i I
c/EPA
 United States
' | Environmental Protection
i I Agency
           Office of
           Water Planning and Standards
           Washington, DC 20460
                                  EPA-440/2-79-018
           Water
Economic Impact Analysis
of Alternative Pollution
Control Technologies

Wood Preserving
Subcategories of the
Timber Products Industry

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This document is available in limited quantities
through  the  U.S.  Environmental   Protection
Agency, Economic Analysis Staff WH-586, 401 M
Street, S.W., Washington,  D.C.  20460,  202-755-
2484.

This document will  subsequently be available
through  the  National  Technical   Information
Service, Springfield, Virginia, 22151.

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EPA-440/2-79-018
        Economic Impact Analysis of
 Alternative Pollution Control Technologies


          Wood Preserving Subcategories
          of the Timber Products Industry
        U.S. Environmental Protection Agency
           Office of Water Planning and Standards
                   September 1979

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     This report has been reviewed by the Office of
Water Planning and Standards, EPA, and approved
for publication. Approval does not signify that the
contents necessarily reflect the views and policies of
the  Environmental Protection  Agency, nor  does
mention of trade names or commercial products
constitute endorsement or recommendation for use.

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                                   PREFACE
     This document is a contractor's study prepared for the Office of Water Planning and
Standards of the Environmental Protection Agency (EPA). The purpose of the study is to analyze
the economic impact which could result from the application of effluent standards and limita-
tions issued under Sections 301, 304, 306 and 307 of the Clean Water Act to the timber products
industry.

     The study supplements the technical study (EPA Development Document) supporting the
issuance of these regulations. The Development Document surveys existing and potential waste
treatment control methods  and technology within particular  industrial source categories and
supports certain standards  and limitations based upon an analysis of the feasibility of these
standards in accordance with the requirements of the  Clean Water Act. Presented in the
Development Document are the investment and operating costs associated with various control
and treatment technologies.  The attached document supplements this analysis by estimating the
broader economic effects which might result from the application of various control methods and
technologies. This study investigates the effect in terms of product price increases, effects upon
employment 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 Water
Planning and Standards of EPA. This report was submitted in fulfillment of Contract Nos. 68-01-
4194 and 68-01-4398 by Arthur D. Little, Inc.

     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. The study is not an official EPA
publication.  It  will be  considered  along  with  the information contained in the Development
Document and  any comments received by EPA on either document before or during final rule
making proceedings  necessary to  establish final regulations. Prior to final promulgation  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 timber products industry.

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                      TABLE OF CONTENTS

                                                          Page

List of Tables                                                  vii

List of Figures                                                 ix

I.   EXECUTIVE SUMMARY                                      1

    A. SCOPE OF WORK                                        1
    B. INDUSTRY CHARACTERIZATION                            1
    C. COSTS OF COMPLIANCE                                   2
    D. ECONOMIC IMPACT                                      3

II.   INDUSTRY CHARACTERIZATION                               7

    A. INDUSTRY DEFINITION                                   7
    B. TYPES OF FIRMS                                        7
    C. PRODUCT DESCRIPTION                                  10
    D. CHARACTERISTICS OF THE EXISTING INDUSTRY PLANTS        15
    E. CHARACTERISTICS OF NEW PLANTS                         17
    F. COMPETITIVE STRUCTURE OF THE INDUSTRY                 21
    G. PRICE AND COST HISTORY                                25
    H. FINANCIAL PROFILES                                   29

III.  COST OF COMPLIANCE                                     35

    A. INTRODUCTION                                        35
    B. CURRENT EFFLUENT STATUS                              35
    C. CONTROL OPTIONS                                     35
    D. COSTS OF COMPLIANCE FOR EXISTING INDUSTRY              36
    E. COST OF COMPLIANCE FOR NEW SOURCES                    36

IV.  ECONOMIC IMPACT ASSESSMENT                              45

    A. ECONOMIC CHARACTERISTICS OF IMPACTED PLANTS           45
    B. ECONOMIC IMPACT ON EXISTING INDUSTRY                  45
    C. ECONOMIC IMPACT UPON NEW SOURCES AND
      CAPACITY EXPANSIONS                                  54

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                   TABLE OF CONTENTS (Continued)

                                                           Page

 V.  LIMITATIONS OF ANALYSIS                                   57

    A.  EPA REGULATIONS AFFECTING WASTE DISPOSAL              57
    B.  RETURN ON INVESTMENT CRITERIA                        58
    C.  COST VARIATIONS FROM PLANT TO PLANT                   58
    D.  FUTURE GROWTH IN DEMAND                             59
    E.  LOCAL CONDITIONS OF IMPACTED PLANTS                   59

REFERENCES                                                 61

BIBLIOGRAPHY                                               63

APPENDIX A- INDUSTRY CHARACTERIZATION                      65

APPENDIX B- PRO-FORMA NEW SOURCE MODELS                    69

APPENDIX C- EPA FINANCIAL 308 SURVEY                         79

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                                      LIST OF TABLES

Table No.                                                                        Page

  1-1     Total Cost of Compliance Wood Preserving Industry                           4
  1-2     Summary of Economic Impact Steaming Indirect Dischargers                   5
  1-3     Summary of Economic Impact Boulton Indirect Dischargers                   6
  11-1    Pressure Cylinder Capacity of the Ten Largest Wood Preserving Firms, 1976     8
  11-2    Wood Preserving Plants Form of Business Organization, 1976                   9
  11-3    Preserved Wood Products and Their Potential Substitutes                     11
  II-4    Wood Treated With Preservatives, 1955-1976                                12
  11-5    Value of Shipments for the Wood Preserving Industry, 1958-1976             13
  II-6    Distribution by Annual Sales Value                                         17
  II-7    Number of Production Employees Per Plant, 1976                           19
  M-8    Distribution of Wood Preserving Plants by Year of Initial Operation            19
  H-9    Profitability of New Plants versus Older Plants,  1976                         20
  11-10   Estimated Fixed Capital Requirements for the Manufacture of Preserved
         Wood (organic treatment)                                                  22
  11-11   Estimated Annual Operating Costs for the Manufacturing of Preserved Wood   23
  11-12   Concentration Ratios in the Wood Preserving Industry, 1963-1976             24
  11-13   Selected Operating Ratios for the Wood Preserving Industry: 1964 to 1976     27
  11-14   Pro-For ma Income Statements of Wood Preserving Plants by Sales
         Category                                                                 30
  11-15   Wood Preserving Plants Asset Turnover by Sales: Service Category, 1976        31
  11-16   Wood Preserving Plants Distribution of Assets by Sales and Service Company
         1976                                                                    32
  11-17   Capital  Expenditures and Productivity in Wood Preserving Industry, 1967-
         1976                                                                    33
  11-18   Target Rate of Return for Investments Made by Wood Preserving Industry      34
  111-1    Wood Preserving Steaming Indirect Dischargers  Cost of Compliance Under
         Alternative Technologies                                                  37
  III-2    Wood Preserving Boulton Indirect Dischargers Cost of Compliance Under
         Alternative Technologies                                                  38
  III-3    Total Cost of Compliance Wood Preserving Industry Installing Least-Cost
         Technology                                                              39
  HI-4    Wood Preserving Industry Production Size Cutoffs Indirect Dischargers         40
  III-5    Total Cost of Compliance Wood Preserving Industry Installing Least-Cost
         Technology (With Size Cutoff)                                             41
  111-6    Model Plants for New Source Performance Standards                         42
  111-7    Cost of Compliance New Wood Preserving Plants                             43
  IV-1    Land Availability for Plants                                                46
  IV-2    Indirect  Discharger Wood Preserving Plants Percentage Decline in Profitability
         After Compliance Without Price Increases                                   49
  IV-3    Form of Business Organization by Discharge Status                           52
                                            vu

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                               LIST OF TABLES (Cont)

Table No.                                                                     Page

  IV-4     Wood Preserving Industry Potential Plant Closures Under BAT
           Alternatives                                                         53
  IV-5     Wood Preserving Industry Employment Losses from Plant
           Closures                                                            54
  IV-6     Impact of BAT Requirements Upon Long-Run Revenue Required
           to Support New Sources                                              56
  V-1      Changs in Revenue Required by Discount Rate                           58
                                          vm

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                                LIST OF FIGURES

Figure No.                                                                    Page

    11-1         Sales Trends for Preserved Wood Products 1960-1988               14
    11-2         Wood Preserving Plants in the United States, 1974                  18
    II-3         Wood Preserving Industry - Price Indices of Raw
                Materials, 1970-1978                                            26
    II-4         List Prices of Selected Preserved Wood Products, 1969-1978         28
    IV-1         Price Increases Required to Recover Costs of Compliance            48
    IV-2         Investment Required for BAT Alternatives as a Percentage
                of Cash Flow                                                   51
    V-1         Revenue Requirement as a Percentage of Sales by ROR
                for Sample Plants                                               59
                                         IX

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                       I.  EXECUTIVE SUMMARY

A.  SCOPE OF WORK
     The U.S. Environmental Protection Agency (EPA) is required by Section 301 (d) of the
Clean Water Act to review and revise, if necessary, effluent limitations promulgated pursuant to
Sections 301, 304, and 306 within five years of promulgation of these regulations.  This study
presents an economic impact analysis of alternative pollution control technologies for the wood
preserving subcategories of the timber products industry. It characterizes each wood preserving
subsegment; summarizes alternative technologies and their related costs of compliance* and
analyzes and discusses the anticipated economic impact on those plants that would have to make
investments to be in compliance with alternative regulation options. The EPA assisted in the
analysis by surveying the wood preserving industry through a Financial 308 Letter.

     The study does not address the costs and economic impacts that might or might not  be
incurred as a result of other environmental or other Federal regulations, such as EPA solid waste
regulations, EPA air pollution regulations, EPA pesticide regulations or Occupational Safety and
Health Administration regulations.

B.  INDUSTRY CHARACTERIZATION
     The wood  preserving industry  comprises establishments primarily engaged  in treating
wood, sawed or planed in other establishments, with creosote or other preservatives to prevent
decay and to protect against fire and insects. This industry also includes the cutting, treating,
and selling of crossties, poles, posts, and pilings.

     The wood  treating process can employ either pressure  or non-pressure systems. Non-
pressure processors use open tanks containing the preservatives in which the wood is immersed.
Pressure processors can be either "full-cell," commonly used with aqueous solutions, or "empty-
cell," used with oil preservatives.

     The industry is composed of a large number of small, privately owned plants and a few
larger establishments, totaling 302 companies that operated about 415 wood preserving plants in
the United States in 1976. Of these companies, 87% are single-plant firms. The largest, Koppers
Company, operates 25 plants, whereas the other multi-plant firms operate 10 or fewer. The  10
largest represent approximately 51% of total industry pressure-tank capacity.

     Wood preserving companies vary with respect to  the degree of vertical integration and
ownership. Most of the companies are not integrated back to the ownership of timberland but
purchase wood or treat customer-owned wood on  a service basis only. Ownership is about 22%
through publicly held corporations, 69% privately held and 9% proprietorships.

     In general, firms located in the  South are treating mostly Southern Pine while those in the
West treat mostly Douglas Fir. The industry uses either oil-borne (organic) preservatives for
products such as poles, pilings  or  railroad ties, or waterborne  (inorganic) preservatives for
plywood and lumber. The majority (80%) of firms treat with organic preservatives.
'Derived from Revised Technical Review of Best Available Technology. Best Demonstrated Technology and Best
 Demonstrated Technology and Pretreatment Technology for the Timber Products Point Source Category, as prepared
 for the Environmental Protection Agency by Environmental Science & Engineering, Inc.

                                           1

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     Wood preserving plants are distributed throughout the United States, but 45% are located
in the Southeast. Of plants responding to the EPA Financial 308 Survey, 30% described their
plant site as urban, whereas 25% were reported to be suburban and 45%, rural. The industry
exhibits a fairly even distribution by annual sales value, with 45% of the facilities having sales
between $300,000 and $2.4 million.

     The value of shipments by the wood preserving industry rose from $344 million in 1967 to
$761 million in 1974, before easing in the succeeding two years. The volume of wood preserved
peaked at  286 million cubic feet in 1967; in 1976, the most recent year for which data are
available, the total volume was 257 million cubic feet. Future growth will vary by product but is
forecast by Arthur D. Little, Inc., to average three percent per year to 1988.

     Preserved wood is largely a commodity market modified by transportation costs which give
regional advantages to some producers. Sometimes, the availability of a particular wood  specie
can also be a factor. Demand elasticity in the industry varies somewhat among products but the
major factors governing demand are the competition within the industry, the economic climate of
user industries and the cost-effectiveness of substitute products.

     The  industry has experienced  significant cost increases for some  of  the  principal raw
materials used, especially chemicals and wood. However, producers have been largely able to pass
on increased costs in the form of higher selling prices, although margins have eased during the
1970's.

     Pro-forma income statements developed for seven  sales and service categories of wood
preserving  plants indicate a range in after-tax profit of 0.5% to 6%. (Plant models were developed
for five plants treating owned-wood products and ranging in sales from $200,000 to $7.5 million,
and  two  plants offering a  treating service only and having sales  of $250,000 and $1 million,
respectively.) The return on total capital in 1976 for 314 of the 337 respondents  to the EPA
Financial 308 Letter ranges from 1.9% to 32%. The ratio of sales to total assets ranges from
2.5 to 5.

C. COSTS OF COMPLIANCE
     Costs of compliance were developed for three levels of treatment for each indirect discharge
plant:

     •  Biological treatment;
     •  Metals removal; and
     •  Zero discharge.

     Six options were examined for indirect dischargers:

     •  Option 1: Existing interim final standards; i.e., no further regulation;
     •  Option 2: Biological treatment only for plants using pentachlorophenol;
     •  Option 3: Metals removal for plants with  fugitive metals;
     •  Option 4: Zero discharge only for plants using pentachlorophenol or plants with
                  fugitive metals;

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     •  Option 5: Zero discharge for plants using pentachlorophenol; and
     •  Option 6: Zero discharge for all indirect dischargers.

     The total investment required for all indirect dischargers is highest under Option 6, at $6.1
million, and lowest for Option 3, at $1.6 million (Table  1-1).

    . The cost of compliance was also calculated using a set size-cutoff criterion. The effect of
using the size cutoff is to cut in half the number of impacted plants and the total industry cost of
compliance.

     There is only one direct discharging plant; and for that plant, two levels of treatment
technology were developed:

     •  Additional biological treatment with activated carbon adsorption; and
     •  No discharge, through spray evaporation.

D.  ECONOMIC IMPACT
     A  small portion  (10%) of the  wood preserving  subcategory will be  affected  by the
alternatives that were considered.

     The EPA is  proposing Option 5 without a  size cutoff as the Pretreatment Standard for
Existing Sources for both Boulton and steaming indirect dischargers. A total of 21 steaming
plants and 6 Boulton plants  will  be  impacted by Option 5. Revenue required to recover cost
ranges from 2% to 33% (Table 1-2) for impacted steaming plants and 2% to 49% (Table 1-3) for
Boulton plants. Under Options 2  and 3, required price  increases would  have been lower while
under Options 4 and 6 the required price increase to recover cost would have been about the same.

     There will be no general price  increase as a consequence of the alternatives  studied.
Individual plants may be able to recover their cost if local market conditions permit. Therefore,
the profitability of impacted plants will decline.

     The investment required under each  option studied is generally larger than average annual
cash flow for indirect dischargers  (Table 1-2). An estimated 25% of annual cash flow could be
made available for pollution control investment; thus most plants will require external financing.

     Under Option 5, there could be from two to seven plant closures in the steaming category
and one to three in the Boulton category. The employment losses associated with plant closures
are expected to range from 103 to 383  in the steaming category and from 15 to 56 in the Boulton
category. Under Options 2 and 3, in the steaming category, plant closures and  employment
would  have been  lower while under  Options 4 and 6 both would  be higher. In  the  Boulton
category, the plant closures and employment losses are the same under Options 3, 4 and 6 as for
Option 5.

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               II.  INDUSTRY CHARACTERIZATION

A.  INDUSTRY DEFINITION
     As defined in Standard Industrial Classification (SIC) 2491, the wood preserving industry
"comprises establishments primarily engaged in treating wood, sawed or planed in other estab-
lishments, with creosote or other preservatives to prevent decay and to protect against fire and
insec.ts. This industry also includes the cutting, treating, and selling of crossties, poles, posts, and
piling."

B  TYPES OF FIRMS
     The wood preserving industry is composed of a large number of small, privately owned
plants and a few larger establishments. Larger establishments are generally either:

     •   Owned by companies whose major source of income is not wood preserving:  e.g.,
        Koppers, Kerr-McGee Chemical Corp., Southern Wood Piedmont Co., and Inter-
        national Paper Company; or
     •   Owned by companies which are primarily wood preservers; e.g.,  J. H. Baxter &
        Co., Wyckoff Co.

     Each of these firms operates at numerous locations. There were approximately 302  com-
panies  and 415 wood preserving plants in  the country in 1976. The Environmental Protection
Agency Financial 308 Letter* was answered by 337 plants.

1.  Size of Firm
     The wood preserving companies vary considerably in both sales and number of wood
preserving operations. Of 302 wood preserving  companies, 263 (87%) are single-plant firms, 39
(13%) are multi-plant firms. Koppers Company operates 25 plants; the other multi-plant firms
operate 10 or fewer plants.

     Available information shows that total annual sales of these companies,  including sales
from other operations, range from less than $200,000 to over $1 billion.

     The wood preserving industry has a large  number of small firms. However, on the basis of
pressure tank capacity, the 10 largest firms represent approximately 51%  of the total industry.
While actual production may not be  directly correlated with pressure tank capacity because
capacity utilization may vary and different products and different species of wood require varying
treating times, pressure tank capacity is an indicator of production capacity. In 1976, Koppers
Co., Inc., represented 20% of total industry capacity, while the four largest firms represented 37%
of total capacity (Table II-l).

2.  Integration
     Wood preserving companies also vary with respect to vertical integration. Some plants are
part of lumber operations or associated with a company sawmill. In such cases, the wood treating
operation may be an additional service for lumber customers.  In other cases, such as Koppers
•Survey conducted by EPA under Section 308 of the Federal Water Pollution Control Act, as amended, referred to
 throughout as the "EPA Financial 308 Letter." A response summary and the tabulated data are contained in Appendix
 D. The number of responses to individual questions often are fewer than 337.

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                                      TABLE 11-1

                  PRESSURE CYLINDER CAPACITY OF THE TEN LARGEST
                            WOOD PRESERVING FIRMS, 1976
                                                Total Pressure
                                                Tank Capacity           Percent of Total
  Company                                    (thousand cubic feet)       Industry Capacity

  Koppers Co., Inc.                                      415                   20
  Kerr-McGee Chemical Co.                               127                    6
  Southern Wood Piedmont Co.                            123                    6
  J.H.Baxter                                          108                    5
  Wyckoff Co.                                           73                    3
  Atlantic Creosoting Co., Inc.                               57                    3
  International Paper Company                              51                    2
  McCormick & Baxter Creosoting Co.                        50                    2
  Crown Zellerbach Treated Wood Products                    45                    2
  Cascade Pole Co.                                         34                    2
  All others                                           1,OM                   49
  Total Industry                                       2,106                  100

  Source:  Arthur D. Little, Inc., estimates based upon Ernst and Ernst Wood Preservation Statistics —
          1976.

Company, Weyerhaeuser, and International Paper, where the company is involved in  wood
products and/or chemicals, the treatment of wood for customers is a natural expansion of its
existing resources. In a few cases, railroads and utility companies own wood treatment facilities,
which serve as  captive suppliers of poles,  ties, crossarms, etc., and seldom sell to others. The
Atchison, Topeka  & Sante Fe  Railway Company, Burlington Northern, Southern California
Edison Company, Texas Electric Cooperatives, Inc., and Utah Power & Light are some of these.

     Most of the companies, however, are not integrated back to wood; i.e., they do not own their
own timberland, and they purchase wood. A  number of plants treat  wood for customers on a
service basis  only,  while other plants treat wood for customers on a service basis and also treat
purchased wood.

3.  Ownership Characteristics
     Both privately and publicly  held companies are represented in this industry segment. In
general, the smaller, single-plant companies are privately held and the  largest companies are
publicly held.

     There are basically two different patterns of ownership and management in the industry. In
the first category are plants owned by publicly held corporations which may or may not do wood
preserving as the primary activity. These plants are managed by individuals with little or no
equity in the corporation. Plants following the second pattern are owner-managed and may be
proprietorships or  privately held corporations. They may even have been owned by the same
family for several generations.

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     The ownership and management patterns in an industry are important for an assessment of
how the industry will be impacted by pollution control costs. Profitability requirements are very
different between an owner-manager and a corporation which more critically views the return on
investment from one of many plants. The former may accept an increase in abatement costs as a
neccessity for staying in business, while the latter may decide that the increased cost is not
justified by the expected returns. On the other hand, a closely held company may have difficulty
obtaining capital investment funds and thus be unable to continue to operate.

     Among  these plants  primarily treating with organic preservatives,  25% are owned  by
publicly held corporations. Among the plants primarily treating with inorganic preservatives,
only 10% of  the plants are owned by publicly held corporations  (Table  II-2).  Publicly held
corporations owned only 22% of the total number of plants responding to the EPA financial 308
survey; but according to the 1972 Bureau of Census statistics, publicly held corporations ac-
counted for 73% of the total value added of the wood preserving industry.

