EPA-230/3-7E-D16
MAY 1976
ECONOMIC ASSESSMENT OF PROPOSED
TOXIC POLLUTANT EFFLUENT STANDARDS
FOR MANUFACTURERS AND FORMULATORS OF
ALDRIN/DIELDRIN, DDT, ENDRIN
AND TOXAPHENE
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Planning and Evaluation
Washington, D.C.
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ERRATA
ECONOMIC ASSESSMENT OF PROPOSED
TOXIC POLLUTANT EFFLUENT STANDARDS
FOR MANUFACTURERS AND FORMULATORS OF
ALDRIN/DIELDRIN. DDT, ENDRIN
AND TOXAPHENE
EPA-230/3-76-016
MAY 1976
Page 33- last paragraph
2nd line - change "carbon" to "resin"
11 » » J _ V _ II r I l__ _ _ __ J - _. i^ i I I
6th line - change activated carbon to resin adsorption
Page 34 - 4th paragraph
1st line,- change "reductive degradation or carbon" to "resin"
2nd line - change "$0.0090/kg" to "$0. 0178/kg"
3rd line - change " 1.1%" to "l.~6-2.1%"
Page 43
Under title insert "Cotton"
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EPA-230/3-76-016
ECONOMIC ASSESSMENT OF PROPOSED TOXIC POLLUTANT STANDARDS
FOR MANUFACTURERS AND FORMULATORSOF
ALDRIN/DIELDRIN, DDT, ENDRIN AND TOXAPHENE
Contract No. 68-01-1902
OFFICE OF PLANNING AND EVALUATION
ENVIRONMENTAL PROTECTION AGENCY
Washington, D.C. 20460
May 1976
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PREFACE
The attached document is a contractor's study prepared for the Office of Planning
and Evaluation of the Environmental Protection Agency (EPA). The purpose of the study
is to assess the economic impact which could result from the application of effluent
standards to be established under Section 307(a) of the Federal Water Pollution Control
Act, as amended.
The study supplements the technical study prepared by Midwest Research Institute
supporting the issuance of proposed regulations under Section 307(a). The technical study
surveys existing and potential waste treatment control methods and technology within
particular industrial source categories and supports proposal of certain effluent standards
based upon an assessment of the feasibility of these standards. Presented in the technical
study are the investment and operating costs associated with various alternative control and
treatment technologies. The attached document supplements this assessment 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 ap-
proaches in terms of product 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 Contract
No. 68-01-1902 by Arthur D. Little, Inc. Work was completed in May 1976.
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 Sec-
tion 307(a) of the Act for the subject toxic pollutants and categories of sources. The study
is not an official EPA publication. It will be considered along with the information
contained in the technical study and any comments received by EPA on either document
before or during proposed rule making proceedings necessary to establish final regulations.
Prior to final promulgation of regulations, the accompanying study shall have standing in
any EPA proceeding or court proceeding only to the extent that it represents the views of
the contractor who studied the subject industry. It cannot be cited, referenced, or repre-
sented in any respect in any such proceeding as a statement of EPA's views regarding the
subject industry.
111
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TABLE OF CONTENTS
Page
List of Tables ix
1.0 EXECUTIVE SUMMARY 1
1.1 INTRODUCTION AND CONCLUSIONS 1
1.2 CHARACTERIZATION OF THE GENERAL PESTICIDE INDUSTRY 3
1.3 CHARACTERIZATION OF THE PORTION OF THE PESTICIDE
INDUSTRY COVERED BY THE PROPOSED TOXIC POLLUTANT
STANDARDS 4
1.3.1 Toxaphene 4
1.3.2 DDT 4
1.3.3 Endrin 4
1.3.4 Aldrin/Dieldrin 5
2.0 INDUSTRY CHARACTERIZATION 7
2.1 GENERAL DESCRIPTION OF PESTICIDE INDUSTRY 7
2.1.1 The Manufacturers 7
2.1.2 The Formulators 11
2.2 CHARACTERIZATION OF PRODUCERS AND FORMULATORS OF
PESTICIDES SUBJECT TO THE PROPOSED TOXIC STANDARDS 13
2.2.1 Toxaphene 13
2.2.2 DDT 18
2.2.3 Endrin 19
2.2.4 Aldrin/Dieldrin 20
2.3 SELLING PRICES 21
2.3.1 Selling Prices of Pesticides Covered by the Proposed Toxic
Standards 21
2.3.2 Selling Prices of Formulated Products Containing Pesticides
Covered by the Proposed Toxic Standards 21
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TABLE OF CONTENTS (Continued)
Page
3.0 TREATMENT TECHNOLOGIES AND ASSOCIATED COSTS 23
3.1 TREATMENT TECHNOLOGIES AND ASSOCIATED COSTS FOR
PESTICIDE MANUFACTURERS AS REPORTED BY MIDWEST
RESEARCH INSTITUTE 23
3.1.1 Toxaphene 23
3.1.2 DDT 25
3.1.3 Endrin 25
3.1.4 Aldrin/Dieldrin 25
3.2 ESTIMATED ADDITIONAL TREATMENT COSTS 25
3.2.1 Toxaphene 30
3.2.2 Endrin 30
3.3 COST TO THE FORMULATORS OF MEETING THE PROPOSED
STANDARDS 30
4.0 ECONOMIC IMPACT ASSESSMENT 33
4.1 MANUFACTURERS 33
4.1.1 Aldrin/Dieldrin 33
4.1.2 DDT 33
4.1.3 Endrin 33
4.1.4 Toxaphene 34
4.2 FORMULATORS 35
APPENDIX I - PROFILE OF THE PESTICIDE FORMULATOR INDUSTRY 39
A. NUMBER/SIZE OF PLANTS 39
B. GENERAL STATISTICS 39
C. REGIONAL PROFILE (ACTIVE FORMULATORS} 40
APPENDIX II - POSSIBLE ALTERNATES FOR THE PESTICIDES
COVERED BY THE PROPOSED TOXIC POLLUTANT
STANDARDS 41
VI
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TABLE OF CONTENTS (Continued)
Page
APPENDIX II-Continued
A. INTRODUCTION 41
B. TOXAPHENE 42
C. ENDRIN 50
APPENDIX III - REPRESENTATIVENESS OF THE ADL TELEPHONE
SURVEY 55
VII
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LIST OF TABLES
Table No. Page
1.1 307(a) Compliance Costs for Pesticide Manufacturers 2
2.1.1 A Total U.S. Synthetic Organic Pesticide Production 8
2.1.1B Estimated Composition of U.S. Pesticide Sales 9
2.1.1C U.S. Synthetic Organic Herbicide Production 9
2.1.1D U.S. Synthetic Organic Insecticide Production (1960-1974) 10
2.1.1E U.S. Synthetic Organic Fungicide Production (1960-1974) 11
2.2.1 A Estimated U.S. Toxaphene Production (1974) 14
2.2.1 B Size Distribution of Toxaphene Formulators (1975) 15
2.2.1 C Breakdown of Typical U.S. Toxaphene Use in the 1970's 16
2.2.3 Size Distribution of Endrin Formulators (1975) 19
2.3.1 Selling Prices for Pesticides (1975) 21
2.3.2 Average Current Selling Price of the Formulated Product 22
3.1.1 Investment and Operating Costs Associated with the Proposed
Technologies for Treating Toxaphene-Containing Effluents 24
3.1.2 Investment and Operating Costs Associated with the Proposed
Technologies for Treating Effluents Containing DDT 26
3.1.3 Investment and Operating Costs Associated with the Proposed
Technologies for Treating Effluents Containing Endrin 27
3.1.4 Investment and Operating Costs Associated with the Proposed
Evaporation Technology for Treating Effluents Containing
Aldrin/Dieldrin 28
3.1.5 Pesticide Treatment Cost to Selling Price Ratios 29
4.2 Results of the Telephone Survey 36
IX
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1.0 EXECUTIVE SUMMARY
1.1 INTRODUCTION AND CONCLUSIONS
The purpose of this report is to assess the potential costs and economic impact of toxic
pollutant effluent standards for the manufacturers and formulators of aldrin/dieldrin, DDT,
endrin, and toxaphene. Effluent standards for these pesticides are being proposed by the
U.S. Environmental Protection Agency (EPA) under the authority of Section 307(a) of the
Federal Water Pollution Control Act Amendments of 1972. The proposed standards for
manufacturers are limitations on the discharge of the respective pesticides to the navigable
waters expressed in terms of concentrations (g/1) and mass emissions (g/kg of production) in
the effluent stream. For formulators, the standards specify a prohibition on the discharge of
pollutants. Controls or restrictions upon the production, marketing, or application of these
pesticides are beyond the statutory scope of these regulations; therefore, compliance with
any such regulations (under FIFRA or other authority) will not be considered here.
Compliance with the proposed effluent standards may require manufacturers or for-
mulators to install pollution abatement equipment, to modify current technical operations,
or to incorporate specialized facilities in new installations. The EPA contracted the services
of Midwest Research Institute (MRI) to examine alternative abatement technologies capable
of meeting the proposed effluent standards and to assess the costs of these treatment
systems. Detailed information on technologies and costs may be found in the series of MRI
reports entitled, "Wastewater Treatment Technology for (specific pesticide) Manufacture
and Formulation," dated February 1976. The MRI cost data were developed on the
assumption that none of the required treatment had as yet been installed; however, in
utilizing these data as the basis for economic impact assessment, Arthur D. Little, Inc.
(ADL), made appropriate adjustments for treatment already installed to determine the
additional costs attributable to the 307(a) regulations. The general conclusion of this
economic assessment is that there will be no significant economic impact upon the
manufacturers and formulators of these four pesticides resulting from compliance with the
proposed 307(a) standards.
For the manufacturers, this conclusion was reached following an examination of the
additional cost of complying with these standards, together with a general assessment of the
supply, demand, and pricing for the products and the business condition of the respective
firms. On the basis of this information, ADL concluded that the unit compliance costs were
sufficiently low that a detailed financial analysis was not necessary to determine that there
would be no adverse impact on sales, profitability, employment, or the end-use markets for
these pesticides. The basis for this conclusion is presented in the economic impact sections
for each product; the general cost information is summarized in Table 1,1.
For the formulators of these pesticides, ADL concluded that most plants would face
little or no additional cost in meeting the proposed standards. This conclusion was based on
a telephone survey of 16 companies operating 32 plants of the approximately 145 plants
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TABLE 1.1
307(a) COMPLIANCE COSTS FOR PESTICIDE MANUFACTURERS
DDT/no direct
discharge
Ald-Dield/no
direct discharge
Endrin/
Velsicol
Toxaphene/
Hercules
Toxaphene/
Riverside
Toxaphene/
Vicksburg
Total
Selling Price
S/kg
-
6.60
0.84
0.84
0.84
Annual
Production in
Met. Tons
(million Ib)
-
2,730(6)
22,700(50)
6,820(15)
4,545(10)
Compliance
Technology1
'
Reductive
degradation
Resin
adsorption
Contract
disposal
Evaporation
& incineration
Proposed
Effluent
Limitations
(ppb)
0
0
1.5
1.5
1.5
1.5
Investment
($000)
-
242- 362
543- 716
20
40
Additional Cost2
Annual
($000)
-
-_
109-161
295-400
81
40
Unit
-
0.040-
0.059
0.013-
0.018
0.011
0.009
845-1138
525-682
0.6-0.9
1.6-2.1
1.3
1.1
1. Treatment technology which meets the proposed limit. See Section 3 of this report for basis.
2. Additional cost of compliance, computed as total cost of compliance less technology in place. Range indicates flow assumptions used in cost com-
putations by Midwest Research Institute.
