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 referred to as “’inputs to equations’ data 

elements”) until March 31, 2015, The EPA expressed its intent to further evaluate the “inputs to 

equations” data elements to determine which, if any, could result in competitive harm if made 

publicly available. The EPA outlined a four-step process for this evaluation in the final rule and 

in a supporting memorandum entitled “Process for Evaluating and Potentially Amending Part 98 

Inputs to Emission Equations” (docket EPA-HQ-OAR-2010-0929). 

The purpose of this memorandum is to describe the 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 Program (GHGRP) with “inputs to equations.” 1 

This analysis of competitive harm includes: 

 Part One: An evaluation of the current market structures for sectors required to report 

“inputs to equations” data elements, to determine whether conditions exist within the 

market structures such that the release of the data could result in competitive harm, and 

 Part Two: For those sectors for which the market structure analysis determined that 

reporting of the “inputs to equations” data elements could result in competitive harm, an 

evaluation of each individual “inputs to equations” data elements to determine whether its 

release would be likely to cause competitive harm. 

                                                           

1 The review was not conducted for 2015 data inputs in subpart I because reporting of the “inputs to equations” data elements for 

that subpart was addressed in a separate proposed action [see 77 FR 63538]. Additionally, the evaluation of the subpart C 

“inputs to equations” in this memorandum encompasses the one subpart A “input to equation” data element. As a result, the 

one subpart A “input to equation” is not listed explicitly in this memorandum. 
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The EPA’s evaluation of current market structures is presented in Part One of this memorandum. 

For all sectors in which the market structure analysis summarized in Part One determined that 

the conditions exist within the market such that firms could use released “inputs to equations” 

data elements to gain a competitive advantage, the EPA proceeded to evaluate each individual 

“inputs to equations” data element. Part Two of this memorandum presents an evaluation of 

each individual “inputs to equations” data element to determine whether potential release would 

be likely to cause substantial competitive harm. 

 
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Part 1: Evaluation of Market Structures 

1.0 Introduction 

The following section describes the overall process used to assess the market structures that exist 

within the different subparts of 40 CFR part 98 with “inputs to equations” data elements, to 

determine whether conditions exist within the market such that competitive harm could occur 

should “inputs to equations” data elements be released to the public. Section 2.0 summarizes the 

connection between market structure and the potential for information to cause competitive 

harm. Section 3.0 presents the process used for the assessment. Section 4.0 presents the results of 

the market structure assessment for each subpart evaluated. Section 5.0 presents a summary of 

the overall results of this analysis.

2.0 Importance of Market Structure 

Market structure affects firms’ ability to use information about other firms in their market. 

Market structure is defined in terms of the number of firms supplying a commodity in the 

market, and the degree of control that individual firms have over the price they obtain for their 

product. The market, in turn, is defined in terms of the commodity marketed and the geographic 

scope of the market. 

Competitive markets are characterized by many suppliers and products that are identical or 

nearly identical, in terms of product characteristics that users value. In such markets, firms are 

“price takers”; that is, they are unable to influence the market price, and must determine their 

profit-maximizing production level as a function of the price set by the market. In such markets, 

strategic behavior is not possible because there are too many competitors, making it impossible 

for them to make decisions based on their competitors’ actions, and thereby affect market price. 

Thus, for firms to be able to use information either to cause competitive harm or to coordinate 

their pricing with competitors, the number of firms in the market must be small enough that 

firms can identify their competitors, and identify critical information about their competitors’ 

operations. Markets with a relatively small number of firms are termed "concentrated." 

In the following section, we describe methods for assessing whether markets are concentrated. 

We then examine several sectors covered by the GHGRP, to determine their level of 

concentration. 

3.0 Process for Assessing Market Structures and Potential for Competitive Harm 

Economists assess market concentration using measures that characterize the share of the market 

served by the largest firms. Specific tools used include the Herfindahl-Hirschman Index (HHI). 
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For a given market, the HHI is calculated by squaring the market share of each firm competing in 

the market, then summing the squared shares. 

HHI = isi

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

Potential values of the HHI range from near zero (if each of the top 50 firms has one-50th 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 smaller the number of firms in the market and (2) 

the greater the disparity in size between the firms. The U.S. Department of Justice (DOJ) and the 

Federal Trade Commission (FTC)2 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 considered 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 process level because customers make purchasing 

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

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

competitors, and thus subparts for which revealing sensitive information would have the 

potential to lead to competitive harm, it is not the only indicator that a market may have the 

potential to lead to competitive harm should sensitive information be released. Some sectors 

(defined at the 6-digit NAICS code level) that are not concentrated at the national sector level 

may produce some products for which there are sufficiently few firms producing the product that 

they are aware of each other’s operations and may behave strategically. In these cases, 

publication of some data could result in either reduced competition or competitive harm. 

Similarly, some products are traded in regional, rather than national markets; for these, even if 

the sector does not appear concentrated or moderately concentrated at the national level based 

upon its HHI, regional markets, which have fewer firms on the supply side compared to the 

national sector, may be concentrated. In addition, some NAICS may include multiple industry 

sectors, only one of which is covered by a subpart. If this is the case, the industry sector may 

have concentrated or moderately concentrated markets even if the overall NAICS is not 

concentrated or moderately concentrated. As a result, for subparts for which the national-level 

NAICS assessment indicates that the sector may be unconcentrated, the EPA performed 

additional assessments. 

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

                                                           

2 Department of Justice. Use of HHI. http://www.justice.gov/atr/public/divisionmanual.html , and Federal Trade Commission 

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

http://www.ftc.gov/opa/2004/08/oilmergersrpt.shtm

3 Census Bureau. Economic Census, Concentration Ratios, 2007. http://www.census.gov/econ/concentration.html
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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 subpart, and not all NAICS are in the same 

concentration category, the EPA determined whether a majority of the facilities reported 

concentrated or moderately concentrated NAICS. 

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

facilities report under unconcentrated NAICS, the EPA determined whether: 

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

b. The NAICS is broader than the affected market, or there are sub-sector markets 

within a sector, such as markets for specialty products. 

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

EPA examined the market itself (either regional or sub-sector/product-specific) to determine if it 

is concentrated or moderately concentrated. If the EPA found that none of the above criteria is 

true for a subpart, the EPA determined that the market is unconcentrated, and that the risk of 

competitive harm or diminished competition resulting from the release of “inputs to equations” 

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

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

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

proceeded to evaluate each “inputs to equations” data 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 (Combustion), II (Industrial Wastewater Treatment), and TT 

(Industrial Landfills), the subparts represent a process that may take place at facilities in a 

number of industry sectors. Another subpart, subpart U (Miscellaneous Uses of Carbonates), also 

includes a variety of industry sectors. The markets in which these facilities compete, and for 

which concentration must be assessed, are the markets for the goods or services they produce. To 

evaluate the concentration in these markets, therefore, the EPA identified the NAICS codes for 

the industry sectors reported by these facilities, and examined their concentration. 

For sectors that did not have manufacturing NAICS codes, subparts W (Petroleum and Natural 

Gas Systems) and CC (Soda Ash), HHI values were not available. As a result, the EPA 

conducted a qualitative analysis of the market structure. 

4.0 Results of Analysis 

The EPA calculated HHI values using NAICS codes reported by facilities for reporting year 

2011. For the 27 subparts for which this analysis was conducted, the EPA identified 296 unique 

NAICS codes that facilities reported. Of these 296, 200 are manufacturing sector NAICS codes, 
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for which HHI information is compiled by the Census Bureau. Subparts CC and W4 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 concentration at the regional, 

product, or process level. Section 4.3 presents the results of the analysis of subparts representing 

processes from many Sectors (i.e., subparts C, U, II, and TT). Section 4.4 presents the results of 

the analysis of non-manufacturing Sectors (i.e., subparts W and CC). 

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

To begin its assessment of the potential for the release of the “inputs to equations” data elements 

to lead to reduced competition or competitive harm, the EPA determined the level of sector 

concentration at the national NAICS code level. If the EPA determined that the NAICS code 

identified by a majority of firms in a subpart is concentrated or moderately concentrated at the 

national NAICS code level, the EPA concluded that the firms in the subpart are likely are aware 

of each other’s actions. The EPA focused its assessment on the 200 manufacturing sector NAICS 

codes associated with GHG reporting facilities. 

Appendix A lists concentration ratios for the 6-digit NAICS codes cited by facilities, as well as 

values of the Herfindahl-Hirschman Index (HHI) published by the U.S. Census Bureau for 

affected manufacturing NAICS codes. In addition, Appendix A presents information about the 

number of reporting facilities in a subpart that identified each NAICS. This information allowed 

the EPA to identify which NAICS codes within a subpart represent the majority of reporting 

facilities.5 

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

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

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

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

rest of this document, the EPA refers to such subparts as concentrated or moderately 

concentrated. Using this criterion, the EPA found that the following subparts are at least 

moderately concentrated based on the NAICS codes associated with them: subparts F, G, L, N, 

O, S, V, Z, AA, BB, and EE. As a result, the EPA further evaluated these subparts by examining 

individual data elements to determine if harm would be likely to occur. Refer to the Part 2 of this 

memorandum for this evaluation. 

                                                           

4 Three of the 1,549 facilities reporting under subpart W in 2011 reported manufacturing NAICS codes. See section 4.4 for 

further discussion. 

5 Some facilitiesreported multiple NAICS; thus, facilities may be counted several times within a subpart, and the sum of NAICS 

cited by facilities within a subpart may exceed the number of facilities reporting under that subpart. 
7

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 for the goods they produce were examined to 

determine if the markets for some or all of the goods are concentrated within a particular NAICS, 

or if the goods are traded in regional markets, which would have fewer firms than the national 

markets and thus are more likely to be concentrated; see the analysis below. 

Subpart E, Adipic Acid Producers. Production of adipic acid falls under NAICS 325199, All 

Other Basic Inorganic Chemical Manufacturing; this is a very broad NAICS code, encompassing 

production of many different inorganic chemicals. Adipic acid production is a small subset of the 

overall NAICS. Thus, the EPA examined adipic acid producers specifically, rather than relying 

on a NAICS-level assessment. Three facilities reported under subpart E for Reporting Year 2011. 

Even without firm-level data, the HHI is useful because with only three plants, the lowest value 

the HHI could have is 3,267.6 Because this source category does not have a threshold for 

applicability, all adipic acid producers in the U.S. are reporting under the GHGRP. Thus, the 

EPA concluded that the market for adipic acid is concentrated at the national level. As a result, 

the EPA further evaluated the “inputs to equations” data elements in Subpart E by examining 

individual data elements to determine if harm would be likely to occur. Refer to Part 2 of this 

memorandum for this evaluation. 

Subpart H: Portland Cement Sector. Subpart H is the Portland cement industry. Nationally, the 

HHI for the cement industry is 609.9; the four largest firms produce 40.8% of value of 

shipments, according to the 2007 Economic Census. In addition, Appendix 1 shows that the 

NAICS codes reported by GHGRP facilities in 2011 are unconcentrated. Therefore, the EPA 

proceeded to assess whether regional markets are concentrated. 

