United States      Control Technology       EPA-450/3-90-001
Environmental Protection Center             October 1989
Agency         Research Triangle Park NC 27711
Affordability Analysis of
Lead Emission Controls
for a Smelter-Refinery
 control ^ technology center

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                                              EPA 450/3-90-001
AFFORDABILITY ANALYSIS OF LEAD EMISSION CONTROLS
                FOR A SMELTER-REFINERY
                CONTROL TECHNOLOGY CENTER

                       SPONSORED BY:

            Emission Standards and Engineering Division
            Office of Air Quality Planning and Standards
              U.S. Environmental Protection Agency
           Research Triangle Park, North Carolina 27711

          Air and Energy Engineering Research  Laboratory
              Office of Research and Development
              U.S. Environmental Protection Agency
           Research Triangle Park, North Carolina 27711

           Center for Environmental Research Information
              Office of Research and Development
              U.S. Environmental Protection Agency
                     Cincinnati, Ohio 45268

                        October  1989
                      U.S. Environmental Protection Agency
                      Region 5 Library (PL-12J)
                      77 West Jackson Blvd., 12th Floor
                      Chicago, IL 60604-3590

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                                            EPA 450/3-90-001
                                            October  1989
AFFORDABILITY ANALYSIS OF LEAD EMISSION CONTROLS
                FOR A SMELTER-REFINERY
                             by:

                     Thomas M. Scherer
                      JACA  Corporation
                     550 Pinetown Road
              Fort Washington, Pennsylvania 19034

                 EPA Contract No. 68D80072

                       Project Officer

                      Donald G. Gillette
           Office of Air Quality Planning and Standards
              U.S. Environmental Protection Agency
          Research Triangle Park,  North Carolina 27711

                        Prepared for:

                  Control Technology Center
              U.S. Environmental Protection Agency
          Research Triangle Park,  North Carolina 27711

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ACKNOWLEDGMENTS

      This report was prepared for EPA's  Control Technology  Center
(CTC) by  Thomas M. Scherer of JACA Corporation, Fort Washington, PA.
The project officer was Don Gillette  of EPA's Office of Air Quality Planning
and Standards (OAQPS).  The author gratefully acknowledges Don Gillette,
Al Wehe and Robert Blaszczak of OAQPS,  Charles Darvin of EPA's  Air and
Energy Engineering Research Laboratory, and Chuck Marshall of JACA for
their helpful suggestions and  for their comments on the draft; and Roger
Ellefson, P.E. of JACA for reviewing and  analyzing the compliance cost
estimates.  Special thanks  are also due  to Carl DiFrancesco and Gary
Peterson of the Bureau of Mines' Minerals Availability Field Office in Denver,
CO for running their lead smelter cost model and for supplying the terms of
a recent lead concentrate contract  between a smelter and a mine.

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PREFACE

      This project was funded by EPA's Control Technology Center (CTC)
in response to a request for assistance from EPA Regional Office VII.

      The CTC was established by EPA's Office of Research and Devel-
opment (ORD) and Office of Air Quality Planning and Standards  (OAQPS)
to provide technical  assistance to  State  and  Local air pollution control
agencies. Three levels of assistance can be accessed through  the CTC.
First,  a  CTC  HOTLINE has been established to provide telephone assis-
tance on matters relating to air pollution control technology. Second, more
in-depth engineering assistance can  be provided when appropriate.  Third,
the CTC can provide technical guidance through  publication of technical
guidance documents,  development  of personal computer software,  and
presentation  of  workshops on control technology matters.

      Engineering assistance projects such as this one focus on specific
problems or concerns  that are identified through contact  with  State  and
Local agencies.  In this  case, the CTC became involved as a result of a
request  by EPA  Region  VII to evaluate the affordability and economic im-
pact of additional control measures deemed necessary for a smelter-refin-
ery to meet the  lead emissions standard.   The  emphasis in the  analysis is
on the impact of control costs on the smelter-refinery's profitability.  The
analysis was performed  using  control cost data from two different lead
smelter studies  in conjunction with existing  firm  and industry data.
                                 IV

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 Introduction

       This report examines the economic  impacts  of EPA's  ambient  air lead
 standard of 1.5 yg/m3 on The Doe Run Company primary lead smelter-refinery
 in Herculaneum, Missouri.  The Herculaneum facility is  currently  not in
 compliance with the standard.
       The economic impacts of  the lead standard  are evaluated  in  this
 report by assessing whether Herculaneum  can  afford to invest 1n pollution
 controls.   The  report begins with background information  on Herculaneum and
 the U.S.  primary lead industry.   Then, two alternative  representations of
 the costs  necessary for  Herculaneum  to achieve compliance with the  lead
 standard  are presented.   Next,  the impact of the control  costs on
 Herculaneum's profitability is  evaluated.  This will depend on the  extent
 to which  compliance costs must  be absorbed.   Lead  1s an internationally-
 traded commodity whose price is  determined by global market factors.  In  a
 global  context,  the lead  market  is competitive, and Herculaneum acts as a
 price  taker.  Therefore,  1t is  recognized that Herculaneum will not be able
 to recover  compliance costs by  increasing prices.   However, because
 Herculaneum and  its mines  are  interdependent, Herculaneum may be able to
 pass some of  its  compliance costs  back to the mines.  Finally, the ability
 of Herculaneum  to  finance  the  initial capital outlay required for
 compliance  is examined.

