vvEPA
United States
Environmental Protection
Agency
Office of Analysis and Evaluation
Office of Water and
Waste Management
Washington, DC 20460
EPA-440/2-80-001
November 1979
Water
Economic Impact Analysis of
Proposed Revised Effluent
Guidelines and Standards for the
Paint Manufacturing Industry
QUANTITY
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EPA-440/2-80-001
November 1979
ECONOMIC ANALYSIS OF PROPOSED REVISED
EFFLUENT GUIDELINES AND STANDARDS
FOR THE PAINT MANUFACTURING INDUSTRY
Prepared for
OFFICE OF WATER PLANNING AND STANDARDS
ENVIRONMENTAL PROTECTION AGENCY
Washington, D. C. 20460
under
Contract No. 68-01-4466
ion Agency
US.
Region V, Li: *^ street
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U»6. Environment-1
'rc.taction Agency
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This report has been reviewed by the Office of
Planning and Evaluation. EPA, and approved
for publication. Approval does not signify that
the contents necessarily reflect the views and
policies of the Environmental Protection
Agency, nor does mention of trade names or
commercial products constitute endorsement or
recommendation for use.
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PREFACE
The attached document is a contractor's study prepared for the Office of Analysis and
Evaluation of the Environmental Protection Agency ("EPA"). The purpose of the study is to
analyze the economic impact which could result from the application of alternative BPT, BAT,
PSES, NSPS, PSNS guidelines established under the Federal Water Pollution Control Act (the
Act), as amended.
The study supplements the technical study ("EPA Development Document") supporting
the proposal of regulations under the Act. The Development Document surveys existing and
potential waste treatment control methods and technology within particular industrial source
categories and supports proposed limitations based upon an analysis of the feasibility of these
limitations in accordance with the requirements of the Act. Presented in the Development
Document are the investment and operating costs associated with various alternative control and
treatment technologies. The attached document supplements this analysis by estimating the
broader economic effects which might result from the required application of various control
methods and technologies. This study investigates the effect of alternative approaches in terms of
product price increases, effects upon employment and the continued viability of affected plants,
effects on production, effects upon foreign trade, and other community and competitive effects.
The study has been prepared with the supervision and review of the Office of Analysis and
Evaluation of the EPA. This report was submitted in fulfillment of Contract No. 68-01-4466 by
Arthur D. Little, Inc. This report reflects work completed as of October 1979.
This report is being released and circulated at approximately the same time as publication
in the Federal Register of a notice of proposed rule making. The study is not an official EPA
publication. It will be considered along with the information contained in the Development
Document and any comments received by EPA on either document before or during proposed rule
making proceedings necessary to establish final regulations. Prior to final promulgation of
regulations, the accompanying study shall have standing in any EPA proceeding or court
proceeding only to the extent that it represents the views of the contractor who studied the
subject industry. It cannot be cited, referenced, or represented in any respect in any such
proceeding as a statement of EPA's views regarding the paint manufacturing industry.
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TABLE OF CONTENTS
Page
List of Tables v
List of Figures viii
I. EXECUTIVE SUMMARY 1
A. PURPOSE AND SCOPE 1
B. METHODOLOGY 1
C. PRESENT ECONOMIC CONDITIONS 1
D. SUMMARY OF ECONOMIC IMPACT 2
E. LIMITS OF THE ANALYSIS 4
II. PURPOSE AND AUTHORITY 5
A. BAT EFFLUENT LIMITATIONS 5
B. NEW SOURCE PERFORMANCE STANDARDS 5
C. PRETREATMNT STANDARDS FOR EXISTING SOURCES 6
D. PRETREATMENT STANDARDS FOR NEW SOURCES 6
III. METHODOLOGY 7
A. INDUSTRY SEGMENTS AND MODEL PLANTS 7
B. PRELIMINARY DETERMINATION OF IMPACT 7
C. ECONOMIC IMPACTS 7
D. SENSITIVITY 7
IV. PRE-REGULATION INDUSTRY CONDITIONS 9
A. INDUSTRY CHARACTERISTICS 9
B. INDUSTRY SEGMENTATION 11
V. CONTROL COSTS 20
A. OPTIONS 20
' B. APPLICATION OF COSTS 20
VI. ECONOMIC IMPACT 24
A. IMPACT SCREENING 24
B. IMPACT ANALYSIS OF SELECTED OPTIONS 28
111
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TABLE OF CONTENTS (Continued)
Page
VII. LIMITS OF THE ANALYSIS 35
A. MODEL PLANTS 35
B. CONTROL COSTS 35
C. AMOUNT OF EFFLUENT 35
D. CAPITAL AVAILABILITY 35
E. PRICE INCREASE 35
F. CONTRACT HAULING COSTS 36
G. CAPITAL INVESTMENT PAYBACK 38
H. WASTEWATER/PRODUCTION RATIO 40
I. DISCOUNTED CASH FLOW VS. PLANT SALVAGE VALUE 42
VIII. REFERENCES 43
IV
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LIST OF TABLES
Table No. Page
1 Summary of Economic Impact of P/C Pretreatment on the
Paint Industry 2
2 Summary of Economic Impact of Zero Discharge on the
Paint Industry 2
3 Summary of Impact of Wastewater Treatment Costs
BAT, NSPS, PSES, PSNS 3
4 Paint Plants by Corporate Organization 12
5 Plant Distribution by Site Status 12
6 Average Number of Employees per Paint Plant 13
7 Distribution of Paint Plants by Age of Operation 13
8 Average Paint Plant Production Last Five Years 14
9 Distribution of Trade Sales as a Percent of Total Paint Produced 14
10 Distribution of Chemical Coatings as a Percent of Total Paint
Produced 15
11 Distribution of Allied Products as a Percent of Total Paint
Produced 15
12 Distribution of Water-Thinned Paints as a Percent of Total 16
13 Distribution of Solvent-Thinned Paints as a Percent of Total 16
14 Financial Profiles of Model Paint Plants 18
15 Physical Chemical Pretreatment Costs 21
16 Physical Chemical Pretreatment With Biological Treatment Costs 21
17 Wastewater Recycle With Contract Hauling Costs 21
18 Wastewater Recycle With Physical Chemical Pretreatment Costs 22
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LIST OF TABLES (Continued)
Table No. Page
19 Wastewater Recycle With Physical Chemical Pretreatment and
Biological Treatment Costs 22
20 Contract Hauling Costs 22
21 Manually Operated Physical Chemical Pretreatment Costs 23
22 Impact of Physical Chemical Pretreatment Costs 24
23 Impact of Physical Chemical Pretreatment With Biological
Treatment Costs 24
24 Impact of Wastewater Recycle With Contract Hauling Costs 25
25 Impact of Wastewater Recycle With Physical Chemical
Pretreatment Costs 25
26 Impact of Wastewater Recycle With Physical Chemical
Pretreatment and Biological Treatment Costs 26
27 Impact of Contract Hauling Costs 26
28 Impact of Manually Operated Physical Chemical Pretreatment Costs 27
29 Summary of Impact of Wastewater Treatment Costs
BAT, NSPS, PSES, PSNS 23
30 Average Price Increase to Maintain ROI Physical Chemical
Pretreatment 30
31 Industry Control Costs for Option 1 Physical Chemical
Pretreatment 30
32 Industry Costs for Option 2 - Zero Discharge 31
33 Impact of Zero Discharge Control Costs on Direct Dischargers 31
34 Effect of 24 Price Increase 32
35 Profit Before Tax After Treatment Per Gallon Product 32
VI
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LIST OF TABLES (Continued)
Table No. Page
36 Wastewater Discharge Practice 33
37 Sensitivity of Contract Hauling Costs on Physical Chemical
Pretreatment Costs 36
38 Sensitivity of Contract Hauling Costs on Wastewater Recycle
Costs 36
39 Sensitivity of Contract Hauling Costs on Manually Operated
Physical Chemical Treatment Costs 37
40 Sensitivity of Contract Hauling Costs on Contract Hauling 37
41 Effect of Payback Period for Manually Operated Physical
Chemical Treatment Investment 38
42 Effect of Payback Period for Contract Hauling Investment 39
43 Effeet of Increased Wastewater/Product Ratio 40
44 Cost for Reduction of Wastewater From 0.2/Gal to 0.04 Gal/Gal
Via High Pressure Rinsing With Contract Hauling 41
45 Impact of Wastewater Reduction With Contract Hauling Costs 41
46 Discounted Cash Flow Vs. Salvage Value 42
VII
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LIST OF FIGURES
Figure No. Page
1 Geographical Distribution of Paint Manufacturing Sites TO
2 Percentage of Total Plants by Segment Vs. Percentage of
Total Production by Segment 19
Vlll
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I. EXECUTIVE SUMMARY
A. PURPOSE AND SCOPE
The work covered in this report was authorized by the Environmental Protection Agency
under contract number 68-01446. The objective of the work was to examine the economic impact
of various options for the control of wastewater from paint manufacturing plants. The control of
wastewater from paint manufacturing plants will be covered under BAT, PSES, PSNS and
NSPS regulations. BAT is the best available technology covered in the Development Document
and will affect all plants which discharge wastewater. PSES is pretreatment standards for
existing sources, and the regulation will cover all plants which are currently indirect dischargers.