                                        TABLE 11-2

                               WOOD PRESERVING PLANTS
                         FORM OF BUSINESS ORGANIZATION, 1976
                 Primary
                 Organic Preservatives                        #           %

                 Proprietorship                             23          10
                 Co-op                                     1           0
                 Privately Held Corporation                  158          65
                 Publicly Held Corporation                   59         _25

                                                         241         100

                 Primary
                 Inorganic Preservatives

                 Proprietorship                              5           8
                 Co-op                                    —           —
                 Privately Held Corporation                   54          82
                 Publicly Held Corporation                    7          10
                                                          66         100

                 Total

                 Proprietorship                             31           9
                 Co-op                                     1           0
                 Privately Held Corporation                  230          69
                 Publicly Held Corporation                   72          22
                 Number of Respondents to Question          334         100

                 Source: Derived from EPA 308 Financial Letter

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C.  PRODUCT DESCRIPTION
1. Type of Products
     The development of the wood preserving industry in the United States has been based on
the need for prolonging life in wooden structural products. Historically, railroads ties, utility
poles, and pilings treated with creosote have been the major products of the industry. In recent
years, lumber and plywood treated for fire retardancy, insect resistance, arid rot resistance have
experienced rapid growth.

     The industry's products as listed in SIC 2491"" include:

        Bridges and trestles of wood, treated
        Creosoting of wood
        Crossties, treated
        Flooring, wood block, treated
        Mine props, treated
        Millwork, treated
        Piles, foundation and marine construction, treated
        Piling of wood, treated
        Poles, cutting and preserving
        Poles and pole crossarms, treated
        Structural  lumber and timber, treated
        Vehicle lumber, treated
        Wood products, creosoted

     The industry can be categorized according to size, product, technology, or location. Gener-
ally speaking, the firms that are located in the South are treating mostly Southern Pine, and
those in the West  are treating mostly Douglas Fir. The industry uses oil-borne  (organic)  or
waterborne  (inorganic) preservatives. The products treated with oil, such as poles, piling, and
railroad ties, have a distinct odor and "oiliness," which makes them unsuitable for use where odor
is objectionable. The waterborne preservatives are used for preserving plywood and  lumber,
especially when treating for fire retardancy.

     Competition in the wood preserving industry is normally very keen and usually based on
price. Many suppliers only exist to serve regional markets, and some regions are served by only
one or two  suppliers. There is some limited competition from other materials,  such as steel,
concrete, and aluminum (Table II-3). In addition to price differentials, there! are advantages and
disadvantages to each type of material. Generally the type of use dictates the type of material
required. For example, treated wood piles must be used in acidic soil (such as in a sanitary
landfill)  because acidic conditions corrode steel and concrete. Of particular interest is the
possibility of more vigorous competition from concrete railroad ties; concrete ties are being used
in several parts of the United States and this use is growing.

2.  Market Size
     From 1955 to 1976, the volume of wood treated with preservatives fluctuated from a low of
213.9 million cubic feet in 1962 to a peak production of 286.4 million cubic feet in 1967 (Table II-
4). Production  was 257.2  million cubic feet in 1976, the most recent year for which data are
available. The industry's historical peak production level, 356.6 million cubic feet,  was in 1947,
indicating that the long-term trend is down.

                                           10

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                              TABLE 11-3

PRESERVED WOOD PRODUCTS AND THEIR POTENTIAL SUBSTITUTES
   Preserved Wood Product

   Piling
    Marine piling



    2 x 4's, etc.



    Plywood




    Fire-retardant lumber, plywood, etc.



    Poles


    Railroad ties
Potential Subttitute1

In-place concrete
Driven concrete
Steel piling
Hollow I beams

In-place concrete
Driven concrete
Interlocking iron sheets

Metal studs
I-Beams
Prestressed walls

Concrete
Cinder block
Sheetrock
Particleboard

Asbestos
Gypsum
Metal sheets

Metal poles
Prestressed concrete

Concrete ties
    1.  Not all substitutes have been proven to be reliable. The potential for
       substitution is limited because material selection is often dictated by
       specific uses.

    Source:  Arthur D. Little, Inc., estimates.
                                   11

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     The value of shipments rose from $344.2 million in 1967 to $761 million in 1974, the peak
year (Table II-5). Both 1975 ($647.7 million) and 1976 ($704 million) were below this peak level.
Typically, about 85% of the value of shipments is from owned wood, with the remainder contract
work.
                                       TABLE 11-5

         VALUE OF SHIPMENTS FOR THE WOOD PRESERVING INDUSTRY, 1958-1976
                                       ($ million)
                                     Value of                 Capital
                   Year             Shipments             Expenditures

                   1958                203.0                    3.7
                   1959                218.1                    (D)
                   1960                225.1                    3.7
                   1961                220.1                    4.1
                   1962                230.0                    4.9
                   1963                247.3                    5.5
                   1964                270.9                    5.8
                   1965                279.6                   11.4
                   1966                326.0                   10.4
                   1967                344.2                   10.7
                   1968                375.1                    9.3
                   1969                386.1                   13.2
                   1970                387.8                    8.4
                   1971                416.9                   10.4
                   1972                475.8                   14.8
                   1973                557.4                   11.6
                   1974                761.2                   28.1
                   1975                647.7                   27.5
                   1976                704.3                   22.3

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

 3.  Future Demand Growth
     During the early sixties, the demand for preserved wood products increased dramatically
 compared with levels existing in the fifties (Table II-l). Since then there have been wide swings in
 total annual production but discernible trends for individual product categories.

     The annual production volumes of ties, poles and timbers also exhibit wide swings but there
 are definite trends in each of the major categories shown in Figure II-l. In addition, Arthur D.
 Little, Inc. and others have concluded that these trends are likely to continue over the next 10
 years.

     The forecast values from 1978 through 1988 were derived by analyzing the production trend
 from 1963 to 1976 for each product category as well as the annual fluctuations. The growth rate (or
 decline)  underlying the trend was compared to with the forecast growth rates of other studies to


                                          13

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300

290

280

270

260

250

240

230

220

210

200
              Total
                                                110

                                                100

                                                 90

                                                 80

                                                 70

                                                 60

                                                 50

                                                 40

                                                 30

                                                 20

                                                 10
                                                                    Cross Ties
                                                                 I   I  I   I   I
                                                                                 I   I  I   I   I  I   I   l   I
     60 62 64 66 68 70 72 74 76 78 80 82 84 86 88
                      Year
                                                     60 62 64 66 68 70 72 74 76 78 80 82 84 86 88
                                                                      Year
110

100

 90

 80

 70

 60

 50

 40

 30

 20

 10
Poles
       I  I  I   I  I  I  I  I   I   I  I   I   I  I   l
     60 62 64 66 68 7072 74 76 78 80 82 84 86 88
                      Year
                                                 10 -
                                                     60 62 64 66 68 70 T.l 74 76 78 80 82 84 86 88
                                                                       Year
    Source:  Historic Data — Ernst & Ernst data cited in The Analysis of Existing Wood Preserving Techniques and Possible
           Substitutes, June 1977.
           Forecast — Arthur D. Little, Inc., estimates.

             FIGURE 11-1     SALES TRENDS FOR PRESERVED WOOD PRODUCTS 1960-1988
                              (Thousand Cubic Feet)
                                               14

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check for reasonableness and to establish a range.  As a group, all the other preserved wood
products exhibited no upward or downward trend and were assumed to remain stable at about
42,000 cubic feet per year. The forecast for total preserved wood products is the sum of the
individual product forecasts.

     This analysis was performed to identify product areas when the demand might be declining
and thus  provide a  basis for assessing the willingness and unwillingness of impacted plants to
make an investment in pollution control expenditures. Product growth areas were also examined
to gauge the extent to which they would take up the slack in the production of declining products
and also to evaluate the potential for any price increase.

     On balance, the future outlook for preserved wood products appears good, with the decline
in pole demand being offset by the increase in demand for ties and timbers. The pole demand will
decline because of slowdowns in growth of utilities and because the size of new transmission lines
will require steel. Also, the demand for  poles in  new urban  areas is  being affected by the
requirement to place utility distribution lines underground. The demand  for railroad ties is a
result of the rebuilding of roadbeds, which will produce an upward trend over the next 10 years,
which will level off as the railroad industry shifts from rebuilding to maintenance. The growth in
demand for timbers and lumber is in part a consequence of FHA requirements for preserved wood
in home construction. While the average  annual growth in timbers from 1963 to 1974 was 5.4%, a
future real growth rate of 3% is forecasted to reflect the expected construction of single-family
units in the 1978 to 1988 period.

D.  CHARACTERISTICS OF THE EXISTING INDUSTRY PLANTS
1.  Process Technology
    Wood preserving is a two-stage process; first, the wood is preconditioned to reduce its
moisture content; and, second, the wood is treated with preservatives.

    Any one of several methods can be used to precondition, including: seasoning in large, open
yards;  kiln drying;  pressure steaming in a retort,  followed by vacuum drying;  heating in  a
preservative bath under reduced pressures (Boulton Process); or vapor drying. Pressure treat-
ment  is the most common form of processing.  As widely recognized,  this form  of treatment
provides a superior product to that resulting from the brush or dip application of preservative.

    Wood treating can  be either  a pressure or non-pressure process. In the non-pressure pro-
cesses, the wood is immersed in  open tanks containing the preservatives. The pressure processes
can be either "full-cell"  or  "empty cell." In the "full-cell" process,  a vacuum is created in the
retort and the preservative is added and forced into the wood under pressure. The "full-cell"
process is commonly used with  aqueous  solutions. In the "empty-cell" process, preservative is
added to the retort and forced into the wood under pressure; then the retort is evacuated.

    The typical pressure treatment facility includes three major processing areas:

    •  A treating  cylinder, or pressure vessel,  with the necessary pumps, tanks,  and
        control equipment;
    •  A boiler plant to heat the solution and to pressurize the cylinder;
                                           15

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     •  A seasoning and storage yard, including the cylinder loading track and ancillary
        transportation facilities;
     •  Support equipment, such  as hoists and lifts for handling timber; finishing equip-
        ment, for incising, boring, blocking, framing and shaving materials; and kilns, or
        other processing facilities, for artificial seasoning of selected products.

     The treating cylinders are the most important component of a wood treatment plant. These
steel cylinders (retorts), typically used in pressure treatment, are from 4 to 10 feet in diameter
and up to 175 feet in length. As an indication of the "charge" size held by a treating cylinder, the
average charge for a 6-foot by 36-foot cylinder, typical for a facility in the Northeast, can be 6,000
board feet (500 cubic feet) of lumber.

     Wood preserving plants can also be categorized on the basis of the types of preservatives
used, as follows:

     •  plants treating with organic materials, such as pentachlorophenol, oil, and creosote
        solutions;
     •  plants treating with waterborne inorganic salts, principally zinc, copper, arsenic,
        and chromium; and
     •  plants treating with both organic and inorganic preservatives.

     Of the plants identified by the  1976 AWPA Wood Preservation Statistics, 49% treat with
organics, 21% treat with inorganics, and 24% treat with both types of preservatives.

2.  Product  Diversification Within Plants
     Although the  industry treats a wide range of wood products,  individual  plants usually
concentrate on a limited range of products. Plants using inorganic (waterborne) preservatives
treat mostly dimension lumber, posts, and poles for insect and rot resistance and fire retardancy;
(oil-borne) plants using organic preservatives treat  primarily poles, posts, pilings, and railroad
ties, and a few other products such as cross arms and bridge timber. Poles and ties are the major
production items of organic plants; inorganic plants  have a greater  variety  of treated wood
products,  but their volume may be smaller.

3.  Size of Plants
     There are no published data on individual plant capacities or production, because capacity
varies with the type of wood treated, the type of treatment and the type  of conditioning. For
example, Douglas Fir requires a considerably larger residence time than species found in other
parts of the country. Although the numbers of cylinders and types of processes are known, there is
not  necessarily  a  correlation between these and either plant capacity or production. Some
industry members reported that a  typical 80-ft. cylinder, operating with an organic process, has
an output of 30,000 to 45,000 board feet per day (based on 15,000 board feet per charge, 2 or 3
charges per day). Daily inorganic production may be somewhat higher because of shorter treat-
ment times. Reported annual operating rates (time used for treating as a percent of total time
available for treatment, not including loading and unloading time) for the industry range from
40% to 70%.
                                           16

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     Taking 1976 annual sales value as an indicator of size,  the  plants are very  uniformly
distributed among the value of sales size categories shown in Table II-6. The median plant size
lies in the $0.7 to $1.2 million annual sales range. Six of the 319 plants responding to the EPA
Financial 308 Letter had sales of over $11.5 million, whereas 25 plants had sales of less than $70
thousand.
                                      TABLE 11-6

                        DISTRIBUTION BY ANNUAL SALES VALUE
   1976 Sales
                             Plants Built              Plants Built
                             Since 1970             1970 or Earlier                Total
    ($000)                  #        %             #         %             #        %

      0-70                 8        16            17         6            25        8
     71-155                48            21         8            25        8
    156-300                10        20            19         7            29        9
    301-700                8        16            40        15            48       15
    701-1200               5        10            45        17            50       16
   1201-2400               5        10            37        14            42       14
   2401-3200               5        10            21         8            26        8
   Over 3200                _5        10            69        25           _74       23
   Total Responding          50       100           269       100           319      100

   Source: Derived by Arthur D. Little, Inc., from EPA Financial 308 Letter.

4.  Location
     Although there are no statistics available on the geographical distribution of consumption,
both production and consumption follow the distribution pattern of facilities (Figure II-2). Most
of the plants (45%) are in the Southeast region. Of the plants responding to the EPA Financial
308 survey, 30% described their plant site as urban, whereas 25% were suburban and 45% rural.

5.  Employment
     The median sized plant employs  10 to 19 production  workers (Table II-7). Two plants
employ more than 125 workers,  while 22% of all plants employ fewer than 3 workers. The Bureau
of the Census estimated the total employment of the wood preserving industry to be 9,700 in 1976.
Because of the increased use of materials handling equipment, employment has decreased from
the peak of 12,800 in 1968.

E.  CHARACTERISTICS OF NEW PLANTS
1.  Plants Constructed Since 1971
     Of the 332 plants responding to the question in the  EPA 308 Letter, 56  plants began
operation in the 1971-1977 period (Table II-8). Table II-6 showed the size distribution of 50 of
these new plants based on the value of their 1976 sales. The average new plant is smaller than the
older plants,  possibly  suggesting that  facilities typically expand over their production life.
Comparing the plant size distribution of the new plants  to  the size distribution of all plants
                                          17

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                               TABLE 11-7

          NUMBER OF PRODUCTION EMPLOYEES PER PLANT, 1976
Number of Production
 Employees per Plant           Number of Plants             Percentage of Plants

       1-3                        73                           22
       4-6                        39                           12
       7-9                        26                            8
      10-19                       56                           17
      20-34                       55                           17
      35 - 48                       27                            8
      49-75                       36                           11
      76-99                        8                            2
     100-125                       6                            2
      Over 125                       2                            1

          Subtotal                  328                          100
          No Response              	9_

          Total                     337

     Source: Derived by Arthur D. Little, Inc., from Environmental Protection
            Agency Financial 308 Letter.
                                TABLE 11-8

              DISTRIBUTION OF WOOD PRESERVING PLANTS
                    BY YEAR OF INITIAL OPERATION
Year of Initial Operation            Number of Plants          Percentage of Plants

   Before 1930                           58                       17
   1931 -1940                          13                        4
   1941-1950                          46                       14
   1951-1960                          83                       25
   1961 -1970                          76                        3
   1971-1977                          56                       17
       Subtotal                       332^                     100
       No Response                      5
       Total                          337

   Source: Derived by Arthur D. Little, Inc., from Environmental Protection Agency
         Financial 308 Letter.
                                   19

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(Table II-6), one can see that the median new plants are smaller than all the older plants. The
median annual sales of the new plants is $0.3 to $0.7 million, whereas the median annual sales of
older plants is $0.7 to $1.2 million.

     The median age of the 332  plants responding to the EPA Financial  308 survey is approx-
imately 20 years; 55 plants were built before  1930 and 56 plants began operation between 1971
and  1977, i.e., an average of 7 per year (Table II-8). Most of the responding plants were built in
the 1950's and 1960's.

     The profitability of the two groups is roughly comparable (Table 11-9). The older plants and
the new plants have a median profitability after tax of 2% of sales value.

                                        TABLE 11-9

               PROFITABILITY OF NEW PLANTS VERSUS OLDER PLANTS, 1976
        1976 Prof it
        *fterTax  .                  New Plants1                     Older Plants1
     as Percentage of            	           	
        Sales Value             Number      Percentage           Number      Percentage

        Under 1                  16            37                56            25
        1-2                     6            14                58            25
        3-4                     7            16                47            21
        5-7                     7            16                38            17
        Over 7                   _7_           J6                26            11

          Subtotal               43           100               227           100
          No Response            7                              60

          Total                  50                             287
        1.  New plants are those beginning operation between 1971 and 1977, while older plants
           began operation before 1971.

        Source: Derived by Arthur D. Little, Inc., from Environmental Protection Agency Financial
               308 Letter.

      When industry capacity utilization is low, or demand growth is slow, a competitor has
 difficulty entering the industry. As the industry has become more automated and hence more
 capital intensive in recent years, the  capital cost for entry, in real terms is significantly higher
 now than it was five or ten years ago.

 2.  Capital and Operating Costs for New Plants
      Capital and operating costs were developed for model new source plants proposed by the
 technical contractor. Two plants sizes were selected, with each assumed to be producing one of
 four preserved wood products. The plant sizes are as follows:

      1. Two cylinders, each seven-foot diameter by 130 feet long.
      2. Five cylinders, each seven-foot diameter by 130 feet long.

                                            20

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     The product, location and process relationships are as follows:

Case         Product                     Location           Process
  A           Railroad Ties                South Central      Boultonizing
  B           Southern Pine poles          South Central      Steaming
  C           Douglas Fir poles             West Coast         Boultonizing
  D           Southern Pine lumber        South Central      Inorganic

     The total installed cost for the 5-cylinder facility is about $6.5 million, compared to $3.3
million for the two-cylinder plant (Table 11-10), added to Table 11-11. Of the respondents to the
308 Financial Survey, only 7 (2%) indicated that they had net fixed assets over $2 million.

     The two-cylinder  plant has 25 operating, 7 maintenance and 13 supervisory and office
employees, at an average annual cost of $15,000 per employee (Table 11-11). The five-cylinder
plant is assumed to have 50 operating, 14 maintenance and 20 supervisory and office personnel,
reflecting scale economies over the two-cylinder plant. Taxes and insurance are estimated at 4%
of the capital cost. While maintenance and other consumable supplies, such as packaging,  vary
with the operating volume of each plant, these variations are too small to affect overall operating
costs and have been assumed to be a constant percentage of sales.

     The following additional assumptions were made:

     •  One-product operation was assumed, although most facilities have variable and
        constantly changing product mixes,  depending on  specific and local market
        conditions.
     •  Capital requirements for the  West Coast facility are estimated to be 10% greater
        than for the Southern plants.
     •  Land requirements are 50 acres and 75 acres, respectively, for the two plants.
     •  Raw wood and preservative costs are as specified in accepted, published industry
        references.
     •  40% of the cylinder volume is used for each charge, plants operating three shifts a
        day and 300 days per year.
     •  While cycle  time depends on wood specie,  moisture content,  type of process
        employed and degree of preservation required, the following, perhaps conservative,
        cycle times were used:
         —  Railroad ties (Boultonized) — 30 hours
         —  Southern Pine poles (steamed) — 16 hours
         —  Douglas Fir poles, green (Boultonized) — 40 hours
         —  Southern Pine lumber(CCA) — 16 hours

 F.  COMPETITIVE STRUCTURE OF THE INDUSTRY
 1.  Market Structure
     Although the industry is composed of many small firms, the four largest firms had 37% of
 the total market in 1976, and the eight largest firms had 47% of the total market (Table 11-12).
 The size of the firms vary considerably. The top company has about 20% of the market, the next
                                          21

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                                 TABLE 11-10
  ESTIMATED FIXED CAPITAL REQUIREMENTS FOR THE MANUFACTURE OF
                PRESERVED WOOD (ORGANIC TREATMENT)
                                     ($000)

Location:      South, new facility or replacement value1
Cylinder Size:  7-foot diameter, 130 feet long, 5000 cubic feet in volume
Site Preparation3
Yard Equipment4
Pressure Cylinder
Storage Tanks and Pumps
Utilities:
   Boiler and Compressor5
   Dry Kilns
Primary  Oil-Water Separation6
     Subtotal

Engineering, Construction and
Contingency at 25%
     Total Fixed Capital7

Bare Cost
of Equipment
Per Cylinder

400
250
100
125
100
NA
Installed2
Cost of a
Two Cylinder
Plant
200
800
700
250
400
250
40
Installed2
Cost of a
Five Cylinder
Plant
300
1,600
1,700
400
750
400
57
975
2,640
                    660
                  3.300
5,207


1,302
6,509
1. Add 10% for West Coast construction cost differential.

2. Installation includes piping, instrumentation, electrical, structures, foundations, erec-
   tion labor, and allocated portion of shops and offices.

3. Site preparation costs estimated at $4,000 per acre.

4. Yard Equipment includes track and trams for cylinder loading, trimming and framing
   equipment, and mobile equipment. Processing is based on receipt of rough sawn wood,
   and specifically excludes debarking and rough sawing.

5. A wastewood-fired boiler is assumed.

6. For the primary oil-water separation system, 50% of the cost is included in the cost of
   the plant, as indicated on pages 8-60 through 8:63 of the August 29, 1978, ES&E report.

