### 1

DATE: January 31, 2014

SUBJECT: Final Economic and Small Business Impact Analysis for the Final PAI

- PEPO

P&R IV NESHAP

FROM: Larry Sorrels, EPA/OAQPS/HEID

TO: Nick Parsons, EPA/OAQPS/SPPD

This report by the U.S. Environmental Protection Agency (EPA) contains the economic
impact and small business analysis for this rulemaking, which consists of three different rules, all
of which are National Emissions Standards for Hazardous Air Pollutants (NESHAP). The three
rules are the Group IV Polymers and Resins (P&R IV), Polyether Polyols (PEPO), and the
Pesticide Active Ingredient (PAI) NESHAP. All of these rules are to be promulgated under

court

- order by January 31, 2014. This rulemaking contains final rules that consist of reviews of
existing NESHAP for these chemical source categories. Table 1 lists the portions of the chemical
manufacturing sector that are affected by each of these rules.

Below is a description of the types of sources affected by these rules. This description is
followed by a detailed indus try profile containing economic and financial data for the industry in
which all of these sources is found, NAICS 325 (Chemical Manufacturing). Finally, the
economic and small business analyses and results are presented at the end of the report.

### 2

Table 1. NESHAP AND INDUSTRIAL SOURCE CATEGORIES AFFECTED BY THIS

FINAL ACTION
NESHAP and Source Category NAICS code 1



### Group IV
Polymers and

Resins Acrylic

- Butadiene

- Styrene Production 325211

Methyl Methacrylate

- Acrylonitrile

Butadiene

- Styrene Production 3 

### 325211

Methyl Methacrylate

- Butadiene

- Styrene

Production 325211

Nitrile Resins Production 3 

### 325211
Polyethylene Terephthalate Production 325211
Polystyrene Production 325211
Styrene

- Acrylonitrile Production 325211

Pesticide Active Ingredient Production 325199,

325320
Polyether Polyols Production 325199

1 North American Industry Classification System.

2 Maximum Achievable Control Technology.

3 There are no longer any operating facilities in either the Methyl Methacrylate

- Acrylonitrile

- Butadiene

- Styrene Production or Nitrile Resins Production source categories, and we do not anticipate that any will begin operation in the future. Therefore, this rulemaking does not address these source categories.

### 3

1.0 Backgroun d on each Rule and Chemical Source Categories Regulated by these

Rules

The Group IV Polymers and Resins MACT standards regulate HAP emissions resulting
from the production of thermoplastics. A thermoplastic is a resin that softens wi th heat and
rehardens to a rigid material upon cooling, without generally showing any change in the physical
properties of the thermoplastic, even with repeated heating and cooling. Thermoplastics are
composed of high

- molecular

- weight polymers which are sy nthesized from monomers; the
thermoplastics covered in these seven source categories, with one exception, use styrene
monomer as the basic feedstock. Generally, the production of these polymers entails four
processes: (1) Raw material ( i.e. , solvent) stora ge and refining; (2) polymer formation in a
reactor (either via the solution process, where monomers are dissolved in an organic solvent, or
the emulsion process, where monomers are dispersed in water using a soap solution); (3)
material recovery; and (4) finishing ( i.e. , blending, aging, coagulation, washing, and drying).

Sources of HAP emissions from thermoplastics production include raw material storage
vessels, continuous and batch process vents, wastewater operations, heat exchangers and
equipment leaks. The Group IV Polymers and Resins MACT standards include a combination of
equipment standards and emission limits for the various emission sources, which vary in
stringency in some cases between the source categories.

Each of the five Group IV Polym ers and Resins source categories addressed in this
rulemaking are discussed further below. 1



### 1.1 Acrylonitrile butadiene styrene (ABS)
ABS resins consist of a terpolymer of acrylonitrile, butadiene, and styrene and can be
synthesized by emulsion, suspension, a nd continuous mass polymerization. The majority of ABS
resin production is by batch emulsion. Typical products made from ABS resins are piping,

1 Two of the Group IV Polymers and Resins source categories no longer have any operating facilities in the U.S. and are not included in this action. Those source categories are MABS and nitrile resins.

### 4

refrigerator door liners and food compartments, automotive components, telephones, luggage
and cases, toys, mobi le homes, and margarine tubs.

We identified six currently operating ABS facilities subject to the Group IV Polymers
and Resins MACT standards. Styrene, acrylonitrile and 1,3

- butadiene account for the majority of
the HAP emissions from the ABS production processes at these facilities (approximately 189
tons per year (TPY) and 69 percent of the total HAP emissions by mass). These facilities also
reported relatively small emissions of 24 other HAP. We estimate that the MACT

- allowable
emissions ( i.e. , the max imum emission levels allowed if in compliance with the MACT standard)
from this source category are approximately equal to the reported, actual emissions.

1.2 Styrene acrylonitrile (SAN)
SAN resins are copolymers of styrene and acrylonitrile, and they may be synthesized by
emulsion, suspension, and continuous mass polymerization; however, the majority of production
is by batch emulsion. Typical uses include automobile instrument panels and interior trim and

housewares.

We identified three currently operatin g SAN facilities subject to the Group IV Polymers
and Resins MACT standards. Ethyl benzene and styrene account for the majority of the HAP
emissions from the SAN production processes at these facilities (approximately 3 TPY and 73
percent of the total HAP emissions by mass). These facilities also reported relatively small
emissions of methylene chloride and acrylonitrile. We estimate that the MACT

- allowable
emissions ( i.e. , the maximum emission levels allowed if in compliance with the MACT standard)

from th is source category are approximately equal to the reported, actual emissions.

1.3 Methyl methacrylate butadiene styrene (MBS)
MBS resins are prepared by grafting methyl methacrylate and styrene onto a styrene

butadiene rubber in an emulsion process. The prod uct is a two

- phase polymer used as an impact
modifier for rigid polyvinyl chloride products. These products are used for applications in
packaging, building, and construction.

### 5

We identified two currently operating MBS facilities subject to the Group IV P olymers
and Resins MACT standards. Methyl methacrylate and 1,3

- butadiene account for the majority of
the HAP emissions from the MBS production processes at these facilities (approximately 4 TPY
and 75 percent of the total HAP emissions by mass). These faci lities also reported relatively
small emissions of ethyl acrylate, methanol, styrene, and hydrochloric acid. We estimate that the

MACT

- allowable emissions ( i.e. , the maximum emission levels allowed if in compliance with
the MACT standard) from this source category are approximately equal to the reported, actual

emissions.

