# Technical Support Document Additional Threshold Analysis Greenhouse Gas Tailoring Rule

Air Quality Policy Division Office of Air Quality Policy and Standards

U.S. Environmental Protection Agency

October 12, 2011i Table of Contents

Page

1. Purpose.................................................................................................................... .................. 1

2. Overview .................................................................................................................. ................. 1

3. Step 3 Emissions-based Thresholds Analysis Methodology ................................................. 2

3.1 Threshold Levels ......................................................................................................... ......... 2 3.2 Greenhouse Gases ......................................................................................................... ....... 2 3.3 Source Sectors ........................................................................................................... ........... 3 3.4 Potential to Emit Methodology ............................................................................................ 4 3.5 New and Modified Sources ................................................................................................. . 4 3.6 Sectors and Subsectors Unaffected by Thresholds Between 50,000 and 100,000 .............. 5 3.7 Thresholds Analysis-Thresholds Between 50,000 and 100,000 tons CO 2 e ......................... 6

4. Electricity Generating Sector ............................................................................................. ..... 8

5. Industrial Sector.......................................................................................................... ........... 10

5.1 Industrial Sector Overview ............................................................................................... . 10

5.1.1 Data Sources ........................................................................................................... .... 12 5.1.2 Potential to Emit Methodology ................................................................................... 12 5.1.3 Methodology for New Units ....................................................................................... 13

5.2 Ammonia Production ....................................................................................................... .. 13 5.3 Cement Production......................................................................................................... .... 14 5.4 Electronic Production .................................................................................................... ..... 15 5.5 Food Processing .......................................................................................................... ....... 17 5.6 Glass Manufacturing ...................................................................................................... .... 18 5.7 Hydrogen Production ...................................................................................................... ... 19 5.8 Iron and Steel Production................................................................................................. .. 20 5.9 Lead Production .......................................................................................................... ....... 22 5.10 Lime .................................................................................................................... ............. 23 5.11 Nitric Acid Production .................................................................................................. ... 24 5.12 Petrochemical Production ................................................................................................ 25 5.13 Petroleum Refineries .................................................................................................... .... 26 5.14 Pulp and Paper Manufacturing......................................................................................... 27 5.15 Unspecified Industrial Stat ionary Combustion Sources .................................................. 29ii Table of Contents (cont.)

Page

6. Energy Sector ............................................................................................................. ............ 30

6.1 Oil and Gas Systems ...................................................................................................... .... 30 6.2 Underground Coal Mining ................................................................................................. 31

7. Waste Sector .............................................................................................................. ............. 33

7.1 Landfills ................................................................................................................ ............. 33 7.2 Municipal Solid Waste Combustors .................................................................................. 35

8. Commercial Stationary Fuel Combustion ........................................................................... 37

9. Residential Stationary Combustion...................................................................................... 40

9.1 Multi-Family Residential Buildings .................................................................................. 40

References .................................................................................................................... ................ 46

Appendix A .................................................................................................................... .............. 49

Appendix B .................................................................................................................... .............. 501 Technical Support Document for A dditional Threshold Analysis Greenhouse Gas Tailoring Rule

1. Purpose

In the final Tailoring Rule, EPA established an enforceable commitment to propose or solicit comment on a third step of the phase-in approach. This Technical Support Document (TSD) provides the background information used to support EPA's Step 3 decision process for evaluating potential greenhouse gas (GHG) em ission thresholds between 50,000 and 100,000 tons per year for New Source Review (NSR) and Title V permitting. The analysis conducted provides estimates of the number of existing and new f acilities (e.g., industrial plant, commercial building) that would exceed differing GHG emis sion threshold levels, summarizing the results for each sector. The results of this analysis serv ed as one of the fundamental bases for evaluating administrative burdens at different permitting thresholds to address administrative necessity

concerns.

2. Overview

The Step 3 threshold analysis relies on th e analysis conducted to support the threshold decisions in the final Tailoring Rule, which is documented in the Technical Support Document for Greenhouse Gas Emissions Thresholds Evaluation , EPA-HQ-OAR-2009-0517-19158 (March 29, 2010).

The analysis developed information on the number of affected f acilities at both the current permitting major source thresholds (gener ally, 100 tons per year for Title V and 100 or 250 tons per year for PSD depending on the source category classification) and at alternative higher thresholds. An affected facility w ould be one whose annual GHG emissions equal or exceed the emissions threshold being evaluated.

Also in the original analys is, eight threshold levels of GHG emissions ranging from 100 to 100,000 tons per year carbon dioxide equivalents (CO 2 e) were evaluated. Some of these thresholds (e.g., 25,000 tons per year CO 2 e) were the same as those considered in previous studies and in support of EPA's GHG Repor ting Program (GHGRP) (74 FR 16447-731). One key difference between the emissions data devel oped for the permit threshold analysis and that developed to support the GHGRP is that the permit threshold analysis is based on a facility's "potential to emit" (PTE), while the GHGRP is based on "actual" emissions (i.e., a facility’s actual emissions in a given year). PTE is de fined as the maximum capacity of a stationary source to emit a pollutant under it s physical and operational de sign, including certain legal limitations on such things as emissions or hours of operation. The NSR and Title V programs both use PTE for defining major sources, where the e nd result is generally that more facilities will exceed a given threshold on a PTE basis than on an actual basis. This is an important differentiation for both evaluating the thresholds under this proposed rule and comparing the results to other threshold analyses, such as the supporting data for EPA's GHGRP.2 In performing the permitting threshold analysis , EPA made use of earlier analyses from the development of emission thresholds for th e GHGRP, or used the same data sources when additional analyses were required. EPA did not conduct primary research, instead relying on published research and publicly available government data, in cluding the Agency’s own eGRID database of electric generating source emissi ons, U.S. Census Bureau Economic and Housing data, and Energy Information Agency (EIA) data on energy consumption.

Although the primary focus of the analysis was on the potential administrative burden associated with different GHG permitting emission levels as represented in terms of number of facilities potentially subject to permitting, inform ation on GHG emissions from affected facilities was also developed to assess th e relative coverage of nationa l stationary source GHG emissions at the different threshold levels. Although EPA di d not use the environmental impact associated with the different GHG permitting levels as the basis for the GHG thresholds in the rule, the information on national emissions coverage provid es a useful measure of the potential scope of the proposed alternative thresholds, their covera ge of key GHG emission source categories, and their promotion, if any, of the environmental purposes of the PSD and Title V programs. This is true as well for the additional Step 3 anal ysis of annual GHG thresholds between 50,000 and100,000 tons CO 2 e.

3. Step 3 Emissions-based Thresholds Analysis Methodology

3.1 Threshold Levels

As noted above, in the analysis for the fina l Tailoring Rule EPA evaluated eight different PTE thresholds between 100 tons per year CO 2 e and 100,000 tons per year CO 2 e, including 50,000 tons per year CO 2 e. For the Step 3 analysis, EPA refined its previous analysis by evaluating eight additional thresholds between 50,000 and 100,000 tons per year CO 2 e in 5,000 ton increments (55,000 through 95,000 tons per year CO 2 e).

3.2 Greenhouse Gases

EPA evaluated emissions of GHGs that are directly emitted by human activities at the eight threshold levels. Table 3- 1 indicates which GHGs were eval uated. For purposes of this analysis, emissions were evaluated on a CO 2 e basis. CO 2 e normalizes the different heat trapping capacities of the various GHGs to that of CO 2 . A quantity of a GHG is converted to a CO 2 e basis by multiplying the mass of the compound emitted by its Global Warming Potential (GWP). The GWP is a metric that incorporates both the heat-trapping ability and atmospheric lifetime of each GHG relative to CO 2
.3 Table 3-1 Major GHGs Directly Emitte d by Human Activities

Greenhouse Gas Chemical Formula or Acronym Global Warming Potential (GWP)*

Carbon dioxide CO 2 1

Methane CH 4 21

Nitrous oxide N 2 O 310
Perfluorocarbons PFCs Varies by compound
Hydrofluorocarbons HFCs Varies by compound

Sulfur hexafluoride SF 6 23,900

* EPA has chosen to use GWPs from th e Intergovernmental Panel on Climate

Change (IPCC) Second Assessment Report (SAR) published in 1996. For fluorinated compounds that are not listed in the SAR, EPA is using the most recent available GWPs from either the IPCC Third Assessment Report (2001) or Fourth Assessment Report (2007). Table A-1 in the GHGRP rule contains more specific informati on about the GWP of specific GHGs.

Each sector covered in this document incl udes a description of the GHGs evaluated. Because CO 2 constitutes over 99% of GHG emissions from fossil fuel combustion, the threshold analyses for stationary fossil fuel com bustion were often simplified by excluding CH 4 and N 2 O emissions.

3.3 Source Sectors

EPA evaluated the same stationary source ty pes with direct GHG emissions as are found in the GHGRP. The GHGRP source categories we re based on a comprehensive review of all U.S. source categories with GHG emissions, and include those with the most significant GHG emissions. The stationary sources can be grouped in these sectors:

● Electricity Generation (facilities with fossil fuel-fired electric generating units);

● Industry (range of industries with process and combustion GHG emissions);

● Energy (oil and gas extractio n, transport, and processi ng; underground coal mining);

● Waste Treatment (landfills and municipal solid waste incinerators);

● Agriculture (stationary fuel combustion);

● Commercial (stationary fuel combustion); and

● Residential (stationary fuel combustion).4 Some direct emission source types included in the GHGRP were not included in the PTE analysis because their GHG emissions were primarily “fugitive”. Fugitive emissions are emissions that are not released, or could not be reasonably releas ed, through a stack or vent. Excluded fugitive emissions sources include:

● Electrical equipment SF 6 emissions;

● Wastewater treatment plants not associ ated with one of the 28 listed PSD source categories (combustion is captured in the commercial sector analysis); and

● Agricultural manure management.

3.4 Potential to Emit Methodology

As noted above, PTE is the amount of emissions that can be emitted from a source operating at full capacity. The annual PTE is ba sed on operation at full equipment capacity -- 24 hours per day, 365 days per year (8,760 hours per y ear). For example, if a boiler has a maximum rated heat input capacity of ten million Btu (mmB tu) per hour, the annual PTE for that boiler is the amount of emissions from burning 87,600 million Btu of fuel:

10 mmBtu/hr x 8,760 hrs/yr = 87,600 mmBtu/yr

Capacity information and annual GHG emissions were available for some of the source categories from analyses performed to support the GHGRP. In instances where the supporting analyses had already calculated GHG emissions on a full capacity basis, EPA directly used those estimates as PTE estimates. Alternatively, some data from the supporting analysis estimated actual annual emissions using a baseline year. If capacity an d baseline year production information was provided in the supporting data , EPA adjusted the source category’s actual emissions estimate by the ratio of annual capacit y to baseline production to estimate PTE. If capacity information was not available, EPA used capacity factors from other data sources to adjust actual emission estimates to PTE estimates. These capacity factors add varying uncertainty to the PTE estimate. Detailed de scriptions of the diffe rent PTE calculation methodologies are included in the source descriptions in the following sections.