PSNS and NSPS are regulations for new sources and cover pretreatment standards for indirect
dischargers and performance standards for direct dischargers.
Technical data concerning costs for various control options, numbers and sizes of plants and
their respective wastewater discharge characteristics were furnished by the technical contractor
to the Effluent Guidelines Division. Other information and data were obtained from National
Paint and Coatings Association, Robert Morris Associates, Kline Guide to the Paint Industry,
various trade journals, U.S. Government data, and Arthur D. Little, Inc., estimates.
The regulations will be established to control discharge of pollutants by plants manufac-
turing paint as defined in SIC 2851.
B. METHODOLOGY
The paint manufacturing industry was characterized in a general way by reviewing Bureau
of Census data, the Paint Industry Redbook, Kline's Guide to the Paint Industry, the EPA 308
survey, and Arthur D. Little, Inc., estimates. Using this data, the industry was segmented by
plant production size. Financial models for plants in each segment were prepared to correspond
with available financial data. A preliminary determination of impact was prepared using the
control costs furnished by EPA. Before-tax return on investment was selected as the screening
criterion, since there was little difference in this value on the basis of plant size. On the basis of
the screening analysis, two segments very small, and small were determined to be poten-
tially impacted. For these segments detailed impact evaluations were made for two control
options zero discharge by contract hauling and physical/chemical pretreatment. Price effects,
plant closures, production effects, and employment effects were calculated. In addition, total
industry costs for investment and annual operating costs were calculated.
C. PRESENT ECONOMIC CONDITIONS
The paint industry comprises some 1500 plants. Sixty-five percent of these plants are small,
single-location, privately owned firms with less than 20 employees, less than $1 million in sales
and with manufacturing facilities more than 30 years old. Together these plants account for only
11% of the total paint production. Some 35% of the plants account for 90% of the U.S. paint
production. Sales range from less than $250,000 for the smallest plants to over $50 million for the
very largest. Return on investment before tax ranges from 14 - 20%.
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D. SUMMARY OF ECONOMIC IMPACT
An examination of the economic impact of control costs on model plant profitability
indicates that the smallest plants are the most seriously affected. While the Effluent Guidelines
Division presented costs for several control options, two were selected for detailed analysis.
Option one involves physical-chemical pretreatment and Option two provides for zero discharge
by the most economical method. In the case of Option one, the total industry costs are expected to
be in the order of $5.5 million, which will be partly offset by an expected price increase of about
2.0d; gallon. Closures of 155 very small plants can be expected on the basis of economic impact.
Total industry costs for plants to comply with Option two are about $11 million. In this case, 232
very small plants can be expected to close because of economic impact, as shown in Tables 1 and
2. Table 1 summarizes the impact of Option one Physical/Chemical Pretreatment. Table 2
shows the impact for Option Two Zero Discharge by the most economical means (contract
hauling for very small, small and medium plants, wastewater recycle with contract hauling for
the rest).
TABLE 1
SUMMARY OF ECONOMIC IMPACT OF P/C PRETREATMENT ON THE PAINT INDUSTRY
($000)
Segment
No. Plants
Plants in Compliance
Balance
Total Investment to Comply
Total Annual Cost
Predicted Closures
Unemployment Estimate
VS
M
VL
Total
469
314
155
2945
1503.5
155
775
513
344
169
3211
1639.3
0
0
296
199
97
3016.7
1746
0
0
111
74
37
1639.1
947.2
0
0
111
74
37
2516
1783.4
0
0
1500
1005
495
13327.8
7619.4
155
775
TABLE 2
SUMMARY OF ECONOMIC IMPACT OF ZERO DISCHARGE* ON THE PAINT INDUSTRY
($000)
Segment
No. Plants
Plants in Compliance
Balance
Total Investment to Comply
Total Annual Cost
Predicted Closures
Unemployment Estimate
VS
M
VL
Total
469
237
232
881.6
1020.8
232
1160
513
259
254
965.2
1778
0
0
296
150
146
1591.4
3518.6
0
0
111
56
55
2805
1848
0
0
111
56
55
4565
2816
0
0
1500
758
742
10808.2
10981.4
232
1160
'Contract hauling for VS, S and M wastewater recycle with contract hauling for L and VL.
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TABLE 3
SUMMARY OF IMPACT OF WASTEWATER TREATMENT COSTS
BAT. NSPS, PSES. PSNS
Segment
Treatment
Physical Chemical
Physical Chemical with Biological Treatment
Wastewater Recycle with Contract Hauling
Wastewater Recycle with Physical Chemical
Wastewater Recycle with Physical Chemical
Pre-Treatment and Biological Treatment
Contract Hauling
Manually Operated Physical Chemical
vs
A
-4.2*
25.2*
-8.9*
13.5*
27.3*
4.5*
-0.4*
B
88*
697*
89.4*
160*
768*
17.6
17.6
S
A
10.2*
-10.0*
8.3*
4.8*
-12.1*
12.9
12.9
B
47*
373*
47.7*
85.4*
411*
9.4
9.4
M
A
16.8
8.7*
16.4
15.7
7.9*
16.5
18.6
B
10.8
56.3*
11.8
17.1
62.6*
3.8
1.6
L
A
12.8
9.9*
12.4
12.2
7.0*
12.1
NA
VL
B
6.1
24.0
7.0
9.0
26.9*
2.1
NA
A
17.7
16.7
17.6
17.6
16.6
16.7
NA
B
2.4
7.0
2.9
3.7
8.3
1.2
NA
A = Before Tax Return on Investment After Treatment
B = Control Investment as % of Fixed Assets
* = Potential Impact
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E. LIMITS OF THE ANALYSIS
There are several critical assumptions which have a bearing on the accuracy of the analysis.
1. Model Plants
It is assumed that all plants in a segment are identical to the financial model for that
segment. Any serious discrepancy in the 1976 profitability ratios could produce a large change in
the degree of impact.
2. Control Costs
The sensitivity analysis indicated that no serious changes in impact occurred if operating
costs were underestimated. However, if investment costs and annual capital costs are under-
estimated then a much larger portion of the small segment and part of the medium segment
would become potential closure candidates.
3. Amount of Effluent Discharged
A major variable concerns the ratio of wastewater discharged to the number of paint gallons
produced. The 308 survey indicated a wide range of values. If this is much larger than estimated,
the impact will be more serious because of both the increased investment cost and increased
operating and maintenance costs to handle a larger volume.
4. Capital Availability
For the economic analysis, capital was assumed borrowable on a 5 year direct reduction
annual payback note at 12% interest. While the interest rate sensitivity is an important factor in
the overall cost, the payback period has greater sensitivity. For instance, in the case of very small
and small plants where financing might be difficult at best, a negative cash flow would result on
paybacks of three years or less. In addition, the amount of capital required is a large percentage of
plant fixed assets for very small and small plants. In this case, any loan would probably have to
be self-financed or secured by a second mortgage on the owner's home, etc., at much higher
interest rates.
5. Contract Hauling Costs
In some sections of the country, contract hauling costs are reported higher than those
furnished. The sensitivity analysis shows that this also is a critical area.
Four factors contributing to control costs were found to be very sensitive in terms of their
effect on closure probability. One is the cost for contract hauling of wastewater. If these costs are
greater than those presented, a negative cash flow may result for all of the very small plants and
for some of the small plants. Second, the cost of capital and, particularly, its payback period are
important. Any requirement for capital investment for non-productive equipment is extremely
difficult for small plants to manage, particularly on a short-term payback basis. Third is the ratio
of water-thinned production to total paint production. Any increase in the ratio provided by EPA
will result in a comparable increase in costs and reduced profits. Fourth, and perhaps most
important, is the amount of wastewater discharged per unit of production. For the smaller plants,
even a slight increase in this ratio will reduce profits to zero. Since about 20% of the industry
responses to the 308 survey indicated ratios as much as five times higher than the ratio selected
by the technical contractor, the actual number of closures may be higher than that estimated.
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II. PURPOSE AND AUTHORITY
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). By July 1, 1977, existing industrial dischargers were required to achieve
"effluent limitations requiring the application of the best practicable control technology cur-
rently available" ("BPT"), Section 301(b)(l)(A); and by July 1, 1983, these dischargers were
required to achieve "effluent limitations requiring the application of the best available tech-
nology economically achievable. . . . which will result in reasonable further progress toward the
national goal of eliminating the discharge of all pollutants" ("BAT"), Section 301(b)(2)(A). New
industrial direct dischargers were required to comply with Section 306 new source performance
standards ("NSPS"), based on best available demonstrated technology; and new and existing
dischargers to publicly owned treatment works ("POTW's) were subject to pretreatment stand-
ards under Sections 307(b) and (c) of the Act. While the requirements for direct dischargers were
to be incorporated into National Pollutant Discharge Elimination System (NPDES) permits
issued under Section 402 of the Act, pretreatment standards were made enforceable directly
against dischargers to POTW's (indirect dischargers).
