vvEPA
           United States
           Environmental Protection
           Agency
            Office of Water Regulations
            and Standards
            Washington, DC 20460
EPA 440/2-84-013
June 1984
           Water
Economic Impact Analysis
of Effluent  Limitations and
Standards for the Inorganic
Chemicals Industry,
Phase II
                      QUANTITY

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         Economic Impact Analysis of
Effluent limitations  Guidelines and Standards
for the Inorganic Chemicals Industry—Phase II
                Prepared for-

     U.S.  Environmental Protection Agency
      Office of Analysis and Evaluation
  Office of Water Regulations and Standards
           Washington, D.C.   20460
              Meta Systems,  Inc
             10 ftolworthy Street
            Cambridge, MA  02138
                  July 1984

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 f
  \      UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

   '                     WASHINGTON, D.C.  20460
     This document  is  an economic impact  assessment of  the  recently

 promulgated  effluent  guidelines.   The  report  is being  distributed to EPA

 Regional Offices and  state pollution control  agencies  and directed to the

 staff  responsible  for writing industrial discharge permits.  The report

 includes detailed  information on  the costs and economic impacts of various

 treatment technologies.  It should be helpful to the permit writer in

 evaluating the economic  impacts on an industrial facility that must comply

 with BAT limitations or water quality standards.

    A limited number of copies of this report are available from the Economic

 Analysis Staff in the Office of Water Regulations and Standards at EPA

 Headquarters:

                   401 M Street, S.W.  (WH-586)

                   Washington,  D.C.  20460

                   (202) 382-5397

This staff economist for this project  is  Josette Bailey (202/332-5382).

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                                Table of Contents
Section
Number

Section 1.  Executive Summary 	
     1.1    Introduction  	
     1.2    Qualitative Economic Assessment 	
     1.3    Methodology 	
     1.4    Effluent Limitations Options and Compliance Costs
     1.5    Results 	
     1.6    Regulatory Flexibility Analysis 	
     1.7    Limits to the Analysis  	
     1.8    Sodium Sulfite Impact Analysis  	
     1.9    Sodium Chloride Impact Analysis 	


Section 2.  Qualitative Economic Assessment 	
     2.1    Introduction  	
     2.2    Plants and Producers  	
     2.3    Economic Profile and Future Trends  	
     2.4    The Cyclic Behavior of the Inorganic
            Chemical Industry 	


Section 3.  Economic Impact Methodology 	
     3.1    Introduction  	
     3.2    Baseline Calculations 	
     3.3    Impact Projections  	
     3.4    Employment  	
     3.5    Foreign Trade Impacts 	
     3.6    New Source Analysis 	
     3.7    Small Business Analysis 	


Section 4.  Effluent Limitations Options and Compliance Costs
     4.1    Introduction  	
     4.2    Treatment Technology Options  	
     4.3    Current Treatment and Treatment Costs 	


Section 5.  Results 	
     5.1    Introduction	
     5.2    Plant Level Impacts 	
     5.3    Product Level Impacts 	
     5.4    Closure 	
     5.5    Employment  	
     5.6    Foreign Trade Impacts 	
     5.7    New Source Analysis 	
 Page
Number

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  2-2
  2-9

 2-19
  3-1
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  3-3
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  3-8
  4-1
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  5-1
  5-1
  5-2
  5-7
  5-7
  5-7
  5-8
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                                Table  of  Contents
                                   (continued)
Section
Number

Section 6.  Regulatory Flexibility Analysis
     6.1    Introduction  .........
     6.2    Definition of a Small Firm  . .
     6.3    Results 	

Section 7.  Limits to the Analysis  ....
     7.1    Introduction  	
     7.2    Data Limitations  	
     7.3    Methodological Limitations  . .
     7.4    Sensitivity Analyses  	
     7.5    Conclusions 	

Section 8.  Sodium Sulfite Impact Analysis
     8.1    Introduction  	
     8.2    Qualitative Information ....
     8.3    Methodology 	
     8.4    Compliance Costs  	
     8.5    Results 	

Section 9.  Sodium Chloride Impact Analysis
     9.1    Introduction	
     9.2    Methodology 	
     9.3    Results-	
Appendix 2A:  Process Descriptions

Appendix 2B:  Regression Equations for Business
              Cycle Analysis

Appendix 3A:  Calculation of Manufacturing Costs

Appendix 3B:  Actual Plant Manufacturing Costs Adjustments

Appendix 3C:  Estimation of Supply Curves, Elasticities,
              and Cost Pass-Through Factors
 Page
Number

  6-1
  6-1
  6-1
  6-2

  7-1
  7-1
  7-1
  7-2
  7-2
  7-5

  8-1
  8-1
  8-1
  8-2
  8-2
  8-3

  9-1
  9-1
  9-1
  9-3
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                            List of Tables and Figures
Table                                                                  Page
Number                                                                Number

Table 1-1.  Summary Statistics for Phase II
            Inorganic Chemicals 	      1-3
      1-2.  Summary of Impacts	      1-5
      2-1.  Plants Producing Phase II Inorganic Chemicals ....      2-3
      2-2.  Phase II Inorganic Chemicals by Producer  	      2-6
      2-3.  D.S. Cadmium Sulfide Production	     2-11
      2-4.  Subcategory Summary:  Cadmium Salts and Pigments  .  .     2-12
      2-5.  Average Annual Producer Price for Cobalt  	     2-12
      2-6.  Subcategory Summary:  Cobalt Salts  	     2-14
      2-7.  Subcategory Summary:  Copper Salts  	     2-15
      2-8.  Subcategory Summary:  Nickel Salts  	     2-17
      2-9.  U.S. Sodium Chlorate:  Capacity and Production  .  .  .     2-18
     2-10.  Subcategory Summary:  Sodium Chlorate 	     2-18
     2-11.  Subcategory Summary:  Zinc Chloride	     2-19
     2-12.  Selected Inorganic Chemicals Price and
            Production Data	"	     2-20
     2-13.  Inorganic Chemicals Industry Data 	  .....     2-21
      4-1.  Current Treatment-in-Place by Option
            for Existing Sources  	      4-4
      4-2.  Wastewater Treatment Cost by Model Plant	      4-5
      4-3.  Example of a Treatment Cost Allocation
            of a Hypothetical Multi-Product Plant  	        4-6
     4-4a.  Level 1 Treatment Costs	      4-8
     4-4b.  level 2 Treatment Costs	      4-9
      5-1.  Manufacturing Costs Increases by Control Level  .  .  .      5-3
      5-2.  Profitability Reduction by Control Level  	      5-4
      5-3.  Price Increases by Subcategory  	      5-5
      5-4.  Production Decreases by Subcategory 	      5-6
      5-5.  Impact Analysis for New Source Performance
            Standards	      5-7
      6-1.  Distribution of High Impact Plants by
            Firm Employment Size	      6-2
      6-2.  Small Business Level 2 Treatment Cost Summary ....      6-3
      8-1.  Plant Level Impacts—Sodium Sulfite Subcategory .  .  .      8-3
      9-1.  Sodium Chloride Model Plant Treatment Costs  	      9-2
      9-2.  NSPS Bnpact Analysis for Sodium Chloride	      9-4
     3A-1.  Summary of Model Plant Costs  	     3A-2
     3B-1.  Hypothetical Calculation of Manufacturing Costs
            for a Multi-Product Plant	     3B-2
     3C-1.  Supply Elasticity and Cost Pass-Though Estimates
            by Subcategory	     3C-3
                                    -iii-

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                          List of Tables and Figures
                                  (continued)
Figure
Number

Figure 2-1.
       2-2.
       2-3.

     .  2-4.
Price-Cost Comparisons 	
Phase II Inorganic Production Trends . .
Inorganics Shipments Compared to
U.S. Industrial Production 	
Inorganic Chemical Profitability Trends
 Page
Number

 2-23
 2-24

 2-25
 2-26
Chart
Number
                                                         Page
                                                        Number
Chart 2-1.  Number of Chemicals Produced by Plants (1979)
                                                          2-9
                                     -iv-

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                                    PREFACE
 This document is a contractor's  study prepared for the Office of Water Regu-
 lations and Standards  of the  Environmetal  Protecton  Agency  (EPA).  The pur-
 pose of the study is  to analyze  the  economic  impact  which could result from
 the application of effluent standards and  limitations guidelines issued
 under Sections 301,  304,  306,  307  and 501  of  the Clean Water Act to the
 inorganic chemicals manufacturing  industry.

 This study supplements the  technical study (EPA Development Document) sup-
 porting the issuance  of these  regulations.  The Development Document surveys
 existing and potential waste treatment control methods and technologies
 within particular industrial source  categories and supports certain stand-
 ards and limitations based  upon  an analysis of the feasibility of these
 standards in accordance with the requirements of the Clean Water Act.  Pre-
 sented 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 th'e effect in terms of product
'price increases, effects upon  production 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 Regulations and  Standards  of EPA.  This report was submitted in ful-
 fillment of Contract No.  68-01-6426  by Meta Systems  Inc and completed in
 October 1983.
                                      -v-

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                                 Section 1
                             Executive Summary


1.1  Introduction

    This study presents the economic effects of the effluent limitations
and standards on the inorganic  chemicals manufacturing industry.  The
study was prepared under the supervision of the Office of Analysis and
Evaluation, U.S. Environmental  Protection  Agency  (the "Agency").  This
section, the Executive Summary, presents brief descriptions of other
sections of the report:

    o   Qualitative Economic Assessment

    o   Methodology

    o   Effluent Limitations Options and Compliance Costs
    o   Results

    o   Regulatory Flexibility  Analysis
    o   Limits to the Analysis

    o   Sodium Sulfite Impact Analysis

    o   Sodium Chloride Impact  Analysis (NSPS)
1.2  Qualitative Economic Assessment

    The Agency is required by  the Settlement Agreement and the Clean Water
Act to issue effluent limitations for the Inorganic Chemicals Manu-
facturing Point Source Category.  This category includes all products
identified under Standard Industrial Classification (SIC) code numbers
2812, 2813, 2816, and 2819.  Regulation of the Inorganic Chemicals Point
Source Category was divided into two phases.  Effluent limitations for
Phase I were promulgated in June 1982; they addressed 60 subcategories and
covered 85 percent of the toxic pollutant discharges from the industry.
Phase II includes six subcategories that consolidate 17 chemicals.

The six subcategories (and 17  chemicals) in Phase II are analyzed here as
nine separate chemical groups:

    1.  Cadmium Pigments
    2.  Cadmium Salts
            cadmium chloride
            cadmium nitrate
            cadmium sulfate
    3.  Cobalt Salts
            cobalt chloride
            cobalt nitrate
            cobalt sulfate

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    4.  Copper Carbonate
    5.  Copper Salts
            copper chloride
            copper iodide
            copper nitrate
    6.  Nickel Carbonate
    7.  Nickel Salts
            nickel chloride
            nickel fluoborate
            nickel nitrate
    8.  Sodium Chlorate
    9.  Zinc Chloride

    These chemicals represent a very small portion of the inorganic
chemicals produced in the U.S.  Thirty-six firms operate the 46 plants
that produce these chemicals.  Both the firms and the plants range  in size
from very small to very large.  Virtually all of the plants also  produce
chemicals other than those examined in this study.

    In addition we analyze the economic impacts of the current regulations
in the sodium sulfite and sodium chloride subcategories.

    The summary statistics of  the subcategories are presented in  Table  1-1.
Sodium chlorate has by far the largest production of the nine groups.   It
has experienced significant  growth in recent years.  Growth of the  other
chemicals has varied, but has  generally been stagnant.
1.3  Methodology

    The economic impact assessment methodology consists of a  baseline
analysis and a subsequent impact analysis.  The initial baseline analysis
provides a basis against which potential impacts are assessed.  Baseline
values are calculated for manufacturing costs, profitability, and product
price without additional treatment costs.

    The extent to which treatment costs have an impact on plants and sub-
categories is determined in a series of steps.  First, costs  of treatment
are estimated for each plant.  The changes in manufacturing costs and
profitability are estimated for each plant and aggregated for each sub-
category.  Price increases and production decreases are also  calculated.

    A plant closure analysis is performed for those plants with large
changes in profitability (i.e., greater than 10 percent).   A  liquidity
test compares annual treatment costs to annual cash flow (before treat-
ment)  at each plant.   Where treatment costs exceed cash flow, a potential
plant closure is projected.  The second step of plant closure analysis is
a solvency test.  The test compares the magnitude of a plant's salvage
value to the present value of the cash flow.  If the discounted cash flow
is less than salvage value, it is worth more to the operator  to sell the
facilities than to continue production.  Hence, a potential closure is
projected.

                                     1-2

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         Table 1-1.   Summary Statistics for Phase II Inorganic Chemicals
              I   Average  I                   I            I  Estimated  I    Baseline
              I    Price   I                   I   Number    I  Demand     I   Production
 Subcategory  I(1982 $/kg)I   Major End Uses  I  of Plants  I Elasticity  I (Metric ton/yr)
Cadmium
  Pigments
9.71
Cadmium Salts   5.71
Cobalt Salts   18.26
Copper
  Carbonate     2.62
Copper Salts    2.99
Plastics, paint,
glass colorant

Printing, battery
electrolyte, metal
finishing

Electroplating,
glazes, inks,
pigments, dyes
            Agricultural,         6
            textiles,  paints

            Colorant,  battery   10
            electrolyte,
            feed additive
              -0.1
                                              -0.3
                                             -0.4
                                  -0.2
                                  -0.3
2,860
                            618
                            871
                          4,365


                          1,990
Nickel
  Carbonate
Sodium
  Chlorate
6.67
Nickel Salts    2.77
0.46
Zinc Chloride   0.91
Pigments, electro-   7
plating
            Electroplating,
            batteries,  glass
            colorant
Pulp bleach,
chlorate inter-
mediate, herbicide

Deodorant,
disinfectant,
fabric sizing
                    12
13
              -0.15
              -0.2
                                                             -0.15
                                             -0.2
  924
7,443
                                                       312,300
                         39,714
                                     1-3

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Employment and foreign trade  impacts are assessed' by further inter-
pretation of the closure analysis.  The possibility of disproportionate
impacts on small business is  assessed in a separate small business
analysis.  Impacts on new sources are analyzed by examining model plants
with proposed treatment options.
1.4  Effluent Limitations Options and Compliance Costs

    Section 4 discusses the effluent regulations, the wastewater treatment
options that were analyzed, 'and  the costs associated with those options.

    The treatment technologies for all subcategories except sodium
chlorate are:

    Level 1:   Alkaline precipitation, clarification, sludge dewatering,
               pH adjustment.

    Level 2:   Filtration of clarified wastewater from Level 1.

For sodium chlorate plants, the  treatment technologies are:

    Level 1:   Chromium reduction followed by lime precipitation and
               clarification.  Reduction follows to destroy residual
               chlorine.

    Level 2:   Filtration of clarified wastewater from Level 1.

    Plant level treatment costs  are estimated from model plant costs and
from available production, wastewater flow, and existing treatment-in-
place data except where plant-specific costs are provided by EPA.   The
wastewater treatment costs are summarized in Table 1-2.
1.5  Results

    The results of the impact analysis are presented under the subheadings
of plant level impacts,  product level impacts, closure, employment
impacts, foreign trade impacts, and new source performance standards.  A
summary of results is presented in Table 1-2.
1.5.1  Plant Level Impacts

    The plant level impacts examined are 1) the ratio of treatment costs
to manufacturing costs and 2) the ratio of treatment costs to net revenue
(i.e., the change in profitability).  At both Level 1 and Level  2 costs,
five plants have treatment costs in excess of 2 percent of manufacturing
costs.  At Level 2,  the  average change in profitability is 4.4 percent for
direct dischargers and 1.7 percent for indirect dischargers.  Six plants
have treatment costs greater than 10 percent of net revenues. These six
plants are examined further in the closure analysis.

                                     1-4

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                         Table 1-2.   Summary of Impacts

Total number of plants
Number of Plants
Incurring Cost
Investment Cost
($000)
Total Mnual Cbst
($000)
I Direct
1 Level 1
21
8
3,917
1,974
Dischargers I
1 Level 2 |
21
12
4,799
2,337
Indirect
Level 1
8
5
868
410
Dischargers
1 Level 2
8
6
1,116
501
Change in Return
  on Investment {%)

Price Increase (%)

Closures
3.75
0.81
0
4.44
0.96
o
1.37
0.81
0
1.67
0.96
0
                                      1-5

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1.5.2  Product Level Impacts

    Impacts to products are measured in terms of changes in price and
production volume.   Price increases range from 0.01 to 2.40 percent for
Level 2 controls; the average for all subcategories is 0.96 percent.  The
prices for nickel carbonate show the greatest change and those for cobalt
salts show the smallest change.  Production decreases are small,  ranging
from 0.003 to 0.414 percent for Level 2.
1.5.3  Closure

    Closure potential is identified with a liquidity test and a' solvency
test.  In neither case is a closure predicted.
1.5.4  Employment

    No loss of jobs is expected  to result from compliance with these
treatment requirements.
1.5.5  Foreign Trade Impacts

    No negative foreign trade  impacts are expected to result from com-
pliance with these treatment requirements.
1.5.6  New Source Standards

    The analysis of new source standards  (new source performance
standards, NSPS, and pretreatment standards for new sources,  PSNS)
considers that all new sources will have  treatment requirements equal  to
the BAT/PSES treatment option for existing sources.  An analysis of  these
costs has been performed for the model plants in each subcategory.   The
analysis covers both greenfield sites and major modifications to existing
facilities.  The exception is sodium chloride where alternative
technologies are considered.