Although PTE estimates account for removal by pollution control equipment, such removal is relevant in only a few cases (e.g., thermal oxidation of HPCs and CH 4 ). Also, fugitive emissions were included in the PTE esti mates only if the source was one of the 28 listed PSD source categories. For example, fugitive CH 4 emissions were not included in CH 4 or CO 2 e emissions from oil and gas processing plants but were included for iron and steel plants.

3.5 New and Modified Sources

The source population data from the analyses supporting the GHGRP as well as other data sources provide information on existing so urces and their emissions. The PSD and NSR program construction permit requirements, howev er, apply to new or modified sources.5 The general approach for new sources was to ap ply growth rates in the number of units or facilities in a source category to the number of existing facilities at the different thresholds. Growth rates were available from a variety of sources including U.S. Census Bureau Economic data, EIA energy survey data, and various EPA regulatory impact analyses (RIA) and information collection requests (ICR) requiring source population estimates. In some cases, there was sufficient information to distribute new sources to different thresholds based on emission information specific to the new sources (e.g., electric generating, municipal solid waste combustors, and commercial stationary fuel co mbustion). Where sufficient information was not available, EPA assumed the same size and thres hold distribution for new units as for existing units. For example, if the annual growth rate in a category was 1%, the number of existing facilities above a threshold was multiplied by th e fractional growth rate to estimate the number of new facilities at that threshold per year.

EPA did not develop estimates for modifications as part of this th reshold study, but did do so under another technical suppor t document (TSD) for the original threshold burden analysis (EPA-HQ-OAR-2009-0517-19157).

3.6 Sectors and Subsectors Unaffected by Thresholds Between 50,000 and 100,000

Certain sectors and subsectors are not affected by threshold changes between 50,000 and 100,000 tons because all of the fac ilities in the sector or subsec tor are either below 50,000 tons per year or above 100,000 tons per year. Tables 3- 2 and 3-3 provide counts of stationary source facilities in these unaffected se ctors and subsectors along with th e actual GHG emissions from these facilities. These GHG emissions are expresse d in teragrams (Tg), which is equivalent to a million metric tons. SI units were used for the covered emissions to be consistent with the U.S. GHG Inventory and the GHGRP. The analysis discussion and comple te data for the sectors and subsectors are provided in the Technical Support Document for Greenhouse Gas Emissions Thresholds Evaluation , EPA-HQ-OAR-2009-0517-19158 (March 29, 2010).

Table 3-2 Categories with No Sources Captured by the 50,000 and 100,000 Tons CO 2 e Thresholds

Sector/Source Category Highest Threshold Exceeded by a Source Number of Existing Sources Number of New Facilities Added per Year CO 2 e Emissions Covered (Tg per year)
Agriculture/Stationary Combustion 250 37,351 299 0.5

Residential/ Single Family Stationary Combustion 250 45,350 515 1.76 Table 3-3 Categories with All Sources Captured by the 50,000 and 100,000 Tons CO 2 e Thresholds

Sector/Source Category Number of Existing Sources Number of New Facilities Added per Year CO 2 e Emissions Covered (Tg per year)
Industrial /Adipic Acid Production 4 0 9.3

Industrial/Aluminum Production 15 0 4.0
Industrial/Ferroalloy Production 9 0 1.7

Industrial/ HCFC-22 Production 3 0 13.8
Industrial/Magnesium Production 9 0 2.8
Industrial/Phosphoric Acid Production 14 0 3.8
Industrial /Silicon Carbide Manufacturing 1 0 0.1

Industrial/Soda Ash Production 5 0 3.1

Industrial/Titanium Dioxide 8 0 3.7

Industrial/Zinc Production 5 0 0.8

Total 73 0 43.2

3.7 Thresholds Analysis-Thresholds Between 50,000 and 100,000 tons CO 2 e

Table 3-4 indicates those s ectors and subsectors affected by changes in thresholds between 50,000 and 100,000. These sectors were the focus of the Step 3 threshold analysis. The sections following the table desc ribe the sector specific analysis performed for each sector, and resulting counts of affected stationary source f acilities, new facilities, and the amount of actual GHG emissions covered at each of th e additional PTE thresholds. Re sults for all of these sectors are identified in Appendix A, and suppor ting data are listed in Appendix B.7 Table 3-4 Source Categories Affected by Addition al Thresholds Between 50,000 and 100,000

Sector/Source Category 50,000 Tons/Year PTE Threshold 100,000 Tons/Year PTE Threshold

Number of

Existing Sources CO 2 e Emissions

Covered (Tg per year) Number of Existing Sources CO 2 e Emissions

Covered (Tg per year)
Electricity Generation/Electricity Generating Units 1,911 2373.1 1,721 2371.9

Industrial/Ammonia Manufacturing 24 14.5 22 14.5

Industrial/Cement Production 107 86.8 106 86.7
Industrial/Electronics Manufacturing 54 5.1 22 3.4
Industrial/Food Processing 10 0.6 0 0

Industrial/Glass Production 21 1.2 3 0.4
Industrial/Hydrogen Production 38 14.9 32 14.4

Industrial/Iron and Steel Production 116 84.8 113 84.7

Industrial/Lead Production 12 0.8 1 0.1
Industrial/Lime Manufacturing 66 26.5 60 26.2

Industrial/Nitric Acid Production 43 17.7 42 17.7

Industrial/Petrochemical Pr oduction 94 54.7 91 54.5

Industrial/Petroleum Refineries 137 204.5 129 204.0
Industrial/Pulp and Paper Manufacturing 422 57.7 410 57.5
Industrial/Unspecified Industrial Stationary Combustion (Other Manufacturing and Industrial Facilities) 3,272 206.9 958 145.1

Energy/Oil and Natural Gas Systems 1,045 56.9 387 32.8
Energy/Underground Coal Mines 78 32.8 55 31.2

Waste/Landfills 1,684 92.3 967 72.7
Waste/Municipal Waste Combustors 67 6.1 40 5.0
Commercial/Stationary Fuel Combustion 600 6.0 51 1.0
Residential/Multi-family Fuel Combustion 20 0.1 0 0.08 4. Electricity Generating Sector

The electricity generating sector consists of facilities with fossil fuel fired electric generating units that rely on fu el combustion for their energy source and that have a North American Industry Classification System (NAICS) code prefix of 22 (Utilities).

Data Sources

EPA's eGRID database (2006) was used to estimate the PTE of el ectricity generating facilities and counts of units a bove the different emission thres holds. eGRID includes year 2004 characteristics, operating informati on, and annual emissions (including CO 2 ) for U.S. facilities that have a generation capacity greater than one MW and sell electric power to the grid.

Potential to Emit

A facility's PTE was estimated based on the eGRID generator table, which draws from the 2004 EIA Form 860 database, and provides pr ime mover, generator nameplate capacity, and primary energy source (fuel type) for each generator down to 0.1 MW. To calculate PTE, EPA combined the nameplate capacity and primary fuel for each of the fossil-fired units with average fuel-based prime mover heat rates (Btu/kWh) published by EIA (EIA, 2007).

Table 4-1 EGU Prime Mover Heat Rates (EIA Electric Power Annual, Table A7, 2007)

Prime Mover Fuel Average Heat Rate (Btu/kWh)

Steam turbine Coal 10,114

Gas 10,466
Oil 10,400

Simple combustion turbine Gas 11,459
Oil 13,216

Combined cycle combustion turbine Gas 7,445
Oil 11,015

Internal combustion engine Gas 9,923
Oil 10,149

The eGRID database includes cogeneration plants and generating units at industrial plants that primarily supply electric power and steam to a host facility. EPA eliminated these units from the electric generation facility popul ation based on their NAICS code; thus, the only facilities included were those with a NAI CS code prefix of 22 (Utilities).9 The generator-nameplate-heat-rate appr oach potentially underestimates PTE for cogeneration plants, where a por tion of the burner heat input pr ovides useful thermal energy in addition to electric output. This potential to underestimate PTE affects 321 of the 2,237 facilities evaluated, or 14% of those facilities.

Fuel combustion was the only source of GH G emissions considered for the electricity generating sector. Using eGRID and EIA data EPA calculated a maximum annual fuel heat input based on 8,760 hours of operation for the combus tors associated with the generator. This calculated maximum annual heat input was used with fuel combustion CO 2 emission factors from the GHGRP for the primary fuel to calculate the facility PTE. EPA did not estimate the much less significant CH 4 and N 2 O contribution from fuel combus tion. The calculations covered 10,487 fossil fuel-fired generators with name plate capacities down to 0.1 MW or 100,000 kW.

Fossil fuel-fired steam electric plants with heat input greater than 250 mmBtu/hr are one of the 28 listed PSD source categories that includ e fugitive emissions when calculating PTE. However, EPA did not evaluate fugitive CH 4 emissions from coal piles at these facilities. The CO 2 PTE from combustion alone for this size fac ility is about 225,000 tons per year, which far exceeds the emission thresholds in this analys is without accounting for the contribution of fugitive CH 4
.

New Units

The eGRID generator table includes an online year field. To determine the number of new units per year at different thresholds, EPA counted generators online each year and totaled the emissions associated with those generators at the facility level over the 15-year period from 1990 – 2004. EPA determined the number of fa cilities over the different PTE thresholds and averaged over the 15 years to arrive at the num ber of new or modified facilities per year.

Threshold Summary

The table below shows the facilities and emissions covered at the different emission thresholds based on the described methodology. There were a total of 2,237 facilities in the electric generation population. Almost all emissi ons (99.9%), and about 75% of facilities, are covered at the highest 100,000 ton PTE threshold.10 Table 4-2 CO 2 e Threshold Summary Results -- El ectricity Generating Sector

GHG Threshold (tons per year) Number of Existing Sources Number of New Facilities Added per Year CO 2 e Emissions Covered (Tg per year)

50,000 1,911 64 2,373.1

55,000 1,890 64 2,372.9

60,000 1,865 63 2,372.8

65,000 1,838 63 2,372.6

70,000 1,822 62 2,372.6

75,000 1,806 62 2,372.5

80,000 1,789 61 2,372.4

85,000 1,778 61 2,372.4

90,000 1,763 61 2,372.4

95,000 1,746 60 2,372.2

100,000 1,721 60 2,371.9

5. Industrial Sector

The industrial sector consists of establishm ents engaged in the mechanical, physical, or chemical transformation of materials, subs tances, or components into new products, and specifically includes businesses cl assified by NAICS in Sectors 31 – 33. Industrial source GHGs result from manufacturing processes as well as combustion processes. Because there is a great deal of variability with in the sector, this technical suppor t document includes industry-specific discussions after a general sector overview.

