Technical Support Document for Food Processing Facilities Proposed Rule for Mandatory Reporting of Greenhouse Gases


February 4, 2009
TECHNICAL SUPPORT DOCUMENT FOR FOOD
PROCESSING FACILITIES: PROPOSED RULE
FOR MANDATORY REPORTING OF
GREENHOUSE GASES
Climate Change Division
Office of Atmospheric Programs
U.S. Environmental Protection Agency
February 4, 2009

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CONTENTS
1.	Industry Description	3
2.	Total Emissions	3
3.	Review of Existing Programs and Methodologies	3
4.	Types of Emissions Information to be Reported	3
5.	Options for Reporting Threshold	3
5.1	Emissions-based Thresholds for Wastewater	3
5.1.1	Meat and Poultry Processing Wastewater Treatment Threshold Analysis	4
5.1.2	Fruits and Vegetables Processing Wastewater Treatment Threshold Analysis	6
5.2	Emissions-based Thresholds for Onsite Landfills	6
5.3	Other Threshold Options	7
6.	Options for Monitoring Methods	7
7.	Options for Estimating Missing Data	7
8.	QA/QC Requirements	8
9.	References	8
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1.	Industry Description
Food processing facilities prepare raw ingredients for consumption by animals or
humans. Many facilities in the meat and poultry, and fruit, vegetable, and juice
processing industries have on-site wastewater treatment. This can include the use of
anaerobic and aerobic lagoons, screening, fat traps and dissolved air flotation. These
facilities can also include onsite landfills for waste disposal. There are approximately
5,720 food processing facilities in the United States.
The sources of GHG emissions at food processing facilities considered in the analysis for
the proposed rule are stationary combustion, onsite landfills and onsite wastewater
treatment.
Data is unavailable on stationary combustion at food processing facilities, but it is
believed that some of these facilities may have stationary combustion systems with
significant GHG emissions.
2.	Total Emissions
In 2006, CH4 emissions from wastewater treatment at food processing facilities were 3.7
MMTC02e, and CH4 emissions from onsite landfills were 7.2 MMTCC^e.
Estimates of total national emissions stationary combustion at food processing facilities
are unavailable.
3.	Review of Existing Programs and Methodologies
For information on the review of existing programs and methodologies, please refer to
the Technical Support Documents for general stationary fuel combustion (EPA-HQ-
OAR-2008-004), landfills (EPA-HQ-OAR-2008-034), and wastewater treatment (EPA-
HQ-OAR-2008-035).
4.	Types of Emissions Information to be Reported
For information on information to be reported, please refer to the Technical Support
Documents for general stationary fuel combustion (EPA-HQ-OAR-2008-004), landfills
(EPA-HQ-OAR-2008-034), and wastewater treatment (EPA-HQ-OAR-2008-035).
5.	Options for Reporting Threshold
5.1 Emissions-based thresholds for Wastewater
In evaluating thresholds for food processing facilities, we first considered emissions-
based thresholds of CH4 generation at onsite wastewater treatment system ("generation
threshold") and CH4 emissions at wastewater treatment systems ("emissions threshold")
of 1,000 mtC02e, 10,000 mtCC^e, 25,000 mtCC^e, and 100,000 mtCC^e per year. Data
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on emissions from stationary combustion sources at food processing facilities were
unavailable to conduct similar analyses for these sources. The "generation threshold" is
the amount of CH4 that would be emitted from the facility if no CH4 recovery takes place.
This includes all CH4 generation from all wastewater treatment system types, including
digesters. The "emissions threshold" includes the CH4 that is emitted to the atmosphere
from these systems. In the emissions threshold, CH4 that is recovered and combusted at
digesters is taken into account and deducted from the total CH4 generation calculated.
Please see the Technical Support Document for Wastewater (EPA-HQ-OAR-2008-035)
for more information.
Table 1. Summary of Threshold Analysis for Industrial Wastewater Treatment at
Threshold
(mlC ()2e)::
#
Systems
% Systems
Emissions
(mlC ()2e)
% Emissions
Meat Processing -Emissions
1,000
<616
<18
<2,024,125
<100
10,000
<45
<1.3
<1,125,000
<56
25,000
<13
<0.4
>325,000
>16
100,000
1
<0.1
>100,000
>5
Meat Processing - Generation
1,000
<616
<18
<2,024,125
<100
10,000
<45
<1.3
-1,125,000
>56
25,000
<19
<0.6
>425,000
>23
100,000
2
<0.1
>200,000
>10
Poultry Processing - <
feneration and Emissions
1,000
86
16
>1,286,000
>85
10,000
50
9.3
>1,250,000
>82
25,000
NE
NE
NE
NE
100,000
0
0
0
0
Fruit and Vegetable - Generation and Emissions
1,000
<100
<6%
<123,000
<100
10,000
0
0
0
0
25,000
0
0
0
0
100,000
0
0
0
0
* Threshold analyzed is based on wastewater treatment emissions only.
