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Final Economic Impact Analysis for the Proposed Chemical Sector NESHAPs

– November 2011

This report contains the economic impact and small business analysis for the proposed chemical sector rule. This rulemaking consists of three different proposed rules, all of which are
National Emissions Standards for Hazardous Air Pollutants (NESHAP). The three rules are the Polymers and Resins IV, Polyether Polyols, and the Pesticide Active Ingredients NESHAPs. All of these rules are to be proposed under court

- order by November 30, 2011. This rulemaking contains proposals that consist of reviews of existing NESHAPs 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 i s followed by a detailed industry 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 th e end of the report.

Table 1. NESHAP AND INDUSTRIAL SOURCE CATEGORIES AFFECTED BY THIS PROPOSED 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 Ingredients 325199, 325320 Polyether Polyols 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 proposal does not address these source categories.

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

The Polymers and Resins IV MACT standards regulate HAP emissions resulting from the production of thermoplastics. A thermoplastic is a resin that softens with hea t 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 synthesi zed 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) storage 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) finish ing
( 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. T he MACT standards for Polymers and Resins IV production 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 Poly mers and Resins Production source categories addressed in this proposal are discussed further below. 1



### 1.1 Acrylonitrile butadiene styrene resin (ABS). Acrylonitrile

- butadiene

- styrene resins consist of a terpolymer of acrylonitrile, butadiene, and styrene and can be synthesized by emulsion, suspension, and continuous mass polymerization. The majority of ABS resin production is by batch emulsion. Typical products made from ABS resins are piping, refrigerator door lin ers and food compartments, automotive components, telephones, luggage and cases, toys, mobile homes, and margarine tubs.

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

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

- butadiene account for the majority of the HAP emissions from the ABS production processes at these facilities (approximately 156 tons per year (TPY) and 76 percent of the total HAP emissions by mass). These facilities also reported relatively small em issions of 23 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 category are approximately equal to the reported, actual emissions.

1.2 Styrene ac rylonitrile resin (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 automo bile instrument panels and interior trim and

housewares.

We identified two currently operating SAN facilities subject to the Polymers and Resins IV MACT standard. Ethyl benzene and styrene account for the majority of the HAP emissions from the SAN produc tion processes at these facilities (approximately 2 TPY and 82 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 this source category are approximately equal to the reported, actual emissions.

1.3 Methyl methacrylate butadiene styrene resin (MBS).

MBS resins are prepared by graf ting methyl methacrylate and styrene onto a styrene

butadiene rubber in an emulsion process. The product is a two

- phase polymer used as an impact modifier for rigid polyvinyl chloride products. These products are used for applications in packaging, buildin g, and construction. We identified two currently operating MBS facilities subject to the Polymers and Resins IV MACT standard. Methyl methacrylate and 1,3

- butadiene account for the majority of the HAP

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

MACT

- allowable emissions ( i.e. , t he 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 resin. Polystyrene resins are those produced by the polymerization of styre ne monomer. This type of resin can be produced by three methods: (1) Suspension polymerization (operated in 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 consumer and construction products are made from polystyrene resins, including disposable dinnerware, shower doors, light diffusers, soap
dishes, insula tion board, food containers, drain pipes, audio and video tape, picnic coolers, loose fill packaging, and tubing.

We identified 11 currently operating polystyrene resins facilities subject to the Polymers and Resins IV MACT standard. Styrene accounts for the majority of the HAP emissions from the polystyrene resin production processes at these facilities (approximately 85 TPY and 94 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 compliance with the MACT standard) from this source category are approximately equal to the reported, actual emissions.

### 5

1.5 Poly (ethylene terephthalate) res in (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 dimeth yl terephthalate or terephthalic acid. PET meltphase polymer is used in the production of all three of these resins. 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 polyester fibers are apparel, home furnishings, carpets, fiberfill, and other industrial processes.