High cement transportation cost relative to product value leads to regional cement markets with a 

small number of competing firms. In previous analyses supporting the EPA rule making, the 

cement industry has been modeled as regional, and imperfectly competitive.7 That is, market 

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

For example, this analysis identified 20 regional markets for gray cement (a subset of this 

sector), with the number of plants in each market ranging from one to nine6

; such markets are 

clearly concentrated at the regional level. 

In such markets, firms may have the ability to influence market prices by their production 

choices. In addition, firms are more likely to behave strategically based on their knowledge of 

other (competing) producers’ behavior. In addition, they would be aware of their competitors’ 

identity and interested in production and market information about their competitors. It is 

                                                           

6 Assuming each firm has an equal one-third share of the market results in an HHI of 3,267 (3 x 332

). In fact,the threshold of 

1,000 for moderately concentrated markets translates to a minimum of 10 firms. 

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/regdata/RIAs/portlandcementfinalria.pdf, EPA-HQ-OAR-2002-0051-3477. 
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important to note that facilities in the cement industry may produce a variety of cement products. 

Some cement products are homogeneous (e.g. gray cement) and are traded in regional markets; 

others such as white, Type III and Type V represent niche products with different markets, with 

few firms but possibly serving a larger geographic area.8 

As a result of these assessments, the EPA concluded that the structure of the markets that exist 

within this source category warrant further evaluation of the “inputs to equations” data elements 

in subpart H. Therefore, the EPA further evaluated the “inputs to equations” data elements by 

examining each individual data element to determine if harm would be likely to occur. Refer to 

Part 2 of this memorandum for this evaluation. 

Subpart K, Ferroalloys. According to the 2010 Statistics of U.S. Business9, there are 19 firms 

nationwide that produce ferroalloys. Of the 10 firms reporting under subpart K, nine selected 

NAICS 331112, for which no HHI information is available from the Census. As a result, we 

conducted a qualitative assessment of the market structure. Firms in an industry with only 19 

firms would be aware of their competitors. In addition, if a sector that has 19 firms nationwide 

includes a few firms with relatively large market share (as opposed to a sector where all firms are 

similar 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 further evaluation of the “inputs to equations” in subpart K. 

Therefore, the EPA further evaluated the “inputs to equations” data elements by examining each 

individual data element to determine if harm would be likely to occur. Refer to Part 2 of this 

memorandum for this evaluation. 

Subpart P: Hydrogen Production. Most hydrogen is produced at petroleum refineries and 

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

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

structure of the markets that exist within this source category warrant further evaluation of the 

“inputs to equations” data elements in subpart P. Therefore, the EPA further evaluated the 

“inputs to equations” data elements by examining each individual data element to determine if 

harm would be likely to occur. Refer to Part 2 of this memorandum for this evaluation. 

Subpart Q: Iron and Steel Sector. The EPA assessed the market structure of the iron and steel 

sector, using HHI data from the Census Bureau and other information. Steel production is 

generally characterized by economies of scale, resulting in markets dominated by a few large 

firms. Economies of scale favor large furnaces (high capital investment costs) and pose entry 

barriers. High transportation cost relative to product value is associated with regional steel 

                                                           

8 EPA’s Regulatory Impact Analysis: National Emissions Standards for Hazardous Air Pollutants from the Portland Cement 

Industry, April 2009, shows that only 4 plants nationwide produced 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. 
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markets with a small number of competing firms. As a result, firms may have the ability to 

influence market prices by their production choices. In addition, firms are more likely to behave 

strategically based on their knowledge of other (competing) producers’ behavior. Nationally, the 

majority of facilities reporting under this source category had a NAICS code that was 

unconcentrated. , for the reasons mentioned above, the national NAICS-level assessment may be 

misleading. Some steel products are homogeneous and are traded in regional markets; others 

represent niche products with relatively few firms, serving different markets (possibly different 

geographic dimensions). Both regional markets and niche markets have relatively small numbers 

of producers, indicating at least moderate market concentration. 

The EPA computed HHI at the process, region, and parent company 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 website10. 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 process. The results indicated that there are 116 facilities located in 

31 states, and production is not concentrated nationally, as indicated by relatively low HHI 

values. However, when data are grouped by state or parent company, the HHI values show at 

least moderate concentration, with the exception of EAFs, which are unconcentrated even at the 

state level. As a result, when the EPA accounted for the distinctions of region, parent company 

ownership, and steelmaking process the EPA concluded that the structure of the markets that 

exists within this source category warrant further evaluation of the “inputs to equations” data 

elements in subpart Q. Therefore, the EPA further evaluated the “inputs to equations” data 

elements by examining each individual data element to determine if harm would be likely to 

occur. Refer to Part 2 of this memorandum for this evaluation. 

Subparts R (Lead Smelting) and GG (Zinc Smelting). The EPA determined that markets served 

by firms reporting under subparts R and GG are concentrated at the national level. Both subpart 

R (lead smelting) and subpart GG (zinc smelting) fall under NAICS 331410, Nonferrous Metal 

(except Aluminum) Smelting and Refining. In addition to lead and zinc, many other nonferrous 

metals are included under NAICS 331410. Thus, the EPA examined the markets for lead and 

zinc individually. For subpart R, there is only one primary lead smelter, and seven firms with 14 

secondary smelters nationwide (USGS, 2010a). For subpart GG, there is only one primary zinc 

smelter and two secondary smelters nationwide (USGS, 2010b). Thus, firms in both of these 

subparts produce commodities whose markets are concentrated nationally. As a result, the EPA 

concluded that the structure of the markets that exist within these source categories 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%20Steel/Where%20Its%20Made.aspx
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determine if harm would be likely to occur. Refer to Part 2 of this memorandum for this 

evaluation. 

Subpart X: Petrochemicals. In 2011, 64 petrochemical manufacturing facilities identified 14 

NAICS codes. Of these, two NAICS, identified by 19 facilities, are concentrated based on their 

HHI values. Facilities within this subpart produce one of six products: carbon black, methane, 

acrylonitrile, ethylene, ethylene oxide, and ethylene dichloride. The EPA examined the markets 

for these products, and found that none of them had more than 17 firms, and most had ten or 

fewer.11 As a result, the EPA concluded that the structure of the markets that exist within this 

source category warrant further evaluation of the “inputs to equations” data elements in subpart 

X. Therefore, the EPA further evaluated the “inputs to equations” data elements by examining 

each individual data element to determine if harm would be likely to occur. Refer to Part 2 of 

this memorandum for this evaluation. 

Subpart Y: Petroleum Refinery Sector. There are two types of barriers to entry facing firms 

wanting to enter the refining industry. First, there are significant economies of scale in refinery 

operations, so firms would need to start a fairly large-scale operation or they would face higher 

unit costs than their competitors. Second, legal barriers may also present obstacles (e.g., patented 

processes). 

Nationally, the HHI for the refinery industry is 807; the four largest firms produce 47.5% of 

value of shipments, according to the 2007 Economic Census. While 807 is not considered 

concentrated, the industry has become more concentrated over time, even when considered 

nation-wide (HHI in 1996 was 412, in 2000 the HHI was 611, and in 2007 it was 807). 

Concentration has occurred through mergers, which has reduced the number of refinery 

companies in the U.S. Examining HHIs by the five PADDs (Petroleum Administrative Districts 

for Defense”12, the Federal Trade Commission (FTC, 2004) found that PADD V (the West Coast 

including Alaska and Hawaii) was moderately concentrated (HHI=1,246 in 2003). 

Individual petroleum products are relatively homogeneous, although different firms produce a 

different mix of products, and some produce specialty products for which there are few other 

producers. The U.S. Department of Energy collects data on refineries in a petroleum supply 

survey which is published as an annual Petroleum Capacity Report. 13 The EPA reviewed the 

latest data (2012) containing 31 separate products and processes at 95 different facilities owned 

by 63 different firms. To better characterize the petroleum market, the EPA analyzed this data at 

the product/process level, applying the HHI measure to test for market concentration. The result 

of calculating the HHI at the product/process level for petroleum refineries shows that activity 

for several key products/processes is at least moderately concentrated. The data includes 

                                                           

11U.S. Environmental Protection Agency. Technical Support Document for the Petrochemical 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/info/twip/padddef.html 

13 http://www.eia.gov/petroleum/refinerycapacity/ 
11

capacity data for 3 thermal cracking processes (visbreaking, fluid coking, other) and together 

there are only 9 facilities nationwide with this capability (HHI = 5,568, 2,463, and 10,000 

respectively). Similarly, desulfurization and catalytic hydrocracking 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 moderately concentrated in PADD V and because the 

markets for some petroleum products were at least moderately concentrated, the EPA concluded 

that the structure of the markets that exist within this source category warrant further evaluation 

of the “inputs to equations” data elements in subpart Y. Therefore, the EPA further evaluated the 

“inputs to equations” data elements by examining each individual data element to determine if 

harm would be likely to occur. Refer to Part 2 of this memorandum for this evaluation.

4.3 Analysis of Subparts Representing Processes from Many Sectors

Subparts C, II, TT, and U have reporters from a large number of sectors. As opposed to many of 

the other source categories reporting under the 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 defined by production processes or waste management processes (C, 

II, and TT) or inputs used (U). As a result, it is not possible to make a determination based on the 

subpart as a whole. Instead, whether information related to these source categories has the 

potential to cause competitive harm depends on the concentration of the markets in which the 

facilities sell their products rather than on the total number of facilities reporting under each 

source category. Thus, the EPA determined that it would be necessary to identify the markets 

affected, and examine their market structure. 

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

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

where the national level 6-digit NAICS indicated unconcentrated HHIs, EPA did not proceed 

with evaluating each of the NAICS codes to determine whether regional or product-specific 

concentration occurred. Because these facilities come from a wide variety of sectors for which 

the EPA does not have specific information beyond the 6-digit NAICS code provided, and 

because many of the NAICS reported for these sectors are not manufacturing NAICS codes, 

further analysis of each of these sectors would be resource-intensive, and would be likely to have 

a large uncertainty without obtaining additional information from the facilities on the specific 

markets in which these facilities operate. 

A summary of the results for the HHIs computed for these subparts is provided, by subpart, in 

Table 1. Refer to Appendix A for a complete list of the HHIs for NAICS codes reported by these 

facilities. The EPA’s analysis of HHIs for manufacturing NAICS codes listed by facilities in 

these subparts shows that some of the affected markets for goods produced by facilities in each 

of these subparts are concentrated or moderately concentrated. For these facilities, therefore, 
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publishing the information contained in the “inputs to equations” data elements could potentially 

cause competitive harm or reduce competition. Due to the limitations of the market structure 

analysis for these subparts, and because the results of the analysis demonstrate that some of the 

facilities that report under these subparts are in sectors that are at least moderately concentrated 

at the national level, the EPA proceeded to evaluate the individual data elements to determine if 

harm would likely occur (refer to Part Two of this memorandum). 