    As found in the analysis of existing plants, the impacts  are generally
quite small.  They are not predicted to present barriers to entry for  new
plants in any of the subcategories.

    As part of the proposed regulations, pretreatment standards for  new
sources  (PSNS)  are being proposed for twelve additional subcategories.
The PSNS requirement is zero discharge of process wastewater.  In each of
these subcategories, existing dischargers are subject to, and meeting  zero
discharge effluent limitations.  No cost disadvantages or other impacts
are expected from these new PSNS.
                                     1-6

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1.6  Regulatory Flexibility  Analysis

    The differential impact  on  small businesses is analyzed at Level 2 for
direct and indirect dischargers.  Small businesses are defined as corpora-
tions employing less than 1,000 persons.  No closures are predicted in
this group.  No disproportional burden is detected.
1.7  Limits to the Analysis

    The analysis of the economic impact of treatment costs on the
inorganic chemicals industry  is limited by the data.  Many plant level
economic characteristics are  not available, and model plant information is
necessary to supplement the actual plant data.  The resulting plant level
estimates of manufacturing costs, treatment costs, and the various finan-
cial ratios that use these values may not be accurate.  To protect against
the failure to identify significant impacts, conservative (i.e., worst-
case scenarios)  assumptions are made and sensitivity analyses are
performed.

    The sensitivity analyses  test alternative assumptions for interest
rates, cost pass-through,  manufacturing costst and treatment costs.  The
results of the impact analysis are not sensitive to reasonable variations
in the critical assumptions.  No reasonable variation in interest rates,
cost pass-through or treatment costs causes major changes to the report's
original conclusions.
1.8  Sodium Sulfite Impact Analysis

    As part of the rulemaking for Inorganic Chemicals,  Phase  II, the
Agency is including revisions to existing BAT and NSPS  limitations in the
sodium sulfite subcategory.  Section 8 of this report addresses the impact
of compliance costs for existing and new dischargers in this  sub-
category.  Results of  the cost analysis suggest that the existing zero
discharge limitations  are not economically achievable.   The results
support revision of the existing requirements to allow  discharge of
process wastewater.
1.9  Sodium Chloride  Impact Malysis

    In conjunction with  the Phase II rulemaking EPA reexamined the zero
discharge effluent limitations and performance standards in  the sodium
chloride subcategory.  The agency is revising the BAT limitations because
of the lack of toxic pollutants in the BPT discharge.   Section 9 of this
report addresses the  impact of compliance costs for new dischargers in
this subcategory.  Several alternative treatment technologies are examined
which achieve zero discharge of new sources.  The analysis suggests that
zero discharge limitations do not result in any barriers to  entry for new
sources.

                                     1-7

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                                  Section  2

                       Qualitative  Economic  Assessment
2.1  Introduction

    The Agency is required by the Settlement Agreement and the Clean Water
Act to issue effluent limitations for the Inorganic Chemicals Manufact-
uring Point Source category.  This category includes all products identi-
fied under Standard Industrial Classification (SIC) code numbers 2812,
2813, 2816, and 2819.   Regulation of the Inorganic Chemicals Point Source
category was divided into two phases.  Effluent limitations for Phase I
were promulgated in June 1982 V.  They addressed 60 subcategories and
covered 85 percent of the toxic pollutant discharges from the industry.
Phase II initially included 124 subcategories,  many of which are excluded
from further national regulation development under the provisions of
Paragraph 8 of the Settlement Agreement.  The remaining 17 chemicals are
the focus of the Phase II study.

    This section presents an industrial and economic profile of the
inorganic chemicals included in the Phase II economic impact analysis.
The 17 chemical products are grouped into six subcategories, with three
subcategories—Cadmium Compounds, Copper Salts  and Nickel Salts—further
divided.  In this report, the 17 chemicals are  divided into nine chemical
groups:

     1. Cadmium Pigments
     2. Cadmium Salts
            cadmium chloride
            cadmium nitrate
            cadmium sulfate
     3. Cobalt Salts
            cobalt chloride
            cobalt nitrate
            cobalt sulfate
     4. Copper Carbonate
     5. Copper Salts
            copper chloride
            copper iodide
            copper nitrate
     6. Nickel Carbonate
  I/ 47 FR 28260.

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     7. Nickel Salts
            nickel chloride
            nickel fluoborate
            nickel nitrate

     8. Sodium Chlorate

     9. Zinc Chloride

    In addition we analyze the economic impacts of the current regulations
in the sodium sulfite and sodium chloride subcategories.               ,
2.2  Plants and Producers
    In terms of both value added and number of plants,  Phase  II chemicals
represent a very small portion of the inorganic chemical industry.   For
example, according to the Annual Survey of Manufacturers in 1980,  inor-
ganic pigments represent 0.95 percent of the total inorganic  chemical
market, and the inorganic pigments included in Phase II are a small por-
tion of this 0.95 percent market.  The SIC category for inorganic
chemicals not elsewhere classified (2819)  includes some of the Phase II
chemicals and represents about 7.9 percent of the value added in the
inorganic chemical industry.  There are 564 establishments included in the
SIC 2819 category.  This analysis concerns 46 plants,  or about 8 percent
of the establishments in the SIC 2819 category.

    Table 2-1 lists the producers of Phase II compounds.  The majority of
these plants produce a variety of chemicals,  only some of which fall into
Phase II subcategories.  Table 2-2 gives chemical-specific information on
producers and also indicates the relative importance of Phase II chemicals
to the plants.  In many cases the Phase II chemical production is  not the
major production activity at the plant.

    Thirty-six firms operate the 46 plants which produce the  compounds
included in this analysis.   The Richardson-Merrell plant in Phillipsburg,
New Jersey produces 13 of the 17 Phase II chemicals.  These 13 chemicals
are 11 percent of the roughly 120 chemicals produced at that  plant.  Gulf
Oil's Cleveland, Ohio plant produces 10 compounds,  which account for one-
third of the 30 chemicals produced at that plant.  The  plant  operated by
The Shepard Chemical Company in Cincinnati, Ohio produces 9 of the  Phase
II chemicals, and McGean Chemicals in Cleveland, Ohio  produces seven.
Cadmium pigments and sodium chlorate are manufactured  exclusively  by
plants that produce no other Phase II inorganic chemicals.  As Table 2-2
and Chart 2-1 indicate, most plants produce several chemical  compounds.
                                      2-2

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            Table 2-1  Plants Producing Phase II  Inorganic  Chemicals
  SUBCATEGORY
        PLANTS
Cadmium
 Pigments
ASARCO Inc., Denver, CO
Ciba-Geigy Corp., Glens Falls, NY
H. Kohnstamm & Co.,  Inc., Newark,  NJ
Gulf Oil  (Harshaw),  Louisville, KY
SCM Corp., Baltimore, MD
Cadmium
 Salts
C.P. Chemicals, Sumter, SC
Hall Chemical Co., Arab, AL
Gulf Oil  (Harshaw), Cleveland, OH
Richardson-Merrell, Phillipsburg, NJ
Shepard Chemical Co., Cincinnati, OH
United Catalysts Inc., Louisville, KY
W.A. deary Corp., Somerset, NJ
Cobalt
 Salts
Alfa Products, Danvers, MA
C.P. Chemicals, Sewaren, NJ
Gulf Oil  (Harshaw), Cleveland, OH
Hall Chemical Co., Arab, AL
Richardson-Merrell  (J.T. Baker),
  Phillipsburg NJ
Hall Chemical Co., Wickliffe, OH
McGean Chem., Cleveland, OH
Mooney Chems., Franklin, PA
The Shephard Chem. Co., Cincinnati, OH
United Catalysts Inc., Louisville, KY
Copper
 Carbonate
C.P Chemicals, Inc., Sewaren, NJ
Cities Services, Copperhill, TN
Kocide Chemical Co., Houston, TX
Mineral Research Development, Concord, NC
North American Philips, Brea, CA
Richardson-Merrell, Philipsburg, NJ
The Shepard Chemical Co., Cincinnati, OH
United Catalysts, Louisville, KY
                                      2-3

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             Table 2-1  Plants Producing  Phase  II  Inorganic  Chemicals
                                    (continued)
  SUBCATEGORY
        PLANTS
Copper
 Salts
Ajay Chemical Co., Powder Springs, GA
C.P. Chemicals, Powder Springs, GA
Chemetals Corp., Curtis Bay, MD
Deepwater Chem. Co.,  Irvine CA
Gulf Oil  (Harshaw), Cleveland, OH
McGean Chemical Co.,  Cleveland, OH
Mineral R & D Corp.,  Concord, NC
Richardson-Merrell  (J.T. Baker),
  Phillipsburg, NJ
The Shepard Chem., Co., Cincinnati,  OH
Southern California Chemical Co.,
  Garland, TX
United Catalysts, Louisville, KY
Nickel
 Carbonate
C.P. Chemicals, Inc., Sewaren, NJ
Gulf Oil, Cleveland, OH
Hall Chemical Co., Wickliffe, OH
McGean Chemical Co., Cleveland, OH
Richardson-Merrell, Phillipsburg, NJ
The Shepard Chemical Co., Cincinnati, OH
United Catalysts, Inc., Louisville, KY
Nickel
 Salts
Alfa Products, Danvers, MA
Allied Chemical, Claymont, DE
C.P. Chems., Inc., Sewaren, NJ
C.P. Chems., Sumter, SC
Gulf Oil  (Harshaw), Cleveland, OH
Hall Chemical Co., Arab, AL
Hall Chemicals, Wickliffe, OH
Harstan Chemicals, Brooklyn, NY
McGean Chemical Co., Cleveland, OH
Richardson-Merrell  (J.T. Baker),
  Philipsburg, NJ
The Shepard Chem., Co., Cincinnati, OH
United Catalysts Inc., Louisville, KY
                                      2-4

-------
             Table 2-1  Plants Producing Phase II  Inorganic Chemicals
                                    (continued)
  SUBCATEGORY                             PLANTS
Sodium                            Brunswick Pulp & Paper, Brunswick, GA
 Chlorate                         ERGO  Industries, Monroe, LA
                                  Georgia-Pacific Corp., Plaguemine, LA
                                  Huron Chems. of Am., Ridgewood, NC
                                  Kerr-McGee Corp., Hamilton, MS
                                  Kerr-McGee Corp., Henderson, NV
                                  Occidental Chemical Corp.  (Hooker Chem),
                                    Columbus, MS
                                  Occidental Chemicals Corp., Taft, LA
                                  Olin Corp., Mclntosh, AL
                                  Pacific Eng. & Production, Henderson, NV
                                  Pennwalt Corp., Calvert City, KY
                                  Pennwalt Corp., Portland, OR
                                  Pennwa11 Co rp, Tacoma, WA

Zinc                              C.P. Chemicals, Sewaren, NJ
 Chloride            .             C.P. Chemicals, Sumter, NJ
                                  DuPont, Cleveland, OH
                                  Madison Indust., Inc., Old Bridge, NJ
                                  Mallinckrodt, Inc., St. Louis, MO
                                  Mineral Res, s Dev. Corp., Freeport, TX
                                  Richardson-Merrell  (J.T. Baker),
                                    Philipsburg, NJ.

Source:   SRI 1979 Directory of Chemical Producers, EPA.
                                      2-5

-------
Table 2-2.  Phase II Inorganic Chemicals by  Producer
FIRM AND PLANT
Ajay Chemical Co., Powder Springs, GA
Alfa Products, Danvers, MA
Allied Chemical Co., Claymont, DE
Asarco, Inc., Denver, CO
Brunswick Pulp and Paper, Brunswick, GA
Ciba-Giegy Corp., Glens Falls, NY
Chemetals Corp., Curtis Bay, MD
Cities Services, Copperhill, TN
Cleary Corp., Somerset, NJ
C.P. Chemicals, Inc., Powder Springs, GA
C.P. Chemicals, Inc., Sewaren, NJ
C.P. Chemicals, Sumter, SC
Deepwater Chemicals, Carson, CA
DuPont, Cleveland, OH
ERCO Industries, Monroe, LA
Georgia Pacific, Plaguemine, LA
Gulf Oil, Cleveland, OH
(Harshaw)
Gulf Oil, Elyria, OH
Gulf Oil, Louisville, KY
TOTAL
PHASE TOTAL
PHASE II CHEMICALS
II CHEMICALS PRODUCED
CHEMICALS PRODUCED (Approximate)
Copper Iodide
Nickel Fluoborate
Cobalt Chloride
Nickel Chloride
Nickel Fluoborate
Cadmium Pigments
Sodium Chlorate
Cadmium Pigments
Copper Chloride
Copper Carbonate
Cadmium Chloride
Copper Chloride
Cobalt Chloride
Cobalt Nitrate
Cobalt Sulfate
Copper Carbonate
Nickel Carbonate
Nickel Chloride
Zinc Chloride
Cadmium Nitrate
Nickel Nitrate
Zinc Chloride
Copper Iodide
2inc Chloride
Sodium Chlorate
Sodium Chlorate
Cadmium Chloride
Cadmium Sulfate
Cobalt Chloride
Cobalt Nitrate
Cobalt Sulfate
Copper Chloride
Nickel Carbonate
Nickel Chloride
Nickel Fluoborate
Nickel Nitrate
Copper Nitrate
Cadmium Pigments
1
2
2
1
1
1
1
1
1
1
7
3
1
1
1
1
10
1
1
5
95
10
19
3
NA
15
14
1
8
41
4
22
17
1
10
30
31
30
                        2-6

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Table 2-2.  Phase II Inorganic Chemicals by Producer
                     (continued)
                                             TOTAL
                                             PHASE       TOTAL
FIRM AND PLANT
Hall Chemical Co., Arab, AL
Hall Chemical Co., Wickliffe, OH
Harstan Chemicals, Brooklyn, NY
Huron Chemicals, Ridgewood, NC
Kerr-McGee, Hamilton, MS
Kerr-McGee, Henderson, NV
Ifocide Chemical Co. , Itouston, , TX
H. Kohnstamm & Co., Inc., Newark, NJ
Madison Industries, Old Bridge, NJ
Mallinckrodt, Inc., St. Louis, MO
McGean Chemical Co., Cleveland, OH
Mineral Research & Development,
Concord, NC
Mineral Research & Development,
Freeport, TX
Mooney Chemicals, Inc., Franklin,, PA
North ftnerican Philips, Brea, CA
Occidental Chemical Co., Columbus, MS
Occidental Chemical Co., Taft, LA
01 in Corp., Mclntosh, AL
Pacific Engineering & Production Co.,
Henderson, NV
Pennwalt Corp., Calvert City, KY
Pennwalt Corp., Portland, OR
Pennwalt Corp., Tacoma, WA
PHASE I I
II CHEMICALS
CHEMICALS PRODUCED (A
Cadmium Nitrate
Cobalt Nitrate
Cobalt Sulfate
Nickel Nitrate
Cobalt Chloride
Cobalt Sulfate
Nickel Carbonate
Nickel Chloride
Nickel Nitrate
Nickel Chloride
Nickel Fluoborate
Sodium Chlorate
Sodium Chlorate
Sodium Chlorate
Copper Carbonate
Cadmium Pigments
Zinc Chloride
Zinc Chloride
Cobalt Chloride
Cobalt Nitrate
Cobalt Sulfate
Copper Chloride
Nickel Carbonate
Nickel Chloride
Nickel Nitrate
Copper Carbonate
Copper Nitrate
Zinc Chloride
Cobalt Sulfate
Copper Carbonate
Sodium Chlorate
Sodium Chlorate
Sodium Chlorate
Sodium Chlorate
Sodium Chlorate
Sodium Chlorate
Sodium Chlorate
4
5
2
1
1
1
1
2
1
1
7
2
1
1
1
1
1
1
1
1
1
1
CHEMICALS
PRODUCED
pproximate
NA
NA
30
1
6
9
17
3
6
100
28
30
3
70
10
NA
6
5
3
15
9
7
                      2-7

-------
                Table 2-2.  Phase II'Inorganic Chemicals by Producer
                                     (continued)
FIRM AND PLANT
  PHASE
    II
CHEMICALS
  TOTAL
  PHASE       TOTAL
   II       CHEMICALS
CHEMICALS   PRODUCED
PRODUCED  (Approximate)
Richardson-Merrell, Phillipsburg, NJ
    (J. T. Baker)
Cadmium Chloride
Cadmium Nitrate
Cadmium Sulfate
Cobalt Chloride
Cobalt Nitrate
Cobalt Sulfate
Copper Carbonate
Copper Chloride
Copper Nitrate
Nickel Carbonate
Nickel Chloride
Nickel Nitrate
Zinc Chloride
                                                                  12
                100
SCM Corp., Baltimore, MD
Cadmium Pigments
Shepard Chemical Co., Cincinnati, OH
Cadmium Nitrate
Cobalt Chloride
Cobalt Nitrate
Cobalt Sulfate
Copper Carbonate
Copper Iodide
Copper Nitrate
Nickel Carbonate
Nickel Nitrate
                                                                             80
So. Cal. Chemicals Co. Inc., Garland, TX   Copper Chloride
                                 NA
United Catalysts Inc., Louisville, KY
Cadmium Nitrate
Cobalt Nitrate
Copper Carbonate
Copper Nitrate
Nickel Carbonate
Nickel Nitrate
                                                                             40
NA:  Information not available.
Source:  SRI 1979 Directory of Chemical Producers, EPA.
                                      2-8

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                                     Chart 2-1

                   Number of Chemicals Produced by Plants (1979)
         30

         25

Plants   20
in
Study    15

         10

          5
           15
10
               Over 100  99-50     49-25     24-10      9-2
                         Number of Chemicals produced.