3. Does not include cost of monitoring and analysis. Inclusion of these costs at $40,000/year (per suggestion of the Department of Commerce) for the
two continuous dischargers raises the cost-sales ratios to 0.8-1.1% for Velsicol and 1.8-2.3% for Hercules. Compliance technology for Riverside and
Vicksburg is based upon no discharge of effluents; thus monitoring is not required.
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which currently formulate these pesticides. The sample surveyed included plants with a wide
range in size and geographic distribution. All formulators surveyed indicated that they
believed their present operations already complied with the proposed standards. ADL believes
that the findings of the telephone survey are representative of the practices of the pesticide
formulation industry, and that none of the formulators will incur a significant capital cost in
meeting the proposed standards. If, however, some plants do have to install facilities to
avoid contaminated runoff and/or require disposal of contaminated material, the unit cost
would not be large, except possibly for those firms which formulate very small volumes of
these four pesticides. The EPA estimated that, if a company were not presently meeting the
standards, it would have to install roofing and curbing, and incur an annual cost ranging
from about $1000 to $4000. EPA, assuming that no formulators presently meet the
standards, estimated that the preceding costs would have an adverse economic impact on
approximately 20 plants. Based on its telephone survey, ADL believes that substantially all
formulators now meet the standards. ADL thus concludes that the potential impact
estimated by EPA is very unlikely.
While the basic conclusion is that there will be no significant economic impact from
compliance with these regulations, we have presented some of the data collected during the
study for the use of the interested reader and to support our assumptions and conclusions.
1.2 CHARACTERIZATION OF THE GENERAL PESTICIDE INDUSTRY
The pesticide manufacturing industry is a major sector of the U.S. chemical industry
with the 1975 value of synthetic organic chemical active ingredients produced exceeding
$2160 million at the manufacturer's level. The major market for pesticides in the United
States is agriculture which we estimate consumes more than 90% of the pesticides used.
Pesticides are usually classified as herbicides, fungicides, or insecticides. Virtually all
domestic production of pesticides falls within these three classes, although small amounts of
rodent, bird, and other types of control materials are also produced.
Between 1960 and 1974 the quantity of pesticides produced more than doubled and
the manufacturers' value of pesticide production increased by more than fourfold. The
largest single component of U.S. pesticide production is herbicides which account for about
50% of the total pesticide value. During the 1960's herbicide production experienced
considerable growth. However, since 1968 pesticides and fungicides have had higher growth
rates.
There are a relatively small number of firms manufacturing pesticides, but they manu-
facture a wide variety of products. We estimate that the 10 largest firms account for about
75% of total U.S. pesticide sales.
The companies which dominate the pesticide industry, for the most part, achieved
their position through the sale of proprietary products. Industry observers estimate that the
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relative profitability (per sales dollar) of proprietary products is normally at least double
that for products which do not have patent protection.
The pesticide formulation industry is more difficult to characterize than the pesticide
manufacturing industry. There are a large number of small formulators for whom statistics
are not readily available. The Midwest Research Institute indicated in 1975 that there are
presently 5300 plants manufacturing some pesticide formulations. A large number of these
plants are primarily involved in other businesses. However, the 1972 Census of Manufactures
showed only 388 establishments whose primary business is the making of pesticide formu-
lations. The Census also showed that the 388 establishments employed 12,200 people, had
payrolls of $116.5 million, and made a product valued at $1196.2 million.
1.3 CHARACTERIZATION OF THE PORTION OF THE PESTICIDE INDUSTRY
COVERED BY THE PROPOSED TOXIC POLLUTANT STANDARDS
1.3.1 Toxaphene
Toxaphene is the most widely used insecticide in the United States in terms of total
poundage. At present there are four manufacturers of toxaphene in the United States, viz.,
Hercules, Tenneco, Vicksburg, and Riverside. Only Hercules, Vicksburg, and Riverside are
direct dischargers. In 1974, approximately 90 million pounds of toxaphene were produced.
Reportedly toxaphene production dropped significantly in 1975 due at least partially to a
30% decrease in cotton acreage, the primary target crop for this product.
In 1975, there were 99 plants formulating products containing toxaphene. The median
toxaphene formulation plant had an annual production of 255,000 pounds of formulated
product. The average selling price is $0.50/lb of formulated product.
1.3.2 DDT
The Montrose Chemical Company facility in Torrance, California, is the only plant manu-
facturing DDT in the United States. It is also the major formulator of DDT. All the DDT manu-
factured at this plant is exported. Montrose produces between 18,100 and 27,200 metric tons
of DDT per year, depending on market conditions, and supplies about 50% of the world market
for DDT. Most of the market is comprised of various international health organizations. Mont-
rose will not be affected by the proposed toxic standards because it is not a direct discharger.
1.3.3 Endrin
The Velsicol Chemical Corporation plant in Memphis, Tennessee, is the only facility
within the United States manufacturing endrin. It produces approximately 2700 metric tons
of endrin per year. Of the 1975 production, only approximately 16% was applied within the
United States. Approximately two-thirds of this volume was used on cotton with the other
major application being on corn. Velsicol manufactures about 25 to 30% of the world
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market for endrin. In 1975, Velsicol Chemical also produced about 50% of all endrin
formulations. The remaining endrin formulations were produced by 38 other plants. The
median endrin formulator produced 13.6 metric tons of product valued at $7.26/kg. Other
pesticides can be used to control the same pests controlled by endrin although these
pesticides may not be as efficient or as economical.
1.3.4 Aldrin/Dieldrin
In 1974 the EPA banned the agricultural use of aldrin/dieldrin. The use of aldrin/
dieldrin for the protection of shelters was not banned.
At the time use of aldrin/dieldrin for agricultural purposes was banned, Shell was the
only producer in the United States. Shell formally announced the closing of its plant
following the ban on agricultural use. At present aldrin/dieldrin is being produced overseas
by Shell; however, there appear to be no plans to resume production in the United States.
We have been unable to locate any aldrin/dieldrin manufacturing operations which are direct
dischargers or any formulators of aldrin/dieldrin.
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2.0 INDUSTRY CHARACTERIZATION
2.1 GENERAL DESCRIPTION OF PESTICIDE INDUSTRY
2.1.1 The Manufacturers
The pesticide manufacturers represent a major sector of the U.S. chemical industry.
The value of synthetic organic chemical active ingredients produced by this industry in 1975
exceeded $2160 million at the manufacturer's level. The major market for pesticides in the
United States is agriculture. We estimate that more than 90% of all pesticides consumed
domestically is used for the protection of agricultural products.
The most common categorization of pesticides is by type of pest controlled, e.g.,
weeds, insects, fungal diseases, and the like. Three classes of products herbicides, fungi-
cides, and insecticides (including nematocides and acaracides) compose virtually all
domestic pesticide production, although small amounts of rodent- and bird-control materials
are also produced.
The physical volume of pesticide production more than doubled between 1960 and
1974. During the same period, the manufacturers' value of this production increased by
more than 400%. Historical information on U.S. pesticide production value, and average
price are presented in Table 2.1.1 A.
The largest single component of U.S. pesticide production in terms of value is
herbicides. With an average manufacturer's price of $4.80/kg ($2.18/lb), herbicides ac-
counted for about 60% of total pesticide value, while providing less than 40% of pesticide
poundage. The relative importance of the three product classes is given in Table 2.1.1B.
The proportionate value of these components has changed considerably since 1960
with herbicide production exhibiting dramatic growth during the 1960's. Since 1968,
however, both insecticides and fungicides have exhibited a greater annual growth rate in
sales than herbicides. Historical production and value data for herbicides, insecticides, and
fungicides are presented in Tables 2.1.1C, 2.1.ID, and 2.1.IE.
The pesticide industry is composed of a relatively small number of firms producing a
wide variety of products. There is considerable concentration in the industry with the 10
largest firms estimated to account for about 75% of total U.S. pesticide sales. The industry
is further stratified by the fact that less than 10% of the products (45) are estimated to be
responsible for nearly 70% of the total pesticide sales value. In fact, industry experts
estimate that as few as 12 products comprise over 40% of the total value of pesticide sales.
Companies which dominate the pesticide industry, for the most part, achieved their
position through sales of proprietary products, i.e., products for which they hold a patent
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TABLE 2.1.1 A
TOTAL U.S. SYNTHETIC ORGANIC PESTICIDE PRODUCTION1
(1960-1974)
(active ingredients at the manufacturer's level)
Average Price
Year Metric Tons Millions of Pounds Value
($ millions)
1960 295.000 648 306
1961 318,000 700 366
1962 332,000 730 458
1963 347.000 764 453
1964 356.000 783 513
1965 399.000 877 607
1966 460.000 1,013 761
1967 477,000 1,050 988
1968 542.000 1.192 1.138
1969 502,000 1.104 1.113
1970 470,000 1,034 1.087
1971 516.000 1,135 1.276
1972 526.000 1.157 1.313
1973 585.000 1,289 1.453
1974 642.000 1,415 1.950
1960-1968 8 18
1968-1974 2 6
1. Herbi.cides. insecticides, and fungicides
Source: United States International Trade Commission.
$/kg
1,03
1.14
1.39
1.30
1.45
1.52
1.65
2.07
2.09
2.22
2.31
2.46
2.49
2.49
3.04
$/lb
0.47
0.52
0.63
0.59
0.66
0.69
0.75
0.94
0.95
1.01
1.05
1.12
1.13
1.13
1.38
9
3
position. Industry observers estimate that the relative profitability (per sales dollar) is
normally at least doubled for proprietary products versus commodity products (no patent
protection). This profit relationship will, of course, vary with manufacturing costs, value of
crop protected, potential pest damage, and the like.
In the pesticide industry the relative profitability of a product is affected by the
competitiveness of the market for control of the specific pests. For instance, some industry
8
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TABLE 2.1.18
ESTIMATED COMPOSITION OF U.S. PESTICIDE SALES
(1974)
Class Metric Tons
Herbicides 275,000
Insecticides 295,000
Fungicides 74,000
644,000
Volume
Millions of
Pounds Percent
604 43
650 46
163 11
1,417 100
Manufacturers'
Value
Million $ Percent
1,211 62
605 31
138 7
1,954 100
Source: Arthur D. Little, Inc., calculations based on United States International
mission data.