5.1 Industrial Sector Overview

EPA identified the 23 industrial sectors with significant GHG emissions in the GHGRP. These sectors are listed in Table 5-1.11 Table 5-1 Industrial Source Categories and GHG Emissions

NAICS Code Industrial Source Category CO 2 CH 4 N 2 O SF 6 HFC PFC
325199 Adipic Acid Production X X

331312 Aluminum Production X X

325311 Ammonia Production X

327310 Cement Production X
334 Electronics Manufacturing X X X X

331112 Ferroalloy Production X X
3116 Food Processing X

327 Glass Production X

325120 HCFC-22 Production X X
Hydrogen Production X

331111 Iron and Steel Production X X

3314 Lead Production X
327410 Lime Manufacturing X
3314 Magnesium Production X X

325311 Nitric Acid Production X X

3251 Petrochemical Production X X

324110 Petroleum Refineries X X
325312 Phosphoric Acid Production X
3221 Pulp and Paper Manufacturing X

327910 Silicon Carbide Production X X
325181 Soda Ash Manufacturing X

325188 Titanium Dioxide Production X

3314 Zinc Production X

In addition, there are a large number of i ndustrial establishments across all industrial sectors that emit less significant amounts of GHGs (primarily CO 2 ) from stationary source fuel combustion. Combustion emissions from thes e establishments were analyzed under the Unspecified Industrial Stationary Combustion source category.12 5.1.1 Data Sources

EPA relied upon several primary data sources to prepare the permit threshold analysis, and consulted GHGRP analyses of the 23 industr ial sectors for which combustion, process and fugitive emissions were significant. These documents can be found in Supporting Data for Threshold Analysis Subpart E-W, Gree nhouse Gas Mandatory Reporting Rulemaking , March 10, 2009, EPA-HQ-OAR-2008-0508 ( Supporting Data for Threshold Analysis Subpart E-W) . The TSDs contain industry-specific analyses of pr ocess, fugitive, and combustion emissions for industries. Supporting analyses used to prep are the TSDs are found in entries 0046.7 and 0046.8 of the GHGRP docket (EPA-HQ-OA R-2008-0508-0046.7 and EPA-HQ-OAR-2008-0508- 0046.1). These emissions estimate details were helpful in breaking down TSD emission estimates to compare facility-specific emissi ons against the additional threshold levels considered in the original permit threshold an alysis, including 100, 250, 5,000, and 50,000 tons
per year.
Combustion emissions analyses for the Unsp ecified Industrial Stationary Combustion sectors drew data from the 2002 Manufacturing Energy Consumption Survey (MECS) and the U.S. Census Bureau's 2002 Economic Census. MECS is an EIA survey of manufacturing and industrial energy uses and co sts (EIA, 2007). Data is collected by the manufacturing establishment through mailed questionnaires. Th e 2002 MECS data reflect responses accounting for approximately 98% of the manufacturing payr oll and reports separate energy use estimates for 48 NAICS industrial sector groups. The MECS data provide the amount of fuel burned in 2002 by sector on an employment basis. The 2002 Economic Census data provide the number of establishments sorted by three-digit NAICS code and disaggregated into specific size categories based on employment (U.S. Census, 2004).

5.1.2 Potential to Emit Methodology

The GHGRP TSDs for the specific industrial so urce categories listed in Table 6 generally included facility GHG emission estimates at facility capacity or at actual production levels. If the estimates were made at capacity, no adjustments were needed for PTE beyond conversion from metric to short tons. If estimates were of actual emissions at less than full capacity, the actual emissions were adjusted to reflect capacity based on facility sp ecific capacity, if available.

Where capacity information was not availabl e to estimate PTE, the analyses applied utilization rates from the I ndustrial Production and Capacity Utilization, Federal Reserve Statistical Release G-17, to adjust actual emissions to determine PTE emissions. These utilization rates are prepared quarterly with annual revisions and ar e published on the web ( http://www.federalreserve.gov/releases/g17 ). The main data source for the industrial production and capacity utilization rates is the U.S. Cens us Bureau's Census of Manufactures. Data introduced from other Census Bureau publicatio ns include the Census of Services and the Services Annual Survey (for publishing) and se lected Current Industrial Reports. Additional government source data include new annual data on minerals from the U.S. Geological Survey (USGS) and updated deflators from the Bureau of Economic Analysis (BEA). In addition, the annual revisions include monthly production estimates that refl ect updated seasonal factors and13 the inclusion of monthly source data that became av ailable (or were revised) after the closing of the regular four-month reporting window.

For the general unspecified stationary co mbustion category, EPA assumed a capacity factor of 50% to adjust actual emissions to PTE.

5.1.3 Methodology for New Units

To determine the number of new units per year, EPA compared the number of establishments by three-digit NAICS code in 1998 to the number of establishments by three-digit NAICS code in 2002 and determined an average annual growth rate for each three-digit NAICS code. The growth rates were applied to each th reshold count to determine the number of annual new establishments per industry per threshold. If the growth rate was determined to be negative, EPA assumed that no new establishments would be added; however, establishments were not reduced to reflect negative growth rates. EPA also supplemented these growth rates with agency estimates of expected new sources from various ICRs and RIAs.

5.2 Ammonia Production

EPA reviewed the Supporting Data for Threshold Analysis Subpart E-W(EPA-HQOAR-2008-0508-0046.7) to determine actual emissi ons and calculate the PTE for 24 ammonia plants in operation. The an alysis spreadsheet details CO 2 actual emission calculations for each plant based on ammonia producti on and urea production, and CO 2 , CH 4 , and N 2 O emission calculations for stationary fuel combustion base d on 2006 data. For purposes of permit threshold analysis, the CH 4 and N 2 O emissions from combusti on were not significant.

Potential to Emit

Capacity information in the spreadsheet is based on the engineering design capacity adjusted for 340 days per year of effective pr oduction capability, using information provided by the USGS. The PTE estimates were made by multiplying the actual emission estimates by the ratio of annual ammonia capacity to annual ammonia production adjusted to 365 days a year of operation instead of 340. EPA assumed that ratio al so held for stationary combustion units at the plant.

New Units

EPA assumed that no new plants woul d be constructed for this sector.14 Threshold Summary

Table 5-2 CO 2 e Threshold Summary -- Ammonia Production

GHG Threshold (tons per year) Number of Existing Sources Number of New Facilities Added per Year CO 2 e Emissions Covered (Tg per year)

50,000 24 0 14.5

55,000 24 0 14.5

60,000 24 0 14.5

65,000 24 0 14.5

70,000 24 0 14.5

75,000 23 0 14.5

80,000 22 0 14.5

85,000 22 0 14.5

90,000 22 0 14.5

95,000 22 0 14.5

100,000 22 0 14.5

5.3 Cement Production

The second largest source of industrial CO 2 emissions in the United States is processrelated CO 2 emissions from cement production. Cement production is done in two stages. The first stage is clinker production, in which raw materials (primarily limestone) are heated to induce calcination and produce lime. Lime react s with silica-containing materials and iron ore and aluminum to form clinker. During the process, CO 2 is generated as a byproduct and released to the atmosphere. In addition, some of the clinker raw materials form partially or fully calcinated cement kiln dust instead of forming c linker, resulting in a dditional process-related CO 2 emissions. In the second stage of the pr oduction process, the cli nker is ground and mixed with gypsum and other materials to make cement.

Potential to Emit

The Technical Support Document for Process Em issions from Cement: Proposed Rule for Mandatory Reporting of Greenhouse Gases (EPA-HQ-OAR-2008-0508-0008) identifies 107 cement facilities in the United States, 106 of which exceed all permit thresholds for CO 2 . Based Table 4.1 of the TSD indicates that the one faci lity that did not exceed the 100,000 tons per year threshold has a clinker capacity of about 102,000 metric tons per year, and emissions of about 90,000 metric tons per year. On a short ton basis this facility would be very close to the 100,00015 tons/year threshold, at least 99,000 tons per year. For this analysis, EPA ke pt this facility below 100,000 tons per year but over 95,000 tons per year CO 2 e PTE.

New Units

As growth for the industrial sector was esti mated at 0.4%, no additional facilities were included in this analysis.

Threshold Summary

Table 5-3 CO 2 e Threshold Summary -- Cement Production

GHG Threshold (tons per year) Number of Existing Sources Number of New Facilities Added per Year CO 2 e Emissions Covered (Tg per year)

50,000 107 0 86.8

55,000 107 0 86.8

60,000 107 0 86.8

65,000 107 0 86.8

70,000 107 0 86.8

75,000 107 0 86.8

80,000 107 0 86.8

85,000 107 0 86.8

90,000 107 0 86.8

95,000 107 0 86.8

100,000 106 0 86.7

5.4 Electronic Production

The Technical Support Document for Process Em issions from Electronics Manufacture (Semiconductors, MEMs, Liquid Crysta l Displays, and Photovoltaics) (EPA-HQ-OAR-2008- 0508-0009) examined emissions of high GWP ga ses for semiconductor and related industry plants. Emissions from stationary fuel comb ustion were not included in the source category analysis, but were instead captured by the unspeci fied industrial stationary combustion analysis. EPA has followed this approach here as well.

Approximately one million metric tons of SF 6 as CO 2 e were emitted from the semiconductor industry in 2006 (Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990 – 2007). This is equivalent to 46 short tons of SF 6 . The semiconductor industry uses multiple16 long-lived fluorinated gases in plasma etching and plasma enhanced chemical vapor deposition (PECVD) processes to produce semiconductor produc ts. These include PFCs, which are also used as heat transfer fluids. Approximately 3.5 million metric tons of PFCs as CO 2 e were emitted from the semiconductor industry in 2006 (Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990 – 2007).

Table 5-4 Electronic Production PFC Emissions

Semiconductor PFC 2006 CO 2 e Emissions (million mtons) PFC GWP 2006 PFC Emissions (tons)

CF 4 1.2 6,500 204

C 2 F 6 2.2 9,200 264

C 4 F 8 0.1 8,700 13

Total 3.5 -- 481

Potential to Emit

The Federal Reserve capacity ut ilization factor for the el ectronics industry in 2006 was 79.8%. Based on this capacity utilization factor , the PTE of all semiconductor plants combined is an estimated 56 tons of SF 6 and 600 tons of PFC.

EPA identified 216 facilities in the semiconductor-electronics sector. Of these, the largest facility emitted 6% of to tal semiconductor emissions on a CO 2 e basis (includes nonPFCs), which is a maximum of 30 tons of PFC. On a PTE basis, the largest facility would emit 36 tons, based on an assumption that the industry cap acity is distributed similarly to emissions. Therefore, no facility exceeds 100 tons pe r year on an actual or PTE basis for PFC.