7. Does not include cost of land acquisition, because land costs vary considerably from
   site to site.

Source:   Arthur  D. Little, Inc., estimates based on industry interviews.
                                       22

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4
Largest
Companies
34
35
34
35
37
8
Largest
Companies
44
44
NA
44
47
20
Largest
Companies
64
63
NA
60
NA
50
Largest
Companies
84
84
NA
78
NA
                                      TABLE 11-12

         CONCENTRATION RATIOS IN THE WOOD PRESERVING INDUSTRY, 1963-1976

                              Percent of Value of Shipments Accounted for by
          Year

          1963
          1967
          1970
          1972
          1976

          Source: 1963-1972: U.S. Bureau of Census, Annual Survey of Manufacturers,
                 1976: Arthur D. Little, Inc. estimates.

three companies have 5% to 6% each, and the next four about 2% each. The remainder of the top
20 have market shares of 1% each and the next 30 have shares averaging a.bout 0.6%. The level of
concentration has not changed significantly since 1963, indicating a stable market structure.

     Preserved wood is largely a commodity market modified by transportation costs which give
regional advantages to some producers. While there is some interregional competition in the
industry, the cost of inbound and  outbound transportation results in predominantly  regional
markets. For some applications, a particular wood specie is preferred and wood may be shipped
over longer distances in these cases; more often, a suitable wood specie may be found locally.

2.  Pricing Mechanism
     Pricing mechanisms appear to be quite varied. For some products (mostly lumber), whole-
salers and  commission firms conduct continuous pricing and bidding between the preserving
plants and the final customers via the telephone. Some of the preserved lumber is sold from price
lists. On the other hand, most  poles,  piling, and railroad ties are sold directly to the customer
through formal bids for specific projects. Purchase decisions are made on the basis of price,
availability, and delivery of future production, since most preservers only keep small inventories
and make the products only on order.

3.  Price Elasticity  of Demand
     Demand elasticity varies somewhat according to the product. The major factors governing
demand  are competition  within the industry and the economic climate  of user industries.
Demand for those products with high demand growth potential (such as dimensionalized lumber)
wil probably not be affected by an  increase in prices. Those products which are threatened by
lower demand growth potential (such as utility poles) have higher price elasticity and will be less
likely to pass along cost increases as increases in price.

     For the immediate future,  the demand for  railroad ties is expected to continue to  grow
strongly because of tightened federal railroad safety regulations and the Northeast Railroad
Reorganization Act. However, concrete ties are now being  used  for some of the replacements.
                                          24

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Inorganically treated  products  (using inorganic salts), although a small portion of all treated
products,  have recently had rapid growth, even  up to 20%  per  annum, and are  expected  to
continue at a growth rate higher than GNP as the construction market improves and demand for
dimension lumber and plywood increases. The market for utility  poles is not expected to grow
strongly, as previously discussed. Currently, it is mostly a replacement market, and threatens to
be diminished  in the future by the requirement for underground wiring. Although there are
economic  and technical difficulties with underground wiring, if these are worked out they may
replace  wooden poles for some  applications. Other products, such as  construction  and marine
pilings,  face some pressure from substitute products. In summary,  it appears that although some
products will have high growth rates, production for the whole industry will continue to have little
long-term growth. This situation will make it difficult for producers to increase prices.

G.  PRICE AND COST HISTORY
     In the 1970-1978 period, the costs of wood preservative chemicals have shown  the greatest
increase, followed by those of wood (lumber, piles, and ties), and finally labor (Figure II-3A). All
of these costs have increased at  a rate greater than that of general inflation (Figure II-3B).

     The  cost of labor in the wood preserving industry has been increasing steadily; the average
payroll  per worker was more than 60% higher in 1978 than in 1970, an annual increase of 6.2%.
However,  since 1970, labor as a percent of value added and per dollar of shipments has declined
(Table 11-13). In fact,  employment in the industry as a whole has declined, from 12,000 in 1970 to
9,700 in 1976, and the percentage of the workforce classified as production workers has also
declined,  from 849o to 79% for the same period, mainly because of the greater use of materials
handling equipment to reduce labor costs.

     Naturally, the most significant raw material cost is that for wood, which represents from
40% to 75% of the selling price of the preserved wood product. The  selling prices of untreated ties
and piles  (Figure II-3A) and lumber (Figure II-4) have increased, respectively, 12.4%, 8,8%, and
13.7% annually in the 1970-1978 period, or faster than the rate of overall inflation. The higher rate
of increase for ties versus piles is attributable in part to favorable demand levels for railroad ties.
The proportion of wood cost to  total sales dollars has remained roughly constant over the 1970-
1978 period and, except for the 1974-1975 recession, the combined cost of all raw materials has
been a stable proportion of the sales dollar (Table H-13).

     Thus, producers have been able to pass on increased costs of wood in the form  of increased
selling prices, as indicated by selling prices having closely tracked  wood costs  (Figure  II-4).

     After years of relatively constant prices, the prices of major chemical preservatives, pen-
tachlorophenol  and, particularly, creosote oil  have increased dramatically since 1973. The price
increases for these chemical preservatives over the 1970-78 period, averaging 11.1% and 12.6% per
year, respectively, are greater than those of the final products. This indicates their increased
importance as an input cost, although they still make up a smaller portion of the total than either
wood or labor.

     The  previous discussion of potential industry growth suggests that future demand will be
weaker, and the industry will have a more difficult time in passing along increased costs in the
form of price increases. However, the pollution abatement cost is predominantly fixed rather than
variable. A change in fixed cost represents a change in long-run  average total cost; therefore,
assuming  the historic supply/demand balance, it is likely that the cost per unit of production for a
                                           25

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250.0
200.0
150.0
100.0
 50.0
    A.  Average Annual Increase:
      Current $(1972 =100)
                                 Creosote 12.6%


                                 Pentachlorophenol
                              / Lumber 13.7% 11'1%


                                 Labor  6.2%
                               II     I     I     I     I
                                                   J	  I    I     I
               1968      1970     1972      1974      1976      1978     1980

     1972 Values: creosote, 27d/gallon; pentachlorophenol 18^/pound; labor $3.31/hour
200.0
150.0
100.0

 75.0

 50.0
    B.  Average Annual Increase:
      Constant $(1972 =100)
                                                                    Creosote 7.
                                                                  Pentachlorophenol 3.7%

                                                                   Lumber 6.7%
                                                                 Labor 0.9%
           I     I
             I    I     I     I     I
                         J	I
                              I     I    I
               1968
           1970
1972
1974
1976
1978
1980
     Sources:
(chemicals) Chemical Marketing Reporter
(wages) Employment and Earnings, US Department of Labor, Bureau of Labor Statistics
(lumber) Wholesale Prices and Price Indexes, US Department of Labor,  Bureau of Labor Statistics
(GNP deflator) Economic Indicators, Council of Economic Advisors.

    FIGURE 11-3   WOOD PRESERVING INDUSTRY
                   PRICE INDICES OF RAW MATERIALS, 1970-1978
                                          26

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Year

1964
1965
1966
1967
1968
1969
1970
1971
1972
1973
1974
1975
1976
                               TABLE 11-13

                   SELECTED OPERATING RATIOS FOR
             THE WOOD PRESERVING INDUSTRY: 1964 to 1976
Cost of
Materials
Per
Dollars of
Shipments
(dollars)
Cost of
Materials &
Payrolls
Per Dollar
Shipments
(dollars)



Value Added
Per Employee
(dollars)



Payrolls as
Percent of
Value Added
0.63
0.64
0.63
0.62
0.61
0.64
0.63
0.64
0.64
0.67
0.63
0.64
0.68
0.81
0.81
0.80
0.80
0.79
0.81
0.81
0.82
0.80
0.80
0.75
0.78
0.81
 8,788
 9,050
10,479
11,103
11,540
11,818
12,017
13,800
15,557
18,446
30,783
24,548
23,608
49
48
45
46
45
47
51
48
42
40
29
38
41
Source: U.S. Department of Commerce, Bureau of the Census, Census of Manufactures,
       1973, 1974, 1975, 1976; and Arthur D. Little, Inc., estimates.
                                   27

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    12

    11

    10

     9

     8

     7
•=    6
Q_
	 Treated
•— — • Untreated

Y / /\ Value Added in Wood
        Preserving
                                                                          Average Annual
                                                                             Increase
                                                                             19 oo/
                                                                             I ^.O/O
                                                                 12.4%
                                                                                9.4%
                                                                                s.8%
                 1968
                 1970
1976
                                                                            1978
1980
                                 1972        1974
                                        Year

 List prices are given because they provide a comparable basis for analysis over an extended period
 of time. The majority of contracts specify prices which provide substantial discounts from list
 prices.
o
 Piles:  Points: 12" - 3 ft. from butt 7 in.; Length: 40 to 50 ft., truck lots,New York
3Ties: 6" x 8" x 8'6", Chicago, Red Oak, Carload lots
Source:  Engineering News Record.

        FIGURE 11-4      LIST PRICES OF SELECTED PRESERVED WOOD PRODUCTS,1
                          1969-1978
                                         28

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larger, more efficient plant will set the maximum amount of price increase. Since the effluent
abatement cost per unit of production will be greater for smaller plants, smaller plants may not
recover the entire cost increase through higher prices. Market factors will determine whether this
cost increase may be passed along through price increases or will be absorbed by reducing profits.

H. FINANCIAL PROFILES
1.  Income and Asset Analysis
     In assessing the economic  impact of an EPA regulation upon  a specific  industry, the
impacted industry is examined on a  stand-alone basis with out regard to the other businesses
associated with it or to resources available to the parent companies of industry plants. For this
reason, it is important to have an accurate picture of the revenues 
-------
                                    TABLE 11-14

                         PRO-FORMA INCOME STATEMENTS
                           OF WOOD PRESERVING PLANTS
                            BY SALES CATEGORY ($000)
Sales
Cost Goods Sold
  Wood
  Payroll
  Other Expenses
  Depreciation

Total Cost Goods Sold

Gross Margin
Selling General
  & Administration
Interest Expense

Profit Before Tax
Profit After Tax

Number of 308 Letter
  Respondents

Percent of Total
  Respondents1
Plants
200
100
44
19
18
4
85
15
11
3
1
0.5
Treating
700
100
44
17
17
2
80
20
12
2
6
3
Owned-Wood Products
1,800
100
55
13
15
2
85
15
11
1
3
2
3,500
100
50
12
20
	 2_
84
16
9
1
6
3
(TOWP)
7,500
100
55
19
12
	 2_
__88_
12
5
1
6
3
Treating Service
Only (TSO)
250
100
8
20
39
5
72
28
14
2
12
6
1,000
100
24
19
34
	 2_
21
21
15
1
6
4
50
81
15%    25%
40
         12%
50
          15%
50
          15%
            2%
37
11%
1.13 plants (4%) had sales evenly split between TSO and TOWP.

Source: Derived by Arthur D. Little, Inc., from EPA Financial 308 Letter.
                                        30

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                                        TABLE 11-15

                                WOOD PRESERVING PLANTS
                  ASSET TURNOVER BY SALES/SERVICE CATEGORY, 1976
                                              Turnover Ratio
    Sales/Service
  Category ($000)

  TOWP
    200
    700
  1,800
  3,500
  7,500

  TSO
    250
  1,000
Total
Plants1
  50
  81
  40
  50
  50
   6
  37
   Sales/
Total Assets
    2.5
    3.0
    3.0
    2.5
    2.5
    3.0
    5.0
   Sales/
Net Assets2
    3.8
    4.7
    4.3
    3.1
    3.1
    4.0
    8.0
   Sales
Fixed Assets
     5.0
     8.0
    10.0
    10.0
     8.0
     5.0
    10.0
   1976
 Return on
   Total
Capital (%)3
    1.9
   11.1
    8.6
    9.3
    9.3
   24.0
   32.0
  1. Based on 327 responses; 13 plants were equally split between TSO and TOWP.
  2. Total assets less current liabilities.
  3. Profit After-Tax (Table 11-14) = Margin
     Sales/Net Assets = Turnover; Net Assets = Total Assets — Current Liability
     Rate-of-Return on Total Capital = Margin x Turnover

  Source:  Derived by Arthur D. Little, Inc., from Environmental Protection Agency Financial 308 Letter.

distribution of assets varies with size of plant (Table 11-16). For plants engaged in treating owned-
wood products, fixed assets  as a  percentage of total assets generally decline  as sales level
increases. While the reverse is true for TSO plants (Table 11-16), the variability and small total
number of plants are such that the two plant sizes are not statistically different in the percentage
of assets in plant and equipment.

     The  "other current asset" category includes inventory items. As expected, plants treating
owned-wood products, except the smallest plants, have a higher percentage of assets in this item
than plants engaged in treating service only. For both plant categories, accounts receivable
decrease as a percent of total assets as sales increase.

     In recent  years, more than 85% of the industry's capital  expenditures have been on new
machinery and equipment to reduce  labor costs (column 3 of Table 11-17). This investment has
reduced total employment and raised the level of industry productivity (shown as a real increase
in value added per employee in 1967 dollars in column 7) by about 25% in the 1967-76 period.
However,  a number  of firms have  not made the expenditures  to reduce  labor costs; their
comparatively less favorable cost structure will make the financing of major capital expenditures
for pollution control especially difficult.
                                            31

-------
                                      TABLE 11-16

                              WOOD PRESERVING PLANTS
                               DISTRIBUTION OF ASSETS
                        BY SALES AND SERVICE COMPANY, 1976
Sales Category ($000)

Accounts Receivable
Other Current Assets
Total Current Assets
Fixed Assets
Total Assets

Average Value of
Total Assets ($000)

Number of Plants in
Sample1
Plants Treating Owned-Wood
200
35.0%
20.0
55.0
45.0
700
35.0%
30.0
65.0
35.0
1,800
30.0%
40.0
70.0
30.0
Products (TOWP)
3,500
20.0%
55.0
75.0
25.0
7.500
20.0%
50.0
70.0
30.0
Treating Service
Only (TSO)
250
35.0%
25.0
60.0
40.0
1,000
26.0%
24.0
50.0
50.0
                      100.0%    100.0%    100.0%    100.0%    100.0%
                      270
320
617
1,805
3,710
                                          100.0%    100.0%
1.3
751
                       50        81        40         50       50          6        37

1.  Based on 327 responses; 13 plants were equally split between TSO and TOWP.

Source: Derived by Arthur D. Little, Inc., from Environmental Protection Agency Financial 308 Letter.
                                          32

-------
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-------
2. Investment Criteria
     As part of the  Environmental Protection Agency Financial 308 Letter, wood preserving
plants were asked to provide their criteria for investment in wood preserving plant and equip-
ment. This information is used in the economic impact assessment to estimate the price increase
required to recover the cost of pollution control investment. A total of 119 (35%) of the plants
indicated  an investment criterion; 22% provided target internal rate-of-return values,  and 6%
provided payback criteria.

     Plants providing rates-of-return criteria represented a cross section of the wood preserving
plants responding. There were too few responses to the question to subcategorize the  rate-of-
return by  plant characteristics. However, the  distribution of respondents to the question were
similar to  that of the total sample with respect to sales level, current discharge status and type of
preserved  wood product. The distribution of target rates of return was taken as representative of
the total industry.

     The  average and median pre-tax rates of return are in  the 20-24% category (Table 11-18).
Using  midpoints of the categories, the weighted average after tax rate-of-return is about 12%,
assuming  a 48% tax rate. The impact was assessed (Chapter IV) using the weighted average value
and the sensitivity was analyzed (Chapter V) to determine the impact of different rates-of-return
on the results.
                                        TABLE 11-18

                             TARGET RATE OF RETURN FOR
                  INVESTMENTS MADE BY WOOD PRESERVING INDUSTRY
                    Pro-Tax
                     Rate of                                  % of
                   Return (%)              #               Respondents

                     0-4                  0                     0
                     5-9                  2                     4
                    10-14                  7                    13
                    15-19                 11                    21
                    20-24                  8                    15
                    25-29                 12                    25
                    30-40                  8                    15
                    40 or more             4                   	7
                                         52                   100
                                                          #              %of
              Distribution of Sample                     Respondents         Total

              Plants Using Rate-of-Return Criteria              75               22
              Plants Using Payback Criteria                    21                6
              Plants Using Other Methods                     23                7
              Not Answering Question                       218               65
                                                         337              100

              Source:  Environmental Protection Agency Financial 308 Letter.
                                            34

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                       I.  COST OF COMPLIANCE
A.  INTRODUCTION
     The costs of compliance for a number of alternative BAT regulations have been developed
by the EPA Technical Contractor, Environmental Science and Engineering, Inc.6 The purpose of
this Chapter is to summarize the costs of compliance associated with each option, review the
current status  of the industry,  and describe the investment and operating costs that will be
incurred under each alternative.

B.  CURRENT EFFLUENT STATUS
     One wood preserving plant discharges into navigable waters, i.e., it is a direct continuous
discharger, while 42 discharge into municipal systems, i.e., indirect discharge. Inorganic plants
are required to be at no discharge; all remaining organic plants do not discharge. The plants that
will be required to make expenditures represent a minority of the industry. In total,  the 43
potentially impacted plants represent about 10% of the 415 plants in the industry.

     The one direct discharge plant is a steaming plant. An additional 31 plants in the organic
category and 11 Boulton plants discharge into municipal systems.

     The costs of  compliance developed by the  EPA technical contractor were based upon a
separate EPA Technical 308 Letter as well as on plant visits and sampling data. The technical
contractor developed cost of compliance data for each plant separately, including two plants that
did not provide economic data.  Current effluent status was verified by the technical contractor
through follow-up phone calls.

C.  CONTROL OPTIONS
     Six options were examined for indirect dischargers:

     •   Option 1: Existing interim final  pretreatment  standards;  i.e.,  no  further
                 regulation;
     •   Option 2: Biological treatment only for plants using pentachlorophenol;
     •   Option 3: Metals removal for plants with fugitive metals;
     •   Option 4: Zero discharge  only  for plants  using pentachlorophenol or fugitive
                 metals;
     •   Option 5: Zero discharge for plants using pentachlorophenol; and
     •   Option 6: Zero discharge for all indirect dischargers.

     Treatment technology as developed by the technical contractor differed by wood preserving
process; and for indirect dischargers, two treatment subcategories were used:

     •   Boulton Process; and
     •   Steaming Process.
                                         35

-------
     Two levels of treatment technology are applicable to the one direct discharge steaming
plant:

     •  Additional biological treatment with activated carbon adsorption; and
     •  No discharge through spray evaporation.

     The costs of effluent monitoring were generated by the  EPA and not the technical con-
tractor. These costs will add $5,000 to $10,000 per year to operating costs.

D.  COSTS OF COMPLIANCE FOR EXISTING  INDUSTRY
     Tables III-l and III-2 contain the investment and operating costs associated with additional
cost of the options, or levels of control, respectively, for the Boulton and steaming plants. The
land investment has been broken out separately because it permits comparison of the relative
amount  of  land required  for each of these control options. On the basis  of the Technical
Contractor's work and the results of the Financial 308 Survey, a cost of $5000 per acre was taken
for land; thus the number of acres required for each can readily be determined. Land investment
was separated from  other investment in the  economic impact  assessment because land is not a
depreciable asset and, therefore, must be treated separately. As the tables show, the compliance
costs vary considerably from plant to plant, depending upon the volume of water effluent.

     For indirect discharge steaming plants the cost of compliance, in terms of both investment
and monitoring, increases with the stringency of the pollution control requirement. In contrast,
for most Boulton plants, the cost of no discharge can be lower than  the cost of metals removal or
biological treatment. (The obvious exceptions to this are the  two  Boulton plants which would
incur zero cost except under a no-discharge option.)

     Table III-3 shows the total costs of compliance that will be incurred by the direct and
indirect dischargers in the wood preserving industry.  Since  "no discharge"  is generally less
expensive for Boulton plants than heavy metals removal, the six Boulton plants would presum-
ably install the cooling tower evaporation control equipment under Option 3. Table III-3 illus-
trates the total cost of  compliance  assuming that plants will install no discharge control
equipment where biological treatment or metals removal are more expensive.

     The lowest cost alternative for indirect discharges is Option 3, where total investment is $1.7
million and the fewest number of plants (11) are affected. Under Option 6, which represents no
discharge for all indirect dischargers, the cost of compliance is $6.1  million.

     The EPA also considered the use of production cut-off levels  (Table III-4) to trigger
compliance for indirect dischargers. Applying the cutoffs under each alternative produces sub-
stantially lower compliance costs and fewer impacted plants (Table HI-5). Under each alterna-
tive the investment cost, operating costs and number of impacted plants are about half the levels
with no size-cutoff criterion.

E.  COST OF COMPLIANCE FOR NEW SOURCES
     Costs of compliance for new sources were generated by the technical contractor for organic
plants using the Boulton process and organic steaming methods. Under BPT guidelines,  new
wood preserving plants using inorganic processes are required to have zero discharge; therefore,
they were not analyzed.

