PRELIMINARY DATA SUMMARY

                    FOR THE

MACHINERY MANUFACTURING AND REBUILDING INDUSTRY
   Office of Water Regulations and Standards
                Office of Water
 United States Environmental Protection Agency
                Washington,  DC

                  October  1989

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                             PREFACE
     This is one of a series of Preliminary Data Summaries
prepared by the Office of Water Regulations and Standards of the
U.S. Environmental Protection Agency.  The Summaries contain
engineering, economic and environmental data that pertain to
whether the industrial facilities in various industries discharge
pollutants in their wastewaters and whether the EPA should pursue
regulations to control such discharges.  The summaries were
prepared in order to allow EPA to respond to the mandate of
section 304(m) of the Clean Water Act, which requires the Agency
to develop plans to regulate industrial categories that
contribute to pollution of the Nation's surface waters.

     The Summaries vary in terms of the amount and nature of the
data presented.  This variation reflects several factors,
including the overall size of the category (number of
dischargers), the amount of sampling and analytical work
performed by EPA in developing the Summary, the amount of
relevant secondary data that exists for the various categories,
whether the industry had been the subject of previous studies  (by
EPA or other parties), and whether or not the Agency was already
committed to a regulation for the industry.  With respect to the
last factor, the pattern is for categories that are already the
subject of regulatory activity (e.g., Pesticides, Pulp and Paper)
to have relatively short Summaries.  This is because the
Summaries are intended primarily to assist EPA management in
designating industry categories for rulemaking.  Summaries for
categories already subject to rulemaking were developed for
comparison purposes and contain only the minimal amount of data
needed to provide some perspective on the relative magnitude of
the pollution problems created across the categories.

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                        ACKNOWLEDGMENTS

Preparation  of  this Preliminary Data Summary  was  directed  by
Sabita  K.  Rajvanshi,  Project  Officer,  industrial  Technology
Division.  The economic and environmental analyses were  provided
by Lynne Tudor and Allison Greene, respectively/ Office of  Water
Regulations and Standards.

Persons interested in obtaining additional copies of this summary
may write to the following address:

     U.S. Environmental Protection Agency
     Industrial Technology Division  ;(WH-552)
     401 M Street, S.W.
     Washington, D.C.  20460

     Telephone  (202)  382-7124

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                        TABLE OF CONTENTS
Section
II
III
IV
 V
                                                  Page

MACHINERY MANUFACTURING AND, REBUILDING PROJECT
  EXECUTIVE SUMMARY	•.	        1

FINDINGS			        3

   SUMMARY OF FINDINGS		» . . .	        3

PROJECT PROFILE	. .	. . . . .	       13

   INTRODUCTION			       13

   BACKGROUND	       15

   PROJECT ANALYSIS		.	. .       18

     Review of Available  Information	       19
     Refinement of.Available Information	       21
     Collection of New Data.	       24

   MM&R PROFILE	       26

     Number of Facilities .	       26
     Water Use and Pollutant Loadings	       28
     Discharge Status	       29
     Existing Treatment Technologies	       29
     Regulatory Control	w ...........       3O

   SUMMARY.		...			........       J3Q

REGULATORY APPROACH AND STRUCTURE	       49

   BACKGROUND		.	       49

   REGULATORY STRUCTURE	       5O

   REGULATORY APPROACH		       51

     Mass-Based Regulatory  Approach and
       Structure	       51
     Alternative  Regulatory Approaches.......       53

WASTE USE AND WASTEWATER  CHARACTERISTICS  	       57

  INTRODUCTION 	 	       57

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Section
V
VI
VII
        TABLE  OF  CONTENTS (Continued)







   APPROACH TO DATA COLLECTION	



   TYPE OF DATA COLLECTION	



   NUMBER OF OPERATIONS  CHARACTERIZED	



   WATER USE AND  WASTEWATER DISCHARGE  FLQWS,,
            !              •"''," li'j, "'f ,„ •" i .j1 ' ,;! '  ' "  "  .1 " '«,


   RAW WASTEWATER CHARACTERISTICS	



   CURRENT DISCHARGE AND TREATMENT

     PRACTICES	



   SOLID WASTE AND  SLUDGE CHARACTERISTICS.,..



   SUMMARY	,	



   ADDITIONAL  DATA  GATHERING NEEDED	



POLLUTANTS OF  CONCERN	 «	



   INTRODUCTION		.	



   BASIS FOR TECHNICAL EVALUATION	



   POLLUTANTS  IDENTIFIED	



   SOURCE OF POLLUTANTS..	



CONTROL AND TREATMENT TECHNOLOGY	



   INTRODUCTION		



   CONTROL AND TREATMENT  TECHNOLOGY CURRENTLY

     IN USE	



   ALTERNATIVE CONTROL TECHNOLOGIES	
Page


  59


  66


  68



  69


  71




  73


  74


  77


  78


,115


 115


 116


 118


 119


 145


 145




 147


 149
                               ii

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Section
VIII
IX
 X
        TABLE OF CONTENTS (Continued)

                                                  Page

CONTROL AND TREATMENT COSTS. .	      153

   INTRODUCTION.............	.............      153

   COST ESTIMATION APPROACH.	.....;...      154

     Normal Plants	      154
     Treatment Technologies	      155
     Cost Estimates ....• i.	      158

   SUMMARY OF COSTS.	.....................      158

RAW WASTEWATER LOADINGS  AND POLLUTANT
  REDUCTION ESTIMATES.........	...........      165

   INTRODUCTION............... .... ......... . .      165

   RAW WASTEWATER LOADINGS.		• • • •      1 67

   APPROACH FOR ESTIMATING RAW WASTEWATER
     LOADINGS			.......      169

     Pollutant Loadings  for First  Phase......      169
     Pollutant Loadings  for Second Phase	      172

   POLLUTANT REDUCTION ESTIMATES.............      174

   APPROACH FOR ESTIMATING POLLUTANT
     REDUCTION............	........ ......       177

   SUMMARY...		.	.	..........       178

ECONOMIC ASSESSMENT	     ..  193

   TRANSPORTATION.... . ........... .... . . .	. .       195

     Motor Vehicle Transportation....	       196
       Economic and  Financial  Characteristics       196
         Vehicle  Manufacturing. .-. ............       196
         Retail Trade		.........      201
         .Transportation  Services.............      205
       Preliminary Economic  Impact Assessment      209
         Automobile  Rebuilding and Maintenance    2 TO
         Automobile,  Truck,  and Bus Parts
           Rebuilding.	       215
                                iii

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Section
X (Cont.)
                  .TABLE OF CONTENTS (Continued)
      Bus and Truck Rebuilding and
        Maintenance	 .      217
      Radiator Rebuilding and Maintenance.      223
  Air Transportation	      224
    Economic and Financial Characteristics      225
      Aerospace Manufacturing.	      225
      Air Services,	      230
    Preliminary Economic Impact Assessment      231
      Rebuilding	      232
      Maintenance	i.. .	      234
  Rail Transportation	,	      236
    Economic and Financial Characteristics      237
      Line Haul Railroads	      237
      Railroad Equipment Manufacturing and
        .Rental	      240
    Preliminary Economic Impact Assessment      241
  Summary of Economic Impacts for the
    Transportation Sector	      244

OFFICE MACHINES	,		      246

  Economic and Financial Characteristics..      247
  Economic Impact Assessment	      250
    Manufacturing	      250
    Rebuilding	      254

EFFECT OF MILITARY CONTRACTING PROCEDURE..      256

  Department of Defense Maintenance
    Policies	      256
  Industrial Funds	      259
  Industrial Fund Activity and Depot Level
    Maintenance	 .      263
    Army Industrial Fund	      263
    Navy Industrial Funds	      265
    Air Force Industrial Funds and the Air
      Force Logistics  Command	      268
    Marine Corps Industrial Fund	      272
  Possible Effects of  New Environmental
    Regulations	      272
    Effect of Regulations on Organizational
      Maintenance	      273
    Effect of Environmental Regulations  on
      Intermediate Maintenance	      274
    Effect of Environmental Regulations  on
      Depot Level  Maintenance	      274
                               iv

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                  TABLE OF CONTENTS (Continued)
Section

X (Cont.)    LIMITATIONS OF THE ANALYSIS.......,,.,.

               Scope of the Regulation.	
               Treatment Cost Estimates.	
               Economic and Financial Data.	

             COST-EFFECTIVENESS ANALYSIS	

               Methodology	.....*....,.......
                 Pollutant Loadings and Removals	
                 Treatment Costs	
               Cost-Effectiveness Results..............
               Limitations		,
               Pollutant Loadings, Removals, and Cost-
                : Effectiveness Results by Segment.
                 Automobile Rebuilding and Maintenance
                 Automobile, Bus, and Truck.Parts
                   Rebuilding	,
                 Bus and Truck Rebuilding..............
                 Bus and Truck Maintenance	.,
                 Radiator Rebuilding	,
                 Aircraft Rebuilding...................
                 Aircraft Maintenance.	......;
                 Railroad Rebuilding	
                 Railroad Maintenance. .	
                 Office Machine Manufacturing.........;
                 Office Machine Rebuilding	 .
 285

 286
 286
 289
 289
 295

 296
 296

 297
 298
 299
 300
 301
 302
 302
 303
 3O4
'305
                                v

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                         LIST OF TABLES
Table
 III-2



 III-3


 III-4


 III-5

 III-6


 III-7


 III-8


 V-1


 V-2


 V-3


 V-4


 V-5


 V-6

V-7



VI-1
          POINT SOURCE CATEGORIES LISTED IN APPENDIX B
          OF THE 1976 SETTLEMENT AGREEMENT	
          INDUSTRIAL CATEGORIES DERIVED FROM THE
          MACHINERY AND MECHANICAL PRODUCTS MANUFACTURING
          CATEGORY. .		

          SUMMARY OF INFORMATION COLLECTED FOR THE MM&R
          PROJECT		

          DEFINITIONS USED FOR MACHINERY MANUFACTURING
          AND REBUILDING PROJECT	
          MM&R UNIT OPERATIONS
          MACHINERY MANUFACTURING AND REBUILDING SEGMENTS
          FOR NEW DATA COLLECTION	. . ,	

          MACHINERY MANUFACTURING AND REBUILDING
          SECTORS AND SEGMENTS	
          MACHINERY MANUFACTURING AND REBUILDING
          PROJECT DATA SUMMARY	
          MM&R UNIT OPERATIONS HAVING ANALYTICAL, FLOW,
          AND PRODUCTION DATA	

          MM&R UNIT OPERATIONS WITHOUT ANALYTICAL, FLOW,
          AND PRODUCTION DATA	

          WASTEWATER DISCHARGE RATES FROM MM&R UNIT
          OPERATIONS	

          MAXIMUM CONCENTRATION MEASURED (mg/1) FOR MM&R
          UNIT OPERATIONS	

          RAW WASTEWATER CONCENTRATION DATA FOR SELECTED
          MM&R UNIT OPERATIONS	
         TREATMENT  IN PLACE  AT MM&R FACILITIES
         MM&R OPERATIONS  GENERATING HAZARDOUS OR
         POTENTIALLY HAZARDOUS SOLID WASTE
         AND SLUDGE	
         FREQUENCY OF OCCURRENCE  OF  POLLUTANTS FOR MM&R
         UNIT OPERATIONS	
Page


  32



  33


  34


  35

  36


  38


  39


  41


  81


  82
 86


 11,0

 112



 113


 120
                               vi

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                   LIST OF TABLES (Continued)
Table
Page
VII-1

VIII-1
VIII-2

IX- 1

IX-2

JX-3

IX-4

IX-5

X-1

X-2

X-3

X-4

X-5

X-6

X-7

TREATMENT SYSTEM PERFORMANCE AT TWO MM&R .
FACILITIES. . ..................:. 	 .... . '•-> . ...
NORMAL. PLANT SUMMARY. 	 	 	 	 	 	 	 	
SUMMARY OF TREATMENT COSTS FOR DIRECT AND
INDIRECT DISCHARGERS 	 	 	
RAW WASTEWATER POLLUTANT LOADINGS FOR 11
MM&R SEGMENTS 	 	 .;............,. . ;
SUMMARY OF RAW WASTEWATER POLLUTANT LOADINGS
FOR MACHINERY MANUFACTURING AND REBUILDING. . ;
.SUMMARY OF RAW. WASTEWATER LOADINGS .FOR
OTHER METALS INDUSTRIAL CATEGORIES. 	 	 	
POLLUTANT' REDUCTION ESTIMATES FOR DIRECT
DISCHARGERS , 1 1 MM&R SEGMENTS . . . . . 	 ......
POLLUTANT REDUCTION ESTIMATES FOR INDIRECT
DISCHARGERS 1 1 , MM&R SEGMENTS. . . 	 . . . 	
* - • , " ,"•;•-.'• - -
NUMBER OF FACILITIES FOR MACHINERY MANUFAC-
TURING & REBUILDING ...........................
- _ • - - .
TRANSPORTATION EQUIPMENT MANUFACTURING:
MOTOR VEHICLES 	 	
BEFORE TAX PROFITS AS A PERCENT OF SALES:
MOTOR VEHICLE MANUFACTURING . . . .... . . . . . . 	 	
RETAIL TRADE— TRANSPORTATION: MOTOR
VEHICLES .... 	 	 	 . 	 	 	 .... .... . ...
-• • • .:
BEFORE TAX PROFITS AS A PERCENT OF SALES:
MOTOR VEHICLE RETAIL TRADE . . 	 . . . ... . . . .
RETAIL TRADE — TRANSPORTATION: MOTOR
VEHICLES . . 	 . . 	 	 	 	 . .... . .•"...' 	 	
BEFORE TAX PROFITS AS A PERCENT OF SALES:
BUSES AND TRUCKS 	 	 	 . .........

152
160

164

18O

181

186

188

190

307

315

316

317

• 319'

32O

322
                               vii

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                                                       '1,
         LIST OF TABLES  (Continued)
MOTOR VEHICLE SEGMENTS  AND  IN-SCOPE  SIC CODES
Page

 323
Table

 X-8

 X-9      AUTOMOBILE REBUILDING AND MAINTENANCE:
          ESTABLISHMENT,  REVENUES,  AND PROFITS,  1984 	    325
                             '.   ••      -"' '  ' ">   ' 'I      .',',''•"  , • ''"  '. ""'"'
 X-1O     AUTOMOBILE REBUILDING AND MAINTENANCE:
          ESTIMATED TREATMENT  COSTS AND IMPACTS	...'..    326
                    ' ''.'•,''•       "    I'"1"  ' • •  "1 ;"11;"1  '   .""''',    '  J '• ;
 X-11     REVENUES AND  PROFITS FOR  AUTOMOBILE, TRUCK,
          AND BUS PARTS REBUILDING	    327
                        ,'   	"    • .    -,-•' • . . •' ' •" •,  ; '••  ~f;          ;
 X-12     ANNUALIZED TREATMENT COST ESTIMATES FOR
          BUS AND TRUCK REBUILDING  AND MAINTENANCE 	    328

 X-13     BUS REBUILDING  AND MAINTENANCE:   ESTIMATED
          COSTS, REVENUES,  PROFITS  AND IMPACTS	    329

 X-14     TRUCKS:  1986 REVENUES AND PROFITS . ."	    330

 X-15     TRUCK REBUILDING,  REPAIR  AND MAINTENANCE:
          TREATMENT COSTS AND  IMPACTS		...    331

 X-16     TRANSPORTATION  EQUIPMENT  MANUFACTURING:
          AIRCRAFT AND  PARTS	 ,	    332
                                 " i,             | ii'     '
 X-17     TRANSPORTATION  EQUIPMENT  MANUFACTURING:
          GUIDED MISSILES AND  SPACE VEHICLES & PARTS ....    334

 X-18     OTHER TRANSPORTATION SERVICES		    335

 X-19     REVENUES, EMPLOYMENT,  AND PROFITABILITY OF
          CERTIFIED AIR CARRIERS,  1982-1986	    336

 X-2O     ESTIMATION OF 1986 NON-MILITARY  AIRCRAFT
          MANUFACTURING REVENUES 		    337

 X-21     REVENUES, EMPLOYMENT,  AND PROFITABILITY OF
          CLASS I RAILROADS,  1982-1986 	••••••	    338

 X-22     MANUFACTURING AND RENTAL  OF RAILROAD CARS 	    339

 X-23     RAIL CAR REBUILDING  AND MAINTENANCE:
          TREATMENT COSTS AND  IMPACTS		.	    34O
                    Vlll

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                   LIST OF TABLES (Continued)
Table                                                       Page

 X-24     TRANSPORTATION SECTOR SUMMARY OF TREATMENT
          COSTS, REVENUES, PROFITS AND IMPACTS '..........    341

 X-25     OFFICE EQUIPMENT MANUFACTURING	    342

 X-26     REVENUES AND EMPLOYMENT OF COMPUTER EQUIPMENT
          MANUFACTURERS, 1983-1986 ....	..... ...	.    344

 X-27     COMPUTER AND OFFICE EQUIPMENT MANUFACTURING
          REVENUES AND PROFITS FOR MAJOR FIRMS,  1982
          AND 1988	. .			    345

 X-28     ADJUSTED 1982 SEGMENT REVENUES:  COMPUTERS,
          COPIERS, AUTOMATIC TYPEWRITERS AND WORD
          PROCESSORS					. .    346

 X-29     ESTIMATION OF 1988 REVENUES FOR ESTABLISHMENTS
          MANUFACTURING COMPUTERS, COPIERS, AUTOMATIC
          TYPEWRITERS, AND WORD PROCESSORS ..............    347

 X-3O     1988 COST EFFECTIVENESS CRITERIA AND WEIGHTS
          NON-VOLATILE POLLUTANTS	 .    348

 X-31     NONCONVENTIONAL NON-PRIORITY POLLUTANTS  	...    352

 X-32     SUMMARY OF DISCHARGES AND REMOVALS FOR MM&R
          SECTORS/SEGMENTS	 .	    353

 X-33     NORMAL PLANT COST-EFFECTIVENESS VALUES OF
          EFFLUENT LIMITATION CONTROLS FOR DIRECT
          DISCHARGERS BY SECTOR OR SEGMENT OF MACHINERY
          MANUFACTURING AND REBUILDING	    354

 X-34     NORMAL PLANT COST-EFFECTIVENESS VALUES OF
          EFFLUENT LIMITATION CONTROLS FOR INDIRECT
          DISCHARGERS BY SECTOR OR SEGMENT OF
          MACHINERY MANUFACTURING AND REBUILDING ....	    355

 X-35     COST EFFECTIVENESS COMPARISON FOR DIRECT
          DISCHARGERS (TOXIC AND NONCONVENTIONAL
          POLLUTANTS ONLY) COPPER BASED WEIGHTS  	    356
                               ix

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                   LIST OF TABLES  (Continued)


Table                                                        Page

 X-36     INDUSTRY COMPARISON, COST EFFECTIVENESS
          COMPARISON FOR INDIRECT  DISCHARGERS  (TOXIC
          AND NONCONVENTIONAL POLLUTANTS ONLY) COPPER
          BASED WEIGHTS 	     357

 X-37     POLLUTANT REDUCTION ESTIMATES NORMAL PLANT
          LOAD - AUTOMOBILE REBUILDING - MAINTENANCE  ....     358

 X-38     POLLUTANT REDUCTION ESTIMATES NORMAL PLANT
          LOAD - AUTOMOBILE, BUS AND TRUCK PARTS
          REBUILDING	     360

 X-39     POLLUTANT REDUCTION ESTIMATES NORMAL PLANT
          LOAD - BUS AND TRUCK REBUILDING . .	. .	     362

 X-40     POLLUTANT REDUCTION.ESTIMATES NORMAL PLANT
          LOAD - BUS AND TRUCK MAINTENANCE -",..	     365

 X-41     POLLUTANT REDUCTION ESTIMATES NORMAL PLANT
          LOAD - RADIATOR SHOPS . . . .		     36?

 X-42     POLLUTANT REDUCTION ESTIMATES NORMAL PLANT
          LOAD - AIRCRAFT REBUILDING	     369

 X-43     POLLUTANT REDUCTION ESTIMATES NORMAL PLANT
          LOAD - AIRCRAFT MAINTENANCE			     372

 X-44     POLLUTANT REDUCTION ESTIMATES NORMAL PLANT
          LOAD - RAILROAD REBUILDING .,			     374

 X-45     POLLUTANT REDUCTION ESTIMATES NORMAL PLANT
          LOAD - RAILROAD MAINTENANCE 	     376

 X-46     POLLUTANT'REDUCTION ESTIMATES NORMAL PLANT
          LOAD - OFFICE MACHINE MANUFACTURING  	     378

 X-47     POLLUTANT REDUCTION ESTIMATES NORMAL PLANT
          LOAD - OFFICE MACHINE REBUILDING ....'	     380
                                x

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Figure
II-2
III-2
IX-1
                         LIST OF FIGURES
          VOLUME OF WASTEWATER GENERATED BY
          INDUSTRIAL CATEGORY	 	
          SUMMARY OF RAW WASTEWATER LOADS BY
          INDUSTRIAL CATEGORY.	
          CURRENT REGULATORY COVERAGE OF METALS INDUSTRIES
          AND MACHINERY MANUFACTURING AND REBUILDING...

          ORGANIZATION OF THE MACHINERY MANUFACTURING
          AND REBUILDING PROJECT AREA		
          SUMMARY OF RAW WASTEWATER LOADS BY  INDUSTRIAL
          CATEGORY .......... ... ............... . ____ ....
Page


  10


  11


  46


  47


 191
                               xi

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         MACHINERY MANUFACTURING AND REBUILDING PROJECT

                        EXECUTIVE SUMMARY




The U.S. Environmental Protection Agency has conducted a prelimi-

nary study of  machinery manufacturing,  rebuilding, and  mainte-

nance facilities because of  concern for the potential  discharge

of toxic and hazardous pollutants and in response to findings and

recommendations made in the  Domestic Sewage Study.  The  purpose

of the machinery manufacturing and rebuilding (MM&R) project  was

to prepare a  preliminary data  summary to assist  the Agency  in

deciding whether to develop national effluent limitations  guide-

lines and standards for  MM&R facilities.  This preliminary  data

summary includes two studies:  a  technical support study and  an

economic impact and cost effectiveness study.
Currently, the scope of  the MM&R project  is broadly defined  to

include  all  facilities  which  perform  any  one  of  45  major

wastewater-generating  metal   processes  on   machinery.    This

includes industries related  to transportation, office  machines,

electronic and electrical equipment and machinery, laboratory and

medical instruments, household appliances, industrial tools,  and

other miscellaneous manufacturing  and repair.   In total,  there

are an estimated  970,000 facilities which  potentially could  be

covered by regulation.   These facilities  are presently  unregu-
                                                               ^
lated,  i.e.,  not   covered  by   national  effluent   discharge

regulations, though many  may be covered  by individual  permits.

                                 1

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Preliminary data  evaluations  were  based  on  data  from  about



278,OOO facilities  with more  than nine  employees.   Sufficient



data for evaluations were not available for the remaining facili-



ties.







For the purpose of  performing preliminary evaluations, new  data



were collected from facilities  in the transportation and  office



machine industrial  sectors.  These  data  on the  metal  process



operations were used  to develop  a data base  for 11  industrial



segments for which preliminary economic and environmental assess-



ments were done.  Currently, the project area is divided into  15



industrial sectors and 43 segments.
The results of the preliminary analyses indicate that  discharges



of pollutants from MM&R  facilities are environmentally  signifi-



cant and that developing a regulation to control these discharges



is appropriate.  MM&R facilities generate raw wastewater contain-



ing 68 million kilograms per year (kg/yr) (150 million pounds per



year (lbs/yr» of toxic metals, 16.5 million kg/yr (36.3  million



Ibs/yr) of toxic organics (including cyanide), and 3,40O  million



kg/yr (7,50O  million Ibs/yr)  of conventional  pollutants.   The



total wastewater  flow  estimated  for  MM&R  facilities  is  2.4



trillion liters per  year (63O  billion gallons  per year).   The



MM&R raw  wastewater flow  and  pollutant loading  estimates  are



based on  data representing  about 278,000  facilities with  more



than nine employees.

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                           SECTION II

                            FINDINGS             .-•:-,'.''-.



This section presents  a summary  of findings  for the  Machinery

Manufacturing and Rebuilding (MM&R), project area.



SUMMARY OF FINDINGS



The study  of the  MM&R project  area resulted   in the  following

findings:                                                        "


1.  The number of facilities, wastewater flow, and pollutant
    loads (toxic and nonconventional) are significant.


The MM&R project area  includes approximately 97O.OOO   facilities

engaged in  the  manufacturing,  rebuilding,  or maintenance  of

machinery, including 'transportation,  office machines,  electronic

and electrical equipment  and machinery,  laboratory and  medical

instruments,  household  appliances,  and   industrial   tools   and

equipment.  Approximately 70  percent of  the facilities   involve

transportation and office machines.   An estimated 67  percent  of

the facilities have  less than  10 employees.
 The total  wastewater  flow estimated for  MM&R facilities is  2.4

 trillion liters   per year  (63O billion  gallons per  year).   As

 shown in Figure   II-1 (page  10),  this is  of the  same order  of

 magnitude  as other previously regulated categories.

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 MM&R facilities  generate raw  wastewater containing  68  million

 kilograms per year (kg/yr) (150 million pounds per year (Ibs/yr))

 of toxic  metals, 16.5  million kg/yr  (36.3 million  Ibs/yr)  of

 toxic organics  (including  cyanide),  and  3,400  million  kg/yr

 (7,50O million Ibs/yr) of  conventional pollutants.  Figure  11-2

 (page 11).shows that these raw wastewater pollutant loadings  are

 higher than the loadings for other regulated categories,  with the

 exceptions  of the Iron and Steel and the Metal Finishing   Catego-

 ries.   The  MM&R raw wastewater  flow and pollutant loading  esti-

 mates  are  based on  data representing   about 2?8,OOO  facilities

 with more  than  nine  employees.    Sufficient  data  to   develop

 estimates for the remaining facilities  were  not available.    Over

 9O percent  of the  remaining facilities are   small (less  than  1O

 employees)  and have not been characterized by the  available  data

 which  are based on larger  facilities.


 2.   This  study largely confirmed  the findings of the  Domestic
     Sewage  Study with respect to  the MM&R project  area.


 The  Domestic   Sewage   Study (DSS)  raised the concern  that  the

 discharge of   toxic   pollutants   is  a   threat   to   the  treatment

 capability of many  POTW.   The discharge   of  these  pollutants   to

 surface water   is also  a serious  problem, affecting  the  NPDES

 Program.  The MM&R  project study confirmed   the findings of  the

DSS  that,  because  of  the  large  quantities  estimated,   the

discharge of  hazardous  waste  to POTW  by  MM&R   facilities   is

significant.   As  discussed  in  Section  #1  above,  wastewater

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pollutant loadings from MM&R facilities are large.  "Current  data

indicate that 7O percent of MM&R facilities discharge to POTW and

1O percent discharge  directly to surface  waters.  Over half  of

the indirect dischargers studied  have oil separation  treatment,

but only 30 percent use chemical precipitation and  sedimentation

technology.  About 75 percent of direct dischargers studied  have

at least  chemical  precipitation  ,and  sedimentation  treatment.

These preliminary findings show that a significant portion of the

pollutant load from MM&R  is being discharged untreated  directly

to POTW and surface waters.


3.  A comprehensive MM&R regulation will address a regulation gap
    now managed by Best Professional Judgment (BPJ) or local
    limits.


Current  federal  regulations  allow  major  gaps  in   coverage.

Specifically, gaps in regulatory  coverage occur  in the  electro-

plating, metal finishing,  and electrical  and electronic  compo-

nents categories.  Some permit writers, faced with these gaps   in

regulatory coverage, have been applying electroplating and  metal

finishing regulations  to  MM&R  facilities,  resulting  in  non-

uniform  regulatory  coverage.   The  electroplating  and   metal

finishing regulations were developed based on 13,50O  manufactur-

ing facilities which perform electroplating operations.  The MM&R

project area  includes 970,OOO  facilities engaged in  manufactur-

ing,  rebuilding,  or maintenance.  BPJ permits allow for  inconsis-

tent  controls and limitations,   thus impacting water quality  and

POTW  sludges.

                      '        '   5   '

-------
4.  Concentration  of pollutants  in MM&R wastewater  are  found
    at  treatable levels  and are  as high,  and  in  some  cases
    higher  than, concentrations  of pollutants found in
    wastewater  from other  regulated categories.


Wastewater  from MM&R unit  operations was  characterized  by concen-

trations of toxic  metal  pollutants  as  high as 91,OOO  milligrams

per liter (mg/1),  and concentrations of toxic organic  pollutants

as high as  4,27O mg/1.   Oil and  grease  and total  suspended  solids

were measured in MM&R wastewater  with  concentrations as high  as

336,070 mg/1 and 64,OOO  mg/1,  respectively.
The concentrations of pollutants measured  in MM&R wastewater  are

treatable by  technologies demonstrated  in previously  regulated
                                                        ">! . • 	
categories (Aluminum  Forming, Copper  Forming, Iron  and  Steel,

Metal Finishing, Nonferrous Metals Forming, and Monferrous Metals

Manufacturing).  These treatment technologies include oil separa-

tion (oil skimming),  cyanide precipitation (where  appropriate),

chromium reduction (where  appropriate), chemical  precipitation,

sedimentation, and multimedia filtration.


5.  Preliminary findings show that a comprehensive rulemaking for
    the MM&R project area may be a major regulation.

                               ".'••...,.• ii;  , , ii   ,-  ,,      >•	•••
Given the large  number of  facilities that might  be covered  by

regulation of the entire MM&R category, the estimated control arid

treatment costs  would likely  be sufficiently  high to  classify

this project area as a  major regulation, requiring a  Regulatory

Impact Analysis  (RIA).  Executive  Order 12291  requires EPA  to

                         	  '  :    6

-------
conduct an RIA for any regulation that imposes an annual cost  to



the economy of $1OO million or more.  Preliminary cost, estimates



for MM&R direct  dischargers are  $55O million  capital and  $310



million annual (May 1988 dollars).   Estimated costs for  indirect



dischargers are  $5.6 billion  capital and  $3.2 billion  annual.



These costs are preliminary (i.e.,  based solely on one  treatment



option — lime, settle, and filter) and do not take into  account



reductions which may be  attained through alternative  regulatory



approaches such as  best management  practices.  The  preliminary



costs were  estimated for  11 transportation  and office  machine



segments,  representing  coverage  of  approximately  50  percent



(147,000 out of 278,000)  of the facilities  in the MM&R  project



area known at the time the cost analysis was conducted.







6.  MM&R operations impact hazardous waste disposal.
Some MM&R operations generate  hazardous solid waste and  sludge,



although the   total quantity  generated is  not known  currently.



Analytical data   collected at  MM&R  facilities  (46 samples  were



analyzed) showed  that  2O  percent of the  solid waste arid  sludge



samples analyzed  were hazardous or  potentially  hazardous.    A



promulgated MM&R  regulation could result in a reduction of   solid



waste  and  sludge by   using waste  minimization and  control  and



treatment techniques.

-------
 7.
Some MM&R  segments  may sustain  significant  economic  and
financial impacts if a national effluent guideline regula-
tion is developed for this project area.
 With the exception of the treatment costs estimates,  the Economic

 Impact Analysis  was based  exclusively  on data  from  secondary

 sources.  Since elasticities  of demand were  not available  from

 these sources,  the analysis assumed  zero cost pass  through 	   a

 conservative, worst case assumption.




 The motor  vehicle service-related  segments  would be  the  most

 severely affected.   The Radiator Rebuilding segment would sustain

 the  most  severe  revenue  impact;   annualized  treatment  costs

 represent 6.5 percent of  their  annual  revenues.   The  Automobile

 Rebuilding and  Maintenance  segment and the Automobile,  Bus  and

 Truck Parts Rebuilding  segment  could  incur  moderate   revenue

 impacts   and  severe  profit  impacts.    The average  Automobile

 Rebuilding and  Maintenance  facility   would sustain  a   revenue

 impact of about  1.4 percent  and  a  profit impact  of almost  35

 percent.   This  profit impact means that if  facilities are  unable

 to pass on any of  their   treatment costs in  the form of  higher

 prices, profits  could  be  reduced by   35 percent.   The  average

 Automobile, Bus and  Truck  Parts Rebuilding establishments  could

 incur a revenue impact of  1.9  percent and a profit impact of  48

percent, assuming no  cost pass through.   Other segments which may
                                 8

-------
sustain less severe, but notable, impacts include Trucking firms,

Aircraft Rebuilding, Office Machine Rebuilding and Office Machine

Manufacturing.


8.   The  cost-effectiveness  of   treatment  technology   varies
     considerably across the MM&R segments considered.


The cost-effectiveness analysis estimated the annualized cost per

pound of pollutant removed and per pound-equivalent of  pollutant

removed for the  one control option  considered by the  technical

analysis.  Based on  the cost per  pound-equivalent removed,  the

control option considered is  most cost-effective for the  Office

Machine Manufacturing ($19 and  $46 per pound-equivalent  removed

for direct and indirect  dischargers, respectively) and  Aircraft

Rebuilding ($28 and $126 per pound-equivalent removed for directs

and  indirects,  respectively)  segments.   It  is  least   cost-

effective for Bus and Truck  Rebuilding ($39,486 and $43,434  per

pound-equivalent removed  for  direct and  indirect  dischargers,

respectively) and Bus  and Truck Maintenance  ($3,627 and  $8,O77

for  directs  and  indirects,  respectively).   Cost  per  pound-

equivalent removed for the remaining segments range from $125  to

$1,791 for  direct  dischargers  and  from  $158  to  $8,O61  for

indirect dischargers.

-------
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                           SECTION III



        .                 PROJECT PROFILE








INTRODUCTION







This section provides  an overview and  historical background  of



the machinery manufacturing and  rebuilding (MM&R) project  area.



It includes the regulatory history  of the project, a  definition



of the project area, and a summary of the population,  operations



performed,  wastewater  generation,   and  wastewater   treatment



characteristics.  Tables and figures are  included at the end  of



the section.








The MM&R  project evolved  as  a result  of the  1976  Settlement



Agreement with the  Natural Resources Defense  Council and  other



environmental groups, and also as a result of the 1986 report  to



Congress on the discharge of  hazardous wastes to publicly  owned



treatment works (POTW).  Analysis, of these two sources  revealed



that there is a significant  gap in national effluent  regulatory



coverage in the metals industries area.  Specifically, there  are



many facilities which are not presently regulated and are causing



environmental problems.   Review  of the  existing  coverage  and



problems at POTW show a  workable scheme for data collection  and



analysis.
                                 13

-------
Data for the project  collected from  1986  to  1989 indicate  that



the project scope includes 970,000 facilities  of diverse size and



complexity.  These facilities  range  from  less than   10 to  50OO



employees in size  and perform one  or more of 45 major  process



operations which discharge wastewaters, primarily to POTW.







Initial estimates indicate that 7O percent of  the facilities  are



indirect dischargers, 10  percent are direct   dischargers and  20



percent do  not discharge.   Facilities included  in the  project



area account for  45 percent of  all non-agriculture   employment.



The focus of the data collection effort for this preliminary data



summary encompassed  278,OOO  facilities  or 3O  percent  of  the



project area.   It is  estimated  that these   278,OOO  facilities



generate 84.5  million kilograms  (186 million pounds) of  toxic



pollutants and 3,40O million kilograms (7,500  million  pounds)  of



conventional pollutants annually.







The MM&R project area is under the authority of the Federal Water



Pollution Control Act as amended  (the Act, sometimes  called  the



Clean Water Act or CWA).  On August 25, 1988 (53 FR 32584),  MM&R
                      ";    . i  ,•      ,n   „ .    ,' „ ,    • ! , '    '"   •  ,' ',    "'i1 ' v ,!!'', ";l"


was identified  as a  project for  study under the directive  of

                                           :	  ••' '• '  /r:'! •  /•  ' -I ',,	":"l

Section 304(m) of the Act.
                                 14

-------
BACKGROUND







The Clean  Water Act,  as  amended, establishes  a  comprehensive



program to  restore  and  maintain the  chemical,  physical,  and



biological integrity of the  nation's waters.  Specifically,  the



Act requires the promulgation  of effluent limitations and  stan-



dards for  existing  and  new  dischargers  from  categories  and



classes of point sources.







When the .effluent regulations were  not promulgated by the  dates



contained in the 1972 Act, the Natural Resources.Defense  Council



and several  other  environmental  groups sued  the  Agency.   In



settlement of this lawsuit, a "Settlement Agreement" was approved



by the Court  (June, 1976)  which required the  development of  a



program to adhere to a schedule for promulgating effluent regula-



tions for 21 point source categories for 65 "priority" pollutants



and classes  of pollutants  (Natural Resources  Defense  Council,



Inc. ,1 et. al v. Train. 8  ERG 212O (D.D.C. 1976), modified  March




9, 1979).







The 21  point  source categories   listed  in  Appendix  B  of  the



Settlement Agreement included two which are relevant to the  MM&R



project,  the  Machinery  and  Mechanical  Products  Manufacturing



Point Source Category (the M&MP category), and  the Electroplating



Point Source  Category (Table  II1-1,  page 32).   The  Agreement
                                  15

-------
listed each point source  category as well as  the Standard   Indus-


trial Classification  (SIC)  code number  for  those types  of  facili-


ties to be included in each category.   With the exception  of   the


auto and  other laundries   point source category, all  SIC code


listings included facilities performing manufacturing   activities


as opposed  to those  facilities  performing  service  and   repair
                                            ; "  i      ," '•'    i' '   ,   , '

types of activities.





When the Settlement Agreement was modified  in 1979 by including a


specific promulgation date  schedule,  the M&MP category had been


divided into ten industrial categories  (Table III-2, page  33).  A


detailed analysis  was conducted  to separate  the M&MP category


into individual categories.   This analysis, which  was based  on


process operations, water use,  economic indicator data, and   SIC
                                              	   ,       , i",  ' '    •* •
code groupings,  shows  the mechanical  products  category,  with


about 89,OOO facilities covered, to  be the largest, followed  by


electroplating  with  about 13,5OO  facilities.   This analysis


considered only those facilities engaged in manufacturing activi-


ties.





During the  period between   1977 to  1984, these  ten   industrial


categories as well as  electroplating were analyzed, and  regula-


tions were  promulgated  as  appropriate.   An  analysis  of   the


regulatory coverage of these regulations revealed that  there is a


significant number  of dischargers  (over 89,OOO)  that were  not


considered for regulation.
                                 16

-------
According to  the preamble  to  the metal  finishing  regulation,



there are  about  13,5OO facilities  which  would be  covered  by



either the  electroplating  or the  metal  finishing  regulation.



This estimate agrees with  the original analysis which  estimated



that there are about 13,OOO electroplating facilities.  The metal



finishing regulation (40  CFR Part 433),  as promulgated in  1983



(48 FR 32462, July  15, 1983), applies  only to facilities  which



perform one  or  more  of six  major  processes  associated  with



electroplating (electroplating,  electroless plating,  anodizing,



chemical conversion coating,  chemical etching  and milling,  and



printed circuit board  manufacturing).  Any.  facility which  only



performs some  of  the  4O  additional  metal  finishing  process



operations  on  metals  is  not  regulated.   The  electroplating



regulation (4'O CFR Part 413) presently covers indirect  discharg-



ing job shop  electroplaters who  were performing  electroplating



operations prior to August  31, 1982.  Therefore, the  mechanical



products category which includes 89,OOO facilities is not covered



by national effluent regulations.







Another analysis,  The Report  to Congress  on the  Discharge  of



Hazardous Wastes to Publicly  Owned Treatment Works (EPA  53O-SW-



86-OO4, February 1986), referred to as the Domestic Sewage  Study



or DSS,  also revealed  that  there is  a significant  number  of



facilities discharging pollutants to POTW  which are a threat  to



the treatment capability of the  POTW.  These pollutants are  not
                                 17

-------
regulated by national  effluent regulations.  Some  of the  major


areas identified were  in the metals  industries areas,  particu-


larly an area called  equipment manufacturing and assembly.   The


DSS estimated that this category discharges 7,715 metric tons per


year of priority hazardous  organics which are presently  unregu-


lated.   Data  on  priority  hazardous  metals  discharges   were ,


unavailable for this category.
Based on a preliminary review of the regulatory coverage for  the
                                          f  ',n ' „   "  "     •        "' '

metals industries processing  functions and the  DSS, a  decision


was made to perform a detailed analysis on the unregulated  areas


for metals  industries.   The result  of  this analysis  was  the

                                        	 • I ;        is  ,,    ,     , , , '
development of the machinery manufacturing and rebuilding project


area.


                                           '• ,i J'   .'    '  • ,       '  . '  ' '•„ '• •"



PROJECT ANALYSIS






The project analysis proceeded in three stages.  The first  stage


consisted of reviewing existing  information to define a  project


area and  identify the  population  for evaluation.   The  second


stage consisted of refining existing information and planning for

                                           i          '      "   • '  i , !'

the  collection  of  additional  information.   The  third  stage


consisted of collecting new information  which could be used  for


quantifying the significance of the environmental problems caused
                                 18

-------
by this particular  project area.  A  summary of the  information



collected is in Table II1-3, page 3M.








Review of Available Information







The initial approach used for  evaluating the gaps in  regulatory



coverage and  the problem  areas  identified by  the DSS  was  to



review all existing data bases in the metals industries areas  to



determine what  information had been collected.







The initial  analysis  in   1986 of  the  coverage  of the   existing



regulations for metals  industries revealed  that  the major gaps  in



coverage were  in  the metal  finishing  regulation.   The  analysis  of



the mechanical  products manufacturing   category in   1977  showed



that  there were 89,OOO facilities performing  process  operations



on metals  not associated   with  major  electroplating  processes.



The final metal  finishing regulation was  intended  td cover  the



 13,50O facilities which perform electroplating   and  in   addition



may perform one  or more of  the 40  other  process operations  on




metals in a manufacturing  setting.







 The  1986 analysis showed that three regulations were  promulgated



 for  metal manufacturing  (the iron and  steel, nonferrous  metals



 manufacturing and ferroalloy  categories); five regulations  were



 promulgated for metal forming (the iron and steel, metal  molding
                                  19

-------
 and casting,  aluminum forming,  copper forming,  and  nonferrous


 forming categories);  and that  although four  regulations  (coil


 coating, porcelain enameling, battery manufacturing, and electri-


 cal and electronic component manufacturing) had been  promulgated


 for the component  finishing of mill  products, the coverage  was


 incomplete.  This left a large area of metals industry  functions


 unregulated.  (Figure II1-1, page 46.)





 During this same time period, the DSS was published.  This report
                                              (";'   i .,      •     '• ,

 substantiated the fact  that a  major group  of facilities  which


 performs various processes  on metals are  unregulated.   The  DSS


 referred  to  this  group  as  the  equipment  manufacturing  and


 assembly  category.    This  category  included  facilities  which


 manufacture  such   products   as   office   machines,   household


 appliances,  scientific  equipment,  and  industrial machine  tools


 and  equipment.    Further  review   of  the   DSS  revealed   other


 categories  which were  related  to metals  industries, namely  the


motor vehicle  category, which includes servicing  of  new and  used


 cars, and   engine and  parts  rebuilding;  and  the  transportation


services category,  which includes   railroad   operations,   truck


service and  repair, and  aircraft  servicing and  repair.   This


highlighted  the   fact  that  service-related   facilities    which


previously had not been considered for effluent regulations  were


causing treatment problems at POTW and should be evaluated.
                                 20

-------
At this  point  the  MM&R analysis  consisted  of  attempting  to



determine an approach  for studying  the types  of facilities  in



these categories.   Following  an  engineering  analysis  of  the



existing data, the determination was made that any one or all  of



the currently unregulated facilities  are performing a series  of



process operations on  metal parts.  Also,  these facilities  are



performing these operations  in a manufacturing  setting or in  a



repair or maintenance setting.







This analysis recognized that.metal parts could be referred to as



machines or machinery.  These metal parts or "machines" could  be



manufactured, rebuilt, or  maintained by undergoing  a series  or



sequence of  process  operations in  a  machinery  manufacturing,



rebuilding, or maintenance facility (defined in Table III-4, page



35).  These definitions would cover almost all of the  facilities



in the  metals   industries  area  which  were  unregulated.   The



project at this  time was referred to as the machinery manufactur-



ing, rebuilding  and maintenance project.







Refinement of Available Information







Once the scope of  the project area had been defined, the existing



data were  reviewed  to  formalize definitions  for  the   various



process operations performed on machines, and to establish a more



accurate estimate  of the  number of  facilities in  the   project
                                  21

-------
area.   A   review  of  all  existing   metals  industries   regulations


resulted  in  a  list  of 45  major  unit   operations  which  can   be


performed on machines.  These  major metal processing   operations


include various  sub-operations  directly  related   to   the  major


operation (Table  III-5, page 36).   For  example, the unit   opera-


tion acid treatment includes  acid cleaning,  acid chemical  etch-


ing, and  pickling as sub-operations.





The initial number  of facilities   in the project area  was   deter-


mined by  using  Dun  & Bradstreet information  and Standard   Indus-


trial Classification (SIC)  codes  for facilities  which would   be
                                     1' "I '     •'' :' ','','',' • "   '    ,'  '.' ' •. 1 :

involved  in the manufacture, repair, or  maintenance of  machines.


This included anything  from manufacture  of appliances  and   house-


hold electrical equipment to  the  maintenance of air   transporta-


tion equipment.   This analysis showed there were 278,OOO  facili-


ties with more  than  nine employees in the project  area.   At  the


time, data on the number of facilities with less than  1O  employ-


ees were  not available.





In April  1989, Dun & Bradstreet released new  data on all   facili-


ties (i.e., facilities with one  or more employees).  These  data


revealed  that there  are  approximately 970,000 facilities  in  the


MM&R project area.
                                 22

-------
A review of the types of facilities included in the project  area



led to  two  conclusions.  One  was  that the  population  to  be



immediately evaluated was too large and complex to do a  prelimi-



nary evaluation  of everything  at once.   The determination  was



made to focus  initially on  two major  industrial sectors  which



would envelope almost  all of the  unit operation variations  for



manufacturing and rebuilding.  The  two industrial sectors  which



fulfilled these needs were the transportation and office  machine



sectors.   These  sectors  encompass  a  population  of   147,OOO



facilities or about  half of  the known  project population  with



more than nine  employees (278,000).  The  second conclusion  was



that maintenance operations appeared to be a subset of rebuilding



type operations and that in many instances could not be separated



from rebuilding  operations.  The  project area  then became  the



machinery manufacturing  and rebuilding  project, or  MM&R,  with



maintenance included as a subset of rebuilding.







The approach  for summarizing  existing data  and collecting  new



data for the MM&R project was based on the engineering assumption



that the types  and quantities  of pollutants  generated by  MM&R



facilities would vary  by the  process operation  performed on  a



particular metal.   This assumption  was applied  to all  of  the



industrial  sectors  evaluated.   This  concept  or  approach  is



summarized in Figure  III-2, page  47.  Existing  data were  then



evaluated to  find  out the  amount  of data  available  on  each
                                 23

-------
operation which would   contain production,   flow,  and   analytical



information.  New data  would be  collected on as many processes as



possible with the project  resources available.







Collection of New Data








In addition  to the  compilation of  existing data for the  MM&R



project, new data were  collected from  1986-1988.  This  included



data from meetings with nine trade associations, Bureau of Census



information, 21 engineering visits (including 4 military instal-



lations), 7 sampling visits, a  voluntary telephone survey of  38



companies,  data   collection   portfolio  surveys   from   eight



companies, and miscellaneous discussions with and  data   collected



from control authorities.








Available resources limited the amount of new data which could be



collected for  the  MM&R  project area.   However,  for  sampling



visits, sites were selected  which would provide analytical  data



on as many process operations  as possible.  Once collected,  the



data were evaluated for  deciding on the  best approach  for  pre-



senting a preliminary profile of MM&R.








The initial  approach used  consisted  of segmenting  the  trans-



portation and office machine sectors  into 11 segments for  which



pollutant loadings,  economic  impacts, and environmental  impacts
                                 24

-------
could be evaluated.  .These 11 segments  represented coverage  of



approximately 50 percent (147,000 out of 278,000) of the  facili-



ties in  the MM&R  project  area with  more than  nine  employees



(Table III-6, page  38).  The 11  segments currently account  for



about 15 percent of the total MM&R population.      ,







Raw wastewater  pollutant  loadings  were estimated  for  all  11



segments,  which encompassed rebuilding and maintenance operations



(10 segments) and  manufacturing operations  (one segment).   The



approach was to use these estimates .for filling gaps in the  data



for the remaining MM&R facilities based on the ratio of number of



facilities.  The remaining  facilities are  primarily engaged  in



manufacturing.








After completing the pollutant loading estimates, a comparison of



manufacturing and rebuilding loadings for office machines  showed



that the ratio of facilities was not an adequate characterization



of  the  relationship  between  loadings  for  manufacturing  and



rebuilding.  Within  the office  machine segments,  the .measured



pollutant loadings  for  manufacturing  were  several  orders  of



magnitude greater  than the  loadings for  rebuilding, using  the



ratio of facilities.







The approach for  estimating pollutant loadings  was revised  for



the remaining  manufacturing  facilities.  The  revised  approach
                                 25

-------
included review and identification of  data in the Machinery  and

Mechanical Products category record  and an estimate of  loadings

for manufacturing  facilities independent  of the  new data  col-

lected for  the  11  segments.  The  M&MP  data  identified  were

compiled in 1975, but were sufficient for developing  preliminary
            ''         '        '             ' '' ' III'  '" „,  ,  '"',    "' '
estimates of the pollutant  loadings.  Pollutant loadings for  31

manufacturing segments were estimated.




In the process  of performing this  analysis,  the remaining  MM&R

facilities were  placed in  sectors .according  to four-digit  SIC

codes.  The  result was  15 industrial  sectors comprised  of  43

segments within the  MM&R project  area (Table  III-7, page  39).

The transportation sector  was divided into  six sectors:   motor

vehicle, bus  and truck,  aircraft,  space,  railroad,  and  ship.

This realignment would not affect the economic and  environmental

impact analyses  significantly,  since the  types  of  facilities

within the new sectors did not change.




MM&R PROFILE




Number of Facilities




According to 1986  Dun & Bradstreet  estimates, the MM&R  project

area consisted of  278,000 commercial facilities  with more  than

nine employees which  are located throughout  the United  States.
                                 26

-------
In.April 1989, this estimate  was revised to include all  facili-



ties (i.e., facilities with one or more employees).  As a result,



the MM&R project area  consists of approximately 970,OOO  facili-



ties, including 329,000  with more than  nine employees.   Intui-



tively, facilities which are  service-related are more likely  to



be located in populated areas.  In addition to commercial facili-



ties, military installations included in the MM&R population  are



scattered throughout the United States.







Although estimates for determining  the.number of facilities  are



based on Dun  & Bradstreet,  other sources  of information  which



became available  during the  project  study were  evaluated  and



compared with the Dun & Bradstreet totals.  One source. The   1984



Service Job Analysis (Hunter  Publishing, Des Plaines,  Illinois)



reported that the population of automotive service establishments



is approximately 339,000.







After evaluating  the size  and population  of the   MM&R  project



area,  it   can  be concluded  that  although the  totals  are  not



precise, the MM&R population is approximately 970,000  facilities,



larger  than any previous effluent guideline category effort.  For



the  purpose  of  determining  whether   or  not  to  pursue   full



regulatory coverage  for. the  project area,  a sub-population  of



 147,000 was  evaluated  initially.     Within  the  147,000,    21



facilities were  visited   and  the process  operations at  seven
                                  27

-------
 facilities were sampled to  determine the pollutant loadings  and


 wastewater flows,  and to estimate  the cost of compliance for  11

 industrial segments.




 Water Use and Pollutant Loadings




 When  working  with  metal machinery,   water is used  in the  various


 process  operations to treat  and   clean the surface of the  metal,

 to  cool  the surface of the metal  following finishing  operations,

 and to perform  other operations  on the  metal   products such  as

 testing.   Water is also used  for cleaning the  process areas  and

 equipment.  Water  is  used  in manufacturing and  rebuilding facili-
                           "                 • ' .:•' '!       "!  ,, '
 ties  for  the  same  purposes  with  one exception.  In a rebuilding

 facility,  the  initial  process  operation is  disassembly of  the

 used  machinery followed by cleaning.




 Total  wastewater generation  flow  and  pollutant  loadings  for  the

 MM&R  project   area (Table III-8,  page   41}  indicate that   MM&R

 facilities annually   generate 2.4  trillion liters   (630   billion

 gallons) of wastewater   and  84.5 million   kilograms  (186   million

 pounds) of toxic pollutants  from MM&R operations.   In addition,

MM&R  facilities discharge  3,40O million kilograms  (7,500   million

pounds) per year of   conventional pollutants, which  consist   pri-

marily of  oil  and grease  and  total suspended  solids.    These

 totals are based on 278,000  facilities.
                                 28

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Discharge Status








Based on  the information  collected on  MM&R facilities,  it  is



estimated that 7O percent of the plants are indirect dischargers,



10 percent are  direct dischargers,  and 2O percent  do not  dis-



charge process wastewaters.  Because  most of the facilities  are



indirect dischargers, it is expected that problems might occur at



POTW, especially with  respect to the  discharges of  chlorinated



solvents which would cause air pollution problems, and of  metals



which will affect the.final .use of-POTW sludges.  In  particular,



an analysis  of  46 solid  waste  and sludge  samples  from  MM&R



facilities revealed that  20 percent  of them  were hazardous  or



potentially hazardous.







Existing Treatment Technologies







Based on  the MM&R  plants  studied, over  half of  the  indirect



dischargers have oil  separation treatment, but  only 30  percent



use chemical addition and sedimentation or flocculation technolo-



gy.  About 75 percent of  the direct dischargers studied have  at



least chemical  and sedimentation  treatment.  These  preliminary



findings indicate  that a  significant portion  of the  pollutant



loadings from MM&R facilities is being discharged untreated.
                                 29

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Regulatory Control






Presently, there are no national effluent regulations which  were


intended to control wastewaters  from MM&R facilities.  Based  on
                                       1  ' " •  '"I:' ', :;,,;  ,  • : •" ,   ' .••  ;"',.. 	 .''

informal telephone discussions,  various control authorities  and


permit writers have been using  either the rnetal finishing  regu-


lation or local  limits, in  the absence  of national  standards,


where legally feasible.
SUMMARY





A review of the regulatory coverage of metals industries   facili-


ties revealed that there is a significant gap in national  efflu-


e)nt regulations.  This  fact was substantiated  by the DSS which


identified categories including  the equipment manufacturing  and


assembly, the  motor  vehicle, and  the  transportation  services


categories as ones which are causing problems at POTW.  Following


a review  of these  problem  areas, machinery  manufacturing  and


rebuilding (MM&R) was listed as a  study area to be reviewed  for


regulation under  the directive  of Section  3O4(m) of  the   1987


Amendments to the Clean Water Act.
The MM&R project area includes any facility which performs one or


more of the defined 45  major unit operations on machinery  which


is manufactured, rebuilt, or maintained.  Initial estimates  were


that this included 278,000  facilities which were unregulated  by


                                 30

-------
national effluent  limitations  or standards.   This  figure  was



updated to 970,000 facilities  presently unregulated by  national



regulations by including those facilities employing less than  1O



persons.







To estimate preliminary pollutant reduction estimates and perform



economic and environmental impact  analyses for MM&R, two  indus-



trial sectors,  the transportation  and office  machine  sectors,



were selected and  further divided  into 11  segments.  These  11



segments account for 147,OOO MM&R facilities.  To further  define



the contribution  of manufacturing  facilities to  the  pollutant



loadings, the project area was re-divided into 15 sectors and  43



segments.  The analytical  and flow  data for  these 43  segments



(278,000  facilities)  reveal  that  the  discharges  from   MM&R



facilities are significant (84.5  million kilograms (186  million



pounds) of toxic pollutants per year).







Analysis of  the  MM&R project  area  shows that  the  facilities



engaging in  MM&R  are  highly diverse  in  terms  of  wastewater



generation and  amounts of  pollutant discharge.   However,  each



facility uses some  combination of  the 45  unit operations,  and



each discrete unit  operation generates  wastewater with  similar



characteristics  regardless  of  the  facility.   Therefore,   an



important  aspect  to  consider  for  the  MM&R  project  is  the



development  of  a  sound  regulatory  strategy  which  will   be



equitable for all sizes and types of facilities.
                                 31

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                                  Table III-1

                 POINT SOURCE CATEGORIES LISTED IN APPENDIX B
                       OF THE 1976 SETTLEMENT  AGREEMENT
 1.  Timber Products Processing
 2.  Steam Electric Power Plants
 3.  Leather Tanning and Finishing
 4.  Iron and Steel Manufacturing
 5.  Petroleum Refining
 6.  Inorganic Chemicals Manufacturing
 7.  Textile Mills
 8.  Organic Chemicals Manufacturing
 9.  Nonferrous Metals Manufacturing
10.  Paving and Roofing Materials (Tars and Asphalt)
11.  Paint and Ink Formulation and Printing
12.  Soap and Detergent Manufacturing
13.  Auto and Other Laundries
14.  Plastic and Synthetic Materials Manufacturing
15.  Pulp and Paperboard Mills; and Converted Paper .Products
16.  Rubber Processing
17.  Miscellaneous Chemicals
18.  MACHINERY AND MECHANICAL PRODUCTS MANUFACTURING*
19.  ELECTROPLATING*
20.  Ore Mining and Dressing
21.  Coal Mining
*Relevant to Machinery Manufacturing and Rebuilding Project Area.
                                     32

-------
                                  Table III-2

                    INDUSTRIAL CATEGORIES DERIVED FROM THE
           MACHINERY AND MECHANICAL PRODUCTS MANUFACTURING CATEGORY
 1.   Aluminum Forming
 2.   Battery Manufacturing
 3.   Coil Coating
 4.   Copper Forming
 5.   Foundries (Metal Molding and Casting)
 6.   Photographic Supplies
 7.   Plastics Processing
 8.   Porcelain Enameling
 9.   Mechanical Products
10.   Electrical and Electronic Components
                                     33

-------
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                                  Table II1-4

                 DEFINITIONS USED FOR MACHINERY MANUFACTURING
                            AND REBUILDING PROJECT
Machine:  As used for this project, machine is defined as an assembly of parts
operating together to do work.  It is applied technically to any device
increasing intensity of applied force, changing direction of force or changing
one form of motion or energy into another.  Thus the lever, pulley, inclined
plane, screw, and wheel and axle are simple machines.  Complex machines are
complicated combinations of the simple machines.  Certain machines used to
transform some other form of energy (e.g., heat) into mechanical energy are
known as engines.

Machinery Manufacturing:.  Machinery manufacturing is the series of operations
necessary to produce machines primarily from metal parts.  Machinery
manufacturing is generally conducted in a production environment.

Machinery Rebuilding;  Machinery rebuilding is .the series of operations
necessary-to disassemble previously manufactured and used machines into parts
(primarily metal), replace the parts or subassemblies or restore them to
original function, and then reassemble the restored machine.  Machinery
rebuilding is generally conducted  in a production environment.