TABLE 2.1.1C
Average Price
$/kg $/lb
4.40 2.00
2.05 0.93
1.86 0.85
Trade Corn-
U.S. SYNTHETIC ORGANIC HERBICIDE PRODUCTION
(1960-1974)
(active ingredients at the manufacturer's level)
in
Year Metric Tons
1960 47,000
1961 55,000
1962 69,000
1963 80,000
1964 103,000
1965 120,000
1966 147,000
1967 136,000
1968 213,000
1969 179,000
1970 184,000
1971 195,000
1972 205,000
1973 225,000
1974 239,000
Annual Growth (Percent)
1960-1968
1968-1974
Volume
in
Millions of Pounds
103
121
151
175
226
263
324
409
469
393
404
429
451
496
525
21
2
Value in
$ Millions
79
113
147
166
243
302
386
617
718
662
663
800
816
844
925
32
4
Average Price
$/kg $/lb
1.69 0.77
2.05 0.93
2.13 0.97
2.09 0.95
2.38 1 .08
2.53 1.15
2.62 1.19
3.32 1.51
3.37 1.53
3.70 1.68
3.61 1.64
4.08 1.86
3.98 1.81
3.74 1 .70
3.87 1.76
9
2
Source: United States International Trade Commission
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TABLE 2.1.1D
U.S. SYNTHETIC ORGANIC INSECTICIDE PRODUCTION
(1960-1974)
(active ingredients at the manufacturer's level)
Volume
Value in Average Price
$ Millions $/kg $/lb
157 0.95 0.43
193 1.03 0.47
258 1.23 0.56
234 1.08 0.49
219 1.08 0.49
248 1.12 0.51
317 1.25 0.57
304 1.34 0.61
347 1.34 0.61
383 1.47 0.67
340 1.52 0.69
393 1.54 0.70
406 1.58 0.72
495 1.69 0.77
605 2.05 0.93
Annual Growth (Percent)
1960-1968 6 10 4
1968-1974 3 85
Source: United States International Trade Commission
personnel believe that profitability per sales dollar is generally higher for herbicides than for
insecticides because of the high degree of competition in the insecticide market.
The willingness and the ability of the pesticide user to tolerate price increases will vary
for different crops, according to the pest to be controlled and the crop value at risk. Once a
crop is planted, it is only a question of how much pesticide costs versus the value of the
crop yield to be saved. Growers of a high-value crop would normally be more willing to
absorb price increases than growers of low-value crops such as grain.
The only portion of the pesticide industry covered by the proposed standards for toxic
pollutants is the manufacture and formulation of toxaphene, DDT, endrin, and aldrin/
10
Year
1960
1961
1962
1963
1964
1965
1966
1967
1968
1969
1970
1971
1972
1973
1974
in
Metric Tons
166.000
187.000
210,000
217,000
202,000
223,000
251,000
225,000
259,000
260,000
223,000
254,000
256,000
290,000
302,000
in
Millions of Pounds
366
411
461
478
444
490
552
496
569
571
490
558
564
639
650
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TABLE 2.1.1E
U.S. SYNTHETIC ORGANIC FUNGICIDE PRODUCTION
(1960-1974)
(active ingredients at the manufacturer's level)
Year
1960
1961
1962
1963
1964
1965
1966
1967
1968
1969
1970
1971
1972
1973
1974
in
Metric Tons
82,000
76,000
54,000
50,000
51,000
56,000
62,000
65,000
70,000
64,000
64,000
68,000
65,000
70,000
73,000
Volume
in
Millions of Pounds
180
168
118
111
113
124
137
144
154
141
140
149
143
154
163
Annual Growth (Percent)
1960-1968
1968-1974
-2
1
Value in Average Price
$ Millions $/kg $/lb
70 0.86 0.39
60 0.79 0.36
53 0.99 0.45
53 1.06 0.48
51 0.99 0.45
58 1.03 0.47
60 0.97 0.44
66 1.01 0.46
72 1.03 0.47
68 1.06 0.48
71 1.12 0.51
82 1.21 0.55
92 1.41 0.64
114 1.63 0.74
138 1.86 0.85
<1 2
10 9
Source: United States International Trade Commission
dieldrin. All. of these pesticides are chlorinated organic compounds. At present, there are no
producers who are direct dischargers of DDT and aldrin/dieldrin in the United States.
2.1.2 The Formulators
The pesticide formulation industry is difficult to characterize accurately. There are
a large number of small formulators for whom statistics are not readily available. According
to Midwest Research Institute's formulation technology documentation,* there are pre-
sently 5300 plants manufacturing pesticide formulations. However, the 1972 Census of
Manufactures shows only 388 establishments whose primary business is in SIC 2879, the
*Wastewater Treatment Technology Documentation for aldrin/dieldrin, toxaphene, DDT, endrin, formu-
lators, May 1976.
11
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SIC category covering pesticide formulators. The Census shows that the 388 establishments
employed 12,200 people, had payrolls of $116.5 million, and made products valued at
$1196.2 million.
Companies owning pesticide formulation plants range in size from those having only
one or two registrations to those having hundreds. Plants in the formulation industry fall
into one of the following three categories: (l)the pesticide producer and formulator,
(2) the independent formulator, and (3) the small packager. Only categories (2) and (3) are
of concern in this section of the report. Those formulators affected by the proposed toxic
standards and falling in category (1) are covered with the manufacturers of the respective
pesticide.
The independent formulator typically formulates a number of products which he
markets under his own brand, although he may also formulate products on a contractual
arrangement with a manufacturer. He often manufactures the contracted products under the
manufacturer's brand. The reason for contract formulation is that a number of large
pesticide manufacturers do not formulate any of their own products.
The small packager typically manufactures one to five formulations which he markets
under his own brand. Pesticide formulation is often only a small portion of his business and
sometimes small packagers will contract an independent formulator to do their formulation
work.
A formulator takes technical-grade pesticide active ingredients, dilutes them, and
transforms them into a usable form. The dilution is carried out by combining the technical-
grade pesticides with an inert material. Often, for efficacy reasons, a pesticide formulation
will contain more than one type of active ingredient. For example, many formulations often
combine methyl parathion with toxaphene. In its final physical form, a formulation can be
an emulsifiable concentrate, a powder, a dust, or granules.
Emulsifiable concentrates are combinations of technical-grade pesticides and emulsi-
fiers in a solvent. The emulsifiable concentrate formulations are always diluted by water or
oil before application. Emulsifiable concentrates usually contain 15% to 50% concentrations
of the technical-grade pesticide, although they can contain 80% or more pesticide materials
when combinations of different pesticides are used. The concentration of emulsifiers is
usually 5% or less. Typical solvents used to make emulsifiable concentrates include xylenes,
methyl isobutyl ketone, and deodorized kerosene.
Powders are a mixture of pesticide, inert carriers, and adjuvants that are mixed with
water by the user before application. The powders usually contain a concentration of 15%
to 95% of the technical-grade pesticide and a concentration of 1% to 5% surfactant to
improve wettability and suspendability.
12
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Dusts are formulations which contain a relatively low concentration of the technical-
grade pesticide absorbed onto an inert powder. While the potency of dusts is low, they are
relatively inexpensive and simple to apply. However, their use is becoming less common
because of problems caused by the ease with which they can be blown away by the wind.
Granules are similar to dusts and are formed by impregnating the technical-grade
material onto granular carriers. Common carriers include clay, vermiculite, sand, carbon, and
diatomaceous earth. The content of fine particles is minimized to prevent the problems that
occur with the use of dust.
2.2 CHARACTERIZATION OF PRODUCERS AND FORMULATORS OF PESTICIDES
SUBJECT TO THE PROPOSED TOXIC STANDARDS
Four pesticides are subject to the 307(a) toxic standards. These are toxaphene, DDT,
endrin, and aldrin/dieldrin. The EPA supplied ADL with a profile of the pesticide formu-
lator industry subject to the proposed standards. A copy of this profile is presented as
Appendix I.
2.2.1 Toxaphene
Toxaphene is the most widely used insecticide* in the United States in terms of total
poundage. A 1974 study** sponsored by the Office of Pesticide Programs, U.S. Environ-
mental Protection Agency (EPA), estimated 1972 domestic consumption at 26,300 metric
tons (58 million Ib). Our recent assessment of the toxaphene market indicates that domestic
consumption probably did not change through 1974 with consumption in the range of
25,000 to 28,000 metric tons (55 to 62 million Ib). Reportedly toxaphene usage dropped
significantly in the United States in 1975. The drop was due, at least partially, to the 30%
decrease in cotton acreage planted, the primary target crop of this product.
Four companies (Hercules, Tenneco, Riverside, and Vicksburg) manufacture toxaphene
in the United States. The production of these companies (delineated in Table 2.2.1 A) is
sufficient to supply U.S. toxaphene needs and about 60% of non-U.S. toxaphene demand
which is estimated at something less than 23,000 metric tons (50 million Ib) annually.
In 1975, 133 plants were registered to formulate products containing toxaphene. The
mean output of 99 plants for which production data were available was 594,000 pounds of
formulated product per year, and the median output was 255,000 pounds of formulated
product per year. Table 2.2.IB shows the size distribution of toxaphene formulators for
1975.
'Chemical and Engineering News, July 28, 1975.
'"Production, Distribution, Use and Environmental Impact Potential of Selected Pesticides, OPP, U.S.
EPA, 1974.
13
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TABLE 2.2.1 A
ESTIMATED U.S. TOXAPHENE PRODUCTION
(1974)
Toxaphene Sales
Company
Hercules
Tenneco
Vicksburg
Riverside
Total
United
Thousand* of
Metric Tons
14.5-15.9
4.5- 5.5
2.3
3.6- 4.5
24.9-28.2
States
Millions
of Pounds
32-35
10-12
5
8-10
55-62
Exports
Thousands of
Metric Tons
8.6-10
2.7- 3.6
1.8
0
13.1-15.4
Millions
of Pounds
19-22
6- 8
4
0
29-34
Total
Thousands of
Metric Tons
24.5
8.2
4.1
3.6-4.5
±41
Millions
of Pounds
54
18
9
8-10
-90
Source: Arthur D. Little, Inc., estimates.
-------
TABLE 2.2.1B
SIZE DISTRIBUTION OF TOXAPHENE FORMULATORS
(1975)
Projected Output Number of
of Toxaphene in 1975 Plants
(thousands of pounds)
1- 10 6
11- 25 10
26- 50 9
51- 100 9
101- 200 11
201- 300 9
301- 400 6
401- 500 5
501- 750 12
751-1000 4
1001-1500 7
1501-2000 6
2001-3000 2
3001-4000 1
4001-5000 1
5001+ _1
99
Source: Environmental Protection Agency
The most important use of toxaphene has traditionally been in the control of cotton
insects, usually in combination with other insecticides (DDT until 1973, methyl parathion,
and others). Toxaphene can easily be formulated or mixed with other insecticides, and it is
often desirable to do so. Toxaphene appears to act as a solubilizer for insecticides that have
low solubility by themselves. Additionally, some combinations of toxaphene with other
insecticides are reported to have synergistic properties. Although less significant than
cotton, other important uses for toxaphene are on livestock and various field crops
(including soybeans and peanuts). Somewhat marginal uses (in the context of the total
market) are on vegetable crops and ornamentals.
Typical toxaphene use during the 1970's is given in Table 2.2.1C. However, usage can
vary considerably on an annual basis depending on the level of cotton acreage planted in any
given year.
Resistance of some target pests is a problem with crops in certain regions. Often
combining toxaphene with other insecticides has been sufficient to overcome the resistance
problem. Some non-target species (fish) in areas of heavy toxaphene use can have also de-
veloped resistance.
