# Technical Support Document f or Greenhouse Gas Emissions Thresholds

Evaluation

Air Quality

Policy Division Office of Air Quality

Policy and Standards U.S. Environmental Protection Agency

March 2 9 , 2010i Table of Content s Page 1. Purpose ................................ ................................ ................................ ................................ ...... 1 2. Overview ................................ ................................ ................................ ................................ ... 1 3. Emissions - based Threshold Analysis ................................ ................................ ..................... 2 3.1 General Description of Overall Approach ................................ ................................ ........... 2 3.1.1 Threshold Levels ................................ ................................ ................................ ........... 2 3.1.2 Greenhouse Gases ................................ ................................ ................................ ......... 3 3.1.3 Source Sectors ................................ ................................ ................................ ............... 4 3.1.4 Potential to Emit Methodology ................................ ................................ ..................... 5 3.1.5 New and Modified Sources ................................ ................................ ........................... 6 3.2 Threshold Summary

Results ................................ ................................ ................................ 6 3.3 Electri city Generating Sector ................................ ................................ ............................... 9 3.4 Industrial Sector ................................ ................................ ................................ ................. 11 3.4.1 Data Sources ................................ ................................ ................................ ............... 14 3.4.2 Potential to Emit ................................ ................................ ................................ ......... 14 3.4.3 Methodology

for New Units ................................ ................................ ....................... 14 3.5 Methodology

for Existing Unspecified Industrial Stationary Combustion Source Category Emissions ................................ ................................ ................................ ............ 15 3.6 Methodology

for Existing Specific Industrial Sectors Considering Combustion, Process , and Fugitive Emissions ................................ ................................ ........................ 17 3.6.1 Adipic Acid Production ................................ ................................ .............................. 17 3.6.2 Aluminum Production ................................ ................................ ................................ . 19 3.6.3 Ammonia Prod

uction ................................ ................................ ................................ .. 21 3.6.4 Cement Production ................................ ................................ ................................ ..... 22 3.6.5 Electronic Production ................................ ................................ ................................ . 24 3.6.6 Ethanol Production ................................ ................................ ................................ ..... 25 3.6.7 Ferroallo y Production ................................ ................................ ................................ . 27 3.6.8 Food Processing ................................ ................................ ................................ .......... 29 3.6.9 Glass Manufacturing ................................ ................................ ................................ ... 30 3.6.10 HCFC - 22 Production ................................ ................................ ................................ 31 3.6.11 Hydrogen Production ................................ ................................ ................................ 33ii Table of Contents (cont.) Page 3.6.12 Iron and Steel Production ................................ ................................ ......................... 34 3.6.13 Lead Production ................................ ................................ ................................ ........ 37 3.6.14 Lime ................................ ................................ ................................ .......................... 38 3.6.15 Magnesium Production and Processing ................................ ................................ .... 39 3.6.16 Nitric Acid Production ................................ ................................ .............................. 41 3.6.17 Petrochemical Production ................................ ................................ ......................... 42 3.6.18 Petroleum Refineries ................................ ................................ ................................ . 44 3. 6.19 Phosphoric Acid Production ................................ ................................ ..................... 46 3.6.20 Pulp and Paper Manufacturing ................................ ................................ ................. 47 3.6.21 Silicon Carbide Manufacturing ................................ ................................ ................. 48 3.6.22 Soda Ash Production ................................ ................................ ................................ 50 3.6.23 Titanium Dioxide Production ................................ ................................ ................... 51 3.6.2 4 Zinc Production ................................ ................................ ................................ ......... 52 3.7 Energy

Sector ................................ ................................ ................................ ..................... 53 3.7.1 Oil and Gas Systems ................................ ................................ ................................ ... 53 3.7.2 Underground Coal Mining ................................ ................................ .......................... 54 3.8 Waste Sector ................................ ................................ ................................ ...................... 57 3.8.1 Landfills ................................ ................................ ................................ ...................... 57 3.8.2 Municipal Solid Waste Combustors ................................ ................................ ........... 59 3.9 Agriculture (Stationary Fuel Combustion) ................................ ................................ ........ 60 3.10 Commercial Stationary Fuel Combustion ................................ ................................ ........ 62 3.11 Residential Buildings ................................ ................................ ................................ ....... 65 3.11.1 Single - Family

Homes ................................ ................................ ............................... 66 3.11.2 Multi - Family

Residential Buildings ................................ ................................ ......... 67 References ................................ ................................ ................................ ................................ .... 72 Appendix A ................................ ................................ ................................ ................................ .. 77 Appendix B ................................ ................................ ................................ ................................ .. 781

Technical Support Document for Permit Thresholds for Greenhouse Gases 1. Purpose The purpose of this document is to provide the background information that was used to support EPA ' s decision process on evaluating and selecting greenhouse gas ( GHG) major source applicability thresholds for Prevention of Significant Deterioration (PSD) and Title V permitting for EPA’s final rule “Prevention of Signficant Deterioration and Title V Greenhouse Gas Tailoring Rule” . The document describes the analysis used to estimate the number of existing and new facilities (e.g., industrial plant or commercial building) that would exceed different GHG emission threshold lev els. The document also summarizes the results of this analysis for each sector. The results of this analysis served as one of the fundamental bas e s for evaluating administrative burdens at both exi s ting permitting thresholds and for evaluating and selecting proposed alternative permitting thresholds to address administrative necessity concerns . 2. Overview In order to support EPA ' s assess ment of the administrative burden created by adding GHGs to existing Prevention of Significant Deterioration (PSD) and Title V permitting programs , it was necessary to develop information on the number of affected facil ities at both the current permitting major source thresholds (generally , 100 tons per ye ar for Title V and 100 or 250 tons per year for PSD depending on the source category classification) and at alternative higher thresholds. An affected facility would be one who ' s annual emissions of the GHG equal or exceed the major source threshold being evaluated. Eight threshold levels ranging from 100 to 100,000 tons per year of GHG emission s were evaluated. Some of the alternative thresholds evaluated are the same as ones (e.g., 25,000 tons per year CO 2 - equivalents) considered in previous studies and in support of EPA ' s proposed and final GHG m andatory reporting r ule s (GHG MRR, 74 FR 68, pp. 16447

– 16731 and 74 FR 209, pp. 56260 - 56519, respectively) . One key difference between the emissions data developed for this analysis and the emissions data developed to support the proposed GHG MRR is that this anal ys is i s based on a facil ity' s " potential to emit " (PTE) while the propose d GHG reporting rule was based on " actual " emissions ( i.e. , the emissions a facility actually emits in a given ye ar) . PTE is defined as the maximum capacity of a stationary source to emit a pollutant under its physical and operational design, including certain legal limitations, for example, on emissions or hours of operation. NSR and Title V programs both use PTE for defining major sources. The end result is generally

that more facilitie s will exceed a given threshold on a PTE basis than on an actual basis. This is an important differentiation in terms of both evaluating the thresholds under this rule and when comparing the results to other threshold anal ys is, such as the supporting data for the EPA ' s GHG MRR . Although the primary

focus of this analysis was on the potential administrative burden associated with different GHG permitting emission levels as represented in terms of number of facilities potentially

subject to permitting, inf ormation on GHG emissions from affected facil ities2

was also collected to assess the relative coverage of national stationary source GHG emissions at the different threshold levels. While the environmental impact associated with the different GHG permitting levels was not used as the basis for the GHG applicability thresholds identified in the final GHG tailoring rule, the information on national emissions coverage provide s a useful measure to consider the potential scope of the proposed alternative thresho lds , their coverage of key GHG emission source categories , and whether they promote the environmental purposes of the PSD and Title V programs. 3. Emissions - based Threshold Analysis 3.1 General Description of Overall Approach This section presents a g eneral description of the overall approach EPA used to evaluate a range of permitting thresholds in terms of the number of sources affected, and amount of emissions covered. EPA made use of earlier anal ys es performed to develop emission thresholds for the proposed and final GHG MRR , or used the same data sources when additional anal ys es were required. EPA did not conduct primary research for this analysis, but instead relied on published research and publicl y available government data, such as EPA ' s e GRID database of electric generating source emission s , Economic and Housing Census data, and Energy Information Agency (E IA) data o n energy

consumption. 3. 1.1 Threshold Levels EPA evaluated eight different GHG emission thresholds: GHG Thresholds (tons p er year ) 100 250 1,000 5,000 10,000 25,000 50,000 100,000 The first two thresholds are the current Clean Air Act major source criteria pollutant thresholds for the federal operating permit program under Title V (generally , 100 tpy for major source applic ability) , and the PSD construction permit program under Title I . Under PSD, a "major stationary

source" is any

source belonging to a specified list of 28 source categories which emits or has a PTE of 100 tpy or more , or any

other source type which emits o r has the potential to emit such pollutants in amounts equal to or greater than 250 tpy.3

The six additional thresholds cover the range of thresholds evaluated for the proposed GHG MRR , and add two additional thresholds at 5,000 and 50,000 tons per year. Like the Clean Air Act , the permit thresholds are based on U.S. short tons (tons) instead of metric tons (mtons). There is a three - orders - of - magnitude range in the thresholds which reflects the much higher quantity

of GHG emissions compared to criteria p ollutant emissions from the primary source of GHG emissions, fossil fuel combustion. For example , an uncontrolled natural gas fired boiler that emits 100 tons of NO x annually would at the same time emit about 100,000 tons of CO 2 . The threshold anal ys is of source counts and emission s was done on a " potential to emit " basis , because that is the basis that is relevant for the permitting requirements under PSD and title V . Potential emissions (in short tons) from each source were evaluated against the threshold levels in order to determine whether or not a source would be included in the threshold count. When a source was identified as being covered b y a given threshold level, the actual emissions from that source were included to determine the emissions co vered b y the threshold. In other words, where summary

tables present " Tg GHG Emissions Covered p er Year " these are the actual emissions that would be covered b y the threshold level , given the source count arrived at considering potential to emit emission levels. 3.1.2 Greenhouse Gases EPA evaluated emissions of the major GHGs that are directl y emitted by human activities at the eight threshold levels. The GHGs evaluated are shown below in Table 1 . For purposes of this analysis emissions were evaluated on both an individual GHG mass basis and CO 2 - equivalent basis (CO 2 e). CO 2 e normalizes the different heat trapping capacities of the different GHGs to that of CO 2 . A quantity of a GHG is converted to a CO 2 e basis b y multiplying the mass of the compound emitted by its Global Warming Potential (GWP) . The GWP is a metric that incorporates both the heat - trapping ability and atmospheric lifetime of each GHG relative to CO 2 .4 Table 1 Major GHGs Directly Emitted by Human Activities Greenhouse Gas Chemical F ormula or Acronym Global Warming

Potential (GWP) * Carbon dioxide CO 2 1 Methane CH 4 21 Nitrous oxide N 2 O 310 Perfluorocarbons PFCs Varies by compound Hydrofluorocarbons HFCs Varies by compound Sulfur hexafluoride SF 6 23,900

* GWP values as codified in the EPA’s final GHG mandatory reporting rule : Table A - 1 to Subpart A of Part 98

– Global Warming Potentials, FR, Vol.74, No. 209, p. 56395.

Sector descriptions contained in this document include a discussion of GHG s evaluated for each sector. I f the analysis included more than one GHG , the description includes gas specific counts as well as a CO 2 e count. The threshold analyses for stationary fossil fuel combustion were simplified by excluding CH 4 and N 2 O emissions , because CO 2 comprises over 99 percent of GHG emissions from fossil fuel combustion . 3.1.3 Source Sectors In this analysis EPA evaluated the same range of stationary source typ es with direct GHG emissions as identified in the proposed and final GHG MRR . The proposed GHG MRR source categories were based on a comprehensive review of all U . S . source categories with GHG emissions, to include the categories that emit the most significant amount of GHG emissions. The stationary

sources evaluated in this anal ys is can be grouped in the se ctors shown below : ● Electricity

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

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

(oil and gas extraction, transport, and processing; underground coal mining) ; ● Was te Treatment (landfills and municipal solid waste incinerators) ; ● Agriculture (stationary fuel combustion); ● Commercial (stationary fuel combustion) ; and ● Residential (stationary fuel combustion) . A number of direct emission source types included in the GHG MRR anal ys is were not included in the potential to emit analysis because the GHG emissions from these sources were5

primarily fugitive emissions. Fugitive emissions are emissions which are not released, or could not be reasonably

released, through a stack or vent. Under the PSD rules, fugitive emissions are only included in potential to emit estimates if the source is one of 28 listed PSD source categories. Excluded fugitive emissions sources are listed below: ● Electrical equipment SF 6 emissions ; ● Wastewater treatment plants not associated with one of 28 listed PSD source categories (combustion is captured in the commercial sector anal ys is) ; and ● Agricultural manure management . 3.1.4 Potential to Emit Met hodology As noted earlier, the potential to emit (PTE) is the amount of emissions that can be emitted from a source operating at full capacity. The annual PTE is based on operation at full equipment capacity , 24 hours per day , 365 days per year (8 , 760 hours per year). For example, if a boiler has a maximum rated heat input capacity of ten million Btu per hour, the annual PTE for that boiler is the amount of emissions from burning 87,600 million Btu of fuel: 10 mmBtu/hr x 8 ,760 hrs/yr = 87,600 mmBtu/yr Capacity information and annual GHG emissions were available for some of the source categories from analyses performed to support the GHG MRR . In some cases the supporting anal ys es had already calculated GHG emissions on a full capacity basis, in which ca se EPA directly used those estimates as PTE estimates. Alternatively , some data from the supporting anal ys is estimated actual annual emissions using a baseline year. If capacity and baseline ye ar production information was provided in the supporting data , EPA adjusted the source actual emissions estimate by

the ratio of annual capacity to baseline production to estimate PTE. If capacity information was not available , EPA used capacity factors from other data sources to adjust actual emission estimates to PTE estimates. These capacity factors add varying uncertainty to the PTE estimate. Detailed descriptions of the different PTE calculation methodologies are included in the source descriptions in the following section. Removal by

pollution control equipment was considered in the PTE estimates, though control equipment removal was relevant in only a few cases (thermal oxidation of HPCs and CH 4 ). Also , as noted earlier, fugitive emissions, were onl y included in the PTE estimates if the source was one of the 28 listed PSD source categories. For example , fugitive CH 4 emissions from oil and gas transmission stations were not included in CH 4 or CO 2 e emissions when comparing to the different thresholds, but were included for iron and steel plants.6

3. 1.5 New Construction The source population data from the analyses supporting the GHG MRR , and other data sources provide information on existing sources and their emissions. The PSD and title V program requirements and applicability determinations , however, als o apply to newly constructed sources. The general approach for estimating the annual number of newly constructed sources was to apply growth rates in the number of units or facilities in a source category to the number of existing facilities at the different thresholds. Growth rates were available from a variety of sources including Economic Census data, EIA energy survey data, and various EPA regulatory impact anal ys es and information collection requests which require source population estimates. In som e cases there was sufficient information to distribute new sources to different thresholds based on emission information specific to the new sources (electric generating, municipal solid waste combustors, and commercial stationary fuel combustion). Otherwise EPA assumed the same size and threshold distribution for new units as for existing units. For example , if the annual growth rate in a category was one percent , the number of existing facilities above a threshold were multiplied by the fractional growth rate to estimate the number of new faciliti es at that threshold per ye ar. EPA did not develop estimates for modifications to exsiting sources (which can be potentially

subject to PSD requirements) as part of this threshold study ; estimates for modifications were prepared under a separate burden anal ys is prepared for the final GHG tailoring rule and located in the final docket for the rulemaking 1

. 3. 2 Threshold Summary Results The resulting counts of affected stationary source facilities and the amount of actual GHG emissions covered at different PTE thresholds for all sectors are shown in the tables below . GHG emissions covered at each threshold are in Tg, which is equivalent to million metric tons . SIunits were used for the covered emissions to be consistent with the EPA’s official U.S. GHG Inventory so that comparions could be made to the inventory in terms of emissions coverage at different applicability

thresholds . The complete data for the sectors and subsectors are provided in supporting spre adsheets that accompany this report. These spreadsheets are identified in Appendices A and B.