Table 1. Summary of National Level Herfindahl-Hirschman Index (HHI) for the Industry 

Sectors Subject to Subparts C, II, TT, and U 

Subpart # of NAICS 

Reported 

# of Reporters # of Facility 

Reports of 

NAICS with 

HHIs,1,2

# of Facility 

Reports of 

NAICS with at 

Least 

Moderately 

Concentrated 

HHIs1

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 facilities, because some facilities report multiple NAICS codes. 

2

Includes only facility reports of NAICS codes with non-missing HHI values. 

4.4 Analysis of Non-Manufacturing Sectors 

As shown in Appendix A, HHIs were not available for subpart W14 (Petroleum and Natural Gas) 

and subpart CC (soda ash manufacturing). As a result, a qualitative analysis of the market 

structures that exist within these source categories was conducted. 

Subpart W: Petroleum and Natural Gas. 

Subpart W includes facilities operating in eight related segments of the petroleum and natural gas 

sector. Because subpart W is not a manufacturing sector, HHIs were not available for the vast 

                                                           

14 Of the 1,549 facilities that reported under subpart W in 2011, three facilities reported manufacturing NAICS codes for which 

HHIs are available and were moderately concentrated. Of these, one facility with a NAICS of 325181 (alkalies and chlorine 

manufacturing), reported a small amount of emissions under LNG storage. EPA determined that this LNG storage process is 

separable from the remainder of the facility and is unrelated to the alkalies and chlorine manufacturing market. EPA believes 

that the NAICS for the remaining two facilities were reported in error. 
13

majority of facilities. As a result, the EPA conducted a qualitative analysis of the segments 

within this sector. 

For each segment, the EPA examined the market structure to determine if revelation of “inputs to 

equations” data elements by firms in that segment had the potential to cause competitive harm or 

reduce competition. For source categories that are in the manufacturing sector, as shown in 

Sections 4.1 and 4.2 of this memorandum, the EPA examined concentration at the national level, 

as well as at the regional, product, or process level. Because of the unique nature of the subpart 

W source category with a relatively large number of producers selling a relatively homogeneous 

product, the EPA determined that it would not be appropriate to assess the market structure at the 

product or process level. As a result, the EPA considered the market structure of each segment as 

well as the types of information that are collected through this source category. The EPA’s 

findings for each subpart W segment are reported below. 

Onshore Petroleum and Natural Gas Production 

The onshore petroleum and natural gas production segment covers emissions related to 

onshore production wellheads. The market structure for petroleum and natural gas was 

considered separately for this segment. Onshore petroleum production is a regionally 

concentrated market, with wells located in fixed geological formations. Decisions on where 

to drill wells may be based on proprietary information during the early development of a 

formation when lease prices have not stabilized and operators are taking risks by drilling 

explorations wells in formations that do not have proven production records. After several 

wells have been drilled in an area, information about production becomes publically 

available and the advantage incurred by the operator drilling exploration wells is lost. 

However, once a well has been drilled, decisions to produce are based on market prices and 

the ability to control flow from the well. Although this could pose a potential data sensitivity 

with respect to exploration wells, this issue is addressed by the fact that onshore production 

data is reported at a sub-basin level, as defined by county boundaries, and which is a large 

enough scale that disclosure of the data collected under subpart W would not reveal any 

proprietary information about the facility or cost to do business. 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. 

The onshore natural gas production market overlaps many of the geological formations of 

petroleum production. Furthermore, the market itself is structured the same, with a large 

number of operators within each formation. Like onshore oil production, disclosure of data 

for onshore natural gas production at the sub-basin level would also not reveal any 

proprietary information about the facility or cost to do business. 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. 
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 drilling and exploration that is not associated 

with production platforms. The products created on offshore production platforms are 

delivered into the same market as onshore petroleum and natural gas production, which is a 

competitive market. The reported data is specific to a latitude and longitude 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 production would not reveal 

any proprietary information about the facility or cost to do business. As the likelihood of 

harm can be characterized for all information collected for this segment, the EPA did not 

proceed to evaluate each “input to equation” data element in this segment. 

Natural Gas Processing 

Natural gas processors are regionally located close to production wellheads. The market itself 

is large, with roughly 500 firms. These firms are located in close proximity to given natural 

gas plays. However, we do not believe that this regional concentration would pose data 

sensitivity issues because the “inputs to equations” data elements in this segment would not 

reveal any proprietary information about the facility, cost of natural gas, or cost to do 

business. As the likelihood of harm can be characterized for all information collected for this 

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

segment. 

Natural Gas Transmission Compression 

Natural gas transmission compression operators transport natural gas from processors to end 

users. Firms are regionally concentrated, having control over particular segments of the 

pipeline infrastructure. Although the number of firms and the regional concentration could 

pose data sensitivity issues, we do not believe this is an issue for three reasons: (1) there are 

few technological secrets related to pipeline construction and natural gas transmission; 

technological innovation is mainly in the area of pipeline security; (2), the rate charged for 

transport is highly regulated, preventing use of the data for strategic price competition; and 

(3) once pipeline and compression are built in a given corridor, there is little incentive for a 

competitor to build additional pipeline and compression along the same route. As a result, the 

“inputs to equations” data elements in this segment would not reveal any proprietary 

information about the facility or cost to do business. As the likelihood of harm can be 

characterized for all information collected for this segment, the EPA did not proceed to 

evaluate each “input to equation” data element in this segment. 
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 end-users. This market is regionally located 

with distributers having exclusive access to specific cities and other localities. Both publiclyand privately-owned companies are highly regulated, unable to charge market based rates for 

service. The regulation by government and the monopoly rights distributors hold over given 

regions prevents competitors’ use of the data for strategic purposes. As a result, the “inputs to 

equations” data elements in this segment would not reveal any proprietary information about 

the facility or cost to do business. As the likelihood of harm can be characterized for all 

information collected for this segment, the EPA did not proceed to evaluate each “input to 

equation” data element in this segment. 

Underground Natural Gas Storage 

Underground natural gas storage is used to smooth out volatility in consumption and use of 

natural gas. The market is regional; facilities are located either near major distribution centers 

or near oil and gas fields. Even with the regional market structure, competitors are not known 

to engage in strategic competition in building storage facilities. First, facilities are built in 

response to other upstream factors, such as increased gas supply coming to distributors, not 

to undermine other competitors. Second, storage firms are constrained by the geographical 

and geological requirements needed for underground storage, preventing firms from moving 

in and increasing their market share. Finally, storage technology is widely known and not 

used to garner a competitive advantage. As a result, the “inputs to equations” data elements 

in this segment would not reveal any proprietary information about the facility or cost to do 

business. As the likelihood of harm can be characterized for all information collected for this 

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

segment. 

Liquefied Natural Gas Storage 

Liquefied Natural Gas (LNG) storage operates much the same as underground natural gas 

storage, with storage used to smooth volatility related to consumption. The small size of the 

LNG storage market could create the possibilities for disruptive competitive undercutting; 

however, there we determined that this is unlikely for the following two reasons. First, LNG 

storage is primarily owned by highly regulated distributors, preventing competitive firms 

from undercutting the market. Second, LNG storage occurs in response to increase supply 

upstream or decreased demand downstream, and is not responsive to cost advantages. As a 

result, the “inputs to equations” data elements in this segment would not reveal any 

proprietary information about the facility or cost to do business. As the likelihood of harm 

can be characterized for all information collected for this segment, the EPA did not proceed 

to evaluate each “input to equation” data element in this segment. 
16

Liquefied Natural Gas Import/Export 

Currently the U.S. has only twelve LNG import terminals and one LNG export terminal. 

There are nine onshore import terminals and three offshore import terminals. LNG 

technology is not proprietary. The technology is relatively simple and has been around for 

many years. The market is regional and small with import terminals located along the Gulf 

and East coasts. Although there are a small number of facilities that import and/or export 

LNG, they may be viewed as a part of the larger natural gas supply sector that is a much 

larger market. The product delivered or consumed by LNG Import/Export is identical to the 

product generated in onshore and offshore natural gas production. Functionally, Import and 

Export terminals may be considered as a large producer or consumer of natural gas. Import 

and Export terminals are generally located in regions of supply restrictions or excess to 

maximize price margins. However, the trading prices 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. Therefore, release of information about import/export terminals would 

not change the operations of other firms in the market. As a result, the “inputs to equations” 

data elements in this segment would not reveal any proprietary information about the facility 

or cost to do business. As the likelihood of harm can be characterized for all information 

collected for this segment, the EPA did not proceed to evaluate each “input to equation” data 

element in this segment. 

In summary, the EPA determined that, for all of the industry segments within Subpart W, either 

the data are reported at a level of geographical aggregation that protects individual well 

information, or the markets in which the affected firms operate are structured in ways that 

disclosure of “inputs to equations” data elements would not be likely to cause competitive harm. 

As a result, the EPA did not further evaluate the “inputs to equations” data elements in Subpart 

W. 

Subpart CC, Soda Ash. The four facilities reporting under subpart CC in 2011 identified NAICS 

212391, Potash, Soda, and Borate Mineral Mining. This is not a manufacturing NAICS, so HHI 

is not published for it. However, there are only 18 firms in this sector nationwide.15 If a sector 

that has 18 firms nationwide includes a few firms with relatively large market share (as opposed 

to a sector where all firms are similar size, and each has roughly 1/18 share of the market), it is 

likely to be concentrated. As a result, the EPA concluded that the structure of the markets that 

exist within this source category warrant further evaluation of the “inputs to equations” data 

elements in subpart CC. Therefore, the EPA further evaluated the “inputs to equations” data 

elements by examining each individual data element to determine if harm would be likely to 

occur. Refer to Part 2 of this memorandum for this evaluation. 

5.0 Summary 

                                                           

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 within the market structure such that release of 

these data could result in competitive harm. The EPA determined that such conditions exist 

within the market structures for all of the subparts examined except for facilities 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” data 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 Individual Data Elements 

1.0 Introduction 

As discussed in Part One of this memorandum, the EPA determined that conditions exist within 

the market structures such that competitive harm could occur should certain types of information 

be released for all of the subparts examined in this memorandum except for facilities reporting 

under subpart W. As a result, no further evaluation of competitive harm was conducted for this 

source category. The remaining “inputs to equations” data elements in 26 subparts were further 

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

2.0 Evaluation of Harm 

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

39115 – 39116, July 7, 2010), the EPA’s previous consideration of comments received on the 

proposed CBI rule (see final CBI rule, 76 FR 30806, May 26, 2011), and the EPA’s more recent 

consideration of comments received on the Call for Information (75 FR 81366, December 27, 

2010), the EPA identified certain types of data that would reveal information that likely cause 

competitive harm, if reported and publicly released. These data include: 

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

 Process design, process performance and operation, and cost to do business. 

Additionally, the EPA determined that many other “inputs to equations” data elements, which 

alone would not reveal information that could cause competitive harm, would reveal the types of 

data specified above if known together with certain additional data elements (i.e., multiple 

reported “inputs to equations” data elements would be needed to back-calculate the types of data 

specified above). 

