### Author: Abt Associates Inc.

Date Created: Date Modified: 3/14/2011

Purpose: This file estimates the impact that compliance requirements will have on facilities' financial performance. This is done using two tests, a test of severe impacts - whether a facilities' net present value on a tax-adjusted basis remains positive - and a test of moderate impacts which compares a facility's financial health to the lower 25th percentile of firms in it industry.

File Contents: Worksheet Contents RFA Tables Summarizes Impacts by Sector for the RFA analysis

Frim Analysis Calculates firm-level impacts by summing costs for all facilities own by the firms. Analysis is done using two different weighting scenarios, one assuming that firms own all the facilities represented by their facilities' weights and second that assumes firms only own the facilities they are known to own and other, similar firms own facilities represented by their facilities' weights. Facility Data Reads in facility data including parent, size, weight, and compliance costs Total Small Firms by Industry Table of the total number of small firms in each sector (not limited to those in the 316(b) analysis)

Input Files: External data used in calculations/analysis: Aluminum Profile Table.xls Chemicals Profile Table.xls Food & Bev Profile Table.xls Man_Cost_Control.xls Man_Facility_Impact.xls MN_Facility_Data.xls P3F MN Survey Data.xls Paper Profile Table.xls Man_Parent_Info_Size.xls Petroleum Profile Table.xls Steel Profile Table.xls

The original version of this file contains, or is linked to a file that contains, confidential business information (CBI), or information that could be used to reveal CBI. As a result, the values for any variables determined by EPA to be CBI, or that could be used to reveal CBI, have been concealed.

### IM Only Everywhere (2+MGD) P3-Survey

2 3 4 5 6 7 8 Firms Owning In-scope Facilities Costs as percent of firm revenue <1% 1-3% >3% No Rev Small 27 24 0 2 1 Large 99 96 0 1 2

ctr_firm_facilwts_Total Total 126 120 0 3 3 Small 67 60 0 2 5 Large 301 294 3 0 4

ctr_firm_firmwts_Total Total 368 354 3 2 9

Case 1 Case 2 Total Sector Small Manufacturing Firms 316(b) Small

Manufacturing Firms Percent of

Small Firms Subject to RegulationTotal Sector

Small Manufacturing Firms 316(b) Small

Manufacturing Firms Percent of Small

Firms Subject to Regulation Paper 

### 218 9 4.1% 218 29 13.2% Chemicals 

### 2,506 4 0.2% 2,506 18 0.7% Petroleum 

### 188 4 2.1% 188 4 2.2% Steel 

### 1,149 3 0.3% 1,149 8 0.7% Aluminum 

### 227 2 0.9% 227 5 2.0% Food 

### 23,546 1 0.0% 23,546 0 0.0% Firms that own facilities in Primary Manufacturing Industries 

### 27,834 23 0.1% 27,834 63 0.2%

Option Weights

Assuming Firms Own Both Surveyed Facilitiesandthose represented by their sample weights Firms Assumption Size

Assuming Firms Own Only Surveyed Facilities (Not those represented by their sample weights)

Firm Sector

### Case 1 Case 2
Total 316(b) Manufacturing Firms Small 316(b)

Manufacturing Firms Percent of

Regulated Firms that are Small Total 316(b)

Manufacturing Firms Small 316(b)

