas during the performance test (as required to be reported in 40 CFR 98.56(j)(5)), and number of test runs (as required to be reported in 40 CFR 98.56(j)(6). 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(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 (as required to be reported in 40 CFR 98.56(j)(1)), N 2 O concentration per test run during performance test (as required to be reported in 40 CFR 98.56(j)(4)), and number of test runs (as required to be reported in 40 CFR 98.56(j)(6). 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 (as required to be reported in 40 CFR 98.56(j)(1)), N 2 O concentration per test run during performance test (as required to be reported in 40 CFR 98.56(j)(4)), and volumetric flow rate per test run during performance test (as required to be reported in 40 CFR 98.56(j)(5). 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.

## 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(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. (FC N ) E-3c Provides data described in section 2.3 in Part Two of this memorandum that could be used to calculate the mass of adipic acid produced if all of the following data are also known: annual N 2 O mass emissions from adipic acid production (as currently reported under 40 CFR 98.3(c)(4) and made publicly available) 5 , EFs (as required to be reported in 98.56(j)(1)), DFN (as required to be reported in 40 CFR 98.56), and the abatement utilization factor (as required to be reported in 40 CFR 98.56(h)). 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. 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 cellday. (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 (as required to be reported in 40 CFR 98.66(c)(3) 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) 5 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) 5 are also known.

## 59 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 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 (as required to be reported in 40 CFR 98.66(c)(3)) 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) 5 are also known. 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 (as required to be reported in 40 CFR 98.66(c)(3) 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) 5 are also known. F §98.66(c)(2) Potline overvolta ge. 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) 5 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 (as required to be reported in 40 CFR 98.66(c)(2)) and reported GHG emissions (as currently reported under 40 CFR 98.3(c)(4) and made publicly available) 5 are

## 60 Subpart Rule Citation in 40 CFR Part 98 Data Element Description Data Element is used as Input to Equation . . . Analysis Results 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) 5 are also known. F §98.66(e)(1) Annual anode consumption. (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. (No CEMS) (PC ) 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 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.

## 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(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. 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

## 62 Subpart Rule Citation in 40 CFR Part 98 Data Element Description Data Element is used as Input to Equation . . . Analysis Results 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 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 CO 2 emission factors for each kiln. H-2 Provides data described in section 2.3 of Part Two of this memorandum that could be used to calculate the mass of clinker produced if reported GHG emissions (as currently reported under 40 CFR §98.3(c)(4) and made publicly available) 5 , are also known.

## 63 Subpart Rule Citation in 40 CFR Part 98 Data Element Description Data Element is used as Input to Equation . . . Analysis Results H §98.86(b)(11) Quarterly kiln-specific CKD CO 2 emission factors for each kiln. H-2 Provides data described in section 2.3 in Part Two of this memorandum that could be used to calculate the mass of clinker produced if all of the following data are also known: CKD not recycled to the kiln (as required to be reported in 40 CFR 98.86(b)(5)), CO2 emissions (as currently required to be reported under 40 CFR 98.3(c)(4) and made publicly available) 5 , kiln-specific clinker emission factor (as required to be reported in40CFR 98.86(b)(10)), and kilnspecific CKD emission factor (as required to be reported in 40 CFR 98.86(b)(11)). 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 consumption 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) 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.

## 64 Subpart Rule Citation in 40 CFR Part 98 Data Element Description Data Element is used as Input to Equation . . . Analysis Results K §98.116(b) Annual production by product from each EAF (tons) (used as input to Eq K-3). K-3 Provides production or raw material data described in section 2.1 of Part Two of this memorandum. K §98.116(e)(4) Annual material quantity for each material included for the calculation of annual process CO 2 emissions (No CEMS): Mreducing agenti= Annual mass of reducing agent i fed, charged, or otherwise introduced into the EAF (tons). K-1 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

K §98.116(e)(4) Annual material quantity for each material included for the calculation of annual process CO 2 emissions (No CEMS): Melectrodem= Annual mass of carbon electrode m consumed in the EAF (tons). K-1 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

K §98.116(e)(4) Annual material quantity for each material included for the calculation of annual process CO 2 emissions (No CEMS): Moreh= Annual mass of ore h charged to the EAF (tons). K-1 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

K §98.116(e)(4) Annual material quantity for each material included for the calculation of annual process CO 2 emissions (No CEMS): Mfluxj= Annual mass of flux material j fed, charged, or otherwise introduced into the EAF to facilitate slag formation (tons). K-1 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

K §98.116(e)(4) Annual material quantity for each material included for the calculation of annual process CO 2 emissions (No CEMS): Mnon-product outgoingl= Annual mass of non-product outgoing material l removed from EAF (tons). K-1 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

K §98.116(e)(5) Annual average of the carbon content determinations for each material included for the calculation of annual process CO 2 emissions (No CEMS): Creducing agenti= Carbon content in reducing agent i (percent by weight, expressed as a decimal fraction). K-1 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

## 65 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)(5) Annual average of the carbon content determinations for each material included for the calculation of annual process CO 2 emissions (No CEMS): Celectrodem= Carbon content of the carbon electrode m (percent by weight, expressed as a decimal fraction). K-1 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

K §98.116(e)(5) Annual average of the carbon content determinations for each material included for the calculation of annual process CO 2 emissions (No CEMS): Coreh= Carbon content in ore h (percent by weight, expressed as a decimal fraction). K-1 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

K §98.116(e)(5) Annual average of the carbon content determinations for each material included for the calculation of annual process CO 2 emissions (No CEMS): Cfluxj= Carbon content in flux material j (percent by weight, expressed as a decimal fraction). K-1 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

K §98.116(e)(5) Annual average of the carbon content determinations for each material included for the calculation of annual process CO 2 emissions (No CEMS): Cproductk= 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 CO 2 emissions (No CEMS): Cnon-product outgoingl= Carbon content in non-product 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.

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.

## 66 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) 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.

## 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) 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

## 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)(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

## 69 Subpart Rule Citation in 40 CFR Part 98 Data Element Description Data Element is used as Input to Equation . . . Analysis Results memorandum.

L §98.126(b)(9)(iii) Th e 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 theconcentration of fluorinecontaining 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 by-product (FEBk). L-11 This data element is not addressed because this is a reported emissions value, which is addressed in a separate action related to subpart L of part 98.