Source:  SRI 1979 Directory of Chemical Producers


2.3  Economic Profile and Future Trends

    The economic profile and future trends for  each  chemical were deter-
mined through public documents.   In the following  sections, baseline
prices are expressed in second quarter 1983 dollars  ($1983 Q2).  Appendix
2A provides a brief description of the chemical processes by which  the
chemicals are produced.


2.3.1  Cadmium Salts and Pigments

    There are at least eight commercially important  cadmium compounds
including the oxide, chloride, sulfate, nitrate, hydroxide, red pigments,
yellow pigments, and various organic cadmium salts.   Five of these  for
which there is economic data—chloride, nitrate, sulfate, cadmium red and
cadmium yellow—are included in the present study.

    There are many other inorganic chemicals that  can substitute for
cadmium salts in the various end-use markets.   However,  in the paints and
pigments end-uses, other inorganics lack the heat  stability of cadmium
and, in most cases, the brilliance in colors.   Zinc  can  be substituted for
cadmium in electroplating,  except when the plate must be exceptionally
thin, or when solderability is important.   Lead-acid batteries are  the
lowest cost substitute for  cadmium batteries, but  they lack dependability
and longevity;  therefore the demand for cadmium for  batteries should
remain strong.   For low-melting point alloys, a number of other metals can
be used.

                                      2-9

-------
    2.3.1.1  Cadmium Chloride

    Three firms are known to produce cadmium chloride.  The major uses
include:  metal finishing, photo copying, printing, dyeing and catalysis.
The price of cadmium chloride, as reported by The Chemical Marketing
Reporter between 1978 and 1982 averaged about $5.65/kg (in second quarter
1983 dollars).  The cadmium chloride metal finishing bath, because it can
be used in place of cyanide-based baths, is expected to increase its share
of the metal finishing market in the next 20 years.
    2.3.1.2  Cadmium Nitrate

    Five firms are known to produce cadmium nitrate.   Cadmium nitrate is
the preferred starting material for the active material in nickel-cadmium
and silver-cadmium alkaline storage batteries.  It is also used  in  color-
ants for the ceramics industry and in combination with magnesium as a
flash powder.  The median CMR price was $4.80/kg.  The demand for cadmium
compound batteries is expected to be strong in coming years and  the demand
for cadmium nitrate is thus expected to increase.
    2.3.1.3  Cadmium Red

    Cadmium red is produced by at least two firms.   The pure  red  pigment,
cadmium selenide, is produced by reacting cadmium sulfate with  selenium.
It is used in various pigments ranging from orange through maroon.   The
median price reported in CMR between 1978 and 1982 was $9.70/kg but  the
many different grades in color shades vary in price.  Cadmium red's  market
is tied directly to the markets of the products that it colors.  It  is
expected to grow over time because of cadmium red's superior  qualities as
a colorant.
    2.3.1.4  Cadmium Sulfate

    Cadmium sulfate is produced by several firms as  intermediate  to
cadmium pigments.  Two other firms are known to produce cadmium sulfate as
a final product.  Cadmium sulfate solution is the electrolyte  in  standard
cells such as the Weston cell and is used industrially as  an alternative
to the cadmium cyanide solution used in electroplating baths.   It is also
used in pigments, medicine vacuum tubes and flourescent screens.   The
median CMR price was $7.00/kg.  That cadmium sulfate can replace  cyanide
electroplating baths implies growth over the next few decades.
                                     2-10

-------
     2.3.1.5   Cadmium Yellow

     Cadmium yellow  (cadmium sulfide) occurs naturally but-is also made
commercially  by passing hydrogen sulfide gas into a solution of cadmium
salt acidified with hydrochloric acid.  An estimated four firms produce
cadmium sulfide, and most of this is used for pigments.  The main use for
these pigments is in the plastics industry where over 1,000 tons (measured
by cadmium content) were used in 1976.  This amount represents 75 percent
of all cadmium pigments used in that year.  Additional colorant uses
include:  paints, soaps, rubber, paper, glass, printing inks, ceramic
glazes, textiles and the blue color in fireworks;

     Although  Table 2-3 shows that production of cadmium sulfide declined
over 65 percent between 1973 and 1981, a recent entry into the market is a
sign that this trend has changed.  The outlook for cadmium yellow is,
therefore, stable.
                   Table 2-3.   U.S. Cadmium Sulfide Production
                         (Metric Tons, Cadmium Content)
       Year
Production
Year
Production
1971
1972 .
1973
1974
1975
1976
1
1,230
1,493
1,555
1,194
1,086
884

1977
1978
1979
1980
1981

i 1
774
698
813
801
527


Source:  U.S. Bureau of Mines:  Mineral Facts and Problems,  1980.
    2.3.1.6  Cadmium Salts and Pigments Summary  Discussion.

    Table 2-4 presents the summary statistics  for  the  cadmium compounds
subcategory.  Production of cadmium salts and  pigments is currently light
and utilizes only 25 percent of subcategory capacity.   The chemical groups
are expected to grow over the next decade.   The  baseline prices for the
subcategory range from $4.80/kg to $9.70/kg.   The  demand elasticities for
these chemicals and the other chemicals in  this  analysis have been
estimated from information on market growth and  competition  in the
different end-use sectors.
                                     2-11

-------
           Table  2-4.   Subcategory  Summary:  Cadmium Salts and Pigments
               Total Subcategory Production: 3,478 metric tons/year
                     Subcategory Capacity Utilization:  25%
1
1
Chemical 1
Cadmium
Pigments
1
Cadmium
Chloride
1
Cadmium
Nitrate
1
Cadmium
Sulfate
Baseline 1
Price I
($1983 Q2) I
$9.70Ag
1
$5.65/kg
1
$4.80/kg
1
$7.00/kg
1
1
1
Major End-Uses 1
plastics
paint
glass colorant
metal finishing
printing
photo copying .
alkaline storage
batteries
ceramic colorant .
electroplating
battery electrolyte ,
Number of
Plants
5
3
5
2
1
I Demand
1 Elasticity
-.1
!
-.3
1
-.1
1
1 -2
Sources:  Chemical Marketing Reporter, 1978-82.
          Effluent Guidelines Division, EPA, 1983.
          Meta Systems, Inc.
2.3.2  Cobalt Salts

    Reported domestic consumption of cobalt decreased 12 percent overall
between 1977 and 1980.  The decline in consumption can be attributed to
cobalt's rapidly rising price which has encouraged substitution, and
conservation by consumers.  Table 2-5 shows cobalt's price increase from
$7.63Ag in 1974 to $55/kg in February 1980.
            Table 2-5.  Average Annual Producer Price for Cobalt   —
                               (dollars per kg)
                                                                   I/
    Year
Price
Based on Constant
   1978 Dollars
1974
1975
1976
1977
1978
1979
1980
7.63
8.77
9.79
12.30
25.41
54.17
1 55'°° 1
9.98
10.49
11.13
13.20
25.41
49.79
46.46
   ±/ Prices are weighted averages based on African Metals Corporation
price list.

Source:  U.S. Bureau of Mines:  Mineral Facts and Problems, 1980.

                                     2-12

-------
     The SRI  Chemical Bionomics Handbook for 1981 estimates that demand for
 superalloys  and cobalt-rare earth magnets in the auto industry should keep
 cobalt salt  demand strong in these end-uses.  Demand for cobalt salts is
 projected to be generally constant.  However,  it will be stronger  for
 ceramics and glass uses with a probable growth from 1.63 million pounds in
 1978 to 5 million pounds in the year 2000.

     The major cobalt salts included in this study are cobalt chloride,
 cobalt nitrate and cobalt sulfate.
     2.3.2.1  Cobalt Chloride

     Cobalt chloride is produced by seven firms.   End-uses for cobalt
 chloride include:  electroplating, inks and dyes, animal feed supplements,
 catalysis, and numerous laboratory uses.  The median CMR price was
 $25.40/kg (in second quarter 1983 dollars).  Prices have fluctuated quite
 widely over the past few years.
     2.3.2.2  Cobalt Nitrate

     Cobalt nitrate is produced by seven firms;   The  most common end-uses
are  in glass and porcelain coloring and as a laboratory reagent.  The
median CMR price was $15.90/kg.
    2.3.2.3  Cobalt Sulfate

    Eight firms produce this compound.   The  most common end-uses are
similar to the other cobalt salts:   pigments and glazes, additives for
soil and animal feeds,  and as a  catalyst.  The median CMR price was
$16.80/kg.
    2.3.2.4  Cobalt Salts Summary  Discussion

    Table 2-6 presents the summary statistics for this subcategory.
Cobalt salts are produced in  very  small quantities, less than 1,400 metric
tons annually.   All three of  the Phase II cobalt salts are used largely as
pigments and are expected to  maintain their current level of production.
These three salts are  very expensive with prices ranging from $15.9/kg to
$25. 4/kg.
                                     2-13

-------
                 Table 2-6.   Subcategory Summary:  Cobalt Salts
              Total Subcategory Production:   871 metric  tons/year
                Subcategory Capacity Utilization:  Not Available
1
1
Chemical 1
Cobalt
Chloride
1
Cobalt
Nitrate .
Cobalt
Sulfate .
Baseline 1
Price I
($1983 Q2) I
$25.40Ag
I
$is.90Ag
1
$i6.80Ag
1
1
1
Major End-Uses 1
electroplating
inks
dyes (
glass and porcelain
colorant ,
pigments
glazes .
Number of
Plants
7
7
8
1
1 Demand
1 Elasticity
-.4
I
-.4
1
-.3
I
Sources:  Chemical Marketing  Reporter 1978-82.
          Effluent Guidelines Division, EPA, 1983.
          Meta Systems,  Inc.
2.3.3  Copper Salts

    Copper is widely distributed through the world and is one of the trace
metals essential to life.   In  sufficiently large quantities, however,
copper can be poisonous and for many generations copper salts have been
used as fungicides.

    Industrially important copper compounds number in the hundreds.
Copper salts, however,  are a minor part of total production compared to
other copper compounds.  The four copper salts included in this study are
copper carbonate, copper chloride, copper iodide, and copper nitrate.
    2.3.3.1  Copper Carbonate

    Copper carbonate is  produced by eight firms.  The major uses of copper
carbonate are diverse and include:  agricultural uses, paints, catalysts
for curing rubber,  corrosion inhibitors, textiles and organic reactors.
The median _CMR price between 1978 and 1982 was $2.60/kg (in second quarter
1983 dollars).
    2.3.3.2  Copper Chloride

    Copper chloride is produced by five domestic firms and has a  wide
range of uses:  as a battery electrolyte, lubricant, ceramic decolorizer,
stabilizer in nylon manufacture, catalyst in olefins manufacture, flame-
proofing agent and wood preservative.  It is also used in textile bleach,
soldering fluxes and pigments and dyes.  The median CMR price was $2.20/kg.
                                     2-14

-------
     2.3.3.3  Copper  Iodide

     Copper iodide is produced by three firms and is used in the manu-
facture of photographic emulsions and conductive transparent films, as a
catalyst with olefins, as a promoter in cloud seedings and as an additive
in animal feeds and table salt.  Its price, quoted by a producer, is
roughly $21.00/kg.
    2.3.3.4  Copper Nitrate

    Copper nitrate is produced by five firms.  It has wide applications in
ceramic color, as a mordant in dyeing, as a catalyst in solid rocket
fuels, as a drilling mud disperant, as an agent to reduce carcinogenic
gases in tobacco smoke, and as a corrosion inhibitor.  CMR reports indi-
cated a baseline price of $1.04/kg.
    2.3.3.5  Copper Salts Summary Discussion

    Table 2-7 presents the summary statistics for copper salts.   The Phase
II copper salts make up a very small portion of overall copper demand
end-uses and their demand is expected to grow-very little over the next
two decades.  Prices within the subcategory range from $1.04/kg  to
$21.00/kg.  Production capacity is utilized at about 30 percent.

                 Table  2-7.   Subcategory  Summary:  Copper  Salts
             Total Subcategory Production:  6,345 metric tons/year
                    Subcategory Capacity Utilization:   30%
1
1
Chemical !
Copper
Carbonate
!
Copper
Chloride
1
Copper
Iodide
1
Copper
Nitrate
I
Baseline I
Price I
($1983 Q2) 1
$2.60A9
1
$2.2C/kg
1
$21.00/kg
1
$1.04/kg
1
1
1 Number of
Major End-Uses 1 Plants
agricultural 8
textiles
paints .
battery electrolyte 5
pigment
dye
textile bleach
photographic emulsions 3
olefin catalyst
feed additive .
ceramic colorant 5
dye mordant
rocket fuel .
1
1 Demand
1 Elasticity
-.2
1
-.2
!
-.3
!
-.2
1
Sources:   Chemical Marketing Reporter,  1978-32.
          Effluent Guidelines Division,  EPA,  1983.
          Meta Systems,  Inc.
                                     2-15

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 2.3.4   Nickel  Salts

     There are  at  least 10 commercially important nickel compounds
 including the  oxide, sulfate, nitrate, carbonate, hydroxide, and fluo-
 borate  of nickel.  Four of these for which there is economic data are
 included  as  Phase II chemicals:  the nitrate, chloride, carbonate, and
 fluoborate.

     Nickel salts  are primarily used in nickel electroplating and as an
 intermediate in the manufacture of nickel catalysts.  Nickel salts can
 also be used as an alternative to cadmium and cobalt salts for petro-
 chemical  hydrogenation, desulfurization, and as denitrogenation
 catalysts.   Nickel is sometimes used as a catalyst with other elements
 (primarily tungsten and molybdenum) when high concentrations of nitrogen
 and sulfur are present in petroleum fractions and distillates.
     2.3.4.1  Nickel Carbonate

     Seven firms produce nickel carbonate.  It is used in the manufacture
of catalysts, in the preparation of colored glass, in pigments, and as a
neutralizing compound in nickel electroplating solutions.  It also is used
in the preparation of many specialty nickel compounds.  The CMR median
price is $6.70Ag-
     2.3.4.2  Nickel Chloride

     Seven firms produce nickel chloride.  Nickel chloride is used as  a
reagent in a variety of reactions used to form compounds of nickel and  in
the  electroplating industry.  The median CMR price is $3.30/kg.
    2.3.4.3.  Nickel Fluoborate

    Four firms produce nickel fluoborate.   It is used as an  electrolyte  in
specialty high speed nickel plating.  The  median CMR price is  $3.00/kg.
    2.3.4.4  Nickel Nitrate

    Eight firms produce nickel nitrate.   Nickel nitrate  is  an  intermediate
in the manufacture of nickel catalysts.   It is important in the manufac-
ture of nickel-cadmium batteries.   It is also used  as  a  glass  colorant and
in nickel plating.  The median CMR price is $2.20/kg.  Because of  its use
in nickel-cadmium batteries, a growing commodity, the  production of nickel
nitrate can be expected to increase over the next decade.
                                     2-16

-------
     2.3.4,5   Nickel Salts  Summary  Discussion

     Table 2-8 presents  the summary statistics for this subcategory.
 Nickel salts  ace generally used  in electroplating, as catalysts in the
 refining  business and in batteries.  The prices within the subcategory
 range  from $2.20/kg to  $6.70A9-  To the extent that nickel salts can
 replace cadmium and cobalt (the  former quite toxic and the latter
 expensive) as catalysts, their demand can be expected to grow.  The
 production of nickel nitrate, because of its use in nickel-cadmium
 batteries, will also increase over the next decade.

                 Table  2-8.  Subcategory Summary:  Nickel Salts
              Total Subcategory Production:   8,367 metric  tons/year
                     Subcategory Capacity Utilization:  20%
1
1
Chemical |
Nickel
Carbonate.
Nickel
Chloride .
Nickel
Pluo-
borate
1
Nickel
Nitrate
Baseline I
Price |
($1983 Q2) I
$6.70Ag
1
$3.30Ag
1
$3.ooAg
1
$2.20Ag
1
1
1
Major End-Uses I
pigments
electroplating
electroplating
1
electroplating
!
batteries
glass colorant .
Number of
Plants
7
7
4
8
I
1 Demand
1 Elasticity
-.15
1
-.2
!
-.2
I
-.15
1
Sources:  Chemical Marketing Reporter, 1978-82.
          Effluent Guidelines Division, EPA, 1983.
          Meta Systems, Inc.
2.3.5  Sodium Chlorate

    Sodium chlorate is one of two important salts of chloric acid  (the
other is potassium chlorate).  It is produced by nine firms that operate
thirteen plants.  Through the 1960's and 1970's,  the manufacture of  sodium
chlorate was one of the most rapidly growing segments of the heavy
chemical industry.  Table 2-9 shows production to have been 157,000  metric
tons in 1975 and about 316,000 metric tons in 1982.   In January  1980,
capacity was 357,000 metric tons resulting in capacity utilization of
close to 80 percent.

    The major use of sodium chlorate is as a pulp bleach.   Most  industry
analysts expect declining demand for U.S.  produced sodium chlorate over
the next decade in large part due to increasing competition from the
Canadian and Japanese pulp and paper industries.
                                     2-17

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            Table 2-9.  U.S. Sodium Chlorate:  Capacity and Production
                            (Thousands  of Metric  Tons)

             |                   |                     |       Capacity
    Year      I      Capacity      I     Production      I     Utilization
1970
1975
1976
1977
1978
1979
1980
1982
269
246
246
280
342
380
357
357 ,
180
157
181
228
240
244
280
1 316
.861
.638
.736
.814
.702
.642
.784
. .880
 Sources:  SRI, Chemical  Economic Handbook, 1981, the technical 308 survey
 and Meta Systems' estimates.
    The second largest use of sodium chlorate is as an intermediate in the
 production of other chlorates and perchlorates.

