EPA-230/1-73-014
AUGUST 1973
          ECONOMIC ANALYSIS
                    OF
   PROPOSED EFFLUENT GUIDELINES


      GRAIN MILLING INDUSTRY
                   QUANTITY
      U.S. ENVIRONMENTAL PROTECTION AGENCY
          Office of Planning and Evaluation

             Washington, D.C. 20460
                       \

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             This document is available in limited
quantities through the U.S. Environmental Protection A gency,
      Information Center, Room W-327 Waterside Mall,
                  Washington, B.C.  20460
        The document will subsequently be available
     through the National Technical Information Service,
                Springfield, Virginia  22151

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EPA - 230/1-73-014
                      ECONOMIC ANALYSIS

                               OF

               PROPOSED EFFLUENT GUIDELINES

                   GRAIN MILLING INDUSTRY
                        Samuel G. Unger
                     Michael W. Woolverton
                      r-.v---- :	' •": Protection

                                   ,;;:om Street
                          August, 1973
                          Prepa red for
                 Office of Planning and  Evaluation
                 Environmental Protection Agency
                      Washington, D. C.  20460

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This report has beer, reviewed bv the Office of Planning
and Evaluation, EPA. ar.d approved for publication.
Approval does  r.ot si^r.ifv tha: the contents necessarily
reflect the views ar.d policies c: the Environmental
Protection Ager.cv.  nor does mention of trade narr.es or
corr.rr.ercial products constitute endorsement or recom-
mendation for use.

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                            PREFACE
The attached document is a contractor's study prepared for the Office
of Planning and Evaluation of the Environmental Protection Agency
("EPA").  The purpose of the study is to analyze the economic impact
which could result from the application  of alternative effluent limitation
guidelines and standards of performance to be established under sections
304(b) and 306 of the Federal Water Pollution Control Act, as amended.

The study supplements the technical study  ("EPA Development Document")
supporting the issuance of proposed regulations under sections  304(b) and
306.  The Development Document surveys  existing and potential waste
treatment control methods and technology within particular industrial
source categories and supports promulgation of certain effluent limitation
guidelines and standards of performance based upon an analysis of the
feasibility of these  guidelines and standards in  accordance with the require-
ments of sections 304(b) and 306 of the Act.  Presented in the Development
Document are the investment and operating costs associated with  various
alternative control  and treatment technologies.  The attached document
supplements this analysis by estimating the broader economic effects
which might result  from the required application of various control
methods and technologies.  This study investigates the effect of alter-
native approaches in terms of product price  increases, effects upon em-
ployment and the continued  viability of affected plants,  effects upon
foreign  trade  and other competitive effects.

The study has been prepared with the  supervision and  review of the Office
of Planning and Evaluation of EPA. This report was  submitted in fulfill-
ment of  Contract No.  68-01-1533, Task Order  No. 2 by Development
Planning and Research Associates, Inc. Work was completed as  of
August,  1973.

This report is being released and circulated  at approximately the same
time as publication in the Federal Register of a notice  of proposed rule
making  under sections  304(b) and 306 of the Act for the subject  point
source category.  The  study has not been reviewed by EPA and is not
an official EPA publication.  The study  will be  considered along with the
information contained in the Development Document and any comments
received by EPA on either document before or  during  proposed rule  making
proceedings necessary to establish final regulations.   Prior to  final  promul-
gation of regulations,  the accompanying study shall have standing in  any
EPA proceeding or court proceeding only to the extent  that it represents
the views of the contractor who studied  the subject industry.  It cannot be
cited, referenced,  or represented in any respect in any such proceeding
as a statement of EPA's views regarding the subject industry.

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                             CONTENTS

                                                                   Page

  I      INTRODUCTION                                           1-1

 II      SIC Z041:  FLOUR AND OTHER GRAIN MILL
        PRODUCTS                                                II-1
              Bulgur Industry Segments                            II-2
                    Types  of Firms                                II-4
                    Types  of Plants                                II-4
                    Number of Plants and Employment by
                     Segment                                      II-7
                    Selection of Segments to Total Industry         II-7
                    Likely Impacted Segments                      II-7
              Bulgur Financial Profile                             II-9
                    Plants by Segment                             II-9
                    Distribution of Model Plant Financial Data     11-15
                    Ability to Finance New Investment             11-18
              Bulgur Pricing                                       11-21
                    Price Determination                           11-21
                    Expected Price Changes                       11-25
              Corn Dry Milling Industry Segments                  11-26
                    Types  of Firms                                11-26
                    Types  of Plants                                11-26
                    Number of Plants and Employment by
                     Segment                                      11-29
                    Selection of Segments to Total Industry         11-29
                    Likely Impacted Segments                      11-29
              Corn Dry Milling Financial  Profile                   11-31
                    Plants by Segment                             11-31
                    Capital Structure                               11-33
                    Cost Structure                                 11-35
                    Distribution of Model  Plant Financial Data     11-38
                    Ability to Finance New Investment             11-38
              Corn Dry Milling Pricing                             11-40
                    Price Determination                           11-40

III      SIC 2044: RICE MILLING                                 III-1
              Industry  Segments                                    III-l
                    Types of Firms                                III-l
                    Types of Plants                                III-3
                    Number of Plants and Employment by
                     Segment                                      III-5
                    Selection of Segments  to Total Industry         III-5
                    Likely Impacted Segments                      III-5

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                     CONTENTS (continued)

                                                                 Page

             Financial Profile                                    III-6
                   Plants by Segment                             III-6
                   Distribution of Model Plant Financial Data     III- 12
                   Ability to Finance New Investment             III-16
             Pricing                                             III-17
                   Price Determination                          III-19

IV     SIC 2046:  WET CORN MILLING                          IV-1
             Industry Segments                                   IV- 1
                   Types of Firms                                IV- 1
                   Types of Plants                                IV-3
                   Number of Plants and Employment by
                    Segment                                     IV-4
                   Selection of Segments to Total Industry        IV-6
                   Likely Impacted Segments                     1V-6
             Financial Profile                                    IV-7
                   Plants by Segment                             IV-7
                   Distribution of Model Plant Financial Data     IV - 1 5
                   Ability to Finance New Investment             IV-17
             Pricing                                             IV-20
                   Price Determination                          IV-20

V      ECONOMIC IMPACT METHODOLOGY                     V-l
             Proposed Standards                                 V-l
             General Methodology                                V-2
                   Benefits                                       V-5
                   Investment                                    V-6
                   Cost of Capital - After Tax                    V-7
                   Construction of the  Cash Flow                 V-9
             Price Effects                                       V-9
             Financial Effects                                    V- 1  1
             Production  Effects                                  V- 1  1
             Employment Effects                                 V-12
             Community Effects                                  V-12
             Other Effects                                       V-l3

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                      CONTENTS (continued)

                                                                  Page

VI     POLLUTION CONTROL REQUIREMENTS AND COSTS     VI-1
             Pollution Control Requirements                      VI-1
                   Corn Wet Milling                              VI-4
                   Corn Dry Milling                              VI-6
                   Bulgur Processing                            VI-7
                   Parboiled Rice Milling                        VI-8
             Pollution Control Costs                              VI-9
             Status of Wastewater Treatment                     VI-11
                   Corn Wet Milling                              VI-11
                   Corn Dry Milling                              VI-12
                   Bulgur Processing                            VI-12
                   Parboiled Rice Milling                        VI-12

VII    IMPACT ANALYSIS                                       VII-1
             Corn Wet Milling                                    VII-2
             Corn Dry Milling                                    VII-10
             Bulgur Processing                                  VII-17
             Parboiled  Rice Milling                              VII-21

VIII   LIMITS OF THE ANALYSIS                               VIII-1
             General Accuracy                                   VIII-1
             Range of Error                                      VIII-2
             Critical Assumptions                                VIII-3
             Remaining Questions                                VIII-5

SELECTED REFERENCES

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                     ECONOMIC IMPACT OF
  COSTS OF PROPOSED EFFLUENT LIMITATION GUIDELINES
              FOR THE GRAIN MILLING INDUSTRY
  PHASE I - INDUSTRY DATA AND ANALYTICAL FRAMEWORK


                       I.   INTRODUCTION
The total grain mill products (SIC204)  industry is currently comprised of
seven four-digit industries .   This study considers three of the seven:

       SIC  2041   Flour and Other Grain Mill Products (Flour only)
       SIC  2044   Rice Milling
       SIC  2046   Wet Corn Milling

In 1967, the three selected four-digit industries accounted for 20.4
percent of the establishments and 34.7 percent of the employees of the
total grain mill products industry.  (The other four-digit industries  in
grain milling which are  excluded from this study are SIC  2043 -  Cereal
Breakfast Foods,  SIC 2045 - Blended and Prepared  Flour, SIC 2047 -
Pet Food, and SIC 2048  -  Prepared Feeds.)

A brief description of each industry included is  as follows:

       SIC 2041 -- Flour  and Other Grain Mill Products

       This industry comprises establishments primarily enga ged in
       milling flour from grain, particularly wheat.  Products are  sold
       to the baker for manufacture into bread and  cake products,  or to
       grocery stores for sale to the consumer in packaged form.   Durum
       products are sold to  macaroni  and spaghetti  manufacturers.  Flour
       is  also  sold or used  in prepared mixes.  A specialty wheat product
       called bulgur is also produced  in this industry.  Bulgur manufacture
       requires water for processing  and is therefore noted.   Corn dry
       milling is  also included in this industry.  Major products  of  corn
       dry milling are corn grits,  corn meal and corn flour.

       SIC 2044 -- Rice Milling

       This industry comprises establishments primarily engaged in
       cleaning and polishing of rice,  and in the manufacture  of rice
       flour or meal.  Important products of the industry include milled
       rice, brown rice,  rice polish,  rice bran, and rice flour.   Con-
       ventional rice milling is a dry  process,  but  parboiling operations
       are an important segment of the industr/ which utilizes water for
       processing.


                                1-1

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       SIC 2046 -- Wet Corn Milling

       This industry is mainly comprised of establishments engaged
       in milling corn or grain sorghum (milo) by the wet process.
       Products include starch,  syrup, sugar, oil and byproducts ,
       such as  gluten feed and meal.  Establishments manufacturing
       starch from other sources such as wheat,  rice  and potatoes
       are also included in this industry.

Each of th _> above industries involves  unique  products,  production pro-
cesses and other  specialized characteristics. Hence,  each industry
ivill  be considered separately insofar  as  determining the economic impact
of the'' .'o^ts o4  alternative levels of pollution abatement.  As an overview
t>*~ the u.'ri'ral size of each industry,  the  following numbers of establish-
rnent* in  -ach  >f the three  selected industries, as reported by the U.S.
Ccii.-u-i o' Manufactures, were as follows in  1963 and 1967.
No. of
Plants

Mill Products
1963
618
74
60
1967
541
68
45
No. of
Companies
1963 'T9~6T
510
62
49
438
54
32
                      In dust ry
        /,041 Flour and Other Gr
        -'04 1 Rice Milling
        ZCH6 Wet Corn Milling

Klo'i- an 1  Other Grain Mill Products plants have been steadily declining
in number for many  years' whereas, Rice  Milling and Wet Corn Milling
,;!ant--  rearht-d a pvik in 1963 and have subsequently declined in numbers
 I he plan of thi-.  report i:- to discuss eac'h of the above industries separately
 liei au^e ol  raiher marked differences in the types of processes involved,
 •liilereiue> in produ< t> produced, and different effluent characteristics.

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    II.  SIC 2041:  FLOUR AND OTHER GRAIN MILL PRODUCTS
 Establishments in SIC 2041  tend to further group into four separate
 subindustries on the basis of primary products produced.  These
 four groupings, representing different product classes, are as follows:

                SIC                    Description

              20411          Wheat flour, except flour mixes
              20413          Corn  mill products
              20415          Flour mixes, refrigerated doughs made
                              in flour mills
              20416          Other grain mill products

 The most dominant of these subindustries is SIC  20411, which represents
 approximately 75 percent of the total  industry shipments.

 Based upon industry contacts and  discussions,  only very limited portion-
 of this  industry have any water pollution control problems,  In particular.
 only two portions of the overall industry have potential water pollution
 problems associated with milling  per se:

        (1)  Bulgur (wheat) processors   -    wa shwate r and/o r " bteepo/.i ir
                                               d ra ina ge
         (2)  Dry Corn  Millers            -    wa shwate r

 Most of the corn dry millers using the te'npering-degt- rmmat .no pr s
 Smaller mills producing ground whole < orn art- believed to ;M>( wash c orn
 before grinding.  The  smaller mills are excluded from this study  s:n r tin
 larger mills that wash corn  are of primary  concern.

 Wheat flour millers, the  largest single category of SIC 2041, are  not
 generally  concerned with water pollution problems.   In < orrcspundciK >•
 •with the Miller's National Federation, a national  as sor iat mn  ol the
 flour milling industry,  it was indicated that—". . most oi  the mills cer-
 tainly do not feel that they have any real effluent problem in their  flour
 milling operations..."   This confirmation of the absence of water pollution
 problems  in flour milling suggests that no further study is probably  needed-

As a further check, the results of an informal survey by the Technical
 Committee of the Association of Operative Millers  was made available to
 DPRA.   This committee is mostly comprised of superintendents of
                                   II-l

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cram mills  from companies dispersed throughout the U.S.  Represen-
tatives of wheat.  d ry co rn and buLgu r mills were included.  In the infor-
mal  survey,  17 of the committee's membe rs we re polled concerning wate r
pollution problems being  encountered or anticipated by their respective
lompames.   In this  case, 7 said they did have some water pollution prob-
lems in wheat milling and 10 said they did not.  The major problem with
water wa s not in  milling  per se, but because of bulk rail car washing.
A summary of  the results of this  'survey' are presented in Table II-1.
Also noted is that three companies had  one or more mills in which some
wheat was washed, although from only 5 to 7 percent of milled wheat was
wa shed.

Regarding dry  corn milling (note  only four members represented corn
mills),  four indicated that all corn milled for human consumption was
washed,  involving from 5 to 7 gallons of water per bushel.  The extent
that  this creates  a problem was not certain, although three discharge
into  municipal  sewer systems.

Three members were from companies which had bulgur mills.   In  this
case, no  respondent indicated that they had a special waste water dis-
posal problem  with bulgur.  This response is not conclusive, however,
since different processes exist in bulgur production.

With respect to SIC 2041,  two  subindustries will be studied further:
Bulgur processing and corn dry milling.  Wheat flour millers may
have some problems with rail bulk  car  washing wastes, but no further
assessment is  planned herein.
                     Bulgur Industry Segments
Bulgur production was established in the U.S. on a commercial basis
in the  mid-to-late 1950's.  The original producers marketed primarily
to ethnic oriented outlets, e.g., Armenian.   However,  since that time,
domestic use has been eclipsed by export sales via U.S. export trade
programs,  especially under USDA relief programs and Title I of PL 480.
                                II-Z

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 Table II-1.  Responses from  17 members of the Technical Committee of
           the Association of Operative Millers  concerning water
                  pollution problems in grain milling


Wheat Milling
Do you have a water pollution problem?
If




If
you do, is it because of wheat washing?
- bulk car washing?
- bulk truck washing?
- wet scrubber dust collecting?
- othe r
other - what?

Yes
7
3
7
2
0
0


No
10
5
1
2
4
0

No
Re sponso
0
9
9
13
13
17

 Wheat Washing

 If you wash wheat, what % is washed?                  (5-7%)
 How many gallons of water per bushel are used?        (4 gallons)
 Does the water go straight to the sewer?              10      1

 Bulk Car and Truck Washing

 If you use water to clean bulk cars or trucks, about
 how many gallons per car are used?
 Does it go straight to the municipal sewer?
 Is there a special charge for this?
 Do you expect to be required to treat this water?

 Bulgur (Note:  Only 3 had bulgur  mills)
 If you make bulgur, is there a special waste water
 disposal problem?

 Dry Corn Milling (Note: Only 4 had corn mills)

 Do you wash all corn to  be milled  for human
 c on s umpti on ?
 How many gallons of water per bushel?
 Does the water go straight to the sewer?

 Water Treatment
 (J.500 gallons)
11      1       5
 737
 449
              16
 4      0
 (5-7  gallons)
 3      1
Do you have a water treatment system?                 1     11
Do you use strainers?                                  8      3
Do you use settling tanks?                              5      5
     -  other?
What other?       Starch/gluten a big problem -
                  recover  solids for resale but
	quite expensive	
13
13
               5
               6
               7
                               H-3

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Types of Firms

Six U.S. milling firms are now actively engaged in the production of
bulgur on a commercial basis. Since the late  1950' s there have been
at least 17 processors who have entered into bulgur production, but
now only six firms remain active.  The most recently closed mill,
which is presently being dismantled, is one owned by Far-Mar-Co. ,
Inc. in Hutchinson, Kansas.  This plant was a 'medium'size plant
relative to the rest of the  industry.

The six firms each have but one bulgur mill (see TableII-Z below).  In
every case,  the firms have other milling units and bulgur would gen-
erally be  considered a relatively small part of the overall firms oper-
ations. For example,  three of the firms  are among the top twenty
wheat flour millers in the U.S.

Types of Plants

The six remaining bulgur  plants in the industry are as shown in Table
II-2. Also shown are the  plant locations  and the estimated capacities
per day for each plant.  Bulgur mills are dispersed throughout  the mid-
western and western states.  One plant each is in Kansas, Nebraska,
Oklahoma,  Texas, California  and Washington.  The Fisher mill in
Seattle, Washington is the dominant plant in the industry.

Capacities range from 2,500 cwt. to 9,000 cwt.  per day;  and an average
capacity is approximately  5, 000 cwt. per day.  The  composite annual
capacity of the industry is slightly over ten million hundredweight.  In
1971 and  1972. bulgur production totaled  about five million hundredweight.
Hence, utilization of capacity  is about one-half of capacity (based on 330
days,  24 hours per day).

Because of the young age  of the industry, the level of technologies is
reasonably mode rn.  However, there are a variety of processes for
bulgur production and each requires different equipment.

Four processes for gelatinizing wheat to  produce bulgur are illustrated
in Figure II-1.  These are referred to as:  (1) Albany process ,  (2)
Robbins process.  (3) second generation Robbins process, and (4)  third
generation Robbins process.  Only the Albany process involves any
wastewater drainage from the hydration procedure.  Otherwise, all
process water is  eventually vaporized in driers.   (Another water-use
step may be wheat washing prior processing, but none are known to now
wash wheat.)
                                II-4

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    Table II-2.  Listing of bulgur mills and their plant locations
    Bulgur Plants and Location	Estimated Capacity
                                                       (cwt/day)

 Archer Daniels Midland Co.                               5,000
  Shawnee Mission, Kansas  66207
  Plant: Abilene, Kansas

  Burrus Mills, Inc.                                        3,200
  Dallas, Texas  75201
  Plant:  Dallas, Texas

  California Milling Corp.                                   4,500
  Los Angeles, Cal.  90058
  Plant:  Los Angeles,  California

  Fisher Mills, Inc.                                         9,000
  Seattle,  Washington 98134
  Plant:  Seattle, Washington

  Lauhoff Grain Co.                                         6,500
  Crete, Nebraska
  Plant: Crete, Nebraska

  Leger Mill Co.                                            2, 500
  Altus, Oklahoma  73521
  Plant: Altus, Oklahoma
Sources:  " Bulgur Mills," The Northwestern Miller, Vol. 278, No.  9,
          September,  1971~

          Fisher, Glen W- ,  The Technology of Bulgur Production, Association
          of Operative Millers, Bulletin, May, 1972.
                                II-5

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 wheat
 20% norsl \
                         PENETRATION
                         B^T CONVEYOP
                           I70 -ISO0"
          mois'	steom
OELATINIZED
  WHEA"
T0 DRIEF
                        ALBANY
                       PROCESS
rrr.
                 ^EANED *HE4T


                   i ,—WATER

                             25-/. I
                            •SOT ;
                            4 hr
                                                                                       35'A
                                                                                      llSO'
                                                                                      i 2 H,
       ^

        "1




ROBBINS  PROCESS
                                                                                               18L4NCH£fi
                                                                                                M5%
                                                                                                \za-f
                                                                                              GCLATINI^ED
                                                                                              WHEAT TO
                                                                                              DRIER
                                  ROBBINS
                                  PROCESS
                                                           PROCESS
                                                            GELATINIZED
                                                              WHEAT
                                                             TO  DRIER



1
j
"SB" 	

I 1
1 1


> "
1

1

1
        Figure II-l.  Illustration of modern bulgur gelatinization processes.

                                              II-6

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 Number of Plants and Employment by Segment

 Of the six remaining plants in the industry, two each might be classed
 as small,  medium and large.  Employment data is not published, but
 estimated employee  requirements (assuming each mill only processed
 bulgur) range from about ZO to 45 per mill based on size.   Total em*
 ployment is estimated at approximately 180 to 210 as  follows:
        Plants       Range         No. Mills          Total

        Small        20-25             2                40-50
        Medium      30-35             2                60-70
        Large        40-45             2_                80-90
        Total                          ~6               180-210

Selection of Segments to Total Industry

All plants with drainage and/or other wastewaters,  e. g. ,  wheat washing,
will be affected substantially if waste treatment facilities must be installed
at the  plant level.  The plants  by size class are estimated to  have the
following distributions regarding production and employment.

        Plants             %  of Production            % of Employment

        Small                    19                           23
        Medium                 31                           33
        Large                   50                           44
        Total                   100                         100

Again,  only  six plants  are involved.

Likely Impacted Segments

Within the size  range of plants involved,  all would likely be affected sub-
stantially with increased costs associated with pollution control facilities
if required.   Thus, no plants are eliminated  due to size.  However, as
noted above, if  no  washing occurs, and if a Robbins process  is used,
then no wastes of consequence are believed involved.  These  plants may
be eliminated.  (Steam  generation water wastes and sanitary  wastes
are excluded.)
                             U-7

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To determine how much the study scope might be narrowed on the basis
of type-of-process used, a poll was made concerning all the bulgur
plants.  The results were as follows:

       1.   No  wheat washing (except "steeping") is practiced.

       2.   No plant indicated  that water wasteflows were  a problem.

       3.   Only minor overflows (excess water drainage) were experienced
            in "steeping"  wheat.  The  objective is to add water only to the
            level which can be  retained by the wheat mix.

From all indications  the bulgur plants do not have a significant water
pollution control problem.  Only minor  volumes of wasteflow are indicated
and these are apparently being discharged for adequate treatment-
                                   II-8

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                     Bulgur Financial Profile
Financial data on the bulgur industry per se are not available.  Bulgur
operations comprise a portion of larger more complex  milling organizations,
primarily wheat flour milling.  To assess this industry, it was necessary
to resort to model plant data representing the industry.  Within the time
frame available, attention was  focused on a ' medium' sized  operation to
reflect industry averages.

Plants by Segment

Bulgur processing is a rather straight forward milling  process with only
bulgur as the primary product (a small amount of millfeed byproduct is
also produced).  Sizes of  units  range from about  2,500  to 9,000 cwt- per
day.  The medium plant modeled herein is rated at 5,000 cwt- per day.

Small, medium and large  categories of plants would be defined as:

                 Small               2,500  - 4,000  cwt. /day
                 Medium             4 , 000  - 6 , 000  cwt. /day
                  Large               6,000  - 9,000  cwt. /day

As stated, only a medium sized plant was modeled  to reflect average con-
ditions in the industry at this time.  A characteristic of the  industry is
that only about one-half of the maximum machine capacity is being utilized
to meet demand requirements.   For example, the medium 5,000 cwt./day
plant has a rated annual capacity of about  1-65 million cwt.  (7,920 produc-
tion hours),  but throughput volume estimated is 0. 832 million cwt.  (4,000
production hours) or approximately 50 percent of the  maximum.

Annual Profit before Taxes

Based upon the model plant concept and the operating assumptions employed,
estimated annual pre-tax  income and selected rates of return on average
fixed investment are as shown in Table II-3.  After tax RO1  is estimated
as ?• 0%  and  after tax earnings  on sales are a relatively low  1-7 %-  Earnings
are  sensitive to changes in sales prices, e.g. a 1% change in price down-
ward would reduce after tax ROI  to 4. 4%
                                  II-9

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  Tn! ic 11-•>   !"!»: .mated pr«--^ax net income and rate  of return on average
        iivi-sicd i ip tal and after-tax ret >rn on sales for a medium
                         !,-ulgu.r pror t-ss :ng plant
Fi.aiu .a I Measure                                  Value

Pre-tax tu-t  income ($000)                             171

Pre-tax ROI:;: <%)                                     12. 6

After-tax ROI':' (%)                                    7- 0

After-tax return on sales {%)                          1. 7
                                    n-io

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No bulgur processing plants are believed to have maintained high profit
levels because of the generally low utilization rates (and limited bulgur
demand) in the industry.  The recent closure of the Fa r-Ma r-C o.  plant
at Hutchinson, Kansas, which was a medium  sized plant,  suggests also
the questionable profitability of bulgur processing.

Average fixed investment, on which the rates of return were calculated,
was derived by  dividing replacement costs by two (an estimate of average
fixed assets) plus total working capital (current assets)  less current
liabilities (based on grain milling industry averages).  The  average
fixed or invested capital estimate is intended to approximate invested
capital in reported financial data. After  tax income  was based on a 48%
tax rate without either carry forward or back tax provisions.

Annual Cashflow

Estimated annual cashflow (after tax income plus depreciation) and return
on average fixed investment are as shown in Table II-4 for the selected
model plant.  Depreciation for the plant was based on an expected  25
year life for buildings and 15 years for equipment.

The cashflow data are considered nominal for grain milling firms. It is
expected that pollution control cost impacts can be assessed adequately
given conditions reflected in the cashflow data shown plus subsequent
scale adjustments.

Market (Salvage)  Value  of Assets

No data  is generally available concerning salvage values of  bulgur plants
per  se.  Bulgur plants appear to  have  little value to others in the industry
under the present condition of major underutilization of maximum plant
capacities.   However,  some components  of bulgur  operations  (e.g. aspirators,
elevators, dryers, etc. ) are common to the grain milling industry and
salvage  values might be estimated on a dismantled plant basis.

Capital Structure - Agricultural processing industries generally require
a relatively low investment per dollar of  sales.  This is true of bulgur
processing where an investment of  $1. 00 results in sales  of $4. 22 based
on the model plant data  developed.

The  capital required to generate  such sales for the model bulgur plant
is indicated in Table II-5.  The estimated replacement value of fixed
investments as shown includes land, buildings, equipment and associated
installation costs.  Excluding land,  the total plant investment cost was
                               n-ii

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  Table II-4. Estimated cash flow for a. medium bulgur processing plant
Financial Measure                                 Value

Annual cash flow ($000)                             143

Cash flow on average fixed
   investment (%)                                   11.0
                                    11-12

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65% for buildings and 35% for equipment based on an engineering synthesis
of model plant data by DPRA.

Total working capital requirements of $1. 36 million,  as also presented in
Table II-5, exceed the $1.089 million in plant and equipment.  This working
capital requirement equals about 25% of annual operating costs.  Thus,
while bulgur processing is not particularly capital intensive, it does have
substantial working capital requirements.   As a  part  of salvage value that
would be recoverable in case  of plant closure, the working capital compo-
nent is significant, i. e. 55% of replacement value of total assets.

Cost Structure - Model plant  data and budgets were prepared to estimate
the cost structure of representative operations.

Fixed or plant related expenses were defined as  those which do not directly
vary as a function of throughput.   These expenses include:

          maintenance and supplies
          taxes and insurance
          plant and labor overhead
          sales, general and administrative

Additionally  cost estimates were made for  depreciation and interest costs.
Variable or production related expenses were defined as those  which wi.il
generally vary proportionately with throughput -- in other words, a ;,xed
amount per unit processed.   They include:

          raw materials
          power
       •   water
          process supplies, chemicals, etc.
          operating labor
          plant supervision and fringe benefits

Fixed costs -As shown in Table II-6, the  indirect operating costs for the
budgeted medium bulgur processing plant represent only 3 percent of sales-
This is due to the dominance of raw grain  purchases as input and the
relatively low value added process that is  involved.   Presumably, smaller
plants would have relatively higher fixed costs and larger plants relatively
lower.

Depreciation is also a small percent  of sales, 0-9%, as  shown.  This again
reflects the low fixed asset capital requirements of bulgur productior relative
to other inputs.

Interest costs are shown as equal  to  1-0%  of sales for the model plant.

                                11-13

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 Table 11-5.  Estimated re p lac-erne nt value and working capital requirements
              for a medium bufgur processing plant
Capital component
Requirement
Replacement value of plant,
   equipment 8t site

Total working capital

Replacement value of total
   assets
   ($000}


   1,089

   1,360


   2,449
                                 11-14

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Variable costs - Variable costs are also shewn in Table Il-o fcr two
major components;  raw materials, and other direct operating costs.
Raw materials costs represent almost 80% of sales  and is overwhel-
mingly the most dominant production  cost component.  This is expected,
however,  in processes like bulgur production where the processing
is rather  simple and straight forward.

Direct operating costs are second in importance relative to sales; and
the model plant direct costs were estimated as  equal to 12. 1% of sales.
This percentage is expected to vary among plant sizes  as is to be  determined
in subsequent study.

 Distribution of Model Plant Financial Data

 There was no known individual plant financial data  concerning bulgur
 operations in published sources.  Consequently, the contractors had
 to rely upon model plant  cost and returns data which were generated
 specifically for this study.  Because bulgur processing is  generally
 straight-forward and not overly complex, it was possible to design
 and simulate engineering cost estimates  for the model plant specified
 within the time constraint of this  study.  Unfortunately,  alternative
 mill sizes could not be developed for comparative purposes.  However,
 the "medium" size plant was  chosen to best reflect what might be
 termed average conditions in the  industry.

 Most of the financial data generated  has been  summarized above.  How-
 ever, a composite  summary plus key assumptions  and some selected
 additional data are presented in Table II-7.

