20367
                  ECONOMIC IMPACT ASSESSMENT FOR THE

            NATIONAL AMBIENT AIR QUALITY STANDARD FOR LEAD
             Office of A1r Quality Planning and Standards
                   Office of Air and Waste Manaqement
                 U.S. Environmental Protection Aqency
                        November 22, 1977

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                      ECONOMIC IMPACT ASSESSMENT
Chapter 1  Summary and Introduction
        1.1  Summary
        1.2  Introduction
Chapter 2    Stationary Source Assessment
        2.1  Primary Lead Smelting
        2.1.1  Industry Structure
        2.1.2  Model Plant Specifications and Dispersion Model Results
        2.1.3  Control Costs
        2.1/4  Model Plant Closure Assessment
        2.2  Secondary Lead Smelting
        2.3  Primary Copper Smelting
        2.4  Grey Iron Foundry Casting
        2.5  Gasoline Lead Additives Manufacturing
        2.6  Lead-Acid Battery Manufacturing
Chapter 3    Other Affected Sectors
        3.1  Mobile Source Assessment
        3.2  State and Local Control Agency Assessment

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1.0  SUMMARY AND INTRODUCTION
1.1  Summary
     The purpose of this analysis is to estimate the economic impact
which can be expected from a constant air quality for lead.  This analysis
examines three levels which are deemed to fall within the likely range of
the final standard.  It should be noted, however, that this economic assess-
ment is not a basis for selecting the standard 'since the Clean Air Act
requires that the standard be based solely on health and welfare criteria.
This assessment considers three possible standards:  1.0, 1.5, and 2.0
      (monthly average).  The economic impact assessment emphasizes the  impacts
upon stationary source  lead emitters but also discusses the  impacts upon
mobile source lead emitters and state and  local control agencies
charged with implementing the standard.
     Dispersion models  indicate that plants  in  at  least six  industries may
be required to install  control devices to  meet  the alternative  standards
under consideration.  These control devices  would  be  in addition  to those
control systems required by typical state  regulations for  control  of  particulate
or other emissions.  The six industries under consideration  are primary  lead
smelting,  secondary  lead smelting,  primary copper  smelting,  grey  iron foundries,
gasoline lead additive  manufacturing, and  lead-acid storage  battery manufacturing.
     The economic  impact assessment is based primarily upon  the use of model
plants and estimated emission factors.  The  model  plant emissions were used in
a meteorological dispersion model that predicts maximum ambient lead  concen-
trations.  The dispersion modeling  results were then  used  to estimate which
emission sources needed additional  control to meet the alternative ambient
standards  and the  extent of control required.   The resulting control
requirement then determined the type of control equipment  needed  and
the cost of the equipment.  Control costs  to meet  alternative standards  were
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then factored into a discounted cash flow model that served as the basis for
evaluating potential plant closures.
     As expected, the results of the economic impact analysis indicate
that model plants of the six industries mentioned above will be affected
in varying degrees by the alternative standards under consideration.  As
shown in Table 1-1, annual1zed compliance costs expressed as a percent
of model plant revenues range from  zero to over 7 percent depending upon
the level of the standard and the type of model plant being analyzed.
     It is possible that some plants, facing control costs of the magnitude
shown in Table 1-1, may choose to close rather than comply with emission
regulations required to achieve a given ambient lead standard.  An
analysis of this issue shows that,  for lead air quality  standards of
either  T.5 or 2.0 yg/ra3, potential  plant  closures may be possible in  the
      »                        *
primary lead industry, the  secondary lead industry, and  the  primary
copper  industry.  In addition, at an ambient standard of 1.0 ug/m   plant
closures may he  possible for some grey iron foundries.   Plant closures  are
not projected for gasoline  lead additive  plants or  lead-acid battery
plants  for any of the alternative standards under consideration.
     The  economic  impacts described above are  based upon a number of  factors
such as emission rates,  plant  profit margins,  and terrain and weather conditions
 in the  vicinity  of  the  source.  Since these variables are difficult to quantify
with any  reasonable degree  of-precision,  it must  be borne in mind that impacts
 at any  one  specific source  may vary considerably  from the impacts described here.
 It should be noted  that  a  rollback  analysis  (an  analysis that assumes a linear
 relationship between  the  percent  of air  quality  improvement and emission
 reductions)  indicated  that  only two industries—  primary lead smelting and

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                          Table 1-1.  RELATIVE COSTS OF ALTERNATIVE AMBIENT LEAD STANDARDS - MODEL
                                      PLANT ANNUALIZED COSTS AS A PERCENT OF ANNUAL REVENUE
                                                 Alternative Ambient Standards
                                                     (yg/m3 monthly average)
Model Plant Type
Primary Lead
Secondary Lead
Primary Copper
Grey Iron
Gasoline Lead Additives
Lead Add Batteries
2.0
0.9% to 7.7%*
7.4%**
0.0% to 3.3%
0.0% to 2.0%
0.2%
0.0% to 0.1%
1.5
1.2% to 7.7%*
7.4%**
0.0% to 4.3%
0.0% to 3.8%
0.2%
0.0% to 0.1%
1.0
1.8% to 7.

7%*
7.4%**
0.0% to 5.
0.0% to 6.
0.2%
0.0% to 0.
2%
2%

1%
 *The control efficiency of the costed system 1s assumed to be 95%.   At this  level  of efficiency the model  primary
  lead smelter with high fugitive emissions could only attain an air quality  standard of 3.9 ng/m3.

**The model secondary lead smelter with low fugitive emissions could meet a standard  of 2.0  ug/m3  with  an expen-
  diture of 7.4% using the 95% control system referred to above.  A  model  secondary lead smelter with high
  fugitive emissions, however, could only meet an air quality level  of 3.7 ng/m3  with the same

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primary copper smelting—would need to install  control  devices to meet the
alternative standards. 'This result is at variance with the dispersion analysis
upon which the stationary source economic impact assessment was based that
indicated six industries would need to install  control  devices.  This fact
emphasizes the effect of various modeling assumptions upon the results of
the economic impact analysis as well as the general problem of the variability
of the results depending upon various input assumptions.
     An analysis of potential impacts to mobile source lead emitters for the
ambient lead standards under consideration has also been developed.  This
analysis indicates that mobile sources in portions of one to four Air
Quality Control Regions, or a possible total of 58,000 to 1,300,000 vehicles,
may have to be controlled, assuming the ambient lead standard must be achieved
in 1982.  However, because of lead phasedown regulations and the increased
use of lead free gasoline for catalyst equipped vehicles, the total number of
mobile source lead emitters is expected to decrease after 1982.  One control
device that may be feasible for mobile sources is  a lead trap muffler.  Other
means of control include reducing vehicle miles traveled and further reducing
the lead content of gasoline.
     State and local air pollution control agencies will also  incur costs
to develop and implement plans to achieve an ambient air quality standard for
lead.  Total first year costs for all state and local agencies are estimated
to range from $1.0 - $1.7 million, or 0.6 - 1.0 percent of current expenditures.
Recurring costs are estimated to be $1.4 - $2.8 million, or 0.9 - 1.8 percent
of current expenditures.  Man-year requirements, both first-year and recurring,
are similarly estimated to be less than 2 percent  of current levels.

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1.2  INTRODUCTION
     This report assesses the cost and economic impact of alternative
ambient lead standards.  The stationary sources covered in the assessment
are model primary lead smelters, secondary lead smelters, gasoline lead
additive manufacturing plants, lead-acid battery manufacturing plants,
primary copper smelters, and grey iron foundries.  In addition, the
potential costs of mobile source emission control and of requisite state
and local control agency information, administration, and enforcement
activities for alternative standards are also estimated.  The alternative
standards considered are 2.0, 1.5, and 1.0 ug/m  , monthly average.  The
detailed methodology and documentation of the analysis are provided in
the report entitled "Background Document Supporting  the Economic  Impact
Assessment of the Lead Ambient Air Quality Standard".
1.2.1  Reasons for Selection of Sources for  Consideration
      In  1975, about 142 thousand metric tons of  lead were emitted nationwide.
Combustion of lead containing gasoline accounted  for 90% of  those emissions.
Combustion of waste crankcase oil, solid waste,  oil, and coal accounted  for
an additional 5% of national emissions in 1975.   The remaining  5% came from
19 industrial stationary source types.   As  a  result of  phasedown of  lead
in gasoline, lead emissions  from gasoline combustion are expected to
                                               2
decrease about 60% by  1985 from current levels.   Although  this is a  large
relative decline, gasoline combustion emissions  are  still  projected  to
be the greatest emission source nationally  in  1985.  Because of this,