## 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)(12) The fraction of the mass emitted that consists of eachfluorine-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 eachfluorine-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. 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. 2L §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

## 71 Subpart Rule Citation in 40 CFR Part 98 Data Element Description Data Element is used as Input to Equation . . . Analysis ResultsL §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. 2L §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. 2L §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. 2L §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. 2L §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. 2L §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

## 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(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 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

## 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) (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 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. (RE D ) L-31 Provides production or raw material data described in section 2.1 of Part Two of this memorandum. L §98.126(h)(2) If applicable, the heel factor calculated for each container size and type. (hfj) L-34 Provides data described in section 2.3 of Part Two of this memorandum that could be used to calculate the number of tanks processed if the emissions from each type of container (as required to be reported in 40 CFR 98.126(h)(1 )) are also known. The number of each type of tank processed and the size of the tanks could provide insight 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 carbonate-based raw material charged to a furnace. N-1 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

## 74 Subpart Rule Citation in 40 CFR Part 98 Data Element Description Data Element is used as Input to Equation . . . Analysis Results 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 averagemass fraction of carbonatebased mineral in carbonatebased 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) 5 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 (G 23 in Eq. O-4). O-4 Provides production or raw material data described in section 2.1 of Part Two of this memorandum. O §98.156(a)(8) Annual mass of any HFC-23 sent off site for sale (S 23 in Eq. O-4). O-4 Provides production or raw material data described in section 2.1 of Part Two of this memorandum. O §98.156(a)(9) Annual mass of any HFC-23 sent off site for destruction (OD 23 used in Eq. O-4). O-4 Provides production or raw material data described in section 2.1 of Part Two of this memorandum. O §98.156(a)(10) Mass of HFC-23 in storage at the beginning of the year (used to calculate I 23 , which is used in Eq. O-4). O-4 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

O §98.156(a)(10) Mass of HFC-23 in storage at the end of the year (used to calculate I 23 , which is used in Eq. O-4). O-4 Provides production or raw material data described in section 2.1 of Part Two of this memorandum. O §98.156(b)(1) Annual mass of HFC-23 fed into the destruction device (FD used in Eq. O-8 and O-9). O-8 Provides production or raw material data described in section 2.1 of Part Two of this memorandum. O §98.156(b)(1) Annual mass of HFC-23 fed into the destruction device (FD used in Eq. O-8 and O-9). O-9 Provides production or raw material data described in section 2.1 of Part Two of this memorandum. O §98.156(b)(2) Annual mass of HFC-23destroyed (D23 used in Eq. O8). O-8 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(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. No Equation - Used to calculate Destruction Efficiency 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, revealinginformation about the HCFC22 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 (as required to be reported in 40 CFR 98.156(d)(1)), flow rate at the outlet of the destruction device (as required to be reported in 40 CFR 98.156(d)(3) (or emission rate as required to be reported in 40 CFR 98.156(d)(4)). If the facility produces HCFC-22 onsite, this HCFC-23 production rate reveals information about process efficiency, revealinginformation about the HCFC22 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.

## 76 Subpart Rule Citation in 40 CFR Part 98 Data Element Description Data Element is used as Input to Equation . . . Analysis Results 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 (as required to be reported in 40 CFR 98.156(d)(5)) is also known. If the facility produces HCFC-22 onsite, this HCFC-23 production rate reveals information about process efficiency, revealinginformation about the HCFC22 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 (as required to be reported in 40 CFR 98.156(d)(5)) is also known. If the facility produces HCFC-22 onsite, this HCFC-23 production rate reveals information about process efficiency, revealinginformation about the HCFC22 production rate. However, if the destruction efficiency were not reported, would not reveal any proprietary information about facility or process performance, design, and operation; cost to do business; raw 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. O-9 Provides information about process efficiency, revealinginformation about the HCFC22 production rate, if the facility produces HCFC-22 onsite. Also, provides data described in section 2.3 of Part Two of this memorandum that could be used to estimate HCFC-23 production if the HCFC-23 production rate is known.

## 77 Subpart Rule Citation in 40 CFR Part 98 Data Element Description Data Element is used as Input to Equation . . . Analysis Results 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, revealinginformation about the HCFC22 production rate. P §98.156(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 §98.156(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 §98.156(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 §98.156(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 §98.156(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 §98.156(b)(5) Monthly analyses of carbon content for each fuel and feedstock used in hydrogen production: Solid. P-3 Provides production or raw material data described in section 2.1 of Part Two of this memorandum. P §98.156(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 quantity taconite pellets produced (No CEMS). Q-1 or the calculation method specified in 98.273(b)(2)(iv)for the sitespecific emission factor method Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

Q §98.176(b) Annual quantity coke produced (No CEMS ). Q-2 or the calculation method specified in 98.273(b)(2)(iv)for the sitespecific emission factor method 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 Q §98.176(b) Annual quantity iron produced (No CEMS). Q-2 or the calculation method specified in 98.273(b)(2)(iv)for the sitespecific emission factor method Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

Q §98.176(b) Annual quantity raw steel produced (No CEMS). Q-2 or the calculation method specified in 98.273(b)(2)(iv)for the sitespecific emission factor method Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

Q §98.176(b) Annua l quantity sinter produced (No CEMS). Q-4 or the calculation method specified in 98.273(b)(2)(iv)for the sitespecific emission factor method Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

Q §98.176(b) Annual quantity raw steel produced (No CEMS). Q-5 or the calculation method specified in 98.273(b)(2)(iv)for the sitespecific emission factor method Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

Q §98.176(b) Annual quantity raw steel produced (No CEMS). Q-6 or the calculation method specified in 98.273(b)(2)(iv)for the sitespecific emission factor method Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

Q §98.176(b) Annual quantity iron produced (No CEMS). Q-7 or the calculation method specified in 98.273(b)(2)(iv)for the sitespecific emission factor method Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

Q §98.176(e)(1) Carbon content of each process input used to determine CO 2 emissions (No CEMS) - solid fuel combusted (Csf). Q-1 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

## 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 CO 2 emissions (No CEMS) -gaseous fuel combusted(C gf ). Q-1 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

Q §98.176(e)(1) Carbon content of each process input used to determine CO 2 emissions (No CEMS)- liquid fuel combusted (C lf ). Q-1 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

Q §98.176(e)(1) Carbon content of each process input used to determine CO 2 emissions (No CEMS)- greenball pellets produced (Co). Q-1 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

Q §98.176(e)(1) Carbon content of each process output used to determine CO2 emissions (No CEMS) - Fired pellets produced (Cp). Q-1 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

Q §98.176(e)(1) Carbon content of each process output used to determine CO 2 emissions (No CEMS) - air pollution control residue collected (Cr). Q-1 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

Q §98.176(e)(1) Carbon content of each process input used to determine CO 2 emissions (No CEMS)- Iron (C iron ). Q-2 Provides production or raw material data described in section 2.1 of Part Two of this memorandum. Q §98.176(e)(1) Carbon content of each process input used to determine CO 2 emissions (No CEMS)- Scrap (C scrap ). Q-2 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

Q §98.176(e)(1) Carbon content of each process input used to determine CO 2 emissions (No CEMS)- Flux (C flux ). Q-2 Provides production or raw material data described in section 2.1 of Part Two of this memorandum. Q §98.176(e)(1) Carbon content of each process input used to determine CO 2 emissions (No CEMS)- Carbonaceous material (C carbon ). Q-2 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