A. BAT EFFLUENT LIMITATIONS
The factors considered in assessing best available technology economically achievable
(BAT) include the age of equipment and facilities involved, the process employed, process
changes, non-water quality environmental impacts (including energy requirements) and the costs
of application of such technology [Section 304(b) (2)(B)]. In general, the BAT technology level
represents the best economically achievable performance of plants of various ages, sizes, proc-
esses or other shared characteristics. BAT may include process changes or internal controls, even
when not common industry practice.
The Agency has considered the volume and nature of discharges, the volume and nature of
discharges expected after application of BAT, the general environmental effects of the pollutants,
and the costs and economic impacts of the required pollution control levels.
Despite this expanded consideration of costs, the primary determinant of BAT is effluent
reduction capability. As a result of the Clean Water Act of 1977, the achievement of BAT has
become the principal national means of controlling toxic water pollution. Although direct dis-
charges of paint wastewater are small fractions of wastewater from paint manufacturing oper-
ations, the Agency is setting BAT limitations which are also applicable to existing indirect
dischargers who might convert to direct discharge. The paint formulating industry discharges
over 50 different toxic pollutants and EPA has selected among seven available BAT technology
options which will reduce this toxic pollution by a significant amount.
B. NEW SOURCE PERFORMANCE STANDARDS
The basis for new source performance standards (NSPS) under Section 306 of the Act is the
best available demonstrated technology. New plants have the opportunity to design the best and
most efficient paint manufacturing processes and wastewater treatment technologies, and, there-
fore, Congress directed EPA to consider the best demonstrated process changes, in-plant controls,
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and end-of-pipe treatment technologies which reduce pollution to the maximum extent feasible.
Because BAT represents the limit of current technology, the seven options considered for NSPS
are identical to the seven options described above under BAT Effluent Limitations. No further
improvement in technology is anticipated in new sources. However, a new plant may reduce the
hazardous waste generated in meeting NSPS as a result of extensive in-plant control being
incorporated into plant design.
C. PRETREATMENT STANDARDS FOR EXISTING SOURCES
Section 307(b) of the Act requires EPA to promulgate pretreatment standards for existing
sources (PSES), which must be achieved within three years of promulgation. PSES are designed
to prevent the discharge of pollutants which pass through, interfere with, or are otherwise
incompatible with the operation of POTWs. The Clean Water Act of 1977 adds a new dimension
by requiring pretreatment for pollutants, such as heavy metals, that limit POTW sludge manage-
ment alternatives, including the beneficial use of sludges on agricultural lands. The legislative
history of the 1977 Act indicates that pretreatment standards are to be technology-based,
analogous to the best available technology for removal of toxic pollutants. The general pre-
treatment regulations (40 CFR Part 403), which served as the framework for these proposed
pretreatment regulations for the paint formulating industry, can be found at 43 FR 27736 (June
26,1978).
D. PRETREATMENT STANDARDS FOR NEW SOURCES
Section 307(c) of the Act requires EPA to promulgate pretreatment standards for new
sources (PSNS) at the same time that it promulgates NSPS. New indirect dischargers, like new
direct dischargers, have the opportunity to incorporate the best available demonstrated tech-
nologies, including process changes, in-plant controls, and end-of-pipe treatment technologies,
and to use plant site selection to ensure adequate treatment system installation. The pre-
treatment options for new dischargers to POTWs are the same as those for PSES, presented in the
preceding section.
The purpose of this report is to provide the economic impact support for any BAT, BPT, or
NSPS pretreatment standards for existing sources (PSFS), and pretreatment standards for new
segments of the Paint Industry, under Sections 301, 304, 306, 307 and 501 of the Clean Water Act.
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I. METHODOLOGY
A. INDUSTRY SEGMENTS AND MODEL PLANTS
After the Paint Industry was characterized in a general way, the plants were segmented by
size in terms of sales/production. Sizes were selected to correspond with available financial data.
For each segment, a model statement of revenues minus total costs was prepared. The major item
from which control costs were to be subtracted is profit before tax. Other features such as plant
fixed assets, working capital, etc., were also calculated. Return on investment before tax was
selected as a key financial indicator because there is little difference in this value for each of the
model plants. It therefore offers the opportunity of comparing the impact of various control costs
regardless of plant size by applying a single criteria for evaluating the impacts.
B. PRELIMINARY DETERMINATION OF IMPACT
Applying costs for control to the profit before tax for each model resulted in an estimated
profit before tax after treatment. This value divided by the total plant investment (net fixed
assets plus working capital) resulted in a Before Tax Return on Investment After Treatment.
For purposes of screening, it was assumed that any plant having a Before Tax Return on
Investment After Treatment of 10% or less would be in the highly impacted category. For plants
whose Before Tax Return on Investment After Treatment is significantly above this value no
further detailed analyses were made. However, the cost for compliance for those plants was
calculated and included in the total industry costs. In addition, any control option whose
investment cost was greater than 25% of plant fixed assets was also considered to be highly
impacted.
C. ECONOMIC IMPACTS
Before Tax Return on Investment was selected as the closure criterion since it is independ-
ent of plant size, it is easily understood by the small plant investors and it is a reasonable test for
a plant owner to judge whether he should keep his money in the paint business or place it
elsewhere. Ten percent was selected as a lower limit because this rate of return is readily
obtainable from a variety of sources which suggests that a return at a lower rate would create an
incentive to close the plant and re-invest in some other fashion.
It is recognized that many small plants will stay in operation despite an unfavorable return
vis-a-vis alternative investment opportunities. Nevertheless, in conducting an impact analysis
one must utilize the data available and closure predictions must be made on the basis of financial
judgments not emotional judgments.
D. SENSITIVITY
Those plants in the highly impacted category, as determined by the initial screening, were
further examined by determining the sensitivity to variables such as contract hauling costs,
capital payback periods, ratio of wastewater to product, etc.
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1. Price Effects
Since one method of recovering costs would be to raise prices, the average cost per gallon of
product was calculated for each segment to maintain its Before Tax Return on Investment before
treatment. From this data, an average price increase was calculated by dividing industry costs by
gallons produced.
Assuming an average price increase, Before Tax Return on Investment After Treatment was
again determined and capital availability estimated to see if those plants previously impacted
could recover sufficiently to be removed from the potential closure category.
2. Capital Costs and Availability
Assuming that the necessary capital must be raised from outside financial assistance,
capital costs were calculated for two long- and two short-term payback periods. These costs were
used in determining Before Tax Return on Investment After Treatment for each of the segments
determined as highly impacted in the screening analysis.
3. Discounted Cash Flow Analysis
Another method for determining potential plant closures is to examine the net present value
of future revenues by discounted cash flow after treatment equipment is installed vs. plant
salvage value. In the paint industry discounted cash flow analyses are not used as investment
criteria except perhaps by the largest plants and are certainly not used as a criteria for closure.
Salvage value of paint plants would be very difficult to estimate with any degree of accuracy.
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IV. PRE-REGULATION INDUSTRY CONDITIONS
A. INDUSTRY CHARACTERISTICS
The paint industry comprises about 1200 companies operating 1500 manufacturing plants
distributed throughout the United States (Figure 1). For the most part, the industry is dominated
by a large number of very small companies which sell their products on a local or regional basis.
This structure has come about partly because of high distribution costs and partly because it
takes very little capital and little sophistication to enter this business. The large majority of paint
plants blend the raw materials together according to formulae that have been handed down
through the family or are readily available from one of their raw material suppliers. Only the very
large plants manufacture some of their own raw materials and do the research and development
required for new products.
An overview of the types of plants in this industry responding to the EPA survey, Depart-
ment of Commerce data and Arthur D. Little, Inc., estimates shows that 67% are single-location
operations, 74% are privately owned, 63% have fewer than 20 employees, 84% produce less than 1
million gallons of product annually, 50% are over 20 years old, 61% have annual sales of less than
$1 million, and 30% ship their product less than 100 miles.
1. Description of the Products
The paint industry manufactures a wide variety of products generally sold in two classifica-
tions: trade sales and chemical coatings. It manufactures a few allied products, such as putty,
shellac, etc., that are outside these categories, but they represent a very minor portion of the total
industry. Companies and/or plants in the trade sales segment of the industry manufacture
products sold directly to professional painters or to the public through company-owned and
operated stores, hardware stores, retail stores and discount stores. The products are sold under
nationally known brand names, private labels, and local or regional brand names. Chemical
coatings, on the other hand, are generally sold directly to an industrial finisher, or manufactured
and used in-house, and in a few cases, sold to the public.
Some companies manufacture only trade sales paints, others manufacture only chemical
coatings, and still others manufacture only allied products. Most of the companies, however,
manufacture products in more than one category. According to the 308 survey, 35% of the
industry manufactures no trade sales paints, 20% manufactures no chemical coatings, and 75%
manufactures no allied products. At the other end of the scale, 14% manufactures only trade-sales
paints, 26% manufactures only chemical coatings, and about 4% manufactures only allied
products. More than 50% of the production of 42% of the plants is for trade sales; more than 50%
of the production of 46% of the plants is for chemical coatings; and more than 50% of the
production of about 7% of the plants is for allied products.
