EPA-230/1-73-OBB
MARCH 1974
ECONOMIC ANALYSIS
OF
PROPOSED EFFLUENT GUIDELINES
TEXTILES INDUSTRY
QUANTITY
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Planning and Evaluation
Washington, D.C. 2046O
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This document is available in limited quantities through the
U. S. Environmental Protection Agency, Information Center,
Room W-327 Waterside Mall, Washington, D. C. 20460.
The document will subsequently be available through the
National Technical Information Service, Springfield, Virginia
22151.
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230173028
EPA-230/1-73-028
ECONOMIC ANALYSIS
OF
PROPOSED EFFLUENT GUIDELINES
TEXTILES INDUSTRY
March 1974
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Planning and Evaluation
Washington, D.C. 20460
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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 contractors' study prepared for the Office of Planning and
Evaluation of the Environmental Protection Agency ("EPA"). The purpose of the study is
to analyze the economic impact which could result from the application of alternative
effluent limitation guidelines and standards of performance to be established under sec-
tions 304(b) and 306 of the Federal Water Pollution Control Act, as amended.
The study supplements the technical study ("EPA Development Document") sup-
porting the issuance of proposed regulations under sections 304(b) and 306. The Develop-
ment Document surveys existing and potential waste treatment control methods and
technology within particular industrial source categories and supports promulgation of
certain effluent limitation guidelines and standards of performance based upon an analysis
of the feasibility of these guidelines and standards in accordance with the requirements of
sections 304(b) and 306 of the Act. Presented in the Development Document are the
investment and operating costs associated with various •alternative control and treatment
technologies. The attached document supplements this analysis by estimating the broader
economic effects which might result from the required application of various control
methods and technologies. This study investigates the effect of alternative approaches in
terms of produce price increases, effects upon employment and the continued viability of
affected plants, effects upon foreign trade and other competitive effects.
The study has been prepared with the supervision and review of the Office of Planning
and Evaluation of EPA. This report was submitted in fulfillment of Task Order No. 10 of
Contract 68-01-1541 by Arthur D. Little, Inc. Work was completed as of March 1974.
This report is being released and circulated at approximately the same time as
publication in the Federal Register of a notice of proposed rule making under sections
304(b) and 306 of the Act for the subject point source category. The study has not been
reviewed by EPA and is not an official EPA publication. The study will be considered along
with the information contained in the Development Document and any comments received
.by EPA on either document before or during proposed rule making "proceedings necessary to
establish final regulations. Prior to final promulgation of regulations, the accompany study
shall have standing in any EPA proceeding or court proceeding only to the extent that it
represents the views of the contractor who studied the subject industry. It cannot be cited,
referenced, or represented in any respect in any such proceeding as a statement of EPA's
views regarding the subject industry.
ill
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TABLE OF CONTENTS
Page
List of Tables vii
List of Figures xi
1. EXECUTIVE SUMMARY 1
2. INDUSTRY PROFILES 11
a. Wool Finishing 11
b. Woven Fabrics — Dyeing and Finishing 20
c. Knitted Fabric — Dyeing and Finishing 26
d. Yarn and Stock — Dyeing and Finishing 33
3. IMPACT ANALYSIS IN SPECIFIC TEXTILE CATEGORIES 43
a. Introduction 43
b. Category 1 — Scenario of Wool Scouring 50
c. Category 2 — Scenario of Wool Dyeing and Finishing 58
d. Category 4 — Scenario of Woven Fabric Dyeing and
Finishing (Cotton and Synthetics) 66
e. Category 5 — Scenario of Knit Fabric Dyeing and
Finishing (Cotton and Syntheti9s) 72
f. Category 7 - Scenario of Stock and Yarn Dyeing 80
APPENDIX - WASTE TREATMENT MODEL FOR TEXTILE
EFFLUENT GUIDELINES 91
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LIST OF TABLES
Table No. Page
1-1 Estimated Waste Treatment Investments and Annual
Operating Costs to Meet Proposed Textile Guidelines 4
1-2 Financial Profile Summary — Textile Industry 5
1-3 Price Impact Summary 7
1-4 Summary of Impact on Mill Closings and Unemployment 8
2-1 Total Fiber Consumption 11
2-2 Woolen and Worsted Looms in Place 12
2-3 Index of Industrial Production 12
2-4 Wool Scouring and Combing Plants Industry Growth
1958-1970 13
2-5 Wool Scouring and Combing — Size Distribution 14
2-6 Category 1 — Raw Wool Scouring Mills 14
2-7 Wool Scouring and Combing Plants — Geographic
Distribution 15
2-8 Weaving and Finishing Wool Fabrics Industry Growth
1958-1970 16
2-9 Weaving and Finishing Wool Fabrics — Size Distribution 17
2-10 Category 2-Wool Finishing Mills 17
2-11 Wool Weaving and Finishing Mills — Geographic
Distribution 19
2-12 Woven Fabrics Dyeing and Finishing 20
2-13 Woven Fabrics 21
2-14 Category 4 — Woven Fabrics, Dyeing, and Finishing 22
vn
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LIST OF TABLES (Continued)
Table No. Page
2-15 Woven Fabrics — Cotton Dyeing and Finishing 23
2-16 Woven Fabrics — Synthetic Dyeing and Finishing 24
2-17 Financial Profile 27
2-18 Dyeing and Finishing — Knitted Fabrics Industry Growth
1958-1970 28
2-19 Knitted Fabrics Manufacturers — Dyeing and Finishing 28
2-20 Category 5 — Knit Fabric, Dyeing and Finishing 29
2-21 Geographic Distribution of Knitted Fabric Manufacturers
Including Dyeing and Finishing 30
2-22 Geographic Distribution of Knitted Fabric Dyers and
Finishers Only 31
2-23 Financial Profile — Profit Margin of Integrated Knitting
Mills 1970-1971 34
2-24 Financial Profile — Profit Margin of Largest Commission
Dyers of Knitted Fabric 1969-1971 34
2-25 Yarn and Stock Dyeing and Finishing Industry Growth
1958-1970 35
2-26 Yarn and Stock Dyeing and Finishing 36
2-27 Category 7 — Yarn and Stock — Dyeing and Finishing 37
2-28 Yarn and Stock Dyeing and Finishing 37
2-29 Finishing Plants, Yarn and Stock 39
2-30 Financial Profile 41
3-1 Representative Very Small Raw Wool Scouring Mill 52
Vlll
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LIST OF TABLES (Continued)
Table No. Page
3-2 Representative Small/Medium Raw Wool Scouring Mill 53
3-3 Economic Impact of Effluent Guidelines on Wool
Scouring Mills, Category 1 54
3-4 Representative Very Small Wool Dyeing and Finishing Mill 59
3-5 Representative Wool Dyeing and Finishing Mills 60
3-6 Economic Impact of Effluent Guidelines on Wool Dyeing
and Finishing Mills, Category 2 62
3-7 Representative Very Small Broad Woven Dyeing and
Finishing Mill 67
3-8 Representative Broad Woven Dyeing and Finishing Mills 68
3-9 Economic Impact of Effluent Guidelines on Broad Woven
Dyeing and Finishing Mills, Category 4 70
3-10 Representative Very Small Knit Fabric Dyeing and
Finishing Mill 75
3-11 Representative Knit Fabric Dyeing and Finishing Mills 75
3-12 Economic Impact of Effluent Guidelines on Knit Fabric
Dyeing and Finishing, Category 5 78
3-13 Representative Knit Fabric Dyeing and Finishing Mills 81
3-14 Representative Very Small Stock and Yarn Dyeing Mill 83
3-15 Representative Small Size and Medium Stock and Yarn
Dyeing Mills 84
3-16 Economic Impact of Effluent Guidelines on Stock and
Yarn Dyeing Mills, Category 7 86
IX
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LIST OF FIGURES
Figure No. Page
2-1 Dyeing and Finishing — Woven Cotton and
Synthetics 25
2-2 Knit Fabric Finishing 32
2-3 Yarn and Stock Dyeing and Finishing 38
XI
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1. EXECUTIVE SUMMARY
a. Introduction. This study examines the economic impact on the textile industry
of the proposed effluent guidelines for:
• the proposed best practicable technology,
• the proposed best available technology, and
• new source performance standards (NSPS).
The textile industry has been divided into seven categories for the purpose of
establishing effluent guidelines. They are:
• Wool scouring,
• Wool dyeing and finishing,
• Greige goods mills,
• Woven fabrics dyeing and finishing (cotton and synthetics),
• Knit fabric dyeing and finishing (cotton and synthetics),
• Carpet mills, and
• Stock and yarn dyeing and finishing.
The economic impact of the proposed guidelines has been examined for five of
the above categories. They are:
• Wool scouring,
• Wool dyeing and finishing,
• Woven fabric dyeing and finishing (cotton and synthetics),
• Knit fabric dyeing and finishing (cotton and synthetics), and
• Stock and yarn dyeing and finishing.
Two other categories - greige goods mills and carpet mills - have been precluded
from this initial study of the economic impact on the assumption that they would not be
significantly impacted by the proposed effluent guidelines.
In addition to setting aside two of the seven textile categories from this initial
study, we have also set aside large integrated te'xtile mills which will not be significantly
impacted, generally because of their higher profit levels, larger size and integrated produc-
tion, as well as their ability to apply a strong price on levels within the industry. The ability
to raise (control) prices will allow them to pass on the cost of pollution control.
This assumption was made at the outset of this study and has largely been borne
out by the results of the analysis, since there is minimal impact from the proposed best
practicable technology, and it is similarly minimal if municipal treatment is used instead of
activated carbon following secondary biological treatment technology for the proposed best
available technology and new source performance standards.
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b. Methodology. This study is divided into two parts. The first part produces a
profile of the five categories studied based upon published information, in-house informa-
tion, and other readily available sources. The contractor has profiled the category in terms
of the number of mills, size distribution, type of product, financial status, type of plant,
geographic distribution, and sector segments to be affected by the guidelines.
The second half of the study discusses the economic impact that the proposed
effluent guidelines may have upon the five categories and is presented in the form of a
scenario. For each of the categories studied, personal interviews with operating mills were
made and used in conjunction with telephone interviews with operating mills and other
industry sources. The contractor also relied on his textile industry specialists to provide
direct input into the scenarios.
Each scenario describes the categories in some detail and presents a composite of
a mill believed to be representative of mills within each category. Composites of a small mill
with under 20 employees, and both small and medium size mills are presented for each
category, with the exception of wool scouring in which there are only two size classifica-
tions. A wide range of sizes (3) was not found in the wool scouring sector, as found within
the other categories. The dimensions of each composite mill are presented in terms of
annual sales, profit, depreciation expense, cash flow, production, waste loads, water usage,
and similarly related dimensions.
The composite mill is then used as the basis for calculating annual operating costs
and investments necessary for pollution control within each category and mill size. For
example, the waste load and water usage estimated for each composite mill is applied to the
methodology of Appendix A to determine the operating costs and investment for each level
of treatment.
To measure the impact in terms of mill closings, we have assumed a mill will close
only if the annual cost of treatment exceeds the annual cash flow of the mill.
The estimated range of cash flows has been compared to the annual operating
cost, and we assumed no mill would close if the minimum annual cash flow exceeded the
estimated incremental annual operating costs of effluent treatment. In those cases where the
annual operating costs of treatment exceeded the minimum estimated cash flow but did not
exceed the maximum cash flow, we estimated the number of plant closings as a percentage
proportional to the linear relationship between the operating cost and the cash flow. For
example, if the cash flow ranged between $0 and $1000 and the annual operating costs were
$250, then 25% of the mills operating in this category and size classification would be
expected to close.
Other impacts on employment and production are derived directly from the
estimated number of mill closings. Tangential impacts, such as those relating to community
pricing, financial and foreign trade, are treated for the most part independently.
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The impact on a specific mill and/or on a group of mills that form a slightly
different composite can be estimated with material presented in the appendix of this study.
This material permits estimates of the initial investment and annual operating costs for
pollution control. The cash flow criterion for a mill closing or other criteria, such as
profitability or rate of return on invested assets, can then be applied.
c. Costs. The costs of alternate waste treatment methods to meet the guidelines
have been calculated on the basis of initial capital investment and annual operating costs for
each of the composite mills. The basis for these calculations are described in detail in
Appendix A, and the results of this analysis are presented in Table 1-1.
Costs for best practicable technology waste treatment have been calculated on the
assumption that extended biological treatment will enable a mill to meet the guidelines for
BOD, COD, and color.
Best practicable technology (BPT) for the textile industry, as specified by the
EPA, includes pretreatment of wastes (screening and 8-hour holdup) and subsequent
municipal treatment, or alternatively, self-treatment by preliminary screening, primary
settling (wool scouring only), coagulation (carpet mills only), secondary biological treat-
ment by extended aeration and stabilization ponds, and chlorination.
Best available technology (BAT) for the textile industry, as specified by the EPA,
includes the preliminary screening, primary settling (wool scouring only), coagulation
(carpet mills only), secondary biological treatment by extended aeration and stabilization
ponds, and chlorination listed under Best Practicable Control Technology. In addition, it
includes advanced treatment techniques, such as multimedia filtration and/or activated
carbon adsorption following biological treatment. Small plants with less than 20 employees
have not had COD limits set so only a multimedia filter is required for them to meet BAT
requirements.
d. Financial Profiles. Financial profiles for each category were derived from field
interviews, contractors' in-house knowledge, and other industry sources. The profiles repre-
sent commission houses, with the exception of the very small raw wool scouring and wool
dyeing and finishing. A summary of pertinent financial data drawn from each composite
mill representation of its category and size classification is presented in Table 1-2.
e. Impacts. The impact of the guidelines on prices, plant closings, unemployment,
communities, international trade, and other areas has been estimated for each of the five
categories. A summary of these findings is given below.
(1) Prices. In general, industry sources state that any added costs cannot be
readily passed on to the mills' customers since the mills affected are the smaller, indepen-
dent companies which work in the aftermarket of small lots for fill-in needs of the
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customers. Their price structure is determined by the larger corporations which do the
volume production. The smaller firms may charge a small premium of 5% or so on the going
rate, but if much more than that is charged, the larger mills will undertake the work. The
larger companies have already accomplished much of the expenditures necessary to meet the
best practicable treatment guidelines and, presumably, their present prices reflect this and
other factors such as overseas competitive effects. Specific category comments follow.
Wool scouring is a special case. The wool market has been depressed for
some time and mills have been closing with fair regularity, resulting in a highly competitive
situation that precludes higher pricing.
Broad wovens may be able to pass on a good share of the costs in the case of
the best practicable treatment since the market there is strong. Knits cannot do so now, but
within six months or so the knit market is expected to firm up at which time it may be able
to pass on most treatment costs. Stock and yarn dyeing mills also share a reasonably strong
market at present and may be able to pass on at least a portion of the treatment costs.
Table 1-3 provides a summary of the base price currently charged for
processing, and the incremental price increase that would result for the various treatment
costs, if these costs could be passed on, assuming no mark-up by the mill.
(2) Plant Closings and Unemployment. Table 1-4 summarizes the impact on mill
closings and unemployment projected for the five categories considered in this study. In
each case, the impact is considered as if all mills in that category had to treat their wastes in
the manner described, such as in the municipal treatment, where we have assumed that all
mills must connect to municipal treatment plants, and we have calculated the percentage
that can or cannot afford to do so by the cash flow criterion. The table shows that the
greatest relative effects will be in the wool categories, which is already a distressed industry.
The greatest effect on groupings appears to be on small mills having to meet best available
self treatment.
(3) Community Impacts. A large percentage of the small and medium sized
independent mills are located in small communities where the mills hold a significant
position. They often account for up to 5% of the town's direct employment, and sometimes
as much as 30%. Hence, although the impact may be small in light of the total industry,
local impacts will be significant.
(4) International Trade. In terms of international trade, the impact of the
guidelines on the industry appears to be of little consequence. If, in fact, the guidelines
produced a much greater effect than predicted in this study, imports would be further
encouraged since the smaller, independent mills provide the fast turnaround on small lots
that neither the large domestic mills nor the overseas mills can provide.
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TABLE 1-3
PRICE IMPACT SUMMARY
1
Wool Scouring
Very Small Small/Medium
Wool Dyeing and Finishing
Very Small Small Medium
Base Price ($/pound of product)
Incremental Price for:
Municipal Treatment
BPT, Self-Treatment
BAT, Self-Treatment
.13
.0018
.0041
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1.73
.0020
.0038
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$1.43
.0113 .0093
.0151 .0083
.0958 .0548
Base Price ($/pound of product)
Incremental Price for:
Municipal Treatment
BPT, Self-Treatment
BAT, Self-Treatment
Woven Goods Knit Goods
Dyeing and Finishing Dyeing and Finishing
Very Small Small Medium Very Small Small Medium
0.37-0.70 0.53
.0231 .0147 .0102 .0165 .0118 .0095
.0404 .0151 .00545 .0171 .0099 .0054
.0522 .0964 .0330 .0243 .0578 .0323
Stock and Yarn Dyeing
Very Small Small Medium
Base Price ($/pound of product) 0.54
Incremental Price for:
Municipal Treatment .0183 .0131 .0113
BPT, Self-Treatment .0194 .0122 .0080
BAT, Self-Treatment .0303 .0767 .0504
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f. Study Limitations. This study was undertaken to permit an initial estimate of the
economic impact that the proposed effluent guidelines would have upon certain sub-
categories of the textile industry. The contractor was placed under severe calendar time and
budgetary constraints which have tended to limit the accuracy of the analysis. The contract
required the contractor to prepare a scenario or word picture of the impact that the
proposed effluent guidelines would have upon the textile industry. This means that the
analysis was more judgmental than analytical, when compared with the economic analyses
of other industries. It is not that the EPA has not made available the same resources for the
study of the textile industry as it has for other industries, but rather that the major
economic impact that will occur within the textile industry will occur to companies which
are generally small, privately held, and are very reticent and, in many cases, actually refused
to reveal details of their financial profitability and expected impact of the effluent
guidelines on their businesses. Responsible and knowledgeable people have been contacted
and the contractor discussed the composite mill for each sub-category and size classification
and these persons believe that the composites are representative of their category and size
classification. On that basis the study is presented as an initial view of the impact that the
proposed effluent guidelines will have upon this industry.
Follow-on studies, should they be required, can build upon the methodology used
in this study to improve the understanding of the impact that the guidelines will have upon
this industry. For example, the number of interviews conducted could be increased to a
point that forms a statistically valid sample of the industry in each category. It is anticipated
that the statistical sample will be developed on the basis of personal interviews and the
balance of the industry could be conducted by means of mail questionnaires sent to
companies listed in Davidson's Blue Book or similar directories.
-------
2. INDUSTRY PROFILES
This chapter presents a profile of the five sectors of the textile industry considered in
this study. Based in part on the Annual Survey of Manufacturers, a Department of
Commerce publication, each profile presents a table illustrating the size distribution of mills
according to number of employees, as defined by the Annual Survey, followed by a similar
table listing the number of mills and size distributions expected to be impacted, and the
rationale employed to identify them.
The discussion on size distribution is followed in each case by the types of plants
considered, their geographic distribution, the type of product segments of the sector
which will be affected by the requirements to meet the guidelines, and a brief financial
profile.
a. Wool Finishing.
(1) U.S. Wool Industry - General
(a) U.S. Fiber Consumption. The consumption of wool declined drastically
between 1960 and 1972. Table 2-1 illustrates a fiber consumption of 411 million pounds in
1960 declining to 219 million pounds in 1972.
TABLE 2-1
TOTAL FIBER CONSUMPTION
(millions of pounds)
Year Cotton Man-made Fiber Wool
1960 4,191.0 1,874.7 411.1
1965 4,477.4 3,614.1 387.0
1970 3,815.6 5,501.3 240.3
1972 3,841.3 7,588.0 219.2
Source: Dept. of Agriculture Textile Organon
(b) Looms in Place. To ascertain woolen and worsted productive capacity,
we analyzed the number of looms producing fabric that were in place between 1965 and
1972. Table 2-2 illustrates that in 1965 approximately 7000 looms were engaged in the
manufacture of woolen and worsted fabrics, declining to an estimated 3000 looms in 1972.
11
-------
TABLE 2-2
WOOLEN AND WORSTED LOOMS IN PLACE
Vear |\|0. of Looms
1965 6,967
1970 3,735
1972 2,881
Source: Dept. of Commerce, Bureau of
the Census, 1967
(c) Index of Industrial Production. Table 2-3 illustrates the index of indus-
trial production between 1960 and 1972, where total textile mill products rose from 100 in
1967 to 114 in 1972. Wool fabrics, on the other hand, declined from a total of 100 in 1967
to 44 in 1972.
TABLE 2-3
INDEX OF INDUSTRIAL PRODUCTION
Annual Averages
1967 1970 1971 1972
Total index 100.0 106.6 106.8 114.4
All manufacturing 100.0 105.2 105.2 113.1
Textile mill products 100.0 106.3 108.6 114.5
Cotton fabrics 100.0 87.4 90.7 86.5
Man-made fabrics 100.0 125.6 118.9 133.4
Wool fabrics 100.0 72.5 47.5 44.3
Knit goods 100.0 130.5 134.3 147.7
Fabric finishing 100.0 90.1 89.1 92.1
Carpeting 100.0 129.3 148.0 164.1
Yarn & misc. textiles 100.0 96.6 103.3 107.3
Source: U.S. Federal Reserve System
(2) Wool Scouring.
(a) General. According to the 1967 Census of Manufactures, 68 establish-
ments were engaged in wool scouring and/or worsted combing. Table 2-4 illustrates the
relative position of wool scouring and combing plants between 1958 and 1970 during which
period employment dropped sharply from 6,000 to 3,900.