 Background

       The Doe Run Co. lead  smelter-refinery at Herculaneum, Missouri is the
 largest primary  lead production facility in the U.S., with an annual capa-
 city of 225,000  short tons  (204,117 metric tons)  of refined lead.   In 1988,
 Herculaneum produced at capacity, with refined lead output of 225,403 short
 tons (204,482 metric tons).l  In comparison, total  industry output of pri-
mary refined lead in 1988 was 380,000 metric tons.2  m  1987,  total  output
 of primary refined lead 1n the U.S. was  373,610 metric tons.   This
accounted for almost 12 percent of total  world output of 3,176,600 metric
tons.3  Lead is  also produced from secondary sources.  In  1988,  total
secondary lead production in the U.S. was 635,000 metric tons.4  570,000
                                    -1-

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 metric tons,  or 90 percent,  of secondary  production  in  1988  came  from  scrap
 batteries.
       For most of 1988,  only four  primary lead  smelters and/or  refineries
 were in operation in  the United States.   ASARCO Inc. operated a smelter-
 refinery in Glover, Missouri;  a smelter in E. Helena, Montana; and a refi-
 nery in Omaha, Nebraska.  The  fourth  operation  was Doe  Run's Herculaneum
 smelter-refinery.  Combined,  these operations have capacity  to produce
 468,000 metric tons of  refined lead annually.5   In late 1988, Doe Run
 reopened parts of its smelter-refinery in Buick, Missouri, adding 127,000
 metric tons to domestic  refined lead  capacity.   This brought total domestic
 capacity for  refined  lead to 595,000  metric tons.
       In 1981,  annual domestic refined lead capacity was 715,000 metric
 tons.   Capacity declined,  however,  as a result  of the closure at the end of
 1981  of Bunker Hill's smelter-refinery in Kellogg, Idaho.  In addition,
 ASARCO has  since closed  its  smelter in El  Paso, Texas.  The domestic pri-
 mary  lead industry has retrenched  in  response to decreased lead consump-
 tion,  worldwide  overcapacity,  low  prices,  and environmental regulations.6
 The decline in  consumption can  be  attributed to a phase-down in the use of
 lead  solder,  lead-based  paints, and lead-based gasoline antiknock addi-
 tives.   Whereas  tetraethyl lead, a gasoline antiknock additive, once
 accounted for over 20 percent  of lead demand,  it accounted for only about 2
 percent  in  1988.7  The phase-down  is considered to be complete, and demand
 has stabilized.   Long-term demand  growth of 1-2 percent per year is
 projected,  1n part from  new battery applications.8
       The Doe Run Co.  was formed in November 1986 when St.  Joe Minerals
 Corp., a subsidiary of Fluor Corp., and Homestake Mining Co.  combined their
 lead mining, milling,  and smelting-refining interests in Missouri.  Fluor
 has a  57.5 percent interest in the partnership,  while Homestake Mining  is a
 42.5 percent partner.   In total, Doe Run owns  six mines, four mills,  and
 two smelter-refineries,  and is the largest fully integrated producer  of
primary  lead in North  America.   In addition to the 204,482  metric  tons  pro-
duced at Herculaneum in  1988, Doe Run  produced 9,525  metric tons  of  refined
 lead at its  Buick smelter-refinery. The combined annual  capacity  of
Herculaneum  and Buick  is approximately 331,000 metric tons  of refined lead.9
                                    -2-

-------OCR error (C:\Conversion\JobRoot\0000064S\tiff\2000MMU8.tif): Unspecified error

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       The  first  estimate  is  derived  from a  study of  lead emission  controls
 at Herculaneum conducted  in  April  1989  by Fluor Daniel, Inc., a  unit  of
 Fluor Corp.,  one of  the parent  companies of Doe Run.14  Based on Fluor
 Daniel's  study,  it is  estimated that the capital cost of controls  is  $7.7
 million.   The study  does  not assume  any annual operating and maintenance
 costs,  possibly  because new  control  equipment would  replace existing  equip-
 ment.   Consequently, annual ized compliance  costs consist only of annual ized
 capital.   Capital can  be  annual ized  through use of the Capital Recovery
 Factor  (CRF), which  expresses a capital asset as an  annuity over its  useful
 life:

                              CRF  *  1
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       The  two  estimates are widely disparate.  On a per-pound basis, the
 Fluor  Daniel annualized cost  is 0.3  cents, while the BOM annualized cost  is
 3.7  cents.  There are  two main reasons for the disparity.
       First, the BOM estimate is based on reducing lead emissions to the
 lowest level theoretically achievable.  This may exceed what Is necessary
 to meet the current lead standard.   Thus, the BOM estimate may  be
 overstated.  Information in the Fluor Daniel report on emissions reductions
 is largely qualitative.  Consequently, it is not possible to quantify the
 emissions  reduction that Fluor Daniel expects to be able to achieve.
 Presumably, it will reduce lead emissions to the current standard, though
 such a claim is not made.
       Secondly, the Fluor Daniel and BOM estimates are based on entirely
 different prescriptions for what 1s  necessary to reduce lead emissions.
 The supposition in the Fluor Daniel  estimate is that Best Available Control
 Technology (BACT) is currently not in place, and that necessary reductions
 in lead  emissions can be achieved by improving the efficiency of controls
 on point sources of emissions, and by improving housekeeping and making
 minor  process  and equipment changes.  Fluor Daniel estimated capital-costs
 using  internal company factors that were not specified; therefore, it is
 not possible to judge the accuracy of their method.  The BOM, on the other
 hand,  stipulates that point sources are already controlled with BACT, and
 that lead emissions can only be reduced by controlling fugitive emissions
 sources.  This would entail enclosing the operation,  installing new
 baghouses, and adding workplace controls for exposures to emissions that
would be contained by an enclosure.  The BOM estimated capital  costs by
 factoring direct materials, labor,  and construction equipment usage costs.
This method is probably accurate to +30 percent.
      It is not known  which of the  two cost  estimates  more  accurately
reflects the  changes required  to  bring Herculaneum into compliance  with  the
lead  standard.   It  is  possible that the true  cost  lies  somewhere between
the two estimates.   Therefore,  in this  report,  the  economic  impacts  of both
control costs  will  be  examined.
                                    -5-