2. Industry Pricing
The paint industry, with few exceptions, is extremely competitive; prices are very fre-
quently established to meet those of the competition. Some companies will calculate the lowest
possible break-even selling price and try to establish their actual selling price somewhere between
that price and one that provides a reasonable profit. Sometimes, small paint companies will sell
at break-even or below, simply to keep their equipment running and their personnel busy.
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a
JT Alaska
ina.l onlo
106 1 34 \ 103
p..
Puerto Rico &
Virgin Islands
Source: 308 Survey.
FIGURE 1 GEOGRAPHICAL DISTRIBUTION OF PAINT MANUFACTURING SITES
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In inflationary times, labor costs tend to rise rapidly. To maintain some profit, the increased
labor costs must be offset by higher selling prices, increased productivity, or lower raw material
costs. Between 1960 and 1967, however, labor costs in the paint industry rose approximately 3.7%
annually. At the same time, prices were increased approximately 1.2%, with an actual decline in
raw material costs of about 1.6%. An increase in productivity of 1.9% coupled with the differential
between rising labor costs and lower raw material costs provided relatively good profitability for
the industry. Since 1967, however, gains in productivity have not offset the spread. The annual
labor rate has been rising about twice as fast as in the 1960-67 period and raw material costs have
also increased. This created a situation where profit margins declined considerably. The drastic
increases in the cost of raw materials in 1973 and 1974, were coupled with a rather large increase
in selling price that arrested this decline and put the paint industry back to the average
profitability that it enjoyed in the 1960-67 period. Unfortunately, however, the industry is again
facing the same conditions that it faced in 1967-74 and it is inevitable that industry profits will
decline.
One of the key issues in looking at the economic impact of the control regulations on this
industry is to determine whether prices will increase because of the regulations. This, of course, is
extremely difficult to determine until the regulations are actually established. On the basis of
previous studies, it may be expected that many plants will have treatment facilities already
installed, so any wastewater effluent will meet the regulations. No price increase would be
required on the products sold by these companies, which account for approximately 70% of
industry sales.
3. Seasonality
Companies manufacturing predominantly trade sales paints have a marked seasonal pat-
tern. Sales generally rise through the first half of the year, cool off through the summer months,
and then decline steadily until they reach a minimum in December and January. Chemical
coatings do not reflect the same seasonal pattern as the trade sales products although they do
reach a peak during the middle of the year and then tend to drop off again in the December-
January period. Sales of trade sales paints tend to increase during times of unemployment
because workers then can spend their idle time repainting their homes.
The years 1974 and 1975 were not good for the paint industry, primarily because of general
economic conditions and the extreme shortage of some essential raw materials. Trade sales paints
showed about an 18% increase in dollar volume, but only a 4% increase in production over 1973.
Sales of chemical coatings increased by more than 20%, but production actually declined over the
same period. Growth in the industry has historically been somewhat slower than that of the gross
national product and shows seasonally, particularly in architectural paints, which tend to peak
in the summer and to correspond with housing starts. Chemical coatings generally tend to
correspond with sales of the automotive and appliance industries and show less seasonality. The
total value of shipments by the industry in 1974 was some $3.7 billion for about 900 million
gallons.
B. INDUSTRY SEGMENTATION
In order to look at the impact of control regulations on individual plants it would be
necessary to have financial data on each individual plant. For the "large" and "very large"
segments, financial data on companies are available, as most of these are publicly owned and are
required to provide such data to stockholders and other interested parties. There is a problem,
however, because the financial data for these multi-plant companies are presented for the
11
-------
ompany as a whole and not on a plant by plant basis. At the other end of the scale, for single-
dant companies, such detailed financial information is not generally available and one has to
nake assumptions about the financial profile of such companies. Models showing the financial
>rofiles of typical plants within each segment of the industry have been constructed using data
>rovided by the National Paint and Coatings Association in its publication "Operating Cost
Survey 1976"; Kline Guide to the Paint Industry, 1975; Annual Statement Studies, 1976 Robert
vlorris Associates; and Arthur D. Little, Inc. estimates.
I. Types of Plants
The EPA's 308 survey of the industry, the previous economic study, company annual
eports, private economic studies of the paint industry, government data, data made available
rom the National Paint and Coatings Association, and Arthur D. Little, Inc., estimates indicate
,he distribution of these plants by various characteristics. The overwhelming majority is under
jrivate ownership (Table 4) and about two-thirds of the plants represent a single-plant company
[Table 5). Ten plants are in the "captive" category, but for the most part these are owned by
automotive or appliance manufacturers. Most of the plants have fewer than ten employees,
[Table 6) which is not surprising in an industry that is composed of so very many small
companies. Almost one-half of the plants are more than 30 years old (Table 7). Table 8 shows the
average production by plant size. Tables 9, 10 and 11 show the distribution of plants versus the
percentage of product type produced trade sales, chemical coatings and allied products. Tables
12 and 13 show the distribution by plant of the percentage of water-thinned and solvent-thinned
paints, respectively. There are 136 plants that use thinner other than water or organic solvent for
at least a portion of their production, and 112 plants that manufacture resin.
TABLE 4
PAINT PLANTS BY CORPORATE ORGANIZATION
No.
Public 301 20.0
Private 1111 74.1
Partnership 22 1.5
Proprietorship 61 4.1
Cooperative 5 0.3
100.0
TABLE 5
PLANT DISTRIBUTION BY SITE STATUS
No. %
Single-plant Company 1004 66.9
Branch 311 20.7
Division 175 11.7
Captive 10 0.7
100.0
Source: 308 Survey and Arthur D. Little, Inc., estimates.
12
-------
TABLE 6
AVERAGE NUMBER OF EMPLOYEES PER PAINT PLANT
(1349 plant base)
No.
Less than 10 562 41.7
11-20 286 21.2
21-30 134 9.9
31-40 64 4.7
41-50 66 4.9
51-60 49 3.6
61-70 30 2.2
71-80 15 1.1
81-90 19 1.4
91-100 19 1.4
101-150 52 3.8
Over 150 53 3.9
Source: 308 Survey
TABLE 7
DISTRIBUTION OF PAINT PLANTS
BY AGE OF OPERATION
(1352 plant base)
No. %
Less than 3 years 67 4.9
3-5 102 7.5
6-10 168 12.4
11-20 321 23.7
21-30 268 19.8
Over 30 426 31.5
Source: 308 Survey
13
-------
TABLE 8
AVERAGE PAINT PLANT PRODUCTION
LAST FIVE YEARS (GALLONS)
(1327 plant base)
No. %
Less than 50,000 373 28.1
50,001-200,000 359 27.0
200,000-1,000,000 387 29.2
1,00,000-5,000,000 181 13.6
More than 5,000,000 27 2.0
Source: 308 Survey
TABLE 9
DISTRIBUTION OF TRADE SALES AS A PERCENT
OF TOTAL PAINT PRODUCED
(1312 Rant Base)
Percent Trade Sales No. Plants %
0 464 35.4
1-10 125 9.5
11-20 39 3.0
21-30 44 3.4
31-40 39 3.0
41-50 58 4.4
51-60 34 2.6
61-70 47 3.6
71-80 43 3.3
81-90 77 5.9
91-100 160 12.2
100 182 13.9
Source: 308 Survey
14
-------
295
190
62
56
38
66
26
33
44
44
111
340
22.6
14.B
4.8
4.3
2.9
5.1
2.0
2.5
3.4
3.4
8.5
26.0
TABLE 10
DISTRIBUTION OF CHEMICAL COATINGS AS A PERCENT
OF TOTAL PAINT PRODUCED
(1305 Plant Base)
Percent Chemical
Coatings No. Plants %
0
1-10
11-20
21-30
31-40
41-50
51-60
61-70
71-80
81-90
91-100
100
Source: 308 Survey
TABLE 11
DISTRIBUTION OF ALLIED PRODUCTS AS A PERCENT
OF TOTAL PAINT PRODUCED
(1252 Plant Base)
Percent of Allied
Products No. Plants %
0
1-10
11-20
21-30
31-40
41-50
51-60
61-70
71-80
81-90
91-100
100
Source: 308 Survey
15
919
170
22
17
22
15
6
4
7
8
25
37
73.4
13.6
1.8
1.4
1.8
1.2
0.5
0.3
0.6
0.6
2.0
3.0
-------
TABLE 12
DISTRIBUTION OF WATER-THINNED PAINTS AS A
PERCENT OF TOTAL
(1304 Plant Base)
Percent Water-Thinned No. Plants
0
1-10
11-20
21-30
31-40
41-50
51-60
61-70
71-80
81-90
91-100
100
Source: 308 Survey
345
274
86
53
52
63
83
99
79
61
54
55
26.4
21.0
6.6
4.1
4.0
4.8
6.4
7.6
6.1
4.7
4.1
4.2
TABLE 13
DISTRIBUTION OF SOLVENT-THINNED PAINTS AS
A PERCENT OF TOTAL
(1308 Plant Base)
Percent Solvent
Thinned No. Plants
0
1-10
11-20
21-30
31-40
41-50
51-60
61-70
71-80
81-90
91-100
100
Source: 308 Survey
16
135
98
66
100
78
114
60
50
51
97
229
230
10.3
7.5
5.0
7.6
6.0
8.7
4.6
3.8
3.9
7.4
17.5
17.6
-------
2. Model Plant Development
On the basis of the industry segmentation, model plants were constructed to represent
typical financial operating data for representative plants in each segment. In the construction of
these models certain assumptions were necessary. Some assumptions were established by the
EPA's technical contractor i.e. wastewater flow ratios of 0.2 gal/gal waterbased paint, and 50% of
production is waterbased paint. This study assumes that the financial condition of all plants in
the segment is the same as the model plant. Owners salary and other considerations to small
plant owners are shown as normal profit before tax just as if the small individually owned plant
were a part of a large corporation and would use equivalent financial reporting techniques.