We identified 15 currently operating PET facilities subject to the Polymers and Resins IV MACT standard. Ethylene glycol, acetaldehyde and methanol account for the majority of the HAP emissions from the PET production processes at these facilities (approximately 1,048 TPY and 89 percent of the to tal HAP emissions by mass). These facilities also reported relatively

small emissions of 34 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

catego ry are approximately equal to the reported, actual emissions.

1.6 Pesticide Active Ingredients (PAI) The PAI MACT standard applies to major sources and regulates HAP emissions resulting from the production of active ingredients in insecticides, herbic ides, fungicides, and related products. Typically, the active ingredients subject to the PAI MACT standards are subsequently formulated with inert ingredients to create end

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

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

Pesticide active ingredients 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,

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

The HAP emission sources at PAI production facilities include storage vessels, process vents, equipment leaks, wastewater systems, heat exchange systems, bag dumps, and product dry ers. 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 emissio n sources. We identified 17 currently operating facilities subject to the PAI MACT standard.

Toluene, methanol and methylene chloride account for the majority of the HAP emissions from the PAI production processes at these facilities (approximately 177 TPY and 51 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 67 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 category are approximately equal to the reported, actual

emissions.

1.7 Polyether Polyols (PEPO) The PEPO MACT standard applies to major sources and regulates HAP emissions resulting fro m 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 have 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 materi al in the production of polyurethanes, including slabstock and molded flexible foams, rigid foams, and other polyurethanes including microcellular products, surface coatings, elastomers, fibers, adhesives, and sealants. Nonurethane polyether polyols are us ed as surfactants, lubricants, degreasing agents, hydraulic fluids, cosmetics, and pharmaceuticals.

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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 propylene oxide are both HAP but THF is not. For the MACT regulation, two subcate gories of polyether polyols were created based on the use of either epoxides or THF in polymerization.

We identified 25 currently operating facilities subject to the PEPO MACT standard. Ethylene glycol, ethylene oxide and propylene oxide account for the m ajority of the HAP emissions from the PEPO production processes at these facilities (approximately 269 TPY and 61 percent of the total HAP emissions by mass). A variety of chemicals are used in the production of PEPO, and these facilities also reported emi ssions of 81 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 category are approximately equal to the reported,

actual emissions.

2.0 Chemical Ma nufacturing

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

2.1 Introduction
The chemical manufacturing industry produces over 70,000 chemical substances, many of which are ubiquitous in American life. Broadly speaking, chemical manufacturing operates by converting feedstocks into chemical products that can serve as intermediate go ods or final products such as medicine, soap, and printer ink. From 1997 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 199 7 to 2007 because of the decline in the number of employees (Table 3). Shipments per employee grew 54% from 1997 to 2007, with much of that growth taking place between 2002 and 2006 (Table 4).

### 8

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

 

### Bulk Chemicals

— Includes the most energy

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

 

### Pharmaceutical and Medicine Manufacturing (NAICS 3254)

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

 

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

1997 2002 2006 2007
Shipments ($2007, millions) $521,251 $531,173 $675,223 $738,303 Payroll ($2007, millions) $49,961 $51,317 $46,981 $49,648
Employees 882,645 853,224 747,134 814,024

Establishments 13474 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://factfinder.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 (1997 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; ―Sect or 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]

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Table 3. Industry Data: Chemical Manufacturing (NAICS 325)

Industry Data 1997 2002 2006 2007
Total shipments ($2007, millions) $521,251 $531,173 $675,223 $738,303 Shipments per establishment ($thousands) $38,686 $39,419 NA $57,069 Shipments per employee ($2007) $590,556 $622,548 $903,750 $906,979 Shipments per $ of payroll ($2007) $10.43 $10.35 $14.37 $14.87 Annual payroll per employee ($2007) $56,603 $60,145 $62,882 $60,991
Employees per establishment 66 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://factfinder.census.gov>; (July 8, 2008)

. U.S. Census Bureau; generated by RTI International; us ing American FactFinder; ―Sector 00: All Sectors: Core Business Statistics Series: Comparative Statistics for the United States and the States (1997 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]



### 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: Manuf

acturing: Industry Series: Detailed Statistics by Industry for the U.S.: 2007.‖ Release date: October 30, 2009. Accessed on December 27, 2009

.