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gasoline combustion sources (mobile sources) are included in the economic
impact assessment.
     Combustion of waste crankcase oil, solid waste, oil, and coal is not
                                             o
considered in the economic impact assessment.   Combustion of waste crankcase
oil is nqt considered because the phasedown of lead in gasoline will cause
combustion of waste crankcase oil to cease to be a major source.  Combustion
of solid waste is not considered in the analysis since many solid waste
combustion facilities (i.e., municipal incinerators) are scheduled to be closed.
Therefore, lead emissions from this source category will be substantially
reduced.  Finally, sources burning oil and coal are not considered since
dispersion modeling and ambient data analysis near these sources have indicated
that oil and coal combustion will probably not result in violations of any of
the alternative ambient standards under consideration.
     Growth projections as well as analyses of estimated emissions and measured
ambient impacts were developed for the 19 industrial stationary source types
previously mentioned.  As a result, 8 of the 19 were identified as sources
                                               4
probably requiring additional emission control.   These 8 industrial source
types are primary lead smelters, secondary lead smelters, primary copper
smelters, gasoline lead additives manufacturing plants, lead-acid battery
manufacturing plants, grey iron foundries, ferroalloy plants, and lead ore
crushing and grinding plants.  The economic impact assessment includes the
first six of the aforementioned source types.  Ferroalloy plants are not
considered in the economic impact assessment because dispersion modeling
indicated that emissions from a model ferroalloy plant in zero background-isolated

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source situations should not result in violations of any of the alternative
standards under consideration. Ore crushing and grinding plants are not
considered in the economic impact analysis because of the inability to
adequately measure fugitive emissions from these sources and also to predict
the ambient impact of these emissions.  These fugitive emissions are a
function of particle density and wind speed.  The density data is not
currently available nor is a dispersion model which handles windblown
emissions.
     One assumption which tends to understate the economic impact of any
given ambient lead standard is that each model plant is an isolated source
with no background ambient levels of lead present.  To the extent that
sources of'lead  emissions may be clustered, the combined ambient lead
concentrations of the cluster result in higher control costs and impacts
than assumed.
     In addition, even  if the isolated source assumption were valid, there
are other factors that  influence the results of the economic impact analysis.
These include topographical and meteorological conditions, stack characteristics,
particulate emission factors, lead content  and particle size of particulate,
fugitive emissions factors, and baseline  process economics.  Values for many
of these factors are initially specified  as range estimates with midpoints
(arithmetic means) of the ranges used  in  the model plant analysis.  For other
factors, values  used in the model plant analysis are derived from  site specific
measurements.  However, the degree of  error in the measurement per se or  in the
application  of the measured value to the  model plant is not well known.

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   Variations  in  these  data  inputs  (factors)  among  plants  and  source
'pes  limit  the  accuracy  of the economic  impact assessment.   However,
le assessment does explicitly address  some variations  via  a reasonable
mge  analysis for  certain data inputs.
.2.2   Methodology
.2.2.1  Stationary Source Assessment Methodology
    Plant,  dispersion, control cost, and discounted cash flow models provide
fie bases for the economic impact assessment for the selected stationary sources
utputs of the plant models include emission, size, process, and location
haracteristies.  These are inputs to the dispersion model.  The dispersion
ode! provides maximum predicted concentrations and source contribution file
stimates.  The latter relate point and fugitive emissions generated by the
lant to maximum predicted ambien-t concentrations.  The outputs of the disper-
ion model are used together with control  systems engineering and cost data
o produce estimates of  investment and annualized control costs.  These
stimates are the  outputs  of  the cost model.   They are used  together with
rocess economic data  in the  discounted  cash flow models to  produce a numerical
stimate  of the value  of a plant after control.  If  these  calculations show  a
lant is  worth more closed than it is open,  closure  is predicted.
     In  situations where all  control costs could be  passed on without any
ffect on production levels,  closure would never be  predicted  using  the
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forementioned methodology.  However, the ability of an individual plant to
ass costs on and sustain pre-control production levels becomes less likely
s alternatives to accepting the cost pass on become available to his
ustomers or raw materials suppliers.  The assumptions of the economic impact
ssessment and the competitive structure of the industries analyzed imply
any alternatives to accepting a cost pass on.  Consequently, no cost pass-on
s considered in the closure analysis.
 .2.2.2  Mobile Source Assessment Methodology
    A 1975 source emissions inventory and projected mobile and stationary
ource growth rates are used to estimate a 1982 lead emissions inventory for
:ach Air Quality Control Region.  In a similar manner, ambient concentrations
 re rolled forward.  If the alternative ambient standards are predicted to  be
txceeded, the 1982 source emissions  inventory and ambient concentrations are
tilled back so that the standard is  achieved.  Of course, several different
 ombinations of mobile and stationary source control can achieve  the  same
 oil back.  In this analysis mobile source control is assumed used as  a last
 esort and then with emission  reduction effectiveness  limited to  75%.
    The  1982 stationary  source emissions inventory used in the mobile source
 ssessment includes eleven types of  process sources.   These are primary lead
melting, secondary lead  smelting, primary copper smelting, grey  iron production,
 asoline  lead additives production,  lead-acid  storage  battery production,
 erroalloy production, coal-fired power generation, oil-fired power generation,
 olid waste  incineration,  and  iron and steel  production.   It is important  to
 ote that only primary lead  smelting and primary copper  smelting  were projected
 o require additional rollback in 1982.  This  runs  counter to the dispersion

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model findings o'f the stationary source assessment which identify the first 6
of the 11 aforementioned sources as requiring further control,  This apparent
inconsistency is a function of the different methodologies employed and serves
to underscore another source of variability.  Moreover, like data variability,
this inconsistency limits our ability to make accurate judgements regarding impact.
1.2.2.3  State and Local Control Agency Assessment Methodology
     The state and local control agency assessment builds on the stationary
and mobile source assessments.  Control requirements for the stationary source
model plant assessments for the three alternative standards are aggregated to a
national level and used as inputs to EPA's Air Pollution Strategy Resource
Estimator (APSRE).  APSRE then provides an estimate of additional stationary
source related state and local control agency needs.  Additional resource
requirements resulting from mobile source control are developed as supplementary
calculations using the findings of the mobile source assessment.
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2.1  PRIMARY LEAD SMELTING
2.1.1  Industry Structure
     Six primary smelters owned by four corporations comprise the domestic
industry.  Company names, the plant capacities and locations are given
in Table 2-1.
     The four corporations smelting lead are both vertically and horizontally
integrated.  For example, they mine lead ore and refine smelted lead.  In
addition, they mine, smelt, and/or refine zinc, silver, coal, molybdenum,
and  copper.  The dependence that these corporations have on lead varies,
ranging from 6.U of revenues for AMAX to 17.955 for Gulf Resources and Chemical.
     Lead is an intermediate good.  As such, the demand for lead is derived
from the demand from lead-using products.  These include batteries, gasoline
lead additives, electrical cables and sheathing, paints, sheeting, plumbing,
and  ammunition.  Through  the year 2000, U.S. lead demand is projected to grow
at 1.5%  per year.
     Lead is a small percent of end product value and  has  few  close  substitutes.
Therefore,  its .demand  is  charactericterized as  price inelastic.   This means
that when lead prices  increase, total revenue  (price times quantity  sold)  increases.
     Price  inelastic demand notwithstanding, domestic  primary  smelters  still
could  face  competitive pressures  from other lead  suppliers.  For example,
unilateral  price  increases  by  domestic  primary smelters  could  foster increased
competition from  domestic secondary  producers.  Also,  unilateral price  increases
 by domestic primary smelters  could also foster increased competition from foreign
 producers.   As  indicated in Table 2-2,  foreign producers'  prices
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                            Table 2-1.   U.  S. PRIMARY LEAD SMELTERS
Company
Amax
ASARCO
Gulf Resources
 & Chemical
St. Joe Minerals
 Corp.
Plant(s) Locations)
Boss, Missouri
East Helena, Montana
El Paso, Texas
Glover, Missouri
Kellogg, Idaho
Herculaneum, Missouri
      1974 Capacity
(thousands of metric tons)
           127
            82
            82
           100
           118

           204
           713
Source:   U.S.  EPA,  October  1974.  Background Information for New Source Performance Standards:   Primary
         Copper,  Zinc,  and  Lead Smelters; Volume 1;  Proposed Standards.Bureau of Mines  Minerals Fact;
         and Problems.  1975.

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                                                  Table z-z. •  -LEAD PRICES
                                      (Average annual price, cents per kilogram)
             Year

             1964

             1965

             1966

             1967

_,           1968
CJ
             1969

             1970

             1971

             197Z

             1973

             1974

            1975

            1976
London Metals Exchange
27.8
31.8
26.3
22.7
24.1.
28.9
30.5
25.4
30.2
43.0
59.2
41.5
45.3
Mineral Facts and Problems, 1975.
Minerals and Materials, December, 1976.
New York
30.0
35.3
33.6
30.9
29.1
32.9
34.7
30.7
33.1
36.0
49.7
47.5
51.0

                     Bureau of Mines, Minerals Yearbook,  1970,  1972,  1974.