1.4 Polystyrene
Polystyrene resins are those produced by the polymerization of styrene monomer. This
type of resin can be produced by three methods: (1) Suspension polymerization (operated i n batch mode); (2) mass (operated in a continuous mode); and (3) emulsion process (operated in a
continuous mode). The mass and suspension methods are the most commercially significant,
whereas use of the emulsion process has decreased significantly since the mid

- 1940s. The uses
for polystyrene resin include packaging and one

- time use, expandable polystyrene beads,
electronics, resellers and compounding, consumer and institutional products, and furniture,
building, or construction uses. A wide variety of co nsumer and construction products are made
from polystyrene resins, including disposable dinnerware, shower doors, light diffusers, soap
dishes, insulation board, food containers, drain pipes, audio and video tape, picnic coolers, loose
fill packaging, and tubing.

We identified ten currently operating polystyrene resins facilities subject to the Group IV
Polymers and Resins MACT standards. Styrene accounts for the majority of the HAP emissions
from the polystyrene resin production processes at these facilit ies (approximately 76 TPY and 93
percent of the total HAP emissions by mass). These facilities also reported relatively small
emissions of eight other HAP. We estimate that the MACT

- allowable emissions ( i.e. , the
maximum emission levels allowed if in compl iance with the MACT standard) from this source
category are approximately equal to the reported, actual emissions.

### 6

1.5 Poly (ethylene terephthalate) (PET)
Three different types of resins are made by sources covered by the PET source category:

Solid

- state resins (PET bottle grade resins); polyester film; and engineering resins. They are all
thermoplastic linear condensation polymers based on dimethyl terephthalate or terephthalic acid.
PET meltphase polymer is used in the production of all three of these re sins. PET production can
occur via either a batch or continuous process. The most common use of PET solid

- state resins is
in soft drink bottles, and some industrial fiber

- graded polyester ( e.g. , for tire cord) is also
produced from PET solid

- state resins. The most common uses of PET film are photographic film
and magnetic media. PET is used extensively in the manufacture of synthetic fibers ( i.e.

, polyester fibers), which compose the largest segment of the synthetic fiber industry. The most
common uses of p olyester fibers are apparel, home furnishings, carpets, fiberfill, and other
industrial processes.

We identified 13 currently operating PET facilities subject to the Group IV Polymers and
Resins MACT standards. Ethylene glycol, acetaldehyde and methanol account for the majority of
the HAP emissions from the PET production processes at these facilities (approximately 711
TPY and 86 percent of the total HAP emissions by mass). These facilities also reported relatively

small emissions of 18 other HAP. We est imate that the MACT

- allowable emissions ( i.e. , the
maximum emission levels allowed if in compliance with the MACT standard) from this source
category are approximately equal to the reported, actual emissions.

1.6 Pesticide Active Ingredients (PAI)

The PAI MA CT standard applies to major sources and regulates HAP emissions resulting
from the production of active ingredients in insecticides, herbicides, fungicides, and related
products. Typically, the active ingredients subject to the PAI MACT standards are subs equently
formulated with inert ingredients to create end

- product pesticides for application. The MACT
standards do not apply to the formulation of end

- product pesticides or to other types of active
ingredients such as biocides.

Pesticide active ingredient s are made from a number of raw materials in a variety of
processes. A process often consists of several steps, which may include reaction, crystallization,

### 7

washing, solvent extraction, distillation, and/or drying.

The HAP emission sources at PAI producti on facilities include storage vessels, process
vents, equipment leaks, wastewater systems, heat exchange systems, bag dumps, and product
dryers. In the production of PAI, HAP are used primarily as reactants or extraction solvents;
some of the PAI products are also HAP. The MACT standards for PAI production include a
combination of equipment standards and emission limits for the various emission sources.

We identified 18 currently operating facilities subject to the PAI MACT standards.
Toluene, methanol and methylene chloride account for the majority of the HAP emissions from
the PAI production processes at these facilities (approximately 179 TPY and 59 percent of the
total HAP emissions by mass). A variety of chemicals are used in the production of PAI, and
these facilities also reported emissions of 56 other HAP.

1.7 Polyether Polyols (PEPO)
The PEPO MACT standard applies to major sources and regulates HAP emissions
resulting from the production of chemical products with repeating ether linkages ( i.e.

, - R

- O

- R

- )
formed by the reaction of ethylene oxide, propylene oxide, or other cyclic ethers with
compounds having one or more reactive hydrogens. (This definition excludes materials regulated
as glycols or glycol ethers under the HON.) Polyether polyols do not ha ve significant uses of
their own but are used to make a variety of other products. Urethane grade polyether polyols
( i.e. , those that are free of water) are used as raw material in the production of polyurethanes,
including slabstock and molded flexible fo ams, rigid foams, and other polyurethanes including
microcellular products, surface coatings, elastomers, fibers, adhesives, and sealants. Nonurethane
polyether polyols are used as surfactants, lubricants, degreasing agents, hydraulic fluids,
cosmetics, an d pharmaceuticals.

Polyether polyols can be produced by either polymerization of epoxides ( i.e. , a three

membered cyclic ether, such as ethylene oxide or propylene oxide) or tetrahydrofuran (THF).
The former process is usually conducted as a batch process, while production of polyols using
THF is generally a continuous process. Ethylene oxide and pr opylene oxide are both HAP but

### 8

THF is not. For the MACT regulation, two subcategories of polyether polyols were created based
on the use of either epoxides or THF in polymerization.

We identified 23 currently operating facilities subject to the PEPO MACT standards.
Ethylene glycol, ethylene oxide and propylene oxide account for the majority of the HAP
emissions from the PEPO production processes at these facilities (approximately 234 TPY and
59 percent of the total HAP emissions by mass). A variety of chem icals are used in the
production of PEPO, and these facilities also reported emissions of 80 other HAP. We estimate

that the MACT

- allowable emissions ( i.e. , the maximum emission levels allowed if in compliance
with the MACT standard) from this source categ ory are approximately equal to the reported,
actual emissions, with the exception of certain types of process vents, which may be up to 5
times higher than the MACT

- allowable emissions.

### 9

2.0 Chemical Manufacturing

Below is a profile of the chemical manufacturing industry, various portions of which will
be impacted by one of the three NESHAP. Economic data for this industry and portions thereof
will be presented.

2.1 Introduction
The chemical manufacturing industry produces over 70,000 chemical substance s, many of which are ubiquitous in American life. Broadly speaking, chemical manufacturing operates by
converting feedstocks into chemical products that can serve as intermediate goods or final
products such as medicine, soap, and printer ink. From 2002 to 2007, shipments in the industry
grew 42%, while employment declined by 8% (Table 2). While total payroll dropped 0.6% over
this time, annual payroll per employee rose 7.8% from 2002 to 2007 because of the decline in the
number of employees (Table 3). Ship ments per employee grew 54% from 1997 to 2007, with
much of that growth taking place between 2002 and 2006 (Table 4).