12
-------
TABLE 2-4
WOOL SCOURING AND COMBING PLANTS
INDUSTRY GROWTH 1958-1970
1970
1958
No. Employees
No. Payroll
(000) ($MM)
3.9 23.9
6.1 22.7
Value
Added
($MM)
27.4
36.1
Cost of
Materials
($MM)
30.2
48.5
Value of
Shipments
($MM)
62.5
87.6
Capital
Expenditures
($MM)
2.4
1.3
Source: Annual Survey of Manufacturers
Value of shipments declined from a high of $87 million in 1958 to $62
million in 1970. Capital expenditures on the other hand, increased from 1.3 million in 1958
to $2.4 million in 1970. This relates directly to the fact that worsted-type fabrics have been
declining in the United States between 1958 and 1970, and the increased capital investment
is a reflection of modernization of those plants that have not gone out of business.
(b) Size Distribution. Table 2-5 illustrates that of a total of 68 wool
scouring plants, only one employed 1000 people or more. Eleven plants employed 100 to
500 people, and the remaining 56 employed less than 100 people. We estimate, however,
that between 1967 and 1972 the number of establishments declined drastically. Of 68
establishments in operation in 1967, we estimate that in 1973 the following 16 establish-
ments were in business:
Amos Abbott Corp., Dexter, Maine
Hart Wool Combing Inc., Holyoke, Mass.
Barre Wool Combing Co., N. Barre, Mass. - Large
Hudson Combing Co., Inc., Hudson, Mass.
Gilet Wool Scouring Corp., North Chelmsford, Mass.
Southwell Combing Co., North Chelmsford, Mass.
Caron International, Rochelle, 111.
Santee River Wool Combing Co., Inc., Jamestown, S.C. — Large
Roddie Wool Scouring Co., Brady, Texas
Bollman Industries, San Marcos, Texas
San Angelo Wool Processing Co., San Angelo, Texas
Associated Wool Processors of Texas, Inc., Del Rio, Texas
Burlington Industries, Clarksville, Va. — Large
Burlington Industries, Lees Carpets Div.; Glasgow, Va. - Large
J.P. Stevens Inc., Allendale, S.C. - Large
Columbia Wool Scouring Mills, Portland, Oregon
Wellman Industries of Johnsonville, S.C., has recently decided to withdraw
from this industry.
13
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We estimate that three of the above mills fall into the "less than 20
employees" category, and that nine are in the "medium" classification. Refer to Table 2-6
for a comparison of the Census figures with the distribution chosen for use in this study.
TABLE 2-5
WOOL SCOURING AND COMBING - SIZE DISTRIBUTION
Total establishments
Establishments with an
average of:
No. of
Establishments
68
No. of
Employees
(OOO's)
5.0
1 to
5 to
10 to
20 to
50 to
100 to
250 to
,000 to
4 employees
9 employees
19 employees
49 employees
99 employees
249 employees
499 employees
2,499 employees
14
5
10
21
6
7
4
1
.1
.7
.4
1.0
2.7
Source: Census of Manufactures, 1967
TABLE 2-6
CATEGORY 1 - RAW WOOL SCOURING MILLS
(No. Mills)
3
9
_
12
Census
Size
Division
(No. Employees)
0- 19
20- 49
50- 99
100-249
250-499
Unadjusted
Census
(No. Mills)
29
21
6
7
4
&7
Adjusted*
Census
(No. Mills)
3
5
1
2
1
12
Study
Size
Division
Extra Small
Small
Medium
*Mills remaining in business, excluding large plants.
14
-------
(c) Types of Plants. The 16 plants still active in wool scouring have
equipment and technology that is adequate when compared with competing enterprises in
Europe and Japan.
(d) Geographic Distribution. Table 2-7 gives the 1967 geographic distribu-
tion of wool scouring and combing plants and shows that of a total of 68 the majority - 52
plants— was located in the northeastern region, 12 were located in the southern
regions, and 4 (not listed) were located elsewhere. Many scouring plants in the northeastern
region have shut down since the 1967 Census, shifting the distribution to about equal for
the northeastern, south Atlantic, and west south central regions.
TABLE 2-7
WOOL SCOURING AND COMBING PLANTS - GEOGRAPHIC DISTRIBUTION*
No. of Establishments No. of Employees
(OOO's)
United States 68 5.0
Northeastern Region 52 —
New England Division 35 2.6
Massachusetts 20 1.8
Rhode Island 10 .7
Middle Atlantic Division 17 —
New York 5 _
Pennsylvania 10 4
Southern Region 12 1.5
South Atlantic Division 6 1.3
South Carolina 4 _
West South Central Division 6 -2
Texas 6 .2
Source: Census of Manufactures, 1967
*The subtotals do not add up to totals in all cases, since all geographic areas
have not necessarily been included.
(e) Types of Products. The plants listed in this, section are engaged in the
purchase of raw wool from various parts of the world which, in turn, is scoured, carbonized,
combed, and converted into top. The tops are then sold to customers who are engaged in
spinning and weaving operations. They, in turn, convert them into yarn.
(f) Segments to be Affected. We believe that the majority of the 16 plants
currently in operation has already taken steps to abide by governmental regulations. The
large mills will probably stay in business since they are top mills which operate an integrated
facility, buying the wool, scouring it, and converting it into top. Their margins are adequate
to warrant taking significant steps for pollution control.
The very small and small/medium mill groups often do commission
scouring and, consequently, are vulnerable to impact from the guidelines.
15
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(g) Financial Profile. Financial data are not available from independent
manufacturers. All larger manufacturers are, in turn, a part of larger integrated textile mills,
such as Burlington and J.P. Stevens. Financial data available from these firms do not permit
separation of the wool scouring operations from the balance of companies' operations.
(3) Weaving and Finishing of Wool Fabrics.
(a) General. No official breakdown exists to segregate wool fabric finishers
from weaving mills engaged in the manufacture of woolen fabrics. Therefore, all data
pertaining to this segment take into account:
(1) integrated establishments having wool weaving, dyeing, and
finishing;
(2) wool commission finishers; and
(3) wool weavers.
According to the Census of Manufactures, some 310 mills were engaged
in the manufacture of woolen and worsted woven fabrics, including dyeing and finishing, in
1967. Table 2-8 illustrates the relative position of woolen and worsted weaving and finishing
plants between 1958 and 1970, during which period employment dropped sharply from
56,000 to 32,000. The value of shipments declined from $929 million in 1958 to $770
million in 1970. This relates directly to the fact that woolen fabrics have been declining in
the United States between 1958 and 1970.
TABLE 2-8
WEAVING AND FINISHING WOOL FABRICS
INDUSTRY GROWTH 1958-1970
1970
1958
No. Employees
No. Payroll
(000) ($MM)
32.4 187.6
56.0 206.1
Value
Added
($MM)
310.6
336.6
Cost of
Materials
($MM)
443.9
576.6
•Value of
Shipments
(SMM)
770.4
929.0
Capital
Expenditures
(SMM)
24.7
9.7
Source: Annual Survey of Manufacturers, Dept. of Commerce, 1967
Capital expenditures, on the other hand, increased from $9.7 million in
1958 to $24 million in 1970, and increased capital investment is reflected in modernization
of establishments that have not gone out of business.
16
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(b) Size Distribution. Table 2-9 illustrates that in 1967 only three or four
of a total of 310 mills employed 1000 or more people, and that small plants accounted for
the major portion of the inudstry, with 157 plants employing less than 50 people, and 95
plants employing from 100 to 500 people. Refer to Table 2-10 for a comparison of the
Census figures with those chosen for this study.
TABLE 2-9
WEAVING AND FINISHING WOOL FABRICS - SIZE DISTRIBUTION
Total establishments
Establishments with an
average of:
1 to
5 to
10 to
20 to
50 to
TOO to
250 to
500 to
4 employees
9 employees
19 employees
49 employees
99 employees
249 employees
499 employees
999 employees
1,000 to 2,499 employees
Source: 1967 Census of Manufactures
No. of
Establishments
310
54
17
22
64
41
60
35
14
3
No. of
Employees
(OOO's)
41.8
.1
.1
.3
2.0
2.9
10.3
12.2
13.9
Study
Size
Division
Extra Small
Small
Medium
TABLE 2-10
CATEGORY 2 - WOOL FINISHING MILLS
Census
Size
Division
(No. Mills) (No. Employees)
23
33
20
76
Unadjusted
Census
(No. Mills)
(93)
(64)
(41)
(60)
(35)
Adjusted*
Census
(No. Mills)
23
17
11
16
9
76
'Mills remaining in business and having wet processing operations.
17
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(c) Types of Plants. With the exception of four to six of the largest
manufacturers, equipment for both weaving and finishing proved to be outmoded, and the
level of technology was below average compared to competing European and Japanese mills.
(d) Geographic Distribution. Table 2-11 gives the geographic distribution of
wool weaving and finishing mills in 1967 and shows that, of the total 310 mills, the
northeast region accounted for two-thirds of the industry. In the north central region there
were 22 establishments, 52 in the southern region, and 20 in the western region.
(e) Types of Products. The wool fabric industry basically produces two
types of products:
(1) Worsted fabrics, the raw material of which is wool top. This is
woven into medium- and light-weight fabrics; and is mostly used
in men's tailored clothing, including slacks. Fabrics are 100% wool
or of a blend of wool and polyester.
(2) Woolen-type fabrics that are composed of medium-weight and
heavy fabrics and are utilized in both men's and women's sports-
wear. These fabrics are made of 100% wool or blends of various
fibers with wool.
Because the raw materials of wool have doubled in price and the supply
has been curtailed over the past 18 months, very few mills in the United States classified under
this segment are engaged in the manufacture of 100% wool content fabric. In most cases,
both in worsted- and woolen-type fabrics, blends of wool with other fibers are being
manufactured.
(f) Segments to be Affected. Of the 310 establishments accounted for in
the 1967 Census of Manufactures, we estimate about 150 of these went out of business
between 1967 and 1972. Of the remaining mills, eight of the largest establishments, which
have integrated weaving, dyeing, and finishing facilities, and account for 70% of the total
fabric output, and of the remaining 152 mills, we estimate that 50%, or 76 of the mills, have
their own dyeing and finishing facilities, and hence will be exposed to impact by the
guidelines. Because of the small size, we believe this segment will be significantly impacted
due to:
(1) relatively weak financial structure in a declining market, and
(2) inability to engage in major capital investment.
(g) Financial Profile. No pertinent information is available on mills exclu-
sively engaged in woolen weaving, dyeing, and finishing, since the major factors in this
business are divisions of large diversified textile companies, where the wool portion is only a
small percentage of the total volume.
18
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TABLE 2-11
WOOL WEAVING AND FINISHING Ml LLS - GEOGRAPHIC DISTRIBUTION*
No. of Establishments No. of Employees
(OOO's)
United States 310 41.8
Northeastern Region 216 22.2
New England Division 127 16.3
Maine 18 4.0
New Hampshire 16 3.6
Vermont 7 .4
Massachusetts 41 4.8
Rhode Island 36 2.2
Connecticut 9 1.1
Middle Atlantic Division 89 5.9
New York 39 3.2
New Jersey 10 .6
Pennsylvania 40 2.1
North Central Region 22 1.3
East North Central Division 12 .9
Ohio 5 2.5-5.0
Illinois 3 -
Wisconsin 2 -
West North Central Division 10 .5
Minnesota 6 -
Missouri 3 .2
South Region 52 17.2
South Atlantic Division 43 15.0
Maryland 3 1.0
Virginia 10 2.5
West Virginia 1 -5
North Carolina 6 4.0
South Carolina 11 2.5
Georgia 11 2.5
EastSouth Central Division 7 1.0-2.5
Tennessee 2 1.0
Alabama 2 1.0
West South Central Division 2 -
Texas 2
West Region 20 1.1
Pacific Division 18 1.0-2.5
Washington 1 .5
Oregon 8 .5
California 9 .2
Source: Census of Manufactures, 1967
*The subtotals do not add up to totals, in all cases, since all geographic areas are not
necessarily included.
19
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b. Woven Fabrics - Dyeing and Finishing.
(1) General. According to the Census of Manufactures, during 1967 a total of
449 establishments were engaged in the dyeing and finishing of synthetic and cotton woven
goods. Table 2-12 illustrates the relative position of cotton finishing plants and synthetic
finishing plants between 1958 and 1970. During that period there was a drastic reduction of
employment. In cotton finishing plants, an employment level of 49,000 in 1958 declined to
29,000 in 1970. Employment in synthetic finishing plants rose from 16,000 in 1958 to
34,000 in 1970. This trend directly reflects a shift in U.S. mill fiber consumption between
1958 and 1970. Other indicators, such as value added and value of shipments, also reflect
this trend.
(2) Size Distribution. Table 2-13 illustrates size breakdown of various plants by
number of employees and illustrates the following:
Cotton Finishing: Cotton finishing is a highly fragmented industry where
small plants (50 employees and under) accounted for more than half the
establishments, or 122.
Synthetic Finishing: In synthetic finishing, there is a similar pattern, where
plants with up to 50 employees accounted for 50% of all establishments, or
115.
Refer to Table 2-14 for a comparison of the Census figures with those
chosen as a basis for this study.
TABLE 2-12
WOVEN FABRICS
DYEING AND FINISHING
No.
Employees Payroll
(OOO's) ($MM)
Value Cost of Value of Capital
Added Materials Shipments Expenditures Total
($MM) ($MM) ($MM) ($MM) Plants
Cotton finishing plants: ratio of concentration, 1967: 4 large, 42%; 8 large, 59%
1958
1970
49.2
28.9
189.9
180.1
289.1
252.7
3S9.1
304.2
686.2
603.0
15.7
22.9
Synthetics finishing plants: ratio of concentration, 1967: 4 large, 37%; 8 large, 49%
1958
1970
16.2
33.8
74.3
220.4
114.8
429.0
95.3
608.9
210.7
1,011.6
3.6
29.3
216
233
Source: Annual Survey of Manufacturers, 1970
20
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TABLE 2-13
WOVEN FABRICS
(Dyeing and Finishing Establishments)
1967
Number of Number of
Establishments Employees
(OOO's)
Finishing plants — cotton:
Total establishments 216 35.7
Establishments with an
average of employees:
1to4 42 0.1
5 to 9 13 0.1
10 to 19 25 0.4
20 to 49 42 1.4
50 to 99 29 2.0
100 to 249 26 4.6
250 to 499 15 5.6
500 to 999 21 21.6
1,000 to 2,499 1 -
2,500 or more 2 -
Finishing plants - synthetics:
Total establishments 233 25.7
Establishments with an
average of employees:
1to4 21 -
5 to 9 14 0.1
10 to 19 31 0.5
20 to 49 49 1.7
50 to 99 47 3.5
100 to 249 44 7.1
250 to 499 17 5.8
500 to 999 9 7.0
1,000 to 2,499 1
2,500 or more - -
Source: Census of Manufactures, 1967
21
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TABLE 2-14
CATEGORY 4 - WOVEN FABRICS, DYEING, AND FINISHING
Study
Size
Division
Extra Small
Small
Medium
(No. Mills)
146
167
102
415
Census
Size
Division
(No. Employees)
0- 19
20- 49
50- 99
100-249
250-499
Unadjusted
Census
(No. Mills)
(146)
( 91)
( 76)
( 70)
( 32)
Adjusted
Census
(No. Mills)
146
91
76
70
32
415
(3) Type of Plants. Types of plants vary greatly, depending on the size, and the
types of products they process, since the industry is engaged in bleaching, printing, dyeing,
and finishing. The smaller plants with no more than 50 employees, in most cases, have old
equipment that has not been modernized due to lack of capital resources. The larger plants,
both independent and those that are part of weaving complexes, are modern and efficient.
(4) Geographic Distribution. Tables 2-15 and 2-16 illustrate the geographic dis-
tribution of the industry. In cotton finishing plants the northeastern region accounted for
the majority of establishments, mostly composed of the 125 out of 216 establishments. In
the southern region, where most of the large integrated establishments are located, there are
67 establishments. The synthetic finishing plants show a similar pattern, where the north-
eastern region represents over 50%, or 177 plants, and the southern region 46 plants of a
total 233.
(5) Level of Integration. Figure 2-1 is a schematic layout illustrating the level of
integration of cotton and synthetics finishing establishments. There are basically two types
of establishments:
(a) Those owned by large weaving mills: These are separate dyeing and
finishing companies owned by large textile corporations, such as Bur-
lington, Stevens, and Deering Milliken, which might within a single
corporate complex own up to four finishing plants. We estimate that
out of a total of 450 establishments between 100 and 130 are inte-
grated. However, value of shipments of these establishments accounted
for an estimated 50 to 60% of the total dyeing and finishing industry.
22
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TABLE 2-15
WOVEN FABRICS - COTTON DYEING AND FINISHING
(Geographic Distribution)
With 20 or
No. of Establishments More Employees
Finishing Plants - Cotton:
United States 216 136
Northeastern Regin 125 70
New England Division 37 27
New Hampshire 2 2
Massachusetts 15 11
Rhode Island 15 9
Connecticut 5 5
Middle Atlantic Division 88 43
New York 44 19
New Jersey 25 16
Pennsylvania 19 8
North Central Region 18 6
East North Central Division 14 4
Illinois 9 3
Southern Region 67 59
South Atlantic Division 54 49
Delaware 1 1
Maryland 3 3
Virginia 2 2
North Carolina 18 .18
South Carolina 17 17
Georgia 10 6
East South Central Division 8 7
Tennessee 3 2
Alabama 3 3
West South Central Division 5 3
Arkansas 1 1
Oklahoma 1 1
Sources: Census of Manufactures, 1967, ADL estimates and industry listings.
(b) Commission dyers and finishers: We estimate that 320 to 350 of a total
of 449 are independent commission dyers and finishers without corpo-
rate relationship to weaving mills. Their sole function is to commission-
finish woven goods, supplying such services as bleaching, dyeing, print-
ing, and finishing.
23
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TABLE 2-16
WOVEN FABRICS - SYNTHETIC DYEING AND FINISHING*
(Geographic Distribution)
With 20 or
No. of Establishments More Employees
Finishing Plants - Synthetics:
United States 233 167
Northeastern Region 177 124
New England Division 43 35
New Hampshire 1 1
Massachusetts 20 16
Rhode Island 9 8
Connecticut 13 10
Middle Atlantic Division 134 89
New York 58 28
New Jersey 67 54
Pennsylvania 9 7
Southern Region 46 39
South Atlantic Division 45 38
Virginia 5 5
North Carolina 24 21
South Carolina 10 9
Georgia 2 1
East South Central Division 1 1
Tennessee 1 1
West Region 6 2
Pacific Division 5 2
California 5 2
Sources: Census of Manufactures, 1967, ADL estimates and industry listings.
*The subtotals do not add up to totals, in all cases, since all geographical areas are not
necessarily included.
(6) Types of Products. Both the synthetic and cotton fabric finishing industries
are engaged in processing the following products:
— Bleaching operation — the major volume is household domestics, in-
cluding sheets and pillowcases;
— Dyeing, plain colors — a conversion of greige woven goods into dyed
fabric for both apparel and household products;
— Printing - a conversion of woven greige goods into printed fabrics; and
- Special finishing - includes all processes after dyeing to impart special
effects to fabrics, such as heat setting, water repellency, or other
finishes.
24
-------
Cotton Weaving
380 Establishments
Synthetics Weaving
400 Establishments
Integrated
Weaving, Finishing, and
Dyeing
100- 130
Establishments
Total
449
Establishments
Commission
Dyers and Finishers
320 - 350*
Establishments
Bleach
Dye
Print
Finish
"Vulnerability -320-350 Establishments
Source: ADL Estimates
FIGURE 2-1 DYEING AND FINISHING - WOVEN COTTON AND SYNTHETICS
25
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(7) Segments to be Affected.
(a) Integrated Weaving-Finishing. We feel that these plants, which are
integrated with weaving and finishing operations, will not be affected due to their substan-
tial size and their ability to make the necessary capital investment to abide by government
rules, and their ability to pass on the increased cost to the apparel manufacturer and the
consumer.
(b) Independent Commission Dyers and Finishers. We believe that this
segment will be significantly impacted because over 50% of the establishments are small and
fragmented, with weak financial structure, and thus would be unable to make a major
capital investment. The larger units in this segment, however, would be able to do so.
In all cases, we anticipate that the independent commission dyers and
finishers will be able to pass the cost on to their customers, if they can raise the capital required.
(8) Financial Structure. No published financial structure for independent
dyeing and finishing establishments is available. We have therefore included financial data
relating to large textile companies which own facilities for dyeing and finishing their own
fabrics, or provide commission dyeing and finishing services (Table 2-17).
c. Knitted Fabric - Dyeing and Finishing.
(1) General. Census figures are available for mills that perform dyeing and
finishing only (commission dyers) and for total knit mills which include both "knitting
only," as well as commission finishers, and integrated establishments that have both knitting
and dyeing and finishing. We have therefore estimated the breakdown between integrated
finishing mills and those mills that do knitting only.
According to the Census of Manufactures 1967, some 541 mills were
engaged in the manufacture of knitted fabrics, including dyeing and finishing.
Table 2-18 illustrates the relative position of the industry between 1958 and
1970. Employment rose sharply from 18,000 in 1958 to 48,000 in 1970. A similar
relationship is reflected in the value of shipments and capital expenditures. This relates
directly to the fact that knitted fabrics have been the fastest growing segment of the textile
industry in the United States between 1958 and 1970.
(2) Size Distribution. Table 2-19 illustrates the size distribution of knit fabric
mills and also illustrates the nature of the industry, which is highly fragmented with small
plants being the dominant factor. Plants with under 50 employees per establishment
accounted for a total of 371 establishments out of 541.
Refer to Table 2-20 for a comparison of these Census figures with those
chosen for this analysis.