1 See “Summary of Methodology and Data Used to Estimate Burden Relief and Evaluate Resource Requirements at Alternative Greenhouse Gas (GHG) Permitting Thresholds” contained in the public docket for the final tailoring rule at EPA - HQ - OAR - 2009 - 0517.7 Table 2 CO 2 e Threshold Summary -- All Stationary Source Sectors GHG Threshold (t ons p er year) Number of

Existing Sources Number of New

Facilities Added p er Year CO 2 e Emissions Covered (Tg p er year) 100 6, 118,252 67, 4 69 3 , 86 7 250 1, 079,483 19, 755 3 , 78 6 1,000 302,863 4, 43 0 3 , 723 5,000 59,140 549 3 , 622 10,000 30, 341 31 3 3 , 56 4 25,000 16,564 140 3 , 493 50,000 9,980 96 3 , 3 87 100,000 5,3 2 6 72 3 , 26 7 Table 3 CO 2 Threshold Summary -- All Stationary Source Sectors GHG Threshold (tons per y ear) Number of

Existing Sources N umber of N ew

Facilities Added p er Year CO 2 Emissions Covered (Tg p er year) 100 6, 113,861 67, 469 3 , 651 250 1, 075,078 19, 755 3 , 570 1,000 2 98, 527 4, 43 0 3 , 513 5,000 55,313 549 3 , 413 10,000 2 6,836 31 3 3 , 35 7 25,000 13,637 139 3 , 293 50,000 8, 109 96 3,2 12 100,000 4,2 2 6 72 3 , 11 48 Table 4 CH 4 Threshold Summary - - All Stationary Source Sectors GHG Threshold (tons per y ear) Number of

Existing Sources Number of New

Facilities Added p er Year CH 4 Emissions Covered (Tg p er year) 100 4,201 0 7.807 250 3,851 0 7.759 1,000 2,887 0 7.321 5,000 1,042 0 4.740 10,000 466 0 3.697 25,000 138 0 2.234 50,000 34 0 1.185 100,000 3 0 0.211 Table 5 N 2 O Threshold Summary - - All Stationary Source Sectors GHG Threshold (tons per y ear) Number of

Existing Sources Number of New

Facilities Added p er Year N 2 O Emissions Covered (Tg per y ear) 100 47 0 0.074 250 46 0 0.074 1,000 31 0 0.068 5,000 5 0 0.0 22 10,000 0 0 0 25,000 0 0 0 50,000 0 0 0 100,000 0 0 09 Table 6 High GWP Gases Threshold Summary - - All Stationary Source Sectors

GHG GHG

Threshold* (tons per y ear) Number of

Existing Sources Number of New

Facilities Added p er Year GHG Emissions

C overed (Tg per y ear) HFC 100 3 0 0.001 HFC 250 3 0 0.001 HFC 1,000 1 0 0.001 HFC 5,000 and above 0 0 0 PFC 100 and above 0 0 0 SF 6 100 and above 0 0 0 * Where a threshold is not listed for a particular GHG, threshold counts for that threshold and any higher thresholds can be assumed to be zero. 3.3 Electricity Generating Sector Data Sources The latest version of EPA ' s e GRID database (2006) was used to estimate the PTE of electricity generating facilities and counts of units above the different emission thresholds. The e GRID database includes year 2004 characteristics, operating information, and annual emissions (including CO 2 ) for U.S. facilities that have a generation capacity greater than one MW, and sell electric power to the grid. A facility' s PTE was estimated based on the e GRID generator table. The generator table, which is based on the 2004 EIA form 860 database, provides prime mover, generator nameplate capacity , and primary

energy source (fuel ty

pe) for each generator down to 0. 1 MW. To calculate PTE , we combined the nameplate capacity and primary

fuel for each of the fossil - fired units with average fuel based prime mover heat rates (Btu/kWh) published by EIA ( EIA, 2007).10 Table 7 EGU Prime Mover Heat Rates (EIA Electric Power Annual, Table A7, 2007) Prime Mover Fuel Average Heat Rate (Btu/kWh) Steam turbine Coal 10,114 Gas 10,466 Oil 10,400 Simple combustion turbine Gas 11,459 Oil 13,216 Com bined cycle combustion turbine Gas 7,445 Oil 11,015 Internal combustion engine Gas 9,923 Oil 10,149 The e GRID database includes cogeneration plants and generating units at industrial plants that primarily

supply electric power and steam to a host facility . We eliminated these units from the electric generation facility population based on North American Industry Classification System (NAI CS ) code, so that the only facilities included were facilities with a NAI CS code beginning with 22 (Utilities). The generator- nameplate - heat - rate approach potentially underestimates PT E for cogeneration plants, where a portion of the burner heat input provides useful thermal energy in addition to electric output. This potential to underestimate PTE affects 321 of 2,237 or 14 percent of facilities evaluated. Methodology for Existing Fa cilities Fuel combustion was the only source of GHG emissions considered for the electric ity generation sector. From the e GRID and EIA information EPA calculated a maximum annual fuel heat input based on 8,760 hours of operation for the combustors assoc iated with the generator. This calculated maximum annual heat input was used with fuel combustion emission factors from the GHG MRR for the primary fuel, to calculate the facility PTE. The calculations covered 10,487 fossil fuel - fired generators with nam eplate capacities down to 0.1 MW or 100,000 kW. EPA also did not evaluate fugitive CH4 emissions from facility coal piles. Fossil fuel fired steam electric plants with heat input greater than 250 mmBtu/hr heat input are one of the 28 listed PSD source c ategories that include fugitive emissions when calculating PTE. However, the CO 2 PTE from combustion alone for this size facility is about 225,000 tons per year. This is11

well over all of the emission thresholds considered in this analysis without consideration of the contribution of fugitive CH 4 . New Units The e GRID generator table includes an online ye ar field. To determine the number of new units per ye ar at different thresholds EPA counted generators online each year and totaled the emissions assoc iated with those generators at the facility level over the 15 - ye ar period from 1990 through 2004. Counts were made of the number of these facilities over the different PTE thresholds, and averaged over the 15 ye ars to arrive at the number of new or modifi ed facilities per year. Threshold Summary The table below shows the facilities and emissions covered at the different emission thresholds based on the described methodology . There were a total of 2,237 facilities in the electric generation population , so all facilities and all emissions are covered up to the 5,000 ton PTE thresho ld. Almost all emissions (99.9 percent), and about 75 percent of facilities are covered at the highest 100,000 ton PTE threshold. Table 8 CO 2 Threshold Summary Results - - E lectricity Generating Sector GHG Threshold (tons per y ear) Number of

Existing Sources Number of New

Facilities Added p er Year CO 2 Emissions Covered (Tg per y ear) 100 2,237 93 2,373 250 2,237 93 2,373 1,000 2,237 93 2,373 5,000 2,237 91 2,373 10,000 2,195 86 2,373 25,000 2,076 73 2,373 50,000 1,911 64 2,373 100,000 1,721 60 2,371 3.4 Industrial Sector The industrial sector comprises establishments engaged in the mechanical, physical, or chemical transformation of materials, substances, or components into new products, and specificall y includes businesses classified in Sectors 31

– 33 according to the North American12

Industry Classification System (NAICS) . Industrial source greenhouse gases result from manufacturing processes as well as combustion processes. Because there is a great deal of variability

within the sector, this technical support document includes industry- specific discussions a fter a general sector overview. For the industrial sector, EPA considered the six individual greenhouse gases separatel y, and also prepared an analysis considering CO 2 e. In preparation of the GHG MRR, EPA identified 23 industrial sectors where the GHG emissions were significant ; these sectors are listed in Table 9 .13 Table 9 Industrial Sectors and GHG Emis sions NAICS Code Industrial Sector C O 2 CH 4 N 2 O SF 6 HFC PFC 325199 Adipic Acid Production X X 331312 Aluminum Production X X 325311 Ammonia Production X 327310 Cement Production X 334 Electronics Manufacturing X X X X 325193 Ethanol Production X 331112 Ferroalloy Production X X 3116 Food Processing X 327 Glass Production X 325120 HCFC - 22 Production X X

Hydrogen Production X 331111 Iron and Steel Production X X 3314 Lead Production X 327 410 Lime Manufacturing X 3314 Magnesium Production X X 325311 Nitric Acid Production X X 3251 Petrochemical Production X X 324110 Petroleum Refineries X X 325312 Phosphoric Acid Production X 3221 Pulp and Paper Manufacturing X 327910 Silicon Carbide Production X X 325181 Soda Ash Manufacturing X 325188 Titanium Dioxide Production X 3314 Zinc Production X In addition , there are a large number o f industrial establishments across all industrial sec tors that emit less significant amounts of GHGs (primarily CO 2 ) from stationary source fuel combustion. Combustion emissions from these establishments were analyzed under the Unspecified In dustrial Stationary Combustion source category .14

3.4 .1 Data Sou rces There were several primary data sources used in preparation of the permit threshold anal ys is. EPA consulted anal ys es prepared in support of the GHG MRR for the 23 industrial sectors for which combustion, process and fugitive emissions were significa nt . These documents can be found in the docket numbered EPA - HQ - OAR- 2008 - 05 08. The TSDs contain industryspecific anal ys es of process, fugitive, and combustion emissions for industries. Supporting anal ys es used to prepare the TSDs are found in entries 00 46.7 and 0046.8 of the GHG MRR docket. These emissions estimate details were helpful in breaking down TSD emissio n estimates to compare facility- specific emissions against the additional threshold levels considered in the permit threshold anal ys is, including 100, 250, 5 , 000, and 50,000 tons per year. Combustion emissions analyses for the Unspecified Industrial Stationary Combustion sectors used data from the 2002 Manufac turing Energy Combustion Survey

(MECS ) and the U.S. Census Bureau ' s 2002 Economic Census . MECS is a survey of manufacturing and industrial energy

uses and costs prepared b y the EIA (EIA, 2007) . Data is collected b y manufacturing establishment through mailed questionnaires . The 2002 MECS data reflects responses accounting for approximatel y 9 8 percent of the manufacturing payroll , and reports separate energy

use estimates for 48 NAI CS industrial sector groups. The MECS provided information on the amount of fuel burned in 2002 by sector on an employ

ment basis. The 2002 Economic Census data provided information on the number of establishments sorted by three digit NAICS code and disaggregated into specific size categories based on employ ment (U.S. Census, 2004). 3.4 .2 Potential to Emit As mentioned earlier in this document, permit thresho ld anal ys es considered both actual emissions and PTE. When capacity information was not available, the analyses applied utilization rates from the Industrial Production and Capacity Utilization, Federal Reserve Statistical Release G - 17 in order to adjust actual emissions to determine PTE emissions. These utilization rates are prepared quarterl y with annual revisions , and are published on the web (http://www.federalreserve.gov/releases/g17 ). The main data source for the industrial production and capacity utilization rates is the U.S. Census Bureau ' s Census of Manufactures . Data introduced from other Cens us Bureau publications include the Census of Services and the Services Annual Survey

(for publ ishing) and selected Current Industrial Reports . Additional government source data include new annual data on minerals from the U.S. Geological Survey (USGS) and updated deflators from the Bureau of Economic Anal ys is (BEA) . In addition, the annual revisi ons include monthly production estimates that reflect updated seasonal factors and the inclusion of monthly

source data that became available (or were revised) after the closing of the regular four- month reporting window. 3.4 .3 Methodology for New Units To determine the number of new units per ye ar, EPA compared the number of establishments by

three - digit NAICS code in 1998 to the number of establishments by three - digit NAI CS code in 2002, and determined an avera ge annual growth rate for each three - digit NAI CS15

code. The growth rates were applied to each threshold count to determine the number of annual new establishments per industry per threshold. If the growth rate was determined to be negative, EPA assumed that no new establishments would be added; however, establishments were not reduced to reflect negative growth rates. EPA also supplemented these growth rates with agency estimates of expected new sources from various information collection requests (I CR) and regulatory

impact anal ys es (RIA) efforts. 3.5 Methodology for Existing Unspecified Industrial Stationary Combustion Source Category Emissions In order to determine establishment counts and emissions totals for the unspecified industrial stationary

combustion sources, EPA used 2002 Economic Census data showing manufacturing employ

ment by NAICS code and Manufacturing En ergy Consumption Survey (MECS) data published by EIA. Calculating greenhouse gas emissions required determining energy consumption per employee by industry and applying emissi on factors specific to the consumption profile derived from MECS data. The Economic Census data (2002) provide a count of establishments by employ ment category , where employment category is defined by

number of employees (e.g., 1

– 4, 5

– 9,...,500

– 999,... , more than 2,500). The MECS energy consumption data provide energy consumption by industry . Both the employ ment data and the energy consumption data are organized according to the NAICS codes. As part of this anal ys is, EPA calculated industry- specific GHG emission factor s . Th e factor s were calculated by considering actual fuel consumption in 2002, as determined b y EIA. Actual fuel consumed was multiplied by fuel - specific GHG emission factor s to determine GHG emissions by

fuel type b y industry . To simplify the anal ys is, EPA only

included CO 2 emissions and ignored CH 4 and N 2 O in the CO 2 e calculations. CO 2 make s up between 99. 3 and 99. 7 percent of estimated CO 2 e emissions. Emissions for each fuel type were combined to determine total emissions for a s ector. Total emissions per sector w ere divided by total energy consumption per sector to determine a factor to calculate GHG emissions per mmBtu of energy consumption spec ific to the industrial sector. The GHG emission factors were then multiplied by the energy

consumption per employee in order to determine emissions per employee. Multiplying the result by the average number employee s per establishment, EPA determined total GHG emissions per establishment. The total emissions numbers were used to determ ine number of establishments and volume of emissions that would be caught b y each of the permit thresholds under consideration. As discussed previousl y, a separate threshold analysis was conducted for 23 industrial s ectors determined to have significant GHG emissions in the GHG MRR analy sis . In order to quantify the unspecified industrial stationary combustion source emissions, the combustion emissions and establishment counts from 19 of the se sectors were subtracted from the total industrial MECS analysis. For the remaining four industries, HCFC - 22 production, hydrogen production, magnesium production, and nitric acid production, EPA could not readily isolate combustion emissions. For these industries, their establishment counts were subtracted from the16

unspecified industrial source threshold counts based on process emission threshold evaluations , assuming that any facility exceeding a threshold for process -based emissions would exceed the threshold regardless of their combustion CO 2 emissions . Pote ntial to Emit In order to determine potential to emit from the MECS and Economic Census numbers, EPA assumed a capacity utilization factor of 50%. There is a wide variety of generally

smaller manufacturing sources included under this general source categ ory . Based on comments we received on the proposed GHG tailoring rule, w e are using a 50% capacity utilization rate for this final anal ys is to better reflect what can be deemed reasonable operation under normal conditions for facilities in these source categories. Sources may operate their combustion equipment at levels above and below this capacity utilization rate , but we believe the 50% utilization rate reflects a reasonable average rate across the variety of facilities represented in this category . New Units EPA applied industry- specific growth rates to each sector and summed across sectors in order to determine number of new units. Threshold Summary Table 10 CO 2 e Threshold Summary - - Unspecified Industrial Stationary Combustion GHG Threshold (tons p e r year) Number of