                                          36

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                                       TABLE 111-3

               TOTAL COST OF COMPLIANCE WOOD PRESERVING INDUSTRY
                         INSTALLING LEAST-COST TECHNOLOGY
                                          ($000's)
 Indirect Dischargers

 Option 1
   Steaming
   Boulton
 Option 2
   Steaming
   Boulton
Option 3
   Steaming
   Boulton


Option 4
   Steaming
   Boulton


Option 5
   Steaming
   Boulton
Option 6
   Steaming
   Boulton
Direct Dischargers
   Biological Treatment
   with Carbon Adsorption
   Discharge/Spray
   Evaporation
No. of
Plants
                                                     Investment
Total
Land
   Other
Investments
               69.0
              177.0
                    69.0
                    177.0
 Annual
Operating
  Cost
19
6
25
8
6
14
25
7
32
21
6
27
31
11
42
1,828.0
773.5
2,601.5
957.2
575.6
1,532.8
4,006.2
810.2
4,816.4
3,231.9
626.1
3,858.0
5,006.5
1,274.2
6,280.7
26.0
5.0
31.0
1.0
1.3
2.3
76.2
3.2
79.4
55.8
2.0
57.8
101.2
3.2
104.4
1 ,802.0
768.5
2,570.5
955.4
574.3
1,529.7
3,930.0
807.0
4,737.0
3,176.1
624.1
3,800.2
4,930.3
1,271.0
6,201.3
441.7
196.8
638.5
179.3
196.8
376.1
451.0
207.3
658.3
365.7
164.2
529.9
546.4
405.8
952.2
Source:  Data supplied by EPA and Environmental Science and Engineering, Inc., revised by
        Arthur D. Little, Inc., to reflect land cost of $5000 an acre.
                            23.0

                            15.0
                                           39

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                             TABLE 111-4

         WOOD PRESERVING INDUSTRY PRODUCTION SIZE CUTOFFS
                       INDIRECT DISCHARGERS
                               STEAMING
Alternative

Option 1
Option 2
Option 3
Option 4
Option 5
Option 6
Plants Impacted
Without Cutoff
0
19
8
25
21
31
Cutoff
(000 Cu. Ft.)
Not Applicable
900
1,200
1,200
1,200
1,200
Plants Impacted
With Cutoff
0
13
2
12
12
15
                               BOULTON
Option 1
Option 2
Option 3
Option 4
Option 5
Option 6
0
6
6
7
6
11
Not Applicable
700
700
1,100
1,100
1,100
0
5
5
3
2
6
                                 40

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                                     TABLE 111-5

             TOTAL COST OF COMPLIANCE WOOD PRESERVING INDUSTRY
                        INSTALLING LEAST-COST TECHNOLOGY
                                 (WITH SIZE CUTOFF)
                                        ($000-5)
                                                 Investment
Indirect Dischargers

Option 1
   Steaming
   Boulton
Option 2
   Steaming
   Boulton


Option 3
   Steaming
   Boulton


Option 4
   Steaming
   Boulton


Option 5
   Steaming
   Boulton


Option 6
   Steaming
   Boulton
Direct Dischargers
   Biological Treatment
   with Carbon Adsorption
   No Discharge/Spray
   Evaporation
No. of
Plants
Total
Land
   Other
Investments
  Annual
Operating
   Cost
13
5
18
2
5
7
12
3
15
12
2
14
15
6
21
1,324.1
636.5
1,960.6
214.9
636.5
851.4
1,836.3
484.6
2,320.9
1,836.3
300.5
2,136.8
2,268.1
879.8
3,147.9
19.3
3.8
23.1
1.1
3.8
4.9
26.7
2.5
29.2
26.7
1.2
27.9
35.7
2.5
38.2
1,304.8
632.7
1,937.5
213.8
632.7
846.5
1,809.6
482.2
2,291.8
1,809.6
299.3
2.108.9
2,232.4
877.3
3,109.7
318.9
164.4
483.3
45.7
164.4
210.1
205.3
104.4
309.7
205.3
61.3
266.6
260.8
274.8
535.6
1 69.0
1 177.0
69.0
177.0
23.0
15.0
Source: Data supplied by Environmental Science and Engineering, Inc., revised by Arthur D. Little,
       Inc., to reflect land cost of $5000 an acre.
                                        41

-------
     The treatment technology for new Boulton plants consists of:(8)

     •  Primary gravity oil-water separation;
     •  Flocculation followed by rapid sand filtration; and
     •  Evaporation in cooling tower, with provisions for additional heat input through a
        heat exchanger.

     The treatment technology for a new steaming plant consists of:

     •  Primary gravity oil-water separation;
     •  Flocculation followed by rapid sand filtration; and
     •  Containment and spray evaporation.

     Cost-of-compliance estimates were based upon the plant types and sizes shown in Table
III-6. Two sizes of Boulton plant are shown (one with two 130' x 7' cylinders, and one with five
cylinders), each treating Douglas fir poles, which require a long residence time in a retort. Costs
were also developed for two sizes of organic steaming plants treating southern pine poles. Boulton
plants treating southern oak railroad ties would have production rate and wastewater flows
similar to those for the organic steaming plants,  but the treatment technology shown for the
Boulton plant.
                                       TABLE  111-6

               MODEL PLANTS FOR NEW SOURCE PERFORMANCE STANDARDS

                                      Design Production                 ...
                                  	             Wastewater
                                  Cubic Feet/       Product                Flow
       Plant Type                      Day            Type              (Gal./Day)

       Boulton Process
         Plant A                     3,200         Douglas Fir               4,000
                                                    Poles
         PlantB                     8,000             "                  10,000

       Organic Steaming Plants
         Plant C                     6,000        Southern Pine              2,500
                                                    Poles
         Plant D                    15,000             "                   7,000
       Source: Environmental Science and Engineering, Inc.

     The cost of compliance with the new source treatment technology is shown in Table III-7 for
each model plant. The compliance investment and operating costs reflect only one half of the cost
of primary oil-water separation; the remainder has been included in the new plant baseline data
described in Chapter II and included in Chapter IV. The total cost of primary oil-water separation
is also shown in Table ID-?; these costs differ by size of plant but not by treatment method.
                                           42

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                                 TABLE 111-7

                           COST OF COMPLIANCE
                      NEW WOOD PRESERVING PLANTS

Model Plant Type
Boulton Plant A1
Boulton Plant B1
Organic Plant C1
Organic Plant D1
Total
Investment
$161,030
223.310
267,640
427,500
Operating
Cost
$66,260
99,260
73,640
105,300
Acres of Land
Required
0.50
0.75
0.90
1.95
Total Requirement
Primary Oil-Water
Separation
2-CyUnder Plant
5-CyMnder Plant
 80,000
113,500
8,000
9,500
1.  Half the investment and operating cost of primary oil/water separation has been excluded.

Source:  Environmental Science and Engineering, Inc., letter dated August 11,1978, adjusted
        to reflect land cost of $5000 an acre.
                                     43

-------
           IV.  ECONOMIC IMPACT ASSESSMENT

    This chapter discusses the results  of the economic impact  assessment of the costs of
complying with the BAT options studied. It also contains a description of plants that will be
required to install or modify equipment (thus incurring higher costs of operation) to comply with
the studied  control options, and compares these plants with those that currently have self-
contained or no discharge.

A.  ECONOMIC CHARACTERISTICS OF IMPACTED PLANTS
    As described in Chapter III, only 10% of the plants in the wood preserving industry will be
impacted by the BAT alternatives studied because the remaining 90% of the industry is currently
not discharging a liquid waste into navigable water or into a municipal system. The impacted
plants were compared with the balance of the industry  in several areas important to determining
the impact of the alternatives on the industry:

       Sales
       Process
       Profitability
       Product Mix
       Location

    With the exception of plant sales, size, and location, impacted plants are not significantly
different from non-impacted plants. In general, plants impacted by BAT requirements are larger
than non-impacted plants.

    Most of the impacted plants (75%) are in urban areas while most of the no discharge plants
(77%)  are in suburban or rural areas (Table IV-1). The impacted plants located in urban  areas
cited a lack of available adjacent  land for an effluent treatment system (17 of 40 impacted
respondents). Hence, land  availability does not appear to be a problem  in suburban or rural
locations.

B.  ECONOMIC IMPACT ON EXISTING INDUSTRY
    The economic impacts of the compliance costs for each studied alternative were analyzed
with respect to:

    • Price
    • Demand reduction/shifts
    • Financial effects
    • Plant closures and market structure

    The sensitivity of these economic impacts to the assumptions that were made is discussed in
Chapter V, Limitations of Analysis.

1.  Price Impacts
    The potential long-run price  impacts resulting  from the control alternatives that were
studied were addressed by estimating the "long-run price increases" — i.e., those necessary to
                                       45

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recover  all costs associated with  a control option, including a normal rate-of-return on in-
vestment, associated with the costs for each control alternative. The rate-of-return on investment
that was used was the average value for the plants responding to the rate-of-return criteria
question posed in the EPA Financial 308 Letter. (See Chapter II.)

     An estimate was made  of the revenue  required  for plants to recover  the  total cost of
compliance (Figure IV-1). Since the costs of compliance were developed by plant, the required
revenue for each option is shown as a percentage of sales by sales level. The relative increase in
revenue required to recover compliance costs varies with size of plant.

     The  revenue required to recover  compliance costs can be viewed as the average  price
increase across all products required by a plant in a given sales category. Obviously, small plants
have  a  higher  revenue  requirement because compliance  costs for  a  given option are dis-
proportionately higher for small plants than for large plants.

     Because only 10% of the plants in the industry will be impacted by the regulation, the price
increases expected from the regulation are likely to range from 0% to the same percentage as that
for the larger plants. The wood preserving industry is competitive and while the industry demand
curve for most preserved wood products is relatively inelastic, the demand  curve facing individual
firms is quite elastic. However, the following factors and circumstances may enable these plants
to obtain price increases to recover cost:

     •  The impacted plants are generally larger than the industry average;
     •  They may be in isolated geographic markets;
     •  The general price level inflation in the U.S. (6-8% per year) may facilitate at least
        partial  cost recovery.

     During the 1970's, the prices of preserved wood products have outpaced general  price
inflation. Given  "customary," inflation-related price increases of 6-8%, impacted wood preservers
may be able to  recover an additional 1-2% of increased cost associated  with pollution control.
Also, larger plants are often associated with multi-plant companies which have some market
power and may be able to obtain a price increase to recover a portion of the cost of compliance.*
Finally, plants in locations  where there are few or no competing firms may be able to raise prices,
limited  primarily by the  cost of transporting  products from  the nearest plant that is  not
impacted.

     Note that  the analysis of plant closures viewed each plant as  a  stand-alone operation,
unable to recover the cost of compliance through price increases.

2.  Production Shifts
     Growth rates in the demand for preserved wood products will affect the ability of impacted
plants to obtain  price increases. Plants predominantly producing poles will be unlikely to obtain
higher prices for this product in the face of a declining industry demand. Shifting from poles to
other products may enable a  plant to produce a product with higher added value to maintain
current  production levels. However, tight capacity is not forseen for any preserved wood product
and thus the ability of impacted plants to increase real prices will be inhibited.
  Although there are occasions when multi-plant companies do not have market power at a specific location,
  economic theory and actual experience indicate that such market power generally exists.

                                           47

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     While the selection of preserved wood versus steel or concrete materials is predominantly
based upon structural requirements, for railroad ties this situation could change. If concrete ties
prove to be technically  feasible — and economically producible — a portion of the market
expansion forecast for ties could be captured by concrete substitutes, especially if the life-cycle
costs become more competitive. While this may not be a factor until the mid-1980's, that would
coincide with the deadline for BAT compliance and would further prevent the impacted plants
from recovering costs of compliance through price increases.

3.  Financial Impact
     It  is unlikely  that  the  impacted plants  as a group  will be able  to recover the costs of
complying with  BAT regulations through higher prices. If they elect  to install the pollution
control  equipment, profitability is likely to decline. Table IV-2 shows the impact of increased
operating costs and investment upon profitability in the absence of price increases. The analysis
considered the impact on operating costs due to out-of-pocket expenditures; i.e., while potential
interest payments on debt are included as a cost, the total cost of capital is not included in the
figures. Also, the lowest-cost means of achieving compliance was used i.e., if Option 4 is less
expensive than Option 3  for a plant, it is assumed the plant will install Option 4.

                                         TABLE IV-2

                     INDIRECT DISCHARGER WOOD PRESERVING PLANTS
           PERCENTAGE DECLINE IN PROFITABILITY* AFTER COMPLIANCE WITHOUT
                                     PRICE INCREASES
                  Plant Sales ($000):    200
           700      1800       3500
         Percent Decline in Profitability*
      Option 2
         Steaming
         Boulton
      Option 3
         Steaming
         Boulton
      Option 4
         Steaming
         Boulton
      Option 5
         Steaming
         Boulton
      Option 6
         Steaming
         Boulton
260
260
260
260
20-86     8-155
  347

   79         6
  400

21-100    8-174
   400
21-87
   400

21-87
   400
                    8-174
8-174
   89
 6-46
16-42

36-113
16-45

 6-208
16-45

 3-208
16-45

 3-208
16-45
                              7500
 2-45
13-68

    4
13-68

 3-50
13-68

 3-50
13-68

 3-50
13-68
      *Change in Profit/Precompliance Profit: the absolute value of the changes in profit divided by
       precompliance profit. A value greater than 100% means plant is operating at a loss.

      Source: Arthur D. Little, Inc., estimates.
     Because the costs of compliance for small plants are relatively higher, small firms will suffer
the greatest decline in profitability as a result of compliance. The small plants with lowest sales
volume would be in a negative profit situation under all of the control options studied. Plants in
the other sales categories would suffer a decline in profitability and most impacted plants would
still be profitable under each alternative.
                                          49

-------
     Any price increases the impacted plants are able to obtain would mitigate the reduction in
profitability for small and medium-sized plants. However, as discussed above, price increases
that do occur (barring a tight market) will reflect the cost structure of the larger plants. Even with
price increases, many plants with less than $1.8 million in sales are likely to become unprofitable
if they make the compliance expenditures.

     Reduction in profitability is not the only financial impact of the regulation. If one were to
assume that all impacted  plants could recover the  pollution control expenditures through price
increases,  it is still likely that a number of impacted plants would  be unable to finance the
required investment.

     For small plants with sales under $1 million, the investment required for all options studied
exceeds annual plant cash flow for all but one plant  (Figure IV-2). Even for larger plants, the
studied alternatives often require investment exceeding a single year's cash flow. Considering the
fact that a portion of  the plant's cash flow must be used for expenditures other than those
associated with BAT regulations, impacted plants  will not generate sufficient cash flow to self-
finance compliance with these regulations. The impacted plants generate an annual cash flow
equivalent to approximately 4% of sales.* About 3% of sales is reinvested to maintain industry
assets leaving about 1% of sales for dividends, retained earnings, and other purposes. To  have
available the equivalent of one year's cash to invest in pollution control, wood preservers would be
required to accumulate four years'  cash flow in excess  of maintenance investment requirements.
Therefore, if BAT regulations are required in 1984, any plant with a pollution control investment
requirement in excess of one year's cash flow will probably  have  to obtain external financing
between 1979 and 1983 to fund pollution control expenditures.

     Assuming that a  plant is viable — i.e., prices will eventually increase to cover the  BAT
investment expenditures  — a plant will have to seek financing from a parent company or the
financial community. However, the wood  preserving industry is dominated by  privately held
corporations, and only 22% of all plants are publicly held  (Table IV-3). Inasmuch as many of the
privately held corporations and proprietorships are one-plant corporations, effectively the plant
and corporate cash flows are one and the same. Also, the ownership pattern of the plants that will
be impacted by BAT regulations is only slightly more favorable than that of the industry overall,
with  22  (55%)  of the discharging plants  organized   as  proprietorships  or privately  held
corporations.

     More likely, the privately  held corporations will require external financing to a greater
extent than the publicly  held corporations. In either case, the financial community or parent
corporations  is less likely  to be willing to make investments in financially nonviable plants. On
the basis of the financial criteria, only  the larger  impacted plants would be able to make the
investment required to satisfy BAT requirements.

4.  Plant Closures
     The impacted wood  preserving plants (especially the small ones) will be unable fully to
recover costs through price increases. Further, a number of plants  will have cash flow shortfalls
relative to pollution control investment requirements. Thus plant shutdowns in the wood pre-
serving industry are likely to occur.
 * Based upon responses to the EPA Financial 308 Letter. See Chapter II.


                                           50

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                              51

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                                        TABLE IV-3

                 FORM OF BUSINESS ORGANIZATION BY DISCHARGE STATUS


                                Discharging Plants        Zero Discharge*           Total Plants
Form of Business Organization       Number    Percent      Number    Percent      Number   Percent

                               \    1         2      1    31        11      }    32         9
Co-op                          '                     J                     '
Privately Held Corporation            21        53         209        71          230        69
Publicly Held Corporation             1£        45           54        18           72        22
  Total**                         40       100         294       100          334       100

 *Plants currently at, or currently required to be at, zero discharge.
**Total respondents to question.

      The  evaluation of whether a plant would shut down rather than  .make the investment
 required to  comply with pollution control regulations is  imprecise. First, the evaluation is
 external to the corporate environment and based on no knowledge or consideration of corporate
 goals and objectives. Second, the evaluation is based on financial criteria  and, while they are in
 turn based upon industry data and a distribution of wood preserving plant  rate-of-return criteria,
 they may not reflect the actual parameters that would be used in the individual decision-making
 process, especially since few plants provided information on financial decision criteria.

      With those caveats in mind, the analysis indicates a number of closure candidates (Table
 IV-4), based on by the following characteristics:

      •  Low Sales,
      •  Low Profitability, and/or
      •  Negative Cash Flow.

      The  profitability and  cash  flow  of each  discharging plant was  derived from the EPA
 Financial 308 Letter.  The change in operating cost and relationship of investment required to
 cash flow was examined under each control option. The plants were assumed to install the least
 costly treatment technology that would achieve compliance; for example, Option 6 (no discharge)
 costs were used if less costly than Options 2 or 3.

      If  a plant could  finance the pollution  control investment from cash flow and maintain a
 positive profit margin  in the absence of price increases, then the plant was judged likely to remain
 open. A plant was designated as a high probability of closure where required investment was on
 the order of 200% of annual cash flow and/or post-compliance profit margins would be negative.
 Plants judged to have  a moderate probability of closure were those for which investment would be
 100% to 200% of annual cash flow but which would still have a positive profit after tax.

      Since compliance costs are disproportionately high for smaller plants, plants with low sales
 volumes are more highly impacted. Under the control options studied, up to 8 plants with sales
                                             52

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                                       TABLE IV-4

                WOOD PRESERVING INDUSTRY POTENTIAL PLANT CLOSURES
                               UNDER BAT ALTERNATIVES
                             Without Size Cutoff
                                          With Size Cutoff
 Alternative

 Option 2
    Steaming-lndirect
    Boulton-lndirect
      Total

 Option 3
    Steaming-lndirect
    Boulton-lndirect
      Total

 Option 4
    Steaming-lndirect
    Boulton-lndirect
      Total

 Option 5
    Steaming-lndirect
    Boulton-lndirect
      Total

 Option 6
    Steaming-lndirect
    Boulton-lndirect
      Total
   High       Moderate
Probability   Probability   Total
                                     High
                                  Probability
                                  Moderate
                                  Probability
                                    Total
             3
             ^
             5
 2
J_
 3
 6
J_
 7
 2
J_
 3
 8
J_
 9
5

7


5

7
 6
_2
 8
            3
           _2_
            5
           4
           _3
           7
           11
           _3
           14
           7
           3
          10
14
_3^
17
                                                    2

                                                   ~2


                                                    2

                                                    2


                                                    2

                                                   ~2
                                      2

                                      2
                                                3

                                                3
 Source: Arthur D. Little, Inc., estimates.
under $3.5 million would be unlikely to make the investment in control equipment for financial
reasons — i.e., the plant is likely to incur operating losses as a result of compliance costs or be
unable to finance the investment. Under Option 2, three steaming plants and two Boulton plants
could close (Table IV-4). The number of potential closures increases with the  stringency and
scope of the regulatory alternative and under Option 6 up to 14 steaming plants and 3 Boulton
plants face closure. If the EPA were to apply a size cutoff, the number of potential closures falls
off radically, with plant closures foreseen only under Options 4,  5, and 6.

5.  Employment Effects
     The potential employment  losses attributable to plants with a high probability of closure
increases under each of the options and  reaches a maximum of 3.5% of the industry production
workers under Option 6 (Table IV-5). The employment losses associated with moderate probabil-
ity plant closure are about the same under Options  4 and 5 at about 4% of the workforce.
                                           53

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 Alternative

 Option 2
    Steaming-lndirect
    Boulton-lndirect
      Total
      % Employees*
 Option 3
    Steaming-lndirect
    Boulton-lndirect
      Total
      % Employees*
 Option 4
    Steaming-lndirect
    Boulton-lndirect
      Total
      % Employees*
 Option 5
    Steaming Indirect
    Boulton-lndirect
      Total
      % Employees*
 Option 6
    Steaming-lndirect
    Boulton-lndirect
      Total
      % Employees*
                                      TABLE IV-5

                             WOOD PRESERVING INDUSTRY
                      EMPLOYMENT LOSSES FROM PLANT CLOSURES
                             Without Size Cutoff
                                            With Size Cutoff
   High
Probability
Moderate
Probability
              130
               41
              171
                2.2%
 Total
            130
            Jl
            171
              2.2%
   High
Probability
Moderate
Probability
Total
77
15
92
1.2%
54
41
95
1.2%
131
56
187
2.4%
  199
   15
  214
    2.£
 280
   41
 321
   4.2%
470
 56
535
  5.7%
103
15
118
1.5%
280
41
321
4.2%
383
56
439
5.7%
              199

              ?99~
                2.6%

              199
            199

            199
              2.6%

            199
  253
   15
  268
    3.5%
 295
   41
 336
   4.4%
548
 56
604
  7.8%
  27

  27
   0.3%
  199
    2.6%

  199

  199
    2.6%
199
  2.6%

226

226
  2.9%
 * Based upon 7,700 production workers in 1976, Department of Commerce, Bureau of Census, Annual Survey
  of Manufacturers: General Statistics. Plant production employment data from EPA Financial 308 Letter.