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(London Metals Exchange)  have been consistently less than domestic
producers'  prices (New York Exchange).  Anticipated reaction by foreign
producers to domestic primary smelter price increases may determine
whether domestic smelters elect to absorb long run cost increases or
push them forward as price increases.
2.1.2  Model Plant Specifications and Dispersion Model Results
     The model plant specifications used in the economic impact assessment
are primarily dependent on the assumptions and data requirements of the
dispersion model.  The dispersion model employed in the assessment is
the Single Source (CRSTER) Model.   It is a steady state Gaussian
plume dispersion model.  CRSTER will be recommended to the  states to
develop lead emission regulations for isolated stationary sources.
     Flat terrain is a basic assumption inherent in the CRSTER dispersion
model, and hence is one of the model primary lead smelter's specifications.
The flat terrain assumption may be important in predicting  the distance
of the maximum concentration from plant.  The maximum concentration for
the model primary lead smelter is predicted to be 300 meters away from
the plant.  With rugged terrain, the maximum concentration  could be expected
to be closer to the plant.  A review of topographical maps  for all six
smelters indicates elevations greater than the smelter site within 300
meters of the* plant.  Consequently, the maximum concentration may occur
closer to the plant than 300 meters.
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   Data  requirements of the dispersion model  include meteorological
iditions such as wind speed, wind direction,  and ambient temperature.
;h data  is not always available for every plant location.  St. Louis
teorological  data is available and is used in the analysis, since three
!the six smelters are located near St. Louis.
   Data  requirements of the dispersion model  also include emission
aracteristics such as stack gas exit velocity and temperature as well
5 point and fugitive emission rates and release heights.  These emission
Aracteristics are sometimes related to plant size.  The production rate
ed in the dispersion modeling is 62 thousand metric tons annual production.
is size is smaller than the current production rates of 4 of  the 6
elters.   However, this size was chosen because fugitive emission
asurements were available  for a plant of  that size.  Furthermore, because
ission characteristics are dependent on factors  other  than  size, scaling
  the fugitive emission measurements of the model  plant to  be  consistent
th an average plant  size could provide atypical  results.
   The model smelter is assumed  to have  both stack  and fugitive  emissions
  lead particulate.   Stack  emissions  are  assumed  controlled  to average
P particulate allowable process  weight rates.   The  fugitive emissions
•e assumed uncontrolled.  These emissions  come  from  the sinter machine
hiding,  blast furnace building,  reverberatory  furnace  building,  zinc
aning area, and  the  zinc furnace  building.
    Stack emissions  from the model  smelters have a negligible  effect on
•edicted maximum ambient lead concentrations.  Moreover,  higher stack emission
ites within a range  thought to be reasonable  do  not  change  this finding.
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gitive emissions have the predominent impact on predicted ambient
ncentrations,  and this impact appears to vary significantly from
elter to smelter.  For example, fugitive emission rates derived from
asurements at  a Montana primary lead smelter result in a maximum
edicted concentration for the model smelter of 3.8 yg/m , monthly
erage.  Fugitive emission rates derived from measurements at an Idaho
alter are higher and result in a maximum predicted concentration before
                  3
rttrol of 78.2  ug/m , monthly average.
1.3  Control Costs <
1.3.1  Model Plant
   The alternative ambient standards considered here are 2.0,  1.5, and
D pg/tn , monthly average.  The predicted ambient concentrations
om both sets of fugitive emission rates mentioned above are greater  than
a alternative standards.  Hence, control costs corresponding to  reduced
gitive emission rates which achieve the alternative ambient standards should
 developed for the model primary lead smelter.  Control costs  representing
 » least costly means of achieving the three  standards were developed for
 » lower set of derived fugitive emission rate.  For the higher set,  control
 ;ts  corresponding to 95% control efficiency  were developed.  The 95% estimate
 an  engineering judgement based on the best  demonstrated control system
 •rently available (building evacuation to  a  fabric filter).  However,  95%
 itrol applied to the higher set of fugitive  emission  rates  still results  in
 •redicted maximum concentration of 3.9 ug/m3 which exceeds  any of the  alternative
 ndards.  The control efficiencies required  to get to 2.0,  1.5,  and  1.0
 m3, respectively, are estimated to be 97.4%, 98.1%,  and 98.7% as compared
 h  95Z which is judged to be  the maximum attainable.
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     The  absolute and relative magnitude (as a percent of annual revenue)
of the developed investment and annual ized costs are presented in Table 2-3.
For the lower fugitive emission rates, relative annualized control costs range
from 0.9% to meet a standard of 2.0 vg/m3 to 1.8% to meet a standard of
1.0 ug/m3-   For the higher fugitive emission rates, relative annualized costs
are 7.7% to meet an ambient level of 3.9
2.1.3.2  Industry
     The most critical factor in the model plant control cost  assessment is
the fugitive emission rates.  As indicated previously, these rates  have been
derived from fugitive emission measurements at  two  of the  six  currently
existing primary lead smelters.  However, site  specific  topographical,
meterological , and smelter size, configuration, and emission rates  data are
 required to assess the ambient and  cost impact  at  these  six smelters with
 reasonable certainty.  Assuming all primary lead smelters  have the  same site
 specific characteristics as the model  smelter,  five of  the six existing
 smelters would probably have  low fugitive emission rates and hence  have
 ambient impacts closer to 3.8 than  to  78.2 ug/m3,  monthly average.   For
 three  (the Missouri  smelters) of the  five smelters this judgement is based
 primarily on the presumption  that  since these smelters  are newer they are
 better controlled.   For the other  two of the five smelters (Montana and Texas),
"similarity  to  the  hypothetical  smelter in terms of size, lower measured
 fugitive emissions,  and/or  lower measured ambient concentrations is the
 basis for  the  Judgement.  Higher measured fugitive emission and ambient
 concentrations are the  reasons for classifying the Idaho  smelter  (the
 sixth smelter) as  having  ambient impacts closer to 78.2
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      Table 2-3.   CONTROL COSTS FOR THE  MODEL PRIMARY LEAD  SMELTER

                                   Maximum  Predicted Ambient Levels
                          	(yg/m3 , monthly average)
Higher Fugitive
Emission Rates
                           3.9
                 2.0
1.5
1.0
Investment
 OOO's of $

 as a % of
 annual revenue
10800
 34.455
Annualized Cost
  OOO's of $'s

  as a % of
  annual revenue
 2400
  7.7%
Lower Fugitive
Emission Rates

Investment
  OOO's of S's

  as a % of
  annual revenue

dualized Cost
  OOO's of $'s

  as a % of
  annual revenue
0
0
0
0
1300
4.0%
300
U.9X
1600
5.2%
400
1.2%
24UU
7.5%
600
1.8%
*The control efficiency of the best demonstrated control system is limited
 according to engineering judgement to  95%.   This is not sufficient to achieve
 the alternative ambient standards for  the model plant with higher fugitive
 emission rates.
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    To draw further inferences from  the model  plant assessment Is tenuous.
However, assuming production  is proportional  to the number of smelters
in each category and the model smelter  costs  can be extrapolated linearly to
higher production volumes, industry control cost estimates can be developed.
For 83.3% of the industry  (current production share at the five plants
assumed to have low fugitive  emission rates), the respective investment costs
                                              o
in 1982 for meeting the 2.0,  1.5, and 1.0  ug/m  standards are $11.9 million,
$15.3 million, and $22.4 million.  The  corresponding annualized costs are $2.8
million, $3.5 million and  $5.3 million. For  the remaining 16.7% of the industry
(current production share  of  the  other  smelter), control cost estimates are
those corresponding to 95% control efficiency.   They are $20.5 million for
investment and $4.6 million for annualized costs.
2.1.4  Model Plant Closure Assessment
    Using a discounted cash  flow analysis technique, synthesized model plant
process economics, the aforementioned control costs, and assuming no other
lead emitters in the vicinity,  the potential  for closing the smelter on
financial grounds is assessed.   Process economics  (e.g., revenues, costs) were
developed using Bureau of  Mines  data  as well  as financial data from specific
companies.
    Given the lower set of  derived  fugitive emission estimates, the model
smelter should not close regardless  of the level of the standard.  This finding
is true for  several sets of  circumstances.  They include a  range of marginal
tax rates  and minimum  acceptable return rates thought to be reasonable, full
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absorption of control  costs,  low profit margin and fully depreciated smelter,
and full absorption  of operation and maintenance cost required for the proposed
Occupation Safety  and  Health  Administration Lead Standard (100 ug/ro3, 40 hour
time weighted average  and  60  ug/100 g whole blood).
    Given the higher  set  of  derived fugitive emission estimates, the ability
of the model smelter to achieve maximum (9558) control of fugitive emissions
(assuming this amount  of control is satisfactory) and remain open is unclear.
The critical factors among previously described set of circumstances are the
marginal tax rates and the minimum acceptable return rates.  Marginal tax rates
are the  rates applicable to plant and not, for example, to the parent firm.
Minimum  acceptable return  rates are the profits available from the next best
investment opportunity. If the minimum acceptable return rates are not
realized, the plant  will close; and, the next best investment opportunity will
be capitalized.   If  the tax and return rates are on the high end of the range
thought  to be reasonable,  it would be in the best financial interest of model
smelter  to close.  If  the  rates are lower, the model smelter with higher
fugitive emission  rates should make the expenditures to achieve 95% control
and remain open.
                               20