    The use of sodium chlorate as an herbicide accounted for about 4,550
 metric tons in 1975.  Other agricultural uses for sodium chlorate are as a
 defoliant for cotton and as a desiccant for soybeans.  The median CMR
 price for sodium chlorate was $0.20/lb which'is $0.46/kg in second quarter
 1983 dollars.
     2.3.5.1  Sodium Chlorate Summary Discussion

     The summary statistics for this subcategory are presented in
Table 2-10.  Sodium chlorate production utilizes close to 90 percent of '
its capacity.  Over 80 percent of the chemical is consumed by the pulp and
paper industry, and projections for its growth are directly tied to this
industry's health.

               Table 2-10.  Subcategory Summary:   Sodium Chlorate
             Total Subcategory  Production:   312,300 metric  tons/year
                     Subcategory Capacity Utilization:  88%
1
1
Chemical I
Sodium
Chlorate
I
Baseline I
Price |
($1983 Q2) |
$0.46Ag
1
1
1
Ma-jor End-Uses I
pulp bleach
chlorate intermediate
herbicide
1
Number of
Plants
13
1
1 Demand
1 Elasticity
-.15
I
Sources:  Chemical Marketing Reporter,  1978-82.
          Effluent Guidelines Division,  EPA,  1983.
          Meta Systems,  Inc.

                                     2-18

-------
 2.3.6   Zinc  Chloride

     Zinc chloride is one of the more industrially important zinc com-
 pounds. It has been called the "butter of zinc" because upon evaporation
 it forms a white semi-solid which is similar in consistency to common
 table butter.  Zinc chloride production accounted for about 1.1 percent of
 total zinc demand in 1979 (1,090 metric tons) and 7.0 percent of zinc's
 non-metal end-uses  (185 metric tons).  Zinc chloride is used in deodo-
 rants, disinfectants, embalming fluids and wood preservatives.  It is also
 used for fireproofing, etching and galvanizing.  Other end-uses of zinc
 are in the manufacture of dyes, parchment paper, and fabric sizing.   The
 median CMR price is $1.06/kg.

    There are six firms producing zinc chloride in seven different loca-
 tions.  Production levels have declined in recent years.  Given that no
 new end-uses for zinc chloride have been developed, this decline in
 production can be expected to continue.
    2.3.6.1  Zinc Chloride Summary Discussion

    The summary statistics for this subcategory are presented in Table
2-11.  The zinc chloride industry currently utilizes its capacity at  about
60 percent.  The average price of the chemical is $1.06/kg.   This varies
according to the manner in which it is formulated.   Production of zinc
chloride has been declining over the past decade and this trend can be
expected to continue.

                Table 2-11.  Subcategory Summary:   Zinc Chloride
             Total Subcategory Production:  39,714  metric tons/year
                     Subcategory Capacity Utilization:   60%
1
1
Chemical 1
Zinc
Chloride
1
Baseline I
Price |
($1983 Q2) |
$1.06/kg
1
Major End-Uses
soldering flux
deodorant
disinfectant
fabric sizing
1
I Number of
1 Plants
7
1
1
I Demand
1 Elasticity
-.2
1
Sources:  Chemical Marketing Reporter,  1978-82.
          Effluent Guidelines Division, EPA,  1983.
          Meta Systems,  Inc.
2.4  The Cyclic Behavior of the Inorganic  Chemical  Industry
2.4.1  Trends in the Inorganic Chemicals  Industry

    The chemicals examined in this  study  are produced  in small volume and
thus have incomplete statistics regarding price and production over the

                                     2-19

-------
years.   Examination of chemical specific information reveals that prices
generally rise with materials costs and that annual production trends vary
widely  from chemical to chemical.  Aggregate information from the Census
of Manufactures provides some further insights into industry behavior and
is the  basis of most of the analysis of this section.

    Price and production time series information that is available for
individual chemicals is presented in Table 2-12.  Table 2-13 presents
similar data for SIC groups 2816  (inorganic pigments) and 2819 (inorganic
chemicals, not elsewhere classified) and also the macroeconomic indicators
used in this analysis:  the U.S. industrial production index, GNP, the
price index for inorganic chemicals (SIC 281), and the price index for
metal and metal products (SIC 33).
       Table 2-12.   Selected Inorganic  Chemicals  Price and  Production Data





1960
1965
1970
1971
1972
1973
1974
1975
1976
1977
1978
1979
1980
1981
1982

i Zinc
1 Chloride
1
1 Price
1 (*/lb. )

12.45
14.15

14.15
14.45
14.45
33.95
33.95
33.95
38.4
38.4
41.5


1
Cadmium I
Sulfide I
Production I
(Metric Tons, 1
Cadmium Content) I


1,187
969
1,231
1,281
984
895
729
639
699




1 I
Cobalt Salts
and Dyes
Consumption
(Metric Tons,
Cobalt Content)


180



817.5
1,303
1,992.5
2,449






I Sodium
1 Chlorate
1 Production
1 (Metric Tons
1 x 1000)







157
181
228
240
244
280 (est.)


1
Source:  SRI Chemical Bronomics Handbook,  1980.
                                     2-20

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    Figure 2-1 compares inorganic compounds prices to the price of their
major feedstocks and shows the two to be highly correlated.   In both
examples presented, the price of the inorganic chemicals follows the price
of the major feedstock at a lag of one year.   Accounting for  this time
relationship, the price of zinc chloride and zinc have a correlation
coefficient of 0.91.  Similarly, the price indices for SIC group 281
(inorganic chemicals)  and the metal products (SIC class 33) have a corre-
lation coefficient of 0.88, allowing for the time lag.

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the overall industrial production index 2/ (IPI)  in Figure 2-2.   The
figure illustrates a weak correlation between most of the chemical
products and the IPI.   Only sodium chlorate appears to follow the IPI
trends.

    Production data are not available at the 4-digit SIC level,  but a
proxy for production was created by dividing value of shipments for SIC
groups 2816 and 2819 by the Metals Price Index .?/ lagged by one year.
The production proxies for SIC groups 2816 and 2819, are compared to the
IPI in Figure 2-3.  Their correlations with IPI are indicated by corre-
lated coefficients of 0.29 and 0.90, respectively.

    Profitability at the 4-digit SIC level is measured by a cash flow to
sales ratio  (CFR).  This is obtained from the Census of Manufactures
according to the following formula:

               Value Added - Payroll
    CFR   =    ^______^____^^_^_
                 Value of Shipments

    Figure 2-4 compares the CFR for SIC groups 2816 and 2819  to the IPI
and Metal Price indices.  The cash flows for the two variables were
regressed against the IPI, the Metals Price Index (in constant dollars)
and Time.  The model for SIC class 2816 showed a good fit, with IPI the
least important of the three independent variables.  The CFR  for SIC 2819
correlates very weakly to these variables.  Details of these  regression
analyses are explained in Appendix 2B.
2.4.2  Forecasts of Inorganic Industry Variables

    The examination of industry trends indicates that the performance
characteristics (e.g., price, profitability)  of most inorganic  chemicals
in this study cannot be forecasted with a high level of  confidence.  Pro-
duction can sometimes be extrapolated since some of the  chemicals  have
demonstrated recent trends of increasing or decreasing production.
Profitability is less predictable.  The cash flow ratios for  the 2816
industry sector show weak correlations to overall industrial  production
and strongest correlation to the unidentified phenomena  represented  by the
Time variable.
   ±/ These indices are developed by the Federal Reserve  Board,


                                     2-22

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 2.4.3   Conclusions

    The Business Cycle Analysis attempts to predict the price,  production
levels and profitability of a set of small volume chemicals produced at
various sites in the country.

    The results of this trend analysis are used to estimate the business
conditions which will exist when the regulation is promulgated.  Due to
the incomplete information available for thes«* chemicals,  this  task  is
extremely difficult.  Consequently,  the impact analysis section of this
study assumes that the profitability, price and production levels of the
different chemicals will remain at the 1981 levels.   The sensivitity of
the results to reasonable variations to this assumption is examined  in
Section 7 of this report.
                                     2-27

-------
                                  Section  3

                         Economic  Impact Methodology
 3.1  Introduction

    The economic impact methodology consists of a baseline analysis and  a
subsequent impact analysis.  The initial baseline analysis provides a
basis against which potential impacts are assessed.   Baseline values are
calculated for manufacturing costs, profitability, and product price
before treatment costs.

    The extent to which treatment costs have an impact on specific plants
is determined in a series of steps.  First, costs of treatment are
estimated for each plant and any price increases and subsequent production
decreases caused by those costs are determined.  Second,  the profitability
reduction, calculated as the ratio of plant specific treatment costs to
net revenues, is developed.  For plants with large profitability reduc-
tion, further analysis is undertaken to predict closure.   Plant closure
analysis consists of a liquidity test and a solvency test.  Employment and
foreign trade impacts are determined from the closure analysis.   Final
sections of the methodology assess the effects of the treatment costs on
new sources and small businesses.

    Many sources of information and data have been used in developing this
analysis.  They include publicly available data (text books,  government
publications, 10K Reports)  and plant specific data gathered by EPA through
a technical survey of the industry.  (Such surveys are authorized by
Section 308 of the Clean Water Act.)
3.2  Baseline Calculations

    Manufacturing costs, production values (in dollars)  and quantities,
and indices of profitability—without regulation—serve as a  baseline
against which the impacts from regulatory action are estimated. The
economic variables used in baseline calculations assume median values
observed between 1978 and 1982.   Manufacturing costs are composed of fixed
and variable costs.  The analysis of profitability uses return on invest-
ment to provide a basis of comparison of profitability across plants.  All
monetary quantities are expressed in second quarter 1983 dollars.
3.2.1  Manufacturing Costs

    Manufacturing costs are an important factor  in  determining economic
impacts.  Actual plant specific manufacturing costs are  not available

-------
 because this  type of  financial/economic information was not part of the
 Agency's survey of  the  industry.  In the absence of detailed knowledge
 about the costs for each plant, EPA has estimated manufacturing costs for
 model plants  in each  subcategory.  Appendix 3A summarizes these model
 plant manufacturing cost estimates and outlines the method by which they
 are developed.   These model plant costs and plant specific information
 (such as a facility's capacity, production rate, and operating time)  are
 then used to  estimate manufacturing costs at the actual plants.  Appendix
 3B outlines the procedure by which model plant costs are used to estimate
 the actual plant costs.

     For the purposes  of this analysis, manufacturing costs are calculated
 as the sum of variable costs and 13 percent of fixed costs, where 13  per-
 cent represents the annuity factor associated with 10 percent interest
 rate over 15  years.
 3.2.2   Profitability

    The index of profitability is return on investment as  defined by  the
 ratio of a plant's net revenues  (in this case defined as sales minus  the
 variable costs of manufacturing)  to the fixed cost.   The net  revenues
 reflect the conditions of a typical base year.and  are appropriate for
 estimating net revenues for the year when the regulation is implemented.
3.2.3  Price and Production

    Baseline prices of individual chemicals are based on median prices
reported in the Chemical Marketing Reporter  (CMR) between 1978 and 1982
and have been adjusted to second quarter  1983 dollars.  Production
weighted averages were taken to derive subcategory prices.
3.2.4  Interest Rates

    This analysis assumes an 8  percent  return on equity and a 13 percent
interest rate on borrowed capital.   This  return on equity is comparable to
observed values of return in this industry, and the estimated rate for
capital is based on forecasts of industrial bond rates.  According to
FINSTAT I/ data, the industry generally funds 30 percent of its capital
expenditures from loans and  70  percent  from equity.  Therefore, the appro-
priate interest rate for capital expenditures is a weighted average of the
two—(.3)(.13)  +(.7)(.08)  =  0.095 cr roughly 10 percent.  The 10 percent
interest rate is used to amortize treatment and manufacturing costs.  The
8 percent return of equity assumption is  used in the solvency test, which
is described in Section 3.3.3.2.   Treatment facilities are amortized over
10 years and production facilities are  amortized over 15 years.
   I/ U.S. Small Business Administration, 1982.

                                      3-2

-------
 3.3   Impact Projections

    The addition of treatment costs affects the cost of production and can
have  an impact on production levels, price, profitability, plant closures
 and employment.
 3.3.1 Product level Impacts


    3.3.1.1  Price and Production

    Price increase is estimated as the product of the average unit treat-
ment cost for the subcategory  (weighted by the annual production of each
 plant) and the cost pass-through factor, which depends on the elasticities
of supply and demand.  Because the price increase is based on the average
 treatment costs in a subcategory, the profitability of a plant may rise or
fall due to treatment, depending on the treatment costs incurred by the
plant.  The elasticities of supply and demand and cost pass-through values
calculated in the baseline analysis are used to estimate the effects of
 treatment costs on product prices and volume.  Price increases will cause
production to decline in proportion to the elasticity of demand (i.e.,
percent production change is calculated as the product of demand elasti-
city and percent price change).


    3.3.1.2  Cost Pass-Through

    The pass-through of treatment costs is estimated as a function of
supply elasticity and demand elasticity for the different subcategories in
 this study.  Where the data permit, the supply elasticities (es)  are
estimated by construction of supply curves and measurement of the slopes
in the relevant production range.  The demand elasticities (e^)  are
estimated from market observation and are presented in Section 2 of this
report.  For subcategories with several chemicals that have different
demand elasticities, the most elastic is used for the subcategory value.

    The amount of cost pass-through is defined as the ratio of the
increase in product price (P) to the unit treatment costs (t), or dP/t.
If the supply curve is horizontal there is full (dP/t = 100 percent)  pass-
through—all treatment costs are passed on in the form of higher  price.
If the supply curve is vertical all additional treatment costs are ab-
sorbed by the plants and prices do not change (dP/t = 0). I/  In  indus-
tries with excess production capacity, as is found in this sector of the
   —'  Since the elasticity of supply measures the  slope of  the supply
curve, the large values of es indicate a  high cost pass-through.  This
is shown in by the formula used to estimate dP/t;  i.e., dP/t  =
es/(es-ed) .
                                      3-3

-------
inorganic chemicals industry/ the cost of producing an additional unit
will not exceed'that of the previous unit;  hence, the supply curves are
close to horizontal.

    The product level impact analysis assumes a  100 percent pass-through
on the grounds that:  1) a horizontal supply curve is a reasonable
approximation of industry conditions;  and 2) demand in this industry is
inelastic.  The assumption of 100 percent pass-through implies the worst
case for the product level impact analysis.  With this assumption the
maximum price increase and production decrease are examined.  Section 7
presents an analysis of the sensitivity of the impact analysis results to
this assumption.   Appendix 3C details the development of supply curves and
the derivation of elasticities and cost pass-through factors.  Treatment
costs and the methodology for their derivation are presented in
Section 4.

3.3.2  Plant Level Impacts

    The analysis of plant level economic impacts draws on plant specific
data such as production/ wastewater flow/  and treatment-in-place.  The
projected impact for an individual plant depends on the values of these
variables for the plant in question and for  other plants manufacturing the
same product.  Other plants have an effect because the product price
increases are expected-to be uniform and depend on such factors as average
treatment costs for a subcategory.  The methodology focuses on two
measures:  change in manufacturing costs and changes in profitability.

    3.3.2.1  Manufacturing Cost Increases

    Manufacturing costs increases are calculated for each subcategory and
for each discharge status.  The increase is  calculated as treatment costs
divided by manufacturing costs.

    3.3.2.2  Profitability

    Change in profitability due to treatment costs is reflected by the
change in return on investment (ROI)  resulting from the treatment costs.
When a zero cost pass-through is assumed,  the change in ROI is represented
by the ratio of plant specific treatment costs to net revenues..!/  The
ratio represents the maximum reduction in profits due to treatment; that
is, the reduction in profits that would result if the cost pass-through is
zero and all costs are absorbed by the plant.  The costs used are for
those plants upgrading from the current treatment-in-place to more strin-
gent levels of control.   Twenty (20)  percent of  the plants have treatment
   I/ Return on investment is  estimated as  (PQ-VCJ/FC where: PQ = price
x production quantity (= sales);  VC  = variable costs; and PC = fixed cost.
With treatment costs (T)  added to the variable costs, and no change in price
 (i.e., h zero cost pass-through), the change  in ROI is equal to T/(PQ-VC).

                                     3-4

-------
costs greater than 10 percent of net revenues,  which is taken  as  a  reason-
able criterion of potentially significant impact.   Plants with smaller
ratios are unlikely to have high impacts, especially in view of the supply
curve analysis, which indicates that cost pass-through is nearly  full.
3.3.3  Closure


    3.3.3.1  Liquidity Test

    The liquidity test is applied to plants that have a  treatment cost  to
net revenues ratio greater than 10 percent.  The purpose of  the  test  is to
determine a plant's ability to finance wastewater treatment  from their
current cash flow.  The test estimates cash flow before  treatment costs
and assumes that a cash flow greater than treatment costs enables a plant
to cover treatment costs.  A cash flow less than treatment costs in a
particular year does not necessarily mean a plant is unable  to handle
treatment costs  (it is not uncommon for plants to have negative  cash  flow
years from time to time), but it can be an indication of stress  that  the
plant experiences from incurring treatment costs.

    The method for deriving cash flow requires factoring in  the  conse-
quences of taxes on net revenues.  Therefore:

Cash Flow    =  Net revenues - Taxes

where:

Net revenues =  Sales - Variable Costs

Taxes        =  net revenue x 0.4

Tax assumption:  plant is in a 40 percent corporate income tax bracket.