Q §98.176(e)(1) Carbon content of each process output used to determine CO 2 emissions (No CEMS) - Steel produced (C steel ).. Q-2 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

Q §98.176(e)(1) Carbon content of each process output used to determine CO 2 emissions (No CEMS) - Slag produced (C slag ). Q-2 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

Q §98.176(e)(1) Carbon content of each process output used to determine CO 2 emissions (No CEMS) - Air pollution control residue collected (C R ). Q-2 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 CO 2 emissions (No CEMS)- Coal charged to coke battery (C coal ). Q-3 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

Q §98.176(e)(1) Carbon content of each process output used to determine CO 2 emissions (No CEMS) - Coke produced by coke battery (C coke ). Q-3 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

Q §98.176(e)(1) Carbon content of each process output used to determine CO 2 emissions (No CEMS) - Air pollution control residue collected from coke battery (C R ). 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 CO 2 emissions (No CEMS)- Gaseous fuel combusted in the sinter process (C gf ). Q-4 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

Q §98.176(e)(1) Carbon content of each process input used to determine CO 2 emissions (No CEMS) - sinter feed (C Feed ). Q-4 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

Q §98.176(e)(1) Carbon content of each process output used to determine CO 2 emissions (No CEMS) - sinter (C Sinter ). Q-4 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

Q §98.176(e)(1) Carbon content of each process output used to determine CO 2 emissions (No CEMS) - Air pollution control residue collected from sinter process (C R ). Q-4 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

Q §98.176(e)(1) Carbon content of each process input used to determine CO 2 emissions (No CEMS)- Iron (C iron ) used in EAF. Q-5 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

Q §98.176(e)(1) Carbon content of each process input used to determine CO 2 emissions (No CEMS)- Scrap (C scrap ) used in EAF. Q-5 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

Q §98.176(e)(1) Carbon content of each process input used to determine CO 2 emissions (No CEMS)- Flux (C flux ) used in EAF. Q-5 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

Q §98.176(e)(1) Carbon content of each process input used to determine CO 2 emissions (No CEMS)- Carbonaceous material (C carbon ) used in EAF. Q-5 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

## 81 Subpart Rule Citation in 40 CFR Part 98 Data Element Description Data Element is used as Input to Equation . . . Analysis Results Q §98.176(e)(1) Carbon content of each process input used to determine CO 2 emissions (No CEMS)- Electrode consumed in EAF (C electrode ). Q-5 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

Q §98.176(e)(1) Carbon content of each process output used to determine CO 2 emissions (No CEMS) - Steel produced (C steel ) in EAF. Q-5 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

Q §98.176(e)(1) Carbon content of each process output used to determine CO 2 emissions (No CEMS) - Slag produced (C slag ) in EAF. Q-5 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

Q §98.176(e)(1) Carbon content of each process output used to determine CO 2 emissions (No CEMS) - Air pollution control residue collected (C R ) for EAF. Q-5 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

Q §98.176(e)(1) Carbon content of each process input used to determine CO 2 emissions (No CEMS) - molten steel before decarburization (C steelout ) in EAF. Q-6 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

Q §98.176(e)(1) Carbon content of each process output used to determine CO 2 emissions (No CEMS) - molten steel after decarburization (C steelout ) in EAF. Q-6 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

Q §98.176(e)(1) Carbon content of each process output used to determine CO 2 emissions (No CEMS) - Air pollution control residue collected (C R ) for EAF. 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 input used to determine CO 2 emissions (No CEMS) - Gaseous fuel combusted in the direct reduction furnace (F g ) . Q-7 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

Q §98.176(e)(1) Carbon content of each process input used to determine CO 2 emissions (No CEMS) - iron ore or iron ore pellets fed into the direct reduction furnace (C ore ) . Q-7 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

Q §98.176(e)(1) Carbon content of each process input used to determine CO 2 emissions (No CEMS)- Carbonaceous material (C carbon ) used in the direct reduction furnace . Q-7 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

## 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)(1) Carbon content of each process input used to determine CO 2 emissions (No CEMS) - Other materials charged to the direct reduction furnace (C other ). Q-7 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

Q §98.176(e)(1) Carbon content of each process output used to determine CO 2 emissions (No CEMS) - Iron produced from direct reduction furnace (C iron ). Q-7 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

Q §98.176(e)(1) Carbon content of each process output used to determine CO 2 emissions (No CEMS) - Non-metallic materials produced from direct reduction furnace (C NM ). Q-7 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

Q §98.176(e)(1) Carbon content of each process output used to determine CO 2 emissions (No CEMS) - Air pollution control residue collected (C R ) for direct reduction furnace. 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 CO 2 emissions (reported separately for each type in standard cubic feet) (No CEMS) - Taconite Indurating Furnace. Q-1 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

Q §98.176(e)(3) Annual volume of each type of liquid fuel used to determine CO 2 emissions (reported separately for each type in gallons) (No CEMS). 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 other process input used to determine CO 2 emissions (No CEMS)- Annual mass of greenball (taconite) pellets fed into the furnace (O). 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 other process input used to determine CO 2 emissions (No CEMS)- Annual mass of solid fuel combusted (Fs). Q-1 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

Q §98.176(e)(3) Annual mass (in metric tons) of each other process output used to determine CO 2 emissions (No CEMS) - Annual mass of air pollution control residue (R). 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 other process output used to determine CO 2 emissions (No CEMS) - Annual mass of fired pellets produced (P). Q-1 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

## 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 other process input used to determine CO 2 emissions (No CEMS)- Annual mass of molten iron charged to furnace (Iron). 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 other process input used to determine CO 2 emissions (No CEMS)- Annual mass of scrap charged to the furnace (Scrap). Q-2 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

Q §98.176(e)(3) Annual mass (in metric tons) of each other process input used to determine CO 2 emissions (No CEMS)- Annual mass of flux charged to the furnace (Flux). Q-2 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

Q §98.176(e)(3) Annual mass (in metric tons) of each other process input used to determine CO 2 emissions (No CEMS)- Annual mass of carbon (e.g., coal, coke) charged to furnace (Carbon). Q-2 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

Q §98.176(e)(3) Annual mass (in metric tons) of each other process output used to determine CO 2 emissions (No CEMS) - Annual mass of steel produced (Steel). Q-2 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

Q §98.176(e)(3) Annual mass (in metric tons) of each other process output used to determine CO 2 emissions (No CEMS) - Annual mass of slag produced (Slag). Q-2 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

Q §98.176(e)(3) Annual mass (in metric tons) of each other process output used to determine CO 2 emissions (No CEMS) - Annual mass of air pollution control residue collected (Residue). 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 other process input used to determine CO 2 emissions (No CEMS)- Coal charged to battery (Coal). 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 other process output used to determine CO 2 emissions (No CEMS) - Annual mass of coke produced (Coke). Q-3 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