Machinery Maintenance:  Machinery  maintenance includes the various mechanical
operations on original or replacement parts required to keep machinery in
operating condition.  Machinery maintenance is  generally conducted in a
non-production environment.
                                      35

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                                   Table II1-5

                              MM&R UNIT OPERATIONS
  1.  Abrasive Blasting                   22,
      a.  Bead
      b.  Grit
      c.  Sand
      d.  Shot
      e.  Other
  2.  Abrasive Jet Machining
      (Vapor Blasting)
  3.  Acid Treatment
      a.  Acid Cleaning
      b.  Chemical Etching
          i.    Bright Dipping
          ii.   Other
      c.  Pickling
      d.  Other                           23.
  4.  Adhesive Bonding                     24.
  5.  Alkaline Treatment
      a.  Alkaline Cleaning
      b.  Other
  6.   Anodizing
  7.   Assembly
  8.   Barrel Finishing  (Tumbling)
  9.   Brazing
 10.   Burnishing
 11.   Calibration                          25.
 12.   Chemical Conversion  Coating          26.
      a.   Chromate Conversion Coating      27.
      b.   Phosphate Conversion Coating
      c.   Complex  Oxide Conversion
          Coating
      d.   Coloring
      e.   Passivating
      f.   Other
 13.   Chemical Machining (Chemical
      Milling)
 14.   Corrosion Preventive Coating
      (Other than  conversion coating)
 15.   Disassembly
 16.  Electrical Discharge Machining
 17.   Electrochemical Cleaning
 18.  Electrolytic Cleaning
 19.  Electron Beam Machining
20.  Eleotropolishing
21.  Grinding
 Heat Treating
 a.  Tempering
 b.  Carburizing
 c.  Cyaniding
 d.  Nitriding
 e.  Annealing
 f.  Aging
 g.  Normalizing
 h.  Austenitizing
 i.  Austempering
 j.  Siliconizing
 k.  Martempering
 1.  Malleablizing
 m.  Other
 Hot Dip Coating
. Impact Deformation
 a.  Peening
 b.  Shot Peening
 c.  Forging
 d.  Coining
 e.  High Energy Forming
 f.  Heading
 g.  Stamping
 h.  Other
 Laminating
 Laser  Beam Machining
 Machining
 a.  Turning
 b.  Milling
 c.  Drilling
 d.  Boring
 e.  Tapping
 f.  Planing
 g.  Broaching
 h.  Sawing
 i.  Cutoff
 j.  Shaving
 k.  Shearing
 1.  Threading
m.  Reaming
n.  Shaping
o.   Slotting
p.   Hobbing
q.   Chamfering
r.   Other
                                         36

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                           . Table II1-5 (Continued)

                             MM&R UNIT OPERATIONS
28.  Metal Spraying
29.  Painting
     a.  Electropainting (Electro-
         phoretic Painting)
     b.  Electrostatic Painting
     c.  Other
30.  Plating
     a.  Electroplating
     b.  Electroless Plating
     c.  Immersion Plating
     d.  Mechanical Plating
     e.  Vapor Plating
     f.  Other
31.  Plasma Arc Machining
32.  Polishing
33.  Pressure .Deformation
     a.  Rolling
     b.  Drawing
     c.  Bending
     d.  Embossing
     e.  Necking
     f.  Forming
     g.  Crimping
     h.  Flaring
     i.  Other
34.  Rinsing
     a.  Countercurrent Cascade
     b.  Stagnant Dip
     c.  Recirculating Dip
     d.  Spray
     e.  Other
35.  Salt Bath Descaling
36.  Soldering
37.  Solvent Degreasing (Solvent
     Cleaning)
38.  Sputtering
39.  Stripping
     a.  Paint Strip
     b.  Plating Strip
     c.  Other
40.   Testing
      a.  Dye Penetrant Testing
      b.  Hydraulic Testing
      c.  Other
41.   Thermal Cutting
42.   Thermal Infusion
43.   Ultrasonic Machining
44.   Vacuum Metalizing
45.   Welding
      a.  Gas Welding
      b.  Resistance Welding
      c.  Arc Welding
      d.  Cold Welding
      e.  Electron Beam Welding
      f.  Laser Beam Welding
                                         37

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                                  Table  II1-6

                MACHINERY MANUFACTURING  AND REBUILDING^SEGMENTS
                            FOR NEW DATA COLLECTION
TRANSPORTATION SECTOR

Aircraft Rebuilding
Aircraft Maintenance
Automobile Rebuilding-Maintenance
Automobile, Bus, and Truck Parts Rebuilding
Bus and Truck Rebuilding
Bus and Truck Maintenance
Radiator Shops for Automobiles, Buses, and Trucks Rebuilding-Maintenance
Railroad Rebuilding
Railroad Maintenance

OFFICE MACHINE SECTOR

Office Machine Manufacturing
Office Machine Rebuilding
                                         38

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                             Table III-7

                 Machinery Manufacturing and Rebuilding
                         Sectors and Segments
Sector

MOTOR VEHICLE
Segment
Motor Vehicle Manufacturing Engines ft Trim
Motor Vehicle Manufacturing Bodies
Automobile Operations
Automobile Repair
BUS & TRUCK
Bus & Truck Manufacturing
Bus & Truck Rebuilding & Maintenance
AIRCRAFT
Aircraft Frames Manufacturing
Aircraft Engines & Parts Manufacturing
Aircraft Operations
Aircraft Maintenance
SPACE
(Not segmented)
RAILROAD
Railroad Manufacturing
Railroad Maintenance
SHIP
Ship Repair and Manufacturing
Boat Repair and Manufacturing
Ship Maintenance
Boat Maintenance
OFFICE MACHINE
Office Machine Manufacturing
Office Machine Maintenance
                                        39

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                              Table III-7
                              (Continued)
                  Machinery Manufacturing and Rebuilding
                          Sectors and Segments
 Sector

 HARDWARE
 Segment
 Screw Machine Products
 Metal Forging & Stamping Products
 Metal Spring Products
 Metal Pipes & Valves
 Machine Tools
 Heating Equipment
 Fabricated Structural Metal Products
 ORDNANCE
 (Not segmented)
STATIONARY INDUSTRIAL EQUIPMENT
Heavy Equipment Manufacturing
Industrial Machine & Equipment Manufacturing'
Electrical Equipment Manufacturing
Equipment Rebuilding & Maintenance
MOBILE INDUSTRIAL EQUIPMENT
Industrial Equipment Manufacturing
Heavy Equipment Manufacturing
HOUSEHOLD EQUIPMENT
Residential Equipment Manufacturing
Household Electric Equipment Manufacturing
Household Equipment Maintenance
ELECTRONIC EQUIPMENT
Communication Equipment Manufacturing
Electronic Components Manufacturing
INSTRUMENTS
                                     Measurement & Control Instrument Manufacturing
                                     Specialty Equipment Manufacturing
                                     Specialty Instrument Maintenance
PRECIOUS & NONPRECIOUS METALS
(Not segmented)

  40

-------
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-------
                           SECTION IV
                REGULATORY APPROACH AND STRUCTURE

                                                         f
This section presents the  approaches and structure for  effluent
limitations and  standards for  the Machinery  Manufacturing  and
Rebuilding project.


BACKGROUND


Machinery Manufacturing  and  Rebuilding  (MM&R)  facilities  are
highly diversified in  terms of number  of employees, water  use,
and operating practices.   There are about  970,000 MM&R  facili-
ties, varying in size from small shops with less than ten employ-
ees to large  industrial complexes employing  over 5,OOO  people.
The MM&R  project area  encompasses several  areas of  industrial
activity, including  transportation, office  machines,  hardware,
ordnance,  industrial   equipment,   household   and   electronic
equipment, and instruments.


A common  factor for  all  MM&R facilities  is that  the  process
operations performed  on metals  are  similar at  each  facility.
This holds true for both commercial and military facilities.  The
result is each facility generates the same types of pollutants in
varying quantities.

-------
As discussed in Section III  (page  18), metal finishing facilities

which do not perform one  of the six major electroplating  opera-

tions (i.e., only perform some of  the 40 additional metal finish-
                                            111111            . I ' :f "
ing process  operations) are not  currently regulated.   A  MM&R

regulation  will  include  these   facilities.   Facilities  whose

primary business is metal finishing  will continue to be  covered

by the metal finishing regulation.



REGULATORY STRUCTURE



The regulatory structure is  shaped by the diversity of the  plant
                                           I"  !
types, sizes,  unit  operations, production  accounting  methods,
                                     , ,     "lif  i       j  ' !   '   •   '
water use and wastewater characteristics, economic and  financial
                                              Li    ' , 'i         '•'',•. ,,
capability, and  other prominent  factors identified  during  the

data collection  and  assessment  phases  of  a  project.   These

factors were evaluated in this study for existing data to  arrive

at a potential  regulatory structure for  the MM&R project  area.

Although available data suggest that the regulatory structure for

MM&R should be  based on  the process  operations, the  available

data are not  sufficient to  develop  the regulation.   Additional

analytical, flow,  and  production information  will  be  needed.

Also, additional information regarding each of the factors listed

above is  needed  before  a  final  regulatory  structure  can  be

determined.
                                 50

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REGULATORY APPROACH







The data collected for the MM&R project strongly suggest  conven-



tional engineering approaches to developing effluent  limitations



and standards.  Current practices,  as reflected in the  existing



data, also suggest  some alternative approaches  to reducing  the



release of wastewater and other pollutants into the  environment.



Traditional or  conventional engineering  approaches to  effluent



guidelines  include  both   mass-based  and   concentration-based



limitations and standards.  Alternative approaches under  consid-



eration  include  combined  concentration  and  flow  restriction



alternatives, and  best  management  practices  (including  waste



reduction).  The approaches considered for the MM&R project  area



are discussed below.  Each should be considered in the context of



a practical regulatory structure that accounts for the  diversity



inherent to facilities  within  the MM&R  project area.   Ideally,



the alternative  regulatory  approaches will  achieve  measurable



environmental protection,  while  allowing  financially  burdened



facilities to remain as viable  entities.







Mass-Based Regulatory Approach  and Structure







As discussed  in  Section  III  (page 22), many facilities of  varying



size and with diverse markets  comprise the MM&R project  area.   At



first  glance,   this  would  suggest  that  a common  basis   for
                                  51

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 regulation would be difficult,   if not impossible.   However,   the


 MM&R facilities are held together by a common thread,  namely   the


 major unit operations  performed in  MM&R processes.    Mass-based


 (production-related) effluent limitations  and standards  control


 the discharge of toxic pollutants by providing a discharge allow-


 ance for pollutants per unit of metal processed (i.e.,   manufac-


 tured,  rebuilt  or  maintained).    Mass-based limitations  provide


 technical equality  and fairness   across plants of varying  sizes.


 Large plants  as well as small plants are required to achieve   the


 same degree  of environmental protection proportional   to their


 level of production.
The limitations are  based upon  the  best available  technologies


economically achievable  (BAT).   The production normalization  and


the technology basis for pollutant removal provide for a  consis-
                                       1	- 	                •  	,..

tent application of the  regulation across facilities.  In  cases


where new  wastewater  characteristics and  wastewater  discharge


data show significant  differences in  identical unit  operations


performed on  different  metal   types,  this  approach  may  need


modification to include separate  effluent limitations and  stan-


dards for unit operations by metal type or some other appropriate

                                        •       |        '      •   .   •

factor.  From what has been learned to date, mass-based  effluent


limitations guidelines applied  to the 45  unit operations  would


provide a consistent  means of  controlling pollutant  discharges
                                 52

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across diverse  MM&R facilities,  and would  provide a  practical



regulatory structure for the MM&R project area.







Qualitative and quantitative  analyses of the  data suggest  that



facilities performing the 45 MM&R  unit operations fall into  two



large groups:   manufacturing and  rebuilding (including  mainte-



nance).  The data show that the series of operations required  to



manufacture machinery products  is different than  the series  of



operations to rebuild  machinery products.  Also,  water use  and



wastewater characteristics between  manufacturing and  rebuilding



operations appear  different  (more  .data are  required  to  make



meaningful statistical inferences).  Available data also  suggest



that maintenance operations  are a  subset of  rebuilding and  in



some cases are identical.  The series of unit operations used  in



rebuilding and maintenance are  similar and generate similar  raw



wastewater pollutant loadings.







Alternative Regulatory Approaches







As described  in  Section III,  the  MM&R project  area  includes



facilities ranging  in  size  from small  shops  to large  corporate



industrial complexes.  Although the unit operations performed  at



these  facilities are identical and generally vary only in  number



of process lines, the financial and personnel  resources may  vary



sufficiently  to warrant  consideration of alternative  regulatory
                                  53

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 approaches.   Prior  regulatory  efforts  have  shown  that  plant


 closures as   a result  of  a regulation  usually occur  at  small


 plants.  Generally,   the  small  plants  are  less flexible  finan-


 cially and may  not  be  able to   absorb the  costs of  wastewater


 control and  treatment without some  financial impact.   With  this


 historical perspective  in mind,  alternative regulatory approaches


 for the MM&R  project area   have been   considered.   Clearly,   the


 alternatives ought  to  achieve  the  environmental goals  of  the


 Clean Water  Act  while allowing financially burdened facilities to


 remain economically  viable.




 Two alternative  regulatory   approaches  have  been  identified   and


 are recommended  for   further consideration:   combined   concentra-


 tion and flow restriction guidelines and  best management practice


 (BMP) guidelines.
Although data clearly indicate that mass-based regulations can be


applied to  most MM&R  unit  operations, concentration  and  flow


restriction guidelines may be  appropriate in cases where  waste-


water from a  variety of production  operations are combined  for


treatment.  Flow  limitation and  concentration guidelines  would
                                        . - ,  ..ri'iV '''"-i-,    , '".;, I.-  "'	 ; ,i ': t / '  • i '

limit the quantity  of pollutants discharged  while allowing  the


combining of wastewaters for treatment.

-------
Another approach  is to  develop  best management  practices  for



specific processes when  such practices  could achieve  pollutant




reduction.







BMPs would provide wastewater management techniques for achieving



reduced pollutant discharges while reducing the financial  burden



of traditional  wastewater treatment  systems, since  BMPs  often



require little or no investment in capital equipment.  BMPs could



be a viable  regulatory alternative for  smaller facilities  that



would be disadvantaged financially.







BMPs rely on pollution  reduction techniques  that are  relatively



simple, inexpensive to implement,  and proven effective,  such  as



conscientious  housekeeping  practices,  preventive  maintenance,



source  reduction, and material  reuse.  Since, in many  cases, MM&R



process operations  can be  operated  independently of  one   another,



BMPs might  be  cost  effective for  controlling  pollutant discharges




at  the  process source.
                                  55

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                            SECTION V



            WATER USE AND WASTEWATER CHARACTERISTICS








INTRODUCTION







This section  presents the  water use  and wastewater  character-



istics associated with operations of the Machinery  Manufacturing



and Rebuilding (MM&R) project area.  It includes the approach  to



data collection, type of data collected, water use and wastewater



discharge flows,  raw  wastewater characteristics,  current  dis-



charge and  treatment  practices,  and  solid  waste  and  sludge



characteristics.







As discussed in Section III,  a review of existing metals  indus-



tries regulations resulted in a list of 45 major unit  operations



which can be performed on  machines made of various metal  types.



The approach  to data  collection was  to collect  water use  and



wastewater characteristics data  on as many  unit operations  and



metal types as possible.







Data sources  included  project records  for  prior  regulations,



telephone surveys, engineering site visits, wastewater and  solid



waste field  sampling,  data  collection  portfolios,  and  trade



associations (Table  II1-3, page  34).  Data  were obtained  from



these   sources   by   examining   water   use   and   wastewater
                                 57

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characteristics  measured   for   individual   unit   operations   at
                                      • ,,      L „,  ! „   *     '      , '  '	;
specific  facilities.  Data  obtained  included analytical   (concen-

tration),  flow, and production data.



This section also  includes  a summary of  the current  discharge and

treatment practices at several   MM&R facilities.   An analysis  of

the current discharge  practices determined the  fraction of the

raw wastewater pollutant loadings  that  are currently  discharged

to surface waters  (i.e., direct  dischargers), and  to POTW   (i.e.,

indirect   dischargers).   This  .distinction is  important    when

assessing  the effects of MM&R wastewater on the environment.  The

current treatment  practices described  in this section were  also

used in  Section VIII  to  assess the  costs estimated  for  MM&R

facilities to install and operate wastewater treatment systems.



Finally, this section  includes  a discussion  of analytical  data
                                      *   ." '.  ' in  !• '  '!• ,  ' !'  i ' 'I ' "• • ','>'  ','•,, '"'"
obtained from a solid waste and  sludge sampling program.    Sludge

generated by  specific MM&R  unit  operations and  by  wastewater

treatment  technologies may  impact wastewater management  programs

by increasing the  waste load to  POTW, or increasing the cost of

wastewater treatment.   Further,  the  recently  proposed   sludge

regulations1 require  facilities, including  MM&R  facilities,   to
     1Under Section 405(d) of the Water Quality Act of 1987,  EPA
                                               (Footnote Continued)
                                58

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 closely examine  their sludge  management practices.   For  these

 reasons,  solid  waste  and  sludge  characterization  data  were

 collected from MM&R facilities.



 APPROACH TO DATA COLLECTION



 Forty-five major unit operations  are performed on various  metal

 types to  manufacture and  rebuild  machines.  These  major  unit

 operations include various sub-operations directly related to  the

 .major operation (Table III-5, page 36).  The general approach   to

 data collection was to collect  water use and wastewater  charac-

 teristics data  on as  many unit  operations and  metal types   as

 possible.  This approach was based on the engineering  assumption

 that the types  and quantities  of pollutants  generated  by  MM&R

 facilities would  vary  by  the unit  operation   performed  on  a

 particular metal, regardless of the industrial sector.  In  order

 to fully characterize wastewater  from unit  operations, analytical

 (concentration), flow, and production data  were evaluated for  the

 wastewater streams.
(Footnote Continued)
  is  required  "to  impose  conditions  on NPDES permits issued to POTW
  or   take   other    such   measures   as   the  administrator   deems
  appropriate  to protect  public health and the environment from any
  adverse   effects  which  may  occur   from  toxic  pollutants   in
  wastewater sludges."  EPA has  implemented an interim program  to
  control sludge before technical criteria are developed under  4O
  CFR 503.
                                  59

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Only fully  characterized wastewater  streams can  be  accurately



compared among  facilities and  point source  categories.  It  is



necessary to group these three  types of data, together to  under-



stand the  nature  of  MM&R  processes.   Analytical,  flow,  and



production data  on unit  operations used  in manufacturing  were



available  from  previous  studies  (1976-1982)  and  promulgated



regulations (1981-1986).  Virtually  no data  were available  for



rebuilding and  maintenance processes.   Therefore, the  approach



for gathering sufficient data on the major unit operations needed



to include  two  major  elements:   data  on  .manufacturing  from



existing sources and data on rebuilding and/maintenance  obtained



from new collection efforts.  The new collection efforts included



some manufacturing unit operations where  there were gaps in  the



existing manufacturing data.  Effluent guideline regulatory  data



bases and records examined  for analytical, flow, and  production



data are listed below,  along with the period  in which the  data



were generated.







1.   Aluminum Forming (1979-1983);



2.   Battery Manufacturing (1979-1983);



3.   Beryllium Copper Forming (1985-1987);



4.   Coil Coating (1978-1979);



5.   Copper Forming (1978-1982);



6.   Electroplating (1974-1983);



7.   Iron and Steel Manufacturing (1974-1980);
                                60

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8.   Metal Finishing (1978-1983);



9.   Metal Molding and Casting (1977-1984);



10.  Nonferrous Metals Forming (1983-1984);



11.  Nonferrous Metals Manufacturing (1977-1985);



12.  Porcelain Enameling (1979-198O); and



13.  Transportation (1986).







New analytical, flow, and production data on MM&R unit operations



were collected  from 1986-1988.   The  sources of  data  included



telephone surveys  (1986-1987),  engineering site  visits  (1986-



1987), sampling  visits  (1986-1987), data  collection  portfolio



surveys (1987-1988) and a trade association (1986).  The approach



used for each of these sources is discussed below.  The  informa-



tion collected through telephone screening surveys and  engineer-



ing site  visits  was used  in  the analyses  for  this  document



(described later in this section and in Sections VIII and IX) and



for selecting facilities for the field sampling program.







As described in Section III (page  23), the initial focus of  the



study was the  transportation and office  machine sectors,  which



involved almost all of the unit operations for manufacturing  and



rebuilding.  An engineering site  visit program was conducted  to



obtain data on the unit  operations within these sectors.   Tele-



phone screening surveys were  conducted to select facilities  for
                                 61

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engineering site visits.  Facilities provided data on a voluntary
                                        '.'', '.•• , '•  . •;  ' j I1,,'  '   • .     J  •   > ,'"
basis.




Thirty-eight facilities  provided useful  information during  the

telephone screening surveys.  Engineering   site visits were  con-

ducted at 17 facilities and four military installations.
Candidate facilities for the telephone surveys were selected from

industrial and business  directories, trade association  directo-

ries, and local telephone directories.  Facilities were  selected

for telephone contact because they  fulfilled one or more of  the

following criteria:


1.   Large diversified  manufacturing facilities  with  potential
     for conducting many  different MM&R  unit operations.   This
     judgment  was  generally  based  on  sales  associated  with
     facility,  number  of  employees,  or  common  knowledge  of
     company and products;

2.   Major  transportation  carriers  with  potential  of  having
     extensive maintenance and  rebuilding operations.   Selected
     based on size of company (e.g., number of employees,  number
     of vehicles rebuilt or maintained);
             \           '            •     ',• ''"?• '•        ' " ''':•'  ,'
3.   Facilities that  are situated  in  locations that  could  be
     visited while conserving budget resources; facilities either
     within driving  distance of  Washington, D.C.  or within  an
     industrial hub  (i.e.,  Wichita  for  aircraft,  Boston  for
     computers); and
     Facilities that produce
     industrial segment.
a variety of  products within  each
                                62

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From the results of  the telephone surveys, candidate'- facilities

for engineering  'site visits  were  selected using  the  criteria

above with the addition of the following:


1.   Facilities performing many MM&R  unit operations on  several
     metal types that generate wastewater; and

2.   Facilities operating wastewater treatment systems.


The four  military  installations visited  were  selected  during

discussions with Department of Defense officials.  The  installa-

tions chosen are major  rebuilding and maintenance centers  where

numerous MM&R unit operations are performed.



The field sampling program was a screening study, which  involved

collecting samples from process wastewater streams and wastewater

treatment system streams at seven MM&R facilities.  These facili-

ties participated in this screening  study on a  voluntary  basis.

The screening study was designed to characterize preliminary   the

type of wastewaters typically generated  by MM&R  facilities.



Sampling and analysis protocols  used during the screening  study
   '       ' '   .    .                          *2
are  described   in  other  EPA  documents.    Wastewater  samples
      2"Sampling  and   Analysis  Procedures   for  Screening   of
 Industrial  Effluents for Priority  Pollutants,  "  USEPA,   Effluent
 Guidelines   Division,   Washington,   D.C.    2O46O   (April   1977);
 "Handbook for  Sampling  and  Sample Preservation  of  Water  and
                                                (Footnote Continued)
                                 63

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  collected during the screening study were analyzed for  124 of the

  126  priority  pollutants,3  conventional  pollutants   (oil   and

  grease, TSS, and pH),  and nonconventional organic and   inorganic

  pollutants.  The  nonconventional  pollutants analyzed   are  pub-

  lished in ITD's "List of Analytes," which is a list of  pollutants

  of concern that may be found in wastewater samples.  The "List of

  Analytes" was derived from the "List of Lists", a compilation  of

  substances that pose environmental concerns.  The "Listof Lists"
                                '•',  :;   '' ' •  '  '-i,, i,,! "',;'; i ;   ! • ;	,; i •;'",' L t: "•,_•" : •• ;/, ';
  includes substances  of concern  identified! by  the Agency  while

  conducting air, water, solid  and .hazardous waste, and   Superfund

  programs.
I"! "> >'•
"   '
  Two of the seven MM&R plants sampled operate wastewater treatment

  systems.   Data were collected at these facilities to measure  the

  efficiency of  specific  treatment technologies  on  MM&R  waste-

  waters.   These data are examined in Section VII.
(Footnote Continued)
 Wastewater,"     USEPA,     EMSL,     Cincinnati,     Ohio     45268,
 EPA-600/4-79-020  (March  1983);   "Guidelines  Establishing  Test
 Procedures  for the Analysis of  Pollutants Under the Clean  Water
 Act, 49   CFR  43234  (October 26,   1984); and  "Test Methods  for
 Evaluating  Solid   Waste,"  USEPA,    Office  of   Solid   Waste,
 Washington, D.C.    2C46O,  SW-846,   3rd edition  (November  1986).
 The Toxicity  Characteristic  Leaching Procedure  (TCKP), used  to
 analyze   samples  for  the  Industrial  Technology  Division,  is
 described in  40  CFR Part 268, Appendix 1.

      3Asbestos and dioxin  (TCDD) are  not expected to be  present
 in MM&R wastewaters and were not analyzed for.
                                  64

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The seven-MM&R facilities for wastewater and solid waste sampling

were selected  from the  list of  facilities visited  during  the
     \

engineering site  visit  program.   The  criteria  for  selecting

facilities for sampling included:


1.   Facility performed  manufacturing, rebuilding,  and  mainte-
     nance or some combination of the three, so that unit  opera-
     tions from more than one general operation could be  charac-
     terized with one sampling episode;

2.   Facility conducted  many  MM&R unit  operations  on  several
     metal types.  Sampling would fill  a maximum number of  data
     gaps from operation-metal type combinations;

3.   Facility operated a  wastewater treatment system,  providing
     the opportunity to gather  treatment effectiveness data  for
     MM&R wastewater; and

4.   Facility discharged  industrial  wastewater to  a  POTW  and
     sample characteristics  would  provide data  for  comparison
     with the Domestic Sewage Study.


Additional data were collected from MM&R data collection  portfo-

lios (dcps) sent to eight trucking companies.  The dcps were sent

under authority  of Section  3O8  of the  Clean Water  Act.   The

trucking companies were selected to receive a dcp using the  same

methodology and sources used for selecting site visit  facilities

(described above), with  one exception.   Several small  trucking

:companies were selected to  gather economic information on  small

firms and to  allow comparison  of MM&R  unit operations  between

facilities of varying size.   This dcp survey  was a pretest  and

was  intended to precede a full-scale dcp mailing.  The full-scale

survey  was  not conducted  because of  limited budget  resources.
                                 65

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 Therefore,  the analysis of facilities  of varying size could  not


 be completed due to a lack of data.

           i»                  :             l| , „ ,n ' '  !     '    „• i'   . •  , '  '''
         "        '             ''"  '  I" (   •'' "• • '.,  ' *','' ,„   „            ,      ,

 The  Automotive  Parts  Rebuilders   Association  (APRA)  provided


 sampling data for sludges and  solid wastes  from MM&R  operations


 at automotive  parts rebuilding  facilities.   APRA  compiled  the


 data in  1986.   The  wastes were analyzed using  the  Extraction


 Procedure (EP)  Toxicity test.




.TYPE OF DATA COLLECTED




 Analytical,  flow,  and production data from 559 process wastewater


 streams  collected  for  prior  effluent  guidelines    regulatory


 efforts (1974-1986)  were used in characterizing wastewaters from


 MM&R operations.   The regulations developed with these data apply


 to facilities in  SIC codes that  do not fall within  the MM&R  SIC


 codes.   These data  are useful because  they characterize   waste-


 water from   unit   operations identical  to  those found  in MM&R


 facilities.   These  unit operations  are practiced  in a   similar


 fashion on the  same   metal types, and  therefore are  expected   to


 generate raw wastewaters with similar pollutant loadings.    Thus,


 these data were considered along with the data collected at MM&R


 facilities when performing the analyses for this preliminary data


 summary.  Permit writers have recognized these similarities when


 they  have transferred or  have attempted to transfer   limitations
                                66

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from other  regulations  to  MM&R  facilities.   In  some  cases,



permits have been successfully  negotiated.  In other  instances,



lacking adequate  data, strong  protective permits  could not  be




issued.







The telephone screening surveys (1986-1987) obtained  information



on the unit operations, the metal or alloys processed, water use,



discharge volume, discharge status, type of wastewater  treatment



(if any),  and  disposal  method.  The  engineering  site  visits



(1986-1987) verified this - information and provided more  detailed



information on  process  techniques, water  use,  wastewater  and



solid  waste  generation,  wastewater  treatment,  and   disposal



practices.  The site visits  also confirmed that MM&R  operations



at military installations are identical to operations at  commer-



cial facilities with respect  to operating practices,  wastewater



generation, and wastewater treatment.







The field sampling  program  (1986-1987)  resulted  in  analytical,



flow,  and production data for 129 process wastewater streams  from



seven  MM&R facilities.   Analytical and  flow  data  from  12  waste-



water  treatment system streams were also collected.







The data collection portfolio   surveys (1987-1988)   resulted  in



data on  the   number and  type of unit operations,  water use   and
                                 67

-------
 discharge data,  treatment system data,  and economic and financial
                                               	       c
 information.   The dcp did not provide wastewater analytical data^



 NUMBER OF OPERATIONS CHARACTERIZED



 The sources of data examined  provided data useful for   character-

 izing 24  of the  45 MM&R unit  operations presented in Section  III

 (Table HI-5,  page  36).   Table   V-1  (page 81)   lists  these unit

 operations, and  the number of specific  wastewater streams  in each

 unit  operation   and  sub-operation   that   were   sampled.    Also

 included  at the end  of the   list are   miscellaneous  operations

 associated  with   MM&R unit operations  (e.g.,  wet air  pollution

 control,  floorwash).   Table  V-2  (page   82) lists the MM&R unit

 operations  and their sub-operations that have not yet been   fully

 characterized.   For  these   operations,  either  complete flow and

 production  data  to   support the analytical  data  were not   avail-

 able, or no analytical data were  available (i.e., no  wastewater

 samples were taken).




 The sub-operations are specific types of operations that comprise

 various MM&R unit operations listed  on Table III-1 (e.g.,   bead,

 grit, sand, shot, and other  abrasive blasting comprise the  unit

 operation abrasive blasting).    These sub-operations  may or  may

not generate wastewater.  Further, many of the surface  treatment

sub-operations, such as  acid cleaning,   may generate  wastewater
                                68

-------
from both the spent cleaning  solution and the spent  rinsewater.



Each of  these sub-operations  and wastewater  streams have  been



included on either Table V-1 or V-2, depending on whether or  not



they have been characterized.







WATER USE AND WASTEWATER DISCHARGE FLOWS







In general, water is used  in MM&R operations for surface  treat-



ment and rinsing  of workpieces and  parts, cooling and  lubrica-



.tion, .quenching, spray  booths, testing,  equipment washing,  and



other  miscellaneous  applications.   The  total  raw  wastewater



discharge flow estimated for the  MM&R project area is 2.M  tril-



lion liters  per  year  (63O billion  gallons  per  year).   This



estimate is based on  278,000 facilities or  about 30 percent  of



the entire project area.







Wastewater discharge flow data are  presented by MM&R unit  opera-



tion in  Table  V-3 (page  83)  for the   11  industrial  segments



included in the preliminary  analysis.  The data shown account for



67O billion liters per year  of wastewater discharged.  Flow  data



from all MM&R  industrial  segments  were not  available on  a  unit



operation  basis.







Some unit  operations have   sub-operations that   generate  waste-



water.   For each  wastewater   stream within each operation,  Table
                                 69

-------
                                         i   I'/ll1 „:, ' ' . , '   '  '    ' •  '!•'"' '":,ll!l , ' ," ''ih, ' • ,
 V-3 (page S3) shows the total wastewater discharge.flow in liters


 per year (1/yr),   and the production  normalized wastewater  dis-


 charge flow in liters  per metric ton  (1/kkg) of metal  manufac-


 tured,  rebuilt,  or  maintained.  These two  values are useful  in


 assessing the magnitude of the environmental impact of each  MM&R


 operation.   The  total flow value describes hpw much wastewater is


 discharged  to  the environment  from  each MM&R  operation.   The
                                               ! ,  •    ,i  ' I"! . "• ' iv ,1^1, i' i|	 ,1

 production  normalized flow (PNF)  presents this same  information

                              ,  '  V  '  ;   ' •   •;>,' '	i- •   :;  i- ', V"  ,', >,.'•!••". ;• V
 on  a common mass  basis,   allowing comparison of flow rates  among


 facilities  with .diverse production values.






 Table V-3 shows the relative magnitudes of wastewater flows among


 unit operations within the MM&R project area.   Alkaline cleaning,


 acid cleaning, and plating account for the largest unit operation


 flows.  Total  flows (1/yr) from 17 of the  45 unit  operations  and


 four miscellaneous  operations   are available.   Some  MM&R  unit


 operations  for which total flow data are not available may  be dry


 processes,  and not  generate any wastewater.    In  addition,   some


 MM&R operations may be performed in  either a  w.et  or  dry manner.


 A preliminary  engineering evaluation  of  these unit  operations


 suggests  that most of these unit operations?   are  more likely  to


use water than not.
                                70

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RAW WASTEWATER CHARACTERISTICS





This subsection summarizes  the raw wastewater  data for each  of


the MM&R operations that  are characterized by analytical,  flow,


and production data.  A review of the data show that many of  the


MM&R unit  operations generate  wastewater containing  measurable


concentrations of  toxic  pollutants.   Pollutant  concentrations


found in  MM&R  wastewaters  are similar^bo  concentrations  for


pollutants that were regulated in other point source  categories.
                                              \

Also, many of  the MM&R unit  operation wastewaters have  maximum


pollutant concentrations that exceed the treatment ^effectiveness


concentrations  demonstrated  in  other  regulatory   development

                                      - ~-" ""•>
efforts.





Table V—4 (page 86) shows the maximum concentration measured  for


each pollutant  in  each operation.   The  maximum  concentration


measured gives an indication of the magnitude of the  contamina-


tion present in the wastewater  from each MM&R operation.   Table


V-4 shows pollutant concentrations  measured  below  the  detection


limit as "ND," and pollutants that were not analyzed as "MA."





For illustrative purposes, several  MM&R unit operations  charap-


terized by high maximum concentrations are presented in Table V-5


(page  11O).  As shown  in Table V-5, concentrations  of toxic metal


pollutants as high  as 91,OOO  milligrams per liter (mg/1),  and


concentrations of toxic organic pollutants as high  as 4,270  mg/1


                                71

-------
 were measured in  MM&R wastewater  streams.   Oil  and grease  and
 total suspended  solids were  measured in  MM&R wastewaters  with
 concentrations as high as 336,O7O  mg/1 and 64,000 mg/1,   respec-
 tively.   The specific pollutants  of concern in MM&R  wastewaters
 are discussed in Section VI,  drawing upon the data presented  in
 Tables V-4 and VI-1.

• It is believed that the organic pollutant concentrations  shown in
 Table V-4 and the organic pollutant loadings reported in   Section
 IX are  understated by  a significant  margin because,  for  each
 sample,  only  a  single  dilution was  made  in  preparation  for
 analysis of the organic pollutants.  If the wastewater  pollutant
 matrix was such  that other contaminants  blockred measurement  of
 the organic  pollutants (e.g.,  oily  in nature;  high  dissolved
 solids),  no follow-up analysis was  conducted.   As a result,   the
 analytical detection   limits reported  with the  data were  quite
 high in  many cases.
 For many  of the organic pollutants,  the detection  limits  were too
 high  to characterize the  sample definitively.   Process   informa-
 tion  and  the interchangeability of organic  compounds   demonstrate
 that  the  organic compounds are used  in  MM&R operations.   The  high
 detection limits prevented verification of  the  presence of  these
 compounds.   The interchangeability of organic compounds used  in
 performing the  same   MM&R operation  is   a phenomenon  observed in
 developing other effluent guidelines, including Aluminum  Forming
                                 72

-------
and Nonferrous Metals Forming.  A process solution used in a MM&R



operation may vary slightly  in composition from one  application



to another, but is essentially performing the same function.   An



example of this  is a metal  cleaning solution containing  either



phenol or toluene, both chemicals accomplishing similar purposes.








CURRENT DISCHARGE AND TREATMENT PRACTICES








This subsection summarizes  the current  discharge and  treatment



practices at MM&R facilities.  Based on the information collected



at MM&R  facilities, .it is  estimated  that 1O  percent  of  the



facilities  are  direct  dischargers,  7O  percent  are  indirect



dischargers, and 20 percent are zero dischargers.







Table V-6 (page 112) presents the type of treatment  technologies



currently in use in MM&R facilities, and gives a breakdown of the



percent of total, direct, and indirect dischargers with each type



of treatment  in place.   These data  show that  oil  separation,



chemical treatment, and sedimentation technologies are frequently



found at MM&R facilities.







About 75 percent of the direct dischargers use chemical  addition



and sedimentation  technology.  Over  half of  the indirect  dis-



chargers have oil separation treatment,  but only 3O percent  use



chemical  addition  with  sedimentation  or  flocculation.   This
                                73

-------
preliminary analysis  shows  that  a  significant   portion  of  MM&R


wastewater is discharged untreated directly  to surface  waters and


POTW.  This reinforces  the findings  of  the Domestic  Sewage   Study


that the pollutant  discharges  to POTW   from MM&R facilities are


large.




SOLID WASTE AND SLUDGE  CHARACTERISTICS




MM&R unit operations generate   pollutants that are discharged  in


wastewaters, solid wastes (including.sludges), and air  emissions.


Solid waste  and  sludge  are generated  directly by   MM&R  unit


operations (e.g., machining  fines, dirt  and  grime in sludge  from


alkaline cleaning solution)  or by   wastewater treatment  systems


(e.g., sludge  from a   chemical precipitation  and sedimentation


system).  Solid  wastes  and sludges  may  be disposed  of   in  a


wastewater stream, mixed with   sludges from  wastewater  treatment


operations, or handled  separately under RCRA.    The solid   waste


and sludge  from  MM&R unit  operations  often contain  the  same

                                1 "       .. ; i   ' ' . i   ... •   '  •''  •  ' .
pollutants  as  wastewater   from  these  operations.    For   these
                                      ^     ;v \	j ; ;•.!  "   ' .. '  ...  „;' , '•. „.'' *;„;
reasons, and because of other   regulations (such  as RCRA  and  the


Section 405(d) sludge regulation),^ a preliminary solid waste and
           '                 ' '            '   ' ':	 !"  ,	'

sludge sampling  program  was   included  as  part of   this  data
     'See page 55.

-------
gathering effort.   The  program  was designed  to  quantify  the

pollutant  concentrations  in  a  select  group  of  solid  waste

streams.



Analytical data are available for  solid waste and sludge  gener-

ated by several MM&R operations.  The number, source, and type of

data available are as follows:
     1 .
     2.
     3.
Fifteen  samples  from  12  process  operations  and  3
treatment operations  collected  during  1986-1987  and
analyzed for total  concentration (total analysis)  and
by  the  Toxicity  .Characteristic  Leaching   Procedure
(TCLP); see footnote 2, page 63;

Twenty-two samples from  three operations analyzed  for
EP Toxicity submitted by an aircraft rebuilding  facil-
ity (1987); and

Eight samples  from seven  operations analyzed  for  EP
Toxicity, submitted by the Automotive Parts  Rebuilding
Association (APRA) (1986).
Based on  the  maximum  concentration  of  contaminants   for   the

characteristic of EP Toxicity  (40  CFR 261.24), about 2O  percent

of  the  solid waste  and  sludge  samples exhibited  hazardous  or

potentially hazardous characteristics.5  These wastes are  listed

in  Table  V-7  (page  113).   The wastes from abrasive blasting   and

paint stripping  are generated  from rebuilding operations.  Wastes
      5Maximum concentrations for the TCLP are not available;  TCLP
 results were compared to EP Toxicity maximum concentrations as  a
 qualitative assessment.
                                 75

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 from alkaline   cleaning,   cleaning   rinse,  grinding,  painting,

 soldering, and solvent degreasing are generated from  manufactur-

 ing, rebuilding, or maintenance.



 Other sludges, residues, and  spent solutions that are  generated

 by operations similar to MM&R operations are listed as  hazardous

 wastes from non-specific sources under  RCRA (4O CFR 261.31).   A

 list of these  wastes is  also shown  on Table  V-7.  The  wastes

 include wastewater  treatment  sludges  from  electroplating  and

 chemical conversion  coating,  as  well  as  spent  solvents  and

 electroplating solutions.



 The Domestic Sewage  Exclusion (DSE)°  for POTW  provides that  a

 hazardous waste  is  not  considered hazardous  when  mixed  with

 domestic sewage.  The exclusion allows facilities discharging  to

 POTW to discharge hazardous wastes to sewers containing  domestic

 sewage without having to comply with RCRA manifesting and report-

 ing requirements.  POTW receiving  DSE wastes are not  considered

 to have received  hazardous wastes  and are not  subject to  RCRA

 treatment, storage,  and  disposal  facility  requirements.   The

Domestic Sewage Study examined  the exclusion and determined  the
     640 CFR 261.4(a)(1)(ii);  Specified in  Section 1O04(2?)  of
the Resource Conservation and Recovery Act.
                                76

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amount of hazardous  waste being discharged  to sewers (see  page


17).
An assessment of the  hazardous nature of  solid waste from  MM&R


operations and the DSE is required to assess accurately the	oos_t_


of wastewater treatment, and hence the development of  wastewater


regulations.  The cost  of wastewater treatment  is important  in


determining the economic achievability  of regulations, which  is
                                                 '

discussed in  Section  X.   The hazardous  nature  of  wastewater
                                                        \

treatment :sludges was  considered in the  preliminary cost  esti-


mates (Section VIII).
SUMMARY





The preliminary  water use  and wastewater  characteristics  data


presented in this section lead  to several conclusions about  the


MM&R project area.  Raw  wastewater pollutant concentrations  are


high, and are  comparable to  (and in several  cases exceed)  the


concentrations of pollutants that  were regulated in other  point


source categories.   Many MM&R  unit operations  generate  waste-


waters  with  pollutant  concentrations  that  are  treatable  by


conventional  treatment  technologies.   Compared  to  previously


regulated categories, MM&R operations generate a large volume  of


wastewater, which   contains a  large  load of  toxic  pollutants.


Several solid wastes produced by MM&R operations and by  treatment
                                 77

-------
of wastewater from MM&R operations may be classified as hazardous

and would require significant disposal costs.  These observations

all point to the need for regulatory control of the MM&R  project

area.  However,  it  must be  stressed  that the  water  use  and

wastewater characteristics data currently available are  prelimi-

nary and likely underestimate  the national discharge of  toxics.

Much of the  data collected  regarding water  use and  wastewater

characteristics were collected from  MM&R facilities on a  volun-

tary basis.  These  facilities appeared  to be  taking an  active

approach toward pollution control, using wastewater reduction and

good  housekeeping  techniques  to  limit  pollutant  discharges.

Also, several of the MM&R facilities were operating under  waste-

water discharge permits based  on existing regulations for  other

processes.  Although  these  regulations were  not  intended  for
                   \
                   \
these MM&R facilities (see  page 3O), an  attempt to comply  with

any  permit  fosters  an  increased  awareness  of  environmental

practices at the facility and generally results in a decrease  in

pollutant discharges.



ADDITIONAL DATA GATHERING NEEDED



Additional data  gathering  efforts  are needed  to  support  and

expand the existing data base, with respect to defining the water

use rates and the process wastewater characteristics of  specific
                                        1    v ''   :  ,   ,  ' ,   • ''  „  "'• '' ]'
MM&R operations.  The information collected to date is useful  in
                                78

-------
initially determining  the environmental  significance of  waste-

waters from MM&R facilities, in  comparing the MM&R project  area

to other regulated categories, and for preparing this preliminary

data summary.  However, this data base does not meet the  techni-

cal and legal standards  for regulation development and  support.

Additional waste characterization data are needed to:


1.   Corroborate existing analytical,  flow, and production  data
     for 25 of the 45 unit operations (see Table V-1, page 81);

2.   Fill gaps in analytical, flow, and production data for 33 of
     the 45 unit operations (see Table V-2, page 82);

3.   Gain a  better  understanding  of dry  unit  operations  for
     consideration of waste reduction .techniques and best manage-
     ment practices;

4.   Expand the data base on  current discharge and waste  treat-
     ment practices; and

5.   Further assess  the hazardous  nature  of solid  wastes  and
     sludges generated by MM&R operations.


Flow and  production  data are  needed  for each  MM&R  operation

considered for regulation to compute production normalized  flows

for mass-based limitations.  Additional   raw wastewater data  are

needed to fully and  accurately assess the environmental  impacts

of MM&R operations, and to estimate the environmental benefits of

applying treatment technologies.



Two approaches  are recommended  for collecting  additional  data

needed to technically and legally defend  a regulation:  a  survey

of MM&R operations,  through use of  a data collection  portfolio
                                 79

-------
(dcp), and  additional sampling  of raw  wastewaters, along  with



paired treatment influent—treatment  effluent sampling  efforts..
                       1   '                   » "i. ' '       „, ,'           '"' '


The dcp will provide information on the types and number of  unit



operations performed  at MM&R  facilities.   It will  also  yield



information on water use, dry operations, production,  wastewater



generation, solid  waste and  sludge generation,  and  wastewater



treatment throughout the MM&R  project area.  The  dcp is also  a



means of  gathering economic  and financial  data needed  for  an



economic impact analysis.  Given  the large number of  facilities



in the MM&R project area (approximately 970,000), the dcp mailing



will require  a. statistical  sampling.  Sampling  and site  visit



data will  supplement the  data obtained  from the  dcp, and  are



essential  for  characterizing  the  raw  wastewaters  from  MM&R



operations, and for characterizing  the efficiency of  wastewater



treatment operations.
                                80

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                                        Table V-1

        MM&R  UNIT OPERATIONS HAVING ANALYTICAL,  FLOW,  AND PRODUCTION DATA
              Operation
                                Number Of
                                 Streams
                                 Sampled
           Operation
Number Of
 Streams
 Sampled
10
12
14,
21.
22.
Abrasive Blasting                          23.
b. Grit                             3      24.
Acid Treatment                             27.
a. Acid Cleaning                           28.
   i.  Solution                     5      29.
   ii. Rinse                        7
b. Chemical Etching
   i.  Bright Dipping                      30.
       - Solution                   2
       - Rinse                      1
   ii. Other (not specified)
       - Solution                   3
       - Rinse                      5
c. Pickling                                32.
   i.  Solution                    44      33.
   ii. Rinse                       94      34.
Alkaline Treatment
a. Alkaline Cleaning
   i.  Solution                    61      35.
   ii. Rinse                       '58      36.
b. Chemical Etching
   ii. Rinse                        3      37.
Anodizing
   i.  Solution                     2      39.
   ii. Rinse                        3
Barrel Finishing
   i.  Solution                     8
Burnishing                                 40.
   i.  Solution                     2
Chemical Conversion Coating
a. Chromate Conversion
   i.  Solution                     1
   ii. Rinse                        3
b. Phosphate Conversion                    46.
   i.  Solution                     2
   ii. Bonding and Sealing          1
   iii.Rinse                        3
c. Other (not specified)
   i.  Solution                     2
   ii. Rinse                        1
Corrosion Preventative Coating
   i.  Solution                     7
   ii. Rinse                "       2
Grinding                           19
Heat Treating                      53
Hot Dip Coating                      1
Impact Deformation                   9
Machining                           31
Metal Spraying                       1
Painting
a. Electropainting                   1
b. Electrostatic Painting            3
Plating
a. Electroplating
    i. Solution             ,         1
   ii. Rinse                    ,     2
b. Electroless Plating
   ii. Rinse                         2
Polishing                            2
Pressure Deformation    '           156
Rinsing
d. Spray                             2
e. Other (not specified)             3
Salt Bath Descaling                 16
Soldering
   i.  Pressure Bonding              1
Solvent Degreasing
   ii. Rinse                         5
Stripping
a. Paint Stripping
   i.  Solution                      2
   ii. Rinse                         1
Testing
a. Dye Penetrant
   i.  Rinse                        10
b. Hydraulic                         5
c. Other
   i.  Ultrasonic                    1
Miscellaneous
a. Wet Air Pollution Control
   -Abrasive Shot Blasting           2
   -Acid Pickling Absorber Vent      4
   -Acid Pickling Fumes              6
   -Grinding                         1
   -Pickling                         1
   -Pressure Deformation             1
   -Surface Treatment                5
d. Floorwash                         2
e. Laundry                           1
                                             81

-------
                                    TABLE V-2
       MM&R UNIT OPERATIONS WITHOUT ANALYTICAL, FLOW, AND PRODUCTION DATA
               Operation
               Operation
1.  Abrasive Blasting
    a. Bead
    c. Sand
    d. Shot
2.  Abrasive Jet Machining
4.  Adhesive Bonding
5.  Alkaline Treatment
    b. Other
       i.  Chemical Etching
           - Solution
7.  Assembly
8.  Barrel Finishing
       ii. Rinse
9.  Brazing
10. Burnishing
       ii. Rinse
11. Calibration
12. Chemical Conversion Coating
    c. Complex Oxide Conversion Coating
    d. Coloring
    e. Passivating
13. Chemical Machining
15. Disassembly
       i.  Engine Coolant
       ii. Engine Fluids
       iii.Miscellaneous
16. Electrical Discharge Machining
17. Electrochemical Cleaning
18. Electrolytic Cleaning
19. Electron Beam Machining
20. Electropolishing
25. Laminating
26. Lasar Beam Machining
29. Painting
    c. Other
       -Spray Painting
30. Plating
    b. Electroless Plating
       i.  Solution
    c. Immersion Plating
    d. Mechanical Plating
    e. Vapor Plating
31. Plasma Arc Machining
34. Rinsing
    a. Countercurrent Cascade
    b. Stagnant Dip
    c. Recirculating Dip
36. Soldering
       ii. Rinse
       iii.Quench
37. Solvent Degreasing
38. Sputtering
39, Stripping
    b. Plating Strip
       i.  Solution
       ii. Rinse
    c. Other
       i.  Carbon Strip
           -Solution
           -Rinse
       ii.. Silicone Strip
           -Solution
41. Thermal Cutting
42. Thermal Infusion
43. Ultrasonic Machining
44. Vacuum Metalizing
45. Welding
46. Miscellaneous
    a. Wet Air Pollution Control
       -Assembly
       -Forging
       -Heat Treating
       -Metal Spraying
       -Other (not specified)
    b. Battery Wash
    c. Coolant Flush
                                     82

-------
                                        TABLE V-3
                  WASTEWATER DISCHARGE RATES FROM MM&R UNIT OPERATIONS
10
12
              Operation
Abrasive Blasting
b. Grit
Acid Treatment
a. Acid Cleaning
   i.  Solution
   ii. Rinse
b. Chemical Etching
   i.  Bright Dipping
       - Solution
       - Rinse
   ii. Other (not specified)
       - Solution
       - Rinse
c. Pickling
   i.  Solution
   ii. Rinse
Alkaline Treatment
a. Alkaline Cleaning
   i.  Solution
   ii. Rinse
b. Chemical Etching
   ii. Rinse
Anodizing
   i.  Solution
   ii. Rinse
Barrel Finishing
   i.  Solution
   ii. Rinse
Burnishing
   i.  Solution
Chemical Conversion Coating
a. Chrornate  Conversion
    i.  Solution
    ii. Rinse
b.  Phosphate Conversion
    i.   Solution
    ii.  Bonding and Sealing
    iii.Rinse
 c.  Other (not specified)
    i.   Solution
        Rinse
       11.
                                           Flow
                                          (i/yr)
                                               NA
                                           2,600,000
                                         28,000,000,000
                                           1,700,000
                                         9,900,000,000

                                               NA
                                               NA

                                           1,500,000
                                           12,000,000
320,000,000,000
 93,000,000,000

       NA

       NA
       NA

  480,000,000
   41,000,000

       NA
                                                NA
                                                NA

                                           120,000,000
                                             240,000
                                          6,600,000,000

                                                NA
                                                NA
                       PNF  (1)
                       (1/kkg)
                          740
                          990
                         39,000
                           36
                        130,000

                         1,100
                         10,000

                          880
                         3,700
56,000
6,800

16,000

  80
19,000

4,400
 N/A

35,000
                         1,100
                         17,000

                           34
                           18
                         1,900

                          140
                         1,000
(1) Production Normalized Flow
NA  MM&R flow not available.
N/A Production in mass units not_ available.
                                         83

-------
                                          TABLE V-3 (Continued)
                    WASTEWATER DISCHARGE RATES FROM MM&R UNIT OPERATIONS


14.


15.


21.
22.
23.
24.
27.
28.
29.




30.




32.
33.
34.


35.
36.

37.

39.



40.






Operation
Corrosion Preventative Coating
i. Solution
ii. Rinse
Disassembly
i. Engine Coolant
iii . Miscellaneous
Grinding
Heat Treating
Hot Dip Coating
Impact Deformation
Machining
Metal Spraying
Painting
a. Electropainting
b. Electrostatic Painting
c. Other
- Spray Painting
Plating
a. Electroplating
ii. Rinse
b. Electroless Plating
ii. Rinse
Polishing
Pressure Deformation
Rinsing
d. Spray
e. Other (not specified)
Salt Bath Descaling
Soldering
i. Pressure Bonding
Solvent Degreasing
ii. Rinse
Stripping
a. Paint Stripping
i . Solution
ii. Rinse
Testing
a. Dye Penetrant
i . Rinse
b. Hydraulic
c. Other
i . Ultrasonic
Flow
(1/yr)

430,000,000
NA

6,900,000,000
1,600,000
44,000,000
120,000
NA
NA
3,600,000,000
21,000,000

NA
NA

5,200,000,000


154,000,000,000

NA
NA
NA

697,000,000
NA
NA

NA

9 , 500 , 000


2,500,000
4,000,000,000


4,000,000,000
120,000,000

NA
PNF (1)
(1/kkg)

1,800
1,500

N/A
N/A
5,600
8,700
610
750
70,000
14

230
100,000

N/A


9,800

20,000
2,700
1,300

1,900,000
1,900
2,000

83

1,000


5,100,000
98,000


1,300
94

9
(1) Production Normalized Flow
NA  MM&R flow not available.
N/A Production in mass units not available.
                                        84

-------
                                         TABLE V-3 (Continued)
                   WASTEWATER DISCHARGE RATES FROM MM&R UNIT OPERATIONS
               Operation
41. Thermal Cutting
46. Miscellaneous
    a. Wet Air Pollution Control
       -Abrasive Shot Blasting
       -Acid Pickling Absorber Vent
       -Acid Pickling Fumes
       -Grinding
       -Metal Spraying
       -Pickling
       -Pressure Deformation
       -Surface Treatment
    c. Coolant Flush
    d. Floorwash
    e. Laundry

Total
      Flow
     d/yr)
 PNF (1)
 (1/kkg)
    130,000
     1,400
       NA
       NA
  250,000,000
    570,000
       NA
       NA
       NA
 20,000,000,000
 2,700,000,000
 5,100,000,000
   N/A
-   670
   560
   120
  6,700
   N/A
   620
   900
   690
   N/A
22,000,000
  21,000
670,000,000,000    Not Applicable (2)
 (1) Production Normalized Flow
 (2) Data are not available to document the total mass of metal manufactured,
    rebuilt, or maintained in the MM&R project area or the total mass of
    metal processed for each unit operation.
 NA  MM&R flow not available.
 N/A Production in mass units not available.
                                      85

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-------
                                   Table V-5

             RAW WASTEWATER  CONCENTRATION DATA FOR  SELECTED
                            MM&R UNIT OPERATIONS
          Pollutant

Toxic Organics

  7.  Chlorobenzene

 11.  1,1,1-Trichloroethane



 29.  1,1-Dichloroethene

 38.  Ethylbenzene

 44.  Methylene chloride



 55.  Naphthalene

 64.  Pentachlorophenol

 65.  Phenol



 81.  Phenanthrene

 86.  Toluene

Toxic Metals

117.  Beryllium


119.  Chromium (total)
    Unit Operation
Machining

Alkaline Treatment
Paint Stripping
Solvent Degreasing

Alkaline Treatment

Painting

Alkaline Treatment
Paint Stripping
Solvent Degreasing

Dye Penetrant Testing

Machining

Alkaline Treatment
Painting
Paint Stripping

Machining

Solvent Degreasing
Acid Treatment
Alkaline Treatment

Acid Treatment
Painting
Paint Stripping
     •  Maximum
Concentration (mg/1)
          21.148

         173.802
           3.057
          28.291

          14.989

          71.000

         213.880
       4,270.940
         789.340

          12.989

         145.000

         391.630
          14.000
           4.480

          32.607

           8.900
      15,000
       1,500

      19,400
        750
         73
                                        110

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                             Table V-5 (Continued)

                RAW WASTEWATER CONCENTRATION DATA FOR SELECTED
                             MM&R UNIT OPERATIONS
          Pollutant

Toxic Metals (Cont.)

120.  Copper



122.  Lead


124.  .Nickel


128.  Zinc



Conventionals

Oil and Grease




Total Suspended Solids
    Unit Operation
Acid Treatment
Alkaline Treatment
Machining

Alkaline Treatment
Painting

Acid .Treatment
Machining

Acid Treatment
Alkaline Treatment
Paint Stripping
Alkaline Treatment
Dye Penetrant Testing
Machining
Paint Stripping

Acid Treatment
Alkaline Treatment
Machining
       Maximum
Concentration (mg/1)
      91,000
       1,000
          96.5

         632
       3,500

      39,000
          66

     ,45,000
         453
         130
      90,000
     336,070
      23,000
       4,800

      64,000
      23,000
      32,000
                                         111

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                                    Table  V-6

                     TREATMENT  IN  PLACE AT MM&R FACILITIES
Treatment'

Oil Separation
pH Adjustment
Chemical Precipitation
Sedimentation
Flocculation
Cr Reduction
Multimedia Filtration
 .following L^rae and :Settle
Dissolved Air Flotation
Emulsion Breaking
CM Destruction
Chlorination
Activated Carbon
Equalization
Ultrafiltration
Deep Well Injection
Biological Oxidation
% of Total
Dischargers
   Using
Treatment^

    52
    35
    35
    19
    19
    16

     3
    11
    11
     8
     8
     6
     6
     4
     3
     3
% of Direct
Dischargers
   Using
Treatment^

    33
    67
    44
    78
    11
    33

    11
     0
    11
    11
    11
    22
    11
     0
    11
    11
   % of
 Indirect
Dischargers
   Using a
Treatment^

    55
    30
    33
    11
    20
    14

     2
    12
    11
     8
     8
     3
     5
     5
     2
     2
 'These treatment technologies are defined in Section VII of the Nonferrous
 Forming Development Document.                         >
                                                 . .    '  i», :' ,           •  '  /'
^Based on 75 dischargers.

^Based on nine direct dischargers.

^Based on 66 indirect dischargers.
                                         112

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                                   Table V-7

              MM&R OPERATIONS GENERATING HAZARDOUS OR POTENTIALLY
                       HAZARDOUS SOLID WASTE AND SLUDGE
       Operation

Abrasive Blasting (with Glass Beads)
Abrasive Blasting (with Steel Shot)
Alkaline Cleaning
Cleaning Rinse (type not specified)
Grinding
Painting
Paint Stripping
Soldering
Solvent Degreasing
     Waste

Dust and Beads
Dust
Sludge
Sludge
Dust
Dried Paint Bottoms
Solids and sludges
Waste Solder
Sludge
                LISTED HAZARDOUS WASTES"POTENTIALLY APPLICABLE
                              .TO.MM&R OPERATIONS
F001-F005:  Halogenated and non-halogenated solvents.