    3.3.3.2  Solvency Test

    To determine whether or not a plant remains open,  the present value of
the plant's cash flow after treatment (CP)  is  compared to the salvage
value of the equity of the plant.  Present value of CF is the estimated
time stream of cash flow over the life of the  plant (assuming there is  no
change in production levels or discounted price)  plus  the present value of
salvage at the end of the time period.   It is  calculated as  follows:

                         N
 Present Value (CF)   =  2   CF/(l+r)i  =  CF  x [l-(l+r)"N]  /r + SV 1 + R)~T
                                      3-5

-------
where N is the life of the investment  (assumed to be 15 years in accord-
ance with the general investment practices in the industry),  and r repre-
sents the return on investment required for equity assets.  An 8 percent
value of r is used because it is the return on equity that has prevailed
for the inorganic chemicals industry for the past two years and can be
expected to continue to prevail for the base period.  The interest rate
assumptions made in this analysis are discussed in Section 3.2.4 of this
report.  Section 7 of this report presents a sensitivity analysis of the 8
percent figure by comparing it with r values of 7, 10 and 12 percent.

    If the present value of cash flow is greater than the salvage value of
the plant, then the plant is worth more open and operating than it would
be closed.  If, on the other hand, the salvage value of the plant is
greater than the net present value of cash flow, the plant is worth the
salvage value and, discounting the possibility of extenuating circum-
stances (like captive consumption or subsidization), should be sold for
that amount.  In the event that a plant's present value of cash flow is
nearly equal to its salvage value, other factors must be taken into
account to form a clear judgment on closure.

    Accurate salvage value estimation requires detailed financial data
that have not been collected for this study.  A reasonable surrogate,
however, can be derived from the Small Business Administration's FINSTAT
data.  These data consist of balance sheet items for plants in the Dun and
Bradstreet financial records for SIC 2816 (Inorganic Pigments)  and SIC
2819 (Inorganic Chemicals, not elsewhere classified).  In order to
estimate salvage value for the plants in this study, two ratios are calcu-
lated from the FINSTAT data.  The first ratio is total assets to sales;
the second ratio is current liabilities to total assets.  The ratios,
found in the FINSTAT data, are ranked from smallest  to largest and the
value at the 75th percentile (.78)  is used to represent the  industry-
wide assets to sales ratio.  The current liabilities to assets ratios  are
also ranked from smallest to largest, and in this case, the median value
(.30)  is used to represent the industry-wide value.   Taking  these values
(75th percentile of one and median value of the other)  overestimates
both the salvage value and the salvage value of equity thus  tending to
make the solvency test less likely to miss potential impacts.

    Using these general,  industry-wide ratios,  plant specific salvage
values are calculated in  the following manner:

    S  =  .78 x sales x .60

where:

    S       =   salvage value

    .78     =   75th percentile of industry wide assets/sales ratios
                                      3-6

-------
    sales   =   plant specific sales

    .60     =   factor to reflect the assumption that a plant is  60
                percent convertible to another use.
Salvage value of equity is then:

    Se  =  S - [(.78 x sales)  x .30]

where:

    Se      =   salvage value of equity

    .30     =   median of industry-wide liabilities/assets ratios

    S, . 78r and sales are the same as in the previous equation.


3.4  Employment

    Unemployment resulting from plant closures is  estimated directly  from
the plant closure analysis.


3.5  Foreign Trade Impacts

    Foreign trade impacts are estimated using the  data presented in the
Industry Profile (Section 2)  and the results of the impact analysis.


3.6  New Source Analysis

    The purpose of the New Source Analysis is to assess the impacts of New
Source Performance Standards  and Pretreatment Standards for New Sources on
entry to the industry.  This  analysis uses the model plant data de-tailed
in Appendix 3A and the industry trend information  developed in Section 2.
Industry trend information makes it possible to forecast growth for the
various subcategories and thus to predict the possible need for capacity
expansion in the future.

    The analysis uses model plant treatment costs  to perform the new
source analysis.   Treatment costs are estimated for each model plant  and
projections are made concerning possible impacts for both newly
constructed facilities and major modifications to  existing facilities.
                                      3-7

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3.7  Small Business Analysis

    The Regulatory Flexibility Act (Public Law 96-354)  of  1980 requires a
Regulatory Flexibility Analysis for all regulations  that have a signifi-
cant impact on a substantial number of "small entities."   This Act also
requires that alternative regulatory options  be considered to mitigate any
significant impact on small businesses.   "Small businesses" are defined by
employment.  This analysis evaluates the differential  impacts of  the pro-
posed regulations on small businesses,  relative to larger  businesses.
                                     3-8

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                                  Section  4
              Effluent Limitations Options and  Compliance  Costs
4.1  Introduction
    The Federal Water Pollution Control Act Amendments of 1972 established
a comprehensive program to "restore and maintain the chemical, physical,
and biological integrity of the Nation's waters" (Section 101(a)).   To
implement the Act, EPA was to issue effluent limitations guidelines, pre-
treatment standards, and new source performance standards for industrial
dischargers.  The Act included a timetable for issuing these standards.
However, EPA was unable to meet many of the deadlines and, as a result,  in
1976, it was sued by several environmental groups.   In settling this law-
suit, EPA and the plaintiffs executed a court approved "Settlement  Agree-
ment" which required EPA to develop a program and to adhere to a schedule
in promulgating effluent limitations guidelines, new source performance
standards, and pretreatment standards for 65 "priority" or toxic pollu-
tants and classes of pollutants for 21 major industries (see Natural
Resources tefense Council, Inc. v. Train, 8 EEC 2120 (D.D.C. 1976},
modified, 12 ERC 1833 (D.D.C. 1979)).

    Many of the basic elements of this Settlement Agreement program were
incorporated into the Clean Water Act of 1977.   Under the Act, the  EPA
program is to set a number of different kinds of effluent limitations and
standards.  The following is a brief summary:
4.1.1  Best Practicable Control Technology Currently Available (BPT)

    BPT applies to existing direct dischargers.   The limitations are
generally based on the average of the best existing performance at plants
of various sizes, ages and unit processes.
4.1.2  Best Available Technology Economically Achievable (BAT)

    BAT also applies to existing direct dischargers.   These limitations,
in general, represent the best existing performance in the industrial
subcategory or category.
4.1.3  Best Conventional Pollutant Control Technology (BCT)

    BCT replaced BAT for the control of conventional pollutants (3005,
TSS, oil and grease, and pH).   The Clean Water Act requires  that BCT
limitations be assessed in light of a two part "cost-reasonableness" test.

-------
 4.1.4  New Source Performance Standards (NSPS)

    NSPS apply to new facilities that discharge directly into the Nation's
waterways and are based on the best available demonstrated technology.
 4.1.5  Pretreatment Standards for Existing Sources (PSES) and New Sources
        (PSNS)

    PSES and PSNS control the discharge of pollutants which pass-through,
 interfere with, or are otherwise incompatible with the operation of a
 publicly owned treatment works  (POTW).  These limitations are to be
 technology-based, with PSES analogous to BAT and PSNS analogous to NSPS.
 4.2  Treatment Technology Options

    This report analyzes the economic impact of wastewater treatment costs
on six subcategories of the inorganic chemicals industry:   cadmium com-
pounds, cobalt salts, copper salts, nickel salts, sodium chlorate, and
zinc chloride.  For purposes of this analysis, some of these subcategories
have been further subdivided.  Detailed descriptions of the treatment
technology options are included in the technical Development Document.
The options are summarized below and are expressed in terms of  different
levels of treatment.  Higher level numbers indicate more stringent
control.

    All subcategories except sodium chlorate have the following options:

    Level 1:    Alkaline precipitation, clarification, sludge dewatering,
                pH adjustment.

    Level 2:    Filtration of clarified wastewater from Level 1.

    The options for sodium chlorate are:

    Level 1:    Hexavalent chromium reduction followed by  lime
                precipitation and clarification.  Reduction will serve the
                added purpose of destroying residual chlorine.

    Level 2:    Filtration of clarified wastewater from Level 1.
4.3  Current Treatment and Treatment Costs
4.3.1  Current Treatment

    EPA conducted a technical survey of plants in  this  industry.   In
addition, EPA contacted or visited many of the plants  in  the  six
                                      4-2

-------
 subcategories.  Table 4-1 summarizes the treatment-in-place determina-
 tions.   Anong 29 discharging plants  (21 direct and 8 indirect),  most of
 the direct dischargers have some level of treatment.  Only one-third of
 the indirect dischargers/ however, pretreat their effluent.
 4.3.2  Treatment Costing

    The costs used in this report are based on engineering estimates of
 treatment costs for model plants, except where plant-specific costs are
 provided by EPA.  The development of these model plant costs is detailed
 in  the technical Development Document.  These costs are then adjusted on
 the basis of current treatment-in-place, wastewater flow rate, and annual
 operating time in order to estimate plant-specific costs.
     4.3.2.1  Treatment Costs for Model Plants

     The model plant costs derived in the technical Development Document
are  summarized in Table 4-2.  The total annual costs are the sum of
amortized capital costs  (assuming an interest rate of 10 percent and an
equipment life of 10 years, as discussed in Section 3.2,4),  operation and
maintenance costs, and sludge disposal costs.-  Sludge disposal costs are
listed separately and the sludge is assumed to be disposed of in
compliance with applicable federal and state hazardous waste regulations.

     4.3.2.2  Plant Specific Treatment Costs

     The analysis of potential economic impacts requires plant specific
treatment costs.  EPA provided treatment costs for all multiproduct plants
and  for all plants in the copper salts, copper carbonate, and zinc
chloride subcategories.  For all other plants treatment costs are obtained
by adjusting the model plant costs.  EPA has gathered data for each plant
on the wastewater flow and the annual operating time, the variables that
most affect plant specific costs.  The procedure for calculating plant
specific costs is explained for two cases:   single product plants and
multi-product plants.

     Consider first the plants which produce chemicals in only one sub-
category.

The capital costs for treatment (CAP)  are:

    CAP  =
where F is the daily wastewater flow rate,  the  subscript m  refers  to the
model plant values, and d is the scaling factor—set equal  to  0.6  (economy
of scale factors in the range 0.5 - 0.7 are commonly used to reflect the
decline in unit costs with increasing size).  The variable  treatment costs
are comprised of operation and maintenance  costs (OM)  and sludge disposal

                                     "4-3

-------
                      Table 4-1.   Current Treatment-in-Place
                          by Option for Existing Sources
Subcategory
Cadmium Pigments
Direct
Indirect
Zero
Cadmium Salts
Direct
Indirect
Zero
Cobalt Salts
Direct
Indirect
Zero
Copper Carbonate
Direct
Indirect
Zero
Copper Salts
Direct
Indirect
Zero
Nickel Carbonate
Direct
Indirect
Zero
Nickel Salts
Direct
Indirect
Zero
Sodium Chlorate
Direct
Indirect
Zero
Zinc Chloride
Direct
Indirect
Zero
1 Number
1 of Plants
5
2
2
1
7
4
2
1
10
5
3
2
7
4
2
1
10
1
4
5
7
4
3
0
12
6
3
3
13
9
0
4
7
5
1
1 1 I
1 No I
1 Treatment I
2
1
1
-
1
0
1
—
2
0
2
—
1
0
1
-
2
0
2
-

0
2
-
2
0
2
-
7
7
0
-
1
0
1
1
1 1
I Level 1 I
0
0
0
-
2
1
1
-
2
1
1
-
2
1
1
-
1
0
1
-

1
1
-
3
2
1
-
0
0
0
-
4
4
0
I
1
i Level 2
2
1
1
-
3
3
0
—
4
4
0
-
3
3
0
-
2
1 '
1
-

3
0
-
4
4
0
-
2
2
0
-
1
1
0
-
Source:  Effluent Guidelines Division, EPA, 1984.
                                      4-4

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                 Table 4-2.  Wastewater Treatment Cost by Model Plant!/




Cadmium Pigments
Level 1
Level 2
Cadmium Salts
Level 1
Level 2
Cobalt Salts
Level 1
Level 2
Copper Carbonate
Level 1
level 2
Copper Salts
Level 1
Level 2
Nickel Carbonate
Level 1
Lsvel 2
Nickel Salts
Level 1
level 2
Sodium Chlorate
Level 1
Level 2
Zinc Chloride
(Small)
Level 1
Lsvel 2
Zinc Chloride
(Large)
Level 1
Level 2
1 1 Daily |
1 Annual I Flow I
I Production | (cubic | Capital
1 (metric tons) I meters) 1 Cost
711 262
303.1
349.7
169 0.07
3.0
3.2
358 0.26
10.4
11.1
155 291
299.1
349.2
85.2 0.8
11.6
12.3
142 94.8
212.9
248.6
429 1.67
21.1
21.8
32,000 237
335.9
379.3

5,700 260
260.0
329.6

26,000 3,785
1,358.0
i i F24-3 i
i i
i i
1 O&M |
1 Cost 1

117.2
126.4

4.3
4.4

6.2
6.4

81.6
91.3

7.6
7.8

59.2
67.0

7.7
7.9

113.6
123.8


101.8
120.7


345.9
393.9


Sludge
Disposal

2.8
3.1

0.1
0.1

1.0
1.0

0.90
1.0

0.7
0.8

0.3
0.3

0.5
0.5

0.4
0.4


0.0
0.0


0.0
0.0
1
1 Total
I Annual
1 Cost

169.3
186.4

4.9
5.0

8.9
9.2

131.2
149.1

10.2
10.6

94.1
107.7

11.6
11.9

168.7
185.9


144.1
174.3


566.8
641.3
   !/in thousands of  1983 dollars
Source:  Effluent Guidelines Division, EPA, 1984.
                                     4-5

-------
costs  (SLUDGE).  Both of these costs depend on the number of days of
operation per year and on the flow:
    OM
              (F/Fm)e (D/Dm) with e = 0.6 to reflect economies of scale
and
    SLUDGE  =  SLUDGED (F/Fm) (D/Dm)
No economy of scale is assumed for sludge disposal because there is fre
quently a fixed cost per ton for hauling.  Since model plant costs are
based on an operating time of DJJ, days/year,  the operating time D,  other
than Dm days is accounted for by the factor D/Dm.
    The values of CAPmf
summarized in Table 4-2.
                             and SLUDGE,,, for each model plant are
    Annual treatment cost (T) is:

    T  =  OM + SLUDGE + 0.1627 CAP

where 0.1627 is the capital recovery factor for an interest rate  of  10
percent and a time horizon of 10 years.

    For plants producing chemicals in more than one subcategory,  we  assume
that the different products are manufactured at different times of  the
year and that the associated wastewatsr streams are treated with  the same
pollution control equipment.  The Agency provides overall treatment  costs
for each of these multiproduct plants.  These costs are allocated among
the several products at each plant on the basis of the wastewater flow
associated with each product.  Table 4-3 shows an example of the
allocation procedure for a plant whose capital costs are $100,000, annual
O&M costs are $50,000,  and annual sludge disposal costs are $10,000.

                                  Table  4-3
                  Example of  Treatment  Cost  Allocation at a
                      Hypothetical Multi-Product Plant
                              Cobalt
                                Salts
                                          Copper
                                            Salts
         Nickel
           Salts
          Total
Total Plant Costs
    - Capital ($ x 103)
    - O&M ($ x 103/yr)
    - Sludge ($ x 103/yr)

Flow (m3/day)

Allocated Costs
    - Capital ($ x 103)
    - O&M ($ x 103/yr)
    - Sludge ($ x 103yr)
                                  70
                                 70
                                 35
                                  7
20
20
10
 2
10
10
 5
 1
100
 50
 10

100
100
 50
 10
                                      4-6

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    Treatment cost estimates for each subcategory are shown in Table 4-4a for
Level 1 and in Table 4-4b for Level 2.   The  sodium chlorate subcategory has no
indirect dischargers,  but dominates costs  for direct dischargers.  The cobalt
salts subcategory has  the smallest costs for direct dischargers.  Among the
indirect dischargers,  the cadmium pigment  subcategory has the largest
treatment costs and the cadmium salts subcategory has the smallest treatment
costs.  Total investment for direct dischargers at Level 2 is $4.8 million and
for indirect dischargers, $1.1 million.  Total annual costs are $2.3 million
for direct dischargers and $0.5 million  for  indirect dischargers.
                                     4-7

-------
                                 Table 4-4a.
                          Level 1 Treatment Costal/
1 Capital Costs
Subcategory
Cadmium
Pigments
Cadmium
Salts
Cobalt
Salts
Copper
Carbonate
Copper
Salts
Nickel
Carbonate
Nickel
Salts
Sodium
Chlorate
Zinc
Chloride
total
1 Direct I
1 Dischargers 1

153.17

0.00

0.00

0.00

0.00

0.0

0.00

3,764.07

0.00
3,917.24
I Indirect I
Dischargers I Total

267.69 420.86

4.27 4.27

6.45 6.45

86.09 86.09

5.81 5.81

282.44 282.44

14.87 14.87

3,764.07

200.02 200.02
867.64 4,784.88
1 Total Annual Costs
I Direct I
1 Dischargers 1

85.03

0.00

0.00

0.00

0.00

0.00

0.00

1,889.29

0.00
1,974.32
Indirect
Dischargers

159.88

1.81

2.73

18.07

2.46

120.19

6.32

1,

98.52
409.98 2,
1
1 Total

244.91

1.81

2.73

18.07

2.46

120.19

6.32

889.29

98.52
384.30
   i/thousands of 1983 dollars
Source:  Meta Systems Inc. estimates.
                                     4-8

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                         Table 4-4b.  Level 2 Treatment Costal/
1 Capital Costs
Subcategory
Cadmium
Pigments
Cadmium
Salts
Cobalt
Salts
Copper
Carbonate
Copper
Salts
Nickel
Carbonate
Nickel
Salts
Sodium
Chlorate
Zinc
Chloride
Total
1 Direct
1 Dischargers
176.71
0.79
0.02
13.00
0.00
26.84
1.01
4,249.91
330.86
4,779.14
I Indirect J
1 Dischargers 1 Total 1
308.84 485.55
4.34 5.12
7.28 7.30
164.44 177.44
9.73 9.73
363.85 390.69
18.52 19.54
4,249.91
238.58 569.45
1,115.58 5,914.72
I Total Annual Costs
I Di rec t
1 Dischargers 1
93.65
0.31
0.01
5.21
0.00
10.76
0.40
2,081.97
144.39
2,336.70
1 Indirect
Dischargers
175.*87
1.82
3.01
44.96
3.82
149.28
7.61
0.00 2,
115.01
501.38 2,
1
I Total
269.52
2.13
3.01
50.17
3.82
160.04
8.01
081.97
259.40
838.07
   i/thousands of 1983 dollars




Source:   Meta Systems Inc. estimates.
                                     4-9

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                                  Section  5

                                   Results
 5.1   Introduction

    The economic analysis of the effects of effluent regulations on  the
 inorganic chemicals industry is conducted in the manner described in
 Section 3.  The results presented in this section are organized under  the
 headings of plant level impacts, product level impacts, closure, employ-
 ment  impacts, foreign trade impacts and new source analysis.
 5.2  Plant Level Impacts

    Plant level impacts are measured by manufacturing cost  increases  and
 profitability changes.  Of the 46 plants presented in Section  2,  two  are
 not presently producing any of the inorganic chemicals examined here.  The
 results in this section consider only the 44 plants that presently produce
 chemicals in the subcategories.
5.2.1  Manufacturing Cost Increases

    Table 5-1 shows increases in manufacturing costs,  by subcategory,  for
each discharge status and level of control.   Cost increases  range  from 0
to 4.8 percent.  Indirect dischargers tend to have higher cost  increases
than direct dischargers.  Eight plants have  increases  over two  percent.
The largest plant level cost increase, 15.1  percent, is  found in the
nickel carbonate subcategory.