## 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 other process output used to determine CO 2 emissions (No CEMS) - Annual mass of air pollution control residue collected from battery (R). Q-3 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

Q §98.176(e)(3) Annual volume of each type of gaseous fuel used to determine CO 2 emissions (reported separately for each type in standard cubic feet) (No CEMS) - Sinter process (Fg). Q-4 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

Q §98.176(e)(3) Annual mass (in metric tons) of each other process input used to determine CO 2 emissions (No CEMS)- Annual mass of sinter feed material (Feed). 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 other process input used to determine CO 2 emissions (No CEMS)- Annual mass of sinter Produced (Sinter). Q-4 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

Q §98.176(e)(3) Annual mass (in metric tons) of each other process output used to determine CO 2 emissions (No CEMS) - Annual mass of air pollution control residue collected from sinter process (R). 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 other process input used to determine CO 2 emissions (No CEMS)- Annual mass of direct reduced iron charged to the EAF (Iron). Q-5 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

Q §98.176(e)(3) Annual mass (in metric tons) of each other process input used to determine CO 2 emissions (No CEMS)- Annual mass of Scrap charged to the EAF(Scrap). Q-5 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

Q §98.176(e)(3) Annual mass (in metric tons) of each other process input used to determine CO 2 emissions (No CEMS)- Annual mass of flux charged to the EAF(Flux). Q-5 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

Q §98.176(e)(3) Annual mass (in metric tons) of each other process input used to determine CO 2 emissions (No CEMS)- Annual mass of carbon electrode consumed in the EAF(Electrode). Q-5 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 other 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 other process input used to determine CO 2 emissions (No CEMS)- Annual mass of steel produced (Steel) in EAF. Q-5 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

Q §98.176(e)(3) Annual mass (in metric tons) of each other process output used to determine CO 2 emissions (No CEMS) - Annual mass of slag produced (Slag) in EAF. Q-5 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

Q §98.176(e)(3) Annual mass (in metric tons) of each other process output used to determine CO 2 emissions (No CEMS) - Annual mass of air pollution control residue collected (Residue) from 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 other process input used to determine CO 2 emissions (No CEMS)- Annual mass of steel charged to the decarburization vessel (Steel). 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 other process output used to determine CO 2 emissions (No CEMS) - Annual mass of air pollution control residue collected (Residue) from the decarburization vessel. Q-6 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

Q §98.176(e)(3) Annual volume of each type of gaseous fuel used to determine CO 2 emissions (reported separately for each type in standard cubic feet) (No CEMS) - direct reduction furnaces (Fg). Q-7 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

Q §98.176(e)(3) Annual mass (in metric tons) of each other process input used to determine CO 2 emissions (No CEMS)- Annual mass of iron ore or iron ore pellets charged to the direct reduction furnace (Ore). Q-7 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

## 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(e)(3) Annual mass (in metric tons) of each other process input used to determine CO 2 emissions (No CEMS)- Annual mass of carbonaceous (coal or coke) material charged to the direct reduction furnace (Carbon). Q-7 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

Q §98.176(e)(3) Annual mass (in metric tons) of each other process input used to determine CO 2 emissions (No CEMS)- Annual mass of other material charged to the direct reduction furnace (Other). Q-7 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

Q §98.176(e)(3) Annual mass (in metric tons) of each other process input used to determine CO 2 emissions (No CEMS)- Annual mass of iron produced (Iron) in direct reduction furnace. Q-7 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

Q §98.176(e)(3) Annual mass (in metric tons) of each other process input used to determine CO 2 emissions (No CEMS)- Annual mass of non-metallic materials produced (NM) 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 other process output used to determine CO 2 emissions (No CEMS) - Annual mass of air pollution control residue collected (Residue) from 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)(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. Q-4 Provides production or raw material data described in section 2.1 of Part Two of this memorandum. Q §98.176(e)(4) Molecular weight of gaseous fuels (No CEMS) - Direct Reduction Furnace. Q-7 Provides production or raw material data described in section 2.1 of Part Two of this memorandum. Q §98.176(f)(1) Measured average hourly CO 2 emission rate during the test (No CEMS). No Equation - Used as input to method described in §98.173(b)(2)(iii). 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 (as required to be reported in 40 CFR 98.176(f)(3)) 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

## 87 Subpart Rule Citation in 40 CFR Part 98 Data Element Description Data Element is used as Input to Equation . . . Analysis Results production.

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)(iii). 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)(iii). 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)(iv). 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 CO 2 emission rate during the test (as required to be reported in 40 CFR 98.176(f)(1)); or CO2 mass emissions (as currently reported under 40 CFR 98.3(c)(4) and made publicly available) 5

. Q §98.176(f)(4) Annual feed rate used to estimate annual CO 2 emissions (No CEMS). No Equation - Used as input in calc. method described in §98.173(b)(2)(iv). Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

Q §98.176(f)(4) Annual production rate used to estimate annual CO 2 emissions (No CEMS). No Equation - Used as input in calc. method described in §98.173(b)(2)(iv). 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.

## 88 Subpart Rule Citation in 40 CFR Part 98 Data Element Description Data Element is used as Input to Equation . . . Analysis Results R §98.186(b)(6) Annual material quantity used for the calculation of annual process CO 2 emissions (No CEMS) (Ore = Annual mass of lead ore charged to the smelting furnace (tons).) R-1 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

R §98.186(b)(6) Annual material quantity used for the calculation of annual process CO 2 emissions (No CEMS) (Scrap = Annual mass of lead scrap charged to the smelting furnace (tons).) R-1 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

R §98.186(b)(6) Annual material quantity used for the calculation of annual process CO 2 emissions (No CEMS) (Flux = Annual mass of flux materials (e.g., limestone, dolomite) charged to the smelting furnace (tons).) R-1 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

R §98.186(b)(6) Annual material quantity used for the calculation of annual process CO 2 emissions (No CEMS) (Carbon = Annual mass of carbonaceous materials (e.g., coal, coke) charged to the smelting furnace (tons).) R-1 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

R §98.186(b)(6) Annual material quantity used for the calculation of annual process CO 2 emissions (No CEMS) (Other = Annual mass of any other material containing carbon, other than fuel, fed, charged, or otherwise introduced into the smelting furnace (tons).) R-1 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

R §98.186(b)(7) Annual average of the carbon content determinations for each material used for the calculation of annual process CO 2 emissions (No CEMS) (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 CO 2 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.

## 89 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)(7) Annual average of the carbon content determinations for each material used for the calculation of annual process CO 2 emissions (No CEMS). (CFlux= Carbon content of the flux materials, from the carbon analysis (percent by weight, expressed as a decimal fraction).) R-1 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

R §98.186(b)(7) Annual average of the carbon content determinations for each material used for the calculation of annual process CO 2 emissions (No CEMS). (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 CO 2 emissions (No CEMS). (COther= Carbon content of the other material 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.