F006:       Certain wastewater treatment sludges from electroplating
            operations.

F007-F012:  Certain solutions and sludges from electroplating and metal heat
            treating operations.

F019:       Wastewater treatment sludges from chemical conversion coating of
            aluminum.
                                         113

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                           SECTION VI

                      POLLUTANTS OF CONCERN



This section presents  the identification and  discussion of  the

pollutants  of  concern  in  wastewaters  discharged  from   MM&R

operations.  This identification and discussion are based on  the

existing MM&R data base, which is presented in Section V.



INTRODUCTION



An evaluation of the significance  of pollutants found in  waste-

water from MM&R operations is required to decide whether effluent

limitations guidelines  and standards  are necessary,7   As  dis-

cussed in Section V  (page 64), the  list  of analytes for  waste-

water analyses conducted  during this study  is a compilation  of

those chemical compounds that pose   a threat to human health  and

the aquatic environment.   As such,  any pollutant  on this  list

which is found  in a  measurable quantity in  MM&R wastewater  is

significant.  An evaluation of pollutants of concern is necessary

to develop effluent guidelines for the following reasons:


1.   It  is necessary  to identify  the toxic  pollutants  in  MM&R
     wastewaters in order  to comply with   the provisions  of   the
     Clean Water Act for application of Best Available Technology
      7See 53  FR 32584  (August 25,  1988),  EPA's Notice of Proposed
 Plans to Implement Section 304(m)  of the  Water Quality Act.

                                 115

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      to limit discharges of the pollutants declared "toxic" under
      Section 307(a) of the Act.

 2.   The classes  or  groups  of pollutants  identified  in  MM&R
      wastewaters determine which types of treatment  technologies
      should be  examined for  reducing pollutant  loadings.   For
      example, if  biodegradable  compounds (e.g.,   phenolic  com-
      pounds) are identified in MM&R wastewaters, then  biological
      treatment systems should be examined for reducing  pollutant
      loadings.


 There are other,  closely related  reasons why it   is helpful  to

 evaluate the pollutants found in wastewater from MM&R operations.

 These reasons point to the  need for an expanded data  collection

 effort,.which would refine the. pollutant analysis  presented here,

 and  include:
 1.
2.
3.
Identification  of  the  type  and  quantity  of  pollutants
present in  discharges from  MM&R  facilities is  needed  to
determine compliance of MM&R  plants with federal and  state
water  quality  requirements,  and  those  currently   under
development;

This analysis may identify pollutants from MM&R unit  opera-
tions that will likely cause failure of biotoxicity tests on
total effluents during the issuance of facility permits; and

Some of  the pollutants  generated  by MM&R  operations  are
likely to affect the  ozone layer.  Some organic  pollutants
used at  MM&R facilities  are volatile  and  photochemically
reactive.   Releases   of   these   pollutants   are   being
investigated by EPA's Office of Air and Radiation,  Division
of Global Change.
BASIS FOR TECHNICAL EVALUATION
The technical evaluation that was performed to identify  prelimi-

narily the pollutants of concern  is based on the raw  wastewater
                                             i,l  i      i         "  	,. '

analytical data that are described in Section V.  The evaluations

                                116

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involved three pollutant  criteria:  pollutant toxicity,  concen-



tration in raw  wastewater, and  frequency of  occurrence in  raw



wastewater.  The first criterion is a measure of the toxic nature



or threat  that  the pollutant  possesses  in relation  to  human



health and the environment.  A discussion of the toxicity of  the



toxic pollutants is found in Section VI of the Nonferrous  Metals



Forming Development Document.







The concentration  of pollutants  in raw  wastewater affects  the



selection of  treatment technology  for treating  the .raw  waste-



water.  Raw wastewater concentrations were compared to  treatment



effectiveness  concentrations  demonstrated  by  treatment  tech-



nologies studied in other categorical regulations (Section  VII).



This comparison provided an  indication of the potential to  treat



MM&R wastewaters.







The frequency of occurrence  of each pollutant in wastewater   from



each MM&R  operation was   computed  as the  number of   times  the



pollutant  was  detected per  number of  times the  pollutant  was



analyzed.  For  example, if  five  samples of  alkaline  cleaning



wastewater were collected  and  analyzed for benzene, and  benzene



was measured at 0.5 mg/1 in  one sample, but not detected in  the



other  four samples, then the frequency of occurrence for  benzene



in alkaline cleaning wastewater  is "1/5."
                                 117

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 The pollutants  of concern  were identified  using a  qualitative


 approach based on  the criteria discussed  above.  Any  pollutant


 measured in MM&R wastewater is of concern,  since only  pollutants


 having some deleterious  effect on human  health and  environment


 were included on the "List of Analytes."  A more detailed consid-


 eration of the toxicity of the non-priority pollutants of concern


 that were identified should be included in  any regulatory effort.


 For this study,  rigorous statistical methods were not employed to


 determine other  inferences or  correlations that may be  inherent


 in  the raw,wastewater data.




 POLLUTANTS IDENTIFIED
All pollutants listed  in Table VI-I  (page  120)  were  identified  as


pollutants of concern, except those  denoted  with a footnote.  The


pollutants of  concern  include   toxic  organics,  toxic  metals,


conventionals, and nonconventionals.  Table  VI-1 summarizes  each


pollutant's frequency of occurrence  in wastewater from eachMM&R


operation.  This table is based on the same  data used to  prepare


Table V-4 (page 86).  For all samples from MM&R unit  operations,


11,168 pollutants  were  measured  out  of   32,678  analyzed  (34


percent).  Table VI-1 shows the  large numbers  of pollutants  and


extensive variety in  the type  of pollutants   present in  waste-


waters from each  operation.  This characterizes  the degree  and
                     , I'       '     '     '   .   •'! ',, '' •' ' ' ,  ; ',' 1I" '! , « "',!!''   ''     :  I'l'li'

complexity of pollution generated by MM&R operations.


                                118
                                                                  '•i'Vt	'. v ;	u

-------
SOURCE OF POLLUTANTS







The pollutants identified above  were detected frequently and  at



high concentrations  in  raw wastewaters  from  MM&R  operations.



These pollutants are expected to be present in these  wastewaters



based on an engineering assessment of the types of raw  materials



and processing  steps involved  in  MM&R operations.   The  toxic



organic pollutants found are frequently used as solvents,  clean-



ers, processing aids, and strippers in metal working  operations.



Toxic metals are likely to .be present in MM&R.wastewaters because



the machinery parts processed are constructed from these  metals.



The nature  and  intent  of  MM&R  processing  operations  (e.g.,



grinding, machining,  polishing)  remove these  metals  from   the



parts and deposits the metals in the process wastewater.  Oil  and



grease  is frequently  found  in  process  wastewaters  because  many



MM&R operations  use oil-based  raw  materials as metal  working



fluids  or lubricants, and because many  parts requiring  rebuilding



or maintenance are  oily and greasy due  to their use.   Noncon-



ventional pollutants are found  in  MM&R wastewater  for  a  variety



of reasons,   including   their   use  as  constituents  of  process



solutions and as the base metal for  the parts.
                                 119

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•""':IX  '";,»: 'ilii  ijf     1   S,

-------
                           SECTION VII



                CONTROL AND TREATMENT TECHNOLOGY








INTRODUCTION







This section briefly  discusses the control  and treatment  tech-



nologies applicable  to wastewater  from MM&R  processing  opera-



tions.  It also summarizes  the effectiveness of treatment  tech-



nologies observed at MM&R facilities during the sampling program.








Wastewater from MM&R operations is characterized by toxic organic



and toxic  metal  pollutants,  oil and  grease,  total  Suspended



solids and a variety of nonconventional pollutants (Section  VI).



In addition, many MM&R operations result in large wastewater flow



rates, ranging  from  14O,OOO  to 32O  billion  liters  per  year



(37,OOO to 84.5 billion gallons per year).  The total raw  waste-



water flow estimated for MM&R  facilities is 2.4 trillion  liters



per year (63O billion  gallons per year).   It is estimated  that



MM&R facilities  generate raw  wastewater containing  68  million



kilograms per year (kg/yr)  (15O million pounds per year (lbs/yr))



of toxic  metals, 16.5  million kg/yr  (36.3 million  lbs/yr)  of



toxic organics  (including  cyanide),  and  3,40O  million  kg/yr



(7,5OO million lbs/yr) of   conventional pollutants.  These  esti-



mates are for about 3O percent of the facilities included in  the



project area.



                                145

-------
                                                                .'• i •".;;».( ">Kt.:	f
The  types  of  control and  treatment technologies  most  often   found


at   MM&R   facilities   include   flow  reduction,   oil   and   grease


removal, and  chemical  precipitation of metals, followed  by  solids


separation and  removal of  sludge.   These  treatment   technologies


have been  found  in other industrial  categories with operations


similar to those in   the MM&R  project area  and are proven   to


effectively reduce metals,  oil  and grease, and  solids  loadings.


Oil  and grease  treatment  technology may remove organic pollutants


incidentally  but  data  were not available  to  show the extent   of


removal.




The  nature of unit operations   used in MM&R processes allows   for


several innovative pollution reduction  techniques.   Although a


typical MM&R  process is comprised  of a series of unit operations,
                   m

each unit  operation generally  is   independent  with   respect   to


process chemicals  used   (e.g., cleaners,  solvents,   lubricants,


coolants)  and  process  wastewater  generated.    This   allows   the


approach for  selecting appropriate  control and treatment technol-


ogies to include pollution  reduction at the source.   Best manage-


ment practices  (including   waste reduction)  and in-process  flow


reduction  are possibly viable   techniques for reducing pollutant


loadings.
A detailed  discussion  of  contr.ol  and  treatment  technologies


applicable to  wastewaters similar  to  those generated  by  MM&R


                                146

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operations is presented in Section.VII of the Nonferrous  Metals



Forming  Development  Document.   That  section  describes   each



treatment technology and discusses its effectiveness at  reducing




pollutant concentrations.







CONTROL AND TREATMENT TECHNOLOGY CURRENTLY IN USE







The data  presented  in Section  V-6   (page 112)  show  that  oil



separation, chemical  precipitation and  solids removal  are  the



most prevalent treatment  technologies used  by MM&R  facilities.



These  technologies  are widely  available, generally  affordable,



and proven effective for wastewater treatment.







Analytical data  were  collected as   part  of  the  MM&R  sampling



program  (1986-1987)  to  evaluate   the effectiveness  of  some   of



these  treatment  technologies  at reducing pollutant concentrations



in MM&R   wastewaters.    Specific  technologies   evaluated   include



dissolved air flotation  (used to  remove oil and grease), alkaline



chlorination of   cyanide,   chemical  reduction   of  chromium,   and



chemical precipitation  and sedimentation   (for metals   removal).



Table  VI1-1   (page  152)  shows a  comparison   of   the   treatment



effectiveness of  these   technologies  as  observed  at   the  MM&R



 facilities  and at facilities in other categories.   The   treatment
                                 147

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 effectiveness concentrations shown for other categories are  part

 of the Combined Metals Data Base (CMDB).^




 Alkaline chlorination  of  cyanide,  and  chemical  reduction  of

 chromium were found to substantially reduce cyanide and  chromium

 concentrations to levels that are comparable to those shown to be

 achievable in the CMDB.   Chemical precipitation and sedimentation

 of toxic  metals  was shown  t,o  be similarly  effective.    These

 cyanide,  chromium,  and toxic metals  analyses were based on  data

 collected at.an aircraft rebuilding facility.




 Dissolved air flotation  (DAF)   was  found to remove  approximately

 one-half of the oil and  grease present in the raw process   waste-

 water at  a railroad rebuilding  facility.   While DAF reduced  oil

 and grease  concentrations,   the concentrations  after   treatment

 were much greater   than  the  effluent concentration  shown  to  be

 achievable for  oil  and grease  treatment (oil skimming technology)


 in the  CMDB.   Additional  treatment  effectiveness  concentration

 data and   a detailed  statistical   analysis   would be needed  to
                                           ,!, i,   ..  JJ,   i |n .|,  i , ;'    ,  f    , ".i
 evaluate  DAF as an  effective technology for  treating  MM&R  waste-

 water.
     Q
      The Combined Metals Data Base  is discussed in Section  VII
of the Nonferrous Metals Forming Development Document.


                                148

-------
The MM&R sampling program did  not include collection of data  to



characterize the effectiveness of treatment technologies used for



removing organic  pollutants from  raw wastewaters  generated  by



MM&R operations.  Organic  pollutant treatment technologies  have



been identified  in  other  industrial  categories  regulated  by



effluent  guidelines  (e.g.,  Organic  Chemicals,  Plastics,  and



Synthetic Fibers), and may be applicable to MM&R wastewater.  The



lack  of  treatment  effectiveness  concentrations  for   organic



pollutants  in MM&R wastewater is a recognized gap in the  current



database   and.will  need  to be , filled  prior to  proposal  and




promulgation.







ALTERNATIVE CONTROL TECHNOLOGIES







Alternate control  technologies  applicable  to  pollutant discharges



from MM&R operations  include  best management  practices (BMPs) and



in-process  flow reduction.  Both  techniques provide reduction   in



pollutant loadings without a great  financial  burden  on  smaller



facilities.  The alternative   control techniques  described  below



are demonstrated  at well-operated   MM&R facilities  and as  such



 could  be viable regulatory  alternatives for  economically  disad-




 vantaged facilities.







 BMPs are based  on relatively simple  techniques for  controlling



 pollutant discharges,  such  as pollution  prevention  and  waste



                                 149

-------
 reduction.  Pollution prevention techniques, such as, good  house-
 keeping practices and preventive  maintenance, are measures  that
 prevent pollutants  from  entering  process  water  at  the  unit
 operation level.  Two examples of good housekeeping practices are
 dry floor  cleaning and  segregation of  process solution  spills
 from floor drains.  Preventive  maintenance on processing  equip-
 ment averts leakage of oils,   lubricants,  or other process  solu-
 tions from entering process water during normal use.    Preventive
 maintenance also reduces the incidence ofequipment failure which
.could cause.significant releases of pollutants.
Waste  reduction  techniques,   such as   wastewater  segregation   and
material  reuse   and  reclamation   reduce  the   vo.lume of   pollutant
discharge and decrease  the amount of  raw materials needed   (e.g.,
cleaners, solvents,  lubricants).   Segregation of  wastewaters with
high pollutant loadings  from those with lower loadings or  dif-
ferent pollutant characteristics  can  often result in  significant
treatment and disposal  cost  savings.    Also, certain  segregated
streams may be more  suitable  for  reuse than others.
BMPs can be tailored to specific process operations which  gener-
ate pollution.  The  independent nature of  many MM&R  operations
allows application of BMP's to the level of control needed (i.e.,
BMPs can be  applied to groups  of operations or  be written  for
specific  unit  operations).   This  flexibility  in  control  of
                                150

-------
pollutant discharges  results  in  .increased  cost  effectiveness



since BMP's only would  be applied to  the operations where  they




were needed.







Flow reduction  is  used  commonly as  an  end-of-pipe  pollution



reduction  technique   (e.g.,  reuse   of  treated   wastewater).



In-process ("at the source") flow reduction affords several added



advantages.  Recycle of process water  increases the concentration



of pollutants  in  the  raw  wastewater  and  allows  end-of-pipe



treatment systems to .remove  pollutants more efficiently.   Also,



recycle reduces  the volume  of wastewater  requiring   treatment,



resulting in savings on   the capital and  operating costs  of   the



treatment system.   Other effective   in-process   flow   reduction



techniques  include use  of multiple counterflow   rinse  tanks   and



spray  rinses.   Also,  inspection  programs  for  processing  tanks



result in timely discovery and repair  of water  leaks.
                                 151

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                                  TABLE VII-1
              TREATMENT SYSTEM PERFORMANCE AT TWO MM&R FACILITIES

                          Dissolved Air Flotation (1)
Pollutant (2)
Cadmium
Copper
Lead
Zinc
Iron
O&G
O&G
O&G
TSS
TSS
TSS
DAF
Influent
(mg/1)
0.012
0.450
0.415
0.250
4.300
NA
525.000
NA
NA
420.000
NA
3
Effluent
(mg/1)
<0.005
0.075
<0.05
0.066
1.800
NA
210.000
NA
NA
200.000
NA
                                                 DAF 4
                                          Influent    Effluent
                                           (mg/1)      (mg/1)
                                           0.008
                                           0.210
                                           0.250
                                           0.380
                                           17.000
                                          100.000
                                          220.000
                                           85.000
                                          380.000
                                          450.000
                                          220.000
                                       <0.005
                                       0.051
                                       <0.05
                                       0.018
                                       1.600
                                      120.000
                                       51.000
                                       66.000
                                       90.000
                                       90.000
                                       30.000
                                                   CMBD (3)
                                                    (mg/1)
                                         0.05
                                         0.39
                                         0.08
                                         0.23
                                         0.28
                                         10.00
                                         10.00
                                         10.00
                                         2.60
                                         2.60
                                         2.60
             Oily Waste Treatment  (4)
Pollutant  (2)
Copper
Zinc
O&G
O&G
O&G
TSS
TSS
TSS
Influent
 (mg/D
 0.250
 0.352
 14.000
 4.000
 9.000
 22.000
 13.500
 10.000
Effluent
 (mg/1)

 0.032
 0.039
   <1
 2.000
 4.000
 14.000
 1.000
 1.000
CMBD (3)
 (mg/1)
  0.39
  0.23
 10.00
 10.00
 10.00
  2.60
  2.60
  2.60
(1) Dissolved Air Flotation includes oil separation and chemical addition
(2) Data presented for metals are from one day of sampling, while data
    presented for Oil and Grease (O&G) and Total Suspended Solids (TSS)
    are from three days of sampling.
(3) CMBD-Combined Metals Data Base.   See Section VII of the
    Nonferrous Metals Forming Development Document
<4) Oily Waste Treatment consists of solids separation,  oil separation
    chemical precipitation and sedimentation,  and biological treatment'
                                    152
                                                                           ..I	!	iilii: lill	II	i,"ii!	'•	i''

-------
                          SECTION VIII

                    CONTROL AND TREATMENT COSTS



INTRODUCTION



This section  presents preliminary  control and  treatment  costs

estimated for facilities  in the MM&R  project area.  Costs  were

developed so  that a  preliminary  economic assessment  and  cost

effectiveness analysis could be performed (Section X).



Costs were  estimated for  11 MM&R  segments9 on  a normal  plant

basis.  The large number  of MM&R facilities  and lack of  suffi,-

cient data precluded  estimation of costs  for each facility.   A

normal plant  is a  hypothetical arrangement  of unit  operations

designed to  approximate the  range of  operations present  in  a

particular industrial segment.  The methodology used to  estimate

costs for the   11 MM&R  segments is   the traditional  methodology

used for  other  effluent  guidelines,  and   involves  estimating

capital and annual operating costs for specific wastewater treat-

ment equipment  (see below).
      ^Section   III   (page
 considered  for  costing.
24)  describes   the  MM&R   segments
                                 153

-------
 COST ESTIMATION APPROACH

                                            i : »'  ! , ' '  • i , 'if ,,., 'i|: ' ,"• , : i ,
 The approach used to estimate capital and annual operating  costs
 for the 11   MM&R segments is  based on the  methodology and   cost
 data presented in Section VIII  of the Nonferrpus  Metals  Forming
 Development Document.   This approach  was selected because  the
 wastewaters generated by MM&R operations have  similar   character-
 istics as   those generated  by nonferrous  metals  forming opera-
 tions.   Therefore,  the  treatment technologies  included in   this
 preliminary analysis for MM&R wastewaters  are the same as  those
 selected for BAT  in the Nonferrous  Metals Forming regulations.
 The  methodology  described  in  the  Nonferrous   Metals  Forming
 Development Document uses cost curves relating capital  and annual
 operating costs  to   wastewater flow for  each  piece of   treatment
 equipment.   That document also presents the specific cost figures
 for each piece of treatment equipment.
                                         , ,,     , ,   ,  i,	 „,  , .

Normal  Plants
As described above, treatment costs were  calculated  for  each  MM&R
segment on  a  normal plant  basis.   For this  preliminary   data
summary, a normal  plant is  defined as   a hypothetical   facility
which consists of all the  unit operations known to  be   performed
in a segment.   The normal  plants are an approximation of   real
            '"  '     i, , , •       i ,, ' '      "     ' lii '. ', , Ull'. ,  • I i   "' ,' 	 . „•       '
plants  based  on  the  data  available.   The  unit  operations
                     >•  	•-	.J-	-154    ;'.  -' " .' .   "    .	   '...

-------
comprising each normal  plant were obtained  from sampling  visit

reports, site  visit  reports, data  collection  portfolios,  and

telephone survey reports.   If a;unit  operation was reported  in

any of these sources, it was included in the normal plant.   This

approach accounts for the full range of operations and  resultant

pollutant discharges found within a segment.


               *
Table VII1-1 (page 160) presents a summary of the unit operations

comprising the normal plant for  each segment.  This table  shows

which operations are present  in the normal 'plant for each  seg-

ment, as  well as  how many  times the  operations occur  at  the

normal plants.  For example, Table  VII1-1 shows that the  normal

plant for the aircraft rebuilding segment has four acid  cleaning

solution wastewater streams and  three acid cleaning rinse  waste-

water streams.



Treatment Technologies



Once the set of unit operations  for each normal plant was  deter-

mined, and  the  wastewater flows  and  pollutant  concentrations

associated with each of  these unit operations were defined, a set

of  treatment technologies were   evaluated and selected to   reduce

pollutant loadings for each normal plant.
                                 155

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 As discussed in Sections V  and VI,  wastewater streams from  MM&R

 operations have substantial flows and contain high levels  of   oil

 and grease,  metals,  and organic pollutants.



 Treatment systems  shown  effective in  treating these   pollutants
 were  selected  for  the  MM&R normal  plants.

 consist  of the following technologies:
                                     Treatment  systems
      o
      o
      o
      o
      o
      o
      o
Oil-water separation;
Cyanide precipitation (where appropriate);
Chromium reduction (where appropriate);
Equalization;
Chemical precipitation, including gravity settling;
Vacuum filtration for sludge from gravity settling; and
Multimedia filtration.
Contract hauling of sludges  is  included  in  these treatment steps.

Cyanide precipitation and  chromium reduction preliminary  treat-

ment technologies  were  included  only  for  those  streams  with

treatable concentrations of  cyanide  and hexavalent chromium,  as

appropriate.  Additional costs  for  handling of hazardous  sludge

from cyanide precipitation were also included.
These treatment technologies were chosen based on the  character-

istics of the wastewater observed  in the MM&R project area,  the

current treatment in  place at MM&R  facilities (Section V),  and

treatment technologies used in  other regulated categories.   The

MM&R wastewater characteristics,  wastewater volumes, and  treat-

ment in place are similar  to those reported in other  categories

                                156

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for. which effluent limitations  guidelines were developed  (e.g.,



Aluminum Forming,  Copper  Forming, Iron  and  Steel,  Nonferrous



Metals Forming).  The  treatment technologies  selected for  MM&R



were based on these similarities.







It should be noted that the treatment technologies selected  here



are those typically  used to implement  a mass-based  regulation.



Although the possibility of using other regulatory approaches was



presented earlier (see Section IV),  no costs were developed  for



these alternative technologies.
A major data gap is  recognized in the assessment of  appropriate



treatment technologies.  No treatment technologies were evaluated



that would  be effective  at removing  organic pollutants.   Some



removal of organic pollutants may  occur during oil skimming  for



removal of oil and grease; however, the extent of such removal is



not currently  quantified.  While  there may  be some  incidental



removal of organic pollutants, the treatment technologies  listed



above would result primarily in removal of oil and grease,  toxic



and nonconventional  metals,  suspended solids,  and  other  non-



organic nonconventional pollutants.  In the process of developing



effluent guidelines for  MM&R facilities,  other treatment  tech-



nologies will be  evaluated for organics  control.  For  example,



wet air oxidation  is a  practical treatment  technology for  low



volume wastewater  streams with  high concentrations  of  organic



                                157

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pollutants.  The  combination of additional treatment technologies
with management   practices  designed  to  minimize the  amount  of
organic pollutants  entering the wastewater should fill this  data
gap.

Cost Estimates

Following the methodology presented in   Section  VIII of the  Non-
ferrous Metals Forming Development   Document, and using the  cost
data presented there, capital and annual operating costs for  each
MM&R segment were   calculated.   Cost estimates   are presented  in
May 1988 dollars at the end of  this section.
Cost estimates are affected by  three major factors:   the  waste-
water flow to  treatment, the pollutants   in  the wastewater,   and
the treatment equipment  currently in place   at MM&R   facilities.
These factors were presented in Section V  of  this document.

SUMMARY OF COSTS
Costs for  direct  and  indirect  dischargers  are  presented  by
segment in Table VIII-2 (page 164).10  The estimated control  and
     10
       A discussion of  discharge status for  MM&R facilities   is
                                               (Footnote Continued)
                                158
                     mi 'Hhii1 li  „» 
-------
 treatment costs for the 11 MM&R segments are sufficiently high to

 classify this project area as a major regulation.  Costs of  this

 magnitude would require a  Regulatory Impact Analysis (RIA),  per

 Executive Order 12291.  However, cost reducing measures, such  as

 innovative and alternative  wastewater management techniques  and

 waste reduction practices,  were not  estimated.  The  compliance

 cost estimates presented represent costs for about 15 percent  of

 the total MM&R facilities (see Section III, page 25).



 Table VII1-2 shows that  aggregate compliance costs for  indirect

 dischargers are much  larger than those  for direct  dischargers.

 This was expected since available data showed that  approximately

 7O percent  of  the  MM&R facilities  are   indirect  dischargers.

 Also, certain  segments  have much  higher  estimated  compliance

 costs than  others (e.g.,  bus and  truck rebuilding,  automobile

 rebuilding-maintenance,  bus  and  truck  maintenance,   aircraft

 rebuilding, and office machine  manufacturing).  Again,  this  was

 expected since  these  segments discharge   much  more  wastewater

 (i.e., have higher wastewater flows)  than the other segments.
(Footnote Continued)
  presented   in  Section  V  (page  73).    Direct  dischargers  are
  facilities  that  discharge wastewater directly to surface  waters
  such as  rivers,   lakes,  streams, etc.    Indirect dischargers  are
  facilities  that   discharge  to  publicly  owned  treatment  works
  (POTW).
                                  159

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                                                    Table VII1-1

                                              NORMAL  PLANT  SUMMARY
                                                                        Transportation Sector
               Operation
Wet:
3.  Acid Treatment:
    a. Acid Cleaning
       i.  Solution
       it. Rinse
    b. Chemical Etching
       i.  Bright Dipping
           - Solution
           - Rinse
       ii. Other (not specified)
    c. Pickling
       i.  Solution
       it. Rinse
5.  Alkaline Treatment
    a. Alkaline Cleaning
       i.  Solution
       ii. Rinse
6.  Anodizing
8.  Barrel finishing
       i.  Solution
       it. Rinse
12. Chemical Conversion Coating
    a. Chromate Conversion
       i.  Solution
       ii. Rinse
    b. Phosphate Conversion
       i.  Solution
       ii. Sending and Sealing
       {{{.Rinse
14. Corrosion Preventive Coating
15. Disassembly
       i.  Engine Coolant
       ii. Engine Fluids
       HI.Miscellaneous
21. Grinding
22. Heat  Treating
       -  Cooling Water
       -  Quench OU
27. Machining
28. Ketal Spraying
29. Painting
    a. Electropainting
       -  Solution
       -  Rinse
    c. Other
       -  Solution
30. Plating
    a. Electroplating
       i.  Solution
       ii. Rinse
    b. Electroless Plating
32. Polishing
34. Rinsing
37. Solvent Oegreasing
       i.  Solution
       ii. Rinse
                               Automobile   Automobile, Bus,
Aircraft       Aircraft       Rebuilding-   and Truck Parts  Bus and Truck   Bus and Truck
Rebuilding    Maintenance     Maintenance      Rebuilding      Rebuilding     Maintenance
    31
    16
    1
    1
    26
    1
    50
    7
   13
   1
                                                           160

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                                          Table  VIII-1  (Continued)

                                              NORMAL PLANT SUMMARY
                                                                      Transportation Sector
              Operation
39. Stripping
    a. Paint Stripping
      i.  Solution
      ii. Rinse
    b. Plating Stripping
      i.  Solution
      ii. Rinse
    c. Other
      i.  Carbon Stripping
          - Solution
          • Rinse
      ii. Silicons Stripping
          -Solution
40. Testing
    a. Dye Penetrant
      i.  Rinse
    b. Hydraulic
 41 Thermal Cutting
46. Miscellaneous
    a. Air Pollution Control
    b. Battery Wash
    c. Coolant Flush
    d. Flooruash
    e. Laundry

Dry:
1.  Abrasive Blasting
7.  Assembly
8.  Barrel Finishing
9.  Brazing
10. Burnishing
11. Calibration
14. Corrosion Preventive Coating
15. Disassembly
21. Grinding
22. Heat Treating
24. Impact Deformation
27. Machining
28. Metal Spraying
29. Painting
32. Polishing
36. Soldering
39. Stripping
    a. Paint Stripping
40. Testing
45. Welding
46. Miscellaneous
    a. Coating-Oil
    b. Thermal Cleaning
Aircraft
Rebui Iding
8
3
1
1
1
1
1
1
1
1

6
1
14
1
1
1
1
1

1
1
1
1
3
1
1

1
1
1
1
1
Automobile Automobile, Bus,
Aircraft Rebuilding- and Truck Parts Bus and Truck Bus and Truck
Maintenance Maintenance Rebuilding Rebuilding Maintenance
1
1






1
1
1 1
1 2 1 1

12 1
1111
1
1 1

1 1
1
1
1 1


2 2

1 2
1 1 1

1
1 2
1 1 1

                                                           161

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                                       Table VIII-1  (Continued)

                                          NORMAL  PLANT SUMMARY
                                            Transportation Sector (continued)
                                                    Office Machines Sector
               Operation
    Radiator
   Rebuilding
for Automobiles,     Railroad       Railroad
Buses,  and Trucks   Rebuilding    Maintenance
 U«t:
 3. Acid Treatment:
    a. Acid Cleaning
       i.  Solution
       ii. Rinse
    b. Chemical Etching
       i.  Bright Dipping
           - Solution
           • Rinse
       ii. Other (not specified)
    c. Pickling
       i.  Solution
       ii. Rinse
 5. Alkaline Treatment
    a. Alkaline Cleaning
       i.  Solution
       ii. Rinse
 6. Anodizing
 7. Barrel Finishing
       i.  Solution
       ii. Rinse
 12. Chenical Conversion Coating
    a. Chromate Conversion
       i.  Solution
       ii. Rinse
    b. Phosphate Conversion
       i.  Solution
       ii. Bonding and Sealing
       iii.Rinse
 14. Corrosion Preventive Coating
 15. Disassembly
       i.  Engine Coolant
       ii. Engine Fluids
       iii.Miscellaneous
 21. Grinding
 22. Heat  Treating
       -  Cooling Water
       -  Quench Oil
 27. Machining
 28. Metal Spraying
 29. Painting
    a. Electropainting
       -  Solution
       -  Rinse
    c. Other
       -  Solution
30. Plating
    a. Electroplating
       i.   Solution
       ii.  Rinse
    b. Electroless Plating
32. Polishing
34. Rinsing
37. Solvent Decreasing
       i.   Solution
       ii.  Rinse
  Office         Office
 Machine        Machine
Rebuilding   Manufacturing
                       16
                       6
    10
    10
                                                                    130
                                                        162

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                                    Table VII1-1  (Continued)

                                       NORMAL  PLANT  SUMMARY
                                           Transportation Sector (continued)           Office Machine* Sector
              Operation
    Radiator
   Rebuilding                            •
for Automobiles,     Railroad        Railroad
Buses, and Trucks   Rebuilding     Maintenance
                                                                                     Office
                                                                                     Machine
                                                                                    Rebuilding
    Office
   Machine
Manufacturing
39. Stripping
    a.  Paint Stripping
       i.  Solution
       ii. Rinse
    b.  Plating Stripping
       i.  Solution
       ii. Rinse
    c.  Other
       i.  Carbon Stripping
          - Solution
          - Rinse
       ii. Silicone Stripping
          -Solution
40. Testing
    a.  Dye Penetr&nt
       i.  Rinse
    b.  Hydraulic
41. thermal Cutting
46. Miscellaneous
    a.  Air Pollution Control
    b.  Battery Wash
    c.  Coolant Flush
    d.  Flooruash
    e.  Laundry

Dry:
1.  Abrasive Blasting
7.  Assembly
8.  Barrel Finishing
9.  Brazing
10. Burnishing
11. Calibration
14. Corrosion Preventive Coating
15. Disassembly
21. Grinding
22. Heat Treating
24. Impact Deformation
27. Machining
28. Metal Spraying
29. Painting
32. Polishing
36. Soldering
39. Stripping
    a. Paint Stripping
 40. Testing
 45. Welding
 46. Miscellaneous
    a. Coating-Oil
    b. Thermal Cleaning
                                                        163

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                                                Table VIII-2
           SUMMARY OF  TREATMENT  COSTS FOR DIRECT  AND  INDIRECT DISCHARGERS *
                                             Direct Dishargers
                                                                                     Indirect Dischargers
            Segment
 Transportation Sector:
   Aircraft Maintenance
   Aircraft Rebuilding
   Automobile RebuiIding-
    Maintenance
   Automobile, Bus, and
    Truck Parts RebuiIding
   Bus and Truck Maintenance
   Bus and Truck Rebuilding
   Radiator RebuiIding-
    Maintenance for Automobiles,
    Suses, and Trucks
  Railroad Maintenance
  Railroad Rebuilding
Office Machines Sector:
  Office Machine Manufacturing
  Office Machine Rebuilding
Total
Annual Cost
$1.200,000
$24,000,000
$94,000,000
Capital Cost
$1,400,000
$25,000,000
$150,000,000
Annual Cost
$12,000,000
$260,000,000
$920,000,000
Capital Cost
$13,000,000
$310,000,000
$1,500,000,000
$1,400,000
$5,700,000
                                        $14,000,000
                                         $59,000,000
$53,000,000
$120,000,000
$3,800,000
$220,000
$310,000

$14,000,000
$24,000
$310,000,000
$75,000,000
$260,000,000
$10,000,000
$620.000
$680,000
V.
$25,000,000
$110,000
$550,000,000
$500,000,000
$1,300,000,000
835,000,000
$2,300,000
$3,200,000

$160,000,000
$260,000
$3,200,000.000
$680,000,000
$2,700,000,000
$100,000,000
$6,400,000
$6,700,000

$250,000,000
$1,200,000
$5,600,000,000
 *  Costs shown are in Hay, 1988 dollars.  Costs account for treatment already in place in each
                                                                                           segment.
                                                     164
                                                             	,.,.", i if" '  'if.'-.	 llvi. Hi l'i!:l!lii.  i "  I ''!,'• '•.    ••! V1!",  I    • :' i OIRhliiiiiii'i'i i ,i!	i

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                           SECTION IX



    RAW WASTEWATER LOADINGS AND POLLUTANT REDUCTION ESTIMATES








INTRODUCTION







This section presents  the preliminary  raw wastewater  pollutant



loadings and pollutant reduction  estimates for the MM&R  project



area.  It also  presents the  approach taken  for estimating  the



loadings and pollutant reduction values.







Raw wastewater pollutant loadings  were estimated to measure  the



extent of potential  environmental contamination as  a result  of



MM&R operations.  Pollutant  reduction estimates were  calculated



to indicate the effectiveness that treatment technologies have on



limiting pollutant  discharges.  Also,  preliminary loadings  and



pollutant reductions were  estimated so that  a preliminary  eco-



nomic impact analysis  and cost effectiveness  analysis could  be



performed (see Section X).







As discussed in  Section III (page  24), pollutant loadings  were



estimated initially  for  .11 industrial  segments  consisting  of



transportation and office machine facilities engaged  in  rebuild-



ing  and maintenance  operations (10  segments) and  manufacturing



operations   (one  segment).   These  segments  included    147,OOO



facilities or  15 percent of  the  current MM&R project area.   The



remaining facilities,  primarily  engaged   in manufacturing,  were



                                165

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 grouped in a  miscellaneous sector.   The approach   was  to  apply

 pollutant loadings for transportation and office machines  to  the

 entire project area based on  the ratio of number of  facilities.

 Once the pollutant  loading estimates were  completed  for  the   11

 segments,  a comparison of  manufacturing and rebuilding  loadings

 for office machines showed  that the manufacturing loadings  were

 up to five orders  of magnitude greater  than would  be  estimated

 using the  ratio of facilities.



 The approach  was  revised.    The 278,OOO  MM&R  facilities  were

 placed  in  sectors  according  to  industrial  boundaries   using

 four-digit SIC  codes.11    The  result  was  15  sectors  and  43

 segments (31  manufacturing  and 12  rebuilding and  maintenance).

 The original  transportation  sector was realigned and divided into

 six sectors:    motor  vehicle,   bus  and truck,   aircraft,  space,

 railroad,  and  ship.   The facilities  within these  new  sectors

 corresponded  to  those  in the  original  transportation  sector.
                                •','••  »• ' '   -, •  i, " .   i ' „ ''     '   IN	

 Therefore,  this   realignment   does    not   affect  the   economic
     11 At. the time  the pollutant loading analysis was  conducted,
the Dun &  Bradstreet list  contained  approximately 278,000  MM&R
facilities.  This figure  only  represented  facilities with  more
than nine employees.  After the analysis was completed, new  data
became available  that showed   there were  approximately  97O,OOO
MM&R facilities, including  those with nine employees or less (see
page 26).
                                 166
                                            ••/>s'.;'''('i  , i1 "'i'"1-''',;'";i*',..'1* "
                                            frAMi:-	iAi!	 ,j.|:i''..n F'!i,T.'.!•••"'; Si '
                                                                 ;	••,!	:,	a, ,,a	'; .if

-------
and  environmental  impact  analyses.   Pollutant  loadings   for



manufacturing  segments  were  estimated   based  on  data   from



manufacturing  facilities   identified  in   the  Machinery   and



Mechanical Products  category  record  and in  Bureau  of  Census



publications.  Limited budget resources prevented revision of the



cost estimates.







RAW WASTEWATER LOADINGS







Tables IX-1  (page  180) and  IX-2   (page 181)  present  the  raw



wastewater pollutant loadings for  the original 11 MM&R  segments



and 38 of the 43 segments, respectively.  Data were not available



to estimate  loadings for  five rebuilding  and maintenance  seg-



ments.  Loadings for the following groups of pollutant parameters



are shown:  Total Toxic .Organics (including cyanide), Total Toxic



Metals, Total  Wonconventional  Organics,  Total  Nonconventional



Metals, Total  Other Nonconventionals,  and Total  Conventionals.



Tables IX-1 and IX-2 show  that MM&R wastewaters  have more  toxic



metals present in   raw wastewater  than  toxic  organics and  that



MM&R wastewaters contain  a large amount  of conventional  pollu-



tants  (total suspended solids and oil and grease).







For comparative  purposes, Table  IX-3   (page  186)  presents  raw



wastewater   pollutant  loadings  from  other   metals    industrial
                                 167

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 categories.   Figure  IX-1  (page  191)  illustrates  this   comparison,

 showing  that  the  quantity of toxic and  conventional pollutants  in

 MM&R raw wastewaters  is  greater  than  raw   wastewaters  from all

 other metals  categories,  except Iron and Steel and Metal  Finish-

 ing.



 The pollutant loading  analysis did  not quantify  the amount   of

 pollutants currently  discharged  by MM&R   facilities.    Current

 discharge  loadings  were approximated  by  the  raw  wastewater

 loadings for  several reasons.
 1.   Sufficient  data  on  the  pollutant  removals  achieved  by
     treatment in place at MM&R facilities were not available.

 2.   In the  absence  of  national  regulations,  permit  writers
     traditionally direct  state  and  federal  resources  toward
     larger, more visible facilities.   MM&R is characterized  by
     numerous,   diverse   facilities,   including   many   small
     facilities that are not generally visited by permit writers.
     Thus,  these  small  facilities  are  likely  to   discharge
     wastewater untreated.

 3.   State and local regulations are  believed to be less  strin-
     gent and not as strictly  applied to MM&R facilities as  the
     type of national regulations applied to facilities in  other
     point  source  categories  generating  wastewater   loadings
     comparable to MM&R loadings.  For example, POTWs may require
     oil and grease concentrations in  a plant effluent to be  50
     mg/1, independent  of wastewater  flow (which  leads to  the
     possibility that compliance  may be  achieved by  dilution).
     Other effluent  guidelines for  categories similar  to  MM&R
     have only provided a discharge allowance of 10 mg/1 for  oil
     and grease  for only  those  operations that  generate  oily
     wastewaters,  thus regulating concentration and flow.

4.   The Domestic Sewage  Study (discussed in  Section III,  page
     17) highlights  the  relatively  large  load  of  wastewater
     toxics currently  discharged  by MM&R  facilities  to  POTW.
     This corroborates the estimates  presented here, which  were
     developed independently from the Domestic Sewage Study.
                                168

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APPROACH FOR ESTIMATING RAW WASTEWATER LOADINGS







The approach for estimating raw wastewater pollutant loadings had



two phases.  In  the first phase,  pollutant loadings were  esti-



mated for the  original 11 segments  using data collected  during



the MM&R  sampling  program  and from  prior  effluent  guideline



regulation records (Section  V, page 60).   In the second  phase,



pollutant loadings for 31  manufacturing segments were  estimated



based on data from the Machinery and Mechanical Products category



record.  Both phases of the approach are described below.








Pollutant Loadings for First Phase







The approach used to estimate raw wastewater loadings for the  11



MM&R segments is the traditional methodology used for  developing



effluent guidelines (Section X  of the Nonferrous Metals  Forming



Development Document).  This methodology was selected because the



wastewaters generated  by MM&R  operations are  similar to  those



generated by nonferrous metals forming operations.  The methodol-



ogy involves  estimating  wastewater  loadings  as  the  mass  of



pollutants generated by a specific group of unit operations known



as a normal plant.   Normal plants are hypothetical  arrangements



of  unit  operations  designed   to  approximate  the  range   of
                                 169

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 operations  present in  each segment.   The  development of  normal


 plants  is described in Section VIII  (page 154).






 For  the 11  industrial segments,  raw wastewater pollutant  loadings


 were calculated  for the  wastewater streams from unit   operations


 as the   product  of  the concentration   (mg/1) and   the flow  rate


 (1/yr)  for  each pollutant.    The unit operation  raw   wastewater


 loadings were  then added together to estimate the  raw   wastewater


 loadings for the normal plants.






 Raw  wastewater   loadings for   the 11   industrial   segments  were


 calculated  by scaling the normal plant loadings  up to  the segment


 level on a  production-normalized basis.   Scaile up  was   calculated


 on a stream-by-stream  basis,  since individual   streams had  dif-


 ferent production  values.  The  scale-up  factors were   calculated


 as number   of units   or   fleet size  (e.g., number  of aircraft,


 number of   office  machines)  serviced  or  manufactured  in  the


 segments divided by  the  number of units or  fleet size  serviced or


manufactured at  the   normal plants.  The  data available did  not
                                          1  ''«!.""  i ,'"!	  :    ii  ;     , .:"•	

allow scale-up factors  to be  calculated  on a mass or  production


basis for each unit operation and associated wastewater stream.
For toxic and  nonconventional organic  pollutants measured  more


than once  in a  given wastewater  stream, the  maximum  reported


concentration measured  for each  organic pollutant  was used  to


                                170

-------
calculate the loadings.  This approach was taken since there were



limited organics  data available  and  the detection  limits  for



organic analyses  of MM&R  wastewaters  were higher  than  method
detection limits.
                 12
This appears to overstate the raw wastewater loadings for organic



pollutants.  However, the data do not allow inferences about  how



representative the  wastewater  characteristics  at  the  sampled



plants are compared to all other MM&R plants.  It is not known if



the sampled plants represent the better plants or plants that  do



not consciously  strive  to  reduce  wastewater  loading  in  the



absence of regulations.   When considering the  full spectrum  of



plants within  the MM&R  project area,  it is  believed that  the



sampled plants represent  the better plants.   They were  sampled



after searching for  plants exemplifying well-operated  technolo-



gies in terms of both  process techniques and end-of-pipe  treat-



ment practices.  These  plants were also  sampled on a  voluntary



basis, partly  acknowledging  their  willingness  to  demonstrate



their confidence  and pride  in their  wastewater management  and



treatment  practices  (i.e., they had nothing  to hide).
      12See page 72.
                                 171

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 This approach for estimating pollutant loadings  is  also supported

 by the interchangeability  of toxic organic  pollutants in  metal

 processing  and  the  diversity of  process   chemicals   containing

 organic pollutants used by MM&R  facilities (see Section V,   page

 72).   Using  the  maximum  concentration  of organic   pollutants

 considers the full  range of organic  pollutants present in   MM&R

 wastewaters.   For metals,  non-conventional  (other than   organic),

 and  conventional pollutants,  the  mean concentration was used  to

 calculate the loadings,  since these pollutants do not exhibit the

 same  interchangeability as organlcs.



 Pollutant Loadings for  Second Phase
                                    .   ,:  , , .,   ,  . ,'•  •             .
For 31 manufacturing segments, raw wastewater  pollutant  loadings

were calculated  using  concentration and  wastewater  flow  data

compiled for  each of  the four-digit  SIC codes  comprising  the

industrial segments.  Two sources of data were used:


o    1982 Department of  Commerce "Water  Use  in  Manufacturing";
     and

o    Draff Development Document  for Effluent Limitations  Guide-
     lines and  Standards of  Performance for  the Machinery  and
     Mechanical Product Manufacturing Point Source Category, June
     1975 (M&MP report).


The 1982 Department  of Commerce  (DOC) report  presents data  by

four-digit SIC code  on water and  wastewater discharges in  MM&R

manufacturing facilities.

                                172

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The 1975 M&MP report presents  concentration data for 12  subcat-



egories, which are based on  groups of manufacturing unit  opera-



tions, not SIC codes.   Mine of the  12 subcategories pertain  to



MM&R.  One or  more of the  nine subcategories characterize  each



four-digit SIC code.  The M&MP report also presents the  percent-



age of  facilities within  each SIC  code that  fall within  each



subcategory.  For  each SIC  code, this  percentage was  used  to



compute a factor for scaling the wastewater flow attributable  to



each subcategory.







Within an SIC code, pollutant loadings estimated for each subcat-



egory were the product of the process wastewater discharge  flow,



the scaling factor, and the pollutant concentration.  Subcategory



loadings were then added to calculate the total pollutant loading



for the  SIC  code.  The  total  pollutant loading  from  a  MM&R



segment is the  sum of  the loadings from  applicable SIC  codes.



The total pollutant loading from a MM&R sector is the sum of   the



loadings from the applicable MM&R segments.
                                 173

-------
                                          ' "il
 POLLUTANT REDUCTION ESTIMATES
 The  preliminary   pollutant  reductions  estimated  for  direct  and



 indirect  dischargers  in each of  the  11 MM&R segments as a  result



 of applying  treatment technologies   are presented in Tables   IX-4



 and  IX-5  (pages  188 and 19O), respectively.  The  treatment  tech-



 nologies  selected for the  11 segments  are presented in  Section



 VIII  (page 156).  These reduction estimates are based on  147,000



 facilities or  15  percent of the  number of facilities in the   MM&R



 project area.  Reduction estimates are presented  for the  follow-



 ing   groups  of   pollutant  parameters:   Total   Toxic   Organics



 (including cyanide),  Total Toxic  Metals, Total  Nonconventional



 Organics, Total   Nonconventional Metals,  Total Other  Nonconven-



 tionals,  and  Total  Conventionals.   These  pollutant   removal



 estimates should  be revised after  more data are  acquired on  raw



 wastewater loadings and on  the   type and effectiveness of  treat-



ment  technologies on MM&R wastewaters.
When considered along  with other information  presented in  this



preliminary data summary, several  conclusions can be drawn  from



the data presented in Tables IX-4 and IX-5 that provide a  better



understanding of  the MM&R  project area.   First, it  should  be



pointed out that  the amount  of toxic  pollutants generated  and



discharged by indirect dischargers  (Table IX-5) is greater  than



the amount of hazardous pollutants discharged by MM&R  facilities



                                174

-------
estimated in the  Domestic Sewage  Study (see  Section III,  page



20).  The DSS estimated that manufacturing facilities engaged  in



equipment manufacturing and  assembly, electroplating, and  metal



finishing discharge approximately  8,900 kkg/yr  of toxic  pollu-



tants to POTW.  The DSS did  not report the number of  facilities



represented by  this  estimate.   The MM&R  estimates  show  that



approximately 13,OOO kkg/yr of toxic pollutants are discharged to



POTW.  This estimate is  based on only about  50 percent  of  all



MM&R facilities, but unlike the DSS, includes facilities  engaged



in rebuilding and maintenance as well as manufacturing.







Second, these tables  show much greater  raw wastewater  loadings



for indirect dischargers  than for direct  dischargers.  As  dis-



cussed in  Section V,  70 percent  of MM&R  facilities  discharge



wastewater to POTW, while only 1O percent discharge wastewater to



surface waters.  Further,  many MM&R  facilities which  discharge



wastewater to POTW are small facilities, and these small   facili-



ties, in aggregate,  contribute a large  amount of the  pollutant



loading.  These facts,  combined with the  large amount of toxic



metals and volatile  organics shown to  be generated  by  indirect



dischargers, have severe  implications for POTW,  which are  cur-



rently being studied by various  parts of the Agency.  The large



metal loadings may become part  of the sludge generated by POTW,



which may then  hinder sludge management  alternatives for POTW.



The volatile  organic loadings  may be  emitted by  the  aeration



                                 175

-------
 basins at POTW,  and  contribute to ozone  formation in the  lower
        11           '       n      '•      '   ""  ' ""li, ' !i|!  '   '  ii ' • , '   ''"''„'  ,'• ' i'1 :,!'„!'
 atmosphere or ozone depletion  in the stratosphere.  The  overall
 toxics loadings   from  MM&R  facilities may contribute  to  the
 toxicity  of the  POTW effluent,   and contribute  to forcing a  POTW
 to  undergo a toxics reduction evaluation (THE), at great  expense
 to  the municipality.   All   of   these impacts   on POTW  would  be
 greatly lessened if national regulations  were  put in place  that
 would  achieve removals  (at  the  MM&R facility) equal to or greater
 than those  shown on Table IX-5  for indirect  discharging  MM&R
 facilities.

 Finally,   these   tables  show  that  the  treatment  technologies
 preliminarily selected for  MM&R  would effectively remove  metals
 and other  conventional pollutants.

 It should  be   noted  that the pollutant reduction  estimates  pre-
 sented  in  this section do   not  quantify the  amount of  pollutants
 currently  being   removed   by   in-place treatment  technologies.
Based on the  available data characterizing treatment in-place  at
MM&R facilities,   very  little   removal  of   pollutants   from   raw
wastewaters is currently  being  achieved.  As  a result,  most  of
the pollutants generated  by MM&R unit   operations  currently   are
being discharged without  treatment to either  surface  waters   or
POTW.
                                176

-------
APPROACH FOR ESTIMATING POLLUTANT REDUCTION



The approach used to estimate pollutant removals for the 11  MM&R

segments is  the  traditional  methodology  used  for  developing

effluent  guidelines.   Pollutant   removals  are   traditionally

estimated as  the  difference  between  the  mass  of  pollutants

generated and  the mass  of pollutants  discharged following  the

application of best available control and treatment technologies.



The mass of pollutants  discharged after treatment is  calculated

as the product of  the wastewater flow  and.the treatment  effec-

tiveness concentrations  for a  specific set  of treatment  tech-

nologies.  As discussed  in Section VIII,  the technologies  pre-

liminarily selected  for  MM&R  include  oil  skimming,  chemical

precipitation, sedimentation, and multimedia filtration.  Cyanide

precipitation and  chromium reduction  preliminary treatment  are

included if appropriate.  For  the MM&R estimates, the  treatment

effectiveness concentrations for these technologies were  concen-

trations used  to  develop  effluent  guidelines  for  categories

similar to  MM&R.1^  A  complete description  of the  traditional

methodology used to  estimate  pollutant removals is presented   in
      ^Treatment  effectiveness  concentrations  were taken  from the
 Combined  Metals Data Base  (CMDB),   which is  discussed in   Section
 VII  of the Nonferrous Metals  Forming  Development Document.

                                 177

-------
 Section X of the Nonferrous  Metals  Forming  Development  Document.

 This  methodology was  selected   because  the  wastewaters  generated

 by  MM&R operations  are  similar   to  thosegenerated by   nonferrous

 metals  forming  operations.




 SUMMARY




 Raw wastewater  pollutant  loading estimates  show  that MM&R  facili-

 ties  generate 68 million  kilograms  per year  (150  million  pounds

 per year)  of toxic  metals,  16.5 million  kg/yr  (36.3  Ibs/yr)  of

 toxic organics,11* and 3,400 million kg/yr (7,50O million   Ibs/yr)

 of  conventional  pollutants (TSS and oil and grease).   Figure IX-1

 (page 191)   presents these  preliminary loadings  for  MM&R along

 with  pollutant   loading   estimates  for  other  metals   industrial

 categories already  regulated.  Figure  IX--1 shows  that the  raw

 wastewater pollutant  loadings  for the MM&R  project area  are

 slightly higher  than the  loadings for the other  categories,  with

 the exceptions   of  the  Iron and  Steel and the Metal  Finishing

 Categories.   This  shows  that  MM&R  operations  generate  more

 pollutants than  other point source  categories previously selected

 for regulation.
      '^Cyanide is grouped with toxic organic pollutants for  this
analysis.

                                178

-------
Preliminary pollutant reduction estimates  are presented for  the



original 11 segments  in Tables  IX-4 (page 188)  and IX-5  (page



190) for direct  and indirect  dischargers, respectively.   These



tables demonstrate that application of the treatment technologies



would result in significant  pollutant removal, particularly  for



toxic metal and conventional pollutants.  These tables show  that



96 percent  of  toxic  metals, and  99  percent  of  conventional



pollutants, can be removed with treatment.







No removals occur for toxic organic pollutants because   treatment



technologies specifically designed  to remove organic  pollutants



were not included   in the  MM&R treatment  scheme   (see page   156,



Section VIII).   For  the purpose  of  these  tables,  cyanide   is



grouped with toxic  organic  pollutants.  Since  cyanide in waste-



water generated  by electroplating operations   in  the   aircraft



rebuilding segment  is removed by  the preliminary  MM&R   treatment



scheme, pollutant removals are shown under  toxic  organic  pollu-



tants for  the  aircraft  rebuilding  segment.
                                 179

-------







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-------
                                       Table |X-3

                        SUMMARY OF RAW WASTEWATER LOADINGS FOR
                          OTHER METALS INDUSTRIAL CATEGORIES
 CATEGORY:   SUBCATEGORY

 ALUMINUM FORMING:

     Rolling with Neat Oils
     Extrusion
     Forging
     Drawing with Neat Oils
     Drawing with Emulsions


 BATTERY MANUFACTURING:

     Cadmium
     Calcium
     Lead
     Leclanche
     Lithium
     Magnesium
     Zinc
                                        Total Toxic
                                          Metals

                                          (kg/yr)
                                            252,000
                  To.tal.  Toxic
                 Organics  and
                    Cyanide
                    (kg/yr)
                       4,700
                  Conventional
                   Pollutants

                    (kg/yr)
                      5,018,000





1,


1,




18,502
193,948
17,457
20,500
1,445
811,000
194,242
8
604,930
5,570
3.7
160
5,678
1,668
2,576
125
183
145
36
36
._
--
--
--
--
--
1,473,000
2,676,000
366,000
382,000
121,000
9,736,000
295,000
47
9,390,000
44,298
157
1,592
5,310
COIL COATING:

     Aluminum
     Canmaking
     Galvanized
     Steel
                                            307,000
                      45,000
                  : ",i,P  . ,,: 'H' ,„ f ,,,, , ,„ |
                   104,000,000
205,123
31,710
50,401
20,181
2,995
39,800
120
1,736
668,667
103,000,000
100,259
663,479
 IRON AND STEEL:

     Coke Making
     Sintering
     Iron Making
     Steel Making
     Vacuum Degassing
     Continuous Casting
     Hot Forming
     Salt Bath Descaling
     Pickling
     Cold Forming
     Alkaline Cleaning
     Hot Coating
106,000,000

    117,000
    290,000
 31,000,000
 20,000,000
    606,000
    523,000
 44,500,000
    170,000
  6,700,000
    300,000
      6,100
  1,900,000
22,000,000

 7,500,000
    44,000
14,000,000
    10,800
   332,000
     1,100
                                                                        12,405,000,000

                                                                             5,630,000
                                                                         2,700,000,000
                                                                         2,300,000,000
                                                                         1,800,000,000
                                                                             4,600,000
                                                                            27,000,000
                                                                         5,450,000,000
                                                                               454,000
                                                                            10,000,000
                                                                           103,000,000

                                                                             4,090,000
METAL FINISHING:
                                        73,816,000
                 16,757,000
                  NOT REPORTED
                                            186

-------
                               Table IX-3 (Continued)

                      SUMMARY  OF RAW WASTEWATER LOADINGS FOR
                        OTHER  METALS INDUSTRIAL CATEGORIES
CATEGORY:  SUBCATEGORY

NONFERROUS METALS FORMING:

     Lead-Tin-Bismuth
     Magnesium
     Nickel-Cobalt
     Precious Metals
     Refractory Metals
     Titanium
     Uranium
     Zinc ,
     Zirconium-Hafnium
     Metal Powders
                                       Total Toxic
                                         Metals

                                         (kg/yr)
346,000

    262
 16,911
103,837
    170
    354
    797
     62
221,977
   15.5
  1,239
             Total Toxic
            Organics and
               Cyanide
               (kg/yr)
41,000

    .6
   .11
   .09
  , 67
   .03
   .77
   .09
40,372
   640
  3.13
             Convent ional
              Pollutants

               (kg/yr)
784,000

  5,990
  3,626
543,139
 14,763
 64,500
 47,400
 12,874
 24,853
 10,115
 56,436
NONFERROUS METALS MANUFACTURING:          2,610,000

     Primary Aluminum                       70,516
     Secondary Aluminum                     20,896
     Primary Copper                         48,939
     Secondary Copper                        9,462
     Primary Lead                            4,880
     Primary Zinc                        1,805,875
     Metallurgical Acid Plants             161,635
     Primary Tungsten                        8,888
     Primary Columbium - Tantalum           80,243
     Secondary Silver                       36,000
     Secondary Lead                         73,721
     Primary Antimony                       17,584
     Primary Molybdenum fie Rhenium           73,670
     Secondary Nickel                        1,687
     Primary Precious Metals
          and Mercury                       50,447
     Secondary Precious Metals             144,144
     Secondary Tin                             804
     Primary and Secondary Titanium            512
     Secondary Uraniua                         173
                 161,000

                 159,870
                     739
                     1.5
                     .14
                      18
                     265
                       9
                31,971,000

                21,715,230
                   721,263
                    49,946
                     4,080
                   275,231
                   398,678
                   491,565
                   .89,571
                 2,353,016
                    31,602
                 4,139,370
                     9,144
                    53,817
                   933,533

                     3,353
                    80,316
                   508,815
                   111,000
                    ' 1,089
                                           187

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'mi    '   ,!„   'I   !    ,i!	I,,,,

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                            SECTION X
                       ECONOMIC ASSESSMENT
The U.S. EPA  is considering development  of effluent  guidelines

for the  Machinery  Manufacturing,  Rebuilding,  and  Maintenance

(MM&R) industries.   At this  time, the  scope of  the  potential

regulation is very broadly defined to include facilities  related

to transportation,  office  machines, electronic  and  electrical

equipment and machinery, laboratory and medical instruments,  and

other miscellaneous manufacturing  and repair.   In total,  there

are almost 200 four-digit SIC  codes, which could potentially  be

covered by these regulations.  Almost 97O,OOO facilities could be

covered by an effluent guideline.1^   Due to the large number  of

SIC codes potentially  covered by  these regulations,  it is  not

possible to examine  all of  them  in  this preliminary  analysis.