Under this evaluation, each individual “inputs to equations” data element was evaluated to 

determine whether it includes any of these types of data, as further discussed below. In all, 525 

“inputs to equations” data elements (excluding “inputs to equations” for facilities subject to 

subpart W) were reviewed according to the process described in this section. Refer to Appendix 

B for results of the analysis for each of the 525 data elements. 

2.1 Quantity and Composition of Raw Materials or Products 

The EPA has determined in previous GHGRP actions that publicly releasing facility-specific 

data on the quantity or composition of raw materials or products would likely cause competitive 

harm. In these previous actions, the EPA finalized CBI determinations for such data currently 

reported under Part 98 (e.g., production rates that are currently collected under Part 98, but not 

used to calculate GHG emissions). As further discussed in the proposed CBI rule, disclosing a 

facility’s production or throughput data would be detrimental to a firm’s competitiveness by 

revealing confidential process information and operational and marketing strategies, as follows: 
19

 Annual production quantities, used in conjunction with other publicly available data 

related to capacity, provide insight into a firm’s operational strengths and weaknesses. 

Competitors could determine at what percent capacity a firm is operating, which can 

reveal information on the financial and competitive strength of the firm; 

 Disclosing a facility’s production or throughput quantities and product compositions 

could give competitors insight into a firm’s local and regional market conditions and 

expansion plans, enabling competitors to devise strategies to prevent expansion and to 

steal market share in specific locations; and 

 Disclosing a facility’s feedstock quantities and composition and reactants fed into 

particular processes at a facility could provide insight into a facility’s operational 

strengths and weaknesses, expose a firm’s competitive and marketing strategies, or 

reveal a firm’s suppliers and sourcing strategies. 

Refer to the preamble to the proposed CBI determinations (75 FR 39115 – 39116, July 7, 2010) 

for a more detailed discussion on why reporting production and raw material information would 

be likely to cause competitive harm. 

Under this evaluation, we identified all “inputs to equations” data elements that require reporting 

of data related to the quantity or composition of raw materials or products. We evaluated these 

data elements to identify any attributes in the data elements that would distinguish them as less 

likely to cause competitive harm if released than those data elements previously determined to be 

CBI (see reference above to previously proposed CBI determinations). We concluded that all 

such data elements identified under this analysis would be as likely to cause competitive harm as 

those previously identified. 

Data elements determined to include a requirement to report the quantity or composition of raw 

materials or products are identified in Appendix B. 

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

Business 

Based on a review of comments on the Call for Information (75 FR 81366, December 27, 2010) 

and on previous actions under the GHGRP, the EPA has determined that data related to process 

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

information: 

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

by revealing 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 capacity of a combustion unit (not connected to 

the electric power grid) would disclose the design efficiency of the unit; 

 Disclosing process performance and operation information could be detrimental to a 

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

operational strengths and weaknesses (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, would reveal the amount of product that is 

lost). 

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

above are identified in Appendix B. 

2.3 Other Data that Would Likely Reveal the Types of Data Specified Above if Certain 

Additional Data Are Also Known 

An additional evaluation was conducted to determine whether each “inputs to equations” data 

element not related to the quantity or composition of raw materials or products (see section 2.1), 

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

elements could be used to back-calculate the types of data specified in sections 2.1 and 2.2 (e.g., 

production quantity, cost to do business). For example, for a nitric acid production facility, the 

abatement technology destruction efficiency, if reported alone, would not reveal any information 

that would likely cause harm; however, if reported together with the abatement utilization factor, 

emission factor, and reported N2O emissions, it could be used to back-calculate an estimate of 

the mass of nitric acid produced, which is the type of data identified in section 2.1 of this 

memorandum. Data elements determined to reveal proprietary information in this way are 

identified in Appendix B. 

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

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

abatement utilization factor were reported (as required under §98.226(j)), together with annual 

N2O emissions from nitric acid production (in §98.3(c)(4)), the emission factor (in 

§98.226(m)(1)), and the destruction efficiency (in §98.226(i)), these data together could be used 

to calculate the mass of nitric acid produced. However, if reporting of the emission factor were 

removed, the abatement utilization factor could be reported without revealing proprietary 

information about nitric acid production. Any such “inputs to equations” data elements are 

identified in Appendix B. 

3.0 Summary 

Based on the results of Part 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 memorandum. 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 Assessment, 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 may exceed the total number of facilities reporting under that subpart.

2

 HHI: Herfindahl-Hirschman index This index is calculated by summing the squares of the individual company 

percentages for the 50 largest companies or the universe, whichever is lower. Values less than 1000 are considered 

unconcentrated, values between 1000 and 1800 are considered moderately concentrated, and values over 1800 are 

considered concentrated. VOS is Value of Shipments; VA is Value Added. 

 
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 Competitive Harm from Disclosure of Data 

Elements Deferred to March 31, 2015

Subpart 

Rule Citation in 40 CFR Part 

98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . Analysis Results 

C (Stationary 

fuel combustion 

sources 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 CO2 mass emissions 

at the common stack or duct 

according to the Tier 4 

Calculation Methodology, you 

may report the combined 

emissions from the units 

sharing the common stack or 

duct, in lieu of separately 

reporting the GHG emissions 

from the individual units. 

This monitoring and reporting 

alternative may also be used 

when process off-gases or a 

mixture of combustion 

products and process gases are 

combined together in a 

common stack or duct before 

exiting to the atmosphere. An 

estimate of the heat input from 

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 

CO2 emissions calculations for 

each fuel combusted during 

the reporting year. Report a 

HHV value for each calendar 

month in which HHV 

determination is required. If 

multiple values are obtained in 

a given month, report the 

arithmetic average value for 

the month. 

C-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 CO2 is determined 

according to §98.33(e)(2), 

report the carbon-based Ffactor used in Equation C-13 

of this subpart. 

C-13 Provides data related to process 

design; process performance, 

and operation; and/or cost to do 

business, as described in 

section 2.2 of Part Two of this 

memorandum. Specifically, for 

specialty fuels that 

are byproducts of the 

production process, indicates 

the composition of the process 

byproduct, which could reveal 

information about process 

efficiency and cost to produce a 

product. 
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 CO2 is determined 

according to §98.33(e)(2), 

report the annual average 

HHV value used in Equation 

C-13 of this subpart. 

C-13 Provides data related to process 

design; process performance, 

and operation; and/or cost to do 

business, as described in 

section 2.2 of Part Two of this 

memorandum. Specifically, for 

specialty fuels that 

are byproducts of the 

production process, indicates 

the composition of the process 

byproduct, which could reveal 

information about process 

efficiency and cost to produce a 

product. 

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 CO2 is determined 

according to §98.33(e)(2), 

report the total quantity of 

fossil fuel combusted during 

the reporting year. 

C-13 Provides data related to process 

design; process performance, 

and operation; and/or cost to do 

business, as described in 

section 2.2 of Part Two of this 

memorandum. Specifically, 

indicates the quantity of fuel 

used in the process, which, in 

certain cases, could reveal 

information about the cost to 

produce products. 

C (Stationary 

fuel combustion 

sources 

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 material 

usage; or production. Sitespecific fuel characteristics for 

these units do not vary 

significantly 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 types 

of 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 material 

usage; or production. Sitespecific fuel characteristics for 

these units do not vary 

significantly from publiclyknown average values. 

Additionally for the electric 

utilities, this sector has 

experienced a high level of 

transparency due to the practice 

of passing fuel costs through to 

paying customers. 

C (Stationary 

fuel combustion 

sources 

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 CO2 mass emissions 

at the common stack or duct 

according to the Tier 4 

Calculation Methodology, you 

may report the combined 

emissions from the units 

sharing the common stack or 

duct, in lieu of separately 

reporting the GHG emissions 

from the individual units. 

This monitoring and reporting 

alternative may also be used 

when process off-gases or a 

mixture of combustion 

products and process gases are 

combined together in a 

common stack or duct before 

exiting to the atmosphere. An 

estimate of the heat input from 

each type of fuel listed in 

Table C-2 combusted during 

the reporting year. 

C-10 Would not reveal any 

proprietary information about 

facility or process performance, 

design, and operation; cost to 

do business; raw material 

usage; or production. Sitespecific fuel characteristics do 

not vary significantly from 

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 types 

of 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 types 

of 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 types 

of 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 types 

of 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 types 

of 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 

CO2 emissions calculations for 

each fuel combusted during 

the reporting year. Report a 

HHV value for each calendar 

month in which HHV 

determination is required. If 

multiple values are obtained in 

a given month, report the 

arithmetic average value for 

the month. 

C-2b Would not reveal any 

proprietary information about 

facility or process performance, 

design, and operation; cost to 

do business; raw material 

usage; or production. Sitespecific fuel characteristics do 

not vary significantly from 

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 types 

of 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 types 

of 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 types 

of 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 types 

of 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 types 

of 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 types 

of 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 types 

of 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 material 

usage; 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 material 

usage; 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 material 

usage; 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 material 

usage; 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 types 

of 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 material 

usage; 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 CO2 is determined 

according to §98.33(e)(2), 

report the carbon-based Ffactor used in Equation C-13 

of this subpart. 

C-13 Would not reveal any 

proprietary information about 

facility or process performance, 

design, and operation; cost to 

do business; raw material 

usage; or production. Sitespecific fuel characteristics do 

not vary significantly from 

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 CO2 is determined 

according to §98.33(e)(2), 

report the annual average 

HHV value used in Equation 

C-13 of this subpart. 

C-13 For facilities with these types 

of combustion units, 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 material 

usage; 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 CO2 is determined 

according to §98.33(e)(2), 

report the total quantity of 

fossil fuel combusted during 

the reporting year. 

C-13 For facilities with these types 

of combustion units, 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 material 

usage; 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 N2O abatement 

technology (located after the 

test point) is operating (Pz,N) . 

E-2 Provides production or raw 

material data described in 

section 2.1 of Part Two of this 

memorandum. 
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 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)), 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 N2O 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 N2O 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 N2O 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 N2O 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) N2O concentration per test run 

during performance test for 

each unit (CN2O). 

E-1 Provides data described in 

section 2.3 in Part Two of this 

memorandum that could be 

used to calculate the mass of 

adipic acid produced if all of 

the following data are also 

known: EFs (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)), N2O 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)), N2O 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. (FCN) 

E-3c Provides data described in 

section 2.3 in Part Two of this 

memorandum that could be 

used to calculate the mass of 

adipic acid produced if all of 

the following data are also 

known: annual N2O mass 

emissions from adipic acid 

production (as currently 

reported under 40 CFR 

98.3(c)(4) and made publicly 

available) 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 overvoltage. Used to calculate 

the overvoltage 

factor used as an 

input in Eq. F-3 

Provides data described in 

section 2.3 of Part Two of this 

memorandum that could be 

used to calculate the mass of 

aluminum produced if reported 

GHG emissions (as currently 

reported under 40 CFR 

98.3(c)(4) and made publicly 

available) 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 

CO2 emission factors for each 

kiln. 