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 CO 2 process emissions (as currently reported under 40 CFR 98.3(c)(4) and made publicly available) 5 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 CO 2 process emissions (as currently reported under 40 CFR 98.3(c)(4) and made publicly available) 5 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 byproducts/wastes 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.

## 90 Subpart Rule Citation in 40 CFR Part 98 Data Element Description Data Element is used as Input to Equation . . . Analysis Results S §98.196(b)(6) Annual results of chemical composition analysis of each type of lime byproducts/wastes 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. 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 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) 5 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.

## 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(c) Annual nitric acid production from each nitric acid train (tons, 100% acid basis) (Pt). V-3c Provides production or raw material data described in section 2.1 of Part Two of this memorandum. V §98.226(c) Annual nitric acid production from each nitric acid train (tons, 100% acid basis) (Pt). V-3d Provides production or raw material data described in section 2.1 of Part Two of this memorandum. V §98.226(d) Annual nitric acid production during which N 2 O abatement technology is operating (tons, 100% acid basis). V-2 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

V §98.226(i) Abatement technology destruction efficiency (DF). V-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 nitric acid production (as currently reported under 40 CFR 98.3(c)(4) and made publicly available) 5 , EFs (as required to be reported in 40 CFR 98.226(m)(1)) and the abatement utilization factor (as required to be reported in 40 CFR 98.226(j)). 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(i) Abatement technology destruction efficiency (DF). V-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 nitric acid production (as currently reported under 40 CFR 98.3(c)(4) and made publicly available) 5 , EFs (as required to be reported in 40 CFR 98.226(m)(1)) and the abatement utilization factor (as required to be reported in 40 CFR 98.226(j)). 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.

## 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(i) Abatement technology destruction efficiency (DF). V-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 nitric acid production (as currently reported under 40 CFR 98.3(c)(4) and made publicly available) 5 , EFs (as required to be reported in 40 CFR 98.226(m)(1)), the abatement utilization factor (as required to be reported in 40 CFR 98.226(j)), and the fraction control factor (as required to be reported in 40 CFR 98.226(p). 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(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) 5 , EFs (as required to be reported in 40 CFR 98.226(m)(1)), and the destruction efficiency (as required to be reported in 40 CFR 98.226(i)). 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.

## 93 Subpart Rule Citation in 40 CFR Part 98 Data Element Description Data Element is used as Input to Equation . . . Analysis Results V §98.226(j) Abatement utilization factor (AF). V-3b 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) 5 , EFs (as required to be reported in 40 CFR 98.226(m)(1)), and the destruction efficiency (as required to be reported in 40 CFR 98.226(i)). 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(j) Abatement utilization factor (AF). V-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 nitric acid production (as currently reported under 40 CFR 98.3(c)(4) and made publicly available) 5 , EFs (as required to be reported in 40 CFR 98.226(m)(1)), destruction efficiency (as required to be reported in 40 CFR 98.226(i)), and the fraction control factor (as required to be reported in 40 CFR 98.226(p). 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.

## 94 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-3a Provides data described in section 2.3 of 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) 5

, destruction efficiency (as required to be reported in 40 CFR 98.226(i)), and abatement utilization factor (as required to be reported in 40 CFR 98.226(j)). However, if the destruction efficiency or abatement utilization 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. V §98.226(m)(1) Emission factor calculated for each nitric acid train (EFN2Ot). V-3b Provides data described in section 2.3 of 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) 5

, destruction efficiency (as required to be reported in 40 CFR 98.226(i)), and abatement utilization factor (as required to be reported in 40 CFR 98.226(j)). However, if the destruction efficiency or abatement utilization 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.

## 95 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 Provides data described in section 2.3 of 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) 5

, destruction efficiency (as required to be reported in 40 CFR 98.226(i)), abatement utilization factor (as required to be reported in 40 CFR 98.226(j)), and fraction control factor (as required to be reported in 40 CFR 98.226(p)). However, if the destruction efficiency or abatement utilization 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. V §98.226(m)(1) Emission factor calculated for each nitric acid train (EFN2Ot). V-3d Provides data described in section 2.3 of Part Two of this memorandum that could be used to calculate the mass of nitric acid produced if the annual N2O mass emissions from nitric acid production (as currently reported under 40 CFR 98.3(c)(4) and made publicly available) 5 is also known. 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. V §98.226(m)(4) N 2 O concentration per test run during performance test for 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 (as required to be reported in 40 CFR 98.226(m)(1)), volumetric flow rate of effluent gas during the performance test (as required to be reported in 40 CFR 98.226(m)(5)), and number of test runs (as required to be reported in 40 CFR 98.226(m)(6). 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.

## 96 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)(5) Volumetric flow rate per test run 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 the all following data are also known: EFs (as required to be reported in 40 CFR 98.226(m)(1)), N 2 O concentration per test run during performance test (as required to be reported in 40 CFR 98.226(m)(4)), and number of test runs (as required to be reported in 40 CFR 98.56(m)(6). 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)(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 (as required to be reported in 40 CFR 98.226(m)(1)), N 2 O concentration per test run during performance test (as required to be reported in 40 CFR 98.226(m)(4)), and volumetric flow rate per test run during performance test (as required to be reported in 40 CFR 98.226(m)(5). 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.

## 97 Subpart Rule Citation in 40 CFR Part 98 Data Element Description Data Element is used as Input to Equation . . . Analysis Results 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 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: annual N2O mass emissions from adipic acid production (as currently reported under 40 CFR 98.3(c)(4) and made publicly available) 5 , EFs (as required to be reported in 40 CFR 98.226(m)(1)), destruction efficiency (as required to be reported in 40 CFR 98.226(i)), and the abatement utilization factor (as required to be reported in 40 CFR 98.226(j)). 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. X-1 Provides data related to production/raw materials, process design; process performance, and operation; and/or cost to do business, as described in sections 2.1 and 2.2 of Part Two of this memorandum. Specifically, indicates whether the concentration of a specific compound in a feedstock, byproduct, or product of a petrochemical process is greater than 99.5%. X §98.246(a)(4) Monthly volume values (used in Equations X-1 to X-3) - Volume of gaseous feedstock I introduced in month "n" ((F gf ) n). X-1 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

X §98.246(a)(4) Monthly volume values (used in Equations X-1 to X-3) - Volume of gaseous product i produced in month "n" ((P gf ) n) X-1 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

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.