Existing Sources Number of New

Facilities Added p er Year CO 2 e Emissions Covered (Tg per y ear) 100 172 , 142 546 372.307 250 112 , 659 319 367.636 1,000 64 , 535 239 357.855 5,000 20 , 785 83 318.759 10,000 12 , 215 61 289.198 25,0 00 5 , 875 18 245.579 50,000 3,272 12 206.881 100,000 958 2 145.10617

3.6 Methodology for Existing Specific Industrial Sectors C onsidering Combustion, Process , and Fugitive Emissions These analyses were based primaril y on the GHG MRR TSDs and the supporting anal ys es, including facility specific emission information . The e stimates considered each greenhouse gas separately. The GHG MRR TSDs included threshold counts and emissions calculations for 1 , 000, 10,000, 25,000 , and 100,000 metric tons per ye ar. Two steps were required for permit threshold consideration. First, emissions were recalculated in order to conduct the analysis in short tons for comparison to the permit thresholds. Second, the emissions were considered against the finer threshold stratification considered in the permit threshold anal ys is. For the permit threshold anal ys is, EPA determined that if the GHG MRR analysis showed all of the establishments exceeded a threshold, after adjustment for short tons, all of the establishments exceede d any lower thresholds. However, where fewer than 100 percent of the establishment s exceeded a threshold, additional analysis was required to compare emissions to the permit thresholds of 100, 250, 5,000, and 50,000 tons per year. EPA used the supporting summaries for the GHG MRR which included facility- specific consumption, process, and fugitive emission reports in order to determine counts and emissions for each of the permit thresholds.
3.6 .1 Adipic Acid Production There are four Adipic Acid Prod uction plants in the U.S. , all of which are estimated to exceed the highest 100,000 metric tons per ye ar emission threshold for CO 2 e on an actual emissions basis. Therefore all plants will also exceed all PTE thresholds on a CO 2 e basis. The CO 2 e emission estimate includes N2 O process emissions that total about 5.9 million metric tons CO 2 e, and 3.4 million metric tons of CO 2 from stationary fuel combustion sources. N 2 O Individual plant production and emission estimates were not made available because of confidential business information ( CBI) claims. However, f rom the Technical Support Document for the A dipic Acid Production Sector: Proposed Rule for Mandatory Reporting of Greenhouse Gases (EPA - HQ - OAR - 2008 - 0508 - 0005), o verall U.S. adipic acid production was estimated to total approximately one million metric tons in 2006. The smallest U.S. plant only produced about two percent of the total. This plant, however, is the onl y plant that is uncontrolled. The three larger plants with the bulk of production have control equipment with N 2 O control effici encies that range from 90 to 99 percent . The uncontrolled N2 O emission factor is 300 kg N 2 O/mton adipic acid. Based on the two percent production share, this uncontrolled plant emitted about 6,000 metric tons of N 2 O (no GWP adjustment). This leaves about 13,100 metric tons of N2 O from the three larger controlled plants. Two plant s representing about 64 percent of production have control efficiencies in the18

range of 90 to 95 percent, and one plant with about 34 percent of pro duction has control close to 99 percent (EPA, 2001). Assuming similar production shares today , the share of national production (which is assumed for this anal ys is to be equivalent to capacity) appears to range from 30 to 35 percent for the three plants. Therefore , emissions and PTE for the controlled plants range from to 4 ,0 00 metric tons to 4 ,7 00 metric tons of N2 O per year. CO 2 The CO 2 emissions from fuel combustion can similarly be apportioned to the four plants. The small est plant , with only two percent of national production , is estimated at CO 2 emissions of 67,500 metric tons, and the next smallest, with 30 percent of national production , is estimated at 101,300 metric tons . Potential to Emit The PTE for each facility was assumed to be equivalent to the emissions based on the apportionment described above. New Units EPA assumed that no new plants would be constructed for this sector. Threshold Summary Table 11

CO 2 Threshold Summary - - Adipic Acid Production GHG T hreshold (tons per y ear) Number of

Existing Sources Number of New

Facilities Added p er Year CO 2 Emissions Covered (Tg per y ear) 100 4 0 3.376 250 4 0 3.376 1,000 4 0 3.376 5,000 4 0 3.376 10,000 4 0 3.376 25,000 4 0 3.376 50,000 4 0 3.376 100,00 0 3 0 3.3 0919 Table 12 N 2 O Threshold Summary - - Adipic Acid Production GHG Threshold (tons per y ear) Number of

Existing Sources Number of New

Facilities Added p er Year N 2 O Emissions Covered (Tg per y ear) 100 4 0 0.019 250 4 0 0.019 1,000 4 0 0.019 5,000 1 0 0.006 10,000 0 0 0 25,000 0 0 0 50,000 0 0 0 100,000 0 0 0 Table 13 CO 2 e Threshold Summary - - Adipic Acid Production GHG Threshold (tons per y ear) Number of

Existing Sources Number of New

Facilities Added p er Year CO 2 e Emissions Covere d (Tg p er year) 100 4 0 9.298 250 4 0 9.298 1,000 4 0 9.298 5,000 4 0 9.298 10,000 4 0 9.298 25,000 4 0 9.298 50,000 4 0 9.298 100,000 4 0 9.298 3. 6.2 Aluminum Production The primary

aluminum production process results in emissions of CO 2 and PFCs. The reduction of the alumina occurs through electrol ys is in a molten bath of natural or s ynthetic cryolite (Na3 AlF 6 ). The reduction cells contain a carbon lining that serves as the cathode . Carbon is also contained in the anode, which can be a c arbon mass of paste, coke briquettes, or20

prebaked carbon blocks from petroleum coke . During reduction, most of the carbon in the anode is oxidized and released to the atmosphere as CO 2 . Potential to Emit CO 2 The Technical Support Document for Process Emissions from Primary Production of Aluminum: Proposed R ule for Mandatory Reporting of Greenhouse Gases (EPA - HQ - OAR2008 - 0508 - 0006) apportioned CO 2 emission estimates from the U.S. GHG inventory to the 13 operating smelters based on each smelters share o f total capacity. Operating smelter emissions were all above 100,000 tons of CO 2 , so no PTE estimate was required. Capacity information for the two idle smelters shows that these smelters are also capable of emitting over 100,000 tons of CO 2 per year. P FCs The reduction cells also emit two PFCs : perfluoromethane (CF 4 ) and perfluoroethane (C 2 F 6 ). The GWPs of the two PFCs are 6,500 and 9,200 respectivel y. During the smelting process, when the alumina ore content of the electroly tic bath falls below critical levels required for electrolysis, rapid voltage increases occur, which are termed " anode effects. " Anode effects cause carbon from the anode and fluorine from the dissociated molten cryolite bath to combine, and produce fugitive emissions of CF 4 and C 2 F 6 . Anode effects released approximately 2.5 million metric tons of CF 4 and C 2 F 6 in 2006 as documented in the GHG MRR TSD . CF 4 made up at least 85 percent of the combined emissions in 2006 (Inventory

of U.S. GHG Emissions and Sinks : 1990

– 2007). These emissions on a CO 2 e basis are equivalent to about 410 short tons of combined emissions as PFC. The proposed GHG MRR TSD estimated CO 2 e emissions from primary aluminum smelters at full capacity. The largest smelter has 11 percent of U.S. operating capacity . Therefore the largest smelter has a PTE of not more than 45 tons of PFC, and no facilities have a PTE greater than 100 tons. New Units No new primary

aluminum facilities are expected to be built. The growth rate in primary metals from the E conomi c Census data is only about 0.4 percent . Threshold Summary Threshold summaries are displayed below for CO 2 and CO 2 e. All faciliti es have a PFC PTE less than 100 tons per year on a PFC basis.21 Table 14 CO 2 Threshold Summary - - Primary Aluminum GHG Threshold (tons per y ear) Number of

Existing Sources Number of New

Facilities Added p er Year GHG Emissions Covered (Tg per y ear) 100 15 0 3.800 250 15 0 3.800 1,000 15 0 3.800 5,000 15 0 3.800 10,000 15 0 3.800 25,000 15 0 3.800 50,000 15 0 3 .800 100,000 15 0 3.800 Table 1 5 CO 2 e Threshold Summary - - Primary Aluminum GHG Threshold (tons per y ear) Number of

Existing Sources Number of New

Facilities Added p er Year GHG Emissions Covered (Tg per y ear) 100 15 0 3.951 250 15 0 3.951 1,000 15 0 3.951 5,000 15 0 3.951 10,000 15 0 3.951 25,000 15 0 3.951 50,000 15 0 3.951 100,000 15 0 3.951 3. 6.3 Ammonia Production EPA review ed the proposed Supporting Data f or Threshold Analysis Subpart E

– W, Greenhouse Gas Mandatory Reporting Rulemaking, March 10, 2009 (EPA - HQ - OAR- 2008 - 0508 - 0046.7) to determine actual emissions and calculate the potential to emit for 24 ammonia plants in operation . The anal ys is spreadsheet details CO 2 actual emission calculations for each22

plant based on ammonia production and urea production, and CO 2 , CH 4 , and N 2 O emission calculations for stationary fuel combustion based on 2006 data. For purposes of permit threshold anal ys is, the CH 4 and N 2 O emissions from combustion were not significant. Potential to Emit Cap acity information in the spreadsheet is based on the engineering design capacity adjusted for 340 days per year of effective production capability , using information provided by the United States Geological Survey (USGS ) . The PTE estimates were made by multiplying the actual emission estimates by the ratio of annual ammonia capacity to annual ammonia production adjusted to 365 days a year of operation instead of 340. EPA assumed that ratio also held for stationary

combustion units at the plant. New Units EPA assumed that no new plants would be constructed for this sector. Threshold Summary Table 16

CO 2 e Threshold Summary - - Ammonia Production GHG Threshold (tons per y ear) Number of

Existing Sources Number of New

Facilities Added p er Year CO 2 e Emi ssions Covered (Tg per y ear) 100 24 0 14.543 250 24 0 14.543 1,000 24 0 14.543 5,000 24 0 14.543 10,000 24 0 14.543 25,000 24 0 14.543 50,000 24 0 14.543 100,000 22 0 14. 54 0 3. 6.4 Cement Production Process - related CO 2 emissions from cement pro duction are the second largest source of industrial CO 2 emissions in the United States. Cement production is done in two stages. The first stage is clinker production . In clinker production, raw materials (primarily limestone) are heated to induce calcination and produce lime. Lime reacts with silica - containing materials and23

iron ore and aluminum to form clinker. During the process, CO 2 is generated as a by product and released to the atmosphere. Also during clinker production, some of the clinker raw materials form partiall y or full y calcinated cement kiln dust instead of forming clinker, resulting in additional process - related CO 2 emissions. Inthe second stage of the production process, the clinker is ground and mixed with gy psum and other materials to make cement. Potential to Emit The Technical Support Document for Process Emissions from Cement: Proposed Rule for Mandatory Reporting of Greenhouse Gases (EPA - HQ - OAR- 2008 - 0508 - 0008) shows 107 cement facilities in the U.S., 106 of which exceed all p ermit thresholds for CO 2 ( according to the TSD, the one facility

that does not exceed the 100,000 tons per year threshold accounted for over 90,000 metric tons of CO 2 e and approximately one - tenth of one percent of the cement industry emissions in 2006) . N ew Units Growth for the industrial sector was estimated at 0.4 percent , and as such, no additional facilities were included in this analysis. Threshold Summary Table 17

CO 2 e Threshold Summary - - Cement Production GHG Threshold (tons per y ear) Number of

Existing Sources Number of New

Facilities Added p er Year CO 2 e Emissions Covered (Tg per y ear) 100 107 0 8 6.83 250 107 0 8 6.83 1,000 107 0 8 6.83 5,000 107 0 8 6.83 10,000 107 0 8 6.83 25,000 107 0 8 6.83 50,000 107 0 8 6.83 100,000 106 0 86.7424

3 . 6.5 Electronic Production The Technical Support Document for Process Emissions f rom Electronics Manufacture (S emiconductors, MEMs, Liquid Crystal Displays, and Photovoltaics) (EPA - HQ - OAR- 2008 - 0508 - 0009) examined emissions of high GWP gases for semicond uctor and related industry plants. Emissions from stationary fuel combustion were not included in the source category anal ys is, but were instead captured by the unspecified industrial stationary combustion analysis. EPA has followe d this approach here as well. Approximately

one million metric tons of SF 6 as CO 2 e were emitted from the semi conductor industry

in 2006 (Inventory

of U.S. Greenhouse Gas Emissions and Sinks : 1990

– 2007). This is equivalent to 46 short tons of SF 6 . The semiconductor industry uses multiple long - lived fluorinated gases in plasma etching and plasma enhanced chemical vapor deposition (PECVD) processes to produce semiconductor products. These include PFCs, which are also used as heat transfer fluids. Approximately 3.5 million m etric tons of PFCs as CO 2 e were emitted from the semi conductor industry in 2006 (Inventory

of U.S. Greenhouse Gas Emissions and Sinks : 1990

– 2007). Table 18 Electronic Production PFC Emiss i ons Semiconductor PFC 2006 CO 2 e Emissions ( million mtons) PFC GWP 2006 PFC Emissions (tons ) CF 4 1.2 6,500 204 C 2 F 6 2.2 9,200 264 C 4 F 8 0.1 8,700 13 Total 3.5 -- 481 Potential to Emit The Federal Reserve capacity utilization factor for the electronics industry in 2006 was 79.8 percent . Based on this capacity utilization factor the PTE of all of the semiconductor plants combined is estimated at 56 tons of SF 6 and 600 tons of PFC. EPA identified 216 facilities in the semiconductor - electronics sector. Of these, the largest facility

emitted six percent of total semiconductor emissions on a CO 2 e basis (includes non - PFCs), which is a maximum of 30 tons of PFC. On a PTE basis, the largest facility would emit 36 tons, based on an assumption that the industry capacity is distributed similarly

to emissions. Therefo re no facility exceeds 100 tons per year on an actual or PTE basis for PFC .25

New Units Growth for the industrial sector was estimated at - 1.8 percent , and as such, no additional facilities were included in this analysis. Threshold Summary Electronics industry

emissions from plant processes only exceed emission thresholds on a CO 2 e basis. Facility

stationary

fuel combustion emissions are not included in the threshold comparisons for the industry . Table 19

CO 2 e Threshold Summary - - Electronics Production GHG Threshold (tons per y ear) Number of