Financial profiles of the model plants are shown in Table 14. Other data used in the
construction of the models came from NPCA Operating Highlights, Robert Morris Associates
studies and Arthur D. Little, estimates. The industry can be segmented into five categories on the
basis of sales as follows:
Very large plants sales over $10 million. Plants in this category are in multi-
plant companies which manufacture some of their own resins and some of their
own pigments, have nationwide distribution through a large number of retail stores
or are producing directly for large nationwide distributors. While this segment
contains 111 plants it represents only about eight companies.
Large plants sales between $5-10 million. Plants in this category are very much
like those in the very large category in that they are part of multi-plant companies,
but the individual plants generally are smaller. The major distinction in this group
is that very few, if any, manufacture any of their own raw materials. There are
about 50 companies in this category.
Medium-sized plants sales between $1-5 million. In this category are plants that
are owned by 150-200 companies, most of which have branch plant operations.
These plants, however, are more like the smaller plants in the categories that
follow than they are like those in the largest sales categories. The data indicate
that these plants may be the most efficient in the industry in terms of size of plant
for the market served. Some of the most profitable plants in the industry are in this
category.
Small plants sales $250,000 $1 million. (See following category)
Very small plants sales less than $250,000. Plants in this and the previous
category are all single-company, single-plant locations, are privately owned, and
account for a relatively small percentage of the total dollar volume of paint and
coatings produced. These companies range in size from those with only two
employees to some with 30 or more. Distribution of products from these plants is
usually limited; products are sold through local hardware stores, home improve-
ment centers, etc., generally at a lower retail price than the nationally known
brands. Some companies in these categories, however, produce specialized prod-
ucts and are undoubtedly very profitable.
The distribution of the number of plants and their production by segments (Figure 2) shows
that the very small plant segment has the largest number of plants and the smallest production.
17
-------
TABLE 14
FINANCIAL PROFILES OF MODEL PAINT PLANTS
($000)
Segment
No. Plants
Annual Sales
Approx. No. Employees
Annual Production
(000 gallons)
Plant Profit Before Tax
Plant Net Worth
Plant Working Capital
Plant Total Assets
Plant Fixed Assets
Plant Total Investment
Before Tax Return on
Investment (%)
Very
Small
469
200
5
50
6.8
48.8
27.7
71.9
21.6
49.3
Small
513
600
12
150
27
152
111
189
40.4
151.4
Medium
296
2400
42
600
140
562
404
1106
289
693
Large
111
5000
80
1250
293
1726
1310
2549
732
2042
Very
Large
111
15,000
280
3,750
1,260
4,348
3,928
10,332
2,851
6,779
13.8
17.8
20.2
14.3
18.6
18
-------
100
90
80
70
60
^ 50
0)
S
£ 4
30
20
10
0
Legend:
m
Plants per Segment
Production per Segment
Very Small
Small
Medium
Large
Very Large
FIGURE 2 PERCENTAGE OF TOTAL PLANTS BY SEGMENT VS.
PERCENTAGE OF TOTAL PRODUCTION BY SEGMENT
19
-------
V. CONTROL COSTS
A. OPTIONS
The EPA studied seven alternative methods for controlling pollution from wastewater
discharge by the paint industry:
1. Physical Chemical Pretreatment.
2. Physical Chemical Pretreatment with Biological Treatment.
3. Wastewater Recycle with Contract Hauling.
4. Wastewater Recycle with Physical Chemical Pretreatment.
5. Wastewater Recycle with Physical Chemical Pretreatment, and Biological
Treatment.
6. Contract Hauling.
7. Manually Operated Physical Chemical Pretreatment.
Investment and operating costs have been provided for various size plants. These costs are
presented in detail in the Development Document and are also summarized in Tables 15-21. The
costs shown in this report have been deflated by a factor of 0.835 to reduce them to 1976 dollars,
the base year for the data presented. This factor has been provided by EPA using a reference from
ENR, 12, 21, 78 page 69 showing construction costs for 20 cities 1976-1978. Total investment,
annual capital costs, annual operating costs and total annual costs are shown. The investment
capital is assumed to be borrowed at a five year direct reduction annual payback at 12% interest.
Depreciation figures shown in the Development Document under operating costs have been
deleted so that operating costs show only operational and maintenance figures and the annual
investment cost shows the debt payback for control equipment only.
B. APPLICATION OF COSTS
These costs were used for all segments in the initial screening for impact. Detailed analyses
were made for two options for those segments impacted. In addition, sensitivity analyses were
conducted for contract hauling cost, investment payback and wastewater/product ratios.
20
-------
TABLE 15
PHYSICAL CHEMICAL PRETREATMENT COSTS
($000)
Segment
Total Investment
Annual Investment Cost
Annual Operating Cost
Total Annual Cost
VS
M
VL
19.0
5.3
4.4
9.7
19.0
5.3
4.4
9.7
31.1
8.6
9.4
18.0
44.3
12.3
13.3
25.6
68.0
18.9
29.3
48.2
TABLE 16
PHYSICAL CHEMICAL PRETREATMENT WITH
BIOLOGICAL TREATMENT COSTS
($000)
Segment VS
Total Investment
Annual Investment Cost
Annual Operating Cost
Total Annual Cost 57.1
57.1
M
65.5
73.1
VL
150.6
41.8
15.3
150.6
41.8
15.3
162.7
45.1
20.4
175.8
48.8
24.3
199.5
55.4
40.3
95.7
TABLE 17
WASTEWATER RECYCLE WITH CONTRACT HAULING COSTS
($000)
Segment VS
Total. Investment
Annual Investment Cost
Annual Operating Cost
Total Annual Cost 12.9
12.9
M
20.5
33.6
VL
19.3
5.3
7.6
19.3
5.3
7.6
34.2
9.4
11.1
51.0
14.1
19.5
83.0
23.0
28.2
51.2
21
-------
TABLE 18
WASTEWATER RECYCLE WITH PHYSICAL CHEMICAL PRETREATMENT COSTS
($000)
Segment VS
Total Investment
Annual Investment Cost
Annual Operating Cost
Total Annual Cost 18.1
18.1
M
23.4
35.2
VL
34.5
9.6
8.5
34.5
9.6
8.5
49.3
13.7
9.7
65.6
18.2
17.0
104.7
29.1
21.2
50.3
TABLE 19
WASTEWATER RECYCLE WITH PHYSICAL CHEMICAL PRETREATMENT
AND BIOLOGICAL TREATMENT COSTS
($000)
Segment VS
Total Investment
Annual Investment Cost
Annual Operating Cost
Total Annual Cost 65.5
65.5
M
70.8
82.4
VL
166.0
46.0
19.5
166.0
46.0
19.5
180.9
50.2
20.6
197.1
54.7
27.7
236.2
65.5
31.6
97.1
TABLE 20
CONTRACT HAULING COSTS
($000)
Segment
Total Investment
Annual Investment Cost
Annual Operating Cost
Total Annual Cost
VS
4.4
7.0
M
24.1
f Reduced to reflect smaller volume of sludge disposal costs.
44.2
VL
3.8
1.1
3.3*
3.8
1.1
5.9
10.9
3.0
21.1
15.1
4.2
40.0
33.2
9.2
115.4
124.6
22
-------
TABLE 21
MANUALLY OPERATED PHYSICAL CHEMICAL PRETREATMENT COSTS
($000)
Segment VS S M
Total Investment 3.8 3.8 4.7
Annual Investment Cost 1.1 1.1 1.3
Annual Operating Cost 5.9 5.9 8.6
Total Annual Cost 7.0 7.0 9.9
23
-------
VI. ECONOMIC IMPACT
A. IMPACT SCREENING
As a first screening, the control costs developed by EPA were applied to the financial data
developed for the model plants in each segment shown in Table 14. For this screening it was
assumed that all plants in each segment are identical to the model. The criterion used to
determine impact was a 10% or less before tax return on plant investment after treatment and/or
that the investment for control is greater than 25% of plant fixed assets.
The effects of these costs on the model plants are shown in Tables 22-29.