 Source: Arthur D. Little, Inc., estimates.

C.  ECONOMIC IMPACT UPON  NEW SOURCES AND
    CAPACITY EXPANSIONS
1.  Potential for New Plants
    The wood treating industry is not capital intensive compared with the average manufac-
turing industry; the sales turnover ratios for plants in 1976 was found to range from 3.0 to 10.0 or
more,* whereas the ratio of sales to assets for most process industries is on the order of 1.0 to 2.5.**
There is considerable excess capacity  among existing plants, based upon maximum operating
capacities, but transportation and other factors make it likely that new capacity will be built in
growing regions (e.g., the South) before excess capacity is fully utilized in others.
 * Financial 308 Letter.
** Based on data from FTC-SEC, Quarterly Financial Reports.
                                          54

-------
     Although most new capacity may take the form of incremental expansion (e.g., the addition
of a new retort at an existing site), some 17% (or 56 of 337) of the respondents to the Financial 308
Letter indicated that their wood treating plants have begun operation since 1970.

2. Impact Upon New Plants
     A number of new wood preserving plant models were developed to evaluate the impact of
new source performance standards. (See Chapter II.) Process economic models were developed for
four different plant types:

     •  Boulton plants treating Douglas fir poles in the Northwest;
     •  Organic steaming plants treating Southern Pine poles;
     •  Boulton plants treating oak railroad ties in the South; and
     •  Inorganic plants treating Southern Pine lumber.

     Two plant sizes were created for each type: one with two cylinders and one with five (See
Chapter II). As mentioned in Chapter III, existing standards for new inorganic plants will have no
incremental costs of compliance from BAT revisions. Further, costs of compliance for Boulton
plants treating oak railroad ties were not generated by the technical contractor.

     Table IV-6  depicts the  baseline revenues on each model plant as well as the incremental
revenue required to recover costs of compliance (where available). The model plants are larger
than the average existing plant, with production  and revenue levels  at the upper end of the
spectrum. The revenue required to recover costs for compliance in the long run is similar to that
for existing plants for  Option 6, the no discharge option, in the higher  sales categories shown in
Figure IV-1.  The cost of pollution control equipment per se would not appear to hinder the
addition of new capacity.

     If the existing industry BAT requirements are defined as additional biological treatment or
current pre-treatment standards, then  incremental expansion may be favored as a  means of
capacity  expansion, especially given the incremental land requirements of a no-discharge new
source standard.
                                          55

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                                       TABLE IV-6
                IMPACT OF BAT REQUIREMENTS UPON LONG-RUN REVENUE
                          REQUIRED TO SUPPORT NEW SOURCES
Case   Plant Type/Product
 A    Boulton/Douglas Fir Poles
 B    Boulton/Douglas Fir Poles
 C    Steaming/Southern Pine Poles
 D    Steaming/Southern Pine Poles
 E    Boulton/Oak R.R.Ties
 F    Boulton/Oak R.R.Ties
 G    Inorganic/Southern Pine Lumber
 H    Inorganic/Southern Pine Lumber
   Annual
 Production
(000 Cubic ft.!
     720
    1,800
    1,800
    4,500
     960
    2,400
    1,800
    4,500
 Baseline
Revenues
 ($000)
  7,860
 19,300
 11,300
 28,100
  6,500
 16,000
 13,500
 33,300
 Revenue Required for
BAT Compliance Costs
($000)    % Baseline
  154
  226
  198
  298
2
1
2
1
    Not Available
    Not Available
    Not Available
    Not Available
Source: Arthur D. Little, Inc., estimates.
                                          56

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                  V.   LIMITATIONS OF ANALYSIS

     The economic impact of BAT regulations may differ from the analysis in this economic
impact assessment depending upon the following:

     (1) EPA regulations which affect waste disposal;
     (2) Return-on-investment criteria;
     (3) Cost variation from plant to plant;
     (4) Future growth in demand; and/or
     (5) Local conditions of impacted plants.

     Item (1) was beyond the scope of the technical contractor's or the economic contractor's
work. Items (2) through (5) are limitations in every analysis of this type, but their influence on the
results of a study varies from case to case, and thus requires discussion.

A.  EPA REGULATIONS AFFECTING  WASTE DISPOSAL
     Subtitle C of the  Solid Waste Disposal Act, as amended by the Resource Conservation and
Recovery Act of 1976  (RCRA),  creates a regulatory framework to control hazardous wastes.
Section 3004 addresses standards for owners and operators of hazardous waste treatment, storage
and disposal facilities.  The regulation impacts the analysis of alternative control options because
it specifies the technical and monitoring requirements for each disposal  method,  as well as
restrictions on disposal of waste by method. These, in turn, may limit the application of some of
the control options studied, or result in higher costs for an alternative than indicated by the
technical contractor in this report. Further, wood preserving plants which dispose on-site (28%)
may be impacted,  in that the current method of disposal  may no longer  be environmentally
adequate.

     The application of both no-discharge and discharge options studied in this report will be
affected by RCRA regulations. The lagoons associated with enhanced biological treatment and
the impoundment  associated with  spray evaporation will  both  be  considered as methods of
hazardous waste disposal or storage, and thus plants will be required to monitor groundwater and
surface water as well as to install leachate collection and monitoring systems.

     A leachate  collection and monitoring system is not included in the  cost of compliance.
Assuming the two aerated lagoon cells combined, or  an impoundment, are  analogous in size to
small landfills (5,OOOM3/year), then the incremental compliance cost per plant could be as
follows:

                   Initial Investment:             $129,000
                   Annual Operating Costs:       $ 42,200

     Another source of additional cost is monitoring requirements. The cost of  analysis for soil
and water samples  could be on the order of $60,000 per year.

     Consideration of  whether or not the sludge and effluent of wood preserving plants were
hazardous wastes was  beyond the scope of the  technical contractor's report,  although it was
discussed in the draft report. For off-site disposers, the costs of disposal are expected to double or
                                          57

-------
triple as a result of Section 3004. Therefore, that component of the technical contractor's
operating cost (amounting to about 3% of operating costs) will be two to three times as high, but it
will not change the results of the economic impact assessment.

B.  RETURN ON INVESTMENT CRITERIA
     The use of a higher or lower target rate of return than the median value (12%) produces
noticeably higher or lower required revenue to cover cost of compliance (Table V-l). Comparing
the revenue increase requirement for the low and high ROR scenarios for the sampled plants, the
table shows that the change in revenue requirement for a discount rate change from 12% to 5%
ranges from 22%  to  40% for  the sample plants. There is a greater change in the revenue
requirements from a change in the discount rate of 12% to 20%, and it ranges from 33% to 51%.

                                      TABLE V-1

                  CHANGE IN REVENUE REQUIRED BY DISCOUNT RATE

                                             Discount Rate
                        12%                 5%                       20%
       Revenue
       Required
                       $000          $000   % Change           $000   % Change

                          5             3-40                 7     40
                         39            30     -23                52     33
                         75            52     -31               113     51
                         89            59     -22               121     36
                        108            78     -28               156     44
                        173           118     -32               258     49
                        178           130     -27               255     43
                        434           300     -31               643     48

     There is relatively little variation in the revenue requirement as a percent of sales due to
ROR target (Figure V-l). The requirement seems to be higher for both the smallest plants and the
very large plants, but even these plants require additional revenue of less than 10% of sales. The
bulk of the increases in revenue  to maintain target ROR are within the 1-5% range; on the
average, the ROR scenarios differ by 1 percentage point. Therefore, the economic impact assess-
ment is basically insensitive to the return on investment criteria employed.

C.  COST VARIATIONS FROM  PLANT TO PLANT
     Because of plant-specific conditions, the technical contractor indicated that the cost esti-
mates for an  individual plant could  vary between 75% and 150% of the costs for the control
options presented in Chapter III. The cost differences could arise as a result of such factors as
usable treatment in place,  land availability, and/or cost of controls. The cost of compliance is
based upon land cost per acre, which will vary considerably depending upon the plant  location.
Those plants  with  lower costs  will be less  severely impacted by the alternatives studied. In
addition  to the understatement of compliance cost caused by EPA regulations on hazardous
waste, there could  be plant-specific conditions (e.g., terrain) which contribute to higher costs.
Plants with higher costs will be more severely impacted by the regulation.
                                          58

-------
10
<53
a?
re
rement
01
'5
cr
to
i
0)
0)
CC.
D D ROR = 20%
0 ROR = 12%
0 AROR= 5% D
A
— DO
Q 0
D DA
A 0 °8 A
A ^
I 1 1 1 I I 1 1
            1000     2000     3000     4000     5000     6000
                                       Sales Volume ($ 000)
7000
8000
                   FIGURE V-1     REVENUE REQUIREMENT AS A PERCENTAGE
                                   OF SALES BY ROR FOR SAMPLE PLANTS

D.  FUTURE GROWTH IN DEMAND
     If the forecast growth for railroad ties and timbers does not materialize or if the rate of
decline in poles is greater than forecast, the number of potential closure candidates will increase.
If, on the other hand, demand growth is greater by virtue of a strong housing market growth and
accelerated repair of railroads, then the number of plant closures will be fewer than indicated
because the supply/demand balance is such that high-cost plants (including plants impacted by
the regulation) determine price and therefore can recover costs of pollution control investment.

E.  LOCAL CONDITIONS OF IMPACTED PLANTS
     The analysis of plant closures  is subject to the limitations of any plant closure analysis
(Chapter IV). In addition, local market conditions of some impacted plants will determine to a
significant extent whether a plant will shut down rather than comply  with a regulation. For
example, if an impacted plant were in a market area where there were virtually no competing
firms, it might be able to increase its price and recover the cost of installing control equipment,
limited by the cost of transportation  of the closest competing firm. This would also be the case if
all the plants in an area were required to make equivalent expenditures to comply with pollution
control requirements. Local conditions could produce a worse impact than described in Chapter
IV if, for example, most of the firms in the area are not impacted, in which case the impacted
plant would have very little chance of recovering the costs of pollution control.
                                         59

-------
                              REFERENCES

1. Annual Survey of Manufactures, U.S. Department of Commerce, various years.

2. Trend Impact Analysis Study of the  Wood Preserving Market, Dow Marketing Research
  Reports, February 1976.

3. Ibid, p. 21-22.

4. Ibid, p. 36.

5. Personal communications with members of the AWPA.

6. Revised Technical Review of Best Available Technology, Best Demonstrated Technology and
  Pretreatment Technology for the Timber Products Point Source Category, report to the Envi-
  ronmental Protection Agency by  Environmental Science & Engineering, Project No. 78-052,
  September 1, 1978.

7. Integrated Economic Impact Assessment of Hazardous Waste Management Regulation (Regu-
  latory Analysis Supplement), Preliminary Draft Report prepared for the Office of Solid Waste
  Programs, U.S. Environmental Protection Agency, October 1978.

8. Census of Manufactures, U.S. Department of Commerce, 1972.
                                       61

-------
                              BIBLIOGRAPHY

The Analysis of Existing Wood Preserving Techniques and Possible Substitutes, Contract No. 68-
01-4310, by The MITRE Corporation, for the U.S. Environmental Protection Agency, June 1977.

Annual Survey of Manufactures, Bureau of the Census, U.S. Department of Commerce, various
years.

Cen.su.s- of Manufactures, Bureau of the Census, U.S. Department of Commerce, 1967 and 1972.

Chemical Marketing Reporter, Schnell Publishing Co., Inc., New York, various issues.

Economic Indicators, Council of Economic Advisors,

Engineering News Record, McGraw Hill, Inc., New York, various issues.

Employment  and Earnings, Bureau  of Labor Statistics, U.S. Department  ui  Labor, various
issues.

Integrated Economic Impact Assessment of Hazardous  Waste Management Regulations, Prelim-
inary Draft Report for the Office of Solid Waste, U.S. Environmental Protection Agency, October
1978.

Quarterly Financial Reports, Federal Trade Commission, Securities and Exchange Commission,
various issues.

Revised Technical Review of Best Available Technology, Best Demonstrated Technology and
Pretreatment Technology for the Timber Products  Point Source Category, report to  the U.S.
Environmental Protection Agency, by Environmental Science & Engineering, Project No. 78-052,
September 1,  1978.

Trend Impact Analysis Study of the Wood Preserving Market, J. L. Natonski, February 1976.

Wholesale Prices and Price Indexes, Bureau of Labor Statistics, various issues.

Wood Preserving Statistics, Ernst & Ernst, 1976.
                                         63

-------
       APPENDIX A



INDUSTRY CHARACTERIZATION
           65

-------
                                APPENDIX A
                 INDUSTRY CHARACTERIZATION
1. PRODUCT DIVERSIFICATION
     It is primarily the largest companies in the industry which produce a wide range of products.
Most firms in the industry operate only one plant. In these cases, the plant produces organically
treated products or inorganically treated products, although some single plant firms produce
both. Furthermore, smaller firms tend to specialize on particular preserved wood products. For
example, a  firm may produce only preserved railroad ties or posts  or pilings or dimensional
lumber.  For many of the smaller firms, wood preserving is a service offered by a company in the
lumber and wood products business.

2. IMPORTS AND EXPORTS
     Import and export statistics do not distinguish preserved wood products from other wood
products. However, piling, utility poles, and railway crossties are likely to be preserved when
imported or exported. In recent years, imports, primarily from Canada, have been in the range of
$10 million to $15 million per year (Table A-l). Exports, primarily to wood-poor regions such as
the Middle East and Japan, have totaled $20 million to $35 million in recent years (Table A-2).
About lO'.V to 15' r of the U.S. production of utility poles is exported. With this exception, imports
and exports do not constitute a sizeable portion of any other preserved wood markets.
                                      TABLE A-1

                U.S. IMPORTS OF PRESERVED WOOD PRODUCTS1,1970-1977
                 Timber, Poles, Piling, Posts, and
                    Other Wood in the Rough
                           Value2
      Year                  ($000)

      1970                   7,733
      1971                   8,633
      1972                   9,369
      1973                   8,654
      1974                  15,069
      1975                   9,868
      1976                  10,615
      1977                  10,011
Railroad
Quantity
(MBF)
8,418
3,363
7,924
11,308
13,916
12,475
8,164
7,367
Ties
Value2
($000)
717
385
757
1,505
2,566
2,625
2,314
1,370
 Total
Value2
 ($000)

 8,450
 9,018
10,126
10,159
17,635
12,493
12,929
11,381
      1. U.S. import statistics do not distinguish preserved wood products from other wood products,
        but the products shown are predominantly preserved wood products.
      2. Values shown are f.a.s. (free alongside ship) values.
     Source: U.S. Department of Commerce, Bureau of the Census, U.S. Imports — Schedule A,
            Commodity by Country, FT 135.
                                      67

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        APPENDIX B




PRO-FORMA NEW SOURCE MODELS
             69

-------
                                           TABLE B-1

                                           PLANT A-1
         ESTIMATED OPERATING COSTS FOR THE MANUFACTURE OF PRESERVED WOOD
                                     ORGANIC TREATMENT

               Cylinder Size: 2 cylinders, each 7' diameter x 130' long, 5000 cubic feet
               Capital Cost:  $3,300,000 (1978)
               Location:     South Central
               Production:   2000 cubic feet per charge; 30 hours per charge (Boultonizing)
                            3 shifts per day, 300 days per year
               Product:      960,000 cubic feet per year of Railroad Ties
Item
Raw Materials:
Wood
Creosote
Units
Cubic feet
Gallons
Unit Cost
($)
2.15
0.70
Units Per
Cubic Foot
1.0
1.0
Dollars Per
Cubic Foot
2.15
0.70
Thousand
Dollars
Per Year
2,064
672
Total Raw Materials

Processing:
   Labor, Operating
   Labor, Maintenance
   Maintenance Supplies
   Consumable Supplies
   Fuel and Power
   Plant Overhead
   Taxes and Insurance
Total Processing
Total Cost, F.O.B. Plant
Man hours
Man hours
50% of Labor
4% of Capital
6.00
6.50
                                             2.85
                                          2,736
0.324
0.090
0.090
0.046
0.135
0.207
0.137
1.329
311
86
86
46
132
199
132
992
                                             4.179
                                          3,728
Source:  Arthur D. Little, Inc., estimates based on industry interviews.
                                              71

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                                           TABLE B-2

                                           PLANT A-2
         ESTIMATED OPERATING COSTS FOR THE MANUFACTURE OF PRESERVED WOOD
                                     ORGANIC TREATMENT
               Cylinder Size: 5 cylinders, each 7' diameter x 130' long, 5000 cubic feet
               Capital Cost:  $6,509,000 (1978)
               Location:     South Central
               Production:   2000 cubic feet per charge; 30 hours per charge (Boultonizing)
                            3 shifts per day, 300 days per year
               Product:      2,400,000 cubic feet per year of Railroad Ties
Item
Raw Materials:
  Wood
  Creosote
Total Raw Materials
Processing:
  Labor, Operating
  Labor, Maintenance
  Maintenance Supplies
  Consumable Supplies
  Fuel and Power
  Plant Overhead
  Taxes and Insurance
Total Processing
Total Cost, F.O.B. Plant
   Units
Cubic feet
Gallons
Man hours
Man hours
50% of Labor
4% of Capital
Unit Cost Units Per
($) Cubic Foot
2.15 1.0
0.70 1.0
6.00 0.012
6.50 0.003





Dollars Per
Cubic Foot
2.15
0.70
2.85
0.250
0.076
0.090
0.046
0.135
0.163
0.108
0.869
3.719
Thousand
Dollars
Per Year
5,160
1,680
6,840
600
182
216
110
326
391
260
2,085
8,925
Source:  Arthur D. Little, Inc., estimates based on industry interviews.
                                               72

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                                           TABLE B-3

                                           PLANT B-1
         ESTIMATED OPERATING COSTS FOR THE MANUFACTURE OF PRESERVED WOOD
                                     ORGANIC TREATMENT
               Cylinder Size: 2 cylinders, each 7' diameter x 130' long, BOX cubic feet
               Capital Cost:  $3,300,000 (1978)
               Location:     South Central
               Production:   2000 cubic feet per charge; 16 hours per charge (Steaming)
                            3 shifts per day, 300 days per year
               Product:      1,800,000 cubic feet per year of Southern pine poles
Item

Raw Materials:
   Wood
   Pentach loropheno I
Total Raw Materials
Processing:
   Labor, Operating
   Labor, Maintenance
   Maintenance Supplies
   Consumable Supplies
   Fuel and Power
   Plant Overhead
   Taxes and Insurance
Total Processing
Total Cost, F.O.B. Plant
   Units
Cubic feet
Pounds
Man hours
Man hours
50% of Labor
4% of Capital
Unit Cost Units Per
($) Cubic Foot
3.00 1.0
0.42 0.5
6.00
6.50





Dollars Per
Cubic Foot
3.00
0.21
3.21
0.173
0.048
0.048
0.024
0.072
0.111
0.073
0.549
3.759
Thousand
Dollars
Per Year
5,400
378
5,778
311
86
86
46
132
199
132
992
6,770
Source:  Arthur D. Little, Inc., estimates based on industry interviews.
                                              73

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                                           TABLE B-4

                                           PLANT B-2
         ESTIMATED OPERATING COSTS FOR THE MANUFACTURE OF PRESERVED WOOD
                                     ORGANIC TREATMENT

               Cylinder Size: 5 cylinders, each 7' diameter x 130' long, 5000 cubic feet
               Capital Cost:  $6,509,000 (1978)
               Location:     South Central
               Production:   2000 cubic feet per charge; 16 hours per charge (Steaming)
                            3 shifts per day, 300 days per year
               Product:      4,500,000 cubic feet per year of Southern pine poles
Item

Raw Materials:
   Wood
   Pentachlorophenol
Total Raw Materials

Processing:
   Labor, Operating
   Labor, Maintenance
   Maintenance Supplies
   Consumable Supplies
   Fuel and Power
   Plant Overhead
   Taxes and Insurance
Total Processing
Total Cost, F.O.B. Plant
   Units
Cubic feet
Pounds
Man hours
Man hours
Unit Cost
   <$)
   3.00
   0.42
50% of Labor
4% of Capital
 Units Per
Cubic Foot
    1.0
    0.5
   6.00
   6.50
Dollars Per
Cubic Foot
   3.00
   0.21
                  3.21


                  0.133
                  0.040
                  0.048
                  0.024
                  0.072
                  0.087
                  0.058
                  0.463
                  3.673
Thousand
  Dollars
 Per Year
                 14,445


                    600
                    182
                    216
                    110
                    326
                    391
                    260
                  2,085
                 16,530
Source:  Arthur D. Little, Inc., estimates based on industry interviews.
                                               74

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                                           TABLE B-5

                                           PLANT C-1
         ESTIMATED OPERATING COSTS FOR THE MANUFACTURE OF PRESERVED WOOD
                                     ORGANIC TREATMENT

               Cylinder Size: 2 cylinders, each 7' diameter x 130' long, 5000 cubic feet
               Capital Cost:  $3,630,000 (1978)
               Location:     West Coast
               Production:   2000 cubic feet per charge; 40 hours per charge (Boultonized)
                            3 shifts per day, 300 days per year
               Product:      720,000 cubic feet per year of Douglas fir  poles
Item