H-2 Provides data described in 

section 2.3 of Part Two of this 

memorandum that could be 

used to calculate the mass of 

clinker produced if reported 

GHG emissions (as currently 

reported under 40 CFR 

§98.3(c)(4) and made publicly 

available) 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 

CO2 emission factors for each 

kiln. 

H-2 Provides data described in 

section 2.3 in Part Two of this 

memorandum that could be 

used to calculate the mass of 

clinker produced if all of the 

following data are also known: 

CKD not recycled to the kiln 

(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 in40 

CFR 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 

CO2 emissions (No CEMS): 

Mreducing agenti= Annual 

mass of reducing agent i fed, 

charged, or otherwise 

introduced into the EAF 

(tons). 

K-1 Provides production or raw 

material data described in 

section 2.1 of Part Two of this 

memorandum. 

K §98.116(e)(4) Annual material quantity for 

each material included for the 

calculation of annual process 

CO2 emissions (No CEMS): 

Melectrodem= Annual mass of 

carbon electrode m consumed 

in the EAF (tons). 

K-1 Provides production or raw 

material data described in 

section 2.1 of Part Two of this 

memorandum. 

K §98.116(e)(4) Annual material quantity for 

each material included for the 

calculation of annual process 

CO2 emissions (No CEMS): 

Moreh= Annual mass of ore h 

charged to the EAF (tons). 

K-1 Provides production or raw 

material data described in 

section 2.1 of Part Two of this 

memorandum. 

K §98.116(e)(4) Annual material quantity for 

each material included for the 

calculation of annual process 

CO2 emissions (No CEMS): 

Mfluxj= Annual mass of flux 

material j fed, charged, or 

otherwise introduced into the 

EAF to facilitate slag 

formation (tons). 

K-1 Provides production or raw 

material data described in 

section 2.1 of Part Two of this 

memorandum. 

K §98.116(e)(4) Annual material quantity for 

each material included for the 

calculation of annual process 

CO2 emissions (No CEMS): 

Mnon-product outgoingl= 

Annual mass of non-product 

outgoing material l removed 

from EAF (tons). 

K-1 Provides production or raw 

material data described in 

section 2.1 of Part Two of this 

memorandum. 

K §98.116(e)(5) Annual average of the carbon 

content determinations for 

each material included for the 

calculation of annual process 

CO2 emissions (No CEMS): 

Creducing agenti= Carbon 

content in reducing agent i 

(percent by weight, expressed 

as a decimal fraction). 

K-1 Provides production or raw 

material data described in 

section 2.1 of Part Two of this 

memorandum. 
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 

CO2 emissions (No CEMS): 

Celectrodem= Carbon content 

of the carbon electrode m 

(percent by weight, expressed 

as a decimal fraction). 

K-1 Provides production or raw 

material data described in 

section 2.1 of Part Two of this 

memorandum. 

K §98.116(e)(5) Annual average of the carbon 

content determinations for 

each material included for the 

calculation of annual process 

CO2 emissions (No CEMS): 

Coreh= Carbon content in ore 

h (percent by weight, 

expressed as a decimal 

fraction). 

K-1 Provides production or raw 

material data described in 

section 2.1 of Part Two of this 

memorandum. 

K §98.116(e)(5) Annual average of the carbon 

content determinations for 

each material included for the 

calculation of annual process 

CO2 emissions (No CEMS): 

Cfluxj= Carbon content in flux 

material j (percent by weight, 

expressed as a decimal 

fraction). 

K-1 Provides production or raw 

material data described in 

section 2.1 of Part Two of this 

memorandum. 

K §98.116(e)(5) Annual average of the carbon 

content determinations for 

each material included for the 

calculation of annual process 

CO2 emissions (No CEMS): 

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 

CO2 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) The weighted average 

destruction efficiency of the 

destruction device calculated 

for each stream under 

§98.123(b)(16). (DEavgj) 

L-17 Provides data described in 

section 2.3 of Part Two of this 

memorandum that could be 

used to calculate the 

concentration of 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 each 

fluorine-containing byproduct. (FEBk) 

L-12 This data element is not 

addressed because this is a 

reported emissions value, 

which is addressed in a separate 

action related to subpart L of 

part 98. 

L §98.126(b)(12) The fraction of the mass 

emitted that consists of each 

fluorine-containing byproduct. (FEBk) 

L-13 This data element is not 

addressed because this is a 

reported emissions value, 

which is addressed in a separate 

action related to subpart L of 

part 98. 

L §98.126(c)(1) The quantity of the process 

activity used to estimate 

emissions (e.g., tons of 

product produced or tons of 

reactant consumed). 

(ActivityC or ActivityU) 

L-21 Provides production or raw 

material data described in 

section 2.1 of Part Two of this 

memorandum. 

L §98.126(c)(1) The quantity of the process 

activity used to estimate 

emissions (e.g., tons of 

product produced or tons of 

reactant consumed). 

(ActivityC or ActivityU) 

L-22 Provides production or raw 

material data described in 

section 2.1 of Part Two of this 

memorandum. 

L §98.126(c)(1) The quantity of the process 

activity used to estimate 

emissions (e.g., tons of 

product produced or tons of 

reactant consumed). (Activity) 

L-26 Provides production or raw 

material data described in 

section 2.1 of Part Two of this 

memorandum. 

L §98.126(c)(1) The quantity of the process 

activity used to estimate 

emissions (e.g., tons of 

product produced or tons of 

reactant consumed). 

(ActivityU or ActivityC) 

L-27 Provides production or raw 

material data described in 

section 2.1 of Part Two of this 

memorandum. 

L §98.126(c)(2) The site-specific, processvent-specific emission 

factor(s) for each process vent 

(EFPV). 

L-20 Provides data described in 

section 2.3 of Part Two of this 

memorandum that could be 

used to calculate the process 

feed rate, production process 

rate, or other process activity 

rate if the mass of fluorinated 

GHG emitted from the process 

vent (as required to be reported 

in 40 CFR 98.126(c)(3)) is also 

known. 2

L §98.126(c)(2) The site-specific, processvent-specific emission 

factor(s) for each process vent 

(EFPV–C). 

L-21 Provides data described in 

section 2.3 of Part Two of this 

memorandum that could be 

used to calculate the process 

feed rate, production process 

rate, or other process activity 

rate if the mass of fluorinated 

GHG emitted from the process 

vent (as required to be reported 

in 40 CFR 98.126(c)(3)) is also 

known. 2
71

Subpart 

Rule Citation in 40 CFR Part 

98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . Analysis Results 

L §98.126(c)(2) The site-specific, processvent-specific emission 

calculation factor for each 

process vent. (ECFPV-U). 

L-21 Provides data described in 

section 2.3 of Part Two of this 

memorandum that could be 

used to calculate the process 

feed rate, production process 

rate, or other process activity 

rate if the mass of fluorinated 

GHG emitted from the process 

vent (as required to be reported 

in 40 CFR 98.126(c)(3)) is also 

known. 2

L §98.126(c)(2) The site-specific, processvent-specific emission 

factor(s) for each process vent 

(EFPV–U). 

L-22 Provides data described in 

section 2.3 of Part Two of this 

memorandum that could be 

used to calculate the process 

feed rate, production process 

rate, or other process activity 

rate if the mass of fluorinated 

GHG emitted from the process 

vent (as required to be reported 

in 40 CFR 98.126(c)(3)) is also 

known. 2

L §98.126(c)(2) The site-specific, processvent-specific emission 

factor(s) for each process vent. 

(EFPV) 

L-23 Provides data described in 

section 2.3 of Part Two of this 

memorandum that could be 

used to calculate the process 

feed rate, production process 

rate, or other process activity 

rate if the mass of fluorinated 

GHG emitted from the process 

vent (as required to be reported 

in 40 CFR 98.126(c)(3)) is also 

known. 2

L §98.126(c)(2) The site-specific, processvent-specific emission 

calculation factor for each 

process vent. (ECFPV). 

L-25 Provides data described in 

section 2.3 of Part Two of this 

memorandum that could be 

used to calculate the process 

feed rate, production process 

rate, or other process activity 

rate if the mass of fluorinated 

GHG emitted from the process 

vent (as required to be reported 

in 40 CFR 98.126(c)(3)) is also 

known. 2

L §98.126(c)(2) The site-specific, processvent-specific emission 

calculation factor for each 

process vent (ECFPV). 

L-26 Provides data described in 

section 2.3 of Part Two of this 

memorandum that could be 

used to calculate the process 

feed rate, production process 

rate, or other process activity 

rate if the mass of fluorinated 

GHG emitted from the process 

vent (as required to be reported 

in 40 CFR 98.126(c)(3)) is also 

known. 2

L §98.126(c)(2) The site-specific, processvent-specific emission 

calculation factor for each 

process vent. (ECFPV). 

L-27 Provides data described in 

section 2.3 of Part Two of this 

memorandum that could be 

used to calculate the process 

feed rate, production process 

rate, or other process activity 

rate if the mass of fluorinated 

GHG emitted from the process 

vent (as required to be reported 

in 40 CFR 98.126(c)(3)) is also 

known. 2
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. (RED) 

L-31 Provides production or raw 

material data described in 

section 2.1 of Part Two of this 

memorandum. 

L §98.126(h)(2) If applicable, the heel factor 

calculated for each container 

size and type. (hfj) 

L-34 Provides data described in 

section 2.3 of Part Two of this 

memorandum that could be 

used to calculate the number of 

tanks processed if the emissions 

from each type of container (as 

required to be reported in 40 

CFR 98.126(h)(1 )) are also 

known. The number of each 

type of tank processed and the 

size of the tanks could provide 

insight into product sales. 2

N §98.146(b)(2) Annual quantity of carbonate 

based-raw material charged to 

each continuous glass melting 

furnace (No CEMS). 

N-1 Provides production or raw 

material data described in 

section 2.1 of Part Two of this 

memorandum. 

N §98.146(b)(4) Carbonate-based mineral mass 

fraction of 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 average 

mass 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 (G23 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 (S23 in Eq. 

O-4). 

O-4 Provides production or raw 

material data described in 

section 2.1 of Part Two of this 

memorandum. 

O §98.156(a)(9) Annual mass of any HFC-23 

sent off site for destruction 

(OD23 used in Eq. O-4). 

O-4 Provides production or raw 

material data described in 

section 2.1 of Part Two of this 

memorandum. 

O §98.156(a)(10) Mass of HFC-23 in storage at 

the beginning of the year (used 

to calculate I23, which is used 

in Eq. O-4). 

O-4 Provides production or raw 

material data described in 

section 2.1 of Part Two of this 

memorandum. 

O §98.156(a)(10) Mass of HFC-23 in storage at 

the end of the year (used to 

calculate I23, which is used in 

Eq. O-4). 

O-4 Provides production or raw 

material data described in 

section 2.1 of Part Two of this 

memorandum. 

O §98.156(b)(1) Annual mass of HFC-23 fed 

into the destruction device 

(FD used in Eq. O-8 and O-9). 

O-8 Provides production or raw 

material data described in 

section 2.1 of Part Two of this 

memorandum. 