15
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TABLE 2.2.1 C
BREAKDOWN OF TYPICAL U.S. TOXAPHENE USE IN THE 1970's
Use Percent of Use
Crops 87.7
Cotton 75.0
Soybeans 4.1
Peanuts 3.6
Other Field Crops 2.6
Vegetables 2.1
Fruits and Nuts 0.2
Nursery and Greenhouse 0.1
Livestock 12.1
Beef 9.3
Swine 2.3
Others 0.6
Other 0.1
Total 100.0
Source: Arthur D. Little, Inc., estimates are based on U.S. Department
of Agriculture and industry information.
There are other chemical insecticides which control some or most of the insects
controlled by toxaphene. However, the possible alternates for toxaphene may not be as
efficacious or economical. Appendix II discusses possible alternates for toxaphene.
Each manufacturer of toxaphene uses camphene as a raw material. The camphene is
produced from a-pinene, a product of the gum and wood chemicals industry (SIC 2861).
The following is a description of the toxaphene manufacturers who discharge directly
to the navigable waters:
Hercules
Hercules is the largest producer of toxaphene in the United States. In 1974, it
produced an estimated 24,000 metric tons (54 million Ib), or approximately 60% of the
U.S. toxaphene production volume; it was valued at an estimated $15.7 million at the manu-
facturer level. This represented slightly more than 1% of total Hercules' sales for that year.
Hercules produces its own camphene, the major input for the production of toxa-
phene. Approximately 80 persons are employed in the production of toxaphene and
another 50 are employed in sales and sales-related work for toxaphene.
16
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Hercules is not forward-integrated. However, the firm does contract in the United
States for small amounts of formulation to meet market needs in certain countries with no
formulators. Some 15 to 20 formulators in the United States (out of approximately 80 who
formulate toxaphene) handle the bulk of Hercules' production for the domestic market.
Hercules exported an estimated 8,600 to 10,000 metric tons (19 to 22 million Ib) of
toxaphene in 1974 valued at $7 to $9 million (1974 prices). This represents approxi-
mately 40 to 50% of the non-U.S. world market. Hercules deals primarily with formulators
and governments for all its overseas sales. Hercules is involved in a joint venture in
Nicaragua. In addition, it began to construct a plant in Brazil with an annual capacity of
11,300 metric tons (25 million Ib). However, construction has been halted because the
Brazilian government wants to change the plant location to a site in northern Brazil. As of
December 1975, we believe that the problem had not been resolved. At the present time, we
believe Hercules has no other expansion plans.
The Hercules plant at Brunswick, Georgia (which produces toxaphene as well as other
chemicals), is an old plant which should be fully depreciated. Although maintenance and
repair costs for this plant are probably greater than those of a new plant, they ought to be
lower than interest and depreciation costs on a new plant. This lower cost may give Hercules
greater pricing flexibility than, say, Riverside with its new Texas plant and Vicksburg
Chemical with its Mississippi plant. Hercules' ownership of camphene production facilities
and the economies of scale inherent in large-scale production further contribute to its
favorable market position. Should toxaphene pricing become more competitive in the
future, Hercules would probably have an advantage over its competitors.
Riverside
Riverside Chemical produced an estimated 3,600 to 4,500 metric tons (8 to 10 million
Ib) of toxaphene in 1975 with an estimated manufacturer's value of S3 to $4 million. In
1974, toxaphene products represented 2 to 3% of Riverside's total sales. It supplies
approximately 12 to20%of U.S. production. Some of its production was exported in 1975.
Sonford Chemical was the original owner of the Groves, Texas, toxaphene facility now
owned by Riverside. Bison bought the site from Sonford, tore down the original plant, and
constructed a new one. This new plant was then purchased by Riverside. Riverside recently
finished (August 1975) doubling the size of this plant to its present capacity of 15 million
Ib. This plant employs 29 persons. We believe Riverside has no present plans for further
production expansion, since the expanded plant is presently operating at less than full
capacity.
17
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Riverside plans to increase exports in 1976 so that the plant will be operating closer
to capacity. Since Riverside has no market structure or experience in the foreign marketing
of pesticides, it is probably contracting with brokers to do the marketing for them.
Riverside's toxaphene operations are not back-integrated. Riverside's forward-
integration consists of ownership of 15 formulators who formulate all toxaphene produced
by Riverside as well as other chemicals. (Toxaphene-based products represent 50% of their
formulation business.) Riverside acts as a distributor for all its toxaphene products. Fifty
percent of these products are sold through its own dealers. Unformulated toxaphene
materials "sold" represent only 2 to 3% of Riverside's total sales. However, when distributor
and retail prices of toxaphene-based products sold by Riverside are also included, the value
to Riverside of toxaphene sales become significant. (No estimate of this value is presently
available.)
Vicksburg
Vicksburg Chemical produced an estimated 4100 metric tons (9 million Ib) of toxa-
phene in 1974 which was 10% of the U.S. production. The estimated value of production
was $3.4 million (1975 manufacturers' price), or 8 to 10% of total Vicksburg sales.
Vicksburg marketed approximately 2300 metric tons (5 million Ib) domestically, or 8
to 10% of the U.S. market. Vicksburg neither formulates, distributes, nor retails toxaphene
products.
Vicksburg Chemical's plant in Vicksburg, Mississippi, has a toxaphene capacity of 5900
to 6800 metric tons (13 to 15 million Ib) and employs 12 to 15 persons in toxaphene
production. Vicksburg does produce chlorine, an important input for toxaphene, but not
camphene, the most important input. Vicksburg's toxaphene plant is only two years old
(December 1975).
Vicksburg exports an estimated 1800 metric tons (4 million Ib) of toxaphene annually
which represents 8 to 10% of the world market. The value of these exports would be $1.5
million using 1975 manufacturers' prices. They market almost exclusively in South America
through formulators.
2.2.2 DDT
The Montrose Chemical Company facility in Torrance, California, is the only plant
manufacturing DDT in the United States. This plant is not a direct discharger. The Montrose
plant and one other facility are the only formulators of DDT. All DDT from these plants is
exported, since DDT is not used in the United States.
The major users of DDT are the various international health agencies, such as the Pan
American Health Organization, WHO, and the UN. These organizations distribute DDT to
18
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the health ministries of various governments. The primary health application of DDT is in
the control of malaria-carrying mosquitoes. Many industry observers believe that no other
pesticide is as effective in mosquito control.
Agricultural use of DDT is primarily on cotton, although some is used on the soybean
crop. Throughout the world the system of distribution for agricultural application varies
from government purchase and control to systems similar to that found in the United
States. The agricultural market for DDT is slowly declining because of increased compe-
tition from other products, decreased acreage of crops on which DDT is used, and bans on
its use by some countries.
2.2.3 Endrin
The Velsicol Chemical Company facility in Memphis, Tennessee, is the only plant
manufacturing endrin within the United States. Velsicol is included in the economic
impact assessment because it discharges directly as well as to a municipal system. Approx-
imately two-thirds of the endrin produced is used on cotton. The other major use of
endrin is on corn. It is also used as a rodenticidc and for emergency use on small grains.
There are other pesticides which are used to control some or most of the pests controlled
by endrin. However, the possible alternate for endrin may not be so efficacious or
economical. Appendix II discusses possible alternates for endrin.
Besides Velsicol, some 38 other plants prepare endrin formulations. The mean size of
all plants formulating endrin is 410 metric tons (84,000 Ib) of formulated product per year
and the median size is 13.6 metric tons (30,000 Ib) of formulated product per year.
Table 2.2.3 shows the 1975 size distribution of plants producing endrin formulations.
TABLE 2.2.3
SIZE DISTRIBUTION OF ENDRIN FORMULATORS (1975)
Projected Output Number of
of Endrin in 1975 Plants
(thousands of pounds)
1- 10 7
11- 25 11
26- 50 3
51-100 8
101-200 6
201-300 2
301-400 1
401-500 0
501-750 J
,39
«
Source: U.S. Environmental Protection Agency
-------
Velsicol
Velsicol produces several products at its facility in Memphis, Tennessee. Endrin,
however, is produced in a separate unit within the facility. An estimated 20 to 25 people are
employed in the endrin operation. Production is approximately 2700 metric tons (6 million
Ib) per year. The estimated value of the production for 1976 was approximately $17
million. Of the 1975 production only approximately 16% was applied within the United
States.
Velsicol buys most of the raw materials it uses to manufacture endrin. However, it does
have a captive source of chlorine and cyclopentadiene which are reacted to make hexa-
chlorocyclopentadiene, one of the inputs to the endrin manufacturing process.
Velsicol itself makes more than 50% of all endrin formulations at its Memphis plant.
The remaining formulation is done by 10 to 12 major insecticide formulators. However,
there are 63 companies which have endrin labels registered.
The world market for endrin is 9,100 to 11,300 metric tons (20 to 25 million Ib) per
year. Velsicol has about 25 to 30% of this market, with Dutch Shell being the major
supplier. Most endrin exports are typically in the technical form with only a small amount
already formulated. In Latin America the majority of the endrin produced by Velsicol is
formulated by firms controlled by or contracted to Velsicol. Velsicol then acts as the
distributor of these formulated materials, acting in the capacity of a dealer. The remainder
of the endrin shipped to Latin America is formulated and distributed by non-affiliated
firms. There is minimal government purchasing of endrin in Latin America. Veliscol is
apparently gaining volume and market share hi Latin America.
In Africa and the Near East, most of the marketing of endrin is done through
governments. Loss of a single contract could significantly affect Velsicol's annual sales.
2.2.4 Aldrin/Dieldrin
In 1974, the Environmental Protection Agency banned the agricultural use of aldrin/
dieldrin. At the time, the major uses of aldrin/dieldrin were on corn and for the protection
of structures from termites. Minor uses were on sugarcane, tobacco, and other field,
vegetable, and fruit crops. The use of aldrin/dieldrin for the protection of structures was not
banned by the EPA.
Shell was the only producer of aldrin/dieldrin at the time its agricultural use was
banned. It was producing it at its facility in Denver, Colorado, which still produces
numerous other products. In 1975, Shell formally announced the closing of the aldrin/
dieldrin plant: The plant had employed approximately 80 people. At the time it was shut
down, it is believed to have been operating at approximately 50% of capacity.
20
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In 1971, the Shell plant produced approximately 4100 metric tons (9 million Ib) of
aldrin/dieldrin. At today's prices, this production would have been worth $12.15 million.
The current price is based on production by Shell (London). Shell appears to have no plans
to resume aldrin/dieldrin production in the United States
There are some formulators who have aldrin/dieldrin registrations. As far as we have
been able to determine,however, none of the formulators having aldrin/dieldrin registrations
are making aldrin/dieldrin formulations.
2.3 SELLING PRICES
2.3.1 Selling Prices of Pesticides Covered by the Proposed Toxic Standards
Table 2.3.1 shows the 1975 selling price of the pesticides covered by the proposed
standards for toxic pollutants. Average prices for all pesticides rose at an annual rate of 8
percent from 1960 to 1975. Toxaphene prices rose 50 percent from 1972 to 1975, but
prices of endrin and DDT have not risen so rapidly.