Existing Sources Number of New

Facilities Added p er Year CO 2 e Emissions Covered (Tg per y ear) 100 199 0 5.948 250 19 1 0 5.94 7 1,000 159 0 5.934 5,000 109 0 5.819 10,000 88 0 5.701 25,000 65 0 5.399 50 ,000 54 0 5.100 100,000 22 0 3.417 3. 6.6 Ethanol Production In the proposed GHG MRR, EPA determined that the sources of GHG emissions at ethanol production facilities that must be reported under the proposed rule are stationary fuel combustion, onsite landfills, and onsite wastewater treatment. For the GHG MRR supporting anal ys is, data were unavailable to estimate facility emissions from these combined sources. Instead , data on stationary fuel combustion requirements for different plant capacities were used to estimate the minimum number of facilities that would meet each of the examined reporting rule facility- level thresholds. CO 2 emissions from combustion constitute the majority of the GHG emissions from ethanol production and therefore provide an adequate measure for determining threshold counts.26 Table 20 Ethanol Fuel Combustion CO 2 e Emissions by Plant Size (f rom the Proposed GHG MRR TSD Spreadsheet) Ethanol Produced (wet milling process) ( million gallons) Coal Combustion Emissions ( mtons CO 2 e/year) Natural Gas Combustion Emissions ( mtons CO 2 e/yea r) 290 1,519,585 853,536 245 1,283,787 721,091 200 1,047,990 588,646 200 1,047,990 588,646 100 523,995 294,323 85 445,396 250,174 40 209,598 117,729 35 183,398 103,013 20 104,799 58,865 2 .6 13,624 7,652 Table 2 1 Proposed Reporting Rule Threshold Analysis Results Threshold CO 2 e (tons per y ear) Number of Existing Sources -- Actual Basis Percent of Existing National Sources* 1,000 101 72 % 10,000 93 66 % 25,000 86 61 % 100,000 43 31 %

* National ethanol production source population was estimated at 140 plants nationwide. Potential to Emit The permit threshold PTE anal ys is relied on this same approach and data. Therefore CH 4 emissions from onsite landfills and wastewater treatment plant digesters were not included in the PTE analysis, and we did not estimate emission coverage at each threshold. Also, the anal ys is for the proposed GHG MRR did not evaluate thresholds of 100, 250, 5 , 000, and 50,000 tons per ye ar. EPA assumed that al l existing plants would exceed the 100 and 250 ton per year threshold s27

based on fuel combustion associated with the wet milling process . For the 5,000 and 50,000 thresholds , EPA included the number of sources exceeding the next highest threshold. For example, the count of sources exceeding the 5,000 tons p er year level onl y includes the sources exceeding the 1 0 ,000 ton threshold in the Technical Support Document for Ethanol Facilities: Proposed Rule for Mandatory Reporting of Greenhouse Gases (EPA - HQ - OAR- 2008 - 0508 - 0010) . New Units EPA estimates that ten new ethanol production facilities will be built per year. Threshold Summary Table 2 2 CO 2 e Threshold Summary - - Ethanol GHG Threshold (tons per y ear) Number of

Existing Sources Number of New Sou rces Added p er Year 100 140 10 250 140 10 1,000 101 7 5,000 101 7 10,000 93 7 25,000 86 6 50,000 86 6 100,000 43 3 3. 6.7 Ferroalloy Production In evaluating ferroalloy

production in the U . S . , EPA considered actual production at six facilities , as published in the U . S . Inventory of Greenhouse Gas Emissions and Sinks : 1990

– 2007 for 2006, and the capacity to produce at three facilities for which production information was not published due to competitive concerns. Potential to Emit EPA ' s PT E calculations consider the Federal Reserve ' s 2006 monthl y industrial capacity utilization estimates for the primary metals industry

classification which shows utilization at 85.928

percent for 2006. The PTE calculations do not affect the threshold anal ys is , because all facilities emit over 100,000 metric tons of CO 2 e per year. New Units Applying the growth factor for the industrial sector, 0.4 percent , results in no additional facilities for the anal ys is. Threshold Summary Table 2 3

CO 2 Threshold Summ ary - - Ferroalloy Production GHG Threshold (t ons p er year) Number of

Existing Sources Number of New

Facilities Added p er Year CO 2 Emissions Covered (Tg per y ear) 100 9 0 1.717 250 9 0 1.717 1,000 9 0 1.717 5,000 9 0 1.717 10,000 9 0 1.717 25,000 9 0 1.717 50,000 9 0 1.717 100,000 9 0 1.717 Table 2 4 CH 4 Threshold Summary - - Ferroalloy Production GHG Threshold (t ons p er year) Number of

Existing Sources Number of New

Facilities Added p er Year CH 4 Emissions Covered (Tg per y ear) 100 3 0 0.00 03 250 0 0 029 Table 2 5 CO 2 e Threshold Summary - - Ferroalloy Production GHG Threshold (t ons p er year) Number of

Existing Sources Number of New

Facilities Added p er Year CO 2 e Emissions Covered (Tg per y ear) 100 9 0 1.726 250 9 0 1.726 1,000 9 0 1.7 26 5,000 9 0 1.726 10,000 9 0 1.726 25,000 9 0 1.726 50,000 9 0 1.726 100,000 9 0 1.726 3.6.8 Food Processing Food processing includes meat, poultry and fruit and vegetable processing. Emission s derive from combustion and fugitive methane relate d to wastewater treatment. For purposes of this permit threshold analysis, EPA did not consider the fugitive methane from wastewater treatment because these are the onl y greenhouse gas emissions from the source category other than combustion, and food pro cessing is not a listed PSD source category . Consequently , emissions from this subsector considered in this analysis were limited to combustion emissions and were calculated using the MECS approach. Potential to Emit EPA used the Federal Reserve ' s 200 4 capacity utilization factor of 79.3 percent for the food industry

to calculate PTE emissions. New Units In addition, new establishments were calculated assuming a continuation of the growth rate of 1.2 percent , as calculated using the methodology des cribed earlier in this document.30

Threshold Summary Table 2 6

CO 2 Threshold Summary - - Food Processing GHG Threshold (t ons per y ear) Number of

Existing Sources Number of New

Facilities Added p er Year CO 2 e Emissions Covered (Tg p er year) 100 3946 47 16.848 250 2281 27 16.709 1,000 1 499 18 16. 379 5,000 1030 12 15.723 10,000 749 9 14.354 25,000 482 6 12. 257 50,000 10 0 0.596 100,000 0 0 0 3. 6.9 Glass Manufacturing EPA used the Supporting Data f or Threshold Analysis Subpart E

– W, Greenhous e Gas Mandatory Reporting Rulemaking, March 10, 200 9 (EPA - HQ - OAR- 2008 - 0508 - 0046.7), to anal yz e emissions for permit thresholds from glass manufacturing . Annual fuel combustion and glass production are estimated for each plant based on 2004 estimated plant sales and 2002 MECS energy

intensity (energy per sales dollars). The spreadsheet shows CO 2 emission estimates from industrial process es and stationary fuel combustion , as well as CH 4 and N 2 O emission estimates from stationary fuel combustion. Potentia l to Emit Plant capacities are not available in the spreadsheet. To estimate PTE , EPA divided the actual annual emissions by a capacity utilization factor of 0. 50 or 50 percent . New Units EPA used an estimated annual growth rate of 0.4 percent for the nonmetallic mineral product manufacturing sector to determine the number of new units for this analysis.31

Threshold Summary Table 2 7

CO 2 e Threshold Summary - - Glass Manufacturing GHG Threshold (tons per year) Number of

Existing Sources Number of New

Facilities Added p er Year CO 2 e Emissions Covered (Tg per y ear) 100 36 9 1 4.425 250 36 4 1 4.42 5 1,000 222 1 4.341 5,000 20 1 1 4. 302 10,000 17 5 1 4. 162 25,000 104 0 3.277 50,000 21 0 1. 208 100,000 3 0 0. 366 3.6.10 HCFC - 22 Production Chlorodif luoromethane (HCFC - 22) is produced for use in refrigeration and air conditioning systems and as a chemical feedstock for manufacturing s ynthetic poly mers. Because HCFC - 22 depletes stratospheric ozone, its production for non - feedstock uses is scheduled to be phased out by 2020 under the U.S. Clean Air Act. Feedstock production, however, is permitted to continue indefinitely . A high global warming potential ( GWP ) greenhouse gas , trifluoromethane (HFC - 23), is generated as a b y

product during the manufacture of HCFC - 22. Emissions of HFC - 23 in 2006 were estimated to be 13.8 million metric tons on a CO 2 e basis from three HCFC - 22 production plants. Estimates were based on the plants operating at capacity . Annual emissions in terms of both metric tons CO 2 e and tons HFC - 23 are summarized in Table 30 below.32 Table 28 HCFC - 22 Production HFC - 23 Emissions

HCFC - 22 Production 2006 CO 2 e Emissions ( million metric tons) HFC GWP 2006 HFC Emissions ( short tons ) HFC - 23 13.8 11,700 1,300 Source : Reporting Rule TSD P otential to Emit Confidential business information (CBI) claims on production information limited EPA ' s PTE analysis. The T

echnical Support Document for Emissions of HFC
- 23 from Production of HCFC
- 22: Proposed Rule for Mandatory Reporting of Greenhouse Gases (EPA - HQ - OAR2008 - 0508 - 0015) estimated that all three plants emit over 100,000 metric tons CO 2 e on a capacity basis by a factor of 85 or more, or a minimum of 800 short tons of HFC - 23. These estimates did not account for HFC - 23 capture and destructio n at two of the three plants. Therefore , actual emissions at two of the plants will be lower, and can be limited through permitting. We assumed that all three plants exceed the 100 and 250 ton actual and PTE thresholds, and that one plant (uncontrolled) exceeds the 1 , 000 ton PTE threshold. Because the TSD did not include estimates of CO 2 emissions from fuel combustion, and the CBI claims noted above, the PTE anal ys is does not quantify fuel combustion emissions specificall y for the three plants. Station ary fuel combustion emissions from the plants were instead captured under the anal ys is for unspecified industrial stationary combustion. New Units U.S. production between 1990 and 2006 increased by 11 percent while emissions declined b y 62 percent . Th e declines in emissions from control equipment and process changes offset the production increases. Therefore we did not estimate any new facilities o r modifications that would increase facility emissions more than 100 tons per year.33

Threshold Summary Table 29

HFC Threshold Summary - - HCFC - 22 Production GHG Threshold (t ons p er year) Number of

Existing Sources Number of New

Facilities Added p er Year HFC Emissions Covered (Tg p er year) 100 3 0 0.001 250 3 0 0.001 1,000 1 0 0.001 5,000 0 0 0 Tab le 3 0 CO 2 e Threshold Summary - - HCFC - 22 Production GHG Threshold (t ons p er year) Number of

Existing Sources Number of New

Facilities A dded p er Year CO 2 e Emissions Covered (Tg per y ear) 100 3 0 13.848 250 3 0 13.848 1,000 3 0 13.848 5,000 3 0 13.848 10,000 3 0 13.848 25,000 3 0 13.848 50,000 3 0 13.848 100,000 3 0 13.848 3.6.11 Hydrogen Production EPA estimated CO 2 emissions from merchant hydrogen production using the process and combustion ratio of 8.62 tons of CO 2 emissions per ton of hydrogen production. About 95 percent of all hydrogen (not just merchant hydrogen) produced in the U.S. today is made from natural gas via steam methane reforming. In steam methane reforming fuel ed by natural gas combustion, the process and combustion emissi ons go up the same stack from the boiler/reformer unit. Because the emissions are predominately process emissions and because34

the natural gas combustion products are emitted from the same stack, EPA has treated all the emissions as process emissions. Pot ential to Emit EPA developed estimates assuming hydrogen production at capacity level. Therefore, no adjustment to the emissions estimates is needed to account for PTE emissions . New Units Based on the industry

growth factor of - 0.1 percent for chemical manufacturing, EPA assumed that no new plants would be constructed. Threshold Summary Table 3 1

CO 2 Threshold Summary - - Hydrogen Production GHG Threshold (t ons per y ear) Number of

Existing Sources Number of New

Facilities Added p er Year CO 2 e Emi ssions Covered (Tg p er year) 100 75 0 15.227 250 75 0 15.227 1,000 74 0 15. 226 5,000 62 0 15.202 10,000 51 0 15.130 25,000 42 0 15.007 50,000 38 0 14.8 90 100,000 32 0 14. 441 3.6.12 Iron and Steel Production EPA used the Supporting Data f or T hreshold Analysis Subpart E

– W, Greenhouse Gas Mandatory Reporting Rulemaking, March 10, 2009 (EPA - HQ - OAR- 2008 - 0508 - 0046.7) for the propos ed GHG MRR threshold anal ys is to determine process and combustion CO 2 and process CH 4 . The iron and steel production source category includes taconite iron ore processing facilities, integrated iron and steel making facilities, electric arc furnace (EAF) steelmaking facilities that are not located at integrated iron and steel facilities, and coke oven facilities that are not located at integrated iron and steel facilities. Facility processes and facilities covered in the spreadsheet are shown in the table below.35 Table 3 2 Iron and Steel Processes, Facilities, and Capacity Information Iron and Steel Process Number of Facilities Capacity Information Basic oxygen furnace (BOF) 18 Yes Blast Furnace (BF) 17 Yes Sintering 5 Yes Coke ovens 18 Yes Electric arc furnace (EAF) 92 No Taconite furnace 8 Yes Integrated steel plant fuel combustion* 19 No Coke oven gas combustio n* 9 No EAF steel plant fuel combustion 92 No

* Six plants had emissions from coke oven gas combustion was included in integrated steel plant fuel combustion. Potential to Emit The anal ys is covered 130 plants, and in all cases , except for EAF plants , GHG emissions were estimated based on operations at plant capacity . For EAF plants , EPA used the 2007 Federal Reserve industrial capacity utilization percentage of 86.6 percent for primary metal - - iron and steel production, to adjust estimated actual emissions to PTE. The spreadsheet contained emission CO 2 e estimates which included CO 2 , CH 4 , and N 2 O emissions . Process CH 4 emissions were backed out of the CO 2 e totals using the process CH 4 emissions reported in the U . S . GHG Inventory , and apportioning these emissions to the different plants based on their capacity in those processes. N 2 O emissions are primarily related to fuel combustion and were not backed out for separate treatment. New Units No new iron and steel facilities are expected to be built. The growth rate in primary metals from the Economi c Census data is only about 0.4 percent .36

Threshold Summary Table 3 3

CO 2 Threshold Summary - - Iron and Steel Production GHG Threshold (tons per y ear) Number of

Existing Sources Number of New

Facilities Added per y ear CO 2 Emissions

Covered (Tg per y ear) 100 130 0 85.150 250 130 0 85.150 1,000 130 0 85.150 5,000 129 0 85.148 10,000 128 0 85.141 25,000 123 0 85.057 50,000 116 0 84.831 100,000 113 0 84.655 Table 3 4 CH 4 Threshold Summary - - Iron and Steel Production GHG Threshold (tons per y ear) Number of

Existing Sources Number of N ew

Facilities Added p er Year CH 4 Emissions Covered (Tg per y ear) 100 18 0 0.034 250 17 0 0.033 1,000 1 7 0 0.03 3 5,000 3 0 0.011 10,000 0 0 037 Table 3 5 CO 2 e Threshold Summary - - Iron and Steel Production GHG Threshold (tons per y ear) Number of