 The Protein Cereals  Products Institute,  an industry association,
 represents the bulgur producers.  The institute does not collect or
 analyze data  relating to plant production costs, productivity and
 profitability.  Thus,  this source was not asked to verify production
 data. Also, time did not permit verification •with producers.
                              •

 Wherever data were missing  it was necessary to make personal judgments
 and approximations.  Selected financial data  and ratios, such as from IRS
 business statistics, Dun  & Bradstreet,  Standard fk Poors, Fortune and
 other sources were used as guides and indicators of likely plant charac-
 teristics.  Census  of Manufacturers  data was also  used  concerning the
 grain mill products industry in general and also for selected four-
 digit industries  such as SIC 2041.

 Current  industry prices and costs were used for the bulgur plant oper-
 ation, i.e., first quarter, 1973.  Investment requirements reflect  recent
 costs including adjustments for inflation based on judgment.
                               11-15

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 Table  II-6. Estimated costs for a medium bulgur processing plant











   Item                                $000                 Percent






Sales                                  5,724                  100.0





Raw materials                         4,576                   79-9





Direct operating costs                   692                   12. 1





IrdiT-t-ct operating costs                 173                     3.0





rvpr<-r-at ion                              54                    0.9





lot-rv-st                                  58                     1.0





T.'ta' b- u.rr-tax cost                  5,553                   97.0
                                  - lb

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      Table II- 7.    Summary of financial data pertaining to the
                   bulgur processing model plant
Item
Units
Value
Remarks
Utilization
Annual Thruput
Sales $

Raw Product Cost
Variable Costs
Fixed Costs
Cash earnings
Depreciation
Interest
Pre-tax income
Net income
After-tax cash flow
Replacement Cost
Working Capital
Current Liabilities
Ave. Fixed Invest. (AFI)
Pre-tax income/AFI
Net Income/AFI
Cash Flow/AFI
Net Income/Sales
%
1,000 cwt
1,000

I t
1 1
1 1
11
1 1
t t
f t
1 1
11
T 1
1 t
1 1
M
Ratio
1 1
1 1
1 1
50
832
5,724

4,576
692
173
283
54
58
171
95
149
1,089
1,360
544
1,361
„ 126
.070
- 110
. 017
4, 000 production hours
50# bags
$7.40-. 52 (transport) =
$6. 88 FOB Mill
1. 1 (Thruput) ($5.00)



4% Bldg, 6.7% Equip.
$.07 /cwt



Engineering synthesis
25% Operating Costs
40% Total Working Capital





                               11-17

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       to Finance New Investment
The ability of a firm to finance new investment for pollution abatement
is a function of several critical financial and economic factors.  In
general terms, new capital must  come  from one or more of the following
scmrvfs;  (1) funds borrowed from outside sources; (2) equity capital
through the  sale of common or preferred stock; (3) internally generated
funds- - retained earnings and the  stream of funds  attributed to deprecia-
tion of fixed assets.

For each of the three major sources of new investment,  the most critical
set of fat tors is the financial condition  of the individual firm.  For debt
financing, the  firm's credit rating, earnings record over a period of years,
stability of earnings,  existing debt-equity ratio and the lenders'  confidence
in management will be major conside rations.,  New equity funds through the
sale  of securities will depend upon the firm's future earnings as anticipated
by investors, which in turn will reflect past earnings records.  The firm's
record,  compared to others in its own industry and to firms  in other similar
industries,  will be a major determinant of the ease with which new equity
capital can be  acquired.  In the comparisons,  the investor will probably
look at the trend of earnings  for the  past five or so years.

Internally generated funds depend upon the margin of profitability and the
cash  flow from operations.  Also, in publicly held corporations, stock-
holders must be willing to forego dividends in order to make  earnings
available for reinvestment.

The  condition of the firm's industry and the  general economy are also major
considerations in attracting new capital.   The industry will be compared to
other similar industries (i.e. , other processing industries)  in terms  of net
profits on sales and on net worth, supply-demand  relationships, trends in
production and consumption, the  state of technology, impact of government
regulation,  foreign trade and other significant variables.  Declining or
depressed industries are not good prospects for attracting new capital.  At
the same time, the overall condition of the domestic and international
economy can influence capital markets.  A firm is more likely to attract
new  capital during a boom  period than during a recession.  On the other
hand, the cost of  new capital will usually be higher during an expansionary
period.  Furthermore,  the money markets play a  determining role  in new
financing; the  1973 year has been viewed as especially difficult for new
equity issues,

These general guidelines can be  applied to the milling industry by looking
at general economic data,  industry performance and available corporate
records.
                                   11-18

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There are no available financial data on firms  operating bulgur plants,
One must look at grain mill products as a whole in order to gain im-
pressions about the profitability of the industry and the ability to attract
capital.

Table II- 8  presents  selected financial data on grain milling as a broad
industry category for the years 1967-68 through 1971.  The industry is
below average in profitability, both as a  percentage of sales and of net
worth.  Net profit on sales of 1. 75 to 3. 6 percent compares to Standard
and Poor's 425 industrial  companies' return on sales  of 5.0 to 6. 1 percent
during those same years.   Only in 1968-69, when return on net worth
averaged 11.9 percent,  did grain milling achieve the manufacturing aver-
age of approximately 12 percent.  Returns were down in  1971, owing largely
to higher corn prices and  reduced profit  margins.

The grain milling industry debt situation appears generally sound.  Long-
term  debt averaged 2 1 to 36 percent of net worth, compared to a general
range of 35 to 50 percent for most manufacturing industry groups.  Current
debt levels appear normal with ratios of 1. 8 to 2. 2.  Assuming continued
profitable operations, the  industry should have adequate borrowing capa-
bilities.

Cash  flows, estimated as  a percent of total assets,  ranged from 7. 3 to  9. 3
percent in the thre-year period from 1967-68 through 1969-70, with the
last year at 7.8 percent.  Indications are that  1971 was even lower.  Fur-
ther analysis of grain mill products  firms  by asset size indicate that the
cash flow may be  somewhat higher for the  largest firms (over $100, 000, 000
in assets); beyond that,  asset-size appears to  have little  relationship to
cash flow.

Profit margins in the milling industry in general tend to fluctuate from
product to product and from year to  year.   Millers have little  control over
raw product costs, which usually reflect production changes and prices of
related products.   Thus, there  is an instability of earnings in the industry
which makes it somewhat less attractive for equity capital  and usually
requires lower debt/equity ratios than for  manufacturing in general.  Even
so, there is no evidence that the milling  industry cannot attract sufficient
capital to finance  new investment.
                                  11-19

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Table II- 8 .  Selected financial ratios for grain mill products firms,
                          1967-68 through  1971
1967-68L/
Net profits as % of sales 2.7
Net profits as % of net worth 9. 9
Net sales times net worth 3.7
Net sales times net working
capital 8. 3
Net sales times total assets 2. 1
Total debt as % of net worth 80
Fixed debt as % of net worth 31
Current ratio • 1=9
Cash flow as % of total assets 7s 3
— Troy, Leo, Almanac of Business and
1968-69-
3.6
11.9
3.3
7.8
2. 1
60
21
2.0
9.3
Industrial
! 1969-70
3.3
11. 1
3.4
8.7
1.9
80
36
1.8
7.8
Financial
L/ 19712-/
1.75
8. 3
5. 1
8. 7
N. A.
98
N. A.
2.2
N. A.
Ratios in 1971
   1972 and 1973 editions,  Prentice-Hall, Inc., Englewood Cliffs, N.  J.

_' Dunn and Bradstreet, 1971 Key  Business Ratios--industry median;  each
   ratio is for a different firm (73  companies).
                                 11-20

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                          Bulgur Pricing


 Price Determination

 Price determination for bulgur is somewhat unique in that most sales
 are to the U.S. government on the basis of tenders for bid from U. S,
 bulgur producers.  Contracts are awarded to lowest bidders for speci-
 fied quantities of bulgur which are packed to specification.

 A summary of demand and supply relationships in the industry is pre-
 sented to explain major factors affecting bulgur sales and prices.

 Demand

 Only a small portion of the yearly production of bulgur is sold in retail
 packages in the United States.  Over 99 percent of the bulgur produced
 is bought under contract by the United States Department of Agriculture,
 and,  approximately 99 percent of this amount is exported under various
 foreign aid programs,  such as the P.L.  480 - Food for Peace program.
 A small portion about 3 million pounds of bulgur per year is distributed
 within the United  States in federal school lunch and domestic feeding
 programs.

 Four-fifths of the U. S. produced bulgur is shipped to Southeast Asia,,
 About one-third of that goes to Indonesia.  The  USDA and the association
 of bulgur producers has concentrated its market promotion and education-
 al efforts in that part of the world.  Other areas which offer  opportunities
 for future bulgur  sales include other Asian countries, the Middle East,
 and the new African nations.

 Bulgur is gaining acceptance  in developing nations as a high-protein,
 high quality food.  In response to the nutritional value of food, bulgur
 producers are  increasing  the protein value of bulgur by  adding soy grits,,
 This product, called soy fortified bulgur, is a fairly  recent development
 and consists of 85 percent bulgur and 15  percent soy grits.  The USDA
 has sharply increased its  purchases of this product in the past two years
 due to the great interest shown by the developing nations.

 Total sales of bulgur have grown rather  slowly to a level of about 5 mil-
 lion hundredweight in 1972.  The  trend in exports, representing approx-
 imately 99 percent of sales, is as shown in Figure II-2.  Also shown is
the distribution of sales to major export  markets.  The  total volume  of
bulgur produced in the  U.  S.  is equivalent  to about one-half of one per-
 cent of the nation's annual wheat production.
                                11-21

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                     BULGUR F. XPCR7  MA^Kf IS
                                        I    /I	*~ 1  "J I * L
                  PRODUCTION  CAPACITY COMPARED TO EXPORT SALES - BULGUR
                          *vc c»' Pt« MC\TN  flr rpca, iE/>»s
                         rh  r-
                                                        •OTAI
                                                        CAPACITY
TOTAl.
SAUS
                 1962   1963
Figure II-Z.  Bulgur export sales and sales by market,  1962-1970.

Source:  Fisher, GlenW., "The Technology of Bulgur Production, "
          Bulletin, A ssociation of Ope rative Millers, May,  1972,  p.  3301.
                                  11-22

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Supply

Bulgur supplies are effectively equal to the USDA (ASCS) purchases for
export programs and to a minor extent U. S. domestic donation programs.
Less than one percent of the bulgur produced is distributed through regular
commercial market channels.  A summary of bulgur purchases by USDA
since 1968 is shown in Table  II- 9 .

Bulgur is produced according to rather  stringent government standards
and packaged in high quality bags (normally 50 pounds per bag) for export
(and other)  shipment.  Also,  since  1971, soy fortified bulgur has been
produced and it is rapidly replacing stright bulgur production.  This new
product is still primarily bulgur (85 percent), but as government tenders
for bid are  changed,  the industry firms have quickly added soy grits
blending capability.

Prices

Bulgur prices of concern are  essentially only those at the plant  level.
Domestic sales  are  of minor  consequence relative to total sales; and no
attempt has been made to trace domestic sales beyond first the  ethnic
orientation  of some  markets,  and second, some apparent increase in
bulgur sales among  health food stores.

Competitive bidding for bulgur  (and soy fortified bulgur) production
contracts effectively determines the mill price of bulgur.  Presumably,
bid prices reflect costs of production including wheat purchases and
nominal  rates of return.  Also,  however,  most bid requests are for
delivered port prices at specified sea coast and Great Lakes destinations,
e.g. , Gulf,  West Coast, East Coast and Lakes.  Availability of wheat
supplies and the plant location could result in comparative advantages for
individual mills or groups of  mills when bidding for specific location-
dependent contracts.

Bulgur prices vary directly and proportionally with wheat prices as
expected (and  now with soybean prices also).  For example, bulgur prices
in June,  1972 were $5. 64 per cwt. f. a. s.  at Gulf ports  but rose to $7. 83
in December,  1972.  During this period, wheat prices also rose from
about $1.52 per bushel to $2.  62 or by $1.83 per cwt. After accounting
for processing wheat losses (10 percent including moisture differential),
the change in wheat  costs accounts for almost all the change in bulgur
prices.

In the first quarter of 1973, bulgur  prices averaged about $7. 40 per cwt.
at Gulf ports.  Wheat prices,  delivered to mills, averaged $3. 00 per
bushel (or $5. 00 per cwt. )  during the  same period.

                           11-23

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Table II- 9 ,  USDA purchases of bulgur for export and donation programs,
                                1968-1972
Soy Fortified Bulgur for
Year Bulgur Bulgur Total Exports Domestic Donation
Unon r^\t/f ^
1968 3,749 - 3,749
1969 4,165 - 4,165
1970 5,452 - 5,452
1971 4,070 980 5,050
1972 2,030 2,920 4,950

51
47
43
35
30
Source: National Food Situation, ERS,  USDA,  May,  1973.
                               11-24

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Expected Price Changes

Because of the peculiar structure of the bulgur industry, i. e. ,  99 percent
sales to the government for export under  food-for-peace type programs
and the contracting purchase system, it is first anticipated that any
change in costs for pollution control would be reflected in contract  bid
"prices".  Hence, costs would be passed-through just as is an  increase
in the  cost of wheat  input.

Second,  however, can prices be passed to consumer (foreign countries)
without a change in the quantity demanded?  In this regard it is estimated
that the demand for  bulgur is price elastic (elasticity less than -1.0)
where local currency sales  are made; and,  quantity demand would there-
fore be reduced noticeably given only small percentage changes in price.
Thus,  export requirements  would be lowered and average utilization of
plant capacity in the  U.  S.  would be less.  The least efficient plants
would  then have difficulty  competing.

The smaller bulgur plants are expected to be impacted relatively more
than the larger plants in terms of per unit costs of pollution abatement.
These  plants will first have trouble competing for contracts because of
costs and subsequently  they will also 4e further lisadvantaged if aggregate
demand falls in foreign markets.
                                 11-25

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                   Corn Dry Milling Industry Segments
 This industry manufactures corn meal  for human and animal consumption-
 products ior human consumption include whole corn meal,  degermed
 turn meal, corn grits,  and hominy.  The industry also ma,
-------
Figure II-3.  Distribution of corn dry milling plants among states in the U.S.
Source:  Northwestern Miller,  Vol.  278, No. 9, September,  1971.
1971.

-------
 Table 11-10.  Number and distribution of corn mills by  state, 1971
                   State
No. Mills
              .Alabama
              California
              Delaware
              District of Columbia
              Florida
    3
    2
    2
    1
    2
              Georgia
              Illinois
              Indiana
              Iowa
              Kansas
    5
    4
    4
    1
    2
              Kentucky
              Mississippi
              Missouri
              Nebraska
              North Carolina
    13
    3
    3
    3
    23
              New York
              Ohio
              Oklahoma
              Pennsylvania
     1
     3
     1
     4
              South Carolina
              Tennessee
              Texas
              Virginia
              West Virginia

              Wisconsin
     4
    19
     6
    12
     1
                             Total
   124
Source:  Northwestern Miller,  Vol.  278,  No. 9,  September,  1971.
                               11-28

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Corn dry millers purchase grain competitively in commodity markets.
They generally buy corn of U.S. Grade No. 2 or better,  except for
moisture content.   In 1972,  the industry utilized 139 million bushels
of which 23 million bushels were converted into breakfast foods. _'
This amounts to only about 3 percent of the total domestic use  of
corn in the United States  each year.  Corn prices, therefore,  are
not substantially affected by corn  dry miller's purchases.

Number of Plants and Employment by Segment
                         Zl
Employment data for 70 — of the  124 corn dry milling firms indicate
that employment averages about 50  per mill.  Employee  requirements
would vary according to the size of  the mill.  Total employment in the
70 firms was 3,300 in 1967 as indicated in Table 11-11.

Selection of Segments to Total Industry

There are two basic types of corn dry  mills in the United States,
smaller plants  that produce only ground whole corn and larger corn
mills that produce a variety  of products.  The smaller plants dry clean
grain before grinding and no process wastewaters  are generated.   The
larger  corn dry millers wash the  corn prior to tempering and milling
to remove surface dirt and microorganisms.  During the cleaning pro-
cess the moisture content of the corn increases constituting the first
step in the tempering process.  The spent wash water represents the
bulk of the wastewater from  this segment of the grain milling industry.
The larger corn dry millers process  80 to 90 percent  of corn dry milled
in the United States.  Since the smaller  corn  dry mills generate no waste -
waters, they should not be affected  by water pollution abatement programs
and can be eliminated from consideration.

Likely  Impacted Segments

Corn dry mills using the tempe ring-de ge rmmating process  are likely
to be significantly impacted by water pollution control requirements,,
These mills produce  a high percentage of the  total corn dry mill  products
in the United States.  They tend to be the larger mills in the industry and
most are located in the midwe stern part of the country.
\J Source: Feed Situation, ERS, USDA,  May 1973.
—  Source:  Census of Manufactures, U.  S.  Department of Commerce,
   1967.   Based on establishments with 75 percent or  greater product
   specialization.
                                11-29

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            11-11.  Selected employment, production and financial characteristics of the corn dry milling
                                      industry in the United States,  1967


                             All Employees      Production Workers    Value added                            Capital
Corn Mill       Establish-                           Man-              by manu-     Cost of   Value of    expenditures
Products	ments	No.    Payroll   No.    hours    Wages	facture	materials  shipments	nev
                  (No.)     (OOO's)  (million  (OOO's) (million,)		 Million dolla rs -------- ."777177".
                                        $)
Primary product
Class of establish-
ment (90%  or more
?pec.)              43       2.1      15.2     1.5    3.4      9.5        53.2         159.6       212.3        4.J

Establishments
with 75% or more
specialization
(75-89%  spec)       27       1.2       9.4      .9    2.0      5.8        21.4          89.8       110.7        2,2


Source:  Census of Manufacturers, U.  S. Department of Commerce,  1967

-------
 It is not known how many of the larger corn dry mills currently dis-
 charge into municipal treatment systems or directly into surface
 waters.  Treatment strategy will vary from plant to plant depending
 upon the quantity and quality of corn processed and access  to a munic-
 ipal treatment system*
                 Corn Dry Milling Financial Profile
Published financial data on the corn dry milling industry are not available.
All but a few corn dry millers are too small for  company statistics to be
reported in Standard and Poor's Industry Survey or Moody1 s  Industrial
Manual.    Those companies large enough to be reported are conglomerate-
type companies so that reported data does not accurately reflect corn dry
milling financial data.   To assess this industry fairly and complete the
subsequent plant impact analyses procedure used was to construct a
model plant situation.

Plants by Segment

Of the two basic types of corn dry mills in the  United States, only the
larger mills using the tempering-de ge rminating  process are of  concern
in this study.  The smaller plants, producing only ground whole corn,
dry clean the grain before grinding and generate no process wastewaters.
The larger mills using the tempering-degermmating process range in
size from about 2, 500 to Z0,000 cwt per day capacity of meal production.
A model plant of 12, 000 cwt per day capacity was chosen to represent
the industry.  A plant this size would process 30,000 bushels of corn
per day to produce 12,000 pounds  of finished corn meal products and
should represent the general condition of the industry.

The model plant is assumed to operate at 100 percent of capacity where
100 percent is  defined as 6,240 production hours or 260 days x 24 hours
per day.  The level of production may exceed the 100 percent utilization
standard in the milling industry so that 100 percent of capacity is not
an unrealistic level of production and represents current industry ex-
perience.

Annual Profit Before Taxes

Using the model plant concept and the  operating assumptions, the esti-
mated pre-tax  income and selected rates of return on investment are as
reported in Table 11-12.  After-tax ROI is estimated as 8. 8 percent and
after-tax earnings on sales is 2.6 percent.   These values were  computed
using 1967-1971 average costs of inputs and prices of products.  In light
of the unusual recent prices and the  present unsettled market conditions,
this should improve the chance of  reflecting "normal margins" between
prices paid  and prices  received for corn dry milling products.

                                11-31

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Table II-12.   Estimated pre-tax income and rate of return on average
           invested capital and after-tax return on sales
               for a moderately large  corn dry mill
                      (30,000 bushels per day)
Financial Measure                                    Value

Pre-tax net income ($000)                             843

Pro-tax ROI -  (%)                                      17.0

Alu-r-tax ROI -I (%)                                     8.8

After-tax return on sales (%)                             2.6
--  Average return on fixed in\ e stinent  calculated by financial statement
   method.
                                II-3Z

-------
Average fixed investment, on which the rates  of return were  calculated,
was derived by dividing replacement costs by  two  (an estimate of average
fixed assets) plus total working capital (current assets) less current
liabilities  (based on grain milling industry averages).   The average
fixed or invested capital estimate is intended to approximate  invested
capital in reported financial data.  After-tax income was based on a  48
percent tax rate without either carry-forward  or back tax provisions.

Annual Cashflow

Estimated annual cashflow (after-tax income plus  depreciation) and
the ratio of cash flow to average fixed investment  are as  shown in
Table  11-13.  Annual depreciation is assumed  to equal 6 percent on
equipment and 4 percent on buildings.  Buildings are estimated to
equal 70 percent of the total plant investment and equipment is equal
to 30 percent of the total.

The annual cash flow of $724,000 is also 4.2 percent of sales.  This is
comparable to other milling industry ratios.

Market (Salvage) Value of Assets

Data concerning the  salvage value of corn dry  mills is generally not
available.  A small corn dry mill producing whole corn meal would
have very little value,  even to another  corn dry miller, because of
its  small size and because whole corn meal has been a declining per-
centage of total corn dry milling production indicating declining demand.
A large corn dry mill using the  tempering-de germinating process would
be of little value to anyone other than another  corn dry miller.  The
equipment,  •which is  universally used in the milling industry,  could be
sold but approximately 70 percent of the value of a mill is attributed to
buildings which are potentially suited for general grain milling uses.
Since the model plant is assumed to be a moderately large sized
tempering-de germinating mill,  it should have  value to other grain
milling industry segments and is assumed to have  a positive salvage
value.  For purposes of analysis, a salvage value  of 50 percent of the
estimated replacement value was used.

Capital Structure

The average fixed investment in a corn dry mill "was estimated as
$4.971 million for the moderately large sized  model plant. Sales were
estimated as $17. 160 million per year.  This yields average sales of
$3.45 for each dollar of investment.  This yield is  comparable to other
                                11-33

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     Table 11- 13.  Estimated cash flow for a moderately large
                          ( orn dry mill


Financial Measure                                   Value

Annual cash flow ($000)                               724

Cash flow on average fixed investment (%)              14.6
                                  11-34

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agricultural processing industries which,  in general,  require a low
investment per dollar of sales.

The capital requirements estimated for the model plant are presented
in Table 11-14.  The replacement value  of $6, 198 million assumes a
breakdown of 70 percent for buildings and 30 percent for equipment.
Total annual working capital of $3, 120 million is estimated to equal
approximately 20  percent of total operating costs, including raw
product (corn) costs .

Cost Structure

Model plant data and budgets were prepared to estimate the cost structure
of representative  operations.

Fixed  or plant related expenses were  defined as those which do not
directly vary as a function of throughput.  These expenses include:

            maintenance and supplies
            taxes  and insurance
            plant and labor overhead
            sales,  general and administrative

Additionally cost estimates were made for depreciation and interest
costs.  Variable or production related expenses were defined as those
which will generally vary proportionately with throughput--in other
words, a fixed amount per unit processed. They include:
            raw materials
            power
            water
            process supplies, chemicals,  etc.
            operating labor
            plant supervision and fringe benefits.
Fixed Costs  - Indirect operating costs, as shown in Table 11-15, repre-
sents 7.3 of  sales in the model plant.  This is higher than some of the
other grain milling industries and is due primarily to large selling and
related costs.  Corn dry millers typically spend large amounts on
product promotion in retail markets trying to differentiate  their rela-
tively homogeneous  products in  the mind of the consumer.

Depreciation is a small percent of sales, 1.7 percent, as shown.  This
reflects the fixed asset capital requirements of corn dry milling which
are relatively low compared to other input costs.
                              11-35

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Table II-14.  Estimated replacement value and working capital require-
            ments for a moderately large corn dry mill
Capital Component
Requirement
Replacement value of plant,  equipment
and site

Total working capital

Replacement value of total assets
    ($000)


   6,198.6

   3,120.0

   9,318.6
                                 11-36

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Table 11-15.  Estimated costs for a moderately large dry corn mill






Item                                     $000         Percent





Sales                                   17,160          100.0




Raw materials                          10,374           60.4




Direct operating costs                    4,287           25.0




Indirect operating costs                  1,251            7.3




Depreciation                               285            1.7




Interest                                    120             .7




Total before-tax cost                    16,317           95.1
                            11-37

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Interest costs are shown to be equal to .7 percent of sales for the
model plant.

Variable Costs - Variable costs for the corn wet milling industry
are also shown in Table II- 1 ^ for two major components:  raw materials
(corn) and  direct operating costs.   Raw materials costs were estimated
to be  60.4  percent of sales and are the most dominant production cost
component.

Direct operating costs,  representing 25 percent of sales, are the second
largest cost component.  While not extremely high in comparison to
other grain milling industries,  direct operating costs at this level  indi-
cate that dry corn milling is  a moderately complicated production process.

Distribution of Model Plant Financial Data

There was no known individual  plant financial data concerning corn dry
milling in published sources.  A variety of engineering and financial
guidelines  were used to construct the financial  characteristics of the
model plant.  A summary of the corn dry mill financial characteristics
plus additional values and assumptions are  presented in  Table 11-16.

Selected financial data  and ratios,  such as from IRS business statistics,
Dun  and Bradstreet,  Standard and Poors,  Fortune and  other Sources
were  used  as  guides and indicators of likely plant characteristics.   The
1967  Census of Manufactures volume and value of shipment data was
used  to estimate an average mix of end products and their relative
values.  The result is a model of a moderately large  size tempering-
degerminating corn dry mill.

Because the model plant is intended to reflect  'normal1 financial con-
ditions in the  industry,  average cost and price  data for the  1967-1971
period were used.  The current unsettled market conditions and recent
prices are not considered representative of normal conditions.

Ability to Finance New Investment

It is estimated that the corn  dry millers' ability to finance new  invest-
ment is comparable to the grain milling industry  in general.  No spec-
ific data are available to suggest either a better or worse ability.  The
financial characteristics of the grain milling industry in general were
presented  previously in the  section on bulgur processing.  Summary data
are presented in Table II-8 above.
                                11-38

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          Table 11-16.  Summary of financial data pertaining to the corn dry milling model plants
Values
Item
Utilization
Annual throughput
Sales
Raw Product Costs

Variable costs
Fixed costs
Cash earnings
Depreciation
Interest
Pre-tax income
Net income
After-tax cash flow
Replacement costs
Working capital
Current liabilities
Average Fixed Investment (AFI)
Pre-tax income /AFI
Net income /AFI
Cash flow/AFI
Net income/ sales
Units
%
1,000 bu
$1,000
$1,000

11
it
* 1
1 1
it
1 1
it
it
it
1 1
it
it
Ratio
ii
1 1
ti
15,000 bu/day
100%
3,900
8,580
5, 187

2,340
585
468
142.6
60
265.4
138
280.6
3, 100
1,716
686.4
2,579.6
. 103
.053
. 109
.016
30,000 bu/day
100%
7,800
17, 160
10,374

4,287
1,251
1,248
285
120
843
439
724
6, 199
3, 120
1,248
4,971
. 170
.088
. 146
.026
Remarks
260 days = 52 wks x 5 - 24 hr. days
260 days x 30, 000 bu x 100%
$2.20/bu. value, f.o.b., mill
$1.33/bu. No. 2, yellow corn,
Chicago, 1967-71 ave.
77% of operating cost, excluding corn
23% of operating cost, excluding corn

6% equipment; 4% buildings
.7% sales



30% equipment; 70% buildings
20% sales
40% total working capital





Note: Financial data for the 30,000 bu/day plant (moderately large) are presented in the text.  Data for the
      15, 000 bu/day plant are subsequently used in the Impact Analysis section below.

-------
                    Corn Dry Milling Pricing
Prices in the  corn dry milling industry involve three principal products:
corn grits,  corn meal and corn flour.   These products comprise approxi-
mately 70 percent of the total weight of the  corn  milled.  A  small per-
centage of the remainder is  processed into  corn  oil.  The rest is  sold
as hominy feed for animals.

Mills are highly  flexible and can vary the percentages of the principal
products according to consumer demand.  Typical yields in estimated
pounds per bushel processed are  shown in Table  II-17   .   The product
mix can and does vary from day to day  depending upon the quality of
corn being milled, the type  of milling equipment used and the product
specifications sought.

Price Determination

Demand

A majority of the products of the  corn dry milling industry are used
for human consumption.  The byproducts are utilized  as  livestock
feed.  Some products have limited uses in non-food industrial production.
The primary products: Corn meal, corn grits and corn flour are used
directly in home  meal preparation.  They are also used widely in the
food processing industry as  ingredients in prepared mixes  and other
food products. Besides being used as a  food  ingredient,  corn flour
that has been  specially processed  is used in industry as a binder and
bonding agent. With the exception of corn oil, the fractions  remaining
after the removal of  the primary  products are mixed together and sold
as hominy feed which is an ingredient with exceptional nutritional value
for many types of livestock  feeds.

Table II-1?  shows the per capita  consumption of corn dry milling
primary pi oducts for the years 1950 to 1972. After many years of
decline,  corn meal and flour show a slight increase in per capita
consumption,,  Prepared cereal consumption has increased over the
years as consumer demand  responded to the heavy use of advertising
by the industry.  The per capita consumption of hominy and grits  has
declined slightly after reaching a high point in the early  1960's.