26
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TABLE 2-18
DYEING AND FINISHING - KNITTED FABRICS
INDUSTRY GROWTH 1958-1970
1970
1958
No. Employees
No. Payroll
(000) (SMM)
48.2 296.2
18.4 73.9
Value
Added
(SMM)
648.5
147.4
Cost of
Materials
(SMM)
1,235.9
336.1
Value of
Shipments
(SMM)
1,881.8
487.2
Capital
Expenditures
(SMM)
85.3
7.1
Source: Annual Survey of Manufacturers, Dept. of Commerce
TABLE 2-19
KNITTED FABRICS MANUFACTURERS - DYEING AND FINISHING
(Size Distribution)
Total establishments
Establishments with an
average of
1 to
5 to
10 to
20 to
50 to
100 to
250 to
500 to
4 employees
9 employees
19 employees
49 employees
99 employees
249 employees
499 employees
999 employees
1,000 to 2,499 employees
Source: 1967 Census of Manufactures
No. of
Establishments
541
95
59
93
124
63
75
23
8
1
No. of
Employees
(OOO's)
36.3
.2
.4
1.3
4.0
4.6
11.7
7.7
6.4
28
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TABLE 2-20
CATEGORY 5 - KNIT FABRIC, DYEING, AND FINISHING
Census Size
Division
(No. Mills) (No. Employees)
Extra Small 50 0-19
Small
Medium
25
15
90
20-49
50-99
Censust
(No. Mills)
(247)
(124)
( 63)
Adjusted
Census"
(No. Mills)
50
25
15
90
tTotal mills, including knit only and dry finish.
*Mills dyeing and finishing only.
(3) Types of Plants. The knitted fabric industry emerged in the United States in
1960. Therefore, most equipment on hand is relatively new. The age of plants in most cases
varies from 15 to 5 years.
The level of technology is good and efficiency is excellent in the larger mills,
and below average in the small and fragmented ones.
(4) Geographic Distribution. Table 2-21 shows the geographic distribution of
the knitting industry with the northeastern region accounting for 398, or 74% of the mills,
mostly in the Middle Atlantic section, with employment of 21,000. In the South there are
124 plants, mostly the large integrated mills, employing 14,000.
Table 2-22 gives the geographic distribution of mills engaged in dyeing and
finishing in 1967. Of the total there were only 80 establishments, 63% of which were
located in the Northeast, mostly the Middle Atlantic section, where there were 44 plants.
The southern region accounts for 22 establishments, or 28% of the total. The current
estimate of the number of mills is 90, and the geographic distribution has not changed
significantly.
(5) Level of Integration. Figure 2-2 illustrates the level of integration in the
knitted fabric industry, which can be divided into the following segments:
(a) Knitting mills engaged primarily in knitting and dry finishing (only
320-330 establishments). They purchase dyed yarn from outside
sources and it is knitted on premises and dry-finished, or they purchase
greige yarn that they knit on their own premises and have it commis-
sion dyed and finished by outside sources.
29
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TABLE 2-21
GEOGRAPHIC DISTRIBUTION OF KNITTED FABRIC MANUFACTURERS
INCLUDING DYEING AND FINISHING*
No. of Establishments No. of Employees
(OOO's)
United States 541 36.3
Northeastern Region 398 21.2
New England Division 43 6.0
Massachusetts 17 3.7
Rhode Island 12 1.0-2.5 est.
Connecticut 11 -4
Middle Atlantic Division 355 15.1
New York 233 6.8
New Jersey 60 2.8
Pennsylvania 72 5.6
North Central Region 12 .6
East North Central Division 7 .5-1.0est.
Wisconsin 7 .5-1.0est.
Southern Region 124 14.3
South Atlantic Division 113 12.3
Virginia 6 1.0
North Carolina 86 9.0
South Carolina 14 1.7
Georgia 5 .5~1.0est.
East South Central Division 11 2.0
Tennessee 5 1.0-2.5 est.
Alabama 4 .4
Western Region 7 .2
Pacific Division 7 .2
California 7 .2
Sources: 1967 Census of Manufactures, ADL estimates and industry listings.
*The subtotals do not add up to totals, in all cases, since all geographic areas are
not necessarily included.
(b) Integrated knitting mills (120 establishments). These are the large
knitwear producers of both warp and circular knit fabrics which, in
addition to knitting, have yarn-dyeing facilities and piece-dyeing
facilities. In most cases these mills dye and finish their total fabric
requirements. In some cases, they also act as commission dyers and
finishers for other parties.
(c) Knit goods fabric commission dyers and finishers (60-90 establish-
ments). These are firms which predominantly work on a commission
basis, performing a service for knitting mills that do not have their own
dyeing and finishing facilities.
30
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TABLE 2-22
GEOGRAPHIC DISTRIBUTION OF KNITTED
FABRIC DYERS AND FINISHERS ONLY*
No. of Establishments
United States 80
Northeastern Region 50
New England Division 6
Massachusetts 3
Rhode Island 1
Connecticut 1
Vermont 1
Middle Atlantic Division 44
New York 24
New Jersey 12
Pennsylvania 8
Southern Region 22
South Atlantic Division 14
Virginia 2
North Carolina 10
South Carolina 2
East South Central Division 2
Tennessee 1
Florida 1
Unaccounted for 8
Sources: Census of Manufactures 1967, ADL estimates and industry
listings.
*The subtotals do not add up to totals, in all cases, since all geographic areas
are not necessarily included.
(6) Type of Products. The knitted fabric industry basically produces three types
of products:
(a) Warp knit fabrics, both yarn and piece-dyed, composed of tricot and
raschel types that predominantly utilize three raw materials -filament
acetate, and filament polyester. Sixteen of the largest mills accounted
for 60% of the total productive capacity.
(b) Double-knit fabrics, both yarn and piece dyed, which utilize predomi-
nantly polyester filament yarns and, to a lesser degree, nylon, acrylics,
and cotton, and predominantly produce fabrics for the apparel trade.
Twenty-eight of the largest mills accounted for 50% of total productive
capacity.
31
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541 Mills
Double Knit
Yarn
Warp Knit
Single Knit
Integrated
Finishing
120 Establishments
Commission
Finishing
90 Establishments
Bleach
Dye
Print
Finish
This Group
Services 320-330 Mil Is
Knit Only and
Dry Finish
320-330
Vulnerability - 90 Establishments
'Integrated finishing sometime service outside customers.
Source: ADL Estimates
FIGURE 2-2 KNIT FABRIC FINISHING
32
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(c) Single-knit fabrics, utilizing cotton, acrylics, polyester filament yarn
and piece dyed, for the apparel trades. Thirteen of the largest mills
accounted for 40% of total productive capacity.
(7) Segments to be Affected
(a) Knitting mills primarily engaged in knitting only are segments which
would not be affected, since all wet finishing is done on the outside
(320 mills).
(b) Integrated knitting mills have their own dye and finishing facilities, all
of which are of substantial size, and they have the necessary assets to
make the required capital investment to abide by government rules;
they are also able to control the total manufacturing process and pass
increased cost on to the apparel manufacturer (estimated 120 mills).
(c) Knitted fabric commission dyers and finishers. We believe that this
segment will be significantly impacted due to its relatively weak finan-
cial structure, and because all of these mills perform a service on a com-
mission basis and cannot control total price structure of the product.
We expect that, in the next six months, barring industry-wide recession,
the knit segment will turn profitable once again, as demand takes up
the capacity slack.
We feel the major problem will arise, not in passing additional costs on, but
in ability to make capital investment.
(8) Financial Profile. Table 2-23 represents the financial structure of the largest
integrated knitting mills having their own dyeing and finishing facilities. Table 2-24 repre-
sents financial profiles of the largest independent commission finishers for knitted fabrics.
d. Yarn and Stock — Dyeing and Finishing.
(1) General. According to the Census of Manufactures, during 1967 a total of
192 establishments were engaged in the dyeing and finishing of yarn, stock, and narrow
fabrics. Yarn dyeing facilities accounted for the bulk of these establishments, estimated at
80% of the total.
Table 2-25 illustrates the relative position of yarn dyeing facilities between
1958 and 1970. During that period, employment increased from 7,800 to 12,300, and value
of shipments doubled, and capital expenditures rose from $2.1 million to $13.3 million.
33
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TABLE 2-23
FINANCIAL PROFILE - PROFIT MARGIN OF INTEGRATED KNITTING MILLS
1970-1971
Net Sales ($MM)
1970
1971
Net Profit ($MM)
1970
1971
Profit Margin
1970
1971
Return on Equity-
Return on Investment
1970
1971
Texfi
Industries
97
164
5.3
11.3
5.5%
6.9%
18% 12%
25% 16%
Guilford Mills,
Inc.
43
53
0.7
2.7
1.6%
5.1%
10% 6%
37% 25%
Stevecoknit
27
33
1.6
2.4
5.9%
7.3%
44% 25%
27% 21%
Edmos Corp
25
32
1.8
2.5
7.2%
7.8%
22% 17%
14% 12%
Scottex
Corp
15
24
0.8
1.1
5.3%
4.6%
29% 13%
11% 7%
Source: Based on Company Annual Reports
TABLE 2-24
FINANCIAL PROFILE - PROFIT MARGIN OF THE LARGEST
COMMISSION DYERS OF KNITTED FABRIC (1969-1971)
1969
1970
1971
United Piece Dye Works, Inc.:
Net Sales ($MM)
Net Profit ($MM)
Profit Margin
Return on Equity-Return
on Investment
Capital Expenditures ($MM)
Source: Based on Company Annual Reports.
28
2.1
7.5%
21% 15%
2
28
2.6
9.1%
21% 17%
2
30
3.9
13.2%
26% 23%
2
34
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TABLE 2-25
YARN AND STOCK DYEING AND FINISHING
INDUSTRY GROWTH 1958-1970
No.
Employees
(OOO's)
Payroll
($MM)
Value
Added
($MM)
Cost of
Materials
($MM)
Value of
Shipments
($MM)
Capital
Expenditures
($MM)
Finishing Plants — Yam: Ratio of concentration, 1967: 4 large, 29%; 8 large, 44%
1958 7.8 28.8 52.0 105.7 158.0 2.1
1970 12.3 72.9 141.9 206.5 346.3 13.3
Total Plants: 192
Source: Annual Survey of Manufacturers 1970.
(2) Size Distribution. Table 2-26 illustrates the size breakdown of various plants
by number of employees and differentiates between companies that finish their own yarn,
which in most cases are integrated with spinning or texturizing operations, and commission
finishing plants that only provide a service of dyeing yarns. Refer to Table 2-27 for a
comparison of Census figures with those chosen as a basis for this analysis.
In the case of companies finishing their own yarn, establishments with less
than 50 employees represented over two-thirds of total establishments, or 85 out of 129. A
similar pattern occurs in the case of commission finishing and dyeing, where 42 establish-
ments out of a total of 63 had fewer than 50 employees.
(3) Types of Plants. As we have illustrated in Table 2-25, major capital invest-
ment has occurred in the last 10 years, which is reflected in the relatively modern
equipment in the establishments that are of large size. Small establishments are fragmented
and equipment is not up to date.
(4) Geographic Distribution. Table 2-28 gives the geographic distribution of
yarn finishing plants. Of a total of 192 plants in the United States the majority is in the
northeastern region, where there are 121 plants or two-thirds of the total, and 57 plants or
one-third are located in the southern region.
(5) Level of Integration. Figure*2-3 is a schematic layout illustrating the level of
integration between integrated yarn dyers and independent commission yarn dyers.
35
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TABLE 2-26
YARN AND STOCK DYEING AND FINISHING
Establishments
Finishing Own Yarns:
Total Establishments
Establishments with an average of:
1 to 4 employees
5 to 9 employees
10 to 19 employees
20 to 49 employees
50 to 99 employees
100 to 249 employees
250 to 449 employees
500 to 999 employees
Commission Finishing - yarn:
Total Establishments
Establishments with an average of:
1 to 4 employees
5 to 9 employees
10 to 19 employees
20 to 49 employees
50 to 99 employees
100 to 249 employees
250 to 449 employees
No. of
Establishments
129
29
13
21
22
23
14
4
3
63
9
11
4
18
9
6
6
Source: Census of Manufactures, 1967
No. of
Employees
(OOO's)
8.2
0.1
0.1
0.3
0.7
1.7
2.1
1.3
1.9
4.2
.1
.1
.6
.6
1.0
1,9
36
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TABLE 2-27
CATEGORY 7 - YARN AND STOCK - DYEING AND FINISHING
Study
Size
Division
Extra Small
Small
Medium
(No. Mills)
53
16
21
90
Census
Size
Division
(No. Employees)
0-19
20-49
50-99
Unadjusted Adjusted
Census Census
(No. Mills) (No. Mills)
(87)
(40)
(32)
53
16
21_
90
TABLE 2-28
YARN AND STOCK DYEING AND FINISHING*
(Geographic Distribution)
No. of Establishments
Finishing Plants - Yarn:
United States
Northeastern Region
New England Division
Massachusetts
Rhode Island
Middle Atlantic Division
New York
New Jersey
Pennsylvania
North Central Region
East North Central Division
Ohio
Illinois
Michigan
Wisconsin
Southern Region
South Atlantic Division
Virginia
North Carolina
South Carolina
Georgia
East South Central Division
Tennessee
Alabama
Western Region
Pacific Division
California
192
121
18
103
57
10
7
42
39
22
1
2
1
2
46
10
2
35
4
4
7
3
With 20 or
More Employees
105
53
13
40
45
8
5
14
15
11
39
2
29
3
4
4
2
Sources: Census of Manufactures 1967, ADL estimates and industry listings.
*The subtotals do not add up to the totals, in all cases, since all geographic
areas are not necessarily included.
37
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Independent Yarn
Producers
Staple - Filament
Integrated Textiles
Yarn Producers
Staple - Filament
Dye Yarn in Own
Facilities
Commission Dyers
90
Establishments
Dye Yarn in Own
Facilities
Raw Stock
Yarn
Narrow Fabrics
Knitted and Woven
Fabric Producers
Produce Fabric
in Own Facilities
Total
190 Establishmen
Vulnerability-- 90 Establishments
Source: ADL Estimates
FIGURE 2-3 YARN AND STOCK DYEING AND FINISHING
Level of Integration
38
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(a) Integrated Yarn Dyers. Integrated yarn dyers are composed of two
Jistinct types:
(1) Divisions of the large integrated weaving mills that own their own
spinning and texturizing facilities and utilize their own yarn-
dyeing facilities to finish the output of their spinning and tex-
turizing mills. Dyed yarn is then sold to outside customers or used
internally.
(2) Independent yarn spinners and texturizers that have their own
dyeing facilities and produce yarn only, which in turn is dyed in
their own facilities and sold outside.
In both cases, the dyeing facility could be used to do commission
dyeing for outside customers in addition to its own requirements.
We estimate that out of a total of 190 establishments, between 100 and
110 are parts of independent yarn producers or integrated textile companies.
(b) Commission Yarn Dyers. Commission yarn dyers are independent
plants that perform a service function only. The larger ones purchase yarn and sell dyed
yarns to their customers; the smaller ones simply perform the function of commission
dyeing.
It is estimated that out of a total of 190 establishments, 80 to 90 are
independent yarn dyers and this would also account for the discrepancy in ratios illustrated
according to the Census of Manufactures in Table 2-29.
TABLE 2-29
FINISHING PLANTS, YARN AND STOCK
(Size Distribution by Number of Employees)
No. of No. of
Establishments Employees
(OOO's)
Finishing Own Yarns: 129 8.2
Commission Finishing: 63 4.2
Source: Census of Manufactures 1967
39
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(6) Types of Products. The dyeing of stock and yarn is a limited, specialized
operation, solely limited to imparting color to both filament and staple yarns, predomi-
nantly in cotton and synthetic fibers.
(7) Segments to be Affected.
(a) Yarn Dyeing Facilities Owned by Independent Yarn Producers and
Integrated Textile Producers. We feel that these plants, estimated at 100 to 110, with the
exception of the smaller ones, may not be affected due to their size and ability to make the
necessary capital investment to meet government requirements.
(b) Independent Commission Yarn Dyers. These represent a total of 90
plants. We believe this segment will be significantly impacted because over two-thirds of
these establishments are small and fragmented with weak financial structure, and might be
unable to make the necessary capital investment to abide by government regulations.
Furthermore,current technological advances in multifabric weaving and dyeing are tending to
make this whole industry sector obsolete. Stock and yarn dyeing necessitate less flexibility
to meet changing market demands of style and color, and create a much larger cost because
of the larger inventories required compared to dyeing the knit or woven fabric.
(8) Financial Profile. No financial structure for independent commission yarn
dyers is available. We therefore feel that representative financial structures are expressed in
the category of integrated yarn manufacturing and dyeing as illustrated in Table 2-30.
40
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TABLE 2-30
FINANCIAL PROFILE
(Yarn Spinning and Dyeing)
Net Sales ($MM)
1970
1971
Net Profit ($MM)
1970
1971
Profit Margin
1970
1971
Return on Equity
1970
1971
Return on Investment
1970
1971
Capital Expenditures ($MM)
1970
1971
Dixie
Yarns
87
99
1.7
2.3
2.0%
2.3%
6%
7%
5%
7%
3
—
National
Spinning
Company
75
76
2.1
1.9
2.8%
2.5%
9%
8%
9%
8%
4
2
Standard
Coosa-
Thatcher
50
53
1.9
1.7
3.8%
3.2%
7%
6%
6%
5%
3
6
Burkyarns
Inc.
17
22
0.9
1.3
5.3%
5.9%
25%
24%
15%
15%
3
2
Source: Based on Company Annual Reports
41
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3. IMPACT ANALYSIS IN SPECIFIC TEXTILE CATEGORIES
a. Introduction.
The textile industry has been divided into seven categories by the proposed
effluent guidelines for this industry. They are:
Category 1 — Wool Scouring,
Category 2 — Wool Dyeing and Finishing,
Category 3 — Greige Goods Mills,
Category 4 — Woven Fabric Dyeing and Finishing (Cotton and Synthetics),
Category 5 — Knit Fabric Dyeing and Finishing (Cotton and Synthetics),
Category 6 — Carpet Mills, and
Category 7 — Stock and Yarn Dyeing.
The economic impact of the proposed effluent guidelines has been examined for
five of the above categories. They are:
Category 1 — Wool Scouring,
Category 2 — Wool Dyeing and Finishing,
Category 4 - Woven Fabric Dyeing and Finishing (Cotton and Synthetics),
Category 5 — Knit Fabric Dyeing and Finishing (Cotton and Synthetics), and
Category 7 — Stock and Yarn Dyeing and Finishing.
Two categories — greige goods mills and carpet mills — have been precluded from
this initial study of the economic impact, on the assumption that these two categories
would not be significantly impacted by the proposed effluent guidelines.
Greige goods mills, by definition, are mills employing only dry processes, such as
knitting and weaving. Weaving mills would likely have a slashing operation, but in a well
managed mill the pollution load generated by this process would be negligible. Therefore,
we find greige goods mills have no appreciable pollution load beyond the sanitary load and,
in our judgment, they will be unaffected by the proposed effluent guidelines.
Carpet mills have been set aside from this initial study on the basis that they,
unlike any other category of the textile industry, can pass on treatment costs in the form of
investment or operating costs to their customers. While the situation might change between
now and 1983, we believe that the largely inelastic demand for this product and prevailing
pricing practices will allow absorption of treatment costs in the pricing structure for large,
medium, and small carpet mills. In addition, because of this situation, these mills offer
attractive investments, so that capital should be available to enable them to continue
operation while complying with the guidelines.
A final circumstance that will reduce the impact on the carpet industry is that
well over 50% of the industry is located in Dalton, Georgia, and are connected to the
municipal waste system where the personnel are experienced in handling carpet mill wastes.
43
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In addition to setting aside two of the seven textile categories from this initial
study, we have also set aside large integrated textile mills which will not be significantly
impacted, generally because of their higher profit levels, larger size, and integrated produc-
tion, as well as their ability to influence price levels strongly within the industry and hence
pass on the cost of pollution control. It is generally felt that the small and medium sized
mills do not have the same freedom to increase prices as do the larger, integrated mills. It is
then the small and medium sized mills that must absorb these costs from profits rather than
by passing on the cost to their customers.
Many of the larger, integrated mills have already established treatment facilities
and/or are connected to municipal treatment systems and have already met or exceeded the
requirements of the proposed best practicable technology. They have, in turn, already
absorbed the cost and, if necessary, passed on this cost to their customers. Small and
medium sized mills, in general, service the aftermarket and thus lag behind the larger mills,
and as the market and the pricing structure have already absorbed the costs for larger mills
to control pollution, the small and medium sized mills cannot increase their prices.
Since the impact of pollution control is partially absorbed already by the larger
mills, and since they should not, for the most part, have difficulty in absorbing additional
increments, either from higher profits and/or price increases, we may set them aside and
concentrate on the impact that will be felt by the small and medium sized mills within each
of the five categories studied. In addition, the smaller mills have been divided into two
categories: (l)very small, with under 20 employees, and (2) small, with 20 and over
employees. The very small grouping was developed by EPA as a special group with special
financial restrictions.
(1) Sources. In undertaking the study, the contractor interviewed at least one
representative mill within each size classification and category. In many cases, multiple
interviews were conducted to permit presentation of a more representative example. In
addition to personal interviews, telephone interviews were extensively conducted not only
with operating mills but with other industry sources as well which were able to supply
pertinent information. The contractor also relied on his in-house textile industry specialists
to provide direct input to the study as well as to judge on the relative accuracy of
information gained through confidential interviews.
Because of both budgetary and calendar constraints, the number of interviews
conducted during this study was too small to provide statistically valid conclusions, but it
was adequate to provide a generally qualitative basis. It is anticipated that in subsequent
studies the number of textile companies interviewed — and hence the data base from which
the analysis will be made — will be significantly increased.
(2) Methodology of Impact Analysis. Earlier studies of the textile industry have
concluded that the industry would not be severely impacted by the proposed effluent
guidelines, and that conclusion is largely supported by the findings of this study. Imports
have recently played — and are expected to continue to play — a dominant role in
determining price levels within the industry. In view of this, price levels which permit profit
levels adequate to absorb the cost of pollution controls are sensitive to tariff levels, and we
44
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have assumed that the industry as a whole will continue to be protected from low-cost,
foreign imports — at least at the level of protection now afforded by existing duties, quotas,
and the like. Pricing effects are discussed for each category within the individual scenario for
that category.
For each of the five categories studied, the contractor prepared a scenario to
show how the small mill with less than 20 employees and a medium and small sized mill
would be impacted by the proposed effluent guidelines.
On the basis of the interviews, other industry sources, and in-house informa-
tion, a composite mill was composed for each size classification within each category. This
composite mill is considered representative of a mill of the size classification and category.