Existing Sources Number of N ew

Facilities Added p er Year CO 2 e Emissions Covered (Tg per y ear) 100 130 0 85.151 250 130 0 85.151 1,000 130 0 85.151 5,000 1 30 0 85.1 51 10,000 128 0 85.141 25,000 123 0 85.058 50,000 116 0 84.832 100,000 11 4 0 84.656 3.6.13 Lead Production According to the 2006 U . S . Geological Survey (USGS), lead production in the U . S . includes both the primary , direct smelting (one fa cility) and secondary lead production (16 facilities). Process emissions of CO 2 are a b yproduct of the coke consumed during the smelting or reforming process es . EPA calculated total process emissions based on lead production as reported in the USGS. In the Supporting Data for Threshold Analysis Subpart E

– W, Greenhouse Gas Mandatory Reporting Rulemaking (EPA - HQ - OAR- 2008 - 0508 - 0046.7), c ombustion emissions are combined with process emissions to determine total actual emissions. Potential to Emit In order to determine PTE emissions, EPA considered the Federal Reserve ' s 2006 monthly industrial capacity

utilization estimates for primary metals industry classification which shows utilization at 85.9 percent for 20 06, and adjusted to achieve 100 percent uti lization. New Units EPA assumed no new facilities would be added for the industry , given an expected growth rate of 0.4 percent per year for primary metal manufacturing industry .38

Threshold Summary Table 3 6

CO 2 e Threshold Summary - - Lead Production GHG Threshold (tons per y ear) Number of

Existing Sources Number of N ew

Facilities Added p er Year CO 2 e Emissions Covered (Tg per y ear) 100 17 0 0.861 250 17 0 0.861 1,000 17 0 0.861 5,000 17 0 0.861 10,000 16 0 0.855 25,000 13 0 0.799 50,000 12 0 0.761 100,000 1 0 0.089 3.6.14 Lime The Supporting Data f

or Threshold Analysis Subpart E

– W, Greenhouse Gas Mandatory Reporting Rulemaking, March 10, 2009 (EPA - HQ - OAR- 2008 - 0508 - 0046.7) was also used to estimate GHG PTE for lime plants . Potential to Emit T o estimate PTE , EPA divided annual actual CO 2 emissions from the calcining process and fuel combustion emissions of CO 2 , CH4 , and N 2 O by regional capacity factors available in the spreadsheet for each plant. The capacity factors ranged from 43 to 136 percent . New Units EPA assumed no new facilities would be added for the industry .39

Threshold Summary Table 3 7

CO 2 Threshold Summary - - Lim e Production GHG Threshold (tons per y ear) Number of

Existing Sources Number of N ew

Facilities Added p er Year CO 2 Emissions Covered (Tg per y ear) 100 89 0 27.262 250 89 0 27.262 1,000 89 0 27.262 5,000 89 0 27.262 10,000 89 0 27.262 25,000 86 0 27.237 50,000 66 0 26.533 100,000 60 0 26.180 3. 6.15 Magnesium Production and Processing The magnesium metal production (primary and secondary) and casting industry typicall y uses SF 6 as a cover gas to prevent the rapid oxidation and burning of molten magnesium in the presence of air. A dilute gaseous mixture of SF 6 with dry air and/or CO 2 is blown over molten magnesium metal to induce and stabilize the formation of a protective crust . A small portion of the SF 6 reacts with the magnesium to form a thin molecular film of mostly magnesium oxide and magnesium fluoride. The amount of SF 6 reacting in magnes ium production and processing is being studied but presently assumed to be negligible, and therefore all SF 6 used is assumed to be emitted into the atmosphere. For the proposed GHG MRR Technical Support Document for Process Emissions from Magnesium Produ ction and Processing : Proposed Rule for Mandatory Reporting of Greenhouse Gases , EPA reported that national annual SF 6 emissions from magnesium production and processing totaled approximately 3.2 million metric tons CO 2 e in 2006. The facility population total ed 13 facilities that emitted 3.0 million metric tons CO 2 e. The SF 6 emissions (no GWP adjustment) were 148 and 138 short tons respectivel y. Ten magnesium die casting facilities accounted for 29 percent (44 tons), and primary and secondary production accounted for 64 percent (96 tons) of the total emissions . Other small casting activities account ed for the remaining 7 percent (ten tons).40

Potential to Emit EPA used the anal ys is in the TSD for th e proposed GHG MRR, where EPA had evaluated threshol ds of 1,000, 10,000, 25,000, and 100,000 metric tons per year. Facility- level information is not made publicly available because of confidential business information (CBI) claims . From that earlier anal ys is EPA estimated that the same number of facilitie s exceeded the 100, 250, and 1,000 tons CO 2 e per year PTE threshold as determined in the GHG MRR TSD for the 1,000 metric tons per year threshold. In a similar fashion, EPA used the GHG MRR TSD facility counts at 10,000 metric tons CO 2 e per year to estimate facilities at the 5,000 tons per year PTE threshold, and 100,000 metric tons per ye ar for the 50,000 tons CO 2 e per year PTE threshold. The permit threshold anal ys is did not include CO 2 emissions from fuel combustion . That information was not available in the TSD for the proposed GHG MRR. On an SF 6 mass basis , the average emissions per facility are onl y 11 tons of SF 6 , well below 100 tons per ye ar. Therefore we assumed that none of the facilities have a potential to emit more than 100 tons per year of SF 6 . New Units EPA assumed no new units would be added for the sector. Threshold Summary T able 38

CO 2 e Threshold Summary -- Magnesium Production GHG Threshold (tons per y ear) Number of

Existing Sources Number of N ew

Facilities Added p er Year CO 2 e Emissions Covered (Tg per y ear) 100 13 0 2.955 250 13 0 2.955 1,000 13 0 2.955 5,000 11 0 2.94 10,000 11 0 2.94 25,000 11 0 2.94 50,000 9 0 2.781 100,000 9 0 2.78141

3. 6.16 Nitric Acid Production EPA used the 2006 nameplate capacity (metric tons of HNO 3 100 percent acid basis) for 45 nitric acid plants and 2006 acid production from the GHG MRR TSD supporting spreadsheet (EPA - HQ - OAR- 2008 - 0508 - 0046.7) to determine N 2 O emissions . Potential to Emit The GHG PTE was calculated by multiplying ac tual N 2 O emissions as CO 2 e by the ratio of nameplate capacity

to 2006 production. The permit threshold analysis, based on the GHG MRR TSD, does not include GHG emissions from co - located stationary combustion units . Also the permit threshold analysis does not account for o verlap between facilities in the Nitric Acid and Ammonia categories , which have both ammonia and nitric acid production processes. New Units EPA assumed no new units would be constructed for this sector. Threshold Summary Table 39

N 2 O Threshold Summary - - Nitric Aci d Production GHG Threshold (tons per y ear) Number of

Existing Sources Number of N ew

Facilities Added p er Year N 2 O Emissions Covered (Tg per y ear) 100 43 0 0.055 250 42 0 0.055 1,000 27 0 0.049 5,000 4 0 0.016 10,0 00 0 0 0 25,000 0 0 0 50,000 0 0 0 100,000 0 0 042 Table 4 0 CO 2 e Threshold Summary - - Nitric Acid Production GHG Threshold (tons per y ear) Number of

Existing Sources Number of N ew

Facilities Added p er Year CO 2 e Emissions Covered (Tg per y ear) 100 45 0 17.732 250 45 0 17.732 1,000 45 0 17.732 5,000 45 0 17.732 10,000 45 0 17.732 25,000 44 0 17.724 50,000 43 0 17.706 100,000 42 0 17.667 3. 6.17 Petrochemical Production EPA determined that the portion of the petrochemical production sector most relevant for permit threshold anal ys is includes the manufacture and production of acrylonitrile, carbon black, ethylene, ethylene dichloride, ethyl ene oxide, and methanol , because the IPCC considers production of greenhouse gases from these processes significant compared to other petrochemical processes. Emissions from the manufacturing processes vary significantl y and process emissions take many forms . Process emissions include direct oxidation of CO 2 , off - gassing of CH 4 and CO 2 , and the direct release of CO 2 and CH 4 from equipment leaks . P rocess emissions are the primary consideration for acrylonitrile, ethylene, and ethylene oxide processes . In addition, some processes require combustion of supplemental fuel. Both process and combustion emiss ions are significant for carbon black and methanol processes. Potential to Emit EPA ' s analysis assum ed petrochemical production at the capacity level. Therefore, no adjustment to the emissions estimates is needed to account for PTE . New Units Base d on an industry

growth factor of - 0.1 percent for chemical manufacturing, EPA assumed that no new plants would be constructed.43

Threshold Summary Table 4 1

CO 2 Threshold Summary - - Petrochemical Production GHG Threshold (tons per y ear) Number of

Existi ng Sources Number of N ew

Facilities Added p er Year CO 2 Emissions Covered (Tg per y ear) 100 98 0 52.081 250 98 0 52.081 1,000 98 0 52.081 5,000 97 0 52.080 10,000 96 0 52.073 25,000 96 0 52.073 50,000 94 0 52.005 100,000 91 0 51.806 Table 4 2 CH 4 Threshold Summary - - Petrochemical Production GHG Threshold (tons per y ear) Number of

Existing Sources Number of N ew

Facilities Added p er Year C H 4 Emissions Covered (Tg per y ear) 100 55 0 0.130 250 52 0 0.129 1,000 37 0 0.121 5,000 5 0 0.035 10, 000 1 0 0.010 25,000 0 0 0 50,000 0 0 0 100,000 0 0 044 Table 4 3 CO 2 e Threshold Summary - - Petrochemical Production GHG Threshold (tons per y ear) Number of

Existing Sources Number of N ew

Facilities Added p er Year CO 2 e Emissions

Covered (Tg per y ear) 100 98 0 54.826 250 98 0 54.826 1,000 98 0 54.826 5,000 97 0 54.825 10,000 96 0 54.818 25,000 96 0 54.818 50,000 94 0 54.748 100,000 91 0 54.595 3. 6.18 Petroleum Refineries In developing the permit threshold anal ys is for petroleum refineries , EPA quantif ied CH 4 process emissions from wastewater, fugitive, flares, and storage tanks. Process CO 2 emissions derived from flares, hydrogen plant emissions, and sulfur plant emissions. In addition, on - site combustion emissions were calculated considering fuel consumed b y type. Potential to Emit EPA assum ed that petroleum refineries were operating at capacity level. Therefore, no adjustment to the emissions estimates was needed to account for PTE . New Units According to the ICR prepared for th e New Source Performance Standard (NSPS), EPA expects that no new refineries will be built over the next few year s.45

Threshold Summary Table 4 4

CO 2 Threshold Summary - - Petroleum Refineries GHG Threshold (tons per y ear) Number of

Existing Sources Numbe r of N ew

Facilities Added p er Year CO 2 Emissions

Covered (Tg per y ear) 100 150 0 202.947 250 150 0 202.947 1,000 150 0 202.947 5,000 150 0 202.947 10,000 149 0 202.938 25,000 146 0 202.887 50,000 137 0 202.575 100,000 129 0 202.065 Table 4 5 CH 4 Threshold Summary - - Petroleum Refineries GHG Threshold (tons per y ear) Number of

Existing Sources Number of N ew

Facilities Added p er Year C H 4 Emissions

Covered (Tg per y ear) 100 129 0 0.083 250 109 0 0.080 1,000 31 0 0.042 5,000 0 0 046 Table 4 6 CO 2 e Threshold Summary - - Petroleum Refineries GHG Threshold (tons per y ear) Number of

Existing Sources Number of N ew

Facilities Added p er Year CO 2 e Emissions Covered (Tg per y ear) 100 150 0 204.897 250 150 0 204.897 1,000 150 0 204.897 5,000 150 0 204.897 10,000 149 0 204.888 25,000 146 0 204.835 50,000 13 7 0 204. 513 100,000 12 9 0 203.988 3. 6.19 Phosphoric Acid Production Phosphoric acid is produced b y combining sulfuric acid and phosphate rock. CO 2 is emitted when the limestone component of phosphate rock reacts with the sulfuric acid. Potential to Emit When these process emissions are combined with combustion emissions, all 14 plants have emissions that exceed the highest threshold level; consequentl y, no PTE anal ys is was required. New Units Based on an industry

growth factor of - 0.1 percent for chemical manufacturing, EPA assumed that no new plants would be constructed.47

Threshold Summary Table 4 7

CO 2 Threshold Summary - - Phosphoric Acid Production GHG Threshold (tons per y ea r) Number of

Existing Sources Number of N ew

Facilities Added p er Year CO 2 e Emissions Covered (Tg per y ear) 100 14 0 3.838 250 14 0 3.838 1,000 14 0 3.838 5,000 14 0 3.838 10,000 14 0 3.838 25,000 14 0 3.838 50,000 14 0 3.838 100,000 14 0 3.838 3. 6.20 Pulp and Paper Manufacturing Permit threshold analysis for this sector is focused on the energy intensive, fugitive emitting pulp, paper, and paperboard manufacturing subsectors. Process emissions include CO 2 which is emitted in the recovery cyc le at kraft and soda facilities associated with the chemical pulp process. The CO 2 emitted from kraft mill lime kilns originates from two sources : (1) fossil fuels burned in the kiln; and (2) conversion of calcium carbonate (or " lime mud " ) generated in the recovery

process to calcium oxide. The bulk of the emissions considered derive from combustion. Many boilers use biomass fuel, and the burning of spent pulping liquors to produce steam for facility processes is considered biomass combustion for the GH G MRR . The emissions numbers considered for the permit threshold anal ys is are non -biogenic (net of any biogenic emissions). Considering only non -biogenic emissions, 96.5 percent of the facilities and 99.7 percent of the emissions are captured b y all of the thresholds proposed for consideration of the permit threshold rule. Potential to Emit Because 99.7 percent of emissions were captured at even the highest threshold, no additional PTE estimate was calculated in this analysis.48

New Units Based on an industry

growth factor of - 2.5 percent for paper manufacturing, and previous EPA anal ys is for the pulp and paper NSPS I CR, EPA assumed that no new plants would be constructed . Threshold Summary Table 48

CO 2 e Threshold Summary - - Pulp and Paper Manufactu ring GHG Threshold (tons per y ear) Number of

Existing Sources Number of N ew

Facilities Added p er Year CO 2 e Emissions Covered (Tg per y ear) 100 425 0 57.700 250 425 0 57.700 1,000 425 0 57.700 5,000 425 0 57.700 10,000 425 0 57.700 25,000 425 0 57 .700 50,000 422 0 57.688 100,000 410 0 57.527 3.6.21 Silicon Carbide Manufacturing In 2006, one facility

produced silicon carbide in the U . S. Silicon carbide is primarily an industrial abrasive manufactured from silica sand or quartz and petroleum coke. Approximately 35 percent of the carbon from the petroleum coke is retained with the silicon carbide, and the rest is emitted as both CO 2 and CH 4 . In addition, emissions from combusti on account for approximately

ten percent of total emissions. Po tential to Emit Emissions from this plant exceed all permit threshold levels; as a result, EPA did not consider PTE calculations. New Units EPA assumed there would be no new facilities constructed.49