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 Revenue
       As  a  first  step  in  assessing  the affordability of pollution controls,
 Herculaneum's  revenue  must  be estimated.  Doe Run had total sales in 1988
 of $230 million.16   However, as mentioned, Doe Run operates six mines, four
 mills, and  another  smelter-refinery,  in addition to Herculaneum.  It is
 necessary to  isolate Herculaneum's  revenue contribution.
       Lead  output at Herculaneum  in 1988 was 204,482 metric tons.  This can
 be used as  an  estimate of future  annual output.  The average realized price
 of Herculaneum's  output in  1988 is  not known.  On July 24, 1989, Doe Run
 increased its  list  price  for lead from 40 cents to 42 cents per pound.17
 At the same time, however,  the London Metal Exchange (LME) cash value for
 lead was  only  32.1  cents  per pound.18  Typically, North American producers
 allow  a discount  off of their list  price.  A good estimate of the net price
 is the LME  cash value  plus  an allowance of about 5 cents per pound for
 shipping  costs.19  This implies a current net price of about 37 cents per
 pound.  This  is consistent  with the comment of a battery producer
 (batteries  accounted for  76 percent of lead consumption in the U.S. in
 1987)  that  discounts in the last  week of July were "running over 10 percent
 off the 42  cent list price."20
      The current net  price of 37$/lb can serve as an estimate of the
 future price of lead.  Commodity  prices are notoriously volatile, however.
 Table  1 lists  average  annual North American producer list prices from 1970
 to 1988.21»22  since 1980,  the average annual North American producer price
 has ranged  from a high of 42.4$/lb in 1980 to a low of 19.H/lb in 1985.
 As mentioned,  Doe Run's list price is currently 42$/lb.   Clearly, the
 current price  of  lead  is high by  standards of the past couple decades.   At
 the moment, the lead market is strong, in part because battery producers
 are replenishing  inventories that fell to lower levels than expected over
 the winter.23  If tn1s is temporary, the price of lead could fall  in the
 future.  To account for uncertainty in the price  of lead,  two sensitivities
will be examined:   27c/lb and  47*/lb.   It 1s  particularly  important  to  exa-
mine the downside  sensitivity  -  27
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                    Table 1

         AVERAGE ANNUAL NORTH AMERICAN
    PRODUCER LIST PRICE OF LEAD,  1970-1988
Year
1970
1971
1972
1973
1974
1975
1976
1977
1978
1979
1980
1981
1982
1983
1984
1985
1986
1987
1988
Price (*/lb)
15.7
13.9
15.0
16.3
22.5
21.5
23.1
30.7
33.7
52.7
42.4
36.5
25.5
21.7
25.6
19.1
22.0
35.9
37.1
Source:  References 21, 22.
                     -7-

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       At  37c/lb,  Herculaneum's  revenue  is  calculated  to be  $166.8 million.
 Revenue is $121.7 million  at  27$/lb  and $211.9 million at 47*/lb.   It  is
 conceivable that  Herculaneum  also  derives  revenue  from byproducts such  as
 zinc,  copper,  and silver.   In Homestake Mining's 1988 annual  report, pro-
 duction of zinc and  copper concentrates are  specifically mentioned.
 However,  these are mill  products.  No mention is made in the  annual  report
 of smelting byproducts.  Therefore,  it  is  conservatively assumed that
 Herculaneum's  revenue  derives solely from  the sale of refined lead.

 Profitability

       Lead is  an  internationally-traded commodity  whose price is determined
 by global  market  factors.   In a global  context, the lead market is  com-
 petitive,  and  domestic producers are price takers.  They are  constrained to
 set prices that are  in line with the international exchange price,  relative
 tariffs and quotas,  and  transportation  cost  differentials.  Already, 15
 percent of domestic  lead consumption is  accounted  for by imported lead
 metal  and  lead refined domestically  from imported  concentrates.24
 Therefore,  it  is  unlikely  that Herculaneum would be able to recover
 compliance  costs  through a price Increase.
       On the other hand, it may be possible  for Herculaneum to pass some of
 its  compliance costs back  to  its mines.  This is because Herculaneum and
 the mines are  interdependent.  The mines supply concentrate to Herculaneum,
 while  Herculaneum serves as a smelting and refining outlet for the mines.
 If,  in  the  extreme, compliance costs were to prove to be prohibitive and
 Herculaneum were shut  down, the mines would have to find an alternative
 smelting and refining  outlet.   Perhaps  Buick has spare capacity,  but, in
 general, U.S. lead smelting and refining capacity is  limited.   It  might
 therefore be necessary for the mines to ship their concentrate overseas for
 smelting and refining.   As mentioned previously,  the  transportation  cost
differential relative to  the LME cash price is  about  5 cents per pound.  To
avoid an increase  in  transportation and marketing  costs,  the mines might be
willing to help absorb  some of Herculaneum's  compliance  costs.
      The extent  to which the  mines would be  willing  to  share  the  burden of
Herculaneum's compliance  costs is  not known.  The maximum  impact on
                                    -8-