## 98 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) Molecular weights for gaseousproducts (used in Equation X1). 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. 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" ((F lf ) n ). X-2 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

X §98.246(a)(4) Monthly volume values (used in Equations X-1 to X-3) - Volume of liquid product i for month "n" ((P lp ) n ) . X-2 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

X §98.246(a)(4) Monthly mass values (used in Equations X-1 to X-3) - Mass of liquid feedstock i for month "n" ((F lf ) n ). X-2 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

X §98.246(a)(4) Monthly mass values (used in Equations X-1 to X-3) - Mass of liquid product i for month "n" ((P lp ) n ). X-2 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

X §98.246(a)(4) Monthly carbon content values (used in Equations X-1 to X-3) - Average carbon content of the liquid feedstock i for month "n" ((CC lf )n). X-2 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

X §98.246(a)(4) Monthly carbon content values (used in Equations X-1 to X-3) - Average carbon content of the liquid product i for month "n" ((CClp)n). X-2 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

X §98.246(a)(4) Indicate whether you used the alternative to sampling and analysis. 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%.

## 99 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 mass values (used in Equations X-1 to X-3) - Mass of solid feedstock I for month "n" ((F sf ) n ). X-3 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

X §98.246(a)(4) Monthly mass values (used in Equations X-1 to X-3) - Mass of solid product i for month "n" ((P sp ) n ). X-3 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

X §98.246(a)(4) Monthly carbon content values (used in Equations X-1 to X-3) - Average carbon content of the solid feedstock i for month "n" ((CC lf )n). X-3 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

X §98.246(a)(4) Monthly carbon content values (used in Equations X-1 to X-3) - Average carbon content of the solid product i for month "n" ((CClp)n). X-3 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

X §98.246(b)(5)(iii) Quantity of each type of fuel used in equation C-8 in §98.33(c) for each stationary combustion unit or group of units (as applicable) during the reporting year, expressed in short tons for solid fuels, gallons for liquid fuels, and scf for gaseous fuels. C-8 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

X §98.246(b)(5)(iv) The HHV (either default or annual average from measured data) used in equation C-8 in §98.33(C) for each stationary combustion unit or group of units (as applicable). C-8 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

Y §98.256(e)(6) If using Equation Y-1a: report the molar volume conversion factor (in scf/g-mole) for each flare. Y-1a Would not reveal any proprietary information about facility or process performance, design, and operation; cost to do business; raw material usage; or production. Is a constant value widely known within the industry and publicly available. Y §98.256(e)(7) If using Equation Y-1b: report molar volume conversion factor for each flare. Y-1b Would not reveal any proprietary information about facility or process performance, design, and operation; cost to do business; raw material usage; or production. Is a constant value widely known within the industry and publicly available. Y §98.256(e)(7)(ii) If using Equation Y-1b: report the carbon mole number of each carbon containing compound other than CO 2 in the flare gas stream for each flare. Y-1b Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

## 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(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 (all required to be reported under 40 CFR 98.256(e)(9)). 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 (all required to be reported under 40 CFR 98.256(e)(9)). This information could reveal information on the performance and operation of process units. Y §98.256(e)(9) Volume of gas flared during SSM event. 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 (SSM). 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 (all required to be reported under 40 CFR 98.256(e)(9)).

## 101 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 (SSM). 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 (all required to be reported under 40 CFR 98.256(e)(9)). 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 CO 2 mass emissions (as currently required to be reported under 40 CFR 98.252(b) and made publicly available) 5 , 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.

## 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(f)(11) If you use a unit-specific emission factor for CH4: report the unit-specific emission factor for CH4 each catalytic cracking units, traditional fluid coking units, and catalytic reforming units. 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 N 2 O emissions (as currently required to be reported under 40 CFR 98.252(e) and made publicly available) 5 are also known.Y §98.256(f)(11) Units of measure for the unitspecific CH 4 emission factor. Used in method specified in §98.253(c)(4) Would not reveal any proprietary information about facility or process performance, design, and operation; cost to do business; raw material usage; or production. Provides only the units of measure for the emission factor. Y §98.256(f)(11) Activity data for calculating emissions (input). Used in method specified in §98.255(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 §98.255(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 §98.255(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 §98.255(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 required to be reported under 40 CFR §98.252(e) and made publicly available) 5 are also known.Y §98.256(f)(12) Units of measure for the unitspecific N 2 O emission factor. Used in method specified in 9§8.253(c)(5) Would not reveal any proprietary information about facility or process performance, design, and operation; cost to do business; raw material usage; or production. Provides only the units of measure for the emission factor. Y §98.256(f)(13) Average carbon content of coke. Y-11 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

## 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(h)(4) If Equation Y-12 is used: report the molar volume conversion factor. 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. Y §98.256(h)(4) If Equation Y-12 is used: Annual volumetric flow to the sulfur recovery plant. 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. 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 (if used to calculate recycling correction factor). If a correction for CO2 emissions in the tail gas was used in Eq. Y-12, used in method specified in §98.253(f)(5) Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

Y §98.256(h)(5) Annual average mole fraction of carbon in the tail gas (if used to calculate recycling correction factor). If a correction for CO2 emissions in the tail gas was used in Eq. Y-12, used in method specified in §98.253(f)(5) Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

Y §98.256(h)(5) Value of the correction. If a correction for CO2 emissions in the tail gas was used in Eq. Y-12, used in method specified in §98.253(f)(5) Would not reveal any proprietary information about facility or process performance, design, and operation; cost to do business; raw material usage; or production. Provides only information about quantity of carbon in tail gas recycled to the sulfur recovery plant. Y §98.256(i)(5) If you use Eq. Y-13, report the annual mass of green coke fed to the 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 green coke fed to the 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 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.

## 104 Subpart Rule Citation in 40 CFR Part 98 Data Element Description Data Element is used as Input to Equation . . . Analysis Results 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 collected in 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 2.1 of Part Two of this memorandum.Y §98.256(i)(7) For coke calcining: The unitspecific CH 4 emission factor. Used in method specified in §98.253(c)(4) Provides data described in section 2.3 of Part Two of this memorandum that could be used to calculate either production or raw material consumption (depending on whether the facility uses an emission factor based on production throughput or raw material consumption) if the CH 4 emissions (as currently required to be reported under 40 CFR 98.252(e) and made publicly available) 5 are also known. Y §98.256(i)(7) For coke calcining: Units of measure for the unit-specific CH 4 emission factor. Used in method specified in §98.253(c)(4) Would not reveal any 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. 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 forN2O was used, report the sitespecific 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 N 2 O emissions (as currently required to be reported under 40 CFR 98.252(e) and made publicly available) 5 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

## 105 Subpart Rule Citation in 40 CFR Part 98 Data Element Description Data Element is used as Input to Equation . . . Analysis Results the emission factor.