Facility stationary fuel combustion emi ssions are not included in the threshold comparisons for the industry.

New Units

As growth for the industrial sector was estima ted at -1.8%, no additional facilities were included in this analysis.17 Threshold Summary

Table 5-5 CO 2 e Threshold Summary -- Electronics Production

GHG Threshold (tons per year) Number of Existing Sources Number of New Facilities Added per Year CO 2 e Emissions Covered (Tg per year)

50,000 54 0 5.1

55,000 50 0 5.0

60,000 47 0 4.8

65,000 41 0 4.6

70,000 39 0 4.5

75,000 35 0 4.3

80,000 35 0 4.3

85,000 31 0 4.0

90,000 26 0 3.7

95,000 24 0 3.6

100,000 22 0 3.4

5.5 Food Processing

Food processing includes meat, poultry and frui t and vegetable processing. Emissions derive from combustion and fugitive methane related to wastewater treatment. For purposes of this permit threshold analysis, EPA did not cons ider the fugitive methane from wastewater treatment because these are the only GHG emissions from th e source category other than combustion, and food processing is not a listed PSD source category. Consequently, emissions from this subsector considered in this analysis were limited to combustion emissions and were calculated using the MECS approach described in Section 5.15.

Potential to Emit

EPA used the Federal Reserve's 2004 capacity utilization factor of 79.3% for the food industry to calculate PTE emissions.

New Units

In addition, new establishments were calcu lated assuming a conti nuation of the growth rate of 1.2%, as calculated using the methodology described ear lier in this document.18 Threshold Summary

Table 5-6 CO 2 Threshold Summary -- Food Processing

GHG Threshold (tons per year) Number of Existing Sources Number of New Facilities Added per Year CO 2 e Emissions Covered (Tg per year)

50,000 10 0 0.6

55,000 10 0 0.6

60,000 10 0 0.6

65,000 10 0 0.6

70,000 10 0 0.6

75,000 10 0 0.6

80,000 10 0 0.6

85,000 0 0 0

90,000 0 0 0

95,000 0 0 0

100,000 0 0 0

5.6 Glass Manufacturing

EPA used the Supporting Data for Threshold Analysis Subpart E-W(EPA-HQ-OAR2008-0508-0046.7) to analyze emissions for permit thresholds from glass manufacturing. Annual fuel combustion and glass production are estimated for each plant based on 2004 estimated plant sales and 2002 MECS energy in tensity (energy per sa les dollars). The spreadsheet shows CO 2 emission estimates from industria l processes and stationary fuel combustion, as well as CH 4 and N 2 O emission estimates from stationary fuel combustion.

Potential to Emit

Plant capacities are not available in the spread sheet. To estimate PTE, EPA divided the actual annual emissions by a capacity utilization f actor of 0.50 or 50%.

New Units

EPA used an estimated annual growth rate of 0.4% for the nonmetallic mineral product manufacturing sector to determine the num ber of new units for this analysis.19 Threshold Summary

Table 5-7 CO 2 e Threshold Summary -- Glass Manufacturing

GHG Threshold (tons per year) Number of Existing Sources Number of New Facilities Added per Year CO 2 e Emissions Covered (Tg per year)

50,000 21 0 1.2

55,000 18 0 1.1

60,000 14 0 0.9

65,000 12 0 0.8

70,000 11 0 0.8

75,000 5 0 0.5

80,000 4 0 0.4

85,000 4 0 0.4

90,000 4 0 0.4

95,000 3 0 0.4

100,000 3 0 0.4

5.7 Hydrogen Production

EPA estimated CO 2 emissions from merchant hydrogen production using the process and combustion ratio of 8.62 tons of CO 2 emissions per ton of hydrogen production. About 95% of all hydrogen (not just merchant hydrogen) produc ed in the United States today is made from natural gas via steam methane reforming. In steam methane reforming fueled by natural gas combustion, the process and combustion emissions go up the same stack from the boiler/reformer unit. EPA has treated all thes e emissions as process emissions, because the emissions are predominately process emissions and the natural gas combustion products are emitted from the same stack.

Potential to Emit

EPA developed estimates assuming hydrogen produc tion at capacity level. Therefore, no adjustment to the emissions estimates is needed to account for PTE emissions.20 New Units

Based on the industry growth f actor of -0.1% for chemical manufacturing, EPA assumed that no new plants would be constructed.

Threshold Summary

Table 5-8 CO 2 Threshold Summary -- Hydrogen Production

GHG Threshold (tons per year) Number of Existing Sources Number of New Facilities Added per Year CO 2 e Emissions Covered (Tg per year)

50,000 38 0 14.9

55,000 37 0 14.8

60,000 37 0 14.8

65,000 37 0 14.8

70,000 37 0 14.8

75,000 36 0 14.8

80,000 36 0 14.8

85,000 35 0 14.7

90,000 35 0 14.7

95,000 35 0 14.7

100,000 32 0 14.4

5.8 Iron and Steel Production

EPA used the Supporting Data for Threshold Analysis Subpart E-W(EPA-HQ-OAR2008-0508-0046.7) for the GHGRP threshold analysis to determine process and combustion CO 2 and process CH 4 . The iron and steel production source category includes taconite iron ore processing facilities, integrated iron and stee l making facilities, electric arc furnace (EAF) steelmaking facilities that are not located at in tegrated iron and steel facilities, and coke oven facilities that are not located at integrated iron an d steel facilities. Tabl e 5-9 indicates facility processes and fac ilities covered in the spreadsheet.21 Table 5-9 Iron and Steel Processes, Facili ties, and Capacity Information

Iron and Steel Process Number of Facilities Capacity Information
Basic oxygen furnace (BOF) 18 Yes
Blast Furnace (BF) 17 Yes
Sintering 5 Yes

Coke ovens 18 Yes
Electric arc furnace (EAF) 92 No

Taconite furnace 8 Yes
Integrated steel plant fuel combustion* 19 No
Coke oven gas combustion* 9 No
EAF steel plant fuel combustion 92 No

* Six plants had emissions from coke oven gas combustion was included in integrated steel plant fuel

combustion.

Potential to Emit

The analysis covered 130 plants, and in al l cases, except for EAF plants, GHG emissions were estimated based on operations at plant capacity. For EAF plants, EPA used the 2007 Federal Reserve industrial capacity utilization percentage of 86 .6% for primary metal -- iron and steel production to adjust estimate d actual emissions to PTE.

The spreadsheet contained emission CO 2 e estimates, including CO 2 , CH 4 , and N 2 O emissions. Process CH 4 emissions were backed out of the CO 2 e totals using the process CH 4 emissions reported in the U.S. GHG Inventory, and apportioning these emissions to the different plants based on their capacity in those processes. N 2 O emissions are primarily related to fuel combustion and were not backed out for separate treatment.

New Units

No new iron and steel facilities are expected to be built. The growth rate in primary metals from the U.S Census Bureau’s Economic data is only about 0.4%.22 Threshold Summary

Table 5-10 CO 2 e Threshold Summary -- Iron and Steel Production

GHG Threshold (tons per year) Number of Existing Sources Number of New Facilities Added per Year CO 2 e Emissions Covered (Tg per year)

50,000 116 0 84.8

55,000 114 0 84.7

60,000 114 0 84.7

65,000 114 0 84.7

70,000 114 0 84.7

75,000 114 0 84.7

80,000 114 0 84.7

85,000 114 0 84.7

90,000 114 0 84.7

95,000 114 0 84.7

100,000 113 0 84.7

5.9 Lead Production

According to the 2006 USGS, lead production in the United States includes both primary, direct smelting (one facility), and secondary lead production (16 f acilities). Process emissions of CO 2 are a byproduct of the coke consumed during the smelting or reforming processes. EPA calculated total process emissions based on l ead production as reported in the USGS.

In the Supporting Data for Threshold Analysis Subpart E-W (EPA-HQ-OAR-2008-0508- 0046.7), combustion emissions are combined with process emissions to determine total actual emissions.

Potential to Emit

In order to determine PTE emissions, EP A considered the Federal Reserve's 2006 monthly industrial capacity util ization estimates for primary metals industry classification which shows utilization at 85.9% for 2006, and adju sted to achieve 100% utilization.23 New Units

EPA assumed no new facilities would be a dded for the industry, given an expected growth rate of 0.4% per year for primary metal manufacturing industry.

Threshold Summary

Table 5-11 CO 2 e Threshold Summary -- Lead Production

GHG Threshold (tons per year) Number of Existing Sources Number of New Facilities Added per Year CO 2 e Emissions Covered (Tg per year)

50,000 12 0 0.8

55,000 11 0 0.7

60,000 9 0 0.6

65,000 8 0 0.6

70,000 5 0 0.4

75,000 5 0 0.4

80,000 5 0 0.4

85,000 2 0 0.2

90,000 2 0 0.2

95,000 2 0 0.2

100,000 1 0 0.1

5.10 Lime

The Supporting Data for Threshold Analysis Subpart E-W (EPA-HQ-OAR-2008-0508- 0046.7) was used to estimate GHG PTE for lime plants.

Potential to Emit

To estimate PTE, EPA divided annual actual CO 2 emissions from the calcining process and fuel combustion emissions of CO 2 , CH 4 , and N 2 O by regional capacity factors available in the spreadsheet for each plant. The capacity factors ranged from 43 – 136%.

New Units

EPA assumed no new facilities would be added for the industry.24 Threshold Summary

Table 5-12 CO 2 Threshold Summary -- Lime Production

GHG Threshold (tons per year) Number of Existing Sources Number of New Facilities Added per Year CO 2 e Emissions Covered (Tg per year)

50,000 66 0 26.5

55,000 65 0 26.5

60,000 65 0 26.5

65,000 63 0 26.4

70,000 62 0 26.4

75,000 62 0 26.4

80,000 61 0 26.3

85,000 61 0 26.3

90,000 61 0 26.3

95,000 61 0 26.3

100,000 60 0 26.2

5.11 Nitric Acid Production

EPA used the 2006 nameplate cap acity (metric tons of HNO 3 100% acid basis) for 45 nitric acid plants and 2006 acid production from the GHGRP TSD supporting spreadsheet (EPAHQ-OAR-2008-0508-0046.7) to determine N 2 O emissions.

Potential to Emit

The GHG PTE was calculated by multiplying actual N 2 O emissions as CO 2 e by the ratio of nameplate capacity to 2006 production. The permit threshold analysis, based on the GHGRP TSD, does not include GHG emissions from co-lo cated stationary combustion units. Also the permit threshold analysis does not account for over lap between facilities in the Nitric Acid and Ammonia categories, which have both amm onia and nitric acid production processes.