    Several of the plants with treatments costs greater  than 2  percent of
manufacturing costs actually belong to a multi-product plant.   By
comparing total plant treatment costs with total plant manufacturing
costs, only five plants have treatment costs greater than 2  percent of
manufacturing costs.
5.2.2  Profitability

    The reduction in profitability is  measured  as  the  ratio of treatment
cost to net revenue.  This ratio is equal to the change  in return on
investment, assuming that none of the  treatment cost is  passed on as a
price increase.

-------
    Table 5-2 summarizes profitability changes by subcategory,  control
level and discharge status.  These changes range from zero for  several  of
these categories to 24 percent for indirect discharging copper  carbonate
plants.

    The number of plants with profitability reductions greater  than  10
percent at Lsvel 2 costs are presented in the last column of  Table  5-2.
By considering multiple product plants on the basis of their  aggregate
treatment costs and net revenues, six plants are shown to have  profit-
ability reductions greater than 10 percent.  These six plants are further
examined in the closure analysis.
5.3  Product Level Impacts

    Product level impacts are measured by price increases and production
changes by subcategory.
5.3.1   Price Increases

    Price increases have been calculated assuming a  100 percent cost pass-
through, i.e., the change in the price of a product  is  assumed to be equal
to the average treatment cost for all plants producing  that product.

    The impact of treatment costs on prices is  small.   As  shown in
Table 5-3, subcategory price increases range from 0.01  to  2.40 percent.
level 1 increases range from 0.01 for cobalt salts to 1.81 percent for
nickel carbonate.  Level 2 increases range from 0.01 for cobalt salts to
2.40 percent for nickel carbonate.  At roughly  2 percent,  the estimated
price increases for nickel carbonate and copper carbonate  are high,
compared to other products.  However, these price increases do not
indicate negative impacts.
5.3.2   Production Change

    Production changes are estimated as a  function of  the change in price
and the demand elasticity in each subcategory.   The  estimated production
changes for each subcategory are shown in  Table  5-4.   Production changes
are low because demand for all of the chemicals  is inelastic and thus
relatively unresponsive to price changes.   At  Level  1, production changes
by subcategory range from 0.003 for  cobalt salts to  0.27 percent for
nickel carbonate.  At Level 2, the changes range from  0.003 for cadmium
salts to 0.41 percent for copper carbonate.  All of  these production
changes are considered small.
                                      5-2

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          Table 5-1.  Manufacturing Cost Increases  by Control  Level
1
Subcategory 1
Cadmium Pigments
1
Cadmium Salts
1
Cobalt Salts
1
Copper Carbonate
1
Copper Salts
1
Nickel Carbonate
1
Nickel Salts
1
Sodium Chlorate .
Zinc Chloride
1
Total
1
Discharge I
Status I/ \
D
1
D
i
D
1 1
D
1
D
1 1
D
1
D
1
1
D
1
D
1
Manufacturing Cost
Level 1 1
0.75
1.77 .
0
0.05
0
0.04 .
0
1.60
0
0.05 .
0
3.86
0
0.10
1.41 !
0
2.01 |
1.07
0.99 |
Increase (Percent)
Level 2
0.82
1.94
negl.
0.05
0
0.04
0.19
3.99
0
0.07
0.49
4.79
negl.
0.12
1.55
0.70
2.35
1.27
1.21
   i/ D = direct discharge;  I = indirect discharge.




Source:  Meta Systems Inc.  estimates.
                                      5-3

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            Table 5-2.   Profitability Reduction by Control Level
1
1
I Discharge
1 | Number of Plants
1 Profitability 1 with Level 2
I Reduction (%) 1 Profitability
Subcategory I Status !/ | Level 1 1
Cadmium Pigments
1
Cadmium Salts

1
Cobalt Salts
1
Copper Carbonate

1
Copper Salts
!
Nickel Carbonate

• 1
Nickel Salts

I
Sodium Chlorate
!
Zinc Chloride

1
Total I/
1
D
I
D
I

D
I
D
I

D
I
D
I

D
I

D

D
I

D
I
1.55
3.84
1 1
0
0.06
1 I
0
0.01
1 1
0
9.63
1 1
0
0.64
-I I
0
10.80
1 1
0
0.35
1 1
9.42
1 1
0
5.03
1 1
3.75
! I'36 1
Level 2 I Reductions > 10%
1.71
4.22
1 1
0.03
0.06
1
0
0.02
I
1,24
23.96
1
0
0.98
1
1.75
13.42
1
0.02
0.42
1
10.39
1
0.88
5.87
1
4.44
1.67
0
1
0
0

0
0
0
2

0
0
0
2

0
1

3

1
0

4
6
   i/ D = direct discharge; I = indirect discharge

   2/ Total reflects  individual product lines.  The number of plants overstates
the impacts to some multiple product plants.

Source:  Meta Systems Inc. estimates.
                                     5-4

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                 liable  5-3.   Price  Increases by Subcategory
                                     Price  Increase (Percent)
Subcategory I
Cadmium Pigments
Cadmium Salts
Cobalt Salts
Copper Carbonate
Copper Salts
Nickel Carbonate
Nickel Salts
Sodium Chlorate
Zinc Chloride
Level 1
0.85
0.02
0.01
0.74
0.03
1.81
0.04
1.25
0.26
! Level 2
0.93
0.02
0.01
2.07
0.05
2.40
0.05
1.38
0.69
            **AVERAGE                 0.81             0.96
Source:  Meta Systems Inc. estimates
                                      5-5

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               Table  5-4.  Production Decreases by Subcategory
                             I  Production Decrease (Percent)
Subcategory 1
Cadmium Pigments
Cadmium Salts
Cobalt Salts
Copper Carbonate
Copper Salts
Nickel Carbonate
Nickel Salts
Sodium Chlorate
Zinc Chloride
Level 1
0.085
0.005
0.003
0.149
0.009
0.271
0.009
0.188
0.053
! Level 2
0.093
0.006
0.003
0.414
0.014
0.361
0.011
0.207
0.139
            **AVERAGE               0.167          0.194
Source:  Meta Systems Inc. estimates
                                      5-6

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5.4  Closure

    The six plants that have profitability changes greater than 10 percent
are analyzed for potential closure with a liquidity test and a solvency
test.  A full cost pass-through is assumed for both of these tests.
5.4.1  Liquidity Test

    The liquidity test compares the treatment cost to cash flow.  Where
treatment cost exceeds cash flow, it is possible that the plant will have
difficulty covering the  cost of treatment with internally generated cash
flow.  None of the six plants  indicates liquidity problems resulting from
Level 1 or Level 2 treatment costs.
5.4.2   Solvency Test

    In the test for solvency, salvage value is compared to net present
value of cash flow.  In  theory, where the salvage value exceeds  the
present value of cash  flow, a company should consider selling the produc-
tion facility.  None of  the plants exhibits a salvage value exceeding the
net present value of cash flow.  Therefore, no- closures are predicted by
this test.

    Neither of the closure tests yielded any plants which came close to
meeting the closure conditions.  Thus, none of the compliance costs
associated with either treatment level are expected to result in plant
closures.
 5.5  Employment

    No loss of jobs is  expected to result from compliance with these
treatment levels.
5.6  Foreign Trade Impacts

    The sodium chlorate  industry has recently seen increasing competition
from Canadian producers.  Many of these producers locate their plants near
the northwest U.S. border to meet the demands of U.S.  pulp mills in that
region.

    Since roughly 10 percent of U.S. sodium chlorate demand  is met by
Canadian imports, and  since the sodium chlorate price  is expected to
increase by 1.4 percent  following the promulgation of  this regulation,
some foreign trade impacts might be expected.  However,  sodium chlorate is
produced for regional  markets (due to high transportation costs) and none
of the U.S. producers  in this region are expected to bear any additional
treatment costs with this regulation.  Thus, the impact  of these price
changes on foreign trade is expected to be small.

                                     5-7

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5.7  New Source Analysis

    The examination of new source standards considers that all new sources
will have treatment requirements equal to the Level  2 treatment for
existing sources.   This analysis is performed for the model plants in each
subcategory.   The  treatment costs are compared to manufacturing costs and
net revenues to determine their potential impact as  barriers to entry into
the market.

    The results of this analysis are presented in Table 5-5.  Manu-
facturing cost increases range from 0.37 percent for cobalt salts to 19.78
percent for copper carbonate.  At Level 2, these increases exceed 10
percent in two of  the nine subcategories:  copper carbonate  (19.78), and
nickel carbonate (11.66).  Profitability changes, measured here as treat-
ment costs divided by net revenues, range from 0.2 to 87.3 percent^/
They exceed 10 percent in 3 of the 9 subcategories.   The affected
subcategories are  nickel salts (10.5 percent), nickel carbonate (46.3
percent) , and copper carbonate (87.3 percent).

    Judging from the analysis of existing plants, the impacts of these
costs on new sources are regarded as small.  The level 2 treatment costs
were shown to be economically achievable for existing plants and given
that the estimated cost ratios for new plants fall in the same range, they
should not present barriers to entry for new plants.

    As part of the proposed regulations, pretreatment standards for new
sources (PSNS) are being proposed for twelve additional subcategories.
The PSNS requirement is zero discharge of process wastewater.  In each of
these subcategories, existing dischargers are subject to, and meeting zero
discharge effluent limitations.  No cost disadvantages or other impacts
are expected from  these new PSNS.
   !/ Though a profitability decline of 87 percent for new sources
appears high, it is important to note that existing copper carbonate
producers are operating with only a 10 percent profit margin.  New
sources, as represented by the model plant, should attain a 40 percent
profit margin before regulation.  After the regulation, and its resultant
87 percent profit decline, the new sources should still have a profit
margin of 5 to 6 percent.  For this reason, the regulation is not expected
to present any barrier to entry into the copper carbonate subcategory.
                                     5-8

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                                 Section  6
                      Regulatory Flexibility  Analysis
6.1  Introduction

    Under the Regulatory Flexibility Act of 1980, the EPA and other  regu-
latory agencies are required to consider the effects of environmental
regulations on small entities.  This section reviews the potential impacts
of the environmental regulations on small businesses within the inorganic
chemicals industry.
6.2  Definition of a Small  Firm

    The Act directs agencies  to  the Small Business Administration's  (SBA)
definitions for small firms.   The Small Business Act, Section 3,  defines a
small business in the following  statement:

             11 ... a small  business concern shall be deemed to
             be one which is  independently owned and operated
             and which is not dominant in its "field of opera-
             tion.  In addition  to the foregoing criteria, the
             Administration (of  the SBA), in making a detailed
             definition may use  these criteria, among others:
             Number of employees and dollar volume of business."
    In addition, the SBA published specific employee-based guidelines by
SIC code for various business activities including manufacturing.   For the
plants included in this analysis  (SIC groups 2816 and 2819),  the Small
Business Administration defines a small firm as one with not more  than
1,000 employees..!/  Within the context of this industry's analysis,  even
firms with 1,000 employees may be considered large by the Regulatory
Flexibility Act's definition of small businesses as being those firms
having limited resources with which to comply with regulatory requirements
or those encountering regulation-imposed barriers to entry into the
industry.

    The plants in this analysis have been ranked by number of employees in
the parent corporation, and divided into five sets of eight plants each.
Firms designated by the SBA as small businesses (those with 1,000
employees or less)  make up the first and second size rankings.  Thus,
small businesses account for a total of 16 of the 39 ranked plants in this
analysis.
   I/  Code of Federal Regulations, Title 13, Section 121.3-16.

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6.3  Results

    The number of plants with potentially significant effects appearing in
each firm employee size range has been identified in order to determine
whether a relationship exists between business size and level of impact.
Those plants incurring Level  2 treatment costs greater than 10 percent of
net plant revenue have been designated as having potential significant
effects.  Results are shown in Table 6-1.  Corporate data are unavailable
for six plants.  These plants have not been ranked, and are included in
group six in Table 6-1.

    Two of the 16 plants designated as small businesses are found to have
treatment cost to net revenue ratios greater than 10 percent.  However, as
demonstrated in Section 5 of  this report, none of these plants is expected
to close.  Of the remaining 23 ranked plants, three (13.0 percent)  are
identified as having treatment costs greater than 10 percent of net
revenues.  Judging from the similar ratios of treatment costs to net reve-
nues in the small and large business groups, there appears to be no
significant relationship between business size and degree of impact due to
treatment costs.

                                  Table 6-1.
           Distribution of High Impact Plants by Firm Employment Size
    Plants by
  Firm's. Number
  of Employees
  (From Smallest)
Firm Employment
     Range
Number of Plants Where
Treatment Costs Exceed
10 Percent of Revenues
First Fifth
Second Fifth
Third Fifth
Fourth Fifth
Fifth Fifth
6 Other Plants I/
      0-125
    126-1000
   1001-12,500
 12,501-45,000
 45,501-175,000
 NA
            0
            2
            1
            0
            2
            1
   —  Number of employees  is not known.

Source:  Meta Systems  Inc. estimates.
    The Level 2 treatment costs for these 16 plants owned by small busi-
nesses are summarized  in  Table 6-2.  This table indicates that  the largest
costs at this level are borne by indirect dischargers.
                                     6-2

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          Table 6-2.  Small Business Level 2 Treatment Cost Summary i

Parameter
Number of Plants
Total Investment Cbsts
Total Annual Costs
1 Zero
1 Discharge
4
0.0
0.0
1 Direct I
iDischargel
7
372.5
161.4
Indirect
Discharge
5
1,027.6
482.8
   —  All costs are  in thousands of 1983, second quarter dollars.

Source:   Meta Systems, Inc. estimates.
    In conclusion,  small businesses do not appear to bear  a dispropor-
tionate share of Level  2 treatment costs relative to their net revenues.
                                     6-3

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                                  Section 7
                            Limits to  the Analysis
 7.1   Introduction

     The  basic task of this study is a difficult one—to assess the effects
 of a regulation on a set of small volume chemicals produced at various
 sites in the country.  Little information is available about these
 chemicals, and more importantly, little is known about the facilities that
 produce  the chemicals.  Some specific economies of producing the chemicals
 and  treating the wastes are therefore overlooked.

     The  analysis uses the available information in such a way that the
 closure  results are very conservative (i.e., they represent a "worst case"
 scenario).  The analysis clearly has some limitations in both the
 available data and methodological approach.  Limitations are discussed in
 parts 7.2 and 7.3 of this section.  Those assumptions that may be critical
 to the results of the analysis are examined closely in 7.4, the sensiti-
 vity analysis portion of chis section.
7.2  Data Limitations

    Some of the technical and economic data used in this analysis are
plant specific but are not comprehensive enough to address many economic
problems.  The limitations imposed by data affect the choice of method-
ology as well as the reliability of the results.

    The plant level data used in this analysis are described in
Section 3.  The principal source of these data is the Data Collection
Portfolio for specific plants.  The technical Development Document details
the data collection effort.  These data are from static observations,
though, and may not be a true representation of the industry.  The SRI
Directory of Chemical Producers supplements this by identifying other
products manufactured at these sites.  Since there is no financial survey
of the plants, there is little data available on depreciation,  equity to
assets ratio, or discount rate for the individual plants.  This imposes a
limit to plant level manufacturing cost and profitability estimates.

    Plant level production costs are known to vary according to many
factors, including plant age, production process, product grade, vertical
integration and scale.  Of these, only scale is known well enough to  be
considered in the cost estimates in this analysis.  Here, the lack of
financial and marketing information limits the degree to which  non-
merchant market producers can be identified.