Chemical manufacturing (NAICS 325) covers a diverse set of industry groups, which we
have aggregated into the following three groups:

 

### Bul k Chemicals

— Includes the most energy

- intensive industry groups as
aggregated by the Department of Energy (DOE). Basic Chemical Manufacturing
(NAICS 3251); Resin, Rubber, and Artificial Fibers Manufacturing (NAICS
3252); and Agricultural Chemical Manufactur ing (NAICS 3253).

 

### Pharmaceutical and Medicine Manufacturing (NAICS 3254)

— Consists primarily
of pharmaceutical preparation manufacturing. This industry group is the largest
importer of goods within chemical manufacturing.

 

### Other Chemical Manufacturing: Consi sts of Paint, Coating, and Adhesive
Manufacturing (NAICS 3255); Soap, Cleaning Compound, and Toiletry
Manufacturing (NAICS 3256); and Other Chemical Product and Preparation
Manufacturing (NAICS 3259).

### 10

In 2007, each of these groups generated approximately one

- third of the total employment in
chemical manufacturing (Figure 1). The bulk chemicals group accounted for the biggest share of chemical manufacturing’s total value of shipments (Figure 2).

Table 2. Key Statistics: Chemical Manufacturing (NAICS 325)

2002 2006 2007 Shipments ($2007, millions) $531,173 $675,223 $738,303 Payroll ($2007, millions) $51,317 $46,981 $49,648
Employees 853,224 747,134 814,024

Establishments 13,475 NA 12,937

NA = Not available.
Sources: U.S. Census Bureau; generated by RTI International; using American FactFinder; “Sector 31: Annual

Survey of Manufactures: General Statistics: Statistics for Industry Groups and Industries: 2006 and 2005.” http://f actfinder.census.gov ; (July 8, 2008)

. U.S. Census Bureau; generated by RTI International; using American FactFinder; “Sector 00: All Sectors: Core Business Statistics Series: Comparative Statistics for the United States and the States (199 7 NAICS Basis): 2002 and 1997.” http://factfinder.census.gov ; (July 8, 2008)

. U.S. Census Bureau; generated by Kapur Energy and Environment; using American FactFinder; “Sector 00: EC0700A1: All Sectors: Geographic Area Series: Economy

- Wide Key Statistics: 2007.” http://factfinder.census.gov . Accessed on December 27, 2009 . [Source for 2007 numbers]



### Table 3. Industry D ata: Chemical Manufacturing (NAICS 325)

Industry Data 2002 2006 2007 Total shipments ($2007, millions) $531,173 $675,223 $738,303 Shipments per establishment ($thousands) $39,419 NA $57,069 Shipments per employee ($2007) $622,548 $903,750 $906,979 Shipments per $ of payroll ($2007) $10.35 $14.37 $14.87 Annual payroll per employee ($2007) $60,145 $62,882 $60,991
Employees per establishment 63 NA 63

NA = Not available.
Sources: U.S. Census Bureau; generated by RTI International; using American FactFinder; “Sector 31: Annual

Survey of Manufactures: General Statistics: Statistics for Industry Groups and Industries: 2006 and 2005.” http://f actfinder.census.gov ; (July 8, 2008)

. U.S. Census Bureau; generated by RTI International; using American FactFinder; “Sector 00: All Sectors: Core Business Statistics Series: Comparative Statistics for the United States and the States (199 7 NAICS Basis): 2002 and 1997.” http://factfinder.census.gov ; (July 8, 2008)

. U.S. Census Bureau; generated by Kapur Energy and Environment; using American FactFinder; “Sector 00: EC0700A1: All Sectors: Geographic Area Series: Economy

- Wide Key Statistics: 2007.” http://factfinder.census.gov . Accessed on December 27, 2009 . [Source for 2007 numbers]

### 11

Figure 1. Distribution of Employment within Chemical Manufacturing (NAICS 325):

2007

Source: U.S. Census Bureau; generated by Kapur Energy and Environment; using American FactFinder; “Sector 31: EC0731I1: Manufacturing: Industry Series: Detailed Statistics by Indust ry for the U.S.: 2007.” Release date: October 30, 2009. Accessed on December 27, 2009

.



### Figure 2. Distribution of Total Value of Shipments within Chemical Manufacturing

(NAICS 325): 2007

Source: U.S. Census Bureau; generated by Kapur Energy and Environment; using American FactFinder; “Sector 31:EC0731I1: Manufacturing Industry Series: Detailed Statistics by Industry for U.S.: 2007.” http://factfinder.census.gov . Accessed on December 27, 2009

.

### 12

2.1.1 Supply and Demand Characteristics
Next, we provide a broad overview of the supply and demand side of the chemical
manufacturing industry. We emphasize the economic interactions this industry has with other
industries and people, including identifying the key goods and services used by the industry and
the major uses and consumers of chemical manufacturing products.

The top 10 industry groups supplying inputs to the chemical manufacturing industry in

2002 accounted for 71% of the total int ermediate inputs (Table 4). Bulk chemicals’ production
was the most energy intensive, using 79% of the chemical manufacturing inputs from petroleum
and coal products, electric power generation, transmission and distribution, and natural gas

distribution.

Table 4. Key Goods and Services Used in Chemical Manufacturing (NAICS 325)

($2007, millions )

Good or Service BEA Code Bulk

Chemicals Pharmaceuticals Other

Chemicals Total

Basic chemicals 3251 $59,495 $4,772 $14,021 $78,288
Management of companies and enterprises 5500 $15,071 $19,380 $16,396 $50,846

Pharmaceuticals and medicines 3254 $0 $25,125 $0 $25,125

Wholesale trade 4200 $9,428 $8,367 $6,077 $23,872
Scientific research and development services 5417 $6,172 $6,139 $5,554 $17,865

Petroleum and coal products 3240 $10,066 $398 $3,432 $13,896
Plastics and rubber products 3260 $2,675 $1,132 $5,556 $9,363

Resins, rubber, and artificial fibers 3252 $4,048 $0 $4,949 $8,996
Electric power generation, transmission, and

distribution 2211 $6,025 $716 $807 $7,548

Natural gas distribution 2212 $6,390 $154 $390 $6,934

Total intermediate use T005 $167,699 $82,403 $91,833 $341,935

Source: U.S. Bureau of Economic Analysis (BEA). 2008 . “2002 Benchmark Input

- Output Accounts: 2002 Standard Make and Use Tables at the Summary Level.” Table 2. Washington, DC: BEA.

### 13

2.1.1.1 Goods and Services Used in Chemical Manufacturing In 2007, the cost of materials made up 49% of chemical manufacturing’s total shipment
value ( Table 5). Total compensation to employees represented 9% of total shipment value, down

from 10% in 2005.