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 Herculaneum 1s  represented  by  the  case  of  full-cost absorption.   In  the
 analysis  that follows,  this case will first be  examined.   In  order to  exa-
 mine this case,  profitability  at Herculaneum must  be  isolated.  This is
 equivalent to evaluating  Herculaneum as a  profit center.   Later,
 Herculaneum1s interdependence  with Its  mines will  be  recognized by con-
 sidering  the possibility  that  compliance costs  can be passed  backward  to
 the mines.
       Because it is  privately  held (by  Fluor and Homestake Mining),  Doe Run
 does not  report  its  earnings to the public.  Both  Fluor and Homestake
 Mining disclosed some  results  of Doe Run's operations in their 1988  annual
 reports,  however.  Strangely,  the  disclosures are  contradictory.  Homestake
 Mining reported  that Doe  Run had operating earnings (before interest and
 taxes, which are paid  at  the corporate  —  i.e., Fluor and  Homestake  Mining
 —  level,  and perhaps  some  corporate overhead allocations) of $63.4  million
 on  sales  of $230.2 million  in  1988, and operating  earnings of $24.7  million
 on  sales  of $174.4 million  in  1987.  Of the $63.4  million  in  operating
 earnings  in 1988, Homestake Mining reported its share as $29.8 million (not
 exactly 42.5 percent because of an adjustment made for assets contributed
 by  the company to the  partnership  in excess of  its equity  share).  This
 leaves $33.6 million for  Fluor.  However, Fluor reported its  share of Doe
 Run's  operating  earnings  in  1988 as $29.0 million.  Fluor also reported
 that  its  share of 1988  sales was $123.5 million.   For 1987, Fluor reported
 that Doe Run contributed  $93.1 million  to Its sales and a net operating
 loss of $5.5 million to its  earnings.  The operating margin in 1988 was
 27.5 percent as  reported  by  Homestake Mining,  and 23.5 percent as reported
 by  Fluor.   Despite the differences, both Homestake Mining and Fluor attri-
 buted  the  improved earnings  in 1988 to higher  volume,  lower operating
 costs, and  higher prices  for lead and byproducts.
      Since the  figures reported by Fluor and  Homestake  Mining are for  the
 entire Doe Run  Co.,  they can only be used as guidelines  for profitability
at Herculaneum.   To  estimate Herculaneum1s  profitability,  the  aid  of  the
Bureau of Mines'  Minerals  Availability  Field Office in Denver, Colorado was
enlisted.   The  BOM field office furnished estimates of capital and
operating  costs  for  a generic smelter  similar  to Herculaneum.   In  addition,
the terms  of a  recent (1988) lead  concentrate  contract between a custom
                                    -9-

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 smelter and mine in North America were provided.  This can be used to esti-
 mate the cost to Herculaneum of lead concentrate.
       Of course, Herculaneum does not purchase lead concentrate on the open
 market.  Instead, lead concentrate is supplied by Doe Run's mines.  In
 order to isolate Herculaneum1s profitability, however, it is necessary to
 determine the market value of the lead concentrate supplied by the mines.
 The true economic cost to Herculaneum of lead concentrate is the market
 rate.  Conversely,  there is an opportunity cost to the mines if lead con-
 centrate is transferred to Herculaneum at less than the market rate.
       Specifications of the lead concentrate contract formula supplied by
 the BOM field office and an example of a raw materials cost calculation are
 provided in Exhibit 1.  The contract was executed in 1988 between a custom
 smelter and mine in North America.  Unlike the cost data supplied by the
 BOM field office, the lead concentrate contract is not necessarily generic.
 Contracts are negotiated individually between mines and smelters, and terms
 can vary considerably according to a number of different factors.  In addi-
 tion, not all  concentrates are suitable for all  smelters.   Therefore, the
 contract formula should be considered as allowing for only a crude estimate
 of Herculaneum1s raw materials costs.
       In Exhibit 1,  only the  lead  content is considered in calculating
 the cost of concentrate.   It  is possible that Herculaneum  produces
 small  amounts  of zinc,  copper,  and silver as byproducts.   However,  neither
 Fluor nor Homestake  Mining mentioned  byproducts  in  discussing  smelting-
 refining operations  in  its 1988 annual  report.   Morever, the BOM  field
 office  indicated that,  in  general,  byproducts  do  not  contribute signifi-
 cantly  to profits at  smelters.   For example,  profits  from  silver, which can
 be  appreciable,  tend  to accrue  to  the mine.   Therefore, excluding bypro-
 ducts from  both  revenue and costs  should  have  little  impact on profits.
 Nevertheless, to the extent that byproducts  contribute to Herculaneum's
 profits, profitability in  this analysis will be understated.
      Continuing with Exhibit 1, note that the cost of lead concentrate is
 equal to the concentrate's lead value, minus the cost to smelt and refine
 the concentrate  (treatment charge), and minus a price participation clause
which establishes how the value of lead in concentrate in excess of
smelting and refining costs is shared between the smelter and the mine.
                                    -10-

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                                  Exhibit  1
               CONTRACT FORMULA FOR THE COST OF CONCENTRATE
                            (LEAD  CONTENT  ONLY)3
 Inputs
 (1)   Lead content of concentrate * 75%
 (2)   Lead recovery rate = 95%
 (3)   Grade deduction = 1.5 units
 (4)   Percent paid for = (75-1.5)775 x .95 = 93.1%
 (5)   Refined lead output * 204,482 metric tons
 (6)   Concentrate purchased = 204,482 metric tons * 0.75 * 0.95 = 286,992
      metric tons
 (7)   Treatment charge rate (includes refining charge) = $180/metric ton
 (8)   Variable component of price participation agreement:  l/4t for every
      cent per pound in price of lead above 33$/lb
 (9)   Fixed component of price participation agreement:  12$/lb
 Calculation for a lead price of 37*/1b
 (1)   Value of lead content =
      286,992 metric tons x 0.931 x 0.75 x $0.37/lb x 2,204.62 Ibs/metric
      ton = $163.5 million
 (2)   Treatment charge =
      $180/metric ton x 286,992 metric tons = $51.7 million
 (3)   Price participation = [$0.12/lb + [(37t/lb - 33*/lb) x $0.002511 x
      204,482 metric tons x 2,204.62 Ibs/metric ton = $58.6 million
 (4)   Net paid to mine (cost of concentrate)  =
      $163.5 million - $51.7 million - $58.6  million = $53.2 million

aBased on an actual  North American lead concentrate contract in 1988.
                                    -11-

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 At a lead price of 37*/lb,  the value of the  lead  content  is  $163.5  million
 and the treatment charge is $51.7 million.   The difference,  $111.5  million,
 is divided between the smelter and the  mine, with the  smelter  keeping  $58.6
 million (price participation = $58.6 million)  and the  mine receiving $53.2
 million.   The $53.2 million paid  to the mine is the  smelter's  cost  of  lead
 concentrate.   The results of the  calculations  in  Exhibit  1 for a  lead  price
 of 37
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                          Table 2