TABLE 2.3.1
SELLING PRICES FOR PESTICIDES
<1975)
Selling Price
Pesticide $/kg $/lb
Toxaphene 0.84 0.38
Endrin 6.60 3.00
DDT 0.88-1.10 0.40-0.50
Aidrin/dieldrin 2.97* 1.35*
*Based on Shell (London) prices.
Source: Arthur D. Little, Inc., estimates based on a telephone sur-
vey of industry representatives.
2.3.2 Selling Prices of Formulated Products Containing Pesticides
Covered by the Proposed Toxic Standards
Table 2.3.2 shows the average prices charged by the formulator for products containing
DDT, endrin, and toxaphene.
21
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TABLE 2.3.2
AVERAGE CURRENT SELLING PRICE OF THE FORMULATED PRODUCT
Price of Formulated Product
Pesticide $/lb S/kg
DDT 0.36 0.79
Endrin 3.30 7.26
Toxaphene 0.50 1.10
Source: Arthur D. Little, Inc., estimates based on a telephone survey of in-
dustry.
22
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3.0 TREATMENT TECHNOLOGIES AND ASSOCIATED COSTS
3.1 TREATMENT TECHNOLOGIES AND ASSOCIATED COSTS FOR PESTICIDE
MANUFACTURERS AS REPORTED BY MIDWEST RESEARCH INSTITUTE
Midwest Research Institute (MRI) was retained by EPA to determine what techno-
logies are available for treating effluents from the manufacture of pesticides which will be
subject to the proposed standards for toxic pollutants. For each technology identified they
were to estimate the costs associated with its implementation. In developing these costs,
they were not to take into consideration whether any other steps of the proposed tech-
nology had already been installed.
The proposed standards for toxaphene, DDT, endrin, and aldrin/dieldrin set the
following effluent limitations on manufacturers:
Toxaphene - 1.5 ppb
DDT - 0 ppb
Endrin - 1.5 ppb
Aldrin/dieldrin - 0 ppb
This section presents the technologies and associated costs developed by MRI*.
Although there are no direct discharges of DDT and aldrin/dieldrin, we have included the
MRI data for these pesticides since that information is applicable to new sources. In
Section 3.2, we present estimates of the additional cost each manufacturer who is a point-
source discharger will incur if the proposed standards are implemented.
3.1.1 Toxaphene
In its report dated February 6, 1976, MRI proposes four treatment technologies for
eatine effluents cnntainine toxanhene-
treating effluents containing toxaphene:
1) adsorption on activated carbon;
2) adsorption on XAD^ resin;
3) reductive degradation; and
4) adsorption on XAD^4 resin followed by reductive degradation.
Cost estimates for adsorption on activated carbon were based on an effluent flow rate of
1136 C/min. Since the required adsorption contact time has not been determined, cost
estimates were prepared for two different contact times, viz., 30 minutes and 60 minutes.
The costs of resin adsorption, reductive degradation, and resin adsorption followed by
reductive degradation were each estimated at two effluent flow rates, viz., 757 and 1136
C/min. Table 3.1.1 summarizes the cost information developed by MRI.
"MRI, Wastewater Treatment Technology Document for Aldrin/Dieldrin, Toxaphene, Endrin, DDT,
(February 6, 1976).
23
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TABLE 3.1.1
INVESTMENT AND OPERATING COSTS ASSOCIATED WITH THE PROPOSED TECHNOLOGIES FOR
TREATING TOXAPHENE-CONTAINING EFFLUENTS
Carbon
Adsorption
(30 min.
Carbon
Adsorption
(60 min.
Technology
Effluent Flow Rate
Toxaphene in Treated Effluent
Total Installed Capital
Equipment Cost (1975$)
Annual Operating Costs (1975$)
Direct Costs
Materials
Labor
Supervision
Payroll Charges
Maintenance
Operating Supplies
Utilities
Laboratory
Indirect Costs
Depreciation
Property Taxes \
Insurance j
Capital Cost (interest)
Plant Overhead
Total Operating Costs
Unit Operating Costs $/kg of
Toxaphene Product
Contact Time) Contact Time)
11368/min
< 5 ppb
$617,000
9,800
19,000
3,800
6,800
30,000
1,100
6,200
3.800
39,600
18,500
38,800
16,100
$194,000
0.0086
1136fi/min
<5 ppb
$794,000
9,800
19,000
3,800
6,800
36,800
1,100
6,200
3,800
53,300
23,800
50,000
17,500
$232,000
0.010
Resin Adsorption
Reductive Degradation
Two Systems in Series
757 E/min
1.4 ppb
$586,200
93,400
30,400
6,100
11,000
18,900
1,800
1,500
6,100
66,800
11,700
5,900
36,900
33,800
$324,300
0.014
1136£/min
1 .4 ppb
$770,400
140,100
32,500
6,500
11,700
23,400
2,000
2,300
6,500
91,600
15,400
7,700
48,500
45,000
$433,200
0.019
757 e/min
<3 ppb
$350,700
4,400
30,400
6,100
11,000
16,100
1,800
2,900
6,100
29,900
7,000
3,500
22,100
15,800
$154,100
0.0068
1136£/min
<3ppb
$433,700
6,600
32,500
6,500
11,700
19,900
2,000
4,400
6,500
33,400
8,700
4,300
27,300
18,000
$181,800
0.0079
757 e/min
0.1 ppb
$731,600
97,800
49,900
10,000
18,000
24.500
3,000
4,200
10,000
81,400
14,600
7,300
46,100
43,500
$410,300
0.018
11 36 e/min
0.1 ppb
$955,900
146,700
54,100
10,800
19,500
30,500
3,200
6,400
10,800
110,200
19,100
9,600
60,200
56,400
$537,500
0.024
-------
3.1.2 DDT
The only DDT plant now in operation does not discharge into a navigable stream so
proposed effluent treatments may apply only to new DDT plants that might be constructed.
In its report dated February 6, 1976, MRI proposed solvent extraction followed by a
Friedel Crafts reaction, adsorption on XAD-4 resin, adsorption on activated carbon, or two-
stage extraction with monochlorobenzene as possible technologies for treating effluents
containing DDT. Cost estimates for solvent extraction followed by the Friedel Crafts
reactions are developed for two effluent flow rates, viz., 113,550 and 170,325 £/day. The
cost estimates for the other treatment technologies are based on an effluent flow rate of
113,550 C/day. Table 3.1.2 summarizes the cost information developed by MRI.
3.1.3 Endrin
In the same report, MRI proposed adsorption on XAD-4 resin, reductive degradation,
adsorption on XAD-4 resin followed by reductive degradation, or adsorption on activated
carbon as technologies for treating effluents containing endrin. Cost estimates for all the
treatment technologies, except adsorption on activated carbon, are prepared for two
different effluent flow rates, viz., 1136 and 2271 8/min. Cost estimates for adsorption or
activated carbon were developed for two different contact times (30 and 60 minutes), since
MRI had insufficient data for determining the proper contact time. The cost estimates for
adsorption on activated carbon were based on an effluent flow rate of 1136£/min.
Table 3.1.3 summarizes the cost information developed by MRI.
3.1.4 Aldrin/Dieldrin
In the same report, MRI estimated the cost associated with evaporating the effluent
stream from an aldrin/dieldrin manufacturing plant, indicating no other costs for handling
effluents containing aldrin/dieldrin. The cost estimate for the evaporation pond is based on
an effluent flow rate of 7570 2/day. Table 3.1.4 summarizes the cost information developed
by MRI.
3.2 ESTIMATED ADDITIONAL TREATMENT COSTS
Many of the pesticide manufacturers covered in this study currently practice some
form of wastewater treatment and are already incurring the costs thereof. In these instances,
the cost of the existing wastewater treatment is already exerting its influence on the price
of the product. If the treatment measures presented by MRI are implemented, they will
either replace or be added (in whole or in part) to the existing treatment steps. Therefore,
if such treatment measures are implemented as the result of the proposed standards for
toxic pollutants, the cost directly attributable to the standards would be the cost of the
resultant treatment system less that of the cost of the existing treatment. In the following
sections we explain the rationale we used in estimating the actual additional costs, which
are presented in Table 3.2. These costs are only for toxaphene and endrin, since there are no
point-source dischargers of DDT and aldrin/dieldrin.
25
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TABLE 3.1.2
INVESTMENT AND OPERATING COSTS ASSOCIATED WITH THE PROPOSED TECHNOLOGIES FOR
TREATING EFFLUENTS CONTAINING DDT
Two Stage Extraction
N)
OS
Technology
Effluent Flow Rate
DDT in treated Effluent
Total Installed Capital Equipment Cost (1975$)
Annual Operating Costs (1975$)
Direct Costs
Raw Materials
Operating Labor
Supervision of Labor
Maintenance
Operating Supplies
Utilities
Laboratory Charges
Indirect Costs
Depreciation
Property Taxes
Insurance
Capital Cost
Plant Overhead
Cost for Landfill of Treatment Solid Wastes
($/day)
Coagulation, Sedimentation and Filtration
Total Operating Costs
Unit Operating Cost $/kg of DDT Product
Solvent
Extraction/
Friedel Crafts
113,550fi/day
~ 590 ppb
$381,000
108,778
56,538
11,308
38,099
3,391
145,163
11,308
38,099
7.621
3,809
24,005
74,952
7,920
NONE
$531,000
0.0196
1 70,325 fi/day
~ 590 ppb
$485,000
163,170
62,546 )
12,510 J
48,499 ^
3,751 J
217,746 1
12,510 f
48,499
9,698 }
4,849 j
30,557
104,112
12,240
NONE
$730,000
0.0189
Resin Carbon With
Adsorption Adsorption Monochlorobenzene
1 13,550 B/day 113,550 C/day 113,500 C/day
< 25 ppb < 25 ppb ~ 32 ppb
$209,000 $230,000 $101,000
9,700 \
17,200
5,500
2,300
i
12,100
2,900
6,000
) 24.200
82,800
5,500
5,800 5,800
5,000 5.000 /
$ 72,000 $ 35,000
0.0026 0.0013 0.0031
-------
TABLE 3.1.3
INVESTMENT AND OPERATING COSTS ASSOCIATED WITH THE PROPOSED TECHNOLOGIES FOR
TREATING EFFLUENTS CONTAINING ENDRIN
ro
Technology
Effluent Flow Rate
Endrin in Treated Effluent
Total Installed Capital
Equipment Cost (1975$)
Annual Operating Costs (1975$)
Direct Costs
Raw Materials
Operating Labor
Supervisor of Labor
Payroll Charges
Maintenance
Operating Supplies
Utilities
Laboratory
Indirect Costs
Depreciation
Property Taxes
Insurance
Capital Cost
Plant Overhead
Total Operating Cost
Unit Operating Cost $/kg
Endrin Produced
Resin Adsorption
Activated Activated
Carbon Carbon
Resin
Adsorption
11368/min
1 .4 ppb
$770,000
140,100
32,500
6,500
11,700
23,500
2,000
2,300
6,500
91,500
15,400
7,700
48,500
45,000
$433,200
2271 e/min
1.4 ppb
$1,260,000
280,200
36,400
7,300
13,100
35,500
2,200
4,500
7,300
160,300
25,200
12,600
79,400
77,300
$ 741,300
Reductive
Degradation
1136fi/min
1 ppb
$433,000
6,600
32,500
6,500
11,700
20,000
2,000
4,400
6,500
33,300
8,700
4,300
27,300
18,000
$181,800
2271 C/min
1 ppb
$631,000
13,200
36,400
7,300
13,100
30,200
2,200
8,700
7,300
48,200
12,600
6,300
39,800
23,700
$249,000
and
(30-min
Reductive Degradation Contact Time)
1136E/min
0.1 ppb
$954,000
146,700
54,100
10,800
19,500
30,600
3,200
6,400
10,800
110,000
19,100
9,500
60,100
56,400
$537,200
2271 e/min
0.1 ppb
$1,541,000
293,400
61,900
12,400
22,300
46,300
3,700
12,600
12,400
188,400
30,800 ^
15,400 )
97,100
93,000
$ 889,700
11 36 C/min
<2ppb
$692,000
7,600
19,000
3,800
6,800
30,000
1,100
6,200
3,800
45,400
)
20,700 >
43,600
15,700
$203,700
(60-min
Contact Time)
1136e/min
<2ppb
$870,000
7,600
19,000
3,800
6,800
36,800
1,100
6,200
3,800
59,100
26,100
54,800
17,000
$242,100
0.158
0.273
0.066
0.092
0.198
0.326
0.0748
0.0880
-------
TABLE 3.1.4
INVESTMENT AND OPERATING COSTS ASSOCIATED WITH THE
PROPOSED EVAPORATION TECHNOLOGY FOR
TREATING EFFLUENTS CONTAINING ALDRIN/D1ELDRIN
Effluent Flow Rate 7,570 C/day
Total Installed Capital Cost (1975$) 24,100
Annual Operating Costs (1975$)
Direct Costs
Labor 830
Supervision 170
Payroll Charges 300
Maintenance 800
Operating Supplies 50
Laboratory 170
Indirect Cost
Depreciation 590
Property Taxes 480
Insurance 240
Capital Cost 1,520
Plant Overhead 460
Total Operating Costs 5,610
Unit Operating Cost $/kg aldrin/dieldrin Produced 0.0132
28
-------
TABLE 3.2
PESTICIDE TREATMENT COST TO SELLING PRICE RATIOS*
A. Cost of Proposed Treatment
{from 3.1.1 and 3.1.2)
B. Cost of Existing Treatment
C. Cost of Additional Treatment
Product
Endrin1
Endrin2
Endrin3
Endrin4
Toxaphene
Hercules5
Hercules6
Hercules7
Hercules8
Riverside9
Vicksburgh9
Effluent
Level
Achievable
(ppb)
1.4
1.0
0.1
<2
1.4
<3
0.1
<5
-
-
Selling
Price
<$/kg)
6.60
6.60
6.60
6.60
0.84
0.84
0.84
0.84
0.84
0.84
Treatment Cost
High
(S/kg)
0.273
0.092
0.326
0.088
0.0191
0.0079
0.0238
0.0103
0.