Raw Materials:
   Wood
   Pentachlorophenol
Total Raw Materials

Processing:
   Labor, Operating
   Labor, Maintenance
   Maintenance Supplies
   Consumable Supplies
   Fuel and Power
   Plant Overhead
   Taxes and Insurance
Total Processing
Total Cost, F.O.B. Plant
   Units
Cubic feet
Pounds
Man hours
Man hours
50% of Labor
4% of Capital
Unit Cost Units Per
($) Cubic Foot
3.40 1.0
0.42 0.75

6.00
6.50






Dollars Per
Cubic Foot
3.40
0.32
3.72
0.432
0.119
0.119
0.064
0.183
0.276
0.201
1.396
5.116
Thousand
Dollars
Per Year
2,448
230
2,678
311
86
86
46
132
199
145
1,005
3,683
Source:  Arthur D. Little, Inc., estimates based on industry interviews.
                                              75

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                                           TABLE B-6

                                           PLANT C-2
         ESTIMATED OPERATING COSTS FOR THE MANUFACTURE OF PRESERVED WOOD
                                     ORGANIC TREATMENT

               Cylinder Size: 5 cylinders, each 7' diameter x 130' long, 5000 cubic feet
               Capital Cost:  $7,160,000(1978)
               Location:     West Coast
               Production:   2000 cubic feet per charge; 40 hours per charge (Boultonized)
                            3 shifts per day, 300 days per year
               Product:      1,800,000 cubic feet per year of Douglas fir poles
Item

Raw Materials:
  Wood
  Pentachlorophenol
Total Raw Materials

Processing:
  Labor, Operating
  Labor, Maintenance
  Maintenance Supplies
  Consumable Supplies
  Fuel and Power
  Plant Overhead
  Taxes and Insurance
Total Processing
Total Cost, F.O.B. Plant
  Units
Cubic feet
Pounds
Man hours
Man hours
50% of Labor
4% of Capital
Unit Cost
    ($)
   3.40
   0.42
 Units Per
Cubic Foot
    1.0
    0.75
   6.00
   6.50
Dollars Per
Cubic Foot
   3.40
   0.32
   3.72
                  0.333
                  0.101
                  0.120
                  0.061
                  0.181
                  0.217
                  0.159
                  1.163
                  4.883
Thousand
  Dollars
 Per Year
  6,120
    576
  6,696
                   600
                   182
                   216
                   110
                   326
                   391
                   286
                  2,093
                  8,789
Source:  Arthur D. Little, Inc., estimates based on industry interviews.
                                               76

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                                           TABLE B-7

                                           PLANT D-1
         ESTIMATED OPERATING COSTS FOR THE MANUFACTURE OF PRESERVED WOOD
                                     ORGANIC TREATMENT

               Cylinder Size: 2 cylinders, each 7' diameter x 130' long, 5000 cubic feet
               Capital Cost:  $3,300,000 (1978)
               Location:     South Central
               Production:   2000 cubic feet per charge; 16 hours per charge (Steaming)
                            3 shifts per day, 300 days per year
               Product:      1,800,000 cubic feet per year of Southern pine lumber
Item

Raw Materials:
   Wood
   CCA
Total Raw Materials
Processing:
   Labor, Operating
   Labor, Maintenance
   Maintenance Supplies
   Consumable Supplies
   Fuel and Power
   Plant Overhead
   Taxes and Insurance
Total Processing
Total Cost, F.O.B. Plant
   Units
Cubic feet
Pounds
Man hours
Man hours
50% of Labor
4% of Capital
Unit Cost Units Per
($) Cubic Foot
3.60 1.0
1.00 0.33
6.00
6.50





Dollars Per
Cubic Foot
3.60
0.33
3.93
0.173
0.048
0.048
0.024
0.072
0.111
0.073
0.549
4.479
Thousand
Dollars
Per Year
6,480
594
7,074
311
86
86
46
132
199
132
992
8,066
Source: Arthur D. Little, Inc., estimates based on industry interviews.
                                             77

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                                           TABLE B-8
                                           PLANT D-2
         ESTIMATED OPERATING COSTS FOR THE MANUFACTURE OF PRESERVED WOOD
                                     ORGANIC TREATMENT
               Cylinder Sin: 5 cylinders, each 7' diameter x 130' long, 5000 cubic feet
               Capital Cost:  $6,509,000 < 1978)
               Location:     South Central
               Production:   2000 cubic feet per charge; 16 hours per charge (Steaming)
                            3 shifts per day, 300 days per year
               Product:      4,500,000 cubic feet per year of Southern pine lumber
Item

Raw Materials:
  Wood
  CCA
Total Raw Materials

Processing:
  Labor, Operating
  Labor, Maintenance
  Maintenance Supplies
  Consumable Supplies
  Fuel and Power
  Plant Overhead
  Taxes and Insurance
Total Processing
Total Cost, F.O.B. Plant
  Units
Cubic feet
Pounds
Man hours
Man hours
50% of Labor
4% of Capital
Unit Cost
   ($)
   3.60
   1.00
   6.00
   6.50
 Units Per
Cubic Foot
    1.0
    0.33
Dollars Per
Cubic Foot
   3.60
   0.33
   3.93
                  0.133
                  0.040
                  0.048
                  0.024
                  0.072
                  0.087
                  0.058
                  0.463
                  4.393
Thousand
 Dollars
 Per Year
  16,200
   1.485
  17,685
                    600
                    182
                    216
                    110
                    326
                    391
                    260
Source:  Arthur D. Little, Inc., estimates based on industry interviews.
                                              78

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      APPENDIX C




EPA FINANCIAL 308 SURVEY
          79

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                          TABLE C-1
         RESPONSES TO EPA FINANCIAL 308 SURVEY

                                          #           %*
 Total Mailed                              601
 Less Duplicates                             27            —
 Net Responses                            424          87.1
 Total Applicable Responses                  337          69.2
 Total Non-Applicable Responses**            87            —
 No Answer                               150          30.8
 *Based on sum of "Total Applicable" and "No Answers" (487).
**Plants which indicated that they do not treat wood.
 Source: Arthur D. Little, Inc., estimates.
                             81

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                INSTRUCTIONS AND DEFINITIONS RELATING TO
                               WOOD PRESERVING
 1.  This survey must be completed by each manufacturing facility that treats wood either
    as a treating service only (TSO) or treats wood products owned by it for subsequent
    sale to others.

 2.  A questionnaire for each wood preserving plant has been sent to the corporate address.
    This may or may not be a plant site. All questions on the survey form refer to one
    particular plant  site only and a  separate questionnaire must be completed for each
    location. Questionnaires were mailed to corporate offices because much of the infor-
    mation resides there and typically corporate involvement is required for response to
    material of this kind.

 3.  Please submit one  completed questionnaire  for each plant in the enclosed,  pre-
    addressed envelope by October 21, 1977.

 4.  All questions contained  in this survey are intended to obtain  information about your
    manufacturing operations and activities as they pertain to wood preserving only. Other
    plant operations should not  be  considered in determining your responses unless a
    question specifically instructs you to do so.

 5.  A list of definitions of  terms used  in the survey has been provided to assist you in
    understanding the questions asked and to insure your interpretation of terms is the
    same as  that of the persons who developed the  survey. Please read these definitions
    prior to  completing any questions and refer to them as often as necessary to assure
    accuracy in  the  completion of your response. Defined terms appear in italics in the
    questionnaire.

 6.  All questions should be answered by checking the appropriate  box or boxes. Those
    questions requiring a written response should be answered by printing or typing in
    the appropriate space.

 7.  Attempt to  answer all questions. Where appropriate, answers should be provided for
    the most recent fiscal year. If you cannot provide a full response to a question, answer
    as much of it as you can. If a question is not relevant to your plant operation or the
    information requested is not obtainable, please provide an explanation. If clarification
    or supplementation of any response is necessary,  please attach a separate sheet. If you
    do  not know the answer to a question, write "don't know" or "DK". If the answer
    is "zero", write in zero (0).

 8.  If you have difficulty understanding or answering any question, please call Stephen
    Mermelstein, 202-755-6906.

 9.  Please retain a copy of your completed survey, since it may be necessary to contact
    you in the future to verify your responses.

10.  Definitions appear on the reverse  of this sheet.
                                       82

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                                                DEFINITIONS
Annual Cost of Pollution Control and Other Environmen-
tal Regulations - Depreciation charges for pollution con-
   trol equipment or for plant and equipment modifica-
   tions required by regulations. Operating costs include
   the cost of maintenance and operating labor, supplies,
   fuel, and electricity required to operate the equipment
   related to the regulation.

Depreciation  - Annual book  depreciation of assets at
   this plant. Do not include any Timberland Depletion
   in this figure.

Fixed Assets - Capital  assets, plant site land, and equip-
   ment are all categories of fixed assets. The book values
   or value net to depreciation or depletion should be
   shown. Do not include any  Timberland in this figure.

General and Administrative Cost - Salaries, wages, and
   related labor costs not directly associated with produc-
   tion activity;  state  and local taxes; selling expense
   insurance and other overhead costs.

Gross Margin — Earnings before interest, taxes, general
   and administrative expense.

Navigable Waters - Waters of the United States, including
   ocean, rivers, streams, etc. (surface water).

NPDES (National Pollutant Discharge Elimination System)
Permit — A permit issued by EPA  or an approved  state
   program to point sources which discharge  to public
   waters allowing the discharge of wastewater under
   certain stated conditions.

OSHA - The  Occupational Safety and Health Admin-
   istration.

Other Materials Cost - Chemicals  and  other supplies
   used in  the production of wood treated  products.

Payback Period - The  number of years it takes for an
   investment to repay itself.

Payroll  Costs  — Wages, unemployment insurance, FICA
   and other related costs  of direct labor (and indirect)
   employed in treating wood products.

Peak  Design Capacity   = Design Void  x 0.6  x Charge
   Factor

   Design Void = 3.142 x (Cylinder Radius)* x'Cylinder
   Length

   Charge Factor = Average number of possible charges
   per 24 hour period
Peak Capacity as Modified = Modified Void x 0.6 x Charge
   Factor
   Modified Void = 3.142 x (Current Cylinder Radius)1 x
   Current Cylinder Length
Process Waste - Any used water or liquid waste  product
   which results from or has had contact with the manu-
   facturing process, including any water for which there
   is  a reasonable possibility of contamination from the
   wood preserving process or from  raw material-inter-
   mediate product-final product, storage, transportation,
   handling,  processing or cleaning. For purposes of this
   survey,  cooling  water,  sanitary wastewater, storm
   water and boiler blowdown are not considered process
   waste if they have no contact with the process.

Production Workers — Direct and indirect labor associated
   with and  attributable to wood treating at this plant.

Profit After Tax  - If this is a single-plant company, the
   net profit remaining after Federal Income  taxes.  If a
   multi-plant company, calculate an  approximate profit
   after tax by using the actual corporate tax rate.

Profit Before Tax - Sales less all costs, except Federal
   Income taxes.

Return on  Investment - The average  annual revenue (or
   decreased cost)  realized on  an investment, expressed
   as a percentage of the original investment cost.

Sales  - Sales, fob plant, net of discounts, and  returns. If
   the plant is a cost center, estimate the approximate
   market value (fob plant) of the products produced in
   the most recent fiscal year.

Total Assets -  Fixed assets, inventories, receivables, cash
   securities, et cetera.

Total Liabilities -  Long-term debt, accounts  and notes
   payable, deferred taxes, et cetera.

Treated Wood  Products - Wood treated with  organics
   (oils)  or with  inorganic salt solutions or dual oil  and
   salt treatment.

Unusual Production Costs - Any plant characteristic that
   causes unusual costs should be described as well as the
   impact upon operations. For example, if the plant is in
   a remote location, freight costs to  the nearest market
   may be higher than those of other plants competing in
   the market.

Wood Cost - If this plant is treating service only (TSO),
   wood cost should be zero. If treating  owned wood
   products, show the cost of the wood products before
   treatment. (Use  approximate cost  as a percentage of
   sales if actual cost is unknown.)
                                                      83

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                                  308 QUESTIONNAIRE

                                   WOOD PRESERVING
                                                        Company Code #	
                                                        (for EPA use)

NOTE:    Upon receipt by EPA, this page will be separated from the remainder of the questionnaire so
          that data processing and use of the data is conducted on a coded basis by its contractor.
  i.  Name of Plant
 ii.  Plant Site Address
                          Street
                          City                     State                        Zip

 iii.  Name of Respondent*	
 iv.  Address of Respondent
                          Street              City                Stale               Zip

 v.  Telephone of Respondent	

 vi.  Parent Company	
 vii.  Total number of wood treating wood plants owned by parent	

vui.  Is this plant engaged in treating wood products?

     Yes D   Continue with Questionnaire

     No D   Do not fill  out the questionnaire but return after completing this page, through Question
              viii with a cover letter describing the nature of your business.

 ix.  To assert your claim  of confidentiality, please check off the  box corresponding to the questions,
     which, in the company's opinion, require confidential treatment.

                                                                         22    D     26   D

                                                                         23    D

                                                                         24    D

                                                                         25    D
1
2
3
4
D
D
a
a
5
7
8
9
a
a
D
a
10
11
12
13
a
a
a
a
14
15
16
17
a
D
a
a
18
19
20
21
D
D
a
a
'Person to be contacted in case of questions.
                                          84

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                                 308 QUESTIONNAIRE
                                  WOOD PRESERVING
                                             Company Code
                                             (for EPA use)
A.   GENERAL INFORMATION

     1.    What is the form of business organization of this plant?

               Proprietorship or Partnership      D
               Co-op                         D
               Privately-held Corporation        D
               Publically-held Corporation       D
     2.    Is this wood treating plant a stand-alone  operation or part  of a multi-plant complex at this
          location?

               Stand-alone                    D
               Multi-plant complex             D
     3.    Approximately what percent of total sales at this  complex  or plant was from wood treating
          in FY 1976?	%
     4.    Is this plant at an urban, suburban, or rural location?

               Urban                         D
               Suburban                      D
               Rural                         D

     5.    What year did the wood treating plant begin operation?  	
                                             85

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B.  EFFLUENT INFORMATION

    6.   How does this plant dispose of liquid process waste?

        a.   Discharge into navigable water                         D
        b.   Discharge into municipal sewer                         D
        c.   Disposed on plant site                                 D
        d.   Disposed off plant site                                d
        e.   Process waste is recycled (no discharge)                 D
        f.   This plant does not generate liquid process waste         D
        g.   Other  D  Please specify	
        IF THE ANSWER TO QUESTION 6 IS (c), (d), (e), OR (0, YOU MAY OMIT ANSWERS TO THE
        FOLLOWING QUESTIONS:

            7,10,20,21b,22,25

    7.a  If you do not discharge liquid process waste into a municipal sewer, do you have the option to
        connect?

        Yes  D          No   D           Don't Know   D

      b. If you do have the option to connect to a municipal sewer, what is the initial capital investment
        cost?

        $	           Don't Know   D
      c. If you discharge any wood treating process waste into a sewer system, on what basis are your
        sewer charges made?

        Flat annual fee                      D
        Gallon of effluent                    D
        Other  D  Please Specify	
      d. If you discharge into a municipal sewer, what were your total sewer charges in 1976? $
      e. If you discharge liquid process  waste  into navigable waters, do you have an NPDES permit"!

        Yes  D          No   D           Don't Know  D

      f. Do you own or have available for purchase about one acre of land at or adjacent to this facility
        that could be used for an effluent treatment system?

        Yes  D          No   D

        If yes, what is the current market value per acre? $	

 C.  SALES AND PRODUCT MIX

    8.  Fiscal year 1976 wood treating plant sales (thousands of dollars).

        Under 70   D          301-700      D       1,801-2,400   D       4,801-7,200        D
        71-155     D          701-1,200    D       2,401-3,200   D       7,201-11,500       D
        156-300   D        1,201-1,800    D       3,2014,800   D       More than 11,500   D
                                              86

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 9.  Which of the following product types are treated at this plant:

                                   Treated  	As a percent of Plant Sales	
     Treated Wood Products        at Plant  Under 10   11-30   31-50  51-70   71-90   Over  90
      a. Organic (Oil or Dual Oil
         and Salt Treatment)
        (1) Railroad Ties              D            D     D       D       D       D        D
        (2) Pilings, Poles               D            D     D       P       D       D        D
        (3) Timber, Lumber,
            and Other                 D            D     D       D       D       D        D
      b. Inorganic (Salt Based)
        (1) Pilings, Poles               D            D     D       D       D       D        D
        (2) Timber, Lumber,
            and Other                 D            D     D       D       D       D        D
lO.a.  Are any changes (other than normal business fluctuations) planned in production process or product
      mix?
      Yes    D            No   D     (If No, Go to Part D)
   b.  Process change towards:
      More Organic         D          More Inorganic     D
      Less Organic         D          Less Inorganic      D
   c.  Product Mix Change
      More Ties   D       More Poles   D        More Other   D
      Less Ties    D       Less Poles    D        Less Other    D
   d.  Other, please specify nature of change	
D.   PLANT CAPACITY AND PRODUCTION
11.  What is your peak design capacity (or peak capacity as modified)?  	cu. ft.
     Cubic Feet/24 hour period*
12.a. What region of the country is the origin of most of the wood treated at this facility?
     Northeast   D            Southeast    D           Midwest   D
     Northwest  D            Southwest   D           Other     D
   b. Is the wood mostly:
     Hardwood  D      or        Softwood    D
•If unable to calculate peak (design) capacity by the formula shown in "DEFINITIONS" attach a separate sheet describing
 the radius and length of each cylinder.
                                             87

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13.   Typical number of production days per week?

     14  D           5D          6D             7D

14.   Number of weeks at each shift level (total should add to 52 weeks):


          No. of Weeks

     a. 	 at 0 shifts (shut down or no wood preserving)

     b. 	 at 1 shift

     c. 	 at 2 shifts

     d. 	 at 3 shifts

     e. 	 at 4 shifts

          52 Week*        TOTAL OF (a) + (b) + (c) + (d) + (e)
15.  1976 Production (Thousands of cubic feet)
16.  Typical number of production workers in 1976:

     1-3   D         7-9    D      20-34   D      49-75  D       100-125  D

     4-6   D        10-19   D      35-48   D      76-99  D       Over 125 D

17.  This facility is primarily engaged in (a) treating service only (TSO), and or (b) treating owned wood
     products for sale to others:


                                                       Approximate Percent of Sales
                                           Under   10    10-25    26-50    51-75     Over 75
     a.    Treating Service Only                      D      D        D        D         D

     b.    Treating Owned Wood Products             D      D        D        D         D

 18.  What proportion of owned wood is from company-owned timberland?


                                                 Approximate Percent of Owned Wood Supply
                                              None       1-24     25-49    50-74     75-100
                                               D          D       D       D        D
                                               88

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E.  FINANCIAL STATEMENT

19. Revenue and Expenses

    Check the  box for each item which most closely approximates your 1976 fiscal year expenses as a
    percent of sales.


                                                  Cost as a Percent of Plant Sales


a. Wood Cost
b. Other Materials Cost
c. Payroll Cost

d. Depreciation
Under
10
D
D
D
Under 1
D
10- 16-
15 21
D D
D D
D D
1-2
D
Under 10 11-15
e. Gross Margin

f. General and Administrative Cost

g. Interest Expense

h. Profit Before Tax

i. Profit After Tax
20. How representative was this plant's
About the same
Better than Average
Worse than Average
D
Under 1
D
Under 1
D
Under 1
D
Under 1
D
1976 profit
D
D
D
D
1-5
D
1-4
D
1-4
D
1-2
D
22- 29-
28 38
D D
D D
D D
3-5
D
16-25
D
6-10
D
5-8
D
5-8
D
3-4
D
39- 49-
48 60
D D
D D
D D
6-8
D
26-30
D
11-15
D
9-12
D
9-12
D
5-7
D
before tax experience versus the average for









Over
60
D
D
D
OverS
D
Over 30
D
Over 15
D
Over 12
D
Over 12
D
Over?
D
1971-1975?



                                            89

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21.  Factors related to Revenues and Expenses

     a.   Fixed Costs:  If the plant faces lease, rental or mortgage commitments beyond 1976, (for build-
          ings or  equipment), indicate the average annual charges and the year the commitments expire.

                                      Leases/        Wood          Debt
                                      Rental   D   Contracts  D  Payment   D  Other*    D

          (1)  Average Annual Charge:   $	 $	 $	$	
         (2)  Commitment Expires:     19	  19	  19	19	
              (*if other commitments attach separate sheet)

      b.  What Depreciation Method is Used:                Equipment          Building)
         (1)  Book Basis:
              Straight-Line
              Double-Declir
              Sum of Year's Digits
              Other:
              (Please Specify)

         (2)  Tax Basis:
              Straight Line
              Double-Declinin
              Sum of Year's Digits
              Other:
              (Please Specify)

g Balance
igits


g Balance
ligits

jl Equipment Amortization:
T 5 Years
i other equipment
D
D
D
D
D
D
n
D

D
n
D
D
D
D
D
n
n
n



 22.   Unusual Production Costs

      Are there any circumstances peculiar to this plant which result in unusual production costs?