               CALCULATION OF MATERIALS COST
                         ($ Million)

Value of lead content
Treatment charge
Price participation
Net paid to mines3
(cost of concentrate)

27*/lb
$119.3
51.7
54.1
13.5
Price
37*/lb
$163.5
51.7
58.6
53.2

47*/lb
$207.6
51.7
69.9
86.0
aEqual to the value of lead content minus the treatment
 charge and minus price participation.
                           -13-

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                          Table 3a


             ESTIMATE OF NET INCOME  BEFORE  TAXES
             FROM LEAD PRODUCTION AT HERCULANEUM
                    (Millions of Dollars)

Revenue
Materials cost3
Operating costb
Capital recovery0
Return on capitald
Corporate overhead
Net income before taxes
Before-tax profit margin

27t/lb
$121.7
13.5
50.8
9.1
14.1
13.5
20.7
17.0%
Price
37*/lb
$166.8
53.2
50.8
9.1
14.1
13.5
26.1
15.6%

47*/lb
$211.9
86.0
50.8
9.1
14.1
13.5
38.4
18.1%
Calculated using the lead concentrate contract formula in
 Exhibit I.


blncludes operating and maintenance costs, current environ-
 mental compliance costs, and costs of administration and
 supervision.


cAnnual value of the capital  cost ($135.8 million) amortized
 evenly over 15 years.


dAnnual value required to earn a 15 percent return on capital
 (i.e., to pay for a 15 percent cost of capital).
                            -14-

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                          Table  3b


             ESTIMATE  OF  NET  INCOME  BEFORE  TAXES
             FROM LEAD PRODUCTION AT HERCULANEUM
                     (Cents per  Pound3)

Revenue
Materials costb
Operating cost0
Capital recover/1
Return on capital6
Corporate overhead
Net income before taxes

27*/lb
27.0*
3.0
11.3
2.0
3.1
3.0
4.6
Price
37$/lb
37.04
11.8
11.3
2.0
3.1
3.0
5.8

47*/lb
47.0*
19.1
11.3
2.0
3.1
3.0
8.5
aBased on 1988 production at Herculaneum of 450,806,000 Ibs.

Calculated using the lead concentrate contract formula in
 Exhibit I.


clncludes operating and maintenance costs, current environ-
 mental compliance costs, and costs of administration and
 supervision.


dAnnual value of the capital cost ($135.8 million) amortized
 evenly over 15 years.


eAnnual value required to earn a 15 percent return on capital
 (i.e., to pay for a 15 percent cost of capital).
                            -15-

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       Capital recovery is simply the annual  value of the capital  cost,
 $135.8 million, amortized evenly (straight-line depredation)  over an
 assumed useful  life of 15 years.  The $135.8 million capital  cost is for a
 new facility that, like Herculaneum, is not  in  compliance with the lead
 standard, but is in compliance with existing particulate and  S02  standards.
       A firm will  also require a return to cover its cost of  capital.  To
 finance an investment, a firm can use some combination  of debt and equity.
 In Tables 3a and 3b,  the cost of capital  is  assumed  to  be 15  percent.  In
 order to pay for a cost of capital  of 15  percent,  a  firm needs to earn a 15
 percent return  on investment.  The  average annual  amount required to earn a
 15 percent return on  capital  is calculated to be $14.1  million, or 3.H/lb.
 The calculation is simply the difference  between the annualized capital
 cost, calculated using the Capital  Recovery  Factor over a useful  life of 15
 years at a discount rate of 15 percent, and  the annual  value  of the capital
 cost amortized  evenly over 15 years.  Since  Tables 3a and 3b  account for
 the cost of capital,  net income is  net of interest expense.   However, con-
 sidering that interest rates  are currently less than 15 percent,  return  on
 capital  in Tables  3a  and 3b may overstate the cost of capital  if  the
 investment can  be  financed largely  or entirely  with  debt.  Therefore, the
 net income estimate may be conservative - in the  short run.   In  the long
 run,  a  firm must  cover Us total  cost of  capital.  Fifteen percent  is
 believed to be  a  reasonable estimate of the  total  cost  of  capital,  con-
 sisting  of a mix of debt and  equity.
      The  corporate overhead  factor  of 3.0e/lb  is  from  a previous BOM study
 in  1988.26  This factor  accounts  for overhead such as selling and admin-
 istrative  expenses.   In  the BOM  study, the corporate overhead factor was
 described  as  including  transportation costs to  the consumer.
      The  before-tax  profit margin at 37*/lb, the current price of lead,  1s
 lower than  the operating margins reported by  Fluor and Homestake Mining  for
 Doe Run  in  1988, 23.5 percent and 27.5 percent,  respectively.   However,  the
 Fluor and Homestake operating margins do not  account  for Interest  expense
 and corporate overhead.  Therefore,  the net income calculation in  Tables  3a
 and 3b appears to be reasonable.
      As a sensitivity, net income is recalculated in Table 4  for  a lead
price of 27«/lb  using  a different materials cost.  The price participation
                                    -16-

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                          Table 4
            ESTIMATE OF NET INCOME BEFORE TAXES
     AT A PRICE OF 27*/LB:  MATERIALS COST SENSITIVITY
$ Million */lba
Revenue
Materials cost0
Operating cost0
Capital recoveryd
Return on capital6
Corporate overhead
Net income before taxes
Before-tax profit margin
$121.7
33.8
50.8
9.1
14.1
13.5
0.4
0.3%
27.0*
7.5
11.3
2.0
3.1
3.0
0.1
0.3%
aBased on 1988 production at Herculaneum of 450,806,000 Ibs.
bEqual to one-half of the difference at a lead price of
 27*/lb between the value of lead content, $119.3 million,
 and the treatment charge, $51.7 million.
clncludes operating and maintenance costs, current environ-
 mental compliance costs, and costs of administration and
 supervision.
dAnnual value of the capital cost ($135.8 million) amortized
 evenly over 15 years.
eAnnual value required to earn a 15 percent return on capital
 (i.e., to pay for a 15 percent cost of capital).
                            -17-