O §98.156(b)(1) Annual mass of HFC-23 fed 

into the destruction device 

(FD used in Eq. O-8 and O-9). 

O-9 Provides production or raw 

material data described in 

section 2.1 of Part Two of this 

memorandum. 

O §98.156(b)(2) Annual mass of HFC-23 

destroyed (D23 used in Eq. 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, revealing 

information 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, revealing 

information 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, revealing 

information 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, revealing 

information 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, revealing 

information 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, revealing 

information 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) Annual 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 CO2 emissions (No 

CEMS) - solid fuel 

combusted (Csf). 

Q-1 Provides production or raw 

material data described in 

section 2.1 of Part Two of this 

memorandum. 
79

Subpart 

Rule Citation in 40 CFR Part 

98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . Analysis Results 

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

process input used to 

determine CO2 emissions (No 

CEMS) -gaseous fuel 

combusted(Cgf). 

Q-1 Provides production or raw 

material data described in 

section 2.1 of Part Two of this 

memorandum. 

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

process input used to 

determine CO2 emissions (No 

CEMS)- liquid fuel 

combusted (Clf). 

Q-1 Provides production or raw 

material data described in 

section 2.1 of Part Two of this 

memorandum. 

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

process input used to 

determine CO2 emissions (No 

CEMS)- greenball pellets 

produced (Co). 

Q-1 Provides production or raw 

material data described in 

section 2.1 of Part Two of this 

memorandum. 

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

process output used to 

determine CO2 emissions (No 

CEMS) - Fired pellets 

produced (Cp). 

Q-1 Provides production or raw 

material data described in 

section 2.1 of Part Two of this 

memorandum. 

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

process output used to 

determine CO2 emissions (No 

CEMS) - air pollution control 

residue collected (Cr). 

Q-1 Provides production or raw 

material data described in 

section 2.1 of Part Two of this 

memorandum. 

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

process input used to 

determine CO2 emissions (No 

CEMS)- Iron (Ciron). 

Q-2 Provides production or raw 

material data described in 

section 2.1 of Part Two of this 

memorandum. 

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

process input used to 

determine CO2 emissions (No 

CEMS)- Scrap (Cscrap). 

Q-2 Provides production or raw 

material data described in 

section 2.1 of Part Two of this 

memorandum. 

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

process input used to 

determine CO2 emissions (No 

CEMS)- Flux (Cflux). 

Q-2 Provides production or raw 

material data described in 

section 2.1 of Part Two of this 

memorandum. 

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

process input used to 

determine CO2 emissions (No 

CEMS)- Carbonaceous 

material (Ccarbon). 

Q-2 Provides production or raw 

material data described in 

section 2.1 of Part Two of this 

memorandum. 

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

process output used to 

determine CO2 emissions (No 

CEMS) - Steel produced 

(Csteel).. 

Q-2 Provides production or raw 

material data described in 

section 2.1 of Part Two of this 

memorandum. 

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

process output used to 

determine CO2 emissions (No 

CEMS) - Slag produced 

(Cslag). 

Q-2 Provides production or raw 

material data described in 

section 2.1 of Part Two of this 

memorandum. 

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

process output used to 

determine CO2 emissions (No 

CEMS) - Air pollution control 

residue collected (CR). 

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 CO2 emissions (No 

CEMS)- Coal charged to coke 

battery (Ccoal). 

Q-3 Provides production or raw 

material data described in 

section 2.1 of Part Two of this 

memorandum. 

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

process output used to 

determine CO2 emissions (No 

CEMS) - Coke produced by 

coke battery (Ccoke). 

Q-3 Provides production or raw 

material data described in 

section 2.1 of Part Two of this 

memorandum. 

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

process output used to 

determine CO2 emissions (No 

CEMS) - Air pollution control 

residue collected from coke 

battery (CR). 

Q-3 Provides production or raw 

material data described in 

section 2.1 of Part Two of this 

memorandum. 

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

process input used to 

determine CO2 emissions (No 

CEMS)- Gaseous fuel 

combusted in the sinter 

process (Cgf). 

Q-4 Provides production or raw 

material data described in 

section 2.1 of Part Two of this 

memorandum. 

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

process input used to 

determine CO2 emissions (No 

CEMS) - sinter feed (CFeed). 

Q-4 Provides production or raw 

material data described in 

section 2.1 of Part Two of this 

memorandum. 

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

process output used to 

determine CO2 emissions (No 

CEMS) - sinter (CSinter). 

Q-4 Provides production or raw 

material data described in 

section 2.1 of Part Two of this 

memorandum. 

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

process output used to 

determine CO2 emissions (No 

CEMS) - Air pollution control 

residue collected from sinter 

process (CR). 

Q-4 Provides production or raw 

material data described in 

section 2.1 of Part Two of this 

memorandum. 

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

process input used to 

determine CO2 emissions (No 

CEMS)- Iron (Ciron) used in 

EAF. 

Q-5 Provides production or raw 

material data described in 

section 2.1 of Part Two of this 

memorandum. 

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

process input used to 

determine CO2 emissions (No 

CEMS)- Scrap (Cscrap) used in 

EAF. 

Q-5 Provides production or raw 

material data described in 

section 2.1 of Part Two of this 

memorandum. 

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

process input used to 

determine CO2 emissions (No 

CEMS)- Flux (Cflux) used in 

EAF. 

Q-5 Provides production or raw 

material data described in 

section 2.1 of Part Two of this 

memorandum. 

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

process input used to 

determine CO2 emissions (No 

CEMS)- Carbonaceous 

material (Ccarbon) used in EAF. 

Q-5 Provides production or raw 

material data described in 

section 2.1 of Part Two of this 

memorandum. 
81

Subpart 

Rule Citation in 40 CFR Part 

98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . Analysis Results 

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

process input used to 

determine CO2 emissions (No 

CEMS)- Electrode consumed 

in EAF (Celectrode). 

Q-5 Provides production or raw 

material data described in 

section 2.1 of Part Two of this 

memorandum. 

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

process output used to 

determine CO2 emissions (No 

CEMS) - Steel produced 

(Csteel) in EAF. 

Q-5 Provides production or raw 

material data described in 

section 2.1 of Part Two of this 

memorandum. 

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

process output used to 

determine CO2 emissions (No 

CEMS) - Slag produced (Cslag) 

in EAF. 

Q-5 Provides production or raw 

material data described in 

section 2.1 of Part Two of this 

memorandum. 

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

process output used to 

determine CO2 emissions (No 

CEMS) - Air pollution control 

residue collected (CR) for 

EAF. 

Q-5 Provides production or raw 

material data described in 

section 2.1 of Part Two of this 

memorandum. 

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

process input used to 

determine CO2 emissions (No 

CEMS) - molten steel before 

decarburization (Csteelout) in 

EAF. 

Q-6 Provides production or raw 

material data described in 

section 2.1 of Part Two of this 

memorandum. 

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

process output used to 

determine CO2 emissions (No 

CEMS) - molten steel after 

decarburization (Csteelout) in 

EAF. 

Q-6 Provides production or raw 

material data described in 

section 2.1 of Part Two of this 

memorandum. 

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

process output used to 

determine CO2 emissions (No 

CEMS) - Air pollution control 

residue collected (CR) for 

EAF. 

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 CO2 emissions (No 

CEMS) - Gaseous fuel 

combusted in the direct 

reduction furnace (Fg) . 

Q-7 Provides production or raw 

material data described in 

section 2.1 of Part Two of this 

memorandum. 

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

process input used to 

determine CO2 emissions (No 

CEMS) - iron ore or iron ore 

pellets fed into the direct 

reduction furnace (Core) . 

Q-7 Provides production or raw 

material data described in 

section 2.1 of Part Two of this 

memorandum. 

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

process input used to 

determine CO2 emissions (No 

CEMS)- Carbonaceous 

material (Ccarbon) used in the 

direct reduction furnace . 

Q-7 Provides production or raw 

material data described in 

section 2.1 of Part Two of this 

memorandum. 
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 CO2 emissions (No 

CEMS) - Other materials 

charged to the direct reduction 

furnace (Cother). 

Q-7 Provides production or raw 

material data described in 

section 2.1 of Part Two of this 

memorandum. 

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

process output used to 

determine CO2 emissions (No 

CEMS) - Iron produced from 

direct reduction furnace (Ciron). 

Q-7 Provides production or raw 

material data described in 

section 2.1 of Part Two of this 

memorandum. 

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

process output used to 

determine CO2 emissions (No 

CEMS) - Non-metallic 

materials produced from direct 

reduction furnace (CNM). 

Q-7 Provides production or raw 

material data described in 

section 2.1 of Part Two of this 

memorandum. 

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

process output used to 

determine CO2 emissions (No 

CEMS) - Air pollution control 

residue collected (CR) for 

direct reduction furnace. 

Q-7 Provides production or raw 

material data described in 

section 2.1 of Part Two of this 

memorandum. 

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

gaseous fuel used to determine 

CO2 emissions (reported 

separately for each type in 

standard cubic feet) (No 

CEMS) - Taconite Indurating 

Furnace. 

Q-1 Provides production or raw 

material data described in 

section 2.1 of Part Two of this 

memorandum. 

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

liquid fuel used to determine 

CO2 emissions (reported 

separately for each type in 

gallons) (No CEMS). 

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 CO2

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 CO2

emissions (No CEMS)- 

Annual mass of solid fuel 

combusted (Fs). 

Q-1 Provides production or raw 

material data described in 

section 2.1 of Part Two of this 

memorandum. 

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

of each other process output 

used to determine CO2

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 CO2

emissions (No CEMS) - 

Annual mass of fired pellets 

produced (P). 

Q-1 Provides production or raw 

material data described in 

section 2.1 of Part Two of this 

memorandum. 
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 CO2

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 CO2

emissions (No CEMS)- 

Annual mass of scrap charged 

to the furnace (Scrap). 

Q-2 Provides production or raw 

material data described in 

section 2.1 of Part Two of this 

memorandum. 

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

of each other process input 

used to determine CO2

emissions (No CEMS)- 

Annual mass of flux charged 

to the furnace (Flux). 

Q-2 Provides production or raw 

material data described in 

section 2.1 of Part Two of this 

memorandum. 

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

of each other process input 

used to determine CO2

emissions (No CEMS)- 

Annual mass of carbon (e.g., 

coal, coke) charged to furnace 

(Carbon). 

Q-2 Provides production or raw 

material data described in 

section 2.1 of Part Two of this 

memorandum. 

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

of each other process output 

used to determine CO2

emissions (No CEMS) - 

Annual mass of steel produced 

(Steel). 

Q-2 Provides production or raw 

material data described in 

section 2.1 of Part Two of this 

memorandum. 

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

of each other process output 

used to determine CO2

emissions (No CEMS) - 

Annual mass of slag produced 

(Slag). 

Q-2 Provides production or raw 

material data described in 

section 2.1 of Part Two of this 

memorandum. 

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

of each other process output 

used to determine CO2

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 CO2

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 CO2

emissions (No CEMS) - 

Annual mass of coke produced 

(Coke). 