The analysis  presented here  focuses on  the transportation  and

office machine sectors only.  This chapter describes the economic
 1^Table X-1 (page  307) presents  a list of  segments defined  by
 four-digit SIC codes  with preliminary  counts of  the number  of
 facilities in each SIC code.   These counts, which total  969,710
 facilities, are taken from Dun  & Bradstreet.  They are based  on
 primary SIC code only and include all facilities with one or more
 employees.
                                 193

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                                       ''"I 'in1: ' "!,!• i', 'I!	!",,' '..' , lh,
                                                  	 '"'.ili'i	!i , " ' " 'HI! "VibW'in'!!'!' ' ",•	I'l' W1 JiCllli1 :;illli::'"P .liF'i
and  financial characteristics of and preliminary economic  impacts
on these two sectors.

For  purposes of this analysis, the transportation sector includes
the  manufacture,  rebuilding  and maintenance  of motor  vehicles,
aircraft and  railroad  equipment.  Shipbuilding  and  associated
functions are not addressed at  this time.  The office  machinery
sector   includes   the  manufacture,  repair  and  maintenance  of
duplicating  machines,   typewriters, electronic  computing  equip-
ment,   calculating  and  accounting  machines  and  other  office
machines.
In the  pages   that  follow,   we  present a  preliminary  economic
assessment of   eleven  industry  segments  Included in  these  two
sectors.  This   section   discusses  the  types  of  products  and
services provided  by each of the transportation-related  segments
potentially covered  by  the   regulation and  presents   available
published data  describing their economic and financial character-
istics.  The  section  also   presents  preliminary  estimates  of
economic and financial impacts  that might occur  as a result  of
effluent treatment costs.  Similar  information is presented  for
the office  machine  sector   on  page 246.   The  effect  of  the
                     ,,'  '   ' •: •• i •' ,„    '  ,  :''  •"' " , 'i',1 „• a "I!1!,,,""',, " , !   , •  ,'ii1 . .,, Jij'l „ X' 	„.,,.   "• ,„"' YII'".., '. ,,i,
regulation on   military  contracting  is  discussed on  page  256.
Limitations of  the analysis  are discussed on page 28O.    Finally,
the cost-effectiveness analysis is presentesd on page 285.
                                 194

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It should be  noted that  since this is  a preliminary  analysis,



treatment cost  estimates were  not  available for  all  industry



components potentially covered by the regulation.  Therefore, the



economic profiles are  more inclusive than  the impact  estimates



and attempt  to  cover  all  transportation  and  office  machine



segments.  The  impact  estimates correspond  to  those  segments



covered by  the technical  analysis and  the resultant  treatment



cost estimates.  Descriptions of differences in coverage  between



the profiles and the impact estimates for each industrial segment



are included .in the appropriate section.








TRANSPORTATION







Transportation  is  a  broad  industry classification  which can  be



disaggregated by mode  - highway, rail, air  and water.   Highway or



motor  vehicle   travel   can  be   further   split   into   automobile,



motorcycle,  truck, and bus.   As  indicated above,  the  MM&R   trans-



portation  sector  includes  facilities   which   (1)    manufacture



transportation  equipment  and  components;  (2)   rebuild,  repair,



maintain or otherwise  service motor vehicles on  a retail basis or



as part of another retail operation  (e.g.,  new  car dealers); and



 (3) rebuild,  repair, maintain or otherwise  service transportation



equipment in  the  course  of providing  transportation  services.



The following subsections are organized by  mode of transportation



and by type of industry (manufacturing,  retail  trade or  service)
                                 195

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                                       "i •/, 'JP'ji"1-	; Ilil/i	''In
 within each  subsection.  Where  applicable, an   effort  has   been
 made to identify those segments which provide a significant  share
 of goods or services to the military.
                                                                 ,„ , "!!l '• 1,'il ,•'	;],l*" ,
 Motor Vehicle Transportation

 Highway or motor vehicle transportation includes all firms  which
                                    1 ' •  .   ,. i. HI'1 . ,'"l"i, '.' •  ,' :' , ',      . :  ,	1. 	 ' • '
 manufacture or service  any type  of motor  vehicle.  Within   the
 manufacturing group,   products range  from automobiles,  motorcy-
 cles,  trucks and buses to tanks and tank components.  The  retail
 trade  component includes  both motor vehicle  dealers and  rental
 agencies,  as well  as gasoline  stations and  repair shops.    The
 third  group,   transportation  services,   includes  bus  and  taxi
 service as  well  as   local  and  long   distance  trucking.    The
 segments contained in each of these groups are described  briefly
 below.

 Economic and  Financial Characteristics

 Vehicle  Manufacturing
On the manufacturing  side,  the motor   vehicle category  includes
those establishments which produce:

     o    Components, such as  carburetors  (SIC 3592)  or  electri-
          cal equipment   (SIC  3694).   Carburetor   rebuilding  is
          included as part of  SIC  3592.
                                 196
                                                                 ,1 ",„>:.»! >;

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     o    Motor  vehicle   bodies  for  . automobiles  (SIC   3711).  and
         trucks and  buses  (SIC  3713),   as  well as  motor   vehicle
         parts  and   accessories,  including  engines  (SIC  3714),
         and truck trailers  (SIC  3715).

     o    Motorcycles (SIC  3751) and travel trailers  and   campers
          (SIC 3792).

     o    Tanks   and   tank   components   (SIC  3795).    These  are
         presumably  for military  purposes  only.

     o    Miscellaneous   transportation  equipment  (SIC    3799).
         This includes  such items as golf  carts, snowmobiles and
          trailers.


As shown in  Table X-2 (page  315),  some of  these segments  have

grown over  the past fifteen years while others have contracted or

remained  relatively  stable.17    Increasing  competition   from

imports has led  to a decline   in sales of  domestically-produced

passenger cars, resulting in reductions in the value of shipments

of automobile manufacturers (SIC 3711) and suppliers (SICs 3694 -

Engine Electrical Equipment  and 3714 -  Motor Vehicle Parts  and

Accessories).   (Note that SIC 3592  - Carburetors,  Pistons,  Rings

and  Valves also provides parts  for  other types of  transportation

equipment, such as  aircraft.   Hence,  its  sales  have   remained
 l6Unlike  some manufacturing  SIC  codes,   SIC  3795  (Tanks  and   Tank
 Components)  does   not    have  finer  product  group codes    to
 distinguish  military and non-military products.

 17A11  dollar values presented  in this chapter are reported in May
 1988 dollars.    This was done   to ensure   consistency  between
 economic  and  financial data  and  the  treatment   cost  estimates
 derived by the  technical analysis.   For ease of reference,  these
 May 1988  dollars are referred  to as simply "1988  dollars".
                                 197

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 relatively steady.)  This fall in product demand,  coupled with  a

 move towards  increased automation  and  robotics, has.  caused  a

 substantial  decline  in  employment.   For  example,   production

 worker employment in automobile manufacturing (SIC 3711) fell  by

 approximately 3O  percent between  1972 and  1982; the  value  of

 shipments decreased by about 20  percent over this ten year  time
 period.
        18
 In additionto measures of size such as revenues  andemployment,

 Table  X-2  also presents specialization and  coverage ratios.    The

 specialization ratio   shows the  percentage of revenues   derived

 from products  in  that  SIC  code  relative to  total  product  revenues

 for establishments  classified  in  that SIC  code.  The   coverage

 ratio  depicts  the percentage of total  revenues from the sales  of

 products in  that  SIC   by establishments in   that  SIC relative  to
                                   '     |!  'i i
 sales  of  products  in that SIC  by   all   establishments.    For
            :'•       _                 '    ,' .:lil    i I             "
 example, establishments  in  SIC   3711   (Motor Vehicleand   Car

 Bodies) tend to be highly  specialized  in the production of motor

 vehicles and car  bodies; their  specialization  ratio has   remained
1 fl
  The Census  of  Business, conducted  every  five years  by  the
Department of Commerce, is the most consistent source of  compre-
hensive data  by  detailed  segment (i.e.,  four,  five,  six  or
seven-digit SIC codes).  The most recent data are for 1982.  Data
from the next Census,  which will cover  1987, will be  available
for manufacturing industries  in mid-1989.  Release  of data  for
trade and service industries has not yet been scheduled; however,
they are expected to be available sometime in 1990.
                                198

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at 95 to 96 percent over  the 1972 to 1982 period.  In  addition,

these establishments produce 99  percent of all products  covered

by this SIC code.   These ratios provide interesting  information

in and of themselves and can  also be used to estimate the  total

value of shipments of products in a given SIC code.
Sales of domestic truck  and bus bodies  and truck trailers  also

fell between 1972 and  1982.  While imports  may explain a  small

portion of this decline, particularly  in the light truck segment,

the economic  slowdown  of   1980  to   1982  and  deregulation  as

required by the Motor Carrier Act  of  1980  (MCA) are more  likely

answers.20  Trucking services and, hence, vehicle purchases  tend

to follow the cyclical behavior  of the economy.  More  recently,

the demand for trucking services and,  therefore, for trucks,   has

increased as a result of  general economic  growth.   In  addition,

the initial perturbation caused by deregulation  is subsiding and
         use in estimating product-specific revenues is  discussed
 in greater  detail  on page  2O9  - Preliminary  Economic  Impact
 Assessment.

 2OThe MCA relaxed regulatory barriers into the trucking  industry
 and provided for  price competition among  carriers.  While  this
 resulted in market entry, it also caused a number of  inefficient
 carriers to  exit  from  the  industry.   In  addition,  the  MCA
 permitted backhauls,  i.e., carrying  cargo on  the return  trip,
 which effectively increased existing trucking capacity.
                                 199

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 the market is  beginning to stabilize.21   However, as  remaining

 inefficient trucking firms or  owner-operators continue to  leave

 the industry, the supply of used vehicles will increase, reducing

 sales of new vehicles.22
 While much of  the motor vehicle  manufacturing segment has  been

 experiencing a contraction,  SIC 3795 (Tanks and Tank  Components)

 has  been expanding — probably due to increased defense spending.
                              ,   '•,  •:  ' ,' ',. '.,'; "' ' '.f'li .-'' 1't 'l ;.  ',	•"' '  "	r'SOS ! MJ i'
 Between  1972 and 1982, the  value of shipments (in constant  1988

 dollars) increased by a factor of four  —  from $729.5 million  in

 1972 to  almost $2.5 billion  in 1982. Total employment rose  from

 about 6,000 to 18,000 and the number of establishments  doubled.

 Capital  expenditures  increased from  $8.3  million  (in  constant

 1988 dollars)  in 1972 to $121.9 million in  1982.




 The  generally   poor  performance  of the  early  1980's  is  also

 reflected  in the profit-to-sales ratios shown in Table  X-3  (page

 316).  Looking at  data for   1982 to 1986   shows that   automobile

manufacturers'  profit ratios  reached a low  in 1983,  but rebounded
            '        '    '                  .,,.,.
  See Nicholas A.  Glaskowsky, Effects of  Deregulation  on   Motor
Carriers.   Eno   Foundation   for   Transportation,     Westport,
Connecticut, 1986,  p. 69.   This  1986  publication   acknowledges
that "deregulation of the motor  carrier  industry  is  pretty   much
complete."
22               "    ' "      	      "     ' ''  '" '"  ' ' '   ''.••' •••  ''	'•'	
"U.S. Department  of Commerce,  U.S. Industrial   Outlook.   1988,
p.38-6.	'	'
                                200

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in 1984.   They  have remained  relatively  constant at  about  4

percent of sales  between 1984 and  1986.  According to  Business

Week, 1987  profit to  sales ratios  for the  big three  domestic

automobile manufacturers ranged  from 3.5 to  6.5 percent.   Ford

led with 6.5  percent, followed  by Chrysler at  4.9 and  General

Motors with 3.5 percent.2^



On average, firms in SIC 3713 (Truck and Bus Bodies)  experienced

a loss in  1983 and made a very small profit in 1984.  After that,

conditions seem to have improved; profits averaged over 4 percent

of sales in both 1985 and 1986.



Retail Trade



The  retail  trade  segment  includes  those  establishments  which

sell, service,  or  rent  automobiles,   trucks,  motorcycles  and

recreational vehicles.  Fifteen four-digit SIC codes are  covered,

as follows:


     o     Dealers of  new and  used cars (SICs 5511  and 5521),
           motorcycles   (SIC 5571),   recreational  and   utility
           trailers (SIC 5561)  and other motor  vehicles  such  as
           dunebuggies, snowmobiles, or go-carts (SIC 5599).  Many
           establishments in these  industries also operate vehicle
           repair and maintenance facilities.
 23»Top   1OOO"   (American  Companies   based  upon  Market   Value.)
 Business Week.  April  15,  1988.
                                 201

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           Gasoline* service  stations  (SIC  5541)  which  include
           establishments primarily  engaged in  selling  gasoline
           and lubricating oils.   Many  of these do motor  vehicle
           repairs.
           Rental of passenger cars (SIC 7512),  trucks (SIC  7513)
           and recreational  vehicles  and utility  trailers  (SIC
           7519).  Maintenance and repair of rental fleet vehicles
           is generally done at these establishments.

           Repair shops,  including general automotive  repair  (SIC
           7538)  and services (SIC 7549),  as well  as top and  body
           repair (SIC 7531), automotive  paint  (SIC 7535),   parts
           repair (SIC 7539) and welding shops (SIC 7692).
Table  X-4   (page  317)   presents  available   Census  information   on

sales  and  employment that   can be used  to   assess  changes  in   the

number and size   of these, establishments  over  time.2**   As shown

there, the number of   new car   dealers decreased   from  about   32

thousand in 1972  to approximately 27  thousand in 1982.   Note that

these  include  dealers  of   both  foreign and  domestic   vehicles.

More recent estimates indicate that the number  of   establishments

fell to about 25  thousand in 1984 and  has since  remained rela-

tively constant.25  Sales  increased   by about 18 percent   between

1972 and 1977, but then, in  1982, fell  back to  their 1972  levels.

They have  since regained ground  and  are expected  to reach about

$300 billion in 1988.
      Census of Retail Trade and the Census of Service Industries
do not publish  data on capital  expenditures, specialization  or
coverage ratios.

25U.S. Department of Commerce, U.S. Industrial Outlook. 1988,  p.
61-8.	*	
                                202

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Both used car sales  (by used car  dealers) and motorcycle  sales

have remained  relatively  constant.   The  number  of  used  car

dealers increased slightly between 1972 and 1982, while the total

number of employees fell, suggesting a drop in the average number

of employees  per establishment.   On the  other hand,  both  the

total number  of motorcycle  dealers and  their total , employment

increased over  the ten  year period  to maintain  an average  of

about six employees per establishment.



The number  of gasoline  service  stations fell  dramatically  --

probably as a result of the  gas crises of the 197O's.  In  1972,

there were  over 226  thousand gasoline  service stations.   This

number fell to about  176 thousand in  1977 and to 136 thousand  in

1982.  The drop in employment  was considerably smaller —  about

2O percent between 1972 and  1982.  Sales increased by almost  4O

percent.



According to Census data, the number  of general automotive repair

shops  (SIC 7538)   increased slightly  between   1972 and 1977,  but

fell dramatically  in   1982.26   (See Table  X-M).  Sales   remained

relatively stable  over the  period, however, fluctuating  between

$7 and $8 billion.    Both  the  number and revenues of  automotive
 2^This decline   is   also  evidenced   in   data from   the   1984   Job
 Service  Analysis, Hunter  Publishing  Company,  Des Plains, IL.
                                 203

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 parts and  repair  shops  (SIC   7539)  have  grown  consistently   since

 1972.  This  classification   includes  establishments   specializing

 in  the repair of  specific parts,  e.g., radiators,  transmissions,

 brakes,  carburetors.  The  fact that  it  has grown while  general

 automotive repair has declined  suggests a trend toward  special-

 ization.



 Profit-to-sales ratios  are   lower  for   the  distribution-related

 establishments (SIC 55) as   compared  with the  automotive  service

 group (SIC 75).   (See Table   X-5, page 319.)   Before  tax  profits

 represent  about 1 to 2 percent of sales  for,new car dealers   (SIC

 5511),  gasoline  service  stations   (SIC  5541)  and  motorcycle

 dealers  (SIC 5571).  Profits-to-sales ratios for used car dealers

 (SIC 5521) and  establishments selling   recreational and  utility

 trailers are slightly higher  —   ranging from  1.1 to 2.8  percent
                                            *.  •'   '   '   '• 1   ••   	i
 of sales.
Establishments renting cars and trucks (SICs 7512 and 7513)  have

been earning profits ranging from 5  to 7 percent of sales.   The

remaining service  categories  shown  on Table  X-5  have  profit

margins in the 3 to 6 percent range.
                                204

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Transportation Services
This group includes establishments  whose primary function is  to

move people or  goods over  our nation's  highways.  Since  these

establishments must maintain and repair their vehicles, they  are

considered  within  the  scope   of  the  potential   guidelines.

Specific segments covered include:


     o    Local and suburban passenger  transportation by bus  or
          subway (SIC  4111),  by limousine,  van,  ambulance  or
          hearse (SIC 4119), by taxi (SIC 4121).

     o    Intercity and  rural  highway bus  transportation  (SIC
          4131).

     o    Local and non-local bus charter service  (SICs 4141  and
          4142).

     o    School buses (SIC 4151).

     o    Bus terminals  (SIC  4171) and  maintenance  facilities
          (SIC 4172).

     o    Local trucking  without  storage  (SIC  4212)  and  with
          storage (SIC 4214).

     o    Non-local trucking  (SIC 4213)  and trucking  terminals
          (SIC 4231).


The Census  does  not  cover  these  segments   in  great  detail.

Consistently available data  include only the number of establish-

ments and employment for selected four-digit SIC codes. These are

presented in  Table X-6  (page 320).    As can   be  seen  from the

table,  the number of establishments engaged in  local and  suburban

transit (SIC 4111)  remained remarkably stable  between 1972 and

 1982, varying by less  than  3 percent.  Employment  increased  by   2O
                                 2O5

-------
 percent,  however,   raising the  average number  of employees  per

 establishment from about 3O in 1972  to 37 in 1982. In  intercity

 highway transportation,   both the  number of  establishments  and

 employment remained relatively steady.   The average facility  has

 about  50  employees.
Employment  in  taxi   cab  operations   fell from  over 1O4  thousand

employees in  1972 to under  44  thousand in  1982— a decline  of

about 58  percent.   The  number  of establishments  decreased  by

approximately  25 percent.    This  may  be explained  by the  sharp

increases in gas prices  during  the  197O's.
                                                                »'" • ; 1 if",,	,:!»-'	!:
The number local and long distance  trucking  facilities   increased

by about  10 percent  over the   1972  to   1982 period;employment

increased by an equivalent proportion.  However,  the  1982  data do

not reflect  fully the  effects  of trucking deregulation.    The

Motor Carrier Act of 1980 (MCA), whichrelaxed entry  requirements
                             - -  , ,  ',. ,  	 i- it	i ,'  . -ill	Mi"., [• 	 i '.i' •,' ,  • -I	 ,, •. r ,,' •!.. •„.;.., ,»! i	:,r

and permitted (encouraged) price competition, has had a signifi-

cant impact on intercity carriers (SIC 4213).
Intercity carriers can be divided into two principal segments:


     (1)  Truckload (TL)  -  These  carriers  transport  freight,
          generally for a single shipper on a for-hire basis,   in
          truckload-sized lots.  They go from a single origin^  to
          a single  destinationand  are characterizedby  small
          firms and owner-operators.  Financial barriersto entry
          are relatively low as is  technology, both in terms   of
          equipment and labor skills required.
                                206

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     (2)  Less-than-Truckload (LTL) - Firms in this group carry a
          number of  less-than-truckload  consignments  for  many
          different shippers on a given trip. In order to operate
          profitably, an LTL carrier must sort a large number  of
          small shipments  by  origin, destination  and  time  of
          delivery and combine  those with  common routings  into
          truckload-sized lots.  To do this requires an extensive
          network of terminals with adequate warehouse space  and
          organization (e.g,  a management  information  system).
          For this reason,  financial and technological  barriers
          to entry are high and LTL carriers tend to be consider-
          ably larger than truckload operators.


To a  large  extent,  these  two  segments  serve  two  different

markets.  While LTL carriers  may transport freight in  truckload

lots, TL carriers will seldom handle less-than-truckload lots.
The MCA has had  significant effects on  each of these  segments.

The ease of entry into the TL segment initially resulted in  many
new entrants —  about 12,000, according  to one source
                                                        27
This
caused intense price competition and a resultant decline in  real

prices for truckload shipments.  LTL rates also dropped  sharply,

particularly in  the  early 198O's.   Much  of the  initial  rate

decrease can  be  attributed to  low  shipper demand  and  excess

industrial capacity caused by the  1980-1982 recession.   However,

the downward  pressure  on  LTL rates  remains  as  LTL  carriers
attempt to be among the survivors of the "industry shakeout".
                                                           .. 28
27Glaskowsky, Effects of Deregulation on Motor Carriers, p.  1O,

28Ibid
                                2O7

-------
 The impacts of the MCA,  coupled with insurance premium  increases
 of 72  percent and 29 percent in 1985 and 1986, respectively,  has
 resulted in severe financial pressure and a substantial  increase
 in the number of business failures.2^  The number of failures for
 intercity carriers rose  from 549 in  1984 to 714 in 1985,   almost
 thirteen times the number of such failures in 1978.3°
Table X-7  (page   322)  presents  profit-to-sales ratios  available
from Robert Morris  Associates (RMA).    Of the five SIC codes  for
which data are   available,   operating school  buses  (SIC  4151)
appears  to be  the most profitable,  with an average profit  margin
of about 6 percent.    Profitability in intercity bus  transporta-
tion (SIC  4131) has  been  falling since1983.   This may  reflect
competition from  other modes,  such   as  air,  where  some  fares
dropped  significantly   over   this   time period   as  a  result  of
deregulation.
Since the  demand for  freight   transportation  depends   upon  the
level of  economic  activity, it  is  not  surprising   that  their
                     , .-        ,  ,!  '' I, " I  ,	• •	 !• :  . i .  -. •, ' J "I '.   •'• "if	Hi:::,
profit margins tend to follow the economic cycle.   Both  local
and  long  distance  trucking   saw lower   than average  profits
"if	iii::;,1"*. ft .'•.:»	mi;.1	
2"u.S. Department of Commerce, U.S.  Industrial Outlook.  1987.
30Op.Cit.. p. 8.
                                2O8
                                                                 V<,IW ., •'<

-------
in 1983.  Profit  margins recovered  in 1984  and have  generally
remained in the 3 to 5 percent range.
                                     31
Preliminary Economic Impact Assessment







This section presents  a preliminary assessment  of the  economic



and financial impacts that might occur as a result of  regulating



effluents of motor  vehicle-related industries  engaged in  MM&R.



Since the technical analysis  and the costs  were developed on  a



process basis, they do not, in general, correspond to SIC  codes.



Rather, they  relate to  specific processes  or activities  which



take place in a  given segment.  Table X-8  (page 323) shows  the



general relationships between the processes that were used in the



technical analysis  and the  SIC  codes discussed  above.   Note,



however, that in most cases, segment-level costs and,  therefore,



impacts, do not include all of the four-digit SIC codes shown  in



the table.







The preliminary impact analysis presented  below is based on  the



industry segment effluent  treatment costs and  has, in  general,



disregarded SIC codes.  For purposes of comparing treatment costs



to segment  revenues and  profits, an  attempt has  been made  to
31
  Profit margins for TL vs.  LTL carriers are not available  from
secondary sources.
                                2O9

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 develop  estimates  of revenues  and  profits  that  correspond to  the

 segments used  in the technical analysis.   Impacts  were  estimated

 for  five motor vehicle-related segments, including:
      (1)   Automobile  Rebuilding and Maintenance
      (2)   Automobile,  Bus, and Truck  Parts  Rebuilding
      (3)   Bus and Truck  Rebuilding
      (4)   Bus and Truck  Maintenance
      (5)   Radiator  Rebuilding and Maintenance
Each  is discussed below.
Automobile Rebuilding and Maintenance
This segment has been defined  to include those facilities  which

rebuild or  maintain automobiles.   As   indicated by  Table  X-7,

these generally include service stations, auto repair shops, auto

dealers and auto rental  agencies.  Segment treatment costs  were

estimated based on the number of service bays in the universe  (as

defined by the 1984 Job Service Analysis) relative to the  number

of service bays at the  normal plant.  (SeeSection VIII.)   This

universe includes  approximately  1,88O,OOO service  bays  spread

across service stations,  independent repair shops,  new car   and

truck dealers and self-service fleet shops.  Table X-9 (page 325)

shows the number  of establishments, service  bays, revenues   and

estimated profits  for each  of the  four facility  types and  in

total.      "             ',               	''       	
                                                                 .' >V ' *'«'" .'*
                                210

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Revenues for repair and  service activities of service  stations,

independent repair shops and new car and truck dealers were taken

directly from the 1984 Job  Service Analysis.  Revenue for  fleet

shops was  not  available directly  and  was estimated  based  on

average  revenue  per  bay  for  the  other  three  establishment

types.32   Profits  were  estimated  using   1984  profit-to-sales

ratios from Robert Morris Associates  (Table X-5, page 319).   In

most cases, 1984 also represents the median profit-to-sales ratio

for the 1982  to 1986  time period.  Four-digit  SIC code  ratios

were assigned as follows:
     o
     o
     o
     o
Service stations - SIC 5541 Gasoline Service Stations
Independent Repair Shops - SIC 7538 General Auto Repair
New Car and Truck Dealers - SIC 5511 New Car Dealers
Self-Service Fleet  -  SIC  7512 &  7513  Car  &  Truck
Rentals
To  the extent  that  repair work  done by new  car  dealers  tends   to

be  more profitable  than new  car sales, repair  and  service-related
                                                   O O
profits for new  car dealers  may be  underestimated.^-3   Similarly,
   An unweighted  average  was used,   i.e.,   the mean  of  average
 repair   and  service  revenues  per   bay  for  service  stations,
 independent repair shops and new car and truck dealers.

 33While the relative profitability of new car sales versus repair
 and service work performed by car dealers is not known, the  RMA
 data indicate that overall,  new car dealerships (whose  revenues
 and, hence, profit margins are  clearly weighted towards new  car
 sales)  are  less  profitable than  independent  repair  stations.
 This suggests  that  repair and  service  work carries  a  higher
 profit margin than new car sales.
                                 211

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 the profitability of car and truck rental establishments may  not

 accurately reflect that of all fleet service facilities; however,

 more  comprehensive  data  were  not  available  from   secondary

 sources.
 Table X-10  (page 326)  presents  estimated treatment  costs  and

 impacts for  each of  the four  establishment types  involved  in

 Automobile Rebuilding  and Maintenance  and  for the  segment  in

 total.   Treatment  costs reflect  the  MM&R project  average  for

 treatment in-place as well as  the total for direct and  indirect

 dischargers.   Costs were allocated to each of the four establish-

 ment  types based  on the number of bays in each group.   Annualized

 costs were computed using a  capital  recovery factor,  assuming a

 useful  life of ten years and   an interest rate of 1O.34  percent.

 The interest  rate is  based on the prime  rate in May  1988   (8.84

 percent)   plus 1.5  percentage  points.    The  addition  of  1.5

 percentage points  attempts to  account  forthe fact   that   some

 firms will be able  to borrow  at the  prime  rate,  while   other

 smaller companies will   be  perceived  by   lending institutions  as

 being a  greater  risk  and  will   therefore  need   to pay   interest

 rates equal to several  percentage  points  above the prime.^
34
  A more detailed  discussion of the  rationale for  differential
interest rates is  contained in the  Economic Impact Analysis  of
Effluent Limitations  Guidelines and  Standards for  the  Organic
Chemicals. Plastics  and  Synthetic Fibers  Industry.  U.S.  EPA,
                                  (Footnote Continued)
                                212

-------
Impacts are  measured  as  annualized costs  relative  to  annual

revenues and to  before tax profits.   Since the elasticities  of

demand and supply are not  available from secondary sources,  the

analysis assumes zero cost pass through.  This clearly represents

a conservative, worst case cost pass through assumption.  Cost as

a percent of sales can be interpreted as a rough approximation of

the percentage price increase that would result if a 10O  percent

cost pass through occurred,  (i.e., it represents the  percentage

increase in price needed  to cover treatment  costs).  Cost as  a

percent of profits represents the reduction in profits that would

occur if facilities, in  fact, had to absorb  1OO percent of  the

treatment costs, i.e., if they could not pass through any of  the

costs in the form of higher prices.



The results  of  the  analysis  indicate  that  annualized  costs

represent a fairly consistent  percentage of revenues across  the

four automobile rebuilding  and maintenance establishment   types,

ranging from 1.3 to  1.5 percent with an average of  approximately

1.4  percent.  (See  Table   X-10,  page  326.)   Assuming   that

annualized costs in  excess of 5 percent of revenues represents  a
Office of Water, September  1987.   That analysis used  three   firm
sizes.   It was assumed  that the largest firms  could borrow at the
prime rate, mid-size  firms  at prime  plus  1.5  and  small  firms  at
prime plus.2.5 percentage points.
                                 213

-------
 significant impact, the  average establishment in  this group  is
 unlikely to incur a significant revenue impact.
 There appear to  be profit  impacts in  all four  types of  esta-
 blishments.   Annualized costs for  service stations represent  an
                     i,            '. ,  '  »',,,' 'i! !,"' ,„ ; ..... I' ',»!, .'•'! . i. i I- ...... '! ' i i!!""!f ~ . • .,   '    ..... ,'
 average of  105  percent  of  annual  bef ore-tax  profits.   This
 suggests that if these facilities were unable  to increase  prices
 to cover  at least  part  of the  effluent treatment  costs,   the
 average facility would not only fail to make a profit,  but  would
 also  incur a  loss equal  to about  5 percent   of its   annualized
 treatment costs.   In this   situation,  it is. quite likely that  a
 substantial  number of  service stations would close or discontinue
 performing automobile  repair work.
If one considers only profits associated with service and   repair
work, the average  new car  and truck  dealer is  also likely   to
sustain a significant profit impact — annualized costs represent
about SO percent  of before-tax profits.   This could cause  some
marginal dealerships  to close  their door.   Independent  repair
shops and self-service  fleet establishments are  expected to   be
somewhat less severely affected,  with average profit impacts   of
36 and 22 percent, respectively.

-------
Automobile,  Truck,  and  Bus  Parts Rebuilding




This  segment  includes  facilities   involved  in rebuilding    automo-


bile,  truck and   bus  parts.     Normal  plant   treatment  costs   were


scaled  to   segment  totals   based   on  the   total number  of   motor


vehicle parts   rebuilt   as    reported   by   the   1984   Service   Job


Analysis.   Since  it   is  not  possible   to  directly  derive    revenue


for  this  segment  from  this  source,  revenue  estimates  are  based on


the  1982  Business  Census,  which   includes the Census  of   Manufac-


tures and  the   Census  of   Service  Industries,   scaled  to    reflect


1984 volumes.35


3sDer1vatlon of Revenues for Automobile, Truck and Bus Parts Rebuilding:
The technical and co.t analysis  developed estimate, based on the total number of .elected part, rebuilt in 1984 as reported in the
19B4 Job Service Analysis.  In an effort to make revenue, con.l.tsnt with co.t.. the following procedure  ... u.ed to e.timate 1984
revenues (1n 1988 dollars).
Tn. 19B4 Job Service Analysis reported revenues for motor vehicle repair. Including part, rebuilding, for 1981 as well as for
                     1981

    Service Stations    13.044
    Ind. Repair Shops   28.12S
    New Car Dealers     12.183
     TOTAL REVENUES
                     53.352
                              18.918
                              40,470
                              15,625

                              75,013
The compound average annual growth rate for total sales between 1981 and 1984 was calculated as 0.12.
1984 are In current dollars, this growth rate reflects both real growth and Inflation.

Th1. orowth rate was applied to 1982 revenues from the Census of Manufactures and th
manufactured produ", was adjusted by the specialization and coverage ratio.   (Th..
Ing Industrie..  The specialization ratio give, the proportion of revenues of establ
derived "om the shipment of products 1n that SIC code.  That Is. It reduce, revenue
under consideration.  The coverage ratio represent, the fraction of sale, of product
reporting In that SIC.  It  Is applied to account for th. fact that not all sales of
code and. therefore Increase, revenues for the SIC code being examined.

The adjustment,  then 1s:

    Adjusted Revenue»=Revenue» x Specialization Ratio/Coverage Ratio

And, adjusted revenues are:
                                                                                   Since sales for 1981 and
                                                                    Censu. of Service Industries.  Revenue for
                                                                    ratio, are not available for nonmanufactur-
                                                                   shments reporting In that SIC code that 1.
                                                                    to include only those from the Product.
                                                                    1n an SIC that are shipped by establishments
                                                                    given product are reported under the SIC
                                       1982 Revenues
                                         Unadjusted
             Rebuilt Parts for Motor
             Vehicles,  ex. Carburetors
             and Engine.

     3592171   Carburetors, rebuilt
                                                                           r)*,  This can be transformed to
                                                                                         1s case 3: and exp
 *A11 revenues are shown in millions of dollars.

 "The compound average annual  growth rate (r) was calculated assuming growth of the form A(H-r)'1. This can be
yield r=exp((ln A)/t) - 1. where A = the ratio of 1984 revenues to 1981 revenues; t = the number of years, in th
denotes exponentiation.

 "'Special nation and coverage ratios were available only at the four-digit level.  (See Table X-2 )  When applied to more
disaggregate data, such as the .even-digit SIC code, the specialization ratio may be understated and the coverage ratio
overstated   The net effect on the revenue estimate is unclear, but depends upon the relative measurement errors 1n the two
 ratios.  (Footnote continued)
                                                  215

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Table X-11  (page 327)  shows  estimated  revenues  and profits by SIC

code for this segment.   Rebuilt parts  for motor vehicles,   exclu-

ding carburetors and   engines  is clearly  the largest   component,

representing  approximately   96 percent  of segment  revenues  and

profits. Carburetor rebuilding ranks second, accounting  for about
                       '"I         • "    '     " ' » '' I .  I! ,'. ' I  '• .i '.'•.,	"	I!/ . • , .   . .. .

3.5  percent   of  both  revenues  and  profits.   According  to  the

Census data,  transmission and  diesel engine repair and rebuilding

revenues are  almost negligible by comparison.   To the extent that

additional motor vehicle  parts rebuilding is   done in other  SIC

codes,  e.g.,  service stations,  or  is not  reported separately  by

the   Census,   these   revenue   and  profit   estimates   will   be

understated.
                                                                      '.'•;'.	'
                                                                      "'	'
                            1982 Revenues
                             Unadjusted
   Adjusted***

   7S38(pt)  Transmission RabulIdlng
         1 Repair

   7533(pt)  Diesel Repair             1,1    ,.,

   TOf*1-                      926.5   993.3

Th««« 1982 flgurii »«r« scalld to r«M«ct 1964 volumM and prices:

   SB93.3 I 1.12 > 1.12 > 11246.0

ThU «•• put in 1838 dollars using th» CPI for Automobile Repair and Maintenance:

   $1248.0 x 1.185 • S14I9.0

This »•> the figure used In the analysis.
                                   216

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Total capital  and annual  treatment costs  for both  direct  and



indirect dischargers  with average  treatment-in-place are  esti-



mated at $64.7 million and $15.4 million, respectively.  Assuming



a ten year life expectancy and an interest rate of 10.34 percent,



annuallzed  costs  are  about  $26.1  million  per  year.   These



annualized costs represent  about 1.9 percent  of this  segment's



annual revenues  and  48 percent  of  its profits,  suggesting  a



severe profit impact.  It  should be noted  that if revenues  and



profits are underestimated, these impacts will be overestimated.








Bus and Truck Rebuilding and Maintenance








This segment  includes  facilities  which  rebuild  and  maintain



trucks and buses.   While the technical  analysis considered  bus



and truck rebuilding and bus and truck maintenance separately due



to differences  in  the nature  of  the processes  employed,  the



normal plants were scaled to  represent the same universe —  the



total number of trucks and  buses registered in 1986.   Moreover,



there is  considerable overlap  between facilities  that  rebuild



commercial trucks and those that maintain them.  Likewise,  buses



are often rebuilt and maintained by the same firms.  For purposes



of the economic analysis, separating buses from trucks is a  more



meaningful distinction since much  of the maintenance and  repair



is performed  in-house  by  trucking firms  and  the  larger  bus
                                217

-------
 operators.   Therefore,  segment level impactis are best analyzed by


 examining   those attributable to both rebuilding and  maintenance


 (1)  for  buses  and (2)  for trucks.





 Table X-12  (page 328)  presents total capital,  annual and  annual-


 ized costs  for buses and   trucks fNpr both rebuilding and  mainte-


 nance.   The table also  displays  an  average  cost  per  vehicle.


 This was calculated by  simply dividing total segment costs by the


 universe of vehicles  used in  the technical  and cost  analysis,


 i.e., by 40,861,OOO  vehicles.   The average  cost per vehicle  is


 used in  later   tables to  estimate   effluent  treatment costs  that


might be incurred  by bus  operators and motor carriers.



                     , '     '             M,: :T' , ": ,!'"' i:  i, j' ,     'I, ' '' i	 "  '» •       I I III!
            i        „ '            ,      i    ' i.,,	,	 ,, M,,  • •    •: f"i  ,• i •'',!'  ' ,
There are three major classes of bus  operations:  intercity, local


and  school  buses.   Table  X-13 (page  329)   displays   estimates


treatment costs,   revenues, profit and  impacts   for  each   group.


Annualized treatment costs for each group were estimated by
                                218

-------
 multiplying   the    average    cost    per    vehicle    by    the   number    of

 vehicles  in   each  class.^    Profits were  estimated  by  applying
36Estimation of Bus  Revenuee

There are three major classes of bus operations:   Intercity,  local, ana school  bus.  Th« derivation of revenue for each class  Is
described below.
Information oj revenues and the number of vehicles  for Intercity buses for 1984  is provided by National
Annual  Report :
                                                                                                 Transportation Statistics:
     Intercity
         Operating Revenues
                               S2,279.700.000 (1984$)
                               $2.753,900.000 (1986$, based on  the CPI for Transportation Services)

                                      25.000
The treatment cost estimates derived from the technical analysis are based on the  total number of buses In 1986.  The 1986 reve-
nues were estimated by  assuming that (a) the distribution of buses  by class In 1986  la Identical to that of 1984  and (b) real
revenue per bus remains constant between 1984 and 1986.  Then, as indicated on the table below. 1966 revenue for  intercity buses
is estimated as:  (Number of intercity buses in 1984/Total number of buses in 1984)  x Total number of buses 1n 1986 x Average
revenue per Intercity bus In 1984.
Operating  revenues for local transit as  reported 1n National Transportation Statistics Include revenues from all  types of vehicles
(a a   trolleys  streetcars  rapid transit).  The 1984  revenues for local buses nere estimated based on the proportion that local
buses' represent of total  local transit vehicles, i.e..  (54.460 buses/71.618 total  local transit vehicles) x Total  1984 local
Local  Buses

Ope
(e

^anslt'operatlngrevenues'of $12712615 miiTion'=$ii22iT3'miilIon.  Given an estimate of 1984 operating revenues for local  buses.
the derivation of 1986  local bus revenues 1s analogous to that described for Intercity Buses above.

School Buses

National Transportation Statistics a'so provides information on the number of school buses — reported at 471.461 in 1984.
However, no revenue data were available from this source.

The 1982 Census of Service  Industries  reports the number of establishments providing school bus transportation,  but gives no
Information on revenues or  receipts.   Robert Morris Associates Annual Statement Studies. 1986 contains Information on total
aggregate  revenues for  55 reporting school bus companies; a total  of $160.563,000 1n revenuea was  reported by these firms In 1984.
This Implies an average revenue per firm of $2,920,000.  According to the Census, there were 3344  establishments engaged In
providing  school bus transportation 1n 1982.  Multiplying

     3344  establishments x  S2.920,000/f1rm

gives an "Industry" revenue estimate of $9.697,600,000 (1982$) or $11.714.700.000 (1988$).  To the extent that the firms contained
in the RMA data own more than one establishment, this revenue estimate will be overstated.  However, since RMA tends to be biased
toward smaller firms, this  1s not expected to have a major effect.
 Administration
               Transpo
              ,  19B6.
                                         Annual Report.  U.S. Department  of Transportation, Research and Special Programs
                                                             219

-------
median profit-to-sales  ratios  (Table  X-7,   page  322) from  RMA   to

revenues.    Profit-to-sales   ratios for   SIC  4131    (Intercity   and

Rural Buses)  and SIC  4151  (School Buses)   were  used to  estimate

profits  for Intercity Buses  and  School  Buses, respectively.    No

profit data were available  for Local  Buses.



Impact's,  as measured by the ratios of costs  to revenues and costs

to profits,  do not  appear to   be  significant for  any of the  bus-

related   segments.    Combined   annualized   costs    for   both    (a)

rebuilding  and (b)  repair and  maintenance  are less  than one-third

of one percent of revenues.   The  most severe profit impact  would

be incurred by operators of school buses;  the combined  impact   of

treatment  costs  for both (a) rebuilding  and  (b)  repair  and
                                 BUS REBUILDING AND MAINTENANCE:
                                 DERIVATION OF REVENUE ESTIMATES
                                      (1908 dollars)
O> (2) (3) Actual
Number of Proportion of Number of Revenue
Buses Total 1984 Buses 1984
1!>84 Buses 1986 (millions)
Intercity Buses 25,000 0.05 27.800 2,753.9
tocml Buses 54,460 0.10 60,600 9,221.3
Scnool Buses 471,461 0.86 524,600 11.714,7
TOTAL /AVERAGE 550.921 1.00 613.000 23,689.9
Hotesi
Column (l)i The number of buses In 1984 Is taken directly from National Transportation Statistic:
(5) (6)
Revenue Estimated
per Bus Revenue
1984 1986
(thousands) (millions)
110.16 3,062.3
169.32 10,260.9
24.85 13.035.1
43.00 26.358.4
• ' " .',• : • '(••
,. Annual Report. U.S. Department
Column (2):  Proportion of 1884 bui
         1984.

Column (3)I  Ettlm
                             Iculated by dividing the cell entries In Column (1) by the total number of buses 1n


               using the proportions In Column (2), multiplied by the total number of buses In 1986 (from the technical


Cetuxn (4)i  Revenues for 19E4 for Intercity buses are actuals as reported In National Transportation Statistics. 1984 revenues
         for local buses are also taken from National Transportation Statistics, but have been adjusted to represent revenues
         attributable to buses only (based on the proportion of buses relative to all vehicles. Revenues as reported 1n
         National Transportation Statistics Include those for trolleys, streetcars, etc.) 1984 revenues for school buses .ere
         not available from the National Transportation Statistics and .ere derived from RMA and Census data as described In
         the text.in

Cs1u*n (S)t  Revenues per bus 1n 1984 »ere calculated by dividing Column (4) by Column (1).

                                           1984 revenue per bus from column (5) by the estimated number of
Coluen (6)t  Estimated 1916 revenues .ere computed by
         buses from Coluntt (3).
                                                                                    ,„:>..
                                         220

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maintenance is expected to average about 3.5 percent.   Treatment

costs associated with school bus  rebuilding account for most  of

this impact.



As shown  in  Table  X-14  (page  330),  revenue-producing  truck

operations can be divided into three types:


     o    ICC  Regulated  -  Generally  operating  in  interstate
          commerce under a grant of authority from the Interstate
          Commerce  Commission  (ICC).   These  can  be   further
          divided into Class I, Class  II and Class III based  on
          annual revenues.

     o    Non-ICC Regulated -  Includes intra-state carriers  and
          private carriers hauling goods of their owners.

     o    Local -  Carriers which  operate principally  within  a
          single or contiguous commercial zone.


Total 1984  revenues (in  1988 dollars)  were approximately  $243

billion.37  Profits are  estimated at about  $8 million based  on

median profit to sales  ratios over the 1982  to  1986 period  for

firms in SIC 421 (Trucking and Warehousing) from  RMA.
       data were used because they were  the most recent year   for
which a breakdown  by type  of carrier (i.e.,   long distance   vs.
local) was available.   Use of this  categorization is  desirable
because of differences  in the  profitability of   the two   groups
(median profit-to-sales ratios of 2.7 percent and  4.1 percent  for
long distance and  local carriers, respectively.)   Moreover,  more
recent revenue data  for  the  entire trucking   industry from   the
1988 U.S. Industrial Outlook indicate that revenues have remained
relatively constant in real terms.
                                 221

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 Treatment costs and  impacts are  displayed in  Table X-15  (page

 331).   Two  sets  of  costs numbers  arepresented.   The  first
           '-      '    i     ,       : ,   	• •(',.: "\'\ t ':t •:. ;,„	  ,	
 represents the segment total and includesallregistered  trucks.

 However,  according  to the  1982 Census  of Transportation,  56.7

 percent of  all trucks  are driven  for personal  use only.   The

 second set  of  costs   reflects  this   fact  and  therefore  more

 accurately portrays effluent treatment  costs that willbe  borne

 by motor  carriers  and  shippers.38  Comparing  these costs to motor

 carrier revenues suggests that the average motor carrier will not

 sustain a  significant  revenue  impact.    However,   due  to  the

 relatively low profitability of motor  carrierssince deregulation

 (median profit-to-sales ratio of 2.7 percent,  as compared to  5.8

 and 4.5  for  1972   and  1977,  respectively),   effluent  treatment

 costs may result in some moderate profit  impacts for the  average

 motor carrier.   Annualized  treatment costs for truck  rebuilding,

 alone,  represent about  10  percent of   pre-tax profits.     Addine
              j,       '  .      •:'•;.,;  „" "  !',; -, •; •' 'if;;^V'; ; .  :', •'••!/,' . • ': 	
 treatment costs  associated  with maintenance results  ,in', a ..combined

 profit  impact  of almost 12  percent.39
38Treatment costs associated  with the rebuilding  and  repair   of
trucks for  personal  use  will  probably  be  borne  by   service
stations and repair establishments.  However, the overlap  between
these and segments which have been covered elsewhere  (e.g.,  auto
repair and maintenance) is unclear at this time.

39Impacts may be  slightly overstated.  Costs  are based on  1986
truck registrations.The adjustment for trucks used  for personal
transportation only is based on 1982 data.  Sales of  light trucks
increased by  almost 8O  percent between  1982 and  1986.  It   is
                                   (FootnoteContinued)
                                222

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Radiator' Rebuilding and Maintenance



This  segment  includes  facilities  which  rebuild,  repair   or

maintain radiators for automobiles, trucks and buses.  Generally,

these facilities include radiator repair  shops as well as  other

automotive repair service outlets, trucking firms and the  larger

bus companies.   However,  since no  data  are available  on  the

number or the proportion of total radiator repair work  performed

at each facility type, preliminary impacts have been measured for

the "radiator rebuilding  and maintenance  segment".  While  this

limits our ability  to identify what  types of facilities  (e.g.,

radiator repair shops,  service stations,  service facilities  of

car and truck dealerships) will  be affected by a regulation,  it

does provide a reasonable  estimate of the average  segment-level

impact.



Total segment capital and annual costs are estimated as $11O  and

$38.8 million,  respectively.   These figures  combine  treatment

costs for  direct and  indirect dischargers  and reflect  average

treatment in  place.   Annualized  costs  are  approximately  $57

million per  year.  These  annualized costs  represent about  6.5
likely that many  of these are  used for personal  transportation
only, making the 1982 adjustment factor used in the analysis  too
low, resulting in an overestimate of treatment costs.
                                223

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percent  of   the   radiator  rebuilding   and   maintenance   segment's
estimated  annual   revenue  of   $881.1  million
                                                                40
                                                   suggesting   that
some  facilities  in  this  segment  may  sustain significant   economic
impacts.

Air  Transportation

Air  transportation   includes   those  four-digit   SIC   codes   which
manufacture,  repair,   rebuild  or   service any    type  of   aircraft.
The  manufacturing,segment    includes  establishments which  produce
complete  aircraft,  aircraft engines,  aircraft,parts  and  auxiliary
 ""Oarlvatton of Ravanuaa for Radiator Rapalr Sacton
 Tha IflIZ Canaut of Sarvfca Induatrlaa provldaa tha following Information for Radiator Rapafr (SIC 7539 - part):
    Racalpta
    t Plrma
    * eatabllahnente
1*35.503.000 (1982 $>
SS20.000.000 (1988 S. ualng tha CPI for Motor Malntananca i Repair)
     2.447
     2.511
 Tha normal plant uaad In th* tachnlcal and coat analyala rapalra 1300 radiators/year.  If one assumes that this plant 1s "typical"
 and that average establishment alza haa not changad slnca 1982, thla suggests that 3.264,300 radiators nare repaired by radiator
 repair ahopa In 1882. that la.
    1300/radlators/yesr/eitabUihment x 2S11 establ Ishnents
 The tachnlcal analysts furthar calculataa that a total of 5,531.000 radlatora Mara repaired In 1986.*
 Asaumlno that raal ravanua par radiator 4*pa1rad haa ramalnad constant slnca 1982. 1986 segment ravanuas ara estimated as
 J«II,100.000, that ta.
    S.S3).000/3,264.300 x 1520.000,000
 Slnca the total 5,S3I,000 radiators repaired par yaar Includaa radiators rapalrad at all facility typas, thla ravanua doaa not
 represent exclusively radiator rapair shop racalpts.  Hathar. It raprasants a aagmant-laval aatlmata of ravanuas attributable to
 radiator rapair.  Tola la, ravanuas derived from radiator repair at other facility typas such aa automobile repair ahopa car and
 truck dealerships, ate. are alas Included In thla aatlmate.

 ~       ,        •••        	i      :,   ,	  ,,-,  •	•  	  , 	   ,     ,   •., AW	h,. • »..'  ' : ''; '"  ' ,'.':;.'.,".:! ',"	'i (,*
  This figure la aatimated baaed on the 19J4 Job Service Analysis (adjusted to reflect th« total number of registered automobiles,
 trucks and busea In 1986) and Includes radiators repaired by service stations. Independent repair shops, automobile dealers.
 self-service fleet shops and Jobber machine shops.
                                               224

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equipment as well as those  involved in the production of  guided

missiles and space  vehicles.  Rebuilding  aircraft and  aircraft

components is also done by the manufacturers.  In many instances,

the manufacturing activities can be further divided into military

and  non-military  components.   The  service  segment   includes

passenger and cargo carriers and aircraft repair and  maintenance

facilities.  The major air carriers generally repair and maintain

their own aircraft.  The industrial components of each group  are

described briefly below.



Economic and Financial Characteristics



Aerospace Manufacturing



The manufacturing segment produces  or rebuilds aircraft,  guided

missiles and  space vehicles.   The specific  activities   covered

are:
           Aircraft manufacturing  (SIC  3721),  including  establish-
           ments  engaged  in  manufacturing or  assembling  complete
           aircraft,   repairing  and  rebuilding  aircraft  on    a
           factory basis  and research and development  on  aircraft
           if  the facility is  owned by  an aircraft manufacturer.

           Manufacturing,  repairing    and   rebuilding    aircraft
           engines, engine  parts  (SIC   3724)  and  other  aircraft
           parts  and  auxiliary equipment (SIC  3728).

           Manufacturing  complete  guided  missiles,   ballistic
           missiles,  rockets and space  vehicles  (SIC 3761).
                                 225

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     o    Manufacturing  guided missile and space vehicle  propul-
          sion units   and  parts,   engines  and engine  parts  and
          rocket motors  (SIC  3764).

     o    Other guided missile and  space vehicle  parts such  as
          nosecones,  space capsules,   casings for  missiles  and
          missile  components  for  shipping and storage (SIC 3769).


Facilities which   manufacture  aircraft  and  parts  tend  to  be

different from  those which   produce  guided missiles  and  space

vehicles.  Similarly,  the  institutional and economic forces which

contribute to  industry  growth and  financial health  differ  as

well.  Each group  is  discussed below.
Aircraft and Parts Manufacturers  Table  X-16  (page 332)   presents

information  available  from   the  Census   of  Manufactures   for

aircraft producers.  As  shown by  the table,   data for   aircraft

manufacturing (SIC 3721) are reported to the  five-digit  SIC  code

level.  The value of shipments associated with  the production  of

complete aircraft  for military  purposes (SIC   37211)   increased

slightly between 1972  and  1982.   However, capital  expenditures

increased substantially  in  anticipation   of  increased  defense
          .',i   ,   ;' 1,1 ,,'[   ,   „ , , ,. "„   ,: : '. " ...... r  ' , ...... I, X'.".  ii " \.M ..''iB' .',"!''.. ''I"  :•.'." ''».V "'ill
spending domestically and  abroad.^1  Production of  non -military

aircraft (SIC  37215) increased  substantially  in   1982,  and   has

continued to increase, as airlines order larger, newer planes  to
      37211 includes both aircraft for the U.S. military and   any
other aircraft built to military specifications.
                                226

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compensate for  the  limited number  of  landing slots,  and  the
additional routing of passengers through hubs
                                              42
Aircraft repair and rebuilding for both military and non-military



customers is  included in  SIC 37214  — Aircraft  Modifications,



Conversions and  Overhaul.   Like  SIC 37215,  activity  in  this



product group rose significantly between 1972 and 1982.  Sales of



other aeronautical services (SIC 37216), again for both  military



and civilian purposes, declined slightly between 1977 and  1982.







More recent data indicate that the value of shipments to the U.S.



military reached $21.1  billion ($21.3 billion  1988 dollars)  in



1987.  However, without additional orders, Rockwell was  expected



to close down production of the B-1B  in  1988, while Lockheed will



make the last scheduled delivery  of  the C-5B in 1989.   Although



there are  many new  U.S. military  programs in  the  development



stages, manufacturing rates  are slowing  and many  manufacturers



are seeking modifications work while  waiting to put new  programs



into production.^  Forecasters anticipate that domestic military



orders will  not  increase significantly  in  1989, as  the  U.S.



Government limits its spending.
 42
  !Morton L. Siegel, ValueLine Investment Survey, Oct. 14, 1988,



43U.S. Industrial Outlook. 1988. p. 39-7.
                                 227

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 Sales of commercial aircraft were  expected to reach about  $15.3
 billion ($15.5 billion in 1988 dollars)  in 1987.   Some 85 percent
 of this  figure  is accounted  for  by shipments   of  Boeing  and
 McDonnell Douglas large commercial transport aircraft.^

 A relatively small  number  of establishments  are engaged in  the
 manufacture of  aircraft engines   and  engine parts   (SIC  3724).
 Therefore,  disaggregate industry  statistics such  as  those of  SIC
 code  3721   (Aircraft Manufacturing)  are   often not   reported   to
 avoid disclosure,  thereby limiting the usefulness of the data  and
 our ability to assess  impacts for more precisely  defined economic
 segments.

 Recent aggregate data  indicate  that  sales  of aircraft engines  and
 parts   (SIC 3724)   totalled   $16  billion  ($16.5   billion  1988
 dollars)  in 1986.   For  1987, sales  were  estimated   at   $17.1
 billion  ($17.3  billion   in  1988 dollars).    Similar  volumes  were
 expected for other aircraft equipment  (SIC 3728).  Sales  for 1986
 and 1987  are   estimated at   $16.6   billion ($17.1   billion  1988
 dollars) and $17.5 billion  ($17.7 billion  1988 dollars),  respec-
 tively.
44
  U.S. Industrial Outlook. 1988. p. 39-3,
                                228

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Guided Missiles and  Space Vehicles  As  indicated by Table  X-17



(page 334), the value of  shipments of all components,  including



missiles and  space vehicles  (SIC 3761),  propulsion units  (SIC



3764) and other space vehicle  equipment (SIC 3769) grew  between



1972 and 1982.  And, shipments continue to grow.  Sales of guided



missiles and space vehicles reached $19.0 billion ($19.6  billion



1988 dollars)  in 1986,  an increase  of 71  percent since  1982.



Similarly, shipments  of space  propulsion units  were valued  at



$3.3 billion ($3.4 billion 1988 dollars) in  1986, representing an



increase of 41 percent over 1982 sales.^5







While data documenting  the proportion of  sales to the  military



were not available for this report, it is thought to be sizeable.



According  to   the  1988  U.S.  Industrial Outlook.  the  near-term



success of the U.S. aerospace   industry  "hinges upon the  ability



of  the manufacturers  to weather the decline  in military purchases



by  the Federal Government."    The military  accounted for  three



quarters of  the orders for U.S. launch vehicle equipment  in 1986.



However, no  further  information is available at  this  time.
   U.S.  Industrial Outlook.  1988.  p.  39-9.
                                 229

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 Air Services
 Generally, the larger carriers  of passengers and cargo  maintain

 and repair their own aircraft;  smaller firms may purchase   these

 services  on  a  contract  basis.   Hence,  this  group  includes

 industries which move  passengers and  cargo by air,  as well  as

 those whose primary  purpose is to  repair or maintain  aircraft.

 Four-digit SIC codes considered to the within scope are:
                     . (    ,    '       ' .  ,'••'• •  J||1 '" ,   '

      o    Certified passenger  and  cargo  carriers  (SIC  4511).
           These carriers  operate  over  fixed  routes  on  fixed
           schedules.

      o    Uncertified passenger  and cargo  carriers (SIC  4521).
           In addition  to  irregular  or  non-scheduled  service,*
           these  establishments   include  air   taxis,   charter
           services and sightseeing airplane service.

      o    Aircraft repair  and  maintenance  (SIC  4581).   These
           firms operate and maintain airportis,  flying fields  and
           airport terminals.
Data available  from the Economic Census,  presented in Table  X-18

(page 335),   indicate that  both certified  air carrier  services

(SIC 4511)  and airport  and aircraft  services (SIC  4581)  grew

between  1977  and  1982.   Data  from the Air Transport  Association

of America (ATA)  indicate that the certified or scheduled carrier

industry has  continued   to grow.    As shown in  Table X-19  (page

336), both  operating  revenues  and   employment  have  increased

steadily.  Revenues and employment rose at annualized rates of  4

and 5  percent, respectively,   between 1982 and  1986.    Average
                          ' :  •   '  .• i • . '  .  "'     i'fi: ' ,}"!•('. ••'';;l  ' .,!"!	'. '  ;•" i1'",'!.',.';;1, i-'1,  •	 ;,	j, • ,-"; i	
profitability, however,   has  been   relatively low   due to  strong


                                230

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competition.  Data  from ATA  indicate  that the  U.S.  scheduled

airline industry  incurred an  after-tax loss  in 1986.     Addi-

tional  information  from  the  1988   U.S.  Industrial   Outlook

suggests that the  industry may have  also posted a  net loss  in

1987 because of interest and  tax payments.  However, the  indus-

try's  performance  is  unbalanced.   In   1986,  eight   carriers

accounted for  98  percent  of the  entire  industry's  operating

profit; although data for 1987  are not yet available, a  similar

disparity is expected.