New Units

EPA assumed no new units would be constructed for this sector.25 Threshold Summary

Table 5-13 CO 2 e Threshold Summary -- Nitric Acid Production

GHG Threshold (tons per year) Number of Existing Sources Number of New Facilities Added per Year CO 2 e Emissions Covered (Tg per year)

50,000 43 0 17.7

55,000 43 0 17.7

60,000 43 0 17.7

65,000 42 0 17.7

70,000 42 0 17.7

75,000 42 0 17.7

80,000 42 0 17.7

85,000 42 0 17.7

90,000 42 0 17.7

95,000 42 0 17.7

100,000 42 0 17.7

5.12 Petrochemical Production

The Intergovernmental Panel on Climate Change (IPCC) considers production of GHGs from the petrochemical production sector’s ma nufacture and production of acrylonitrile, carbon black, ethylene, ethylene dichloride, ethylene oxide, and methanol to be significant compared to other petrochemical processes. Thus, EPA determ ined that this portion of the sector is most relevant for permit threshold analysis.

Emissions from the manufacturing processes vary significantly, and process emissions take many forms. Process emissions include direct oxidation of CO 2 , off-gassing of CH 4 and CO 2 , and the direct release of CO 2 and CH 4 from equipment leaks. Process emissions are the primary consideration for acrylonitrile, ethylene, and ethylene oxide processes. In addition, some processes require combustion of supplem ental fuel. Both process and combustion emissions are significant for carbon bl ack and methanol processes.

Potential to Emit

EPA's analysis assumed petrochemical productio n at the capacity level. Therefore, no adjustment to the emissions estimates is needed to account for PTE.26 New Units

EPA assumed that no new plants would be cons tructed, given an industry growth factor of -0.1% for chemical manufacturing.

Threshold Summary

Table 5-14 CO 2 e Threshold Summary -- Petrochemical Production

GHG Threshold (tons per year) Number of Existing Sources Number of New Facilities Added per Year CO 2 e Emissions Covered (Tg per year)

50,000 94 0 54.7

55,000 94 0 54.7

60,000 93 0 54.7

65,000 93 0 54.7

70,000 93 0 54.7

75,000 93 0 54.7

80,000 93 0 54.7

85,000 92 0 54.6

90,000 91 0 54.5

95,000 91 0 54.5

100,000 91 0 54.5

5.13 Petroleum Refineries

In developing the permit threshold analysis for petroleum refineries, EPA quantified CH 4 process emissions from wastewater, fugitive, flares, and storage tanks. Process CO 2 emissions derived from flares, hydrogen plant emissions, and su lfur plant emissions. In addition, on-site combustion emissions were calculated considering fuel consumed by type.

Potential to Emit

EPA assumed that petroleum refineries were operating at capacity level. Therefore, no adjustment to the emissions estimates was needed to account for PTE.27 New Units

According to the ICR prepared for the New Source Performance Standard (NSPS), EPA expects that no new refineries will be built during the next several years.

Threshold Summary

Table 5-15 CO 2 e Threshold Summary -- Petroleum Refineries

GHG Threshold (tons per year) Number of Existing Sources Number of New Facilities Added per Year CO 2 e Emissions Covered (Tg per year)

50,000 137 0 204.5

55,000 136 0 204.5

60,000 135 0 204.4

65,000 135 0 204.4

70,000 134 0 204.3

75,000 132 0 204.2

80,000 131 0 204.1

85,000 131 0 204.1

90,000 129 0 204.0

95,000 129 0 204.0

100,000 129 0 204.0

5.14 Pulp and Paper Manufacturing

Permit threshold analysis for this sector is focused on the energy intensive, fugitive emitting, pulp, paper, and paperboard manufactur ing subsectors. Process emissions include CO 2 , which is emitted in the recovery cycle at kraft a nd soda facilities associated with the chemical pulp process. The CO 2 emitted from kraft mill lime kilns originates from two sources: (1) fossil fuels burned in the kiln and (2) conversion of cal cium carbonate (or "lime mud") generated in the recovery process to calcium oxide.

The bulk of the emissions considered derive from combustion. Many boilers use biomass fuel, and the burning of spent pulping liquors to produce steam for facility processes is considered biomass combustion for the GHGRP. The emissions numbers considered for the permit threshold analysis are non-biogenic (net of any biogenic emissions). Considering only28 non-biogenic emissions, 96.5% of the facilities and 99.7% of the em issions are captured by all of the thresholds proposed for considera tion of the permit threshold rule.

Potential to Emit

Because 99.7% of emissions were captured at even the highest threshold, no additional PTE estimate was calculated in this analysis.

New Units

Based on an industry growth factor of -2.5 % for paper manufacturing, and previous EPA analysis for the pulp and paper NSPS ICR, EPA assumed that no new plants would be constructed.

Threshold Summary

Table 5-16 CO 2 e Threshold Summary -- Pulp and Paper Manufacturing

GHG Threshold (tons per year) Number of Existing Sources Number of New Facilities Added per Year CO 2 e Emissions Covered (Tg per year)

50,000 422 0 57.7

55,000 422 0 57.7

60,000 422 0 57.7

65,000 420 0 57.7
70,000 420 0 57.7
75,000 415 0 57.6

80,000 415 0 57.6

85,000 415 0 57.6

90,000 412 0 57.6

95,000 412 0 57.6

100,000 410 0 57.529 5.15 Unspecified Industrial Stationary Combustion Sources

In order to determine establishment counts and emissions totals for the unspecified industrial stationary combustion sources, EPA used 2002 Economic Census data showing manufacturing employment by NAICS code and EIA MECS data. Calculating GHG emissions required determining energy consumption pe r employee by industry and applying emission factors specific to the consumption profile derived from the MECS data.

The 2002 Economic Census data provide a count of establishments by employment category, where employment category is define d by number of employees (e.g., 1 – 4, 5 – 9, . . . , 500 – 999, . . . , more than 2,500). The MECS data show energy consumption by industry. Both the employment data and the en ergy consumption data are organized according to the NAICS codes.

Potential to Emit

As part of this analysis, EPA calculated industry-specific GHG emission factors. The factors were calculated by consid ering actual fuel consumption in 2002, as determined by EIA. Actual fuel consumed was multiplied by fuel-s pecific GHG emission factors to determine GHG emissions by fuel type by industry. To simplify the analysis, EPA included only CO 2 emissions and ignored CH 4 and N 2 O in the CO 2 e calculations. CO 2 makes up between 99.3 and 99.7% of estimated CO 2 e emissions. Emissions for each fuel type were combined to determine total emissions for a sector. Total emissions per sect or were divided by total energy consumption per sector to determine a factor to calculate GHG emissions per mmBtu of energy consumption specific to the industrial sector.

The GHG emission factors were then multiplied by the energy consumption per employee in order to determine emissions per em ployee. EPA determined total GHG emissions per establishment by multiplying the result by the average number of employees per establishment. EPA assumed a capacity factor of 50% to adjust actual emissions to PTE.

As noted above, a separate threshold anal ysis was conducted for the 23 industrial source categories that were determined to have signi ficant GHG emissions in th e GHGRP analysis. In order to quantify the unspecified industrial stationary combustion source emissions, EPA subtracted the combustion emissions and establis hment counts from 19 of these categories from the total industrial MECS analysis. EPA coul d not readily isolate co mbustion emissions from the remaining four industries: HCFC- 22 production, hydrogen production, magnesium production, and nitric acid productio n. For these industries, EPA subtracted their establishment counts from the unspecified industrial sour ce threshold counts based on process emission threshold evaluations. EPA assumed that any fa cility exceeding a threshold for process-based emissions would exceed the threshol d regardless of its combustion CO 2 emissions.30 Table 5-17 CO 2 e Threshold Summary -- Unspecified Industrial Stationary Combustion

GHG Threshold (tons per year) Number of Existing Sources Number of New Facilities Added per Year CO 2 e Emissions Covered (Tg per year)

50,000 3,272 12 206.9

55,000 1,470 4 163.6

60,000 1,399 4 161.8

65,000 1,399 4 161.8

70,000 1,399 4 161.8

75,000 1,392 4 161.5

80,000 1,392 4 161.5

85,000 1,166 3 153.8

90,000 1,166 3 153.8

95,000 1,024 2 147.9

100,000 958 2 145.1

6. Energy Sector

This sector consists of Oil and Gas Syst ems (oil and gas extract ion, transport, and processing) and Underground Coal Mines.

6.1 Oil and Gas Systems

In consideration of the permit thresholds, EPA considered the Fugitive Emissions Reporting from the Petroleum and Natural Gas Industry: Background Technical Support Document (EPA-HQ-OAR-2008-0508-0023). This document details combustion emissions and fugitive emissions from offshore petroleum and natural gas facilities, onshore natural gas processors, onshore natural gas tr ansmission, underground natural ga s storage, and liquid natural gas storage. EPA determined that oil and ga s exploration, development, transmission, and distribution are not listed PSD s ource categories. Thus, EPA did not consider fugitive emissions from these activities for PSD app licability as it relates to major source thresholds. Rather, EPA's analysis focused on combustion emissions from these sources.31 Potential to Emit

Although the emission information from the GHGRP was limited, it provided process emissions and combustion emission totals and facility counts for four CO 2 e actual emissions thresholds: 1,000, 10,000, 25,000, and 100,000 (S ee EPA-HQ-OAR-2008-0508-0023, Table 4). For this analysis, EPA assumed process emissions were fugitive emissions and used only the average facility combustion emissions by the four thresholds for the PTE analysis. EPA used a capacity utilization figure of 50% applied to the average stationary combustion emissions to determine PTE emission estimates and counts.

New Units

EPA determined new units based on a grow th factor of 1.0% for the sector.

Threshold Summary

Table 6-1 CO 2 e Threshold Summary -- Oil and Gas Systems

GHG Threshold (tons per year) Number of Existing Sources Number of New Facilities Added per Year CO 2 e Emissions Covered (Tg per year)

50,000 1,045 10 56.9

55,000 1,045 10 56.9

60,000 1,045 10 56.9

65,000 1,045 10 56.9

70,000 1,045 10 56.9

75,000 387 4 32.8

80,000 387 4 32.8

85,000 387 4 32.8

90,000 387 4 32.8

95,000 387 4 32.8

100,000 387 4 32.8

6.2 Underground Coal Mining

GHG emissions from underground coal mining include CH 4 fugitive emissions released from the coal seam and surrounding rock dur ing mining and post-mining activities (coal bed CH 4 ), and fuel combustion emissions of CO 2 , CH 4 , and N 2 O. Fugitive CH 4 , emissions are captured and vented by ventilation systems a nd degassing systems. Captured and vented CH 432 emissions from active mines were considered in the PTE analysis. Because underground coal mining is not one of the 28 PSD source categories for which fugitive emissions were required to be included in the emissions determination, fugitive emissions from post mining operations, surface mines, and inactive mines were not included in the permit thresholds analysis.