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2.2  SECONDARY LEAD SMELTING
2.2.1  Industry Structure
    The secondary lead smelting  industry is  a subset of the secondary lead
industry.  The latter includes melters  as well as smelters.  Unfortunately,
industry structure statistics are only  available for the secondary lead industry.
    The secondary lead industry  in  the United States supplied 545,000 metric
tons or 39 percent of total lead  consumption  in 1974.  Approximately 90
companies operating 130 plants produce  lead and lead alloys for industrial
use from recycled materials, principally old  batteries.8  Two companies, NL
Industries, Inc., and RSR Corporation,  operating about 18 secondary plants,
account for over 50 percent of the total  secondary lead production.9  Thirteen
other companies operating approximately 24 plants that manufacture storage
batteries and other metal products account for 45 percent of secondary lead
production.
    Roughly two-thirds of all lead  produced  at secondary smelters is
antiroonial lead and goes into the manufacture of batteries.  Therefore, demand
for secondary lead in the future  is  tied to growth in battery use.  While new,
longer lasting batteries are becoming more and more popular, demand for
replacement batteries is still expected to be 35 percent of total demand each
year until the end of the decade.
    Prices are a critical factor in determining the supply of secondary lead.
Primary lead prices affect secondary lead prices in a direct way.  To the
extent that the secondary industry acts as a  broker, any change in the price
of primary lead will be reflected in the price of scrap.  Secondary producers,
                                 21

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therefore,  could expand or contract their collection effort depending on
changes in  the price of lead.  Although  it may vary above and below the
primary lead price, the secondary soft lead  price follows the average prices
quoted in Metals Week.  Historical primary lead prices are provided in
Table 2-2.
2.2.2  Model Plant Specifications and Dispersion Model Results
    To provide reasonably accurate predictions of ambient impact, the model
plant specifications should be consistent with the assumptions and data
requirements of the dispersion model.  CRSTER, the dispersion model employed
in the assessment, is designed to predict ambient impacts of emissions from a
plant located in flat terrain with meteorological conditions representative
of the area.  To avoid modeling  an atypical  situation, an actual smelter  located
 In flat terrain with  local meteorological  data available is the  plant modeled.
The smelter produces  about 30 metric  tons  of lead a day.  However, this  is
 somewhat low when  compared to the midpoint  of the range of plant sizes specified
 in the Control Techniques Document worksheets.  The range specified  there is
 18 to  68 metric tons  per day with  the midpoint being  43 metric  tons  per  day.
 But the actual size distribution of  the secondary  lead smelters  is unknown.
 Horeover,  an explicit attempt  is made to avoid modeling atypical situations.
 Hence,  the size of the model  plant is not adjusted  upwards  to  reflect the
 m'dpoint of a  size range.
     The model  smelter has  lead particulate stack  emissions  controlled to
 iverage SIP process weight  rates.   These emissions  have  a  negligible impact
 m the maximum predicted  ambient concentrations.   In  addition  there  are
                                  22

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fugitive emissions assumed for  the model  smelter.   These emissions are
uncontrolled and result in a maximum predicted concentration of 56.6 yg/m ,
monthly average for the midpoint (arithmetic mean) fugitive emission estimate.
For a low fugitive emission estimate the maximum predicted concentration is
33.2 ug/m3.  For a high fugitive emission estimate the maximum predicted
concentration 1s 80.5  yg/m  .  The maximum predicted concentrations for all
fugitive emission estimates are extremely sensitive to the assumed release
height of the fugitive emissions.  For example, increasing the release height
by 5 meters for the midpoint  emission estimate reduces the maximum predicted
concentration from 56.6  ug/m3 to 20.0 vg/m3.  However, the release height
assumed originally  (10 meters)  is thought to  be typical  of secondary lead
snelting release  heights.
     If the release  height is typical and best demonstrated  control  cannot
 achieve the standard,  another consideration might be  land acquisition.   The
 predicted  maximum of 56.6 vg/m3 occurs  150 meters from the plant.  If legally
 feasible  and  cost effective,  the plant may  supplement the fugitive emission
 control system by purchasing surrounding  land which has ambient concentrations
 greater than  the standard.  Under such  a  strategy, and with  barriers to limit
 access to these areas, the public would still be  protected from the adverse
 consequences  of concentrations exceeding  the standard.  However, the feasibility
 of land acquisition as a control strategy is beyond the scope of this assessment.
                                   23

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2.2.3  Control Costs
    As previously noted, the maximum  predicted concentrations of 33.2 to
80.5 ug/m , monthly average exceed  the considered alternative ambient standards
for all sets of fugitive emission estimates.   Consequently, fugitive emissions
will have to be reduced to some degree at the model  smelter regardless of the
level of the standard.  Building evacuation to a fabric filter has been applied
to secondary lead smelters before.   However,  the achieved level of control
efficiency is not known.  At present,  95% control efficiency seems to be
the limit applied by engineering judgement on this technically demonstrated
system.
    Applying a 94% or 95% efficient control  system to the model smelter is estimated
to require an investment of $1.8 million which is about 32% of annual revenue.
Corresponding annualized cost is $0.4  million which is about 7% of annual revenue.
A 94Z or 95% control efficiency will achieve the 2.0 yg/m  standard for the
low fugitive emission estimates, but will not achieve any of the more
restrictive alternative ambient standards.  Furthermore, 95% control efficiency
will not achieve any of the considered alternative ambient standards given the
dispersion modeling results for the midpoint and high fugitive emission rate
estimates.  With the midpoint fugitive emission rate estimate, 95% control
efficiency results in a predicted maximum of 2.8 yg/m .  With the high fugitive
emission rate estimate, 95% control results in a predicted maximum of
4.0  wg/m3.
2.2.4  Model Plant Closure Assessment
    The model plant closure assessment for secondary lead smelting includes
                                      24

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an analysis of high, average, and low  profit margin smelters.  The process
economics (e.g., revenues, costs) for  these profit margins are developed using
publicly available financial data on NL  Industries and RSR.
    High profit margin model smelters with plants that are not fully depre-
ciated should be able to absorb the costs  associated with the 94% or 95%
efficiency system and remain open.  This finding holds within a range of
wrglnal tax rates and minimum acceptable  return rates thought to be reasonable.
However, high profit margin model smelters that are fully depreciated will only
be able'to remain open under similar conditions if they have relatively low
marginal tax rates and minimum acceptable  return rates.
    Average profit margin model smelters  not having fully depreciated plants
should be able to absorb the costs associated with the 94% or 95% efficiency
system and remain open under most conditions.  However, with a 94% efficiency
system, this model smelter will close  if the marginal tax rates and minimum
acceptable return rates are reasonably high.  With a 95% efficiency system,
this model smelter will close if the minimum acceptable return rate is
reasonably high and the marginal tax rate  is within a range thought to be
reasonable.
    Low profit margin model smelters  regardless of the depreciation circumstances
and average profit margin model smelters that are fully depreciated would
probably close rather than absorb the  cost of a 94% or 95% efficiency system.
                                    25

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2.3 PRIMARY COPPER SMELTING
2.3.1  Industry Structure
   Eight companies with a combined total of 16 smelters make up the
U.S. primary copper smelting  industry.   Table 2-4 lists the companies,
plants, their locations, and  capacities.
   Smelting is an intermediate production process proceeding refining and
fabrication and following mining, ore benefielation, and/or scrap collection.
Consequently, the demand for  smelted copper is derived from the demand for
refined and fabricated  copper.   Refined and fabricated copper is used primarily
by the construction, communications, and motor vehicle manufacturing industries.
Substitutes for refined and  fabricated copper do exist.  They include aluminum,
steel, and plastic.
   Smelted copper can be  supplied by secondary or primary producers either
located in the U.S. or  elsewhere.  Foreign producers supplied about 10% of
the 1974 U.S. demand for  copper.11  Domestic producers on  the other hand  used
                                                                    12
tout 4% of the 1974 production to satisfy foreign demand  for copper.
Of the domestic production  used to satisfy domestic demand in 1974,
about 45% was supplied  by domestic secondary producers with the  remaining 55%
teing supplied by  primary producers.
    Historical prices  for domestic producers refined  copper are presented
 in Table 2-5.
    The demand for domestic primary smelting output  is  projected to  grow
it ft per year.13   However, limited domestic smelter  capacity could constrain
 this growth  resulting  in excess demand  and  upward  price  pressures for blister,
 refined, and  fabricated copper.  Given  future excess  demand  and  upward price
                                   26

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                                      Table 2-4.   PRIMARY COPPER SMELTERS
ro
Company

The Anaconda Company

ASARCO



Cities Service Corp.