-------
     The plant level data limitations pose a particular problem for plants
 that employ small batch processes.  Where several products are produced
 with a single piece of equipment, the capital costs of that equipment are
 shared.   To the extent that these products are Phase II chemicals, the
 effect of the shared investment can be estimated.  However, most of the
 product lines sharing these facilities are not in Phase II and are there-
 fore not  considered.  In those cases, the Phase II product lines studied
 are  assumed to carry the capital costs of the equipment, and the costs
 will be disproportionately high.

     Product level data limitations present other problems to the
 analysis.  Since the chemicals and subcategories are generally small
 volume, production and price data and demand information are scarce.  The
 absence of this information hinders accurate estimation of demand elasti-
 city and  profitability for the subcategories.
 7.3  Methodological Limitations

    The methodology used in this analysis has been chosen as the best
 means of utilizing the limited information to estimate the effects of this
 regulation on the inorganic chemicals industry.  The principal limitations
 are:  estimation of plant level manufacturing costs froitr model plant
 process economics; estimation of manufacturing capital costs for small
 batch processes; and interpretation of impacts in subcategories that are
 composed of several chemical products.

    Plant level manufacturing costs are estimated by scaling the fixed
 costs and variable cost components from model plant production costs.   The
 scale factors chosen for this extrapolation are intended to capture the
 effects of scale economies.  However, when the actual plants are much
 smaller or much larger than the model plant, the scale factors may produce
 poor cost estimates.   Many of the plant specific attributes (e.g., age,
 joint products)  are overlooked.

    The model plants in multiple-product subcategories represent the
 average process economics and treatment costs for the subcategory.  By
 ignoring chemical specific costs, the model plant procedure may fail to
 identify plants where the chemicals have profitability or treatment cost
 characteristics very different than the model plant.   Four of the six
 subcategories include more than one chemical.

 7.4  Sensitivity Analyses

    Sensitivity analyses have been performed on four  of the major assump-
tions in this study.   These assumptions concern the interest rate used to
 determine the present value of cash flow,  the cost pass-through factor,
 the manufacturing costs and the treatment costs.   These sensitivity
analyses are presented in terms of the liquidity and  solvency test results
shown in Section 5.
                                      7-2

-------
    The set of plants investigated in the sensitivity analysis consists of
all plants that would sustain some treatment costs at the most stringent
level of treatment  (level 2).  Plants producing in multiple subcategories
are considered as single aggregate plants.  In this manner, the sensitiv-
ity analysis examines 19 plants.
 7.4.1    Interest Rate

    The  solvency test assumes that the appropriate interest rate (r)  for
discounting future cash flow is 8 percent over a period (N) of 15 years,
where eight percent is the assumed return on equity.  Algebraically,  the
standard formula for the present value factor (PVF)  is:


           PVF  -  1 - (1 * r) "N                                       (7-1)
An eight percent interest rate results in a factor of 8.56.   Considered
over the same period for 7, 10 and 12 percent, the factor becomes 9.11,
7.61 and 6.81 percent, respectively.  None of these interest rate assump-
tions raise any solvency ratios over 1.  Hence, the interest rate assump-
tion does not affect the results.  Other interest rate and investment life
assumptions have been used elsewhere in the report to determine the cost
of capital for investment in manufacturing facilities (10 percent, 15
years) and treatment facilities  (10 percent, 10 years).   The sensitivity
of the results to these assumptions is not examined separately because the
manufacturing and treatment cost assumptions are themselves  examined.
7.4.2  Cost Pass-Through

    The cost pass-through factor assumed in Section 5 is 100 percent  for
all subcategories.  This factor implies a horizontal supply curve  or  a
market situation in which a change in production does not affect the
price.  That condition is generally true for situations in which capacity
utilization is low, as is the case in these segments of the inorganic
chemicals industry.  (See Section 2 for specifics on capacity utiliza-
tion. )

    To test the sensitivity of the results to this assumption,  a zero
percent pass-through and a 50 percent pass-through are examined.   Neither
of these assumptions causes a change in the liquidity or solvency  test
results.  Thus, while the 100 percent pass-through assumption is extreme,
the consequences of any possible error are unimportant.

    Other measures that are affected by this assumption are price  change,
production change, and profitability.  The effects on price and production
are tautological; a 50 percent pass-through reduces all of these changes
shown in Section 5 by 50 percent.  A zero percent pass-through  results  in

                                      7-3

-------
no price or production change.  The profitability test is only performed
for  the zero percent pass-through, since that is the most extreme situa-
tion.  Alternative pass-through assumptions would simply reduce the
impacts shown by that test.
7.4.3  Manufacturing Posts

    The manufacturing cost assumption has been varied as a means of
testing the sensitivity of the results both to plant level cost and to
plant level profitability changes.  Profitability is defined in Section 3
of this report as return on investment (ROI) where ROI = (PQ-VC)/FC.  An
increase in fixed and variable manufacturing costs, (PC) and (VC)  respec-
tively, will cause a profitability decrease.  The effects of a 20 percent
cost decrease and 20 and 40 percent cost increases were examined.

    Most subcategories are unaffected by any of these cost changes.  All
multiple product plants and all single product plants producing cadmium
salts, cobalt salts, copper salts, nickel salts and zinc chloride have
liquidity and solvency ratios under 25 percent for all these cost assump-
tions.

    With costs increased by 20 percent, two sodium chlorate plants and one
cadmium pigment plant showed closure conditions.  With a cost increase of
40 percent, six of the seven sodium chlorate plants and one of the two
cadmium pigment plants became potential closures.

    The^ensitivity analysis of profitability shows that the baseline
profitability assumptions are extremely important to the results of this
analysis.  Variations in costs affect the baseline closure conditions as
well as impacts due to the regulation.  Since virtually all of the treat-
ment costs are small, the conditions for closure often are that a plant be
only marginally profitable prior to assuming treatment costs.   By
increasing manufacturing costs until the plant is marginally profitable,
any plant with treatment costs can be shown to exhibit closure conditions
due to treatment.  Of the 19 plants with treatment costs at Level 2,  three
would show closure conditions with cost increases of 20 percent and eight
would exhibit these conditions with a 40 percent increase.   These numbers
are not alarming, particularly since six of the eight plants,  which in the
40 percent cost increase scenario would close, produce sodium chlorate—
which is judged to have the most reliable manufacturing cost estimates of
all the subcategories.
7.4.4  Treatment Costs

    The development of a model plant treatment costs is  detailed  in  the
technical Development Document.  These model plants  costs were adjusted  to
provide treatment costs for individual plants.   In order to  address
possible errors in the model plant costs or in the adjustment procedure,
                                      7-4

-------
we performed sensitivity analyses on the treatment costs.   Sensitivity to
variations in treatment costs is estimated by raising and  lowering the
treatment costs values used in the solvency test by 30 percent.   Neither
raising nor lowering the costs by 30 percent has a significant impact on
solvency ratios.  It is  determined that in order to raise any of the
plant solvency ratios to greater than 1, a 100 percent increase in treat-
ment costs would have to occur.  This sensitivity analysis shows that even
if our estimation is off by 30 (or more) percent, the treatment costs do
not have a significant impact on these plants (our conclusion  in
Chapter 5).
7.5  Conclusion

    The analysis of the economic impacts of treatment costs  on  this  seg-
ment of the inorganic chemicals industry is limited by data.  Many of  the
plant level economic characteristics that would allow a reliable  forecast
of impacts are not available.   Model plant information has been used to
supplement the actual plant level economic data.

    The results of the analysis are tested for  sensitivity to variations
in some of the critical assumptions.   Overall,  the  results of the analysis
are not sensitive to reasonable variations in' these assumptions.  The most
critical assumptions are found to be the manufacturing costs; cost
increases of 20 percent result in closure conditions in some plants.
There would be several additional baseline closures were manufacturing
costs to be increased (for reasons other than wastewater treatment)  by 20
percent.  There would not, however,  be additional plant impacts due  to the
regulation.

    In summation, the data and methodological limitations to the analysis
are accommodated with conservative assumptions  throughout the analysis.
The sensitivity analysis that  are performed support the conclusions  in
Section 5 of the report—that  the treatment costs are  not expected to
cause any plant closures.
                                      7-5

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                                 Section 8
                       Sodium Sulfite Impact Analysis
8.1  Introduction

    Effluent limitations guidelines and standards for sodium sulfite were
promulgated in 1974.   The technology basis for BAT, NSPS,  and PSNS limita-
tions was evaporation of the treated wastewater to achieve zero discharge
of process water.  In 1981, the sodium chloride industry requested recon-
sideration of BAT guidelines for sodium chloride (solution brine-mining
process) because they believed the costs of compliance with zero discharge
were too large in comparison to the effluent reductions achieved.  In the
course of the review  for sodium chloride, the Agency also reconsidered the
zero discharge requirement for the sodium sulfite subcategory.

    In its review, the Agency acquired additional data on the cost of the
technology and developed current estimates of costs that existing dis-
chargers would incur  to meet the existing BAT requirements.   Evaporation
of wastewater for the sodium sulfite subcategory is considerably more
expensive than originally estimated, in large part due to the greatly
increased cost of fuel.  Fuel prices increased approximately 500 percent
(on a constant dollar basis) from the assumptions used to evaluate the
1974 regulation.  Operating and maintenance costs, including the costs of
energy, represented approximately 40 percent of the total estimated cost
of compliance in 1974.   Following the revisions to compliance cost
estimates, the comparable cost component represents almost 90 percent of
the total estimated cost of compliance.

    The analysis in this section addresses the economic achievability of
the zero discharge BAT regulation, using the updated treatment costs.
8.2  Qualitative Information

    There are three plants currently producing sodium sulfite by the soda
ash-sulfur dioxide  process which defines this subcategory.   The annual
production capacity is approximately 69,840 metric tons and  the estimated
price (in second quarter  1983 dollars) is $475 per metric ton.  Since the
promulgation of the regulation in 1974, four plants in this  subcategory
have shut down, leaving the three plants examined in this analysis.

    The soda ash-sulfur dioxide process remains the dominant means of
producing both sodium bisulfite and sodium sulfite.  The only other
commercial production is  as a by-product of phenol production through the
reaction of sodium  benzene sulfonate with sodium hydroxide.

-------
    Sodium sulfite is used primarily for deicing, dust control,  in  the
pulp and paper industry,  and other industrial uses.  Sodium sulfite has a
diversity of uses and shares many segments with sodium chlorate, for which
the demand elasticity has been estimated to be -0.15.1./  For this reason
the demand elasticity for sodium sulfite is also expected to be  low (i.e.
-.20) .

8.3  Methodology

    The methodology employed to analyze the impacts of the effluent limi-
tations of sodium sulfite^is essentially the same as that used to analyze
the Phase II inorganic chemicals.  The description in this section, there-
fore, deals with departures from the methodology described in Section 3 of
this report.

    Model plant manufacturing costs were assumed to be four percent larger
for sodium sulfite than those for sodium bisulfite, which was analyzed in
the economic analysis for the Phase I inorganic chemicals.  The  four per-
cent adjustment accounts  for the price difference between the two products.

    Plant level manufacturing costs are estimated using the procedures
presented in Section 3 and described further in Appendix 3B.  A  62 percent
capacity utilization estimate reported for sodium bisulfite is used with
the reported sodium sulfite production levels to estimate the size of the
capital facility.  Plant  level treatment costs are discussed in
Section 8.4.

    The Impact analyses include changes in-manufacturing costs,  profit-
ability, price, and production and tests for liquidity and solvency.
These analyses are performed in the manner described in Section  3.  The
plants.are treated here as single product facilities.

8.4  Compliance Costs

    The effluent limitations costs examined in this section pertain to BAT
and NSPS limitations, only.  The effluent limitation for BAT and NSPS is
zero discharge except for excess water produced from wastewater  impound-
ments designed to contain a 25 year-24 hour storm.  The recommended treat-
ment to achieve this is evaporation via a multiple effect evaporation
system plus, if necessary, an agitated falling film evaporator.

    Plant level production and treatment costs are outlined in the
technical Development Document.  The treatment cost estimates are updated
to reflect current cost assumptions and reflect the costs attributable to
the sodium sulfite flow at the plants.  These treatment costs are
summarized as follows.  (All figures are in thousands of 1983 dollars.)


        Tbtal Capital Investment   =     2,425
        Annual O&M Costs           =     2,285
        Residual Waste             =       884
        Capital Recovery           =       394

        Ibtal Annual Costs         =     3,564
   !/ see Section 2 of this report.

                                     8-2

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8.5  Results
8.5.1  Plant Level Impacts

    The plant level impacts are measured by manufacturing cost increases
and profitability changes.

    Table 8-1 shows plant level impacts, summed across the sodium sulfite
subcategory.   The plant level cost increases are all relatively high, rang-
ing from 4.5  to 37.8 percent.  The average manufacturing cost increase,
shown in Table 8-1, is 23.3 percent.


         Table 8-1. Plant Level Impacts—Sodium Sulfite Subcategoryi/
    Ainual Production  (Metric tons)           43,300
    Annual Manufacturing Costs                15,310
    Annual Treatment Costs                    "3,563
    Annual Sales                             17,060
    Annual Variable Costs                     .12,847
    Manufacturing Cost Increase  (%)               23.3
    Profitability Reduction  (%)                   84.6
   i/Dollar values in thousand of second quarter 1983 dollars.

Source:  Effluent Guidelines Division (EPA) and Meta Systems,  Inc. 1983.
    Profitability for plants is measured.as the ratio of treatment costs
to net revenues,  assuming zero percent cost pass-through.   These values
are all quite high,  averaging 84.6 percent.  At this level of  reduced
profitability, continued manufacturing operations are unlikely.
8.5.2  Product Level Impacts

    Product level impacts on sodium sulfite are measured by price in-
creases and production changes.  There are no price or production changes
with a zero percent cost pass-through.  With the 100 percent cost pass-
through assumption, the  price increase is 20.9 percent and  the  production
decrease is 4.2 percent.  These values are both high.
8.5.3  Closure

    Closure is predicted  if a plant fails to pass either the  liquidity
test or the solvency test.  The liquidity of a plant is tested by
comparing treatment costs to cash flow.  Where treatment costs exceed cash
flow, it is possible that the plant will not have access to sufficient
cash to cover the cost of treatment.  Two of the three plants fail this
test and therefore would  be expected to close.

                                     8-3

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    In the test for solvency,  salvage  value  is compared  to net present
value.  Where the salvage value exceeds the  present value of the estimated
cash flow, a company might consider closing  the  production facility.  The
ratios of salvage value to the present value of  cash  flow range from 11.4
percent to 77.4 percent, but none of the plants  are identified as closures
on the basis of this test.
8.5.4  Employment

    The closure of these plants would result  in  the estimated loss of 38
jobs.
8.5.5  New Source Standards

    New source standards are assumed  to  be equal to the BAT standards.
The treatment costs examined here,  therefore,  represent significant bar-
riers to new plants entering the  sodium  sulfite manufacturing industry.
                                     8-4

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                                  Section 9
                        Sodium Chloride NSPS Malysis
9.1  Introduction
    This section presents an analysis of the impact of the existing no
discharge regulations upon new sources within the sodium chloride
subcategory.  Four alternatives for control of effluents are discussed.  The
first alternative involves the use of a surface condenser in place of a
barometric condenser.  Using a surface condenser of equal size forces a plant
to produce about 10 percent less than if a barometric condenser were used.
The second alternative involves the use of a surface condenser which is
scaled such that there is no difference in the production rate.  The third
and fourth alternatives  involve the use of cooling ponds and cooling towers,
respectively.   The fifth alternative represents the additional costs of
installing a surface condenser with costs 50 percent greater than those of
the second alternative described above (this estimate was provided by Morton
Salts).  Total annual cost of treatment is total capital cost times the
capital recovery factor, 0.1627, plus annual O&M plus annual sludge disposal
costs.
    The costs for the three alternatives involving surface condensers (1A,
IB, and IE) are the additional costs of installing a surface condenser
instead of a barometric  condenser, which is required for normal operation of
a sodium chloride plant. The model plant is assumed to produce 397,226
metric tons of sodium chloride per year with a wasteflow rate of 12 million
gallons per day.
9.2  Methodology
    The analysis described here conforms to that of other'subcategories which
is presented in Section  5.7 of this report.  The treatment costs are compared
to manufacturing costs and to net revenues to determine their potential
impact as barriers to entry into the market.

    Manufacturing costs  (i.e., fixed cost and variable costs) are estimated
using data available from the Census of Manufactures for 1977.  The following
data are taken from the  Census of Manufactures for the 5-digit SIC code
28991, Evaporated Salt.  The figures are expressed in millions of 1977
dollars.

    Value of Shipments                       247.6
    Cost of Materials                         92.8
    Total Wages-Production Workers             41.9
    Capital Expenditures-new                   25.2

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           Table 9-1.   Sodium Chloride Model Plant Treatment Costsi/
      Description                level

Small Surface Condenser^/         LA
Large Surface Condenser^/         IB
Cboling Fond                      1C
Cooling Tower                     ID
Surface Condenser with costs       IE
  150% of large surface
  condenser above:?/
      Treatment Cost
Capital     OM     Sludge
190.3
1566.4
648.0
683.5
2426.5
23.9
230.2
128.1
231.4
364.7
0.0
0.0
0.0
0.0
0.0
   1/thousands of 1983 dollars, using factor of 1.04 to convert 1982
dollars to 1983 dollars.