There are two general classes of corn meal,  whole corn meal and de-
germed corn meal.   Whole corn meal is produced by grinding the whole
corn kernel.  The resulting meal is packaged into small, consumer
sized packages.  The whole  corn  meal may be sifted or bolted to remove

                              11-40

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 Table  II-17. Corn dry milling,  products by percent and weight of
                     bushel of corn processed
                      (degerming system) _'

                              Yield as percent       Estimated pounds
Final Products	of bushel processed	perjjushel processed
Corn grits
Corn meal
Corn flour
Hominy Feed
Corn oil
Shrinkage
Total
35.0
30.0
5.0
25.0
1.0
4.0
100.0
19.6
16.8
2.8
14.0
.6
2.2
56.0
—  Brekke, O.  L. ,  "Corn Dry Milling Industry, " in Corn: Culture,
   Processing, Products.  G. E. Inglett, editor, Westport,  Connecticut:
   The Avi Publishing Co. ,  1970.
                           11-41

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      Table II-18. Per capita consumption of selected corn
                 dry milling products , 1950-197 1
Year
1950
1955
1960
1965
1966
1967
1968
1969
1970
1971
Cornmeal
and
flour
11.8
8.7
6.6
6.5
6.9
7.2
7.3
7.4
7.4
7.4
Hominy
and
grits
2.6
2.7
4.0
4,5
4.4
4.2
4.2
4.2
4.2
4.2
Prepared
ce reals
1.5
1.7
1.9
2.2
2.2
2.3
2.3
2.3
2.3
2.3
Source:  National Food Situation, U.S.D.A,
                              11-42

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particles  of hull and some of the germ to improve the color and texture
of the final product. "Whole  or bolted meal has a short shelf life because
of its high fat content, large surface area, and the action of naturally
occurring enzymes.  Small mills located primarily in the South continue
to market whole corn meal to the local trade.  Because it must be con-
sumed in  a relatively short time after grinding, whole corn meal does
not lend itself to large corn  dry milling operations or long channels of
distribution.

Degermed corn meal is produced in larger, more modern mills and has
improved color and shelf life because the  oil containing germ is removed
before milling.  Consumers  prefer degermed corn meal in comparison
to whole corn meal for most uses because of its improved appearance.  —'
Degermed corn meal is preferred by  food processors for use in prepared
mixes and as an ingredient in other foods  because of  its appearance and
also because of its greater storage life.  Table II- 19 shows the amounts
of both types of corn meal shipped. Although both whole corn meal and
degermed corn meal are  declining as percentages of  total  corn  meal
production,  degermed corn meal is declining less rapidly.  Most of the
decline in production of degermed corn meal can be attributed to  the in-
creased production of corn flour.

The demand for corn flour has increased dramatically in the past few
years as  the demand for snack foods and breakfast cereals has  increased.
This increase in demand  has shifted  corn flour's role from that of a
byproduct to primary product.  Some dry  corn millers have found it
profitable at times to make 100 percent runs of corn  flour at the expense
of meal and grits.  Corn  flour that has been  gelatinized is  also  used in
non-food  industrial applications  such  as a binder for  sand  cores for metal
casting and  as a bonding agent in pelletizing  ores.

Corn grits,  sometimes called hominy grits,  are the largest particle
size product from the corn dry milling process.  When used directly
as a human  food they are simply cooked in boiling water until the tex-
ture has a pleasing balance of soft grittiness and smoothness.   The
greatest demand for corn grits has traditionally been in the South,
although the use of corn grits has been increasing in  other parts of the
country.

As  shown in Table  II*!?,   the use of grits for direct human consumption
as a percentage of  total corn grit production has  dropped substantially
because the demand for brewer's grits and flaking grits has increased
greatly in the past  few years.  Corn grits and flakes  are used by brewer's
JL' Brockington, S. F. "Corn Dry Milled Products" in Corn:  Culture,
   Processing,  Products.  Editor,  G. E. Inglett. Westport, Conn:
   The Avi Publishing Co. ,  1970, pp.  292-306.
                              11-43

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      Table 11-19. Corn dry milling - shipments of products —

                                              Amount Shipped
                                     1958          1963          1967
                                1,000         1,000          1,000
Corn Product	cwt    %	cwt    %      cwt    %

Corn meal for human consumption:
   Whole corn meal              4,900   31     5,042    27     6,543   25
   Degermed corn meal          6,822   43     7,529    41     9,863   38
   Cornflour                    1,675   11     1,652     9     4,003   15

Corn meal for animal feed:       2,314   15     4,281    23     5,700   22

    Total                       15,711  100    18,504   100   26,109   100

Grits and hominy for human
consumption:                    3,976   33    12,807    54     7,454   36

Brewer's  grits and flakes         8, 112   67    10,813    46   13,028   64

    Total                       12,088  100    23,620   100   20,482   100
I/
—  Does not include hominy feed and other byproducts or corn oil.

Source: Bureau of the Census, Census of Manufacters , U.  S. Department
         of Commerce,  1967.
                             11-44

-------
as a source of carbohydrate.  Brewer's generally specify requirements
for moisture, fat content,  crude carbohydrate extract, and granulation
when ordering corn grits from millers.  In order to increase brewing
capacity, some brewers call for specially processed grit flakes with
varying degrees of sta rch modification to increase  the rate of fermen-
tation.  Flaking grits are also used in the manufacture of corn flakes and
snack type ready-to-eat foods.  The demand for Brewer's grits and
flakes is directly influenced by the demand for the end food products
and according to all indicators the increase  in demand should continue.

The corn kernel contains only about 5 percent oil and it is not economically
feasible  to process corn just for the oil.  Corn oil is a byproduct of  corn
dry milling and the demand for corn oil has  little if any effect on the
amount of corn  processed.  Due to the  increasing awareness of the im-
portance of polyunsaturated fatty acids in the diet,  the use of corn oil
in margarines and as-  a  salad  and cooking oil has increased substantially
in the past few years.   Because of the strong demand and relatively  in-
flexible supply, the price of crude corn oil fluctuates erratically.
Besides  the special uses for corn oil, demand and price is influenced
by competition from  other  grain and vegetable oil sources such as soy-
bean, cottonseed, peanut,  palm and safflower oils.

Hominy feed is  a manufactured product which includes corn bran,
corn  germ from whit h oil has been expelled and part of the starchy
portion remaining a fler grits, meal, and flour have been removed.
It is a low protein, 1 i gh energy product that is a more economical
source of protein an-! energy than available feed grains for certain
livestock operations .  Hominy feed prices are regularly reported
along with other feed  ingredients competing  in the same market.  Some
of the competing feedstuffs include wheat millfeeds, rice  bran,  alfalfa
meal and feeding quality molasses.

Table II- 20 summarizes the level  01" •*        for all corn dry milling
products by quantity and value of shipi^	as reported by the Census
of Manufactures.  The total value of shipments for  1967 was $270.6 million
when 117 million bushels of corn were milled.  In 1972 about 116 million
bushels of corn were  milled,  a slight decrease from  1967.  The total
dollar value of shipments will be higher because of inflation but more
important are the shifts that have occurred in product mix.  When
production figures become available for 1972 they will probably show
the trends continuing  toward corn flour and Brewer's grits and away
from whole  corn meal and  grits other than for brewer's use.
                             11-45

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     Table  11-20. Quantity and value of shipments by all producers in SIC 20413: Corn Dry Milling, 1963 and 1967
Proo.'-t

Corn Mill Products, Totali'

Total
Quantity
1963 1967
(million
_
pounds)
_
Shipments Including Interplant Transfers
Value
1963 1967
(million
201.6
pounds)
270. 6
Imputed Price per Pound
1963 1967
(cents per pound)
•• *.
Corn Products -Human Consumption
Whole Cornmeal
Degermed Cornmeal
Corn Grita and Hominy
except for Brewer's use
Corn Grits and Hominy
for Brewer's use
Corn Flour
Feed Products
Cornmeal for animal feed
Hominy Feed and other by-
products
Corn Oili/
Misc. Corn Mill Products

504. 2
752.9

1,280.7

1,081.3
-

428. 1

1,396.0
71.0
165.2
654. 3
986. 7

745.4

1,302. 8
400. 3

570. 0

1,896.0
71.0
-
22. 8
33. 8

48.0

38. 5
-

11. 8

31.4
8.6
6.7
36. 1
49-9

40. 0

53. 1
23.6

16.0

42.2
8. 8
• 9
.045 .055
.045 .051

.037 .054

.035 .041
.059

. 027 . 028

.022 .022
.121 .124
. 041
_'Adjusted to include the value of corn oil.
£/U.S. Fats and Oils Statistics 1950-71,  ERS, USDA, Statistical Bulletin No. 489-

Source:  Bureau of the Census, Census of Manufacturers ,  U.S.  Department of Commerce,  1967.

-------
Supply

Supply of corn dry milling products in total has remained fairly con-
stant over the past few years.  Use of corn dry milling products in direct
food use has declined significantly over the past twenty years but has
been offset by the growing use of the products  as ingredients in pro-
cessed foods.

The supply of corn dry milling products is in direct  relationship to
the amount of corn milled by the  industry.  The annual volumes milled
and the volumes as a percentage  of the utilization of the total U.S.  corn
crop are  shown in Table   11-21  .  The annual volume of corn processed,
although fluctuating slightly, has remained relatively constant during  the
1967- 1972 period. The annual volume  is generally a declining percentage
of the total U.S.  corn crop.

Since the corn dry milling industry utilizes only a  small and declining
portion of the total corn supply, the availability of corn as an input
does not constitute a limiting factor of  production.  Corn dry millers
do purchase  shelled corn competitively in a market largely dominated
by feed manufactures and are  affected by the same factors that influence
the feed market.

Prices

Prices for the end products of the corn dry milling industry are  deter-
mined in  four basic markets:  (1) the  market for home use of cereal
products,  (2) the  food processing ingredient market,  (3) the fats and
oils market, and  (4)  the livestock feed  ingredient market.   These
separate  markets are closely  related because  the same grains  with
a few exceptions,  compete  in all  four markets.  Table II-?2 Compares
the price of corn  to the prices for various end products of the  corn dry
milling industry.  In 1972 and 1973, livestock feed demands and  unusual
increases in exports  of U.S. grain commodities  seriously disrupted
livestock feed markets causing similar disruptions in the other three
markets in which  corn dry milling products were sold.  The result was
a sharp increase  in the price of corn,  the basic input and in the prices
of the products.

Due to the present unsettled condition of the markets in which corn dry
milled products are sold,  the  unusual recent prices,  and the need for
price data to assess  the financial impacts of anticipated water pollution
control costs,  average 1967-1971 prices  were developed for the  model
plant analysis.  The  estimated values used in this  study are shown in
Table 11-23 along with the representative  gross margin developed from
the data.
                              11-47

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    Table  11-21. Total use of corn by the corn dry milling industry
                            1967-1972

                     Use, Dry Milling        Percent of Total U.  S.
Year	Mill. Bu.	Corn Utilization

1967                       117                      2.6
1968                       114                      2.5
1969                       116                      2.4
1970                       119                      2.6
1971                       115                      2.2
1972                       116                      2.0
Source: Feed Situation,  ERS, USDA, 1967-1972
                              11-48

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   Table  11-22.  Corn Dry Milling - prices of input and products
Corn No. 2 Grits
Yellow Bulk
Chicago N.Y.

1967-71 ave.
1972 ave.
1973
Jan. 15
Feb. 15
Mar. 15
April 15
May 15
June 15
$/bu
1.33
1.36

1.74
1.66
1.69
1.74
1.80
2. 12
$/cwt
4.29
4.23

4.64
4.85
4.80
5.01
5.69
6.40
Meal
Yellow
N.Y.
$/cwt
4.79
5.49

6.00
6. 15
6.37
6.05
6.75
7.45
Hominy
Feed
Chicago
$/ton
41.64
54.50

60.50
58.50
59.00
54.00
60. 00
74.00
Corn Oil
Crude
Midwest Mills
f/lb
. 156
. 165

. 178
. 173




Source:  Milling and Baking News
                               11-49

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Table II-2J. Corn dry milling, gross margin per bushel of corn
                 processed (degermining system)
Estimated Pounds
per bu. processed
Final Products
Corn Grits
Corn Meal
Corn Flour
Hominy Feed
Corn Oil
Shrinkage
Total
Cost of Raw Material —
Gross Margin

19.6
16.8
2.8
14.0
.6
2.2
56.0


Price per
pound —

.043
.048
.056
.OZ1
. 156
--



Value per
bu. Ground

.843
.806
. 157
.294
.094
--
2. 194
1.330
.864
—  Brekke,  O. L. , "Corn Dry Milling Industry, " in Corn:  Culture,  Processing
   Products.  G.  E.  Inglett,  editor, Westport,  Connecticut:  The Avi Publishing
   Co.,  1970.
—' 1967-71 average prices.  Source:  Milling and Baking News,  1967-1971.
—  Average  price  of corn grits and hominy for human consumption as well as
   brewer1 s use.
—' 1967-71 average price No.  2 yellow, Chicago.
                              11-50

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                III.   SIC 2044:  RICE MILLING
Rough or hulled rice is milled by one of two processes:  (1) conventional
or regular milling  (a dry process),  (2) parboiled rice milling (a wet
steeping process).   Only the  latter is of concern from the standpoint
of water pollution control.  The following discussion will therefore
be concentrated on parboiling plants in the Industry.
                          Industry Segments
At the beginning of 1973, there were a total of 42 rice mills in the U.S.
which were operated by 36 firms.  Of this total, only 6 mills included
parboiling operations.  Only one mill was strictly a parboiling plant and
the others had mixed operations, i.e., part of the production was dry-
milled and part was parboiled.

Two firms in the industry also produce precooked rice for distribution.
This  is a post-milling process but waste water is  generated and wastes
maybe a problem.  No further analysis of precooked rice operations is
planned  herein but these operations  may warrant further study.

Types of Firms

The six  parboiling mills are owned and operated by six  separate firms.
 Four of the firms are single-plant firms; and two have two mills each,
although only one mill in each firm is involved in parboiling.  The five
parboiling mills are  identified in Table III-l.

Precise estimates of mill size are not yet known,  but relative  to the
rest of the industry,  the parboiling mills are all large operations.  The
firms are consequently also considered large  firms in the industry.

Regular  rice mills in Arkansas and California are frequently cooperatively
owned b/ farmers and thereby integrated backward to the farm level.  How-
ever, all parboiling  mills  but one are privately held and rice is competitively
purchased on a sealed-bid basis. Thus, the firms of concern are not inte-
grated backward to the farm level.   On the other hand,  the parboiling firms
tend to be integrated  forward in terms of packaging sales and distributing
functions to retail markets or other outlets.
                                      III-l

-------
  Table III-  1.      Listing of parboiling rice mills (and precooked rice
                producers) and their plant locations

                                               Number of Total Mills
Parboiling Plants and Location                   Operated by Firm

Blue Ribbon Rice Mills, Inc.
Box 2587
Houston, Texas  77001                                  1

P &L S Rice  Mills, Inc.
Box 55040
Houston, Texas  77055                                  1

Comet Rice Mills, Inc.
(Subsidiary of Early California Industries, Inc.)
Box 1681
Houston, Texas  77001                                  2

Uncle Ben's, Inc.
Box 1752
Houston, Texas  77001                                  1

Riceland Foods
Box 927
Stuttgart, Arkansas  72160                              2

Rice Grower Association of California                     1
111 Sutler Street
San Francisco, California 94104
Plant:  Sacramento, California

Precooked Rice Producers

Riviana Foods
Box 2636
Houston,  Texas  77001                                  3

Uncle Ben's, Inc.
Box 1752
Houston,  Texas  77001                                  1

Source:  Rice Millers Association

                                III-2

-------
 Four  of the six  firms are involved with milling only rice products,
 one firm produces  limited other food products, and one firm produces
 both rice and soybean food products plus associated milling byproducts.
 The level of  diversification of the firms involved in parboiling is con-
 sidered limited on  the basis of the above descriptions.

 A general indication of the relative importance and dominance of the
 largest rice milling firms is shown in Table III-Z for the 4, 8, ZO and
 50 largest companies as  of 1967.  Since that time about 18 companies
 (with mostly small mills) have left the industry,  but the data shown are
 still reflective of the relative  importance  of the larger rice milling com-
 panies .

 Types of Plants

 Most plants in  the  rice milling industry are said  to  range  in capacity
 from 150 to 800 cwt. per hour.  The  parboiling operations are believed
 to involve plants  with 500 cwt.  per hour or more capacities, although
 only in one plant  is all  rice parboiled prior  to milling.  Hence, par-
 boiling must generally  be considered in conjunction with regular  milling
 ope rations.

 Only seven rice mills  are known to have been built in the last 15  years,
 •with the vast majority having been built more than 15 years ago.   All
 of the parboiling  plants are older  mills, although all but one has  'cur-
 rent1  or modern equipment.   Plant buildings are  reported to be in good
 shape.   The age of the  plant, per  se, does not indicate the level of
 technology employed in that worn  equipment is typically replaced as
 required •with modern equipment.

 Rice mills are  typically located in or near the areas  of rice production.
 Four Southern  states (Texas,  Louisiana, Arkansas and Mississippi)
 plus California are the  major  rice producing states and also contain
 almost all rice mills.   Parboiling plants are also concentrated with
 four in Texas (all in Houston) ,  one in Arkansas (in Stuttgart), and
 one in California  (in Sacramento).

 The milling yield of head  rice  (efficiency)  tends to be fairly uniform in
the industry.  One characteristic of parboiling is  to improve  the head
 rice yield  somewhat with  fewer broken heads because of the hardening
effect of parboiling on the rice kernel.  Some sources have indicated
that the higher  head rice  yield due to parboiling is sufficient to essentially
offset the higher processing  cost of parboiling.
                                 Ill-3

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Table HI-2. Percent of selected statistics  accounted for by the 4,  8,
     and 50 largest companies ranked on value of shipments  in
     Indastry  2041:  Flour and Other Grain Mill Products, 1967
20
Percent Accounted for by Largest Companies
Total -
No. companies 438
No. establishments 541
Value of shipments $2,457.4
All employees:
Number (1,000) 20.5
Payroll $142.9
Production workers:
Number (1,000) 14.8
Man-hours 33.2
Wages $ 95.5
Value added by manu-
facture $491.3
Capital expenditures , new:
Total $ 26.3
Structures and additions
to plant $ 6.3
Machinery £z equipment $ 20.0
Cost of materials $1,966.0
i' 4
X
7
30

23
27

24
25
30

30

19

24
18
30
8
X
12
46

36
41

37
37
44

54

42

56
38
44
20
X
19
70

56
61

57
57
65

70

68

68
68
70
50
X
27
89

76
81

77
77
83

87

84

84
84
89
— Values in millions except as indicated
Source: Concentration Ratios in Manufacturing,
Concentration Ratios , U.
Part 2,
S. Dept. Commerce,
Product
1971.
Class

                                 IH-4

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Number of Plants and Employment by Segment

As indicated, only  six parboiling rice mills are in operation in the
rice milling industry.  Also, all are  considered to be large mills rela-
tive to the remainder of the  industry.  Consequently, only a  single
category of plants is  required to characterize the types of plants which
will be  impacted by water pollution controls,  i.e. ,  large  parboiling
rice mills.

Based on secondary data,  employment in each parboiling  mill is esti-
mated to average between 1Z5 and 175 employees.   In 1967,  based on
Census of Manufacturer's data, the thirteen plants associated with the
four largest companies had an average employment of 139 employees
per plant.  Since  1967, the  number of mills has continued to fall,  but
the average mill size has increased.

Selection of Segments  to Total Industry

Parboiling rice mills  represent only  14 percent of the mills  in the in-
dustry,  i.e., 6 out of 42 mills .  Inl971/7Z, these mills produced 11. 9
million hundredweight of parboiled rice out of a total milled  volume of
86.0 million hundredweight.  On a percentage basis, this represents
13.8 percent of the total volume milled.   Comparison of the  13.8 percent
of volume milled with the 14 percent of parboiling plants in the industry
suggests that parboiling operations are only average in size. However,
five of the six parboilers also produce regular milled rice which would
add to the relative size of the overall plant operations-

Total industry employment is currently estimated as 4,000 employees.
The estimated employment in parboiling plants  is 900 or  22. 5 percent of
the total (est. 150  employees per plant).   Hence, approximately  one-fifth
of the industry employment could be affected as a result of water pollution
abatement programs.

Likely Impacted Segments

As  noted above, all six parboiling plants are considered  to belong in a
single category of large mills with parboiling operations.  The impacts
of water pollution controls are therefore expected to be relatively com-
parable among all parboiling plants.
                                Ill-5

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Wastewater is produced as drainage from the parboiling process and
also as waste from steam production.   The former wastewater contains
considerable BOD, COD and dissolved solids loadings.  Consequently,
treatment requirements are expected to be  significant for the parboiling
plants.

The  scope of study for the rice milling industry has been narrowed to
only 6  of 42 mills which have parboiling operations.  The remaining
mills are conventional or regular rice mills (dry processing only) which
do not  require water in their milling processes.

                         Financial Profile
 Limited financial data on regular rice milling (dry process) were found
 in the literature. _'   However,  no financial data on parboiled rice milling
 operations, per  se, were found. The former data have much applicability,
 though, because  the milling operations are similar once rough rice has
 been parboiled and dried prior to milling.

 Parboiled rice mills are known to be large in general ranging from
 about 500 to 800  cwt. /hour capacities. Because plant financial data
 were unavailable, the procedure was to synthesize a model plant  situ-
 ation.  Only one  size  plant (large) is considered adequate to measure
 the relative water pollution control impacts on parboiled rice operations.

 Plants by Segment

 Only large parboiled rice mills are  of concern in this study.  There are
 6 such mills in the U.S.--4 in Houston, Texas, 1 in Stuttgart,  Arkansas, and
 one in Sacramento,  California as previously identified.  A model  plant with a
 500 cwt/hour capacity was chosen.   This  plant was on the lower end of the
 large-size category, and the impacts expected in this situation should be as
 great as expected for  any larger size plant.

 The model plant  is said to operate at "100%" of capacity where  100%
 is defined as  4,000 production hours (or 250 days x 16 hrs per day).
 The level of production is often termed ' 100%' of capacity in the milling
 industry with the understanding that a mill may exceed the 100% utilization
 standard.  Thus, 100% utilization is not unrealistic and it represents re-
 cent milling experiences in the  industry.
-  Wilson  Dale W. and David Volkin, "A Plan for Integrated Rice
   Marketing in Louisiana," Service Report 130, Farmer Coop. Service,
   USDA,  Feb., 1973; and Eiland, J. C. and Theo.  F. Moriak,   Rice
   Milling Costs in the United States, 1971/72,",  ERS, USDA,  Mar.,  1973.
                               Ill-6

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 Annual Profit Before Taxes

 According to the model plant procedures and operating assumptions imple-
 mented,  the estimated  annual pre-tax income and selected rates  of return
 on average fixed investment are as shown in Table III-3.  After tax ROI
          O
 is  estimated as 6. 0 percent and after-tax earnings on sales is  1.6 percent.

Average  fixed investment,  on which the  above rates of  return were
 calculated, was derived by dividing replacements costs by two  (an
 estimate  of average fixed investment) plus total working capital (current
assets) minus current liabilities (based  on grain milling averages).   This
 average fixed investment value is  intended to approximate invested capital
 in  reported financial data.  After tax income was based on a. 48% tax  rate
without either carry forward or back tax provisions.

 The profitability of rice mill operations  has  varied in the past, most
 often as a result of world rice market situations  rather than changes  in
domestic market conditions.   There is currently a world rice  shortage
and exports  have increased sharply with reduced and below average
 carryover stocks available for future distnbution.

Annual Cash flow

Estimated annual cashflow  (after tax  income plus depreciation)  and the
 ratio of cash flow to average  fixed investment are as shown in  Table
III-4 for  the selected model plant.   Depreciation  for the mill was based
 on  a composite discount rate  uf S.  9% (reported by Eiland and Moriak,
 see above) for both buildings  and equipment   Also,  buildings arc esti-
mated to  equal about 40 percent of the plant  investment, and equipment
about 60  percent.

 The annual cashflow of  $466,000 is also  J.2% of sales.  The percentages
 shown appear  comparable to other milling industry ratios.

Market (Salvage) Value  of Assets

Large rice mills with modern equipment would have a reasonable salvage
value to other rice mill operators  in the  industry.  Small mills would
have little value, as most small millers  have generally sought to
consolidate operations to gain throughput economies of  operation,, _'

Since this study is concerned only  with larger operations,  then  there is
presumably a positive salvage value.   This is  confirmed by industry
sources,  although no precise  estimates were given.  As a  rough estimate,
salvage values  of about  50  percent of  book value for well-located and good
condition mills might be expected.
—  Wilson and Volkin,  op.  cit.  This analysis sought an integrated oper-
   ation plan  to improve the economic viability of rice milling in Louisiana.

                                Ill-7

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  Table lli-3 .Estimated pre-tax income and rate of return on average
      invested capital and after-tax return on sales for a large
                     parboiled rice mill
Financial measure                                       Value

Pre-tax net income ($000)                                 463

Pre-tax ROI* (%)                                        11.6

After-tax ROI*  (%)                                        6.0

After-tax return on sales (%)                              1.6
*/  Average return on fixed investment calculated by financial statement
    method.
                               Ill-8

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   Table III-4.Estimated cash flow for a large parboiled rice mill
Financial measure                                   Value
Annual cash flow ($000)                               466

Cash flow on average fixed
   investment (%)                                   11.7
                                  III-9

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Capital Structure - The average fixed investment in parboiled  rice
milling was estimated as $3. 994 million for the model plant described,
and sales were estimated as $14,760 million per year.   This yields
sales of $3.70 for each $1.00 of investment.   This  level is rather
typical  of agricultural processing industries where value added is
not especially high.

The capital required to generate such a ratio for the model parboiled
rice mill are as shown in Table III-5.  The replacement value of $3.813
million assumes a breakdown of 60% equipment and 40% for buildings
and site.  Total working capital of $3. 480 million is estimated to equal
25% of fixed and variable operating costs, including raw product  (rough
rice)  costs.

As  shown, working capital requirements are comparable in magnitude
to the plant investment capital requirements.   This occurs because
relatively expensive inventories of  grain must be purchased and stored
prior to processing, and sales  may remain as  accounts  receivables for
30-60 days following delivery.

Cost Structure - Model plant data and budgets were prepared to  estimate
the cost structure of representative operations.

Fixed or plant related expenses were  defined as those which do not directly
vary as a function of throughput.  These expenses include:

          maintenance and supplies
          taxes and insurance
          plant and labor overhead
          sales,  general and administrative

Additionally cost estimates were made for depreciation  and interest costs.
Variable or production related  expenses were defined as those which will
generally vary proportionately  with throughput --in other words, a fixed
amount per unit processed.  They  include:

          raw materials
          powe r
          wa te r
          process supplies, chemicals,  etc.
          operating labor
          plant  supervision and fringe benefits.
                               Ill-10

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  Table III-5.  Estimated replacement value and working capital requirements
                             for a  large  parboiled  rice mill
Capital component                                   Requirement
                                                        ($000)

Replacement value of plant,                              3,813
   equipment & site

Total working  capital                                    3, 480

Replacement value of                                    7, 293
   total assets
                                 III-11

-------
Fixed Costs  - Indirect operating costs, as shown in Table I1I-6, for
the budgeted parboiled rice mill  represent 3.8 percent of sales.  The
dominance of rough rice  purchase costs (75, 1% of sales) accounts for
this relatively low cost component.  Again, this type of cost structure
is common among agricultural processing industries.

Depreciation is also a  small  percent of sales, i.e. , 1. 5% of sales
as shown.  Accordingly,  fixed asset capital requirements  of rice
milling, as reflected in annual depreciation estimates, are relatively
low relative  to other input costs.

Interest costs as  estimated are equal to 1.0% of sales.  The basis for
the interest cost was $.,076 per cwt. of rough rice milled.  This cost
reflects interest allowances both for fixed assets and borrowed working
capital.

Variable Costs  -  Variable costs  for rice  milling are also  shown in
Table III-6 for two major components:  raw materials (rough rice)
and direct operating costs.  Raw materials costs, as noted, were
estimated  to equal 75.  1% of sales.   This  percentage for parboiled rice
is lower than in regular  rice milling,  however, because processing
requirements and costs are greater due to parboiling.

Direct operating costs, representing 15.4% of sales, are the second
largest cost component of rice milling.  In general, direct costs in the
large-scale plant model are expected to be relatively (as well as absolutely)
lower than would  be the case in smaller plants.  In subsequent study,
further consideration will be given to scale economies even among the
larger mills, e.g., 500  cwt. /hour and up.

Distribution of Model Plant Financial Data

The most useful individual rice milling plant financial data were limited
to the two  sources cited.  These data were partially but not completely
applicable since the studies involved only regular rice mill operations.
Even so, they did serve  as a basis for constructing the representative
plant model for a large-scale parboiled rice  mill.

It was intended that only one  model plant be  constructed since all par-
boiled rice mills  are large.  However, one would still like to complete
some sensitivity analyses to  assess critical variables in the parboiling
operations.  In the impact analysis phase, such analyses are expected.
                               Ill-12

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  Table III-6.  Estimated costs for a  large parboiled rice mill









   Item                                $000                   Percent





Sales                                14,760                     100.0




Raw materials                       11,080                     75.1




Direct operating costs                  2,272                     15.4




Indirect operating costs                  568                      3. 8




Depreciation                             225                      1.5




Interest                                  152                      1.0




Total before-tax cost                 14,297                     96.9
                              III-13

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To further illustrate the financial characteristics pertaining to the  par-
boiled rice milling model plant, a summary of key financial data are as
shown in Table III-7.

The Rice Millers Association, an industry association,  represents
most rice millers,  especially in the southern states.  This Association
was quite cooperative in supplying general industry information for this
study to the extent possible.   Two limitations were:  (1) the association
does not collect  or analyze financial data of individual plants,  and (2)
disclosure guidelines  prohibit release of individual plant production
and distribution  reports.  Aggregate production and distribution data
are published by the association and this information is publicly available.

Under the time constraints of this study it has not yet been possible to
verify the production and financial data presented for the model plant.
Wherever data were missing, it was necessary to make personal judg-
ments and approximations.  A variety of selected financial data and
ratios, such as from IRS business statistics, Dun  &  Bradstreet, Fortune
and other sources were used as guides and indicators of likely plant char-
acteristics.  Census of Manufactures  reports (of SIC 2044 in particular)
were also helpful.