Threshold Summary Table 49

CO 2 Threshold Summary - - Silicon Carbide Manufacturing GHG Threshold (tons per y ear) Number of

Existing Sources Number of N ew

Facilities Added p er Year CO 2 Emissions Covered (Tg per y ear) 100 1 0 0.101 250 1 0 0.101 1,000 1 0 0.101 5,000 1 0 0.101 10,000 1 0 0.101 25,0 00 1 0 0.101 50,000 1 0 0.101 100,000 1 0 0.101 Table 5 0 CH 4 Threshold Summary - - Silicon Carbide Manufacturing GHG Threshold (tons per y ear) Number of

Existing Sources Number of N ew

Facilities Added p er Year C H 4 Emissions

Covered (Tg per y ear) 1 00 1 0 0.0004 250 1 0 0.0004 1,000 0 0 050 Table 5 1 CO 2 e Threshold Summary - - Silicon Carbide Manufacturing GHG Threshold (tons per y ear) Number of

Existing Sources Number of N ew

Facilities Added p er Year CO 2 e Emissions

Covered (Tg per y ear) 100 1 0 0.109 250 1 0 0.109 1,000 1 0 0.109 5,000 1 0 0.109 10,000 1 0 0.109 25,000 1 0 0.109 50,000 1 0 0.109 100,000 1 0 0.109 3. 6.22 Soda Ash Production Soda Ash production emissions were nearl y evenly split between process and combustion emission s. Process emissions result from calcining trona ore to produce soda ash. Potential to Emit P TE emissions were calculated based on the capacities of the production units. New Units In 2006, there was a glut of soda ash in the domestic market; EPA assumed no new units would be constructed.51

Threshold Summary Table 5 2

CO 2 e Threshold Summary - - Soda Ash Production GHG Threshold (tons per y ear) Number of

Existing Sources Number of N ew

Facilities Added p er Year CO 2 e Emissions Covered (Tg per y ear) 100 5 0 3.121 250 5 0 3.121 1,000 5 0 3.121 5,000 5 0 3.121 10,000 5 0 3.121 25,000 5 0 3.121 50,000 5 0 3.121 100,000 5 0 3.121 3. 6.23 Titanium Dioxide Production EPA used USGS as the source for production capacity for the eight facilities that produced titanium dioxide in 2006 . Potential to Emit Emissions were assumed to represent PTE operating levels . New Units EPA assumed that no new plants would be constructed.52

Threshold Summary Table 5 3

CO 2 e Threshold Summary - - Titanium Dioxid e Production GHG Threshold (tons per y ear) Number of

Existing Sources Number of N ew

Facilities Added p er Year CO 2 e Emissions Covered (Tg per y ear) 100 8 0 3.686 250 8 0 3.686 1,000 8 0 3.686 5,000 8 0 3.686 10,000 8 0 3.686 25,000 8 0 3.686 50,0 00 8 0 3.686 100,000 7 0 3.628 3. 6.24 Zinc Production The Zinc p roduction emissions and facility count estimates include process and combustion emissions associated with primary smelting and secondary

recycling facilities. Potential to Emit For PTE estimates , EPA considered the Federal Reserve ' s 2006 monthl y industrial capacity utilization estimates for primary metals industry

classification which shows utilization at 85.9 percent for 2006, and ad justed to achieve 100 percent utilization. New Units EPA assumed that no new units would be constructed.53

Threshold Summary Table 5 4

CO 2 e Threshold Summary - - Zinc Production GHG Threshold (tons per y ear) Number of

Existing Sources Number of N ew

Facilities Added p er Year CO 2 e Emissions Covered (Tg per y ear) 100 9 0 0.852 250 9 0 0.852 1,000 9 0 0.852 5,000 9 0 0.852 10,000 8 0 0.843 25,000 5 0 0.802 50,000 5 0 0.802 100,000 5 0 0. 802 3. 7 Energy Sector 3. 7 .1 Oil and Gas Systems In consideration of the permit thresholds, EPA consi dered the Fugitive Emissions Reporting from the Petroleum and Natural Gas Industry: Backg round Technical Support Document (EPA - HQ - OAR- 2008 - 0508 - 0023) . This document details combustion emissions and fugitive emissions from offshore petroleum and natural g as facilities, onshore natural gas processors, onshore natural gas transmission, underground natural gas storage, and liquid natural gas storage. EPA determined that oil and gas exploration, development, transmission, and distribution are not listed PSD s ource categories, and therefore fugitive emissions from these activities were not considered for PSD applicability as it relates to major source thresholds . EPA ' s analysis focused on combustion emissions from these sources. Potential to Emit EPA used a ca

pacity utilization figure of 50 percent to determine PTE emission estimates and counts. This rate is meant to reasonably represent an average utilization rate across a variety of combustion equipment ty pes used in the oil and gas industry subsectors des cribed above. New Units EPA determined new units based on a growth factor of 1.0 percent for the sector.54

Threshold Summary Table 5 5

CO 2 e Threshold Summary - - Oil and Gas Systems GHG Threshold (tons per y ear) Number of

Existing Sources Number of N ew

Facilities Added p er Year CO 2 e Emissions Covered (Tg per y ear) 100 4762 48 88.264 250 4762 48 88.264 1,000 4762 48 88.264 5,000 3722 37 86.192 10,000 3095 31 83.619 25,000 2496 25 79.386 50,000 1045 1 0 56.949 100,000 387 4 32.750 3.7.2 Under ground Coal Mining GHG emissions from underground coal mining include CH 4 fugitive emissions released from the coal seam and surrounding rock during mining and post - mining activities (coal bed CH 4 ), and fuel combustion emissions of CO 2 , CH4 , and N 2 O. Fu gitive CH 4 , emissions are captured and vented b y ventilation systems and degassing s ys tems. C aptured and vented CH 4 emissions from active mines were considered in the PTE anal ys is. Because underground coal mining is not one of the 28 PSD source categorie s for which fugitive emissions were required to be included in the emissions determination , f ugitive emissions from post mining operations, surface mines, and inactive mines were not included in the permit thresholds analysis . The Technical Support Docu ment for Underground Coal Mines: Proposed Rule for Mandatory Reporting of Greenhouse Gases (EPA - HQ - OAR - 2008 - 0508 - 0032) identified 612 active underground coal mining facilities but analysis of CH4 emissions was limited to 128 " gass y " mines where CH 4 monito ring was already in place ( due to existing CH 4 emissions above Mine Safety and Health Adminis tration (MSHA) threshold levels ) . The U.S . GHG Inventory (EPA, 2008) reports that 233 underground coal mines ( including 133 gass y mines ) ventilated CH 4 in 2007. Fuel combu stion emission estimates for the GHG MRR TSD from all underground coal mines , based on U.S. Census energy use data, were found to comprise between one and three percent of total CO 2 e emissions, with coal bed CH 4 accounting for the bulk of GHG emi ssions.55

In addition to the emissions data on the 128 gass y mines contained in the GHG MRR TSD, EPA considered combustion emissions from 289 bituminous underground coal mines , using U.S. Census data from 2002 . Potential to Emit CH 4 CH 4 emission estimates that were developed for the GHG MRR TSD were used for both actual emissions and PTE emissions permit threshold analysis . EPA assumed that venting and degassing were continuous throughout the ye ar ; therefore , actual emission estimates equal PTE emissio n estimates . The estimates considered 128 gass y mines, which were assumed to be the largest emitters of vented CH 4 . The smallest mine of this group had annual CH 4 emissions of 26 tons ; therefore EPA assumed that the annual CH 4 emissions from the 105 vent ed mines that were not included in the TSD anal ys is were less than 26 tons . CO 2 CO 2 emissions were estimated in the same manner as for other Unspecified Industrial Stationary

Combustion categories, based on the ICF anal ys is (ICF, 2007) using the MECS approach . Emissions were estimated based on Census information including fuel consumption per emplo yee and the distribution of establishments by the number of employees. PTE was estimated by

using a capacity

utilization factor of 86.3 percent as publish ed by the Federal Reserve . New Units The number of underground bituminous coal mines in the U.S. is on the decline. EIA data show that only

Colorado had an increase in the number of underground coal mines between 2006 and 2007 (EIA, 2008). The EIA data show that overall the number of underground coal mines decreased from 2006 to 2007 by eight percent ; consequently , EPA assumed no new underground mines would be built . http://www.eia .doe.gov/cneaf/coal/page/acr/table1.html .56

Threshold Summaries Threshold summary

tables are shown below for CH 4 (vented fugitive emissions), CO 2 (fuel combustion), and CO 2 e (vented fugitive CH 4 and combustion CO 2 ). Table 5 6 CO 2 Threshold Summary - - Un derground Coal Mining GHG Threshold (tons per y ear) Number of

Existing Sources Number of N ew

Facilities Added p er Year CO 2 e Emissions Covered (Tg per y ear) 100 238 0 0.783 250 202 0 0.778 1,000 63 0 0.692 5,000 30 0 0.577 10,000 30 0 0.577 25,000 0 0 0 Table 5 7 CH 4 Threshold Summary - - Underground Coal Mining GHG Threshold (tons per y ear) Number of

Existing Sources Number of N ew

Facilities Added p er Year CO 2 e Emissions Covered (Tg per y ear) 100 110 0 1.586 250 110 0 1.586 1,000 110 0 1.5 86 5,000 53 0 1.420 10,000 38 0 1.361 25,000 24 0 1.147 50,000 13 0 0.784 100,000 1 0 0.10557 Table 58 CO 2 e Threshold Summary - - Underground Coal Mining GHG Threshold (tons per y ear) Number of

Existing Sources Number of N ew

Facilities Added p er Ye ar CO 2 e Emissions Covered (Tg per y ear) 100 238 0 39.520 250 238 0 39.520 1,000 126 0 33.945 5,000 124 0 33.943 10,000 123 0 33.936 25,000 103 0 33.606 50,000 78 0 32.800 100,000 55 0 31.241 3.8 Waste Sector 3.8.1 Landfills The landfill PT E anal ys is includes both municipal solid waste (MSW) landfills and onsite industrial landfills associated with pulp and paper and food processing. The anal ys is used a modification of the landfill emission modeling approach described in the Technical Suppo rt Document for the Landfill Sector: Proposed Rule for Mandatory Reporting of Greenhouse Gases (EPA - HQ - OAR- 2008 - 0508 - 0034) , which was used for the proposed GHG MRR threshold anal ys is . Like the GHG MRR analysis , th e permit threshold PTE analysis did not include onsite industrial landfills for ethanol processing facilities or industrial land application systems. GHG Emissions D ecomposition of waste in landfills generates CH 4 and CO 2 . The amount of CH 4 generated from a given landfill is a function of s everal factors : the total amount of waste disposed in the landfill; t

he characteristics of the waste; and the climatic conditions . The amount of CH 4 emitted is the amount of CH 4 generated minus the amount of CH4 oxidized by aerobic microorganisms in the landfill cover material. Also subtracted from the total is the amount of CH 4 that is destroyed b y combustion of the vented gas. The CO 2 produced by decaying waste is not considered an anthropogenic emission, and is not counted in GHG emission totals. Likewise, CO 2 resulting from the combustion of landfill CH4 is not accounted for as an anthropogenic emission under international accounting guidance. According to the 2008 U.S. Inventory , MSW landfills emitted 111.2 million metric tons CH 4 ( CO 2 e basis) in 2006 . The majority of the CH 4 emissions from on - site industrial landfills58

occur s at pulp and paper facilities and food processing facilities . In2006, these landfills emitted 14.6 million metric tons CO 2 e P otential to E mit The methodology

used for the proposed GHG MRR threshold analysis was also used to estimate CH 4 generation rates and emissions in 2006 for the PTE anal ys is. A landfill - specific model developed b y EPA to support its proposed GHG MRR was used to estimate CH 4 generation and potential generation from municipal landfills. The generation estimate was adjusted with assumptions on oxidation in landfill cover, and destruction b y combustion for energy recovery or flaring. The industrial landfill generation and emission estimates are based o n the U.S. GHG Inventory . Industrial landfill s were assumed not to have energy recovery or flaring, so there was no difference between generation and emissions. New Units EPA did not estimate the number of new facilities added each ye ar with CH 4 emissi ons above the different thresholds due to the time delay between landfill construction and emission generation. Threshold Summary Table 59 CO 2 e Threshold Summary -- Landfills GHG Threshold (tons per y ear) Number of

Existing Sources CO 2 e Emissions Co vered (Tg per y ear) 100 4 , 131 125.621 250 4 , 117 125.619 1,000 4 , 053 125.592 5,000 3 , 564 124.552 10,000 3 , 265 122.788 25,000 2 , 701 115.937 50,000 1 , 684 92.340 100,000 967 72.72259 Table 60 C H 4 Threshold Summary -- Landfills GHG Threshold (tons p er year) Number of

Existing Sources C H 4 Emissions Covered (Tg per y ear) 100 3,885 5.973 250 3,562 5.931 1,000 2,692 5.539 5,000 981 3.274 10,000 427 2.326 25,000 114 1.087 50,000 21 0.401 100,000 2 0.106 3.8.2 Municipal Solid Waste Combustors The threshold anal ys is for the proposed GHG MRR included municipal solid waste combustors (MWC) in the general stationary fuel combustion category . The anal ys is used the e GRID database, which is discussed in the PTE methodology description for electric generating units. Data and Methodology EPA used the latest version of the e GRID database (2006) to estimate the PTE of MWC facilities and counts of facilities above the different emission thresholds. The e GRID database includes year 2004 characteristi cs, operating information, and annual CO 2 emissions for U.S. facilities that have a generation capacity greater than one MW and sell electric power to the grid. By using e GRID , EPA assumed that all MWC facilities sell power to the grid. Potential to Emit EPA identified 75 MWC facilities based on the generator primary fuel in the generator table (primary

fuel equals MSW) in the e GRID database . The e GRID database contains CO 2 annual emissions estimates for the facilities. For CO 2 emissions, e GRID uses a standard assumption that 70 percent of the heat value of the waste stream comes from renewable materials and 30 percent comes from nonrenewable material s. The renewable fraction has a CO 2 emission rate of zero ; therefore, the PTE threshold anal ys is is ba sed on the nonrenewable or fossil fraction assumption. EPA estimated PTE by dividing the annual emissions from eGRID by the e GRID plant capacity

factor.60

New Units To determine the number of new per year at different thresholds , EPA counted the number o f generators online each ye ar, and totaled the nameplate capacity for each online year. This information was compared to the total facility nameplate capacity , and the PTE for the increased capacity was calculated b y multiplying the facility PTE by the fraction of nameplate capacity associated with the new generators. EPA counted the facilities that exceeded the PTE thresholds during each period, and computed a 15 - ye ar average to determine the number of new or modified facilities per year. Threshold Su mmary Table 6 1

CO 2 Threshold Summary - - Municipal Solid Waste Combustors - GHG Threshold (tons per y ear) Number of