Copper Range

Inspirational Consolidated
  Copper

Kennecott Copper Corp.
          Newmont Mining Corp.

          Phelps  Dodge
                                                Smelter Location

                                                Anaconda, Montana

                                                El Paso, Texas
                                                Hayden, Arizona
                                                Tacoma, Washington

                                                Copper Hill, Tenn.

                                                White P1ne»M1ch1gan
Miami, Arizona

Hayden, Arizona
Hurley, New Mexico
McGIll, Nevado
Garfleld, Utah

San Manuel, Arizona

Ajo, Arizona
Douglas, Arizona
Morencl, Arizona
HI1dago, New Mexico
                                                  1974
                                    Smelter Capacity Furnace Charge
                                    	(metric tons/yr)	

                                                   680.000

                                                   523,000
                                                   871,000
                                                   544,000

                                                    68,000

                                                    82.0003
408,000

381,000
363,000
363,000
907,000

726,000

227,000
635,000
816,000
 91,000
           Measured as copper product.
          Source:  Background Information for New Source  Performance  Standards;  Primary Copper, Z1nc, and Lead
                   Smelters - Volume I  - Proposed Standards.U.S.  EPA, Document Nol EPA-450/2-74-002a, October
                   1974, p. 6-3.Also  ADL estimates  for  the  EPA-MBO  Study, forthcoming 1977.

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                  Table 2-5.  COPPER PRICES
           (average annual price, cents per kilogram)
                                         F.O.B.  Domestic Primary
Year                                     Producer Refined Price*
1964                                             70.5
1965                                             77.2
1966                                             79.8
1967                                             84.2
1968                                             92.2
1969                                            104.7
1970                                            127.2
1971                                            113.3
1972                                            111.6
1973                                            129-9
1974                                            168.9
1975                                            140-0
1976                                            151.7

aSource:  Metals Week
                              28

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pressures, domestic smelters will  probably find it better to push forward
any increases in production cost.   The alternative, pushing the costs back
to the ore and matte suppliers,  could spell  the loss of critical raw materials
from marginal ore and matte suppliers.  However, if only one domestic smelter
Is faced with production  cost  increases, it may find it difficult to pass
them forward because of dependence on other domestic smelters following
its lead.  Passing production  costs forward becomes much more plausible,
however, if all or several domestic smelters incur similar production
cost increases.
2.3.2  Model Plant Specifications and Dispersion Modeling Results
    As mentioned in the  primary and secondary lead smelting assessments,
the requirements of the dispersion model affect the specifications of the
ndel plant.  Terrain and meteorological conditions are the two major
Influences.  In essence,  the model plant should be located in flat terrain
irith nearby meteorological  condition data available.  Furthermore, to be
typical, the size and location of the model plant should correspond to an
actual plant.
    The model smelter  is located 1n flat terrain, has Tucson, Arizona
•rteorological conditions, and has furnace charge capacity of 635,000 metric
Urns per year.  These  specifications do correspond to an actual  plant.  More-
over, some of  the other existing smelters do have similar characteristics.
For example, 5 of  the  16 are located  in flat terrain and 6 have  meteorological
conditions similar  to  Tucson,  Arizona.
                                   29

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   The charge rate of the model  smelter is high when compared to the
industry average of 500,000 metric tons per year.  However, no existing
Belters of that charge rate  are located in flat terrain with nearby
leteorological condition  data available.  Consequently, the model smelter
size was not scaled up to the industry average.
   Other model plant specifications Include the process equipment.  These
specifications are for an actual plant with the aforementioned terrain,
rteorology, and size characteristics.  The model plant has a reverberatory
Kiting furnace,  Fierce-Smith converters, and multiple hearth roasters.  Of
the 16 existing  smelters, 12 have reverberatory  smelting furnaces and  15
save Pierce-Smith  converters.  However, only four have multiple  hearth roasters.
Ite others  have  either fluidized-bed roasters or no  roasters at  all.   The
iffect of  process  equipment variations  among smelters  on ambient air  quality
is presently  unknown.
    The model  smelter is assumed to have  both  stack and fugitive emissions of
lead particulate.   Stack emissions  are assumed  controlled  to average  SIP
articulate allowable process weight  rates.  The fugitive  emissions are  assumed
^controlled and to emanate  from  the  roaster,  reverberatory furnace,  and
anverter buildings.
    Stack emissions have a  negligible predicted impact on ambient lead
 toncentrations.  Moreover,  higher emission rates within a range thought to
 te reasonable do  not change this  finding.   Fugitive emissions do have a
 wtlceable predicted ambient impact.   However, fugitive emission estimates
 ire dependent on  the percent lead content of the materials handled.  This
                                   30

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percentage varies  among  smelters.   The fugitive emission estimates felt to
be most  typical of a middle  estimate result in a predicted maximum ambient
concentration of 3.1  yg/m ,  monthly average.   The fugitive emission estimates
felt to  represent  a reasonable lower limit on the percent lead content yield
a predicted maximum ambient  concentration of 0.4 ug/m3, and, estimates for a
reasonable higher  limit  result in  a maximum predicted concentration of
10.7 ug/m  , monthly average.
2.3.3  Control Costs
2.3.3.1  Model Plant
    As  indicated  above, the monthly maximum predicted ambient concentration
for the  middle and reasonable higher limit fugitive emission estimates exceed the
alternative ambient standards (2.0, 1.5, and 1.0 yg/m3) at the model smelter.
Consequently, control  costs  corresponding to reduced fugitive emission rates
nhich will achieve the alternative ambient standards are developed.  These
costs are specifically designed to approximate the least cost means of
achieving each standard.  No costs are developed for the reasonable lower
limit fugitive emission  estimates  since the predicted maximum concentration
in that  case is less than all considered alternative standards.
    The investment, annualized control cost, and investment and annualized
cost as  a percent  of annual  revenue for the model smelter are presented in
Table 2-6.  The middle fugitive emission estimates investment costs range from
$5.2 million for the 2.0 yg/m3 standard to $9.8 million for the 1.0 ug/m3
standard.  The corresponding annualized costs range from $1.1 million to
$2.1 million.  With the  reasonable higher limit fugitive emission estimates,
                                   31

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      Table 2-6.  CONTROL  COSTS FOR THE MODEL PRIMARY SMELTER
arable Higher Limit
Itlve Emission Rates

«tnent
I's of $'s

n % of annual revenue

ilized Cost

I's of $'s

l a % of annual revenue
                                       Maximum Predicted Ambient Levels
                                      	(jfl/m3 monthly averaqe)
                                       2.0
22,300

 15.2



 4,800

  3.3
                 1.5
28,900

 19.7



 6,200

  4.3
                 1.0
35,400

 24.2



 7,600

  5.2
le Fugitive Emission Rates

ttnent

I's of $'s

11 X of annual revenue

«lized Cost

I's of $'s

li Z of annual revenue
5,200
3.5
1,100
0.8
7,600
5.2
1,600
1.1
9,300
6.7
2,100
1.4
ftable Lower Limit Fugitive
Won Rates
  0*
  0*
  o*
tstnent and annualized costs are zero since the maximum predicted concentration
iless than all considered alternative ambient standards.
                                      32

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corresponding investment costs range from $22.3 million to $35.4 million.
The annualized cost range from $4.8 million to $7.6 million.
2.3.3.2  Industry
     A critical factor in drawing inferences from the model plant assessment
and applying them to the entire industry is the amount of control required.  To
determine the amount of control required necessitates categorizing existing
swelters as indicative of the middle, reasonable lower, or reasonable higher
limit fugitive emission estimates.  On the basis of the estimated amount of
lead in the furnace charge at full capacity, three existing smelters are believed
to be indicative of the middle fugitive emission estimate; seven are indicative
of reasonable lower limit fugitive emission estimate; and six are indicative
of the higher limit fugitive emission estimate.  To draw further inferences
is tenuous.  However, if it is assumed that .production is proportional to the
         •
number of  smelters in each category and the model smelter costs can be extrapolated
linearly to higher production volumes, industry control cost estimates can be
developed.  The investment costs for the year 1982 are $184.4 million for a
standard of 2.0 yg/ra3, $241.8 million for a standard of 1.5 yg/m3, and $298.7
•illion for a standard of 1.0 vg/m  .  The corresponding annualized costs are
$40.0 million, $52.3 million, and $64.4 million.
2.3.4  Model Plant Closure Assessment
     Using a discounted cash flow analysis technique and model  plant process
 economics  synthesized from publicly available company  financial  reports, the
 potential  for  closing the smelter on financial  grounds is  assessed.  Given
 the  reasonable lower limit fugitive emission estimates, the model  plant  should
                                                               2
 not  close.  With  a maximum predicted concentration  of  8.4  yg/m , no control
                                   33