The composite, with the exception of wool scouring and wool dyeing and finishing, is in
each case essentially a commission dye house. This kind of model was selected because it
would best represent the impact of water pollution controls or the impact of the proposed
effluent guidelines. Textile mills with both wet and dry processes tend to be more profitable
than those with only wet processes, such as commission dye houses, and thus they will be
impacted to a lesser degree, since they have broader profit bases which they can use to
absorb the costs of pollution control.
Although the limitations caused by the small data base are recognized, a
range of sales revenues, profits, depreciation expenses, annual cash flows, production,
employment, and other parameters have been presented for the composite mills in each size
classification and category.
(3) Meeting the Guidelines. A mill may meet the proposed best practicable technol-
ogy for 1977 in several ways. It may begin or continue to discharge its effluent for
treatment to a municipal facility. If this choice is made, the mill will be obligated to pretreat
its effluent in accordance with the proposed guidelines for pretreatment. This would
include, but not be limited to, extraction of fiber and particulate matter from the stream as
well as the removal of substances which pass through the municipal treatment plant, i.e.,
refractory COD material, or else the effluent might have a deleterious effect upon the
municipal treatment plant such as the discharge of heavy metals (i.e., chrome-based dyes).
However, the mill may choose to treat its own effluent. It is assumed that
the treatment would consist of good, secondary biological treatment with extended aeration
and lagooning. The EPA believes that secondary biological treatment would be adequate to
achieve the proposed guidelines for BOD, COD, and color. In some cases, good secondary
biological treatment may be inadequate to achieve the guideline levels of COD and color
removal. If that eventuality were to come to pass and the guidelines were to be met, then
the contractor suggests that massive lime treatment and activated carbon treatment would
be one method of achieving the guidelines while evaporation of 20% of the discharge stream
and incineration of the solids residue would be another method of achieving the guideline
levels on COD and color. While the latter two treatment systems added to good secondary
biological treatment would undoubtedly produce an effluent within the guidelines, it is not
known whether or not either would be required, and therefore the impact analysis will be
based upon only secondary biological treatment where the mill has adequate space for
lagooning.
45
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In some unusual cases a mill will be situated in a location which prohibits the
use of secondary biological treatment and lagooning, and further is prevented from dis-
charging to a municipal treatment plant either because the municipal treatment plant does
not exist, or is not large enough to handle the additional discharge of the textile mill, or
refuses to accept the mill's industrial wastes. If such conditions were to exist, and this would
be an unusual condition, the mill would have to decide whether to change its product mix,
move its operation, or install a high-rate, activated sludge, two-stage treatment plant.
We have not addressed this space-limited mill condition, since on investiga-
tion we feel that such situations do not really exist or, if they do, they are so few and have
such special conditions that they warrant individual mill-by-mill treatment.
For each of the options discussed above, the mills would have to decide how
to make the new investments in pretreatment or treatment equipment. In some cases, the
mill might choose to fund the investment from its operations. The majority of the small and
medium sized mills would probably finance the investment in new treatment facilities.
Conventional financing might be available through banks handling a company's general
banking needs, but in other cases, probably the majority, the financing would be made
available only with Federal or State guarantees. Another form of financing would be
through industrial bonds issued by the local municipality. In each case, the mill would be
able to continue operations and the problem would merely be one of how to finance or
fund the new investments required.
Some industry sources believe that marginal operations exist and that these
operations are so marginal that they cannot acquire any kind of financing. The contractor
found one case in which the State limits the amount of corporate indebtedness of firms
under its jurisdiction, which provides an artificial limit to financing pollution abatement. In
the case of the marginal mill, it would be faced with either closure or discontinuance of the
wet process operation, thus changing the product mix. Obviously, this latter option would
not be available to those who are simply commission dye houses, except in that instance
where a process change or product mix change might produce an effluent more readily
treatable. If none of the above options is open to the mill, the mill would have to close.
(4) Waste Treatment Costs. For each of the five categories studied, the con-
tractor developed the investment and operating costs necessary to meet the proposed best
practicable technology. The investment and operating costs were developed for municipal
treatment and self-treatment with space available for lagooning. For each category the
investments and operating costs were based upon a very small mill with 19 employees, and
small and medium sized mills operating with the range of estimates presented for the
composite mill of its size and category. The waste and hydraulic loads conform to the
proposed guidelines for water usage and waste. The one exception to this general approach
is wool scouring, where we made estimates for only two size mills - very small, with 19
employees, and small, since there appears to be no medium mill classification.
The basis for the waste treatment cost estimates is the original work
presented in the proposed effluent guidelines for the textile industry. It was under that
46
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contract that the methodology for making the estimates was developed, and this study has
applied that methodology to the proposed effluent guidelines and the models of mills
chosen for this study. Appendix A presents the methodology in an abbreviated form and
can be used to approximate the results of our analysis.
The original work presented in the proposed effluent guidelines study did
not consider chlorination, or color removal. The additional material necessary to make those
calculations has been included as part of Appendix A.
When calculating the annual operating cost for effluent treatment, we
included labor, materials, and utilities. In addition, we included a charge equivalent to 8% of
the capital investment to represent the cost of capital or interest expense applicable should
the investment be financed. Further, we included a depreciation expense of 10% of the
initial capital investment being representative of the total depreciation expense. The latter,
the depreciation expense, is also assumed to be the source of cash for principal repayment
of a 10-year loan repayment schedule.
(5) Best Available Control Technology. In a similar manner, we calculated the
investments and operating costs for mills conforming to the Best Available Technology
(BAT) level, as specified by the EPA for the textile industry. BAT, so defined, includes the
preliminary screening, primary settling (for wool scouring only), coagulation (for carpet
mills only), secondary biological treatment and chlorination. In addition, it includes
advanced treatment techniques such as multi-media filtration and/or activated carbon
adsorption following biological treatment. The very small mills with under 20 employees
have no COD requirements in BAT and, therefore, employ only a multimedia filter.
(6) COD and Color Considerations. In estimating the economic impact that the
proposed best practicable technology portion of the effluent guidelines will have upon the
textile industry, we have assumed that good, secondary biological treatment will be
adequate for the reduction of BOD, COD, and color to the required levels as stated in these
guidelines. There exists the possibility that good, secondary biological treatment will not be
adequate for the reduction of COD and color in certain circumstances, however. Discharges
of some but not all exemplary plants in that report meet the guidelines with secondary
biological treatment. Since detailed information is not available about the raw waste loads
of these exemplary plants, we are uncertain as to whether or not all mills can meet the
guidelines, discharging the raw waste loads and hydraulic loads as proposed in the effluent
guidelines.
While raising the issue, we have not been able to resolve it in a manner that
would be acceptable by all parties. The resolution of this issue will be left to a subsequent
study, or simply by passage of time, with more and more mills demonstrating their ability to
treat the effluent with secondary biological treatment. Therefore, as indicated above, we
have measured the economic impact of the proposed effluent guidelines on the textile
industry by considering the costs and investments of a good secondary biological treatment
plant.
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If in fact the COD and color levels, as described by the proposed guidelines,
could not be met, we suggest that there are two methods which may be employed to achieve
the proper level. Before discussing the methods we must point out that these may not be the
only technologies available for achieving these ends, but rather two technologies which are
practical and recognized.
The first method would be to employ a massive lime treatment to the
effluent, followed by an activated carbon treatment. The second method would be to isolate
the dye stuffs from the rinse waters and wash waters of the effluent. These spent dye stuffs
not only contain most of the colors, but as well include much of the highly refractory COD
components of the effluent. In this method 20% of the total waste water stream, isolated in
the manner described above, would be evaporated and the resulting residue incinerated, thus
creating only a burned waste for disposal.
(7) Mill Closings Criterion. Having estimated the range of cash flows and other
financial characteristics of a mill in each category and size classification studied, and further
having established what the investment and operation costs would be for a mill operating
within this range of financial characteristics, we subtracted the estimated annual operating
cost from the range of annual positive cash flows. When the annual operating cost did not
exceed the minimum cash flow thought to exist for that category, then we assumed the no
plant closings would ensue as the result of meeting the proposed effluent guidelines.
Following this technique, if the annual operating cost should exceed cash flow for any
particular mill example, then we would assume that all mills operating within this category
and size classification would close. Continuing to use the zero cash flow criterion for a plant
closing, we found that some plants within a certain category and size classification might
close, since the operating cost of the treatment system would place them in a zero or
negative cash position. To make an estimate of the percentage of mills within a category and
size classification and in turn an estimate of the number of mills that will close, we assumed
that the cash flow would be distributed linearly throughout the range described. If this
assumption is made, then zero or negative cash flow would be proportional to the
percentage of mills falling below the point where the annual operating cost would penetrate
the cash flow range.
Had the data base been larger it might have been useful to assume a normal
distribution of cash flows for each size mill rather than the linear distribution. Certainly in a
statistical sense this would be a more elegant approach to determining the percentage of
mills closing. For example, if we had reliable and accurate information about at least 30
mills in each size category, we could demonstrate whether or not the cash flows actually
form a normal distribution. Since, for the most part, there are not that many mills in a size
classification for a category, the demonstration of normalcy is not possible.
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Using the simpler linear distribution and the influence that it has upon the
results can be envisioned by examining the figure. The area defined by "a" in the figure
defines the linear distribution where it is equally probable that we will find a cash flow. The
area defined by "b" is that of a normal distribution and would express the probability of
finding a cash flow within a population obeying this distribution. The difference between
these two assumptions can best be seen by comparing "line x" and "line y" which represent
the cumulative probability for the linear and normal distributions. In our model it would
make no difference whether a normal distribution and/or linear distribution were used at
the halfway point. That is to say, both techniques would estimate the same percentage of
mill closings.
Max
Increasing Cash Flow
For cash flows below the mean we would find that the linear distribution
tends to show a larger number of mill closings than does the normal distribution and,
conversely, above the mean the normal distribution tends to increase the percentage of mill
closings until finally at the end point where both distributions once again are equal. The
contractor does not believe that the slight overstatement of the linear distribution is
particularly punitive, since it is his expectation that the firms with lower positive cash flows
would be more inclined to close than those with higher cash flows, even if the distribution
were normal. That is to say, even though the linear distribution tends to bias the percentage
of mill closings below the 50% point, the contractor believes that this may be a more
realistic expectation.
The use of a zero or negative cash flow as the criterion to determine plant
closings tends to understate the number of mill closings if higher level criteria were to be
used. Those higher level criteria would include profitability on sales, minimum rate on
return on invested assets, internal rate of return, discounted cash flow method, or present
49
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value analysis. Each of these forms of analysis would likely carry with it a higher level of
cash flow demand to satisfy the criterion, and hence would tend to increase the potential
number of mill closings. We believe that since a large majority of the'mills of small and
medium size within the five categories studied are privately held companies or corporations,
the zero or negative cash flow criterion most closely approximates the criteria actually (but
perhaps never formally) applied to the decision of a mill closing.
There are an unknown number of mills which face imminent closing deci-
sions and the necessity of meeting the proposed effluent guidelines, and the attendant
investments and operating costs will merely hasten the final decision to close the mill rather
than actually cause its closing, i.e., being the sole factor. There will undoubtedly be closings
that will be ostensibly associated with the mills' inability to meet the investment and
operating costs required by the proposed effluent guidelines. Based upon industry sources
and interviews undertaken in support of this study, we estimate that as many as one-half of
the mill closings which occur as a result of the proposed effluent guidelines will simply be
accelerated closings, i.e., the mill would have closed spontaneously without the necessity of
meeting the effluent guidelines.
Within each scenario, we have presented the investments and annual
operating costs against a background of how a mill would finance its new investments
in waste treatment equipment. While an important criterion, which may in and of itself
lead to mill closings, we have not used this as the closing criterion, but rather have
selected the zero or negative cash flow as the criterion. We reason that far fewer mills will
have great difficulty financing the investment than those which simply cannot afford the
annual operating costs.
b. Category 1 - Scenario of Wool Scouring.
(1) General Description. This segment of the textile industry has been severely
set back by the conversion to synthetic fibers. There are now only about 16 active raw wool
scouring mills in the United States compared with about 21 listed in Davidson's Blue Book
of 1972. (Davidson's listings tend to list mills even after their closing; hence this large
reduction did not necessarily take place entirely since 1971.) The 1967 Census, lists a total
of 68 scouring and combing mills but combing mills are dry operations and hence can be
treated the same as griege mills. Two large mills in Massachusetts and several in Texas are the
only remaining commission scouring mills. The remainder also produce top wool and are
components of vertically integrated organizations.
Wool scouring is conveniently separated from other segments of the textile
industry because of its uniqueness. Raw wool (grease wool) must be wet-cleaned (wet-
processed) before the fiber can be dry-processed to produce top yarn, then fabric.
The grease wool contains 25 to 75% non-wool materials, consisting of wool
grease (a recoverable material of some economic value) and other materials of animal origin
50
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such as urine, feces, sweat, and blood, as well as dirt consisting of both oil and vegetable
matter. Additional materials that may be present include insecticides (sheep dip) and
fugitive dyes used for identification. This variability in both yield and the composition of
impurities and grease causes a correspondingly large variability in raw waste loads.
(2) Process Description. Scouring consists of sorting the fleece and feeding it to
a hopper. The fleece is wet with fresh water in the first bowls. The wool is then carried
through a series of scouring bowls where scour liquor flows countercurrent to it. Detergent
is added in the third or fourth bowls to emulsify the greases and oils. The scoured wool is
then dried. In mills where the cleaned wool is converted into top wool, the wool is combed
and drawn — and sometimes air-washed — to remove the short fibers (used for wool yarn)
from the long fibers (used for worsted yarn).
The wool grease constitutes a special problem in treatment since it does not
appear to be readily biodegradable, unless it is well-emulsified so that bacteria can reach it.
Therefore, the grease-recovery step is important to reduce pollution. The scour liquor from
the separation tank is processed to break the emulsion and recover the wool grease. Two
methods are commonly used in this procedure: centrifuging and acid-cracking.
In the centrifugal method, about 60 percent of the grease is recovered, and
the remaining 40 percent is attached to the dirt and grit. Centrifuging recovers over 90
percent of the grease from the scour liquor. In the acid-cracking method, pilot plant
performance indicates a 98 percent recovery of grease from the degritted liquor. No data are
available to indicate the initial split of grease between the grit and the raw liquor from the
grit settling tank. Grease yield, in total, is 8 to 15 percent by weight of the greasy wool, and
this constitutes 50 to 65 percent of the wool grease intially present. Note that 1 to 3
percent of the wool grease present in the grease wool is allowed to remain on the wool as a
conditioner. The market for recovered, unrefined wool grease is very unpredictable. The
demand varies between zero and a level permitting a price of $0.25 per pound. When prices
are depressed, the mill stores the grease for up to 6 months or more, making it an
unattractive business for many operators.
Some "raw" wools, mostly the Australian and New Zealand wools, are
prescoured at the source. However, this fact does not appear to affect this analysis of U.S.
raw wool scouring mills significantly. Scoured wool is often converted into "tops" at the
same mill. In this operation, the short fibers are separated mechanically from the long ones;
the long fiber "tops" are used for worsted yarn and the short fibers are used to blend into
woolen yarns. No added pollution occurs, but the water load is increased slightly by water
washing of the air from an air washing step. The guidelines developed for Category 1 are
based on the total product fiber and include both short fibers and tops.
Several small mills are connected to municipal treating systems. Most small
mills are not treating their wastes at all. The larger mills are treating their own wastes, with
the exception of Wellman in South Carolina which is connected to a municipal system. Two
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large Burlington mills treat wastes combined from carpet and woolen broad-woven fabric
finishing plants, respectively. We are not considering as exposed those mills which are
integrated into a large corporate organization. This criterion reduces the mills exposed from
16 to 12.
(3) Composite Mill. The wool scouring mills of interest to this study are the
commission scouring mills (4 or 5 mills) and the top-making companies. As stated above we
are not considering those integrated with spinning, knitting, weaving and finishing opera-
tions which are a part of a larger corporate organization. The generalized models are shown
in Tables 3-1 and 3-2. Only a very small mill with 19 employees, and the small mill with 20
to 40 employees are considered. The few "large" mills are now processing about 50,000
pounds per day; the smallest about 5,000 pounds per day. In general, the wool scouring
equipment is old and has been written off long ago.
TABLE 3-1
REPRESENTATIVE VERY SMALL RAW WOOL SCOURING MILL
Sales $650,000
Profit (before taxes) 0-1%
0-$6,500
Profit (after taxes) 0.8%
0-$5,000
Depreciation Negligible
Debt Repayment Not known
Cash Flow 0-$5,000
Salvage Value Negligible
Cost Structure:
Fixed 20%
$129,000
Variable 80%
$515,000
Production 5,000,000 Ib/year
14,300 Ib/day
Employment 19
WorkWeek 5 days, 1 shift
Water Use 7.5 Million gallons per year
21,500 gallons per day
1.5 gallons per pound of clean wool
One scouring line will handle about 15,000 pounds per day. This typical mill
performs commission scouring: many of the scouring mills also make top, a dry operation.
Table 3-2 presents typical ranges of the various business aspects of a small mill involved in
raw wool scouring.
Mills doing commission scouring only will realize about $0.065 per pound of
raw wool, or $0.13/pound of clean wool, resulting in a sales volume of $650,650 per year for
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the production rate shown in Table 3-2. Those mills selected for the small/medium class
perform commission scouring and some top making, resulting in a sales level of about $1.73
per pound of clean wool, based on the mills sampled in this study. Not considered are top
mills which buy all their wool and process it into top, where the sales price could be as high
as $2-3/pound.
TABLE 3-2
REPRESENTATIVE SMALL/MEDIUM RAW WOOL SCOURING MILL*
Sales
Profit (before taxes)
Profit (after taxes)
Depreciation
Debt Repayment
Cash Flow
Salvage Value
Cost Structure
Fixed
Variable
Production
Employment
Work Week
Water Use
$6,500;000-$13,000,000
0-$130,000
0- 1%
0 - $74,000
0 - 0.6%
Negligible
Not Known
0 - $74,000
Negligible
19%
$1,200,000-$2,400,000
81%
$5,280,000 - $10,450,000
3,750,000-7,500,000 Ib/yr
15,000- 30,000 Ib/day
20-40
5 days, 1 shift
9.5 — 19 millions of gallons per year
0.03 — 0.05 millions of gallons per day
1.8 gallons per pound of clean wool
* Assumption: Commission scouring and some top making.
(4) Discussion of Representative Mills. The production and sales levels of the
wool scouring mills, after eliminating the large mills and those that are part of a larger
corporation, do not vary sufficiently to warrant the two categories of small and medhrm
sized mills. Therefore, we have shown only one composite mill model for those two
categories.
We estimate that the representative mills have sales of $500,000 for the very
small mills, and ranging from $6.5 to 13 million per year for the small mill. The lower limit
of the small mill is based on a single scouring line that is up to capacity. Profits from these
mills range from 0 to 1% before taxes. This very low profit level is the result of the
depressed wool market of the last few years, combined with international wool-buying
practices that have left the United States short in supply. The wool business is currently
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looking up but the short supply is causing prices to rise to the point where it may be priced
out of the market. In any event, the low profit levels we found during interviews appear
reasonable to use for this projection.
The wool scouring mills are intensely competitive and, as one fails, the
others see reason to continue existence on the business they can glean from the failed firm.
Hence, the resultant profits after taxes range from $0-$5,000 for the very small mills, and
$0 to $74,000 per year for the small mills.
The equipment found in the wool scouring mills is almost wholly over 15 to
20 years old and has been written off long ago. As a result, depreciation is negligible as is
salvage value of the equipment. We could not determine debt repayment values so we will
use profit after taxes for cash flow. The cash flow of the composite mills therefore will be
between $0 to $5,000 for the very small mill, and between $0 to about $74,000 per year for
the small mill.
(5) Waste Treatment Systems Costs. Operating costs for waste treatment for the
composite wool scouring mill are given in Table 3-3. The very small mill uses 22,000 gpd
while the small mill uses 34,000 gpd of water, using guideline water-use figures applied to
the production rate of clean wool. Based on the methodology presented in Appendix A,
used with the applicable figures, we estimated the investment and operating costs necessary
to achieve the guidelines.
TABLE 3-3
ECONOMIC IMPACT OF EFFLUENT GUIDELINES ON WOOL SCOURING MILLS
CATEGORY 1
Very Small Size Mills Small and Medium Size Mills
Estimated Number of Mills Exposed
Estimated Number of Employees Exposed
Cash Flow (from composite mill)
Impact resulting from proposed best
practicable technology
If all were to use
• Municipal treatment
Annual cost
Mill closings, number (%)
• Self-treatment
Annual cost
Mill closings, number (%)
Impact resulting from proposed best
available technology
If all were to use
• Self-treatment
Add on annual cost
Mill closings, number (%)
3
57
$0 - $5,000
$9,200
3 (100%)
$20,300
3 (100%)
25,300
$25,300
3 (100%)
9
270
$0 to 74,000
$ 11,600
1 (16%)
$ 21,600
3 (29%)
189,500
$189,500
9(100%)
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The guidelines may be met by discharging the mill effluent to a municipal
treatment plant or by self-treatment. The wool scouring mill effluent has a special problem
of high grease content that creates problems in both treatment and sludge disposal. As a
result most municipal systems have refused to accept wool scour wastes, even after recovery
of wool grease (which only removes about 60% of the grease and oils). Work is actively
being performed by at least one wool scourer to make these wastes acceptable to the
municipality. Further, we understand Caron International is on a municipal system. Also,
mixed dye house and scouring wastes are being treated successfully in several private
treatment plants. For purposes of this analysis, we will assume that this grease problem will
be overcome without significant capital or operating costs involved; if it develops that such
costs are significant, they will have to be considered in the impact analysis.
The cost for pretreatment for the very small mill amounts to a capital
investment of $17,400 and an operating cost (including amortization of the capital invest-
ment) of $9,200 per year. Similar figures for the small/medium sized mill are a capital
investment of $21,300 and an operating cost of $10,000, respectively. These calculations
are based on an intermediate sized municipal treatment plant which would charge $0.40 per
1000 gallons treated. If a smaller municipal plant is involved, a higher treatment cost of
$0.68 per 1000 gallons treated should be used.