0.
Low
($/kg)
0.158
0.066
0.198
0.075
0.0143
0.0068
0.0180
0.0086
0110
0088
Percent of
Selling Price
High
<%)
4.1
1.4
4.9
1.3
2.3
0.9
2.8
1.2
1.3
1.0
Low
(%)
2.4
1.0
3.0
1.1
1.7
0.8
2.2
1.0
Percent of
Treatment Cost Selling Price
High Low High Low
($/kg) (S/kg) (%) (%)
0.033 0.026 0.5 0.4
0.033 0.026 0.5 0.4
0.033 0.026 0.5 0.4
0.033 0.026 0.5 0.4
(approx. 0.00128) 0.15
(approx. 0.00128) 0.15
(approx. 0.00128) 0.15
(approx. 0.00128) 0.15
NIL NIL
NIL NIL
Treatment Cost
High
(S/kg)
0.240
0.059
0.293
0.055
0.0178
0.0066
0.0225
0.0090
Low
($/kg)
0.132
0.040
0.172
0.049
0.0130
0.0055
0.0167
0.0073
0.0110
0.0088
Percent of
Selling Price
High Low
(%) (%)
3.6
0.9
4.4
0.8
2.1
0.79
2.7
1.1
1.3
1.1
2.0
0.6
2.6
0.7
1.6
0.66
2.0
0.87
*Monitoring costs are not included above. These costs, EPA reports, could be as high as $40,000 per year if done by an outside laboratory. However, the manufacturers
will probably do the testing themselves for much less.
(1) Treatment via resin adsorption
(2) Treatment via reductive degradation model technology for meeting standards
(3) Treatment via resin adsorption plus reductive degradation
(4) Treatment via activated carbon adsorption
(5) Treatment via resin adsorption model technology for meeting standards
(6) Treatment via reductive degradation
(7) Treatment via resin adsorption plus reductive degradation
(8) Treatment via activated carbon adsorption
(9) Treatment costs supplied by EPA
-------
3.2.1 Toxaphene
Hercules, Inc. Hercules' existing facility currently treats toxaphene-containing
wastewater by means of neutralization and sedimentation. The proposed treatment schemes
include neutralization and sedimentation as pretreatment steps to be used ahead of the more
operationally sensitive resin adsorption, carbon adsorption, and the like. Thus, a portion of
the cost of the proposed treatment is already being incurred. By subtracting those cost
components associated with the neutralization and sedimentation steps, we were able to
estimate the incremental treatment cost for the Hercules plant.
Riverside Chemical Co., and Vicksburg Chemical Co. Since, at this time, the levels
of toxaphene in wastewater from these operations has not been firmly determined, there
is no treatment in place that is specifically intended for toxaphene removal. Therefore,
we have assumed that the treatment costs supplied by EPA are total costs and will be
fully incurred by these plants (should treatment be required).
3.2.2 Endrin
The existing wastewater treatment at the Velsicol Chemical Corp. plant consists of
sedimentation and filtration, both of which are included in the costs for the four treatment
alternatives presented by MRI. As in the case of toxaphene, we estimated the incremental
costs by subtracting the appropriate cost components from the total cost.
3.3 COST TO THE FORMULATORS OF MEETING THE PROPOSED STANDARDS
The proposed standards prohibit any discharge from any formulators of toxaphene,
DDT, endrin or aldrin/dieldrin. These standards apply to all discharges into navigable
waters, including stormwater and other runoff, from formulating areas, loading and un-
loading areas, storage areas, and other areas which are subject to direct contamination by
any of these four pesticides as a result of the formulating process. This includes all dis-
charges of process wastewaters and all discharges of water .used for routine cleanup or
cleanup of spills, but excludes fallout from fugitive air emissions.
The Environmental Protection Agency prepared a worst case estimate of the costs
that formulators would incur in meeting the proposed standards. The EPA cost estimate
assumed that a formulator would have to do the following in order to meet the proposed
standards:
1. Place the entire formulation operation onto a concrete slab.
2. Cover the entire formulation operation with a metal roof.
3. Put curbing around the entire plant to prevent runoff.
Although the ADL survey results indicate that these costs will not generally be incurred by
formulators, it can be assumed that such costs, if necessary, would fall most heavily on
those formulators whose output of the specified pesticides is small in absolute terms
30
-------
(i.e., the cost is large compared to sales volume) but large relative to total output of all
pesticides (i.e., the product line could not be dropped without potentially serious profit
impact). In order to roughly determine the number of plants who might fit this set of
conditions, EPA selected a cost-to-price ratio of 5% or greater and a 307(a) pesticide-to-
total output ratio of 5% or greater. The application of these conditions by EPA indicated
that less than 20 plants fit the specified conditions for worst case costs.
Because of uncertainty as to the increment of the estimated costs that formulators
might incur, a telephone survey was made of pesticide formulators in order to establish
what formulators would actually have to do to meet the proposed standards. ADL selected
for survey by telephone those formulators affected by the proposed standards for whom
information was available based on previous ADL contacts. It is the results of this telephone
survey which form the basis of ADL's appraisal of the economic impact of the proposed
standards as reported in Section 4.0 of this report.
31
-------
4.0 ECONOMIC IMPACT ASSESSMENT
4.1 MANUFACTURERS
4.1.1 Aldrin/Dieldrin
There are no aldrin/dieldrin manufacturers who are point-source dischargers. Thus, the
proposed toxic standards will have no economic impact upon any current aldrin/dieldrin
manufacturers.
When the EPA removed the registration for the agricultural uses of aldrin/dieldrin,
Shell Chemical Company was the only manufacturer. The Shell plant was shut down when
the aldrin/dieldrin registration was cancelled. The effluent treating facilities at the Shell
plant prevented any discharge of effluents containing aldrin/dieldrin. Thus, if Shell resumed
manufacturing aldrin/dieldrin, it would not be impacted by the proposed toxic standards.
Any new manufacturers would be able to install treatment facilities similar to
Shell's. The treatment costs they would incur would, therefore, be no greater than the
costs Shell incurred before it shut down its aldrin/dieldrin plant and those costs have been
reflected in market prices.
4.1.2 DDT
There are no DDT manufacturing operations which are point-source dischargers of
effluents containing DDT. Thus, no manufacturing operations will incur an economic
impact attributable to the proposed toxic standards.
Montrose Chemical Company is currently the only manufacturer of DDT in the United
States. Any new DDT manufacturing operation would be able to meet the proposed toxic
standards using a treatment technology which is less expensive than the technology now
used by Montrose to handle its effluents. Thus, the proposed toxic standards will have no
economic impact on new manufacturers.
4.1.3 Endrin
The only manufacturer of endrin within the United States is the Velsicol Chemical
Corporation. The proposed standards could be met using reductive degradation or carbon
adsorption treatment of effluents. Using reductive degradation, Velsicol would incur a
maximum incremental treatment cost of $0.059/kg (treatment cost to selling price ratio
equals 0.9%). This cost increase would not have an economic impact on either the company
or the community. If activated carbon is used to meet the proposed toxic standards, the
higher treatment cost might cause an economic impact.
33
-------
The nature of the specific economic impacts of a treatment cost higher than the cost of
reductive degradation is dependent upon the competitive market for endrin and for the
company itself. The demand for endrin is generally regarded as inelastic. Endrin can be
characterized as an extremely efficacious, broad-spectrum insecticide which faces competi-
tion only in certain pest control markets.
The impact of treatment costs will be determined more by price competition within
the industry than by price competition from other pesticides. Velsicol faces substantial
competition in the world endrin market. Royal Dutch Shell produces endrin in Europe in
substantial quantities (reportedly about 14-18 million pounds annually or about 2.8-3.6
times Velsicol's annual export sales). Shell is believed to be marketing substantial quantities
of endrin in the United States. Most of this product is presumably from inventory, but
substantial imports were reported to have been made by Shell as recently as 1973. Shell is
recognized as the "price leader" for the endrin market.
4.1.4 Toxaphene
There are four manufacturers of toxaphene: Hercules, Tenneco, Riverside, and Vicks-
burg. Only Hercules, Riverside, and Vicksburg are direct dischargers covered by the pro-
posed standards. Vicksburg and Riverside would incur an incremental treatment cost no
greater than $0.0110/kg (treatment cost to selling price ratio equals 1.3%). The level of cost
increase these two companies would actually incur would not be judged as being economic-
ally impactive to either the companies or the community under our criteria.
