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ratio exceeds 100 percent, it is possible that debt will
have to be issued. Ratios in excess of 100 percent do not,
however, necessarily indicate- that capital costs are
unwieldy. For example, a ratio of 500 percent simply
signifies that it would take five years of cash flow to
finance the capital costs. A ratio of 100 percent is used
as a conservative threshold of the potential need for
external financing.
The ratio of capital costs to total assets is also
the ratio of the change in liabilities (i.e. the additional
liability of purchasing pollution control equipment) to
total assets. In this case, the total asset base is assumed
to be constant. Implied by a constant asset base is that
the purchase of pollution control equipment is a non-
productive investment. Since the installation of control
equipment can in some cases lead to net savings as emissions
are reduced, control equipment does .in some cases add to the
firms productive capacity. However, only those situations
in which annualized control costs are positive will be
examined here.
The ratio of capital costs to total assets gauge the
impact on a facility's capital structure. If the ratio of
capital costs to total assets is greater than 10 percent, it
may be difficult to obtain financing for at least some
facilities. Clearly, there will be some highly leveraged
firms which will be limited to expanding liabilities by this
much, and others which can take on even greater amounts of
debt. However, 10 percent is assumed here to be an
appropriate average where some facilities have difficulty
obtaining external financing.
As shown, facilities in SICs 254, 259, and 367 have
ratios of capital costs to BTNI in excess of 100 percent.
For each of these facilities, the ratio of• capital costs to
total assets is less than 10 percent (in fact, it is less
tha| six percent). Thus, it is concluded here that the
83
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average small facility will not be inhibited from obtaining
the external financing necessary to cover capital costs.
3-5.5 Impacts on Manufacturers of Decreasing
Equipment, in contrast to the negligible impact the
degreasing NESHAP will have on degreasing user industries,
the impacts on degreasing equipment be more significant. In
all likelihood, degreasing equipment manufacturers will
experience increases in demand for their products as a
result of the NESHAP.
Demand for degreasing equipment will come in three
areas. First, demand for organic solvent cleaners, (i.e.
OTVCs and in-line cleaners) will remain as users replace old
machinery and as firms enter user industries. These
. cleaners will differ from many cleaners currently in use in
that they are already equipped with emissions control
devices. While this replacement demand is probably no
larger than the demand that would exist in the absence of
the regulation, the machines have more value-added than
older machines. The second market niche for equipment
manufacturers is in the need for add-on control equipment.
Firms with existing equipment not in compliance will have to
retrofit. The third area of growth for equipment
manufacturers is in alternative systems — primarily
aqueous. Alternative systems can be thought of as
replacement demand as well. However, the replacement of an
organic-solvent system with an aqueous system signifies a
movement from a one-stage system to a three to four stage
system. The senior engineer at Precision tubes estimated
that replacing their forty-five square foot organic solvent
cleaner with an aqueous system would cost approximately one
million dollars. For these, reasons, demand for degreasing
equipment is apt to grow at rates faster than the demand for
degreasing users products. " "
Control equipment manufacturers may actually be hard
pressed to meet_the increased demand for control equipment.
84
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In a telephone survey conducted by JACA Corp. in 1987, two
major suppliers of degreasing equipment who also manufacture
control equipment were both found to be operating at more
than 80 percent of control equipment capacity. One of the
respondents said they could accommodate a "gradual switch"
to controlling degreasing equipment. If current capacity is
not sufficient to meet a sudden increased demand for control
equipment, additional capacity will have to be added, which
could take one or two years.45
3-5.6 Impacts on Solvent Manufacturers. While the
net effect of the degreasing NESHAP on equipment
manufacturers will be positive, the impact on solvent
manufacturers is 'less clear.
It is apparent at the outset .that the demand for
organic solvents should decrease, all else equal, since
emissions will be reduced. However, all else is not equal.
It first must be noted that demand for the regulated
solvents is only in part derived from degreasing end-users'
products. For TCE, TCA, MC, and PCE, degreasing end-uses
account for 90 percent, 52 percent, 15 percent, and 13
percent of total solvent consumption, respectively. Thus,
if demand for each of these solvents were reduced by the
same percentage, TCE would be the most adversely affected.
Several factors temper such a conclusion.
1,1,1, trichloroethane (TCA) is being phased out
under the Montreal Protocol, and will not be available for
use in degreasers. Thus, it can be said that the degreasing
NESHAP will have no impact on the TCA market, as it will not
be available in the baseline.
Trichloroethylene (TCE), due to its reliance on
degreasing end-uses, will indeed .experience reduced demand
by users already consuming TCE. Already, TCE has been
experiencing declining growth of about two percent annually
in vapor degreasing. However, due to its chemical
85
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similarity to TCA (e.g. similar specific gravities, similar
boiling points), TCE is the most likely halogenated solvent
candidate to replace TCA in existing degreasers. In
addition, TCE is being used as a feedstock for CFC
alternatives, which could also boost TCE growth. Also,
increased demand for TCE could lead to upward price
pressure. Thus, TCE can be expected to experience renewed
growth by the mid-1990s."