The annual operating costs for self-treatment for BPT are $20,300 with a
capital investment of $54,400 for the very small mill, and $21,600 operating costs and
$57,300 capital investment for the small/medium sized mill. These cost figures are based on
primary settling followed by a treatment in a well-operated 30-day oxidation pond, since
the guidelines state that good secondary treatment should be able to achieve the limits
stated. To evaluate the impact of the guidelines we have assumed that the low water use and
the COD and color can be reduced to acceptable limits by good secondary treatment. If
further tertiary treatment and extensive process changes are needed, these costs must be
considered.
The costs to the mills to meet BAT in the manner defined in the guidelines
amount to $71,300 for capital investment and $25,300 for operating expenses per year for
the very small mill, and $320,000 for capital investment and $189,500 for operating costs
per year for the small/medium sized wool scouring mill.
(6) Impact. Table 3-3 presents the economic impact of effluent guidelines on
wool scouring mills. As previously mentioned, we have measured the impact of the
guidelines on wool scouring mills by assuming the mill would close when the annual
treatment costs exceeded the cash flow. Furthermore, we assumed the distribution of cash
flows to be linear through the ranges of cash flow. Implementation of BPT or BAT by
the very small wool scouring mills would, in all cases, cause the three mills so classified to
shut down, affecting up to 57 employees.
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Implementation of the best practicable technology by small/medium wool
scouring mills by municipal treatment would cause 16% closings, or 1-2 of the 9 mills
exposed by our standard criteria. This would affect about 26 people. If all mills had to meet
this same goal by self-treatment, 29% closings would occur, or 2-3 mills, affecting 87 people.
Implementation of BAT would require operating costs of $189,500 (and a
capital investment of $320,000) and, as a result, would cause all mills which did not have
the alternative of connecting to municipal systems to close, affecting 270 employees.
Assuming that wool scouring mills could make their effluent acceptable to municipalities,
we feel that the only mills affected by BAT requirements then would be those which do not
have access to municipal systems. We estimate this number to be 2 or 3. Even this
conclusion must be modified by the fact that in those communities with which we are
familiar where wool scouring mills have been trying to connect to municipal sewage systems,
only 1 or 2 appear to be making headway, and there, with almost full-sized self-treatment
systems as pretreatment. Therefore, without more investigation, we must assume the full
impact.
It should be noted, in general, that this industry is very borderline at present;
it has been noted that it expects at least one mill to close a year. Hence, any expenditures
for clean-up may hasten the demise of mills that would have closed soon in any event.
Further, we seriously doubt if good secondary treatment would meet the guidelines for best
practicable treatment, and that most municipalities would continue to resist acceptance of
scouring mill wastes. Hence, the chances are good that more like 7 or 8 mills would close,
even at this first step. However, a study in greater depth would be needed to make a
definitive judgment possible.
(7) Price Effects. The extensive competitiveness of this industry precludes
passing on any costs as prices increase. Mills interviewed had tried to pass on increased labor
costs recently, but could not. If the wool market continues to look up, however, the
surviving mills may be in a position to pass on costs. The situation is too fluid to make
accurate predictions at this stage.
If prices could be passed on, the price increase necessary to meet the
guidelines might be as follows (in dollars per pound of wool scoured):
Very Small Small/Medium
Municipal 0.0018 0.0020
BPT, Self-Treatment 0.0041 0.0038
BAT, Self-Treatment 0.0051 0.0337
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These figures would be added to a processing price of $0.065 per pound of raw wool
(roughly $0.13 per pound of clean wool) for mills doing scouring but which do not own
their own wool and which do not make top. If they own their own wool, the selling price
would be $2.00 or more per pound of clean wool, and in the small/medium mill example
doing mixed work, the average price of their product would be $1.60/pound of clean wool.
(8) Secondary Effects. If the costs of implementing the guidelines can be passed
on, they will be marked up at least 15%. Wool is already in danger of being priced out of the
market, so this increase, plus the increase, from wool-finishing operations, may seriously
affect wool's position in competition with other fibers as well as encouraging wool imports.
(9) Financial Effects. The profitability of wool scouring mills would fall off as
follows:
Present Municipal BPT, Self- BAT, Self-
Profit Treatment Treatment Treatment
'0
Very Small Mill 0-1% 1.8% of Sales 4.1% 5.1%
Small/Medium Mill 0-1% 0.12% of Sales 0.22% 1.9%
Capital availability will affect the marginal mills even on municipal pretreat-
ment; all of the very small and 29% of the small/medium mills may not be able to obtain
internally generated cash for the capital required. Banks are reluctant to invest in wool-
scouring operations, because of their low profit and uncertain future.
(10) Production Effects. Achievement of best practicable technology would
reduce production as follows (assuming as before, that all mills are subject to each given
type of treatment):
Very Small Mills Small/Medium Mills
Municipal 10.6 4.9 MMlbs/yr
BPT, Self-Treatment 10.6 16.3 MMlbs/yr
BAT, Self-Treatment 10.6 50.6 MMlbs/yr
(11) Employment Effects. The same rationale used in estimating the production
effects above yields layoffs as follows:
Very Small Mills Small/Medium Mills
Municipal 57 26
BPT, Self-Treatment 57 87
BAT, Self-Treatment 57 270
57
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Note, however, that the mills that pick up the business from the plants that
close might add a number roughly equivalent to the impacted number to their employment
rolls.
(12) Community Effects. Effects on the communities would be specific to the
towns where the mills affected were shut down. These mills tends to be in small commu-
nities where the local impact would be significant.
c. Category 2 — Scenario of Wool* Dyeing and Finishing.
(1) General Description. The 1967 Census figures for SIC 2231, wool manufac-
turing and finishing, indicate 310 mills operating in this category. Of these, perhaps 160 are
still in business, mostly being located in the northeast region. As discussed in Chapter 2, this
figure of 160 mills reduces to a total of 76 that are potentially exposed to impact by the
guidelines. We estimate that these 76 mills are composed of 23 very small, 33 small, and 20
medium sized mills.
Most small mills do commission dyeing, and even the larger mills that are
part of the larger corporations commonly perform commission dyeing in addition to their
own dyeing. Commission dyeing operations imply a wide range of fabrics and finishes as
well as fiber types.
Probably not more than 5 or 10 mills still process more than 50% wool and
wool blends; the rest process synthetic fabrics principally.
Wool finishing has been differentiated from other finishing categories be-
cause (1) the fiber is dirtier than other fibers, (2) different chemicals are used, and (3) it
involves high water usage per pound of product. Most northern mills are discharging directly
to streams, while a few discharge to municipal systems or to their own treatment plants.
Category 2 involves a high water usage rate caused by washing after the
"fulling" operation (peculiar to wool systems), because the higher quality fabric produced
necessitates more washing and, finally many of the mills in this category are old mills with
inefficient equipment and piping layouts.
Variations occur in processing, similar to other finishing categories, in that
some fabrics are woven or knit from yarns that are already dyed, either in the fiber or yarn
form. A given mill may dye and finish part of its production while only finishing the
remainder. This variation is unpredictable and causes a spread in data on pollution genera-
tion.
"Wool includes not only that from sheep, but also that from other animals, such as alpaca, vicuna, and the
Kashmir goat. Subsequent discussion here will address sheep's wool only: processing the other wool
involves somewhat special finishing techniques.
58
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(2) Process Description. There are three distinct finishing processes: stock, yarn,
and fabric finishing. The pollution generated by the fabric finishing operation is similar to
that generated by the other two, and thus it is included in this category. If the greige goods
are 100 percent wool, they are first cleaned of vegetable matter (and cotton fibers) by
carbonizing (soaking in strong sulfuric acid, dried, and crushed with the char separated from
the cloth). The fabric is then cleaned of spinning oils and any weaving sizes by a light scour
(detergent wash). The 100 percent woolens, with the exception of worsteds, are then
dimensionally stabilized in the presence of detergents to produce a controlled shrinkage or
"felting." Worsteds are hard, tightly-woven and dimensionally stable as received at the
finishing plant; woolens are loosely-woven, soft and often are firmed up by fulling.
The fabric is then batch-dyed in vessels called becks, washed in the same
vessels, and taken to dry finishing operations. The only dry finishing operation of concern
to water pollution is mothproofing.
(3) Composite Mills. The mills of this category could be northern mills, located
in small towns, where the mill is a significant part of the town's economy. Most of the small
and medium sized woolen finishing mills are so located. All woolen mills contacted by the
contractor are integrated, spinning through weaving and finishing. Tables 3-4 and 3-5,
present typical ranges of the various business facets of the very small, small and medium size
mills involved in Category 2 operations.
TABLE 3-4
REPRESENTATIVE VERY SMALL WOOL
DYEING AND FINISHING MILL
Sales
Profit (before taxes)
Profit (after taxes)
Depreciation
Debt Repayments
Cash Flow
Salvage Value
Cost Structure:
Fixed
Variable
Production
Employment
Work Week
Water Use
$675,000
0-6%
0 - $40,500
0-4.1%
0 - $27,600
$6,700
Not Known
$6,700-34,000
$34,000
11-24%
$70,000-$152,000
76-89%
$482\000 - $565,000
495,000 Ib/yr
1,980 Ib/day
19
5 days, 1 shift
6.8 Million gallons per year
0.027 Million gallons per day
1.38 gallons per pound of clean wool
59
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TABLE 3-5
REPRESENTATIVE WOOL DYEING AND FINISHING MILLS
Small
Medium
Sales
Profit (before taxes)
Profit (after taxes)
Depreciation
Debt
Cash Flow
Salvage
Cost Structure
Sales exp.
Fixed
Variable
Production
Employment
Work Week
Water Use
$1,075,000-5,375,000
0-6%
$0 - $322,500
0 - 31/*%
0-$174,000
$10,800-$54,000
Not Known
$10,800-$223,000
$270,000
10%
$212,000-$1,060,000
21%
$700,000 - $3,500,000
69%
750,000 - 4,200,000 Ib/yr
3,000- 16,000 Ib/day
30 - 150
5 day/wk, 1 shift
14.5-77.3 MGPY
0.04 - 0.22 MGPD
13.8gal/lb
$5,375,000 - $17,500,000
0 - 6%
$0-1,653,000
0 - 3.2%
0 - $554,000
$53,800-$175,300
Not Known
$53,800 - $729,300
877,000
10%
$1,058,000-$3,525,000
21%
$3,490,000 - $11,600,000
4,200,000 - 12,000,000 Ib/year
17,000-50,000 Ib/day
150-450
5 day/wk, 1 shift
82 - 242 MGPY
0.23 - 0.69 MGPD
13.8gal/lb
We estimate that the very small mill, with 19 employees, will have $675,000
sales per year. Profits will be 0-6% before taxes, and profits after taxes will range from 0 to
$28,000.
We estimate that the representative small mill will have sales ranging from
$1.1 to 5.4 million per year. Profits from these small mills range from 0 to 6% before taxes.
They operate in a very competitive environment; a few mills have established speciality lines
and enjoy the higher profit level. The resultant profits after taxes range from $0 to
$174,200 per year.
Most of the equipment found in woolen finishing mills is old, having been
written off already. The more progressive woolen finishing mills have modest programs of
reinvestment. The low profit levels cause the depreciation figure to be a significant part of
the cash flow for the poor performers, but quite a small part of the cash flow of those
showing a more normal profit.
60
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The composite mills are integrated mills. The dry operations, such as
spinning and weaving, are more profitable than finishing and help to carry that part of the
operations. The mill owners prefer to carry wet operations in spite of their poor financial
performance, since it gives them the ability to provide fast response to an aftermarket when
cutters need small lots of the more popular styles and shades, which the larger corporations
cannot handle economically.
The representative medium sized woolen fabric finishing mill (also inte-
grated) has sales from $5.4 to 17.5 million per year. Percentage profit before taxes does not
appear to differ much from the small mills and yields an after-tax profit ranging from $0 to
about $554,000. As in the small mills, the medium sized mills' depreciation represents a
significant part of the cash flow only for the poor financial performers.
Operating costs for waste treatment for the very small, the small and the
medium sized woolen finishing mills are found in Table 3-6. The very small mill uses 0.027
MGD while the small sized mill uses .131 MGD, and the medium size mill uses 0.46 MGD.
Based on the methodology presented in Appendix A, used with the applicable figures, we
have estimated the investment and operating costs necessary to achieve the proposed levels
of treatment.
The guidelines may be met by discharging the mill effluent to a municipal
treatment plant or by self-treatment. The costs for pretreatment, plus the annual municipal
charge (which includes amortization of the capital investment), amount to $10,100 and a
capital investment of $19,000 for the very small mill, $28,000 and a capital investment of
$41,100 for the small mill and $75,700 operating and $76,200 capital costs for the
medium-sized mill, based on an intermediate-sized municipal treatment plant which would
charge $0.40 per 1000 gallons treated. If a smaller municipal plant is involved, a higher
treatment cost of $0.63 per 1000 gallons treated should be used.
The costs for self-treatment are based on the use of extended aeration
lagoons. The annual costs for extended aeration lagoons would be $19,800 and the capital
costs would be $55,800 for the very small mill, $37,600 annual costs and $125,300 capi-
tal costs for the small mill, and the annual costs would be $67,100 and the capital costs
$228,500 for the medium sized mill.
In a similar fashion, the costs for BAT self-treatment are $25,200 operating
and $75,200 capital costs for the very small mill, $238,100 and $541,700 for the small, and
$443,900 annual operating costs and $1,165,100 capital investment for the medium-size
mill.
(4) Impact. We have measured the impact of the guidelines on woolen finishing
mills by assuming that the mill would close when the annual treatment costs exceed the
positive cash flow from operations. Further, we assumed that the distribution of cash flows
is linear through the range of cash flows shown. Table 3-6 shows the economic impact of the
effluent guidelines on the wool dyeing and finishing mills.
61
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Based on this assumption, implementation of the best practicable technology
by woolen finishing mills might cause 12% of the very small, 8% of the small and 3% of the
medium-sized mills to close, if all were to go to municipal treatment. This would cause 3, 3
and 1 mill closings, respectively. If self-treatment is required, 47% of the very small, 13% of
the small, and 2% of the medium sized mills would close, or 11,4 and 1 mills, respectively.
Our estimate of actual mill closings and employment affected is shown below:
Very Small Small Medium
Mills Employment Mills Employment Mills Employment
Municipal 3 52 3 49 1 155
BPT, Self-Treatment 11 61 4 80 1 152
BAT, Self-Treatment 15 293 33 2970 12 1612
We find the impact of the proposed best available technology to be signifi-
cant to all three size categories of mills. The annual cost of treatment exceeds the minimum
cash flows and exceeds the maximum cash flow in the case of the small size mills. We
estimate that 67% of the very small mills, 100% of the small mills, and 50% of the medium
size mills will be closed, resulting in 15, 33, and 12 mill closings, respectively.
(5) Price Effects. The current market for woolen fabrics is strong, having turned
around during the past several years. However, the market is considered too competitive to
be able to pass on any appreciable operating expenses incurred by meeting effluent
guidelines. The prime reasons given are that:
a) The large, integrated companies can spread the cost of design and operation
of treatment systems among their many mills;
b) The large integrated companies can and will establish price leadership, even
in view of the need for internally generated funds for items such as the
present guidelines implementation, because they are more diversified and
have greater "staying" power than the smaller mills; and
c) Imports, particularly from the Far East, are still dictating the market price
for woolens and wool blends.
We believe that the real price detriment today is the stiff competition from
synthetic fibers (this is described in the industry profile in Chapter 2).
The price of clean wool has risen so sharply recently that the wool finishing
mills, even with very nominal profit, are being priced out of the market. Therefore, even
though demand is strong, the price the converter can charge for spinning, weaving, and
finishing is very rigid. Therefore, for this analysis, we will assume that the price increases,
due to implementing the guidelines, cannot be readily passed on.
63
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For the composite mills, the price increases necessary to cover the costs of
meeting the guidelines (if these prices could, in fact, be passed on) in dollars per pound are
as follows:
Very Small Mill Small Mill Medium Mill
Municipal 0.0202 0.0113 0.0093
BPT, Self-Treatment 0.0396 0.0151 0.0083
BAT, Self-Treatment 0.0504 0.0958 0.0543
These costs would be added to a current price for finished wool of
approximately $3.50 to 4.00 per pound (clean wool is selling for $2.00 to 3.00 per pound
and spinning, weaving, and finishing adds about $1.00 to the price) for the larger mills, but
for the mills described here, the costs would be added to current prices of $1.43 on the
average for the mixed commission and integrated processing they do.
(6) Secondary Effects. If the costs for implementation of the guidelines could be
passed on, a 15% markup to the cutters would be added.
(7) Financial Effects. The profitability for the wool finishing mills would fall of
as follows:
Present Municipal BPT, Self- BAT, Self-
Profit Treatment Treatment Treatment
Very Small Mill 0-6% 1.5% 2.9% 3.7% of Sales
Small Mill 0-6% 0.9% 1.2% 7.4% of Sales
Medium Mill 0-6% 0.7% 0.6% 3.9% of Sales
(8) Capital Availability. The better performing small specialty mills may be able
to raise $100,000 through bank loans, but we feel anything much higher would require
government guarantees. The marginal small mills could not raise the $ 100,000 without such
guarantees. Therefore, it appears that the projected capital requirements for BAT for small
and medium size mills could be handled only by the better performing woolen mills, and
government guarantees would be needed for most of the mills to do so.
(9) Production Effects. There will be little effect from application of the best
practical technology to the better performers; however, the average mills and the marginal
ones will be affected. Most mills in this category do not have alternative production
capability without appreciable capital expenditures for new becks, etc. Also, since the
guidelines are written on a pounds of pollutant per 1000 pounds of production basis,
curtailing production would be of no help. Furthermore, to this same point, many wool
finishing plants are already processing synthetics and blends, both woven and knits, from a
small percentage to complete conversion. This step has been forced by the distressed wool
64
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market in the past 5 or 6 years. The waste production from synthetic alternates is lower, but
the cost to meet current guidelines does not differ significantly.
Mills that will have trouble meeting guidelines that have combined dry and
wet processing plants, such as spinning and weaving along with dyeing and finishing, have
the choice of closing down wet operations and continuing or expanding their spinning and
weaving operations. This approach means that the marginal small mills will lay off most of
their male help and retain the female help: some of the average mills may also do the same
or divert money into other investment opportunities.
It further means that those mills that do close wet processing will lose the
flexibility for fast-style turnaround that justifies their existence, and perhaps make them
non-competitive. (This aspect should be investigated in greater depth.) This will further
open the door to imports. However, the number of mills so affected by best practicable
treatment will be quite small so these considerations will only gain importance at higher
treatment levels.
Best practicable technology guidelines implementation and zero discharge
requirements will probably reduce production as follows (in millions of pounds per year),
assuming all mills have to meet guidelines for each category:
Very Small Mill Small Mill Medium Size Mill
Municipal 1.4 1.3 4.2
BPT, Self-Treatment 1.6 2.2 4.1
BAT, Self-Treatment 7.9 80.2 43.5
A good share of the lowered production described above would be picked up
by the surviving mills, many of which would probably belong to the larger corporations in
the South.
(10) Employment Effects.
(a) Production Curtailment. The wet processing would likely be dropped.
This would cause the male employees to be discharged, while maintaining the female help in
the spinning/weaving/knitting plant. This percentage of total employment working in the
dyehouse varies from 8% to 100%. A summary of likely layoffs under the different
conditions is shown below:
Very Small Mill Small Mill Medium Size Mill
Municipal 52 49 155
BPT, Self-Treatment 61 80 152
BAT, Self-Treatment 293 2970 1612
65
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(b) Plant Closings. For the reasons given above, it would appear that the
marginal small independent mills would have to close. Further, as mentioned under
"production" above, prospects for growth in employment appear unlikely for those mills
remaining in business. The mill closings and the effect on unemployment are given in
Table 3-5 presented earlier in this section.
(c) Cojrmiunity_^ffects_. Most of the woolen finishing mills are located in
small towns, mostly in Massachusetts, Rhode Island, New York State and Pennsylvania.
Being in small towns, they constitute from less than 5% to 10% of the town's direct
industrial employment.
(11) Balance of Trade. Effects on the balance of trade are considered negligible.
d. Category 4 — Scenario of Woven Fabric Dyeing and Finishing (Cotton and
Synthetics).
(1) General Description. Of the 449 establishments (in 1967) engaged in dyeing
and finishing synthetic and cotton woven goods, about 146 are very small mills employing
less than 20 people, while 167 are small mills, employing between 20 and 99, and 102 are
medium size mills employing between 100 and 500 workers.
The types of plants vary greatly, depending on the size and the type of
products they process, since the industry is engaged in bleaching, printing, dyeing, and
finishing. The smaller plants, with 19 employees or less, in most cases have old equipment
that has not been modernized due to lack of capital resources. The larger plants, both
independent and those that are part of weaving complexes, are modern and efficient.
(2) Process Description. This category is one of the most important, because
such plants are responsible for much of the wastewater effluent load of the textile industry.
Integrated woven fabric finishing mills are also included in this category rather than in
category 3 because the greige goods section of these mills contributes only a small amount
to the overall effluent load.
When starch sizing is used in preparing woven fabrics, it becomes the major
contributor to the BOD load of the plant. Another commonly employed sizing is polyvinyl
alcohol (PVA), which tends to be less biodegradable than starch and therefore presents a
lower BOD level, while contributing significantly to the COD load.
Mill wastes generally have a high total of dissolved solids and color (dye
stuffs), and contain a variety of dye-dispersing agents. The use of caustic soda to mercerize
cottons produces an effluent of high pH dyes, and their associated additives represent the
most complicated treatment problem, since the BOD and COD load, as well as color, can
vary considerably with the type of dyed fabric being processed and the color effects to be
achieved.
66
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Wet process steps include greige goods scouring, bleaching, mercerizing
(cotton), dyeing, washing, and rinsing, followed by application of finishes such as soil
repellants, antistatics, and the like.