Since Hercules can meet the proposed standards using reductive degradation or carbon
adsorption, the additional cost it would incur is less than $0.0090/kg (treatment cost to
selling price ratio equals 1.1%). This additional cost would not be judged as being economic-
ally impactive to either the company or the community. A higher treatment cost might
result in an economic impact. Precise estimation of the impact would be uncertain because
of the following:
The diversity of the crop/pest markets in which toxaphene is consumed;
Differing competitive situations in these markets; and
A complex production structure.
The market for toxaphene is generally characterized by an inelastic demand. The cost/'
benefit ratio for toxaphene users is favorable with respect to competing products, so that
modest price increases for toxaphene are unlikely to induce a switch by consumers to
competing products. Historic sales data show a market insensitivity to price increases.
Toxaphene prices have increased an estimated 50% since 1972, from about $0.55/kg
(S0.25/lb) to about $0.77/kg ($0.35/lb), while U.S. sales are believed to have increased
during the period. A sales drop in 1975 is commonly attributed to decreases in cotton
acreage, not price resistance.
34
-------
As in the case with endrin, the impact of treatment costs on producers depends on the
competitive structure within the industry rather than on competition from other products.
4.2 FORMULATORS
ADL conducted a telephone survey of 16 companies which manufacture formulations
containing pesticides subject to the proposed toxic standards. The 16 companies operate 32
plants of various sizes; the largest operation has around 60 employees and the smallest
operation has only three employees. The plants surveyed are scattered throughout the
United States. Appendix III contains data indicating the representativeness of the ADL
survey.
Table 4.2 shows the size and location of the plants contacted and the results of the
telephone survey. The substance of the proposed regulations was described to an appro-
priate person at each plant contacted. None of the plants contacted indicated that it had
any process or cooling water discharges containing pesticides subject to the proposed
standards. Also, all plants surveyed indicated that their present practices virtually precluded
any accidental discharge of the pesticides subject to the proposed standards. Thus, none of
the plants surveyed would be expected to incur any significant capital costs in meeting the
proposed toxic standards. Some of the small formulators, however, indicated concern about
the administrative and monitoring costs that they might incur, and they indicated that these
costs might cause them to cease formulating the affected pesticides.
ADL believes that the findings of the telephone survey are representative of the
practices in the pesticide formulation industry, and that it is very unlikely that any
formulators will incur significant costs in implementing treatment to meet the proposed
standards.
35
-------
TABLE 4.2
RESULTS OF THE TELEPHONE SURVEY
Company
Contact
No.
1
States in Which
Formulation Plants
are Located
GA
Number of
Plants
SC
KS
NC
NC
AR. MO, MS
TN. TX, NC
SC. AL. FL
GA, CA
17
Number of
Employees
45
45
60
12
1000 total
for company.
Some plants
have as few
as 3 em-
ployees.
FL
CA
50
All formulation is done indoors. Raw materials, including
technical grade toxaphene, are stored in tanks, while formu-
lated product is stored outdoors on a concrete slab. The
loading dock is covered but not enclosed. In the event of a
spill, soda ash is applied to neutralize the toxaphene and
then an absorbent is applied. The absorbent is then picked
up and sent to an EPA-approved landfill.
Formulate mainly toxaphene products. They used to for-
mulate a lot of endrin, but do very little endrin formula-
tion now. Formulation is carried out under a roof; the
formulation area has no walls. Any spills go to a sump
tank, the contents of which will be disposed of at an EPA-
approved landfill. Raw materials are stored in a warehouse
which has a concrete floor. The loading area is uncovered.
Any spills on it would be picked up with absorbents.
Storage is in tanks which are surrounded by dikes. The for-
mulation area is indoors. Liquid spills either go down a
drain to a sump and are evaporated, or are picked up with
absorbent which is taken to an EPA-approved landfill. The
loading dock which is 12' x 60' is not covered. Any spills
on it are immediately picked up with an absorbent.
Formulation is done under a roof; the structure has no
sides. Formulated product is stored in a shed. The loading
dock is covered. All toxaphene spills are immediately neu-
tralized with soda ash and then picked up.
Formulation and storage are all within buildings. The load-
ing dock is covered by an awning. They formulate only
toxaphene dust. Any spills are immediately vacuumed up.
All the toxaphene formulations are emulsifiable concen-
trates. The formulations typically contain toxaphene com-
bined with methyl parathion. an emulsifier, and a solvent
such as xylene or mineral spirits. All tank farms are diked
and pumps are located in the diked areas. Toxaphene ar-
rives by tank truck. Endrin formulation is also done. The
endrin arrives at the plant in drums. Four plants use a slab
height loading station with the truck located in a depressed
loading pit. The concrete floor of the pit ends in a sump
which can be pumped to an evaporation tank. All the other
plants have a canopy-covered loading dock which is at
truck height.
The whole operation storage, formulation, and loading
is carried out within one building.
Formulation is in a steel-roofed shed building. The plant
has a cement curb around it, so spills cannot be washed off
the plant site. The loading dock is wide open. Any spills
are immediately covered with absorbent which is shipped
away for disposal.
36
-------
TABLE 4.2 (Continued)
Company
Contact
No.
States in Which
Formulation Plants
are Located
CA
Number of
Plants
Number of
Empoyees
10
10
CA
20
11
12
OR
MS
45
15
13
IL
50
14
15
16
GA
SC
IL
23
17
They formulate relatively dilute formulations for use by
homeowners. The entire operation is carried out indoors.
The loading area is covered with a roof. The loading dock
also slopes toward the plant so any spills would drain into
the building. The packing material they use would absorb
any spills resulting from broken containers.
The firm believes toxaphene will be cancelled by the EPA
in the near future and therefore it would be unwilling to
spend any money to meet new toxaphene standards. The
contour of their land combined with the large acreage of
their plant site precludes any runoff. Their present opera-
tions meet local regulations which do not permit any dis-
charge by them to sewage, rivers, etc., no matter how in-
direct. Presently their entire operation is conducted out-
doors. To roof their formulation area, they would have to
cover an area 50 feet by 40 feet.
All formulation work is done indoors. Storage tanks are
surrounded by dikes and the loading dock is covered.
Manufacture only about 1000 pounds of toxaphene formu-
lation per year. The firm is located next to a cotton field
where toxaphene is applied by airplane. All their operations
are indoors. Trucks back to the edge of the building for
loading. The open space between the building and the truck
is not greater than six inches.
Have ceased formulating pesticides subject to the proposed
toxic standards. They used up their last supplies of aldrin/
dieldrin two years ago. They said they contacted Shell for
more, but Shell indicated that there was no more available
anywhere. Toxaphene has not been formulated in the plant
for over five years.
Formulation is done indoors. The loading dock is covered.
The formulations are done outdoors! The plant has catch
basins so that all runoff is collected. If a catch basin should
exceeds a critical level, it is drained into drums which are dis-
posed of at an approved landfill.
Purchase formulated material and mix it into only one
product. Storage and formulation are indoors. Loading is
direct from the building into vehicles which drive up
against it.
37
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APPENDIX I
PROFILE OF THE PESTICIDE FORMULATOR INDUSTRYt
A. NUMBER/SIZE OF PLANTS*
Total Plant Formulations (million lb/yr)***
Number of
Formulations
MO
10-20
20-30
30-40
40-65
65-100
100
Total**
Output for Specific Pesticide
(thousands of pounds Range)
Mean)
Endrin
<1 1-10
2 4
5 12
3
1
_ ^
- -
2*
1 25
- 1-70
30
>10
1
1
1
4
7
2-640
102
Total
6
18
3
1
4
1
6
39
1-204
72
<0.1 0.1-1
5 9
5
2
1
4
5 21
1-24
9
Toxaphene
MO
10
15
8
2
10
4
4
53
11-576
168
>10
_
3
5
6
6
20
3-6400
735
Total
24
20
13
3
19
10
10
99
2-3254
815
'Prepared by the Office of Planning and Evaluation, EPA, April 1976, from data provided by the Office
of Enforcement, EPA.
*Plants with registration for pesticide indicating intent to formulate in 1975.
**Endrin and Toxaphene totals do not add, due to double counting.
***Size obtained by rough total adjusting of liquid formulations to pounds at 8 Ib/gal.
*******
B. GENERAL STATISTICS
Formulation per plant ranged from 1000 to 6,400,000 pounds and 1000 to
640,000 pounds for toxaphene and endrin, respectively.
Range, mean, and median output per plant for toxaphene and endrin show no
strong correlations with total output for all formulations or number of formula-
tions. It is assumed that this reflects the fact that the particular combinations of
formulations for a given plant are relatively random events.
For the pesticides other than endrin and toxaphene, there are too few formulators
for any general observations. The breakout is as follows:
39
-------
Pesticide
Aldrin
Dieldrin
DDT
No. of Active
Formula tors
3
6
1
*Disguised - three or fewer plants
C. REGIONAL PROFILE (ACTIVE FORMULATORS)
EPA Region
I
II
III
IV
V
VI
VII
VIII
IX
X
TOTAL
Pesticide
Endrin
Toxaphene
Endrin
Toxaphene
Endrin
Toxaphene
Endrin
Toxaphene
Endrin
Toxaphene
Endrin
Toxaphene
Endrin
Toxaphene
Endrin
Toxaphene
Endrin
Toxaphene
Endrin
Toxaphene
Endrin
Toxaphene
ve
rs
ilanfs
'lulilj
* * * *
III A T^"\ r^O
ULATORS
No. Plants
0
0
1
2
0
0
21
65
0
9
9
24
3
13
1
3
2
10
2
7
39
133
Total Formulation
(this pesticide)
(IbxlO3)
D*
246
D
Output (million ib)
0
0
D*
D
0
0
1.6
45.2
0
0.9
0.8
11.0
D
8.6
D
D
D
1.7
D
0.8
2.4+
68.2+
* Disguised - three or fewer plants
40
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APPENDIX II
POSSIBLE ALTERNATES FOR THE PESTICIDES COVERED
BY THE PROPOSED TOXIC POLLUTANT STANDARDS
A. INTRODUCTION
This appendix presents possible alternates for toxaphene and endrin. Whether the
use of these alternates has been approved by the EPA was not considered in preparing the
information on possible alternates. DDT is not discussed in this section since it is no longer
used in the United States, but it is still widely used in developing countries. Aldrin/dieldrin
is also not covered because its current use is extremely limited in the United States. The
information on alternates was developed for use in assessing the impact of the proposed
standards on the users of toxaphene and endrin. As work progressed, it became evident that
effluent treatment costs at the manufacturing plants may be low enough so that no
significant changes in bulk prices would be encountered. Therefore, the information is
presented as general background information and for possible later use in considering
potential options available to independent formulators.
There are certain aspects of the availability of substitutes that are beyond the scope of
this report. These are:
Relative efficacy Efficacy is a function of crop, region, weather, pest to
be controlled, and the like. Alternates indicated in this section may not be so
efficacious as toxaphene or endrin.
Spectrum of control In many instances, toxaphene and endrin are used to
control a large number of pests. Alternates may not have this characteristic.
The spectrum of control required by users varies considerably.
Relative costs - The raw price of the alternates is not the only factor which
might make alternates more expensive. The substitute might require more
applications, be more expensive to handle, and so forth.