Existing Sources Number of N ew

Facilities Added p er Year CO 2 Emissions Covered (Tg per y ear) 100 75 2 6.255 250 75 2 6.255 1,000 75 2 6.255 5,000 75 2 6.255 10,000 75 2 6.255 25,000 74 2 6.24 50,000 67 1 6.071 100,000 40 1 4.958 3.9 Agriculture ( Stationary Fuel Combustion) The anal ys is for the Agriculture sector was limited to stationary fuel combustion CO 2 emissions from internal combustion diesel engine generators. Fugitive emissions of CH 4 from enteric fermentation, and CO 2 , CH 4 , and N2 O from manure management were not included because farms and related operations are not in the 28 PSD source categories that require quantification of fugitive emission PTE for determining major source status, and because of the large uncertainties and lack of information on determining what component of the non combustion emissions at agricultural operations would be defined as non - fugitiv e for PSD purposes . Fuel combustion for building space heating and other farm purposes were not included in the estimates, but would be a component of farm PTE.61

Data and Methodology EPA used the 2007 ICF analysis to estimate the number of farms covered by the different thresholds (ICF, 2007). Emissions from diesel generators on farms were estimated using data on the average generator size in Delaware ( EEA, 2004), and data on energy use on farms for non transport/non - machinery

motors (Brown and Neal 2 005). Using these data , EPA estimated the number of diesel generators on farms and apportioned the generators across farm sizes, assuming no farm has more than one generator. Potential to Emit EPA assumed that a high proportion of farms would run the generators infrequently , and a smaller proportion would have a generator as the only power source, requiring nearl y constant operation. EPA used this distribution to determine actual and potential emissions , with PTE emissions based on the assumption that the generators ran 24 hours per day , 365 days per year. EPA recognizes that this approach underestimates the PTE for all farm stationary fuel combustion sources , because it is limited to diesel engine generator s used primarily to run pumps and motors , and does not include additional sources such as fuel combustion for drying and curing, space heating, and water heating. New Units New generator installations were estimated based on information in the Regulatory Impact Anal ys is (RIA) for the spark ignition stationary combustion engine NSPS and area NESHAPS (EPA, 2007). The on - farm engine population of diesel generators used for irrigation increased four percent between 1998 and 2003 , or about 0.8 percent annually .62

Threshold Summary Table 6 2

CO 2 T hreshold Summary - - Farm Stationary IC Engines CO 2 Threshold (t ons p er year) Number of

Existing Sources Number of New Engines Added p er Year CO 2 Emissions Covered (Tg per y ear) 100 37,351 299 0.512 250 37,351 299 0.512 1,000 0 0 0 5,000 0 0 0 10,0 00 0 0 0 25,000 0 0 0 50,000 0 0 0 100,000 0 0 0 3. 10 Commercial Stationary Fuel Combustion Data Source EPA used EIA ' s Commercial Building Energy Consumption Survey

(CBECS) to estimate commercial sector stationary fuel combustion GHG emissions an d PTE. CBECS is a national sample survey

that collects information on the stock of U.S. commercial buildings, their energyrelated building characteristics, and their energy consumption and expenditures. Commercial buildings include all buildings in which at least half of the floor space is used for a purpose that is not residential, industrial, or agricultural ; thus, the source category includes building ty pes that might not traditionally

be considered " commercial, " such as schools, correctional institutions, and buildings used for religious worship. The CBECS survey is conducted every

four years and the most recent survey

was completed for 2003 . The CBECS survey

sample was designed so that survey responses could be used to estimate characteristics of the entire nationwide commercial building stock. The 2003 survey selected 6,955 potential case buildings for sampling. The sampling procedures resulted in 5,215 completed building interviews for a response rate of 82 percent. To make national estimates from the sample data, EIA calculated base sampling weights for each building (the reciprocal of the probability

of that building being selected into the sample). In other words, the base sampling weight is the number of national buildings represented b y the sampled building. The base weight was further adjusted to account for nonresponsive bias.63

EIA publishes summary

tables from the survey , and posts " microdata " files on the EIA website. The CBECS microdata consist of the 5,215 sampled building reco rds, which each correspond to a single sampled building. For each building, these files contain information such as the building size, climatic region, census region, year constructed, types of energy used, and energy consumption and expenditures. These individual building microdata records are also the basis for the summary

tables published by

EIA. Emissions Methodology EPA used the CBECS microdata to estimate commercial building emissions and populations above emission thresholds. Each of the 5,21 5 microdata records corresponds to a single sampled building. EIA has made available 20 different data files of the microdata records which contain a wide range of information on characteristics and energy use for each building. EPA ' s analysis relied on guidance provided b y EIA on how to use the data. As noted above, the CBECS sample was designed so that survey responses could be used to estimate characteristics of the entire commercial building stock nationwide. The table below provides examples from EIA on how to calculate national commercial building characteristics from the sample building data. Table 6 3 EIA Website Examples To Find the National E stimate for: Do T his... And You Should G et... Total number of buildings Sum ADJWT8 (weight factor) 4 ,858,749.82 (or 4,859 thousand) Total number of office buildings Sum ADJWT8 for cases where PBA8 (building code) = " 02 " 823,805.47 (or 824 thousand) Total floor space Create a new variable (weighted square footage) by multiplying ADJWT8 by SQFT8 (flo or space) for each case, then sum this new variable 71,657,900,522 (or 71,658 million ft2 ) Total floor space in buildings with air conditioning Sum the new weighted square footage variable (see above) for cases where COOL8 (air conditioning) = " 1 " 63,55 9,999,624 (or 63,560 million ft2 ) Total electricity consumption in KWh Create a new variable (weighted electricity consumption) by multiplying ADJWT8 by ELCNS8 (electricity consumption) for each case, then sum this new variable 1,043,175,710,751 (or 1 ,043 billion kWh) Source : http://www.eia.doe.gov/emeu/cbecs/cbecs2003/public_use_2003/cbecs_pudata2003.html . EIA calculated base sampling weights for e ach surveyed building (these are the reciprocal of the probability of that building being selected into the sample). Therefore, a building with a base weight of 1,000 represents itself and 999 similar but unsampled buildings in64

the total building stock. The base weight is further adjusted to account for non - response bias. The variable " ADJWT8 " in the data file is the final weight. The ADJWT8 weight factor is used as described in Table 63 to extrapolate the survey sample to a national scale for any value . In order to obtain a national value each sample building ' s value must be multiplied by the building ' s weight (ADJWT8). All of the weighted values are then summed. 2003 CO 2 Emissions EPA calculated the CO 2 emissions for each of the 5,215 buildings based on the annual natural gas and oil consumption reported for the building . For national emission estimates and counts of buildings with annual CO 2 emissions over any threshold, EPA multiplied the base weights by

the sample emission totals to determine the national estimate of buildings with emissions over the threshold . Potential to Emit EPA estimates that commercial buildings operate at 15 percent of capacity. EPA considered several sources in making the PTE factor determination: ● A report prepared by

En ergy and Environmental Analysis , Inc. for Oak Ridge National Laboratory describ ing the industrial and commercial boiler population in the United States (EEA, 2005). The report estimated an average commercial boiler capacity factor of 16 percent . ● Reports on cooking equipment energy use b y the Food Service Technology Center in California suggesting that the cooking equipment in food service establishments operate at about ten percent of a theoretical maximum capacity based on 8 , 760 hours per year (Pechan, et.al , 2008). ● A study

of Los Angeles dry

cleaners performed by

the Pollution Prevention Education and Research Center (PPERC) in 2004 which demonstrates that dry cleaners operate boilers at about 10 to 15 percent of maximum capacity over a norm al ye ar (Pechan, et al. , 2008) . New Buildings The CBECS data identifies the year the sampled buildings were constructed. We used the construction year information to identify the number of new buildings built each year in the 1990 to 2003 period. Counts of the average number of these buildings built per year were then made at the different emissions and PTE thresholds. Threshold Summary The count of buildings and emissions at the threshold levels for the entire sector are shown in the table below. Threshold results by commercial building categories (e.g., offices, public assembly , schools) are provided in Appendix B .65 Table 6 4 CO 2 Threshold Summary - - Commercial Sector Stationary Fuel Combustion CO 2 Threshold (tons per y ear) Number of

Existing Sou rces Number of N ew

Facilities Added p er Year CO 2 Emissions Covered (Tg per y ear) 100 1,355,921 22,123 119.262 250 731,477 12,041 105.306 1,000 172,654 2,922 69.885 5,000 18,167 196 29.384 10,000 5,660 96 17.765 25,000 1,161 7 8.790 50,000 600 3 6. 003 100,000 51 2 1.012 3. 11 Residential Buildings Data Sources EPA used residential fuel consumption data from EIA ' s Residential Energy Consumption Survey , and multi - family building and unit data from U.S. Census (Census) surveys to estimate CO 2 emissions and PTE for fuel combustion at single and multi - family residential properties. The RECS is a national area -probability sample survey

that collects energy- related data for o ccupied primary

housing units. The most recent 2005 survey collected data from 4,382 households in housing units statistically selected to represent the 111.1 million housing units in the United States. RECS data are tabulated for the four Census regions, the nine Census divisions, and for the four most populous States -- Cali fornia, Florida, New York, and Texas. The RECS sample was designed so that survey responses could be used to estimate characteristics of the national stock of occupied housing units. In order to arrive at national estimates from the RECS sample, EPA cal culated base sampling weights for each housing unit as the reciprocal of the probability of that building being selected into the sample. Therefore, a housing unit with a base weight of 10,000 represents itself and 9,999 similar, but not sampled housing units in the total stock of occupied residential housing units. The base weight is further adjusted to account for non - response bias. Ratio adjustments were also used to ensure that the RECS weights add up to Census Current Population Survey estimates of the number of households . The RECS data are provided at the housing unit level, and not at the building level. EPA used additional data from the Census on multi - family building population characteristics to estimate total property emissions and PTE for multi - unit properties. Census data were from two66

sources : the Property

Owner and Manager Survey (POM S , 1996) and the American Housing Survey (AHS, 2005). 3.11.1 Single - Fa mily Homes The RECS data was used directly to estimate CO 2 emissions from fossil fuel combustion at sing le - family

housing units for space heating, water heating, and appliances. EPA assumed that each unit in an attached single - famil y building was a separate source, with combustion equipment under different ownership. The annual en ergy

consumption by

fuel (1 , 000 Btus) for the surveyed unit w as multiplied by the fuel CO 2 emission factor to estimate annual emissions. Total single - family unit emissions for the entire country

were calculated by

multiplying CO 2 emissions for each units by the base sampling weight. Potential to Emit The PTE for a single - family unit was calculated b y dividing the CO 2 emissions from the unit by a capacity

factor of 0.1. This factor was estimated by comparing the average annual CO 2 emissions per heated floor space area per hour by climate zone, to required heat input capacity . The required heat input capacity was based on rule of thumb heating s ys tem requirements for the different climate zones. The tab le below shows the average Btu/f t2

- h our from the RECS data and Heating Requirement (Btu/ f t2 ) by climate zone. A heating s ys tem efficiency of 80 percent was used to estimate the required space heating capacity . Table 6 5 Single - Fa mily Detached and Attached Households with Fossil Fuel- Fired Space Heatin g

(from RECS, 2005) Households (millions) Climate

Zone(s) Heating Degree

Day Range Average Annual Fuel

Consumption (Btu/f t 2 - h our) S pace Heating

Requirement* (Btu/f t 2) 6.8 5 > 7,000 4.8 50

– 60 16.7 4 5,500

– 7,000 5.4 45

– 50 17.0 3 4,000

– 5,499 4.6 40

– 45 18.9 1 and 2 < 4,000 3.8 Zone 2 : 35

– 40 Zone 1 : 30

– 35

* Heating requirement ranges are from www.acdirect.com/systemsize.php .67

3. 11.2 Multi- F amily Residential Buildings Emission Rates As noted earlier in the Data Source section, the RECS data are on an individual unit basis, not building or property basis, so a different approach was required for multi - family units where EPA assume d common ownership of the property fuel combustion equipment. In order to estimate property emissions and the number of properties above different emission and PTE thresholds , EPA combined the RECS data with data from the POM S and AHS. From the RECS data , EPA first calculated average residential unit C O 2 emissions for the two most common fuels (natural gas and oil) b y multi - family category . These are shown in the table below. Table 6 6

Multi- Fa mily Residential Unit - - Average Annual CO 2 Emissions

(from RECS, 2005) Multi - Family Category (number of u nits) Natural Gas Space Heating (t ons CO 2/residential unit-y ear) Fuel Oil Space Heating (t ons CO 2/r esidential unit-y ear) 2 to 4 units 4.8 8.3 5 or more units 3.0 8.9 EPA also obtained annual CO 2 emission rates from an EPA anal ys is that was based on L awrence Berkeley

National Lab (LB N L) modeling studies. Those rates were estimated f or old and new building units (s ee Table 67 ). The pre - 1980 building estimate compares with the overall average from the RECS data. The post - 1980 building estimates are much lower, particularl y for units burning fuel oil. Table 6 7

Multi- Fa mily Residential Unit - - Average Annual CO 2 Emissions (from 2008 EPA Analysis based on L B N L , 1997) Multi - Family Category (building age) Gas Serviced Units

(t ons CO 2/residential unit-y ea r) Fuel Oil Serviced Units (t ons CO 2/residential unit-y ear) Pre - 1980 building 4.75 7.17 Post - 1980 building 2.65 3.8768

Existing Property Characteristics In formation on the distribution of multi - family properties by

number of units per p roperty was taken from the 1995

– 1996 POMS. The data are aggregated b y different housing unit ranges. The table below shows the property size distribution from unpublished POM S data (NMHC Quick Facts - - Apartment Stocks (http://www .nmhc.org) ) . The POM S data were f or privately owned housing only and excluded public housing projects (about 13,500 buildings and 1,326,000 units). For our estimates, the building numbers were adjusted to current (2005) levels based on the RECS unit data (unit ratio of RECS to POM S ). EPA assumed the same unit distribution in the adjustment. Table 6 8

Multi- Fa mily Residential Property Size Distribution (from National Multi- Housing Council tabulatio n of unpublished POMS data 1995
– 1996) Number of Ren tal Units on Property Number of Properties (1995
– 1996) Number of Units (1995
– 1996) Average Number

of Units per Property 2 1,558,700 3,093,200 2 3 336,030 1,025,900 3 4 341,350 1,436,800 4 5

– 9 281,500 1,897,700 7 10

– 14 70,390 862,280 12 15

– 19 36,780 602,260 16 20

– 29 38,000 916,750 24 30

– 39 18,166 604,240 33 40

– 49 14,431 702,790 49 50

– 99 26,694 2,009,400 75 100

– 199 19,804 2,952,300 149 200

– 299 7,775 1,948,400 251 300

– 399 2,966 1,058,800 357 400

– 499 1,307 605,130 463 500

– 749 723 431,360 597 Over 750 307 437,670 1 , 426 Total 2,754,923 20,584,98069

The adjusted POM S size distribution and average number of units in each category were combined with information from RECS on the percentage of units that use gas or oil for space heating. The gas and oil emission factors from the previous tables were applied to the average number of units in each property size category by fuel to estimate property annual CO 2 emissions. For our final estimates we used the LB N L based e mission factors for post - 1980 buildings, over the RECS based factor. We found that these lower emission factors resulted in total emissions more in line with the total based on all RECS units and residential sector estimates in the U.S. Greenhouse Gas Inv entory . The RECS -based factors combined with the POM S property

distribution data resulted in a larger overestimate in overall category annual emissions. The lack of information on the building population over 50 units, and lack of information on the correlation between unit emissions and the building/property size are large sources of uncertainty in the estimates at thresholds above 1 , 000 tons. Potential to Emit PTE was estimated using the same ten percent capacity factor as used for the single family residential units New Properties The AHS data provided information on new construction used to estimate the number of new buildings and new units with natural gas space heating that were constructed in the 1999