2.1.1.1.1 Energy
The Department of Energy (DOE) classifies bulk chemical manufacturing as an energy

intensive industry. Pharmaceuticals and other chemical manufacturing are categorized as non

energy

- intensive industries, grouped together with other industry groups under the “Balance of
Manufacturing” category (DOE, 2008 ).

Fuel used in chemical production can either facilitate chemical p rocesses or provide the

feedstock to derive value

- added chemicals. In 2007, 70% of chemical manufacturing’s energy
bill was spent on fuel used as feedstocks (O’Reilly, 2008 ). These fuel costs represented 2% of chemical manufacturing’s total value of shipments (Table 6).

As a whole, chemical manufacturing use less energy over the last 10 years. According to
DOE, natural gas use by the chemical manufacturing industry dropped 30% from 1998 to 2006,
and electricity use fell 10% (Table 6). From 1997 to 2005, when data ceased to be available,
chemical manufacturing used less electricity relative to the manufacturing sector as a whole
(Figure 3).

2.1.1.2 Uses and Consumers
Products manufactured in the groups bulk chemicals, pharmaceuticals, and other
chemicals have very different consumer profiles. Bulk chemicals is dominated by intermediate
use, representing 93% of its total commodity output and 56% of the total intermediate use of
chemical manufacturing products. Pharmaceuticals has both a high leve l of demand from
personal consumption, accounting for 67% of the total personal consumption of chemical
manufacturing products, and a large trade deficit (Table 7).

### 14

Table 5. Costs of Goods and Services Used in Chemical Manufacturing (NAICS 325)

($2007)

Va riable 2005 Share 2006 Share 2007 Share
Total shipments $646,895 100% $675,223 100% $722,494 100%
Total compensation (millions) $62,669 10% $61,683 9% $63,591 9%
Annual payroll $48,159 7% $46,981 7% $48,780 7%
Fringe benefits $14,510 2% $14,702 2% $14,811 2%
Total employees 756,078 747,134 801,567
Average compensation per
employee $82,887 $82,559 $79,333

Total production workers’ wages
(millions) $22,643 4% $22,231 3% $23,157 3%

Total production workers 431,502 430,880 463,802

Total production hours
(thousands) 899,499 885,993 948,244

Average production wages per

hour $25 $25 $24

Total cost of materials
($thousands) $299,859 46% $318,945 47% $357,055 49%

Materials, parts, packaging $247,851 38% $260,934 39% $291,656 40%
Purchase electricity $8,291 1% $8,490 1% $8,936 1%

Purchased fuel $14,568 2% $13,667 2% $14,227 2%

Other $29,148 5% $35,855 5% $42,236 6%

Sources: U.S. Census Bureau; generated by RTI International; using American FactFinder; “Sector 31: Annual

Survey of Manufactures: General Statistics: Statistics for Industry Groups and Industries: 2006 and 2005.” http://f actfinder.census.gov ; (July 8, 2008)

. U.S. Census Bureau; generated by Kapur Energy and Environment; using American FactFinder; “Sector 31: EC0731I1: Manufacturing: Industry Series: Detailed Statistics by Industry for the United States: 2007.” Accessed on December 27, 2009

.

### 15

Table 6. Energy Used in Chemical Manufacturing (NAICS 325)

Fuel Type 2002 2006
Total (trillion BTU) 3,769 3,159
Net electricity a (million kWh) 153,104 151,646
Residual fuel oil (million bbl) 7 4

Distillate fuel oil b (million bbl) 2 2
Natural gas c (billion cu ft) 1,634 1,349

LPG and NGL d (million bbl) 9 2
Coal (million short tons) 14 8
Coke and breeze (million short tons) * *

Other e (trillion BTU) 1,158 1,045
Total (trillion BTU) 3,769 3,159

a Net electricity is obtained by summing purchases, transfers in, and generation from noncombustible renewable resources, minus quantities sold and transferred out. It does not include electricity inputs from on

- site cogeneration or generation from combustible fuels because that energy has already been included as generating fuel (for example, coal).

b Distillate fuel oil includes Nos. 1, 2, and 4 fuel oils and Nos. 1, 2, and 4 diesel fuels.

c Natural gas includes natural gas obtained from utilities, local distribution compa nies, and any other supplier(s), such as independent gas producers, gas brokers, marketers, and any marketing subsidiaries of utilities.

d Examples of liquefied petroleum gases (LPGs) are ethane, ethylene, propane, propylene, normal butane, butylene, ethan e

- propane mixtures, propane

- butane mixtures, and isobutene produced at refineries or natural gas processing plants, including plants that fractionate raw natural gas liquids (NGLs).

e Other includes net steam (the sum of purchases, generation from renewabl es, and net transfers), and other energy that respondents indicated was used to produce heat and power.

* Estimate less than 0.5.
Sources: U.S. Department of Energy, Energy Information Administration. 2007b . “2006 Energy Consumption by

Manufacturers

— Data Tables.” Table 3.1. Washington, DC: DOE. http://www.eia.doe.gov/emeu/mecs/ mecs2006/2006tables.html . [Source for 2006 numbers] U.S. Department of Energy, Energy Information Administration. 2007a . “2002 Energy Consumption by Manufacturers

— Data Tables.” Tables 3.2 and N3.2. Washington, DC: DOE. http://www.eia.doe.gov/emeu/mecs/mecs2002/data02/shelltables.html

.

### 16

Figure 3. Electric Power Use Trends in Chemical Manufacturing (NAICS 325):

1997

– 2005

Source: Feder al Reserve Board. 2009 . “Industrial Production and Capacity Utilization: Electric Power Use: Manufacturing and Mining.” http://www.federalreserve.gov/datadownload /

.



### 2.1.2 Firm and Market Characteristics
This remaining subsection describes geographic, production, and market data. These data
provide the basis for further analysis, including regulatory flexibility analyses, and give a
complete picture of the recent historical trends of production and pricing.

2.1.2.1 Location
In 2002, California had the most chemical manufacturing establishments in the United
States, followed by Texas and New Jersey (Figure 4). The composition of establishments in these
states differs among the different industry groups. Despite the fact that each group employed an
approximately equal share of people in 2002, 54% of the total establishments were other
chemicals establishments, and only 13% were pharmaceutical establishments.