The Technical Support Document for Underground Coal Mines: Proposed Rule for Mandatory Reporting of Greenhouse Gases (EPA-HQ-OAR-2008-0508-0032) identified 612 active underground coal mining fac ilities; however, analysis of CH 4 emissions was limited to 128 "gassy" mines where CH 4 monitoring was already in place (due to existing CH 4 emissions above Mine Safety and Health Administrati on (MSHA) threshold levels). The U.S. GHG Inventory (EPA, 2008) indicates that 233 underg round coal mines (including 133 gassy mines) ventilated CH 4 in 2007. Fuel combustion emission estimates for the GHGRP TSD from all underground coal mines, based on U.S. Census Bureau Energy Use data, were found to constitute 1 – 3% of total CO 2 e emissions, with coal bed CH 4 accounting for the bulk of GHG emissions.

In addition to the emissions data on the 128 gassy mines containe d in the GHGRP TSD, EPA considered combustion emissions from 289 bituminous underground coal mines, using 2002 U.S. Census data.

Potential to Emit

CH 4

CH 4 emission estimates that were developed for the GHGRP TSD were used for both actual emissions and PTE emissions permit threshold analysis. EPA assumed that venting and degassing were continuous througho ut the year; therefore, actual emission estimates equal PTE emission estimates. The estimates considered 1 28 gassy mines, which were assumed to be the largest emitters of vented CH 4 . The smallest mine of this group had annual CH 4 emissions of 26 tons. Thus, EPA assumed that annual CH 4 emissions from the 105 vented mines that were not included in the TSD analysis were less than 26 tons.

CO 2

CO 2 emissions were estimated in the same ma nner as for other Unspecified Industrial Stationary Combustion categories, based on th e ICF analysis (ICF, 2007) using the MECS approach. Emissions were estimated based on U.S Census Bureau data on fuel consumption per employee and the distribution of establishments by the number of employees. PTE was estimated by using a capacity utilization factor of 86.3% as published by the Federal Reserve.

New Units

The number of underground bituminous coal mines in the United States is on the decline. EIA data indicate that the number of undergr ound coal mines decreased by 8% between 2006 and 2007, with only Colorado showing an in crease during that period (EIA, 2008).33 Consequently, EPA assumed that no new underground mines would be built. http://www.eia.doe.gov/cneaf /coal/page/acr/table1.html

. Threshold Summary

Table 6-2 CO 2 e Threshold Summary -- Underground Coal Mining

GHG Threshold (tons per year) Number of Existing Sources Number of New Facilities Added per Year CO 2 e Emissions Covered (Tg per year)

50,000 78 0 32.8

55,000 77 0 32.8

60,000 74 0 32.6

65,000 70 0 32.4

70,000 67 0 32.2

75,000 67 0 32.2

80,000 64 0 32.0

85,000 63 0 31.9

90,000 60 0 31.7

95,000 57 0 31.4

100,000 55 0 31.2

7. Waste Sector

For the waste sector, EPA evaluated La ndfills and Municipal Waste Combustors.

7.1 Landfills

The landfill PTE analysis includes both municipal solid waste (MSW) landfills and onsite industrial landfills associated with pulp and pa per and food processing. The analysis used a modification of the landfill emission modeling appro ach used for the GHGRP threshold analysis. As with the GHGRP analysis, the permit threshol d PTE analysis did not include onsite industrial landfills for ethanol processing facilities or industrial land applic ation systems.

GHG Emissions

Decomposition of waste in landfills generates CH 4 and CO 2 . The amount of CH 4 generated from a given landfill is a function of several factors: the total amount of waste34 disposed in the landfill; the characteristics of th e waste; and the climatic conditions. The amount of CH 4 emitted is the amount of CH 4 generated minus the amount of CH 4 oxidized by aerobic microorganisms in the landfill cover material. Also subtracted fr om the total is the amount of CH 4 that is destroyed by combustion of the vented gas. The CO 2 produced by decaying waste is not considered an anthropogenic emission, and is not counted in GHG emi ssion totals. Likewise, CO 2 resulting from the combustion of landfill CH 4 is not accounted for as an anthropogenic emission under international accounting guidance.

According to the 2008 U.S. Inventory, MS W landfills emitted 111.2 million metric tons CH 4 (CO 2 e basis) in 2006. The majority of CH 4 emissions from on-site industrial landfills occur at pulp and paper facilities and food processing f acilities. In 2006, these landfills emitted 14.6 million metric tons CO 2 e

Potential to Emit

The methodology used for the GHGRP threshold analysis was also used to estimate CH 4 generation rates and emissions in 2006 for the PTE analysis. A landfill-specific model developed by EPA to support its GHGRP was used to estimate CH 4 generation and potential generation from municipal landfills. The genera tion estimate was adjusted with assumptions on oxidation in landfill cover, and destruction by com bustion for energy recovery or flaring. The industrial landfill genera tion and emission estimates are based on the U.S. GHG Inventory. Industrial landfills were assumed not to have energy recovery or flaring, so there was no difference between generation and emissions.

New Units

EPA did not estimate the number of ne w facilities added each year with CH 4 emissions above the different thresholds due to the time delay between landfill construction and emission generation.35 Threshold Summary

Table 7-1 CO 2 e Threshold Summary -- Landfills

GHG Threshold (tons per year) Number of Existing Sources CO 2 e Emissions Covered (Tg per year)

50,000 1,684 92.3

55,000 1,603 90.1

60,000 1,523 88.0

65,000 1,447 86.0

70,000 1,372 84.0

75,000 1,299 82.1

80,000 1,229 80.2

85,000 1,169 78.5

90,000 1,105 76.5

95,000 1,029 74.5

100,000 967 72.7

7.2 Municipal Solid Waste Combustors

The threshold analysis for the GHGRP included municipal solid waste combustors (MWC) in the general stationary fuel combus tion category. The analysis used the eGRID database, which is discussed in the PTE met hodology description for elect ric generating units.

Data and Methodology

EPA used the latest version of the eGRID database (2006) to estimate the PTE of MWC facilities and counts of f acilities above the different emission thresholds. eGRID includes year 2004 characteristics, operating information, and annual CO 2 emissions for U.S. facilities that have a generation capacity greater than one MW and sell electric power to the grid. In using eGRID, EPA assumed that all MWC facilities sell power to the grid.36 Potential to Emit

EPA identified 75 MWC facilities based on the generator primary fuel in the generator table (primary fuel equals MSW) in the eGRI D database. The eGRID database contains CO 2 annual emissions estimates fo r the facilities. For CO 2 emissions, eGRID uses a standard assumption that 70% of the heat value of the wa ste stream comes from renewable materials and 30% comes from nonrenewable material s. The renewable fraction has a CO 2 emission rate of zero. Thus, the PTE threshold analysis is based on the nonrenewable or fossil fraction assumption. EPA estimated PTE by dividing the annual emissions from eGRID by the eGRID plant capacity factor.

New Units

To determine the number of new per year at different thresholds, EPA counted the number of generators online each year and tota led the nameplate capacity for each online year. EPA compared this information to the total facility nameplate capacity and calculated the PTE for the increased capacity by multiplying the faci lity PTE by the fraction of nameplate capacity associated with the new generators. EPA counted the facilities that exceeded the PTE thresholds during each period and computed a 15-year average to determine the number of new or modified facilities per year.

Threshold Summary

Table 7-2 CO 2 Threshold Summary -- Municipal Solid Waste Combustors

GHG Threshold (tons per year) Number of Existing Sources Number of New Facilities Added per Year CO 2 e Emissions Covered (Tg per year)

50,000 67 1 6.1

55,000 65 1 6.0

60,000 55 1 5.7

65,000 53 1 5.6

70,000 51 1 5.5

75,000 48 1 5.4

80,000 47 1 5.3

85,000 45 1 5.2

90,000 44 1 5.2

95,000 42 1 5.1

100,000 40 1 5.037 8. Commercial Stationary Fuel Combustion

Commercial buildings include all buildings in which at least half of the floor space is used for a purpose that is not residential, industria l, or agricultural. Th e source category includes building types that might not traditionally be considered "commercial," such as schools, correctional institutions, and buildings used for religious worship.

Data Source

EPA used EIA's Commercial Building Energy Consumption Survey (CBECS) to estimate commercial sector stationary fuel combustion GHG emissions and PTE. CBECS is a national sample survey that collects information on the stock of U.S. commercia l buildings, their energyrelated building characteristics, and their ener gy consumption and expenditures. The CBECS survey is conducted every four years, with th e most recent survey completed in 2003.

The CBECS survey sample was designed so that survey responses could be used to estimate characteristics of the entire nationwid e commercial building stock. The 2003 survey selected 6,955 potential case buildings for samp ling. The sampling procedures resulted in 5,215 completed building interviews for a response rate of 82%. To make national estimates from the sample data, EIA calculated base sampling weig hts for each building (the reciprocal of the probability of that building being selected into th e sample). In other words, the base sampling weight is the number of national buildings repres ented by the sampled building. The base weight was further adjusted to acc ount for nonresponsive bias.

EIA publishes summary tables from the surv ey, and posts "microdata" files on the EIA website. The CBECS microdata consist of th e 5,215 sampled building records, which each correspond to a single sampled build ing. For each building, these files contain information such as the building size, climatic regi on, U.S. Census region, year c onstructed, types of energy used, and energy consumption and expenditures. These individual building microdata records are also the basis for the summary tables published by EIA.

Emissions Methodology

EPA used the CBECS microdata to estim ate commercial building emissions and populations above emission thresholds. Each of the 5,215 microdata records corresponds to a single sampled building. EIA has made available 20 different data files of the microdata records which contain a wide range of information on ch aracteristics and energy use for each building.

EPA's analysis relied on guidance provided by EIA on how to use the data. As noted above, the CBECS sample was designed so that survey responses could be used to estimate characteristics of the entire commercial build ing stock nationwide. The table below provides examples from EIA on how to calculate national commercial building characteristics from the sample building data.38 Table 8-1 EIA Website Examples

To Find the National Estimate for: Do This... And You Should Get...
Total number of buildings Sum ADJWT8 (weight factor) 4,858,749.82 (or 4,859 thousand)

Total number of office buildings Sum ADJWT8 for cases where PBA8 (building code) = "02" 823,805.47 (or 824 thousand)
Total floor space Create a new variab le (weighted square footage) by multiplying ADJWT8 by SQFT8 (floor space) for each case, then sum this new variable 71,657,900,522 (or 71,658 million ft 2 )

Total floor space in buildings with air conditioning Sum the new weighted square f ootage variable (see above) for cases where COOL8 (a ir conditioning) = "1" 63,559,999,624 (or 63,560 million ft 2 )

Total electricity consumption in KWh Create a new variable (weighted electricity consumption) by multiplying ADJWT8 by ELCNS8 (electricity consumption) for each case, then sum this new variable 1,043,175,710,751 (or 1,043 billion kWh)

Source: http://www.eia.doe.gov/emeu/cbecs/cbecs2003/public_use_2003/cbecs_pudata2003.html

.