Because the model plant is intended to reflect 'normal1  financial con-
ditions in the  industry,  average cost and price data (prices for 1968-71)
were used.  This was especially critical in that only very recently have
rice prices increased dramatically to record highs in face  of world rice
supply shortages.   Current and/or near term market conditions are
simply not considered representative  of normal conditions.
                                Ill-14

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     Table III-7.   Summary of financial data pertainin > to the
                  parbo led rice nilling  node! plant
Item
Unils
                                                                R
-rks
Utilization
Annual throughput
Sales
Raw product costs
Variable costs
Fixed costs
Cash earnings
Depreciation
Interest
Pre-tax income
After tax cash flow
Net income
Replacement cost
Working capital
Current liabilities
Ave. -fixed investment
Pre-tax income/AFI
Net income/AFI
Cash flow/AFI
Net income/sales
%
. , ' 00 cwt.
; ] ,'100
! 1
! 1
1!
1 I
1 !
! t
I t
1 1
"
I 1
1 t
I |
(AFI)
Ratio
! f
1 f
ft
00%
2 iOO
'4, ,'60
11 ,1180
2, 272
^68
£40
225
152
463
466
241
3,813
3;480
1,392
3,994
. 1159
. 0603
. 1167
. 0163
250 -lays x In rs - 100^
R o u . h r i c r , e cl ba s i s
$7. -18/cwt. value (rou^h)
$5. ^47 cwt t . b. mill
H0% jpf-rat. ie "ost excl. r. rice
20% operating cost excl. r. rice

5. 9% replai e.nent cost
$. 076 per cwt




25% operating costs
40% total working capital





                                  III-15

-------
Ability to Finance New Investment

General requirements for financing new investment were set forth in the
earlier section on bulgur, along with general financial data for the mill-
ing industry in general (see  Table II-8 ).

The only financial data currently available on rice  milling plants is in a
study entitled,  A Plan for Integrated Rice Marketing  in Louisiana. LJ
The report analyzes six mills,  with no company identification, and presents
condensed operating statements and balance sheets.  Data are for 1969,
1970 and 1971 and permit an evaluation of the financial structure and
strength of this particular group of mills,,  Since these mills are not en-
gaged in parboiling, they are not strictly comparable to mills  which would
be impacted by pollution  control requirements.

The combined mills had net  sales of $35. 7 million to $41. 7 million during
each of the three years,  1969-1971.   The gross margin on sales ranged
from  12.9 percent in 1970 to 14.8 percent in 1969.  Three of the six mills
lost money in 1969, with the composite loss amounting to $79,000.   Four
mills showed losses in 1970 with a composite loss  of $195, 000.   All six
showed a pre-tax profit in 1971 totalling $485, 000 or 1.2 percent on sales.
Because of prior years' losses, after-tax income is  unknown.

The six mills had a total investment of $7. 1 million at the end of 1971,
with $4. 4 million in net worth.   Total debt amounted to $2.7 million or
61 percent of net worth.  Long-term debt was  only 7 percent of net worth,
an extremely low ratio in comparison to other  manufacturing industries.
The $485, 000 before-tax profit in 1971 amounted to 11 percent of net worth.

In terms of cash flow,  the mills reported $342, 000 to $371,  000  in deprecia-
tion,  or  4.4 to 5. 3 percent of total assets.  If the 1971 level of profits can
be maintained, the mills will be in a relatively strong cash  flow  position.
Continued profits combined  with the extremely low debt situation, would
place these mills in an excellent position to finance new investment.

It must be recognized, however, that the  1971 turn-around in operations
from losses to profitability  does not constitute a trend.   Obviously,  if
operating losses reoccur in the near future,  this group of mills could not
finance new investment.  Data  are not available for these mills  for 1972,
but the strength of world rice prices and U. S. exports  indicate that the
industry should be in a stronger position than in 1971.
 U Dale W. Wilson and David Volkin, A Plan for Integrated Rice Marketing
   in Louisiana, Farmer Cooperative Service, USDA, Service  Report No.
   130, February, 1973.
                                   Ill-16

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As noted previously, these six mills are not strictly comparable to mills
which parboil rice.  The value of any comparison depends upon the relative
financial condition of other mills.   It seems reasonable to assume  that the
parboiling mills are larger and more profitable than the six Louisiana
mills.   They are better located for export markets.  If they are earning at
or above the level of the six mills in 1971,  they should have no difficulty
in financing new investment for pollution abatement.   Internally generated
funds (net profits and depreciation) and borrowing capability would appear
adequate.  Since no  financial data are available on the  other firms, however,
any conclusions as to financial condition remains pure conjecture.  Under
the present time limitations, no valid estimate of ability to finance new
investment is possible.   The contractor intends to seek additional financial
data  on rice milling for inclusion in the Phase II report.

                               Pricing
  Price determination and expected price changes in the  rice milling in-
  dustry are  related first to various end products and byproducts of rice
  milling and their respective markets.  As illustrated in Figure III-l,
  the main milled rice components are hulls,  head rice,  brokens (second
  heads, screenings and brewers),  bran and polish.  A growing export
  demand  for brown rice (dehulled only) also exists.   Each component of
  total supply maybe influenced differently in its respective markets given
  a change in supply of total milled rice  (and associated byproducts).

  Price Determination

  Both demand  and supply  conditions are summarized below to gain an
  understanding of how prices are determined for rice.

  Demand

  In recent years total shipments of U.S. milled rice (excluding only
  hulls, bran and polish) have been broadly:  60 percent to exports  and
  40 percent to domestic trade.  Foreign markets are quite important
  in rice marketing as suggested by the high proportion of export ship-
  ments.  A major factor in the  export market has been that approximately
  two-thirds of total exports have been financed under Title I of P.L.  480.
  The balance has been dollar exports including shipments to U.S.  terri-
  tories.  In addition,  until recently (December, 1972), export sales were
  elgible for export payments equal to the difference between U.S.  and
  world prices  for rice.  Since  December,  1972, world prices have risen
  above U.S.  prices (due to world supply shortages in general) and export
  payments have been discontinued until further notice.
                                 Ill-17

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                           m-1.   RICE MILLING  PROCESS,
                 APPROXIMATE PRODUCT  PROPORTIONS,  A^D  MAIN  USES
ROUGH RICE  100 IBS
 MILLING
   PLANTING SEED
                                           WHITE RICE^ 70 LBS
                    BROWN RICE  80 LBS
                     EXPORTED BULK
                     MILLING COMPLETED BY
                      IMPORTING COUNTRY
   HUMAN FOOD
   DOMESTIC
   EXPORT
   TERRITORIES
BYPRODUCTS   10 LBS
                                          DOMESTIC LIVESTOCK FEED
                                          EXPORT LIVESTOCK FEED
                                                                  HULLS
                                                                   LITTLE VALUE - MOSTLY BURNED


                                                                 • HEAD RICE
                                                                   DOMESTIC CONSUMER PACKAGED
                                                                   EXPORT CONSUMER PACKAGED
                                                                   EXPORT BAGGED
                                                                   CfcREAL PROCESSORS' BULK
                                                                   SOUP PROCESSORS
r LARGE
  SECOND HEAD
  & SCREENINGS
                                                                BROKEN  15 LBS
                                                                DOMESTIC PROCESSORS
                                                                EXPORT BLENDS
                                            BEER
                                            CEREAL
                                            EXPORTS
                                            BABY FOOD
                                            CANNED RICE
                                             PRODUCTS


                                        - BREWERS
                                            BEER
 • BRAN
   LIVESTOCK
   FEED
                                                                                   POLISH
                                                                                     LIVESTOCK
                                                                                     FEED
                                                                                     BABY FOOD
                                                       20 LBS
                                                       55 LBS
                                                                                                10 LBS
5 LBS


7 LBS


3 LBS
                                                                                        TOTAL   100 LBS
I/ WHITE RICE IS COMMONLY REFERRED TO AS TOTAL MILLED PRODUCT.

-------
A characteristic of the export demand for U.S.  rice is that it is an
elastic demand (-1.57), whereas,  in contrast, the domestic demand is
inelastic (-. 14 in 1970). .!/  Under these conditions it is generally de-
sirable for U.S. producers and millers to export any increases in supply.
Any increase in domestic supplies would result in lower returns to the
industry.


U.S. milled rice exports have been shipped to numerous countries
throughout the world.  Since 1970, major markets have included
South Vietnam, Korea, Indonesia,  EEC, and South Africa.  Most ex-
ported rice is either long grain or medium grain; and, further, almost
a third of the exports in recent years  was specialty rice,  i.e. ,  parboiled,
precooked, brown and flavored rice.

Rice distribution within the U.S. involves three broad use  categories:
(1) direct food use,  (2) processed food use, and (3) use by  brewers-
Rice millers  distribute the bulk of the  rice, but repackagers (17 in 1971)
and government agencies are also  involved in marketing and distribution
of rice for use by the civilian population within the United States.  A
summary of the amount distributed by use and distributor for  the  1969-70
marketing year (the most recent data  available) was  as follows (see
Table  III-8).

Most of the rice distributed to food processors was shipped directly
from mills and thus mills are  the dominant distributors of milled  rice
within the  U.S.

Within the processed food use  category, the types of main  products pro-
cessed are (1) cereal - 10.2%,  (2)  soup -  1.0%, (3) babyfood - 0.7%,
(4) package mixes - 1.4%,  and (5)  other - 1.2%.   (The  percentages apply
to the  1969-70 marketing yea r and  total to  14. 5% as indicated  above.)

Byproducts of the rice milling industry include rice bran,  rice polish..
and hulls.  They are most  often sold as rice millfeed which consists of
all byproducts from rice milling combined in the proportions produced..
normally 61% hulls, 35% bran, and 4% polish.  Rice  bran is also sold
separately for use as  a livestock feed ingredient,  as a  source of vitamins
by the pharmaceutical industry or as a source of extractible oil.  Rice
polish is used by the food industry  in preparation  of infant  foods and
special dietary foods.  Rice  hulls have few uses other than as a livestock
feed ingredient.  Nearly half of the hulls resulting from rice milling are
not used and represent a disposal problem for the industry.
 —  Grant, W. R. and D.,  So  Moore,  Alternative  Gove rnment Rice jPrograms,
    An Economic Evaluation, ERS, USDA, AER No.  187.  June'l970.
                                 Ill-19

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   T'ablt- 111-8. Distribution of rice within the U.S. by major use
                    and distributor,  1969-70
                                                           Amount
      Use and Distributor
1, 000 cwt
Percent
Di reel food
   Mills
   Repackagers
   Gove rnment
13,012.8
10,538.7
 1,643. 1
   831.0
   63. 1
   51. 1
    8.0
    4.0
Processed food
   Mills and  repackagers

Beer
   Mills
 2,994.9
 4,631.2
   14.5
   22.4
              Total
20,638.9
  100.0
Source:  Eiland, J.C.  and Theo. F. Moriak,  Distribution Patterns for
         U.S. Rice, 1969-70, USDA, ERS-484, May 1972.
                            111-20

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 The total demand (both domestic and export) for parboiled rice has
 been increasing in  recent years.  In 1971-72, about 73 percent of all
 parboiled rice was  exported.  This percentage is  greater than the per-
 cent of all  rice exported which reflects an increasing preference for
 parboiled rice in export markets.  A  summary of the relative importance
 of parboiled rice in both domestic  and export markets is shown in
 Table  III-9   .   These data represent shipments  of milled rice  from
 all southern states  in  1971-72.
Also shown in Table III-9 are  brown rice and regular milled rice
shipments.  The export demand for brown rice is also growing due to
the availability  of mills in the importing counties plus the general waiver
of import taxes  or levees on brown rice which favors final milling in the
importing country.

Supply

The supply  of rice produced in the U.S. is largely controlled via an
acreage allotment and price support rice program administered by the
USDA.  Under this program rice growers are limited to an annually
specified acreage which in aggregate effectively controls production.
In conjunction with the  allotments, prices are indirectly supported
through establishment of a Commodity  Credit Corporation  support
price and loan rate program.  Rice producers may place part or all
of their crop under loan with the subsequent option to either redeem the
loan (given  rice prices above the support level) or make actual deliveries
to CCC and receive the full  support price.

For the  1970-72 period,  total  acreage allotments in the U.S. were
about 1.8 million acres and  the  national average support price has
ranged from $4. 86 to $5. 27  per cwt.  Because of a growing world
shortage of rice,  the U.S. acreage allotment was increased in 1973
by  10 percent to about 2.0 million acres.  Also, the  1973  support price
(based on 65% of parity) is expected  to  average $5.63 per cwt.

Rice production in the United States  is  heavily concentrated in four
southern states  (Arkansas,  Louisiana,  Mississippi and  Texas) and
in California. Reported harvested acreage and production of rough
rice by major states is  shown for 1971  and  1972 in Table III-10
Also shown is the percentage of total production in each state.

The percentage  production of rice by class for the 1969-72 period has
averaged as follows:

            Class                        Percent of Production
          Long grain
          Medium grain
          Short grain
          Total U.S.
                              Ill-21

-------
 Table III-9. Percentage distribution of shipments of brown  rice,
               parboiled rice and regular milled  rice
                   from Southern States,  1971-72
Type
B rown Rice
Parboiled Rice
B rown
Regula r
Regular Milled Rice
Total -
Percent of
Total
Shipments
16.0
4.0
13.9
66. 1
100.0
Domestic
Domestic
0.7
1.3
27.4
44.6
33,4
-Export
Export
99.3
98.7
72.6
55.4
66.6
Percent
Total
100.0
100.0
100.0
100.0
100.0
-  Total volume shipped in 1971-72 was 52, 189,379 cwt.

Source:  Statistical Statement, Rice  Millers Association, July,  1972.
                                111-22

-------
     Table  III-10. Rough rice production and harvested acreages,  by States, 1971 and  1972

Harvested acreage
State
1971
1972 I/
--1,000 acres--
Southern States
Arkansas
Louisiana
Mississippi
Texas
Missouri
Total Southern
h- 1
^ California
u>
Total United States ?_7

441
522
51
468
5
1,487
331

1,818

441
522
51
468
5
1,487
331

1,818

197:
1, 000 cwt

22,
19,
2,
23,

68,
17,

85,

271
836
346
868
235
556
212

768
Production
!

% of total

25.
23.
2.
27.
.
79.
20.



9
1
7
8
3
8
1



197
1,000 cwt.

21,
19,
2,
22,

66,
18,

85,

939
967
325
122
218
571
583

154
2 I/

% of total

25.
23.
2.
25.
.
78.
21.



8
4
7
9
3
1
8


—  Preliminary
—'Total U. S=  acreage and production reported by SRS,  Exc hides acreage and production in minor
   Southern States.

Source: Rice  Situation.  ERS, USDA. March,  1973.

-------
There is considerable variation among states, however, in the percent
of each class  of rice produced.  The  1969-72 average percentages of
each class of  rice by state are as  shown in Table III-11  .  Texas  and
Arkansas produce the major portions of long grain rice; Louisiana and
California are the major producers of medium grain rice, and California
is almost solely  responsible for the production of short grain rice.

The supply and distribution of milled rice  in the  U.S. since 1965 is as
shown in Table 111-12 „   The main use of milled  rice is for exports,
ranging from  56. 5  to 61.4 percent of the total supply for the periods
shown.  Civilian consumption  is the next largest use-category •which
accounted  for 21.3 to 25.8 percent of the annual  supplies (civilian con-
sumption on a per capita basis was 7.0 pounds in 1971, but it has ranged
from  6.7 to 7.7 pounds  in recent years).  Other  distribution outlets for
milled rice on a percentage basis  are also shown.

Prices

Approximately 60 percent of the rice produced in the  United States
is exported.   The price of exported rice is therefore directly in-
fluenced by the world import demand for rice, which is elastic.   Until
December 21, 1972 the  world  price of rice was lower than the United
States domestic price; however, U.S. rice exporters were  compensated
(via an export payment) for the price differential.  For example,  in
1969  the U.S. export payment was $. 93 per cwt. for long grain rice.
In 1970 the payment was $1.21 per cwt and in 197 1,  $2.35 pe r cwt.
Late  in 1972 the world price of rice moved up sharply due to the normal
2. 5% annual growth in consumption, adverse weather in major rice
producing countries, and disruptions from military conflicts.  This
condition of tight supply is expected to continue into  1974, creating a
favorable  atmosphere for the  export sales of the increased 1973 milled
rice production. —'

The larger U.S. rice millers  often negotiate their own export sales
directly with  the importing nations.  The medium sized and small
rice millers  generally sell to established internal exporters, such as
Continental Grain Company or Connell Rice and  Sugar Company,  who
then perform the exporting functions.
- Rice Situation,  ERS, USDA,  March,  1973.
                               Ill-24

-------
Table III-11.Percent of rice production by class by state.
                  1969-72 averages
State
Arkansas
Louisiana
Mississippi
Texas
Minor States
California
Total
Source: Rice Situation,

Long grain
38.0
12.7
5.5
43.5
. 3
--
100.0
USDA, ERS, Ma
Percent by Class
Medium grain
16.7
43.6
0. i
8.7
.2
30.7
100.0
rch 1973
of Rice
Short grain
2.6
--
—
0. J
97. 3
100.0

                         m-25

-------
       Table  III-12. Supply and distribation of milled rice, United States,  average 1965-70,  1970 and 1971.
i
[NJ


Item
Beginning carryover
Mill production
Imports
Supply
Food
Shipments to territories
Used by military
Civilian consumption
Total food
Used by brewers
Exports
Total disappearance
Ending carryover
Year
Average
1965-70
2, 190
59,644
287
62, 121

2,867
159
14,917
17,943
4,246
37,616
59,805
2,316
beginning

1970
2,328
56,870
1,064
60,262

2,630
227
15,557
18,414
5,000
34,096
57,510
2,752
August

1971
2,752
64, 148
803
67,7-03

3,962
183
14,433
18,578
5,407
41,522
65,507
2,196
Percent
Average
1965-70
3.5
96.0
.5
100.0

4.6
.3
24.0
28.9
6.8
60.6
96.3
3.7
of total

1970
4.0
94.3
1.7
100.0

4.4
.4
25.8
30.6
8.3
56.5
95.4
4.6
supply

1971
4. 1
94.7
1.2
100.0

5.8
..3
21.3
27.4
8.0
61.4
96.8
3.2
    Source:  Rice Situation, ERS, USDA, March, 1973.

-------
The domestic demand for milled  rice is  inelastic but total demand is
also affected by the prices  of substitute foods such as potatoes,  dry
beans and peas, macaroni and other cereal products.  Although rice
is considered a staple food item in the United States,  it  is not a staple
in the same sense as in Asia or other countries around the world.
Per capita consumption of milled rice  in the United States declined
9 percent in 1972 to 7 pounds per person.  This still represents an
upward trend,  however,  from I960, 6.1 Ibs/person, and 1970, 6.7
Ibs/person.

The larger  rice mills generally have the necessary facilities to package
milled rice  in  consumer sized packages.  Most package their  own labeled
brands and distribute both regionally and throughout the United States.
The larger mills also package under various private labels for wholesale
and  retail sale.

The medium and small rice millers tend to export  most of their milled
rice production or  sell to repackagers to avoid the high  cost of packaging.

The rest of the products  of rice milling are treated virtually as byproducts.
Large  second heads and screenings are generally sold to food processors.
Brewers rice is a grade  of smaller broken  rice used in  making beer.
Bran, polish and hulls must compete as  a millfeed.  No attempt will be
made here to review price trends of all rice milling products  and by-
products.  However, estimated values for all products f.o.b.  mills,
as used for  the model plant are as shown in Table III-13.  These are
estimated 1968-72 averages. Also shown are the average percentage
yields of end products from rice milling (parboiled, which has a higher
head rice yield). As previously mentioned, brown rice  is also produced,
primarily for export.  However,  no allowance for this -was included
in the plant  analysis.

As a final overview summary of general conditions now  prevailing in the
U.S. rice industry, Figure III-2 is noted.   This  shows average rough
rice prices  received by farmers since 1965/66.  Since the fall of 1972
a dramatic change in prices occurred.  The reasons were explained
above. -Similar price changes have occurred from the farm to the con-
sumer level.
                               111-27

-------
          Table III-13. Rice Milling.  Gross margin on parboiled rice


                                                      Estimated values
                        Percent breakdown        Derived value   Per cwt
 Product	Initial   Intermediate Finals/   per poundJL/    Rough rice

Hulls                20           20       20      . 0036!/          . 07

Brown Rice          80

  White rice                      70

    Head                                  6o£/    . 1095           6. 57
    Broken
       Large second                         ?£'     .058              .41
        head and
        screenings

       Brewers         .                     s!/     . 047              . 14

  Byproducts                     10

    Bran                                   7       .019              -13
    Polish                                  3       . 0191/           -06
                    100          100      100

Total sales  (estimated value per cwt.  rough rice milled)
Cost of raw materials plus freight cost£/
Gross Margin


_' Values are estimated f. o.b.  mill averages for 1968-72
J*/ End products
3/ Estimated milling averages for parboiled rice.  Head rice percentage is
   higher than regular milled rice due to decreased breakage of the harder
   parboiled rice.  Normal rice milling  percentages are 55% head,  10%
   large second head and screenings, and 5% brewers.
_' Price of hulls imputed from price of rice millfeed.  Millfeed composition is
   61% hulls, 35% bran, and 4% polish.
— Polish price assumed equal to bran price
_' Based on 1968-72 average price of rough rice of $5.42 per cwt. plus $. 12
   cwt. freight cost for rough rice as estimated by Eiland, J.C. and T. F. Moriak,
   "Rice Milling Costs in the United States, 1971/72", ERS, USDA,  March, 1973.
                                111-28

-------
Figure III-2
$ PER
6.90
5.70
4.50
$ PER
6.90
5.70
4.50
4
cv
-
^M
c\
-
»*

ROUGH RICE PRICES RECEIVED BY FARMERS
VT.
19

* — -1
NT.
19

-/N~i
—4 — i— ,
?v ^G
T
65/66

•»•' -
71/7

^~*
.__f___j__j^

*^*-«
2

-
-
f-

-
*•* «-
* i
•ii
-
-
~i^
-
,
'


i.
19

— •*»•
/
/
66/(

—•— «.
•^•••H
197

b7

— •
2/72


LC
i i
AN RATE
— -t I i i
-
-
••_
~



,
-
-
"1
-i—

-

i !
\f~ ^ 's4' O \t- ^ e^
YEAR BEGINNING AUGUST
I
1967/68


19

i j

.'...T.,. ,., -, ...

^^^^
i — t — t- — '


	 1 	 1
i
73/74

j i

,
-
-
».
—
-
,
v?-1 ^

  III-2 9

-------

-------
               IV.  SIC 2046:  WET CORN MILLING
The corn wet milling industry is principally made up of firms engaged
in milling and refining corn (or milo) by the wet process.  This study
is limited to those firms.   Establishments which manufacture starch
from other  sources (wheat, potatoes, etc.) which are included in
SIC2046  have been excluded from this analysis.
                         Industry Segments

Currently there are seventeen plants operated by twelve companies
which comprise the corn wet milling industry.  There is a wide range
in the size of operations  among plants and a broad range of final products
produced.  However, all plants have wastewater emissions and none can
therefore be excluded from this study.

Types of Firms

A listing of the twelve companies or firms in the  corn wet milling  industry
is as shown in Table IV-1.  Three firms,  i. e. , CPC International, A. E.
Staley Manufacturing and Clinton Corn Processing (a Division  of Standard
Brands) are  dominant firms in the industry.  Other major producers are
American Maize -Products ,  Anheuser-Busch,  Hubinger, National Starch
and Chemical and Penick and Ford-   Most of the major firms have diversi-
fied  operations primarily involving other food and kindred products.

On an industry wide basis, the corn wet-millers produce over 500 end-
use products, ranging from corn starch to antibiotics made from steepwater
concentrate.  The  product mix is varied among companies dependent on
product finishing department configurations within each plant.
                                      IV-1

-------
   Table IV-1.  Listing of corn wet milling firms and plant locations,  1973
American Maize-Products Company
250 Park Avenue
New York, New York 10017
Plant:  Hammond, Indiana 46326

Anheuser-Busch,  Inc.
P.O. Box 1810 Bechtold Station
St.  Louis,  Missouri  63118
Plant:  Lafayette, Indiana 47902

Cargill,  Incorporated
Cargill Building
Minneapolis, Minnesota  55402
Plant:  Cedar Rapids, Iowa  52401
       Dayton, Ohio 45400
Clinton Corn Processing' Company
(A Division of Standard Brands Inc.)
Clinton,  Iowa  52732
               The Hubinger Company
               Keokuk, Iowa  52632
               Plant:  Keokuk, Iowa  52632

               National Starch and Chemical Corp.
               750 Third Avenue
               New York, New York 10017
               Plant:  Indianapolis, Indiana  46206

               Penick and Ford, Limited
               (A subsidiary of VWR United Corp  }
               Cedar Rapids, Iowa  52406
               Plant:  Cedar Rapids, Iowa   52406

               A.E. Staley  Manufacturing Compa-.
               Decatur, Illinois  62525
               Plants: Deratur, Illinois 62525
                       Mornsville, Penn.   19067
Corn Sweeteners, Inc.
P.O. Box 1445
Cedar Rapids, Iowa  52406
Plant: Cedar Rapids, Iowa
52404
CPC International Inc.
International Plaza
Englewood Cliffs, New Jersey 07632
Plants: Argo, Illinois 60501
        Pekin, Illinois  61555
        North Kansas City,  Missouri  64116
        Corpus Christi, Texas  78408
Grain Processing Corp.
Muscatine,  Iowa
Plant:  Muscatine, lo .va.

Dimmitt Corn Division
Amstar Corporation
Dimmitt, Texas  79027
Plant: Ditmmitt,  Texas
                                        79027
Source:  Corn Refiners Association
                                     IV-2

-------
The major products produced by the corn wet millers are categorized
a s foil o\v s:
                                          Corn Oil
                                             •  Expellfcr
                                             •  Extracted

                                          Corn gluten feed and meal
                                          Corn germ
                                          Cake meal
                                          Steepwater Concentrate
                                          V ita m i n s
                                          Antibiotics
                                          Chemical manufacture
Corn Starch
     Regular
   '  Modified
   •  Dextrin

Corn Syrup
   •  Regular
   •  Carbon treated
     Ion exchange treated

Corn Sugar
   -  Dextrose
   •  Sugar solids

Lactic acids
Enzymes
Alcohol
Distilled grains
Types of Plants

Also  shown in Table IV-1 are the seventeen plant locations of the twelve
corn  wet milling firms.  A summary of plant locations by state is as
follows:
         No. Plants
                                 State

                                 Iowa
                                 Indiana
                                 Illinois
                                 Missouri
                                 Texas
                                 Pennsylvania
                                 Ohio
As indicated, most corn wet mills are located in the midwest.  The sizes
of plants range from 15,000 to 115,000 bushels capacity'per day.  At this
time, most individual plant  capacities are not known.
                                     IV-3

-------
Nine of the operating mills were built in the early part of the century
and have an average age of more than 60 years.  One (1) mill was built
in the late 1940's,  one  in the early 1950's and six were built in the
1960's.  The older plants are the largest and they comprise over 77
percent of the total capacity in the industry.

The level of technology used within plants is rather constantly changing
as machinery and equipment is  replaced. New capital expenditures in
the industry were reported is $18. 1 million in 1958, $26. 1  million in
1963 and $40. 5 million in  1967.  In 1967, $30. 8 million of the total
capital  expenditures was for machinery and equipment,  and $9- 7 million
was for structures and additions to plants.  Hence,  substantial improve-
ments and modernization of plants is generally indicated.

Corn wet millers are not integrated backward to the farm level.  Grain
corn (No. 3 Grade  or better) is purchased competitively in commodity
markets by the millers.  In total,  corn wet millers purchase about 5%
of the U.S. corn crop each year for processing.  As such, corn prices
are determined principally by other factors, e.g. livestock feed demand
and corn  supply levels, rather than being materially affected by corn
wet milling demands.   In 1972, the corn wet millers processed a total
of about 250,000,000 bushels of corn.

Number of Plants and Employment by Segment
                                                                    j .
It is anticipated that differential economic impacts of water pollution
control might occur among various plants on the basis of size of operation.
For this reason, three size classes are tentatively proposed:

             Bushels Capacity/Day
             15,000 -  50,000
             51,000 -  80,000
             81,000 -  115,000

Depending upon the subsequent availability of sufficient data, analyses of
economic impacts  are  planned for each size class of plants.

Total employment  in the wet corn  milling industry (SIC2046) was estimated
as 14, 100 in 1967 and 13, 500 in 1970 by the Census of Manufactures.  A
further indication of employment by individual establishments is shown
in Table IV-2.   These  data are for 1967 and as  shown a total of 45 establish-  .
ments is  indicated- Industry sources indicate that the smaller establishments
                                      IV-4

-------
Table IV-Z.  Number of establishments by size.  SIC2046: Wet Corn Milling
Size Class by
Number of
Employees
1-4
5-9
10-19
20-49
50-99
100-249
250-499
500-999
1,000-2,499
2, 500 or more
Total
Industry
Number of
establishments
9
4
9
4
5
2
1
5
5
1
45
2046
Percent of
total
20. 0
8.9
20.0
8.9
11. 1
4. 5
2. 2
11. 1
11. 1
2. 2
100. 0
Source:  Bureau of the Census,  Census of Manufacturers,  1967,  U.S.
         Department of Commerce.
                                     IV-5

-------
shown are primarily wheat starch and potato starch operations which
are included in SIC2046.  Actual corn wet millers would typically have
more than fifty employees.

Selection of Segments to Total Industry

All corn wet  millers are proposed for inclusion in a representative
segment (small, medium or  large) of the industry.  It is believed that
no plant should be  excluded because of the absence of water pollution
problems.  That is, water pollution control is  a concern for all corn
wet milling operations.