Preliminary Economic Impact Assessment



This section  presents a  preliminary assessment  of the  impacts

that might  occur as a  result of  regulating effluents associated

with   aircraft  rebuilding  and   maintenance.    (While   aircraft

manufacturing is   considered  to   be  within   the   scope  of   the

potential regulation,  technical   data  were   not   sufficient  to

develop  treatment   costs  estimates.)    Treatment cost  estimates

were developed  for  <1)  aircraft rebuilding   and   (2)  aircraft

maintenance.  In both  cases, estimates for   the normal  facility

were scaled based  on  the  total number of  non-military aircraft in

 the U.S.  in 1986.   This  includes approximately 4,431  commercial

 aircraft (scheduled  passenger   carriers   —   including  commuter
 ^Air Transport, 1987: The Annual Report of the Scheduled Airline
 Industry,  Washington: Air Transport Association, June, 1987.
                                 231

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 carriers, air  taxi  and  cargo  carriers)  and  210,400  general


 aviation aircraft.
 In order to estimate preliminary economic impacts, an effort   was


 made to develop revenue and profit figures that correspond  to  the


 segment-level treatment costs.  This means, for example, that   it


 was necessary to omit revenues and profits thought to be  associ-


 ated with  the rebuilding  or maintenance  of military  aircraft.



 The assumptions made in developing estimates for each segment  are


 described in the discussions of impacts on (1) aircraft  rebuild-


 ing and (2)  aircraft maintenance presented below.






 Rebuilding






 The rebuilding of  aircraft and components  is done primarily  by


 the manufacturers.   While  a  good  deal of  aircraft  and  parts


 rebuilding is  performed  by establishments  in SIC  code 37214  -
                                          "' „  '  . i'  i   '' ''"',' , .H"'1 '(nil','1 ;. ''"Hi" : . ill1 •' "'	' iL",'.:! 1

 Aircraft  Modifications,   Conversions  and  Overhaul,  additional


 rebuilding is  believed  to take  place in other aircraft  manufac-


 turing  facilities.    For  this   reason,  the  revenue estimate  for


 this segment is  based on  all non-military aircraft manufacturing.


 It was  derived  based on  value  of shipments  data   from the   1982


Census  of Manufactures.   (See   Table  X-2p, page  337.)   According

                                „; ::  ';' ,   ,v,,t	I1 i	 t £1:"' 1;,i', '4, " t 	'" ;!'v;'';i 	':f.;"i' ,  i 	, .  (	i-,. ,W,

 to  information published  inthe 1988  U.S.  Industrial  Outlook,  the



value of  shipments   for   SIC  3721  -  Aircraft  Manufacturing  -
                                232
                                   "I,, ' »:, ' ' ,i"' 'Hip 'I

-------
declined at  an  average  annual compound  rate  of  1.1  percent

between 1980 and 1985.  It grew  by 6.7 percent between 1985  and

1986.  The 1986 revenues  shown in Table  X-2O were estimated  by

applying these growth rates  to the 1982  Census figures for  all

non-military aircraft production.1*7  Profits were estimated based

on the median 1982 to   1986 profit-to-sales ratios for  Aerospace

Manufacturers as reported in  the Quarterly Financial Report  for

Manufac tur ing  Cor pora t ions. **8   The  published   prof it-to-sales

ratios reflect after-tax profits. In order to be consistent  with

(before tax)  profit  estimates  based on  RMA  data,   they  were

converted to before tax profits  assuming a marginal tax rate  of

45 percent. ^



The  potential MM&R regulations would cost the aircraft  rebuilding

segment approximately   $335 million  in  capital costs  and  $284
   x^e  growth  rate  for   SIC  3721   includes  both  military  and
 non-military aircraft.    To the  extent  that sales  of  military
 aircraft have increased  relative to non-military aircraft,   these
 revenue estimates may be somewhat overstated.

 ^Quarterly Financial Report for Manufacturing Corporations, U.S.
 Department of Commerce and the Federal Trade Commission,  1987.

 ^The  use of a 45 percent marginal tax rate assumes that  profits
 of these firms fell into the highest tax bracket during the  1982
 to 1986 period.  (The marginal corporate tax rate was reduced  to
 34 percent, effective July 1,  1987, by  the Tax  Reform Act  of
 1986.)  While this is a   reasonable assumption in the absence  of
 information on the effective tax rate for firms in this industry,
 it may tend to overestimate profits and, therefore, to understate
 impacts.
                                 233

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 million in annual costs,  resulting in annualized costs of  $339.3
 million  per  year.
                    50
Assuming  no  cost  pass  through,  these
 annualized costs  represent about  0.9  percent of  revenues  and


 approximately 12.6 percent  of the segment's1986 profits.     If


 facilities in  this segment  are unable  to pass  on any  of  the


 effluent treatment costs in the form of higher prices,  they  could


 sustain a moderate profit impact.





 Maintenance





 Aircraft maintenance is   performed by the  major air carriers  as


 well as  by  independent  aircraft repair  stations.    Major  air


 carriers  are  generally   self-sufficient  in  maintaining    and


 repairing their aircraft.   Smaller carriers and owners  of general
                      , ;      ;  ;    *   • ": V'.- ,;.";	• / ("' 	;' '.I :    ••:•  " °       "

 aviation aircraft  contract  with outside   facilities  for  mainte-


 nance and repair services.   According to  the FAA,  who is  respon-


 sible for certifying aircraft  repair  stations,  there  are approxi-


 mately  2,60O  to 3,OOO certified repair   stations  functioning  as


 independent businesses.    Unfortunately,   however, there  are  no


 revenue estimates  available for  these repair  stations.
50Costs are annualized  using an interest  rate of 10.34  percent
and an assumed useful life of 10 years.
                                234

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While it  is  difficult  to calculate  all  revenues  earned  for

aircraft maintenance, the Air Transport Association reports  that

the major airlines spent $6.O and $6.4 billion (1988 dollars)  on

the maintenance of their aircraft in 1986 and 1987, respectively.

Since these  figures  include  only  expenditures  by  the  major

airlines, i. e. , do not include maintenance by smaller airlines  or

by the  general aviation  community,   they clearly  represent  a
                                                            C -I
lower bound on estimated revenues from aircraft maintenance.-'1
Total segment capital  and annual  costs are  estimated at

million and $13.2 million, respectively.  Using an interest  rate

of  10.34 percent and an assumed useful life of 10 years,  annual -

ized costs  are expected  to  be $15.4  million per  year.   This

represents approximately O.2 percent  of average (1986 and   1987)

annual maintenance  expenditures for  the major  carriers.   This

suggests the average  aircraft maintenance  facility could   cover

effluent treatment  costs by raising prices by about O.2  percent.

Since this impact is relatively small and is known to be  overes-

timated (as a result of assuming that maintenance expenditures  by

the major carriers  represent segment-level revenues), we conclude
 ^1Data on aircraft maintenance expenditures  are not available for
 all  airlines   or   for  general  aviation  aircraft.    Hence,   the
 percentage of total aircraft maintenance expenditures incurred by
 major carriers is  not  known.  We do know,  however,  that it  does
 not   cover all aircraft   maintenance  costs  and,   therefore,
 underestimates total aircraft maintenance expenditures.
                                 235

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 that aircraft maintenance   facilities are  not   likely  to  sustain

 significant economic  impacts  as a  result   of  the potential  MM&R

 effluent guidelines.



 Rail Transportation



 The rail transportation segments include industries which  build,

 operate and service rail cars and equipment.   Five four-digit SIC

 codes (one manufacturing  and four  service) classify  industries
                                            |i,,i', , 	'" ' ! •  ^   . ,    •   	„

 included in this group.  Specifically:


     o    Line-haul railroads,  including  passenger  and  freight
          (SIC 4011) and railroad terminals (SIC 4013).

     o    Railroad equipment (SIC   3743),  covering  all rail  car
          production and  rebuilding.  It   includes the  building
          and rebuilding of locomotives and railroad,  street  and
          rapid transit cars and  car equipment for both  freight
          and passenger service.
                     :           ,  i,  11 '•   ,   " '! In	  "  , „' " .    '      ..nl',  Will'I'!1
     o    Rental of railroad cars with (SIC 4742) or without care
          of  lading  (SIC  4743).   'Care  of lading1  involves
          providing services such as grain leveling or  trimming,
          railroad car cleaning, icing, heating or ventilating or
          precooling of fruits and  vegetables.


Since the technical  and cost analysis  examined rail  car  (i.e.,

locomotive) rebuilding and maintenance  which  is most often  done

by the  railroad themselves,  the   paragraphs  that  follow  focus

primarily,  although not exclusively  on line haul railroads  (SIC

4011).
                                236

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Economic and Financial Characteristics








Line Haul Railroads







The U.S.  railroad  industry began  with  a remarkable  blend  of



government subsidy  and  industrial  entrepreneurialism.  By  the



2Oth century, railroads  had developed the  characteristics of  a



public utility: performing a general public service, experiencing



little  competition  within  the  industry,  and  being   heavily



regulated by government.  The regulations imposed by the  govern-



ment often served  a variety  of non-economic  concerns, and  the



efficiency of  the US  railroads languished  in competition  with



more innovative transportation sectors  like aviation and  truck-



ing.







In 1980, the Staggers Rail Act deregulated much of the  industry,



making it  more responsive  to market  demands.  Since  railroads



rely on transporting the materials and produce of other  sectors,



the market demand for  railroads closely follows economic  growth



in general, and in  fact the growth of  the U.S. railroads  under



deregulation has reflected the steady, moderate growth of GNP.
The most dramatic changes caused by deregulation have occurred in



the  internal  restructuring  of  the  railroad  industry,  where



management has adopted new technologies, revalued assets, and has



trimmed  its  demand  for  labor.  Many  of  management's  latter



                                237

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                                    :	I;!1111*11!!!',;1!.*1")]!'! V I1!1 I1!"	III'"!'!'!!!!''!'!'''!!!)':,11; •* ii"1' •!	VIS1* ;:''	V ":itt"V"! "x „: /Mull'1	W
                                    ; •	,;•'Fl i;S i -', ., • iiiiji; •;	;. 1,flf;" i: | -  'l ',-	, | •_,'' if" •;<< ;'f.f»	
 achievements have occurred on  .Wall  Street,  with several  mergers
          i, •     -                • M '   	, '  ,  ; !| , " ," r     ,„ ,  • : ''.i ii ,  •   „  •' • i,,!"1!" ," ifj!
 of existing lines, and in court,  in  contests with labor  unions.

 The restructuring  has  generally succeeded  in  increasing  the

 productivity of the railroads, and in attracting investors.
 The Interstate  Commerce Commission  divides the  U.S. line  haul

 railroads (corresponding to SIC 4011)  into three classes based on
                     !    '     '      .i'1 	"  ','.,.",,","'  ", '      .I, " ' i"nl  '  ' ' "" ,' !' il
 their annual operating revenues:


      Class I -  Over $88.6  million  in revenues  ($50 million  in
      1979 dollars), with 18 firms reporting.

      Class II -  Between $17  and $88.6  million ($1O-5O  million
      1979 dollars), with 2O firms estimated.

      Class III -  Less than  $17 million ($10  million 1979  dol-
      lars),  with 296 firms estimated.


 The  railroads in  Class I perform  the bulk  of   the rail  freight

 services  provided in the  country, carrying  90   to  95 percent  of

 the  total ton miles.  Total operating  revenues  reported for  this

 class  were $29 billion (1988 dollars)  in 1986.   The ICC does  not

 require that Class II and III railroads report  this  information,

 but  considering that Class I companies earn  9O  percent or more of

 the  total revenues for the industry, the revenues for all classes

are  estimated at $32.2 billion  for  1986.  The  ICC  also does  not
                    „, ;„   '    ,      .       i,   , i ,. » i i1   i • i1      r     ' : •  v . I.:. ''I	'.'Ml - '"
 collect information on Amtrak,  a quasi-governmental  organization

responsible  for  most intercity  passenger rail  transportation.

Amtrak revenues  were  $973.5  million  ($1,011.8   million   1988

dollars)  in   1987,  or  estimated $969.5  million ($1,056   million


                   ,. '        ''.   - 238      	'

-------
1988 dollars)  in 1986. (Amtrak  expenditures were  significantly

higher, at $1,737.8 million  in 1987).  Adding Amtrak's  revenues

to the sector total, the nation  paid $33.3 billion for the  rail

services provided by the companies  encompassed by SIC 4011"  in

1986.



U.S. railroads are primarily dominated by very large firms,  many

of which , have revenues  from  operations completely  outside  of

railroads.  According to the U.S. Department of Commerce in 1987,

"the nation's seven largest railroads accounted for 75 percent of

US rail  line miles  and more  than 8O  percent of  revenues  and

ton-miles."^3  In a  list  of  the 1000  largest  U.S.  companies

(ranked by the total market value of their assets), Union Pacific

was the 57th largest company,^"   and the largest with a  primary

SIC code of  4O11 , its  revenues varying from  $6,574 million  in

1986 to $5,943 million in  1987.  Union Pacific also owns  compa-

nies involved in petroleum production, other energy sources,  and

real  estate.  Other  railroads  ranking-  on  this  list  include

Norfolk Southern Corp ($4,076 million 1986 revenues),  Burlington

Northern  ($6,941  million),  CSX  ($6,345  million),  Santa   Fe
         companies  earned  some  revenues  for  the  repair  and
maintenance of  other  railroad equipment,  as  well as  for  the
transport of freight and passengers .
                                                       c.
53U.S. Industrial Outlook 1987. p. 55-9.
        100O"  (American  Companies  based  upon  Market  Value.)
Business Week, April  15, 1988.

                                239

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                                                                   .f'iii
Southern Pacific ($5,630 million), Conrail ($3,144 million),  CNW



($959 million), Florida  East Coast ($130  million), Kansas  City



Southern ($478  million),  and Chicago  Milwaukee  ($102  million



1987).
The number of individual companies operating the lion's share  of



U.S. railroads may  decline further  in the  next decade  through



mergers.  Several mergers have already been accomplished, such as



1979's merger  of Burlington  Northern and  the St.  Louis-San



Francisco,  which  created   the  country's  largest   railroad.



However,  mergers  may  be  less  common  given  the  intensified



anti-trust scrutiny of the ICC.
As shown  in  Table  X-21  (page  338),  operating  revenues  and



employment of Class  I line  haul railroads  have been  declining



since 1984.  However, after-tax  profits as  a percent  of  sales



rebounded from a low of 2.7 percent in 1982 and have remained  in



the 6 to 9 percent range.







Railroad Equipment Manufacturing and Rental
Other functions performed  within the  railroad segments  include



rail  car  manufacturing  and  rental.   Table  X-22  (page  339)



presents available  information from  the Economic  Census.   The



Census of Manufactures  calculates the  number of  establishments
                                240

-------
engaged in the production  of rail cars  (SIC 3743) increased  by

almost 20 percent between 1972 and 1977, and then remained steady

at about  20O between  1977 and  1982.. Both  employment and  the

value of  shipments  increased slightly  over  the 1972  to  1977

period and  then  fell  in 1982,  suggesting  a  smaller  average

facility.  The specialization  ratio also  fell, indicating  that

establishments reporting in this SIC code are beginning to expand

production to include other products.
                                                                   t


As with  other service  industries, only  data on  the number  of

establishments and  employees  are  available  from  the  Census.

These data indicate growth in both the number of rail car  rental

(SIC codes  4742 and  4743) facilities  and employment  and  also

suggest an increase in establishment size.



Preliminary Economic Impact Assessment



This section presents  a preliminary economic  assessment of  the

impacts that might occur as a  result of rail car  rebuilding  and

maintenance.^  Maintenance and rebuilding of railroad  equipment

is  performed  almost  entirely  within  the  railroad  companies
         rail  car  manufacturing  is also   considered to be  within
 the scope of   the potential regulation,   the  technical data  were
 not sufficient to estimate treatment  costs.
                                 241

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 themselves.   Most of the diesel  . locomotives  built in the  United

 States  are built by General   Motors1  Electric Motor Division   and

 General Electric,  but  even  these major   facilities compete  with

 their own clients,   the major railroads,  for  the rebuilding  of

 locomotive components.   Amtrak   has   facilities,   such  as  Beech

 Grove,  Indiana,   capable  of overhauling  large numbers of   the
            cf.                                  '
 locomotives.-20   Amtrak  has even  assembled   train cars and  compo-

 nents manufactured  and  shipped from other  countries.
Equipment maintenance   is also  done primarily  by the   railroads

themselves.  Hence,  this  analysis addresses   the   impacts   that

railroads might  sustain  as  a result  of  regulating   effluents

associated with  (1) rebuilding and (2) maintenance aswell as  the

combined impacts.



The technical  and cost  analysis estimated  treatment costs   for

locomotive rebuilding and maintenance.  The scale-up factor   from

the normal plant to  the segment (for  both rebuilding and  main-

tenance) was derived as the  number of locomotives "produced"  at

the normal  plant  in  a  year  times  the  estimated  number  of
3°Amtrak reported that its own facilities were able to perform  a
large part of the rebuilding of locomotives, while  manufacturers
of locomotives reported that  their clients, the railroads,  were
also the largest competitors in  the rebuilding and repairing  of
locomotives.
                                                                 4! -'I iJi':• ,,,'ii ml
                                242

-------
locomotives in  the  segment.  The total  number  of  locomotives

estimated for the segment was  determined based on the number  of

locomotives in Class I  (21,161) and the  number of freight  cars

owned by Class I  railroads (798,631).  Specifically, the  number
                                                           55
of Class I locomotives was multiplied by the proportion of:


          Total # Freight Cars All Classes
          Total # Freight Cars Class I


As shown in Table X-23 (page 34O), the total treatment costs  for

direct and indirect dischargers  are slightly greater for  equip-

ment rebuilding as compared with equipment maintenance.  Assuming

average  treatment  in  place,  total  combined   (rebuilding  and

maintenance)  capital  costs are  $14.4 million.  Annual costs  are

estimated at  approximately $6.0 million.  Using an  interest   rate

of  1O.34 percent and  an assumed useful life of  10 years,   annual-

ized costs are  about  $8.4 million per year.



Since  most   repair,  maintenance,   and   rebuilding  of   railroad

locomotives  and cars   is  performed by  the  railroads  themselves,

the costs  of compliance will be borne primarily by  the railroads.
 55Some 437,318 of the  total number of freight  cars used in  the
 analysis (1,339,453)  are  owned  by  shippers,  rather  than  by
 railroads.  It is likely that shippers own fewer locomotives  per
 freight car than  do railroads.   Thus, it is  possible that  the
 total number of locomotives is overestimated.  To the extent that
 this is  true,  treatment  costs  and,  hence,  impacts  will  be
 overstated.
                                 243

-------
 As illustrated in  Table X-23, the  combined annualized  costs  of

 treatment for the rebuilding  and maintenance of railroad  equip-

 ment would amount to approximately 0.03 percent of totalsegment

 revenues, and  0.17  percent  of  pre-tax  profit.56   Given  the

 relatively small size of these  impacts and the fact that  treat-

 ment costs may be overestimated, these impacts are not considered

 significant.
 Summary of Economic Impacts for the Transportation Sector

  '   '       ''              "   '•' ' V ' '••• 'i ' ••:",'« '••1**it-| •'.. V'v" :\ • '  ';, ';"H


 Table X-24  (page  341)  summarizes  treatment  costs,  revenues,

 profits and impacts for the nine transportation-related  segments

 addressed by the  impact analysis.   Total  segment capital  costs

 range from a high  of $1,255 million  (Radiator Rebuilding)  to  a

 low   of  $7.0  million  (Railroad  Equipment  Maintenance).The

 Automobile Rebuilding  and  Maintenance segment  will  incur  the

 greatest annualized cost —$1,817.3  million per year, while  the

 Rail  Equipment  Maintenance segment  will see the smallest.
  Revenues are estimated  at $3.3  billion as  described  on  page
237. Profits are  based on the  median after-tax  profit-to-sales
ratio over  the   1982 to  1985  period from  Table  X-21.    These
profits were then adjusted to reflect pre-tax profits assuming   a
marginal tax rate of 45$.
                                244

-------
In  general,  the  motor  vehicle-related  service  segments  are



expected to  sustain  the  most  severe  impacts.    The  Radiator



Rebuilding segment  is projected  to incur  the most  significant



revenue impact; their annualized  costs represent 6.5 percent  of



their annual revenues.  This means  that the average facility  in



this segment would need to  increase its prices by  approximately



6.5 percent to  cover the costs  associated with effluent  treat-




ment .







Two segments (Automobile Rebuilding  and Maintenance and  Automo-



bile, Bus  and Truck  Parts  Rebuilding) may  sustain  relatively



severe profit impacts if they are  unable to pass through any  of



their treatment costs in the form of higher prices.  Assuming  no



cost pass through, before tax profits for the average  Automobile



Rebuilding and Maintenance facility would be reduced by almost 35



percent.  Similarly,  if Automobile, Bus and Truck Parts  Rebuild-



ing establishments  are unable   to pass  on any  of their  costs,



profits could decline by an average of 48 percent.







While trucking firms  are not expected  to sustain a   significant



revenue impact,  they may  incur  a moderate impact on profits.   As



described on page  199, profit   margins in  trucking have  eroded



since deregulation.   If trucking firms are unable  to pass  through



any of  their   costs,  the  combined   costs of treatment  associated
                                 245

-------
 with equipment rebuilding and maintenance activities could reduce

 profits by almost 12 percent.



 OFFICE MACHINES



 The MM&R  office machines  sector includes  those  establishments

 which  manufacture,   rebuild   and  maintain  mechanical   office

 equipment.   As described below,   most rebuilding is performed  in
                            , ,. • •' '      ,• • s   	• ii!" • :,!.;:, „ .,i(, MI •„" i •, •   '• i' •  , i: ,„• '".".  , i,	n
 the manufacturing segments,  while  equipment maintenance is  done

 by  facilities   classified as  service establishments.    Available

 information describing  the economic and  financial characteristics

 of  office  equipment   manufacturers and,   to a  lesser  extent,   of

 equipment  maintenance establishments is  presented on page 247.  A

 preliminary assessment  of the  economic  impacts  that might  occur

 as  a result of compliance with   effluent guidelines by   manufac-

 turers  and  rebuilders  of office   machines  is  presented onpage

 25O.57
-"'While office  machine  maintenance  would  be  covered  by  the
potential MM&R limitations and standards, the technical data were
not sufficient to develop treatment cost estimates at this time.
                                246
                                                                   	HI JIlJl	<
                                                                &	il	l^ii

-------
Economic and Financial Characteristics



The office machines sector  performs the manufacture, repair  and

maintenance  of  typewriters,  electronic  computing   equipment,

calculating and  accounting machines  and photographic  equipment

and supplies.   A total  of five  manufacturing and  two  service

segments are included, as follows:


     o    Manufacturers of computers and peripheral equipment and
          major logical components intended for use in electronic
          computer systems (SIC 3573)  and other calculating  and
          accounting machines  such as  calculators, cash  regis-
          ters, and adding machines (SIC 3574).

     o    Manufacture of  office  machines, not  elsewhere  clas-
          sified, including typewriters,  word processing  eguip-
          ment, address labelling machines, etc. (SIC 3579).

     o    Manufacturers  of  photographic  equipment,    including
          photocopy machines and  cameras as  well as  sensitized
          film, cloth paper  and prepared photographic   chemicals
          (SIC 3861).

     o    Computer-related  services,  not  elsewhere  classified
          (SIC 7379).  Until 1987,  this SIC  code covered  estab-
          lishments  engaged   in  computer  and  data  processing
          equipment and repair.  These facilities now fall  under
          SIC 7378, computer maintenance and  repair; SIC 7379 now
          includes consultant  services as well as disk conversion
          and re-certification service.

     o    Electronic  repair  shops, not elsewhere classified   (SIC
          7629).  This  includes  establishments engaged  in  the
          repair  of electrical household  appliances  as well   as
          electronic  industrial equipment.
 58Until 1977,  establishments which manufactured typewriters  were
 classified in   SIC  3572,   Typewriters.   In  1977,   this  classi-
 fication was  abolished and  typewriters were  combined with  SIC
 3579.

                                 247

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 This sector also includes  facilities that rebuild office  equip-


 ment, such as  copiers.  While there  is no SIC  code for  office


 equipment rebuilding, available  information indicates that  this


 is often  done by  the  manufacturer and  is sold  as  "like-new"


 equipment.   Onecompany,  which manufactures  copiers, calls  the


 refurbished product "remanufactured  equipment" and provides  the


 same purchase warranty and service maintenance agreements as  are


 available for new equipment.   In addition,  the purchase prices of


 the remanufactured machines  are reported  to be  thesimilar  to


 those of new copiers.^9






 Table X-25   (page  342)  presents  available  Census   data  which


 describe some general   industry characteristics  for  both  office


 machine  manufacturing  and servicing.  With  the notable  exception
                    , I  ..         . •' | '    "     ,• It .I'.,    ,    i  '. i; '. t  ' ,  „ '..	i\>: 1  	

 of  computer  manufacturing (SIC  3573),  the  value of shipments  of


 office machine manufacturers   declined   or  rose only   slightly


 between  1972  and  1982.    Sales  of electronic computing  equipment


 (SIC  3573) almost  tripled over  this  time period,  growing  from $17


 billion  in  1972 to  $39  billion  in  1982.   Revenues and  employment


 peaked in 1984 at almost  $53 billion and  374  thousand  employees.


 (See Table X-26, page  344).
59Xerox Publication,  General  Services  Administration,  Federal

Supply Service, Covers the period October 1, 1987 - September 30,
199O.
                                248

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Since 1982, demand  for the  sector's products  and services  has

been varied and uncertain.  According to U.S. Outlook,  the  value

of shipments for computer equipment (SIC 3753) fell approximately

13 percent between 1984 and 1986.  In 1986, before tax profits as

reported by RMA  represented 1.3  percent of  sales, as  compared

with approximately 5 percent in earlier years.  More recent  data

for  the  largest  computer  manufacturers  indicate  that  their

revenues rose over 13 percent between 1986 and 1987; profits  for

these large firms rebounded as  well.°°  Computer orders in  1988

appear to have risen  even further in what  appears to be a  very

good year for computer  manufacturing as a  whole, with IBM,  the

industry leader, reporting year-end profits up 10 percent  ($5.81

billion). ^  Even with  revenues growing  steadily, firms  cannot

afford to be sanguine.  These firms fiercely compete in marketing-

new innovations at  lower prices,  and a consortium  of firms  is

competing with IBM in  establishing an alternative new  architec-

ture for their central processing units (CPU's), the "heart" of a

computer. 2  The design  which best meets  market demand for  new

products  and  capabilities   may  establish   a  new   "industry
6°Business Week. Special Bonus Issue, April  15, 1988, p. 270.

61"IBM has Best Year Since  "85," Boston Globe, Jan.  19,  1989,  p.
42.

62Mary  K.  Flynn,  "EISA   takes  on  IBM's  Micro   Channel,"  PC
Magazine, Nov. 29,1988, p.33.
                                249

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standard," meaning  a design to  which future competitors need  to

adapt.
            '  .  •  ,'v	'  <:'•;  .:•'.• .  ••,.. , •  v •••'  '*":'  r..•:'••..:' ••••! - ••• •'  ••••••' :



The suppliers  of  office equipment  and services experienced a  16

percent  increase  in  sales (domestic  and international)  between

1986 and 1987,  rising to $1O  billion in 1987.  This was  accom-

panied by  a 26   percent increase  in profits.  3    This  revenue

aggregate includes  not  only the manufacturers   of office  equip-

ment, such as  Pitney Bowes and Electronic DataSystems, but  also

paper suppliers,  and wholesalers.




Economic Impact Assessment




The Office  Machines   sector  impact  analysis   was   designed  to

estimate impacts  for  the two  segments for which treatment  costs

were developed.   Preliminary estimates  of  economic  impacts  on

each segment are  discussed below.




Manufactur ing




The treatment  cost  estimates of office machine  manufacturing  are

based  on  flows    only  from  the    manufacture  of   computers,
63Business Week. April  15,  1988.
                                250

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duplicating machines, and automatic typewriters and word  proces-

sors.  (The latter two are  considered as a single group).   Data

were not available to estimate flows and, subsequently  treatment

costs, for manufacturers of other equipment such as  calculators,

cash  registers,  or  adding   machines.   Since  the  costs   ,pf

compliance were  estimated  for  only a  portion  of  the  office

machine manufacturing  segment,  they  can be  compared  only  to

revenue and  profit figures  for  these components.   Hence,  the

economic analysis disaggregates  total sector  revenues into  its

components that manufacture computers, duplicating machines,  and

automatic typewriters and word processors.



Revenues for each  component included in  the cost analysis  were

estimated based on data from  the 1982 Census of Manufactures  as

well as more  recent information  from Value  Line.  The  product

groups covered  by the  technical  analysis correspond  to  three

five-digit SIC codes:


     o    Computers - SIC 35731
     o    Automatic Typing & Word Processing Machines - SIC 35792
     o    Duplicating Machines - SIC 35793


Data documenting the value of shipments for these groups  in  1982

are reported in  the Census  of Manufactures.   However, as  des-

cribed  above,  sales  of  these  product  groups   (particularly

computers) have grown since 1982.  In order to make revenues more

representative of current  conditions, these  1982 sales  numbers
                                251

-------
 were inflated by  the median change  in constant dollar  revenues


 between 1982 and 1988 for firms covered by the Value Line Invest-


 ment Survey.  Table X-27 (page 345) shows 1982 and 1988 sales for


 the leading firms which manufacture products in each of the three


 five-digit SIC codes.   The table also displays firm-specific  and

 median  percentage changes in revenues.
                                         L .' I	 .    i    '    '      '  /', i'



 The actual  procedure   used  to estimate  1988  revenues  was  as


 follows:   The  1982 Census  figures were  first adjusted  by  the


 specialization ratios   to  account  for the  fact  that  not  all


 revenue in a given SIC code comes from the shipments of  products


 in  that SIC code  (see Table X-28,  page  346).64  They  were  then


 adjusted using the coverage  ratio to reflect  the fact that  not


 all  the revenue from the manufacture and sale of products in this

 group is covered  by this  SIC  code.   Finally,   since the  latest


 figures on  revenues for  computer,   copier,  and  word   processor
   i        '          •     "'.'"'   •   •' '"« '• • "' " ' ' '" ! ' ''l!	' '"' 1|!"' •'  "'" ' ' ""  ' ' ' ' "'"' "ll"'	' !
 manufacturers  are   reported from  the Census  of Manufactures  in


 1982, the  analysis  assumes  that these segments  have  grown at  the


median  rate  at  which  the  leading  firms in  these segments   have


grown (from  Table X-27).    Thus,  in  Table   X-29 (page 347),   1988


 revenues for the computer manufacturing  industry are  estimated as


 the product  of  the  median rate  of growth  of leading   computer
"^Adjusted 1982 revenues equals  1982 revenues multiplied by  the
specialization ratio and divided by the coverage ratio.
                                252

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manufacturers and  the  segment  revenues reported  in  the  1982



Census of Manufactures.







Profits were estimated  by computing  profit-to-sales ratios  for



each of the firms  shown in Table X-27,  taking the median  value



for 1988 and applying it to the estimate of revenues.  Use of the



median should  reduce  anomalies that  might  be caused  by  very



profitable or unprofitable firms.







Assuming that  segments that  manufacture computers,  duplicating



machines, automatic typewriters and  word processors grow at  the



median rate  of  growth of  their  leading firms,  then  adjusted



revenues  from  duplicating   machine  manufacture  equals   $226



million, from computers $35 billion, and from automatic  typewri-



ters and  word  processors  $3 billion.   The  combined  adjusted



revenues of these segments equals $38 billion, with approximately



90 percent of this revenue  contributed by the computer  manufac-



turers.  The profits in  each of these  product groups are  esti-



mated at $3 billion for computers, $319 million for word  proces-



sors and automatic typewriters,  and $14 million for  duplicating



machines, yielding a total segment profit of $3.1 billion.







Total capital  and  annual costs  of  compliance for  direct  and



indirect dischargers  combined,  assuming average  treatment  in-



place, are $275 million and $174 million, respectively.  Using an
                                253

-------
 interest  rate of 10.34 percent and an assumed useful life of  ten



 years, annualized costs  are estimated  at $219  million, or  0.6



 percent and   7.0  percent  of  the  total  segment  revenues  and



 profits,  respectively.  This suggests  that the average  facility



 would need to  increase prices  by 0.6 percent  to recover  costs



 associated with compliance.   If facilities are unable to pass  on



 any their costs increases in  the form of higher prices,  profits



 would be  reduced  by approximately  7. O percent  for the  average



 facility.  These impacts are not considered to be significant.
Rebuilding
For  purposes  of   this   analyses,   this  segment  includes  only
                             i ,,        , 111!, "• ;  .'' 'ih I' '<|W ii'll '''N.'  i • ' pi''1!! " ' '' i . .......  " ' '  '!!' i,1 yi'1 ,n!r ,i.i!' .
           111       . . .'    • ....... '    , - , ,,  ..  .,  ..... ;, (;, ..... ; ,;; ,' ..;,.'j ,;. : ,,, • ; ..... ..... , - ,, ,  • ...... , , •;** ••!'.)"? '

facilities which rebuild  copiers.   While other types of equipment




manufacturers would potentially  be   covered by a regulation,   the




technical data were sufficient  to  estimate  treatment  costs   for




rebuilding copiers  only.   According to the technical data,   there




are 12 facilities nation-wide which  rebuild  a combined total  of



100,000 copiers per year.
No published data  are available  on   revenues or profits  derived



from either  rebuilding  copier   services  or   from  the  sale  of



rebuilt copiers.  Hence, revenue  estimates used in this  analysis



are based  pn  the normal  plant   constructed for  the  technical

           • *'     '    !"'         , ..       : ' ,'.ii

analysis.  Revenues for this plant are  estimated at $2.7  million
                                254

-------
(1988 dollars) for 1987.  Assuming  that,  on average, each of  12

facilities have approximately  equivalent annual revenues,  total

segment revenues would be $32.3 million per year.65  Profits  are

estimated at $2.0 million per  year assuming that profit  margins

on rebuilt copiers are equal to those on new ones. °
Total segment  capital treatment  costs for  direct and  indirect

dischargers  (combined)  are  $1.3  million.   Annual  costs  are

$284,OOO, which  result in  an annualized  cost of  $300,200  per

year.  This represents 0.9 percent of revenues and 15 percent  of

profits for the average facility.  While some facilities will  be

more severely affected than others,  overall, this segment is  not

expected to sustain a  significant revenue impact.  However,  the

average facility may incur a moderate profit impact.
        scale-up  is  consistent  with  that  used  to   estimate
treatment costs.
       estimate  of profits  is based  on the  median  before-tax
profit-to-sales ratio for SIC 35793 - Duplicating Machines - from
Table X-29.
                                255

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 EFFECT OF MILITARY CONTRACTING PROCEDURE






 Department of Defense Maintenance Policies






 Department of Defense (DoD)  authorizes the performance  of  three


 major  types of maintenance that  could be covered by an   Environ-


 mental Standard covering Machinery Manufacturing, Rebuilding,  and


 Maintenance (MM&R).






 Military  maintenance levels  have been  established and   standar-


 dized  in  ascending order of  complexity and cost, beginning  with


 determination of the problem and  how to go about correcting   it.


 Conditions  Determination   involves  complete   analytical    and


 operational inspections  on customer's  site.  Repair is   intended


 to correct component  part failures or  other known defects,   but


 not intended to  restore the machine  to- its original  condition.


 Rebuild is the  return of the machine to its "like new" condition,


and involves completely  dismantling the machine and restoring  it.
            ,i "    'I, „    I  "' ill',,,  " ' ,  '       ,,,'.'.  ' , •  ",,i' ',"''' !,„ !'   '  •!, T I , I'' , ' ,"  ' , ',„ ", lili .1	 /1111'"! '

 Rebuild and Retrofit rebuilds  the machine and replaces  obsolete


and non-supportable  "numerical   control" units  with more  modern


units.  Remanufacture involves same  process as  rebuilding  and


retrofitting but  further improves the capabilities of the machine


to a level  beyond  its original  design.
                                256
                                     '(V , .If' *.» If ,,!.! iFI'lll!	3!	ill H,( 	I" i,J,\:t 'Mi	1!	 	In;!, r 1(1*	III!!:1' P. 'I1' -ill''if!	I] Jlil'll'' alt,! nil	«

-------
The three types of maintenance defined by DoD include:
     (1)  Organizational  Maintenance.    This   maintenance   is
          usually done  adjacent  to  the system  or  item  being
          repaired.  An example would be repairs done directly on
          an aircraft or on board  a ship.  Any military base  is
          able to do this type of repair and it is done mostly by
          military  personnel.   Organizational  maintenance   is
          funded with Operations and Maintenance funding.

     (2)  Intermediate Maintenance.  This maintenance is  usually
          not done on an operating site  but is done at a  nearby
          repair facility.  While a large percentage of this type
          of maintenance is performed by the military, some of it
          is done  by private  companies  under contract  to  the
          military. Intermediate maintenance normally consists of
          calibration,  repair  or  replacement  of  damaged   or
          unserviceable  parts,  components  or  assemblies;  the
          manufacture of critical unavailable parts; and  provid-
          ing technical assistance to those using and maintaining
          the material.   Intermediate  maintenance  is  normally
          accomplished in fixed or mobile tenders or shore  based
          repair facilities.

          The Army facility at Fort  Riley, Kansas is an  example
          of a consolidated maintenance  facility (CMF) in  which
          intermediate level repair work is done for the military
          on government  property  by private  contractors.   Two
          companies, E.G.  Services and  Doss Aviation  (helicop-
          ters) operate under a "cost plus awards fee"  contract.
          Under this contract the companies earn a base fee of  2
          percent and based on performance can earn an award  fee
          of up  to  5  1/2  percent.   Under  this  system,  the
          government provides the  work space and  all tools  and
          parts, and the contractor delivers their services on  a
          monthly basis.

     (3)  Depot Maintenance.  The purpose of depot maintenance is
          to support organizational and intermediate  maintenance
          by providing more extensive shop facilities, equipment,
          and personnel of higher level technical skill than  are
          available at lower levels of maintenance.  Depot  main-
          tenance involves  inspection, test,  repair,  modifica-
          tion, alteration,  modernization, conversion,  overhaul
          reclamation,  or  rebuilding   of  parts,   assemblies,
          subassemblies,  components,   equipment,   and   weapon
          systems; the manufacture of critical unavailable parts;
          and  providing  technical  assistance  to  intermediate
          maintenance  organizations.    Depot   maintenance   is
                                257

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          'normally accomplished  in fixed  shops, shipyards,  and
          other shore based facilities or by depot "field  teams".
         • Depot maintenance may be performed either as government
          owned government  operated  facilities, or  by   private
          sector  contractors.   The  operation  and  maintenance
          appropriation is the largest source of funds for depot
          maintenance activities, although  many other funds  and
          appropriations have budget authority "to authorize depot
          maintenance work.   Most major  repairs are  done at  a
          depot, with approximately 40 percent of the $12  million
          to $14  million  worth  of  work  done  in  FY87 being
          contracted to private industry and the other 6O  percent
          done by government employees.


Maintenance and repair activities are  performed at a variety  of

military  facilities  by  different  types  of  personnel.   Many

competing forces  help to  determine the  amount of  repair  work

which is done by military personnel, civil servants, and   outside

contractors.  These competing forces include:


     (1)  OMB Circular A76 - the Office of Management and  Budget
          circular which was  first put forth  in the 1950's  and
          deals with the use of outside contractors.

     (2)  Core logistics  -  a Department  of  Defense  Directive
          which  deals  with  the  use  of  contractor  and   DoD
          resources for maintenance of material.  This  directive
          states that it is DoD policy that "maintenance   support
          of DoD material is essential t^o |^l|e rapid and sustained
          application of  military power",and that  DoD  "shall
          provide an adequate program for maintenance of assigned
          material to:  (a) Provide  for mobilization  and  surge
          requirements as specified in  the most current   Defense
          Guidance; (b) Meet  efficiently and effectively  peace-
          time readiness and  combat sustaiiiability  objectives."
          The  directive  further  states  that  "To  the  extent
          possible, a  competitive commercial  depot  maintenance
          industrial base shall ,b:e established and,  as  required,
          shall be capable of expanding during mobilization."

     (3)  Directive 4151.1 - In the past, there was, in  general,
          a 70 percent  - 30 percent  split.,  with  7O percent  of
          repairs being done in house  by either the military  or
          civil  servants,   and  3O percent   done  by   outside
                                258

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         contractors.  Current  DoD  directives  decree  that  a
         decision-tree process must be developed by each of  the
         branches of  the military  service  to help  them  make
         decisions  concerning  which   types  and  amounts   of
         maintenance and  repair work  will be  contracted  out.
         This decision-tree  process does  not affect  the  Navy
         which is discussed  in (4) below.   The military  would
         like to contract  out as much  as possible while  still
         maintaining surge capacity,  mobilization ability,  and
         core logistics.

     (4)  DoD Appropriations Act -  FY85 legislation directed the
         Navy to initiate  a test of  the feasibility of  public
         and private  competition  for  the  overhaul  of  naval
         ships, and  required that  the  Navy compete  two  ship
         overhauls between the private and public sectors.   The
         FY86 appropriations Act  further required  the Navy  to
         compete at least four ship overhauls in FY86, with  the
         Navy  actually  competing   eight.   FY87   legislation
         required  that   the Navy  continue   to compete  out  the
         overhaul  of ships, and further stated that they  should
         now compete  the overhaul  of airplanes.  To meet  this
         requirement, Navy Aviation  is competing  the new  F-14
         overhaul  package, with  both military  depots and  with
         private  industry.  This legislation is unique  in  that
         it only   affects the  Navy; there   is no  corresponding
         legislation for the  other branches  of  the  service..
         This legislation originated because the U.S. shipbuild-
         ing  industry  is collapsing under competition from  Japan
         and Korea.  Currently, all ship  construction  is  done at
         private  yards  and  great pressure  is  being applied   to
         have  the remaining shipyards  do military work.   It   is
         interesting   to note    that  this   legislation    could
         possibly conflict with core  logistics  legislation.


Industrial  Funds



Each year  the  Office  of the  Assistant  Secretary   of  Defense

establishes stabilization rates for   each of the military  indus-

trial funds.  These fund rates are to be established at estimated

cost plus a surcharge.
                                259

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 Each military repair facility funded with industrial funds has  a



 dollar per  hour  charge which  it  levies  for  maintenance  and



 repair work.   This  charge is  called  a customer  rate  and  is



 established once a  year for  each industrial  fund.  Once  esta-



 blished, the rate charged  remains constant for  the year but  is



 adjusted annually.   Industrial  funds operate  on  a  break-even



 basis over the long run.  If profits occur they are refunded  and



 losses are adjusted through the collection of an amount equal  to



 the losses and  is called  a "pass-through".    Refunds and  pass-



 throughs occur between  the applicable industrial  funds and  its



 parent operation and maintenance  appropriation but do not  occur



 through the rate structure.   in other words,  adjustments are made



 at  the appropriation level  rather  than for each purchase  because



 this  would involve more  administrative  time  and effort than  the



 military believes it  warrants.  This approach  is  practical  for



 the military in  that the operation and maintenance   appropriation



 would receive the primary benefit  for refunds  and would bear  the



 primary  burden of any pass-through.   For  this reason,   providing



 for refunds  and pass-throughs  at  the appropriation  level  signi-



 ficantly  simplifies  the  process.   Large profits  or pass-throughs,



 unless considered  a  one  time occurrence, may be  reflected  in  the



 rate structure the following  year, and if  the  facility makes' a



profit, the dollar amount charged  the next year will be decreased



appropriately  until  the  budget  is  zero  profit,  zero   loss.
                                260

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Although it may not be exact,  this stabilization rate corresponds

to some degree with the cost of running the facility.



Stabilization rates have five major components: (1) direct  labor

(civilian; military  labor is  paid by  appropriated funds);  (2)

direct material, which the  military considers the driving  force

in determining rates; (3) direct other, which includes  temporary

duty (TDY) for Depot Field Teams and a small percent of  contract

support; (4) production, or operations, overhead, which  includes

shop-level personnel  (indirect  labor), shop  support  expenses,

supervisors, indirect material, and indirect other costs; and (5)

general and  administrative  (G&A) expenses,  which  consists  of

labor, material,  and other  expenses outside  of the  production

divisions but necessary for the overall mission.
To modernize  its facilities or possibly upgrade  its environmental

waste  treatment program,  the military may provide  funds  in   three

major  ways.   These ways  include:


      (1)   Military Construction  (MILCON) Funds.  These funds  are
           direct appropriations  from Congress  and do not   impact
           Industrial  Fund  rates   except for   Minor  Construction
           projects under $2OO,OOO.   They do not  directly impact a
           facility's   rate structure   for  repairs.   They   are
           usually used for major  one time projects.

      (2)   Industrial  Fund Surcharges.   The Asset  Capitalization
           Program  (ACP)   provides  funds for   minor  construction
           projects which  are  less  than $20O,OOO  and   equipment
           purchases or rehabilitations  greater  than  $5,000.  The
           obligation  authority for  ACP purchases  is  based on  a
           combination of  depreciation  expense  and  surcharge.
                                 261

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           Surcharges were instituted because  Congressional  appro-
           priations committees  required DoD   to  include  a  sur-
           charge in the Industrial Fund  rates  if the  budget  ACP
           requirements were in  excess of estimated  depreciation
           expenses.  Acquisitions under ACE' cannot exceed the sum
           of the  budgeted depreciation  expense  and   surcharge.
           Minor construction funds represent  only a small portion
           of the  total  amount  set  aside   in   the   rates.   The
           Product Investment Fund (PIF) and the Product  Enhance-
           ment Capital  investment Fund  (PECI) are  appropriated
           funds.  These funds are not part of the Industrial  Fund
           and are  not  subject  to  recovery through the  rate
           structure or as a surcharge to the  rates.

      (3)  The Defense Environmental  Restoration  Account  (DERA).
           centrally funds  the Defense  Environmental  Investment
           Program.   DERA funds may be used to finance  appropriate
           projects.  Clean up of sites contaminated with  hazard-
           ous waste is the main use of DERA funds.  Part of  this
           money is  allocated  for minimization.  Hazardous  waste
           on DoD facilities has a short  and a long term cost  to
           DoD.   Long term cost will greatly exceed the short  term
           cost.   The Hazardous  Waste Minimization  Program will
           reduce this long term cost by such projects as  finding
           substitutes for hazardous materials purchased by  DoD.
           The Defense Supply Centers  and the Defense  Industrial
           Plant Equipment Center  (DIPEC)  will identify,   priori-
           tize  and  review  the  specifications  and   standards
           pertaining to items   for which their  Center has  inte-
           grated material  management responsibility.   This  will
           facilitate  DoD   purchase   of   less   hazardous   or
           non-hazardous alternatives to  items, compositions  and
           formulations  and   industrial   processes    that   are
           presently required  or  allowed  by  requirements  docu-
           ments .
Differences  in   the  time   frame  in which  a  project has  to  be

completed, the size  of  the facility,  and the amount of work  that

has to be  done  determines which of these  methods the  military

will use to  upgrade .a facility.
Sometimes a  combination  of   these methods   may   be  used.    For
        '  '•       ' ' '• '"" •    ..<• "    >"*,.' ; , ': • :VW(*v*''V;v"" -i'1'' •'>!:'' ''" ' ''l|i;'l;;l"'""'1 ' '>> • ' ^:'rV
example, when a new solvent reclamation program was instituted at
                                262

-------
the Philadelphia Naval  Shipyard,  the Navy  centrally funded  the



equipment and the shipyard picked up the remaining costs.








Industrial Fund Activity and Depot Level Maintenance








Army Industrial Fund







The Army  Industrial  Fund  covers four  separate  commands:  the



Armament, Munitions and  Chemical Command;  the Missile  Command;



the Military Traffic Command; and the fund that we are  primarily



concerned with, the Depot System Command.







The Army provides depot maintenance at twelve  facilities,   eleven



of which are located within the United States.  These  facilities



are  currently  government  owned  and   government   operated  and



compete against each other  as well  as competing   with  private



industry. Although  most  of   the  work   is  done  by  government



employees,  some minor jobs are contracted out. The  scope  of  the



work and  contracting   procedures are presently  being  reviewed




under  OMB Circular  A-76.







For  the  expressed purpose of  improving  competition and to   insure



 the  availability of  some highly   skilled   labor,   army   depots



 specialize  in  different types  of  maintenance  and  repair  acti-



 vities.   For example,   the army  depot  in  Corpus Christi,  Texas
                                 263

-------
 specializes in aircraft (helicopters); Anniston, Alabama special-

 izes in  combat  vehicles (tanks);  Tooele,   Utah in  heavy  duty

 trucks; and Letterkenny,  Pennsylvania in tracked  self-propelled

 guns,  and heavy duty trucks.


                                          ,lli, ,  „ !!,, T ,;,    '       ,   „ ., , ,.   i'jn,;,,
 The Army depot command system  is funded through two  independent

 but related  industrial funds  with each  fund charging  separate

 rates:
                 " ,        :., •..   •• -	, (    is -	i,	'. .1	f  ni!   I''  "i'  • 	
           Supply operations include  receipt,,  storage,  issue,   re-
           warehousing,  preservation,  packing and packaging,   set
           assembly,  disassembly  and shipment  of stocks.    Other
           operations include  ammunition surveillance,  calibration
           of  equipment,   quality control  in   maintenance   and
           supply,  and  base    operations   support.    The    rates
           assigned to  these   funds   would  not  be affected  by
           changes in the  cost of  environmental  regulations.

           Depot  operations  include  inspection,   test,   repair;
           modification,   overhaul,    renovation  of   ammunition,
           reclamation  and  rebuilding  of  parts,    assemblies,
           subassemblies;  the  emergency manufacture of  parts  when
           otherwise  not  attainable;  and   provision  of  technical
           assistance to  other  DpD  organizational  units   and
           intermediate  maintenance organizations.
Army depot facilities  are of World-War-Two   vintage and   require

remodernization.  The military plans to spend 36 billion   dollars

in modernizing  these  facilities by  the  1990's.  It  is quite

possible that  military  construction  funds  could  be  used   to

accomplish  modernization  that  is  necessary  to  their   waste

treatment facilities,  and some  of this  may already  be  in  the

planning stages.
                                                                   • .i liii
                                264

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Presently there is  a changeover occurring  in the weapons  being



used by the Army  which has resulted in  a temporary decrease  in



repairs that are  currently being required,  particularly in  the



hard iron  work.   While the  Army  has  let a  large  number  of



civilian employees go,  it is  hesitant to  release more  workers



because of fear of losing its skilled staff.








Navy Industrial Funds







The Navy has forty-nine different industrial funds to fund  their



activities which  include  the  majority  of  the  Navy's  rework



facilities (shipyards,  air  rework, and  ordinance  facilities),



base service centers,  research and  engineering facilities,  and



the Military Sealift Command.







Naval Air Rework  Facilities (NARF)  perform a  complex range  of



depot level  rework  operations  on  designated  weapon  systems,



subsystems, accessories,  and  equipment in  support  of  various



weapon systems.  NARF facilities manufacture parts and assemblies



as required, provide engineering  services in the development  of



changes of  hardware  design,  and furnish  technical  and  other



professional  services  on  aircraft  maintenance  and   logistic



problems.   They  may  also  support  other  levels  of  aircraft



maintenance.  There are currently six naval aviation depots.
                                265

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Naval Shipyards provide  logistic support for  ships and  service



craft.  The shipyards are capable  of performing work in  connec-



tion with construction, conversion, overhaul, repair, alteration,



drydocking, and  outfitting.   They also  perform  manufacturing,



research, development, testing, and other services.







Navy shipyards have  been out  of the  new construction  business



since the early 1970's when the federal government concluded that



combat ships  could  be built  more  efficiently by  the  private



sector.  Navy shipyards, however,  perform a significant  portion



of Naval ship repairs, overhauls, and conversions.







The eight  existing military  shipyards are  complete  facilities



which include a foundry,  sheetmetal shop, pipe shop,  electrical



and electronics complex, electroplating shop, machine shop, winch



overhaul facility, paint and blast facility, and drydocks.







While each of  the shipyards  performs a  multitude of  services,



there is some specialization between  the shipyards.  Two of  the



eight shipyards (Philadelphia and Long Beach) are not equipped to



handle nuclear  repairs,  therefore nuclear  submarines  are  not



usually sent  there  for  routine  repairs.All  eight  of  the



shipyards have  electronics departments  but different  shipyards



specialize in  different  equipment,  and are  geared  to  handle



different types of radar.
                                266

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For example,  the  Philadelphia  Naval  shipyard  specializes  in



electronic  computerized  tracking  systems  (NTDS,  SPA25  radar



repeaters, SP4O  modules, and  SPSIO's).  Philadelphia's  foundry



does amalgamated castings which means they are capable of meeting



any casting specification for any metal.  They:are also the  only



shipyard that produces the  catapult launching hooks that  launch



airplanes off aircraft carriers.







Naval Industrial  Fund rates  used for  competitive purposes  may



vary from those used internally, and shipyards are told by  upper



management level DoD  personnel how they  should construct  their



rates for bidding purposes.







All eight shipyards are currently government owned and government



operated although there is some work that is contracted out.  For



example, there is  a shortage  of some  types of  workers at  the



Philadelphia Naval shipyard and some  of the repair work is  done



on the site by a drydock contracting company, PhillyShip.  On one



recent ship  overhaul,  3O,OOO  of the  130,OOO  person-days  the



overhaul  required  were  contracted  out.   While  much  of  the



equipment used was  provided by the  contractor, large  equipment



and the large drydock cranes were provided by the government.  In



addition there  is further  subcontracting that  is done  by  the



contractors (i.e., Frazier Boiler).
                                 267

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Currently a study  is being  done  by  the  Supervisor of Shipbuilding
                     :     i,        •• '    ,, •  . Ji" ,,„ !,"  T "III i '• ' .'i  ••!•'•   	  »  ' "   M'1'1  " ,^T
          *' 'I        '      ''        .    .,    ' '  I	I If.,,  ,|  I1",I H'v    I'll.  :   T  "'  i",1' • •
(SUPSHIP) Brooklyn in  which they are evaluating  the use  of

contractors for naval maintenance and repairs.



Air Force Industrial Funds  and the  Air  Force Logistics  Command



The Air Force industrial fund is composed of four separate  funds;

the Airlift Service Industrial Fund,  The Laundry and Drycleaning

Fund, San Antonio  Real Property Maintenance, and   the one  that

Concerns us, the Depot Maintenance  Industrial Fund.



Maintenance and repair work is   done at five Air Force   Logistics

Command (AFLC) Centers  which are operated  as government   owned,

government operated facilities.
The AFLC is composed of  12 directorates and  include:
     (1)  XR, AFLC management, is responsible for policy   regard-
          ing personnel manning, contracting, budgeting,   regula-
          tions , etc.

     (2)  DS  handles  the  distribution  of  all  equipment  and
          material.

     (3)  DA is in charge of forms, labels, and printing.

     (4)  SG is the Surgeon General's office and is involved with
          health issues  (bio  environment),  safety   (OSHA  com-
          pliance) and the Hazard Communication Act.

     (5)  JA is the judge advocate, it is the legal division.

     (6)  DE is  responsible  for  environmental  management  and
          contains  the  civil   engineering  group.   They   are
                                268

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     (7)
involved with housing, buildings, and all services that
the tenants of a base need.

SE/IG is involved in safety organizations and under the
Inspector General.
     (8)  PA is responsible for Public Affairs.

     (9)  PM is responsible for contracting.

    (1O)  MM is responsible for Material Management. They  manage
          the Air Force  weapon systems,  and determine  policies
          governing how components are to be maintained, as  well
          as the criteria  used to determine  what chemicals  and
          processes will be employed.

    (11)  MA is responsible for  Maintenance of the AFLC  weapons
          systems.   MA  has  its  own  environmental  management
          personnel to deal  with processes.   The command  which
          needs to have the work done, the using command, (Tacti-
          cal Air  Command  (TAG), Material  Air  Command  (MAC),
          Strategic Air Command (SAC)) turn their planes into MM,
          and, for  a fee,  MM  contracts the  work to  either  a
          contractor or MA.  If MA does the work, then MA charges
          MM for work done  for TAG and SAC,  who are both  under
          the Direct Air Force,  Major Force Program VII  (DAF-7)
          funding  program.  AFLC  sets   budgets  and   provides
          funding for  all DAF-7  requirements; therefore,  there
          are  no  reimbursements.  However,  MAC  is  under   an
          Industrial program, and MM  direct cites for work  done
          (MAC monies are used).


XR, DA, SG, JA, DE,  SE/IG, PA, PM, and  MM are funded by  Opera-

tions and Maintenance (O&M);  DS is both  O&M and stock  funded.

Only MA (Maintenance) is industrially funded.



Each of the  five logistic  centers has  information systems  and

perform contracting,  manufacturing,  distribution,  maintenance,

and material  management.  All  report directly  to  Headquarters

AFLC, Wright-Patterson Air Force Base, Ohio.  Beginning in  1988,

it will also include operations at the Aerospace Maintenance  and
                                269

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Regeneration Center at  Davis Monthan  Air   Force  Base  in   Arizona



where  storage,  reclamation,    regeneration,  and   disposal    of



aircraft and  other equipment   for all branches  of the   service



takes place.






Depot maintenance  services  involve   the   conversion,  overhaul,
                       „ „   i» n •      f ' •   '„'•'' i'',' . WLiiii1; .ii!' .,W!i''  |. i f  ', , "!  :'	•   ,,; ,,'"'''


repair  or  alteration  of  aircraft   and   other  equipment.    In



addition to work for the Air Force, AFLC provides support  for  the



Air National  Guard,  the  Air  Force   Reserve,  other   government



agencies, and "friendly" nations receiving U.S.  military   assis-



tance.                                 ,     ",",,„',, '    '          ".    "."..'






Since the early  seventies, the Air  Force  Logistics Command   has



been aligned  by  the  Technology Repair  Center  (TRC)  concept.



Under TRC,  repair  capabilities for   specific  technologies   and



components are  assigned to  a  depot   based on  consolidation   of



particular organic workloads.    Today  there are  20  technologies



spread across five depot structures and at  the Aerospace Guidance



and  Metrology  Center  (AGMC),  plus   selected   capabilities   at



Support Group Europe (SGE) and  Support Center Pacific  (SCP).