      Yes   D           No  D

      If Yes, please describe:	
                                                90

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23.  Historical/Annual Cost of Pollution Control and Other Environmental Regulations:
                                              Don't
                                              Know
          None
                Fiscal Year Ending
                                                                         1975
                                        1976
     (1) Water Pollution Regulations:

         (a)  Annual Operating Costs
         (b)  Annual Depreciation Charges

     (2) Solid Waste Disposal (including waste
         water sludge and wood waste, con-
         tract hauling):
D
D
D
D
(a) Annual Operating Costs
(b) Annual Depreciation Charges
(3) Other Environmental Regulations
Affecting Production Processes
and Production Costs
(Please Specify V

(a) Annual Operating Costs
(b) Annual Depreciation Charges
D
D

D
D
D
D
Air
D

D
D
s
s
OSHA
D

$
$
$
S


$
$
      (4)  Other Administrative Costs:
          Environmental department,
          research, litigation, consultants,
          additional administrative costs.
D
D
24.   Value of wood treating plant  Assets and Liabilities (as of the end of the most recent fiscal year).
      a.   Net Fixed Assets (Gross Fixed Assets
          less cumulative depreciation)
      b.   Total Assets: (Net Fixed Assets, Cash
          receivables, inventory, other assets)
      c.   What was the value of this wood treating
          plant's accounts receivable?
      d.   What was the value of this wood treating
          plant's accounts payable?
      e.   Current Plant Debt (i.e., debt maturing in
          current year or payable on demand).
      f.   Long-Term Plant Debt (debt maturing
          beyond the current year [1977])
      g.   Total Plant Liabilities (long-term debt,
          accounts payable, deferred taxes, other
          debt, etc.)
                                  Don't Know   D
                                  Don't Know   D
                                                91

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25.  Capital Investment Criteria for the Plant

     a.  What investment criteria do you use?

          Return on Investment (RO1)         D
          Payback                           D
          Discounted Cash Flow               D
          Other                             D

     b.   If you use return on investment criteria:

          (1)   What is the target internal pre-tax rate  of return on capital required for investment in
               this plant?	.

          (2)   At what ROI would you consider plant shutdown?	.
     c.   If you use payback period criteria, what is the required payback period for investment?

          	 years

     d.   What is the current long term interest rate you must pay for new capital?

          	 percent per year

26.  Capital Investment for the Plant  (not  including capitalized operating or maintenance expenses).
                              (1)

                          Total Capital
                           Investment
      (Actual) 1971-76

      (Planned) 1977
     (2)

Water Pollution
    Control
             (3)
    Other Environmental
 Regulation  (State or Federal)
Impacting Production Processes
                                               92

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        STRAIGHT TABULATION OF WOOD PRESERVING INDUSTRY RESPONSES
A.  GENERAL INFORMATION

    1.  What is the form of business organization of this plant?

                                        Number     Percent
        Proprietorship or Partnership     31        9.28
        Co-op                              1         .30
        Privately-held Corporation       230       68.86
        Publically-held Corporation       72       21.56
            Total                        334      100.00
    2.  Is this wood treating plant a stand-alone operation or part of
        a multi-plant complex at this location?
                                        Number;     Percent
         S t and-alone                      268      80.00
         Multi-plant complex               67      20.00
             Total                        335     100.00
                                  93

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3.   Approximately what percent of total sales at this complex or plant
    was  from wood treating in FY1976?
r — — .
I
I

0
I_
11
0.2971
._.______ T —— -
1
0.297
l -9;; :
I_ _,
211
6.2311
21
6.231
L0-19£
___ __ __ T _
101
2.9671
- — __ _— T _ — .
10
2.967
20-29* '
(
51
1.4841
5
1.484
?0-3c'>o <
61
1.7831
""""
6
1.780
VO-499C
5
1.4b4
5
1.464
                                      80-R9*      90-99%
1 	
I
I
1
	 	 I 	
171
5.J45I
17
5.045
	 i 	
21
0.5931
?
0.593
	 1 	
151
4.4511
_ __ T ____
15
4.451
	 1 —
221
6.I;2BI
22
6.52*
	 1
581
17.2111
53
17.211
                                                                number
                                                                percentage

                                                                number
                                                                percentage
                              NO              ROW
                            ANSWER          'SUMS
            I	j	1
            I         1551          201        337
            I      45.9941      5.9351    100.000
            I	j	j
                     155           20         337
                  45.994       5.935     100.000
                               94

-------
4.  Is this plant at an urban, suburban, or rural location?

Urban
Suburban
Rural
Total
5. What year did the wood treating plant
PEFORc
1930 1931-1940 1941-


I 5S I 131
I 17.4561 3.6461 1
T 	 T 	 _ 	 1 _____
59 H
17.45& 3.8t6 I

1961-1970 1971-1977 OTHER


761 561
22.4851 16.56BI

76 56
22.485 16.56B
Number Percent
98 29.38
85 25.22
153 45.40
336 100.00
begin operation?

1950 1951-1960

	 1
461 831
3.0091 24.5561

46 83
3.609 24.556
NO
ANSWER


I 51
I 1.4791


1.479










number
percentage



RPal
SUMS


337 number
100.000 percentage

337 number
1 00 . 000 percentage
                               95

-------
B.  EFFLUENT INFORMATION

    6.  How does this plant dispose of liquid process waste?
                                       Number      Percent
        Direct discharge                 10          2.9
        Indirect-steaming                30          7.8
        Indirect-Boulton                 10          2.7
        Disposed on plant site           98         26.2
        Disposed off plant site          18          4.8
        No discharge (recycled)         126         33.8
        No liquid waste                  60         16.1
        Inorganic                         5          1.3
        Other                             7          1.9
        No entry                       	9          2.4
            Total                       337        100.0
    IF THE ANSWER TO QUESTION 6 is (c), (d), (e) OR (f), YOU MAY OMIT
    ANSWERS TO THE FOLLOWING QUESTIONS:
                       7, 10, 20, 21b, 22, 25
    7.(a) If you do not discharge liquid process waste into a municipal
          sewer, do you have the option to connect?
                                      Number      Percent
        Yes
        No
        Don't Know
            Total
2
19
9
30
6.67
63.33
30.00
100.00
                                    96

-------
7 (b)  If you do have the option  to connect to a municipal sewer, what is  the
      initial  capital  investment cost?

0-5,000
T 	

I
I
T 	







I
I
— T —



5,000- 10,000-
10,000 13,000


11
0.2*61


1
0.296
15,000-
20,000


I
I




20,000-
?5,000

	
I
I

	 	 	





-I
I
T

- I


                                                                          number
                                                                          percentage
25,000-
30,000


-
1
I
30,000-
35,000


I
I
-T-
35,000-
40,000


1
1
- T-
40,
45

000-
,JOO

45,
50
I
I
-T 	
000-
,000

50,000
_T _ 	 	
I
I
- T
i
i
-T
                                                                              number
                                                                              percentage
                      DONT  KNOW
  NO
ANSWER
1 	
I
I

	 i —
111
3.2541
11
3.254
	 1
3251
96.4501
_____ ___ r
325
96.450
                                                        ROU
                                                        337
                                                   100.000
                        number
                        percentage
                                                        337  number
                                                   100.000  percentage
          7.(c)  If you  discharge any wood treating process waste into a sewer
                system,  on what basis are your sewer charges made?
               Flat annual fee
               Gallon of  effluent
               Other
                   Total
        Number
           7
          21
          13
          41
Percent
  17.07
  51.22
  31.71
 100.00
                                         97

-------
7. (d.)  If you discharge into a municipal sewer, what were your total
       sewer charges in 1976?  $	.
 7.(e) If you discharge liquid process waste into navigable waters,
       do you have an NPDES permit?
                                      Number     Percent
       Yes
       No
       Don"t Know
           Total
10
 4
 2
16
 62.50
 25.00
 12.50
100.00
                                 98

-------
7.  (f)Do you own or have available for purchase about  one  acre of land at or
      adjacent to this  facility that could be used for an  effluent treatment
      system?


I
I





0-500

0.



0.


21
5921


2
592
500-
1,000

0.



0.


1
296


1
296


I
I




1 ,000-
1,500
21
0.5921


2
U.b92
1,500-
2,000
21
0.5921


2
0.592
2,000-
2,500

J.5<



0.5<


1
L.
1
5,000



0.



0.



2
592


2
592



I
I




5,000



3.



3.



12
-------
C.  SALES AND PRODUCT MIX




    8.  Fiscal year 1976 wood treating plant sales (thousands of dollars)

Under 70
71 - 155
156 - 300
301 - 700
701 - 1,200
1,200 - 1,800
1,801 - 2,400
2,401 - 3,200
3,201 - 4,800
4,801 - 7,200
7,201 - 11,500
More than 11,500
Total
9. Which of the following product
a. Organic (Oil or Dual Oil and
(1) Railroad Ties
Under 10
11 - 30
31 - 50
51 - 70
71 - 90
Over 90
Total
Number
25
25
29
48
50
21
21
26
24
30
13
6
318
types are
Percent
7. .86
7, .86
9 ,. 12
15.09
15 ,.7 2
6,60
6 . 60
8,18
7.55
9 . 43
4.09
1.89
100.00
treated at this plant:
Salt Treatment)
Number
35
19
7
10
10
20
101
Percent
34.65
18.81
6.93
9.90
9.90
19.80
100 . 00
                                   100

-------
(2) Pilings, Poles
Under 10
11 - 30
31 - 50
51 - 70
71 - 90
Over 90
Total
(3) Timber, Lumber, and Other
Under 10
11 - 30
31 - 50
51 - 70
71 - 90
Over 90
Total
9b. Inorganic (Salt Based)
(1) Pilings, Poles
Under 10
11 - 30
31 - 50
51 - 70
71 - 90
Over 90
Total
(2) Timber, Lumber, and Other
Under 10
11 - 30
31 - 50
51 - 70
71 - 90
Over 90
Total
101
Number
23
30
21
15
25
35
149
Number
64
48
33
14
19
30
208

Number
33
11
0
0
1
2
47
Number
13
26
13
6
14
59
131

Percent
15.43
20.13
14.10
10.07
16.78
23.49
100.00
Percent
30.77
23.07
15.86
6.73
9.13
14.42
100.00

Percent
70.21
23.40
.00
.00
2.13
4.25
100.00
Percent
9.92
19.85
9.92
4.58
10.68
15.04
100.00


-------
 9c.   Other
      in production process or product mix?
      Yes
      No
          Total
lOb.  Process  changes towards:
      More Organic
      Less Organic
      More Inorganic
      Less Inorganic
          Total

lOc.  Product Mix Change

      More Ties
      Less Ties
      More Poles
      Less Poles
      More Other
      Less Other
          Total
Number
1
Percent
100
.00
mal business flucti
:t mix?
Number
11
123
134
Number
1
6
3
0
10
Number
2
0
0
0
4
0
6
Percent
8
91
100
.21
.79
.00
Percent
10
60
30

100
.00
.00
.00
.00
.00
Percent
33.
.
.
•
66.
9
100.
33
00
00
00
67
00
00
                                102

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D.  PLANT CAPACITY AND PRODUCTION

    12a.  What region of the country is the origin of most of the wook
          treated at this facility?

Northeast
Northwest
Southeast
Southwest
Midwest
Other
Total
12b. Is the wood mostly:

Hardwood
Softwood
Total
13. Typical number of production

1-4 days
5 days
6 days
7 days
Total
Number
15
65
146
39
40
24
329

Number
62
267
329
days per
Number
32
252
26
17
327
Percent
4.55
19.75
44.37
11.85
12.16
7.29
100.00

Percent
18.84
81.16
100.00
week?
Percent
9.79
77.06
7.95
5.20
100.00
                                  103

-------
14.  NfKnber of weeks at each shift level (total  should add to 52 weeks):
         at 0 shifts (shut down or no wood preserving)
                 0-9
10-19
20-29
                                   30-39
1 —
I
I

	 1 	
2811
83.1361
281
83.136
	 	 	 -1- —
121
3.5iOI
12
3.550
------- 1 --•
101
2.9591
10
2.959
•-----—i
61
1.7751
6
1.775
number
percentage
number
percentage
-49       50-52
	T	1.
     II           II
 0.2961      0.2961
	1	1-
     1            1
 0.296       0.296
                                         POOR
                                         DATA
                                        	1
                                              271
                                           7.9831
                                        	1
                                              27
                                           7.988
                             ROW
                            SUMS

                             338
                         100.000

                             338
                         100.000
                       number
                       percentage

                       number
                       percentage
                                     104

-------
  14. Number of weeks at each  shift level  (total should add to 52 weeks):
(cont)      at 1  shift
                       0-9
     10-19
     20-29
I —
I
I
—
	 1 	
9bl
30.3681
96
30.863
	 1 	
101
3.2151
10
3.215
171
5.4661
	 T
17
5.466
number
percentage
number
percentage
                 30-39
                --------- 1
                        161
                    5.1451
                        16
                    5.145
 40-49
	1-
       191
    6.109T
	1-
       19
    6.109
 50-52
	1
      1531
   49.1>6I
	1
      153
   49.196
    ROW
   SUMS

    311
100.000

    311
100.000
number
percentage

number
percentage
                                      105

-------
 14.  Number of weeks  at each shift level  (total should add to 52 weeks):

(cont)    at 2 shifts

I
I

0-9
2611
83.9231
261
83.923
10-19
191
6.1091
19
6.109
20-29
8
2.572
a
2.572
                                                        I
                                                       81  number
                                                        I  percentage
                                                        I
                                                           number
                                                           percentage
                                                            RQrt
                 30-39       40-I      
-------
  14.  Number of weeks at each shift level  (total should add to 52 weeks):

      at 3 shifts

I__
I
I

0-9 ]
I__
2311
7^.2771
I___
231
74.277
LO-19 ;
	
41
1.2861
	
4
1.2a6
>0-29
51
1.6C6I
5
1.608
                                                           number
                                                           percentage

                                                           number
                                                           percentage
                                                            ROM
                  30-39       40-49       50-52            SUMS
                 --------- 1 ---------- T ---------- i

                         51           71          591        311  number
                     1.6081      2.2511     IP. 9711    100.000  percentage
                         5            7           59         311  number
                     1.608       2.251      18.971    loo.ooo  percentage
                                      107

-------
  14. Number of weeks at each shift level (total  should add to 52 weeks)
(cent)     at 4 Sh1fts
I_-
I
I
I_.

0-9
I_
3071
98.7UI
_________ T _
307
98.714
10-19 20-29
21
0.6
-------
15.  1976 Production  (Thousands of cubic feet).

I
I

0
T
1

250, OOC
—
1201
35.61 1
12C
35.61
500,000
56
16.617
56
16.617
                                                  250,000-

                                                                I
                                                                l number
                                                                1 percentage
                                                                I
                                                                  number
                                                                  percentage
500.
750




000-
,000

R

e


30
.902
30
.902


--
I
1
-•

750,000-
1,000.000

*>•

5.


17
044
17
044


I
I


>
1,000,000
5>
17.751

17.751

T — —
i
i
r —


NO
ANSWER

16

16


55
.320
35
.320
                                                                         I
                                                                         I   number
                                                                         I   percentage
                                                                         I
                                                                            number
                                                                            percentage
                                          ROW
                                         SUMS


                                          33?
                                     100.000
number
percentage
                                          337   number
                                     100.000   percentage
                                    109

-------
16.  Typical number of production workers in 1976:
1-3
4-6
7-9
10 - 19
20 - 34
35 - 48
49 - 75
76 - 99
100 - 125
Over 125
Total
Number
73
39
26
56
55
27
35
8
6
2
327
17. This facility is primarily engaged in
only (TSO) , and/or (b) treating owned
to others:
a. Treating Service Only
Under 10
10 - 25
26 - 50
51 - 75
Over 75
Total
b. Treating Owned Wood
Products
Under 10
10 - 25
26 - 50
51 - 75
Over 75
Total
Number
134
49
30
14
28
256
Number
21
20
17
39
212
309
Percent
22.32
11.93
7.95
17 . 12
16.92
8.26
10.70
2.45
1.83
.61
100.00
(a) treating service
wood products for sale
Percent
52 . 55
19.22
11.76
5.49
10.98
100.00
Percent
6.80
6.47
5.50
12 . 12
68.61
100.00
                               110

-------
    18.  What proportion of owned wood is from company-owned  timberland?
E.  FINANCIAL STATEMENT
    19.  Revenue and Exp«n»*s
         a.  Wood Cost
             Under 10
             10 - 15
             16 - 21
             22 - 28
             29 - 38
             39 - 48
             49 - 60
             Over 60
                 Total

         b-  Oth«r Materials Coat
             Under 10
             10 - 15
             16 - 21
             22 - 28
             29 - 38
             39 - 48
             49 - 60
             Over 60
                 Total
Number
256
59
3
2
9
329
Number
17
10
10
15
49
59
69
70
299
Number
65
74
72
44
27
13
1
5
301
Percent
77.81
17.93
.91
.61
2,74
100.00
Percent
5.67
3.34
3.34
5.02
16.39
19.73
23.08
23.41
100.00
Percent
21.60
24.50
23.92
14.62
8.97
4.32
.33
1.66
100.00
                                  111

-------
c.  Payroll Cost
    Under 10
    10 - 15
    16 - 21
    22 - 28
    29 - 38
    39 - 48
    49 - 60
    Over 60
        Total
d.  Depreciation
    Under 1
    1-2
    3-5
    6-8
    Over 8
        Total
     Gross Margin
     Under 10
     10 - 15
     16 - 25
     26 - 30
     Over 30
         Total
Number
103
102
45
36
13
4
1
	 2
306
Number
59
117
85
26
20
307
Number
102
53
87
27
37
306
Percent
33.66
33.23
14.71
11 ,,76
4.24
1.30
.,33
,,65
100 ,.00
Percent
19.22
38.11
27 . 69
8.47
6.51
100.00
Percent
33.33
17.32
28.43
8.82
12.09
100.00
                           112

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f.  General and Administrative
    Cost
    Under 1
    1-5
    6-10
    11 - 15
    Over 15
        Total
Number
Percent
g.  Interest Expense
    Under 1
    1-4
    5-8
    9-12
    Over 12
        Total
h.  Profit Before Taxes
    Under I
    1-4
    5-8
    9-12
    Over 12
        Total
18
88
93
48
48
295
Number
171
84
24
5
4
288
Number
68
83
61
46
31
289
6.10
29.83
31.52
16.27
16.27
100.00
Percent
59.37
29.01
8.33
1.73
1.38
100.00
Percent
23.53
28.72
21.11
15.92
10.73
100.00
                         113

-------
    i.  Profit After Tax            Number     Percent
        Under 1
        1-2
        3-4
        5-7
        Over 7
             Total
76
63
56
45
33
273
27.84
23 .,08
20, .51
16.42
12.04
100 . 00
20.  How representative was this plant's 1976 profit before
     tax experience versus the average for 1971-1975?
                                    Number     Percent
     About the Same                   70        40.69
     Better than Average              36        20.93
     Worse than Average               66       _3JL_2Z
         Total                       172       100,00
                              114

-------
 21. Factors  related to Revenues and  Expenses
         a.  Fixed Costs:  If the plant faces lease, rental  or mortgage commit-
            ments beyond  1976, (for  buildings or equipment), Indicate the
            average annual charges and the year the commitments expire.
                                          Leases/Rental
            (1) Average Annual Charge:     $	
                       <        25,OUO-    50,000-    75,OJO-
           0         25,000     50,000     75,000    100,000
      I	I	L	J	l	y.
      I        2471         681         101          41          II  number
      I    73.0771    20.11*1      2.9591      1.1331      o.29ol  percentage
      I	i	t	r	j	T_
               247          68          10           4           i   number
           73.077     20.118       2.959       1.183       0.290   percentage




 100,000-   1?5,000-    150,000-    175,000-    200,000-    225,000-
 125,000    150,000     175,000     200,000     225,000     250,000
	1	1	1	T	_	1	T
         31          21          31           I            I            I  number
     o.SoPi      0.5921      0.8881           I            I            i  percentage
 	I	T	!	1	r	j
         3^3                                       number
     C.888       0.592       0.888                                       percentage



                               >               ROW
                            250,000           SUMS
                         I	1
                         I           I        338  number
                         I           I    100.000  percentage
                         I	1
                                              338  number
                                          100.000  percentage
                                    115

-------
 21.  Factors related to Revenues and  Expenses
(cont)     a> p^xe(j cost;S: if the plant faces lease, rental or mortgage commit-

             ments beyond 1976, (for  buildings or equipment), Indicate the

             average annual charges and the year the commitments expire.
                                          Wood Contracts

               (1) Average Annual Charge;   $	
                3251
             9&.154I
                325
            96.154
   <        25,000-     50,000-     75,,000-
 25,000      50,000      75,000     100,000
	j	j	j	

         51          U            I

	ll^!1.     °-^q6l            I      O.CJ88I  percentage
          i       -    i            i	j
         5
    1.479
     i
0.296
                               J

                              31
        number
     3
0.888
number
percentage
100,000-
125,000











-
I
I

•


1?5»000-
150,000


11
0.2961


1
0.296
150,000-
175,000


31
H.88PI


3
0.888
175,000- 200,000-
200,000 225,000


I
I
. 	 T 	



2?5,000-
250,000


I
I






.T

I
I
-T



                                                                              number
                                                                              percentage

                                                                              number
                                                                              percentage
                           250,000
                         I	1
                         I            I
                         I            I
                         I	1
                        ROW
                       SUMS


                        338
                    100.000


                        338
                    100.000
              number
              percentage

              number
              percentage
                                      116

-------
 21.  Factors related to Revenues and  Expenses

(cont)     a  pjxed costs: if the plant faces lease, rental or mortage commit-

             ments beyond 1976, (for  buildings or equipment), indicate the

             average annual charges and the year the commitments expire.