Manufacturing Firms Percent of Regulated

Firms that are Small Paper 

### 42 9 21.4% 126 29 22.9% Chemicals 

### 26 4 15.4% 116 18 15.2% Petroleum 

### 17 4 23.5% 24 4 17.7% Steel 

### 16 3 18.8% 43 8 19.2% Aluminum 

### 5 2 40.0% 14 5 31.6% Food 

### 8 1 12.5% 24 0 0.0% Multiple 

### 3 0 0.0% 13 0 0.0% Firms that own facilities in Primary Manufacturing Industries 

### 117 23 19.7% 359 63 17.7% Other 

### 9 4 44.4% 9 4 44.4% 1 Firm Sectorfor RFA



### Firm Sector Total 316(b) Manufacturing Firms Small 316(b)

Manufacturing Firms Small Firms

with Costs > 1% of RevenueSmall Firms

with Costs > 3% of Revenue

Paper 

### 42 9 0 0 Chemicals 

### 26 4 0 0 Petroleum 

### 17 4 1 1 Steel 

### 16 3 0 0 Aluminum 

### 5 2 0 0 Food 

### 8 1 0 0 Multiple 

### 3 0 0 0 Firms that own facilities in Primary Manufacturing Industries 

### 117 23 1 1 Other 

### 9 4 1 1 rfa_facilwts_Total

Total 

### 126 27 2 2

Paper 

### 126 29 0 0 Chemicals 

### 116 18 0 0 Petroleum 

### 24 4 1 1 Steel 

### 43 8 0 0 Aluminum 

### 14 5 0 0 Food 

### 24 0 0 0 Multiple 

### 13 0 0 0 Firms that own facilities in Primary Manufacturing Industries 

### 359 63 1 1 Other 

### 9 4 1 1 rfa_firmwts_Total

Total 

### 368 67 2 2 Case 1

Case 2

### for RFA tables in doc. Hard-coded Table 1

‐4: Number and Percentage of Small Firms Subject to the Proposed Regulation, by Industry

1% of Revenue3% of Revenue 1% of Revenue 3% of

Revenue 

### Option 1: IM Everywhere Paper 

### 42 9 1 0 126 29 1 0 Chemicals 

### 26 4 0 0 116 18 0 0 Petroleum 

### 17 4 1 1 24 4 1 1 Steel 

### 16 3 0 0 43 8 0 0 Aluminum 

### 5 2 0 0 14 5 0 0 Food 

### 8 1 0 0 24 0 0 0 Multiple 

### 3 0 0 0 13 0 0 0 Firms that own facilities in Primary Manufacturing Industries 

### 117 23 2 1 359 63 2 1 Additional firms that own known facilities in Other Industries 

### 9 4 1 1 9 4 1 1 Option 2: Cooling Towers for Facilities with DIF > 125 MGD, Else IM Paper 

### 42 9 1 0 126 29 1 0 Chemicals 

### 26 4 0 0 116 18 0 0 Petroleum 

### 17 4 1 1 24 4 1 1 Steel 

### 16 3 0 0 43 8 0 0 Aluminum 

### 5 2 0 0 14 5 0 0 Food 

### 8 1 0 0 24 0 0 0 Multiple 

### 3 0 0 0 13 0 0 0 Firms that own facilities in Primary Manufacturing Industries 

### 117 23 2 1 359 63 2 1 Additional firms that own known facilities in Other Industries 

### 9 4 1 1 9 4 1 1 Small Firms with Costs Exceeding

Firm Sector Total 316(b) Firms Small 316(b)

Firms Total 316(b) FirmsSmall 316(b) Firms Case 1: Lower bound estimate of number of firms owning facilities that face requirements under the regulatory analysis Case 2: Upper bound estimate of number of firms owning facilities that face requirements under the regulatory analysis Small Firms with Costs Exceeding

### Table 1

‐4: Number and Percentage of Small Firms Subject to the Proposed Regulation, by Industry

1% of Revenue3% of Revenue 1% of Revenue 3% of

Revenue Small Firms with Costs Exceeding

Firm Sector Total 316(b) Firms Small 316(b)

Firms Total 316(b) FirmsSmall 316(b) Firms Case 1: Lower bound estimate of number of firms owning facilities that face requirements under the regulatory analysis Case 2: Upper bound estimate of number of firms owning facilities that face requirements under the regulatory analysis Small Firms with Costs Exceeding



### Option 3: Cooling Towers Everywhere Paper 

### 42 9 3 0 126 29 3 0 Chemicals 

### 26 4 1 0 116 18 1 0 Petroleum 

### 17 4 1 1 24 4 1 1 Steel 

### 16 3 1 0 43 8 1 0 Aluminum 

### 5 2 0 0 14 5 0 0 Food 

### 8 1 0 0 24 0 0 0 Multiple 

### 3 0 0 0 13 0 0 0 Firms that own facilities in Primary Manufacturing Industries 

### 117 23 6 1 359 63 6 1 Additional firms that own known facilities in Other Industries 

### 9 4 1 1 9 4 1 110 6 9 2 Firm Info

Parent Name Sector Revenues Size Facilities Owned8 Survey IDs of Facilities Owned

1 2 3 4 5 6 7 8 9 10 11 128 Weights of Facilities Owned

1 2 3 4 5 6 7 8 9 10 11 12 Facility weights and their associated costs and revenues are color coded from high to low for firms owning facilities with different weightsIn-scope Facilities