It is noted again,  however, that a portion of SIC2046 is  excluded from
this initial study.   In particular, wheat  starch  and potato  starch  plants
are excluded because of their limited operations.   For example, it is
estimated that over 93 percent of the total U.S. production of starch
comes from  corn.   The  relatively small balance is produced by wheat
and potato starch operators.   Wheat  starch plants utilize  low grade
wheat  flour (clears) in their  plants to produce both starch and gluten.
Potato starch plants utilize low grade or cull potatoes and often these
plants only operate seasonally when cull potatoes are available.

Likely Impacted Segments

Each size class of the  corn wet milling  industry is expected to be
significantly impacted  due to increased  expenditures for water pollution
control.  While there may be economies of scale in treatment costs for
large mills it is noted  ;hat the largest corn wet mills are also the
oldest.  Both additional  land and building space are problems for these
plants.  Thus,  the largest mills may have offsetting  factors  whic h w ould
increase their per unit treatment costs.

Among the seventeen corn wet milling plants, twelve currently discharge
into municipal treatment works. The five remaining plants discharge
directly into surface water receptors.   The treatment strategy to be
developed may  differ substantially among plants with and without tie-in
to a municipal treatment system.
                                      IV-6

-------
                              Financial Profile
Financial data for the corn wet milling  (or, also, corn refining) industry
is essentially limited to selected company statistics  such as  reported in
Standard and Poor's  Industry Survey and Moody's Industrial Manual.
(See section "Ability to Finance New Investment" below for a summary
of key financial ratios for four main companies in corn wet milling,, )
Further,  corporate annual reports were screened with only partial suc-
cess in isolating corn refining division  statistics  of the corporations  in
the industry.  In general, corn refiners are conglomerate-type companies
such that reported data may not accurately reflect corn refining financial
data.   Except for one case,  no individual  plant financial data or studies
were  found.  In order to  complete the type of plant impact analyses planned
and relate the financial characteristics of the industry as fairly as possible
it was necessary to construct representative model plants.  Time was
available to complete only one  such model plant for this report.

Plants by Segment

Corn wet milling plants are complex and very capital intensive in structure.
These plants are effectively refineries. After corn  is milled to produce
basic starch,  then finishing or refining of starch is continued to produce
many possible products.   The most common products derived from starch
are corn syrup and corn  sugar (dextrose), plus, of course,  starch itself
(including modified starches  such as dextrin). However,  further  process-
ing of each of these products is completed in many plants.

Each plant in the industry is  considered unique beyond the starch  (or
starch slurry) production stage,  but all are believed to produce some
starch (including dextrin), corn syrup and corn sugar.  By-products  of
corn oil,  corn gluten feed and meal, and  steepwater concentrate  are  also
normally produced.  A 'basic' model plant to reflect these major  products
is proposed.  The  proportions  of each product are assumed to be  the same
as was reported for the industry as a whole by the Census of Manufacturers
in 1967 (the latest reported shipment data).

Attention was given to the synthesis  of  a "medium1 (60,000 bushels)
per day capacity) plant model.   This size of plant falls well within the
proposed size  categories  of the industry which have  been tentatively
defined as follows:

                   Bushels Capacity/Day          Class
                     15,000 -  50,000              Small
                     51,000 -  80,000              Medium
                     81, 000 -115,000              Large

                                     IV-7

-------
In subsequent study the 60,000 bu. per day plant was scaled up to
90,000 bu. per day to assess the impact of water pollution controls
on a large plant and scaled down to 30, 000 bu. per day to consider
the impact upon a small plant.  Only the 'medium' sized plant is
described in this section,  although comparative data for three plant
sizes are presented in Table IV-7 below.

Annual Profit Before  Taxes

Based on the selected financial data reported below, net profit as a per-
cent of sales ranged from 2. 7 to 4,9  in  1970 and from 1. 6 to 3. 8 in 1971
for four corn refiners.  These data are  probably indicative of corn  re-
fining profits even though the data are lor the companies' total operations.

According to the model  plant concept, procedures,  and operating assump-
tions implemented, the  estimated pre-tax income and selected rates of
return on investment are  as  reported in Table IV-3.  After-tax ROI is
estimated as 5. 1 percent  and after-tax earnings on sales is 3,. 7 percent.
The latter value is comparable to those  reported above for the four com-
panies in 1970 and 1971.

One qualification of the  model plant data is that costs and prices of products
were estimated  1967-1971 averages,. The main reason for this  is to
improve the chance of reflecting normal 'margins'  between prices paid
and prices  received for corn wet milling products.

Average fixed investment, on which the  rates of return were calcukited,
was derived by dividing replacement  costs by two (an estimate of average
fixed assets) plus total working capital (current assets)  less current
liabilities (based on grain milling industry averages).   The average fixed
or invested capital estimate  is intended to approximate invested  capital
in reported financial data.  After-tax income was based on a 48 percent
tax rate without either carry-forward or back tax provisions.

Annual Cashflow

Estimated annual cashflow (after-tax income plus depreciation) and the
ratio of cash flow to average fixed investment are as shown in Table IV-4
for the selected corn wet mill model plant.  Annual depreciation is
assumed to equal 5 percent on equipment and 4 percent on buildings,
Also,  equipment is estimated as equal to 75 percent of the total plant in-
vestment and buildings as equal to 25 percent of the total.  (Note the
capital intensive ratio. )
                                     IV-8

-------
Table IV-3.  Estimated pre-tax net income and rate of return on average
      invested capital and after tax return on sales for a medium
                      corn wet milling plant
Financial Measure                                 Value

Pre-tax net income ($000)                          3,615

Pre-tax ROI* (%)                                    9- 8

After-tax ROI* (%)                                   5. 1

After-tax return on sales (%)                         3.7
    Average  return on fixed investment calculated by financial statement
    method.
                                     IV-9

-------
  Table IV-4.  Estimated cash flow for a medium corn wet milling plant
Financial Measure                                Value

Annual cash flow ($000)                            4, 742

Cash flow on average fixed
   investment (%)                                   12. 9
                                     1V-10

-------
The annual cashflow of $4. 742 million is also 9. 3 percent of sales.
Unlike most other agricultural processing industries, the cashflow
percentage to sales is relatively high for the corn wet milling industry.

Market (Salvage) Value of .Assets

Fixed assets of a corn wet mill would have little  value to any producer
other than another corn wet miller.  However,  due to general growth
in demand for corn refining products,  one would expect that a well
located plant in generally good condition would have a significant salvage
value.

There is a recent known  case where a corn wet mill was closed and
subsequently sold to another corn  refining company (i. e. , Corn Sweetners,
Inc. bought the Union Starch Refining Company plant at Granite City
Illinois after it was closed.   Union Starch  was a subsidiary  of Miles
Laboratories, Inc.).  This plant was reported to  have been  operated for
about six  months but then reclosed.  Apparently old and worn equipment
resulted in inefficient operation of the plant.

Capital Structure  -  The average fixed  investment in a corn refinery was
estimated as $36.735 million for the medium sized model plant as des-
cribed, and  sales were estimated  as $50.949 million  per year.  This
yields an average sale:; of $1. 39 for each dollar of investment.  Compared
with other agricultural processing industries,  this level of sales to in-
vestment  is  low.  A major difference in corn refining is its high capital-
ization requirements.  Also, corn refining is a high value added process-
ing industry compared to most other agricultural processors.

The capital requirements estimated for the medium model plant are presented in
Table IV-5.  The  replacement value of $60. 25 million assumes a break-
down of 75 percent equipment and  25 percent for buildings and  site.
Total annual working capital is estimated as $11.016 million which is
equal to 25 percent  of total operating costs,  including raw material (corn)
costs.  Corn refiners maintain inventories of both raw materials and
finished goods as well as normal accounts receivables.

Cost Structure - Model plant data and budgets were prepared to estimate
the cost structure of representative  operations.

Fixed or plant related expenses were defined as those which do not direct-
ly vary as a function of throughput.  These expenses include:


                                    IV-11

-------
 Table IV-5.  Estimated replacement value and working capital requi re n
-------
          maintenance and supplies
          taxes and insurance
          plant and labor overhead
          sales,  general and administrative

Additionally cost estimates were made for depreciation and interest costs.
Variable or production related expenses were defined as those which will
generally vary proportionately with throughput--in other words, a fixed
amount per unit processed.  They include:

          raw materials
          power
        .  water
          process  supplies, chemicals, etc.
          operating labor
          plant supervision and fringe benefits

Fixed costs - Indirect operating costs, as shown in Table IV-6,  represent
7.4 percent of sales in the budgeted plant.  This is higher than the other
grain milling industries and is primarily due to the typically large selling
and related costs involved.  Sales offices and distribution centers are
common in the industry since many sales are to industrial outlets.

Deprei lation, at  50 6 percent of sales is relatively high compared with
other agricultural  processors.  The capital intensive nature of corn
refining is the principal c;»use.

Interest costs are  nominal at 0.8 percent of sales.

Variable costs -  Variable costs for the corn  wet milling industry are also
shown in Table IV-6 for two major components:  raw materials (corn),
and direct  operating costs.  Of special note is the relatively high direct
operating cost component representing 42. 1 percent of sales.  Also, the
raw materials costs (for corn) are relatively low as compared to other
agricultural processors,,  Both of these relative values reflect that corn
refining is indeed a high  value added industry.

In the event thai additional model plants can be constructed,  it will be
important how the  variable costs — which are  dominant, can be controlled.
Efficiency  criteria seem especially relevant.
                                    IV-13

-------
 Table IV-6.  Estimated costs for a medium corn wet milling plant
    Item                           $000                   Percent





Sales                             50,949                   100.0




Raw materials                     18,819                     36.9




Direct operating costs             21,458                     42. 1




Indirect operating costs             3,787                      7.4




Depreciation                       2,862                      5.6




Interest                              408                      0. 8




Total before-tax cost              47,334                     92-9
                                   IV-14

-------
Distribution of Model Plant Financial Data

The financial data base on which the model plant characteristics were
based were extremely limited for the corn wet milling industry. A
variety of engineering and financial guidelines were used to construct
the financial characteristics of  the model plant.  A summary of the
financial characteristics,  plus various additional values and assumptions
are presented in Table IV-7.   It is felt that the model reflects  the basic
conditions and characteristics of this industry.

Considerable reliance- was placed on common financial data sources as
stated previously for Imlgur and rice.  Also, particular use  was made of
the 1967 Census of  M.I nufactures volume and value of shipment  data to
estimate an average mix  of end products (and by-products) produced by
corn refiners.

Finally, a concern  ON  • ts over appropriate  commodity prices and product
values to use in subsequent analysis.  Current commodity prices are at all
time highs.  Corn re I. :ers will be dramatically affected and problems will
be faced in markets ul.ere substitutes for corn products exist,  e.g.  cane
and beet sugar  vs.  corn sweeteners.
                                  IV-15

-------
Table IV-7.   Summary of financial data  pertaining to the corn wet milling model plants
Values
Item Units
Utilization %
Annual throughput 1 , 000 bu.

Sales $1,000
Raw product costs "

Variable costs "

Fixed costs ''

Cash earnings "
Depreciation "
Interest "
Pre-tax income "
Net income "
After-tax cash flow "
Replacement costs "
Working capital "
Current liabilities "
Average fixed investment (A FI) "
Pre-tax income/AFI Ratio
Net iricome/AFI "
Cash flow/AFI "
Net income/sales "
Financial data for the 60,000 bu/day
M bu/day plants are subsequently used
i
o
30,000 bu./day 60

7,650

25,475
9,410

11,054

1,951

3,060
1,722
204
1, 134
590
2,312
36,250
5,604
2,242
21,487
. 053
. 027
. 108
. 025
,000 bu. /day

15,300

50,949
18,819

21,458

3,787

6,885
2,862
408
3,615
1,880
4,742
60,250
11,016
4,406
36,735
. 098
. 051
. 129
. 037
plant (medium) are presented in the
in the Impact Analysis


section below


90, 000 bu. /day

22,950

76,424
28,229

31,602

5, 577

11,016
3,860
611
6,545
3,403
7,263
81, 250
16,352
6,541
50,436
. 130
. 067
. 144
. 045
text. Data for the
.


Remarks
300 days x 60,000 bu x

85%
Bu. processed basis. Many
products .
$3. 33/bu. value, f. o. b.
$1. 23/bu. , f. o.b, mill
(19o8-71)
85% of operating costs,
c luding corn
15% of operating costs,
eluding corn

5% equipment; 4% bldg.





mill


ex -

ex-







75% equipment, 25% bldg.
25% operating cost
40% total working capita





30, 000 and VO , 000




1










-------
Ability to Finance New Investment

In the earlier section on bulgur,  general requirements for financing
new investment were  set forth, along with the  general conditions in
the milling industry.   Table II-8   presented selected financial data
for all grain milling firms.

It is extremely difficult to  segregate financial  data for wet corn milling
operations.  Standard and Poor's Industry Survey has a ten-year (1967-71)
series for a group of  corn  refiners, including  three companies which
operate a total of seven wet corn mills  (of a total of 17).  Although wet
corn milling does not constitute the entire operations  of these three
companies, their financial data provide useful insights into the industry.
A fourth company, Hubinger, which operates one plant has financial
data available for 1970 and 1971.

The three  companies from Standard and Poor's Industry Survey are
summarized in Table  IV-8 from 1962 through 1971; Hubinger Co, is
included as data are available.   CPC International experienced a steady
decline in net profit on sa les from  5. 9 pe rcent in 1963 to 3.6 percent in
1971; Staley had an  irregular pattern of profits on sales which peaked at
4.3 percent in 1966, fell to 2.3 percent in 1968, rose to 2.8 percent in
1969 and fell to 1.6 percent in 1971; American Maize  peaked in  1965 at
6. 7 percent and declined irregularly to  3. 3 percent in 1969 and to 3. 8
percent in 1971.  Hubinger experienced a general decline  from 6.3 percent
in 1964 to 2.2 percent in 1971.   Corn refiners  as a group  experienced a
general decline from 5.9 percent in 1962 to 3.3 percent in 1971.

These same companies have demonstrated quite different  performances
in profit as a percent  of net worth.  CPC has had a remarkably steady
return ranging from 16.4 percent in 1963 to 13.3 percent  in 1971; Staley
has fluctuated from 12. 1 percent in 1966 to 5.2 percent  in  1971; American
Maize has  bounced from  5.2 percent in  1967 to 12. 5 percent in  1968, with
a 1971 return of 11. 5  percent.  Hubinger earned 13. 0  pe rcent on net worth
in 1970 but dropped to 5. 5 pe rcent in 197 1.

At the same time, except for Hubinger,  the companies had a  fairly high
debt-equity ratio in 1971 -- CPC at 50 percent, Staley at 44 percent and
American Maize at 44 percent  Hubinger had only 10.6  percent.  This places
the three at the upper part  of the  range  for manufacturing companies and
considerably higher than the 36 percent average  of all firms in 1970.  When
combined with the earnings picture, the  debt ratio indicates that there may
be some serious limitations on the  ability of firms with  low earnings to
finance pollution abatement installations with borrowed funds.
                                    IV-17

-------
                                                                                              I/
                  Table IV-8. Selected financial data for four wet corn milling firms,  1962-1971 —'
1962
1963 1964
1965 1966
Net Profit as a
CPC International 5.8
A. E. Staley 2.7
American Maize-Prod. 4.4
Hubinger

CPC International 15,6
A. E. S taley 6. 4
Am. Maize-Prod. 7.0
Hubinger
<^
i
oo
CPC International
A. E. Staley
Am. Maize-Prod.
Hubinger
5.9 5.5
3.0 2.4
4.1 5.4
6.3
Net
16.4 15.4
7.0 6.9
6.7 9.1
--
5.6
3.8
6.7
5.8
5.6
4.3
5.6
5.2 .
Profit as a Percent
16.2
10.2
7,5
--
Current Ratio

__
--
__
— — _ _

--
--
--
_ _
16.3
12. 1
7.3
--
1967
1968 1969
1970
1971
Percent of Sales
4.7
2.5
2.8
3.4
of Net
13.8
7.3
5.2
--
(Current Assets to

--
--
--
— ~

--
--
--
—
4.7
2.3
4.6
4.7
4. 5
2.8
3.3
4.0
4.4
2.7
3.8
4.9
3.6
1.6
3.8
2.2
Worth (Estimated)
14.3
7.0
12.5
--
Current

--
--
--
- -
15.0
8.5
9. 1
--
Liabilities)

- -
--
--
- —
15. 1
8.3
10.6
13.0


1.8
1.9
4. 1
2.5
13.3
5.2
11.5
5.5


1.7
1.9
4.2
2.8
I/
—  Source: Standard and Poor's Industry Survey,  Nov. 23, 1972 and Moody's Industrial Manual,  1972.

-------
The short-term debt situation appears marginal.  Only brief data are
available,  but it indicates that the ratio of current assets to current
liabilities  for grain milling in general was 1.9 to 2.2 in  1971.  CPC had
a current ratio  1.7, Staley of 1.9,  American Maize of 4.2 and Hubinger
of 2.8.

The corn refiners have traditionally been subject to widely varying
earnings.  Profits are affected by corn production, corn costs and
the production and prices of related products. Margins may vary
from product to product and from year to year since the  refiner has
little control over the factors affecting his profit margins.  This makes
equity offerings less attractive than for industry in general.

As  evidence of this, corn refiners stock prices have declined by about
45 percent from 1964  to  1972 while Standard and Poor's 425 industrial
stock index rose approximately 60 percent.  The price earnings  ratio
for corn refiner stocks have also declined from a high-low range of
28-20 in 1962 to 17-12 in 1971.  These facts indicate that equity financing
has become less attractive for corn refiners.

On  balance, however, the. foregoing data indicate that the wet corn
milling group has adequate financial strength to finance pollution abate-
ment from both internal and external sources.  At the  same time, any
further  deterioration in  earnings  will diminish the industry's ability to
meet future obligations.  A fall in corn prices would help restore profit
margins and strengthen  the financial position of the group.
                                     IV-19

-------
                              Pricing

Prices in the corn wet milling industry involve a multitude of end products
and byproducts from corn refining.  The "basic" products of the industry
are said to be four in number:  (1) corn starch,  (2) dextrin (a "cooked"  or
"roasted" starch for industrial uses, especially in adhesives),  (3) corn
syrup and (4) corn sugar (dextrose). However,  many other products may
be produced  by further processing.  Also,  byproducts such as corn oil,
corn gluten feeds  and meal, steepwater concentrate and others  serve
additional markets.

Because so many  products are produced and different markets are involved,
pricing is a complex question.  In this  brief description only some of the
major  factors involved are described.

Price Determination

Demand

Products of the corn refining industry are  utilized in the home, by industry
for food  and  industrial purposes,  and in feeding livestock.  Uses  in the  home
include corn  syrup for table use,  corn  starch for  home cooking and laun-
dering, and corn oil for qooking.   Much greater volumes, however,  are
utilized by manufacturing plants of all kinds:  textile mills,  paper mills,
commercial  laundries, foundries, tobacco and cigarette plants,  rubber
factories, chemical and drug manufacturers,  feed mixers, soap makers
and many food processors -- such as bakers, confectioners, brewers,
soft-drink bottlers,  canners and frozen food packers.  These industries
use the refined corn products as raw material input for further processing.

Products for the home are packed in consumer-sized containers and. shipped
to wholesale  or retail outlets for  distribution.  Industrial  markets and
users generally require deliveries in commercial containers or in bulk lots.
For example, corn syrups are usually  shipped in  steel cans, drums, tank
trucks  of various  sizes, and in 8, 000 gallon or more railroad tank cars.
The dry  sweetners (dextrose and  corn syrup solids) are shipped mostly
in 100-pound multiwall paper bags.  Closed hopper cars are sometimes
used for bulk shipments of dextrose.
                               IV-20

-------
Corn starch is either packaged or shipped in bulk to major users,  such
as in the paper and textile industries.  Corn oil for home consumers and
small industrial users is packed in bottles,  cans and drums of various
sizes.  To large users, shipments are usually  made in tank trucks and
railroad tank cars.

Each of the end-products or byproducts of the corn refining industry
effectively enters different markets with varied demand conditions.
Many sales are  made via individual customer negotiation and  often in
advance  of production.  Refining operations  might  then be scheduled and
the product mix modified to meet  sales demands.  However, certain
end products  such  as  corn oil,  corn syrup and dextrose have established
wholesale markets (New York and Chicago) where bulk rate competitive
prices are determined-  Wholesale prices for corn gluten feed (Chicago
and Tri-cities) and corn gluten meal   (Tri-cities) are also regularly
reported.  Average vlaues  of other end products are not generally
reported for the  industry -- although value of shipment data by product
class is  included in periodic Census of Manufactures reports.

Despite the lack  of formal markets for ma ny corn  refining products,
the industry is considered to be very competitively structured-  Firms
compete with each  other for industrial and consumer sales. Also, some
of the main products (corn  syrup, dextrose and oil) compete with other
commodity  sources ot sweetners and food oils.   For example, corn
sweetners  compete with cane and beet sugar sources -which are dominant
in the sweetner  market-  Corn  oil competes  vwith various other grain and
vegetable oil  sources such as cottonseed,  palm, peanut, soybean and
safflower oils-

An overall summary of the level  of demand for  wet corn milling product s
(primary only) is indicated in quantity and value of shipment data reported
by the Census of Manufactures.  The most recent data available are for
1967 as shown in Table IV-9  -   The value of total  shipments for  1967
was $646. 6 million when 207 million bushels of corn were milled by the
wet process.  For  comparison,  about 250 million bushels of corn were
processed  in  1972 which is a 21 percent increase.   Value of shipments
have increased proportionately more which is indicative of a growing
demand for corn refining products.

As indicated above, refined corn products have a wide variety of both
food and non-food (industrial) uses-  About 60 percent of the primary
products are  said to go into food products, but the  proportions of each
into food/nonfood uses differs approximately as follows:
                               IV-21

-------
   Table IV-9-  Quantity and Value of Shipments by All Producers in SIC 2046:  Wet Corn Milling,
                                      1963 and 1967

Product

1963
Total shipments including
Quantity
1967
-- (million pounds) --
Wet corn milling products, total
Corn syrup, unmixed .
Low (28 to 37 D.E.)-
Regular (38-47 D.E.)
Intermediate (48-57 D.E.)
High (58-67 D.E.)
Extra High (68 and over D.E.)
Corn sugar
Corn syrup solids
Cornstarch, including milo
Dextrin
Corn Oil (crude and refined)
Wet Process corn byproducts
Steepwater concentrates (50%)
Corn gluten feed
Corn gluten meal
Other byproducts
__

89.4
1,200. 5
128.4
843.0

1,093.6
110.4
2,565. 1
118.9


42,7
1,316.8
1,078.2
N,A.
—

210. 5
1,423.0
175.0
871.4
60.6
1,227.9
127. 1
3, 119.0
168.7
--

78.0
2,365.9
875.2
341.4
inte rplant
1963
transfers
Value
1967
--(million dollars)--
547.2

4. 5
60. 1
6.4
42. 5

71. 5
8. 8
177.3
9.9
60.9

1.0
27.4
33.3
25.8
646.6

10. 5
66.6
8.3
43.2
2.8
81.6
10.4
199.5
16.0
76.4

1.5
55. 1
36.6
27. 1
— D. E. = dextrose equivqlent

Source: Bureau of the Census,  Census of Manufacturers, U.  S.  Department of Commerce,  1967.

-------
                                                           Percent into
         Product                Percent into Food          non-food uses

         Corn starch                  12%                      88%
         Corn syrup                   94%                       6%
         Corn sugar (Dextrose)        85%                      15%

Corn oil, a byproduct of the refining process, is also primarily used in
food products.

An effective measure of the relative demand for corn products used in
foods is  per capita consumption  over time as shown in Table IV-10.
Corn sweetners (corn syrup and dextrose) have grown in importance
in the caloric  sweetner market which is suggested by the increased
per capita data shown.  Corn starch for food purposes has remained
relatively constant on a per capita basis for the past twenty years although
total demand has increased with f-.he growth  in population.  Again,
corn starch in food uses is a relatively minor portion of the total
demand for starch, however.  Corn oil consumption has also remained
relatively constant on a per capita basis for many years.

Non-food uses account for an increasing percentage of the steadily
growing  total demand for corn starch.  Most of the starch used indus-
trially goes into the paper and textile industries.  Estimated average
annual use of corn starch by these industries and  in total for all indus-
tries is shown in Figure  IV-1 •   Of the total 2,470 million Ib. estimated
for 19S9, 1,600 million Ibs. (65%) was used for paper and paper products,
350 million Ib. (14%) was used in the textile industry, and 520 million
Ib.  (21%) was  used for a wide variety of other industrial purposes.  Other
industrial uses include applications in  adhesives,  building materials,
foundry binders, laundry starches, explosives,  oil-well muds and other
mining applications.  (Dextrin, a roasted starch,  is included with the
above.  It is used almost enitrely for industrial purposes, primarily in
the manufacture of adhesives. Dextrin is considered a basic product
of the industry along with regular starch, syrup and sugar.)

Non-food uses of corn syrup and corn sugar also include a wide  range
of industrial applications.  Examples of applications of each are as
follows:
                               IV-23

-------
Table IV-10.  Per capita consumption of selected corn milling
                      products,   "960-1971
Year
I960
1961
1962
1963
1964
1965
1966
1967
1968
1969
1970
1971
— Food use only.
Sources: National Food
Corn Corn Corn
Sugar Syrup Starch —
3. 7
3. 7
3.9
4.5
4,4
4.5
4.6
• 4.6
4. 7
4.9
4.9
5.2

Situation, ERS,
U. S. Fats and Oils Statistics
Statistical
Bulletin No. 489
10. 1
10.6
11.5
12.3
13.6
13.7
14.0
14. 1
14.8
15.4
16.0
16.2

USDA, Feb.,
1950-71, ERS
.
1.8
1.8
1.8
1.8
1.8
1.8
1.8
1.8
1.9
1.9
1.9
1.9

1973.
, USDA,

Senti, F. R. and W. C. Schaefer, "Corn--Its Importance
Feed, and
Corn
Oil
1.9
2. 0
2.0
2.0
2.3
2.4
2.2
2.2
2.2
2. 1
2.2
2. 1




in Food
Industrial Uses, " Cereal Science Today,
      17:352-356, November,  1972.
                          IV-24

-------
Millions Pounds 2 470
2.400
2,000

1.600

1200

800

400



3
Qothei Industnes
,_ imHPaPe' ini Papei'oard
I^Uilile 1
_
1
-
654
537

- 323 [JIT
fm •! |

rvj *•*•'
D054 X1!







*~*~

I
1 ''
V*1!

v!^







117

1

i
w


.vi





39
TTT

i
1]
|i|
\\f

Ll1^
'Jv








733

TTT
1
i

i

V \

''•>
^_Jii

















i







            193539 194044 194549  195054  195559 196064  196S
                           Penofls

Figure IV- 1  .  Estimated industrial use of corn starch in
                 the U.S., expressed as annual averages
                 for the periods shown.  (From Moore and
                 Dwoskin )
                           IV -25

-------
         Corn Syrup Applications          Corn Sugar Applications

         Adhesives                        Acid production
         Chemicals                        Adhesives
         Dygs and inks                    Organic chemicals
         Explosives                       Dyes
         Leather tanning                  Enzymes
         Metal plating                     Explosives
         Glassive and parchment paper     Fermentation products
         Shoe polish                       Leather tanning
         Textile finishing                  Textile dying and finishing
         Tobacco products

Corn oil also has some non-food uses such as in pharmaceuticals, in
leather dressings and as a carrier for insecticides.  Also, and most
importantly, crude corn oil {and its derivative, soap stock) is used
in soap making.

Other corn wet milling products and byproducts are produced and marketed.
Corn gluten feed and meal, and corn oil meal are  important byproducts
which are sold as livestock feeds primarily to the dairy, poultry and  hog
industries.   Steepwater concentrate is also utilized either in corn  gluten
feed or for use in the  pharmaceutical industry to produce antibiotics,
such as penicillin, and certain vitamins.  Other products  such as lactic
acids,  enzymes, alcohol and distilled grains are produced and marketed
by some firms in the industry.

Supply

Supply of corn wet milling and refining products for the  past twenty years
has steadily increased with high correlations  to growth in population,
GNP, and total food production.  Corn refining products have either
maintained or increased their  relative importance  in food and industrial
uses and the industry has grown in volume of  products supplied as a
consequence.

The supply of corn wet milling products is indirectly reflected given the
amount of grain corn milled by the wet milling industry.   The annual
volumes milled for 1968 to 1972 are shown in Table IV-11 .  In  1972
an estimated 250 million bushels was processed and this represented
about 4. 3 percent of the total corn utilized.
                                IV-26

-------
                                 Table IV- 11    U.S.  Corn Utilization,  1968-1972
1968
Use
Feed
Export
Wet Milling
Dry Milling
Alcohol
Breakfast Foods
Seed
Total Utilization
Mill. Bu.
3,580
520
221
114
33
22
12
4,502
Percent
79.5
11.6
4.9
2. 5
. 7
. 5
. 3
100. 0
Mill. Bu
3,795
598
226
116
31
22
13
4,801
1969
. Percent
79. o
12. 5
4. 1
2.4
. 6
. 5
. 3
100. 0
1970
Mill. Bu.
3,581
502
229
119
24
22
17
4,494
Percent
79- 7
11.2
5. 1
2. 6
. 5
. 5
. 4
100. 0
1971
Mill Bu.
3,978
786
242
115
25
22
15
5, 183
Percent
76. 8
15, 1
4. 7
2 2
, 5
, 4
. 3
100, 0
1972
MAI Bu
4, 365
984
250
116
26
23
16
5,780
Perc t-:v
75 5
17 1
4, 3
2 0
4
4
3
100 0
Source: Feed Situation,  ERS, USDA, 1968-1972.