– 2005 period. To simplify the anal ys is, EPA ignored the limited use of fuel oil for space heating in new units. The AHS data provided separately the number of new buildings with gas space heating per year, and a size distribution for all new buildings per year. The AHS size distribution stopped at 50 and larger, and was slightl y different in other categories from the POM S data . EPA adjusted the distribution based on the POM S distribution and then used the same emission and capacity factor approach as used for existing units.70 Table 6 9 Am e rican Housing Survey New Building Data Building Size: Number of Units per Building Number of New

Buildings per Year (1999
– 2005 ) (thousands) Fraction of All

NewBuildings per Year (1999
– 2005) NewGas Buildings

p er Year (1999
– 2005) (thousands) Numbe r of New

Gas Buildings per Year 2 6.3 0.22

16.0 3 , 468 3

– 4 5.4 0.19 2 , 995 5

– 9 6.1 0.21 3 , 389 10

– 19 6.0 0.21 3 , 310 20

– 29 3.1 0.11 1 , 734 30

– 49 1.0 0.03 552 50 or more 1.0 0.03 552 Total 29.0 1.00 16.0 16,00071

Threshold Summary Tabl e 70

CO 2 Threshold Summaries - - Residential Sectors Threshold (tons per y ear) Number of

Existing Sources Number of New

Facilities Added p er Year CO 2 Emissions

Covered (Tg per y ear) Multi- F amily Residential

100 610,500 11,300 54.285 250 137,000 6,400 42.192 1,000 51,200 1,100 32.399 5,000 7,800 120 14.934 10,000 1,400 20 4.933 25,000 160 3 1.392 50,000 20 0 0.006 100,000 0 0 0 Single - Family Residential

100 3,925,000 33,000 51.408 250 45,350 515 1.67 0 1,000 0 0 0 Total Residential Sector

10 0 4,535,500 44,300 105.693 250 182,350 6,915 43.862 1,000 51,200 1,100 32.399 5,000 7,800 120 14.934 100,00 1,400 20 4.933 25,000 160 3 1.392 50,000 20 0 0.006 100,000 0 0 072

References Brown, E., and Elliott, R.N., On
-Farm Energy Use Characterizations , Report Number IE052, ©American Council for an Energy- Efficient Economy , Washington, D.C., March 2005. http://www.aceee.org/pubs/ie052full.pdf E.H. Pechan & Associates, Inc., Perrin Quarles Associates, Inc., and Alpine Geophysics, LLC , Greenhouse Gas (GHG) Emissions and New Source Review , Work Assignment No. 1 - 06, EPA Contract No. EP - D - 07 - 097, April 10, 2008 ( EPA - HQ - OAR- 2008 - 0318 - 0080 ) . Environmental Energy

and Analysis, Inc. (EEA), Characterization of the U.S. Industrial Commercial Boiler Population , submitted to Oak Ridge National Laboratory, May 2005 ( EPA - HQ - OAR- 2008 - 0318 - 0005 ) . http://www1.eere.energy .gov/industry /distributedenergy

/pdfs/characterization_industrial_comme rical_boiler_population.pdf Energy and Environmental Anal ys is, Inc . ( EEA), World of Distributed Generation in Delaware , February 2004 . http://www.eeainc.com/rrdb/DGRegProject/Documents/DEDGWorld.pdf Federal Register, 74 FR 16447 , Mandatory Greenhouse Gas Reporting Regulations ; Proposed Rule, Washington, D .C., April 10, 2009 . Federal Reserve, Statistical Release G17. Industrial Production and Capacity Utilization . http://www.federalreserve.gov/releases/g17/About.htm IC F, International , Memorandum from Chris Steuer, Marian Van Pelt and Robert Lanza regarding Methodology

Description for Industrial Sector GHG Thres hold Analysis, November 2, 2007 ( EPA - HQ - OAR- 2008 - 0318 - 0079 ) . Lawrence Berkeley

National Laboratory

(LBNL). Energy Data Sourc ebook for the U.S. Residential Sector . Prepared b y Energy Analysis Program, Environmental Energy Technologies Division, LBNL, University of Cali fornia, Berkeley , CA, September 1997. http://enduse. lbl.gov/info/Pubs95_99.html National Multi - Housing Council (NMHC), Quick Facts Apartment Stock: Distribution of Apartments by Size of Property , NMHC tabulation of unpublished data from the U.S. Census Bureau ' s 1995

– 1996 Property Owners and Managers Survey . http://www.nmhc.org/ U.S. Census Bureau (2 006), American Housing Survey for the United States: 2005 . http://www.census.gov/hhes/www/housing.html . U.S. Census Bureau (2004), 2002 Economic Census, August 2004. http://www.census.gov/econ/census02/73

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

Information Administration (EIA), Electric Power Annual , 2007, January 21, 2009. http://www.eia.doe.gov/cneaf/electricity/ epa/epa_sum.html U.S. Energy

Information Administration (EIA), Annual Energy Review 2005 , DOE/EIA - 0384, July 1, 2006. U.S. Energy

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

Information Administration (EIA), 2003 Commercial Building Energy Consumptio n Survey , December 2006. http://www.eia.doe.gov/emeu/cbecs/cbecs2003/public_use_2003/cbecs_pudata2003.html U.S. Energy

Information Administration (EIA), 2 002 Manufacturing Energy Consumption Survey , January

2007. http://www.eia.doe.gov/emeu/mecs/contents.html U.S. Environmental Protection Agency (EPA), Inventory of U.S. Greenhouse Gas Emissio ns and Sinks: 1990

– 2007, April 2009, US EPA 430 - R- 09 - 004. http://www.epa.gov/climatechange/emissions/usinventory report.html U.S. Environmental Protection Agency (EPA), Supporting Data f or Threshold Analysis Subpart E

– W, Greenhouse Gas Mandatory Reporting Rulemaking, March 10, 2009 ( EPA - HQ - OAR2008 - 0508 - 0046.7 ) . U.S. Environmental Protection Agency (EPA ), Supporting Data f

or Threshold Analysis Subpart X

– PP, Greenhouse Gas Mandatory Reporting Rulemaking, March 10, 2009 ( EPA - HQ - OAR2008 - 0508 - 0046.8 ) . U.S. Environmental Protection Agency (EPA), Emissions &Generation Resource Integrated Database (eGRID) 2004 , May 2007. http://www.epa.gov/cleanenergy /energy- resources/egrid/index.html U.S. Environmental Protection Agency (EPA), Regulatory Impact Analysis for the Stationary Spark
-Ignition New Source Performance Standard (SI NSPS) and New A rea Source NESHAP , December 2007 , US EPA 452/R- 07 - 015 . http://www.epa.gov/ttn/atw/nsps/sinsps/sinspspg.html U.S. Environmental Protection Agency (EPA), Draft U.S. Adipic Acid and Nitric Acid N 2 O Emissions 1990

– 2020: Inventories, Projections and Opportunities for Reductions , November 2001. http://www.epa.gov/nitrousoxide/pdfs/adipic_nitric_n2o.pdf74

U.S. Environmental Protection Agency (EPA), Climate Change Division, Fugitive Emissions Reporting from the Petroleum and Natural Gas Industry: Background Technical Support Document, undated, FR publish date: March 26, 2009 (EPA - HQ - OAR- 2008 - 0508 - 0023) . U.S. Environmental Protection Agency (EPA), Office of Air and Radiation, Technical Support Document for the A dipic Acid Production Sector: Proposed Rule for Mandatory Reporting of Greenhouse Gases, January 22, 2009 (EPA - HQ - OAR- 2008 - 0508 - 0005) . U.S. Environmental P rotection Agency (EPA), Office of Air and Radiation, T echnical Support Document for Process Emissions from Primary Production of Aluminum: Proposed R ule for Mandatory Reporting of Greenhouse Gases, February 4, 2009 (EPA - HQ - OAR- 2008 - 0508 - 0006) . U.S. Environmental Protection Agency (EPA), Office of Air and Radiation, Technical Support Document for the Ammonia Production Sector: Proposed Rule for Mandatory Reporting of Greenhouse Gases, January 22, 2009 (EPA - HQ - OAR- 2008 - 0508 - 0007). U.S. Environmental Prote ction Agency (EPA), Office of Air and Radiation, Technical Support Document for Process Emissions from Cement: Proposed Rule for Mandatory Reporting of Greenhouse Gases, January 28, 2009 (EPA - HQ - OAR- 2008 - 0508 - 0008). U.S. Environmental Protection Agency ( EPA), Office of Air and Radiation, Technical Support Document for Process Emissions From Electronics Manufacture (Semiconductors, MEMs, Liquid Crystal Displays, and Photovoltaics), January 29, 2009 (EPA - HQ - OAR- 2008 - 0508 - 0009). U.S. Environmental Protectio n Agency (EPA), Office of Air and Radiation, Technical Support Document for Ethanol Facilities: Proposed Rule for Mandatory Reporting of Greenhouse Gases, February

4, 2009 (EPA - HQ - OAR- 2008 - 0508 - 0010). U.S. Environmental Protection Agency (EPA), Office of Air and Radiation, Technical Support Document for the Ferroalloy Production Sector : Proposed Rule for Mandatory Reporting of Greenhouse Gases, January 22, 2009 (EPA - HQ - OAR- 2008 - 0508 - 0011). U.S. Environmental Protection Agency (EPA), Office of Air and Radiation, Technical Support Document for the Glass Manufacturing Sector : Proposed Rule for Mandatory Reporting of Greenhouse Gases, January 22, 2009 (EPA - HQ - OAR- 2008 - 0508 - 0014). U.S. Environmental Protection Agency (EPA), Office of Air and Radiation, T ech nical Support Document for Emissions of HFC
- 23 from Production of HCFC
- 22: Proposed Rule for Mandatory Reporting of Greenhouse Gases, February 06, 2009 (EPA - HQ - OAR- 2008 - 0508 - 0015). U.S. Environmental Protection Agency (EPA), Office of Air and Radiation, Technical Support Document for the Hydrogen Production : Proposed Rule for Mandatory Reporting of Greenhouse Gases, August 5, 2008 (EPA - HQ - OAR- 2008 - 0508 - 0016).75

U.S. Environmental Protection Agency (EPA), Office of Air and Radiation, Technical Support Docu ment for the Iron and Steel Sector : Proposed Rule for Mandatory Reporting of Greenhouse Gases, September 9, 2008 (EPA - HQ - OAR- 2008 - 0508 - 001 7 ). U.S. Environmental Protection Agency (EPA), Office of Air and Radiation, Technical Support Document for the Land

fill Sector : Proposed Rule for Mandatory Reporting of Greenhouse Gases, February

4, 2009 (EPA - HQ - OAR- 2008 - 0508 - 0034). U.S. Environmental Protection Agency (EPA), Office of Air and Radiation, Technical Support Document for the Lead Production Sector : Proposed Rule for Mandatory Reporting of Greenhouse Gases, January 22, 2009 (EPA - HQ - OAR- 2008 - 0508 - 0018). U.S. Environmental Protection Agency (EPA), Office of Air and Radiation, Technical Support Document for the Lime Manufacturing Sector : Proposed Rule fo r Mandatory Reporting of Greenhouse Gases, January 22, 2009 (EPA - HQ - OAR- 2008 - 0508 - 0019). U.S. Environmental Protection Agency (EPA), Office of Air and Radiation, Technical Support Document for Process Emissions from Magnesium Production and Processing: Proposed Rule for Mandatory Reporting of Greenhouse Gases , February 10 , 2009 (EPA - HQ - OAR- 2008 - 0508 - 0020). U.S. Environmental Protection Agency (EPA), Office of Air and Radiation, Technical Support Document for the Petrochemical Production Sector : Proposed Rule for Mandatory Reporting of Greenhouse Gases, September 9, 2008 (EPA - HQ - OAR- 2008 - 0508 - 0024). U.S. Environmental Protection Agency (EPA), Office of Air and Radiation, Technical Support Document for the Petroleum Refining Sector : Proposed Rule for Man datory Reporting of Greenhouse Gases, September 9, 2008 (EPA - HQ - OAR- 2008 - 0508 - 0025). U.S. Environmental Protection Agency (EPA), Office of Air and Radiation, Technical Support Document for the Phosphoric Acid Production Sector : Proposed Rule for Mandator y Reporting of Greenhouse Gases, February 20, 2009 (EPA - HQ - OAR- 2008 - 0508 - 0026). U.S. Environmental Protection Agency (EPA), Office of Air and Radiation, Technical Support Document for the Pulp and Paper Sector : Proposed Rule for Mandatory Reporting of Greenhouse Gases, February 11, 2009 (EPA - HQ - OAR- 2008 - 0508 - 0027). U.S. Environmental Protection Agency (EPA), Office of Air and Radiation, Technical Support Document for the Silicon Carbide Production Sector : Proposed Rule for Mandatory Reporting of Greenho use Gases, January 22, 2009 (EPA - HQ - OAR- 2008 - 0508 - 0028). U.S. Environmental Protection Agency (EPA), Office of Air and Radiation, Technical Support Document for the Soda Ash Manufacturing Sector : Proposed Rule for Mandatory Reporting of Greenhouse Gases, January 22, 2009 (EPA - HQ - OAR- 2008 - 0508 - 0029).76

U.S. Environmental Protection Agency (EPA), Office of Air and Radiation, Technical Support Document for the Titanium Dioxide Production Sector : Proposed Rule for Mandatory Reporting of Greenhouse Gases, January 22, 2009 (EPA - HQ - OAR- 2008 - 0508 - 0031). U.S. Environmental Protection Agency (EPA), Office of Air and Radiation, Technical Support Document for Underground Coal Mines: Proposed Rule for Mandatory Reporting of Greenhouse Gases, February 4, 2009 (EPA - HQ - OAR- 2008 - 0508 - 0032). U.S. Environmental Protection Agency (EPA), Office of Air and Radiation, Technical Support Document for the Zinc Production Sector : Proposed Rule for Mandatory Reporting of Greenhouse Gases, January 22, 2009 (EPA - HQ - OAR- 2008 - 0508 - 0033).77 Appendix A Sector Permit Threshold Counts and Emissions by GHG The listed electronic spreadsheet files contain the permit threshold counts and emissions for each sector and subsector by GHG. These listed files are included in separate files in the docket (EPA - HQ - OAR- 2009 - 0517 ). Please refer to the following file names for additional information on specific sectors and GHGs: ● GHG Data for Final Tailoring Rule Development - CO2e .xls ● GHG Data for Final Tailoring Rule Development - CO2 .xls ● GHG Data for Final Tailoring Rule Development - CH4 .xls ● GHG Data for Final Tailoring Rule Development - N2O .xls ● GHG Data for Final Tailoring Rule Development - HFC .xls ● GHG Data for Final Tailoring Rule Development - PFC .xls ● GHG Data for Final Tailoring Rule Development - SF6 .xls78 Appendix B Commercial Building Sector - - Permit Threshold Results by Commercial Category Pl ease refer to the electronic file " Commercial Building Category CO 2 Permit Threshold Results.xls . " in the docket for EPA - HQ - OAR- 2009 - 0517 .79