### 17

Table 7. Demand by Sector: Chemical Manufacturing (NAICS 325) ($2007 millions)

Sector BEA

Code Bulk

Chemicals Pharmaceuticals Other

Chemicals Total
Plastics and rubber products manufacturing 3260 $39,353 $0 $3,057 $42,410
Basic chemical manufacturing 3251 $33,972 $0 $1,675 $35,647

Pharmaceutical and medicine
manufacturing 3254 $4,778 $25,125 $462 $30,365

Resin, rubber, and artificial fibers
manufacturing 3252 $28,249 $0 $1,076 $29,325

Ambulatory health care services 6210 $2,716 $22,900 $934 $26,550

General state and local government

services S007 $7,150 $10,586 $8,807 $26,543

Hospitals 6220 $2,936 $15,390 $394 $18,720
Other chemical product and preparation
manufacturing 3259 $8,021 $0 $2,680 $10,701

Textile mills 3130 $9,568 $0 $930 $10,498
Soap, cleaning compound, and toiletry
manufacturing 3256 $3,886 $0 $6,289 $10,176

Total intermediate use T001 $212,996 $83,279 $82,107 $378,382
Personal consumption expenditures F010 $4,449 $123,746 $55,882 $184,077
Exports of goods and services F040 $47,121 $15,683 $13,136 $75,940
Imports of goods and services F050

− $38,732

− $67,950

− $10,906

− $117,588
Total final uses (GDP) T004 $15,733 $73,485 $58,023 $147,241
Total commodity output T007 $228,729 $156,765 $140,129 $525,623

Source: U.S. Bureau of Economic Analysis (BEA). 2008 . “2002 Benchmark Input

- Output Accounts: 2002 Standard Make and Use Tables at the Summary Level.” Table 2. Washington, DC: BEA.

### 18

Figure 4. Establishment Concentration in Chemical Man ufacturing (NAICS 325):

2002

Source: U.S. Census Bureau; generated by RTI International; using American FactFinder; “Sector 31: Manufacturing: Geographic Area Series: Industry Statistics for the States, Metropolitan and Micropolitan Statistical Areas, Coun ties, and Places: 2002.” http://factfinder.census.gov ; (July 23, 2008)

.



### 2.1.2.2 Production Capacity and Utilization
Capacity utilization of the chemical manufacturing industry has been broadly in line with
the manufacturing sector (Figure 5). In the second half of 2005, the chemical manufacturing industry’s capacity utilization fell dramatically because of the multiple hurricanes affecting the

Gulf Coast s tates. The impact of the economic downturn in 2001 can be seen in the capacity
utilization of both manufacturing and chemical manufacturing.

2.1.2.3 Employment
The geographic distribution of employment in chemical manufacturing differs largely
among the different groups. In California, 52% of the chemical manufacturing employment
comes from the pharmaceutical industry, while 60% of the chemical manufacturing employment
in the Gulf Coast states comes from bulk chemicals manufacturing (Figure 6).

2.1.2.4 Plants and Capacity
Production capacity in chemical manufacturing has grown 33% since 1997. This growth,
however, is 9% less than the growth rate for the manufacturing industry as a whole (Figure 7).

### 19

Figure 5. Capacity Utilization Trends in Chemical Manufacturing (NAICS 325 )

Source: Federal Reserve Board. 2009 . “Industrial Production and Capacity Utilization: Capacity Utilization.” http://www.federalreserve.gov/datadownload/

.



### Fi gure 6. Employment Concentration in Chemical Manufacturing (NAICS 325): 2002

Source: U.S. Census Bureau; generated by RTI International; using American FactFinder; “Sector 31: Manufacturing: Geographic Area Series: Industry Statistics for the States, Metro politan and Micropolitan Statistical Areas, Counties, and Places: 2002.” http://factfinder.census.gov ; (July 23, 2008)

.

### 20

Figure 7. Capacity Trends in Chemical Manufacturing (NAICS 325)

Source: Federal Reserve Board. 2009 . “Industrial Production and Capacity Utilization: Industrial Capacity.” http://www.federalreserve.gov/datadownload/

.



### 2.1.2.5 Firm Characteristics In 2007, the top six companies by chemical sales had greater than $10 billion in sales.
Together, their sales are great er than the next 44 highest chemical companies combined. These,
however, are global companies, with a large portion of both sales and production coming from
operations outside of the United States (Table 8). The largest chemical manufacturing company,

Dow Chemicals, has 108 out of 150 manufacturing sites located outside of the United States
(Dow Chemical Company, 2008 ).
In 2007, 58% of U.S. chemical manufacturing corporations generated net income.
Including those with and without net income, chemical manufacturers had an average before

- tax profit margin of 10.24%. Profitability is highest for pharmaceutical and medicine corporations
(Table 9).

### 21

Table 8. Top Chemical Producers: 2007

Chemical Sales ($millions) % of Total Sales % of Sales in United States

Dow Chemical 53,513 100% 35%

ExxonMobil 36,826 9% 38%

DuPont 29,218 100% 38%
Lyondell a 16,165 57% 80%
Chevron Phillips 12,534 100% 86%

PPG Industries a 10,025 90% 56%

Huntsman Chemical 9,651 100% 50%

Praxair 9,402 100% 43.5%

Air Products a 8,820 88% 51%

Rohm & Haas b 7,837 88% 49%

a Percentage of sales in the United States calculated from total sales, not chemical sales.

b Percentage of sales in the United States is actually percentage of sales in North America.
Source: O’Reilly, R. 2008 . “Chemicals.” Standard and Poor’s Industry Surveys. 176(28).



### Table 9. 2007 Corporate Income and Profitability (NAICS 325)

Industry Number of

Corporations Number of

Corporations

with Net

Income Total

Rece ipts ($thousands) Business

Receipts ($thousands) Before

Tax Profit
Margin After

- Tax

Profit
Margin

Basic chemical 1,244 757 $195,022,700 $178,019,490 5.07% 4.10%
Resin, synthetic rubber,
and artificial synthetic

fibers and filaments 1,067 648 $44,692,366 $40,078,009 8.06% 6.33%

Pharmaceutical and

medicine 1,034 611 $381,339,258 $317,414,432 15.63% 11.66%

Paint, coating, and

adhesive 1,411 1,260 $51,778,868 $49,486,744 5.39% 4.02%

Soap, cleaning compound,
and toilet preparation 1,862 463 $150,506,485 $139,836,602 9.07% 7.51%

Other chemical product
and preparation 2,946 1,773 $89,014,032 $84,062,534 6.71% 5.27%

Chemical manufacturing 9,564 5,512 $912,353,710 $808,897,810 10.24% 7.89%

Source: Internal Revenue Service, U.S. Department of Treasury. 2008b . “Corporation Source Book: Data File 2007.” http://www.irs.gov/taxstats/article/0,,id=167415,00.html ; (January, 15, 2010).

### 22

2.1.2.6 Size Distribution
The primary criterion for categorizing a business as small is number of employees, using
definitions by the SBA for regulatory flexibility analyses. The data describing size standards are
provided in Table 10. In 2002, enterprises with fewer than 500 employees accounted for 27% of
employment and 15% of receipts within the chemical manufacturing industry) as noted in Table

11.

2.1.2.7 Domestic Production
In the late 1990s, overall manufacturing production was growing much faster than the
chemical manufacturing component (Figure 8). Following the recession of 2001, however, the
components have moved broadly in line with one another, except for the drop in chemical
manufacturing production caused by the hurricane season of 20 05.