Q-3 Provides production or raw 

material data described in 

section 2.1 of Part Two of this 

memorandum. 
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 CO2

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 

CO2 emissions (reported 

separately for each type in 

standard cubic feet) (No 

CEMS) - Sinter process (Fg). 

Q-4 Provides production or raw 

material data described in 

section 2.1 of Part Two of this 

memorandum. 

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

of each other process input 

used to determine CO2

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 CO2

emissions (No CEMS)- 

Annual mass of sinter 

Produced (Sinter). 

Q-4 Provides production or raw 

material data described in 

section 2.1 of Part Two of this 

memorandum. 

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

of each other process output 

used to determine CO2

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 CO2

emissions (No CEMS)- 

Annual mass of direct reduced 

iron charged to the EAF 

(Iron). 

Q-5 Provides production or raw 

material data described in 

section 2.1 of Part Two of this 

memorandum. 

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

of each other process input 

used to determine CO2

emissions (No CEMS)- 

Annual mass of Scrap charged 

to the EAF(Scrap). 

Q-5 Provides production or raw 

material data described in 

section 2.1 of Part Two of this 

memorandum. 

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

of each other process input 

used to determine CO2

emissions (No CEMS)- 

Annual mass of flux charged 

to the EAF(Flux). 

Q-5 Provides production or raw 

material data described in 

section 2.1 of Part Two of this 

memorandum. 

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

of each other process input 

used to determine CO2

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 CO2

emissions (No CEMS)- 

Annual mass of steel produced 

(Steel) in EAF. 

Q-5 Provides production or raw 

material data described in 

section 2.1 of Part Two of this 

memorandum. 

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

of each other process output 

used to determine CO2

emissions (No CEMS) - 

Annual mass of slag produced 

(Slag) in EAF. 

Q-5 Provides production or raw 

material data described in 

section 2.1 of Part Two of this 

memorandum. 

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

of each other process output 

used to determine CO2

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 CO2

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 CO2

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 

CO2 emissions (reported 

separately for each type in 

standard cubic feet) (No 

CEMS) - direct reduction 

furnaces (Fg). 

Q-7 Provides production or raw 

material data described in 

section 2.1 of Part Two of this 

memorandum. 

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

of each other process input 

used to determine CO2

emissions (No CEMS)- 

Annual mass of iron ore or 

iron ore pellets charged to the 

direct reduction furnace (Ore). 

Q-7 Provides production or raw 

material data described in 

section 2.1 of Part Two of this 

memorandum. 
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 CO2

emissions (No CEMS)- 

Annual mass of carbonaceous 

(coal or coke) material 

charged to the direct reduction 

furnace (Carbon). 

Q-7 Provides production or raw 

material data described in 

section 2.1 of Part Two of this 

memorandum. 

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

of each other process input 

used to determine CO2

emissions (No CEMS)- 

Annual mass of other material 

charged to the direct reduction 

furnace (Other). 

Q-7 Provides production or raw 

material data described in 

section 2.1 of Part Two of this 

memorandum. 

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

of each other process input 

used to determine CO2 

emissions (No CEMS)- 

Annual mass of iron produced 

(Iron) in direct reduction 

furnace. 

Q-7 Provides production or raw 

material data described in 

section 2.1 of Part Two of this 

memorandum. 

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

of each other process input 

used to determine CO2 

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 CO2

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 CO2

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 CO2

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 CO2 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 CO2 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 CO2 emissions (No 

CEMS) (Ore = Annual mass 

of lead ore charged to the 

smelting furnace (tons).) 

R-1 Provides production or raw 

material data described in 

section 2.1 of Part Two of this 

memorandum. 

R §98.186(b)(6) Annual material quantity used 

for the calculation of annual 

process CO2 emissions (No 

CEMS) (Scrap = Annual mass 

of lead scrap charged to the 

smelting furnace (tons).) 

R-1 Provides production or raw 

material data described in 

section 2.1 of Part Two of this 

memorandum. 

R §98.186(b)(6) Annual material quantity used 

for the calculation of annual 

process CO2 emissions (No 

CEMS) (Flux = Annual mass 

of flux materials (e.g., 

limestone, dolomite) charged 

to the smelting furnace (tons).) 

R-1 Provides production or raw 

material data described in 

section 2.1 of Part Two of this 

memorandum. 

R §98.186(b)(6) Annual material quantity used 

for the calculation of annual 

process CO2 emissions (No 

CEMS) (Carbon = Annual 

mass of carbonaceous 

materials (e.g., coal, coke) 

charged to the smelting 

furnace (tons).) 

R-1 Provides production or raw 

material data described in 

section 2.1 of Part Two of this 

memorandum. 

R §98.186(b)(6) Annual material quantity used 

for the calculation of annual 

process CO2 emissions (No 

CEMS) (Other = Annual mass 

of any other material 

containing carbon, other than 

fuel, fed, charged, or 

otherwise introduced into the 

smelting furnace (tons).) 

R-1 Provides production or raw 

material data described in 

section 2.1 of Part Two of this 

memorandum. 

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

content determinations for 

each material used for the 

calculation of annual process 

CO2 emissions (No CEMS) 

(COre= Carbon content of the 

lead ore, from the carbon 

analysis results (percent by 

weight, expressed as a decimal 

fraction).) 

R-1 Provides production or raw 

material data described in 

section 2.1 of Part Two of this 

memorandum. 

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

content determinations for 

each material used for the 

calculation of annual process 

CO2 emissions (No CEMS). 

(CScrap= Carbon content of 

the lead scrap, from the carbon 

analysis (percent by weight, 

expressed as a decimal 

fraction).) 

R-1 Provides production or raw 

material data described in 

section 2.1 of Part Two of this 

memorandum. 
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 

CO2 emissions (No CEMS). 

(CFlux= Carbon content of the 

flux materials, from the carbon 

analysis (percent by weight, 

expressed as a decimal 

fraction).) 

R-1 Provides production or raw 

material data described in 

section 2.1 of Part Two of this 

memorandum. 

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

content determinations for 

each material used for the 

calculation of annual process 

CO2 emissions (No CEMS). 

(CCarbon= Carbon content of 

the carbonaceous materials, 

from the carbon analysis 

(percent by weight, expressed 

as a decimal fraction).) 

R-1 Provides production or raw 

material data described in 

section 2.1 of Part Two of this 

memorandum. 

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

content determinations for 

each material used for the 

calculation of annual process 

CO2 emissions (No CEMS). 

(COther= Carbon content of 

the other material from the 

carbon analysis results 

(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 CO2 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 

CO2 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 N2O abatement 

technology is operating (tons, 

100% acid basis). 

V-2 Provides production or raw 

material data described in 

section 2.1 of Part Two of this 

memorandum. 

V §98.226(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) N2O 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)), N2O 

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)), N2O 

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" 

((Fgf)n).

X-1 Provides production or raw 

material data described in 

section 2.1 of Part Two of this 

memorandum. 

X §98.246(a)(4) Monthly volume values (used 

in Equations X-1 to X-3) - 

Volume of gaseous product i 

produced in month "n" ((Pgf)n)

X-1 Provides production or raw 

material data described in 

section 2.1 of Part Two of this 

memorandum. 

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 gaseous 

products (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" ((Flf)n ). 

X-2 Provides production or raw 

material data described in 

section 2.1 of Part Two of this 

memorandum. 

X §98.246(a)(4) Monthly volume values (used 

in Equations X-1 to X-3) - 

Volume of liquid product i for 

month "n" ((Plp)n ) . 

X-2 Provides production or raw 

material data described in 

section 2.1 of Part Two of this 

memorandum. 

X §98.246(a)(4) Monthly mass values (used in 

Equations X-1 to X-3) - Mass 

of liquid feedstock i for 

month "n" ((Flf)n ). 

X-2 Provides production or raw 

material data described in 

section 2.1 of Part Two of this 

memorandum. 

X §98.246(a)(4) Monthly mass values (used in 

Equations X-1 to X-3) - Mass 

of liquid product i for month 

"n" ((Plp)n ). 

X-2 Provides production or raw 

material data described in 

section 2.1 of Part Two of this 

memorandum. 

X §98.246(a)(4) Monthly carbon content values 

(used in Equations X-1 to X-3) 

- Average carbon content of 

the liquid feedstock i for 

month "n" ((CClf)n). 

X-2 Provides production or raw 

material data described in 

section 2.1 of Part Two of this 

memorandum. 

X §98.246(a)(4) Monthly carbon content values 

(used in Equations X-1 to X-3) 

- Average carbon content of 

the liquid product i for month 

"n" ((CClp)n). 

X-2 Provides production or raw 

material data described in 

section 2.1 of Part Two of this 

memorandum. 

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" ((Fsf)n). 

X-3 Provides production or raw 

material data described in 

section 2.1 of Part Two of this 

memorandum. 

X §98.246(a)(4) Monthly mass values (used in 

Equations X-1 to X-3) - Mass 

of solid product i for month 

"n" ((Psp)n). 

X-3 Provides production or raw 

material data described in 

section 2.1 of Part Two of this 

memorandum. 

X §98.246(a)(4) Monthly carbon content values 

(used in Equations X-1 to X-3) 

- Average carbon content of 

the solid feedstock i for month 

"n" ((CClf)n). 

X-3 Provides production or raw 

material data described in 

section 2.1 of Part Two of this 

memorandum. 

X §98.246(a)(4) Monthly carbon content values 

(used in Equations X-1 to X-3) 

- Average carbon content of 

the solid product i for month 

"n" ((CClp)n). 

X-3 Provides production or raw 

material data described in 

section 2.1 of Part Two of this 

memorandum. 

X §98.246(b)(5)(iii) Quantity of each type of fuel 

used in equation C-8 in 

§98.33(c) for each stationary 

combustion unit or group of 

units (as applicable) during the 

reporting year, expressed in 

short tons for solid fuels, 

gallons for liquid fuels, and 

scf for gaseous fuels. 

C-8 Provides production or raw 

material data described in 

section 2.1 of Part Two of this 

memorandum. 

X §98.246(b)(5)(iv) The HHV (either default or 

annual average from measured 

data) used in equation C-8 in 

§98.33(C) for each stationary 

combustion unit or group of 

units (as applicable). 

C-8 Provides production or raw 

material data described in 

section 2.1 of Part Two of this 

memorandum. 

Y §98.256(e)(6) If using Equation Y-1a: report 

the molar volume conversion 

factor (in scf/g-mole) for each 

flare. 

Y-1a Would not reveal any 

proprietary information about 

facility or process performance, 

design, and operation; cost to 

do business; raw material 

usage; or production. Is a 

constant value widely known 

within the industry and publicly 

available. 

Y §98.256(e)(7) If using Equation Y-1b: report 

molar volume conversion 

factor for each flare. 

Y-1b Would not reveal any 

proprietary information about 

facility or process performance, 

design, and operation; cost to 

do business; raw material 

usage; or production. Is a 

constant value widely known 

within the industry and publicly 

available. 