For each surveyed building EIA calculated base sampling weights, which are the reciprocal of the probability of that building being selected into the sample. Thus, a building with a base weight of 1,000 repr esents itself and 999 similar but unsampled buildings in the total building stock. The base weight is further adjusted to account for non-response bias. The variable "ADJWT8" in the data file is the fina l weight. The ADJWT8 wei ght factor is used as described in Table 8-1 to extrapolate the survey sample to a national scale for any value. In order to obtain a national value each sample build ing's value must be multiplied by the building's weight (ADJWT8). All of the weighted values are then summed.

2003 CO 2 Emissions

EPA calculated the CO 2 emissions for each of the 5,215 buildings based on the annual natural gas and oil consumption reported for th e building. For national emission estimates and counts of buildings with annual CO 2 emissions over any threshold, EPA multiplied the base weights by the sample emission totals to determine the national estimate of buildings with emissions over the threshold.39 Potential to Emit

EPA estimates that commercial buildings ope rate at 15% of capacity. EPA considered several sources in making the P TE factor determination:

● A report prepared by Energy and Environmen tal Analysis, Inc., for Oak Ridge National Laboratory describing the indus trial and commercial boiler population in the United States (EEA, 2005). The report estimated an average commercial boiler capacity factor of 16%.

● Reports on cooking equipment energy use by the Food Service Technology Center in California suggesting that the cooking equipment in food service establishments operate at about 10% of a theoretical maximum cap acity based on 8,760 hours per year (Pechan et.al, 2008).

● A study of Los Angeles dry cleaners perfor med by the Pollution Prevention Education and Research Center (PPERC) in 2004 which demonstrates that dry cleaners operate boilers at about 10 – 15% of maximum capacity over a normal year (Pechan et al., 2008).

New Buildings

The CBECS data identifies the year the samp led buildings were constructed. EPA used the construction year information to identify th e number of new buildings built each year in the 1990 to 2003 period. Counts of the average number of these buildings built per year were then made at the different emi ssions and PTE thresholds.

Threshold Summary

The count of buildings and emissions at the threshold levels for th e entire sector are shown in Table 8-2. Threshold results by comm ercial building categories (e.g., offices, public assembly, schools) are provided in Appendix B.40 Table 8-2 CO 2 e Threshold Summary -- Commercial Sector Stationary Fuel Combustion

GHG Threshold (tons per year) Number of Existing Sources Number of New Facilities Added per Year CO 2 e Emissions Covered (Tg per year)

50,000 600 3 6.0

55,000 534 3 5.5

60,000 346 3 4.1

65,000 268 3 3.4

70,000 262 3 3.4

75,000 225 3 3.0

80,000 201 3 2.7

85,000 106 2 1.7

90,000 74 2 1.3

95,000 63 2 1.2

100,000 51 2 1.0

9. Residential Stationary Combustion

EPA’s original threshold analysis for th e Tailoring Rule evalua ted both stationary combustion emissions from both single family and multi-family buildings. Single family buildings are not affected at the 50,000 to 100,000 tons CO 2 e thresholds and are not included here.

9.1 Multi-Family Residential Buildings

Data Sources

EPA used residential fuel consumption data from EIA's Residential Energy Consumption Survey (RECS) and multi-family building and unit data from U.S. Census Bureau surveys to estimate CO 2 emissions and PTE for fuel combustion at single and multi-family residential properties. The RECS is a national area-probabi lity sample survey that collects energy-related data for occupied primary housing units. The most recent 2005 survey collected data from 4,382 households in housing units statistically selected to represent the 111.1 million housing units in the United States. RECS data are tabulated fo r the four Census regi ons, the nine Census divisions, and for the four most populous States -- California, Florida, New York, and Texas.

The RECS sample was designed so that su rvey responses could be used to estimate characteristics of the national stock of occupied housing units. In order to arrive at national41 estimates from the RECS sample, EPA calculated base sampling weights for each housing unit as the reciprocal of the probability of that building being selected into the sample. Therefore, a housing unit with a base weight of 10,000 represen ts itself and 9,999 similar, but not sampled, housing units in the total stock of occupied reside ntial housing units. The base weight is further adjusted to account for non-respons e bias. Ratio adjustments were also used to ensure that the RECS weights add up to the U.S Census Bureau’s Current Population Survey estimates of the number of households.

The RECS data are provided at the housing uni t level, and not at th e building level. EPA used additional U.S Census Bureau data on mu lti-family building population characteristics to estimate total property emissions and PTE for multi -unit properties. Census data were drawn from the Property Owner and Manager Survey (POMS, 1996) and the American Housing Survey (AHS, 2005).

Emission Rates

As indicated above , the RECS data are on an individua l unit basis, not a building or property basis. Thus, EPA was required to us e a different approach for multi-family units, assuming common ownership of the property fuel combustion equipment. In order to estimate property emissions and the number of properties above different emission and PTE thresholds, EPA combined the RECS data with data from the POMS and AHS.

From the RECS data, EPA first calculated average residential unit CO 2 emissions for the two most common fuels (natural gas and oil) by multi-family category. These are shown in the table below.

Table 9-1 Multi-Family Residential Unit -- Average Annual CO 2 Emissions (RECS, 2005)

Multi-Family Category (number of units) Natural Gas Space Heating (tons CO 2 /residential unit-year) Fuel Oil Space Heating (tons CO 2 /residential unit-year)

2 to 4 units 4.8 8.3

5 or more units 3.0 8.9

EPA also obtained annual CO 2 emission rates from an EPA analysis that was based on Lawrence Berkeley National Lab (LBNL) modeling studies. Those rates were estimated for old and new building units (see Table 9-2). The pre-1980 building estimate compares with the overall average from the RECS data. The post-1980 building estimates are much lower, particularly for units burning fuel oil.42 Table 9-2 Multi-Family Residential Unit -- Average Annual CO 2 Emissions (2008 EPA Analysis based on LBNL, 1997)

Multi-Family Category (building age) Gas Serviced Units (tons CO 2 /residential unit-year) Fuel Oil Serviced Units (tons CO 2 /residential unit-year)
Pre-1980 building 4.75 7.17
Post-1980 building 2.65 3.87

Existing Property Characteristics

Information on the distribution of multi-family properties by number of units per property was taken from the 1995 – 1996 POMS. The data are aggregated by different housing unit ranges. The table below shows the property size distribution from unpublished POMS data (NMHC Quick Facts -- Apartment Stocks ( http://www.nmhc.org )). The POMS data were for privately owned housing only and excluded public housing projects (about 13,500 buildings and 1,326,000 units). For its estimates, EPA adjusted the building numbers to current (2005) levels based on the RECS unit data (unit ratio of RECS to POMS) and assumed the same unit distribution in the adjustment.

Table 9-3 Multi-Family Residential Pr operty Size Distribution (National Multi-Housing Council tabulat ion of unpublished POMS data, 1995-1996)

Number of Rental Units on Property Number of Properties (1995-1996) Number of Units (1995-1996) Average Number of Units per

Property

2 1,558,700 3,093,200 2

3 336,030 1,025,900 3

4 341,350 1,436,800 4

5 – 9 281,500 1,897,700 7

10 – 14 70,390 862,280 12

15 – 19 36,780 602,260 16

20 – 29 38,000 916,750 24

30 – 39 18,166 604,240 33

40 – 49 14,431 702,790 49

50 – 99 26,694 2,009,400 75
(cont.)43 Table 9-3 Multi-Family Residential Property Size Distribution (National Multi-Housing Council tabulation of unpublished POMS data, 1995-1996) (cont.)

Number of Rental Units on Property Number of Properties (1995

– 1996) Number of Units (1995 – 1996) Average Number of Units per

Property

100 – 199 19,804 2,952,300 149

200 – 299 7,775 1,948,400 251

300 – 399 2,966 1,058,800 357

400 – 499 1,307 605,130 463

500 – 749 723 431,360 597
Over 750 307 437,670 1,426

Total 2,754,923 20,584,980

The adjusted POMS size distribution and av erage number of units in each category were combined with information from RECS on the percentage of units that use gas or oil for space heating. The gas and oil emission factors from th e previous tables were applied to the average number of units in each property size categ ory by fuel to estimate property annual CO 2 emissions.

For its final estimates, EPA used the LBNL based emission factors for post-1980 buildings, over the RECS based factor. EPA fou nd that these lower emission factors resulted in total emissions more in line with the total ba sed on all RECS units and residential sector estimates in the U.S. GHG Inventory. The RECS-based factors combined with the POMS property distribution data resulted in a larger overestimate in ov erall category annual emissions. The lack of information on the building populatio n over 50 units and on th e correlation between unit emissions and building/property size is a significant cause of uncertainty in the estimates at thresholds above 1,000 tons.

Potential to Emit

PTE was estimated using the same 10% capacity factor as used for the single family residential units. This factor was esti mated by comparing the average annual CO 2 emissions per heated floor space area per hour by climate zone to required heat input capacity. The required heat input capacity was based on rule of thum b heating system requirements for the different climate zones. The table below shows the average Btu/ft 2 -hour from the RECS data and Heating Requirement (Btu/ft 2 ) by climate zone. A heating system efficiency of 80% was used to estimate the required space heating capacity.44 Table 9-4 Single-Family Detached and Attached Households with Fossil Fuel-Fired Space Heating (RECS, 2005)

Households

(millions) Climate Zone(s) Heating Degree Day Range Average Annual Fuel Consumption (Btu/ft 2 -hour) Space Heating Requirement* (Btu/ft 2 )

6.8 5 > 7,000 4.8 50 – 60

16.7 4 5,500 – 7,000 5.4 45 – 50

17.0 3 4,000 – 5,499 4.6 40 – 45
18.9 1 and 2 < 4,000 3.8 Zone 2: 35 – 40 Zone 1: 30 – 35

*Heating requirement ranges are from www.acdirect.com/systemsize.php

.

New Properties

The AHS data provided information on new construction used to estimate the number of new buildings and new units with natural gas sp ace heating that were constructed in the 1999 – 2005 period. To simplify the analysis, EPA ignored the limited use of fuel oil for space heating in new units.