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

(NAICS 3 25): 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 Dec ember 27, 2009

.


### 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 peop le, 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 intermediate 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
di stribution.

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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.



### 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 s hipment 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 fa cilitate chemical processes 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
chemic al 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,

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and electricity use fe ll 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, pharmaceu ticals, 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 level of demand from personal consumption, accounting for 67% of the total personal consumption of chemical manufacturing products, and a large trade deficit (Table 7).

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

($2007)

Variable 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://factfinder.census.gov>; (July 8, 2008)

.

### 13 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

.


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

Fuel Type 1998 2002 2006

Total (trillion BTU) 3,704 3,769 3,159
Net electricity a (million kWh) 169,233 153,104 151,646

Residual fuel oil (million bbl) 8 7 4

Distillate fuel oil b (million bbl) 2 2 2
Natural gas c (billion cu ft) 1,931 1,634 1,349

LPG and NGL d (million bbl) 15 9 2

Coal (million short tons) 13 14 8

Coke and breeze (million short tons) * * *

Other e (trillion BTU) 748 1,158 1,045

Total (trillion BTU) 3,704 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 examp le, 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 companies, 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, ethane

- 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 renewables, 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

Manufacturer s

— 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>.

### 14

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

1997

– 2005

Source: Federal 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 comple te 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 th ese 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 establis hments.

### 15

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.

### 16

Figure 4. Establishment Conce ntration 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, Metropolitan and Micropolitan Statistical Areas, Counties, 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 states. The impact of the ec onomic 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 chem ical 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).

### 17

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/>.



### Figure 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, Metropolitan and Micropolitan Statistical Areas, Counties, and Places: 2002.‖ <http://fac tfinder.census.gov>; (July 23, 2008)

.

### 18

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

Source: Federal Reserve Board. 2009 . ―Industrial Production a nd 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 greater than the next 44 hi ghest 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, ch emical manufacturers had an average before

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

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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

Receipts ($thousands) Busine ss

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).

### 20

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 2005.

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 manufactur ing 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 overall 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.

### 21

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

NAICS Description Employees

325110 Petrochemical Manufacturing 1,000

325120 Industrial Gas Manufacturing 1,000

325131 Inorganic Dye and Pigment Manufacturing 1,000

325132 Synthetic Organic Dye and Pigment Manufacturing 750

325181 Alkalies and Chlorine Manufacturing 1,000

325182 Carbon Black Manufacturing 500

325188 All Other Basic Inorganic Chemical Manufacturing 1,000

325191 Gum and Wood Chemical Manufacturing 500

325192 Cyclic Crude and Intermediate Manufacturing 750

325193 Ethyl Alcohol Manufacturing 1,000

325199 All Other Basic Organic Chemical Manufacturing 1,000

325211 Plastics Material and Resin Manufacturing 750

325212 Synthetic Rubber Manufacturing 1,000

325221 Cellulosic Organic Fiber Manufacturing 1,000

325222 Noncellulosic Organic Fiber 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). 2010 . ―Table of Small Business Size Standards Matched to North American Industry Classification System Codes.‖ Effective November 5, 2010. Found on the Internet at http://www.sba.gov/sites/default/files/Size_Standards_Table.pdf

.

### 22

Table 11. Distribution of Economic Data by Enterprise Size: Chemical 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 Ma nufacturing (NAICS 325)

Source: Federal Reserve Board. 2009 . ―Industrial Production and Capacity Utilization: Industrial Production.‖ <http://www.federalreserve.gov/datadownload/>.

### 23

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

Source: U.S. International Trade Commission. 2008 . ―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/ho me.htm>.

### 24

3.0 Results of Economic and Small Business Analyses

For economic impact analyses of rules such as these that affect a single industry, the Agency 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 to 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 companies. This latter type of analysi s is called a screening analysis, and is applied when a partial equilibrium approach is deemed more than necessary given the expected size of the impacts. We apply a screening analysis to estimate the economic impacts for these rules given that the annual compliance costs for all 3 rules combined is about $2 million, a very small amount relative to the
size of NAICS 325 as shown in the previous section of this report. 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 the proposal.