The extent of this growth will be determined largely
by the substitution choices made by the user industries. A
portion will surely move away from halogenated solvent use
altogether and into aqueous systems. In a survey conducted
by the Alliance of Metal Working Industries, the National
Screw Machine Products Association reported that their
members were already moving towards aqueous use in favor of
halogenated solvents, of those firms with less than $5
million in annual sales, eighty-four percent had indicated
they were investigating alternatives to halogenated solvents
(sixty percent were looking to aqueous systems). For firms
earning over $5 million in annual sales, eighty-three
percent were looking at alternatives (seventy-seven percent
•aqueous) ,47
As with the other regulated solvents, methylene
chloride will exhibit diminished growth stemming from
reduced emissions. Unlike TCE, MC is not seen as an ,
effective substitute for TCA. However, discussions with
Precision Tube Inc. indicate that they plan to replace their
Freon based cleaner with MC. Thus, there could be some
substitution into the MC market as a result of the Montreal
protocol. Nonetheless, in most end-uses, MC demand is
shrinking. The degreasing NESHAP is likely to accelerate
this trend to some extent.
Perchloroethylene (PCE) .is the least dependent of the
regulated solvents on degreasing end-uses. Again,
36
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degreasing end-uses will be reduced as a result of emissions
reduction. However, unlike MC, PCE does have end-uses that
should exhibit growth by mid-decade, most notably as a
feedstock for CFC replacement. Reduced demand for
degreasing consumption could be offset by increased demand
for CFC feedstock consumption. In addition, PCE holds more
than 75 percent of the market for solvent use in dry
cleaning. Therefore, on the whole PCE demand is likely to
remain relatively strong.
3'5'7 Small Business Impacts. The RFA (Public Law
(96-354, September 19, 1980) requires Federal agencies to
give special consideration to the impact of regulation on
small businesses. The RFA specifies that a regulatory
flexibility analysis must be prepared if a proposed
regulation will have (l) a significant economic impact on
(2) a substantial number of small entities. Regulatory
impacts are considered significant if:
- • Annual compliance costs increase total costs of
production by more than 5 percent
• Annual compliance costs as a percent of sales are at
least 10 percent (percentage points) higher for
small entities
• Capital cost of compliance represent a significant
portion of capital available to small entities
* • The requirements of the regulation are likely to
result in closures of small entities
A "substantial number" of small entities is generally
considered to be more than 20 percent of the small entities
in the affected industry. since this analysis deals only
with small entities, conclusions can be drawn from the above
sections. Each of the criteria for significant impacts will
be considered in turn.
Table 30 in section 3.5.3 presented control costs as a
percent of total costs of production for impacted facilities
in the relevant sics. Recall that the largest cost increase
87
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was 0.61 percent for SIC 359. This figure is well below the
significant-impact threshold of five percent.
Assessing the differential impacts, measured by a
comparison of compliance costs as a percent of sales for
small and large entities, is more problematical as large
model facilities were not modelled in this analysis.
Treatment of this small business impacts criterion involves
creating two large model facilities and employing the data
from Precision Tubes Inc. to serve as a third, "actual"
case.
If it is assumed that large facilities use large
degreasers, than compliance costs for large facilities are
actually savings, as estimated by RADIAN Corp. To be
conservative, it is assumed here that large model facilities
possess five very large degreasers, so that a "maximum
savings" case is modelled. This case is important as it
models the maximum cost differential between large and small
entities. The selection of five degreasers as a
conservative number is based on the 1976 Dow Chemical study
referenced earlier, which found that the average number of
open-top and conveyorized degreasers in facilities with 500-
or more employees was 3.76.
Large model facilities were created for SICs 359 and
254. SIC 359 was chosen because the small model facilities
in this group experience the highest cost absorption impact
when compared with other small model facilities, in SIC
254, firms with greater than 100 employees had the smallest
average per-facility revenue when compared with firms of
greater than 100 employees in other SICs. Thus, if firms in
SIC 254 incur the same dollar- value of savings as other
large firms in .other SICs, their savings as a percent of
avergae per-facility revenue will be the higher than the
38
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other large firms. Finally, the actual case of Precision
Tubes Inc. is used. Precision tubes reports to SIC 335.
Table 33 displays the comparison of cost absorption for
small and large model facilities. Presented are the average
per-facility revenues, the percent cost absorption (negative
for the large facilities as they incur savings), and
thepercentage point differential of cost absorption between
small and large facilities. As shown, the cost
differentials are in no case larger than one percentage
point, much less ten percentage points. Thus, by this
criterion, small business impacts are not deemed
significant.