-------
Since the corn wet milling industry utili/.es only a relatively small part
of the total corn  supply, the availability of grain corn is not regarded ;> s
a physically limiting factor of production.  Corn wet millers do,  how-
ever, purchase shelled corn competitively in a market  dominated by
livestock feed manufacturers; and, corn prices are effectively exogenously
determined as viewed by the torn wet millers. It is also noted that corn
wet millers typically do 71 ot maintain large storage reserves of grain.
They tend to buy currently,  although the commodity futures market is
often used to  hedge corn purchases, especially during periods of uncer-
tainty about the size of the upcoming corn crop.

Pric es

Prices for each of the numerous end products of  the corn refining industry
are effectively determined in separate and often unrelated markets.   Prices
are not reported for all products, so tracing market trends is difficult
without first-hand knowledge of industry  sales and pricing procedures.

As a brief overview of prices and price trends in  the corn wet milling
industry, selected data from Wholesale Prices and Price Indexes (published
monthly by Bureau of Labor Statistics, U.S.  Department of Labor) are
presented in Table IV-12.  First, it is noted that  all but corn syrup
and corn gluten feed were priced considerably higher in 1972 than in
1967 based on the  index values.  However, the gluten feed prices almost
doubled  between July,  1972 and February, 1973.  Corn syrup also began
to recover, and  other items, except crude corn oil were generally stable.

Several  factors are pertinent to the specific changes involved,  e.g.,  an
unprecedented "price war" for corn syrup began  in December,  1971 but
prices were  beginning to return to normal by  February 1973; and live-
stock feed demand increases plus unusual export demands for U.S. grain
commodities  has seriously disrupted  livestock feed markets.   However,
more generally, the price indexes shown illustrate the independence  of
various  markets for different end products of the  corn  wet  milling industry.

Corn wet millers often have little control over product prices in markets
where there are close substitutes.  As was mentioned  previously, corn
sweetners compete with sugar (cane and beet) and thus changes  in produc-
tion costs cannot necessarily be passed through to consumers.   This will
be true  rega-rding the effects of pollution control costs  (just as  current
increased corn costs will likely severely effect industry relative to current
market  prices).
                                    IV-28

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  Table IV-12.  Selected prices and price indexes for corn wet milling
                            industry end products.
Product

Corn syrup,
Unit

100 lb.
July,
Price
$ (
3.675
1972
Index
1967=100)
78.4
Februa
Price
$
4. 214
ry, 1973
Index
(1967 = 100)
89.9
confectioners
Crude corn oil
Refined corn oil
Corn gluten feed
Dextrin Canary Da
\Vhite
Source: Wholesale
lb.
lb.
Ton
rk!00 lb.
Prices and
. 150
.203
44. 00
11.080
10.820
Pri ce Indexes
120.8
127.9
91.0
127.5
126.8
, Bur.
. 173
. 198
80.000
11.080
10.820
138.7
125.3
165.5
127.5
126.8
Labor Statistics, USDL,
       for Feb. 1973, (April 1973), and for July,  1972, (November 1972).
                               IV-29

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Corn oil, gluten feed and meal,  and steepwater concentrates also are
sold in markets with relatively close substitutes even though the markets
are different.

Of the basic  products,  starch and dextrin are the least affected by substitute
products.  Corn starch comprises about 93% of the starch market and most
price increases could likely be passed through to consumers (mostly
industrial).  Dextrin is even  more unique and free from  major competition.

Despite the complexity in  arriving at "representative" prices for this
industry, price data is needed to assess the financial impacts of anticipated
water pollution control costs.  Because of peculiarities which may exist
from year-to-year, estimated average  1967-1971  prices (and imputed values)
were developed for the model plant analysis.

For reference, and as a guide to the product mix assumed, the estimated
values used in this study are as shown  in Table IV-13.   It is believed that
representative gross margin data is best reflected in the manner shown.
                               IV-30

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      Table IV-13. Corn wet milling, gross margin per bushel
                        of corn processed
Estimated Pounds I/ 1967-7 1 Ave. £/ Value Per
Final Products per Bu. Processed Price Per Pound Bu. Ground
Starch
Cornstarch
Dextrin
Sweeteners
Corn Syrup
Corn Syrup Solids
Corn Sugar
Oil
Byproducts
Corn Gluten Feed
Corn Gluten Meal
Steepwater
Other byproducts
Total Sales (estimated
Cost of Raw materials
Gross Margin

15. 1
.8

13.2
.6
5.9
1.9
11.4
4.2
.4
1.6
55. 1
value per
4/

.072
. 107

.067
.081
.090
.169
.024
.043
.020
.082
Total
Transportation Differential J./
bushel processed f. o.b. mill)


1.09
.09

.88
.05
.53
.32
.27
. 18
.01
. 13
3.55
-.22
3.33
1.23
2. 10
—' Estimates based on actual quantity of each end product produced in 1967
   compared to total bushels of corn ground by the wet milling industry in 1967.
_' Average prices are determined by multiplying the 1967 Census of Manufactures
   price by the 1967-71 average wholesale price index for each product or group
   of products.
—  Prices on corn sweeteners are quoted on New York basis.  Prices on corn
   gluten feed and meal are quoted on Chicago bases.  Transportation allowance
   reflects shipment from plant to market of these products to give FOB mill
   values.
4 /
—  1967-71 average price of corn per bushel, No. 3 yellow, Chicago.  Source:
   Statistical Bulletin No. 410,  ERS, USDA, July 1972.
                              IV-31

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             V.   ECONOMIC IMPACT METHODOLOGY
 The remaining portion of this grain milling industry study is devoted
 to analyzing the economic impact of pollution abatement requirements
 under the Federal Water Pollution Control Amendments of 1972.  The
 preceding findings, plus the addition of estimated pollution control
 requirements  and costs,  will serve as the basis  for the impact analysis.
                         Proposed Standards
 For the purposes of th : impact analysis,  three  levels of wastewater
 treatment will be cone dered for each applicable segment of the grain
 milling industry:

        Level I:     Be t practicable control technology currently
         (BPT)      av< Liable  - to be met by 1977.

        Level II:    Br t available technology economically achievable -
         (BAT)      to  e met by 1983.

        Level III:   N<  ' source performance standards - to be  applied to
        (NSPS)      all new facilities that discharge directly to  na\igable
                    wr, ers - to be met by approximately January 1,  1974.

 A fourth level - new s jurce  pretrea tment standards - which would be
 applied to all facilities that use municipal systems constructed after
 promulgation of the pi oposed guidelines is not considered further in
 this report.  No cost i ata are provided for these standards.  It is noted,
 however,  that grain n tiling wa stewate rs are generally considered com-
 patible for treatment ,n normal municipal treatment systems.

 It is further noted that the new source performance standards  (NSPS)
 above are taken as  equal  to the best available technology (BAT)
 standards.  The treatment  requirements and costs are also assumed
 to be equal for purposes of this analysis.


Specifications and costs of each treatment level as  described below
were  supplied by EPA.  These data  are comparable with  limited alter-
native sources of cost data, and thus no additional  cases  were examined.
However, to assess the sensitivity of impacts to the estimated  pollution
control costs,  a range of estimated  costs of plus or minus thirty percent
(+ 30%) were also analyzed.
                                V-l

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The specific impacts to be examined include:

        1.   Price effects
        2.   Financial effects
        3.   Production effects
        4.   Employment effects
        5.   Community effects
        6.   Other effects

The types of analysis  planned for each of these effects  is outlined
following a  brief summary of the  general methodology used.
                        General Methodology
The basic approach taken in the impact analysis is similar to the nor-
mally done for any feasibility capital budgeting study of new investments.
The problem is essentially one of deciding whether a commitment of
time and money to a project (in this case,  adding pollution control
facilities) is worthwhile in terms  of net benefits derived.  The problem
is complicated in that benefits accrue over time and generally simplifying
assumptions are required to project into the future.  Also, many unique
factors of individual operations within an industry cannot be explored.

The core analysis for this  study is based upon synthesizing physical and
financial characteristics of the various industry segments through model
or representative plants.  Incremental impacts of pollution control require-
ments are then assessed in terms  of the same  model plants. The estimated
cash flows for selected model plants  are  as summarized in Chapters II-IV.

The primary factors involved in assessing the financial and production
impacts of pollution  control are profitability changes, which are a function
of the cost of pollution control and the ability  of firms to pass along these
costs in higher prices.  Other factors, of course, influence production and
closure decisions -- such as personal values, ability to finance new in-
vestments,  relationship of the plant in the  total corporate structure, and
many others.

While these and other factors are relevant in  business  decisions, emphasis
is given herein to economic analysis  to provide insight into potential business
responses to new investment decisions as represented  by required  invest-
ment in pollution control facilities. Given expected pricing conditions, the
                                V-2

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impact on profitability (and possible plant closure) can be determined
by simply computing the ROI (or other profitability measures) under
conditions of the new price (if changed) and the incremental investment
in pollution control.  The main consequence of profit changes is the
probable  impact on the plant in terms of plant shutdown or making the
required  investment to meet pollution control requirements.

In the  most fundamental  case, a plant will be closed  when variable ex-
penses (Vc) are  greater  than revenues (R) since by closing the plant,
losses can be avoided.  However, in practice plants  continue to operate
where apparently Vc>R.  Reasons for this include:

            lack of cost accounting detail to determine when  Vc > R.

            opportunity cost of labor or some other resource is less
            than market  values.  This would be particularly  prevalent
            in proprietorships where the owner considers his labor as
            fixed.

            other personal and external financial factors.

            expectations  that revenues will shortly increase  to cover
            variable expenses.

A more probable situation is the  case where Vc< R but revenues are
less than  variable costs plus cash overhead expenses (TCc) which are
fixed in the  short run.  In this situation, a plant would likely continue
to operate as contributions are being made toward covering a portion of
these fixed cash overhead expenses.  The  firm cannot operate indefinitely
under this condition,  but the  length of this period is uncertain.  Basic to
this  strategy of continuing operations is the firm's expectation that re-
venues will increase to cover cash outlay.  Factors involved in closure
decisions  include:

            extent of capital resources.  If the owner has other business
            interests or debt sources that will supply capital input, the
            plant will continue.

            lack of cost accounting detail or procedures to  know that
            TCc,^ R,  particularly in multiplant or business situation.

            labor or other resources may be  considered fixed and the
            opportunity cost for these items is less than market value.
                                V-3

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 Identification of plants where TCc  R, but Vc   R leads to an estimate
 of plants that should be closed over some period of time if revenues do
 not increase.  However,  the timing of such closures is difficult to predict.

 The  next level of analysis, where TCc /  R, involves estimating the
 earnings before and after investment in pollution abatement.  So  long
 as TCc   R it seems  likely that investment in  pollution control will be
 made and plant operations continued so long as the capitalized value
 of earnings (CV), at the firms (industry) cost of capital, is greater
 than the  scrap or salvage value  (S) of the sunk plant investment.  If
 S  CV,  the firm could realize S in cash and reinvest and be financially
better off.  This presumes reinvesting at least at the firms (industry)
 cost of capital.

 Computation of CV involves discounting the future earnings flow  to
present worth through the  general discounting function:
                                  t
                      V     =     V       A  (l+i)-n
                                   i        n
                                 n=l

                      where

                      V     =    present value
                      An   =    a future value in n^*1 year
                      i     =    discount rate as  target ROI rate
                      n     =    number of conversion products,  i.e. ,
                                 1 yea r,  2 yea rs, etc.

It should be noted that a  more  common measure of  rate of return is
the book rate,  which mea sures the after-tax profits as a  ratio of  in-
vested capital, net •worth or sales.  These ratios  should not be
viewed as a different  estimate of profitability as opposed to DCF
measures (discounted cash flow) but rather an entirely different
profitability concept.   The reader is  cautioned not to directly compare
the DCF rates with book rates.  Although both measures will be reported
in the analyses,  the book rate  is  reported for informational purposes only.

The two primary types of DCF measures of profitability are used.  One
is  called the internal  rate  of return or yield and is  the computed discount
rate (yield) which produces a zero present value of the cash flow.   The
y.eld is the highest rate  of interest the investor could pay if all funds
                                V-4

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were borrowed and the loan was returned i rom cash proceeds of the
investment.  The  second DCF measure is ihe net ore-em value  concept.
Rather than solve for the yield,  a  discount rate ecu.-/alem to the :'ir:r.s
cost of capital  is used.  Independent investments with net present values
of above zero are accepted; those  below zero are rejected.   The concept
of comparing capitalized earnings  with the sunk investment value  is
a variation of the  net present value method.
The data input requirements for book and DCF measures are derived,
to a large extent, from the same basic information although the final
inputs are handled differently for each.

1.   Benefits
For purposes of this analysis,  benefits for the book analysis have been
called aftar-tax incoine and for the DCF analysis after-tax cash proceeds.
The computation of each is shown below:
       After tax income    =     (l-T)x(R-E-I-D)


       After tax cash proceeds   =   (1  - T)x(R - E - D)   + D

       where

               T   =    tax rate

               R   =    revenues

               E   =    expenses other than depreciation and interest

               I =  =    interest expense

               D   =    depreciation charges

Interest in the cash proceeds computation is omitted since it is reflected
in the discount rate, which is the after-tax cost of capital,  and will be
described below.  Depreciation is included in the DCF measure only in
terms of  its tax effect and is then added back so that a cash flow over
time is obtained.
                                V-5

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A tax rate of 48 percent was used throughout the analysis.  Accelerated
depreciation methods, investment  credits,  carry forward and carry back
provisions were  riot used  due to their complexity and  special limitations.
It is recognized that in some  instances the effective tax rate may je lower
in a single plant situation, but with the dominance  of multiplant firms, the
firm's tax rate will be close to the 48 percent  rate.

Revenue, expenses, interest  and depreciation  charges used were those
discussed in Chapters II-IV and Chapter VI tor pollution control facilities.
These items were assximed to constant over the period of analysis.

Z.   Investment
Investment is normally thought of as outlays for fixed assets and working
capital.  However,  in evaluating closure of an on-going plant where the
basic investment is sunk, the value of that investment must be made in
terms of its liquidation or salvage value,  that is, its  opportunity cost or
shadow price. _'  For purposes of this analysis, sunk investment was
taken as the sum of equipment salvage value plus land at current market
value plus the value of the net working capital (current assets less current
liabilities) tied up by the plant,  This same amount wa s taken as a nega-
tive investment in the terminal year.  Replacement inve stment for plant
maintenance was taken as equal to annual depreciation,  which corresponds to
operating policies of some managements and  serves as  a  good proxy for
replacement in an ongoing business.

Investment in pollution control facilities was  taken as the estimates
provided by EPA and shown in Chapter VI.  The cost  data provided
represent estimated total facilities  and operating costs  for water
pollution control, although at least some plants have partially com-
pleted construction of required facilities.  The average increments.1
costs requi reel may therefore be less than shown; however, the model
plant data  assumed no pollution control.  The overall affects of pollu-
tion control are  projected for the model plant cases.  To  reflect the
effect of in-place facilities ,  pollution control costs of -30% of the total
are also shown.   In this manner,  the impact of lower incremental
costs can be judged.

The above discussion refers primarily to the DCF analysis.   Investment
used  in estimating book rates was taken as invested capital - book value
of assets plus net working capital.  In the  case of new investment, its
book  rate was estimated as 50 percent of the  original value.
_' This  should not be confused with a simple  buy sell situation which
   merely involves a transfer of ownership from one firm to another.
   . n this instance, the opportunity cost (shadow price) of the invest-
   ment may take on a different \aluc.

                                 V-6

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3.   Cost of Capital  - After Tax

Return on invested capital is  a  fundamental notion in U.S. business.
It provides both a  measure of actual performance of a firm as well
expected performance.  In this latter case,  it is also called the  cost
of capital.  The cost of capital  is defined as the -vei'/nted avjracie of
the cost of each type of capital  employed by the firm,  in  general terms
equities and inte rest bearing  liabilities.  There is no methodolo 2v that
yields the precise  cost of  capital,  but it can be approximated within
reasonable bounds.

The cost of equities  was estimated by two methods  --  the dividend v.eld
method and the earnings stock price (E/P ratic'i  method.  Both are
simplifications of  the more complex DCF methodology.   The  dividend
method is:
                    k  =  -r  + g

        where
                    k =  cost of capital
                    D =  dividend yield
                    P =  stock price
                    g =  growth

        and the E/P method is simply

                    k  -  E/P
        where
                    E  =  earnings
                    P  =  stock price
and is a further simplication of the first.  The latter assumes future
earnings as a  level, perpetual stream.

  The above methods for  estimating the cost    equity capital were
  explored f&r this industry.

  The after tax cost of debt  capital was estimated by using estimated 7. 5
  percent cost of debt and multiplying by  . 52  -- assuming a 48 percent
  tax rate.  These values were weighted by the respective equity to total
  asset and total liabilities  _' to total asset ratios.
 _' It is recognized that liabilities contain non interest bearing liabilities,
    but its weight is believed to be an adequate proxy for the weight of debt

                                  V-7

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The average cost of capital for the grain milling industry was estimated
as follows:
       Weighted Average        _     (1-t) (B)  (A) + (1/PE) (100)
       Cost of Capital  (CC)                   (1 + A)
       where

                          Debt
           A
                         Equity

            B      =     Cost of debt (before tax)

            PE     =     Price/Earnings ratio

            t       =     Tax rate  (.48)
Based upon industry data that was available, the following ranges
and averages for the above components were:
       Item             Range                 Average

        A              .333 to 1.0               .667
        B               6% to 9%                7.5%
        P.E.           9.69 to 11. 16           10. 10

and,

       CC              6.8 to 8.Z               7.5%
In subsequent analyses,  the 7. 5% cost of capital estimate will be used
to estimate various financial effects in the grain milling industry.
                              V-8

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 4.   Construction of the Cash Flow

 A twenty-two period cash flow was used in this analysis and was  con-
 structed as follows:

         1.   Sunk investment (selvage market value of fixed assets plus
             net working capital) taken in year tQ.

         2.   After tax cash proceeds taken for years t} to t2Q.

         3.   Annual replacement investment, equal to annual current
             depreciation taken for years tj  to t£Q.

         4.   Terminal value equal to sunk investment taken in year t-,^

         5.   Incremental pollution control investment taken in year tQ
             for  1977 standards  and year t^ for 1983 standards.

         6.   Incremental pollution expenses  taken  for years tj to  t2Q
             for  1977 standards  and years tj to t2Q for  1983 standards,
             if additive to the  1977  standards.

         7.   No replacement investment taken on incremental pollution
             investment on assumption of a 20 year life as provided by EPA.

         8.   Terminal value of pollution facilities  are  assumed equal  to
             zero in year t-> i   No estimate of land values were given, but
             land is not believed a major factor in this  industry.
                         B.   Price Effects
At the outset, it must be recognized that price  effects and production
effects are intertwined with one effect having an impact upon the other.
In fact, the very basis of price analysis is  the premise that  prices and
supplies (production) are functionally related variables which are simul-
taneously resolved.

Solution of this  requires knowledge of demand growth, price elasticities,
supply elasticities,  the decree to which regional markets exist,  the degree
                               V-9

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of dominance experienced by large firms in the industry, market concen-
tration exhibited by both the industry's suppliers  of inputs and purchasers
of outputs,  organization and coordination within the industry, relation-
ship of domestic output with the world market, existence and nature of
complementary goods,  cyclical trends  in the industry,  current utilization
of capacity and,  exogenous influences upon price  determination (e. 'g. ,
governmental regulation).

In view of the complexity and diversity of factors involved in determin-
ation of the market price, a purely quantitative approach to  the problem
of price effects is  not feasible.  Hence, the simultaneous considerations
suggested above  will be made.   The judgment factor will be  heavily em-
ployed in  determining the  supply response to a price change  and altern-
ative price  changes to be employed.

Asa  guide to the analysis of price effects,  the estimated price  required
to leave the model plant segment as well off will be computed.  The  re-
quired price increase at the firm level will be evaluated in light of the
relationship of the model plant to the industry and the understanding of
the competitive position of the industry.  The required  price increase  can
be readily computed  using the DCF analysis described above, but dealing
only with  the incremental pollution investment and cash proceeds.

Application of the above DCF procedure to these costs will yield the present
value of pollution control costs (i.e. ,  investment plus operating cost less
tax savings).  If  this is  known, the price increase required to pay for
pollution  control can readily be  calculated by the  formula

                          _   JPVP) (100)
                      XX   —
                             (1-T) (PVR)

       whe re:

            X   -    required percentage increase in price

           PVP =    present value of pollution control costs

          PVR =    present value of gross revenue  starting in the year
                     pollution control is imposed

Note that this formula implies that incremental profits  resulting from
the price increase will be taxed at a rate of 48 percent.
                                 V-10

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                        C.  Financial Effects
In Chapters II-IV, the financial characteristics of model plants were pre-
sented.  These data will serve as the base point for the analysis  of financial
effects of pollution control.  The primary focus of analysis will be upon
profitability in the industry and the  ability of the firms to secure external
capital. Hence, it is obvious that this portion of the analysis cannot be
divorced from production effects since profit  levels and the ability to fi-
nance  pollution abatement facilities will have  a direct influence on supply
responses -- utilization of capacity and plant  closures.

The measures of profitability utilized will include after-tax book rate of
return on invested capital and cash  flow (after-tax profit plus deprec-
iation) will be measured. After-tax profit as  a percent of sales will
also be reported to assist in comparing financial data with standard
industrial measures.

In addition to these factors, two additional measures of economic profit-
ability will also be examined:  (1) capitalized  value of earnings and (2)
present values estimated by the procedures described.  Both of these
measures will be calculated on pre- and post-pollution control bases.

Given  these financial measurements, the ability of the industry to
finance the required pollution control expenditures will be reexamined
in light of the financial results and the information shown in Chapters
II-IV.   This ability will vary from one industry subsector to  another
due to differential financial structures,  profitability and abatement
requirements.
                      D.  Production Effects
Potential production effects include reductions of capacity utilization
rates, plant closures and stagnation of industry growth.  It is antici-
pated that reductions  in capacity utilization will be estimated via quali-
tative techniques given the analysts' knowledge of the industry.  The
same is  true for assessing the extent to which plant closures may be
offset by increases  in capacity utilization on the part of plants remaining
in operation.  Data  limitations and time constraints are expected to re-
quire that the impact  of pollution control standards upon future growth
of the industry also be estimated via qualitative methods.
                                 V-ll

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The  remaining effect, plant closures,  is very difficult to measure
realistically. As a starting point in the plant closure analysis, a
shutdown model will be employed to indicate which model plants  should
be closed,  the marginal operations and the  sound operations.   These
conclusions will be based upon the decision rule that a plant will be
closed when  the net present value of the cash flow is less than zero.

It is  recognized that the use of models to  represent an industry is
imperfect and that not all of the  relevant values  or factors can be
included in the models.  Other factors are considered as necessary
in the subsequent analysis.

The  above analysis will be  done  under a without pollution control con-
dition and a with pollution control condition.  The former will establish
a baseline against which after pollution control impacts will be assessed.
                     E.   Employment Effects
Given the production effects of estimated production curtailments, plant
closings and changes in industry growth, a major consideration arises
in the implications of these factors upon employment in the industry.
The employment effects stemming from each of these production impacts
will be  estimated.   To  the extent possible,  the major employee classifi-
cations involved will be examined as will the  potential for  re-employment.
                      F.   Community Effects
The direct impacts of job losses  upon a  community are immediately
apparent.  However, in many cases, plant closures and cutbacks have
a far greater impact than just the employment loss.  Multiplier effects
may result in even more unemployment.   Badly needed taxes for vital
community services  may dwindle.  Community pride  and spirit may be
dampened.  However, in some cases, the negative  community aspects
of production effects may be very short-term in nature with the total
impact barely visible from the viewpoint of the overall community. In
a few cases, the closure of a plant may  actually be viewed as a positive
net community effect (e. g. ,  a small plant with a high effluent load in  an
area with a labor shortage).

These impact factors will be qualitively analyzed as appropriate.
                                 V-12

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                          G.   Other Effects
Other impacts such as direct balance of payments effects will also be
included in the analysis.  This too will involve qualitative analyses.
                                   V-13

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    VI.  POLLUTION CONTROL REQUIREMENTS AND COSTS
The water pollution control standards,  technology and  costs used in this
analysis were provided by the Environmental Protection Agency. _'
Alternative standards were set for different segments  of the  grain milling
industry.  This information is summarized briefly below for reference.
Estimated pollution control costs are also summarized for selected model
plants in each segment of the industry.

Although cost data were not provided for alternative  plant sizes within
es.ch segment of the grain milling industry, it is believed that repre-
sentative plant data,  as provided, are adequate to project the overall
expected impacts.  The main reason for this judgment is that most grain
milling plants currently discharge into  municipal systems.  Consequently,
only limited numbers  of plants will be directly affected by the proposed
guidelines.  Those which are affected may be characterized by the  model
plant  data presented.  Also, in all segments studied, that portion of the
industry which discharges to municipal treatment systems will effectively
determine  levels of output and prices in the industry.
                  Pollution Control Requirements
 The Best Practicable Control Technology (BPT) and the Best Available
 Technology (BAT) tentative guidelines proposed for the corn wet milling,
 corn dry milling, parboiled rice milling and bulgur processing segments
 of the grain milling industry are as summarized in Tables VI-1 and VI-2,
 respectively.

 To achieve the BPT and BAT proposed guidelines, each segment of the
 grain milling industry would be required to apply suitable treatment
 practices.  In the information provided by EPA, specific possible water
 treatment practices were identified for each segment of the grain milling
 industry to achieve effluent reductions corresponding to both levels.  In
 all cases, the BAT proposed practices assumed compliance with the BPT
 practices followed by additional treatment to attain the  higher standards.
—  Based upon materials prepared for EPA in "Development Document
   for Effluent Limitations Guidelines and Standards of Performance,
   Grain Milling," by Sverdrup and Parcel and As sociates , Contract
   No.  68-01-1503, June,  1973.
                                VI-1

-------
Table  VI-1.   BPT  Pollution Control:  Effluent reduction attainable
         through the application of best practicable control
                   technology currently available
Industry Segment

Corn wet milling
Corn dry milling
Bulgur
Parboiled rice milling

BOD
(lbs/MSBu)L/
50.0
4.0
0.5
(Ibs/cwt)
0.014
BPT Proposed Standard
Suspended
solids
(Ibs/MSBu)
35.0
3.5
0. 5
(Ibs/cwt)
0.008

pH

6-9
6-9
6-9
6-9
Source:  EPA and Sverdrup & Parcel and Associates

—  MS Bu equals  thousand standard bushels.
                                VI-2

-------
    Table VI-2.  BAT  Pollution Control:  Effluent reduction attainable
         through the application of best available technology
                      economically achievable
BAT Proposed Standard
Industry Segment

Corn wet milling
Corn dry milling
Bulgur

Parboiled rice
BOD
(Ibs/MSBu) If
20.0
2.0
0.3
(Ibs/cwt)
0.007
Suspended
solids
(Ibs/MSBu)
10.0
1.0
0.2
(Ibs/cwt)
0.003
PH

6-9
6-9
6-9

6-9
Source:  EPA and Sverdrup & Parcel and Associates

—  MS Bu equals thousand standard bushels.
                               VI-3

-------
For each segment of the  grain milling industry, a brief summary of
indicated treatment practices proposed to meet the tentative guidelines
is presented below.  In general terms, application of the  "best practi-
cable control technology  currently available" (BPT) in the grain
milling industry results in a high level of waste treatment together with,
in some instances,  requisite iu-plant modifications.  Application of the
"best available  technology economically achievable" (BAT) generally
requires improved solids separation following activated sludge or com-
parable biological treatment.

The specific types  of treatment and  technological assumptions used to
achieve the proposed guidelines  are  briefly as follows for each segment
of the grain milling industry included in this study.

Corn Wet Milling

General Requirements

Plants in the corn wet milling industry discharging directly to surface
waters  must undertake major pollution abatement activities to meet
effluent limitations.  These activities  cpnsist of in-plant  modifications
and biological wastewater treatment.  Plants discharging to municipalities
will be  under increasing  pressure from the municipalities to make  in-
plant modifications  to reduce the waste levels 'of the if Waste -flaw's:'- 5ru-  '
plant modifications  include the following:

        (1)  Isolate and collect polluting wasteflows.
        (2)  Recirculate cooling waters by using cooling tower systems
            or surface  condensers to eliminate once-through barometric
            cooling waters.
        (3)  Isolate once-through non-contact cooling-waters for  direct
            discharge.
        (4)  Dike all process areas to  contain accidental spills.
        (5)  Install entrainment separators in steepwater  and  syrup
            evaporators.
        (6)  Monitor waste streams  to control heavy product losses.

Corn wet mills  discharging directly to surface  waters must provide exten-
sive waste treatment for process waste vaters, after careful  efforts to
keep wasteloads to a minimum,  in order to meet effluent limitations.
Treatment processes necessary to meet effluent limitation levels are
as follows:
                                VI-4

-------
       (I) BPT:  Equalization and Activated Sludge - The treatment
       process at this level  consists of grit removal,  ph adjustment,
       nutrient addition,  12  to 18 hours of aerated equalization,
       complete-mix a ctiva ted sludge processing, secondary sedi-
       mentation, and sludge dewatering.

       (II) BAT:  Equalization, Activated Sludge, and Deep Bed
       Filtration - Includes  the Level I treatment process plus deep
       bed filtration.

Industry Experience

The effluent  limitation levels can be met by applying current technology
since each of the  in-plant modifications  and treatment control processes
is currently  being used by one or more corn wet mills.  The practices
have been in effect in a number of mills for several  years  and reduce
waste loads by 25 to  50 percent in some plants.  The treatment of corn
wet milling wastes with activated sludge and other biological systems
is practiced  at seven mills.  One mill presently meets effluent limitations
by using an activated sludge  system followed by aerated lagoons.
                              VI-5

-------
Corn Dry Milling

General Requirements

The waste-waters of concern in the corn dry milling industry are gener-
ated by corn washing.  Little can be done to  reduce the wasteload with
in-plant controls as long as  corn washing is  practiced.  Treatment of
the entire waste  stream is necessary to meet the proposed effluent
guidelines and consists of the  following practices:

       (1)   Collect wastewaters including those from car washing.
       (2)   Primary solids separation by sedimentation.
       (3)   Biological treatment
       (4)   Final separation of solids by sedimentation.