For the parts of NAICS 325 affected by the proposal, we find that the great majority of the companies affected are large, US owned multinational companies with s ubstantial revenues and extensive product mixes. Very few of these companies are small by the Small Business Administration’s (SBA) small business size standard. We generally find that the cost imposed
on these companies is a very small fraction of the c ompanies’s revenues, and should yield small
economic impacts on these chemical producers. In turn, such small economic impacts should yield small impacts on their customers (intermediate or end

- use).

For the Polymers and Resins IV proposal, there are 18 parent companies that are affected. Of the 18, only one of them is a small business according to the SBA small business size standard (for NAICS 325320, 750 employees or less). The impact of the proposed rule on this small business is an annual complianc e cost of less than 0.02 percent of the firm’s annual sales
based on 2010 revenues. Based on the small size of the impact and only one affected small

### 25

business, there is no SISNOSE for this proposal. Details on the impacts of this proposal by

parent compa ny are below in Table 12.

Table 12. Economic Impacts to Parent Firms with P&R IV Facilities
Parent Companies Affected by Proposed Rule Total Annualized

Cost for Affected

Parent Companies**
(2010 dollars) Revenues for

Parent Companies**
(billions in 2010) Total Annualized

Cost/Revenues for

Affected Parent Companies (%)



### 3M $55,136 $26.70 0.0002

Alfa S.A.B. de C.V. 55,136 11.01 0.0005

Arkema 55,136 6.40 0.0009

Chevron 27,568 198.20 <0.0001
Core Moldings Technology 27,568 0.1 0.028

Dart Container 55,136 0.5 0.011

Dow 137,840 53.40 0.0002

DuPont 55,136 51.05 0.0001

Eastman 55,136 5.05 0.001

Emerald Performance

Materials* 27,568 0.18 0.015

GE 82,704 150.21 <0.0001
Grupp 27,568 2.00 0.0014

Ineos 27,568 28.40 <0.0001

Koch Industries 27,568 100.0 <0.0001
M&G Group 27,568 3.00 0.0009

Mitsubishi 27,568 13.41 0.0002

Nan Ya 27,568 11.17 0.0002

Performance Fibers 28,056 0.80 0.0035

*small business. Has 700 employees according to data at http://www.emeraldmaterials.com/cms/epm/home.html

. ** Parent company revenues and compliance costs can be found in the spreadsheet ― PAI

- PEPO

- P&RIV Firm Revenues Costs ‖, that is in the docket for this rulemaking.

### 26

For the PAI proposal, there are 11 parent companies affected. Of the 11, only one of them is a small business according to the SBA small business size standard (for NAICS 325199, 500 employees or less). The impact of the proposed rule on this small business is an annual compliance cost of less than 0.3 percent of the firm’s annual sales based on their 2010 revenues.
Based on the small size of the impact and only one affected small business, there is no SISNOSE for this pr oposal. Details on the impacts of this proposal by parent company are below in Table

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

Rule Total Annualized

Cost for Affected Parent Companies**
(201 0 dollars) Revenues for

Parent Companies**
(billions in 2010) Total Annualized

Cost/Revenues for

Affected Parent Companies (%) 

### Arysta $27,568 $1.40 0.0002

BASF 27,568 84.64 <0.0001
Bayer 27,568 51.85 <0.0001

Chemtura 27,568 2.80 0.001

Dow 110,272 53.40 0.0002

DuPont 82,704 51.05 0.0002

Eastman 27,568 5.05 0.0005
McLaughlin Gormley King* 27,568 0.01 0.28

Monsanto 27,568 10.50 0.003

Occidental 27,568 15.53 0.0002
Syngenta AG 55,136 11.60 0.0005

*small business. Has 50 to 99 employees according to data at http://www.manta.com/c/mmc1pmb/mc

- laughlin

gormley

- king

- co

. ** Parent company revenues and compliance costs can be found in the spreadsheet ―Chemicalsectorrulefirmrevenuescostsproposal‖, that is in the docket for this rulemaking.