The third criterion alludes to the amount of capital
available to small businesses. This analysis does not
calculate the amount of capital available to impacted
facilities. It does, however, calculate the ability of
facilities to obtain capital if needed in section 3.5.4. It
was concluded that the assets of small facilities will not
be so adversely affected as to prohibit the procurement of
outside financing. It is assumed, then, that capital
availability will not be an obstacle for small entities in
complying with the regulation.
Criteria number four stipulates that small business
impacts are significant if compliance leads to closure. The
only implication of closure in this analysis is found in
section 3.5.2 concerning earnings impacts. Here it was
found that, under worst-case assumptions, closures might
occur in SICs 254 and 259, given their low rate of
profitability in the baseline. If this indeed occurs, the
question of whether or not these closures make up a
substantial portion of small facilities must be addressed.
The total number of facilities in each of the 39
potentially impacted SICs is known, but 'the number of firms
which have uncontrolled degreasers in each SIC is not known.
One way to estimate the percentage of impacted small
90
-------
facilities is to assume that, all SICs are affected in the
same proportion (i.e. equal proportions of the facilities in
each SIC will be impacted by the NESHAP.) Given this
assumption, a proxy for the share of impacted small
facilities in SICs 254 and 259 is the total number of small
facilities in these SICs as a share of the total number of
small facilities in. all 39 SICs. SICs 254 and 259 hold a
combined 3,194 small facilities. All 39 SICs hold a total
of 93,121 small facilities. Thus, SICs 254 and 359 make up
3.4 percent of the total number of small facilities.
Therefore, in the extreme case that some closures result,
the number of closures is estimated to be far less than the
amount required for substantial number of impacted firms
(recall that a substantial number is 20 percent.)
In conclusion, it seems highly unlikely that the impact
of the degreasing NESHAP will be significant for a
substantial number of small entities.
91
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4.0 REFERENCES
1. U.S.. Environmental Protection Agency. Alternative
Control Technology Document-Haloaenated Solvent
Cleaners, Research Triangle Park, NC, August 1989, p.
«""* J* •
2. Reference 1, p. 3-23.
3. Reference 1, p. 3-23.
4. Reference 1, p. 3-3.
5. Reference 4- .. •
6. Reference l, p. 3-13.
7. Reference 6.
8. Reference 6.
9. Executive Office of the President, Office of Management
and Budget. Standard Industrial Classification Manual.
1987. p. 211.~
10. U.S. Environmental Protection Agency. "Profile for the
Degreasing NSPS and NESHAP," EPA 68-02-4320, Number 22,
April 13, 1987, pp. 9-36 - 9-37.
11. Reference 4.
12. Reference 1, p. 3-1.
13. Reference 9, p. 140.
14t Chemical Marketing Reporter, chemical Profiles from:
January 23, 1989, February 6, 1989, July 1, 1989, July
8, 1989. J
15. Mannsville Chemical Products Corporation, "Chemical
Products Synopsis-Trichloroethylene," February, 1989.
16. "Chemical Profile — Trichloroethylene." chemical
Marketing Reporterr July 1, 1989.
17; "U.S. Regs Catalyze Changes in Solvents." Chemical
Marketing Reporterr January 21, 1991, p. 5."
18. Reference 16.
19. Reference 17.
92
-------
20. "The Recycling Loop Closes For Solvents."
Chemical Engineering. June 1991, p. 43.
21. Reference 18.
22. Reference 18.
23. Reference 18.
24. Reference 1, p. 4-66.
25. Chemical Marketing Reporter. January 27, 1992.
26. Chemical Marketing Reporter. February 3,- 199-2.
27. Chemical Marketing Reporter, March 2, 1992.
28. Chemical Marketing Reporter-,, January 20, 1992.
29. U.S. Environmental Protection Agency. Organic Solvent
Cleaners-Background Information for Proposed Standards,
Research Triangle Park, NC, October 1979.
30. "U.S. Industrial Analysis Service," Wharton Econometric
Forecasting Associates. Growth rate data are in the
form of indices of industrial output. The average
annual growth rate is compounded. These forecasts were
revised in mid-September, 1991.
31. U.S. Department of Commerce, International Trade
Administration. U.S. Industrial Outlook 1992.
Washington, D.C. p. 36-17.
32. Standard and Poor's Corp. Industry Surveys "Auto-Auto
Parts — Basic Analysis." New York, NY, January 30,
1992, p. A95.
33. Monthly Labor Review. "Productivity in Automotive
Repair Shops". March 1988 p. 23.