5.1.1 Meat and Poultry Processing Analysis for Wastewater Treatment Threshold
EPA was unable to obtain a dataset containing plant-specific information to calculate
greenhouse gas emissions for meat processors or poultry processors. Therefore, using
national default values for wastewater generation, COD in wastewater rates, and
assuming all wastewater is treated anaerobically on site, EPA back-calculated the
production rate that would trigger each of the four emission thresholds.
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Table 2. Summary of Minimum Amount of Product Processed to Meet Thresholds
for Wastewater Treatment at Food Processing Facilities	
Threshold
(mtCOie)
Meat Processing Production
Poultry Processing Production
Thousand
metric tons
Million lbs
Thousand
metric tons
Million lbs
1,000
5
12
4
9
10,000
53
117
42
93
25,000
133
292
105
232
100,000
531
1,170
421
928
EPA's Office of Water (OW) established national effluent limitation guidelines and
standards for this industry in 2004. At that time, OW estimated that nonsmall poultry
processors processed over 100 million pounds of meat per year. This is very close to the
estimated production cutoff for facilities to meet the 10,000 mtC02e threshold. OW
estimated that there were 206 nonsmall poultry processors (EPA 2004), and that 25% of
poultry processors have onsite anaerobic lagoons. Therefore, EPA estimates that
approximately 50 poultry processors would exceed the 10,000 mtC02e threshold. If we
assume the average production for these large poultry processors is about 200 million
pounds, these 50 plants account for about 70% of the greenhouse gas emissions for this
sector. Because of a lack of data, we assumed that no poultry processors collect biogas
for recovery. Therefore, we believe this is a conservatively high estimate.
EPA estimated that there are 145 small poultry processors. Assuming 25% have onsite
anaerobic lagoons, EPA estimates that no more than 36 poultry processors could exceed
the 1,000 mtC02e threshold. EPA assumed emissions from these operations are at least
36,000 mtC02e.
Data are not available to estimate the number of poultry processors that exceed the
production level for the 25,000 mtC02e threshold; however, EPA believes there are no
plants that meet the production level for the 100,000 mtC02e threshold. Because of the
assumption that no poultry processors collect biogas, generation is equal to emissions.
EPA also estimated that there were 139 nonsmall meat processors that processed >50
million pounds per year. Of these, EPA estimates that 33% have onsite anaerobic
treatment. Therefore, EPA estimates that no more than 45 meat processors would exceed
the 10,000 mtC02e threshold. If we assume the average production for these large meat
processors is about 350 million pounds, these 45 meat processors account for about 67%
of the greenhouse gas emissions for this sector. We believe this is a conservatively high
estimate.
EPA estimated that there are 1,730 small meat processors. Assuming 33% have onsite
anaerobic lagoons, EPA estimates that no more than 571 meat processors could exceed
the 1,000 tC02e threshold. EPA assumed emissions from these operations are at least
571,000 tC02e.
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These estimates also assume that no meat processing facilities collect biogas for
recovery. However, data available on one food processor's web site indicates that covers
have been installed on anaerobic lagoons at five meat processing plants (4 beef, 1 pork).
Prior to the installation of the covers, all five sites were estimated to emit more than
25,000 mtC02e and one of these sites emitted more than 100,000 mtCC^e. Following
installation of the covers, only one of these sites emits more than 25,000 mtCC^e and
three more emit more than 10,000 mtCC^e.
Data from another food processor's web site indicates that the processor has installed
covers on all of its anaerobic lagoons at U.S. meat packing plants (8 beef, 2 pork). It is
estimated that these plants would have emitted more than 25,000 tC02e each. It is
unknown what their actual emissions are now.
From these data, then, we estimate that no more than 13 meat processing facilities emit
more than 25,000 mtCC^e and one of these plants may emit more than 100,000 mtCC^e,
and no more than 19 plants generate more than 25,000 mtCC^e and two of these plants
may generate more than 100,000 mtCC^e.