(3) Composite Mill. The following examples are for mills that do commission
dyeing and finishing only. Those that do spinning and weaving as well will show a higher
profit from the contribution of the dry processing, and the sales volume per pound of goods
produced will increase by a factor of about 3.5. Therefore, they will be in better shape to
handle waste treatment costs. Tables 3-7 and 3-8 present typical ranges of the various
business facets of the small and medium size mills involved in category 4 operations.
TABLE 3-7
REPRESENTATIVE VERY SMALL
BROAD WOVEN DYEING AND FINISHING MILL
Sales $204,700
Profit (before taxes) 6-6%
$0-$12,300
Profit (after taxes) 0 - 4.7%
$0 - $9,600
Depreciation $14,300
Debt Repayment Not Known
Cash Flow $14,300 - $23,900
Salvage Value $50,000
Cost Structure
Fixed 38%-43%
$72,600 - $82,600
Variable 52%-62%
$109,800-$119,800
Production 550,000 Ib/yr
2,200. Ib/day
Employment 19
Work Week 5 days 1-2 shifts
Water Use 9.9 million gallons per year
0.04 million gallons per day
18.0 gallons per pound of product
We estimate that the representative very small mill will have sales of
$204,700 per year. Profits will be from 0-6% before taxes, resulting in an after-tax profit of
0-$9,600.
The representative small mill will have sales ranging from $1.6 to $2.1
million per year. Profits from these small mills range from 0 to 6% before taxes. They
operate in a well established and very competitive environment. This would result in profits
67
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after taxes of $0 to $72,600/year. These sales include printing operations and other
specialty work that reflects a higher price per pound than that found in the very small mills,
and reflects our findings from field interviews.
TABLE 3-8
REPRESENTATIVE BROAD WOVEN DYEING AND FINISHING MILLS
Small
Medium
Sales
Profit (before taxes)
Profit (after taxes)
Depreciation
Debt Repayment
Cash Flow
Salvage Value
Cost Structure
Fixed
Variable
Production
Employment
Work Week
Water Use
$1,060,000-$2,120,000
$0-$127,200
0 - 6%
$0 - $72,600
0 - 3.4%
$74,200-$148,400
Not Known
$74,200-$221,000
$265,000 - $530,000
$400,000 - $752,000
$660,000-$1,240,800
62%
1,500,000-3,000,000 Ib/yr
6,000 - 12,000 Ib/day
50- 100
5-6 days, 2-3 shifts
37.8- 75.6 MGY
6.1 -6.2MGD
18.0gal/lb
$8,480,000 - $15,900,000
$0 - $954,000
0 - 6%
$0 - $502,600
0 - 3.2%
$593,600-$1,113,000
Not Known
$593,600-$1,615,600
$2,120,000-$3,975,000
$3,222,000 - $5,640,000
38%
$5,258,000-$9,306,000
62%
12,500,000 - 23,800,000 Ib/yr
50,000 - 95,000 Ib/day
300 - 600
5-6 days, 2-3 shifts
315- 598 MGY
0.9- 1.71 MGD
18.0gal/lb
Most of the equipment found in woven goods finishing mills is old, much of
it having been written off already. It will not be quite as old as that found in woolen
finishing plants, however. The more progressive woven goods finishing mills will have had a
small capital improvement program that may have resulted in at leas a few jet becks as well
as pressure becks and perhaps, in the larger mills, a continuous washer. The low profit levels,
however, cause this depreciation expense to represent a significant part of the cash flow.
The composite mills depicted here are commission dye houses, and will be
more severely impacted than the integrated mills. The latter are able to carry low-profit dye
house performance by offsetting it with more profitable spinning and weaving operations.
They prefer to do so (carry the wet operations) in spite of their poor performance, however,
because the reason they exist is most often their ability to provide fast response to the
aftermarket when cutters need small lots of the more popular styles and shades, and the
larger corporations are not set up to handle these small lots economically.
68
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The representative medium-sized woven fabric finishing mill (also a commis-
sion dye house with printing and/or other specialties) has sales ranging from $8.5 to $15.9
million per year. Profit before taxes does not appear to differ much from the small mills and
yields an after-tax profit from $0 to $954,000. As in the small mills, the medium sized mills'
depreciation is a significant part of the cash flow.
The water use for the mills interviewed during this study was found to be
about twice that proposed in the effluent guidelines. The water use for the example
composite mill was reduced to the levels proposed in the guidelines. Therefore, we assumed
that these mills could accomplish such a reduction in the use of water primarily by better
operating practice (in process changes) rather than by any significant capital expenditures. If
such investments or operating costs associated with the reduced water usage are necessary
and significant, then such costs must be included in calculating the impact of the guidelines
on the mill. As with other facets of the impact, this must be considered on a mill-to-mill
basis and cannot be generalized upon. The raw waste loads of the mills interviewed were
found to be similar to those described in the guidelines, and the composite mill is assumed
to conform.
(4) Impact. Operating costs for waste treatment for both the small- and the
medium-sized woven goods finishing mills are given in Table 3-9 and the economic impact of
the effluent guidelines on broad woven dyeing and finishing mills (Category 4) is presented
in Table 3-8. Based on the methodology presented in Appendix A, used with the applicable
figures, we have estimated the investment and operating costs necessary to achieve the
proposed levels of treatment.
The guidelines may be met by discharging the mill effluent to a municipal
treatment plant or by self-treatment. If discharging to a municipal plant, the annual
operating costs for pretreatment and the annual municipal charge are estimated to be
$12,700 for the very small mill, $33,000 for the small mill and $188,100 for the medium-
sized mill, with an initial investment of $23,000, $45,600 and $127,000, respectively. The
municipal charge is based on an intermediate-sized municipal treatment plant charging $0.40
per 1000 gallons of wastes treated. If a smaller municipal plant is involved, a higher
treatment cost of $0.63 per 1000 gallons treated should be used.
The costs for BPT self-treatment are' based on the use of extended aeration
lagoons. The annual operating costs for extended aeration lagoons would be $22,200 for the
very small mill, $34,000 for the small mill, and $100,600 for the medium-sized mill with
initial investments of $68,700, $111,600 and $353,700, respectively.
The cost to apply best available technology, as defined in the guidelines,
amounts to $93,700 capital expenditure and $28,700 annual operating cost for the very
small mill, $511,100 capital expenditure and $216,800 annual operating expenses for the
small mill and $1,895,100 capital expenditure and $609,400 annual operating expenses for
the medium sized mill.
69
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We have measured the impact of the guidelines on woven goods finishing
mills by assuming, as before, that the mill would close when the annual treatment costs
exceeded the annual cash flow, and that the distribution of cash flows would be linear
through the ranges given for the three mill groupings.
Implementation of the best practicable technology by woven goods finishing
mills, both small- and medium-sized, would not cause mill closings since the annual costs of
either municipal or self-treatment would not exceed the respective cash flows. However,
very small mills would experience significant impact from both best practical and best
available technology guidelines implementation if they must accomplish those goals through
self-treatment.
In addition, implementation of best available technology by self-treatment
would cause almost all of the small mills to shut down.
(5) Price Effects. The current market for broad-woven finished fabrics is reason-
ably strong. However, the finishing mills servicing this market are well established and the
competition is also strong. Industry sources stated that imports set the price and have
caused shutdowns already in this category. In addition, we stated that the larger, integrated
companies would be less impacted by the guidelines and this would penalize the small
independents. We feel, however, that probably all would be able to pass a good share of the
cost of implementing the guidelines on to the customers.
For the composite mills, the price increases necessary to cover the costs of
meeting the guidelines, in dollars per pound, would be as follows:
Very Small Small Medium
Municipal 0.0231 .0147 .0102
BPT, Self-Treatment 0.0404 .0151 .00545
BAT, Self-Treatment 0.0522 .0964 .0330
These costs would be added to a current charge of roughly $0.37 per pound
for dyeing and finishing broad woven fabrics, or about $0.70 per pound for those mills doing
printing and other specialties.
(6) Secondary Effects. The costs (for implementation of the guidelines), if
passed on to the cutters, would be done so with an additional 15% markup.
(7) Financial Effects. The profitability for woven fabrics finishing would fall off
as follows:
71
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Present Municipal BPT, Self- BAT, Self-
Profit Treatment Treatment Treatment
Very Small Mills 0-6% 6.2% 2.1% 1.5% of Sales
Small Mills 0-6% 10.8% 2.1% 0.8 % of Sales
Medium Mills 0-6% 14.0% 13.6% 5.0% of Sales
Capital availability might not be a problem for some mills since they could
divert capital expenditures from normal mill improvements to treatment operations. Other
mills would have to look to some form of debt financing.
(8) Production Effects. Compliance with the guidelines could reduce production
as follows:
Municipal BPT, Self- BAT, Self-
Treatment Treatment Treatment
Very Small Mills
Small Mills
Medium Size Mills
(9) Employment
0 68.3
0 0
0 0
Effects. Compliance with
83.2 MMlbs/yr
354 MMlbs/yr
12.7 MMlbs/yr
the guidelines coulc
lowing layoffs in number of employees:
Municipal BPT, Self- BAT, Self-
Treatment Treatment Treatment
Very Small Mills 0 2,275 2,774
Small Mills 0 0 11,788
Medium Size Mills 0 0 318
Implementation of the guidelines at all levels would cause a temporary halt
to providing increased jobs from mill expansions for an increasing population.
(10) Community Effects. Effects on the communities would be highly specific
to those mills that would be shut down. As in other categories, the small mills are often a
major part of the town's employment.
(11) Balance of Payments Effects. The balance of payments effects would be
negligible.
e. Category 5 — Scenario of Knit Fabric Dyeing and Finishing (Cotton and Syn-
thetics).
72
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(1) General Description. The knitting industry is characterized by a large num-
ber of plants and a structure organized along specialized product segments. The major
segments are knit-fabric piece goods, hosiery, outerwear, and underwear. The geographical
distribution of knit mills (SIC Code 225), according to 1967 census data, is as follows:
No. Plants
Northeast Region 1616
North Central Region 76
South Region 910
West Region 96
Total 2698
While the industry has shown substantial growth in value of shipments, we
estimate that - through consolidation and other factors - the current number of plants in
this industry is about 2,500. Of this number, we estimate that 1,100 plants have only dry
operations. These are plants, such as sweater mills in the outerwear segment, which knit
goods from purchased or commission dyed yarns, or mills which have finished goods dyed
on a commission basis and therefore have no process water requirements. Most of these mills
are located in the Northeast.
Of the 1,400 plants estimated to have wet process operations, we estimate
that 85 percent discharge to municipal treatment systems. The great bulk of these are
hosiery plants (700-800) located primarily in North Carolina, Tennessee, and Pennsylvania.
Census data (1968) on process water use and discharge indicates that virtually all (more than
90%) of the hosiery plants discharge to municipal systems.
The knit fabric mills within this segment amount to about 541 mills. Of
these, the commission finishers, about 90 mills, will be those most likely impacted. These
plants are the source of finished knit piece or yard goods for the apparel, industrial, and
household good trades, and also supply fabric to underwear and outerwear manufacturers.
The large knit fabric plants are located mainly in North and South Carolina and Georgia, but
substantial numbers are also located in New^York and Pennsylvania.
The production of knit fabrics for women'* and men's wear has been the
fastest growing sector of the textile industry over the past decade. Synthetic fibers are the
predominant types used in knit goods, except for cotton goods produced for apparel,
underwear, and sleepwear. In the latter case, however, polyester has been replacing in-
creasing proportions of cotton fiber. Plants which previously processed only cotton are
using greater amounts of polyester, and the trend is expected to continue.
(2) Process Description. The wet processing operations performed in knit fabric
dyeing and finishing are described below, with specific operations employed varying from
plant to plant.
73
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Yarns are purchased in the undyed state, with a knitting oil finish to provide
lubrication for the knitting operation. The amount of finish on the yarn ranges from 5-15
percent, depending on the type of yarn and fiber. There is a significant difference between
knitting and weaving yarns, since the latter are sized with starch or other polymeric
materials to add strength during the weaving operation.
After the yarn has been knit into fabric, the fabric may be processed by one
or more alternative routes. Typically, it is processed in piece goods form. The fabric is
washed in continuous countercurrent washers (warm water and detergent) prior to being
loaded in dye machines. This washing step removes knitting oils and other contaminants. In
some processes, washing is the first step in the dye machine cycle. The types of dyeing
equipment used include: pressure becks, pressure jet becks, and sometimes atmospheric
becks. The types of dyestuffs, auxiliaries, and conditions employed for dyeing knit goods
are essentially the same as for woven goods of comparable fiber composition.
Most knit fabrics are treated with softeners, antistats, and resin finishes, and,
in some cases, water and oil repellents. These finishes are applied from a pad bath just prior
to the final drying and dry finishing operations. These baths are discharged periodically, as
required, for fabric lot or formulation changes, but the total daily volume of discharge is
very small.
(3) Composite Model. The composite small and medium mills are commission
dyers and finishers. Because the average age of the equipment is much lower than in the
other finishing categories, knit finishing operations have higher salvage and depreciation
levels.
An increasing number of knit finishers are involved in knitting, along with
dyeing and finishing. Their sales dollar per pound of product will be about twice as high as
that of commission dyers. The profit for the dry operations is 1 or 2% (after taxes) higher
than for dyeing and finishing.
Some mills in this category buy their own yarn, knit it, and then dye and
finish the knitted fabric. In these mills, the sales dollar per pound of product will be about
five times what the commission dyers charge. As in the case of the knitter/finisher described
above, the profit level will be higher since the dry operations are more profitable than
dyeing and finishing.
Note that employees are hourly employees and salvage value is for equip-
ment only.
Tables 3-10 and 3-11 present typical ranges of the various business facets of
the very small, small, and medium size mills involved in Category 5 operations.
74
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TABLE 3-10
REPRESENTATIVE VERY SMALL
KNIT FABRIC DYEING AND FINISHING MILL
Sales
Profit (before taxes)
Profit (after taxes)
Depreciation
Debt Repayment
Cash Flow
Salvage Value
Cost Structure:
Fixed
Variable
Production
Employment
Work Week
Water Use
$1,015,000
0-5%
0 - $50,800
0-314%
0 - $32,900
$101,500
$40,600
$60,900 - $93,800
$335,000
28%
$284,200 - $270,400
72%
$730,800 - $694,000
1,897,500 Ib/yr
7,590 Ib/day
19
5 day, 3 shift
37,950,000
Note: This size classification has experienced a business downturn
and some small mills will close, primarily because of increasing
vertical integration, but the remainder will increase sales and
profits. The above representative mill will be valid for about
6 months. It is expected that vertical integration will be com-
plete within 5 years.
TABLE 3-11
REPRESENTATIVE KNIT FABRIC DYEING AND FINISHING MILLS
Small
Medium
Sales
Profit (before taxes)
Profit (after taxes)
Depreciation
Debt Repayment
Cash Flow
Salvage Value
Cost Structure
Fixed
Variable
Production
Employees
Work Week
Water Use
1,605,000-
$0-
0-
$0-
0-
$160,500-
$64,200 -
$96,300 -
$529,650
$3,210,000
$160.500
•5%
$90,000
2.8%
$321,000
$128,400
282,600
$1,059,300
$450,000 - $855,000
28%
$1,155,000 -$2,194,500
72%
3,000,000 - 6,000,000 Ib/yr
10,000 - 20,000 Ib/day
25-50
5-6 day, 3 shifts
70-140MGY
0.2 - 0.4 MGD
20 gal./lb
$5,082,500
$203,300
0
$112,200
2.2
$508,250
$203,300
$417,200
$1,677,200
$8,560,000
-$1,027,200
-12%
- $540,600
• 6.3%
- $856,000
- $342,400
-$1,054,200
- $2,824,800
$1,368,000-$2,112,000
27 - 28%
$3,511,200 - $5,420,800
73-72%
9,500,000 - 16,000,000 Ib/yr
30.00D - 50,000 Ib/day
75-125
5-6 day, 3 shifts
210-350MGY
0.6-1.0 MGD
20 gal./lb
75
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The very small mill will have sales of about $1,000,000, with profits of 0-5%
before taxes, yielding after tax profits of $0-33,000.
We estimate that the representative small mill will have sales ranging from
$1.6 to $3.2 million per year. Profits for these small mills range between 0 and 5% before
taxes, because of current distressed market conditions for polyester double-knits. This
results in after-tax profits of $0 to $90,000.
A large percentage of the equipment found in knitting and knit finishing
mills is relatively new. The higher temperatures needed for dyeing polyester with disperse
dyes and the need to handle knits much more gently than woven piece goods have required
new equipment designs: principally, the pressure jet beck. As a result, combined with the
low profit level, depreciation is a major contributor to cash flow.
The composite mill is presented as a commission dye house, which should be
more severely impacted than an integrated mill, since it cannot carry dye house losses or
overhead by the more profitable dry operations.
The representative medium-sized knit finishing mill (also a commission dye
house) has sales ranging from $5.08 to $8.56 million per year. Profits before taxes for the
medium sized mills not expected to be as low as some of the small mills, and will range
from 4 to 12%.
After-tax profits, therefore, result in values of $112,216 to $540,644.
Similar to the small mill example, the new equipment generates high depreciation expenses
which, even with substantial principal repayments deducted, provide an adequate cash flow
of $0.42 to $1.05 million.
The rate of water use in the mills interviewed during this study was found to
be substantially the same as that proposed in the guidelines. As a consequence, we assume
that all knit finishers can achieve the proposed water use rate "without significant added
costs for either new equipment or modifications to existing equipment. If it is necessary to
make substantial investments to meet such water conservation goals, the cost will have to be
included in calculating the guidelines' impact on the mill. As with other facets of the
impact, this must be considered on a mill-to-mill basis and cannot be generalized.
The raw waste loads were found to be similar to those described in the
guidelines.
(4) Waste Treatment System Costs. Investments and operating costs for waste
treatment for the very small, small- and the medium-sized knit finishing mills are presented
in Appendix A where we have estimated those costs necessary to achieve the proposed levels
of treatment.
76
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The guidelines may be met by discharging the effluent to a municipal
treatment plant or by self-treatment. The costs for pretreatment, plus the annual municipal
charge, amount to $44,100 capital cost and $31,400 operating cost for the very small mill,
$61,600 capital cost and $53,100 operating cost per year for the small mill and $121,700
capital cost and $96,000 operating cost per year for the medium-sized mill, based on an
intermediate sized municipal plant which would access a charge of $0.40 per 1,000 gallons
treated. If a smaller municipal plant is involved, in the order of 1 MGD capacity, a higher
treatment charge of $0.63 per 1,000 gallons treated should be used.
The costs for self-treatment are based on extended aeration lagoons. The
extended aeration lagoons will have a capital cost of $105,800 and an annual operating cost
of $32,500 for the very small mill, $148,300 capital cost and $44,400 annual operating costs
for the small mill, and $240,100 capital cost and $69,600 operating cost for the medium-
sized mill.
The costs to apply best available technology, as defined in the guidelines,
amounts to $167,900 capital costs and $46,200 annual operating costs for the very small
mills, $699,700 capital expenditure and $260,000 annual operating expenses for the small
mill, and $1,293,100 capital expenditure and $412,400 annual operating expenses for the
medium sized mill.
(5) Impact. As described in the introduction to this chapter, we have measured
the impact of the guidelines on knit finishing mills by assuming that a mill would close when
its annual treatment costs exceeded its positive cash flow. Furthermore, we assumed that
the distribution of cash flows is linear through the ranges for the three mill groups shown.
Table 3-12 presents the economic impact of effluent guidelines on the knit fabric dyeing
and finishing mills.
Implementation of the best practicable technology by knit finishing mills
will not cause mill closings in any of the three size categories, based on the observation that
the annual operating costs of either municipal or self-treatment will not exceed their
respective cash flows. The same observation is true for best available technology implemen-
tation, except in the case of the small mills having to undertake self-treatment in order to
meet guidelines. In that case, 88%, or 22 mills, will be shut down.
(6) Price Effects. The current market for finished knit fabrics is depressed.
Because of the intense competition, particularly in doubleknits, the mills interviewed feel
they will be unable to pass on the increased costs (from implementation of the guidelines)
to their customers. This is probably true since knits, according to industry experts, are
selling at cost right now and probably will continue to do so for the next 6 months or so.
77
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For the composite mills, the price increases necessary to cover the costs of
meeting the guidelines, in dollars per pound, are
Very Small Small Medium
Municipal 0.0165
BPT, Self-Treatment 0.0171
BAT, Self-Treatment 0.0243
0.0118 0.0095
0.0099 0.0054
0.0578 0.0323
These costs would be added to a current charge of roughly $0.535 per pound
for dyeing and finishing.
(7) Secondary Effects. Price increases in knit finishing may occur in the next 6
months or so. Presumably, demand will catch up with supply and the pricing structure for
knits and knit finishing will become more elastic. When that occurs, the added costs will be
passed on to the cutters with about a 15% markup.
(8) Financial Effects. The profitability for knit dyeing and finishing will prob-
ably fall off as a percent of sales, before taxes, as shown below, due to compliance with the
guidelines:
Present Municipal BPT, Self- BAT, Self-
Profit Treatment Treatment Treatment
Very Small Mills 0-5% 3.1% 2.2% 1.8%
Small Mills 0-5% 3.2% 1.8% 1.0%
Medium Size Mills 4-12% 4.6% 10.8% 6.0%
Capital availability should not be a major problem for most mills. The small,
marginal mills and the space-limited mills will have problems, however, and will have to seek
debt financing.
(9) Production Effects. Compliance with the guidelines could reduce production
as follows:
Municipal
Treatment
BPT, Self-
Treatment
BAT, Self-
Treatment
Very Small Mills 0
Small Mills 0
Medium Size Mills 0
0
0
0
0
8.3 MMlbs/yr
0
79
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(10) Employment Effects. Potential number of employees that would be laid off
as a result of the mill closings due to compliance with the guidelines is as follows:
Municipal BPT, Self- BAT, Self-
Treatment Treatment Treatment
Very Small Mills 000
Small Mills 0 0 69
Medium Size Mills 000
(11) Community Effects. Effects on the communities will be highly specific to
those mills that will be shut down. The few examples of space-limited mills which do not
have the option of connecting to municipal systems indicate they are located in small towns
where the impact on the local community will be significant.