The waste treatment practices proposed to meet the proposed guidelines
are as follows:

       (I) BPT:  Primary Sedimentation and  Activated Sludge -  Treatment
       consists of  primary sedimentation, nutrient addition, complete-
       mix activated sludge,  secondary sedimentation,  and sludge de -
       watering.

       (II) BAT:  Primary Sedimentation, Activated Sludge, and Deep
       Bed  Filtration - Includes BPT  treatment plus deep bed
       filtration.

Industry Experiences

Treatment of wastewater discharges is limited in the Corn Dry Milling
industry.  Most mills discharge to  municipal systems.  An unknown
number discharge  directly to  receiving waters.   The level of treatment
practiced by those  discharging directly to  receiving waters is also
unknown.  One plant is known to pretreat.  While the level of treatment provided
is not  consistent with the proposed  effluent guidelines, it does  show that waste-
flows from  corn  dry mills are amenable to conventional biological treatment.
The corn dry milling industry can reach the  BPT and BAT guidelines  by
transferring proposed treatments from other food processing industries.
                                 VI-6

-------
Bulgur Processing

General Requirements

The only wastewater of concern in the -wheat flour milling industry re-
sults from bulgur processing.  All of the mills producing bulgur at the
present time discharge directly to municipal systems.  For those plants
that would be  concerned with meeting new source performance  standards,
the treatment required includes:

        (1)  Primary solids separation
        (2)  Biological treatment
        (3)  Final separation  of solids by sedimentation

To meet the proposed effluent guidelines, the treatment practices pro-
posed are as follows:

        (I) BPT: Activated Sludge - This process includes an activated
        sludge system with nutrient addition and secondary sedimen-
        tation.  Primary sedimentation is not included because  of low
        flows.

        (II)  BAT: Activated Sludge and Deep Bed Filtration - Deep bed
        filtration system is added to the  BPT  activated sludge system

Industry Experience

None of the bulgur mills provides wastewater treatment at the present
time.   The  proposed treatment practices represent currently applied
technology in  related areas of food processing.  The solids separation
.and biological treatment processes in use should also be applicable to
the treatment of wastewater from bulgur processing.
                                 VI-7

-------
Parboiled Rice Milling

General Requirements

The milling of rice  involves no process water and no wastewater dis-
charge.   The exceptions  are those mills producing pa rboiled rice.  The
wastewater from parboiling rice  comes from the  steeping operation.
In-plant controls generally have no influence  on the quantity or quality
of wastewater.  None of the six mills parboiling rice are known to treat
their discharges which go to municipal systems.   For those plants
who cease to discharge to municipal systems or for  new sources, the
treatment required  to meet effluent standards includes:

        (1)  Biological treatment
        (2)  Final separation of solids by sedimentation.

The following treatment practices are proposed to meet  the effluent
limitation guidelines if required:

        (I) BPT: Activated Sludge - Treatment includes nutrient addition
       a  complete-mix activated  sludge process,  and secondary sedimen-
       tation.   The activated sludge wastes could possibly be  dewatered
       by a centrifuge and added  to the animal feed byproduct stream.

       (II) BAT: Activated Sludge and Deep Bed Filtration - This
       treatment includes the BPT  activated sludge  system followed
       by deep bed  filtration.

Industry Experience

None of the  six rice parboilers in the United States is known to be
treating discharges-at the present time.  The  general nature of the
wastewater  indicates it can be treated by biological processes similar
to those  used in other food processing industries.
                                  VI-8

-------
                          Pollution Control Costs
Both the BPT and BAT estimated costs for pollution control for each
applicable segment of the grain milling  industry are as summarized in
Table  VI-3.   The cost  data provided are for selected model plants within
each segment of the industry.  Cost data for alternative sized waste
treatment  operations were not provided; however, the model plants were
selected to represent the most representative impacted size category of
plants.

The plant sizes represented  in Table VI-3  correspond identically or close-
ly with the primary model plants of this study.  Thus,  the cost data can be
used directly for comparable plants.  However, in two segments,  DPRA
generated alternative sized plants for the impact analysis as summarized
below.  In the absence of scale factors for adjusting the waste treatment
costs, the following relative  estimates were used:
    Industry
Corn wet milling
Corn dry milling
Bulgur
Parboiled rice milling
EPA (S&P)
Plant Size
60, 000 bu/day
DPRA Plant
Sizes
60, 000 bu/day
30, 000 bu/day
90,000 bu/day
Cost
Factor
1.0
0. 75
1.5
30,000 bu/day


 8, 000 bu/day


 8, 000 cwt/day
30, 000 bu/day
15, 000 bu/day

 5, 000 cwt/day
(8, 350 bu/day)

 8, 000 cwt/day
   th r uput
(500 cwt/hr max)
1.0
0.75

1. 0
1.0
The scaled estimates were made to approximate costs of pollution control
in alternative sized plants based on economies-of-scale relationships
found in other industries.  In this way,  it is possible to provide at least
some insight into the  relative financial effects  of pollution control costs
among plants within a given segment of the grain milling industry.  The
assumed data are subject to verification,  however,  it is noted that a
procedure was adopted to v^ry the estimated pollution control costs by
f 30 percent for all cases studied.  This procedure  provides sensitivity
information which aids in the  impact assessment.
                                    VI-9

-------
Table   VI-3. Estimated "BPT" and "BAT"  wastewater effluent treatment costs for selected segments
                                   of the Grain Milling Industry
BPT
Industry Segment
Wet Corn
Dry Corn
Bulgur
Parboiled Rice
Type Plant
60,000 bu/day
(medium)
30,000 bu/day
(moderately
large)
8,000 bu/day
(medium)
8,000 cwt/day
(moderately
large)
— Appendix A supplement to source
Source: Sverdrup and Parcel and
Best Practicable Control Technology
Currently Available
Investment
$2,544,000
$ 291,000
$ 24,000
$ 313,000
O&M */
$230', 000
$ 52,800
$ 9,200
$ 57,300
BAT
Best Available
Economically
Investment
$2,832,000
$ 323,000
$ 93,000
$ 347,000
Technology
Achievable
O&M I/
$278,000
$ 62,200
$ 15,700
$ 66, 100
cited. Operating and maintenance annual costs including energy and power costs.
Associates, Development Document for Effluent Limitations Guidelines and
     Standards of Performance, Grain Milling, Draft report to EPA, June 1973.

-------
                  Status  of Wastewater Treatment
A major consideration in assessing the expected impacts of improved
pollution controls on a given industry is the current state-of-art of pollu-
tion control and the consequent incremental requirements to achieve  the
proposed new abatement guidelines.   In the case of grain milling,  and
especially for selected segments, it was found that most plants, if not
all  plants within a  segment, are presently discharging to municipal
treatment  systems so that individual plant treatment facilities will not
be  required.  Consequently, only limited numbers of plants are ex-
pected to be impacted by the proposed effluent limitation guidelines.

Four grain milling industry segments have been identified as having sig-
nificant volumes  of wastewater effluents irrespective  of their current
treatment  status:   Corn wet milling, corn  dry milling, bulgur processing,
and parboiled rice  milling.  Effluent limitation guidelines and proposed
treatment  strategies to meet the  guidelines have also  been established
(as  described above).  Next, a brief summary of the state-of-art of
pollution control in each of the four industry segments is presented.

Corn Wet Milling

There are  currently 17 plants in  this  segment of the grain milling in-
dustry.  Major sources of wasteflows in the corn wet  milling industry
are those from steepwater evaporation, modified starch production,
and syrup  refining.  The quantity and character of the wasteflows  can
vary  greatly,  depending upon the  type of cooling system and the products
being manufactured.   Total water use by plants in the corn wet milling
industry can vary from  1 mgel to  50 mgd depending upon the types  of
cooling  systems employed. —

In general, the wastewater discharges from the corn wet milling plants
can be classified as high in wasteloads. The  BOD varies from 255 to
4, 450 mg/1.  Suspended solid  levels vary from 81 to 2,458 mg/1.

Of the 17 plants in  the industry,  only five discharge directly into re-
ceiving  waters.   The other plants discharge into municipal systems.
Of the five, three process wastewater in their own treatment facilities.
One plant is constructing treatment facilities  at the present time and
the  last plant plans to discharge  into a municipal system now under
construction.
_L' The wide variance in water requirements is primarily due to differ-
   ences in types of cooling systems employed.  Those plants using a
   once through cooling water system will have a total water use substantially
   greater than plants using recirculating cooling water systems.

                               VI-11

-------
Corn Dry Milling

There were 124 corn dry mills in operation in  1971.  Many of these
mills are small and located in the Southeastern United States.  The
larger plants are located primarily in the Corn Belt states.   The major
source of wastewater from corn dry milling is  from corn washing, be-
fore milling.  Generally, small mills to not wash corn before milling
and large mills  do wash.  Since approximately 90 percent of the industry
production occurs in large mills, small dry corn mills can be eliminated
from consideration.

Wastewater discharges from  corn dry mills vary from 3.2 to 6 gal per
bu of corn processed or a total wastewater flow of up to  240,000 gpd.  The
waste waters are characterized by high BOD and suspended  solids con-
centrations.  BOD varies from 900  to 2,700 mg/1. Suspended solids
concentrations vary from  1,500 to 3, 500 mg/1.

Most corn dry mills generating wasteflows discharge into municipal
systems  but a complete  inventory of wasteflow disposal methods is not
available.

Bulgur Processing

Of the normal wheat flour milling operations, only those plants engaged
in bulgur production discharge significant amounts of wastewater. At
the  present time six plants in the United States are processing bulgur.
The major source of process wastewater is from the steaming and cooking
of bulgur.

The water requirements of bulgur plants are from 30,000 to  65,000 gpd
depending upon the daily capacity of bulgur production.  Of this total
water requirement,  about 10,000 to 30,000 gpd is discharged as waste-
water.  The wasteload of bulgur wastewater is moderately high.  BOD
varies from 238 to 521 mg/1.  Suspended solids levels vary  from 294 to
414 mg/1.

All six plants processing bulgur are reported to  be discharging into
municipal  systems.

Parboiled Rice Milling

Rice milling ordinarily involves no process waters and no wastewaters.
The exceptions are those plants producing  parboiled rice. Of the 42
rice mills in the United States, only six plants produce parboiled rice.
                                VI-12

-------
The major source of wastewater in the parboiling plants  is the steeping
and cooking process.   Water use varies from 17 to 25  gal/cwt of rough
rice processed.   Total waste wate r volume va ries from 70,000 to 200,000 gpd.

The waste loads  from  the parboiling of rice can be characterized as having
a high soluble  BOD content and a low suspended solids  level.  BOD levels
va ry from 1,280 to 1,305 mg/1.  Suspended solids va ry from  33 to 77 mg/L

All six rice mills that parboil  rice are reported to discharge  their waste
water  into municipal systems.
                                  VI-13

-------
                      VII.   IMPACT ANALYSIS
 The impacts of direct discharge effluent guidelines on the grain milling
 industry as described herein will not likely be  severe.   The main reason
 for this is that most grain milling plants currently discharge into munic-
 ipal treatment systems where adequate treatment can be performed.
 Grain milling wastewaters, which are  typically high in BOD and suspended
 solids concentrations, are generally well suited for biological treatment
 as performed by municipal works.

As indicated in the preceding chapter,  only limited numbers of corn
wet milling and corn dry milling plants  currently discharge directly
into  surface waters.  The proposed  "BPT" and "BAT" standards
will  therefore only apply to these subindustnes  of the grain milling
industry.   All bulgur and parboiled  rice mills discharge effluents  into
municipal  treatment systems and no BPT or BAT  standards are appli-
cable.  However, consideration is given to the  potential impact of new
source performance standards (NSPS) which would apply to any new
firms  entering these industries.

The  NSPS  standards are assumed equal to the BAT standards pro-
vided, and the  estimated costs for BAT are subsequently used for
assessing  the new source  potential impacts.  No new source pre-
treatment  standards were provided  for any subindustry and thus no
such impact analysis is included.

The  following discussion is presented on a subindustry basis:  corn wet
milling, corn dry milling, bulgur processing and parboiled rice milling.
For  each subindustry, the  impacts considered in the analysis include
the following:

            Price effects
            Financial  effects
            Production, effects
            Employment effects
            Community effects
            Other effects,  e.g.,  balance of payments.

Because of the limited applicability  of the proposed effluent limitation
guidelines, many of the above effects are expected to be minimal. The
greatest attention is therefore given to the  model plant financial analyses
and expected individual  plant effects.  In general,,  only individual plants
rather than the industry (or subindustry) as a whole will likely be adversely
impacted by the proposed  standards  and associated treatment requirements.

                                VII-1

-------
                         Corn Wet Milling
As an overview,  the following factors regarding the corn wet milling
industry are pertinent to this analysis:

            Only 5  of 17 existing plants  currently discharge  directly
            into surface waters.

            Three of the  5 plants have some biological treatment facil-
            ities in place; 1  is constructing a  treatment system; and 1
            will soon discharge into a municipal system under con-
            struction,

            A broad range of plant sizes, from about 24,000 to 120,000
            bushels per day  capacity, are involved.

            The 5 plants  represent  about 30 percent of the industry
            capacity.  (The 4 plants to continue direct  discharge
            represent about  23 percent  of the  total.)

            Treatment facilities for this industry are  quite costly, but
            all plants affected have taken positive steps toward meeting
            prospective effluent guidelines.

The  primary concern of this analysis is regarding the  5 (or soon only 4)
plants which directly discharge to surface  waters.  However, as a con-
sequence of the developments  indicated, the  BPT (1977) and BAT
(1983)  guidelines are not expected to  severely alter the structure of the
corn wet milling industry as a whole.  Much of the expected impact will
have occurred via treatment practices in place prior to the  enforcement
of the proposed effluent guidelines.  This does not reduce, however, the
treatment cost burden of the impacted plants  either individually or rela-
tive  to the remainder of the  industry.

Price effects.  Based upon individual model plant analysis,  it is esti-
mated that prices of corn wet milling products would have to increase
from about 1.2 to 1.9 percent in order  to cover the costs of pollution
control (as provided) -- assuming no prior treatment.  However, can
the few firms which must treat their  own wastes pass-through their
higher treatment costs relative to the remainder of the industry?
                                VII-2

-------
Because of the competitiveness of the corn wet milling industry, it is
not expected that the few impacted firms will be able to pass-through
their full additional costs for pollution control.  Perhaps  location or
product mix factors could influence  some prices, but on an industry-
wide basis price effects  should be well below the levels indicated.

For example, even if the plants affected  could pass through their costs,
the industry average prices would increase only from about . 3 to .5
percent.  Competitive factors should result in changes of less  than
these levels.

A  related factor is the possibility of generally higher municipal treat-
ment charges (coupled with pretreatment practices which may  be needed)
that would affect the  remainder of the industry.  In this case industry
prices would likely be affected and increased throughout the  industry.
However, this would not result directly from the guidelines of  this
study.

Financial effects.  The profitability of those plants required to add pollu-
tion control facilities  will be adversely affected.  As an indication of the
level of impact which is  expected (assuming no change in prices  received),
net profit as a percent of sales was  calculated for a series of model  plant
situations (Table VII-1).

Three different sizes  of  corn wet milling model plants , i.e., 30, 60 and
90 thousand bushels per  day capacity, were examined.  Both BPT and
BAT pollution control costs were imposed and  compared  with the base
case without pollution controls. Further, to assess the  sensitivity of the
impacts  relative to the pollution control costs  provided,  these  costs  were
arbitrarily varied by  + 30 percent.

As shown in Table  VII-1, only the 30, 000 bu/day plant is  subject to a
serious decline  in profitability.  Given the  "target" pollution control
costs _', the smallest plant showed a decline of . 8%  in net profit on
sales (from 2.5% to 1.7%).  The 60,000 and 90,000 bu/day plants showed
a decline of  .4%.   These effects were only marginally different with  the
+ 30 percent in estimated pollution control  costs.
—  Estimated pollution control costs were provided only for the 60, 000
   bu/day plant.  This data was scaled by DPRA for the 30,000 (.75 times
   the 60,000 bu/day plant costs) and the 90,000 (1.5 times the costs given)
   bu/day model plants.
                                VII-3

-------
Table VII-1.  Net profit as a percent of sales in the corn wet milling
            industry with and without pollution controls
              I/
                                            Level of Pollution Control
Size and Cost _'                  None            BPT              BAT

30,OOP bu/day
   Target cost plus  30%           --             1.6               1.5
   Target pollution cost -'        2.5             1.8               1.7
   Target cost less  30%           --             1.9               1.9

60,OOP bu/day
   Target cost plus  30%           --             3.2               3.2
   Target pollution cost          3.7             3.3               3.3
   Target cost less  30%           --             3.4               3.4
90,000 bu/day
Target cost plus 30%
Target pollution cost 4. 5
Target cost less 30%

4.0
4. 1
4.2

3.9
4.0
4. 1
_' No provision made for cost recovery by sale of recovered wastes.

—  Target pollution cost estimates are those estimated by EPA for the
   60, 000 bu/day plant. Other data estimated by DPRA.
                                VII-4

-------
Alsonoted is that while the profitability declined in all cases,  no model
plant was shown to become unprofitable. Although faced with declining
profitability,  it does not appear that plants would close solely as a re-
sult of pollution controls.

Further measures of the financial effects of the proposed pollution con-
trols on the corn wet milling industry are the  estimated model plant
financial ratios shown  in Table VII-2.  Both pre-tax and after-tax
Return on Investment (ROI)  ratios are shown for each model plant
situation previously described.  As  explained  in Chapter IV, the average
invested capital is estimated as equal to one-half of the replacement cost
(including pollution control costs if applicable) plus net working  capital.
For the  Level II target pollution control cost situation the after-tax ROI
drop from 2.7 to 1. 9% for the small model plant, from 5. 1 to  4. 4% for
the medium plant,  and from 6.7 to 5.8% for the large plant.  These data
reflect the negative impact on profitability,  but do not indicate that plant
closures are expected.

Another measure of the financial capacity of a plant is the Net Present
Value (NPV) of its future streams of costs and revenues.   By discounting
at the cost of capital rate,  then positive NPV's would indicate  the likeli-
hood of continued plant operation versus closure.  To complete this
analysis, the following assumptions were made:

        1.   The existing plants have sunk investments but they could
            be  disposed of today for a salvage  value and reinvested
            elsewhere  if the corn wet milling function were discon-
            tinued.  However, only  10 percent of the  estimated replace-
            ment cost is assumed recoverable for  this industry.  This
            relatively low value is estimated because corn wet mills
            are capital intensive and equipment would have  little salvage
            value in alternative uses outside the wet milling industry.

        2.   Revenues and expenses are assumed to remain  constant
            over time,  i.e. ,  20 years of operation.

        3.   The estimated cost of capital for the industry is 7. 5 percent.

The Net Present Values, calculated for the model  plants, both with
and without pollution  controls  -- and with a + 30 percent change  in the
target pollution control costs, are as shown in Table VII-3.  As  indicated,
all plant cases examined had positive NPV's which indicates that the plants
                                VII-5

-------
            Table VII-2.  Estimated pre-tax net income and rates of  return on average  invested capital
                        in the corn wet milling industry with and without pollution controls
I
0s-
Size and Level
of Pollution Control
Without Pollution Control
30,000
60,000
90,000
With BPT
30,000
60,000
90,000
With BAT
30,000
60,000
90,000
bu/day
bu/day
bu/day
Control
bu/day
bu/day
bu/day
Control
bu/day
bu/day
bu/day
Pre-tax income
T+30%




786
3, 151
5,849

738
3,063
5,717
rp I/
- ($000) -
1, 134
3,615
6,545

866
3,258
6,009

816
3, 191
5,908
T-30%





3
6


3
6




946
,365
, 170

911
,318
,099
Pre-tax ROI
T+30%


•

3.5
8.Z
11. 1

3.3
7.9
10.7
T
_ _ (o?,\ _
\ fa)
5.3
9.8
13.0

3.9
8.6
11.5

3.6
8.4
11.2
T-30%




4.3
8.9
11.9

4. 1
8.8
11.7
After -tax ROI
T+30%




1.8
4.3
5.7

1.7
4. 1
5.6
T
lot \
- - 1 73) -
2.7
5. 1
6.7

2.0
4.5
6.0

1.9
4.4
5.8
T-30%




2.2
4.7
6.2

2. 1
4.6
6. 1
    —  T = Target pollution cost as estimated by EPA for the 60, 000 bu/day plant.
       Other data estimated by DPRA.

-------
Table VII-3.  Net present values of corn wet milling model plant cash flows with and without pollution controls —
                                                 ($000)
                                                                                                           I/
Level of Pollution
Control and Cost
Without Pollution Control
With BPT Control
Target cost + 30%
Target pollution cost —
Target cost - 30%
With BAT Control
Target cost + 30%
Target pollution cost
Target cost - 30%

30,000 bu/day
($000)
6,334
3,277
3,983
4,688
2,978
3,753
4,527
Net Present Values of Cash Flows
60,000 bu/day
($000)
19,604
15,528
16,469
17,409
15,317
16,307
17,296
by Plant Size
90,000 bu/day
($000)
35,202
29,088
30,499
31,910
28,490
30,039
31,588
—  Assuming 20 year operating cash flow at 7. 5% cost of capital and a salvage value of 10% of original value
   of investment.
-I Target pollution cost as estimated by EPA for the 60, 000 bu/day plant.
   Other data estimated by DPRA.

-------
are not likely to shutdown.   The low salvage values utilized contributes
to the positive NPV's and contributes toward existing plants being locked-
in. the wet milling industry.

The fact that all existing mills which discharge into streams are  already
taking positive  steps to establish water treatment systems is  a direct
indication that no plants are likely to shutdown due  to pollution control
requirements per se.  The  financial characteristics displayed provide a
basic rationale for the behavior being observed in this industry.

Capital availability in the corn wet milling industry for pollution control,
is not regarded as a  major  limiting factor even though capital  require-  -
ments will be extensive.  Both internal and external sources of capital    '•'
are believed available.  The conglomerate type structure of many firms  ^
in the industry broadens the base on which to  generate internal capital.    .T
Also, the plants themselves generate sizeable after-tax cash  flows which
might be  retained.  Further, the industry as a •whole has developed a
generally stable growth pattern with favorable prospects for continued
growth  in demand.  These latter factors strengthen the ability of  firms
in the industry to acquire funds from external sources.

Production effects.  No curtailment  in production is projected for corn
\vet milling industry as a  whole, nor are any plant closings expected.
As indicated above, all plants involved  in direct discharges of waste-  - :
waters  have  already taken positive steps to treat their own wastes or
have them treated.  Current production levels are expected to be  main-
tained.
                                                                         '!
The most serious concern regarding production  involves the industry.
capacity for  growth.  Wastewater flows are substantial per 1000 bushels
processed,  and the  capacity for waste treatment (including wastef low's
into municipal systems) may be limiting in the future.  Effluent over-
loads and periodic spills have been a reoccurring problem in  the  corn,
wet milling industry based on experience to date.  Before  the industry,
can expand output significantly, improvements will need to be  made  in
controlling overloads and spills.

Another related concern in  the corn •wet milling  industry is the potential
for new plants in the industry and growth through time.  NSPS, new
source  treatment standards, inapplicable, would be a partial deterrent -
to entry.  However,  the  relative effect  of these standards  and  associated
costs should be comparable .to those shown above for the BAT cases.
In essence,  if a  new plant is sufficiently viable without pollution controls,
then the imposition of the estimated  pollution  control costs is not likely
to prohibit entry.  The incremental costs of pollution control  represent
less than 5 percent of the remainder of the capital investment required  in
corn wet milling.
                              VII-8

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Employment effects.  Because neither production cu vta ; Iments nor plant
closings are projected, then no associated employment losses are ex-
pected.  In the recent past, total employment in the  industry has trended
downward,  e. g. ,  14, 100 in 1967 and 13, 500 in  1970.   This has occurred
even though industry output has increased.  Newer plants and modernized
plants tend to be less labor and more  capital intensive.  These trends
may continue,  but such changes would not necessarily be  linked to pollu-
tion control changes.

Those plants which install treatment systems would  require some addi-
tional  labor for waste treatment control.   Hence,  the general effect
would  be to increase employment somewhat in the industry.

In contrast, the plants which must install  treatment  systems, without
apparent increases in prices to cover pollution control costs, will be
under  greater pressure to improve in-plant efficiency. The employment
consequences of such actions,  which would be induced by  the pollution
control may be a factor.

Community effects.  No significant community effects are projected
as a result of the  proposed pollution controls on the  corn  wet  milling
industry.   This follows  in that no plant closures nor  production cur-
tailments are expected in the industry.

Other  effects.    Corn wet milling products are numerous and many
different markets are involved. Competitive relationships could change
in some of these markets due to pollution  controls in general, e. g. ,
pollution control impacts on the beet and cane sugar  industries, with
relative advantages or disadvantages occurring to the corn wet milling
industry.   However, major disruptions originating from the corn wet
milling industry are not expected.

Some products are exported, but little change is expected in general.
Consequently,  no  major changes in balance of trade  relationships are
indicated.

Power and energy needs for pollution control are not estimated to be
excessive,  thus this requirement is  not expected  to be a major problem
area for the industry.
                                VII-9

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                         Corn Dry Milling
The  corn dry milling industry is distinctly different from the corn wet
milling industry in that milled products (corn grits, meal and flour)
rather than "refined" products  are the  primary end-use products.
Process wastewaters primarily involve water used for washing corn
prior to milling (plus limited rail car washing water which can be
eliminated using dry vacuum cleaning techniques).   The effluents of
this  industry are quite  amenable to biological waste treatment.

As background for assessing the expected economic impacts of water
pollution controls on this industry, the  following items are highlighted:

            Approximately 124 corn dry mills were  recently in operation.

            The larger mills, primarily located in the  Corn Belt States
            generally wash their corn prior to milling.

            The  smaller mills,  which grind whole corn and are concen-
            trated in the Southeastern United States, typically do not
            wash corn.

            Approximately 90 percent of the industry production is
            milled in the larger plants.

            Rather limited volumes  of wastewater are generated by
            plants and  consequently the estimated costs for waste
            treatment are not excessive relative to other milling
            investments and costs.

            Most (if not all) dry corn mills with process wastewaters
            are said to discharge into municipal treatment systems
            (a complete inventory is not available),  and thus the pro-
            posed guidelines will directly impact only a relatively
            small portion of the industry.

            No  known separate treatment  systems exist.

The  main concern of this impact analysis is directed toward a rela-
tively few of the larger corn dry milling operations which are believed
to discharge into surface waters. As is later shown,  the expected
impacts are not severe for the model plant cases  studied.  Thus, while
specific plants  that discharge directly  and their locations have not
                                 VII-10

-------
been pinpointed, such additional information is not expected to alter
the conclusions reached.

Price effects.   Based upon individual model plant  analysis for both a
medium plant (15,000 bu/day} and a moderately large plant (30,000 bu/day)
in the corn dry milling industry,  it is  estimated that prices of milled
products would have to increase from  about „ 6 to  1. 1% to recover  the
estimated  costs of pollution control.   The upper value was based on
the impact to the medium sized plant.

In that only relatively few firms are estimated to be impacted, it is
not likely that prices in the industry as a whole will be increased.
The impacted firms, operating in a  competitive industry, will not
be able to  pass-through the additional  costs for pollution control.

Financial effects.  The profitability of the plants impacted will be  lower
due to pollution control costs, but the  impact as indicated in terms of
net profit as a  percent of sales is not  substantial.  As  shown in Table
VII-4, the medium plant had  a decline of .4% in net profit on sales
(from  1.6  to 1.2%) at the target rate —' ,  and the larger plant had a
decline of  .3%  (from 2. 6-to 2.3%).

A further indication that  the impacts are not expected to be overly
severe is the stability of the  overall impacts within a _j- 30  percent
range in the  estimated pollution control  costs  (as are also  presented
in Table VII-4).  Both the BPT and BAT  cases were assessed
in relation to the base case without pollution controls.

It is noted that the 15,000 bu/day plant had a relatively low net profit
on sales value  in the base case, yet the  estimated  pollution control
costs did not result in an unprofitable  situation. Neither model plant
was shown to become unprofitable, and although faced with declining
profitability, it does not  appear that the types of plants which might
be impacted  would likely close solely as a. result of pollution control
impacts.

Additional financial measures of the corn dry milling model plants
both with and without pollution controls are presented in Table VII-5.
The measures  shown were developed as  shown for the  base case in
Chapter II.  For the BAT (1983) treatment cases,  the after-tax ROI
   Estimated pollution control costs were provided only for the 30,000
   bu/day model plant.  DPRA estimated that the 15,000 bu/day plant
   would  incur costs equal to  .75 times the costs given.

                               VII- 11

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Table VI1-4.  Net profit as a percent of sales in the corn dry milling
           industry with and without pollution controls


                                            Level of Pollution Control
Size and Cost _'                  None           BPT              BAT
15,000 bu/day
Target cost plus 30%
Target pollution cost .£' 1.6
Target cost less 30%
30,000 bu/day
Target cost plus 30%
Ta rget pollution cost 2.6
Target cost less 30%

1.2
1.3
1.4

2.3
2.4
2.4

1.0
1. 2
1.3

2.2
2.3
2.4
—  No provision made for cost recovery by sale of recovered wastes.