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expenditures are required.  Given the middle fugitive emission estimate, the
model smelter should not close even though control costs must be expended to
achieve all  alternative standards.  This finding is true for a range of marginal
tax rates and minimum acceptable return rates thought to be reasonable, full
absorption of all control costs, and a fully depredated model plant.
     Given the reasonable higher limit fugitive emission estimates, the ability
of the model smelter to remain open on financial grounds alone is unclear.
However, the potential for remaining open is greater with a standard of 2.0
    •a                                               3
ug/m  than with either a standard of 1.5 or 1.0 ug/m •  With a standard of
2.0 ug/m  certain marginal tax rate and minimum acceptable return rate combina-
tions within a range thought to be reasonable do permit a fully depreciated
plant absorbing all the control costs to remain economically viable.  With the
.1.5 or the 1.0 ug/m3 standards, a fully depreciated plant absorbing all the
control cost is not economically viable under any marginal tax rate and minimum
acceptable return rate combinations judged to be reasonable.
                                 34

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2.4  GREY IRON FOUNDRY CASTING
2.4.1  Industry Structure
    There are about a 1000 establishments  classified as  grey iron foundries.14
firey iron is produced at these  foundries  in cupola,  electric, and reverberatory
furnaces.  The main output of the  foundries is  castings.   These come in a
variety of sizes and shapes having different chemical and physical properties.
    The grey iron foundry industry produces intermediate goods.  Castings
become part of and/or are used  in  the production of  automobiles and trucks,
construction machinery, railway equipment,  electrical and farm machinery,
rolling mills, and machine tools.   Consequently, the demand for grey iron
is a function in part of the demand for these products.   Demand for grey iron
is projected to grow at 3..2% per year.
    Historically, the average  price of grey iron castings has risen slightly
faster than the Wholesale Price Index.  However, what product that average
price represents is not clear.   The selling price for grey iron varies
depending on the size, shape, and  chemical  and physical  properties of the
product.  In 1976  the average price of a grey iron casting was $340/metric
ton.16
2.4.2  Model Plant Specifications  and Dispersion Modeling Results
    The model foundry specifications are consistent with the assumptions
and  data requirements of  the  dispersion model.  For example, the model grey
Iron foundry  is  located  in  flat terrain with representative meteorological
condition data available.   The  model foundry specifications are also
consistent with  the  objective of modeling a realistic situation.  For
example, like  60%  of the  grey iron foundry establishments, the model
swelter  is located in  an  east north central state.    Moreover, like 70%
                                 35

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 F the grey iron produced nationally, the model foundry produces grey
 ron in a cupola furnace.18  In addition, the size of the model foundry,
 .3 metric tons/hour melt rate, corresponds to an actual foundry
 Dcated in flat terrain in an East North Central State.
    The model smelter has lead particulate stack emissions  controlled  to
nverage SIP process weight rates for particulate.  Stack emissions  have a
legligible impact on the maximum predicted ambient concentrations.   Fugitive
missions are assumed for the model grey iron foundry.  These emissions are
issumed uncontrolled.  For a low fugitive emission rate estimate,  the maximum
predicted concentration is 0.3 ug/m3, monthly average.  For  a midpoint  fugitive
emission rate estimate, the maximum predicted concentration  is 1.8 ug/m .
tod, for a high fugitive emission  rate  estimate,  the maximum predicted  concen-
tration  is 3.7 ug/m3, monthly average.
Z.4.3  Control Cost
    No  control costs need to  be developed  for  the  low fugitive emission  rate
estimate since the  predicted monthly  average maximum concentration of 0.3
iig/m3  is  less than  any of  the  alternative  standards  (i.e., 2.0, 1.5, and
1.0 ug/m3).   For  the midpoint  fugitive  emission rate estimate control  costs
ire developed for the 1.5  and  1.0  ug/m3 alternatives since the predicted
maximum  (1.8 ug/m3) is  greater than  these  levels.   However,  no control  costs
ire developed for the 2.0  ug/m3 alternative since the predicted maximum is
less.   For the  high estimate,  since  the predicted monthly average maximum
3f 3.7 ug/m3 is  greater  than  the  three  considered alternative standards,
:ontrol  costs are developed  for all  three  standards.
                                 36

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    The  investment,  annual 1 zed  costs,  and investment and annualized costs
as a percent of  annual  revenue are presented in Table 2-7.  The control
system  costed  1s side draft and  canopy  hoods which are ducted to a fabric
filter.   For the midpoint fugitive emission rate estimate, investment cost
                                                                    3
as a percent of  annual  revenue is 9.8%  for both the 1.5 and 1.0 ug/m  standards.
Annualized cost  as a percent  of annual  revenue for both standards is 2.0%.
The reason the costs do not vary between the 1.5 and 1.0 ug/m  standards
is that the control system costed is assumed incapable of distinguishing
between the required control  efficiencies needed to attain both  standards.
     For the  high fugitive emission rate estimate, the required  control
efficiencies  for the 1.5 and 1.0 ug/m3 standard are greater than for the
midpoint fugitive estimate.  These greater efficiencies  are assumed reflected
in different control system design and operating needs,"and hence in the  cost.
Investment cost as a percent of annual revenue  ranges  from 9.8%  for the
2.0 ug/m3 standard to 30.4% for the 1.0 ug/m3  standard.   Corresponding
annualized cost as a percent of annual revenue  ranges  from 2.0%  to  6.2%.
2.4.4  Model  Plant Closure Assessment
     The baseline  process economics for the  grey  iron  foundry model  plant
are developed using  financial data contained in Leo  Troy's  1977  Almanac
of Business and Industrial Financial Ratios.
     Assuming zero background concentrations of lead and no  other lead emitters
in the area,  the model  grey  iron  foundry  with low or midpoint fugitive
emission  rates  should  remain  open regardless of the  level of the standard.
For the model with low fugitive emission  rates, no control  costs need
be expended since  all  alternative standards are predicted to be achieved.
                                    37

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  Table 2-7.  CONTROL COST FOR THE MODEL  GREY  IRON  FOUNDRY PLANT
                                 Maximum Predicted Ambient Levels
                              	(ug/m3 monthTy average)
                                 2.0            1.5            KO
 ^Fugitive Emission  Rates
 
-------
Hence, it is clear that the model foundry should remain open.  For the
model with midpoint fugitive emission rates, no control cost expenditures
                             3
are required for the 2.0 wg/m  standard.  However, the model foundry
                                                 3             3
must expend control costs to achieve the 1.5 wg/m  and 1.0 wg/m  standards.
Given that these costs must be absorbed, the model foundry is fully
depreciated and the foundry faces a reasonable range of marginal tax and
minimum acceptable return rates; it should remain open on financial
grounds.
     The model foundry with high fugitive emission rates requires control
expenditures for all alternative standards.  For the 2.0 and  1.5 wg/m
standard, the model foundry should remain open on financial grounds
given the cost absorption, depreciation, and marginal  tax and return
rate conditions mentioned previously.   However, with the 1.0  wg/m
standard, a fully depreciated  foundry absorbing the control  costs  should
close for most marginal  tax rate  and  minimum  acceptable  return rates
within a range thought  to be  reasonable. Only with marginal  tax and
minimum acceptable  return rates  at the low end of the  reasonable range
will  a fully  depreciated model  foundry absorb the control  costs needed
to meet a  1.0 wg/m3 standard  and remain open  on financial  grounds.

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  GASOLINE LEAD ADDITIVES MANUFACTURING
  1   Industry Structure
  Four companies with a combined  total of  six plants  comprise the
  gasoline additives (lead alkyl)  industry.  Table  2-8  lists the
 panics, their plants, capacities,  and  locations.  Present  annual
 adty is 403 million kilograms of tetraethyl lead (TEL)  equivalent.
 wal  production in  1974 was about  318 million kilograms  of  TEL equivalent
                      10
 (about 80% of capacity.
  Gasoline lead additives are mixed  with gasoline to  raise the  Octane
 *er  and consequently, reduce engine  knock.  Low production cost and
 $ effectiveness in raising the Octane  Number resulted in widespread
 i of  lead additives with little competition from other compounds.
  However, EPA's lead phasedown regulations will result in the
 relopraent and acceptance of other  compounds and  hence, slow down
                                                                   20
 tore  domestic production and consumption of gasoline lead additives.
 though most analysts agree the future U.S.  production  of lead additives
 <11 be less than it  is today, the exact  decline in future production is
 known.  Industry representatives are  optimistic  with regard to export
                                                         21
 ssibilities even though domestic consumption will decline.    However,
 tters  feel the export market growth may  not  materialize if foreign
 untries also adopt  lead phasedown  regulations.
  Even with a production decline, given tight energy  supplies and
 ejected increases in the demand for gasoline, future lead additives
fices  should not decline.   In 1976, pure TEL sold for about  223.3
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                      Table Z-a.   u>s. GASOLINE ADDITIVE (Lead Alkyl) MANUFACTURING PLANTS
                                                                                         1974 Capacity
                                                                                       (millions of Kg
        Company                                Plant(s) Locatlon(s)                     Tetraethyl Lead)
E.I. duPont de Nemours                         Antloch, California                           154
  & Company, Inc.                              Deepwater, New Jersey
Ethyl Corporation                              Baton Rouge, Louisiana                        177
                                               Pasadena, Texas
PPG Industries, Inc.                           Beaumont, Texas                                54
Nalco Chemical  Company                         Freeport, Texas                                18
                                                                                             403
Source:  Chemical  Economics  Handbook p.  671.5042  C,  December,  1975.