34. Reference 33.
35. Reference 33.
36. Reference 33.
37. Reference 33, p. 36-19.
38. Reference 33.
39. Reference 33.
93
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40. Telseon. Holmes, C., JACA Corp., with Reiss, D., Motor
and Equipment Manufacturers Association. April 20,
1992. Discussion of the aftermarket industry.
41. Suprenant, K.S. and D.W. Richards, Dow Chemical
Company. Study to Support New Source Performance
Standards for Solvent Metal Cleaning Operations.
Prepared for U.S. Environmental Protection Agency.
Research Triangle Park, NC. Contract No. 68-02-1329,
Task Order No. 9. June 1976.
42. Reference 43.
43. Confidential report on chlorinated solvents. Prepared
for U.S. Environmental Protection Agency. Washington,
DC. Contract No. 68-02-4235. March 13, 1987.
44. Telecon. Donato, S.A., JACA Corp., with
representatives of eight manufacturers of solvents and
three manufacturers of degreasing equipment. November
11-18, 1987. Telephone survey.
45. National Screw Machine Products Association,
Chlorinated Solvent Emissions Survey. Summary Letter,
May 28, 1993, p. 2.
94
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Appendix A: Aggregate Changes In the Industries Using
Decreasing Equipment:
In 1987, the SIC classification system was reorganized,
and eleven of the 3-digit industries using degreasing
equipment changed in aggregate terms. The eleven industries
were SICs 354, 355, 356, 357, 359, 362, 364, 366, 369, 381,
and 382.
The changes were as follows. What was, formerly SIC
3623, Welding Apparatus, Electric, was added to SIC 354,
Metalworking Machinery. SIC 355, Special Industry
Machinery, now includes two 4-digit industries formerly
identified as SICs 3549, Metalworking Machinery, Not
Elsewhere Classified, and 3636, Sewing Machines. SIC 356,
General Industrial Machinery, now includes the former SIC
3551, Food Products Machinery. Computer and Office
Equipment, SIC 357, added the former SIC 3661, Telephone and
Telegraph Apparatus, and SIC 3662, Radio and Television
Communication Equipment. The former SIC 3561, Pumps and
Pumping Equipment, and SIC 3563, Air and Gas Compressors,
are now part of SIC 359, Industrial Machinery, Not Elsewhere
Classified. Electrical Industrial Apparatus, SIC 362,
picked up the former SIC 3613, Switchgear and Switchboard
Apparatus. SIC 364, Electric Lighting and Wiring Equipment,
acquired the old 3699, Electrical Equipment and Supplies.
The former 3573, Electronic Computing Equipment, was added
to SIC 366, Communications Equipment. SIC 369,
Miscellaneous Electrical Equipment and Supplies, added four
old 4-digit industries including 3573, Electronic Computing
Equipment, 3679, Electronic Components, Not Elsewhere
Classified, 3549, Metalworking Machinery, Not Elsewhere
Classified, and 3662, Radio and Television Communication
Equipment. SIC 3662 was also added to SICs 381 and 382.
SIC 382 also includes the former 3811, Engineering and
Scientific Instruments, and 3832, Optical Instruments an
Lenses.
. 95
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TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing)
REPORT NO.
1PA 453/D-93-058
2.
3. RECIPIENT'S ACCESSION NO.
TITLE AND SU8TITUE
Economic Impact Analysis of the Halogenated
Solvent Cleaning NESHAP
5. REPORT DATE
November 1993
6. PERFORMING ORGANIZATION CODE
. AUTHOR(S)
8. PERFORMING ORGANIZATION REPORT NO.
PERFORMING ORGANIZATION NAME AND ADDRESS
U.-S. Environmental Protection Agency
Office of Air Quality Planning and Standards
Research Triangle Park,..NC 27711
1O. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
68-D1-0143
2. SPONSORING AGENCY NAME AND ADDRESS
Director
Office of Air Quality Planning and Standards
Office of Air and Radiation
U. S. EPA, Research Triangle Park, NC 27711
13. TYPE OF REPORT AND PERIOD COVERED
14. SPONSORING AGENCY CODE
EPA/200/04
5. SUPPLEMENTARY NOTES
6. ABSTRACT
Under authority of the 1990 Clean Air Act Amendments, a National Emission Standard
of Hazardous Air Pollutants (NESHAP) is being proposed to control methylene chloride,
perchloroethylene, Trichloroethylene, trichloroethane, and CFC-113 emissions from
facilities with halogenated solvent cleaners. Thirty-eight (38) 3-digit and one. (1)
2-digit SIC industries were evaluated. This report analyzes economic and financial
impacts at the selected regulatory alternatives for facilities with positive costs as
a result of complying with the proposed standard.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b.lDENTlFIERS/OPEN ENDED TERMS
c. COSATI Field/Group
Air pollution
Halogenated solvent cleaning
Hazardous air pollutants
Emission controls
Economic impact
Air pollution control
18. DISTRIBUTION STATEMENT
19. SECURITY CLASS (This Report)
UNCLASSIFIED
99
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