(12) Balance of Trade. Effects on the balance of trade would be negligible.
(13) Consideration of Future Trends in Knit Finishing Business Outlook. If the
knit finishing industry does experience a return to good profitability in the next 6 months
or so, as is considered probable, then the composite mills might look like those described in
Table 3-13. These improved cash flows would reduce the impact on the small mill having to
meet best available technology treatment to zero mill closings, thereby establishing essen-
tially no mill closings in any of the three size categories, even under the need to treat wastes
according to best available technology.
f. Category 7 — Scenario of Stock and Yarn Dyeing
(1) General Description. Category 7 includes plants which clean, dye, and finish
fiber stock or yarn. The plants may or may not have yarn-spinning facilities. Sewing thread
and textile and carpet yarn are typical products. According to the 1967 Census of
Manufactures, 192 establishments were engaged in the dyeing and finishing of yarn, stock,
and narrow fabrics. We estimate that 90 plants in the country perform dyeing and finishing
only, on a commission basis, and hence will potentially be impacted significantly by the
guidelines.
A strong trend is occurring in which mills in this group are changing from
commission dyeing to buying their own yarn, dyeing and finishing it, and then selling it.
These integrated operations will make them much less susceptible to impact by compliance
with the guidelines.
About 60 percent of yarn dyeing activity is divided between Virginia, North
Carolina, South Carolina, Georgia and Alabama, with the remainder distributed across other
eastern and western states.
Most of the small and medium sized independent mills are commission
houses located in the Northeast Region. Such commission establishments are disappearing in
favor of integrated mill operations.
80
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TABLE 3-13
REPRESENTATIVE KNIT FABRIC DYEING AND FINISHING MILLS*
Very Small Mill
Small Mill
Medium Mill
Sales
Profit (before taxes)
Profit (after taxes)
Depreciation
Debt Repayment
Cash Flow
Salvage Value
Cost Structure
Fixed
Variable
Production
Employment
Work Week
Water Use
$ 1,015,162
0-5%
SO - 50,758
0 - 3.2%
$0 - 32,894
$101,516
$ 40,606
$60,910-93,804
$335,003
28%
$270,394
72%
$694,010
1,897,500 Ib/yr
7,590 Ib/day
19
5 day 3 shift
38MGY
0.15MGD
20gal/lb
1,783,0003,576,470
10- 15%
178,300-536,471
5.6 - 8%
99,216-285,465
178,300-357,647
71,320- 118,024
285,280 - 525,088
588,390- 1,180,235
28%
$450,000 - 840,000
72%
$1,155,000-2,200,000
3,000,000 - 6,000,000 Ib/yr
10,000-20,000 Ib/day
25-50
5 day, 3 shift
70- 140MGY
0.2-0.4MGD
20 gal/lb
5,082,500
10
508,250
5.3
270,790
508,250
203,300 •
575,740
1,677,225-
8,560,000
15%
1,284,000
7.9%
674,180
856,000
342,400
1,187,780
2,824,800
28%
1,368,000- 2,112,000
72%
3,511,200- 5,420,800
9,500,000 - 16,000,000 Ib/yr
30,000 - 50,000 Ib/day
75- 125
5 day, 3 shift
210- 350 MGY
6.6- 1.0 MGD
20gal/lb
*lf greater profit appears as expected, within the next 6 months or so.
Assumption: A return to a 15% profit, before taxes, for the larger, well-run plants.
Most dyed yarns are used in woven fancy piece goods, Jacquard knits, and
carpets, which constitute a strong segment of the current textile market.
Stock-dyed fiber is losing importance. Stock dyeing was used to obtain yarns
containing fibers of different shades; i.e., blended from different stock fibers. Use of newly
developed specific cationic dyes provides a similar effect in single-bath piece dyeing (after
weaving or knitting) at a lower production cost and provides a rapid turnaround of
inventories and quickened delivery to the customer.
(2) Process Description. The raw material for the plants of Category 7 is staple
or filament yarn. The yarn may consist of either natural or synthetic fibers or a blend of
both. Wet processes used by yarn mills include scouring, bleaching, mercerizing, and dyeing.
Yam dyeing is different from woven fabric dyeing inasmuch as there is no desizing
operation. It is different from knit fabric dyeing because its water use is significantly
smaller.
Several techniques for processing raw yarn into the finished product are
available. The most common process is probably package dyeing, but other processes, such
81
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as space dyeing, are widely used as well. In the former process, yarn wound on perforated
tubes is placed in a large vessel, which is then sealed. The dye solution is circulated through
the yarn at an appropriate temperature. The dyed yarn is then washed, rinsed, and dried. In
space dyeing, yarn is knit and the fabric is piece-dyed, washed, rinsed, and dried. The fabric
is then unravelled and the yarn is wound onto cones.
(3) Composite Model. A representative small or very small mill dealing in this
category might be a small northern yarn mill with some of its buildings dating from the late
1800's with newer sections built in the 1920's, and then modified in the 1950's. Some
production equipment might be 30 years old with some pressure dye kettles being less than
5 years old. The average age of the equipment might range from 8 to 10 years.
A representative medium sized mill might be an urban-type mill located in
one of the mid-Atlantic states. This mill would likely be a commission dye house which
buys its own yarn, dyes it, and then sells it to its customers (formerly the customer owned
the yarn). Thus the mill would have appreciable capital tied up in yarn inventory. The age of
its equipment would vary considerably, as with the small mills, with some of its machines
being 30 or more years old and some relatively new, since the medium sized mills generally
have a regular capital improvement program.
The medium sized mill would likely process both synthetic and natural
fibers, including wool, but it would not likely have space for treatment facilities. Any
treatment required would have to be performed in some of its present production or
warehouse space, as they may be space-limited. Tables 3-14 and 3-15 present typical ranges
of the various business facets of the very small, small and medium size mills involved in
Category 7 operations.
We estimate that a representative very small size mill would have sales of
$916,400, per year. Industry sources report profits, before taxes, ranging from 0 to 5%. On
this basis, we estimate an after-tax profit ranging from 0 to $30,300. Because newer
equipment has been installed in these mills in recent years, the depreciation expense may be
in the order of $64,200 and become a major contributor to the cash flow. To isolate the
impact upon a mill performing dyeing and finishing only, we assumed that the representa-
tive mill would be a commission dye house.
The representative small size stock and yarn dyeing mill (also assumed to be
a commission dye house) would have sales ranging from a low of $916,400 to a high of
$2,687,500. The representative medium size mill would have sales ranging from $2,687,500
to $5,375,000. For purposes of this study, however, mills within this category having sales
greater than $5,000,000 were assumed to be large plants that would be substantially
unaffected (minimal impact) by pollution control as promulgated in the proposed effluent
guidelines. As a composite of mills of medium size operating within this category, we
estimate that profits, before taxes, would range from 4 to 6%. On that basis, after-tax
profits would range from $62,400 to $174,200. As in the case of the small mill, recent
82
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TABLE 3-14
REPRESENTATIVE VERY SMALL STOCK AND YARN DYEING MILL
Sales $916,400
Profit (before taxes) 0-5%
0 - $45,800
Profit (after taxes) 0-3.3%
0 - $30,300
Depreciation $64,200
Debt Repayment Not Known
Cash Flow $64,200 - $94,500
Salvage Value $229,000
Cost Structure
Fixed 24%
219,900-202,500
Variable 76%
696,500-668,100
Production 1,705,000 Ib/yr
6,820 Ib/day
Employment 19
Work Week 5 day, 3 shift
Water Use 52,514,000 GPY
150,040 GPD
22gallon/lb
Note: This industry subcategory probably won't be
affected by the vertical integration picture, as in
Category 5, but it is becoming technologically
obsolete with significant impact expected in
3-5 years. (Texturized filament yarns of differen-
tial dye affinity permit wearing pattern in the
greige and developing colors in a single dye bath.)
83
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TABLE 3-15
REPRESENTATIVE SMALL SIZE AND MEDIUM STOCK AND YARN DYEING MILLS
Sales
Profit (before taxes)
Profit (after taxes)
Depreciation
Debt Repayment
Cash Flow
Salvage
Cost Structure
Fixed
Variable
Production
Employment
Work Week
Water Use
Small
$916,400-$2,687,500
$0-$134,400
0-5%
$0 - $76,400
0 - 2.8%
$64,000-$138,100
Not Known
$64,000 - $264,500
$229,100-$671,900
$202,500 - $593,750
23%
$668,100-$1,959,400
77%
1,705,000-5,000,000 Ib/yr
6,820- 16,000 Ib/day
20-40
5 day, 3 shift
52.5- 123 MGY
0.15-0.35MGD
22 gal/lb
Medium
$2,687,500 - $5,375,000
$107,500-$322,500
4 - 6%
$62,400-$174,200
2.3 - 3.2%
$188,100-$376,250
Not Known
$250,500 - $550,500
$671,900-$1,343,750
$593,400-$1,175,000
23%
$1,986,600-$3,877,500
77%
5,000,000 - 10,000,000 Ib/yr
16,000-32,000 Ib/day
40-80
5-6 day, 3 shifts
52.5 - 246 MGY
0.15-0.70MGD
22 gal/lb
investments in new equipment would produce higher depreciation expenses, which would,
in turn, contribute significantly to the cash flow. On the basis of these assumptions the cash
flow would range from $250,500 to $550,5UO.
While these composite mills — being representative of small and medium size
stock and yarn dyeing mills — do not embrace all possible financial and production
combinations, they are merely meant to be representative of their size within each category.
The water use for the mills interviewed during this study was found to be
higher than that used in the representative plants described here, although not substantially
so. This latter water use, in fact, conforms with the proposed guidelines which assume
"in-process changes" which will substantially reduce the use of water in many cases. For
purposes of this study, we have assumed that the reduction in water use will be achieved
through process change which will not involve significant cost either for new equipment or
modification of existing equipment. If, in fact, it becomes necessary to make a substantial
investment in equipment or in the modification of existing equipment, the associated cost
would have to be included in the impact upon the mill. As with many other facets of the
impact, this would have to be considered on a mill-by-mill basis and cannot be treated as a
generality.
84
-------
(4) Waste Treatment System Costs. Investments and operating costs for waste
treatment for the three size groupings of mills in this category are calculated for the various
proposed levels of treatment and presented in Appendix A.
The guidelines may be met by discharging the effluent to a municipal
treatment plant or by self-treatment. In the case of municipal treatment, we assumed that
the effluent would be pretreated, requiring an investment in equipment and an associated
annual operating cost. The operating expense includes municipal charges of $31,200,
$43,800 and $84,800 for the very small, small and medium sized mills, respectively, and is
based on a 40
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86
-------
The cash flows as presented in this table are drawn from Tables 3-14 and
3-15 for the composite mill of each size. As described in the introduction of this chapter, we
have measured the impact on this category by assuming that, if the annual treatment costs
produce a negative cash flow, then the plant (mill) will close. Further, we assumed the
distribution of cash flows to be linear through the ranges shown for each of the three size
groupings.
The impact of the proposed best practicable technology upon stock and yarn
dyeing mills, assuming either municipal treatment or self-treatment, is considered to be
negligible since the annual cost of treatment for municipal treatment and self-treatment is
in each case lower than the minimum cash flow for the size mill considered.
While the impact from the proposed best practicable technology is minimal,
we find the impact resulting from the proposed best available technology and new source
performance standards to be considerable in an economic sense for the small and medium
size mills. The add-on annual cost of treatment exceeds the annual cash flows of a portion of
our composite mills; therefore, following our assumption, some mills within these groups
would close if all were required to meet the guideline requirement of BAT. (Probably most
of these mills, however, will be connected to municipal systems and will have their own
pretreatment systems, for which costs are not much greater than the annual cost for
municipal treatment under the proposed best practicable technology.)
There are undoubtedly a few mills which are so borderline in their economic
posture as to declare a mill closing if faced with any of the additional costs due to meeting
the proposed guidelines. Implementation of these guidelines will, therefore, only hasten the
closing of such marginal activities rather than being the cause of such closings.
In summary, plants in this category discharging to municipal treatment
plants would probably not close, while many mills having to conform to a BAT guideline
would close.
(6) Price Effects. The price of finished yams is flexible since they are used
principally in woven fabrics of the fancy type, Jacquard knits and carpets and all three
end-use markets are currently strong. Therefore, assuming no federal restrictions on the
procedure, the short-term view indicates that the price increases in this category may be
passed on to the ultimate consumer.
For the representative mills, the price increases necessary to cover the costs
of meeting the guidelines in dollars per pound (assuming a direct pass-on) are:
Very Small Small Medium
Municipal $0.0183 $0.0131 $0.0113
Self-Treatment 0.0194 0.0122 0.0080
Zero Discharge 0.0303 0.0767 0.0504
87
-------
These costs would be added to a current charge of roughly $0.54 per pound.
(7) Secondary Effects. If price increases in this segment of the industry can
occur, they may be passed on through the weaving, knitting, and carpet mills where this
price will be marked up by 15% on the price charged for woven and knit fabrics and
carpeting, on the average. This last figure will be a direct increase in cost to the carpet
purchaser; the cost increase on fabrics will receive another markup by the converters before
purchase by the ultimate consumer.
The larger companies (not considered in the study) may increase their own
interplant costs (if allowed under federal pricing guidelines) where they have not already
done so. Even if they do not, the small commission dyer may still have some flexibility of
charging up to a 10% premium for his services in fulfilling his normal role of supplying the
aftermarket for small-lot re-orders.
(8) Financial Effects. The "before tax" profitability of the representative mills
would decrease, as a percentage of sales, due to the annual cost of meeting guidelines,
according to the following schedule:
Percent Municipal BPT, Self- BAT, Self-
Profit Treatments Treatment Treatment
Very Small Mills 0-5% 3.4% 2.4% 2.1%
Small Mills 0-5% 4.8% 2.3% 1.5%
Medium Size Mills 4.6% 5.6% 14.3% 9.4%
Capital availability should not provide a major problem to most mills since
they can divert capital from normal reinvestment programs or acquire debt financing.
(9) Production Effects. There will be little effect on production since mill
closings are expected only when small- and medium-size mills must treat their own wastes
and meet best available technology guidelines. In this case, the production would be expected
to decrease by 111 million pounds of finished yarn per year from the small mills, and 24.9
million pounds per year from the medium size mills. Growth, however, may slow down
somewhat since the capital normally assigned for new equipment, modernization (including
instrumentation), and expansions will be tied up for several years by the need to meet the
guidelines.
(10) Employment Effects. As in the "Production Effects" discussion above, there
will be little impact on employment levels primarily in the cases where the small- and
medium-size mills must meet best available technology treatment, by self-treatment. An
estimate of employees affected is 886 for the small mills and 199 for the medium sized
ones. Even employment displacement from the Northeast and Mid-Atlantic Regions
probably will not occur, since expansion of even the more profitable high-volume work in
the Southern Region is being held up due to a labor shortage and rapidly rising labor costs.
-------
The slowdown in industrial growth will cause a temporary halt in providing
increased jobs for a growing population, from mill expansions in the medium sized mills.
(11) Community Effects. Effects on the communities will likely be negligible on
the basis of the foregoing analysis, for achievement of best practicable treatment. In
attaining best available treatment, however, as in other categories, the mill shutdowns will
probably often be in relatively small communities where the mill constitutes a significant
part of the local employment.
(12) Balance of Trade. There will be negligible impact in the balance of trade
picture as well.
89
-------
-------
APPENDIX
WASTE TREATMENT MODEL FOR TEXTILE EFFLUENT GUIDELINES
1. BEST PRACTICABLE TREATMENT TECHNOLOGY (LEVEL I)
The proposed Level I guidelines are based primarily on secondary biological treatment.
The BOD levels proposed by EPA are assumed to be met by extended biological treatment
which also reduces COD. But, by definition, COD consists essentially of refractory organic
compounds which are not degraded readily by biological treatment. The available data on
COD reduction in a biological system and the ultimate effluent levels which can be achieved
are quite limited.
Costs for Level I guidelines have been 9alculated on the assumption that extended
biological treatment would enable the plant to meet the guidelines for BOD and COD. For
some plants this level of treatment alone may not be adequate to meet Level I guidelines
and tertiary treatment may be required.
To reflect the very different treatment economics between small and medium plants,
costs have been developed for three plant sizes in each industry category (except Cate-
gory 1). Treatment plant size is based on actual production and the assumed water use
(gal/lb product) from the EPA guidelines for that category. No allowance has been made for
increased in-plant costs to reduce water use, where plants have a higher water use rate than
the standard set for that category.
Information on actual treatment cost experience in the textile industry was available in
varying degrees of completeness from the exemplary plants visited. To verify the quality of
the data received and to provide a broader basis for estimation, a costing model was
developed based on standard wastewater treatment practice. This model covers both capital
and operating costs for the equivalent of what appears to be the best technology currently
practiced by the industry: essentially primary and secondary treatment as extended aeration
with stabilization ponds. Over a plant size range of 400-12,000 cubic meters per day (0.1 to
3.0 mgd) the cost experience data from the plants visited came within ± 30 percent of that
predicted by the cost model. The costs calculated from the model, therefore, are believed to
be realistic bases for estimating the (replacement) value of existing facilities and the
economic impact of further secondary-type treatment requirements.
The cost data used were derived from varied industrial and municipal applications.
They are adjusted where possible to reflect specific changes necessary for the textile
industry. Costs have been adjusted to the national average cost level of 1973, using
the ENR Construction Cost Index. The estimated cost curves have been adjusted to exclude
unusual construction or site-specific requirements. The curves include all elements of
construction cost which a contract bidder would normally encounter in completing the
wastewater treatment. Included are building materials, labor, equipment, electrical, heating
91
-------
and ventilation, normal excavation and other similar items. Also included are the engi-
neering costs. The annual operating costs include operation and maintenance labor, chemi-
cals, power, material and supplies, and depreciation.
a. Land Available. The best practicable treatment technology in this industry, when
land is available, is considered to be the end-of-pipe treatment steps shown in Figure A-l.*
• Primary Treatment: For removal of suspended solids, including screening
and chemical coagulation or precipitation (to remove heavy metals where
required); and
• Secondary Treatment: Primarily for removal of BOD5, including aerated
stabilization basins, sludge recycle and disposal, and final clarification with a
long-duration polishing lagoon and chlorination. (Land and landfill require-
ments are very small.)
A description of the major cost elements is given below.
(1) Primary Treatment. This consists of grit removal and flow measurement as a
means of protecting subsequent facilities from excessive wear and deposition of grit,
including pH control, screening, and coagulation. Costs include flow channels and super-
structures, grit handling equipment, electrical, heating, ventilating, and auxiliary equipment
as required.
(2) Aerated Stabilization Basin System. The lagoons are sized for a given reten-
tion time (determined on the basis of available treatability data) with a depth of 7 feet.
These data were extended to the higher inlet and lower effluent BOD levels by assuming
constant ratios of biological characteristics to be applicable over the entire range. Costs
include lagoon construction, access road, outfall sewer, fencing, seeding, and other construc-
tion work (excluding costs for aeration equipment). The costs of aeration equipment are
based upon mechanical surface aeration equipment sized on the basis of 50 Ib BODS per
horsepower-day. Good design practice dictates that total requirements be divided between
two or more aerator units. In addition, a complete spare unit is provided. Costs include the
aerator motor, gearbox, impeller, draft tube, supporting structure, and applicable electrical
work.
The sludge lagoons are sized for 5-months' retention with an 8-inch depth.
Sludge production is small (0.2 Ib sludge/lb BODS removal and 1 Ib sludge/lb suspended
solids removal). Cost includes normal excavation, dike construction, and sludge distribution
piping. Sludge pumps are designed for periodic operation only. Nutrient addition is based
upon: nitrogen at 0.008 Ib/lb BOD5. Costs are included for periodic hauling of the
accumulated sludge to landfill.
'Points on all curves are calculated rather than data points.
92
-------
Raw Wastewater
Primary Screening
Primary Settling
(Wool Scouring Only)
Aeration
Stabilization
Basin
j)
u
u
0)
QC
Clarifier
Three-Day
Non-Aerated
Lagoon
Final Discharge
FIGURE A-1 SCHEMATIC FLOW DIAGRAIVTOF PROCESS STEPS
AND COST CENTERS FOR LEVEL I TREATMENT
93
-------
(3) Clarification. Basin construction costs are related to surface area, since the
range of normal liquid depths is relatively small. These costs generally decrease as the basin
size is increased. It is considered good practice to provide at least two independently
operated basins. The size is based upon an overflow rate of 600 gpd/ft2 and a depth of 12
feet. Costs include all necessary excavation, backfill, concrete, mechanical and electrical
equipment, piping, and other work related to the basin construction.
(4) Non-Aerated Lagoon. The lagoon is sized for a 3-day retention time with a
depth of 7 feet. Costs include lagoon construction, access road, outfall sewer, fencing,
seeding, and other construction work.
(5) Chlorination. Chlorine is added to wastewater during the treatment process
as an aid to treatment and for disinfection prior to discharge of effluent to a receiving
stream. The cost of chlorine varies with the quantity used and the distance between the
point of manufacture and the point of use. Our cost estimates are based upon the purchase
of chlorine in 150 or 2,000 pound cylinders. About $0.15 per pound might be a maximum
at a small plant distant from the manufacture point and $0.03 per pound a minimum. The
construction costs include the chlorination equipment, chlorine feed building, chlorine
storage building and handling equipment and scales. The contact basin is sized for 30-minute
detention.
(6) Other Contributions to Capital Cost.
(a) Yard work. The cost of a treatment plant also includes costs of general
site clearing and grading, intercomponent piping, lighting, control structures, road paving,
and other items outside the structural confines of an individual plant component. These
items are commonly called yardwork and are included in the construction cost as an
additional 15% of the total construction cost of the individual steps.