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                   1964                           124.6
                   1965                           127.9
                   1966                           126.3
                   1967                           125.0
                   1968                           124.1
                   1969                           127.4
                   1970                           128.5
                   1971                           133.6
                   1972                           135.4
                   1973                           137.3
                   1974                           157.6
                   1975                           200.0
                   1976                           223.3
Source:  Chemical  Economics  Handbook,  "Tetraethyl Lead and Tetramethyl Lead", Stanford Research
         Institute,  p.  671.5042  R,  December  1975. and DuPont, 1976.  Antiknock mix prices were
         multiplied  by  1.626 assuming  1.626  pounds of antiknock per pound of pure TEL.

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:.5.2  Model Plant Specifications and Dispersion Modeling Results
   Of the six gasoline  lead additives plants, all are located in flat
;errain, 74% of their combined capacity produces tetraethyl lead (TEL)
ising the sodium-lead alloy  process,  three are located in Southeast Texas,
aid the average capacity  of  each plant is 67,000 metric tons of TEL
njuivalent.  The model  plant used in  the dispersion modeling is located
in flat terrain, produces TEL using the sodium-lead alloy process, has
touston, Texas meteorological conditions, and produces about 54 thousand
stric tons of TEL annually.
   The model plant  is assumed to-have lead stack emissions in both  the
liarticulate and vapor phases.  The lead recovery furnace stack emits
lead in the particulate phase and is  controlled to the average SIP
allowable process weight  rate.  The process vents and sludge pit exhaust
stacks emit lead in the vapor phase and are uncontrolled.   No fugitive
missions are assumed.  The maximum predicted concentration for the lead
stack emissions is  15.7 ug/m , monthly average.
Z.5.3  Control Costs
2.5.3.1  Model Plant
   Since  15.7 pg/m   is  greater than all the considered standards,
control costs  indicative  of reduced stack emission rates are developed
for all the considered  standards.  The costed control system includes
packed  scrubbers  and  increased pressure drop on an existing venturi
scrubber.   The model  plant investment, annualized  control  cost,  and
investment and  annualized cost as a percent of  annual revenue  are  presented
                                  43

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'able 2-10.   Investment control costs for the model  plant  range from $519
jsand for meeting the 2.0 yg/m  standard to $521  thousand  for meeting the
mg/m  standard.   Annualized control cost as a  percent of  product sales
ce is about 0.2%. for the three considered standards.
,J.2  Industry
 A critical factor in the model plant  impact assessment is the
Hired reduction in the baseline emission rates  to achieve  the alternative
lient standards.  The required reduction could be greater for larger
.planter ^pr TEL plants clustered  among other lead emitters.
ever, to tharextent that the required reductions at the six existing
aline lead additive plants are similar  to those at the model plant,
aevement of all three alternative  ambient standards would appear to
itechnically possible by all plants.   Furthermore, if model plant
irol costs are related linearly to 1974 production, the estimated

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          Table  2-10.   CONTROL COSTS FOR THE MODEL GASOLINE
                       .LEAD ADDITIVES PLANT
                          Maximum Predicted Ambient Levels
                              (yg/ro3 , monthly average)
                          2.0            1.5            1.0
Investment
 OOO's of $'s             519             519              521
 as a % of annual          0.4%           0.4%           0.4%
  revenue
tonualized Control  Cost
 OOO's of $'s             270             270              271
 as a % of annual          0.2%           0.2%           0.2%
  revenue

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o achieve all standards  under a variety of circumstances.   These include
ill marginal tax  rate  and minimum acceptable return rates thought to be
tasonable, fully depreciated plant, sustained production decline (25%),
n increase in the raw material lead price (as a result of the lead
rirfent air quality standard, i.e., 1.8%), and full absorption of all
mrtrol costs.

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2.6  LEAD-ACID BATTERY MANUFACTURING
2.6.1  Industry Structure
     Currently there are about 200 lead acid battery manufacturing
plants in the United States ranging in size from about 50 to about
11,500 batteries per day.
     Two major types of lead add storage batteries are manufactured in
the United States.  Starting-Lighting-Ignition  (SLI)  batteries which are
used  in auto, aircraft, and golf carts are  one  type.  The units account
for more than 80 percent of the  market.22   The  second type  includes
 industrial storage  batteries for such uses  as  low-voltage power systems
 and  industrial fork!ift trucks.
      The market for lead-acid  storage is composed of three  segments.
 The  largest  segment in terms of sales is the domestic replacement market.
 This includes  replacement batteries for automobiles, trucks, buses,  farm
 machinery, and heavy  equipment.   The original  domestic equipment  market
 is the second largest segment.  This includes batteries sold to producers
 of new vehicles  and equipment.  The export sector is the smallest market.
 This includes replacement batteries in existing equipment and batteries
 for new equipment. The overall  demand for batteries  in these market
                                                             23
 segments is expected  to grow between 3.5* and  8.2% per year.
      Prices for automobile SLI  batteries are about $16 to  $22 f.o.b.
 plant and about $35 to $50 retail.24  Prices for  industrial storage
 batteries range from  $200 to  $11,500.25 Because  batteries  represent
 such a small  percentage of vehicle costs and appear  to have few  close
                                     47

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substitutes, demand  is  thought  to  be price Inelastic.   However,  the
replacement demand market segment  for batteries is thought to be less
rice inelastic than the  new demand segment since useful  battery life
'An be extended by improved maintenance, servicing, and repair.
1.6.2  Model Plant Specifications  and Dispersion Modeling Results
    Two model lead  acid  battery plants are used in the dispersion
ndeling.  One is capable of producing 500 batteries per day; the other
is capable of producing 6500 batteries per day.  These two plant sizes
ire thought  to bound the  reasonable range of actual industry plant.sizes.
'insistent with the  dispersion model, both plants are located in flat terrain
rtth area meteorological  condition data available.  This situation is not
itypical since there is an actual  battery plant with similar terrain and
 cteorological features.
    None of the model  lead acid battery plants are assumed to have
 \ig1tive emissions.   All  emissions emanate from point sources.  These
 oint  sources are  controlled to average SIP allowable process weight
 ites.   The  maximum predicted concentration for the 500  battery per day
 lant  is 0.9 ug/m3,  monthly average.  The maximum  predicted concentration
 or a  6500 battery per day plant is  7.6 ug/m  , monthly average.
  .6.3   Control  Cost
     Since the maximum predicted concentration  for the model  500  battery
  er day plant does not exceed any  of the  considered standards,  no  control
  wts  are developed for  that model  plant.  Control  costs are  developed for the
  adel  6500 battery per day plant since  the maximum predicted  concentration
                                   48

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(7.6 ug/m ) does exceed the considered standards of 2.0, 1.5, and
1.0 y
     The only point source requiring control is the three process operation
stack.  Required control efficiencies for this source are about 75
percent, 81 percent, and 88 percent for the respective standards of 2.0,
1.5, and 1.0 ug/m .  A wet impingement scrubber is assumed to achieve
those control efficiencies at least cost.  The investment cost 1s not
assumed to vary with the required control efficiency and is estimated at
$130 thousand.  Operating costs  are, however, assumed affected to some
degree by the required control efficiency.  Respective annualized costs
for meeting 2.0, 1.5, and 1.0 standards are $57,000, $57,400, and $57,900.
Annualized cost as  a percent of  annual revenue  (assumes price per battery
of $18.50) is about 0.1% for each of three  standards.
2.6.4  Model Plant  Closure Assessment
     A low profit margin fully depreciated  model  6500  battery per day
plant should be able to  absorb the  control  costs  associated with any of
the  standards and  still  remain open.   This  finding holds for a  range of
marginal  tax rates and minimum  acceptable return  rates thought  to be
reasonable.   It  also  holds  given the assumptions  that  raw  material  lead
prices  increase  as a  result of  the lead ambient air quality  standard and
that this cost  increase (1.8 percent)  is absorbed.
      Process economics were developed using published  financial  data for
Gould,  Inc.  and Northwest Industries,  Inc.'s General  Battery Division.
                                    49