   .?_/Additional costs of  installing a surface condenser instead of a
barometric condenser.

Source:  Effluent Guidelines Division, EPA, 19-84.
                                     9-2

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The annual variable cost of manufacturing is estimated as the cost of
materials plus production worker wages, or 134.7 million dollars.  Annual
fixed cost is assumed to be equal to new capital-expenditures, or 25.2
million dollars.  Total fixed cost is estimated to be 193.8 million dollars,
using a capital recovery factor of 0.13.  Since total industry variable costs
represent 54 percent of the total value of shipments, the estimate of
variable cost for a particular plant is estimated as 54 percent of sales at
the plant.  Likewise, total fixed cost is estimated to be 78 percent of plant
sales.

    Plant sales is calculated as model plant production times a sodium
chloride price of 57.3 dollars per metric ton..!/  Model plant compliance
costs are provided by EPA for the five alternatives and are presented in
Table 9-1.
9.3  Results
    The results of the analysis for the five alternatives are summarized in
Table 9-2.   Itote that the production under Level  1A  (small surface condenser)
is 10 percent lower than the others.

    The use of a large surface condenser (Level IE) has the largest impact on
production cost and profit.  For this alternative treatment costs represent
7.3 percent of the profit and 5.2 percent of production cost.  None of the
alternatives presents any barrier to market entry.
   i/ Chemical Marketing Reporter, December 6,  1982—350 per short ton,
converted to 1983 dollars using factor of 1.04.
                                     9-3

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                           Table 9-2.   NSPS  Impact Analysis
                                  Sodium ChlorideV
Level
1A
IB
1C
ID
IE
Annual
Production
357.6
397.3
397.3
397.3
397.3
Fixed
Cost
17747
17747
17747
17747
17747
Ann.
Var.
Cost
12286
12286
12286
12286
12286
Annual
Sales
20477
22752
22752
22752
22752
Net Rev.
as % of
Fixed Cost
46.2%
57.2
57.2
57.2
57.2
Tot. Ann.
Trtmt.
Cost
54.9
485.1
233.6
342.6
759.5
Prod.
Cost
Change, %
0.38%
3.32
1.60
2.35
5.20
Profit
Decline, %
0.67%
4.63
2.23
3.27
7.26
   I/thousands of  1983 dollars, using factor of  1.04 to convert 1982 dollars to  1983
dollars.

Source:  Meta Systems, Inc. estimates.
                                     9-4

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                                 Appendix 2A
                            Process Descriptions
 Cadmium  Pigments

     Yellow cadmium pigments are made by precipitating a cadmium sulfate
 solution with a sodium sulfide solution.  Red tones are produced by first
 dissolving selenium in the sulfide solution in a ratio to cadmium that may
 vary from 1:9 to 3:7.  Zinc compounds may be added to obtain some lighter
 yellow and red tones and barium salts are used for lithopones,  but the
 model plant manufacturing costs are based on selenium and cadmium only in
 a  ratio  of 2:8.  The precipitate is dewatered, calcined, ground, washed,
 dried and mechanically processed.
 Cadmium Salts

    Cadmium chloride, nitrate and sulfate are made by dissolving metallic
 cadmium in the respective acid.  The solution is filtered and the salt
 concentrated by evaporation.  Cadmium chloride is crystallized.   The solid
 salts are separated from the mother liquor and dried.
Cobalt Salts

    Cobalt chloride, nitrate and sulfate are made by dissolving the  metal
or oxide in the respective acid.  The raw solution is a marketable pro-
duct.  Alternatively, it is purified, and the salt subsequently evapo-
rated, crystallized, separated and dried.
Copper Salts

    Copper carbonate is made by precipitating a copper sulfate solution
with carbon dioxide or aqueous sodium carbonate.

    Copper chlorides are produced either by the chlorination of copper  in
a gas-liquid-solid system, or by interaction of copper sulfate and  barium
chloride solutions.  In the former case, both cuprous and cupric chlorides
will form in various proportions depending on the operating conditions.
The cuprous salt crystallizes first and cupric chloride is then concen-
trated by evaporation.  In the barium route, a cupric chloride solution  is
obtained after the insoluble barium sulfate is separated.  The cupric ions
may then be reduced to the cuprous form by metallic copper.  Both salts
are ultimately concentrated by evaporation.

    Copper iodide is synthesized in molten form from its elements,  molded
and ground.  It can also be produced by precipitation.

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    Copper nitrate is made by dissolving the metal or oxide in nitric acid
 (a saleable product) and purifying and evaporating the resulting solu-
tion.  The present estimates are based on the production of the dry salt.
Nickel Salts

    Nickel chloride and nitrate are made by dissolving metallic nickel  or
the oxide in the respective acid.  The solution is a marketable product
but this study assumes further purification, evaporation,  crystallization,
salt separation and drying.

    Nickel carbonate is produced from the nitrate solution by  precipita-
tion with a sodium carbonate solution.  The precipitate is separated  and
dried.

    Nickel fluoborate is sold in an aqueous solution obtained  by dis-
solving the carbonate in concentrated fluoboric acid and purifying  the
resulting liquid if necessary.
Sodium Chlorate

    Sodium chlorate is made by the electrolysis of  a  purified  sodium
chloride brine in the presence of sodium dichromate and  hydrochloric
acid.  The resulting solution is evaporated and filtered.   The salt is
then crystallized, dried and ground.
Zinc Chloride
    Zinc Chloride is produced by dissolving the  metal  or  oxide  in hydro-
chloric acid.   After removing iron impurities  (if  necessary) and decolor-
izing, the solution is concentrated by evaporation and sold.  Alterna-
tively, the solution is purified, if necessary,  and evaporated  to a higher
degree (5 percent water).   The solid "butter of  zinc," as the product is
known, then solidifies on  cooling.
                                    2A-2

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                                 Appendix 2B

              Regression Bguations for Business Cycle Analysis
    The Business Cycle Analysis of Section 2 evaluated certain ratios in
an attempt to estimate changes in profitability over time.  Regressions
were run and discussed briefly in Section 2.  This appendix provides tech-
nical back-up for the information presented in Section 2.

    Cash flow ratios (defined as value added - payroll/value of shipment)
for the two principal SIC groups, 2816 and 2819, were regressed against
various macroeconomic variables.  The variables were the Industrial Pro-
duction Index, the Metals Products Price Index, and a trend variable.  SIC
2819 exhibited poor correlation with all of the variables examined.  SIC
2816 showed a high correlation to several of the variables.

    The assumption of the following model is that profits are related to
capacity utilization, price, and some  (unidentified) time related pheno-
mena.  Profit is represented by the cash flow ratio described above,
capacity utilization is represented by total industrial production (IPI),
and price is represented by the metals price -index (in constant dollars)
lagged one year.

    The estimated equation for SIC group 2816 is presented below with the
t-statistics for each coefficient noted in parentheses.  A t-statistic
close to 2 or -2 indicates that there is a 90 percent probability that the
variable associated with that t-statistic has some impact on the dependent
variable (in this case Log CFR).
    Log(CFR28i6)  = -10.169  +  0.939 Log(IPI)   +  1.06 Log (DMPI)  - 0.069 TIME
                     (-2.69)    (1.75)              (2.69)            (-3.26)

    R2  =  0.781

where:

    CFR2816     =   tne ratio of cash flow to value of industry shipments  for
                    SIC group 2816

    IPI         =   Industrial Production Index

    DMPI        =   the Metal products  (SIC33)  price index, lagged  one  year,
                    in constant 1972 dollars
    TIME        =   trend variable with 1=1965,  2=1966,  etc.
    Two of the three coefficients are highly significant and  the  fit  is
good.  The cost variable, DMPI, has a coefficient significant at  the  0.02
level.  A value of 1.06 indicates that increases in  metal prices  are
reflected in even greater increases in CFR.   The IPI variable is  signifi-
cant only at the 0.11 level.   The coefficient of log (IPI)  is 0.939,
indicating that the CFR is slightly less sensitive to changes in  IPI.  For

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practical purposes, the coefficients of IPI  and  DMPI  are both close to
1.0, indicating that the rate of change of cash  flow  is close to propor-
tional with respect to either of these variables.   The trend variable TIME
is significant at the 0.02 level.   It has  been specified here as a
logistic decay function (i.e., the  incremental effect of TIME on CFR will
dampen the growth of CFR as TIME increases).

    Considering the anticipated values of  IPI, DMPI and TIME over the next
several years, TIME has by far the  greatest  influence on changes in CFR.
This suggests that some time-related conditions  other than metals price
and industrial production have more influence on the  CFR than the IPI or
the Metal Price Indices.
                                     2B-2

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                                Appendix  3A
                     Calculation of Manufacturing Costs
    Manufacturing costs are developed for model inorganic chemical plants
producing cadmium pigments, cadmium salts, cobalt salts,  copper  carbonate,
copper salts, nickel carbonate, nickel salts,  sodium chlorate, and zinc
chloride.  Table 3A-1 summarizes the characteristics and  process economics
for the model plants used in this analysis.  The production rates were
chosen to represent typically-sized facilities in order  to estimate treat-
ment costs.

    The process economics were developed for this study based on litera-
ture review and the application of engineering principles.   The  process
economics consist of capital investment and the different operating costs—
materials, utilities, operating labor, maintenance labor, supervision,
other fixed costs such as taxes and insurance.  Capital investment
estimation requires information regarding the  production  units used in
these plants, scale, and the specific heat and pressure requirements of
the process.  Labor requirements were estimated using empirical  relation-
ships between labor requirements and production units.  Materials require-
ments are estimated by stoichiometry and estimated reaction efficiencies,
and the other costs are estimated using standard cost estimation tech-
niques and these estimates of fixed cost, labor and materials.

    Process economics for specific plants were estimated  from these model
plant process economics following the procedures described  in Appendix 3B.

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            4J _fl
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          •5 -w O
          at m »
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          — Ox
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         - 0 J •"

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                S§
                 2  .5
                          .a IA

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                                  3A-2

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                                 Appendix 3B

                 Actual Plant Manufacturing  Cost  Adjustments
    Manufacturing costs for a specific plant are estimated by using model
plant costs with adjustments for production capacity and operating time.
Assuming equal capacity utilization rate, the ratio of real plant capacity
to the model plant capacity is  (Q/Qn,)  (D^/D), where Q is annual produc-
tion, D is the number of operating days per year and the subscript m
denotes model plant values.  Fixed costs (PC) for the actual plant are
then estimated as:

     FC =  [(Q/Qm)  (Djn/D)]3 FC^


where a =0.5 for small plants  (Q less than 10,000 metric tons/year)  and a
= 0.6 for large plants.  The use of a smaller exponent for small plants is
based on the fact that, because of the fixed startup costs applicable to
even the smallest plants, unit costs rapidly decrease with size.  The
costs for materials and utilities (MU) are assumed directly proportional
to production:

     MU =  (Q/Qj,,) MUm.
Operating labor costs (OL)  are estimated by scaling according to both
capacity and operating time:

     OL =  [
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                                  Table 3B-1.

                Ifypothetical  Calculation of Manufacturing Costs
                           for a Multi-Product Plant

Q(MT/yr)
D(days/yr)
FC( J>xl03)
MU ($x!03/fyr )
OL($xlo3/yr)
ML($xlo3/yr)
SUP(£xl03/yr)
OV($xl03/7r)
OFC ($X 103/yr }
VC{fixl03/yr)
P($/MT)
1 Cobalt
I Salts
1
35
40
2,500
100
50

10



8,527
1
1 Copper I
I Salts |
90
25
6,800
130
15

3



3,193
1 - 1
Nickel
Salts
440
160
4,700
620
200

40



3,237
1
1 Entire
1 Plant
565 I/
225 I/
6,800 I/
850 I/
265 I/
132
53 I/
160
221
1,681
1
    / Sum of values for individual products.

   2/ Maximum of values for individual products.
    Table 3B-1 shows the figures for  a hypothetical multi-product plant
that produces cobalt, copper and nickel salts.   Copper  salt manufacturing
has the highest fixed costs of the three and  thus  the fixed costs for  the
entire plant are assumed to be $6,800 x 10^.  Variable  costs  that are
independent of fixed costs (maintenance and utilities - MU, operating
labor - OL, and supervision - SUP)  are summed across the products.
Variable costs that depend on fixed costs (maintenance  and labor--ML,  and
other fixed costs—OFC)  are calculated as a fraction of $6,800 x 103.

    For all plants (single or multi-product), the  total variable costs
(VC)  are:
    VC
MU + OL + ML + SUP + 0V + OFC
The amortized fixed costs (AFC)  are  calculated based on a  10 percent
interest rate and a time horizon of  15  years.
                                     3B-2

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                                Appendix 3C
                  Estimation of Supply Curves, Elasticities

                       and Cost Pass-Through Factors
    This appendix addresses the estimation of  the portion of  treatment
costs which are passed through to consumers as higher  prices.   The estima-
tion of cost pass-through factors requires information on supply elasti-
cities which, in turn, requires the construction of  supply curves.  This
appendix will discuss, in turn, supply curve construction, supply elasti-
city estimation, and cost pass-through factor  estimation.
    Supply Curve Construction

    The information necessary for a precise supply curve—marginal costs
as a function of quantity produced—is not available.   However,  the
following method serves as a reasonable surrogate.  The unit manufacturing
costs for all plants in a subcategory are estimated  and ranked  from
smallest to largest.  Let C^ be the itfl smallest  unit cost and  qj be
the production of the corresponding plant.  If  the price  P is at least
C^, then plants 1 through i would each produce  an amount  leading to an
output of
    * -
The points (Q^, Ci)  then define the supply curve.  The  supply curve
can be "calibrated"  to fit a subcategory by adjusting  the  return on
investment (ROD  portion of the plant costs,  C^, until  a horizontal line
passing through the  price for that subcategory  intersects  the curve near
(what is judged to be)  the marginal plant in  that  subcategory.

    For subcategories with adequate data, the supply curve is expressed
algebraically by fitting a cubic equation to  the point  (Qj_, C^) where
C, the cost,  translates into P, the price in  the following equation:

    P  =  a + bQ + cQ2 + dQ3

For other subcategories, this curve is expressed graphically by fitting a
smooth curve  to the  observed points.

    The representation of the different plants  in  an industry segment with
a supply curve implies, among other things,  that those  plants produce the
same product and sell it to a single market.  Of the seven industry sub-
sectors considered i/,  sodium chlorate comes  closest to this descrip-
tion.  Zinc chloride plants produce several grades of zinc chloride for
   i/ For this analysis,  copper salts have been  combined with copper
carbonate and nickel salts have been combined with nickel carbonate.

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 both captive and merchant markets.  The other subcategories are aggregates
 of several chemicals and therefore depart even further from the one
 product, one market paradigm.  Sodium chlorate is therefore the only
 subcategory to be represented algebraically.  The fitted equation is:

 P  =  0.256 +  (1.487 x 10~6)Q - (8.713 x ICT12)  Q2 + (1.855 x 10~17)Q3


 The other subcategories were fitted graphically.


    Supply Elasticity Estimation

    The elasticity of supply (es)  is the slope of the supply curve at
 the current price Po and production QQ.  It is estimated by:

    es  =  (PO/OO) (<3Q/<3P)0

    Supply elasticity is estimated in the sodium chlorate subcategory  to
 be 1.03.  Supply elasticities in other subcategories range from 0.24 to
 3.15, but they are based on less reliable supply curve information.  These
 values are presented in Table 3C-1.  These supply elasticities are used in
 the following estimation of the cost pass-through factor.


    Cost Pass-Through

 The cost pass-through (the ratio of price increase to the unit cost of
 treatment) is

    dP/t = es/(es - ed)

 where es and e
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                   Table 3C-1.
Supply Elasticity and Cost Pass-Through Estimates
                 By Subcategory
Subcategory
Copper Salts (including
  Copper Carbonate)

Nickel Salts (including
  Nickel Carbonate)

Sodium Chlorate

Zinc Chloride
                               0.24


                               0.19

                               1.03

                               0.161
                                       [Cost Pass-Through
                                           dP/t  (%)*
Cadmium Pigments
Cadmium Salts
Cobalt Salts
3.15
0.81
0.78
-0.1
-0.3
-0.4
95
73
66
                                              -0.3


                                              -0.2

                                              -0.15

                                              -0.2
                                              44


                                              49

                                              87

                                              45
   * dP/t =
the report.
                      ,  with
                estimates as described in Section 2 of
                    3C-3

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    The actual pass-through of treatment costs is more complicated than
this estimation technique can capture.  In the case of sodium chlorate/
there are several plants of similar size selling to a merchant market,  and
the results of the supply curve analysis suggest that a high proportion of
the costs will be passed through.  With zinc chloride, various product
grades are produced and the plant sizes range from less than 5,000 to
almost 30,000 tons per year, suggesting that captive markets exist and
that a single supply curve is a less appropriate tool for this purpose.
The supply curves in the other subcategories are composites of plants with
different scales, markets and products, and are therefore even less likely
to respond to treatment costs in a manner shown by this graphical  pro-
cedure.

    In theory, since this sector of the inorganic chemicals industry
produces at significantly less than productive capacity, the supply curve
should be close to horizontal, the supply elasticity should be high and
the cost pass-through should be close to 100 percent.  The results of the
sodium chlorate analysis support this theory.  Since that analysis is the
most valid and assuming that pricing behavior for the other chemicals is
similar, the 100 percent cost pass-through has been used for all of the
subcategories.  Accordingly, section 5 of the report assumes that  the cost
pass-through is 100 percent.  Section 7 tests the sensitivity of the
results of the analysis to this assumption.
                                    3C-4

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