OwnedHighest ----------------------------------------------------------------------> Lowest 5 Revenues of Facilities Owned

1 2 3 4 5 6 7Highest ----------------------------------------------------------------------> Lowest

8 9 10 11 12 1 2 3 4Highest----------------------------------------------------------------------> Lowest 11 Compliance Costs of Owned Facilities

5 6 7 8 9 10 11 12Highest----------------------------------------------------------------------> Lowest
Unique Weights of Facilities Owned

1 2 3 4 5 6 7 8 9 10 11 12# Unique weights?????? Leave out the lowest weight? Leaves out the 2nd lowest wgt?

Leaves out the 3rd lowest wgt? Represented Firm Weights Represented Firm Costs

1 2 3 4 5 1 2 3 4 5Leaves out the 3rd lowest wgt? Represented Firm Cost-Revenue

1 2 3 4 5Weighted Costs of Owned Firms

1 2 3 4 5 6 7 8 9 10 11 12 TotalWtd Cost / Parent Rev Represented Firm Sector Represented Firm Size

1 2 3 4 5 1 2 3 4 5 Weighted Cost-RevenueLargest Weight is Left Out?

Represented Facility Firm Category RFA Impact Category Represented Firm Size & Impact Category

1 2 3 4 5 1 2 3 4 5 1 2 3 4 5Largest Weight is Left Out? RFA Size & Impact Category

1 2 3 4 5RFA CategorySize and RFA Category ChemicalsSmall <1% <1% Small_<1% Small_<1% ChemicalsLarge <1% <1% Large_<1%Large_<1% Paper Large <1% <1% Large_<1%Large_<1% MultipleLarge <1% <1% Large_<1%Large_<1% Steel Large <1% <1% Large_<1%Large_<1% Other Large <1% <1% Large_<1%Large_<1% Food Large <1% <1% Large_<1%Large_<1% Paper Large <1% <1% Large_<1%Large_<1% Steel Large <1% <1% Large_<1%Large_<1% Food Large <1% <1% Large_<1%Large_<1% ChemicalsLarge <1% <1% Large_<1%Large_<1% ChemicalsLarge <1% <1% Large_<1%Large_<1% ChemicalsLarge <1% <1% Large_<1%Large_<1% ChemicalsLarge <1% <1% Large_<1%Large_<1% Paper Large <1% <1% Large_<1%Large_<1% Paper Large <1% <1% Large_<1%Large_<1% PetroleumLarge <1% <1% Large_<1%Large_<1% Paper Large <1% <1% Large_<1%Large_<1% PetroleumSmall <1% <1% Small_<1% Small_<1% Food Large <1% <1% Large_<1%Large_<1% Food Large <1% <1% Large_<1%Large_<1% ChemicalsLarge <1% <1% Large_<1%Large_<1% ChemicalsLarge <1% <1% Large_<1%Large_<1% PetroleumSmall <1% <1% Small_<1% Small_<1% ChemicalsLarge <1% <1% Large_<1%Large_<1% ChemicalsLarge <1% <1% Large_<1%Large_<1% PetroleumLarge No Rev No Rev Large_No RevLarge_No Rev Other Large <1% <1% Large_<1%Large_<1% ChemicalsLarge <1% <1% Large_<1%Large_<1% PetroleumLarge <1% <1% Large_<1%Large_<1% Food Large <1% <1% Large_<1%Large_<1% Paper Large No Rev No Rev Large_No RevLarge_No Rev Paper Large <1% <1% Large_<1%Large_<1% ChemicalsLarge <1% <1% Large_<1%Large_<1% ChemicalsLarge <1% <1% Large_<1%Large_<1% ChemicalsLarge <1% <1% Large_<1%Large_<1% ChemicalsLarge <1% <1% Large_<1%Large_<1% ChemicalsSmall <1% <1% Small_<1% Small_<1% ChemicalsSmall <1% <1% Small_<1% Small_<1% Steel Large <1% <1% Large_<1%Large_<1% PetroleumLarge <1% <1% Large_<1%Large_<1% Food Large <1% <1% Large_<1%Large_<1% PetroleumSmall >3% >3% Small_>3% Small_>3% Paper Large >3% >3% Large_>3%Large_>3% Paper Large <1% <1% Large_<1%Large_<1% Paper Large <1% <1% Large_<1%Large_<1% Other Large <1% <1% Large_<1%Large_<1% PaperSmall <1% <1% Small_<1% Small_<1% PetroleumSmall <1% <1% Small_<1% Small_<1% Other Large <1% <1% Large_<1%Large_<1% MultipleLarge <1% <1% Large_<1%Large_<1% ChemicalsLarge <1% <1% Large_<1%Large_<1% AluminumSmall <1% <1% Small_<1% Small_<1% Paper Large <1% <1% Large_<1%Large_<1% Paper Large <1% <1% Large_<1%Large_<1% Other Small <1% <1% Small_<1% Small_<1% PetroleumLarge <1% <1% Large_<1%Large_<1% Paper Large <1% <1% Large_<1%Large_<1% Food Large <1% <1% Large_<1%Large_<1% Steel Small <1% <1% Small_<1% Small_<1% Paper Large <1% <1% Large_<1%Large_<1% Paper Large <1% <1% Large_<1%Large_<1% PaperSmall <1% <1% Small_<1% Small_<1% PaperSmall <1% <1% Small_<1% Small_<1% Paper Large <1% <1% Large_<1%Large_<1%