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 clause in the concentrate contract  Included  a  variable  component  for prices
 of lead exceeding 33*/lb.  It is  possible  that the  contract  formula is  not
 applicable at prices below 33c/lb,  and  that  at 27*/lb,  the contract would
 be renegotiated.   This is suggested by  the change in  the distribution of
 the value of lead content in  excess of  the treatment  charge  at different
 lead prices in Table 2.   Note that  at a lead price  of 47*/lb, price par-
 ticipation for the smelter is $69.9 million, while  the  mines are  paid $86.0
 million.   At 37$/lb, the smelter  keeps  $58.6 million, while  the mines
 receive $53.2. At 27*/lb, however, while  the  smelter keeps  $54.1 million,
 the mines receive only $13.5  million.   The reason for this is that the  lead
 concentrate contract is  formulated  so that at  lead  prices below 33
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                                 Table 5a

                  POST-COMPLIANCE NET INCOME BEFORE TAXES
                               AT HERCULANEUM
                           (Minions of Dollars)

Pre-compliance net
income before taxes
Annual ized compliance
cost
Post-compliance net
income before taxes
Compl
P=27*/
Ib
$20.7
1.3
19.4
iance
P=37*
Ib
$26.1
1.3
24.8
Costia
/ P=47*/
Ib
$38.4
1.3
37.1
Compliance Cost2b
Ib Ib Ib
$20.7 $26.1 $38.4
16.8 16.8 16.8
3.9 9.3 21.6
aThe Fluor Daniel  capital  cost estimate  of  $7.7 million, or $1.3 million
 annualized.

bThe BOM capital  cost estimate of $68.3  million and annual operating cost esti
 mate of $3.7 million, for a total  annuallzed  cost of $16.8 million.
                                   -19-

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                                 Table 5b

                  POST-COMPLIANCE NET INCOME BEFORE TAXES
                              AT HERCULANEUM
                            (Cents per Pound3)
                            Compliance Costib
                             Compliance Cost2c
P=27«/   P=37
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 profitable  after  compliance costs.   In the short run, Herculaneum could
 continue  to operate  because it would be covering operating and materials
 costs,  its  variable  production costs.  Herculaneum could also continue to
 operate in  the  long  run.   In  the  long run, all costs are variable,
 including capital  recovery (in the  long run a firm can change plant capa-
 city  or move to another  industry),  the cost of capital, and overhead.  As
 Tables  5a and 5b  demonstrate, these  costs would also be covered.  Post-
 compliance  net  income, representing  net income in the long term, is greater
 than  zero under each  lead  price scenario:  0.9*/lb at a lead price of
 27*/lb, 2.H/lb at a  lead  price of  37*/lb, and 4.8$/lb at a lead price of
 47*/lb.
      The BOM considers a  15  percent internal rate of return (IRR) as
 necessary for a mineral operation to continue producing over the long
 term.27   A  15 percent IRR  has already been built into the calculation of
 post-compliance net  Income through the requirement of a 15 percent return
 on capital  1n Tables 3a and 3b and the calculation of the annualized
 compliance  cost 1n Tables  5a and 5b using a 15 percent discount rate.
 Therefore,  so long as post-compliance net income is greater than zero,
 Herculaneum will be covering  its cost of capital  by earning a 15 percent
 IRR and will  be making a profit over the long term.
      The effects on net income of the materials cost sensitivity intro-
 duced 1n Table  4 are examined in Table 6.   The sensitivity assumes that
 lead profits  are shared equally by mines and smelters at lead prices below
 33*/lb and  that the price of lead falls by 10*/lb to 27*/lb.   Under both
 compliance  cost scenarios, net Income would become negative.   It would be
 possible  for  Herculaneum to continue operating 1n the short run, but 1n the
 long run  1t would be better for Doe Run to shut down Herculaneum and
 redeploy  its  assets to a more profitable venture (i.e.,  one that earns a 15
 percent return  on investment).
      If Herculaneum were closed,  domestic primary refined lead capacity
would decline by 34 percent.  As a result, it would probably  be necessary
 for the U.S.  to export much of its lead ore and concentrate,  and the U.S.
would probably have to increase its reliance on foreign  sources of lead
metal, though perhaps the slack could be picked up  somewhat by  domestic
secondary producers.   The employment impact is not  known,  but  1t could be
                                    -21-

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                                  Table 6


                  POST-COMPLIANCE NET INCOME BEFORE TAXES
             AT A PRICE OF 27*/LB:  MATERIALS COST SENSITIVITY

Pre-compl lance net
Income before taxes
Annual 1zed compliance
cost
Post-compliance net
income before taxes
Compliance Costi3
$ Million $/lbc
$0.4 O.H
1.3 0.3
(0.9) (0.2)
Compliance Cost2b
$ Million C/lbc
$ 0.4 O.H
16.8 3.7
(16.4) (3.6)
aThe Fluor Daniel capital cost estimate of $7.7 million,  or $1.3 million
 annualized.


bThe BOM capital  cost estimate of $68.3 million and annual  operating cost esti-
 mate of $3.7 million, for a total annuallzed cost of $16.8 million.

cBased on 1988 production at Herculaneum of 450,806,000 Ibs.
                                   -22-