Y §98.256(j)(2) Quantity of asphalt blown for each 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 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 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 for each asphalt blowing unit. Y-16b 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 for each asphalt blowing unit. Y-17 Provides production or raw material data described in section 2.1 of Part Two of this memorandum. Y §98.256(j)(5) CO 2 emission factor for each asphalt blowing unit. Y-14 Provides data described in section 2.3 of Part Two of this memorandum that could be used to calculate the annual asphalt production if the CO 2 emissions (as currently required to be reported under 40 CFR 98.252(f) and made publicly available) 5 are also known. Y §98.256(j)(6) CH 4 emission factor for each asphalt blowing unit. Y-15 Provides data described in section 2.3 of Part Two of this memorandum that could be used to calculate the annual asphalt production if the CH 4 emissions (as currently required to be reported under 40 CFR 98.252(f) and made publicly available) 5 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 CO 2 emissions (as currently required to be reported under 40 CFR 98.252(f) and made publicly available) 5 are also known. Y §98.256(j)(8) If Equation Y-16b is used: report the CO 2 emission factor used. Y-16b Provides data described in section 2.3 of Part Two of this memorandum that could be used to calculate the annual asphalt production if both the CO 2 emissions (as currently required to be reported under 40 CFR 98.252(f) and made publicly available) 5 and the carbon emission factor “CEF AB ” (required to be

## 106 Subpart Rule Citation in 40 CFR Part 98 Data Element Description Data Element is used as Input to Equation . . . Analysis Results reported under 40 CFR 98.256(j)(8)) 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 CO 2 emissions (as currently required to be reported under 40 CFR 98.252(f) and made publicly available) 5 and the CO 2 emission factor “EF AB,CO2 ” (required to be reported under 40 CFR 98.256(j)(8)) are also known. Additionally, if the uncontrolled emissions represented by the CO 2 emission factor “EF AB,CO2 ” are very low, could estimate annual asphalt production if only this carbon factor and the CO 2 emissions are known. Y §98.256(j)(9) If you use Eq. Y-17: CH 4 emission factor. Y-17 Provides data described in section 2.3 of Part Two of this memorandum that could be used to calculate the annual asphalt production if the CO 2 emissions (as currently required to be reported under 40 CFR 98.252(f) and made publicly available) 5 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.

## 107 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)(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 delayed coking units: 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 delayed coking units: 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. Y §98.256(k)(4) For delayed coking units: 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 delayed coking units: 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.

## 108 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 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 required to be reported under 40 CFR 98.252(f) and made publicly available) 5 , cumulative number of vessel openings for all delayed coking drums in the set (as required to be reported in 40 CFR 98.256(k)(4), height and diameter of the coking vessel (as required to be reported in 40 CFR 98.256(k)(4), typical venting pressure (as required to be reported in 40 CFR 98.256(k)(4), and the void fraction (as required to be reported in 40 CFR 98.256(k)(4). 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. Y §98.256(m)(3) Uncontrolled blowdown systems reporting under §98.253 (k): CH 4 emission factor used. Y-20 Provides data described in section 2.3 of Part Two of this memorandum that could be used to calculate the quantity of crude oil and intermediate products received from offsite if the CO 2 emissions (as currently required to be reported under 40 CFR 98.252(g) and made publicly available) 5 are also known.

## 109 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): Molar volume conversion factor. Y-20 Would not reveal any proprietary information about facility or process performance, design, and operation; cost to do business; raw material usage; or production. Is a constant value widely known within the industry and publicly available. Y §98.256(m)(3) Uncontrolled blowdown systems reporting under §98.253 (k): Total quantity of crude oil plus the quantity of intermediate products received from off-site that are processed at the facility in the reporting year. Y-20 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

Y §98.256(n)(3) For equipment leaks: Number of each type of emission source listed in Equation Y-21 (if using Eq. Y-21). Y-21 Would not reveal any proprietary information about facility or process performance, design, and operation; cost to do business; raw material usage; or production. These data (e.g., types of units, number of units) are already generally publicly available in permits and permit applications, such that these reported data would not reveal any additional information. Y §98.256(o)(2)(ii) Total qua ntity 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 (required to be reported under 40 CFR 98.252(g)) and the tank-specific methane composition data (required to be reported under 40 CFR 98.256(o)(4)(v)) are also

## 110 Subpart Rule Citation in 40 CFR Part 98 Data Element Description Data Element is used as Input to Equation . . . Analysis Results known.

Y §98.256(o)(4)(iv) For storage tanks that process unstabilized crude oil: Molar volume conversion factor.. Y-23 Would not reveal any proprietary information about facility or process performance, design, and operation; cost to do business; raw material usage; or production. Is a constant value widely known within the industry and publicly available. Y §98.256(o)(4)(v) For storage tanks that process unstabilized crude oil: Average Mole fraction of CH 4 in vent gas from the unstabilized crude oil storage tanks. Y-23 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

Y §98.256(o)(4)(vi) If you did not use Equation Y23: report the gas generation rate 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) 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.. 3

Y §98.256(o)(4)(vi) If you did not use Equation Y23: 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. 3

Y §98.256(o)(6) Mole fraction of CH 4 in vent gas from the unstabilized crude oil storage tank. Y-23 See analysis for 40 CFR 98.256(o)(4)(v). 4

Y §98.256(o)(6) Average pressure differential. Y-23 See analysis for 40 CFR 98.256(o)(4)(iii). 4

## 111 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)(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. 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). 4

Y §98.256(o)(7) Gas generation ra te data. Used in methods specified in §98.253(m)(2) See analysis for 40 CFR 98.256(o)(4)(vi). 4

Y §98.256(p)(2) For loading operations: Quantity of materials loaded by vessel type that have an equilibrium vapor-phase concentration of CH 4 of 0.5 volume percent or greater. Used in methodsspecified 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 CO 2 (ton CO 2 /ton of phosphate rock) for which Equation Z-1b is used (No CEMS). Z-1b Provides data described in section 2.3 of Part Two of this memorandum that could be used to calculate the amount of phosphate rock consumed if the N 2 O emissions (as currently reported under 40 CFR 98.3(c)(4) and made publicly available) 5 are also known. Z §98.266(f)(6) Monthly mass of phosphate rock consumed by origin in production. Z-1a Provides production or raw material data described in section 2.1 of Part Two of this memorandum. Z §98.266(f)(6) Monthly mass of phosphate rock consumed by origin in production. Z-1b Provides production or raw material data described in section 2.1 of Part Two of this memorandum. AA §98.276(b) Annual quantities of fossil fuels used in chemical recovery furnaces. C-1 Provides production or raw material data described in section 2.1 of Part Two of this memorandum. AA §98.276(b) Annual quantities of fossil fuels used in chemical recovery furnaces. C-1a Provides production or raw material data described in section 2.1 of Part Two of this memorandum. AA §98.276(b) Annual quantities of fossil fuels used in chemical recovery furnaces. C-1b Provides production or raw material data described in section 2.1 of Part Two of this memorandum. AA §98.276(b) Annual quantities of fossil fuels used in chemical recovery furnaces. C-2a Provides production or raw material data described in section 2.1 of Part Two of this memorandum. AA §98.276(b) Annual quantities of fossil fuels used in chemical recovery furnaces. C-3 Provides production or raw material data described in section 2.1 of Part Two of this memorandum. AA §98.276(b) Annual quantities of fossil fuels used in chemical recovery combustion units. C-4 Provides production or raw material data described in section 2.1 of Part Two of this

## 112 Subpart Rule Citation in 40 CFR Part 98 Data Element Description Data Element is used as Input to Equation . . . Analysis Results memorandum.