### 27

For the PEPO proposal, there are 13 parent companies affected. Of the 13, none of them is a small business according to the SBA small business size standard (for NAICS 325212, 1,000 employees or less). With no impact on small businesses, there is no SISNOSE for this proposal. Details on the impacts of this proposal by parent company are below in Table 14.

Table 14. Economic Impacts to Parent Firms with PEPO Fac ilities
Parent Companies Affected by Proposed

Rule Total Annualized

Cost for Affected Parent Companies*
(2010 dollars) Revenues for

Parent Companies*
(billions in 2010) Total Annualized

Cost/Revenues for

Affected Parent Companies (%) 

### Arysta $27,568 $1.40 0.002

BASF 137,840 84.64 0.0002
Bayer 27,568 51.85 0.0001

Croda International 27,568 1.00 0.001

Dow 82,704 53.40 0.0002

Eastman 27,568 5.05 0.0005

Huntsman 55,136 9.21 0.0006

Lonza 27,568 2.74 0.001
LyondellBasel 27,568 41.00 <0.0001

Milliken and
Company 27,568 2.0 0.0014

Rubicon 27,568 0.70 0.004

Shell 27,568 368.06 <0.0001
Stepan 27,568 1.40 0.002

* Parent company revenues and compliance costs can be found in the spreadsheet ―Chemicalsectorrulefirmrevenuescostsproposal‖, that is in the docket for this rulemaking.



### Impacts to large companies from each of these rules are annual compliance costs of less than 0.0001 percent of their sales based on 2010 revenues. Thus, the impacts of each of these rules should be quite minimal for these firms, mo st of which are multinational firms with
revenues well over $1 billion based on 2010 financial data. It should be noted that available

### 28

estimates show that the price elasticity of demand for chemical manufacturing output is

- 1.0 2



### , and the price elasticity of supply for chemical manufacturing output is 0.8. 3 

### 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. T hus, 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.

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. Depa rtment 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/t axstats/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. Washing ton, DC: BEA. U.S. Bureau of Labor Statistics. 2009a. ―Producer Price Index.‖ Series ID: PCU321

— 321

— & PCUOMFG

— OMFG

— . <http://www.bls.gov/ppi/home.htm>.

2 Ho, M. S, R. Morgenstern, and J. S. Shih. 2008. ―Impact of Carbon Price Policies on US Industry.‖ RFF Discussion Paper 08

- 37). Http://Www.Rff.Org/Publications/Pages/Publicationdetails.Aspx?. Publicationid=20680. Accessed August 2009. Table 8.A.6.

3 Broda, C., N. Limao, and D. Weinstein. 2008a. ―Export Supply Elasticities.‖ http://faculty.chicagobooth.edu/christian.broda/website/research/unrestricted/TradeElasticities/TradeElastic ities.html . Accessed September 2009.

### 29

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.cens us.gov/csd/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 America n FactFinder). <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 Basis): 2002 and 2007‖ (generated by RTI International using American FactFinder). <http://factfinder.census.gov>. Accessed January 4, 2010.

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

Wide Key Statistics: 2007‖ (generated by Kapur Energy and Enviro nment 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 Ene rgy 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 Statistica l Areas, Counties, and Places: 2002‖ (generated by RTI International using American FactFinder). <http://factfinder.census.gov>. Accessed July 23, 2008.

U.S. Department of Energy, Energy Information Administration. 2007a. ―2002 Energy Consumption by Manufa cturers

— Data Tables‖ (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. 2 007b. ―2006 Energy Consumption by Manufacturers

— Data Tables‖ (Table 3.1).

< http://www.eia.doe.gov/emeu/mecs/mecs2006/ 2006tables.html >.

### 30

U.S. Department of Energy, Energy Information A dministration. 2008. ―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. 2010. ―Table of Small Business Size Standards Matched to North American Industry Classification System Codes.‖ http://www.sba.gov/sites/default/files/Size_Standards_Table.pdf

.