Size (In-scope Owning Only) Impact

Category Size & Impact Category Sector10 6 9 2 Firm Info

Parent Name Sector Revenues Size Facilities Owned8 Survey IDs of Facilities Owned

1 2 3 4 5 6 7 8 9 10 11 128 Weights of Facilities Owned

1 2 3 4 5 6 7 8 9 10 11 12 Facility weights and their associated costs and revenues are color coded from high to low for firms owning facilities with different weightsIn-scope Facilities

OwnedHighest ----------------------------------------------------------------------> Lowest 5 Revenues of Facilities Owned

1 2 3 4 5 6 7Highest ----------------------------------------------------------------------> Lowest

8 9 10 11 12 1 2 3 4Highest----------------------------------------------------------------------> Lowest 11 Compliance Costs of Owned Facilities

5 6 7 8 9 10 11 12Highest----------------------------------------------------------------------> Lowest
Unique Weights of Facilities Owned

1 2 3 4 5 6 7 8 9 10 11 12# Unique weights?????? Leave out the lowest weight? Leaves out the 2nd lowest wgt?

Leaves out the 3rd lowest wgt? Represented Firm Weights Represented Firm Costs

1 2 3 4 5 1 2 3 4 5Leaves out the 3rd lowest wgt? Represented Firm Cost-Revenue

1 2 3 4 5Weighted Costs of Owned Firms

1 2 3 4 5 6 7 8 9 10 11 12 TotalWtd Cost / Parent Rev Represented Firm Sector Represented Firm Size

1 2 3 4 5 1 2 3 4 5 Weighted Cost-RevenueLargest Weight is Left Out?

Represented Facility Firm Category RFA Impact Category Represented Firm Size & Impact Category

1 2 3 4 5 1 2 3 4 5 1 2 3 4 5Largest Weight is Left Out? RFA Size & Impact Category