5.1.2 Fruits and Vegetables Processing Analysis for Wastewater Treatment Threshold
Because of the decentralized and variable nature and of the fruits and vegetables
processing industry, EPA was unable to obtain a dataset containing plant-specific
information to calculate greenhouse gas emissions for fruit and vegetable processors.
The national level of emissions from the U.S. inventory is 123,000 mtCC^e. From the
U.S. Inventory, we estimate there are approximately 100 processors with onsite anaerobic
treatment; therefore, the average emission is about 1,200 mtCC^e per plant. Therefore, it
is not believed that there are many, if any, fruit and vegetable processors that would
exceed thresholds greater than 10,000 mtCC^e. However, up to 100 processors may
exceed the 1,000 mtCC^e threshold based on the average emission rate.
5.2 Emissions-Based Thresholds for Onsite Landfills
The number of food processing facilities having onsite industrial landfills was estimated
based on a 1987 screening survey of industrial Subtitle D waste management practices.
Methane generation and emissions were estimated based on U.S. GHG Inventory
estimates. The number of landfills and percentage of waste covered by each threshold
was estimated based on expert judgment and the average methane emissions potential for
the industrial landfills. Food processing landfills were assumed not to have recovery, so
there is no difference in the number of landfills covered or the emissions covered under
generation versus emissions thresholds.
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Table 3. Threshold Analysis for Landfills at Food Processing
facilities
Threshold
#
%
Emissions
% Emissions
(mtCOie)*
Landfills
Landfills
(mtCOie)
Food Processing -Generation and Emissions
1,000
189
100
7,200,000
100
10,000
170
90
7,000,000
97
25,000
100
53
5,000,000
69
100,000
10
5
1,500,000
21
* Threshold analyzed is based on landfill emissions only.
5.3 Other threshold options
EPA also considered a facility-level threshold for food processing. Data were
unavailable to estimate emissions from stationary combustion at food processing plants,
or to estimate the number of food processing plants having both wastewater treatment
systems and landfills onsite. The table below presents estimates of facility coverage
based on maximum values for number of facilities covered using thresholds for onsite
wastewater treatment systems or landfills.
Table 4. Threshold Analysis for Food Processing Facilities

Niilioiiiil
Idlill
I'lmissioiis Co\oivd
l-'iicililios
('(utml
Threshold l.e\el
r.inissidiis
llll( ();0
Number of
l-'iicililios
llll( ();C/
jesir
IVrcenl
Number
IVrcciH
1,000 mtC02e
NE
5,719
NE
NE
802
14.0
10,000 mtC02e
NE
5,719
NE
NE
170
3.0
25,000 mtC02e
NE
5,719
NE
NE
100
1.7
100,000 mtC02e
NE
5,719
NE
NE
10
0.2
NE = Not Estimated
6. Options for Monitoring Methods
For information on monitoring methods, please refer to the Technical Support Documents
for general stationary fuel combustion (EPA-HQ-OAR-2008-004), landfills (EPA-HQ-
OAR-2008-034), and wastewater treatment (EPA-HQ-OAR-2008-035).
7. Options for Estimating Missing Data
For information on options for estimating missing data, please refer to the Technical
Support Documents for general stationary fuel combustion(EPA-HQ-OAR-2008-004),
landfills (EPA-HQ-OAR-2008-034), and wastewater treatment (EPA-HQ-OAR-2008-
035).
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8. QA/QC Requirements
For information on options for QA/QC requirements, please refer to the Technical
Support Documents for general stationary fuel combustion, (EPA-HQ-OAR-2008-004),
landfills (EPA-HQ-OAR-2008-034), and wastewater treatment (EPA-HQ-OAR-2008-
035).
9. References
EPA. 2008. Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990-2006 (April
2008) USEPA #430-R-08-005.
EPA. 2004. Technical Development Document for the Final Effluent Limitations
Guidelines and Standards for the Meat and Poultry Products Point Source Category
(EPA-821-R-04-011). Office of Water. Washington DC.
IPCC. 2006. IPCC Guidelines for National Greenhouse Gas Inventories: Wastewater
Treatment and Discharge. IPCC (Volume 5 Waste, Chapter 6). Available at
http://www.ipcc-
nggip.iges.or.ip/public/2006gl/pdf/5_Volume5/V5_6_Ch6_Wastewater.pdf.
IPCC. 2006. IPCC Guidelines for National Greenhouse Gas Inventories: Solid Waste
Disposal. IPCC (Volume 5 Waste, Chapter 3. Available at http://www.ipcc-
nggip.iges.or.jp/public/2006gl/pdf/5_Volume5/V5_3_Ch3_SWDS.pdf.
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