TABLE 22
IMPACT OF PHYSICAL CHEMICAL PRETREATMENT COSTS
($000)
Segment VS S M L VL
Fixed Assets (Before Treatment) 21.6 40.4 289 732 2851
Investment % Fixed Assets 88.0 47.0 10.8 6.1 2.4
Profit Before Tax 6.8 27 140 293 1260
Total Annual Cost 9.7 9.7 18.0 25.6 48.2
Profit Before Taxes After Treatment (2.9) 17.3 122 267.4 1211.8
Total Investment After Treatment 68.3 170.4 724.1 2086.3 6847
Before Tax Return on Investment
After Treatment (%) (4.2) 10.2 16.8 12.8 17.7
TABLE 23
IMPACT OF PHYSICAL CHEMICAL PRETREATMENT WITH
BIOLOGICAL TREATMENT COSTS
($000)
Segment VS S M L VL
Fixed Assets (Before Treatment) 21.6 40.4 289 732 2851
Investment % Fixed Assets 697 373 56.3 24.0 7.0
Profit Before Tax 6.8 27 140 293 1260
Total Annual Cost 57.1 57.1 65.5 73.1 95.7
Profit Before Taxes After Treatment (50.3) (30.1) 74.5 219.9 1164.3
Total Investment After Treatment 199.9 302 855.7 2217.8 6978.5
Before Tax Return on Investment
After Treatment (%) (25.2) (10.0) 8.7 9.9 16.7
24
-------
TABLE 24
IMPACT OF WASTEWATER RECYCLE WITH CONTRACT HAULING COSTS
($000)
Segment VS S M L VL
Fixed Assets (Before Treatment) 21.6 40.4 289 732 2851
Investment % Fixed Assets 89.4 47.7 11.8 7.0 2.9
Profit Before Tax 6.8 27 140 293 1260
Total Annual Cost 12.9 12.9 20.5 33.6 51.2
Profit Before Taxes After Treatment (6.1) 14.1 119.5 259.4 1208.8
Total Investment After Treatment 68.6 170.7 727.2 2093 6862
Before Tax Return on Investment
After Treatment (%) (8.9) 8.3 16.4 12.4 17.6
TABLE 25
IMPACT OF WASTEWATER RECYCLE WITH PHYSICAL CHEMICAL
PRETREATMENT COSTS
($000)
Segment VS S M L VL
Fixed Assets (Before Treatment) 21.6 40.4 289 732 2851
Investment % Fixed Assets 159.7 85.4 17.1 9.0 3.7
Profit Before Tax 6.8 27 140 293 1260
Total Annual Cost 18.1 18.1 23.4 35.2 50.3
Profit Before Taxes After Treatment (11.3) 8.9 116.6 257.8 1209.7
Total Investment After Treatment 83.8 185.9 742.3 2107.6 6883.7
Before Tax Return on Investment
After Treatment (%) (13.5) 4.8 15.7 12.2 17.6
25
-------
TABLE 26
IMPACT OF WASTEWATER RECYCLE WITH PHYSICAL CHEMICAL
PRETREATMENT AND BIOLOGICAL TREATMENT COSTS
($000)
Segment
Fixed Assets (Before Treatment)
Investment % Fixed Assets
Profit Before Tax
Total Annual Cost
Profit Before Taxes After Treatment
Total Investment After Treatment
Before Tax Return on Investment
After Treatment (%)
VS
(27.3)
(12.1)
M
7.9
7.0
VL
21.6
768
6.8
65.5
(58.7)
215.3
40.4
411
27
65.5
(38.5)
317.4
289
62.6
140
70.8
69.2
873.9
732
26.9
239
82.4
156.6
2239.1
2851
8.3
1260
97.1
1 1 62.9
7015.2
16.6
TABLE 27
IMPACT OF CONTRACT HAULING COSTS
($000)
Segment
Fixed Assets (Before Treatment)
Investment % Fixed Assets
Profit Before Tax
Total Annual Cost
Profit Before Taxes After Treatment
Total Investment After Treatment
Before Tax Return on Investment
After Treatment (%)
VS
4.5
12.9
M
16.5
12.1
VL
21.6
17.6
6.8
4.4
2.4
53.1
40.4
9.4
27
7.0
20
155.2
289
3.8
140
24.1
115.9
703.9
732
2.1
293
44.2
248.8
2057.1
2851
1.2
1260
124.6
1135.4
6812.2
16.7
26
-------
TABLE 28
IMPACT OF MANUALLY OPERATED PHYSICAL CHEMICAL PRETREATMENT COSTS
($000)
Segment
Fixed Assets (Before Treatment.)
Investment % Fixed Assets
Profit Before Tax
Total Annual Cost
Profit Before Taxes After Treatment
Total Investment After Treatment
Before Tax Return on Investment After
Treatment (%)
VS
21.6
17.6
6.8
7.0
(0.2)
53.1
(0.4)
40.4
9.4
27
7.0
20
155.2
12.9
M
289
1.6
140
9.9
130.1
697.7
18.6
27
-------
1. Impact of Costs on Indirect Dischargers
Table 29 summarizes the impact of control costs for all treatment technologies on various
size paint plants. The control options selected by EPA for PSES are as follows: Option 1
Physical Chemical Pretreatment and Option 2 Zero discharge. For Option 1, small plants may
elect manually operated physical chemical pretreatment and Contract Hauling for Option 2.
Very small plants show potential for high impact by all technologies.
2. Impact of Costs on Direct Dischargers
The control options selected by EPA are those which are required for PSES, namely
Physical Chemical Pretreatment and Zero Discharge. According to the screening analysis the four
small and two large plants in this category can meet zero discharge without the potential of high
impact. They can clearly meet less stringent limitations based on some other technology.
3. New Sources
The requirements for NSPS are the same as BAT. PSNS requirements are the same as
PSES. New sources therefore will have the same limitations as existing sources and will be under
no competitive disadvantage because of regulations. The added investment and cost may slow
entry into the industry, however.
B. IMPACT ANALYSIS OF SELECTED OPTIONS
The options selected by EPA for study are: Option 1 Physical Chemical Pretreatment,
Option 2 Zero Discharge by the most economical method.
1. Industry Wide Price Effects
One of the techniques for recovering the costs associated with effluent control is to pass
these costs through to plant customers. To estimate a general industry price increase, one must
assume that all plants affected will pass on costs for control and that the entire industry will
follow suit, even though a large majority of plants already have controls in place and are already
incurring control costs. For each segment, the amount of additional revenue necessary to main-
tain return on investment at the pre-control level was calculated. This value divided by the
segment production shows the increase in cost per gallon estimated for affected plants in each
segment. Since prices are normally established by the larger producers, no additional price
increase is expected over that shown for the largest segment.
Table 30 shows that in order to maintain ROI in the very large plant a price increase of
2
-------
TABLE 29
SUMMARY OF IMPACT OF WASTEWATER TREATMENT COSTS
BAT, NSPS, PSES, PSNS
VS
M
VL
K)
Segment
Treatment
Physical Chemical
Physical Chemical with Biological Treatment
Wastewater Recycle with Contract Hauling
Wastewater Recycle with Physical Chemical
Wastewater Recycle with Physical Chemical
Pre-Treatment and Biological Treatment
Contract Hauling
Manually Operated Physical Chemical
A
-4.2*
25.2*
-8.9*
13.5*
27.3*
4.5*
-0.4*
B
88*
697*
89.4*
160*
768*
17.6
17.6
A
10.2*
-10.0*
8.3*
4.8*
-12.1*
12.9
12.9
B
47*
373*
47.7*
85.4*
411*
9.4
9.4
A
16.8
8.7*
16.4
15.7
7.9*
16.5
18.6
B
10.8
56.3*
11.8
17.1
62.6*
3.8
1.6
A
12.8
9.9*
12.4
12.2
7.0*
12.1
NA
B
6.1
24.0
7.0
9.0
26.9*
2.1
NA
A
17.7
16.7
17.6
17.6
16.6
16.7
NA
B
2.4
7.0
2.9
3.7
8.3
1.2
NA
A = Before Tax Return on Investment After Treatment
B = Control Investment as % of Fixed Assets
= Potential Impact
-------
TABLE 30
AVERAGE PRICE INCREASE TO MAINTAIN ROI
PHYSICAL CHEMICAL PRETREATMENT
Segment
VS*
s**
M**
L
VL
Total
No. Plants
to Comply
155
169
97
37
37
495
Needed Revenue
($000)
$ 763.8
1,288.7
1,051.0
1,144.8
2,284.4
$6,532.7
Total Gallons
(MM)
7.75
25.35
58.2
46.25
138.75
276.3
Price
Increase/Gallon
(4)
9.8
5.1
1.8
2.5
1.6
2.4 (Ave.!
ZERO DISCHARGE
Segment
VS*
S*
M*
L***
VL***
Total
No. Plants
to Comply
232
254
146
55
55
742
Needed Revenue
($000)
$ 1,143.2
1,936.9
3,838.0
2,194.4
3,714.3
$12,826.8
Total Gallons
(MM)
11.6
38.1
87.6
68.75
206.25
412.3
Price
Increase/Gallon
U)
9.8
5.1
4.4
3.2
1.8
3.1 (Ave.)
'Contract Haul.