—  Target pollution costs, estimated by EPA for the 30, 000 bu/day plant.
   Other data estimated by DPRA.
                                 VII-12

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        Table VII-5.   Estimated pre-tax net income and rates of return on average invested capital
                   in the  corn dry milling industry with and without pollution controls
Size and Level
of Pollution Control
Without Pollution Control
15
30
With
15
30
With
15
30
,000
,000
BPT
,000
,000
BAT
,000
,000
bu/day
bu/day
Control
bu/day
bu/day
Control
bu/day
bu/day
Pre-tax net income
T+30% T y T-30%
( *ton n\
265
843
200 215 230
755 776 796
170 192 214
741 764 788
Pre-tax ROI After-tax
T+30% T

10.
17.
7.3 8.
14.6 15.
6.2 7.
14.3 14.
T-30% T+30%
\______ ____
j ----- -
3
0
0 8.7 3.8
2 15.7 7.6
1 8.0 3.2
9 15.5 7.4
T
- - t°i
\ 1
5.
8.
4.
7.
3.
7.

3
8
2
9
7
7
ROI
T-30%

4.5
8.2
4.2
8. 1
I/
-•  T - Target pollution cost as estimated by EPA for the  30, 000 bu/day plant.

   Other data estimated by DPRA.

-------
dropped from 5.3 to 3.7% for the 15, 000 bu/day mill, and from 8.8 to
7. 7% for the 30, 000 bu/day mill.  The smaller  plant is impacted more
severely, but again neither model plant situation would indicate that
plant closures are expected.

A final type of financial analysis completed is a "shutdown" analysis
based on calculation of a plant's Net Present Value  (NPV) of projected
costs and revenues.  With this  measure it is possible to  assess the
likelihood of continued plant operation versus closure. Under the
assumptions explained below, a positive NPV indicates that a plant
(given sunk investments) will probably continue to operate  rather than
shutdown.   The calculation of NPV is based upon the following assumptions
for the corn dry milling plants  studied:

       1.   Existing plants have sunk investments but presumably they
            could be scrapped or salvaged and the salvage value re-
            invested elsewhere  if the corn dry milling function were
            discontinued.  It is  estimated that the larger mill (30,000
            bu/day), which is comprised largely of  buildings and eleva-
            tors that could be used for other milling functions, would
            have a salvage value equal to 50 percent of the replacement
            cost.  However, the smaller mill (15,000 bu/day) is esti-
            mated to have only  a 30 percent  recovery value because the
            smaller facilities would  be less attractive for alternative
            uses.

       2.   Revenues  and expenses are assumed to  remain  constant
            over time, i.e.,  20 years of operation.

       3.   The estimated cost of capital,  used in calculating the NPV,
            for the industry is  7. 5 percent.

The Net Present Values for the model plants, both  with and without pollu-
tion controls  -- and with a +_ 30 percent change in the target pollution
control costs, are presented in Table VII-6.  In all the situations studied,
the NPV's were positive and significantly above zero. This indicates
that existing plants are not likely to shutdown due solely to the imposition
of pollution controls.

The estimated pollution control costs for the corn dry milling are sub-
stantial but not excessive. Consequently, capital availability for pollu-
tion control in the corn dry milling industry would not appear to be a
major problem.   The profitability of plant operations is  not expected to
be  severely impacted and external sources of capital should generally
remain available.

                                VII-14

-------
 Table VII-6.  Net present values of corn dry milling model plant cash
             flows with and without pollution controls _'
Level of Pollution
Control and Cost
                              Net Present Values of Cash Flows  by
                                            Plant Size
                               15,000 bu/day
30,000bu/day
Without Pollution Control
                                      ($000)
                                   993.7
                                                               ($000)
   2,825
With BPT Control
Target cost + 30%
Target pollution cost _'
Target cost - 30%
With BAT Control
Target cost + 30%
Target pollution cost
Target cost - 30%
416. 1
549.4
682.7
361.5
507.4
653.3
2,054
2,231.9
2,409.8
1,981.2
2, 175.9
2,370.6
 I/
2/
Assuming 20 year operating cash flow at 7. 5% cost of capital and a salvage
value of 50% of original value of investment for the larger mill and 30%
for the  smaller mill.

Target pollution cost as estimated by EPA for the 30, 000 bu/day plant.
Other data estimated by DPRA.
                              VII-15

-------
Production effects.  No curtailment in production is projected for the corn
dry milling as a whole due to pollution controls.  No plant closings are
expected.

Very few firms are potentially affected by the direct discharge effluent
limitation guidelines and these firms are not  expected to close.  Hov/ever,
even if a small number of plants were to close, there is excess capacity
for production in the industry.  Industry-wide production should  not be
curtailed regardless of the impact of the proposed direct discharge
guideline s.

The  volume of corn processed by the corn dry milling industry has remained
rather stable  since  196V.  ranging from only 114 to  119 million bushels per
year from  1967 through 1972.  These levels of production have been  milled
by a steadily declining number of plants, e.g. , 152 in 1965 and 124 in 1971.
In light of the rather static demand situation for corn dry milling products
and the general  excess milling capacity,  the "trends" of industry growth
should not  be  affected by the imposition  of the pollution controls  indicated
in this study.

The NSPS, new source performance  standards,  would have the same
relative effects on new plants as the  indicated BAT effects above.  As
Imc h,  the s e effects would present only a limited deterrent to entry.   The
pollution control investment costs  represent about  5 percent  of the original
investment costs.   This incremental investment requirement should not
prohibit entry if a  new plant is otherwise sufficiently viable.

Employment effects.  Employment losses are not expected because neither
production curtailment nor plant closings are projected  due to the pollution
controls involved.   Increased production costs resulting from pollution
controls, without expected price increases to offset these costs, may induce
other inplant  changes  to improve plant performance. Such changes cannot
be predicted, however, an offsetting factor would be the need for additional
labor for operating the treatment system.  On balance,  no change in  employ-
ment is  projected.

Community effects-  With no plant  closures or production curtailments
expected in the corn dry milling industry, then no significant community
effects are projected.

Other effects. No balance of trade or other detrimental direct effects are
forseen  as a result of the imposition of the proposed effluent limitation
guidelines on the corn dry milling industry.  The direct effects of the pollution
controls should not result in major disruptions in markets  served by this
industry.

 Power and energy needs are estimated to increase only by a small incre-
 ment relative to existing requirements.  Therefore, no problems due to
 excessive increases in the  demand for power and energy are expected.
                                 VII-16

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                        Bulgur Processing


The bulgur industry has a variety of characteristics which, in summary,
preclude its having detrimental economic impacts from the pollution
controls proposed in this study.  In brief, key characteristics of the
bulgur industry affecting this analysis are as follows:

          Only  6 plants currently commercially produce bulgur in the
          U.S.  Total production is  relatively minor in comparison with
          other milling industries.

          Only  small volumes  of wastewater are generated and this flow
          contains moderate wasteloads.

          All   existing plants  are reported to discharge into municipal
          systems for  treatment. No independent treatment  systems
          exist and none are expected to be  required.

          The proposed treatment practices, if required,  are relatively
          inexpensive to construct and operate.

In effect, the  proposed BPT and BAT standards will not apply to
any existing plants in the bulgur industry. Consequently, there is no
expected economic impact from the direct discharge pollution control
guidelines in this industry.

In terms of the  various effects to be evaluated it is concluded:

              Type of Effect            Expected Impact

              Prices                    No change
              Financial                 Controls not applicable
              Production                No change
              Employment              No change
              Community                None
              Other                     None

The proposed NSPS standards  (new source treatment)  could,  however,
provide a deterrent to entry into the bulgur industry.  As a basis  for
judging the potential impact of the NSPS standards,  it  is possible to
utilize the model plant  data  generated for bulgur industry.
                                   VII-17

-------
Assuming that the NSPS impacts would equal the BAT impacts as
previously defined,  then it is convenient to repeat the type of model
plant analysis  shown above where  the  BAT and NSPS effects are con-
sidered equal.  Only one model plant -- a medium sized, 5,000 cwt/day
plant, is evaluated as representative of the industry.

In terms of price effects , it was estimated that prices would have to
increase only by about . 5% to cover the estimated BAT  pollution
control costs.   Hence the proposed treatment  requirements would not
seriously affect plant operations.

The level of profitability would also be affected only slightly as shown in
Table VII-7, where net profit on sales declined from  1. 7 to  1. 5% at the
target pollution control cost level.  Change in control costs  of +30 percent
resulted in less than . 1% additional change in  net profit  on sales.  This
rather tight pattern indicates rather modest impacts within the  range
of costs considered.  If a new plant were considered viable prior to
pollution controls, then the proposed  control costs would not likely be
a deterrent to entry.

Some additional financial measures are indicated in Table VII-8 for the
medium sized bulgur plant.   In this case, for  example,  the estimated
after-tax ROI is estimated to decline from 7. 0 to 6. 0% at the target
rate.  A . 3% additional change is  indicated for either a t 30 change
in estimated pollution control costs.   Again, these data  suggest that
pollution control cost impacts on the bulgur industry are not severe.

The Net Present Value calculations for the shutdown analysis are not
strictly applicable for a  new source situation.  However, these calcula-
tions were made as if an existing  plant were required to treat its wastes.
Relatively large positive NPV's were obtained at a cost  of capital discount
rate of 7. 5%.  This is a  further indication that the proposed controls
should not cause economic dislocations in the  bulgur industry.

In summary, the proposed pollution control costs are not a  serious
deterrent to potential new source  bulgur  processors.  Also, even if
existing plants were required to provide  their own treatment systems,
the estimated  impacts would be nominal.
                                 VII-18

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Table VII-7. Met profit as a percent of sales in the bulgur processing
           industry with and without pollution
Size and Cost
              I/
 Level of Pollution Control
                    NSPS LI
                                           None
Medium Bulgur Plant
   Target  cost plus
   Target  pollution cost±.'
   Target  cost less 30 To
1. 7
1.4
1. 5
1. 5
I/
—  No provision made for cost recovery by sale of recovered wastes.

_' Target pollution cost as estimated by EPA.

3_/ The    NSPS  (New Source) pollution control requirements are assumed
   equal to the   BAT   (1983) requirements as provided.
                                   VII-19

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           Table VII-8.  Estimated pre-tax net income and rates of return on average invested capital

                     in the bulgur processing industry with and without pollution controls
Size and Level
of Pollution Control

Without Pollution Control
Medium bulgur plant
With NSPS Control -^
Medium bulgur plant
Pre-tax net income
T+30% T -' T-30%
_ _ . _ f
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                        Parboiled Rice Milling
Parboiled rice milling is also a rather small segment of the overall
grain milling industry; but it is an economically important industry
and a concern exists regarding the potential  impacts of water  pollution
controls.  However, as indicated briefly below, some key factors
regarding the industry indicate that the proposed direct  discharge
pollution controls will not directly affect this industry:

         • Only  6 of 42 rice mills in the U.S. currently produce
           parboiled rice.

         ' Moderate wasteflows are generated and they are amenable to
           biological treatment.

         • All existing parboiled rice mills discharge wastes into
           municipal treatment systems ( regular mills have no process
           wa stewater s).

         • No independent waste treatment systems are expected to be
           required in the industry.

Because of waste discharges into municipal systems, the parboiled rice
mills will not be affected by the proposed BPT and BAT  standards of
this  study.  Consequently) there is no expected economic impact from the
direct discharge pollution control guidelines  on this industry.

Regarding each of the various effects for which an impact assessment is
desired, the following brief conclusions are  made:

                 Type of Effect           Expected Impact

                 Prices                   No effect
                 Financial                Controls not applicable
                 Production              No change
                 Employment             No change
                 Community              No effect
                 Other                    None

A  related concern,  however, is the potential impact  of the proposed
NSPS standards  (new  source treatment) which could affect the  entry  of
new  firms into the parboiled rice  milling industry.   By utilizing the
model plant data generated for this study, the potential impact of the
NSPS standards  can be judged.

                                 VII-21

-------
In this case it is assumed that the NSPS guidelines and control costs
are equal to the BAT data provided.  Further,  the  impacts are ex-
pected to be equal for purposes of this  analysis and the type of model
plant analysis used above is  repeated to assess the NSPS impacts.  A
moderately large (8,000 rwt/day) mill  is evaluated as a prepresen-
tative mill in the  industry.

It is estimated that the model plant would  require a price  increase of
about .8% on its final products if it were to fully recover the estimated
NSPS costs of pollution control.  Since existing plants would not have
comparable incremental costs, it-is  not expected that a new plant could
pass-through such costs.  Thus, the profitability of a new source1 plant
would be reduced relatively.

As shown in Table VII-9, net profits  as a percent of sales would be re-
duced by about . 2%,  or a decline from  1. 6  to 1. 38% as shown for tre
model plant.  A new plant may have different financial characteristics
than estimated herein, however, the  relative impacts should be comparable
to that shown. The net profit on sales  ratio did not change substantially within
a + 30 percent variance  in the estimated pollution control cost target.  This
reaffirms that the effects on profitability would be approximately as shown
within a  reasonable range of the target costs used.

Additional financial measures, as shown in Table VII-10,  are further
indication of the generally limited impact of estimated pollution control
costs on the profitability of the model plant.  The after-tax  ROI as reported
is shown to decrease from 11. 7 to 10. 7% for the  target level case, or b /
1. 0%. This general level of impact would  probably not deter a new plant
from entry into the industry if it were  otherwise  economically  viable.

The above data suggest that  an existing mill, if it had to provide  waste-
water treatment, would  probably do  so.  Although not strictly applicable
for the new source NSPS case, it is also noted that the Net Present
Values for  existing plants as calculated for the shutdown analysis (dis-
cussed above) were  positive and relatively large for  this industry. This
further  supports  the belief that the proposed controls should not  cause
serious  economic dislocations in the parboiled rice milling industry.

In conclusion, the proposed pollution control costs are not believed to
be a  major deterrent to  potential new source parboiled rice milling
operations.   Further,  in the event that an  existing plant were required
to provide its own treatment system, the estimated impacts would be
marginal.  Based on a representative  model plant case,  existing plants
would not be  expected to close given the target pollution control costs.
                               VII-22

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 Table VII-9.  Net profit as a percent of sales  in the parboiled nee
               milling industry with and without pollution controls
                                            Level of Pollution Control
 Size and Cost—                          None                   NSPS —
Moderately Large Parboiled
	Rice Plant	

   Target  cost plus 30%                                         1.25

   Target  pollution cost—                  1.6                   1.38

   Target  cost less 30%                                         1.42

J7
   No provision made for cost recovery by sale of recovered wastes.

—  The    NSPS  (New Source) pollution control requirements are assumed
   equal to the  BAT   (1983) requirements as provided.

—  Target  pollution cost as estimated by EPA.
                                VII-23

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        Table  VII- 10.  Estimated pre-tax net income and rates of return on average invested capital
                     in the parboiled rice milling industry with and without pollution controls
Size and Level
of Pollution Control
Pre-tax net income
                                                                   Pre-tax ROI
                                                          After-tax ROI
                               T+30%
               T-30%
T+30%     T     T-30%     T+30%   T
                                                                                                               T-30%
Without Pollution Control
   Moderately large parboiled
          rice plant

With NSPS Control —'
   Moderately large parboiled
          rice plant
                                             ($000)-
                                404
                                          463
379      354
8. 4
                                     11.6
                                      9. 1    9.
                                                                                                   11.7
                            10.2    10.7     10.9
Target pollution cost as estimated by EPA.
_ '

—  The    NSPS  (New Source) pollution control requirements are assumed equal to the BAT (1983)  requirements
   as provided.

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                 VIII.   LIMTi;, OF THE ANALYSIS
The foregoing impact analysis was  based upon data and information
from  industry sources, from published secondary data sources, and
from  subjective judgment.  At various stages, the data utilized are
subject to error.

The nature and scope of possible errors should be identified and limits
placed on the analysis accordingly.  The purpose of this final  section
is to present limits of the analysis  in terms of accuracy,  range  of
error,  critical assumptions and questions remaining to be answered.
                          General Accuracy
Financial information  concerned with investments, operating costs and
revenues was in general not available for individual plants  or  firms in
the grain milling industry.   Consequently, the financial aspects of  the
impact  analysis  were,  of necessity,  based upon synthesized costs and
returns for "representative" model  plants within each subindust ry
studied.  The accuracy of the financial  data  used is  difficult to measure,
however it is believed that the data used are representa ti ve.   Various
checks  were made to establish the reasonableness of the data  used.

The requisite data were developed by DPRA from  a  variety of sources
including published materials from universities  and government agencies,
previous  studies done  by DPRA, information obtained from industry
sources including trade associations, published  financial performance
data sources, and from private individuals knowledgeable of the industry.
A variety of crosschecks were made using published information from
the Internal Revenue Service, Standard and Poors, Dun and Bradstreet
and other financial  data sources to ascertain whether the simulated per-
formance of the  model plants were representative of the financial per-
formance experienced in the  respective grain milling subindust ries.
Based on these crosschecks, it is believed that the model plants are
representative and  suitable for  assessing the incremental impacts  of
pollution controls.

It is noted that in the recent past  the grain commodity markets in general
(including corn,  wheat and rice) have been exceptionally volatile and
                                VIII-1

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record high prices have been estabii shed.  These prices directly affect
the grain m lling industry and the full repercussions on the milling
industry are not yet known.  Therefore,  in order to best reflect  normal
milling conditions.  DPRA ejected to base gross margin estimates on
1967-1971 average price conditions.  While this  procedure  does  not
accurately represent current prices,  it was felt  that average  gross
margins would better reflect  expected conditions in the industry.

Water pollution control costs were provided by EPA (and Sverdrup
&j  Parcel and Associates).  These data were developed for a typical
plant within  each subindustry studied.  It was necessary to adapt these
data in some  cases  for alternative sized plants.  DPRA adjusted or
scaled these data  as described above  to reflect the general  type of
change required,  but there may be considerable  inaccuracy involved.

Another  concern involving the water pollution control costs is that no
costs were provided or assumed for in-plant modifications  which may
also be required to  achieve the effluent  guidelines.  As a partial com-
pensation for this potential cost, the control costs given were varied by
+  30 percent.  The  higher level could serve as a surrogate for associ-
ated in-plant  modifications.
                           Range of Error
Different data series and different portions  of the analysis will have
various possible ranges of error.  Subjective estimates  of error  ranges
for the grain milling industry as a whole (or subindustries if indicated)
are as follows:

                                                    Error Range

        1.   Number, location, size or other
            organization and structure in-
            formation
                a.   Corn wet milling
                b.   Corn dry milling                    _+ 10 %
                c.   Bulgur
                d.   Parboiled rice milling

        2.   Price information for products
            and raw materials                           + 5 %
                               VIII-2

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        3.   Cost information for plant
            investments and operating costs            _+ 10 %

        4.   Financial performance information         J^ 10 %

        5.   Salvage values of plants and
            equipment                                 j-20 %

        6.   Water pollution control costs             Unknown


                       Critical Assumptions
In order to complete this analysis of the grain milling industry within
the scope of  study established, a variety of assumptions were  required.
Some critical assumptions were applicable to all segments studied,
while others were specific to a given subindustry.  The main assumptions
deserving further comment are described below.

Representativeness  of Model Plants.  It is difficult to represent an industry
or subindustry with  only 1  to 3 model plant situations when there are
actually many sizes and types of  plants in the industry.  In the four sub-
industries  studied, the most difficult one to  simply represent was  corn
wet milling.  No two plants in this industry are alike because numerous
end-products and product mixes can be produced.

The corn wet milling model plants were assumed to produce an overall
industry "average" mix of products.  This approach seemed reasonable
within the limits of this study,  but additional cases would be required
to simulate various  actual operations.

The other subindustries are less subject to wide  variation although pro-
duct mixes can differ from the assumed conditions,  especially in corn
dry milling.

Model Plant  Cost Data.   Secondary or published investment and operating
cost data are minimal in the grain milling industry.  Engineering  synthe-
sis techniques had to be relied upon as a basis for constructing most of
the model plant cost  data.  Piecemeal published data and information
provided by knowledgeable industry  sources were correlated with  the
engineering data. The resulting  model plant data are believed reason-
able and representative, but it remains  that the  data are not based on
reported "book value" statistics.


                               VIII-3

-------
Prices  and Inflation.  Current prices in the grain milling industry are
presently distorted and not believed representative of future expectations.
Prices  and margins used in the model plant cases  are typically 1967-
1971 averages.  This price data is assumed to better represent the grain
milling industry.

Regarding the impact of inflation on the model plant analyses,  it is
commonly assumed that both costs and returns will be proportionately
affected by inflation such that the impact is offsetting.   However, it is
noted that  pollution control costs are increasing  relatively faster thain
other segments of the economy.  Thus, one might  question the accuracy
of the estimated 1977 and 1983 waste treatment costs relative to other
costs and prices.

Status of Current Effluent Controls.  Within the corn dry milling  sub-
industry it is assumed that only  "very few" of the plants currently dis-
charge  into surface waters and that these mills are large plants.
Further verification of  this assumption is needed.   Contacts with in-
dustry association sources indicated that no plant by plant survey had
been completed, although the  general statements used in this report
were  verified.

Salvage  Values.  The alternative salvage values  presented for the shut-
down  analysis above are subject to wide variation based on plant lo-
cation,  size,  prospective alternative uses,  etc.  The smaller model
plants,  if higher salvage  values  were possible,  would more likely shut-
down  since profits were generally low (although not negative) for  these
cases.

Water Pollution Controls. In assessing the impacts of  the wafer  pollution
control costs provided,  no allowance was assumed  for in-plant modifi-
cation cos's.   Further assessment of this source of costs may be
warranted.  As previously noted, a j 30 percent change in pollution con-
trol costs  V.A.- analyzed to indicate sensitivity of financial measures to
the estimated costs.

Most  of these and other less critical assumptions have  been  discussed
previously in this report.  Such  assumptions are based  upon best judg-
ments given prevailing  conditions in the grain milling industry.
                                VIII-4

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                        Remaining Questions
One of the main questions  remaining concerns a more precise know-
ledge of the number,  size  and location of corn dry milling plants which
discharge directly into surface waters.  Smaller plants would be ad-
versely affected and might close.  This should have  little effect on the
industry as a whole, however.

The availability of land for installing the type of waste treatment fa-
cilities proposed is also a remaining question.   Since the corn wet
millers have  or are building waste treatment systems they have  some
additional land,  but is it adequate for additional  treatment require-
ments,  e.g., deep bed filtration?  Land availability by any affected
corn dry  millers is also of concern.
                                VIII-5

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                      SELECTED REFERENCES
Sensing,  H. O. and D.  R. Brown,  "Process Design for Treatment of
       Corn Wet Milling Wastes, " in Proceedings Third National
       Symposium on Food Processing Wastes,  Corvallis,  Oregon,
       U. S.  Environmental Protection Agency, November, 1972,
       pp.  277-291.

Sensing,  H. O. , D.  R.  Brown and S. A.  Watson,  "Waste Utilization
       and Pollution Control in Wet Milling," Cereal Science Today,
       October, 1972, pp. 304-307.

"The Corn  Refining Industry, " by the Corn Refiners Association, Inc. ,
       (1967).

Eiland, J. C. and  Theo. F. Moriak,  Distribution Patterns  for U.  S.
       RJ£e_LJ_969r_7_0_, ERS-484, ERS,  USDA7~Mayrrr"i"97"2^

Eiland, J. C. and  Theo. F. Moriak,  "Rice Milling Costs in the  United
       States,  1971-72, " Marketing  Economic Division, ERS, US DA,
       March,  1973.

Fisher, Glen W. ,  "The  Technology of Bulgur Production," Bulletin,
       Association of Operative Millers, May, 1972, pp. 3300-3304.

Glade, Edward  H. , and Whitman M.  Chandler, An Interindustry Analysis
       of Grain Production and Processing,  Mktg. Res. Rpt.  No. 962,
       ERS,  USDA,  June, 1972.

Grant, Warren  R.  and D. S.  Moore, Alternative Government Rice Programs,
       An Economic Evaluation,  AER  No. 187, ERS, USDA, June, 1970~

Holder, Shelby  H. , et al. , A Systems Model of the U. S. Rice Industry,
       Tech. Bull. No.   1453,  ERS,  USDA,  November,  1971".

Houston,  D. F.  (ed. ), Rice,  Chemistry and Technology, American Assoc.
       of Cereal Chemists, St. Paul, Minn., 1972.

Inglett, G.  E. (ed. ),  Corn: Culture, Processing,  Products, Avi Publish-
       ing Co. , Westport, Conn. ,  1970.

Joslyn, Maynard A. and J. L.  Heid,  Food Processing Operations,  Their
       Management,  Machines, Materials, and Methods, Avi Publishing
       Co., Westport, Conn., 1964.

-------
Junk,  W. Ray and Harry M.  Pancast, Handbook of Sugars for Processors,
        Chemists  and Technologists,  Avi Publishing Co. ,  Westport, Conn. ,
        __.-


Larkin, L.  C. , Economics of Sweetner Marketing, An Annotated Biblio-
                         ~'~                  ~~~~~~
        gi-aphy oelectedRefereme's~   ERS-474,
        1972.

 Liebenovv,  Robert C, ,  "Statement on Regulations ^: nd Guidelines for
        Effluent Limitations (for the Corn Wet Milling Industry), "
        presented to the Effluent Standards and Water Quality Aclviiury
        Committee, West Lafayett, Indiana, April 30,  1973.

 "List of Flour Mills  in the United States and  Canada with Other Ct rc.ti
        Processing Units," The Northwestern Miller,  Vol. 278, No.  9,
        September, 1971.

 Market Structure of the Food  Industries, Marketing Research Report
       1^7T7l7"E"RS7"MED,  USDA,  September,  1972.

 Maty, Samuel A.  (ed.),  The Chemistry and Technology of Cereals  as
        Food and  Feed; Avi Publishing Co. ,  Westport,  Conn . , 19-9.

 National Commission on Food Marketing, Organization and Competition
        in the Milling and Baking Industries,  Tech. Study No.  5,
        June, 1966.

 Senti, F. R. and  W.  C.  Schaefer,  "Com--Its Importance  in Food,  Feed,
        and Industrial Uses, "  Cereal Science Today,  November,  1972,
        pp.  352-357.

''The Story of Corn and Its Products, " by the Corn Industries Research
        Foundation, Inc.  , 1952.

 Sverdup & Parcel and  Associates,  Inc. ,  Development Document for Effluent
        Limitations Guidelines and Standards of Performance, Grain Milling
        (Draft), for U, S. Invironmental Protection Agency, (Contract No.
        6^-01-1503),  June,  1973.

 Sverdrup &  Parcel and Associates, Inc. ,  Industrial Waste Study Report,
        Grain Milling Industry (Draft),  submitted to EPA,  Washington,  D.  C. ,
        August, ~1971~

 Thuroczy, 'Nicholas  M. and Woodrow A. Schlegel, Costs of Operating
        Southern Rice Mills,  Mktg.  Res.  Rpt. No. 330, MED, AMS~
        USDA, June,  1959.

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Whistler, Roy L.  and Eugene  F.  Paschall (ed.), Starch:  Chemistry and
       Technology, Academic Press, New York,  1967.

Wilson, Dale  W. and David  Volkin, A Plan for Integrated Rice Marketing
       in Louisiana, Farmer  Cooperative Service Report 130, FCS,
       USDA~F?b7uary,  1973.

Witte, George C. , Jr. ,  "Rice Milling in the United States, " Bulletin,
       Association of Operative Millers, February, 1970, pp. 3147-3159.

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 BIBLIOGRAPHIC DATA
 SHEET
I. Report No.
        EPA-230/1-73-014
3. Recipient's Accession No.
4. Ti.U- and Subtitle
     Economic Analysis of Proposed Effluent Guidelines
            Grain Milling Industry
                                               5. Report Date August,  1973
                                                (Date of completion)
                                                                    6.
7. Author(s)
      Samuel G. Unger, Michael W.  Woolverton
                                               8. Performing Organization Kept.
9. Performing Organization, Name and Address
   Development Planning and Resea rch A ssociates , Inc.
   P.  O. Box 727
   Manhattan,  Kansas  66502
                                               10. Project/Task, ttork Unit No.
                                                  Task Order No.  2
                                               11. Contract/Grant No.
                                                 Contract No.
                                                  68-01-1533
12. Sponsoring Organization Name and Address
   Environmental Protection Agency
   Waterside Mall
   4th and M Street, S. W.
   Washington,  D.  C.  20460
                                               13. Type ot Report & Period
                                                  Covered
                                                  Final Report
                                               14.
15. Supplementary Notes
16. Abstracts
      The economic impacts  of proposed effluent limitation  guidelines on four sub-
  industries of the grain milling industry are assessed:  corn wet milling,  corn dry
  milling, rice milling and bulgur (wheat) processing.   The analysis  includes classifi-
  cation and description  of types of firms and plants, financial profiles of selected model
  plants, and prices and  pricing practices within each  subindustry studied.   The financial
  impacts of water pollution control costs on model plants were assessed using discounter.
  cash flow analysis and industry-wide impacts  were projected.
       Grain milling was tewate rs are generally amenable to biological treatment systems,
  Consequently, many milling plants  can and have tied into municipal treatment systems.
  All rice mills (parboiled only), bulgur processors and most corn dry mills discharge
  into municipal systems.  Industry-wide impacts should therefore be minimal.
17. Key U'ords and Document Analysis.  17a. Descriptors

   Water pollution, economic analysis, milling,  grains (food),  food industry, corn,
   rice, wheat, pollution, industrial wa stes ,  economic, demand,  supply, prices,
   variable  costs, fixed costs, fixed investment,  discounted cashflow, mills, wet
   mills ,  flour mills
17b. Idcntifiers/Open-Ended Terms
                    05 Behavioral and social sciences,  C-economics
17c. Co ATI Fieid/r,r,,Up  06 Biological and medical sciences, H-food
18. Availability otatt-r.icnt
  National Technical Information Service
  Springfield, Virginia   22151
                                   20. ,S(.^ urity k  i.iss ( l ins,
                                      Pif.v
                                   	r\ri \ :MHI n
                                                                              22. i ru

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16.     Abstracts  (continued)
     Corn wet mills have the most serious effluent problems.  However,
only 5 of  17 plants  discharge directly into surface waters.  These plants
will be impacted severely relative to the  remainder of the industry, but
none are expected to shut down.

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