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 significant.  Overall, Doe Run employed 1,036 workers at the end of 1988.28
 No  doubt, many  of  these workers are employed at Herculaneum.
       It  should be noted  that in addition to the impact of compliance costs
 on  profitability,  Doe Run would also consider the cost of shutting down
 Herculaneum  in  making a shutdown decision.  To the extent that shutdown
 costs  exceed  salvage value, Doe Run may be willing to sustain small losses
 from operating  Herculaneum in order to postpone a shutdown decision.
       It  is apparent that if the price of lead falls, Herculaneum's long-
 term viability  is  very sensitive to how lead profits are shared by mines
 and smelters.   The lead concentrate contract used to calculate materials
 cost may  not  be applicable for lead prices below 33$/lb.  Additional
 research  is needed to determine the comparative impact on the profitability
 of  mines and  smelters at  lead prices below 33$/lb.
       To this point, Herculaneum's interdependence with its mines has not
 been considered.   If, as discussed previously, Doe Run's mines would have
 an  economic incentive to help share Herculaneum's compliance cost burden,
 the economic  impact on Herculaneum would be less severe.  In the compliance
 cost scenarios  presented in Tables 5a and 5b, Herculaneum's long-term
 viability was already established.  For the materials cost sensitivity in
 Table  6, however,  the interdependence of Herculaneum and Us mines could
 influence Doe Run's decision whether or not to shut down Herculaneum.
 Already, under  the  sensitivity, Herculaneum is close to the shutdown point,
 as  pre-compliance  net income is only O.H/lb.  Therefore, Herculaneum's
 long-run survival  would require that the mines absorb all of the compliance
 costs.  If, in  the event that Herculaneum were shut down, the mines were
 forced to export concentrate in order to stay in business, and marketing
 and transportation costs increased by,  say,  5
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 Capital Affordabillty

       In addition to the ability to absorb annual  compliance costs, it is
 necessary to examine the ability of Herculaneum to finance an initial  capi-
 tal outlay of from $7.7 million to $68.3 million.   One source of financing
 is internal  cash flow.  By making the assumption that capital  expenditures
 are offset by depredation (constant asset base),  net Income is  a proxy for
 cash flow.  As Table 3a indicated, current (price  of lead = 37*/lb) net
 income at Herculaneum is $26.1 million.   Therefore,  Herculaneum  would  be
 able to finance 38 percent of the maximum capital  cost of $68.3  million
 from net income in one year.
       Debt could also be Issued.   At the end  of 1988,  Homestake  Mining  had
 long-term debt of $60.2 million compared to $757.0 million  in  shareholders'
 equity,  while Fluor had long-term debt of $95.0 million and $601.7  million
 in shareholders'  equity.   Both companies have a low  degree  of  financial
 leverage and  should have plenty of capacity to  take  on additional debt.
       Finally,  both parent companies have liquid assets which  could help
 finance  the  Investment 1n pollution  controls.   At  year-end  1988,  Homestake
 Mining had $91.4 million  and  Fluor had $164.6 million  1n  cash  and cash
 equivalents.   With regard to  overall  liquidity,  Homestake Mining  had
 working  capital  (current  assets minus current liabilities)  of  $242.4
 million  at the  end of 1988, while  Fluor  had working  capital  of $154.4
 million.

 Summary  and Conclusions

       Under current market conditions, the Doe  Run Company  primary  lead
 smelter-refinery  in Herculaneum, Missouri would  be able to  invest as much
 as  $68.3 million  in pollution  controls to comply with EPA's  lead  emissions
 standard of 1.5 ug/m3, and would still be profitable In the  long  run.
 Herculaneum would be able to cover Its cost of capital by earning a 15 per-
 cent internal rate of  return (IRR).  Thus, the facility would be able to
meet the Bureau of Mines' criterion of a  15 percent IRR as necessary for a
mineral operation to continue producing over the long term.  Herculaneum
                                    -24-

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would also be able to finance the initial capital outlay required for
compliance.
      In the long run, all costs are variable, and a firm can avail itself
of such opportunities as changing plant capacity or moving to another
industry.  Under current market conditions, the imposition of control costs
would not change Herculaneum's incentive to maintain current capacity and
remain in the lead smelting-refining business.  However, Doe Run may con-
sider other options in order to avoid making the control expenditures, such
as switching production to its Buick facility.  The benefits of doing this
would depend on Buick1s comparative profitability, including the costs —
if any — necessary to bring Buick into compliance with the lead standard.
If the capital  cost is a high as $68.3 million, Doe Run may also consider
investing in a new smelting-refining facility instead of rehabilitating
Herculaneum.  The $68.3 capital cost represents slightly over half of the
estimated cost of the current Herculaneum facility, $135.8 million.  In a
1988 study, the Bureau of Mines found that it would be more cost-effective
for lead producers in Missouri to invest, as a consortium, in a new flash
smelter that would meet current environmental standards, than to rehabili-
tate existing plants.29
      If current market conditions change, i.e., if the price of lead
declines, the affordability of the controls would depend on the cost of
lead concentrate.  The contract formula used to calculate the cost of lead
concentrate may not be applicable at lead prices below 33*/lb.  Applying
the lead concentrate contract at a lead price of 27*/lb, it was found that
Herculaneum would still be profitable after absorbing compliance costs.
Under the hypothetical scenario that lead profits would be shared equally
by mines and smelters at a lead price of 27*/lb, however, it was seen that
Herculaneum's long-term viability could not be assured.  It would be very
useful  to obtain additional information, perhaps from industry sources, on
lead concentrate contracts for lead prices below 33$/lb.
      Even if the price of lead falls to 27$/lb, and lead concentrate
contracts are renegotiated to redistribute lead profits between mines and
smelters, Herculaneum might not have to shut down if Doe Run's mines have a
vested  interest in Herculaneum's survival.   Herculaneum and its mines are
interdependent,  and  the mines may have  an economic incentive to help absorb
                                    -25-

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some of Herculaneum1s compliance costs.  To the extent that Herculaneum1 s
compliance costs can be passed backward to the mines, the economic impact
on Herculaneum of the materials cost sensitivity at a lead price of 27e/lb
would be less severe.
      Finally, two compliance cost estimates were examined that are widely
disparate.  One capital cost is only $7.7, while the other is $68.3
million.  Although both are affordable, the higher cost would have a signi-
ficant impact on Herculaneum1s earnings.  Perhaps additional  research is
needed to come up with a more definitive estimate of compliance costs.
                                   -26-

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 References

 1.     Homestake Mining Company.   1988 Annual Report, p. 15.

 2.     U.S.  Department of the  Interior, Bureau of Mines.  "Mineral Commodity
       Summaries 1989," Lead.  Washington, DC, January 1989.  Page 90.