**Manually operated physical chemical.
***Wastewater recycle with contract haul.
TABLE 31
INDUSTRY CONTROL COSTS FOR OPTION 1
PHYSICAL CHEMICAL PRETREATMENT
($000)
Segment
No. Plants
Annual Control Cost/Plant
Total Annual Cost
Cost/Gallon Product (
-------
232
4.4
1,020.8
8.8
254
7.0
1,778
4.7
146
24.1
3,518.6
4.0
55
33.6
1,848
2.7
55
51.2
2,816
1.4
742
10,981.4
2.7
TABLE 32
INDUSTRY COSTS FOR OPTION 2 - ZERO DISCHARGE
($000)
Segment VS S M L VL Total
No. Plants
Annual Cost/Plant
Total Annual Cost
Cost/Gallon (i)
While Table 32 includes the direct dischargers in the total industry costs for compliance
with zero discharge. Table 33 shows a separate breakdown of these costs. Since zero discharge is
economically achievable, other less stringent levels will also be achievable and therefore have not
been evaluated.
TABLE 33
IMPACT OF ZERO DISCHARGE CONTROL COSTS ON
DIRECT DISCHARGERS
($000)
Segment S VL
No. Plants 4* 2**
Total Investment for Control 15.2 166
Annual Investment Cost 4.4 46
Annual Operating Cost 23.6 56.4
Total Annual Cost 28.0 102.4
Predicted Closures 0 0
Predicted Unemployment 0 0
*Contract Hauling
**Wastewater Recycle with Contract Hauling
3. Closure Analysis
a. Effect on Small and Very Small Segment Impact
Assuming a 2$ price increase for the selected options, the effect of this increase on control
cost impact is shown in Table 34. This price increase does little for the very small plant, but it
may provide enough return to the small plant to avoid closure if profits decline or costs increase in
the future.
A 2<:/gallon price increase does not appear to be a large amount when considering the retail
price per gallon of paint. A better comparison, however, is shown in Table 35, where profit before
tax on a per-gallon basis is shown for Option 1 and Option 2 before and after regulation.
31
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TABLE 34
EFFECT OF 2i PRICE INCREASE
($000)
Segment
Treatment
Profit Before Tax
Investment Cost
Operating Cost
Total Annual Cost
Profit Before Tax After Treatment
Total Investment After Treatment
Before Tax Return on
Investment After Treatment (%)
VS
Contract
Hauling
7.8
1.1
3.3
4.4
3.4
53.1
Manually Operated
Physical Chemical
Pretreatment
30.0
1.1
5.9
7.0
23
155.2
Contract
Hauling
30.0
1.1
5.9
7.0
23
155.2
6.4
14.8
14.8
TABLE 35
PROFIT BEFORE TAX AFTER TREATMENT PER GALLON PRODUCT
U/gal)
Segment
Option
Profit Before Tax
Total Annual Cost
Profit Before
Tax After Treatment
Loss in Profit (%)
VS
M
VL
1
13.6
8.8
4.8
64.7
2
13.6
8.8
4.8
64.7
1
18.0
4.7
13.3
50.7
2
18.0
4.7
13.3
50.7
1
23.3
1.7
21.6
7.3
2
23.3
4.0
19.3
17.2
1
23.4
2.1
21.3
9.0
2
23.4
2.7
20.7
11.5
1
33.6
1.3
32.3
3.9
2
33.6
1.4
32.2
4.2
4. Capital Availability
Summary Table 29 shows the investment for control as a percent of fixed assets.
It was assumed that if this value was greater than 25% then capital availability would be a
problem. Several lending institutions were checked to verify this policy and most agreed that
small companies would have difficulty raising capital without some outside collateral. Second
mortgages on the owner's home was the method mentioned most often. This, of course, would
imply a much higher interest rate than for a commercial loan. Rates and payback periods are
discussed in the section on sensitivity.
32
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Only the very large plants could have capital available for all alternatives. Medium and
large plants could not raise capital easily if biological treatment was selected as the control
technology. For small and very small plants capital availability for most options will be difficult.
Contract hauling is the best from an investment standpoint.
5. Closure Effects
The industry survey developed for EPA by its technical contractor shows in Table V-6 the
waste water discharge volumes of the industry. This table shows 608 zero dischargers out of 1374
total plants, 122 plants did not report the volume discharged. An examination of the answers to
other questions by these 122 plants shows that 86 practice zero discharge for an industry total of
694 or 50.5% of the plants responding to the survey. Using this as a guide the 126 very small plants
not responding to the survey were assumed to follow the same practice. The discharge practice of
the industry therefore, is assumed to be as follows:
758 Zero Discharge
736 Indirect Discharge
6 Direct Discharge
1,500 Total Plants
It is interesting that Table VII-3 in the engineering report, while it contains multiple data
from some plants, it shows that about 64% of the industry practices zero discharge. An analyses of
the responses to the question regarding discharging treated vs. untreated water indicates 58% of
the plants practice zero discharge. Since there is some discrepancy in the total number of zero
dischargers EPA selected the lower number (758 or 50.5%) in order to evaluate the impact on the
greatest number of plants.
The total number of discharging plants is 742 and of these about one third treat the
wastewater before discharging, according to the 308 survey. A breakdown of these data by plant
size is shown in the following table:
TABLE 36
WASTEWATER DISCHARGE PRACTICE
Segment VS S M L VL Total
Zero discharge
Treated discharge
Untreated discharge
Total
Source: 308 survey and Arthur D. Little, Inc., estimates.
237
77
155
469
259
85
169
513
150
49
97
296
56
18
37
111
56
18
37
111
758
247
495
1500
33
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a. Baseline Closures
No baseline closures were predicted for two reasons. First and most important is that
Census of Manufactures data and industry publications indicate a stable condition in the net
total number of plants over a period of years. This indicates that for each plant which closes a new
one starts up (probably on the premises of the closed plant). Secondly, the total number of plants
used in the study (1500), selected on the basis of the 308 survey, appears lower than the number of
plants reported by Department of Commerce data so that deduction of predicted baseline
closures would understate the industry impact due to control costs.
6. Production Effects
Assuming the worst case, e.g., that 232 very small plants closed under Option 2 the total
production from these plants is about 11.6 million gallons annually. Spreading this product
equally among the remaining plants would amount to 9000 gallons annually for each. This
represents an increase of 6% for a small plant and 0.2% for a very large plant. The industry is
currently operating at less than 85% of full production capacity so that no production effects will
be noted.
7. Employment Effects
For Option 1, some 155 plants are predicted to close creating 775 unemployed mostly in
urban areas. Under Option 2, 232 plants are predicted to close with about 1160 unemployed.
34
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VII. LIMITS OF THE ANALYSIS
A. MODEL PLANTS
On the basis of the 308 survey and an analysis of unreturned questionnaires 1500 paint
plants has been adopted as the total figure. This figure is not in agreement with published
"Census of Manufactures" data or the "Paint Red Book." If there are more plants than the 1500
assumed, it is highly likely that they will fall into the very small category and the number of
closures would increase in direct proportion to the number of plants omitted.
It was also assumed that all plants in each segment have financial data equivalent to the
model plant. Recognizing that not all plants of the same size will have the same profitability an
analysis of the range of profitability suggests that no additional closures can be predicted for
plants which differ from the model.
B. CONTROL COSTS
A sensitivity analysis of the effect of increasing contract hauling costs by factors of 2 and 3
show little change in the impact predicted. However, for small and very small plants total
investment and annual investment cost can be critical. Any serious underestimate of these costs
could increase predicted closures.
C. AMOUNT OF EFFLUENT
This is a major variable noted in the 308 survey. Even a slight change in ratios will seriously
affect small plants and if the change is large enough medium sized plants would be highly
impacted. High pressure rinsing will reduce the amount of effluent but even if it reduced it by a
factor of five the small plants would still be affected. In addition the small and very small plants
probably could not borrow the capital necessary to install this equipment.
This is the most serious assumption in the analysis since the entire economic analysis is
based on the assumed ratio. At the higher ratios most of the small paint plants would be
predicted as closures.
D. CAPITAL AVAILABILITY
Capital availability for small plants was assumed available under a five year direct payback
with 12% annual interest. Short term loans are more likely for non-productive equipment
especially where regulations may change and render the equipment obsolete. Short term pay-
backs could create serious cash flow problems for small plants. For some alternatives the capital
investment required is so high that these options are not available for small and very small
plants.
E. PRICE INCREASE
A 2
-------
F. CONTRACT HAULING COSTS
The Development Document used 30(t/gal as the contract hauling charge. Sensitivity has
been examined using 30, 60 and 90
-------
TABLE 39
SENSITIVITY OF CONTRACT HAULING COSTS ON
MANUALLY OPERATED PHYSICAL CHEMICAL TREATMENT COSTS
($000)
Segment
Hauling Costs («i/gal)
Profit Before Taxes
Total Annual Cost
Profit Before Tax After
Treatment
Before Tax Return on
Investment after
Treatment (%)
M
30
140
9.9
60
140
12.3
90
140
13.4
30
27
7.0
60
27
8.7
90
27
9.2
130.1
18.6
127.7
18.3
126.6
18.1
20.0
12.9
18.3
11.8
17.8
11.5
TABLE 40
SENSITIVITY OF CONTRACT HAULING COSTS
ON CONTRACT HAULING
($000)
Segment
Hauling Cost
Profit before Taxes
Total Annual Cost
Profit Before Tax After
Treatment
Before Tax Return on
Investment After
Treatment (%)
2.4
4.5
VS
0.9
(0.6) 20.0 16.2 12.5 115.9
1.7 (1.1) 12.9 10.4
8.1
16.5
M
30
6.8
4.4
60
6.8
5.9
90
6.8
7.4
30
27
7.0
60
27
10.8
90
27
14.5
30
140
24.1
60
140
42.8
90
140
61.6
97.2
13.8
78.4
11.1
37
-------
On the basis of these data, it can be shown that any increase in the costs for contract hauling
will have the most effect on the small and very small plants. Substantial increases could
adversely affect the medium sized plants as well.