AA §98.276(b) Annual quantities of fossil fuels used in chemical recovery combustion units. C-5 Provides production or raw material data described in section 2.1 of Part Two of this memorandum. AA §98.276(b) Annual quantities of fossil fuels used in chemical recovery 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 or site specific emission factor for CO 2 used in equation AA-1. AA-1 Provides data described in section 2.3 of Part Two of this memorandum that could be used to calculate the mass of spent liquor solids combusted if the following data are also known: CO2 emissions (as currently reported under 40 CFR 98.3(c)(4) and made publicly available) 5 and HHV (as required to be reported in 40 CFR 98.276(d). 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.

## 113 Subpart Rule Citation in 40 CFR Part 98 Data Element Description Data Element is used as Input to Equation . . . Analysis Results AA §98.276(e) Default or site specific emission factor for CH 4 used in equation AA-1. AA-1 Provides data described in section 2.3 of Part Two of this memorandum that could be used to calculate the mass of spent liquor solids combusted if the following data are also known: CH4 emissions (as currently reported under 40 CFR 98.3(c)(4) and made publicly available) 5 and HHV (as required to be reported in 40 CFR 98.276(d). 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 or site specific emission factor for N 2 O used in equation AA-1. AA-1 Provides data described in section 2.3 of Part Two of this memorandum that could be used to calculate the mass of spent liquor solids combusted if the following data are also known: N2O emissions (as currently reported under 40 CFR 98.3(c)(4) and made publicly available) 5 and HHV (as required to be reported in 40 CFR 98.276(d). 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.

## 114 Subpart Rule Citation in 40 CFR Part 98 Data Element Description Data Element is used as Input to Equation . . . Analysis Results AA §98.276(g) Annual quantities of fossil fuels used in pulp mill lime kilns. C-5 Provides production or raw material data described in section 2.1 of Part Two of this memorandum. AA §98.276(g) Annual quantities of fossil fuels used in pulp mill lime kilns. C-8 Provides production or raw material data described in section 2.1 of Part Two of this 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 CaCO 3 used for the reporting year used in Equation AA-3. AA-3 Provides production or raw material data described in section 2.1 of Part Two of this memorandum. AA §98.276(i) Make-up quantity of Na 2 CO 3 used for the reporting year used in Equation AA-3. AA-3 Provides production or raw material data described in section 2.1 of Part Two of this memorandum. BB §98.286(b)(1) Monthly consumption of petroleum coke (No CEMS). BB-2 Provides production or raw material data described in section 2.1 of Part Two of this memorandum. BB §98.286(b)(4) Carbon content factor of petroleum coke from the supplier or as measured by the applicable method. BB-1 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

BB §98.286(b)(6) CO 2 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 CO 2 emissions (as currently reported under 40 CFR 98.3(c)(4) and made publicly available) 5 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-1 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-2 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

## 115 Subpart Rule Citation in 40 CFR Part 98 Data Element Description Data Element is used as Input to Equation . . . Analysis Results CC §98.296(b)(10)(i) Stack gas volumetric flow rate during performance test (dscfm) for each manufacturing line or stack. CC-3 Provides information about the exhaust gas flow rate during the performance test and would not reveal any proprietary information about facility or process performance, design, and operation; cost to do business; raw material usage; or production. CC §98.296(b)(10)(ii) Hourly CO 2 concentration during performance test (percent CO 2 ) for each manufacturing line or stack. CC-3 Provides information about the CO 2 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) CO 2 emission factor of process vent flow from mine water for each manufacturing line or stack. CC-5 Does not include, and could not be used to calculate, data or information (about facility or process performance, design, and operation; cost to do business; raw material usage; or production) that would reveal information that could cause competitive harm. CC §98.296(b)(10)(iv) CO 2 emission mass emission rate during performance test (metric tons/hour) for each manufacturing line or stack. CC-4 Would not reveal any proprietary information about facility or process performance, design, and operation; cost to do business; raw material usage; or production. Data cannot be used to calculate the annual production or raw material consumption since the production and raw material usage during the performance test is not reported. CC §98.296(b)(10)(v) Average process vent flow from mine water stripper/evaporator during performance test for each manufacturing line or stack. CC-4 Would not reveal any proprietary information about facility or process performance, design, and operation; cost to do business; raw material usage; or production. Data cannot be used to calculate annual production or raw material consumption since the 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. Could be used to calculate hours of operation if the average process vent flow rate measured during the performance test (reported under 40 CFR 296(b)(10)(v)) is known; however, hours of operation cannot be used to

## 116 Subpart Rule Citation in 40 CFR Part 98 Data Element Description Data Element is used as Input to Equation . . . Analysis Results calculate production since the production rate 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.

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.

## 117 Subpart Rule Citation in 40 CFR Part 98 Data Element Description Data Element is used as Input to Equation . . . Analysis ResultsGG §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 fraction) (No CEMS) - other carbonaceous materials. GG-1 Provides production or raw material data described in section 2.1 of Part Two of this memorandum.

GG §98.296(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.

## 118 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)(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. 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 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 if the amount of waste disposed of in the landfill (reported under 40 CFR 98.466(d)(2) is also known.

1 Stationary fuel combustion sources connected to certain electric generators connected to the local or regional power grid include stationary fuel combustion sources (e.g., individual units, aggregations of units, common pipes, or common stacks) subject to subpart C of Part 98 that

meet the following criteria: (1) the stationary fuel combustion source contains at least one combustion unit connected to a fuel

‐ fired electric generators that has been granted access by the Public Utilities Commission to deliver power to the local or regional electric power grid (excluding electric generators that are connected to combustion units subject to subpart D of Part 98); and (2) the stationary fuel combustion

source is located at a facility for which the sum of the nameplate capacities for all such electric generators is greater than or equal to 1 megawatt electric output.

2 These results are based on the existing subpart L rule (e.g., requires process

‐ specific, chemical specific reporting at 40 CFR 98.126(a)(2)), which

may be amended in a future separate action related to subpart L of Part 98.

3 EPA's intent has been to require reporting of this data element in units of scf per year, which EPA clarified in an April 2, 2013 action (78 FR 19802.)

4 EPA proposed in an April 2, 2013 action (78 FR 19802) to remove this provision because it is redundant to a provision specified in 40 CFR 98.256(o)(4)(iii)

‐ (vi). If this proposed change is finalized, then the specified potential harm would no longer apply.

5 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."