2.1.2.8 International Trade
In the year 2000, the United States moved from having a trade surplus to a trade deficit in
chemical manufacturing products (Figure 9). This change occurred because the trade deficit in pharmaceutical manufacturing, at $35 billion in 2007, overwhelmed the trade surplus of bulk chemicals and other chemical manufacturing combined, which was at $22 billion in 2007.

2.1.2.9 Market Prices
Prices of goods in chemical manufacturing have accelerated rapidly in the last 2 years,
having outpaced ove rall manufacturing since 2002 (Figure 10). Much of this recent acceleration
seen in the industry PPI is due to the bulk chemicals segment, largely reflecting the rapid
increase in fertilizer prices.

### 23

Table 10. Small Business Size Standards: Chemical Manufac turing (NAICS 325)

NAICS Description Employees

325110 Petrochemical Manufacturing 1,000

325120 Industrial Gas Manufacturing 1,000

325130 Synthetic Dye and Pigment Manufacturing 1,000

325193 Ethyl Alcohol Manufacturing 1,000

325194 Cyclic Crude, Intermediate, and Gum and Wood Chemical Manufacturing 750

325199 All Other Basic Organic Chemical Manufacturing 1,000

325211 Plastics Material and Resin Manufacturing 750

325212 Synthetic Rubber Manufacturing 1,000

325220 Artificial and Synthetic Fiber and Filaments Manufacturing 1,000

325311 Nitrogenous Fertilizer Manufacturing 1,000

325312 Phosphatic Fertilizer Manufacturing 500

325314 Fertilizer (Mixing Only) Manufacturing 500

325320 Pesticide and Other Agricultural Chemical Manufacturing 500

325411 Medicinal and Botanical Manufacturing 750

325412 Pharmaceutical Preparation Manufacturing 750

325413 In

- Vitro Diagnostic Substance Manufacturing 500

325414 Biological Product (except Diagnostic) Manufacturing 500

325510 Paint and Coating Manufacturing 500

325520 Adhesive Manufacturing 500

325611 Soap and Other Detergent Manufacturing 750

325612 Polish and Other Sanitation Good Manufacturing 500

325613 Surface Active Agent Manufacturing 500

325620 Toilet Preparation Manufacturing 500

325910 Printing Ink Manufacturing 500

325920 Explosives Manufacturing 750

325991 Custom Compounding of Purchased Resins 500

325992 Photographic Film, Paper, Plate and Chemical Manufacturing 500

325998 All Other Miscellaneous Chemical Product and Preparation Manufacturing 500

Source: U. S. Small Business Administration (SBA). 2013 . “Table of Small Business Size Standards Matched to North American Industry Classification System Codes.” Effective July 22, 2013. Found on the Internet at http://www.sba.gov/sites/default/files/Size_Standards_Table.pdf

.

### 24

Table 11. Distribution of Economic Data by Enterprise Size: Ch emical Manufacturing

(NAICS 325)

Enterprises with

Variable Total 1 to 20 Employees a 20 to 99

Employees 100 to 499

Employees 500 to 749

Employees 750 to 999

Employees 1,000 to 1,499

Employees

Firms 9,341 5,413 1,974 790 95 56 71

Establishments 13,096 5,433 2,208 1,352 250 185 276

Employment 827,430 34,838 78,090 113,326 28,025 18,119 28,338
Receipts ($millions) $468,211 $9,631 $21,394 $39,111 $12,217 $7,324 $14,762

Receipts/firm ($thousands) $50,124 $1,779 $10,838 $49,507 $128,603 $130,779 $207,913

Receipts/establishment ($thousands) $35,752 $1,773 $9,689 $28,928 $48,869 $39,587 $53,485

Receipts/employment ($) $565,862 $276,464 $273,971 $345,117 $435,942 $404,195 $520,920

a Excludes SUSB employment category for zero employees. These entities only operated for a fraction of the year.
Source: U.S. Census Bureau. 2008 . “Firm Size Data from the Statistics of U.S. Businesses: U.S. Detail Employment Sizes: 2002.” http://www.census.gov/csd/susb/download_susb02.htm

.



### Figure 8. Industrial Production Trends in Chemical Manufacturing (NAICS 325)

Source: Federal Reserve Board. 2009 . “Industrial Production and Capacity Utilizat ion: Industrial Production.” http://www.federalreserve.gov/datadownload/

.

### 25

Figure 9. International Trade Trends in Chemical Manufacturing (NAICS 325)

Source: U.S. International Trade Commission. 20 08 . “U.S. Domestic Exports” & “U.S. Imports for Consumption.” http://dataweb.usitc.gov/scripts/user_set.asp

.



### Figure 10. Producer Price Trends in Chemical Manufacturing (NAICS 325)

Source: U.S. Bureau of Labor Statistics (BLS). 2009c . Producer Price Index. Series ID: PCU325

— 325

— &PCUOMFG

— OMFG

— . http: //www.bls.gov/ppi/home.htm

.

### 26

3.0 Results of Economic and Small Business Analyses

For economic impact analyses of rules such as these that affect a single industry or a few
directly affected industries, the EPA typically prepares a partial equilibrium analysis . In this type
of analysis, the focus of the effort is on estimating impacts to the single affected industry or
several affected industries, and all impacts of this rule to industries outside of those affected are
assumed to be zero or so inconsequential t o not be considered in the analysis. If the compliance
costs, which are key inputs to an economic impact analysis, are quite insignificant, then the
impact analysis could consist of a calculation of annual costs as a percent of sales for affected

parent co mpanies. This latter type of analysis is called a screening analysis, and is applied when
a partial equilibrium or more complex economic impact analysis approach is deemed more than
necessary given the expected size of the impacts. We apply a screening ana lysis to estimate the
economic impacts for these rules given that the annual compliance costs for all 3 rules combined is approximately $1 million in 2012 dollars, a very small amount relative to the size of NAICS
325 and any of the six digit NAICS that ar e part of this higher level NAICS as shown in the
previous section of this report. The analysis employed here is a “sales test” that computes the
annualized compliance costs as a share of sales for each company. The annualized cost per sales
for a company represents the maximum price increase in affected product needed for the
company to completely recover the annualized costs imposed by the regulation.

The “sales test” is the impact methodology EPA employs in economic impact analysis

such as this one as o pposed to a “profits test”, in which annualized compliance costs are
calculated as a share of profits. 2 

### This is because revenues or sales data are commonly available
data for entities normally impacted by EPA regulations and profits data normally made avai lable
are often not the true profits earned by firms due to accounting and tax considerations. Firms and
entities often have ways legally available in the tax code to minimize their reported profits; thus,
using reported profits may lead to a less than acc urate estimate of the economic impact of a
regulation to an affected firm or entity and their consumers. While screening level analyses are
often employed to estimate impacts to small businesses or entities as part an analysis in

2 More information on sales and profit tests as used in analyses done by U.S. EPA can be found at http://www.epa.gov/sbrefa/documents/rfaguidance11

- 00

- 06.pdf , pp. 32

- 33.