G. CAPITAL INVESTMENT PAYBACK
Since the payback period on high risk capital may be much shorter than that indicated in
the development document the sensitivity to this variable was determined for medium, small and
very small plants for manually operated physical chemical pretreatment and contract hauling.
Time spans of 3, 5, 10 and 30 years (life of equipment) were used. 12% interest was assumed in all
cases.
TABLE 41
EFFECT OF PAYBACK PERIOD FOR
MANUALLY OPERATED PHYSICAL CHEMICAL TREATMENT INVESTMENT
($000)
Segment S M
Payback Period (yrs.) 3 5 10 30 3 5 10 30
Prof it Before Taxes 27 27 27 27 140 140 140 140
Annual Cost of Capital 1.6 1.1 0.7 0.5 2.0 1.3 0.8 0.6
Operating Cost 5.9 5.9 5.9 5.9 8.6 8.6 8.6 8.6
Total Annual Cost 7.5 7.0 6.6 6.4 10.6 9.9 9.4 9.2
Profit Before Tax After
Treatment 19.5 20.0 20.4 20.6 129.4 130.1 130.6 130.8
Before Tax Return on
Investment After
Treatment (%) 12.6 12.9 13.1 13.3 18.5 18.6 18.7 18.7
38
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TABLE 42
EFFECT OF PAYBACK PERIOD FOR CONTRACT HAULING INVESTMENT
($000)
Segment VS S M
Payback Period (yrs.)
Profit Before Taxes
Annual Cost of Capital
Operating Cost
Total Annual Cost
Profit Before Tax After
Treatment 1.9 2.4 2.8 3.4 19.5 20.0 20.4 20.6 114.4 115.9 117 117.6
Before Tax Return on
Investment After
Treatment (%) 3.6 4.5 5.3 5.6 12.6 12.9 13.1 13.3 16.4 16.5 16.8 16.9
3
6.8
1.6
3.3
4.9
5
6.8
1.1
3.3
4.4
10
6.8
0.7
3.3
4.0
30
6.8
0.15
3.3
3.4
3
27
1.6
5.9
7.5
5
27
1.1
5.9
7.0
10
27
0.7
5.9
6.6
30
27
0.5
5.9
6.4
3
140
4.5
21.1
25.6
5
140
3.0
21.1
24.1
10
140
1.9
21.1
23.0
30
140
1.3
21.1
22.4
-------
H. WASTEWATER/PRODUCTION RATIO
The 308 survey indicated that as much as 19% of the industry created ratios of wastewater to
product of 1:1 or greater. It is anticipated that these higher ratios are found in the smaller plants.
Assuming that capital investment remains as it is at the 0.2 ratio but that operating costs are
directly proportional to volume, the following table shows the effect of increasing ratio on
contract hauling costs for the very small, small and medium segments.
TABLE 43
EFFECT OF INCREASED WASTEWATER/PRODUCT RATIO
($000)
Segment VS S M
Ratio 0.2 0.6 1.0 0.2 0.6 1.0 0.2 0.6 1.0
Profit Before Taxes 6.8 6.8 6.8 27 27 27 140 140 140
Total Annual Cost 4.4 11.0 17.6 7.0 18.8 30.6 24.1 66.3 108.5
Profit Before Tax
After Treatment 2.4 (4.2) (10.8) 20.0 8.2 (3.6) 115.9 73.7 31.5
Before Tax Return on
Investment After
Treatment (%) 4.5 (7.9) (20.3) 12.9 5.3 (2.3) 16.5 10.5 4.5
These data indicate a high impact for all very small plants at all ratios. High impact is also
noted for small and medium plants at the higher ratios. Negative returns for very small plants
and small plants at the 1:1 ratio would predict closure under these conditions.
The Development Document provides capital costs for a high pressure water rinsing system.
Assuming that the volume could be reduced from the average 0.2:1 ratio to 0.04:1 through high
pressure rinsing then the following conditions would result. Operating costs are assumed to be no
higher than those associated with normal rinsing and therefore are omitted. Operating costs for
contract hauling have been included however.
From an economic view the high pressure rinse system is attractive for very large, large and
medium plants which would have to meet zero discharge regulations. Small and very small plants
would not make the investment since conventional contract hauling is less costly and requires less
investment and provides a higher return on investment. It is also apparent that many indirect
dischargers could change to zero discharge by installing this equipment. For instance the return
on investment for very large, large and medium plants is greater using this technology than with
Physical Chemical Pretreatment. Such an effect would reduce the load on POTW's and increase
the demand on landfill operations significantly.
40
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TABLE 44
COST FOR REDUCTION OF WASTEWATER FROM 0.2/GAL TO
0.04 GAL/GAL VIA HIGH PRESSURE RINSING WITH
CONTRACT HAULING
($000)
Segment VS S M L VL
Gal/day 0.2/1 20 50 250 500 1500
Gal/day 0.04/1 4 10 50 100 300
Capital Investment
High Pressure Rinse 16.6 16.6 16.6 16.6 16.6
Capital Investment
Contract Haul 3.8 3.8 3.8 10.9 15.1
Total Investment 20.4 20.4 20.4 27.5 31.7
Annual Cost of Capital 5.7 5.7 5.7 7.6 8.8
Annual Operating Cost
Contract Haul* 2.4 2.9 5.9 9.6 24.8
Total Annual Cost 8.1 8.6 11.6 17.2 33.6
*Sludge disposal varied by volume, other costs (i.e., labor) are as shown in the Engineering
Report.
TABLE 45
IMPACT OF WASTEWATER REDUCTION WITH
CONTRACT HAULING COSTS
Segment VS
Fixed Assets (Before Treat)
Investment % Fixed Assets
Profit Before Tax
Total Annual Cost
PBT After Treatment
Total Investment After
Treatment 69.7
Before Tax Return on
Investment after
Treatment (%) (1.9)
M
21.6
94.4
6.8
8.1
(1.3)
40.4
50.5
27
8.6
18.4
289
7.1
140
11.6
128.4
171.8
10.7
713.4
18.0
732
3.8
293
17.2
275.8
2069.5
13.3
VL
2851
1.1
1260
33.6
1226.4
6810.7
18.0
41
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I. DISCOUNTED CASH FLOW VS. PLANT SALVAGE VALUE
While this technique is not used by the paint industry to determine closure options, one can
predict closure on the assumption that plant salvage value is greater than the discounted value of
a future amount of earnings after treatment. Plant salvage value is, at best, difficult to estimate
in an industry dominated by small, old plants. For the most part, fixed assets of land and
building are what is salvageable and it is extremely difficult to factor land appreciation values
over the projected period. For very small plants, depreciation is estimated at 1.6% of sales or
about $3,200 which represents the present value of equipment. This added to the value of the land
and building suggests that 75% of fixed assets is the lowest reasonable estimate of plant salvage
value that can be used in the analysis. The following table shows the net present value of return
(profit before tax) after zero discharge over 5, 10, 30 and 50 years at 12% discount rate against the
salvage value of small and very small plants.
TABLE 46
DISCOUNTED CASH FLOW VS. SALVAGE VALUE
($000)
VS
Segment Before Treatment After Treatment Before Treatment After Treatment
Prof it before Tax 6.8 2.4 27 20.0
Net Present Value
5 years 24.5 8.7 97.3 72.1
10 years 38.4 13.6 152.6 113
30 years 54.8 19.3 217.5 161
50 years 56.4 19.9 224.2 166
Salvage Value 16.2 16.2 30.3 30.3
This data shows that small plants after treatment still have net present values greater than
salvage values for both short and long term operations. If profitability declines and/or costs
increase during this period then much longer periods of this condition would occur. For instance if
the combination of decreased profitability and cost increases reduced profit by 20% then the very
small plants would have a negative DCF vs Salvage value forever.
42
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VIII. REFERENCES
1. Economic Analysis of Proposed Effluent Guidelines Paint and Allied Products and Printing
Ink Industries EPA-230/1-74-052, August 1974.
2. Kline Industrial Marketing Guide 1MG-1-75 Paint Industry.
3. Paint Red Book Eighth Edition; Palmerton Publishing Company.
4. Operating Cost Survey, 1976. National Paint and Coatings Association.
5. Draft Engineering Report for Development of Effluent Limitations Guidelines for the Paint
Manufacturing Industry. Burns and Roe.
6. U.S. Department of Commerce, Census of Manufactures.
43
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