Y §98.256(e)(7)(ii) If using Equation Y-1b: report 

the carbon mole number of 

each carbon containing 

compound other than CO2 in 

the flare gas stream for each 

flare. 

Y-1b Provides production or raw 

material data described in 

section 2.1 of Part Two of this 

memorandum. 
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 CO2 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 

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)(11) Units of measure for the unitspecific CH4 emission factor. 

Used in method 

specified in 

§98.253(c)(4) 

Would not reveal any 

proprietary information about 

facility or process performance, 

design, and operation; cost to 

do business; raw material 

usage; or production. Provides 

only the units of measure for 

the emission factor. 

Y §98.256(f)(11) Activity data for calculating 

emissions (input). 

Used in method 

specified in 

§98.255(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 N2O emission factor. 

Used in method 

specified in 

9§8.253(c)(5) 

Would not reveal any 

proprietary information about 

facility or process performance, 

design, and operation; cost to 

do business; raw material 

usage; or production. Provides 

only the units of measure for 

the emission factor. 

Y §98.256(f)(13) Average carbon content of 

coke. 

Y-11 Provides production or raw 

material data described in 

section 2.1 of Part Two of this 

memorandum. 
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 CH4 emission factor. 

Used in method 

specified in 

§98.253(c)(4) 

Provides data described in 

section 2.3 of Part Two of this 

memorandum that could be 

used to calculate either 

production or raw material 

consumption (depending on 

whether the facility uses an 

emission factor based on 

production throughput or raw 

material consumption) if the 

CH4 emissions (as currently 

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 

CH4 emission factor. 

Used in method 

specified in 

§98.253(c)(4) 

Would not reveal any 

proprietary information about 

facility or process performance, 

design, and operation; cost to 

do business; raw material 

usage; or production. Provides 

only the units of measure for 

the emission factor. 

Y §98.256(i)(8) For coke calcining: If a unit 

specific emission factor was 

used for the N2O factor: report 

the activity data used for 

calculating emissions. 

Used in method 

specified in 

§98.253(c)(5) 

Provides production or raw 

material data described in 

section 2.1 of Part Two of this 

memorandum. 

Y §98.256(i)(8) For coke calcining: If a unitspecific emission factor for 

N2O was used, report the 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 

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(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) CO2 emission factor for each 

asphalt blowing unit. 

Y-14 Provides data described in 

section 2.3 of Part Two of this 

memorandum that could be 

used to calculate the annual 

asphalt production if the CO2

emissions (as currently required 

to be reported under 40 CFR 

98.252(f) and made publicly 

available)5 are also known. 

Y §98.256(j)(6) CH4 emission factor for each 

asphalt blowing unit. 

Y-15 Provides data described in 

section 2.3 of Part Two of this 

memorandum that could be 

used to calculate the annual 

asphalt production if the CH4

emissions (as currently 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 CO2

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 CO2 emission factor 

used. 

Y-16b Provides data described in 

section 2.3 of Part Two of this 

memorandum that could be 

used to calculate the annual 

asphalt production if both the 

CO2 emissions (as currently 

required to be reported under 

40 CFR 98.252(f) and made 

publicly available)5

and the 

carbon emission factor 

“CEFAB” (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 

CO2 emissions (as currently 

required to be reported under 

40 CFR 98.252(f) and made 

publicly available)5

and the CO2

emission factor “EFAB,CO2” 

(required to be reported under 

40 CFR 98.256(j)(8)) are also 

known. Additionally, if the 

uncontrolled emissions 

represented by the CO2

emission factor “EFAB,CO2” are 

very low, could estimate annual 

asphalt production if only this 

carbon factor and the CO2

emissions are known. 

Y §98.256(j)(9) If you use Eq. Y-17: CH4

emission factor. 

Y-17 Provides data described in 

section 2.3 of Part Two of this 

memorandum that could be 

used to calculate the annual 

asphalt production if the CO2

emissions (as currently 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): CH4 emission 

factor used. 

Y-20 Provides data described in 

section 2.3 of Part Two of this 

memorandum that could be 

used to calculate the quantity of 

crude oil and intermediate 

products received from offsite 

if the CO2 emissions (as 

currently 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 quantity of crude oil plus 

the quantity of intermediate 

products received from off-site 

that are processed at the 

facility in the reporting year. 

Y-22 Provides production or raw 

material data described in 

section 2.1 of Part Two of this 

memorandum. 

Y §98.256(o)(4)(ii) For storage tanks that process 

unstabilized crude oil: 

Quantity of unstabilized crude 

oil received during the 

calendar year. 

Y-23 Provides production or raw 

material data described in 

section 2.1 of Part Two of this 

memorandum. 

Y §98.256(o)(4)(iii) For storage tanks that process 

unstabilized crude oil: 

Average pressure differential. 

Y-23 Provides data related to process 

design; process performance, 

and operation; and/or cost to do 

business, as described in 

section 2.2 of Part Two of this 

memorandum. Specifically, 

could reveal the type of crude 

oil processed, which can 

provide information regarding 

the production process and 

business costs. Additionally, 

provides data described in 

section 2.3 of Part Two of this 

memorandum that could be 

used to calculate the quantity of 

unstabilized crude oil received 

if both the average mole 

fraction of CH4 in the vent gas 

(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 CH4

in vent gas from the 

unstabilized crude oil storage 

tanks. 

Y-23 Provides production or raw 

material data described in 

section 2.1 of Part Two of this 

memorandum. 

Y §98.256(o)(4)(vi) If you did not use Equation 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 CH4 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 rate 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 CH4 of 0.5 

volume percent or greater. 

Used in methods 

specified in AP42, Section 5.2 

(referenced by 

§98.253(n)) 

Provides production or raw 

material data described in 

section 2.1 of Part Two of this 

memorandum. 

Z §98.266(f)(5) Monthly inorganic carbon 

content of phosphate rock for 

each wet-process phosphoric 

acid process line for which 

Equation Z-1a is used (percent 

by weight, expressed as 

decimal fraction) (No CEMS). 

Z-1a Provides production or raw 

material data described in 

section 2.1 of Part Two of this 

memorandum. 

Z §98.266(f)(5) Monthly CO2 (ton CO2/ton of 

phosphate rock) for which 

Equation Z-1b is used (No 

CEMS). 

Z-1b Provides data described in 

section 2.3 of Part Two of this 

memorandum that could be 

used to calculate the amount of 

phosphate rock consumed if the 

N2O emissions (as currently 

reported under 40 CFR 

98.3(c)(4) and made publicly 

available) 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 CO2 used 

in equation AA-1. 

AA-1 Provides data described in 

section 2.3 of Part Two of this 

memorandum that could be 

used to calculate the mass of 

spent liquor solids combusted if 

the following data are also 

known: CO2 emissions (as 

currently reported under 40 

CFR 98.3(c)(4) and made 

publicly available) 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 CH4 used 

in equation AA-1. 

AA-1 Provides data described in 

section 2.3 of Part Two of this 

memorandum that could be 

used to calculate the mass of 

spent liquor solids combusted if 

the following data are also 

known: CH4 emissions (as 

currently reported under 40 

CFR 98.3(c)(4) and made 

publicly available) 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 N2O used 

in equation AA-1. 

AA-1 Provides data described in 

section 2.3 of Part Two of this 

memorandum that could be 

used to calculate the mass of 

spent liquor solids combusted if 

the following data are also 

known: N2O emissions (as 

currently reported under 40 

CFR 98.3(c)(4) and made 

publicly available) 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 CaCO3

used for the reporting year 

used in Equation AA-3. 

AA-3 Provides production or raw 

material data described in 

section 2.1 of Part Two of this 

memorandum. 

AA §98.276(i) Make-up quantity of Na2CO3

used for the reporting year 

used in Equation AA-3. 

AA-3 Provides production or raw 

material data described in 

section 2.1 of Part Two of this 

memorandum. 

BB §98.286(b)(1) Monthly consumption of 

petroleum coke (No CEMS). 

BB-2 Provides production or raw 

material data described in 

section 2.1 of Part Two of this 

memorandum. 

BB §98.286(b)(4) Carbon content factor of 

petroleum coke from the 

supplier or as measured by the 

applicable method. 

BB-1 Provides production or raw 

material data described in 

section 2.1 of Part Two of this 

memorandum. 

BB §98.286(b)(6) CO2 emissions factor for each 

month. 

BB-2 Provides data described in 

section 2.3 of Part Two of this 

memorandum that could be 

used to estimate the amount of 

petroleum coke consumed if the 

CO2 emissions (as currently 

reported under 40 CFR 

98.3(c)(4) and made publicly 

available) 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 CO2 concentration 

during performance test 

(percent CO2) for each 

manufacturing line or stack. 

CC-3 Provides information about the 

CO2 concentration in exhaust 

gas stream measured during the 

performance test and 

§98.would not reveal any 

proprietary information about 

facility or process performance, 

design, and operation; cost to 

do business; raw material 

usage; or production. 

CC §98.296(b)(10)(iii) CO2 emission factor of process 

vent flow from mine water for 

each manufacturing line or 

stack. 

CC-5 Does not include, and could not 

be used to calculate, data or 

information (about facility or 

process performance, design, 

and operation; cost to do 

business; raw material usage; or 

production) that would reveal 

information that could cause 

competitive harm. 

CC §98.296(b)(10)(iv) CO2 emission mass emission 

rate during performance test 

(metric tons/hour) for each 

manufacturing line or stack. 

CC-4 Would not reveal any 

proprietary information about 

facility or process performance, 

design, and operation; cost to 

do business; raw material 

usage; or production. Data 

cannot be used to calculate the 

annual production or raw 

material consumption since the 

production and raw material 

usage during the performance 

test is not reported. 

CC §98.296(b)(10)(v) Average process vent flow 

from mine water 

stripper/evaporator during 

performance test for each 

manufacturing line or stack. 

CC-4 Would not reveal any 

proprietary information about 

facility or process performance, 

design, and operation; cost to 

do business; raw material 

usage; or production. Data 

cannot be used to calculate 

annual production or raw 

material consumption since the 

production rate and raw 

material consumption during 

the performance test is not 

reported. 

CC §98.296(b)(10)(vi) Annual process vent flow rate 

from mine stripper/evaporator 

for each manufacturing line or 

stack. 

CC-5 Would not reveal any 

proprietary information about 

facility or process performance, 

design, and operation; cost to 

do business; raw material 

usage; or production. 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 Results 

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

charged to kilns or furnace 

(including zinc bearing 

material, flux materials, and 

other carbonaceous materials) 

from the annual carbon 

analysis or from information 

provided by the material 

supplier) for each kiln or 

furnace (percent by weight, 

expressed as a decimal 

fraction) (No CEMS) - flux 

materials. 

GG-1 Provides production or raw 

material data described in 

section 2.1 of Part Two of this 

memorandum. 

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

charged to kilns or furnace 

(including zinc bearing 

material, flux materials, and 

other carbonaceous materials) 

from the annual carbon 

analysis or from information 

provided by the material 

supplier) for each kiln or 

furnace (percent by weight, 

expressed as a decimal 

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."