Each center  has a  wide variety of technological   capabilities.



The AFLC Directorate  of Workload Management,  is  responsible   for



effectively posturing these  capabilities for wartime   readiness.



Such issues  as  facility  surge workloads,  repair  techniques,
                                270

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future end-item technologies, and economics must be considered in

the centralized  planning and  control of  all depot  maintenance

workloads.



Specific workloads for each center include:
     (a)
     (b)
     (c)
     (d)
      (e)
      (f)




      (g)


      (h)
Oklahoma City Air Logistics Center (OC-ALC) - B-1B,  B-
52G, and  C-135 aircraft;  E-3A airframe;  TF30,  TF33,
J57, J79, F1O1, F1O7,  F108, and F110 engines.   OC-ALC
is the TRC  for hydraulics and  pneudraulics items  and
engine related accessories and components.

Ogden Air Logistics Center (OO-ALC) - F-4,  F-16,C-130,
and OV-10 aircraft;  Titan, Minuteman, SRAM,  Maverick,
ALCM, Falcon,  Sidewinder and  MX missile  systems  and
components; laser and laser subsystems; and repair  and
overhaul of landing gear.

San Antonio Air Logistics Center (SA-ALC) - B-52G&H, C-
5 and F16 aircraft; F-10O, TF-39, T-5.6 and gas  turbine
engines; and exchangeables.

Sacramento Air Logistics Center  (SM-ALC) - A-7,  A-10,
T-37, F-15 and  F-111 aircraft, Other  Major End  Items
(OMEI),   such   as   Radar   Bomb   Scoring;    Ground
Communication-Electronics;   and    "other"    workload
(software and manufacturing requirements).

Warner Robins Air Logistics Center (WR-ALC) - C-130, C-
141, and  F-15  aircraft; airborne  communications  and
navigation equipment; target  acquisition systems,  and
airborne electronic warfare  equipment.  WR-ALC is  the
TRC for  aircraft propellers,  life support  equipment,
instruments (gyros), and airborne electronics.

Aerospace  Guidance  and  Metrology  Center   (AGMC)
Inertial guidance and  navigation systems for  missiles
and aircraft repair;  and engineering and  consultation
services on inertial systems.
Support Group  Europe   (SGE)  -  organic  repair
capability  for supporting USAFE weapon systems.
                 depot
Support  Center   Pacific   (SCP)
support  to  the Pacific  theater.
-  provides  logistics
                                 271

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The AFLC  is  currently  evaluating  some of  the methods  it  is  using



for repair and maintenance  in  an attempt to determine the  least



environmentally harmful  method   for  getting a  job  done,   For



example,  the military  has  to remove paint before an  airplane can



be repainted and are trying different methods at different AFLC's



to see which is  the least  environmentally harmful and  the  most



effective.   To this end, Ogden AFLC is doing B-Blast  (bead-blast)



stripping, Oklahoma  City AFLC  is doing   chemical stripping  and



Warner Robins AFLC  is using  laser stripping.  The results  will



then be compared and a decision will be made as to which way  all



AFLC's will  strip paint.
The Marine Corps Industrial Fund
There is one  Marine Corps industrial  Fund which supports  depot



maintenance activities  at  two  depots in  Albany,  Georgia  and



Barstow, California.







Possible Effects of New Environmental Regulations







The effect of  any new government  imposed environmental  regula-



tions would vary with the dollar  value of the cost; the  effects



of the regulation on competitors in private industry; whether  it



would effect organizational, intermediate, or depot  maintenance;
                                272

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how the activity is funded; the branch of the military  involved;



and federal regulations and directives in effect at the time that



the environmental regulation becomes effective.








Effect of Regulations on Organizational Maintenance







The effect  of  increased  costs as  a  result  of  environmental



regulations is  likely to  have only  a minor  effect on  overall



maintenance decisions  and  how  maintenance is  carried  out  by



government-owned and  government-operated facilities,  and  main-



tenance would  continue to  be performed  by military  personnel.



Military policies  concerning organizational  maintenance   (i.e.,



maintenance done by  military personnel  on, or  adjacent to  the



system  being  repaired),   and  some  intermediate   maintenance



activities  is likely to be unchanged and thus the effect of  the



regulations on total maintenance activity is likely to be   small.



The reasons  for this  are twofold.   First, the  complexity  and



depth of  the  repair  work  is not  likely  to  require  complex



environmental regulations  (or  possibly even involve  the use  of



water), so  the  magnitude of  regulatory  imposed costs  is  not



likely to be large.  Second, even  if the regulation imposed, some



costs and thereby changed  the amount of money  the military  has to



spend, i.e., it could decrease  the amount of  available funds  oh



other items, it  is not  likely to change  the way  in which  the



military determines where  material will  be repaired and by whom
                                 273

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 (i.e.,  the use of military personnel, civil servants, and private

 contractors).   Hence,  it is impossible to determine a priori  how

 the small shift in military funds would occur.



 Effect  of Environmental Regulations on Intermediate Maintenance
The effect of governmental  imposed environmental regulations  on
                  :,   i;  ,     .     ... ,  ".• - ,.,; ," i. 	 „• ";',;, ,;;,!'.'	 si • • ' :! .;;r ',•'••.• ; f  • r • • • .::,><
government-owned,  contractor-operated  facilities  is also  likely

to involve  little more  than a  shift in  the way  the  military

spends  the allotted money.   While  an   increase in  environmental

spending definitely affects  the money   the military  has to  spend
                                ' '  .'',..' I •!, ,;«! ,,'MI	I	""""I' , i .   ' " I ' ' "  '•  	,
on other items,  it is  not likely to affect where and by whom MM&R

maintenance gets done.   It is a matter  of the  government  affect-

ing the government and the effect of the  shift in spending cannot

be predicted a priori.   The  affect  on  the private contractors  is

likely  to  be  minimal  or  nonexistent as  long   as the  regulation

does not   affect the  time required to perform  the  maintenance

because the  government  provides the   facilities and  materials

necessary  to perform the job.
Effect of Environmental Regulations on  Depot  Level Maintenance
Depot maintenance is the one area where environmental  regulations

may  potentially  affect  the  way  the  military   transacts   its

business (i.e., determines where  material will be  repaired,   and
                                274

-------
by whom).  It is extremely difficult to predict what will happen,



as it depends heavily on  how the military handles the  increased



costs.   Variable types of funding makes observation of the  link



between budgeted amounts for depot maintenance and work  actually



performed  during  depot  maintenance  activities  difficult.  In



addition, costs incurred  by military  personnel and  the use  of



investment-type items  and  modifications  of  the  facility  are



unfunded, i.e., they  are not  financed by  the industrial  fund.



Additional complications occur in attempting to track any effects



of an  increase  in  expenses due  to  environmental  regulations



because  the reporting  of costs, based  on financially  completed



job orders, does not match the reporting of costs  incurred due to



changes  in levels of work in process.  Methods of  cost  reporting



used  by  the military do not match the budget for maintenance work



to be started  during  the accounting  period,  nor  obligations




incurred in  "ordering" the work.







The military  has  the choice  of  using either construction  funds,



or an industrial   fund  (i.e.,  a surcharge),   an  industrial   fund



pass-through  (no  surcharge),   or   the   Defense    Environmental



 Investment  Program  (DERA),   to   finance   any   new  environmental



 regulations.   If they  choose  to   fund  it  through methods  that  do



 not  include an industrial  fund, it  will   decrease the amount"  of



 money they  have to spend  on  other  military items.  It will   not,



 however, show  up in  their  rate structure,   and thus  will  not
                                 275

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 effect the  way the  military  determines where  maintenance  and
                                          1.1,  ' !».',,•,   :  „"'.  * '  • '  '  ' '  : '.''•: "i 1,1 ,1,1;;!'.' ,, /

 repairs will be done and by whom.






 If DoD  chooses to  fund the  cost of  environmental  regulations


 through the  use of  industrial funds,  they have  the option  of


 handling the costs as  a pass-through or  having it reflected  in


 their stabilization rates.  If it  is handled as a  pass-through,


 once again it  will have little  effect on the  way the  military


 determines where and by whom MM&R  work will be done.  As  previ-


 ously explained,  a pass-through represents a collection of  funds


 outside of the industrial rate structure.   Owing to the fact that


 a  pass-through is  an additional  amount  collected by  facilities


 from industrial funds  for costs   in excess of  those charged  to


 industrial fund  customers,   it is  not  reflected in  the  rates


 charged and thus  does  not change the  competitive status of  the


 facility,  either  with other  military facilities  or with  private


 industry.






 If additional expenses  due to  environmental  MM&R  regulations  are


 reflected  in industrial fund stabilization   rates,  it may or  may


 not have an effect  on  how the military  determines where and  by


 whom maintenance will be performed.   It mustbe kept  in  mind that


 other military  facilities and private contractors would  be  faced


with the same regulations  and it  is  not known which  facilities


would have  the advantage  (i.e., might  have already  instituted
                                276

-------
some or  all of  the necessary  environmental controls).   It  is



quite possible that any  competitors, either military or  private



industry, would  be faced  with the  same cost  increases as  the



facility in question.  Furthermore, even if it is known that  the



competition is between  two or more  military facilities,  unless



the military makes an across-the-board judgement, it is not known



how each  installation  will  fund  the  necessary  environmental



controls.  DoD  publications  state  that  although  DoD  program



managers make decisions based  on cost considerations,  decisions



which may  appear  to be  cost  effective to  individual  program



managers or  facilities  may  not,   in fact,  be  the  most   cost



effective for the  department as  a whole.   In  other words   cost



effectiveness for  the  whole is more  than the sum  of  the   indi-



vidual  components.   Add to  this  the fact that the military   must



continually keep core logistics, mobilization, and surge  require-



ments  in mind when  making decisions  as to where and  by   whom



maintenance will be  done.   Additionally, because  it  is   important



to  the military  to maintain  its capabilities on  a broad   geogra-



phic basis  (for  example both  coasts),  the military may  choose  to



do  maintenance at  a facility   with  higher  costs  because of  its



location.   To  complicate matters  even  further,  political   con-



siderations must be  taken into  account  in  attempting to  explain



or  predict military  maintenance and  contracting  decisions.
                                 277

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 This whole  discussion  can  be  interpreted   to  mean  that  the


 military could choose not  to include the  costs of any   environ-


 mental MM&R regulations in their stabilization rates  if  they felt


 it was in the  best interests of the  nation and the   competitive


 status of the military to do so.
 In addition,  it is  quite possible that  even with stringent  new



 environmental  regulations,  some   facilities  would   incur   no



 unplanned or  unexpected costs, because the military is  currently



 planning on  modernizing  many of  its  facilities, and  in  many



 cases,  this  modernization could  include environmentally  signi-



 ficant  process modifications  and upgrading  its waste  treatment



 facilities.   DoD appears  to be concerned  and involved in  waste



 minimization  techniques.   They are  already planning  on  making



 some process  and wastewater treatment changes that might tend  to



 move them in  the direction that a MM&R regulation might take.
                                .  " " if , " « !  	,;•	.'*• •• .Fair, :, ' ' •':" ;, -, ,. :, •,     • -..T	
                                                                   f'li ..... 4
                                               ,, ; ..... '7
In conclusion, even   in areas  such as  depot maintenance,  where



there is a clear  possibility that governmental MM&R  regulations



could affect the way  in which the military conducts its  business



(i.e., effects where  maintenance work  will be done and how,  and



in what way the military chooses to contract out maintenance  and



repair work as opposed   to having it done  by the military or  by



civil servants) it is  not clear that this  .would, occur, and  the



effects would be impossible  to predict.   At the present time,  it

            '4'          I i"  ,     ,       i1  ''!	'"   ,' '  i'i'fl!!,* ' „" ," '  '",, '•:• iiiiii .I'll	;  'i'1 '' ''•"""  i' ' , i" !	»!,,'

is impossible to  predict the   types of  maintenance of  military



                                 278
"Ui'nil!' "I!!"1 "'!'"," ,'1'11"

-------
systems  that may  be necessary  in  the future.   New weapon   systems

may require different types of maintenance, and  thus the  require-

ments of the military and  the   procedures  they use  may  change   in

the future.   Future  types  of repair  work and  their  magnitude,  may

not fully be   comprehended at   the present time.     What is   clear

however,   is   that   governmentally   imposed   MM&R    environmental

regulations would affect the total   amount of money the   military

has to  spend on other items, although  this effect  is not  expected
to be significant or major in any way.
                                                   67
 6?At least one   DoD  command  —   the AFLC—   disagrees with   this
 conclusion.   They feel  that  the   effects  of  the regulation   could
 be significant and,  therefore, feel that  the environmental   costs
 should  be   funded   through a  Congressional   appropriation.     See
 letter  and comments  below.
 Ms. Marianne Baauregard
 Project Managar
 Abt Associates, Inc.      '                                                           '
 55 Wheeler Straat
 Cambridge, MA 02138-1168

 Oaar Ms. Beauregard

 We have reviewed the revised draft of the Department of Defense Maintenance policies «h1ch was Initially sent to us by Dr Lynne
 Tudor of the Environmental Protection Agency.  Our comments on the revised draft follow.
 tract decisions, and 1nterserv1ce proposals.

    b.  Page 16. paragraph (11). the last sentence should read. "However. MAC 1s under an Industrial Fund program, and MM direct
 cites for work done (MAC monies are used)."

    c.  Page 18.  Make the following corrections to specific workloads for each center: (In each case an engine  1s mentioned,
 the "hyphen" should be removed. I.e., TF30 versus TF30.)

       (1)  OO-ALC (para (b)). Add C-130 and OV-10 aircraft.

       (2)  SA-ALC (para (c)). Change B-52H to B-52G&H! delete C-130 and OV-10 aircraft; add F-16 aircraft.

       (3)  SM-ALC (para (0)). Add A-10. T-37-, and F-1S aircraft.

    d.  Page 19, seventh Hne, "OC" should read "Oklahoma City" for consistency.

 This revised draft 1s a much better version. However, we still cannot agree with your summation that the affect of governmentally
 Imposed MM&R environmental regulations affecting the total amount of money the military has to spend on other Items Is not
 expected to be significant or major In any way. We repeat paragraph two of our 2 Dec 87 letter to Dr. Tudor:

    "We recommend that costs associated with environmental Issues be funded by a Congressional appropriation, not Included 1n
 rate structures for Industrial funds.  Our bases for this belief are:
 ture.  (Footnote continued)
                                            279

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 LIMITATIONS  OF  THE ANALYSIS




 The  principal   limitations of   this preliminary   economic   impact

 analysis stem from a   lack of appropriate   data.  This  applies   to

 the  economic and financial profile  and the  subsequent  development

 of an economic  baseline  as well  as  to  the estimation of   effluent

 treatment  costs and the  assessment  of  economic impacts.   Data  for

 all  segments  of  MM&R sectors  are  not available   from a   single,

 consistent source.   Moreover,   "segments" defined   for the   tech-

 nical and  cost   analysis do   not,  in general,   correspond to   SIC
                            .  .  i      '         *  . '.'i   i '  i. "' r i1." i	i	•< «! if '"i i>	•          -  	

 codes or to other  commonly used  industry  definitions.^8
       b.  Current AFIF
assessments made concern
                 IF procedures for equipment and minor construction cost analysis Include the costs for any
 •.<«•• •.„.!,, h  i- .1.1 -   •t>u1P/Mn< or minor construction purchases. As a result, these «ould be the only envlro
•fttch could be Identified prior to a budgeted fiscal year.  Since these costs are not directly associated with prod
services as stated above, they should be pulled from our rate structure and Incorporated In. other QUt environmental

..i -.,.. "'  *'*''.'•*•• •<* Prices are set based on actual charges for a particular Job during a deflnad time fram
ta.j JJ     sometimes the result of past actions. I.e.. old dumps that requires clean-up or catastrophic events
r.,..JL.~! IH  fcliT rf"5  h "I* "v*rfd bv DIM funds.  (Catastrophic events are clearly excluded from A1r Force rate
Customers are Billed for actual «ork accomplished during a particular time frame; therefore,  rates and prices set f
year should not Include costs Incurred from past environmental actions.                    • •« H'
                                                                           nv1ronmenta1
                                                                           mental  costs
                                                                           clng goods and
                                                                           funding costs.

                                                                             Envlronmen-
                                                                           uch as  the
                                                                           tructures.)
                                                                           r a new fiscal
Included
trial fund
 d. There are currently many state and federal programs «h1ch fund environmental Issues. These programs are not
i «n1f!J*IIl*  tV  "••*"• "V*,«r» funded through separate appropriations. Taking environmental Issues from the 1ndus-
d «ould keep all environmental  Issues In Hne with federal and state appropriations "
It
  »e can Be of further assistance, please call Jenny Hagen, HQ AFLC/MAJA.  (513)257-6957.
COAOOH L. MCI.LS, Acto Chief

Financial Mont I. Analysis Olv
                                                                                            ,; ,,;,! f|
CO
   After the  preliminary  cost  analysis,  the  technical analysis  was
expanded  (see page 23).
                                            280

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Scope of the Regulation







This chapter  presented a  preliminary analysis  of the  economic



impacts that might be sustained  by a subset of segments  covered



by the potential limitations and standards.  In its totality, the



regulation could include some 192 four-digit SIC codes, involving



the manufacturing, rebuilding, repair and maintenance of  machin-



ery and  equipment.  While  the establishments  within these  SIC



codes are believed  to use similar  processes and, therefore,  to



generate similar wastewaters,  they are very  dissimilar from  an



economic and financial  perspective.  Hence, the  sheer size  and



diversity of the potentially regulated community has limited  our



ability to perform  a detailed  analysis for any  one segment  in



this preliminary assessment.







Treatment Cost Estimates







The detail of  the impact  assessment is further  limited by  the



format of the  treatment cost estimates.   The preliminary  tech-



nical analysis defines "segments" which are composed of a  number



of four-digit  SIC  codes  or  parts  of  four-digit  SIC  codes.



Facilities within  these segments  are  believed to  use  similar



processes, and  to generate  similar  flows and  are,  therefore-,



represented by a "normal" plant.  Wastewater flows are scaled  to



reflect segment flows and, subsequently, total segment  treatment
                                281

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 costs,  using a variety of data sources and assumptions.   In  most

 cases,  the sectors as  defined by the  technical analysis do  not

 correspond to SIC  codes or to  other commonly accepted   industry

 delineators.   Since  the economic  analysis  is based  solely  on
                      :.   '   •'.   '    "     l!  •„(, i 'Y1:1,;;" ''"  • I ..' ' ,"' "  . ' ,  :  "  .-,  v'!;i;!''';""	
 secondary  data,  which are most frequently available by SIC  code,

 the derivation of appropriate revenue and profit figures  required

 the use of numerous assumptions.   While great care was taken  to

 make certain that  all assumptions were  reasonable, logical  and

 consistent,  the actual effect of these assumptions on the  impact

 estimates  is  not known. However,  they clear limit the' precision

 of the  analysis.



 Technical  data  necessary to   estimate flows  and costs   for  all

 facilities were  not available.   Costs were estimated for  eleven
             1  .,"    '  ! '    '   ;    " i,    ",. " -i	!l ll\ill|11f" .. "• •• -f'','•• '.,." '.;':. • ; '-• • !y V1 •;•* , i f tW \ !'" '?'. .'•'.
 segments in two   broadly defined sectors.    In addition,  in  many
                      ' ,    '    ..•'"'.     , ,,,!,„ ;' ,; • • j "' '   	;['•   • v, v;,"1;  i!	  ' :f	- -",,1 ,(. ,--':;

 instances,  costs  for all components  thought to be included in   a

 given segment could  not be estimated  due to insufficient  data.

 For example,  while the scale-up factors used to estimate  segment-

 level costs   do not,   in  general,  correspond  to SIC  codes,   we

 estimate that approximately 19 four-digit SIC codes were   covered

by costs for  these eleven segments.   This lack of cost  estimates

 for many   facilities   thought  to  be within  the  scope   of   the

regulation has resulted in gaps in  the impact analysis.
                                 282

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The scaling factors used to develop segment-level treatment costs



may have resulted in double-counting some costs.  In addition  to



making it impossible to determine  the total cost of the  regula-



tion, this could result in both overestimates and  underestimates



of impacts.   For  example, treatment  costs  for Truck  ;and  Bus



Rebuilding and Truck and Bus  Repair and Maintenance were  scaled



from the normal  plant to  the sector  level based  on the  total



number of registered buses and trucks in 1987.  However,  -accord-



ing to  the  1982  Census  of  Transportation,  approximately  57



percent of all trucks  are driven for  personal use only.   These



light trucks are most likely  repaired and maintained at  service



stations,  auto  repair  shops  and  motor  vehicle  dealerships.



Treatment costs  associated  with their  rebuilding,  repair  and



maintenance would  be borne  by these  types of  facilities.   At



least some  of  these costs  are  likely  to be  covered  in  the



Automobile Rebuilding and Maintenance sector.  However, since the



extent of the overlap, if any, is not clear at this time, it  was



not possible to assign these treatment costs to specific facility



types.  To the  extent that service  stations, auto repair  shops



and motor vehicle  dealerships will incur  costs associated  with



truck repair and  maintenance, in  addition to  those related  to



auto rebuilding and  maintenance, the impacts  on these  facility



types will be underestimated.
                                 283

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 Economic and Financial Data






 The  economic  data are  drawn  entirely from  secondary  sources.


 Much of the  analysis is based  on data from  the 1982 Census  of


 Business and Robert Morris Associates (RMA).  This information is


 available only in aggregated form, both in terms of "industry" or


 "product" definitions and  in terms of  facilities.   This  limits


 our  ability  to  examine  impacts  on  specific  segments  (e.g.,


 product groups,  size categories)  and on individual facilities.





 The  use of averages  disguises the range  of impacts by  omitting


 the  very large and very small effects.   Smaller facilities may be


 more severely affected than larger ones.   Similarly, some product


 or service groups  may sustain worse  impacts than others.   Such


 differences are  not discernible from the analysis due to the  use
                     i "    j    '       ,      1 ' ' '•	 ',,  • ,'""   :   : ,n i,  • V'1   , „•  "„,, I

 of aggregates.






 The  lack of  facility-specific data  also limits  our ability  to


 project the  likely number   of  facility closures and  attendant


 employment losses.    Impacts  have been  measured as  annualized


 treatment costs  relative  to revenues and to  profits.   While these


are  commonly  accepted  measures,  they fail to identify clearly the
            !?• ,,       :          '   , •'• , iir   ", , i1  . Jin, i i'i,    hi   • , ,i, ,»:  „  • •'	f'1 'j;",,,1" j ,

most significant impact —  the closing  of a  facility.
                                284

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While some firm-level  information was  available from  secondary



sources such as Business Week.  Value Line Investment Survey  and



Dun &  Bradstreet, it  was of  limited use  for several  reasons.



First, many of  the firms  covered by  these sources  tend to  be



large and  to  engage  in  many  activities  unrelated  to  MM&R.



Secondly, even  if it  had been  possible to  identify the  MM&R-



related components of these firms'  business, we had no  informa-



tion  that  would  allow  us  to  scale  normal  plant  costs  to



firm-level costs.







Information on the ability of facilities in the segments examined



to pass through  costs is not  available from secondary  sources.



This made it necessary to  make the conservative assumption  that



all costs are absorbed  by the facility.  To  the extent that  at



least some of the  treatment costs can be  passed through  in  the



form of higher prices, the impacts are overstated.







COST-EFFECTIVENESS ANALYSIS







This section outlines the methodology and results of an  abbrevi-



ated cost-effectiveness  analysis carried  out  for a  series  of



normal plants involved in machinery manufacturing and  rebuilding



(MM&R).  This analysis  evaluates just  one treatment  technology
                                 285

-------
 for  eleven  industry segments  that  perform MM&R  work.   Normal



 plant cost-effectiveness  values are  then compared  across  MM&R



 industry  segments  and also  compared with  categories for  which



 effluent  limitations and standards have been promulgated.








 Methodology








 Pollutant Loadings  and Removals








 A "normal plant"  for each segment  was developed and was used  to



model pollutant removals and   compliance costs representative  of



 that segment.  While normal  plants are not statistically  repre-



sentative of the  segment as a whole,  efforts were made to develop



normal plants  which were  representative  of types  of  business



activity  that take  place in that segment.   Effluent monitoring of



normal plants for   each segment was  conducted.   Annual  baseline
                    in , !      ;    nl "  «,'  ' ,;, .' 'if • ' ' • • iii"1 'i'ii* ' I. . 'J1',' i  "i"1"  • • ', '.'t'  . • • "Vs '•: ic H ,'i '4


pollutant  loadings,  or  discharges,  of normal plant effluents were



calculated from the monitoring data.    The cost  estimates do  not



account   for  the   actual  pollutant   removals   attributable   to



in-place  wastewater  treatment.    Consequently,   this   analysis
           "H          j,	'         i .'   '.: '|.'i HIM,."1!:"'!,,,*" ill1 ', '''i . J ji ",  IB Hi  ' :  r« , •/


evaluates  the average  cost  per   unit  of pollutant removed  rather



than the marginal unit  cost.
                                                           ., ,,

                                                         '"t	v	i:;	;
                                286

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Pollutant  removals  were  estimated  assuming  the   appropriate

combination of  the  following treatment  technologies  for  each

aqueous wastestream:


     - preliminary treatment for cyanide precipitation and
       chromium reduction (where appropriate);

     - skimming for the removal of oil and grease; and

     - chemical precipitation, sedimentation, and multimedia
       filtration for the removal of metals.


Although the  removal of  conventional  pollutants such  as  oil,

grease, and suspended solids  is considerable, this  cost-effect-

iveness analysis is  limited to the  removal of toxic  (priority)

pollutants and other  metals only. ^  One  method of  calculating

cost-effectiveness values  divides the  cost  of removal  by  the

total mass of toxic pollutants  removed (reported in dollars  per

pound of pollutant removed) and makes no distinction between  the

relative harm to the environment and human health that  different

pollutants cause.



In order  to  correct  for  this deficiency  and  to  refine  the

aggregation of pollutant loadings of different chemical  species,
"^Inclusion of conventional  pollutant removals such  as oil  and
grease in the  cost-effectiveness analysis would  lower the  cost
per pound values considerably but  would not change the cost  per
pound-equivalent values because  only non-conventional and  toxic
pollutants are used for that calculation.
                                287

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EPA developed a  weighting  scheme  whereby  the   toxicity  of  each

priority  pollutant   (and   several  non-priority  pollutants)   in

surface waters is  taken  into account.  .The  mass  of each pollutant

(in Ibs)  is adjusted  to  reflect  the relative  toxicity  (to aquatic

ecosystems and human  health) of  each pollutant when compared  to a
                                         ,'i ,  '»,i'i i, , I •  . "    i,ii, ' ,'»,".    	 i •:, •	 '

standard  pollutant — in this  case the standard  is copper.    The

toxic weights of all   126 toxic  pollutants  and  an additional   20

non-priority pollutants  are included  in   Tables  X-30 and  X-31

(pages 348 and 352, respectively).70   In this case,  the   weighted
 %
copper-based  pounds-equivalent   are   used   to    calculate   a

cost-effectiveness value in units of dollars  per pound-equivalent

removed.
Effluent guidelines, and  thus this cost-effectiveness  analysis,

evaluate the change in pollutant  loading to a receiving body  of

water.  Consequently,  the  pollutant loadings  andremovals  of

those  plants  that  discharge  wastewater  to  a  sewer  system,

indirect dischargers,  are modeled  slightly differently  in  the

cost-effectiveness analysis to  discount the  removals that  take

place  at  the  publicly  owned  treatment  works  (POTW).    EPA
7°This analysis evaluates  controls for the  removal of 23  toxic
metals.   Although   other  pollutants   are  present   in   MM&R
wastestreams (See Column  (1) in Tables  X-37 (page 358)  through
X-47 (page  380) for  sector-specific discharges),  they are  not
removed under the assumed control option.
                                288

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developed POTW removal efficiencies for the toxic pollutants used

in this analysis (contained  in Table X-30).    For example, if  a

POTW removes 65  percent of  the zinc  in the  influent then  the

normal plant's end-of-pipe loadings  and removals are  multiplied

by 0.35 (1-0.65) to calculate the pollutant loadings and removals

at the  receiving  stream  that are  attributable  to  regulatory

requirements.



Treatment Costs



Calculation of cost-effectiveness  values requires an  estimation

of treatment costs in addition to the pollutant removals achieved

by the selected control technology.  The treatment costs for  the

selected technology were  estimated by EPA.   Capital costs  were

annualized using a capital recovery factor of 0.165.^1  A  normal

plant's total annualized  cost is  simply the  sum of  annualized

capital and the annual O&M costs.



Cost-Effectiveness Results



Cost effectiveness values are simply the quotient of the costs of

removal, over  a specified  period  of time,   and the  pounds  or
 ' 'Based on  an interest  rate  of 1O.34  percent and  an  assumed
useful life of 1O years.
                                289

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pounds-equivalent removed in that  same  period.   For this  analy-

                     :,,„'.       ,  ", ......... i! "!!;,  '• ',' !,„. „ •"' i?! /; ....... ", ,   i ,:   • , „  • ; •'.; "».. ,,,,,, ••  , • »1;:!'1ih,!|i'i;,;i;j;;i,ii|,
sis,  both costs and removals are reported on  an  annual basis.
                              '      ' '         ' '         "        '
This  cost-effective analysis is influenced  by several factors and


assumptions which  affect  comparison of  the  cost-effectiveness


values  and interpretation of the results.   First,  treatment costs

are dependent upon  the flow treated  at  the  plant  but are  non-


linear;  larger  treatment  facilities  benefit  from  engineering


economies  of scale in their  construction a.nd operation and  tend


to be less expensive  on a unit cost  basis.   This effect can  be
                    1 i; " •   .  .. ' '   .•:> :•:.  • ; „ !t  t;, •;.. ...... ",!: ...... •;;• M* u- ;•• .'.'". "it"1 '•'.•>' '.'-,.> ./' v'vr'S'i.'Mi'
seen  in  the Aircraft Rebuilding, Railroad Maintenance,  and Office


Machine  Manufacturing  segments  where  normal  plants  have  the


largest  wastewater flows, all over  10 million gallons per  year,


and have  the lowest  three cost-effectiveness  values.   Second,

removal  efficiencies depend on  the concentrations of  pollutants


found in the wastewater.  The assumed treatment technologies  are


less  efficient  at  pollutant removal  when   wastewaters  contain


extremely   low  pollutant   concentrations.    In  addition,   the


selected treatment technology may remove  certain pollutants  mor®


or less  effectively than  it does others.  One  or both of  these


technological limitations may  explain the  relatively high  unit
           ,.i i   „     • • •, "     „ ' i '•   |i  • ,   '• '  „  .I'ir'U,, ''!i "! Jhi.:, '.4, .:» „„ . il ..... . , •'• : !'!ii ,.i'   , ., ',,',,   . i, „ „, ""!,i ',:"', .lip1

cost  of  removal  for  three segments where  removals are low  when


compared to  treated flow:   Bus and  Truck Maintenance,  Bus  and
           ,;•      '   i'   >'.  •' . '''' ,'• ..... " '           i               ii          ii
Truck Rebuilding,    and  Office   Machine  Rebuilding.    Third,

  i' "        • i         ';     "• ..... ' • '   ' .'.-          I i   i|
pollutants    that    would    be     removed   by    a
''i.'iC. Mini1 t ', "H ,„ •''
                                 290

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are not  attributable to  pretreatment removal  by indirect  dis-



chargers.  Since the costs of  treatment are the same for  direct



and indirect dischargers but  the at-stream removals of  indirect



dischargers are lower,  the cost-effectiveness value  will be  at



least equal to,  and usually  higher than, the  value for  direct



dischargers.







Table X-32 (page 353) summarizes pollutant loadings and  removals



for all  MM&R  segments.   Bus and  Truck  Maintenance,  Aircraft



Rebuilding, and  Office  Machine  Manufacturing  account  for  70



percent  (when measured in  pounds) of the  413 million pounds  of



non-conventional toxic pollutants that MM&R facilities  discharge



annually (measured at end-of-pipe).   Effluent treatment for  the



Office Machine Manufacturing  segment accounts for  over half  of



the industry's expected removals.  When removals are weighted for



relative  toxicity,   the  Office  Machine  Manufacturing  segment



removals account for  76 percent of removals across all  segments.



On a per plant basis, the greatest toxicity-weighted removals are



achieved in the Aircraft  Rebuilding and Office Machine  Manufac-



turing segments; over 20,OOO Ibs-equivalent are removed by direct



discharging plants.   Controls in  Rail Maintenance normal  plants



also remove over 20,OOO  pounds of pollutants annually.   Because



these are relatively  low-toxicity pollutants,  only about   1,OOO



Ibs-equivalent are removed by controls for this segment.  A  more
                                 291

-------
 detailed  discussion  of  pollutant  loadings,   toxicities,    and
 removals for each segment is presented on page  296.

 The cost-effectiveness analysis results are reported and reviewed
 first in $/lb and then in $/lb-eq.   Tables X-33,  page 354 (direct
 dischargers) and X-34,  page 355 (indirect dischargers)   summarize
 the results  for  all  segments and show that when viewing  cost   per
 pound removed values^  the  effluent  guidelines  are most cost-
 effective for the Railroad Maintenance segment  ($5/lb  for   both
 direct and indirect  dischargers)  and are least  effective for   the
 Office Machine Rebuilding segment ($2,835/lb  for  direct  discharg-
 ers  and  $3,386/lb for  indirect   dischargers)  where only  17 to 20
 pounds of pollutants  are removed  per  year from   a  discharge of
 400,000  gallons.   All but the Bus and Truck Rebuilding and Office
 Machine  Rebuilding segments  have  cost-effectiveness  values under
 $400/lb  removed   and  four   segments  have  values  under   $1OO/lb
 removed.
Reviewing the cost-effectiveness values for the segments in terms
of  pounds-equivalent  of  pollutants  removedyieldssomewhat
different results.   These differences  are due  to the  relative
toxicities of  the  pollutants  being  removed  by  the  selected
treatment technology.   Generally,  the  toxic  weights  of  most
pollutants that would be removed by the MM&R guidelines are lower
than that  of  copper.   Hence, when  the  relative  toxicity  of
                                                                   i i Jii
                                292

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pollutants are taken into account, the cost per  pound-equivalent



removed for most segments is  higher than when measured in  $/lb.



This difference is as much as 25-fold for two segments  (Railroad



Maintenance  and  Bus  and  Truck  Rebuilding)  which   discharge



relatively low-toxicity pollutants.  Values greater than 1 in the



"Relative Toxicity" column in Tables X-33 and X-34 indicate that,



in aggregate, the removals are less toxic than an equivalent mass



of copper.  For  both direct  and indirect  dischargers, Bus  and



Truck Rebuilding has the highest, and thus least desirable, cost-



effectiveness value  ($39,M99/lb-eq. for  direct dischargers  and



$43,323/lb-eq. for indirect dischargers), while Office  Machinery



Manufacturing has the lowest  ($19/lb-eq. for direct  dischargers



and $46/lb-eq. for indirect dischargers).  Bus and Truck Rebuild-



ing is the  only other  segment with  a cost-effectiveness  value



over $1O,OOO/lb-eq.; three  of the eleven  segments have a  value



between  1,9OO and $8,100 per  Ib-eq. for direct dischargers   (six



for the  indirects);  the remaining seven (four for the   indirects)



have values under $1,OOO/lb-eq.







In  summary,   the   selected   wastewater  pollution  controls   are



exceedingly  costly when compared   to  the pollutant  removals   they



achieve  for  three  MM&R segments  (Bus  and Truck  Rebuilding,   Bus



and Truck Maintenance, and Office Machine  Rebuilding).   The   cost



per Ib-eq removed of the  remaining eight segments range from  $19
                                 293

-------
                           .':' v.;	;" '.;;;' • • • ' ••";;;!" ;:l"f % MJK- ?'!	*':[:	^ff *.;!•'"; 'i- :f •	!::!:' f !1;!|	IMB8
 to $1,378 for direct dischargers  and $46 to $5,624 for  indirect
 dischargers.

 The control technologies selected for the MM&R study do not yield
 low cost per pound-equivalent removed values when compared to the
 values obtained by effluent guidelines for other categories.   As
 shown in  Tables  X-35 (page  356)  and X-36  (page  357),   cost-
 effective  values   (1981   dollars)   for  promulgated   effluent
 guidelines generally  range from  $1   to $404/lb-eq.  for  direct
 dischargers   and   from   $1    to   $155/lb-eq.    for   indirect
 dischargers.72  If annualized   cost estimates  for MM&R  segments
 are  adjusted  from  1988 to 1981   dollars (see Column  6 in  Table
 X-33),  five of the eleven MM&R industry segments  fall within  the
 cost-effectiveness range for direct dischargers under established
 effluent limitations  presented   in  Table  X-35.    For  indirect
 dischargers,  only  three  of the  segments  have  cost  per  Ib-eq
 removed (Column  6 in Table X-34)  within the  established range  of
 values presented in  Table  X-36.   Given the  analysis'   limitation
 of  evaluating   a   single  treatment  technology,    it  is    not
 unreasonable  to  assume that the  cpst-effectiy.eness  values may  be
 lowered for the  regulation by  considering  other effluent  control
 technologies.  On the  other hand,  other factors may necessitate
            .       ,     ..      ,       ,,    •.       .    ;;,,     .  •
72Cost-effectiveness guidelines  taken  from  "Cost-Effectiveness
Analysis for Effluent Guidelines," U.S. EPA, OWRS, May  1988.
                                294  	'	  '

-------
adoption  of  treatment  technologies  despite  relatively   high



cost-effectiveness values.








Limitations







It is important to note that this cost-effectiveness analysis did



not evaluate the optimally cost-effective control option for each



segment.   In  this  case,   only  one  control  technology   was



evaluated.   The  monitoring  information  indicated  that   many



segments discharge  significant  amounts of  toxic  organic  com-



pounds.  If  these toxic  compounds  were also  controlled,  then



there would  be a  substantial change  in the  cost-effectiveness



values for each of the segments affected by the MM&R regulation.







Two expected sources for  error in the cost-effectiveness  values



presented in  this  report  result  from  the  protocol  used   in



developing normal plants  and subsequent wastestream  monitoring.



First, while  every  effort  was made  to  select  representative



plants, normal plants may not be representative of  industry-wide



practices within  a MM&R  segment.  In  addition, the  short-term



waste stream monitoring conducted  may not properly  characterize



the effluent and ensure that it is representative of all  activi-



ties carried out  in the  facilities.  The large  range in  cost-



effectiveness values may be, in part, a result of the preliminary



nature of  this  analysis and  extreme  values should  be  viewed



cautiously until further analysis is done.
                                295

-------
Pollutant Loadings, Removals,  and Cost-Effectiveness Results  by



Segment








This section  presents, by  pollutant  within MM&R  segment,  raw



pollutant discharges, end-of-pipe pollutant removals (in pounds),



copper-based toxicity weighting  factors, POTW removal  efficien-



cies, at-stream toxicity-weighted  removals for  both direct  and



indirect discharging plants, and cost-effectiveness results.







Automobile Rebuilding and Maintenance







The normal plant  for the Automobile  Rebuilding and  Maintenance



segment discharges organic compounds and metals. (See Table X-37,



page 358.)   None  of  the  organic  compounds  are  specifically



controlled or removed.   Seven of  the 11 metals  present in  the



wastestream are removed by chemical precipitation and  subsequent



clarification and filtration.  The  127 Ibs of non-  conventional



and toxic pollutants  removed from 66,OOO  gallons of  wastewater



include copper, lead, zinc, aluminum, boron, iron, and tin.  When



weighted by  their  toxicities  relative to  copper,  the  annual



removals total 26 Ibs-equivaient.   For indirect dischargers,  17



Ibs-equivalent would be removed by pretreatment; one-third of the



pollutants in  an indirect  discharger's effluent  (9 of  the  26



Ibs-equivalent) would otherwise be removed by treatment at a POTW



before  ultimate  discharge  to  surface  waters.   Dividing  the
                                296

-------
annualized treatment costs ($21,62O)  by these removals yields  a



cost per  Ib-equivalent removed  of $819  for direct  dischargers



(6th lowest  value across  all eleven  segments) and  $1,244  for



indirect  dischargers  (5th  lowest   value  across  all   eleven



segments).







Automobile, Bus, and Truck Parts Rebuilding








The normal  plant  for  the  Automobile,  Bus,  and  Truck  Parts



Rebuilding segment discharges organic compounds and metals.  (See



Table X-38,  page  36O.)   None  of  the  organic  compounds  are



specifically controlled or  removed.  Thirteen of  the 18  metals



present in the wastestream are removed by chemical  precipitation



and subsequent  clarification and  filtration.   The 871  Ibs  of



non-conventional  and  toxic  pollutants  removed  from   506,OOO



gallons of wastewater  include cadmium,  chromium, copper,  lead,



nickel, zinc, aluminum, barium, boron, iron, manganese, tin,  and



titanium.  When weighted by their toxicities relative to  copper,



the annual  removals  total  159  Ibs-equivalent.   For  indirect



dischargers, 33 Ibs-equivalent would be removed by  pretreatment;



about  three-quarters   of   the  pollutants   in   an   indirect



discharger's effluent  (126  of  the   159  Ibs-equivalent)  would



otherwise be  removed  by treatment  at  a POTW  before  ultimate



discharge to surface waters.   Dividing the annualized  treatment



costs  ($63,4OO) by these removals yields a cost per Ib-equivalent
                                297

-------
 removed of $399  for direct  dischargers (5th lowest value  across

 all  eleven  segments)  and  $1,904 for  indirect dischargers  (6th

 lowest  value across all eleven segments) . ^3

                                        .....


 Bus  and Truck Rebuilding
The normal  plant   for   the  Bus   and  Truck  Rebuilding  segment

discharges organic  compounds   and  metals.  (See  Table X-39,   page
           ..... "HIT,        "'I   i   ,'i,',,:, ,   »:,. „,  • , ..... „' „ ..... !' i'",' ,,,,.,|||'!!',;j, SI!',, - ,M ' ' |,'.'.|; ,„ ' ,i, i ,;v '|. jl',,,11 ..... ! ,„ ••"'!'' ,, i ..,
362.)  None of  the  organic  compounds  are specifically  controlled

or removed.  Five of the 17 metals present in the wastestream are

removed by  chemical precipitation and subsequent   clarification
  "• :   '      , |   .             '• ii;1 ' ,    ..... ' ii        i
and  filtration.    The   SO  Ibs  of  non-conventional  and toxic

pollutants  removed  from  1.98  million  gallons of  wastewater

include zinc, barium,  boron,  iron,   and tin.    When  weighted  by

their toxicities relative to  copper,  the annual  removals total  3

Ibs-equivalent.  For indirect  dischargers,  3 ribs-equivalent would

be removed by pretreatment; less   one tenth of the pollutants  in

an indirect discharger's  effluent  (less  than one pound-equivalent

of the 3 Ibs-equivalent)  would otherwise be removed by   treatment

at a PQTW before ultimate discharge to surface waters.    Dividing

the annualized  treatment  costs   ($129,000)  by these   removals
                                                                •	
    higher rank in cost per pound-equivalent removed for  indirect
dischargers indicates  that  pollutants in  this  sector's  waste
stream are readily removed at the POTW.
                                298

-------
yields a cost  per Ib-equivalent  removed of  $39,486 for  direct



dischargers  (highest  value  across  all  eleven  segments)  and



$43,434 for indirect dischargers (highest value across all eleven



segments).







Bus and Truck Maintenance







The normal  plant  for  the Bus  and  Truck  Maintenance  segment



discharges organic compounds  and metals. (See  Table X-40,  page



365.)  None of the organic compounds are specifically  controlled



or removed.  Six of the 16 metals present in the wastestream  are



removed by  chemical precipitation  and subsequent  clarification



and filtration.   The  125  Ibs  of  non-conventional  and  toxic



pollutants  removed  from  1.41  million  gallons  of  wastewater



include copper,  lead, zinc,  aluminum,  boron, and  iron.   When



weighted by  their  toxicities  relative to  copper,  the  annual



removals total 11  Ibs-equivalent.  For  indirect dischargers,  5



Ibs-equivalent would be removed  by pretreatment; more than  half



of the pollutants in an indirect discharger's effluent (6 of  the



11 Ibs-equivalent) would otherwise be  removed by treatment at  a



POTW before ultimate discharge  to surface waters.  Dividing  the



annualized treatment costs ($39,O95)  by these removals yields  a



cost per Ib-equivalent removed  of $3,627 for direct  dischargers



(2nd highest value  across all  eleven segments)  and $8,077  for
                                299

-------
 indirect  dischargers   (2nd  'highest  value  across  all   eleven
          'Ml" '  '      " '       '     '          '•   Li r  I     ' ' ' „ i ,'i ' ,
 segments).
nii< "'iini,:..in '	,m ,*:
Radiator Rebuilding


The normal plant for   the  Radiator  Rebuilding segment  discharges
organic compounds and  metals.  (See   Table  X-4l,  page 367.)    None
of* the organic compounds are specifically  controlled or  removed.
Seven of the  11 metals present in the  wastestream are removed  by
chemical precipitation and subsequent clarification and  filtra-
tion.  The  40  Ibs  of  non-conventional   and  toxic  pollutants
removed from  25,08O gallons  of wastewater include copper,   lead,
zinc, aluminum, boron,  iron,  and   tin.  When weighted by   their
toxicities relative  to  copper,  the   annual removals  total  9
Ibs-equivalent.  For indirect  dischargers,  5  Ibs-equivalent would
be removed by pretreatment; almost  one-half of the pollutants  in
an indirect  discharger's  effluent   (4 of   the 9  Ibs-equivalent)
would otherwise be removed by  treatment at a  POTW before ultimate
discharge to surface waters.    Dividing the annualized  treatment
costs ($11,759) by these removals yields a cost  per Ib-equivalent
removed of $1,375 for  direct dischargers (8th lowest value  across
                  ...          I         	   . .   '  ;-	
all eleven  segments)  and  $2,529 for   indirect  dischargers  (7th
                                          i  M	,p ,••;<• ,,.' I . •;•••  • -, ; i * •  ",  : .• , i».'itJ"
lowest value across all eleven segments).
                                300

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Aircraft Rebuilding








The normal plant for  the Aircraft Rebuilding segment  discharges



organic compounds,  metals, and  cyanide. (See  Table X-42,  page



369.)  None of the organic compounds are specifically  controlled



or removed.  Eleven of the  23 metals present in the  wastestream



and cyanide are removed by chemical precipitation and  subsequent



clarification and filtration.  The 25,678 Ibs of non-conventional



and  toxic  pollutants  removed  from  63.8  million  gallons  of



wastewater include  cyanide,  cadmium,  copper,  nickel,  silver,



zinc, boron, cobalt,  iron, and manganese  but chromium and  lead



amount for about one-half of  the total removals.  When  weighted



by their toxicities relative to copper, the annual removals total



27,788   Ibs-equivalent.    For   indirect   dischargers,   6,249



Ibs-equivalent  would   be   removed   by   pretreatment;   about



three-quarters of  the  pollutants in  an  indirect  discharger's



effluent (21,539 of the 27,788 Ibs-equivalent) would otherwise be



removed by  treatment  at a  POTW  before ultimate  discharge  to



surface  waters.    Dividing  the   annualized  treatment   costs



($788,700) by  these removals  yields  a cost  per  Ib-equivalent



removed of $28  for direct dischargers  (2nd lowest value  across



all eleven  segments)  and  $126 for  indirect  dischargers  (2nd



lowest value across all eleven segments).
                                301

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 Aircraft Maintenance
 The normal plant for the Aircraft Maintenance segment  discharges



 pesticides,  organic compounds,  and metals.(See Table X-43,page



 372.)   None of the pesticides  or organic compounds are  specifi-



 cally  controlled or removed.   Twelve of the 19 metals present  in



 the wastestream  are  removed  by  chemical  precipitation   and



 subsequent  clarification  and  filtration.    The  232  Ibs   of



 non-conventional  and  toxic   pollutants  removed  from   616,000



 gallons of wastewater  include cadmium,   chromium,  copper,   lead,



 nickel,  zinc,  aluminum,  barium,   iron,  manganese, molybdenum  and



 titanium.   When weighted by their toxicities relative to  copper,



 the annual  removals  total  121  iIbs-equivalent.   For  indirect



 dischargers, 48 Ibs-equivalent  would be removed by  pretreatment;



 more than  half of  the  pollutants  in  an  indirect  discharger's



 effluent (73   of  the  121  Ibs-equivalent)  would  otherwise  be



 removed  by  treatment at a  POTW  before ultimate  discharge  to
            ',;, •  •  "   	 ,.   "• •  i*';/ / •   ;• •• ,	;,;	  i        i          i i  °


 surface  waiters.     Dividing   the   annualissed  treatment   costs



 ($37,61O)  by   these  removals yields a   cost  per   Ib-equivalent



 removed  of $311  for direct  dischargers  (4th lowest value  across



 all  eleven segments)  and  $785  for indirect  dischargers  (4th



 lowest value across all  eleven segments).
'I:
Railroad Rebuilding
The normal plant for  the Railroad Rebuilding segment  discharges



organic compounds and metals. (See  Table X-44, page 374.)   None



           '   /  '     ,    •   .  •  302
                                                                   1	i '= 'ij!-"1,,:. 11

-------
of the organic compounds are specifically controlled or  removed.

Seven of the 18 metals present in the waste stream are removed by

chemical precipitation and  subsequent clarification and  filtra-

tion.  The  858  Ibs  of non-conventional  and  toxic  pollutants

removed from 5.28 million gallons of wastewater include chromium,

copper, lead, zinc,  barium, boron, and  iron.  When weighted  by

their toxicities relative  to copper, the  annual removals  total

163 Ibs-equivalent.  For indirect dischargers, 27  Ibs-equivalent

would be removed by pretreatment; more than three-quarters of the

pollutants in an indirect discharger's  effluent (136 of the  163

Ibs-equivalent) would otherwise be removed by treatment at a POTW

before  ultimate  discharge  to  surface  waters.   Dividing  the

annualized treatment costs ($149,600) by these removals yields  a

cost per  Ib-equivalent removed  of $916  for direct  dischargers

(7th lowest  value across  all eleven  segments) and  $5,624  for

indirect  dischargers  (8th  lowest   value  across  all   eleven

segments).



Railroad Maintenance



The normal plant for the Railroad Maintenance segment  discharges

organic compounds and metals. (See  Table X-45, page 376.)   None
  A higher rank in cost per pound-equivalent removed for indirect
dischargers indicates  that  pollutants in  this  sector's  waste
stream are readily removed at the POTW.

                                303

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of the organic compounds are specifically  controlled  or   removed.

Ten of the 22  metals present  in the  wastestream are' removed   by

chemical precipitation and  subsequent clarification  and   filtra-

tion.  The 25,289  Ibs of non-conventional  and  toxic pollutants

removed from 15.4 million gallons of wastewater  include   cadmium,

chromium, copper, lead, zinc,  aluminum, boron,  iron,  manganese,

and titanium.   When weighted  by  their toxicities   relative   to

copper, the  annual  removals  total  1,O74  Ibs-equivalent.   For
           i,       " '              i   ,  ' • I   ' '"• '"' 'S i i'"' ,," >i ' ' i'     ' ' ' 'I ' I'n"'|i ' ' '' ' ",'illl"1'11'' »fi, '!!,•'"
indirect dischargers,  845  ibs-equivalent would  be   removed   by"

pretreatment; one fifth  of the  pollutants in  an indirect  dis-

charger's effluent  (229  of   the 1,074  Ibs-  equivalent)   would

otherwise be  removed  by treatment  at  a POTW  before   ultimate

discharge to surface waters.   Dividing the annualized treatment

costs  ($133,900)   by  these   removals   yields  a   cost   per

lb-equivalent removed of $125  for direct dischargers  (3rd lowest

value across all eleven segments) and $158 for indirect discharg-

ers (3rd lowest value across all eleven segments).
Office Machine Manufacturing



The normal  plant for  the Office  Machine Manufacturing  segment

discharges organic compounds, metals, and cyanide. (See Table  X-

46, page  378.)  None  of the  organic compounds  or cyanide  are

specfically controlled  or  removed.   Twelve ofthe  27  metals

present in the wastestream are removed by chemical  precipitation
                                304

-------
and subsequent clarification and  filtration.  The 54,647 Ibs  of



non-conventional and toxic pollutants  removed from 24.2  million



gallons of wastewater include cadmium, chromium, copper, mercury,



lead, nickel, zinc,  aluminum, boron, iron,  manganese, and  tin.



When weighted by their toxicities relative to copper, the  annual



removals total 2O,790 Ibs-equivalent.  For indirect  dischargers,



8,8O1 Ibs-equivalent would be removed by pretreatment; more  .than



half of  the  pollutants  in an  indirect  discharger's  effluent



(11,989 of the 20,790 Ibs-equivalent) would otherwise be  removed



by treatment  at  a POTW  before  ultimate discharge  to  surface



waters.  Dividing the  annualized treatment  costs ($404,150)  by



these removals yields a cost per Ib-equivalent removed of $19 for



direct dischargers (lowest value across all eleven segments)  and



$46 for  indirect dischargers  (lowest  value across  all  eleven



segments).