1 2 3 4 5RFA CategorySize and RFA Category Size (In-scope Owning Only) Impact

Category Size & Impact Category Sector MultipleLarge <1% <1% Large_<1%Large_<1% Paper Large <1% <1% Large_<1%Large_<1% Steel Large <1% <1% Large_<1%Large_<1% PaperSmall <1% <1% Small_<1% Small_<1% Paper Large <1% <1% Large_<1%Large_<1% Other Small >3% >3% Small_>3% Small_>3% Paper Large <1% <1% Large_<1%Large_<1% PaperSmall No Rev No Rev Small_No RevSmall_No Rev PetroleumLarge <1% <1% Large_<1%Large_<1% Paper Large <1% <1% Large_<1%Large_<1% Paper Large <1% <1% Large_<1%Large_<1% Paper Large <1% <1% Large_<1%Large_<1% PetroleumLarge <1% <1% Large_<1%Large_<1% PetroleumLarge <1% <1% Large_<1%Large_<1% Paper Large <1% <1% Large_<1%Large_<1% Steel Small <1% <1% Small_<1% Small_<1% PaperSmall <1% <1% Small_<1% Small_<1% AluminumSmall <1% <1% Small_<1% Small_<1% Steel Large <1% <1% Large_<1%Large_<1% Paper Large <1% <1% Large_<1%Large_<1% AluminumLarge <1% <1% Large_<1%Large_<1% Steel Large <1% <1% Large_<1%Large_<1% ChemicalsLarge <1% <1% Large_<1%Large_<1% AluminumLarge <1% <1% Large_<1%Large_<1% Paper Large <1% <1% Large_<1%Large_<1% Paper Large <1% <1% Large_<1%Large_<1% Paper Large <1% <1% Large_<1%Large_<1% PaperSmall <1% <1% Small_<1% Small_<1% PetroleumLarge <1% <1% Large_<1%Large_<1% ChemicalsLarge <1% <1% Large_<1%Large_<1% ChemicalsLarge <1% <1% Large_<1%Large_<1% ChemicalsLarge <1% <1% Large_<1%Large_<1% ChemicalsLarge <1% <1% Large_<1%Large_<1% Other Small <1% <1% Small_<1% Small_<1% Paper Large <1% <1% Large_<1%Large_<1% Steel Large <1% <1% Large_<1%Large_<1% Steel Large <1% <1% Large_<1%Large_<1% Paper Large <1% <1% Large_<1%Large_<1% Other Small <1% <1% Small_<1% Small_<1% Food Small <1% <1% Small_<1% Small_<1% PetroleumLarge <1% <1% Large_<1%Large_<1% PaperSmall <1% <1% Small_<1% Small_<1% Paper Large <1% <1% Large_<1%Large_<1% PetroleumLarge <1% <1% Large_<1%Large_<1% Other Large <1% <1% Large_<1%Large_<1% ChemicalsLarge <1% <1% Large_<1%Large_<1% ChemicalsLarge <1% <1% Large_<1%Large_<1% Steel Large <1% <1% Large_<1%Large_<1% ChemicalsSmall <1% <1% Small_<1% Small_<1% PetroleumLarge <1% <1% Large_<1%Large_<1% Paper Large <1% <1% Large_<1%Large_<1% Steel Large <1% <1% Large_<1%Large_<1% Paper Large <1% <1% Large_<1%Large_<1% Steel Large <1% <1% Large_<1%Large_<1% PetroleumLarge <1% <1% Large_<1%Large_<1% Paper Large <1% <1% Large_<1%Large_<1% AluminumLarge <1% <1% Large_<1%Large_<1% Steel Small <1% <1% Small_<1% Small_<1% PaperSmall <1% <1% Small_<1% Small_<1% Steel Large <1% <1% Large_<1%Large_<1% Steel Large <1% <1% Large_<1%Large_<1%

### 1 2 3 4 1 2 34 6

Facility Survey ID

### Parent Parent_Order Parent Revenue ($)

### 5 6 7 8 9 10 11

3 4 5 6 7 8 9 9 12 8 7 6 22

Parent SizeFacility SectorTech

WeightEcon

WeightIn-ScopeSID (Inscope)Annualized Aftertax Compliance Costs

### 1 2 3 4 1 2 34 6

Facility Survey ID

### Parent Parent_Order Parent Revenue ($)

### 5 6 7 8 9 10 11

3 4 5 6 7 8 9 9 12 8 7 6 22

Parent SizeFacility SectorTech

WeightEcon

WeightIn-ScopeSID (Inscope)Annualized Aftertax Compliance Costs

### 1 2 3 4 1 2 34 6

Facility Survey ID

### Parent Parent_Order Parent Revenue ($)

### 5 6 7 8 9 10 11

3 4 5 6 7 8 9 9 12 8 7 6 22

Parent SizeFacility SectorTech

WeightEcon

WeightIn-ScopeSID (Inscope)Annualized Aftertax Compliance Costs

### 1 2 3 4 1 2 34 6

Facility Survey ID

### Parent Parent_Order Parent Revenue ($)

### 5 6 7 8 9 10 11

3 4 5 6 7 8 9 9 12 8 7 6 22

Parent SizeFacility SectorTech

WeightEcon

WeightIn-ScopeSID (Inscope)Annualized Aftertax Compliance Costs

### SectorFirms with <500 employees

Paper 218 Chemicals 2506 Petroleum 188 Steel 1149 Aluminum 227 Food 23,546 Source: SUSB 2006