### 27

compliance with the Regula tory Flexibility Act (RFA) as amended by the Small Business
Regulatory Enforcement Fairness Act (SBREFA), a screening level analysis can also be
employed in an economic impact analysis such as this one whose focus is on the regulated
companies. In addition , we also include consideration of measures of producer and consumer demand’s responsiveness to price changes to help with examining the economic impacts of these

rules. It should be noted that the compliance costs for the proposal were estimated in 2010

d ollars. For the final rules, the compliance costs are in 2012 dollars. Hence, we use 2012
revenues for affected firms in this report instead of the 2010 revenues included in the economic
impact analysis for the proposal in order to be consistent in estimat ing economic impacts.

For the parts of NAICS 325 affected by these rules, we find that the great majority of the
companies affected are large, US owned multinational companies with substantial revenues and
extensive product mixes. Using the employee size for the parent companies as per SBA guidance
on business definition, very few of these companies are small by the Small Business
Administration’s (SBA) small business size standard. 3 

### We generally find that the cost imposed
on these companies is a very sma ll fraction of the parent companies’ revenues, and should yield
small economic impacts on these chemical producers. The revenue estimate for these companies
reflects all product sales worldwide. In turn, such small economic impacts should yield small
impac ts on their customers (intermediate or end

- use).

3 SBA’s small business size standards can be found on the Internet at http://www.sba.gov/content/table

- small

business

- size

- standards

.

### 28

For the P&R IV final rule, there are 19 parent companies that are affected. Of the 19,
none of them is a small business according to the SBA small business size standard (for NAICS
325320, 750 employees or less). With no economic impact on small businesses, there is no
significant economic impact on a substantial number of small entities (SISNOSE) for this final

rule. Details on the impacts of this rule by parent company are below in Table 12.

Table 12. Economic Impacts to Parent Firms with Affected P&R IV Facilities

Parent Companies Affected by Final Rule Total Annualized Cost for Affected Parent Companies* (2012 dollars) Revenues for Parent Companies* (billions in 2012) Total Annualized

Cost/Revenues fo r Affected Parent Companies (%) 

### 3M $33,274 $29.90 0.00011
Alfa S.A.B. de C.V. 33,346 15.20 0.00023 Arkema 16,637 7.90** 0.00022 Chevron 16,637 241.90 0.0000068 Dart Container 33,274 1.3 0.003 Dow Corning 116,459 56.80 0.00014 DuPont 16,637 34.80 0.00004 Eastman 33,274 8.10 0.0004 Sun Capital Partners (owner of Emerald Polymer Additives, LLC) 16,637 45.0 0.00004

GE 49,911 147.00 0.00003 Huntsman 16,637 11.20 0.0001 INEOS 33,274 43.00 0.00008 Koch Industries 16,673 115.0 0.00003 M&G Group 16,637 3.20 0.0006 Mitsubishi 16,637 67.88*** 0.00004 Nan Ya Technology Group (owner of Nan Ya Plastics) 16,637 1.37 0.0003
Rayonier (owner of Performance Fibers) 33,274 1.57 0.0024
Total S.A. (owner of Atofina Petrochemicals) 16,637 248.00 0.000007
Zeon Corporation (owner of Zeon Chemicals) 16,637 3.17 0.0005

* Parent company revenues and compliance costs can be found in the spreadsheet “Chemicalsectorrulefirmrevenuescostsfinal”, that is in the docket for this rulemaking. **Based on 2012 annual average exchange rate of US dollars to Euros = 1.24, as found at http://www.irs.gov/Individuals/International

- Taxpayers/Yearl y

- Average

- Currency

- Exchange

- Rates

. ***Based on 2012 conversion of 82 yen to the US dollars as used by Mitsubishi in their 2012 financial reporting.

### 29

For the PAI final rule, there are 12 parent companies affected. Of the 12, none of them is

a small business according to the SBA small business size standard (for NAICS 325199, 500
employees or less). With no economic impact on small businesses, there is no SISNOSE for this
rule. Details on the impacts of this rule by parent company are below in Table 13.

Table 13. Economic Impacts to Parent Firms with Affected PAI Facilities

Parent Companies Affected by Final Rule Total Annualized

Cost for Affected Parent Companies* (2012 dollars) Revenues for Parent Companies* (billions in 2012) Total Annualized

Cost/Revenues for Affected Parent Companies (%) 

### Arysta $12,339 $1.60 0.0005 BASF 12,339 63.47 0.00001 Bayer 12,339 32.06 0.00003 Chemtura 12,339 2.60 0.0004 Dow 49,356 56.80 0.00008 DuPont 37,017 34.80 0.0001 Eastman 12,339 8.10 0.0002 Sumitomo Chemical (owner of McLaughlin Gormley King) 12,339 23.00 0.00005

Monsanto 12,339 13.50 0.0001 Occidental 12,339 24.17 0.00005 Syngenta AG 12,339 14.20 0.0002 International Chemical Investors Group (owner of WeylChem) 12,339 0.99 0.0002

* Parent company revenues and compliance costs can be found in the spreadsheet “Chemicalsectorrulefirmrevenuescostsfinal”, that is in the docket for this rulemaking.

### 30

For the PEPO final rule, there are 14 parent companies affected. Of the 14, none of them

is a small business accordin g to the SBA small business size standard (for NAICS 325212, 1,000
employees or less). With no economic impact on small businesses, there is no SISNOSE for this
rule. Details on the impacts of this rule by parent company are below in Table 14.

Table 14. E conomic Impacts to Parent Firms with Affected PEPO Facilities

Parent Companies Affected by Rule Total Annualized Cost for Affected Parent Companies* (2012 dollars) Revenues for Parent Companies* (billions in 2012) Total Annualized

Cost/Revenues for Affecte d Parent Companies (%) 

### AkzoNobel $10,538 $19.08 0.00005 BASF 21,076 63.47 0.00003 Bayer 21,076 32.06 0.00004 Carpenter Co. 10,538 2.0 0.001 Croda International 10,538 1.60 0.001 Dow (owner of Union Carbide) 63,228 56.80 0.0001

Eastman 10,538 8.10 0.0001 Huntsman 21,076 11.20 0.0002 Lonza 10,538 4.02 0.0004 LyondellBasell 10,538 45.35 0.00002 Milliken and Company 10,538 1.99 0.0004 Rubicon 10,538 13.8** 0.00008 Shell 10,538 467.20 0.000002 Stepan 10,538 1.80 0.0006

* Parent company revenues and compliance costs can be found in the spreadsheet “Chemicalsectorrulefirmrevenuescostsfinal”, that is in the docket for this rulemaking. ** Operates as a joint venture between Chemtura and Huntsman.