(b) Engineering Costs. Engineering costs are based upon the total construc-
tion cost, including yardwork.
(c) Land Requirements. Land requirements have not been included in the
initial capital investment. Typically mills do not include this cost in their total cost of waste
treatment. However, land is a legitimate cost factor to the extent that textile mills have- to
buy new land,-especially in urban areas, for wastewater treatment. The costs developed here
are therefore biased on the low side.
(7) Description of Operating Costs.
(a) Material and Supply Costs. Material and supply costs (all of the opera-
tion and maintenance items, excluding chemicals and power) are related, where appropriate,
to the same sizing parameters used for construction costs.
94
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(b) Chemical Costs.
(1) pH Control:
Lime $24/ton
Sulfuric acid $34/ton
(2) Sedimentation Aids. It is assumed that only polyelectrolytes (at
0.5 ppm) will be used in the clarifiers to aid the sedimentation step. Several combinations of
polyelectrolytes, alum, and ferric chloride are commonly used. Their costs are:
Polyelectrolytes $1.25/pound
Ferric chloride $0.04/pound
(3) Nutrients. Nutrients will be added to the activated sludge treat-
ment as follows: nitrogen at 0.8 lb/20 Ib BOD, and phosphorus at 0.5 lb/100 Ib BOD.
Considerably less nutrients will be added to the aerated stabilization basins: nitrogen at 0.16
lb/20 Ib BOD, and phosphorus at 0.1 lb/100 Ib BOD.
Ammonia (25%) $32.50/ton
Phosphoric Acid (72%) $82.80/ton
(8) Operation and Maintenance Labor. The annual labor requirements are
related, where appropriate, to the same sizing parameters used for construction cost
estimates. Requirements were based upon a man-year consisting of 52 weeks at 40 hours per
week, or a total of 2,080 hours per year.
Operation man-hours x $5/hr = direct operation labor cost
Maintenance man-hours x $5/hr = direct maintenance labor cost
(a) Energy and Power Cost. Power costs are related, where appropriate, to
the same sizing parameters used for construction costs. Costs were based upon: $0.015/kwh
and 70% motor efficiency. Fuel costs were based on fuel oil at $ 1.00 million Btu and steam
at $1.50 million Btu.
(b) Landfill Costs. Two costs were considered for landfill operations:
handling and. burial. Handling charges were costed at $0.25/cu ft of solids generated from
incineration; burial costs were based on $ 15 per dry ton of solids.
Cost curves developed from the cost model are presented in Figures A-2
through A-14. (For very small plants, about 110 cu m/day or 30,000 gpd and an overall cost
figure of $1.00 for 1 gpd was assumed.) Figures A-6 through A-14 present the operating and
maintenance costs over the ranges of production found. The initial capital cost of biological
treatment systems depends mainly upon (and here is related to) the hydraulic load, the
other factors making only minor variations in the total cost. Operating costs, on the other
hand, have been viewed as dependent on pollutant as well as hydraulic loads.
95
-------
1,000,000
o
D
o
o
100,000
C
O
o
10,000
10.0
FIGURE A-2 AERATED STABILIZATION BASIN
CONSTRUCTION COST
96
-------
10,000
_ 1,000
o
o
O)
c
O)
c
LLJ
100
10
100
1,000 10,000
Total Construction Cost, ($000)
100,000
FIGURE A-3 ENGINEERING COSTS
97
-------
o
Q
O
o
c
o
'
Ui
8 10x105
1 x 10a
1.0
10.0 100.0
Flow, mgd
FIGURE A-4 CLARIFIER CAPITAL COST
98
-------
10 x 105
o
Q
I
I 1.0x105
i
4-1
I/)
O
o
1,000
y = 67.31 X °'837
10,000
BOD removal, Ib/day
100,000
FIGURE A-5 AERATED STABILIZATION BASIN
(Aeration Equipment Only)
99
-------
10,000
o
g
1,000
100
1.0
y=1009X°'446-
Operation
Maintenance
,y=183.2X°'486
I I 1 I J_
10.0
Flow, mgd
100.0
FIGURE A-6 AERATED STABILIZATION BASIN
ANNUAL OPERATION AND MAINTENANCE LABOR
100
-------
10,000
100
10.0
Flow, mgd
100.0
FIGURE A-7 AERATED STABILIZATION BASIN
1. Material and Supply Costs
2. Chemical Costs
101
-------
100,000
o
Q
*•»
10,000
1,000
1,000
I I I I I 1
y "1.762XOJ
10,000
BOD removal, Ib/day
100,000
FIGURE A-8 AERATION EQUIPMENT
ANNUAL POWER COSTS
Aerated Stabilization Basin
102
-------
10,000
o
c
(0
1,000
c
c
100
1.0
y = 604 X
0.292
Operation
Maintenance
i I
y = 152.4 X0-695
10.0
Flow, mgd
100.0
FIGURE A-9 CLARIFIER, ANNUAL OPERATION AND MAINTENANCE LABOR
103
-------
100,000
o
Q
tt
<3 10,000
ce
3
1,000
Material and Supply Costs
10.0
Flow, mgd
100.0
FIGURE A-10 CLARIFIER
1. Material and Supply Costs
2. Major Chemical Costs
104
-------
100,000
o
Q
o
O
c
o
C
O
o
10,000
1,000
10.0
FIGURE A-11 CONSTRUCTION COST - THREE-DAY
NON-AERATED LAGOON
105
-------
1,000,000
"5
Q
u
c
o
C
O
o
100,000
10,0001
0.1
10.0
Flow, mgd
FIGURE A-12 CHLORINATION - CONSTRUCTION COSTS
(Aerated Stabilization Basin System)
106
-------
10,000
1,000
o
c
03
to
D
C
100
10
0.1
= 372x"542
y = 62.04 x-317
i i i i i
Operation
Maintenance
i i i i i i i i
1.0 10.0
Flow, mgd
FIGURE A-13 CHLORINATION - ANNUAL OPERATION AND
MAINTENANCE LABOR
107
-------
100,000 c
10,000
o
a
o
o
c
<
1,000
100
0.1
1.0
10.0
FIGURE A-14 CHLORINATION - CHEMICALS AND MATERIAL
AND SUPPLIES
108
-------
Costs for representative plants in industry categories were developed
using these curves and assuming an aerated stabilization basin, which is widely used by the
industry when land is readily available. The following items were determined for the
individual treatment steps:
(1) Construction cost as a function of hydraulic load at a given
pollutant level;
(2) Operating and maintenance labor as a function of hydraulic load;
(3) Chemical requirements as a function of hydraulic and pollutant
load;
(4) Power requirements as a function of hydraulic and pollutant load;
and
(5) Additional material and supply cost as a function of hydraulic
load.
b. Land-Limited Waste Treatment. For those plants with only limited space avail-
able, extended aeration and lagoon systems are inapplicable, and a model based on high-rate
activated sludge has thus been developed. No textile plants currently are using this system,
so the model necessarily had to be developed using data from other industries. Unit
operation includes equalization, primary and secondary sludge handling, and an activated
sludge unit. Effective BOD5 removal is achieved through increased nutrient addition and
residence time in the activated sludge unit. Sludge production is greater than in regular
secondary treatment, and thus sludge handling becomes a major contributor to capital
investment. A schematic flow diagram of the process steps is presented as Figure A-15. Cost
curves developed for the cost model are presented in Figures A-16 through A-26. A
description of the design elements in the model is provided below.
(1) Equalization. The cost is based on one-half day retention to protect the
following system components from upsets. This includes the cost of a stirring mechanism
and pumps where necessary.
(2) Primary Sludge Handling from Primary Clarifier.
(a) Primary Sludge Pumping. A common design includes a sludge pumping
station for each pair of sedimentation basins. Each station is equipped with three pumps;
one sludge pump for each basin and a single scum pump. They are identical and their piped
installed capacity is 150 percent of firm capacity. Total construction costs include normal
earth work, station structures, piping and pumping equipment, electrical, ventilating and
heating.
(b) Solids Holding Tank. One-day capacity for primary sludge.
109
-------
Raw Wastewater
Sludge
Handling
Sludge
Disposal
Aeration
Stabilization
Basin
Sludge
Recycle
Sludge
Handling*
Sludge
Disposal
Final Effluent
FIGURE A-15 SCHEMATIC FLOW DIAGRAM OF PROCESS STEPS AND
COST CENTERS FOR HIGH-RATE ACTIVATED SLUDGE
110
-------
100,000 C
o
D
o
o
o
3
c
o
O
10,000
1,000
1,000
I I I I I I I I
y = 1542x
10,000 100,000
BOD Removal, Lb/Day
FIGURE A-16 CONSTRUCTION-ACTIVATED SLUDGE UNIT PROCESS
111
-------
1,000,000
"5
Q
4-1
s
o
o
I
o
-------
1 0
10.0
100
Flow, mgd
FIGURE A-18 SLUDGE HANDLING-CONSTRUCTION COST
113
-------
100,000
o
I
ra
D
c
c
10,000
1,000
1,000
10,000
BOD Removal, Ib./day
100,000
FIGURE A-19 ANNUAL OPERATION AND MAINTENANCE LABOR -
ACTIVATED SLUDGE UNIT PROCESS
114
-------
1,000
o
I
c
ro
to
13
C
C
100
10
1.0
165
Operation
Maintenance
-0-
I i i i i I i
•©'
©"
30
10.0
Flow, mgd
100.0
FIGURE A-20 ANNUAL OPERATION AND MAINTENANCE LABOR - EQUALIZATION
115
-------
100,000
10,000
o
c
OJ
c
c
1,000
100
1.0
I I I I I I I I
Operation
(Sludge to Landfill)
Operation
'(Sludge to Landfill)
Maintenance
10.0
100
Flow, mgd
FIGURE A-21 SLUDGE HANDLING - OPERATION AND MAINTENANCE
116
-------
100,000
o
Q
o
o
C
C
10,000
1,000
Material and
Supply Costs
100.0
FIGURE A-22 ACTIVATED SLUDGE UNIT PROCESS COSTS
1. Material and Supply Costs
2. Chemical Costs
17
-------
100,000
o
Q
ts
o
O
10,000
1,000
Materials
III!
1.0
10.0
Flow, mgd
100.0
FIGURE A-23 SLUDGE HANDLING - MATERIAL AND SUPPLY COSTS -
MAJOR CHEMICAL COSTS
118
-------
10,000 r
o
Q
tt 1 ,000
o
o
3
c
c
100
1.0
I I
y = 64.5 x
I i i i i i
10.0
Flow, mgd
100.0
FIGURE A-24 ANNUAL MATERIAL AND SUPPLY COSTS - EQUALIZATION
119
-------
100,000
o
Q
o
o
To
3
C
C
10,000
1,000
1,000
y = 2x
.969
I I I I I I I I
10,000
BOD Removal, Ib/day
100,000
FIGURE A-25 ANNUAL POWER COSTS - AERATION
EQUIPMENT - ACTIVATED SLUDGE
120
-------
10,000
o
Q
o
O
1.000
100
1,000
10,000
Suspended Solids Removal, Ib/day
100,000
FIGURE A-26 SLUDGE HANDLING - ANNUAL POWER COSTS
121
-------
(c) Centrifugation for Dewatering Sludge. The costs include centrifugation
equipment, sludge pumps and piping, sludge cake conveyors, equipment hoists, electrical
facilities, and an enclosing structure. Capacity used here is the total installed capacity with
one centrifuge inoperative.
(3) Activated Sludge. The costs of the aeration basin (50 Ib BOD/1000 ft3
aeration basin/day) include normal structure related costs and exclude costs of aeration
equipment.
The costs are for mechanical aeration equipment (2-lb O2 /horsepower).
Good design practice dictates that the total be divided between two or more aerator units.
In addition, a complete spare unit is provided. Costs include the aerator motor, gearbox,
impeller, draft tube, supporting structure, and applicable electrical work.
Costs for a nutrient feed system — continuous operations (nitrogen at
0.81b/201b BOD, and phosphorus at 0.5 lb/100 Ib BOD) include feed and handling
equipment, feed building, storage building. The secondary clarifier has an overflow rate of
400 gpd/ft2, and the secondary sludge handling includes pumping, holding, and centrifuga-
tion.
c. Municipal Treatment. To comply with the proposed Level I guidelines, textile
mills may also send their wastewater to a municipal treatment facility. In doing so, certain
pretreatment steps would be necessary, including screening and an eight-hour retention
basin. The cost of treating the wastewater municipally can be added to the pretreatment
costs. A cost schedule has been developed for treatment of wastewater in a municipal
system within two size ranges. On a cents/1000 gal basis, this additional cost would be
$0.39 for a 10- to 20-mgd plant and $0.63 for a 1- to 3-mgd plant. Figures A-27 through
A-30 are the cost curves developed for pretreatment.
2. BEST AVAILABLE TREATMENT TECHNOLOGY (LEVEL II)
The costs for meeting Level II guidelines have been calculated on the assumption that
multimedia filtration and/or activated carbon adsorption would enable the plant to meet the
guidelines. Those plants specified in the guidlines as having no additional COD requirements
in Level II would only be required to install multimedia filtration units to meet the
guidelines. The larger plants would be expected to install activated carbon units. Also,
because they may find it necessary to put the multimedia filter in the system prior to the
carbon unit to avoid blockage problems, this cost has been included in our estimates also.
In determining the costs for the activated carbon adsorption it has been assumed that
60% removal of the COD would be achieved and that the carbon loading would be 0.07 Ib
COD/lb of carbon at a bed volume per hour flow rate of 0.5, i.e., 120 minutes contact time
in the adsorbers. Capital and operating costs have been prepared using the input parameters
of millions of gallons per day and pounds of COD per day applied to the activated carbon
system. Capital investment and operating costs were based on data from references 3, 4, 5.
Figure A-31 shows the process steps involved. Cost curves developed for the cost model are
shown in Figures A-32 through A-39.
122
-------
100,000
o
O
tt 10,000
o
o
c
O
o
u
1,000
I I 1 I I I 1
10.0
FIGURE A-27 SCREENING PRIOR TO MUNICIPAL TREATMENT
(CONSTRUCTION COST)
123
-------
1,000,000
o
Q
u 100,000
o
10,000
10.0
FIGURE A-28 HOLD-UP PRIOR TO MUNICIPAL TREATMENT
(8 HOURS) - CONSTRUCTION COST
124
-------
10,000
o
I
£ i,ooo
C
C
100
10.0
FIGURE A-29 TREATMENT PRIOR TO MUNICIPAL - ANNUAL
LABOR MAN-HOURS
125
-------
10,000
o
Q
4
o
o
3
C
1000
100
10.0
FIGURE A-30 TREATMENT PRIOR TO MUNICIPAL - ANNUAL
MATERIAL AND SUPPLY COSTS
126
-------
Raw Wastewater
Primary Screening
I
Primary Settling
(Wool Scouring Only)
Aeration
Stabilization
Basin
Activated
Carbon
Adsorption
Final Discharge
FIGURE A-31 SCHEMATIC FLOW DIAGRAM OF PROCESS STEPS
AND COST CENTERS FOR LEVEL II TREATMENT
127
-------
te 1,000,000
o
Q
O
O
O
V-1
o
3
c
o
O
100,000
i i i i i i
0.1
1.0 10.0
Average Plant Capacity
FIGURE A-32 MULTI-MEDIA FILTRATION - CONSTRUCTION COSTS
128
-------
10.0
5.0
o
Q
2.0
o
1.0
c
* 0.5
'5.
0.2
0.1
0.1 0.2
i i i
y = 780,000 x
0.673
(Activated Carbon System
Excluding Regeneration System
See Figure A-34)
I I I 111!
0.5
1.0
mgd
2.0
5.0 10
FIGURE A-33 CAPITAL INVESTMENT-ACTIVATED CARBON SYSTEM
129
-------
10
4.0
I 2.0
D
c
g
i 1.0
c
ID
4->
I
0.1
1,000
= 4495x
°-602
Regeneration System
I I I
10,000
Ib COD/Day in Feed to Activated Carbon Adsorption
100,000
Note: Below 700 Ib COD/Day Investment = $225,000
FIGURE A-34 CAPITAL INVESTMENT-REGENERATION SYSTEM
130
-------
o
I
c
to
C
C
1,100
100
1.0
10.0
Flow, mgd
100.0
FIGURE A-35 MULTI-MEDIA FILTRATION - ANNUAL OPERATION AND
MAINTENANCE LABOR
131
-------
1.0
0.3
« 0.2
Q
I 0.1
8
o
•S 0.05
D
C
C
0.02
0.01
1,000
i i i I i t
I I I I I I I I
10,000
100,000
Ib COD/Day in Feed to Activated Carbon Adsorption
FIGURE A-36 LABOR COSTS - ACTIVATED CARBON ADSORPTION
132
-------
10,000
o
Q
O
O
C
1,000
100
1 I I I
1.0
10.0
Flow, mgd
100.0
FIGURE A-37 MULTI-MEDIA FILTRATION - ANNUAL MATERIAL AND
SUPPLY COSTS
133
-------
10,000 cr
0)
~
LU
o
X
2
1 ,000
100
10
100
I till
I 1 I I I I 11
Electricity Consumed
per Year (Carbon
Regeneration)
1 I i I I I 11
1,000 10,000
Ib COD/Day in Feed to Activated Carbon Adsorption
FIGURE A-38 ENERGY COSTS - ACTIVATED CARBON ADSORPTION
134
-------
1.0
o
Q
O
5 0.1
o
o
C
0.01
I I I I
1,000 10,000 100,000
Ib COD/Day in Feed to Activated Carbon Adsorption
FIGURE A-39 CARBON REPLACEMENT ANb FUEL COSTS -
ACTIVATED CARBON ADSORPTION
135
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REFERENCES
1. Ford, D.L., "The Applicability of Carbon Adsorption in the Treatment of Petro-
chemical Wastewaters" - Conference on "Application of New Concepts of Physical-
Chemical Wastewater Treatment" - Vanderbilt University, September 18-22, 1972.
2. Lawson, C.T., and Fisher, J.A., "Limitations of Activated Carbon Adsorption for
Upgrading Petrochemical Effluents" - AIChE 65th Annual Meeting, New York, N.Y.,
November 26-30, 1972.
3. Advanced Wastewater Treatment as practiced at South Tahoe EPA Water Pollution
Control Research Series Report 17010 ELP, 08/71.
4. Advanced Wastewater Treatment — Gulp and Gulp -Van Nostrand-Reinhold, 1971.
5. Cost and Performance Estimates for Tertiary Wastewater Treatment Processes, R.F.
Taft Water Research Center Report No. TWRC-9, PB, 189953, June 1969.
6. The Economics of Clean Water, Vol. 3, U.S. Dept. of the Interior, Federal Water
Pollution Control Administration, (prepared under Contract No. 14-12-592) March
1970.
7. Cost of Wastewater Treatment Processes, Federal Water Pollution Control Administra-
tion, Ohio Basin Region, Cincinnati, Ohio, Report No. TWRC-6, Contract No.
14-12-60, December 1968.
8. Smith, R., Cost of Conventional and Advanced Treatment of Wastewater, U.S. Dept. of
the Interior, Federal Water Pollution Control Administration, Cincinnati Water Re-
search Laboratory, July 1968.
9. Estimating Costs and Manpower Requirements for Conventional Wastewater Treatment
Facilities, Black and Veatch Consulting Engineers, for EPA, Project No. 17090 DAN,
Contract No. 14-12-462, October 1971.
10. Treatment-Cost Relationships for Industrial Waste Treatment, Barnard and
Eckenfelder, Jr., Vanderbilt University. Technical Report No. 23, Environmental and
Water Resources Engineering, 1971.
11. The Cost of Clean Water and Its Economic Impact, U.S. Dept. of the Interior, Federal
Water Pollution Control Administration, January 10, 1969.
12. Industrial Pollution Control Handbook, Lund, H.F., McGraw-Hill, 1971.
136
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13. Advances in Water Quality Improvement, Gloyna and EckenfeMer, University of Texas
Press, Austin, Texas, 1968.
14. Advanced Wastewater Treatment, Gulp and Gulp, Van Nostrand-Reinhold, Co., 1971.
137
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II CIINICAI Rl I'ORT
DAI A I'ACII
I Report No.
EPA-230/1-73-028
3. Recipient's Accession No.
4 I ilk' and SiihhlK-
Economic Analysis of Proposed Effluent Guidelines Textiles Industry
5. Report Date
March 1974
6.
7 Aiithoiis)
Daniel Hefler
8. Performing Organization Rept.'No.
C-75910
'> IVilorinmg Organization Name and Address
Arthur D. Little, Inc.
Acorn Park
Cambridge, Mass., 02140
10. Project/Task/Work Unit No.
Task Order No. 10
11. Contract/Grant No.
68-01-1541
I 2 Sponsoring Organization Name and Address
Office of Planning and Evaluation
Environmental Protection Agency
Washington D.C., 20460
13. Type of Report & Period Covered
Final Report
14.
Supplementary Notes
l(> Abstracts
An initial analysis of the economic impact of proposed water effluent guidelines upon the Textile industry (SIC 221 to 224)
was performed based on abatement cost data supplied by EPA. The impact was evaluated for implementation of best
practicable control technology for mills with physical space and those that are space-limited, as well as for implementation of
best available control technology. Connection to municipal systems creates minimum impact. Self-treatment under best
practicable treatment also produces minimal impact. However, best available treatment will force most mills to close unless
they take the option of connecting to municipal systems. An addendum is included to cover an estimate of the impact of a
major revision to the guidelines accomplished after issuance of a draft of this report.
17. Key Words and Document Analysis. 17a. Descriptors
Economic Analysis
Effluent Guidelines
17b. Identifiers/Open-Ended Terms
I7c COSATI Held/Group
IS. Availability Statement
Limited Availability through U.S. Environmental
Protection Agency Information Center;
Room W-327, Waterside Mall, Washington, D.C., 20460
19. Security Class (This
Report)
UNCLASSIIHD
20. Security Class (This
Pace)
UNCLASSII IFD
21. No.ot'Papes
22. Price
1 ORM NT1S-35 (RKV. 3-72)
USCOMM-DC I4952-I'72
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