The AHS data provided separately the num ber of new buildings with gas space heating per year, and a size distribution for all new bui ldings per year. The AHS size distribution stopped at 50 and larger, and was slightly differe nt in other categories from the POMS data. EPA adjusted the distribution based on the POMS distribution and used the same emission and capacity factor approach as was used for existing units.45 Table 9-5 American Housing Survey New Building Data

Building Size: Number of Units

per Building Number of New Buildings per Year (1999 – 2005) (thousands) Fraction of All New Buildings per Year (1999 – 2005) New Gas Buildings per Year (1999 – 2005) (thousands) Number of New Gas Buildings per Year

2 6.3 0.22

16.0 3,468

3 – 4 5.4 0.19 2,995

5 – 9 6.1 0.21 3,389

10 – 19 6.0 0.21 3,310

20 – 29 3.1 0.11 1,734

30 – 49 1.0 0.03 552

50 or more 1.0 0.03 552

Total 29.0 1.00 16.0 16,000

Threshold Summary

Table 9-6 CO 2 e Threshold Summary – Multi-Family Residential

GHG Threshold (tons per year) Number of Existing Sources Number of New Facilities Added per Year CO 2 e Emissions Covered (Tg per year)

50,000 20 0 0.1

55,000 20 0 0.1

60,000 0 0 0

65,000 0 0 0

70,000 0 0 0

75,000 0 0 0

80,000 0 0 0

85,000 0 0 0

90,000 0 0 0

95,000 0 0 0

100,000 0 0 046 References

E.H. Pechan & Associates, Inc., Perrin Quarle s Associates, Inc., and Alpine Geophysics, LLC, Greenhouse Gas (GHG) Emissi ons and New Source Review, Work Assignment No. 1-06, EPA Contract No. EP-D-07-097, Apr il 10, 2008 (EPA-HQ-OAR-2008-0318-0080).

Environmental Energy and Analysis, Inc. (EEA), Characterization of the U.S. Industrial Commercial Boiler Population , submitted to Oak Ridge Na tional Laboratory, May 2005 (EPA-HQ-OAR-2008-0318-0005). http://www1.eere.energy.gov/indus try/distributedenergy/pdfs/ch aracterization_industrial_comme rical_boiler_population.pdf

Energy and Environmental Analysis, Inc. (EEA), World of Distributed Generation in Delaware
, February 2004. http://www.eeainc.com/rrdb/DGRegPr oject/Documents/DEDGWorld.pdf

Federal Register, 74 FR 16447, Mandatory Gr eenhouse Gas Reporting Regulations; Proposed Rule, Washington, D.C., April 10, 2009.

Federal Reserve, Statistical Release G17. Industr ial Production and Capacity Utilization

. http://www.federalreserve.gov/releases/g17/About.htm

ICF, International, Memorandum from Chris Steuer, Marian Van Pelt and Robert Lanza regarding Methodology Description for Industrial Sector GHG Threshold Analysis, November 2, 2007 (EPA-HQ-OAR-2008-0318-0079).

Lawrence Berkeley National Laboratory (LBNL). Energy Data Sourcebook for the U.S. Residential Sector . Prepared by Energy Analysis Program, Environmental Energy Technologies Division, LBNL, University of California, Berkeley, CA, September 1997. http://enduse.lbl.gov/info/Pubs95_99.html

National Multi-Housing Council (NMHC), Quick Facts Apartment Stock: Distribution of Apartments by Size of Property , NMHC tabulation of unpublished data from the U.S. Census Bureau's 1995-1996 Property Owners and Managers Survey. http://www.nmhc.org/

U.S. Census Bureau (2006), American Housing Survey for the United States: 2005

. http://www.census.gov/hhes/www/housing.html

. U.S. Census Bureau (2004), 2002 Economic Census, August 2004. http://www.census.gov/econ/census02/

U.S. Census Bureau (1998), 1995 Property Owners and Managers Survey , 1998. http://www.census.gov/hhes/www/housing/poms/poms.html

U.S. Energy Information Administration (EIA), Electric Power Annual
, 2007 , January 21, 2009. http://www.eia.doe.gov/cneaf/e lectricity/epa/epa_sum.html47 U.S. Energy Information Administration (EIA), Annual Energy Review 2005 , DOE/EIA-0384, July 1, 2006.

U.S. Energy Information Administration (EIA), 2005 Residential Energy Consumption Survey
, February 2009. http://www.eia.doe.gov/emeu/recs/recspubuse05/pubuse05.html

U.S. Energy Information Administration (EIA), 2003 Commercial Building Energy Consumption Survey , December 2006. http://www.eia.doe.gov/emeu/cbecs/cb ecs2003/public_use_2003/cbecs_pudata2003.html

U.S. Energy Information Administration (EIA), 2002 Manufacturing Energy Consumption Survey , January 2007. http://www.eia.doe.gov/emeu/mecs/contents.html

US. Environmental Protection Agency (EPA), Technical Support Document for Greenhouse Gas Emissions Thresholds Evaluation , March 29, 2010 (EPA-HQ-OAR-2009-0517-19158).

U.S. Environmental Protection Agency (EPA), Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990-2007 , April 2009, US EPA 430-R-09-004. http://www.epa.gov/climatechange/e missions/usinventoryreport.html

U.S. Environmental Protection Agency (EPA), Supporting Data for Threshold Analysis Subpart E-W, Greenhouse Gas Mandatory Reporting Rulemaking , March 10, 2009 (EPA-HQ-OAR2008-0508-0046.7).

U.S. Environmental Protection Agency (EPA ), Supporting Data for Threshold Analysis Subpart X-PP, Greenhouse Gas Mandatory Reporting Rulemaking , March 10, 2009 (EPA-HQ-OAR2008-0508-0046.8).

U.S. Environmental Protection Agency (EPA), Emissions & Generation Resource Integrated Database (eGRID) 2006 , May 2007. http://www.epa.gov/cleanenergy/energy -resources/egrid/index.html#download

U.S. Environmental Protection Agency (EPA), Draft U.S. Adipic Acid and Nitric Acid N 2 O Emissions 1990-2020: Inventories, Proj ections and Opportunities for Reductions , November 2001. http://www.epa.gov/nitrousoxide /pdfs/adipic_nitric_n2o.pdf

U.S. Environmental Protection Agency (EPA), Climate Change Division, Fugitive Emissions Reporting from the Petroleum and Natural Gas Industry: Background Technical Support Document, undated, FR publish date: March 26, 2009 (EPA-HQ-OAR-2008-0508-0023).

U.S. Environmental Protection Agency (EPA), Office of Air and Radiation, Technical Support Document for the Ammonia Production Sector: Proposed Rule for Mandatory Reporting of Greenhouse Gases, January 22, 2009 (EPA-HQ-OAR-2008-0508-0007).48 U.S. Environmental Protection Agency (EPA), Office of Air and Radiation, Technical Support Document for Process Emissions from Cement : Proposed Rule for Mandatory Reporting of Greenhouse Gases, January 28, 2009 (EPA-HQ-OAR-2008-0508-0008).

U.S. Environmental Protection Agency (EPA), Office of Air and Radiation, Technical Support Document for Process Emissions From Elect ronics Manufacture (Semiconductors, MEMs, Liquid Crystal Displays, and Photovoltaics), January 29, 2009 (EPA-HQ-OAR-2008-0508- 0009).

U.S. Environmental Protection Agency (EPA), Office of Air and Radiation, Technical Support Document for the Glass Manufacturing Sector: Proposed Rule for Mandatory Reporting of Greenhouse Gases, January 22, 2009 (EPA-HQ-OAR-2008-0508-0014).

U.S. Environmental Protection Agency (EPA), Office of Air and Radiation, Technical Support Document for the Hydrogen Production: Propose d Rule for Mandatory Reporting of Greenhouse Gases, August 5, 2008 (EPA-HQ-OAR-2008-0508-0016).

U.S. Environmental Protection Agency (EPA), Office of Air and Radiation, Technical Support Document for the Iron and Steel Sector: Propos ed Rule for Mandatory Reporting of Greenhouse Gases, September 9, 2008 (EPA-HQ-OAR-2008-0508-0017).

U.S. Environmental Protection Agency (EPA), Office of Air and Radiation, Technical Support Document for the Lead Production Sector: Pr oposed Rule for Mandatory Reporting of Greenhouse Gases, January 22, 2009 (EPA-HQ-OAR-2008-0508-0018).

U.S. Environmental Protection Agency (EPA), Office of Air and Radiation, Technical Support Document for the Lime Manufacturing Sector : Proposed Rule for Mandatory Reporting of Greenhouse Gases, January 22, 2009 (EPA-HQ-OAR-2008-0508-0019).

U.S. Environmental Protection Agency (EPA), Office of Air and Radiation, Technical Support Document for the Petrochemical Production Sect or: Proposed Rule for Mandatory Reporting of Greenhouse Gases, September 9, 2008 (EPA-HQ-OAR-2008-0508-0024).

U.S. Environmental Protection Agency (EPA), Office of Air and Radiation, Technical Support Document for the Petroleum Refining Sector: Proposed Rule for Mandatory Reporting of Greenhouse Gases, September 9, 2008 (EPA-HQ-OAR-2008-0508-0025).

U.S. Environmental Protection Agency (EPA), Office of Air and Radiation, Technical Support Document for the Pulp and Paper Sector: Proposed Rule for Mandatory Reporting of Greenhouse Gases, February 11, 2009 (EPA-HQ-OAR-2008-0508-0027).

U.S. Environmental Protection Agency (EPA), Office of Air and Radiation, Technical Support Document for Underground Coal Mines: Proposed Rule for Mandatory Reporting of Greenhouse Gases, February 4, 2009 (EPA-HQ-OAR-2008-0508-0032).49 Appendix A

Sector CO 2 e Permit Threshold Counts and Emissions

Please refer to the electroni c file " CO2e Threshold Anal ysis 50000 to 100000.xls" in the docket for EPA-HQ-OAR-20009-0517.50 Appendix B

Additional Supporting Data for Permit Threshold Analyses

Additional supporting data used to conduct the th reshold analysis are included in separate electronic files in this dock et entry (EPA-HQ-OAR-2009-0517). Please refer to the following file names for the additional information on specific sector categories:

● Commercial Buildings.xlsx

● Electricity Generation.xlsx

● Energy Production.xlsx (includes worksh eets for oil and gas and underground coal mining)

● Industrial – Ammonia_Electronics_FoodProce ssing_Glass.xlsx (includes worksheets for, ammonia production, electronics manufacturing, , food processing, and glass production)

● Industrial – Hydrogen_Iron&Steel_Lead_Lime_N itric Acid.xlsx (includes worksheets for hydrogen production, iron and steel production, lead production, lime manufacturing and nitric acid production)

● Industrial Sector Petrochemical_Petro leumRefinery_Pulp&Paper.xlx (includes worksheets for, petrochemical production, petroleum refineries, and pulp and paper manufacturing)

● Industrial – Unspecified Stationary Combustion.xlsx

● Residential – Multi-family.xlsx

● Waste Sector.xlsx (includes worksheets fo r landfills and municipal waste combustors)