Office Machine Rebuilding







The normal  plant  for  the  Office  Machine  Rebuilding  segment



discharges organic compounds  and metals. (See  Table X-47,  page



380.)  None of the organic compounds are specifically  controlled



or removed.  Three  of the  twelve metals present  in the  waste-



stream are  removed  by  chemical  precipitation  and  subsequent



clarification and filtration.  The 20 Ibs of non-conventional and
                                305

-------
                                         	n,1,1,1'i V if'ii'i' r,Hi '•:'!',,' i1 i ;' „ in i
toxic pollutants   removed  from  396,OOO  gallons  of  wastewater


include silver, zinc,  and  iron.  When their toxicities  relative


to copper,   the annual  removals  total 32  Ibs-equivalent.    For


indirect dischargers,  seven  Ibs-equivalent would  be removed  by


pretreatment; more than  three-quarters of the  pollutants in  an


indirect discharger's   effluent  (25 of  the  32  Ibs-equivalent)


would otherwise be removed by treatment at a POTW before  ultimate


discharge to surface waters.    Dividing the annualized treatment


costs ($24,75O) by these removals yields a cost per Ib-equivalent


removed of   $1,791   for  direct dischargers  (3rd  highest  value
                '  ,  ',	      '• 'i"  „ .... „ ;   .' "• '"'if "II'1"1/IT '4K!1  V " I ' "'' , '  v'lii'.'i i. t'". H f:: ,l1:l""l:,;i':-i'il,!!l!'i;

across all eleven segments)   and $8,061 for indirect   dischargers


(3rd highest value across all eleven segments).
                                 306
           i'1

-------
                  Table X-l


        NUMBER  OF FACILITIES FOR
MACHINERY  MANUFACTURING  & REBUILDING
                         Total Number of Facilities
                           Dun I Bradstreet 1989
Total Number of Facilities
 Dun & Bradstreet 1988
SIC Code
Specific Products
(10 or more employees)
(1 or more employees)
MOTOR VEHICLE - Motor Vehicle Manufacturing Engines & Trim
3592
3647
3694
3714
3751
3799

Carburetors, Piston Rings, Valves
Vehicular Lighting Equipment
Electrical Equipment for Motor Vehicles
Motor Vehicle Parts and Accessories
Motorcycles
Miscellaneous Transportation Equipment

176
97
470
3,244
- 202
364
4,553
262
145
790
3,497
565
779
6,038
MOTOR VEHICLE - Motor Vehicle Manufacturing Bodies
3465
3711
3716
3792

Automotive Stampings
Motor Vehicle and Automobile Bodies
Mobile Homes
Travel Trailers and Campers

580
748
18
372
1,718
744
1,434
07
87
1,010
3,275
MOTOR VEHICLE - Automobile Operations
4121
5013
5511
5521
5541
5561
5571
5599
7512
7519

Taxi cabs
Automotive Equipment
Automobile Dealers (New and Used)
Automobile Dealers (Used Only)
Gasoline Service Stations
Recreational & Utility Trailer Dealers
Motorcycle Dealers
Auto. Dealers (Dunebug., Gocart, Snowmble.)
Passenger Car Rental & Leasing, U/0 Driver
Utility Trailer & Rec. Vehicle Rental

848
19.861
24,135
3,349
21,148
1,999
2,413
654
4,734
432
79,573
4,115
41,369
38,137
30,678
102,440
5,269
6 ft .5
,742
3.231
12,487
1,534
246,002
MOTOR VEHICLE -Automobile Repair
7531
7535
7538
7539
7549
7692


Automobile Top and Body Repair
Automotive Paint Shops
General Automotive Repair Shops
Specialized Auto. Repair Shop & Insp. Ctrs.
Auto. Serv. (Includes Diagn. & Insp. Ctrs.)
Welding Shops (Includes Automotive)

MOTOR VEHICLE - TOTAL
6,821
835
11,611
7,905
2,132
1,448
30,752
116,596
41,956
37<1 
-------
                                     Table  X-l  (Continued)

                                  NUMBER OF FACILITIES  FOR
                        MACHINERY MANUFACTURING  & REBUILDING
  SIC Cod*
                        Specific Product*
 IOS t TRUCK -  Bus t Truck RebuiIding & Maintenance
    4111
    4119
    4131
    4141
    4142
    4151
    4171
    4172
    4212
    4213
    4214
    4231
    7513
  Local and Suburban Transit (Bus & Subway)
  Local Psngr. Trans. (Lira., Anfc., Sight See)
  Intercity and Rural Highway (Buslines)
  Local Bus Charter Service
  Bus Charter Service, Except Local
  School Buses
  Bus Terminal Oper. (Motor Vehicle Maint.)
  Haint. Fac. for Motor Vehicle Psngr. Trans.
  Local Trucking Without Storage
  Trucking.  Except Storage
  Local Trucking With Storage
  Freight Truck Terminals, W/ or W/0 Haint.
 Truck Rental  I Leasing,  Without Drivers
                                 BUS & TRUCK - TOTAL

 AIRCRAFT - Aircraft Frames Manufacturing

   3721    Aircraft

 AIRCRAFT - Aircraft Engines & Parts Manufacturing
   3724
   3728
 Aircraft Engines and Engine Parts
 Aircraft Parts and Auxiliary Equipment
AIRCRAFT • Aircraft Operations
   4511
   4521
 Certified Air Carriers (Psngr.  & Cargo)
 Noncertified Air  Carriers (Psngr. & Cargo)
AIRCRAFT • Aircraft Maintenance

   4582   Aircraft and Airport Maintenance

                                   AIRCRAFT - TOTAL

SPACE
   3761
   3764
   3769
Guided Missiles and Space Vehicles
Guided Missile and Space Vehicle Propulsion
Other Space Vehicle and Missile Parts

                           SPACE - TOTAL
                                             Total Number of Facilities
                                               Dun t Bradstreet  1989
                                               (10 or more employees)
   674
 2.659
   688
   333
   608
 1,189
   184
   109
14,609
19,467
 3,646
 2,109
 3,161

49,436

53,877
                                                     273
   487
 1,211

 1,698
 2,722
 1,161

 3,883
                                                   1,899

                                                   7,753
   98
   47
   47

  192
                     Total Number of Facilities
                       Dun & Bradstreet 1988
                        (1 or more employees)
  1,605
  6,973
  1,807
    145
  2,216
  2,163
    293
    139
 55,128
 47,835
  7,306
  1,566
  7,634

134,810

141,276
                                                                                559
   586
  1,639

  2,225
 7,698
   492

 8,190
                           6,175

                           17,149
   143
    75
    71

   289
                                                   308

-------
                            Table X-l  (Continued)

                          NUMBER OF FACILITIES  FOR
                  MACHINERY MANUFACTURING  & REBUILDING
SIC Code
Specific Products
                                           Total Number of Facilities
                                             Dun & Bradstreet 1989
                                             (10 or more employees)
                                               Total Number of Facilities
                                                Dun & Bradstreet 1988
                                                 (1 or more employees)
RAILROAD - Railroad Manufacturing
3743 Rai tears, Railway Systems
RAILROAD - Railroad Maintenance
4011 Line- Haul Railraods
4013 Switching and Terminal Stations

RAILROAD - TOTAL
SHIP - Ship Repair and Manufacturing
3731 Ship Building and Repairing
SHIP - Boat Repair and Manufacturing
3732 Boat Building and Repairing
SHIP - Ship Maintenance
4421 Transportation, Noncontiguous Deep Sea
4422 Coastwise Transportation
4423 Intercoastal Transportation
4431 Great Lakes Transportation
4441 Transportation on Rivers & Canals

SHIP - Boat Maintenance
4452 Ferries
4453 Lighterage
4454 Towing and Tugboat Services
4459 Water Transportation, Local, NEC

SHIP - TOTAL
OFFICE MACHINE - Office Machine Manufacturing
3572 Typewriters
3573 Electronic Computing Equipment
3574 Calculating and Accounting Machines
3579 Office Machines, Not Elsewhere
3861 Photographic Equipment and Supplies

OFFICE MACHINE • Office Machine Maintenance
7379 Computer Related Services
7629 Electrical & Electronic Repair

OFFICE MACHINE - TOTAL

205

1,534
340
1,874
2,079

560

1,126

81
87
35
26
411
640

55
16
531
173
775
3,101

28
3,606
128
342
902
5,006

6,121
3.237
9,358
14,364

283

2,801
316
3,117
3,400

897

3,179

143
165
57
41
484
890

68
35
1,100
528
1,731
6,697

60
5,245
165
555
1,804
7,829

14,279
17,928
32,207
40,036
                                          309

-------
                                   Table X-l  (Continued)


                                NUMBER  OF  FACILITIES  FOR
                      MACHINERY  MANUFACTURING  &  REBUILDING
 SIC Cod*
                       Specific Products
                                           Total Nutter of  Facilities   Total Nuifcer of Facilities
                                             Dun & Bradstreet: 1989       Dun & Bradstreet 1988
                                             (10 or wore employees)       (1 or more enployees)
HARDWARE
3396
3421
3423
3425
3429

HARDWARE
3451
3452

HARDWARE
3412
3462
3466
3469

HARDWARE
3493
3495
3496
3964
- Hand Tools
Metal Heat Treating
Cutlery
Hand I Edge Tools, Except Hach. Tools, Saws
Hand Saws and Saw Blades
Hardware NEC

- Screw Machine Products
Screw Machine Products
Bolts, Nuts, Screws, Rivets, and Washers

- Metal Forging & Stamping Products
Metal Shipping Barrels, Drums, Kegs, Pails
Iron and Steel Forgings
Crowns and Closures
Metal Stamping NEC

- Metal Spring Products
Steel Springs
Wire Springs
Miscellaneous Fabricated Wire Products
Needles, Pins, and Fasteners

567
121
606
118
1,229
2,641

1,350
757
2,107

162
473
46
2,607
3,288

238
249
1,122
262

751
258
1,222
195
., 	 2,116 	 _
4,542

1,968
1,074
," ,' " 	 ' ''".'3,042"

209
646
e*s
DU
3,585
4,490

346
344
1,679
415
HARDWARE - Metal Pipes & Valves

   3494   Valves t pipe Fittings, Except Brass
   3498   Fabricated Pipe and Fabricated Pipe Fittings
   3499   Fabricated Metal Products NEC
HARDWARE - Machine Tools
   3541
   3542
   3544
   3545
   3546
Machine Tools, Metal Cutting Types
Machine Tools, Metal Forming Types
Special Dies I Tools, Die Sets, Jigs,  Etc.
Machine Tool Access. £ Measuring Devices
Power Driyen Hand Tools
                                                           1,871
                                                 1,142
                                                   556
                                                 1,685
                                                  -	'•• in
                                                 3.383
1,215
  580
4,769
1,911
  235

8,710
                                                                            2,784
                           1,558
                            820
                           3,324

                           5,702
 2,123
   881
 8,923
 2,994
   452

15,373
                                                310

-------
                                   Table  X-l  (Continued)

                                NUMBER OF  FACILITIES  FOR
                      MACHINERY  MANUFACTURING  &  REBUILDING
SIC Cod*
            Specific Products
Total  Number of Facilities
  Dun  & BradstrMt 1989
  (10  or wore employees)
Total  Number of Facilities
  Dun  & Bradstreet 1988
   (1  or more employees)
HARDWARE - Heating Equipment

   3433   H«atg. Equip.  Except Elec. & Warm Air Frnc.

          Fabricated Structural Metal Products
HARDWARE -

   3441
   3443
   3444
   3446
   3448
   3449
Fabricated Structural Metal
Fabricated Plate Work (Boiler Shops)
Sheet Metal Work
Architectural and Ornamental Metal Work
Prefabricated Metal Buildings & Components
Miscellaneous Metal Work
                                   HARDWARE -  TOTAL
                                                     515
        2,894
        1,832
        3,352
        1,162
          640
          231

       10,111

       32,626
                                   1,176
        4,161
        2,503
        5,006
        3,655
        1,055
          416

       16,796

       53,905
ORDNANCE

   3482
   3483
   3484
   3489
Small Arms Ammunition
Ammunition, except for Small  Arms
Small Arms
Ordnance and Accessories NEC
                                   ORDNANCE - TOTAL
 STATIONARY INDUSTRIAL EQUIPMENT - Heavy Equipment Manufacturing

   3511    Steam,  Gas, Hydraul. Turbines, Gen. Units
   3519    Internal Combustion Engines NEC
   3531    Construction Machinery and Equipment
   3533    Oil Field Machinery and Equipment
   3534    Elevators and Moving Stairways
   3535    Conveyors and Conveying Equipment
           65
           85
          150
           71

          371
                                                     207
                                                     270
                                                   1.023
                                                     901
                                                     224
                                                     804

                                                   3,429
          201
          118
          308
          122

          749
                                     400
                                     524
                                    1,636
                                    1,636
                                     318
                                    1,005

                                    5,519
                                                     311

-------
                                     Table X-l  (Continued)

                                  NUMBER  OF  FACILITIES  FOR
                        MACHINERY  MANUFACTURING  &  REBUILDING
  SIC Cod*
                         Specific Products
                                             Total Hunter of Facilities
                                               Dun t Bradstreet 1989
                                               (10 or more employees)
                      Total Number of Facilities
                        Dun & Bradstreet 1988
                         (1 or more employees)
 STATIONARY  INDUSTRIAL EQUIPMENT  -  Industrial Machine & Equipment Manufacturing
    3547
    3549
    3551
    3552
    3553
    3554
    3555
    3559
    3561
    3562
    3563
    3564
    3565
    3566
    3567
    3568
    3569
    3576
    3581
    3582
    3585
    3586
    3589
    3599
 Rolling Mill Machinery and Equipment
 Metal Working Machinery NEC
 Food Products Machinery
 Textile Machinery
 Woodworking Machinery
 Paper Industries Machinery
 Printing Trades Machinery and Equipment
 Special Industry Machinery NEC
 Pumps and Pumping Equipment
 Ball and Roller Bearings
 Air and Gas Compressors
 Blowers and Exhaust and Ventilation Fans
 Industrial Patterns
 Speed Changers,  High Speed Drivers & Gears
 Industrial Process Furnaces and Ovens
Mechanical Power Transmission Equip.  NEC
General Industrial Machinery NEC
Scales and Balances, Except Laboratory
Automatic Merchandising Machines
Commercial Laundry Equipment
Refrigeration I  Mr and Heating Equip.
Measuring and Dispensing Punps
Service Industry Machines,  NEC
Machinery,  Except  Electrical  NEC
    90
   529
   902
   485
   281
   307
   696
 1,792
   670
   224
   323
   644
   302
   246
   504
   216
 1,824
   140
   127
    89
 1,094
    68
 1,090
13,814
                                                             26,457

STATIONARY INDUSTRIAL EQUIPMENT -  Electrical Equipment Manufacturing
   3612    Transformers
   3613    Switchgear and Switchboard Apparatus
   3621    Motors and Generators
   3622    Industrial Controls
   3623    Welding Apparatus,  Electric
   3629    Electric Industrial -Apparatus NEC
                                                     825
                                                     814
                                                     932
                                                     124
                                                     365
                                                              3,548

STATIONARY  INDUSTRIAL EQUIPMENT - Equipment Rebuilding & Maintenance

   7394     Equipment Rental  I Leasing Services                 16,906

             STATIONARY INDUSTRIAL EQUIPMENT - TOTAL           50,340
  125
  718

 '794
  458
  405
1,058
2,827
1,062
  882
  996
  319

  258
2,876
  220
  202
  177
1,617
  125
1,581
                           51,883



                              643
                            1,109


                             '247
                              459

                            4,791



                           42,172

                          104,365
                                                   312
                                                                                                        '„ '• I1"'1' I'M :'," ,4'I'1

-------
                             Table X-l  (Continued)

                          NUMBER OF FACILITIES FOR
                  MACHINERY MANUFACTURING  & REBUILDING
SIC Code
Specific Products
Total Number of Facilities
 Dun I Bradstreet 1989
 (10 or more employees)
Total Number of Facilities
 Dun & Bradstreet 1988
  (1 or more employees) •
MOBILE INDUSTRIAL EQUIPMENT - Industrial Equipment Manufacturing
3523 Farm Machinery and Equipment
3524 Garden Tractors & Lawn & Garden Equipment

MOBILE INDUSTRIAL EQUIPMENT - Heavy Equipment Manufacturing
3532 Mining Mach. & Equip., Except Oil Field
3536 Hoists, Industrial Cranes & Monorails
3537 Industrial Trucks, Tractors, Trailers
3795 Tanks and Tank Components

MOBILE INDUSTRIAL EQUIPMENT - TOTAL
HOUSEHOLD EQUIPMENT - Residential Equipment Manufacturing
3631 Household Cooking Equipment
3632 Household Refrig. & Home & Farm & Freezers
3633 Household Laundry Equipment
3634 Electric Houseuares and Fans
3635 Household Vacuum Cleaners
3636 Sewing Machines
3639 Household Appliances NEC

HOUSEHOLD EQUIPMENT - Household Electric Equipment Manufacturing
3641 Electric Lamps
3643 Current-Carrying Wiring Devices
3644 Noncurrent -Carrying Wiring Devices
3645 Residential Electrical Lighting Fixtures
3646 Commercial, Industrial, and Institutional
3648 Lighting Equipment NEC
3651 Radio/Television Sets Except Coramun. Types

HOUSEHOLD EQUIPMENT - Household Equipment Maintenance
7622 Radio & Television Repair Shops
7623 Refrig. & Air Cond. Serv. & Repair Shops

HOUSEHOLD EQUIPMENT - TOTAL

1,440
203
1,643

356
299
499
45
1,199
2,842

82
53
24
303
118
85
74
739

216
568
236
595
336
322
649
2,922

2,452
1,386
3,838
7,499

2,770
294
•.
3,064

567
431
778
78
1,854
4,918

173
152
45
452
285
164
208
1,479

445
740
289
1,012
467
418
1,121
4,492

22,758
9,817
32,575
38,546
                                         313

-------
                                     Table  X-l  (Continued)
                                   ;  ,.     .   ;    ''  :                	    Ill

                                  NTJMBER OF  FACILITIES  FOR
                        MACHINERY MANUFACTURING  &  REBUILDING
 SIC Code
                        Specific Products
                                  Total Number of Facilities   Total  Number of Facilities
                                    Dun & Bradstreet 1989        Dun  i, Bradstreet 1988
                                    (10 or more employees)        (1  or more employees)
 ELECTRONIC EQUIPMENT •
                   "" /

    3662    Radio t TV

 ELECTRONIC EQUIPMENT •

    3675    Electronic
    3677    Electronic
    3678    Connectors
    3679    Electronic
    3699    Electronic
•  Communication Equipment Manufacturing

Communication Equipment

•  Electronic Components Manufacturing

Capacitors
Coils and Transformers
for Electronic Applications
Components NEC
Hach., Equipment,  S Suppl. NEC
                         ELECTRONIC EQUIPMENT - TOTAL

 INSTRUMENTS  - Measurement & Control Instrument Manufacturing

    3479   Coating, Engraving and Allied Services NEC
    3811   Engineering and Scientific Instruments
    3822   Automatic Environmental Controls
    3823   Process Control Instruments
    3824   Fluid Meters and Counting Devices
    3825   Instruments to Measure Electricity
    3829   Measuring and Controlling Devices NEC
 INSTRUMENTS - Specialty Equipment Manufacturing

   3832    Optical Instruments and Lenses
   3841    Surgical t Medical Instruments & Apparatus
   3842    Orthopedic, Prosthetic, t Surgical Suppl.
   3843    Dental Equipment and Supplies
   3851    Ophthalmic Goods
   3873    Watches, Clocks, Assoc. Devices t Parts
   3951    Pens, Mechanical Pencils, & Parts
   3999    Manufacturing Industries NEC
INSTRUMENTS -  Specialty Instrunent Maintenance

   7699    Miscellaneous Repair Shops & Related Serv.

                                 INSTRUMENTS - TOTAL

PRECIOUS & NONPRECIOUS METALS t INSTRUMENTS

   3911    Jewelry, Precious Metel
   3914    Silverware, Plated Ware,  t, Stainless
   3915    Jewelers' Materials t Lapidary Work
   3931    Musical Instruments
   3961    Costume Jewelry

   PRECIOUS t NONPRECIOUS HETALS t INSTRUMENTS - TOTAL
MMtt TOTALS
                                                               2,992
                                                                 123
                                                                 348
                                                                 138
                                                               4,715
                                                                 637

                                                               5,823

                                                               8,815
                                         1,508
                                         1,044
                                           522
                                         1,503
                                           228
                                         1,119
                                           895

                                         6,819
                                           527
                                         1,459
                                         1.518
                                           434
                                           823
                                           207
                                           115
                                         2,892

                                         7,975
                                                              10,531

                                                              25,325
                                                               1,661
                                                                221
                                                                299
                                                                297
                                                                630

                                                              3,108
                                                            328,888
                                                              , ' '(' '( V '
                                                                          "I, ''
 5,001
   147
   423
   157
 6,103
 1,066

 7,896

12,897
                                                                                          2,592
                                                                                          1,635
                                                                                            794
                                                                                          2,379
                                                                                            325
                                                                                          1,557
                                                                                          1,251

                                                                                          10,533
                                                                                            914
                                                                                          1,958
                                                                                          2,576
                                                                                          1,148
                                                                                          1,642
                                                                                            492
                                                                                            169
                                                                                         10,159

                                                                                         19,058
                                                                    62,884

                                                                    92,475



                                                                     4,624
                                                                      520
                                                                      776
                                                                      779
                                                                     1,746

                                                                     8,445



                                                                  969,710
                                                    314

-------
                                                    Table  X-2

                       TRANSPORTATION  EQUIPMENT   MANUFACTURING:
                                              Motor  Vehicles
SIC Code & Description
3592
Carburetors, Pistons,
     1977
     1982

3694
Engine Electrical Equipment
     1972
     1977
     1982

3711
Motor Vehicles & Car Bodies
     1972
     1977
     1982

3713
Truck & Bus Bodies
     1972
     1977
     1982

3714
Motor Vehicle Parts, Accessories
     1972
     1977
     1982

3715
Truck Trailers
     1972
     1977
     1982

3751
Motorcycles, Bicycles,  Parts
     1972
     1977
     1982

3792
Travel Trailers & Campers
     1972
     1977
     1982

3795
Tank & Tank Components
     1972
     1977
     1982

3799
Transportation Equipment
     1972
     1977
     1982
 « of
Est'b
                                      113.0
                                      151.0
                                      171.0
                                      290.0
                                      409.0
                                      433.0
                                      231.0
                                      322.0
                                      355.0
                                      789.0
                                      820.0
                                      681.0
                                     2,119.0
                                     2,623.0
                                     2,420.0
                                      255.0
                                      353.0
                                      324.0
                                      222.0
                                      350.0
                                      273.0
                                     1,030.0
                                       861.0
                                       492.0
                                        22.0
                                        24.0
                                        43.0
                                       501.0
                                       429.0
                                       424.0
Employees
<1000's>
             26.6
             32.2
             31.1
             57.9
             63.8
             42.9
            339.2
            343.6
            240.1
             42.8
             34.8
             28.5
            400.9
            450.7
            321.4
             24.7
             28.1
             18.5
             17.6
             15.6
             13.0
             37.1
             26.3
             13.8
              5.9
              12.4
              18.1
              16.1
              10.3
              10.7
Production
Worker*
                 21.6
                 26.0
                 24.0
                 47.7
                 51.8
                 32.3
                287.0
                289.9
                193.5
                 33.3
                 27.4
                 21.5
                332.3
                372.5
                251.1
                 19.7
                 22.5
                 13.6
                 15.0
                 13.3
                 10.4
                 31.1
                 21.8
                 11.2
                  4.6
                 10.0
                 12.5
                 13.4
                  7.4
                  7.4
Value of
Shipments
                1,994.7
                2,297.0
                2,369.1
                5,453.8
                5,981.4
                3,689.5
              114,987.0
              125,489.2
               75,337.8
                4.204.9
                3,285.4
                2,674.1
               49,133.8
               58,631.3
               38,652.2
                2,996.0
                3,132.6
                1,888.6
                1,767.5
                1,652.5
                1,428.3
                3,597.1
                2,595.1
                1,364.1
                  729.5
                1,532.1
                2,496.0
                1.754.3
                1,018.3
                  943.8
Capital
Expenditures
                     72.6
                    131.0
                    112.9
                     82.5
                    239.4
                     83.5
                  2,458.1
                  2,798.0
                  2,522.2
                    130.0
                     72.5
                     55.1
                  2,983.1
                  3,006.4
                  1,908.2
                     39.1
                     59.4
                     39.7
                     42.9
                     39.5
                     24.6
                     94.3
                     50.8
                     18.0
                      8.3
                     21.6
                    121.9
                     44.6
                     16.1
                     15.8
                                                                                                      Specialzt'n  Coverage
                                                                                                      Ratio       Ratio
                   81.0
                   82.0
                   81.0
                   79.0
                   81.0
                   85.0
                   96.0
                   95.0
                   95.0
                   90.0
                   94.0
                   93.0
                   94.0
                   94:0
                   93.0
                   96.0
                   94.0
                   95.0
                   81.0
                   84.0
                   85.0
                     NA
                     NA
                     NA
                   95.0
                   92.0
                     NO
                   93.0
                   94.0
                   93.0
                                                                                                                      74.0
                                                                                                                      87.0
                                                                                                                      94.0
                                                                                                                      87.0
                                                                                                                      89.0
                                                                                                                      88.0
                                                                                                                      99.0
                                                                                                                      99.0
                                                                                                                      99.0
                                                                                                                      91.0
                                                                                                                      93.0
                                                                                                                      94.0
                                                                                                                      86.0
                                                                                                                      87.0
                                                                                                                      86.0
                                                                                                                      94.0
                                                                                                                      96.0
                                                                                                                      95.0
                                                                                                                      95.0
                                                                                                                      97.0
                                                                                                                      96.0
                                                                                                                        NA
                                                                                                                        NA
                                                                                                                        NA
                                                                                                                      77.0
                                                                                                                      82.0
                                                                                                                      79.0
                                                                                                                      74.0
                                                                                                                      79.0
                                                                                                                      82.0
Notes:

Specialization ratio=Receipts from primary product shipments/total receipts  for primary and secondary products for establishments
  in this SIC code.
Coverage ratio=Receipts from primary products shipped by establishments in this SIC/total  receipts from such products by all
  manufacturing establishments.

Source:  U.S. Bureau of the Census, Censu* of Manufactures,
         1972, 1977, 1982.
                                                          315

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                               Table X-3

             BEFORE  TAX PROFITS AS A PERCENT OF SALES;
                     MOTOR VEHICLE MANUFACTURING
                                            	'I'M i i	i
Industry

SIC 3711
Motor Vehicle
 Manufacturers

SIC 3713
Truck and Bus
 Bodies

SIC 3714
Motor Vehicle
 Parts & Acces~
 sories

SIC 3792
Travel Trailers
 & Campers
1972    1977    1982     1983     1984     1985    1986
 4.2     7.1     1.9      0.1     4.1     3.8     3.9
 n/a     7.0      n/a    -1.1     0.2     4.4     4.3
  5.5     6.9     4-4     2.7     3.9     6.0     4.8
  5.8    -0.1     2.3     2.2     5.6     3.9
                                                                      "li'ill'l "i:1 '	i
 Source:  Robert Morris Associates,  1986 Annual Studies.
                                  316

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                          Table  X-4

         RETAIL  TRADE  ~  TRANSPORTATION:
                     Motor Vehicles
 SIC Code & Description         # of
                              Estbs.

 5511
 Motor Vehicle Dealers  --
 New & Used
     1972                      32,452
     1977                      30,793
     1982                      27,178

 5521
 Motor Vehicle Dealers  --
 Used Cars
     1972                      31,785
     1977                      37,016
     1982                      34,556

 5541
 Gasoline Service Stations
     1972                     226,459
     1977                     176,465
     1982                     135,514

 5561
 Recreational  & Utility
 Trailers
     1972                       2,251
     1977                       5,232
     1982                       3,518

 5571
 Motorcycle Dealers
     1972                       3,416
     1977                       4,901
     1982                       4,617

 5599
Automotive Dealers, n.e.c.
     1972                     1,662.0
     1977                     1,104.0
     1982                       546.0

7512
Automotive Rental & Leasing,
without drivers
     1972                    10,474.0
     1977                     9,387.0
     1982                     9,024.0

7531
Top & Body Repair Shops
     1972                     31,810
     1977                     38,848
     1982                     23,871

7535
Paint Shops
     1972                       2,463
     1977                       2,777
     1982                       2,829
   SALES
 (1000 88$)
 187,671,593
 215,733,376
 181,803,633
  11,581,345
  12,292,965
   9,643.629
  86,157,768
  99,948,615
 114,492,301
   2,988,262
   5,121,624
   3,325,879
   3,020,559
   3,503,979
   3,380,072
 1,266,690.6
   956,899.2
   616,543.7
 9,110,592.0
11,340,452.0
11,329,083.3
   4,547,758
   5,745,393
   5,779,443
     594,854
     772,182
     815,741
  Paid
Employees
 765,606
 790,381
 698,569
  39,445
  42,281
  36,103
 747,668
 672,673
 603,886
  11,579
  20,203
  16,168
  20,178
  24,424
  27,314
 7.268.0
 6,260.0
 4,554.0
62,687.0
75,480.0
94,195.0
  65,659
  87,919
 103,390
  11,470
  15,810
  18,488
                                317

-------
                                                        !'"'	I1"!:'1'1!, 1, i"" 'i	;,l,l	"'.rfii	In, ii'1
                                                                            «,!„{] iii !i''!"n	sracrin,^^
                   Table X-4 (Continued)

             RETAIL  TRADE  ~ TRANSPORTATION:
                       Motor Vehicles
 SIC Codt t Description
 # of
Estbe.
  SALES
(1000 88$)
  Paid
Employee*
753«
General  Automotive Repairs
1972
1977
1982
7539
Automotive Parts & Repairs
1972
1977
1982
7692
Welding Shops
1972
1977
1982
71,863
86,991
40,392


12,034
16,315
19,504


4,313
NA
4,978
8,129,672
9,970,998
8,304,634


3,250,348
4,582,857
5,037,805


940,296
NA
1,142,556
98,235
128,339
144,054


46,850
68,504
84,126


15,857
NA
24,488
Source:  U.S. Bureau of the Census, Census of Retail Trade
         and County Business Patterns, 1972, 1977, 1982.
                                  318

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                               Table  X-5

              BEFORE TAX  PROFITS AS  A PERCENT OF SALES:
                      MOTOR VEHICLE RETAIL TRADE
industry          1972

SIC 5511
New Car Dealers    1.9

SIC 5521
Used Car Dealers   1.9

SIC 5541
Gasoline Service
 Stations          2.8

SIC 5561
Recreational &
 Utility Dealers   n/a

SIC 5571
Motorcycle Dealers  n/a

SIC 7512 & 7513
Car & Truck Rental  5.2
SIC 7531
Auto Top &
 Body Repair

SIC 7538
General Auto
 Repair

SIC 7692
Welding Shops
n/a
3.9
n/a
      1977     1982


       1.8      0.9


       2.4      2.5
                                           1983     1984     1985     1986
       1.5
       0.9
2.7    2.1


0.7    1.2


6.1    5.6



n/a    n/a



4.3    4.7


n/a    n/a
                1.0     1.9
                2.2
                        0.9
                        1.2
                       2.2     2.6
                       -0.3      0.3
                        7.0     6.4
n/a     3.5
                        3.8     3.8
                       -0.4     4.9
                2.1      1.8
        2.4      2.8      1.6
                                        1.5     1.4
                                1.8
                       1.1
                2.0     1.2
                 6.0    5.0
                                         4.7     3.8
                 4.6    3.6
                 5.3    5.6
 Source:  Robert Morris Associates,  1986  Annual  Studies.
  1n/a= not available
                                  319

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                                                                           v, U
                     ••     Table  X-e"    '.     ' 1'

          RETAIL  TRADE —  TRANSPORTATION:
                      Motor  Vehicles
 SIC Cod* t Description         # of          SALES
                :              Estb*.        (1000 8810

 5511
 Motor Vehicle Dealers --
 New & Used
     1972                      32,452       187,671,593
     1977                      30,793       215,733,376
     1982                      27,178       181,803,633

 5521
 Motor Vehicle Dealers --
 Used Cars
     1972                      31,785       11,581,345
     1977                      37,016       12,292,965
     1982                      34,556        9,643,629

 5541
 Gasoline Service Stations
     1972                     226,459       86,157,768
     1977                     176,465       99,948,615
     1982                     135,514       114,492,301

 5561
 Recreational & Utility
 Trailers
     1972                       2,251        2,988,262
     1977                       5,232        5,121,624
     1982                       3,518        3,325,879

 5571
 Motorcycle Dealers
     1972                       3,416        3,020,559
     1977                       4,901        3,503,979
     1982                       4,617        3,380,072

 5599
 Automotive Dealers, n.e.c.
     1972                     1,662.0       1,266,690.6
     1977                     1,104.0        956,899.2
     1982                       546.0        616,543.7

 7512
Automotive Rental & Leasing,
 without drivers
     1972                    10,474.0      9,110,592.0
     1977                     9,387.0     11,340,452.0
     1982                     9,024.0     11,329,083.3

7531
Top & Body Repair Shops
     1972                     31,810        4,547,7158
     1977                     38,848        5,745,393
     1982                     23,871         5,779,443

7535
Paint Shops
     1972                       2,463          594,8154
     1977                       2,777          772,1«2
     1982                       2,829          815,741
   Paid
 Employees
 765,606
 790,381
 698,569
  39,445
  42,281
  36,103
 747,668
 672,673
 603,886
  11,579
  20,203
  16,168
  20,178
  24,424
  27,314
 7,268.0
 6,260.0
 4,554.0
62,687.0
75,480.0
94,195.0
  65,659
  87,919
 103,390
  11,470
  15,810
  18,488
                                320

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                  Table X-6 (Continued)

            RETAIL  TRADE  ~  TRANSPORTATION:
                      Motor Vehicles
  SIC Code & Description
 * of
Estbe.
  SALES
(1000 88$)
  Paid
Employees
7538
General Automotive Repairs
     1972                     71,863
     1977                     86,991
     1982                     40,392

7539
Automotive Parts & Repairs
     1972                     12,034
     1977                     16,315
     1982                     19,504

7692
Welding Shops
     1972                      4,313
     1977                         NA
     1982                      4,978
             8,129,672
             9,970,998
             8,304,634
             3,250,348
             4,582,857
             5,037,805
               940,296
               NA
             1,142,556
               98,235
              128,339
              144,054
               46,850
               68,504
               84,126
               15,857
                   NA
               24,488
Source:  U.S. Bureau of  the Census,  Census of Retail  Trade
         and County Business Patterns,  1972, 1977,. 1982.
                              321

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                                                            !'	HIV"	 I"!'- i>hi •.	,* "..i
                               Table  X-7

             BEFORE TAX PROFITS AS  A PERCENT  OF SALES:
                           BUSES  AND TRUCKS
Industry

SIC 4131
Intercity &
 Rural Buses

SIC 4151
School Buses
1972    1977    1982     1983    1984
 4.1
 n/a1    n/a
SIC 4212
Local Trucking
 Without Storage  7.3
SIC 4213
Long Distance
 Trucking
5.8     4.5
SIC 4214
Local Trucking
 With Storage     3.7
                                   4.5


                                  7.6
                          4.8     4.2
                                  3.3
         1.6      4.3
                         5.0     4.2     3.8
                       1 t" "iii'f1 ' !J1 i " ' '''"l ,jk",' i "I,	l!IUl,' '• H!» j ,"i   „'  !'


                         6.5      5.8      5.2
                          3.0     3.9     4.4
                          1.8     2.6     3.7
                                           2.1     3.7     5.4
                                                 1986
                                                                   6.1
                                                                    3.7
                                                                    2.7
                                                  4.5
                                                                       • .......  . ....... :
Source: Robert Morris Associates,  1986 Annual Studies.
1n/a=not available
                                  322

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                             Table X-8

          MOTOR VEHICLE  SEGMENTS AND  IN-SCOPE SIC  CODES1
Segment

Automobile Rebuilding
 and Maintenance
 SIC Codes Covered

 4121 Taxicabs                       -,,
"5511 Automobile Dealers  (new and used)
 5521 Automobile Dealers (used only)
*5541 Gasoline Service Stations
 5599 Automobile Dealers (dunebuggies,
      gocarts, snowmobiles)
*7512 Passenger  Car Rental and Leasing,
      without drivers
 3711 Motor Vehicle and Automobile Bodies
 7531 Automobile Top and Body Shops
*7535 Automobile Paint Shops
*7538 General Automobile Repair  Shops
*7549 Automotive Services (inc.
      diagnostic and inspection centers)
 5571 Motorcycle Dealers
 3751 Motorcycle Manufacturing
Automobile, Bus & Truck
 Parts Rebuilding
*3592 Carburetors
 3694 Electrial Equipment for Motor
      Vehicles
*7539 Automotive Parts Repair
 7692 Welding Shops  (inc. Automotive)
Bus and Truck Rebuilding
 and  Bus  and Truck Repair
 & Maintenance
 3713 Truck and Bus Bodies
 3714 Motor Vehicle Parts & Accessories
 3715 Truck Trailers
 3792 Travel Trailers and Campers
 3795 Tanks and Tank Components
 3799 Miscellaneous Transportation
      Equipment
 *4111 Local and Suburban Transit
       (bus and Subway)
 4119 Local Passenger Transportation
       (limousine,  ambulance,sightseeing)
 *4131 Intercity and Rural Buses
 *4141 Local Bus Charter
 4142 Bus Charter,  except  local
 *4151 School Buses
 4171 Bus Terminal Operations
        1Four-digit SIC codes included in the analysis of each segment
   are denoted by "*".
                                 323

-------
                                        li
                                         '(I	"I.
                        Table ?C-8  (Continued)

           MOTOR VEHICLE SEGMENTS  AND IN-SCOPE  SIC CODES
Segment.

Bus and Truck Rebuilding
 and Repair and
 Maintenance (cont'd)
  SIC Codes Cover-aid

 4172 Maintenance Facilities for Motor
.     Vehicle Passenger Transportation
^4212  Local Trucking,  without storage
^4213  Trucking,  execpt local
 4214  Local Trucking,  with storage
 4231 Freight Trucking Terminals
 5561 Recreational and Utility Trailer
  /,  ,„ Dealers    r	
 7513 Truck and Leasing, without drivers
 7519 Utility Trailer and Recreational
      Vehicle Rental
Radiator Rebuilding
 7539  (part) Automotive Services
                                324
                                                                    	',;!!	511 Ir/SI	',:.

-------
                               Table X-9
               AUTOMOBILE REBUILDING AND MAINTENANCE:
             ESTABLISHMENT, REVENUES,  AND PROFITS, 1984
                      (millions of  1988 dollars)
Type of Establishment
Service Stations
Independent Repair
  Shops
New Car and Truck
  Dealers (Repair
  & Service Only)
Self Service Fleet
TOTAL
Number of
Establ ishments
115,000
150,000
25,000
39,000
329,000
Number
of Bavs
295,000
679,000
294,000
612,000
1,880,000
Revenue
22,587.5
48,321.2
18,581.6
43, 030. 63
132,520.9
Profits2
271.1
1,836.2
353.1
2,754.0
5,214.4
    source:  1984  Job  se^/ice Analysis. Hunter Publishing Company,  Des  Plains,
    IL.,  unless otherwise  indicated.
         Reported  in millions of May 1988 dollars based on-the
    Consumer Price Index for Automobile Maintenance and Repair.
         2T?«+-Tmated usinct  1984 profit-to-sales ratios from RMA.
     (See TableTx-5 )  ^most clses,  these correspond to the median over the
     1982 to 1986 period.
         Estimated based  on (unweighted)  average revenue per service bay for
     the first three establishment types.
                                       325

-------
                                       Table X-10
                    AUTOMOBILE  REBUILDING AND MAINTENANCE:
                     ESTIMATED  TREATMENT  COSTS  AND IMPACTS
                            (millions  of  1988  dollars)
Type of Establishment
 Service Stations
 Independent Repair Shops
 Hew Car t Truck Dealers
 Self Service Fleet
 TOTAt
Capital Cost
159.1
366.2
158.6
330.1
1,014.0
Annual Cost
258.9
595.9
258.0
537.1
1,650.0
Annualized
Cost
285.2
656.3
284.3
591.6
1,817.3
Annualized Cost
as X of Revenues
, t|iii| 	 ,,, 	 ,,,,1?r3,|ir,,|(,,i 	 ,
1.4
,1-5 	
1.4
1.4
Annualizi
as X of I
105-2
35.7
, 80.5
21.5
34.9
  Motes;
    All iwpact estimates assume zero cost pass through.
    Revenues estimated based on the 1984 Job Service Analysis.  (See Table X-9.)
                  1984 profit-to-sales ratios from RMA,  applied to the revenue estimates.
        Table X-9.
                                    facUlty type based m the nu*er of ^V3 as reported in the
,C«!*
useful
     fn9 8 Capital recovery factor
of 10 years.
                                                          on an interest rate of 10.34% and
                                            326

-------
                               Table X-ll

           REVENUES AND  PROFITS FOR AUTOMOBILE,  TRUCK,  AND
                          BUS PARTS  REBUILDING1
                       (millions of 1988 dollars)
SIC

37143



3592171

7538(part)4


7539(part)
Rebuilt Parts for Motor
 Vehicles, except carbu-
 retors and engines

Carburetors,  rebuilt

 Transmission Rebuilding
 & Repair

Diesel Repair Shops
Revenues




 1,443.4

    43.9


     1.5

     .1.6
Profits5




 63.1

   1.7


   0.06

   0.06
TOTAL3
                                 1,489.0
                                                                64.9
     Reported in millions of May 1988 dollars based on the
Consumer Price Index for Automobile Maintenance and Repair.

     Revenues are based on the 1982 Census of Manufactures and
the 1982 Census of Service Industries, scaled to reflect
1984 volumes.  A detailed explanation of the derivation of
these  figures is presented in Footnote  36  , page 218.

     'profits are estimated using the median profit-to-sales
ratios over  the 1982 to 1986 period for the appropriate
four-digit SIC code.   (See Tables X-3 and  X-5.)  RMA does
not compile  data  for SIC  3592 -  Carburetors, Pistons, Valves
and Rings;   for SIC 3592171  (carburetors,  rebuilt),  the
median profit-to-sales ratio over the 1982 to  1986 period
from RMA  for SIC  3599  - Machine  Shops, Jobbing and Repair  -
was used.

     4Only part of the four-digit SIC code is included in the
figures.

     5Totals may not add due to  rounding.
                                  327

-------
                                                                                	;	""jirjliii1 i, 'is11	g1;;:: inir1.
                           Table X-12


       ANNUALIZED TREATMENT  COST  ESTIMATES  FOR
     BUS AND TRUCK  REBUILDING  AND  MAINTENANCE
 Bus and Truck Rebuilding
                                 Total Segment
                                 Treatment Costs
                                 (millions of 88$)
Average Treatment
Cost per Vehicle
     (88$)



Bus

!,
Capital
Annual
Annual ized
1 .I,1 r " "i ,
and Truck Maintenance
Capital
Annual
Annual ized
Bus and Truck Rebuilding
and Maintenance
Capital


Annual
Annual ized
2,960
1,420
1,908
288
-•l210 . ." v i %." :•
258
, .:• ' ' ! ''HI „„ l! i,ii „' 'li'iiiil. ill'i"', . •
3,248
1,630
2,166
72
35
47
7
5
6
79
40
53
                                                                           ";	'" i;:'"i'- ',,:",, iJl -, if1;
                                                                            11 , niiii' If!, "IP	,i S'liuWI i, Mil, i
                                                                                       'f1;;'	(!"
Notes:
  Annualized costs calculated using a capital recovery factor, assuming
  an  interest rate of 10.34% and a useful like of 10 years.    a'su"lna

  Average treatment cost per vehicle estimated by dividing segment level
  treatment costs by the total number of buses and trucks registered
  in  i906.
                                328
                                                                                   in'':::'!, it '

-------








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ations. They were estimated
istics. Annual Report,
C. V
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-------
                             Table X-14

                 TRUCKS:  1986 REVENUES AND PROFITS
                     (millions of 1988 dollars)
 Type of Truck Operation

   ICC Regulated
    1 • •  •       "• i . . "l1:1    '".: i
   Non-ICG Regulated

   Local

   TOTAL
Revenues

 65,542

 83,486

 93,954

242,982
•'	i*
   Profits2

    1,770
    2,254
    3,852

    7,876
1Source: National Transportation Statistics; Annual Report  1986.
U.S. Department of Transportation, DOT-TSC-RSPA-86-3.
       i  •     „ ;:  ;•   „   i,. '" : ,,,,1.  " ij||» , ,«"! • , '  ' «   ill;, „ ,,„ : , ••' „ "'" " , i. 1	,r ,il < "' ',111,'H 	i,:,.	, ",,i •: ' i	 '",i',,,,i,'i " «.i, ' •, ,!.• i ,"", ii
            l|»  ,', .  ''i  '"' '   ' ' i 'I1'  !„, "'.' « ' • ,/ '' '	  '  :.' ,,,"'•     "I*1!!,"	!	 Ilk i'11' 'i,,', I!   i'!, "',''', !,„'"„ i'' I li*'1'. •%  •', ».i"!i,  ' i !'
Estimated by applying median  profit-to-sales ratio over the 1982
to 1986 period from RMA.   (See Table X-7.)  SIC  code 4213  - Long
Distance Trucking was used for ICC Regulated and Non-ICC
Regulated carriers.  For local carriers, profit-to-sales ratios
for SIC codes 4212  - Local Trucking without Storage and  4214 -
Local Trucking with Storage were combined.  That is,  the ten
profit-to-sales ratios (five for SIC 4212 and  five for SIC  4214)
were ordered  and the median value was identified.
                                  330

-------
                                  Table X-15
            TRUCK  REBUILDING,  REPAIR AND MAINTENANCE:
                      TREATMENT COSTS AND IMPACTS.
                       (millions of  1988 dollars)
Rebuilding
  Capital Cost
  Annual Cost
  Anriualized Cost
                        Total Segment
                          Costs
2,898
1,409
1,887
             Motor Carrier
               Costs
1,255
  610
  817
             Annualized Cost  Amualized Cost'
             X of Revenue     X of Profit
                                                             0.3
                                                                            10.4
Maintenance
  Capital Cost
  Annual Cost
  Annualized Cost
  282
  201
  248
  122
  87
  107
                                                             0.0
                                                                             1.4
Rebuilding and Maintenance
  Capital Cost               3,180
  Annual Cost                1,610
  Annualized Cost            2,135
                1,377
                  697
                  924
                  0.4
                                                 11.7
Notes:
  Total segment cost* include costs for all  registered trucks.  Estimated by multiplying the
  average cost per vehicle (from Table X-12) to the total number of trucks registered in
  1986 (from the technical analysis).
  The motor carrier industry will bear costs equal to 43.3X of  total segment costs.
  According to the 1982 Census of Transportation, 56.7% of all  trucks are used for personal
  transportation.
  Impact estimates are based on estimated 1986 revenues and profits for all motor carriers
  as shown in Table X-14.                                   .      .      :         ,
                                          331

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                                          Table X-16

                   TRANSPORTATION EQUIPMENT  MANUFACTURING:
                                   Aircraft  and  Parts
 SIC Codt ft Description
 37211
 Aircraft, Military
      1972
      1977
      1982

 37215
 Aircraft'-Personal & Utility/
 & Commercial Transport
      1972
      1977
      1982

 37214
 Aircraft Modifications,
 Conversions, Overhaul
      1972
      1977
      1982

 37216
 Aeronautical Services on
 Aircraft, n.e.c.
      1972
      1977
      1982

 37241
 Aircraft Engines  for  Military
     1972
     1977
     1982

37242
Aircraft Engines
 excluding Military
     1972
     1977
     1982

37243
Aeronautical  Services on
Aircraft Engines
     1972
     1977
     1982
 * of
Est'b
 18.0
 13.0
 26.0
 32.0
 33.0
 36.0
 17.0
 19.0
 31,0
 12.0
 8.0
 17.0
10.0
 8.0
 9.0
 5.0
 7.0
 7.0
14.0
17.0
22.0
Employees
(1000's)
   133.2
   100.6
   118.6
    21.3
    43.0
    98.1
    9.4
     ND
   35.8
     NO
   17.6
   22.5
    2.4
     NO
     NO
     NO
     NO
   26.8
   13.2
    9.6
     NO
Production
Uorkeni
(1000'ii)
     73.3
     4JI.O
     56.6
     16.4
     31.2
     49.2
     6.6
      NO
    21.1
      ND
     7.2
    11.4
     1.6
      ND
      ND
      ND
      UD
    13.7
     5,8
     4..1
      IK)
                                                                            Value of
                                                                            Shipments
                                                                            (mi I 88 $)
12,187.0
10,690.0
10,473.7
 1,695.6
 4,340.4
11,213.0
   628.7
      NO
 3,367.3
     ND
 2,400.3
 1,880.5
   139.4
  -  ND
     ND
     ND
     ND
3,383.8
1,189.9
  938.6
     ND
             Capital
             Expenditures
             (mil 88 $)
 72.4
127.8
493.6
 19.3
 64.0
253.8
  4.0
   ND
 95.0
   ND
 28.4
 51.8
  2.7
   ND
   ND
  ND
  ND
 69.3
22.0
15.7
  ND
                                                332
                                                    ,;„-.;„;,', |	

-------
                                 Table  X-16 (Continued)

                       TRANSPORTATION EQUIPMENT  MANUFACTURING:
                                    Aircraft and Parts
 SIC Code & Description
  * of
 Est'b
Employee*
(1000's)
Production
Workers
(1000's)
Value of
Shipments
(mil  88 $}
Capital
Expend!tures
(mil  88 S)
37244
Aircraft Engine Parts
& Accessories
     1972
     1977
     1982

3728
Aircraft Equipment  n.e.c.
     1972
     1977
     1982
139.0
143.0
192.0
694.0
727.0
966.0
   74.5
   42.4
   53.8
  102.2
  102.0
  133.3
    46.0
    27.9
    36.9
    68.1
    58.7
    73.7
 6,506.2
 3,612.3
 4,831.3
 8,125.5
 7,803.1
10,886.3
     127.3
     113.3
     205.4
     104.3
     217.3
     426.7
NA = Not Available
ND 3 Not Disclosed

Source:  U.S. Bureau of the Census, Census of Manufactures,
         1972, 1977, 1982.
                                                333

-------
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-------
                     Table X-18

          OTHER TRANSPORTATION SERVICES
SIC Code & Description
451
Air Carriers
     1972
     1977
     1982

458
Air Transport Services
     1972
     1977
     1982
 # of
Estabs
3,391.0
4,338.0
1,686.0
1,977.0
2,143.0
Paid
Employees
  308,305.0
  373,969.0
   27,637.0
   41,445.0
   52,195.0
Source:  U.S. Bureau of the Census,  County Business Patterns,
          U.S. Summary, 1972,  1977,  1982.
                           335

-------
                             Table  X-19

            REVENUES, EMPLOYMENT,  AND PROFITABILITY OF
                CERTIFIED AIR CARRIERS, 1982-1986
                Operating Revenues1
                 fBillions  198851
                   Employment
                     lOQOisl
            Before Tax
            Profits as
           a Percent
            of Sales3
1982

1983

1984

1985

1986
46.1

47.5

51.4

53.1

61.8
330

329

345

355

422
1.7

0.6

1.8

2.7

2.7
                                                                ,' .. ;• . ,,  ,) .' .T,. I ;:[, ;,'	"„
       Air Transport Association of America, Air  Transport; The
 Annual  Report of the  U.S.  Scheduled Airline Industry, various
 years.

       2Ibid.

       3Robert Morris Associates,   Annual Statement  Studies. 1986.

                           •  '    : 336     "'"    '':.	
                                                II.  'i Hi'", , "I T,
                                          1 IK ;,< ..... ,„"• '.Jmi, • ,'! m JIELK'qi I1!" I1:; I1 u M'S m1;, Nr tiL'ki, 
-------
                                    Table X-20

                ESTIMATION  OF  1986  NON-MILITARY AIRCRAFT
                            MANUFACTURING REVENUES
SIC Code & Description
   1982
Value of
Shipments
(mil 88 $)
   1986
Value of
Shipments
(mil 88 $)
   1986
 Profits
(mil 88 $)
37215
Aircraft--Personal  & Utility/
& Commercial Transport

37214
Aircraft Modifications,
Conversions, Overhaul

37216
Aeronautical Services  on
Aircraft, n.e.c.

37242
Aircraft Engines
excluding Military

37243
Aeronautical Services  on
Aircraft Engines

37244
Aircraft Engine Parts
& Accessories

3728
Aircraft Equipment n.e.c.
 TOTAL
 11,213.0
  3,367.3
  1,880.5
  11,571.8
   3,475.1
   1,940.6
                                        822.9
                                        247.1
                                         138.0
3,383.8
1,041.8
4,831.3
10,886.3
36,604.0
3,492.1
1,075.1
4,985.9
11,234.7
37,775.3
248.3
76.5
354.6
798.9
2,686.2
 Notes:
   1986  Value of Shipments estimated based on average growth of SIC 3721 -
   Aircraft Manufacturing.  Growth rates are taken from  the 1988 U.S.
   Industrial Outlook, page 39-5 and are estimated at -1.1% per year for
   1982  to 1985 and 6.7% between 1985 and 1986.

   Profits estimated by applying the 1982 to 1986 median after tax profit-to-
   sales ratio for aerospace manufacturing from the Quarterly Financial Report for
   Manufacturing Industries (3.2%) to estimated 1986 sales.  After tax profit were
   then converted to before tax profits assuming a marginal tax rate of 45 percent.
                                           337

-------
                             Table X-21

             REVENUES, EMPLOYMENT, AND PROFITABILITY OF
                   CLASS I RAILROADS, 1982 - 1986
                Operating Revenues
                 (Billions 1988S1
1982
1983
1984
1985
1986
34.8
32.6
34.6
31.4
29.0
Employment
 fOOOs)
                                             397


                                             342


                                             3,44.
                                              t,, •::',' ii| ," ,

                                             322


                                             294
After Tax
Profits as
a Percent
of Sales
                 2.7

                 6.9



                 6.4

                 n/a
                                                          i " i	•„' "I,!1! 	„' i
                                                                 " in' i'1 ! J"'!',!!' ..li'li'1' "il'i ii. .||1|ii:!l"i
Source:  Association of American Railroads. Yearbook of  Railroad
Facts; Statistics  of Railroads of Class If various years.
                                  338

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                                      339

-------
                              Table X-23

                   RAIL CAR REBUILDING AND MAINTENANCE:
                       TREATMENT COSTS AND IMPACTS
                       (millions of 1988 dollars)
 Rebuilding
   Capital Cost
   Annual Cost
   Annuali2ed Cost

 Maintenance
   Capital Cost
   Annual Cost
   Annualized Cost

 Rebuilding and Maintenance
   Capital Cost
   Annual Cost
   Annualized Cost
                                 Total
                                 Segment
                                  Costs
 7.4
 3.5
 4.7
 7.0
 2,5
 3.7
14.4
 6.0
 8.4
         Annualized
             Cost
             %lof'.
         __Revenue_
0.01
0.01
                                              0.03
           Annualized
              Cost
              % P.f
             Profit
                                                                  	i	f'«:(«.:* .'"lit.1.	>'
                          0.10
                          0.07
                          0.17
Notes:
          •'  ,  ' :;i  •      '  •"   "',   '••' '    " :'''•;.,';;	J.f1':'.,,.& iiS:1"'",?: i: •„.; :' "  v'*/;,'  ''.    '>;
Annualized  costs based on an  interest rate of 10.34% and an
assumed useful life of 10 years.

Impact  estimates are based on 1986  revenues and profit-to-sales
ratios  for  Class I railroads  from Table X-21.  Revenues from
Table X-21  were modified to represent those from all rail traffic
by adjusting for the fact that Class I  railrocids earn approxi-
mately  90%  of total line haul revenues  and adding Amtrak
revenues.
              ;„,,   '   • ,	i-  , . ••'   ' '- '-    :, • .  "'.'••• ::.; • <	,	•• r;	*  i ,	'• •.,    •'.	J|1

Profits were estimated based  on  the median after-tax
profit-to-sales ratios from Table X-21  multiplied by total
estimated operating revenues.  They were  adjusted to reflect
before-tax  profits assuming a marginal  tax rate of 45 percent.
                                  340

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-------
                   Table X-26

   •..     ,  s,  "'':":  '"''!"';'•':"' ••»''.•   ' "•••,  'i!l!'.; iT'K1,'1!

     REVENUES"AND EMPLOYMENT OF  COMPUTER

     EQUIPMENT  MANUFACTURERS, 1983-1986
                                              	i*y w<':••••
                                              v	,'Si.".)'"/ '«
 1983
  ,, 'Ih



 1984




 1985




 1986
               Value of Shipments

               (Billions 1988 $)
52 . 8



49.1



45.8
                   Employment

                     (000)
374



340



316
Source: U.S. Department of Commerce,  U.S.  Industrial

        Outlook, 1988.
                         344
                                                                    III  111
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                                                        345

-------
                                      Table  X-28

                       ADJUSTED  1982  SEGMENT  REVENUES:
                Computers,  Copiers,  Automatic Typewriters
                                and Word Processors
    sic
             ccaicar
             SEGMENT
                                         Specialization
                           Revenues           Ratio
                       (Millions 1988 $)
35731  Computers
35792 Automatic Typewriters
     & Word Processing

35793 Duplicating Equipment
                                  12912

                                  1682


                                   177
95X

81X


81X
           Coverage
             Ratio
94X

87%


87X
           Adjusted
        1982 Revenues
       (Millions 1988 $)
13049

 1566


  165
                             M	,
Notes:
  Specialization Ratio*Receipts from primary product shipments/total  receipts from primary
    and secondary products for establishments in this SIC code.  Value based on four-digit SIC code.

  Coverage Ratio*Receipts from primary products shipped by establishments in this SIC code/total
    receipts from such products by all manufacturing establishments.  Value based on four-digit SIC code.

  Adjusted Revenues*1982 Revenues X (specialization ratio/coverage ratio).
Source: 1982 Census of Manufactures
                                           346

-------
                                  Table  X-29
                        ESTIMATION  OF  1988  REVENUES
      FOR ESTABLISHMENTS  MANUFACTURING COMPUTERS,, COPIERS,
            AUTOMATIC TYPEWRITERS,  AND  WORD PROCESSORS
                        (millions of 1988 dollars)
SIC Segment
35731 Computers
35792 Automatic Typewriters
Adjusted
1982 Revenues
13049
1566
Percent
Change in
Revenues
166.4
90.6
Before Tax
Profit as X
of Revenues
8.1
10.7
Estimated
1988 Revenues
34,763
2,985
Estimated
1988
Profits
2,816
319
       & Word Processing
  35793 Duplicating Equipment
165
37.4
6.3
226
       TOTAL
                                       37,975
14
                                    3,149
Notes:
  Adjusted 1982 revenues taken from Table X-28.
  Percentage change in revenues are for 1982 to 1988 based on median value of percent changes
   for leading firms from Table X-27.                               '
  Before tax profit-to-sales ratios based on median of 1988 profit-to-sales of leading firms from Table X-16.
  1988 Revenues estimated by multiplying 1982 revenues by percent change in revenues for 1982 to 1988.
  1988 Profits estimated by multiplying 1988 revenues by 1988 profit-to-sales ratios.
                                          347

-------
                    Table  X-30

1988  COST  EFFECTIVENESS CRITERIA AND WEIGHTS
             NON-VOLATILE POLLUTANTS
                                                                    ': .,,,1 a1 ,H'|V"!"
                                                                   l ; '"111	Hilli".:,!1!,,
•' 	 ;; 	
I. PESTICIDES
1. Acrolein
2. AldHn
3. •-IHC (Alpha)
4. B-BHC (Beta)
5. -BHC (GMIM) (Lindane)
6. -BHC (Delta)
7. Chlordane
8. DDD (TOE)
9. DOE (Total)
10. DOT
11. Dieldrin
12. -Endoculfan (Alpha)
13. -Endosulfan (Beta) (Total)
H. Endoculfan Sulfate
15. EndHn
16. EndHn Aldehyde
17. Heptachlor
18. Hcptachlor Epoxide (Total)
19. tsophorone
20. TCOO
21. Toxaphene
II. HCTALS AW INORGANICS
22. Antimony
23. Arsenic (total trivalent)
24. Asbestos (fibers per liter)
25. Beryl Uui
26. CadMiua (Total)
27a. ChroralUM (Total Hexavalent)
27b. ChroaiiuM (Total Trivalent)
28. Copper (Total)
29. Cyanides (Free cyanide)
30. lead (Total)
31. Hercury (Total)
32. Nickel (Total)
33. SeleniuM (Total)
34. Silver (Total)
35. Thaliu*
36. Zinc
Criteria
(Micrograns/l i ter)
Health
Ingesting
Only

780
0.00079
0.31
0.547
0.625
.
0.0048
0.00024
0.00024
0.00024
0.00076
159
159
159
2.71
-
0.0029
0.0029
520000
0.0000001
0.0073

45000
0.175
.
1.17
.
0.16
3433000
-
307692
-
0.146
100
17949
6
48
~
Aquatic
Freshwater
Chronic

11.4
0.22
-
1
0.08
51
0.0043
0.001
0.001
0.001
0.0019
0.056
0.056
0.056
0.0023
0.0023
0.0038
1.2
5850
0.001
0.0002

1600
190

5.3
1.1
11
210
12
5.2
3.2
0.012
160
35
0.12
40
110
Toxic Weights
Copper-Based Weights
Hunan
Based

0.0072
7089
18.06
10.24
8.96

1167
23333
23333
23333
7368
0.0352
0.0352
0.0352
2.0664

1931
1931
0.00001
40000000
767

0.00012
32

4.79

35
0.000001

0.000018

38.36
0.056
0.00031
0.9333
0.1167

Aquatic
Based

0.4912
25.45

5.6
70.0
0.1098
1302
5600
5600 .
5600
2947
100
100
100
2435
2435
1474
4.667
0.0010
5600
28000

0.0035
0.0295

1.057
5.091
0.5091
0.0267
0.4667
1.077
1.750
467
0.0350
0.1600
46.7
0.1400
0.0509
Sum of
Human &
Aquatic

0.4984
7114
18.1
15.8
79.0
0.11
2469
28933
28933
28933
10316
100
100
100
2437
2435
3405
1936
0.0010
40005600
28767

0.0036
32.03

5.84
5.09
35.51
0.0267
0.4667
1.08
1.75
505
0.091
0.160
47.60
0.257
0.051
Removal
Eff.

0.53
0.83

0.43


















0.66
0.39

.
0.61
0.18
0.65
0.84
0.70
0.92
0.60
0.51
0.46
0.78

0.78
                                        ! iir;
                                                                   I  I
                         348
                                                                '!>«'•'	ir •[•' 'lid

-------
           Table X-30  (Continued)

1988 COST EFFECTIVENESS CRITERIA AND WEIGHTS
           NON-VOLATILE POLLUTANTS

III. PCBS AND RELATED COMPOUNDS
37-43 . PCBs (Total)
44. 2-Chloronaphthalene
IV. HALOGENATED ALIPHATICS
45. Methane, Bromo- (Methyl Bromide)
46. Methane, Chloro- (Methyl Chloride)
47. Methane, Dichloro-
-------
           Table X-30  (Continued)
1988 COST EFFECTIVENESS CRITERIA AND WEIGHTS
           NON-VOLATILE POLLUTANTS
1 •
VI. HONOCYCLIC AROMATICS
78. Benzene
79. Benzene, Chloro-
80. Benzene, 1,2-Dichloro-
81. Benzene, 1,3-Dichloro-
82. Benzene, 1,4-Dichloro-
83. Benzene, 1,2,4-Trtchloro-
84. Benzene, Haxachloro-
85. Benzene, Ethyl-
86. Benzene, Nitro-
87. Toluene
83. Toluene, 2,4-Dinitro-
89. Toluene, _2.6-Dinitro-
VII. PHENOLS I CRESOLS
90. Phenol
91. Phenol, 2-Chloro-
92. Phenol, 2,4-Dichloro-
93. Phenol, 2,4,6-Trichloro-
94. Phenol, Pentachloro-
95. Phenol, 2-Hitro-
96. Phenol, 4-Hitro-
97. Phenol, 2,4-Dinitro-
96. Phenol, 2,4-Oimethyl-
99. M-Cresol, p-Chloro-
100. o-Cre«ol, 4-6-Otnitro-
VIII. PHTHLATE ESTERS
101. Phthalate, Dimethyl-
102. Phthalate, Diethyl-
103. Phthalate, Di-n-Butyl-
104. Phthalate, Di-n-Octyl-
105. Phthalate, 8i*-(2-ethylhexyl)-
106. Phthalate, Butyl Benzyl-
Criteria
(micrograiM/liter)
Health
Ingesting
Only

400
15050
2600
2600
2600
98.9
0.0074
3280
2130000
424000
91
-

769000
.
26500
36
29400
.
.
14300
-
.
765

2900000
1800000
154000
.
58.8
.
Aquatic
Freshwater
Chronic

265
10000
360
1510
763
286
120
6800
460
650
1550
990

750
1000
70
3.2
13
1880
414
31
1000
1.5
3.3

1700
10000
47
3
3
220
Toxic Weights
Copper-Based Weights
Human
Based

0.014
0.00037
0.00215
0.00215
0.00215
0.0566
757
0.0017
0.000003
0.00001
0.0615


0.000007

0.00021
0.1556
0.00019


0.00039


0.0073

0.000002
0.000003
0.000036

0.0952

Aquatic
Based

0.0211
0.0006
0.0156
0.0037
0.0073
0.0196
0.0467
i 0.0008
0.0122
0.0086
0.0036
0.0057

0.0075
0.0056
0.0800
1.7500
0.4308
0.0030
0.0135
0.1806
0.0056
3.733
1.697

0.0033
0.0006
0.1191
1.867
1.867
0.0255
Sum of
Human &
Aquatic

0.0351
0.0009
0.018
0.0059
0.0095
0.076
757
0.0025
0.012
0.0086
0.065
0.0057

0.0075
0.0056
0.0802
1.91
0.431
0.0030
0.0135
0.181
0.0056
3.73
1.70

0.0033
0.0006
0.119
1.87
1.96
0.025
Removal
Eff.