 3.     U.S.  Department of the  Interior, Bureau of Mines.  "Preprint from the
       1987  Bureau of Mines Minerals Yearbook — Lead."  Washington, DC.
       Page  1.

 4.     Reference 2.

 5.     U.S.  Department of the  Interior, Bureau of Mines.  Information
       Circular 8962. "Lead and Zinc Availability — Domestic."  Minerals
       Availability Field Office, Denver, CO, 1983.  Page 7.

 6.     U.S.  Department of Commerce, International Trade Administration.
       1989  U.S. Industrial Outlook.  Washington, DC, January 1989. Page
       18-5.

 7.     Reference 6, p. 18-6.

 8.     "Two  Scenarios Try to Explain LME Lead Fall."  American Metal Market,
       February 3, 1989, p. 2.                        - ~ --

 9.     Homestake Mining Company.  Form 10-K for the fiscal  year ended
       December 31, 1988.  Page 13~.

 10.    U.S.  Department of the  Interior, Bureau of Mines.  Mineral Industry
       Surveys. "Lead Industry in February 1989."  Washington, DC, April 24,
       1989.  Page 3.

 11.    Reference 9, p. 14.

 12.    Reference 11.

 13.    Reference 1.

 14.    Fluor Daniel,  Inc.  "Evaluation of Lead Emission Controls at the Doe
      Run Company's  Primary Lead Smelter at  Herculaneum,  Missouri."
      Redwood City,  CA,  April  24, 1989.
15'   ai'i; DHParimnn^ °r the Inter1or»  Bureau of Mines.   Information Circular
      9160, "Lead Reduction in Ambient  Air:   Technical  Feasibility and Cost
      Ana ysis at Domestic Primary Lead Smelters and Refineries."   Minerals
      Availability Field Office,  Denver,  CO,  1987.

16.   Reference 1, p. 31.
                                    -27-

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 17.   Metals Week. July 31,  1989, p.  1.

 18.   Reference  17.

 19.   Reference  8.

 20.   Reference  17.

 21.   Reference  6, p.  18-6.

 22.   U.S. Department  of the Interior, Bureau of Mines.  "Lead ~ A Chapter
      from Mineral Facts and Problems," 1985 Edition.  Washington, DC.  Page
      Ifc •

 23.   Reference  17.

 24.   Reference  2.

 25.   U.S. Department of the Interior, Bureau of Mines.  Information
      Circular 9026. "Primary Lead and Zinc Availability ~ Market Economy
      Countries."  Minerals Availability Field Office, Denver, CO, 1985.
      Page 27.

 26.   U.S. Department of the Interior, Bureau of Mines.  Open File Report
      55^88, "Impact of Existing and Proposed Regulations on the Domestic
      Lead Industry."  Intermountain Field Operations Center, Denver.  CO
      August 1988.  Page 22.

 27.   Reference 25, p.  8.

28.   Reference 9, p. 25.

29.   Reference 26.
                                   -28-

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                                   TECHNICAL REPORT DATA
                            (Please read Instructions on the reverse before completing)
1. REPORT NO.
 EPA-450/3-90-001
                              2.
                                                            3. RECIPIENT'S ACCESSION NO.
4. TITLE AND SUBTITLE
 Affordability Analysis of Lead  Emission Control  for a
 Smelter-Refinery
                     5. REPORT DATE
                         October  1989
                     6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)

 Thomas M.  Scherer
                                                            8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS
 JACA Corporation
 550 Pinetown Road
 Fort Washington, Pennsylvania   19034
                                                            10. PROGRAM ELEMENT NO.
                     11. CONTRACT/GRANT NO.


                        68D80072
12. SPONSORING AGENCY NAME AND ADDRESS
 U.S. Environmental Protection  Agency
 Control Technology Center
 Research Triangle Park, North  Carolina
                     13. TYPE OF REPORT AND PERIOD COVERED
                        Final
                     14. SPONSORING AGENCY CODE
    27711
15. SUPPLEMENTARY NOTES
 Work Assignment Manager:  Donald  G.
Gillette, Office of Air Quality  Planning
             and Standards
16. ABSTRACT

      The primary objective of  this  document is to  evaluate the affordability and
 economic impact of additional  control  measures deemed necessary for a  smelter-
 refinery to  meet the lead emission  standard.  The  emphasis in the analysis  is on
 the impact of control costs on the  smelter-refinery's profitability.   The  analysis
 was performed using control cost  data  from two different lead smelter  studies in
 conjunction  with other existing  industry data.
17.
                                KEY WORDS AND DOCUMENT ANALYSIS
                  DESCRIPTORS
        b.IDENTIFIERS/OPEN ENDED TERMS  C.  COSATI Field/Group
  Lead Smelter  Emissions
  Air Pollution Control Technology
  Lead Smelter-Refineries
  Affordability Analysis-Emission Control
          Lead  Emissions
          Air Pollution Control
          Lead  Smelter Refinery
          Affordability Analysis
18. DISTRIBUTION STATEMENT

  Release unlimited
                                               19. SECURITY CLASS (This Report I
                                                                          21. NO. OF PAGES
                                               20. SECURITY CLASS (Thispage)
                                                                          22. PRICE
EPA Form 2220-1 (R«v. 4-77)   PREVIOUS EDITION is OBSOLETE

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