### 31

Impacts to large companies from each of these rules are annual compliance costs of less
than 0.0001 percent of their sales based on 2012 revenues. Thus, the impacts of each of these
rules should be quite minimal for these firms, most of which are multinational firms with
revenues well over $1 billion based on 2012 financial data. It should be noted that available
estimates of long

- run responsiveness of price changes show that the price elasticity of demand
for chemical manufacturing output is

- 1.0 4 

### , and the price elasticity of supply for chemical

manufactur ing output is 0.8. 5 

### Based on this information, one can conclude that demand will
respond 1:1 with a change in output price, and that supply is inelastic (i.e., will respond less than
1:1) with a change in output price. Thus, the direct impact of this rule appears quite minor, and
thus it is reasonable to infer that the impact on consumers of chemical manufacturing output
from this rule should also be minor. In addition, no small businesses are impacted by this final

rule.

4 Ho, M. S, R. Morgenstern, and J. S. Shih. 2008. “Impact of Carbon Price Policies on US Industry.” RFF Discuss ion Paper 08

- 37). Available on the Internet at http://www.rff.org/Publications/Pages/Publicationdetails.Aspx ?. Publicationid=20680. Table 8.A.6.
5 Broda, C., N. Limao, and D. Weins tein. 2008a. “Export Supply Elasticities.” Available on the Internet at http://faculty.chicagobooth.edu/christian.broda/web site/research/unrestricted/TradeElasticities/TradeElastic ities/html . Accessed September 2009.

### 32

4.0 References
Dow Chemical Company. 2008. “Transforming: The Dow Chemical Company 2007 10

- K and Stockholder Summary.” http://www.dow.com/financial/2007ann

- . Federal Reserve Board. 2009. “Industrial Production and Capacity Utilization.” http://www.federalreserve.gov/datadownload/

. Internal Revenue Service, U.S. Department of Treasury. 2008a. “Corporation Source Book: Data File 2005.” http://www.irs.gov/taxstats/article/0,,id=167415,00.html

. Internal Revenue Service, U.S. Department of Treasury. 2008b. “Corporation Source Book: Data File 2007.” http://www.irs.gov/taxstats/article/0,,id=167415,00.html

.

Kraft Foods Inc. 2008. “Form 10

- K, Period ending December 31, 2007.” http://www.kraft.com/Investor/sec

- filings

- annual

- report/

. O’Reilly, R. 2008. “Chemicals.” Standard and Poor’s Industry Surveys. 176(28).

Standard & Poors, 2008. Standard & Poor’s netAdvantage [electronic resource]. New York: Standard & Poors.

U.S. Bureau of Economic Analysis (BEA). 2008. “2002 Benchmark Input

- Output Accounts: 2002 Standard Make and Use Tables at the Summary Level.” Table 2. Washington, DC: BEA. U.S. Bureau of Labor Statistics. 2009a. “Producer Price Index.” Series ID: PCU321

— 321

— & PCUOMFG

— OMFG

— . htt p://www.bls.gov/ppi/home.htm

.

U.S. Bureau of Labor Statistics. 2009b. “Producer Price Index.” Series ID: PCU322

– 322

– & PCUOMFG

– OMFG

– . http://www.bls.gov/ppi/home.htm

.

U.S. Bureau of Labor Statistics. 2009c. “Producer Price Index.” Series ID: PCU325

— 325

— &PCUOMFG

— OMFG

— . http://www.bls.gov/ppi/home.htm

.

U.S. Census Bureau. 2001. “1997 Census NAICS Definitions.” http://www.census.gov/epcd/ec97/industry/E322.HTM#def

.

U.S. Census Bureau. 2008. “Firm Size Data from the Statistics of U.S. Businesses: U.S. Detail Employment Sizes: 2002.”http://www.census.gov/cs d/susb/download_susb02.htm.

U.S. Census Bureau. “Sector 00: All Sectors: Core Business Statistics Series: Comparative Statistics for the United States and the States (1997 NAICS Basis): 2002 and 1997” (generated by RTI International using American FactFind er). http://factfinder.census.gov . Accessed July 8, 2008.

U.S. Census Bureau. “Sector 00: All Sectors: Core Business Statistics Series: Comparative Statistics for the United States and the States (2007 NAICS Basi s): 2002 and 2007” (generated by RTI International using American FactFinder). http://factfinder.census.gov . Accessed January 4, 2010.

### 33

U.S. Census Bureau. “Sector 00: EC0700A1: All Sectors: Geographic Area Series : Economy

Wide Key Statistics: 2007” (generated by Kapur Energy and Environment using American FactFinder). http://factfinder.census.gov . Accessed December 27, 2009.

U.S. Census Bureau. “Sector 31: Annual Survey of Manufactures: General Statistics: Statistics for Industry Groups and Industries: 2006 and 2005” (generated by RTI International using American FactFinder). http://factfinder.census.gov . Accessed July 8, 2008.

U.S. Census Bureau. “Sector 31: EC0731I1: Manufacturing: Industry Series: Detailed Statistics by Industry for the United States: 2007” (generated by Kapur Energy and Environment using American FactFinder). http:// factfinder.census.gov . Accessed December 27, 2009.

U.S. Census Bureau. “Sector 31: Manufacturing: Geographic Area Series: Industry Statistics for the States, Metropolitan and Micropolitan Statistical Areas, Counties, and Places: 2002” (generated by RTI I nternational using American FactFinder). http://factfinder.census.gov . Accessed July 23, 2008.

U.S. Department of Energy, Energy Information Administration. 2007a. “2002 Energy Consumption by Manufacturers

— Data T ables” (Tables 3.2 and N3.2). http://www.eia.doe.gov/emeu/mecs/mecs2002/data02/shelltables.html

. . U.S. Department of Energy, Energy Information Administration. 2007b. “2006 En ergy Consumption by Manufacturers

— Data Tables” (Table 3.1). http://www.eia.doe.gov/emeu/mecs/mecs2006/2006tables.html . U.S. Department of Energy, Energy Information Administration. 200 8. “Assumptions to the Annual Energy Outlook 2008: With Projections for 2030.” http://www.eia.doe.gov/oiaf/aeo/assumption/

.

U.S. International Trade Commission. 2008 . “U.S. Domestic Exports” and “U .S. Imports for Consumption.” http://dataweb.usitc.gov/scripts/user_set.asp

.

U.S. Small Business Administration. 2013. “Table of Small Business Size Standards Matched to North American Industry Classification System Codes.” http://www.sba.gov/sites/defaul t/files/Size_Standards_Table.pdf

.