0.95
0.96
0.89
0.89
0.52
0.91
0.90
0.94
0.61
0.96
0.55
0.55

0.95
0.95
0.95
0.50
0.45
0.27
0.75
0.90
0.51
0.95
0.93

0.63
0.60
0.79
0.83
0.60
0.90
                                       •:• f
                     350

-------
                       Table X-30  (Continued)

          1988  COST EFFECTIVENESS  CRITERIA  AND WEIGHT. S
                       NON-VOLATILE  POLLUTANTS

IX. POLYCYCLIC AROMATIC HYDROCARBONS
107. Acenaphthene
108. Naphthalene
1 09 . Ft uoranthene
110. Acenaphthylene
III. Anthracene
112. Benzo(a)Anthracene
113. Benzo(b)Fluoranthene
U4. Benzo(k)Fluoranthene
US. Benzo
-------
                                       Table  X-31
             NONCONVENTIONAL NON-PRIORITY  POLLUTANTS
                                                    I1 .,:
                                                                j./ll'IISy/lj'',,,;''; ;!;,,
	
Aluminum
Ammonia**
Barium
Boron
Chlorine
Cobalt
Fluoride
Hydrogen Sulf iete
Iron
Lithium
Magnesium
Manganese
Molybdenum
sulfide
Tantalum
Tin
Titanium
Tungsten
Vanadium
Zirconium
Criteria
(mi crograma/ 1 i ter )
Human Aquatic
Health Freshwater
150
1151
2813
31.6
11.5
38.2
4000
3.6
1000
464
367600
388
27.8
2
94
18.6
191
1066
9
10.3
Toxic Weights
Copper Based Weights
Hunan Aquatic
Based Based
0.0373
0.0049
0.002
0.1772
0.4870
0.1466
0.0014
1.556
0.0056
0.0121
0.000015
0.0144
0.2014
2.80
0.0596
0.3011
0.0293
0.0053
0.6222
0.5437
Copper
Based Weights
Sum of
Human & Aquatic
0.0373
0.0049
0.0020
0.1772
0.4870
0.1466
0.0014
1.556
0.0056
0.0121
0.000015
0.0144
0.2014
2.80
0.0596
0.3011
0.0293
0.0053
0.6222
0.5437
Assumed Temperature '20*  C,  pH * 6
                                               352
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-------
                 «"!  '  ,
                                         Table X-37
                           POLLUTANT  REDUCTION  ESTIMATES
      NORMAL  PLANT  LOAD  -  AUTOMOBILE  REBUILDING  - MAINTENANCE
                                                              	 J	is;  '•	«	'
     TOTAL FLOW (gallons/year):
     Pollutant
   66.000                                            (6)
             <2)                <4>        (5)    At-Stream
   (I)     Removals    (3)      POTW      Direct   Indirect
  Total     Due to    Toxic    Removal  Discharger Discharger
Raw Waste  Treatment Weighting   (for     Removals   Removals
 (lbs/yr)  (lbs/yr)   Factor  indirects) (lbs-eq/yr)(lbs-eq/yr)
 PRIORITY POLLUTANTS
      Organic*	
      13. 1,1-dichloroethane                  0.0       0.0
      20. 2-chloronaphthalene                 0.0       0.0
      3d. ethylbenzene                       0.0       0.0
      42. bis (2-chloroisopropyl) ether        0.2       0.0
      44. methylene chloride                  0.0       0.0
      57. 2-nitrophenol                       2.0       0.0
      58.  4-nitrophenol                       2.2       0.0
      £6.  bis (2-ethylhexayl) phthalate        0.0       0.0
      86.  toluene                            0.0       0.0
   i'     .         "              '"      '  ,  i",, '   i '     "
    Subtotal                                4.4       0.0

    Metals		-	
    114. antimony
    115. arsenic
    117. beryllium
    118. cadmium
    119. chromiiM
    120. copper
    122. lead
    123. mercury
    124. nickel
    125. selenium
    126. silver
    127. thallium
    128. zinc

    Subtotal                               26.8       26.4
0.0
0.0
0.0
0.0
0.0
2.4
4.6
0.0
0.0
0.0
0.0
0.0
19.8
0.0
0.0
0.0
0.0
0.0
2.2
4.6
0.0
0.0
0.0
0.0
0.0
19.6
0.0
32.0
5.8
5.1
0.0
0.5
1.8
505.0
0.1
0.2
47.6
0.3
0.1
                                  0.7
                                  0.4
                                  0.0
                                  0.6
                                  0.7
                                  0.8
                                  0.9
                                  0.6
                                  0.5
                                  0.5
                                  0.8
                                  0.0
                                  0.8
 0.0
 0.0
 0.0
 0.0
 0.0
 1.0
 8.1
 0.0
 0.0
 0.0
 0.0
 0.0
 1.0

10.1
0.0
0.0
0.0
0.0
0.0
0.2
0.6
0.0
0.0
0.0
0.0
0.0
0.2

1.0
HONCONVENTIONAL TOXICS
    Organic*--	
    200. acetone                            0.0
    210. benzoic acid                      90.4
    234. hexanoic acid                      0.2
    246. n-docosene (N-C22)                  0.0
    248. n-eicosane 
-------
                              Table  X-37  (Continued)

                         POLLUTANT  REDUCTION  ESTIMATES
     NORMAL  PLANT  LOAD  -  AUTOMOBILE  REBUILDING  -  MAINTENANCE
  TOTAL  FLOW (gallons/year):
  Pollutant
   66,000                                            (6)
             (2)                <4>        <5>     At-Stream
   (1)     Removals     (3)      POTW      Direct    Indirect
  Total     Due to    Toxic    Removal  Discharger Discharger
Raw Waste  Treatment Weighting   (for     Removals   Removals
   (Ibs/yr)   Factor  indirects) (lbs-eq/yr)(lbs-eq/yr)

















aluminum
barium
boron
calcium
cobalt
iron
magnesium
manganese
molybdenum
sodium
tin
titanium
vanadium
yttrium
Subtotal

2.6
0.0
90.9
24.6
0.0
8.4
6.4
0.0
0.4
501.6
0.4
0.0
0.0
0.0
635.4

1.8
0.0
90.6
0.0
0.0
8.1
0.0
0.0
0.0
0.0
0.4
0.0
0.0
0.0
101.0

0.0
0.0
0.2
0.0
0.1
0.0
0.0
0.0
0.2
0.0
0.3
0.0
0.6
0.0


0.1
0.0
16.1
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.1
0.0
0.0
0.0
16.3

0.1
0.0
16.1
0.0
0.0
0.0
0.0
0.0
0.0
o.b
0.1
0.0
0.0
0.0
16.3
OTHER NONCONVENTIONAL POLLUTANTS









acidity
alkalinity
chemical oxygen demand
chloride
fluoride
phenols, total
sulfate
total dissolved solids
Subtotal
0.0
842.2
106.401.9
84.5
14.7
0.2
152.7
759.4
108,255.6
0.0
0.0
0.0
0.0
5.1
0.0
0.0
0.0
5.1



























CONVENTIONAL POLLUTANTS



__
oil and grease
total suspended solids
Subtotal
==3==========S3S3eS=S3XXZ23S33SS=33S
TOTAL
453.9
30.1
484.0
m»»»«-axx-=-
109,496.9
447.3
28.4
475.6
:=======~X3==
608.1



— — — =— — 3— — — as— x— — — x-




•——===— a— —a——
26.4



_________
17.3
<1) End-of-pip* pollutant dischargM (in pounds).
%l 5Ti r""OVBl» 
-------
                          Table X-38

                POLLUTANT REDUCTION  ESTIMATES
           NORMAL  PLANT LOAD - AUTOMOBILE, BUS  AND
                    TRUCK PARTS REBUILDING
Total Flow (gallons/year): 506,000 (6)
• ' • • 	 ' ' -• '" •• 	 '"•" :" ' <2> ' " <4) (5) At-Stream
(1) Removals (3) POTW Direct Indirect
Total Due to Toxic Removal Discharger Discharger
.,,«., Raw Waste Treatment Weighting (for Removals Removals
Pollutant Ubs/yr) (Ibs/yr) Factor indirects) (lbs-eq/yr)(lbs-eq/yr)
PRIORITY POLLUTANTS
13. 1,1-dichloroethane
20. 2-chloronaphthalene
30. trans-1,2-dichloroethane
44. Hiethylene chloride
65. phenols
66. bis (2-ethylhexyl) phthalate
• • !' , 3 .
Subtotal

114. antimony
115. arsenic
117. beryllium
118. cadmium
119. chromium
120. copper
122. lead
123. mercury
124. nickel
125. selenium
126. silver
127. thallium
128. zinc
Subtotal
121. cyanide

HOHCOHVEHTIONAL TOXICS

200. acetone
210. benzoic acid
234. hexanoic acid
236. fsobutyl alcohol
247. n-dodecane (N-C12)
248. n-eicosane (H-C20
250. n-hexadacane (N-C16)
274. p-cymene
277. safrole
282. thioxanthone
286. tripropyleneglycol met. ether
295. 1,2:3,4-diepoxybutane
318. 2-butanone
0.0
0.4
0.0
1.5
0.0
0.0
i, -
2-°. ,,

0.2
0.0
0.0
4.0
2.0
5.1
69.1
0.0
3.1
0.0
0.0
0.0
53.5
136.8
0.0



0.0
4.6
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
41.6
0.0
1.1
0.0
0.0
0.0
0.0
0.0
0.0
o.o

0.0
0.0
0.0
3.7
1.5
3.1
68.6
0.0
2.0
0.0
0.0
0.0
52.4
131.3
0.0

''

0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0


' '• :" 'I* '.'•'.
0.0
32.0
5.8
5.1
0.0
0.5
1.8
505.0
0.1
0.2
47.6
0.3
0.1

" 	 ,., ' i: :
"! •'' i" ,"'"''
' '"'"'
















; i'
0.7
0.4
0.0
0.6
0.7
0.8
0.9
0.6
0.5
0.5
0.8
0.0
0.8

°-7


















• ;;>*' '. 	 .; ;•
0.0
0.0
0.0
19.0
0.0
1.4
120.1
0.0
0.2
0.0
0.0
0.0
2.7
143.5
0.0
11 , . , ii "I'i'i; '















1 '' :: ,!''• ; , ! . i


0.0
0.0
o!o
7 4
I • **
0.0
0.2
9.6
0.0
0.1
0.0
0.0
0.0
0.6
18.0
0.0
















                                                                       I	|1, "HKiiilllll	
                                                                       : ii'ki.»,;.,n
Subtotal
                           47.3
0.0
                               360
                                                                       ;ilr ,*""

-------
                             Table  X-38   (Continued)

                        POLLUTANT REDUCTION  ESTIMATES
                 NORMAL PLANT LOAD  - AUTOMOBILE,  BUS AND
                             TRUCK  PARTS REBUILDING
    Total Flow (gallons/year):
    Pollutant
       506,000                                          <6>
                  (2)               <4>       (5)    At-Streaa
        (1)     Removals     (3)     POTU     Direct   Indirect
       Total     Due to     Toxic    Removal  Discharger Discharger
     Raw Waste  Treatment Weighting  (for    Removals  Removals
      >.
                                             361

-------
                                                             •Ml  1	i; «!i(l I "	, •	•  1"111	
                                      ;   Table X-39
                 '• i  '    !•  "  ;   !'      ::; •".,:  "' " - ul .'''  i      '  «; • ','
                           POLLUTANT REDUCTION  ESTIMATES
               NORMAL PLANT  LOAD -  BUS AND  TRUCK REBUILDING
    TOTAL FLOW                 (4)        (5)     At-Stream
   (1)     Removals    (3)      POTW      Direct   Indirect
  Total     Due to    Toxic    Removal  Discharger Discharger
Raw Waste  Treatment Weighting   (for     Removals   Removals
 (Ibs/yr)  (Ibs/yr)   Factor  inciirects) (lbs-eq/yr)(lbs-eq/yr)
PRIORITY POLLUTANTS
    Oraanics ---------------------------
     11. 1,1,1-trichloroethane               0.2       0.0
     13. 1,1-dichloroethane                  0.0       0.0
     15. 1,1,2,2-tetrachloroethane           0.2       0.0
     22. 4-chloro-3-methylphenol             0.0       0.0
     38. ethyl benzene                       0.0       0.0
     42. bis (2-cloroisopropyl)              0.0       0.0
     44. ssethylene chloride                  0.2       0.0
     55. naphthalene                        0.7       0.0
     57. 2-nitrophenol                       0.4       0.0
     58. 4-nitrophenol                       0.4       0.0
     65. phenol                             0.0       0.0
     66. bis (2-ethylhexyl) ph thai ate         0.0       0.0
     78. anthracene                         0.2       0.0
     86. toluene                            0.0       0.0

    Subtotal       ^                  '      2.4     "  0.0 ,

    Metals ......... ---- ................ ,     """  '      .....
    114. antimony                           0.0
    115. arsenic                            0.0
    117. beryllium                          0.0
    118. cadmium                            0.2
    119. chromium                           0.4
    120. copper                             5.7
    122. lead                               1.5
    123. mercury                            0.0
    124. nickel                             0.4
    125. selenium                           0.0
    126. silver                             0.0
    127. thallium                           0.0
    128. zinc                              11.9

   Subtotal                               20.2        7.3
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
7.3
0.0
32.0
5.8
5.1
0.0
0.5
1.8
505.0
0.1
0.2
47.6
0.3
0.1
                                  0.7
                                  0.4
                                  0.0
                                  0.6
                                  0.7
                                  0.8
                                  0.9
                                  0.
                                  0.
                                  0.
                                  0.8
                                  0.0
                                  0.8
.6
.5
.5
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.4

0.4
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.1

0.1
   121. cyanide
     0.0
               0,0
                                                             1.1
                                                                       0.7
         0.0
                                                                                            0.0
                                               362

-------
                   Table X-39  (Continued)

                POLLUTANT REDUCTION ESTIMATES
       NORMAL PLANT  LOAD - BUS  AND TRUCK REBUILDING
TOTAL FLOW (gallons/year):
1,980,000
Pollutant
NONCONVENTIONAL TOXICS
200. acetone
210. benzoic acid
234. hexanoic acid
236. isobutyl alcohol
245. n-decane (n-C10)
246. n-docosane (n-C22)
247. n-dodecane (n-C12)
248. n-eicosane (n-C20)
249. n-hexacosane  <4> (5) At-Stream
(1) Removals (3) POTW Direct Indirect
Total Due to Toxic Removal Discharger Discharger
.Raw Waste Treatment Weighting (for Removals Removals
(Ibs/yr) (Ibs/yr) Factor indirects) (lbs-eq/yr)(lbs-eq/yr)
0.2
15.2
0.0
0.0
0.4
0.9
3.5
0.4
0.2
2.0
0.0
0.2
17.8
0.0
0.0
0.2
0.0
0.0
0.0
0.2
0.0
1.5
0.0
42.9
13.4
10.3
20.9
956.1
0.0
58.7
224.8
0.9
0.2
1,422.3
3.3
0.4
0.0
0.0
2,711.5
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
4.8
13.9
0.0
0.0
53.2
0.0
0.0
0.0
0.0
0.4
0.0
0.0
0.0
72.4




0.0
0.0
0.2
0.0
0.1
0.0
0.0
0.0
0.2
0.0
0.3
0.0
0.6
0.0





0.0
0.0
2.5
0.0
0.0
0.3 '
0.0
0.0
0.0
0.0
0.1
0.0
o.o
0.0
2.9




0.0
0.0
2.5
0.0
0.0
0.3
0.0
0.0
0.0
0.0
0.1
0.0
0.0
0.0
2.9
                               363

-------
                                                    1 in1!,,,,; I1 ,i! iiii1'1 !!;pi"	i.i'l,
                                                                         !1:;	jpi	 .pi1 j, || • ,UH *\t •, i	i	; J
                           Table X-39  (Continued)

                        POLLUTANT REDUCTION ESTIMATES
             NORMAL PLANT LOAD -  BUS'AND TRUCK  REBUILDING
     TOTAL FLOW (gallons/year):
1,980,000



Pollutant
OTHER NONCONVENTIONAL POLLUTANTS
acidity (as Ca C03)
alkalinity
chemical oxygen demand
chloride
fluoride
phenols, total
phosphate, total
sulfate
total dissolved solids
Subtotal

CONVENTIONAL POLLUTANTS
oil and grease
total suspended solids


(1)
Total
Raw Waste
(Ibs/yr)

97.2
7,338.8
39,551.4
997.7
43.3
0.0
1.1
2,508.9
16,744.2
67,282.6
ii, f ,„•« i!

1,522.2
1,044.6
..
<2) (4)
Removals (3) POTU
Due to Toxic Removal
Treatment Weighting (for
(Ibs/yr) Factor indirects)

0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0


1,324.2
993.1
,. . • 	 - -. ' (6)
(5) At-Stream
Direct Indirect
Discharger Discharger
Removals Removals
( lbs-eq/yr)( Ibs-eq/yr)











', i«i'i i, I, ' '•' ,l



    Subtotal
    TOTAL
           BKmssmssrsjssssss
 2,566.7   2,317.3


  72,626   "2^397
III f£~0f~pfpe Pfllutant discharges (in pounds)
              '

                                       364

-------
                              Table X-40

                  POLLUTANT REDUCTION ESTIMATES
       NORMAL PLANT  LOAD - BUS  AND TRUCK MAINTENANCE
TOTAL FLOW (gallons/year):
Pollutant
1,408,000
   (1)   Removals    (3)
  Total   Due to    Toxic
Raw Waste Treatment Weighting
        (5)    At-Stream
  POTW      Direct    Indirect
 Removal  Discharger Discharger
  (for     RemovaIs   RemovaIs
indirects) 
-------
                                                                         I1.1	1-
                                                                         '"	' I'	
                                                                                                 ,?	»	fi'i'Ml, •'#	iri*
                                Table  X-40  (Continued)

                            POLLUTANT REDUCTION  ESTIMATES
               NORMAL  PLANT LOAD *-  BUS AND  TRUCK  MAINTENANCE
       TOTAL FLOW (gallons/year):
       Pollutant
 i,408,000

                                          	(6)	
             <2)                 (4)       (5)     At-Stream
   (1)    Removals     (3)       POTW     Direct    Indirect
  Total    Due to     Toxic     Removal  Discharger Discharger
 Raw Waste Treatment Weighting    (for    Removals   Removals
 (Ibs/yr) (Ibs/yr)  factor   indirects) (lbs-eq/yr)(lbs-eq/yr)

aluminum
barium
boron
calcium
cobalt
fron
magnesium
manganese
molybdenum
sodium
tin
titanium
vanadium
yttrium
Subtotal

31.7
3.1
22.7
761.2
0.0
80.1
194.0
1.3
0.2
3,672.9
0.0
1.3
0.2
0.0
4,768.7

10.8
0.0
17.6
0.0
0.0
76.1
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
104.5

0.0
O.CI
0.3!
O.CI
0.1
0.0
0.0
0.0
0.2!
0.0
0.3
0.0
0.6
O.C


0.4
0.0
3.1
0.0
0.0
0.4
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
„. 	 	 3,9 	

0.4
0.0
3.1
0.0
0.0
0.4
0.0
0.0
0.0
0.0
0.0
On
. u
0.0
0.0
3,9
 OTHER NOHCONVENTIONAL POLLUTANTS
      alkalinity
      chemical oxygen demand
      chloride
      fluoride
      phenols, total
      phosphate,  total
      sulfate
      total dissolved solids

      Subtotal

 CONVENTIONAL POLLUTANTS
      oil and grease
      total suspended solids

      Subtotal
  8,961.0
 34,684.3
    740.5
    224.2
     0.4
     0.4
  4,317.9
 22,700.0
'• ,-..'••.	'..:." '"
 71,628.9
  0.0
  0.0
  0.0
 20.0
  0.0
  0.0
  0.0
  0.0
"i"'1!' ,  " ii
 20.0
  5,404.5  5,263.7
  2,339.5  2,303.0

  7,744.0  7,566.7
 TOTAL
                                           84,217    7,712
CD End-of-pipe pollutant discharges (in pounds).
(2) Annual removals (in pounds) with oil skimming,  chemical precipitation, sedimentation, and filtration.
(3) Toxicity of pollutant relative to an equivalent mass of copper.
(4) Pollutant-specific removal efficiency for POTU  treatment (applied to indirect dischargers).
(5) Annual removals for direct dischargers in pounds-equivalent.   Column (2) x Column (3).
(6) Annual removals for indirect dischargers in pounds-equivalent.  Column (2) x Column (3) c (1-Column (4)).
                                                366

-------
                        Table X-41

             POLLUTANT REDUCTION ESTIMATES
          NORMAL PLANT LOAD - RADIATOR SHOPS
Total Flow (galIons/year):
25,080
(2) (4) (5)
(1) Removals (3) POTW Direct
Total Due to Toxic Removal Discharger
Raw Waste Treatment Weighting (for Removals
Pollutarct (Ibs/yr) (Ibs/yr) Factor indirects) (Ibs-eq/yr)
PRIORITY POLLUTANTS
13 1,1-dichloroethane
22 4-chloro-3-methylphenol
38 ethyl benzene
42 bis (2-chloroisopropyl) ether
44 methylene chloride
57 2-nitrophenol
58 4-nitrophenol
65 phenol
66 bis (2-ethylhexyl) phthalate
86 toluene
Subtotal
114 antimony
115 arsenic
117 beryllium
118 cadmium
119 chromium
120 copper
122 lead
123 mercury
124 nickel
125 selenium
126 silver
127 thallium
128 zinc
Subtotal
121 cyanide
NONCONVENTIONAL TOXICS
acetone
benzoi c acid
hexanoic acid
n-docosane
n-dodecane (N-C12)
n-eicosane (N-C20)
n-hexacosane (N-C26)
n-octacosane
o-cresol
p-cresol
safrole
tripropyleneglycol methyl ether
2-butanone (MEK)
2- benzothiazole

0.0
0.0
0.0
0.0
0.0
0.4
0.4
0.2
0.0
0.0
1.1
0.2
0.0
0.0
0.0
0.0
3.3
1.5
0.0
0.0
0.0
0.0
0.0
3.1
8.1
0.0

0.0
22.2
0.2
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0

0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
3.3
1.5
0.0
0.0
0.0
0.0
0.0
3.1
7.9
0.0

0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0



0.0
32.0
5.8
5.1
0.0
0.5
1.8
505.0
0.1
0.2
47.6
0.3
0.1

1.1















-


0.7
0.4
0.0
0.6
0.7
0.8
0.9
0.6
0.5
0.5
0.8
0.0
0.8

0.7


















0.0
0.0
0.0
0.0
0.0
1.5
2.7
0.0
0.0
0.0
0.0
0.0
0.2
4.4
0.0















   Subtotal
                               22.4
  0.0
                               367

-------
                                  Table X-41  (Continued)

                             POLLUTANT  REDUCTION  ESTIMATES
                        NORMAL PLANT  LOAD  -  RADIATOR  SHOPS
    Total Flow (gallons/year):
            25,080





Pollutant

aluminum
barium
boron
calcium
cobalt
iron
magnesium
manganese
Molybdenum
sodium
tin
titanium
vanadium
yttrium
Subtotal


(1)
Total
Raw Waste
(Ibs/yr)

2.6
0.0
22.4
8.1
0.0
7.5
2.2
0.0
0.0
438.2
0.2
0.0
0.0
0.0
481 .4

(2)
Removals
Due to
Treatment
(Ibs/yr)

2.2
0.0
22.4
0.0
0.0
7.5
0.0
0.0
0.0
0.0
0.2
0.0
0.0
0.0
32.3

(4)
(3) POTW
Toxic Removal
Weighting (for
Factor indirects)

0.0
0.0
0.2!
O.CI
0.11
O.CI
O.CI
O.CI
0.2!
0.0
0.3
0.0
0.6
0.0

(6)
(5) At -Stream
Direct Indirect
Discharger Discharger
Removals Removals
Ubs-eq/yrXlbs-eo/yr)

0.1 0.1
0.0 0.0
4.0 4.0
0.0 0.0
0.0 0.0
0.0 0.0
0.0 0.0
0.0 0.0
0.0 0.0
0.0 0.0
0.1 0.1
0.0 0.0
0.0 0.0
0.0 0.0
4.2 4.2
OTHER NONCONVENTIOtiAL POLLUTANTS
          acidity
          alkalinity
          chemical  oxygen demand
          chloride
          fluoride
          phenol, total
          sulfate
          total  dissolved solids

        Subtotal

    CONVENTIONAL POLLUTANTS
          oil and grease
          total  suspended solids

        Subtotal
     0.0
   627.0
22,175.6
   120.1
     9.7
     0.2
   121.4
 1,642.3

24,696.3
   278.5
    12.8

   291.3
  0.0
  0.0
  0.0
  0.0
  5.9
  0.0
  0.0
  0.0

  5.9
276.1
 12.1

288.2
    TOTAL
  25,501
                                                           334
  (1) End-of-pipe pollutant discharge* (in pounds).
  (2) Annual removals (in pound*) with oil skiMing. chemical precipitation, sediMintation, and filtration.
  (3) Toxicity of pollutant relative to an equivalent MM of copper.
  (4) Pollutant-specific renoval efficiency for POTU treatment (applied to indirrect dischargers).
  (5) Annual rssnvels for direct dischargers in pounds-equivalent.  Coltan (2) u Coluan (3).
  (6) Annual removals for indirect dischargers in pounds-equivalent.  Coluei (2» x Colusn (3)  x (1-Coluan (4)).
                                                   368
                                                                  nii: iiI,.!> :' nii'i!iiiiiiiiii!,Mii .:, „ iiunir/j''!!!	Ki

-------
                            Table X-42

                POLLUTANT REDUCTION  ESTIMATES
         NORMAL  PLANT  LOAD  - AIRCRAFT  REBUILDING
TOTAL FLOW (gallons/year):
Pollutant
63,800,000                                       <6)
            (2)              (4)       (5)     At-Strea*
   (1)     Removals     (3)     POTW     Direct    Indirect
   Total     Due to    IOX19   Removal  Discharger Discharger
 Raw Waste  Treatment Weighting   (for    Removals   Removals
 (Ibs/yr)   (lbs/yr>   Factor indirects) (Ibs-eq/yrXlbs-eq/yr)
PRIORITY POLLUTANTS

11.1,1,1-trichloroethane 47.1
13.1,1-dichloroethane 2.6
15.1,1,2,2-tetrachloroethane 982.5
21.2,4,6-trichlorophenol 7.0
23. chloroform 7.0
24.2-chlorophenol 5.7
25.1,2-dichlorophenol 6.4
27.1,4-dichlorobenzene 0.4
34.2,4-dimethylphenol 0.7
38.ethylbenzene 26.0
44.methylene chloride 2,295.5
48.bromodichloromethane 0.4
55. naphthalene 70.8
65. phenol 1,578.5
66. bis (2-ethylhexyl) phthl. 1.5
67. butyl benzyl phthalate 5.1
68.di-n-butyl phthalate 0.9
73.benzo (a) pyrene 0.0
79.benzo (ghi) perylene 0.2
82.benzo (a,h) anthracene 0.0
SS.tetrachloroethene 8,884.3
86. toluene 0.0
Subtotal
U A+ a 1 «••»•»»•»•«».
114. antimony
115. arsenic
117. beryllium
11 8. cadmium
11 9. chromium
120. copper
122. lead
123. mercury
124. nickel
125. selenium
126. silver
127. thallium
128. zinc
Subtotal
121 .cyanide
13,922.7
19.6
3.1
0.2
259.6
5,486.4
277.4
6,730.0
0.2
662.4
0.0
304.0
0.0
297.0
14,040.0
441.5

0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
228.4
5,441.7
28.6
6,679.0
0.0
522.1
0.0
259.4
0.0
150.3
13,309.3
411.6



0.0
32.0
5.8
5.1
0.0
0.5
1.8
505.0
0.1
0.2
47.6
0.3
0.1

1.1



0.7
0.4
0.0
0.6
0.7
0.8
0.9
0.6
0.5
0.5
0.8
0.0
0.8

0.7



0.0
0.0
0.0
1,162.6
145.1
13.3
11,688.2
0.0
47.5
0.0
12,346.5
0.0
7.6
25,410.9
443.3



0.0
0.0
0.0
453.4
50.8
2.1
935.1
0.0
23.3
0.0
2,716.2
0.0
1.7
4,182.6
133.0
                                    369

-------
                                                                                 HI '• ":''ills,']! „ Jin,"1;!!1 „;.(.I
                                                                                 'i	i V iiifli1'" iiiiBj,	i-
                                                                                 '' 'V ' I'1,;"!1!1!  '"''liil''.!.!"':;':";
                                                                                   li'.^dtt.'W 	
                      Table  X-42   (Continued)

                  POLLUTANT REDUCTION  ESTIMATES
          NORMAL  PLANT LOAD  - AIRCRAFT  REBUILDING
TOTAL FLOW (gallons/year):
Pollutant
63,800,000                                         (6)
 '    .     '   (2>,               <*>        (5)     At-Strea*
   <1>      Removals    <3>     POTW      Direct    Indirect
   Total    Due to     Toxic    Removal  Discharger Discharger
 Raw  Waste  Treatment Weighting   (for     Removals   Removals
 (Ibs/yr)   (Ibs/yr)  Factor  indirects) 
NONCONVENTIOMAl TOXICS

200. acetone 960.7
210.benzoic acid 2.9
211. benzyl alcohol 1.5
212.biphenyl o.O
234.hexanoic acid 70.8
245.n-decane 0.7
246.n-docosane o.O
247.n-dodecane 4,200.0
248.n-eicosane 6.8
249.n-hexacoaane 0.7
250.n-hexadecane 8.6
257.n-octaconane 0.4
258.n-octadecane 12.3
259.n-tetracosane 0.9
260.n-tetradecane o.O
263.o-cresol 0.9
273.p-cresol 6.8
274.p-cymene 116.4
311.2,4,5-trichlorophenol 40.5
318.2-butanone 1,105.5
323.2-methylriaphthalene 3.7
Subtotal 6,540.2
Hot-Hi a---- ------------
SOO.aluninum
501. barium
502.boron
503. calcium
504. cobalt
505. iron
506. magnesium
**A«V '
507. manganese
SOS.molybdenuM
509.sodium
STO.tin
511. titanium
512.vanadium
513.yttriu«
Subtotal

948.6
13.0
11,093.1
14,247.0
33.9
1,142.9
876.9
207.0
233.4
150,751.7
0.4
8.4
0.0
0.0
179,556.3

0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0

0.0
0.0
10,863.4
0.0
12.1
964.3
0.0
117.7
0.0
0.0
0.0
0.0
0.0
0.0
11,957.4

.1 '! pi1

0.0
0.0
0.2
0.0
0.1
0.0
0.0
0.0
0.2
0.0
0.3
0.0
0.6
0.0




0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0


I, ' • . i r i , •, •! i , •;

0.0
0.0
1,925.0
0.0
1.8
5.4
0.0
1.7
0.0
0.0
0.0
0.0
0.0
o.o
1,933.9



0.0
0.0
1,925.0
0.0
1.8
5.4
0.0
K7
0.0
0.0
0.0
0.0
0.0
0.0
1,933.9
                                    370

-------
                              Table  X-42  (Continued)

                         POLLUTANT  REDUCTION ESTIMATES
                 NORMAL PLANT LOAD - AIRCRAFT REBUILDING
       TOTAL FLOW (gallons/year):
       Pollutant
 63,800,000                                             (6)
               (2)                <4)        <5>     At-Strea»
    (1)      Removals    (3)      POTU      Direct    Indirect
   total     Due to    Toxic    Removal  Discharger Discharger
  Raw Waste  Treatment Weighting   (for     Removals   Removals
  (Ibs/yr)     Factor  indirects) (lbs-eq/yr)(lbs-eq/yr)
OTHER NONCONVENTIONAL POLLUTANTS
acidity
alkalinity
chemical oxygen demand
chloride
fluoride
phenols, total
phosphate
sulfate
total dissolved solids

43,881.6
44,206.6
238,892.5
950,319.7
33,425.0
3,895.1
1,545.7
21.6
70,561.3

0.0
0.0
0.0
0.0
24,174.0
0.0
0.0
0.0
0.0
       Subtotal
1,386,749.1   24,174.0
CONVENTIONAL POLLUTANTS
          oil and grease
          total suspended solids

       Subtotal
  135,788.8  129,408.8
  135,880.8  134,222.0

  271,669.6  263,630.8
TOTAL
         BS3SSSSSSSSXS

  1,872,919    313,483
27,788
6,249
(1) End-of-pipe pollutant discharge* (in pound*}.
(2) Annual removal* (in pound*) with oil iktaing, chearical precipitation,  MdiMntation,  and filtration
(3) Toxicity of pollutant relative to an equivalent MM of copper.
(4) Pollutant-specific removal efficiency for POTU treatment (applied to indirrect discharger*).
(5) Annual removal* for direct discharger* in pounda-equivalerit.  Colion (2) x Colwn (3).
(6) Annual removal* for indirect discharger* in pound*-equivalent.  Coluan (2) x ColMn (3) x (1-Colum
                                               371

-------
                                       Table  X-43


                         POLLUTANT REDUCTION  ESTIMATES
                NORMAL PLANT  LOAD -  AIRCRAFT  MAINTENANCE
    TOTAL FLOW (gallons/year):
    Pollutant
 616,000                                           (6)
            <2>                (4)       (5)    At-Stream
  (1)     Removals     (3)      POTW     Direct   Indirect
  Total    Due to     Toxic    Removal  Discharger Discharger
Raw Waste Treatment Weighting   (for    Removals  Removals
(Ibs/yr)  (Ibs/yr)   Factor  indirects) (Ibs-eq/yrXlbs-eq/yr)
 PRIORITY POLLUTANTS
    Organic*	-	
     19.2-chloroethylvinyl ether         987.6        0.0
     20.2-chloronaphthnlene              326.7        0.0
     23.chloroform                        0.0        0.0
     38.ethylbenzene                      5.1        0.0
     55.naphthalene                     281.2        0,0

    Subtotal                          1,600.5        0.0
    Metals	
    114.antimony
    117-berylliw
    118.cadium
    119.chromium
    120.copper
    122.lead
    124.nickel
    125.selenium
    126.silver
    128.zinc

    Subtotal
0.4
0.0
14.1
2.0
67.1
3.1
2.6
0.0
0.0
13.0
0.0
0.0
13.9
1.5
64.7
2.6
1.3
0.0
0.0
11.7
0.0
5.8
5.1
0.0
0.5
1.8
0.1
0.2
47.6
0.1
0.7
0.0
0.6
6.7
0.8
0.9
0.5
0.5
0.8
0.8
0.0
0.0
70.6
0.0
30.2
4.6
0.1
0.0
0.0
0.6
0.0
0.0
27.5
0.0
4.8
0.4
0.1
0.0
0.0
0.1
                                       102.3
             95.7
                                                                             106.1
                                                                                        32.9
NONCOHVENTIOMAL TOXICS
    Organic*	
    200.acetone
    205.alpha-terpineol
    220.dibenzofuran
    Pesticides--—	
    410.couiMtphos
    433.lectophos
    450.tetrachlorvinphos
   52.4
  126.9
   10.3
    0.4
    0.0
   29.9
0.0
0.0
0.0
0.0
0.0
0.0
   Subtotal
                                      220.0
                                                  0.0
                                             372

-------
                               Table  X-43   (Continued)

                          POLLUTANT REDUCTION  ESTIMATES
                 NORMAL,  PLANT LOAD -  AIRCRAFT  MAINTENANCE
   TOTAL FLOW {gallons/year):
    Pollutant
 616,000
            <2>                <4>
  (1)    Removals     (3)     POTU
  Total    Due to     Toxic   Removal
Raw Waste Treatment Weighting  (for
(lbs/yr>  (Ibs/yr)   Factor  indirects)
                                                                               (5)     At-Stream
                                                                             Direct    Indirect
                                                                           Discharger Discharger
                                                                            Removals   Removals
                                                                           < Ibs-eq/yrX Ibs-eq/yr)

500. aluminum-
501 .barium
502. boron
503. calcium
504. cobalt
505. iron
5 06. magnesium
507.manganese
5 08. molybdenum
509. sodium
510. tin
511. titanium
512. vanadium

23.1
2.6
0.7
160.2
0.0
52.4
57.6
1.1
77.9
2,587.2
0.2
1.1
0.2

13.9
0.9
0.0
0.0
0.0
50.6
0.0
0.2
70.4
0.0
0.0
0.2
0.0

0.0
0.0
0.2
0.0
0.1
0.0
0.0
0.0
0.2
0.0
0.3
0.0
0.6

0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0

0.5
0.0
0.0
0.0
0.0
0.3
0.0
0.0
14.2
0.0
0.0
0.0
0.0

0.5
0.0
0.0
0.0
0.0
0.3
0.0
0.0
14.2
0.0
0.0
0.0
0.0
    Subtotal
 2,964.3
                                                   136.2
                                                                                 15.0
                                                                                            15.0
OTHER NOMCONVENTIONAL POLLUTANTS
        ammonia, as N                      0.0       0.0
        BOD 5-day (carbonceous)        74,536.0       0.0
        chemical oxygen demand       185,104.9       0.0
        fluoride                           6.2       0.0
        nitrogen, kjeldalhl,  tot.          86.2       0.0
        nitrate-nitrite, as N             14.1       0.0
        sulfide, total                    31.0       0.0
        total dissolved solids        87,472.0       0.0
        total organic carbon          125,356.0       0.0
        total phosphorus, as  P         1,139.6       0.0

    Subtotal                         472,746.0       0.0
CONVENTIONAL POLLUTANTS
        oil  and grease
        total suspended solids

    Subtotal
    TOTAL
 45,584.0   45,522.4
  4,712.4    4,696.3

 50,296.4   50,218.7
                                            ==s=======sa=====:
                                       528,930     50,451
                                                                                              48
 [II Sn^l'?iS^l.lOrSo^%?S oil SE.& che.ic.1 precipitation. Md1«nt.t1on. and filtration
 <3) Toxicity of pollutant relative to an equivalent MM of copper.               ,«,,4,..M,.«v
 (4) PollutJrt-»p5cific r-ov.l efficiency for POTUtreat»ent  <*PP"«I to  ^"Sl^^? ^
  x Col"jnz   MiCol|_
 (6) Annual removal* for indirect discharger* In poun*-equ1valent.  Coluw <2> x Coluw (3) x (1-Coluw
                                                 373

-------
                            Table  X-44


              POLLUTANT REDUCTION ESTIMATES
       NORMAL PLANT LOAD  -  RAILROAD REBUILDING
    Total Flow (gallons/year):
 Pollutant
   5,280,000

               	:; •.:;.•• •; ;.  •   „ (6)
          (2)             (4)       (5)     At-Stream
  (1)    Removals    (3)    POTM     Direct     Indirect
  Total    Ou« to   toxic    Reaovai Discharger  Discharger
Raw Waste Treatment Weighting  (for    Removals    Removals
  (Ibs/yr)  Factor  indirect*) Ubs-eq/yr)
PRIORITY POLLUTANTS
10. 1,2-dichloroethane
11. 1,1,1-trichloroethane
20. 2-chloronaphthalene
23. chlorofor*
44. nethylene chloride
55. naphthalene
57. 2-nitrophenol
59. 2,4-dinitrophenol
65. phenol
66. bis (2-ethylhexyl) phthalate
68. df-n-butyl phthalate
78. arithraeent
81. pnenanthrene
86. toluene
87. trichloronthene
Subtotal

114. antiMony
115. arsenic
117. beryUtua
118. cadiij*
119. chroniuB
120. copper
122. lead
123. Mercury
124. nickel
125. seleniua
126. silver
127. thalliiM
128. zinc
Subtotal
121. cyanide
NONCONVENTIOKAL TOXICS
200. acetone
205. alpha-terpineol
206. aniline
210. benioic acid
212. biphenyl
234. hexanoic tcid
245. n-decane
246. n-docosane
247. n-dodecane
248. n-eico*ane
249. n-hexacosane
250. n-hexadecane
257. n-pctacosane
258. n-octadecan*
259. n-tetracotan*
260. n-tetradecane
261. n-triacontane
274. p-cynene
286. tripropyleneglycol nethyl et
304. 1-Mthylphenanthren*
318. 2-butanone
323. 2-awthylnaphthalen*
324. 2-nftroaniline
340. 4-Mthyl-2-penatmon*

0.0
0.4
0.0
0.0
531.5
0.2
0.0
0.0
84.5
0.2
72.2
0.0
0.0
0.0
0.0
689.0

0.0
0.0
0.0
0.7
17.6
146.1
55.4
0.0
0.9
0.0
0.0
0.0
134.0
354.6
0.0

9.2
0.0
0.0
56.3
0.2
5.7
0.2
0.7
2.0
0.2
0.4
0.4
0.2
0.0
1.8
0.0
15.6
0.0
0.0
0.0
0.0
0.2
0.0
0.0

0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0

0.0
0.0
0.0
0.0
13.9
125.4
51.3
0.0
0.0
0.0
0.0
0.0
121.9
312.4
0.0

0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0



0.0
32.0
5.8
5.1
0.0
0.5
1.8
505.0
0.1
0.2
47.6
0.3
0.1

1.1























".'.'.":'.: "


0.7
0.4
0.0
0.6
0.7
0.8
0.9
0.6
0.5
0.5
0.8
0.0
0.8

0.7
























t

0.0
0.0
0.0
0.0
0.4
58.5
89.7
0.0
0.0
0.0
0.0
0.0
6.2
154.8
0.0


























0.0
0.0
0.0
0.0
0.1
9.4
7.2
0.0
0.0
0.0
0.0
0.0
1.4
18.0
0.0























Subtotal
                               93.3
                                       0.0
                                  374

-------
                           Table  X-44   (Continued)

                      POLLUTANT  REDUCTION  ESTIMATES
             NORMAL  PLANT  LOAD  -  RAILROAD  REBUILDING
  Total Flow (gallons/year):
                                   5,280,000
  Pollutant
  Metals	-•
  500. aluminu*
  501. ban" UK
  502. boron
  503. calcium
  504. cobalt
  505. iron
  506. magnesium
  507. manganese
  508. molybdenum
  509. sodium
  510. tin
  511. titanium
  512. vanadium
  513. yttrium

  Subtotal
                                               (2)                <4>        <5>
                                     (1)     Removals    (3)      POTU      Direct
                                     Total     Due to   Toxic    Removal  Discharger
                                   Raw Waste Treatment Weighting   (for     Removals
                                                   C6>
                                                At-Strt**
                                                 Indirect
                                                Discharger
                                                 Removals
                                   (Ibs/yr)   (lbs/yr>  Factor  indirects) (lbe-eq/yr)(lbs-eq/yr>
    42.5
    25.5
    51.3
  1,689.8
     0.4
   517.4
   647.9
     6.8
     0.9
 37,067.8
     3.1
     2.0
     0.0
     0.0
  0.0
 10.8
 32.3
  0.0
  0.0
502.7
  0.0
  0.0
  0.0
  0.0
  0.0
  0.0
  0.0
  0.0
0.0
0.0
0.2
0.0
0.1
0.0
0.0
0.0
0.2
0.0
0.3
0.0
0.6
0.0
 40,055.4     545.8
0.0
0.0
5.7
0.0
0.0
2.8
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0

8.6
0.0
0.0
5.7
0.0
0.0
2.8
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0

8.6
OTHER NONCOHVEHTIONAL POLLUTANTS
       acidity
       alkalinity
       chemical oxygen demand
       chloride
       fluorid*
       phenols, total
       phosphate
       sulfate
       total dissolved solids
       biological oxygen demand

   Subtotal

CONVENTIONAL POLLUTANTS
       oil and grease
       total suspended solids

   Subtotal
  4,166.8
 85,398.9
339,264.4
  7,111.3
     82.7
     12.3
      0.0
 16,538.1
180,682.0
      3.6

633,260.2
  0.0
  0.0
  0.0
  0.0
  0.0
  0.0
  0.0
  0.0
  0.0
  0.0

  0.0
  2,525.6   1,997.6
 13,406.1  13.268.9

 15,931.7  15,266.5
TOTAL
                                      690,384    16,125
                                                                                163
                                                                                            27
 \2\ An^t^eSSvats1"*'"^)"-!" oil s£±ng. eh.le.1 precipitation, sedimentation, and filtration.
 (3) Toxicity of pollutant relative to an equivalent mass of copper.
 (4) Pollutant-specific removal efficiency for POTW treatment (applied to indirect dischargers).
 (5) Annual removals  for direct dischargers in pounds-equivalent.  Column (2) x Column (3>.
 (6) Annual removals  for indirect dischargers in pounds-equivalent.  Coluan (2) x Colu«n (3) x (1-Column (4)).
                                                 375

-------
                                             111 :. "i 15'SV	'!•
                        Table X-45

             POLLUTANT REDUCTION ESTIMATES
      NORMAL  PLANT  LOAD - RAILROAD MAINTENANCE

Total Flow (galtone/year):   15,400,000
Pollutant
PUIORITY POLLUTANTS
1 acenaphthene
2 acetone
11 1,1,1-trichloroethane
44 methytene chloride
55 naphthalene
57 2-nitrophenol
59 2.4-dinitrophenol
65 phenol
68 di-n-butyl phthalate
80 fluorene
80 phenanthrene
84 pyrene
86 toluene
87 trichloroethene
Subtotal

114 antimony
115 arsenic
117 berylliua
118 cadMiuM
119 chromiua
120 copper
122 lead
123 mercury
124 nickel
125 seleniui
126 silver
127 thallium
128 zinc

Subtotal

121 cyanide
' i 'ii' ' ,,

HONCOHVEHTIOHAL TOXICS

aniline
benzoic acid
dibenzofuran
n-decane
n-docosane
n-dodecane
n-eicotane
n-hexadecane
n-hexacotane
n-octadecane
n-triacontane
n-tetracosane
n-tetradecane
o-crcaol
p-cresol
p-cymene
1 -methylphenanthrene
2-butanone
2-methylnaphthalene
2-nitroaniline
(2) (4) (5) At-Stream
(1) Removals (3) POTW Direct Indirect
Total Due to Toxic Removal Discharger Discharger
Raw Waste Treatment Weighting (for Removals Removals
Clbs/yr) (Ibs/yr) Factor indirects) (Ibs-eq/yrXlbs-eo/yr)

185.5
51.9
6.8
5.7
152.5
0.4
1.1
108.5
0.7
142.3
227.7
1,350.4
2.4
3.1
2,238.9

0.0
2.2
1.5
11.2
174.9
120.1
125.8
0.0
14.1
0.0
0.0
0.0
247.3

697.2

0.0
r j i \



0.2
1.3
60.9
656.0
786.1
14,498.0
6,669.7
7,484.2
230.3
2,593.4
636.5
1,368.8
4,830.8
0.0
0.0
1,390.0
2,988.7
10.6
0.0
0.2
- 1, -*,- --fff- ---,---, --f-~- 	 -J-TF7--rr-----
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0

0.0 0.0 0.7 0.0
0.0 32.0 0.4 0.0
0.0 5.8 0.0 0.0
3.7 5.1 0.6 19.0
164.1 0.0 0.7 4.4
60.1 0.5 0.8 28.0
113.5 1.8 0.9 198.7
0.0 505.0 0.6 0.0
0.0 0.1 0.5 0.0
0.0 0.2 0.5 0.0
0.0 47.6 0.8 0.0
0.0 0.3 0.0 0.0
211.9 0.1 0.8 10.8
i" .' '' „',' , • : ">-, ;'\ ••••:,•• i I
553.3, ' , , ilr 	 ,260.9,,,
.;; . »'• , ( '''.,•,, jtri,,1''?1^'! ' 	
0.0 1.1 0.7 , 0.0
'' '''/ 1' '! '," ' -Ii , 'l:'" fi,1!!' ' '. '•• ! ' .
s " 	 , ' '.. "I- , , ":;::,;,; " i .,


0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0

















0.0
0.0
0.0
7.4
1.5
4.5
15.9
0.0
0.0
0.0
0.0
0.0
2.4

31.7

0.0
























   Subtotal
                     44,205.7
0.0
                                 376

-------
                                Table  X-45  (Continued)

                           POLLUTANT  REDUCTION  ESTIMATES
                 NORMAL  PLANT  LOAD  - RAILROAD MAINTENANCE
    Total  Flow (gallons/year):
 15,400,000





Pol lutant

aluminum
barium
boron
calcium
cobalt
iron
magnesium
manganese
molybdenum
sodium
tin
titanium
vanadium
yttrium
Subtotal


(1)
Total
Raw Waste

-------
                            Table X-46

                  POLLUTANT REDUCTION ESTIMATES
      NORMAL PLANT LOAD - OFFICE  MACHINE MANUFACTURING
    Total Flow (8*1Ions/year):
24,200,000
                                                                   (6)
                                                   <4)      (5)    At-Stream
Pollutant
PRIORITY POLLUTANTS
Total
Raw Waste
(Ibs/yr)

7. chlorobenzene 14.5
U. 1,1,1-trichloroethane 0.7
38. ethyl benzene 0.4
44. methylene chloride 1.3
66. bis (2-ethylhexyl) phthalate 136.9
71. dimethyl phthalate 1.1
86. toluene 0.7
87. trichloroethene 3.3
Subtotal 158.9

114. antimony
115. arsenic
117. beryllium
118. cadmium
119. chromium
120. copper
123. mercury
122. lead
124. nickel
125. selenium
126. silver
127. thallium
128. zinc
Subtotal
121. cyanide
MONCONVENTIOHAL TOXICS

200. acetone
258. n-octadecane (N-C18)
279. styrene
318. butanone (HEK)

0.2
2.9
3.1
13.2
10,231.4
401.3
45,6
145.0
821.9
1.1
3.1
76.5
8,073.5
19,818.8
1.3


6.8
583.8
3.5
32.0
Removals (3) POTW Direct Indirect
Due to Toxic Removal Discharger Discharger
Treatment Weighting (for Removals Removals
(Ibs/yr) Factor indirects)(lbs-eq/yrXlbs-eq/yr)
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0

0.0
0.0
0.0
1.3
10,214.4
306.8
36.8
125.6
768.5
0.0
0.0
0.0
8,017.7
19,471.2
0.0


0.0
0.0
0.0
0.0

• "• :
0.0
32.0
5.8
5.1
0.0
0.5
505.0
1.8
0.1
0.2
47.6
0.3
0.1

1.1







"• 	
0.7
0.4
0.0
0.6
0.7
0.8
0.6
0.9
0.5
0.5
0.8
0.0
0.8

0.7








0.0
0.0
0.0
6.7
272.4
143.2
18,588.3
219.8
69.9
0.0
0.0
0.0
408.2
19,708.5
0.0








0.0
0.0
0.0
2.6
95.3
22.9
7,435.3
17.6
34.3
0.0
0.0
0.0
89.8
7,697.8
0.0






Subtotal
                             626.2
         0.0
                                  378
                                                  .1	

-------
                                 Table  X-46  (Continued)

                            POLLUTANT REDUCTION ESTIMATES
            NORMAL PLANT  LOAD  - OFFICE MACHINE  MANUFACTURING
        Total  Flow
                                                3,000




Pollutant

aluminum
barium
boron
calcium
cobalt
iron
magnesium
manganese
molybdenum
sodium
tin
titanium
vanadium
yttrium

(1)
Total
Raw Waste
.(lbs/yr)

17,420.4
65.9
1,199.0
13,271.4
5.3
16,439.4
3,731.2
126.1
20.5
57,862.1
674.4
9.3
13.9
2.0

Removals
Due to
Treatment
(lbs/yr)

17,059.2
0.0
1,111.7
0.0
0.0
16,371.5
0.0
92.1
0.0
0.0
640.5
0.0
0.0
0.0

(3)
Toxic
Weighting
Factor

0.0
0.0
0.2
0.0
0.1
0.0
0.0
0.0
0.2
0.0
0.3
0.0
0.6
0.0
(4) (5) At-Streara
POTW Direct Indirect
Removal Discharger Discharger
(for Removals Removals
indirects)(lbs-eq/yr)(lbs-eq/yr)

636.3 636.3
0.0 0.0
197.0 197.0
0.0 0.0
0.0 . 0.0
91.7 91.7
.'.', ,0.0 0.0
1.3 1.3
0.0 0.0
0.0 0.0
192.8 192.8
0.0 0.0
0.0 0.0
0.0 0.0
   Subtotal
  110,840.7   35.275.0
                                                                                  1.119.2    1.119.2
OTHER NONCONVENTIONAL POLLUTANTS
   acidity                               2,476.9        0.0
   alkalinity                           54.104.5        0.0
   chemical  oxygen demand             4,468,869.2        0.0
   chloride                               4,538.9        0.0
   fluoride                               1.249.2        0.0
   phenols,  total                             5.5        0.0
   phosphate,  total                       2,643.7        0.0
   sulfate                              21,604.5        0.0
   total dissolved solids             1,637,037.8        0.0

   Subtotal                           6,192,530.1        0.0
CONVENTIONAL POLLUTANTS
   oil and grease
   total  suspended solids

   Subtotal
2,183,289.2 2,180,864.8
   44,324.6    43,694.3

2,227,613.9 2,224,559.1
TOTAL
  8,551,590   2,279,305
20.828
8,817
  (1) End-of-pipt pollutant discharge* (in pound*).
  (2) Annual removals (in pounds) with oil sktalnf. chearical precipitation, sediaMntation,  and filtration.
  (3) Toxicity of pollutant relative to an equivalent MM of copper.
  (4) Pollutant-specific removal efficiency for POTU treatment (applied to indirreet dischargers).
  (5) Annual removals for direct discharger* in pounfc-equivalent.  Coluan (2) x Coluan (3).
  (6) Annual removals for indirect discharger* in paundc-equivalent.  Coluen (2) x Column (3) x (1-Coluan (4)).
                                                   379

-------
                       Table X-47

             POLLUTANT REDUCTION  ESTIMATES
   NORMAL  PLANT  LOAD -  OFFICE MACHINE REBUILDING
    TOTAL FLOW (gallons/year):   396,000
Pollutant
PRIORITY POLLUTANTS
(1) Removals
Total Due to
Raw Waste Treatment
(Ibs/yr) (Ibs/yr)

4. benzene 0.0
11. 1,1,1-trichloroethane 88.2
13. 1,1-dichloroethane 0.2
15. 1,1,2,2-tetrachloroethane 0.0
22. 4-chloro-3-methylphenol 0.0
23. chloroform 0.0
29. 1,1-dichloroethene 7.0
39. fluoranthene 0.0
44. methylene chloride 820.4
55. naphthalene 0.0
57. 2-nitrophenol 0.0
60. 4,6-dinitro-o-cresol 0.0
63. n-nltrododi-n-propylorainc 0.4
66. bis(2-ethylhexyl) phthalate 0.0
67. butyl benzyl phthalate 0.0
68. di-n-butyl phthalate 0.0
70. diethyl phthalate 0.0
71. dimethyl phthalate 0.0
85. tetrachloroethylene 0.0
86. toluene 0.2
87. trichloroethylene 0.0
Subtotal
114. antimony
115. arsenic
117. beryl Hun
118. cadmiUM
119. chroaiiua
120. copper
122. lead
123. Mercury
124. nickel
125. scleniui
126. silver
127. thalliu*
128. zinc
Subtotal
121. cyanide
HONCOKVEMTIOHAL TOXICS

200. acetone
205. alpha-terptneol
206. aniline
212. biphenyl
260. n-tetradecane 
-------
                               Table  X-47   (Continued)


                          POLLUTANT REDUCTION  ESTIMATES
            NORMAL PLANT  LOAD -  OFFICE MACHINE  REBUILDING
           TOTAL  FLOU (gallons/year):
396,000
Pollutant

aluminum
barium
boron
calcium
cobalt
iron
magnesium
manganese
molybdenum
sodium
tin
titanium
vanadium
yttrium
(6)
(4) (5) At-Stream
(1) Removals (3) POTU Direct Indirect
Total Due to Toxic Removal Discharger Discharger
Raw Waste Treatment Weighting (for Removals Removals
< Ibs/yr) (Ibs/yr) Factor indirects) (Ibs-eq/yrXlbs-eq/yr)

2.4
0.2
0.2
160.8
0.0
16.9
39.6
0.0
0.0
151.4
0.0
0.0
0.0
0.0

0.0
0.0
0.0
0.0
0.0
15.8
0.0
0.0
0.0
0>Q
0.0
0.0
0.0
0.0

0.0
0.0
0.2
0.0
0.1
0.0
0.0
0.0
0.2
0.0
0.3
0.0
0.6
0.0

0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0

0.0
0.0
0.0
0.0
0.0
0.1
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0

0.0
0.0
0.0
0.0
0.0
0.1
0.0
- 0.0
0.0
0.0
0.0
0.0
0.0
0.0
       Subtotal
                                        371.6
                                                   15.8
                                                                                0.1
                                                                                           0.1
OTHER HONCONVENTIONAL POLLUTANTS
       acidity                            115.5      0.0
       alkalinity                         763.6      0.0
       chemical oxygen demand            5,557.0      0.0
       chloride                           503.4      0.0
       fluoride                           33.2      0.0
       nitrate                             0.2      0.0
       phenols, total                       0.7      0.0
       phosphate, total                     0.4      0.0
       sulfate                          2,041.6      0.0
       total dissolved solids            2,919.4      0.0

       Subtotal                        11,935.0      0.0
CONVENTIONAL POLLUTANTS
       oil and grease
       total suspended solids

       Subtotal
TOTAL
  891.7
  145.0

 1,036.6



  14,343
852.1
134.6

986.7
1,007
                                                                                 32
(1) End-of-pipe pollutant discharges (in pounds).
(2) Annual removals (in pounds) with oil skimming,  chemical precipitation,  sedimentation, and filtration.
(3) Toxicity of pollutant relative to an equivalent mas* of copper.
(4) Pollutant-specific removal efficiency for POTU  treatment (applied to indirrect dischargers).
(5) Annual removals for direct dischargers in pounds-equivalent.  Column (2) x Column (3).
(6) Annual removals for indirect dischargers in pounds-equivalent.  Column  (2) x Column (3) x (1-Column (4)).
                                                  381

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