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                       3.0  OTHER AFFECTED SECTORS
3.1  MOBILE SOURCE ASSESSMENT
     Several assumptions are used to project mobile source impact.  These
include phasedown of lead in the gasoline pool, improved fuel economy,
and retirement of some older leaded gasoline using vehicles.  For an ambient
standard of 2.0 yg/m3, one Air Quality Control Region (AQCR) 1s predicted
to require mobile source emission control in 1982.  For an ambient standard
of 1.5, the number predicted is two AQCRs.  And, for an ambient standard of
1.0, it is four AQCRs.
     Vehicles using leaded gasoline are retired as they get older, and often
these vehicles are replaced with newer cars using unleaded gasoline.  Hence,
the number, of AQCRs requiring mobile source emission control might be less
in for example 1985 than in 1982.  In 1985, the number of AQCRs requiring
mobile source emission control is predicted to be one for the 2.0 and
        3                                    3
1.5 ug/m  standards, and two for the 1.0  ijg/m  standard.
     To achieve the alternative ambient standards in 1982 by retrofitting
existing leaded gasoline using light duty vehicles with 75% efficient lead
trap mufflers (if available) could affect the following number of vehicles.
For the 2.0 ug/m  standard, the predicted number is 58,000.  For the 1.5
ug/m  standard, the predicted number is 106,500.  And, for 1.0 vg/m3 standard
the predicted number of light duty vehicles affected is 1,300,000.
     Of course retrofitting lead trap mufflers is not the only means of
controlling mobile source lead emissions.  Reduction in vehicle miles
traveled (VMT) and further reduction in the lead content of gasoline are
alternatives.  VMT reductions can be achieved many ways including
                                     50

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carpooling, mass transit, and reduced trips.  Further reduction in the lead
content of gasoline can also be achieved in many ways including using non-lead
gasoline additives and increasing the reforming capacity of the refineries.
Costs for these many ways to achieve alternatives to retrofitting lead trap
mufflers have not been developed.  Consequently, relative cost effectiveness
of retrofitted lead traps 1s not known.
                                  51

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 3.2  STATE AND LOCAL AIR POLLUTION CONTROL AGENCY ASSESSMENT
      Currently there are 55 state and 235 local  air pollution  control
 agencies.   Annually they spend approximately 7100 man-years of effort  and
 $157 million dollars implementing air pollution  control  regulations.
      An ambient lead standard can impose additional requirements (costs)
 on State and local  air pollution control agencies to administer the
 standard.  The added requirements could take the  form of more data gathering,
•enforcement, monitoring, laboratory, support, and management activities.
 The previously described stationary and mobile source assessments are
 the bases for estimating these added requirements.  To the extent that
 these bases understate the magnitude of the problem (for example the
 number of source inspections) the added requirements for State and local
 control agencies are also understated.  But, even if the stationary and
 mobile source assessments do not understate the magnitude of the problem,
 control agency requirements could be understated for another reason.
 The estimates of additional state and local control agency costs do not
 include the requirements for developing completely new fugitive emissions
 inventories.  However, the estimates do include the requirements for
 additional maintenance and update of existing inventories.
      Some requirements  (costs) are estimated to be incurred in the first year
 only while others are on-going.  First year requirements include the costs
 for ambient monitors and laboratory equipment such as hi-vols and spectro-
 photometers.   In addition, there is non-recurring  labor for activities
 such as State  implementation  plan development and  site preparation for monitors.
                                    52

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No enforcement is assumed to take place during the first year while strategy
and regulations are being developed.  Also, in the first year monitoring and
laboratory activities are limited while equipment is being installed.  The
first year requirements in dollar terms range from $1.0 million with a
                    2
standard of 2.0 ug/m , monthly average to $1.7 million with a standard of
1.0 ug/ra .  The relative magnitudes of these costs compared to current
expenditures are 0.6% and 1.0%.  In terms of people, the corresponding
first year requirements are 30 man-years and 40 man-years.  Compared to
current man-years expenditures, these correspond to 0.4% and 0.6%, respectively.
     On-going or annual costs include operating costs but not depreciation
or interest.  Examples of operating costs are maintenance, supplies, and
power for ambient monitors and laboratory equipment.  Operating costs also
include a labor component.  For example, there are the on-going labor-using
activities of mobile and stationary source  inspection and enforcement.
On-going costs range from $1.4 million with a standard of 2.0 yg/m  to
$2.8 million with a standard of 1.0 yg/m .  The relative magnitude of
these costs are 0.9% and 1.8%.  The corresponding man-year requirements
are 60 and 120.  Compared to current man-year expenditures these correspond
to 0.9% and 1.7%, respectively.
     First year and on-going costs for the  3 considered standards are
presented in Table 3-1.
                                   53

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           Table 3-1.   STATE AND  LOCAL AIR POLLUTION CONTROL
                        AGENCY  STANDARDS ADMINISTRATION COST
                                    Alternative Ambient Standards
                                      (ug/m3  . monthly average)
                                  270           1.5            l.Q
irst  Year Cost
 000's  of $'s                      1000           1400          1700
 $  Expenditures  as  a
   %  of current
   expenditures                    .6%            .9%            l.Q*
 Man  year requirements              30            40              40
 Man-year requirements
   as a % of current             0.4%           0,655            0.6%
   expenditures
 i-Going (Annual  Costs)
 000's of $'s                     1*00           2300          2800
 $  Expenditures  as  a %
 of  current expenditures        0.9%           1.5%            1.8%
 Man-year  requirements             60            100            120
 Man-year  requirements
   as a %  of current             0.9%           1.4%            1.7%
   expenditures
                                    54

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                               References


 1.   PEDCo-Enviroranental Specialists, Inc., Draft Document prepared for
     the U.S.  Environmental Protection Agency,  Control  Techniques  For Lead
     Air Emissions, April, 1977, p. xix.

 2.   Ibid.,  p. xix.

 3.   Mitre Corporation/Metrek Division and Office of Air Quality Planning
     and Standards, U.S. Environmental Protection Agency, Draft Environmental
     Impact Statement for the National Ambient Air Quality Standard for Lead,
     November, 1977, Chapter 2.

 4.   Ibid.,  and background information in support of the aforementioned document.

 5.   Bureau of the Mines, U.S. Department of the Interior, Commodity Data
     Summaries: 1977, p. 91.       .

 6.   John Short and Associates, Inc., "Preliminary Technological Feasibility,
     Cost of Compliance and Economic Impact Analysis of the Proposed OSHA
     Standard for Lead", prepared for U.S. Department of Labor under Contract
     No. J-9-F-6-004, 1/77, p. 34.  See also Charles River Associates, Economic
     Analysis of the Lead-Zinc Industry, prepared under contract for the U.S.
     General Services Administration, revised April, 1969, p.  15.

 7.   Office of Air Quality Planning and Standards, U.S. Environmental Protection
     Agency, Users Manual for the Single Source (CRSTER) Model, EPA-450/2-77-013,
     July, 1977.

 8.   Bureau of the Mines, U.S. Department of Interior,  Mineral Yearbook -  1974,
     p. 731.

 9.    Federal Trade Conmission, Docket 18959, 4/20/76.

10.   Ibid.

11.   Stanford Research  Institute, Chemical Economics Handbook:  Copper.
     February 1976, p.  736.1000C.

12.   Ibid,  p. 736.1000B.

13.   Office of A1r Quality Planning and Standards, U.S. Environmental Protection
     Agency, Background Information for New Source Performance Standards:   Primary
     Copper, Z1nc« and  Lead Smelters, Volume I: Proposed Standards, EPA-450/2-74-002a,
   '  October, 1974, p.  6-14.

14.   Bureau of the Census, U.S. Department of Commerce, 1972 Census of Manufacturers,
     p. 33-B-6.
                                  55

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U.S. Department of Commerce, 1977 U.S. Industrial Outlook, p. 82.

Office of Air Quality Planning and Standards, U.S. Environmental
Protection Agency, Standards Support and Environmental Impact Statement:
An Investigation of the Best Systems of Emission Reduction for Electric"
Arc Furnaces in the Grey Iron Foundry Industry, October, 1976, p. 8-32.

Bureau of the Census, U.S. Department of Commerce, op. cit., p. 33-B-6.

PEDCo-Environraental.Specialists, Inc., op. cit.. p. 4-166.

U.S. International Trade Commission, Synthetic Organic Chemicals, U.S.
Production and Sales.  Also, Stanford Research Institute, Chemical
Economics Handbook:  Lead Alkyls, December, 1975, p. 6715042E.

Federal Register. December 6, 1973, 38 (234) 40CFR80: 33734-33741.

Stanford Research Institute, op. cit.. pp. 6715042R-S.

Barkand, R. A.  A Report by the Battery Council  International Statistical
Comnittee.  Replacement Battery; Industry Forecast 1975-1979.  Globe Union,
Inc.  Milwaukee, Wisconsin, p. 1.

Office of A1r Quality Planning and Standards, U.S. Environmental Protection
Agency, Draft Standards Support and Environmental Impact Statement:  Control
of Emissions from the Manufacture of Lead-Add Storage Batteries. September,
1977, p. 3-9 and p. 8-16.

Compiled from Company responses to U.S. Environmental Protection Agency
Inquiry regarding product prices.  The inquiry was issued under Section 114
of the Clean Air Act as Amended, 1970.

Conversation between the staff of JACA Corporation and two battery companies:
Illinois Battery on September 8, 1977, and Moore Battery Company on
September 14, 1977.
                              56

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