                                           Debt Payment

               (1) Average Annual  Charge:    $	
                         25*000
25,000-
 50,000
50,000-
 75,000
75,000-
100,000
1 —
I
I
—
	 1 —
2571
76.0361
257
76.036
311
9.1721
31
9.172
	 i 	
241
7.1011
24
7. mi
	 1 	
111
3.2541
11
3.254
2
J.^2
^
i.
0.592
                                                                        I
                                                                       21 number
                                                                       21 percentage
                                                                        I
                                                                         number
                                                                         percentage
100
125





,000-
,000
5
1.479

5
1.479


I
I



125,000-
150,000
1
0.29o

1
0.2<»6


I
I



150,000-
175,000
3
0.888

3
0.888


I
I



175,000-
200,000
I
I



200,000-
225,000
1
0.296

1
0.296
225,000-
250,000
I
I





I
I





number
percentage

number
percentage
                            250,000
                           . _ ^ _« .** — •* T

                                     31
                                O.d381
                           	1

                                     3
                                0.388
          ROW
         SUMS

          338  number
      100.000  percentage

          338  number
      100.000  percentage
                                      117

-------
 21.  Factors related to Revenues and Expenses
(cont)
a. Fixed Costs: If the plant faces lease, rental  or mortgage commit-
   ments beyond 1976,  (for buildings or equipment), Indicate the
   average annual charges and the year the commitments expire.
                                 Other
     (1) Average Annual  Charge:    $	



—
I
I

—



0


3331
98.5211


333
9d.52l
< 25,000-
25fOOO 50tOOO


21
o . r. y 2 1


2
0.5)2




I
I




50,000- 75,OUO-
75,000 lOOtOOO


II
0.2961


I
0.296


T
1
I number
I percentage
T
L
number
percentage
  100,000-
  125,000
    125,000-
    15U,GOO
150,000-
175,000
175,000-
200,000
200,000-
225,000
225,000-
250*000
                                                                            number
                                                                            percentage
                 250,000
               1	1
               I           21
               I      0.5921
               I	1

                     0.592
                                              ROW
                                            SUMS

                                              338  number
                                         loo.ooo  percentage

                                              338  number
                                         100.000  percentage
                                      118

-------
,21*  .Factors related to Revenues and Expenses
(cont)
         a. Fixed Costs:  If the plant faces lease* rental or mortgage commit-

            ments beyond  1976, (for buildings or equipment), Indicate the

            average annual charges and the year the commitments expire.

                                       Leases/Rental

              (2) Commitment Expires:   19	
           BEFORE                   AFTER          NO
            1985     1935-1995      1995       ANSWER          SUMS
        I ---------- 1 ---------- 1 ---------- 1 ---------- 1
        I          551         IM           41         26"* I        338  number
        I     16.2721      4.1421      1.1831      78.4021    lou.ooo  percentage
                  55          14            4         265         338  number
             16.272       4.142       1.183      78.402     100.000  percentage
                                     119

-------
 21. Factors related to Revenues and  Expenses
(cont)    a> Fixed Costs: If the plant faces lease, rental or mortgage commit-
            ments beyond 1976, (for  buildings or equipment), Indicate the
            average annual charges and the year the commitments expire.
                                      Wood Contracts
              (2) Commitment Expires:   19	
           BEFORc                  AFTER         NO
            1985     1985-1995      1995       ANSWtR           SU^S
        I	1	!	1	1
        I          III            I            I        3271         338   number
        I       3.2541            I            I     96.7461    iOJ.ooo   percentage
        i	1	z	1	:	1
                  11                                  327          338   number
               3.254                               96.746     lOO.ooo   percentage
                                      120

-------
 21.  Factors related to Revenues and Expenses

(cont)     a> Ffxee| costs: If the plant faces lease, rental  or mortgage commit-

             ments beyond 1976, (for buildings or equipment), Indicate the

             average annual  charges and the year the commitments expire.

                                       Debt Payment

               (2) Commitment Expires:   19	
         PfcFURc                  AFTER         NO
           1985     1985-1995       1^5       ANSWER           SUMS
      j	1	1	1	1
      I         541          201          31        2611         338   number
      I     15.9761      5.9171      0.8881     77.2191    iou.ooo   percentage
      I	1	1	1	1
                54           20           J         261          3^8   number
            15.976       5.917       o.88e      77.219     100.000   percentage
                                     121

-------
 21. Factors related to Revenues and Expenses
(cont)
         a. Fixed Costs: If the plant faces lease, rental  or mortgage commit-
            ments beyond 1976, (for buildings or equipment), Indicate the
            average annual  charges and the year the commitments expire.
                                          Other
              (2) Commitment Expires:       19	
       BEFORE                  AFTER          MO             ROw
         1985    1985-1V95      19?5       ANSWER          SU*S
                1	1	1	1
               6i           ii            I        3311        33b  number
           L.775I      0.2961            I     97.9291    loo.oco  percentage
                1	1	1	1
               &            i                      331         33 s  number
           L.775       0.296                   97.929     100.000  percentage
                                    122

-------
     b.
What Depreciation Method is Used:
Equipment
(1) Book Basis
Straight-Line
Double-Declining
Balance
Sum of Year's Digits
Other
Total
Number
109
35
2
2
148
Percent
73.65
23.65
1.34
1.35
100.00
Equipment
(2) Tax Basis
Straight-Line
Double-Declining
Balance
Sum of Year's Digits
Other
Total
Number
81
68
4
2
155
Percent
52.26
43.87
2.58
1.29

                                                           Buildings
                                                       Number   Percent
                                                         121
                                                          13

                                                           2
                                                        	2_
                                                         137
                             87.60
                              9.48

                              1.46
                              1.46
                            100.00
                                                           Buildings
                                                       Number   Percent
                                                          99     72.26
                                                          31     22.63
                                                           4
                                                           3
                                                         138
                              2.92
                              2.19
                            100.00
          (3)   Pollution Control Equipment Amortization
                                    Number   Percent
               Accelerated Over
                 5 Years
               Same method as
                 Other Equipment
                   Total
   13
   96
  109
 11.92
 88.08
100.00
22.  Unusual Production Costs—Are there any circumstances peculiar
     to this plant which result in unusual production costs?
               Yes
               No
                   Total
Number   Percent
            9.77
           90123
          100.00
                                 123

-------
23.  Historical/Annual Cost of Pollution Control and Other Environmental
     Regulations
     (1) Water Pollution Regulations
         a.  Annual Operating Costs      Number     Percent
             Don't Know                   145        63.60
             None                        	83_        36.40
                 Total                    228       100.00
         b.  Annual Depreciation         Number     Percent
             Charges
             Don't Know                   125        57.07
             None                        	94        42.93
                 Total                    219       100.00

      (2) Solid Waste Disposal (including waste water sludge and wood
          waste, contract hauling)
          a. Annual Operating Costs      Number     Percent
             Don't Know                   134        56.07
             None                         105        43.93
                 Total                    239       100.00
          b. Annual Depreciation         Number     Percent
             Charges
             Don't Know                   126        51.63
             None                         118        48.37
                 Total                    242       100.00
      (3) Other Environmental Regulations Affecting Production Processes
          and Production Costs
                                         Number     Percent
          Air                              49        40.83
          OSHA                             33        27.50
          Both                             38        31.67
              Total                       120       100.00
                                   124

-------
    a.   Annual Operating Costs         Number      Percent
        Don't Know                      129        64.82
        None                          	70        35.18
            Total                       199       100.00

    b.   Annual Depreciation           Number      Percent
        Charges
        Don't Know                      122        58.94
        None                          	85        41.06
            Total                       207       100.00
(4)  Other Administrative  Costs:   Environmental  department, research
    litigation,  consultants,  additional  administrative  costs.
                                     Number     Percent
    Don't Know                         126        59.43
    None                                86        40.57
        Total                          212      100.00
                           125

-------
24. Value of wood treating plant Assets and Liabilities  (as  of the end of the
    most recent fiscal  year).
         a. Net FIXED ASSETS (Gross FIXED ASSETS
            less cumulative depreciation).           $    	
0 1 ?
r — _ _______ T —_—__——_—— T__— — — — — — — — T— — —
I 861 421 321
I 25.4441 12.4261 9.4671
I____ __ _ T __________ T __________ T___
86 t2 32
25.444 12.426 9.467
5678
III 41 71
3.2541 1.1831 2.0711 1.
	 _ 	 i 	 _ 	 ____A 	 __ _
1147
3.254 1.183 2.071 1.
> NO
2tOOOtOOO ANSWER
I_____ ____T__ __ ___T
I 71 901
I 2.0711 26.6271
7 90
2.071 26.627
3
_______ i
151
4.4381
15
4.438
41
1P3I
4
183
kOH
SUMS
337
100.000
337
100.000
4
______ ___T
171
5.03JT
17
5.030
1 tOOO.OOO-
9 2fOOO,000
	 _--T 	 - 	 T
31 191
1.1BM 5.6211
	 	 	 T 	 	 T
3 19
1.183 5.621


                                      126

-------
(cont)
     Value of wood treating plant Assets and Liabilities (as of the end of the
     most recent fiscal year).
          b. Total Assets: (Net FIXED ASSETS, Cash
             receivables, Inventory, other assets)
           o
L 	
I
I

— 	 	 i 	
321
9.4671
32
9.467
	 1 	
261
7.6921
26
7.692
191
5.0211
19
5.621
--------i- —
ill
3.2541
11
3.254
221
6.5091
22
6.509
567
71 til
2.0711 2.3671 2
7 6
2.071 2.367 2
2»000»000
I 401
I 12.1301
4Q
12.130
8
71
.0711 2.
7
.071 2.
HO
ANSWER
1191
35.2071
119
35.207
9
81
3671 0.
8
367 0.
ROrt
SUMS
33X
100.000
337
100.000
1 t 000 t 000-
2»OOOtOOO
31 351
88RI 10.3551
3 35
883 10.355


                                        127

-------
 24. Value of wood treating plant Assets and Liabilities (as  of the end of  the
con most recent fiscal  year).
         c. What was the value of this wood treating
           plant's accounts receivable?              $  	
< 25,000- 50,000- 75,000-

I
I




25,000 50,000 75,000 100,000
471
13.9051


47
13.905
181
5.3251


18
5.325
231
6.8051


23
6.805
181
5.3251


18
5.325
      100,000-
      125,000
                1-
           4.1421
                 1
              14
           4.142
 125,000-
 150,000
	1-
        131
     3.8461
	1-
        13
     3.846
150,000
	1-
        981
    ?9.2<>OI
	1-
        98
    29.290
   NO
 ANSWER
	1
      1061
   31 .3611
	1
      106
   31.361
    ROwl
   SUMS

    337
100.000

    337
100.000
                                    128

-------
  24. Value of wood  treating plant Assets and  Liabilities  (as of the end of the
(cont)            _.   ,     .
     most recent fiscal year).
          d. What was the value of this wood  treating
             plant's accounts  payable?                $	


T_

I
I
T _



<
25,000


681
ZO.libI


68
20. Ufa
25,000-
50,000


281
8.2641


28
8.2e           NO
       125,000    150,000     150,000      ANSWcR          SUMS
       	I	i	1	i
               131          41         701        1271         337
            3.64M      1.1331     ?0.414I     37.574I    100.000
       	y	i	T	i
               13           4          70         127          337
            3.846       1.183      20.414      37.574     100.000
                                      129

-------
.  24.  value of wood treating plant Assets and Liabilities  (as of the end of the
(cont)
      most recent fiscal year).
          e. Current Plant Debt  (I.e., debt maturing
             1n current year or  payable on demand)     $.	




I
I




<
25,000


501
14.7931


50
14.793
25,COJ-
50,000


241
7.1011


24
7.101
50,000-
75,000


121
3.5501


12
3.5*0
75,000-
100,000


81
2.3671


8
2.367
        100,000-
        125,000
        	1
                 91
             2.663T
        	1
                 9
             2.663
 125,000-
 150,000
	1-
         1 I
     0.?96I
	1-
         1
     0.296
150,000
--------- 1-
        471
    U.905I
  NO
ANSWER
        47
    13.905
      1861
  55.3251
         1
      186
  55.325
   SUMS

    337
100.000

    337
100.000
                                     130

-------
    24. Value of wood treating  plant Assets and Liabilities (as of the end of the
(cont)  iT)ost recent fiscal  year).
            f.  Long-Term Plant Debt (debt maturing
               beyond the current year [1977])            $	

I
I
—
0
651
19.2311
65
19.231
1
251
7.3961
25
7.396
2
51
L.479I
5
1.479
3
I——.
71
2.0711
7
2.071
4
	 	 T
91
2.66^1
9
2.663

5



1



1




5
.479


5
.479

6
T _ _

I
I








I
T





7


1
0.296


1
0.296

8

	 __-
I
I





9
. _T _______

I
I




1
2


I
I




,000,
,000,



0



0
000-
000


21
.5921


2
.592

2

—
I
I

—


>
,000,



0



0

000


1
.296


1
.296

NO


ANSWER


I
I







64.



64.


217
497


217
497
I
I
I
I


                                                      SUMS

                                                        337
                                                   100.JOO

                                                        337
                                                   100.000
                                        131

-------
25.  Capital Investment Criteria for the Plant
     a.  What investment criteria do you use?

                                         Number      Percent
         Return on Investment (ROI)        75         63.02
         Payback                           21         17.64
         Other                             23         19.34
         No Answer                        218        	
             Total                        337        100.00
                                   132

-------
  24.  Value of wood treating plant Assets and Liabilities  (as  of the  end of  the
(cont)most recent fiscal  year).
           g. Total Plant Liabilities (long-term
              debt, accounts payable, deferred
              taxes, other debt, etc.)                  $	

—
I
I
—
0
18.
18.


631
6391
63
639
i —
1
29
8.580
29
8.580

I
I

2
5.32
1
5.32

5
8
5

I
T_

3
___ T
141
4.1421
4.14?
4
91
2.of>3T
	 _T
9
2.663

5


PI
2.3671
fi
2.367

6

I__
51
1.4791
5
1.479

7

I__
41
1 .1831
4
1.183

8
________ T — —

31
0.8881
3
0.888
1
9 2
I_

21
0.^921
2
0.592
,000,000-
,000,000


131
3.8461
13
3.846

2


I
I




>
,000,000

t_
41
1.1831
I_

4
1.183
NO
ANSWER


1651
49. 1121


165
49.112
ROW
SUMS


337
100.000


337
100.000
                                         133

-------
 26.   Capital  Investment Criteria  for the Plant
(cont)
           b.  If you  use return  on Investment criteria:

                (1) What 1s the  target Internal  pre-tax  rate  of return  on

                   capital  required  for Investment 1n this plant?	
0-4%
	 -— ----1 — •
I I
I I
	 _______ I -.
5-9*
21
0.5921
-
2
0.59?
10-14%
71
2.0711
7
2.071
15-19%
_* _» . __. T _»
III
3.2541
11
3.254
20-245&
81
2.3671
8
2.367
50%
OR
25-29% 30-34* 35-39% 40-44* 45-49% GREATER
131
3.8461
1.
12
3.8t6
81
2.3671
8
2.367
I
I

31
0.8861
3
0.888
I
I

11
0.2961
1
0.296



—
I
I




NOT
APPLIC


2651
78.4021


265
78.402
NO
AMSWER


201
5.9171


20
5.917
RCM
SUMS


333
100.000


338
100.000
                                        134

-------
  26.  Capital Investment Criteria  for the Plant
(cont)      bi jf you use return  on  investment criteria:
                (2) At what ROI  would you consider plant shutdown?

I 	
I
I
I 	
0-4%
	
51
I. 4791
	
5
1.479
5-9% 1
81
2.3671
	
8
2.367
.0-14% 1
	 T __
61
i.7751
6
1.775
.5-19% I
61
1.7751
	 _ 	 r 	
6
1.775
'0-24%
	 1
71
2.367!
	 1
7
2.367
5CU
OR
25-29% 30-34% 35-39% 40-44% 45-49* GREATER
i
I
1

I
I

11
0.2961
1
0.296
I
I

I
I

11
0.2^61
	 	 T
1
0.296




I
I




NOT
APPLIC


2651
78.4021


265
78.402
NO
ANSWER


301
11.2431


38
11.243
                                                      ROW
                                                     SUMS

                                                      33?
                                                  100.000

                                                      337
                                                  100.000
                                        135

-------
  26. Capital  Investment Criteria for the Plant
(cont)     c   If yOU use payback peri0(j criteria,  what Is the required payback
             period for Investment?	years

I
I

2 YRS
11
0.2961
1
0.296
2
21
0.5921
2
0.592
3
21
2
0.592

21
C.592I
2
0.592
5
61
2.0711
,6
2.071
                               6
	 1 	
I
I
	 	 	 T 	
	 	 1-----
I
I
	 T_-___

I
1
__ — _ r — -_-.
— —- 1 - —
I
I
	 1 	
-------- i- —
31
0.8881
	 	 	 T 	

3
0.888

                       10        10 YRS
                                          I
                                          I
                                          I
                                          I
                            3            3
                        0.888       0.888
                      NOT
                     APPLIC
                    --------- 1-
                          3171
                       93.7871
                          317
                       93.787
   NO
 ANSWER
	1
        II
    0.2961
	1
        I
    0.296
   SUMS

    337
100.000

    337
100.000
                                    136

-------
  26. Capital  Investment Criteria for the Plant
(cont)     d.  ^at is the current long term interest rate you must pay for
             new capital?	percent per year

I
I

< 1%
31
0.3881
3
0.888
7
11
0.2961
1
0.296
3
I__
111
3.5501
11
3.550
9
201
5.9171
20
5.917
10
251
7.3961
25
7.396
            11
            	1-
                  31
             0.8681
            	1-
                  3
             0.888
 12
	j.
      51
  1.4791
	1-
      5
  1.479
           NO              ROW
         ANSWER           SUMS
	1	1
    171        2521         337
5.0301     74.5561    100.000
	!	1
    17         252          337
5.030      74.556     100.000
                                    137

-------
  26.  Capital Investment for the Plant (not  Including capitalized operating
(cont)
      or maintenance expenses).
                                       (1)
                                   Total  Capital Investment
          (Actual) 1971-76          $	




I
I




ZE80
ENTRY


I
I





1-250,000


1131
33.4321


113
33.432
250,000-
500,000


561
16.5681


56
16.568
      •500,000-         750,000-                               NO
       750,000         1,000,000                        -   ANSWER
      	1	1	i	1
                 241               341                 I              1101
              7.1011           10.3551                 i          32.5441
      	1	1	i	i
                 24                34                                 110
              7.101            10.355                             32.544
                                        ROW
                                       SUMS
                          I
                          I              337
                          I          1JO.OOO
                          I
                                        337
                                    100.000
                                     138

-------
26.  Capital Investment for the Plant (not Including capitalized operating or
    maintenance expenses).
         (Planned) 1977
    (1)
Total  Capital Investment
$




I
I
1 _













^ERO
ENTRY


31
0.3881


3
0.888

3
__ — _ _ _— T — — .

131
3.8461
_____ __ T _ .

13
3.846

0


931
27.^151


93
27.515




I
I





1

""-
321 -
9.4671

—
32
9.467
M3
ANSvVFR
________ — T

1881
55.6211
__ _____ T

183
55.621

2


91
2.6631


9
2.663
ROW
SUMS


337
100.000


337
100.000
                                      139

-------
26.  Capital  Investment for the Plant (not Including capitalized  operating or
    maintenance expenses).
                                              (2)
                                           Water Pollution Control
         (Actual) 1971-76                   $	
ENTRY
1
I


I
I

0
1011
29.8821
101
29.882
1
161
16
t.734
2
11
0.2961
1
0.296
                                         NJ              ROW
                                       ANSWER          SUMS
                      51            I         2151        337
                  1.4791            I     63.6091    100.000
                       j ---------- j ---------- 1
                      b                      215         337
                                         63.609     100.000
                                    140

-------
  26.  Capital Investment  for the Plant (not  Including capitalized operating or
(cont)
      maintenance expenses).
                                              (2)
                                       Water Pollution  Control
          (Planned)  1977               $	




I
I




ZERO
ENTRY



0.



0.




3




I
8881


3
888





Q



19.



19.




67
812


67
822




I
I





1


3
0.6Pd


3
0.888

2


I
I








I
I




                                          NO              ROW
                                        ANSWER           SUMS
                        !	j	I
                       II            I         26
-------
   26.  Capital Investment for the Plant (not Including capitalized operating or
(cont)  ma1ntenance expenses).
                                           (3)
                                        Other Environmental  Regulation (State
                                        or Federal)  Impacting Production Processes
            (Actual) 1971-76               $




I
I











ZERO
ENTRY


11
0.296!


I
0.296

3

11
0.29ol
I
0.296

0 I


431 31
12.7221 0.8881



-------
  26.  Capital  Investment for the Plant  (not  Including capitalized operating or
(cont)
      maintenance  expenses).
           (Planned)  1977
            (3)
Other Environmental  Regulation (State
or Federal)  Impacting Production Processes
$




I
I














ZERO
ENTRY


51
1.479!
— T —
1
5
1.479

3

I__.
11
0.2961

I__.
1
0.296

0


261
7.6921


26
7.692


I_

I
I
________ i_




1


21
0.^92 I


2
0.592
NO
AiNiSWFR


3041
R9.941I
__ _____ T

304
89.941

2


I
I




ROW
SUMS


338
100.000


338
100.000
                                          143
       * U S GOVERNMENT PRINTING OFFICE • 1979 311-132/152

-------