Supply Alternates may not be produced in sufficient quantities. The
increased demand for the alternates could cause its price to increase.
The alternates that are described in this section are registered in the United States, although
not necessarily for use as endrin or toxaphene alternates. Some of them may not be readily
available for export to foreign customers who are major users of endrin or toxaphene.
41
-------
B. TOXAPHENE
Table II-l presents a breakdown of the major uses of toxaphene. Tables 11-2 through
II-7 show on which pests toxaphene was used for all except the pests of vegetable crops. For
each pest, the possible alternates for toxaphene are indicated. Table II-8 shows the same
information for vegetable crops.
TABLE 11-1
BREAKDOWN OF TOXAPHENE USAGE
Usage Percent
Cotton 75.0
Soybeans 4.1
Peanuts 3.6
Beef Cattle 9.3
Swine 2.3
94.3
Other Field Crops 2.6
Vegetable Crops 2.1
99.0
Source: Arthur D. Little, Inc., calculations based on 1971
U.S. Department of Agriculture data.
42
-------
TABLE 11-2
TOXAPHENE ALTERNATES
*!
U
s
c
Pesticide
Toxaphene
Toxaphene and Methyl Parathion
Toxaphene and Trichlorfon
Toxaphene and MP and Chlordimeform
Aldicarb
Azinphosmethyl
Carbaryl
Chlordimeform
Dicrotophos
Dimethoate
Disulfoton
Endrin
EPN
EPN and Methyl Parathion
Malathion
Methomyl
Methyl Parathion
Methyl Parathion and Chlordimeform
Methyl Parathion and Parathion
Monocrotophos
Monocrotophos and Chlordimeform
Naled
Parathion
Phorate
Phosphamadin
Strobane
Trichlorfon
Beet Armyworms
*
>
0}
UL
O
+*
**
o
u
*
*
*
*
*
*
»
*
*
it-
Cotton Leaf Perforator
#
*
*
*
*
*
* Cutworms
«
*
*
_£
+»
s
CD
0)
Q>
U.
* Garden Webworm
*
*
*
#
* Grasshopper
*
#
*
*
(A
5
00
CO
3
O)
#
*
*
#
*
*
*
*
*
*
*
en
a
i_
£
*
»
*
*
*
K
#
*
#
*
#
Note: This table should in no way be considered complete. These data are based on information contained
in the USDA "Guidelines for the Use of Insecticides," and in the State insect control regulations for
cotton in Texas, California, Alabama, and Louisiana. It is in no way complete. No doubt other
compounds are recommended elsewhere.
43
-------
TABLE 11-3
TOXAPHENE ALTERNATES
Soybeans (4.1%)
3
|S
"p
£
Pest
Bean Leaf Beetle
Corn Earworm
Fall Armyworm
Flea Beetle
Garden Webworm
Grasshopper
Green Cloverworm
Mexican Bean Beetle
Soybean Looper
Thistle Caterpillar
Thrips
Toxaphene
*
*
«
*
»
*
«
*
*
*
Azinohosmethyl
*
»
*
£
.0
s
*
*
«
*
*
*
Carbophenthion
*
Chlordane
*
Disulfoton
*
*
Malathion
*
*
*
*
*
*
Methyl Parathion
*
*
Methomyl
*
*
*
«
Methoxychlor
*
Note: This figure should in no way be considered complete. It is based on the USDA "Guide-
lines for the Use of Insecticides" and on State extension regulations in Iowa. Kansas, and
Virginia.
44
-------
TABLE 11-4
TOXAPHENE ALTERNATES
Peanuts (3.6%)'
0
15
o
1
Pe$t *
Corn Earworm
Cutworm
Fall Armyworm
Green Cloverworm
Potato Leafhopper
Thrips
Toxaphene
*
*
«
*
*
*
t
I
«
O
*
*
*
*
*
Diazinon
*
*
Disulfoton
*
*
Malathion
*
*
Methomyl
*
*
*
1
a.
«
1
o
1
*
There were no recommendations for using toxaphene on peanuts in Virginia, South
Carolina, and in the USDA "Guidelines for the Use of Insecticides." This table was con-
structed using the insects found on cotton which are treated with toxaphene. The competing
chemicals are those actually recommended for peanuts in either Virginia, South Carolina, or
in the USDA guidelines.
45
-------
TABLE 11-5
TOXAPHENE ALTERNATES
Beef Cattle (9.3%)
Peit
Horn Fly
Lice
Mites
Ticks
Toxaphene
«
#
«
»
a.
Q
0
1
_c
i
0
*
«
Coumaphos
»
*
*
Crotoxphos
*
*
#
Crufomate
«
«
*
i
5
o
*
*
1
o
5
#
*
*
i
|
*
*
*
Lindane
*
*
Malathion
#
*
*
Methoxychlor
*
*
Phenathiazine
*
is
Pyrethrins and
Piperonyl Butt
*
Bonnet
#
«
*
Note: This table should not be considered complete. It is based on the USDA "Guidelines for the Use of Insecticides," and the Texas
Extension Services brochure, "Suggestions for Controlling External Parasites of Livestock and Poultry," and the "Summary of
Iowa Insect Pest Control Recommendations for 1974."
-------
TABLE 11-6
TOXAPHENE ALTERNATES
Swine (2.3%)
0)
o
°u
1
Pest
Lice
Mites
Toxaphene
*
*
a.
O
O
Ciodrin and
Coumaphos
Crotoxphos
#
Cruf ornate
Delnav
Dioxathion
*
(0
1
Lindane
#
*
Malathion
"
*
Jj
Methoxychlc
*
0)
Phenathiazin
0)
'x
_ o
c **
IA ^
dt fll
J. .§
"3
o
QC
*
Note: This table should not be considered complete. It is based on the USDA "Guidelines for the Use of Insecticides," and the
Texas Extension Services brochure, "Suggestions for Controlling External Parasites of Livestock and Poultry," and the
"Summary of Iowa Insect Pest Control Recommendations for 1974."
-------
TABLE 11-7
TOXAPHENE ALTERNATES
Other Field Crops (2.6%)
Corn
s
1
M
£
Pest
Armyworm
Chinch Bug
Corn Earworm
Cutworms
European Corn Borer
Fall Armyworm
Grasshoppers
Mormon Cricket
Toxaphene
*
*
*
*
-
*
*
*
2
3
*
*
#
*
*
Carbofuran
(Furadan)
*
Diazinon
*
*
0.
LU
*
Malathion
*
*
i
si
is
#
Parathion
*
*
Thimet
*
Trichlorfon
*
*
oc
Note: This table should in no way be considered complete. It is based on the USDA "Guidelines for the Use of Insecticides," and on the
"Summary of Iowa Insect Pest Control Recommendations for 1974."
-------
Crop
1. Beans
2. Brussel Sprouts
3. Cabbage
4. Cauliflower
5. Co Hards
6. Eggplant
7. Kale
8. Peppers
9. Rutabaga
10. Tomatoes
TABLE 11-8
TOXAPHENE ALTERNATES
Pest
Lygus Bugs
Cabbage Looper and Cabbageworm
Cutworms
Cutworms
Cutworms
Cutworms
Cutworms
Cabbage Looper and Cabbageworm
Pepper Weevil
Cutworm
Blister Beetle
Pesticides for Controlling
Toxaphene and Malathion
Toxaphene and Parathion
Toxaphene
Malathion
Naled
Parathion
Toxaphene
Toxaphene
Toxaphene
Toxaphene
Toxaphene
Bacillus Thuringiensis
Toxaphene
Methomyl
Mevinphos (Phosdrin)*
Parathion
Toxaphene
Toxaphene
Toxaphene
Endosulfan
Methoxychlor
Naled
'Kentucky State Cooperative Extension Service recommendations.
Source: USDA "Guidelines for the Use of Insecticides."
-------
C. ENDRIN
Table II-9 presents a breakdown of the major uses of endrin. Tables 11-10 through II-13
show on which pests endrin is used and the endrin substitutes that are available.
TABLE 11-9
ENDRIN USAGE, 1971
lOOOIbs Metric Tons
Corn 30 13.6
Cotton 1065 483.0
Wheat 5 2.27
Other Grains 25 11.34
Soy Beans 23 10.43
Other Field Crops 226 102.49
Irish Potatoes 5 2.27
Other Vegetables 1 0.45
Apples 2 0.91
Other Fruits and Nuts 33 14.97
1418 641.73
Note: Current usage in the United States is probably only 1
million pounds.
Source: Arthur D. Little, Inc., calculations based on 1971
U.S. Department of Agriculture data.
50
-------
TABLE 11-10
ENDRIN ALTERNATES
Cotton 80%
o>
1
I
Pest
Boll Weevil
Boll worm
Brown Cotton Leafworm
Cabbage Looper
Celery Leaftier
Cotton Leafworm
Cutworms
Flea Hopper
Garden Webworm
Grasshoppers
Greenhouse Leaftier
Leaf Perforator
Lygus Bugs
Rapid Plant Bug
Salt Marsh Caterpillar
Tarnished Plant Bug
Thrips
Endrin
»
*
*
*
*
«
*
*
*
«
»
*
»
*
*
»
*
Aldicarb
*
*
Azinphosmethyl
*
*
*
»
*
*
Bacillus Thuringiensis 1
#
Carbaryl 1
#
»
*
«
*
*
*
*
*
*
*
#
Chlordimeform 1
#
*
*
Diaz in on 1
*
Dicrotophos I
«
#
#
*
#
£
Q
*
*
#
*
«
Dtsulfoton 1
*
Endosulfan |
*
1
UI
#
*
EPN and Methyl Parathion
*
*
Malathion
*
«
*
#
*
*
*
«
*
»
1
*
Methyl Parathion
*
*
*
*
*
*
*
«
*
»
*
«
Ethyl Parathion and Parathion
*
! Monocrotophos
*
*
#
*
*
*
Monocrotophos 1
and Chlordimeform
*
o
_»
2
*
«
Parathion ]
*
«
*
#
Phorate 1
*
1
!
£
*
*
*
Strobane
*
! Toxaphene
#
*
*
*
*
#
*
#
| Toxaphene and Methyl Parathion
*
*
*
*
*
*
Toxaphene and Methyl Parathion
and Chlordimeform J
*
Trichlorfon
*
*
*
#
*
*
*
*
Note: This table should not be considered all-inclusive. It is based on data obtained from Velsicol, the USDA "Guidelines for the use of Insecticides," and
State Extension Services recommendations in Alabama, California, Mississippi, Louisiana, and Texas. Typical endrin usage indicated here is
probably exaggerated. By the five states and USDA, endrin was recommended only for use on bollworms and the greenhouse.
-------
TABLE 11-11
ENDRIN ALTERNATES
Apples
Meadow Mice
Pine Mice
c
1
Ul
*
*1
s
o
c
1
e
o
-c
u
*
8
0>
u
o
_3
U.
E
3
o
CO
*
01
c
ft.
CO
*
«
o
0.
tfl
0
£
CL
U
c
N
#
1. Endrin acts as a repellent for use against the pine mouse.
Source: USDA
TAB LEI 1-12
ENDRIN ALTERNATES
Sugarcane Beetle*
c
h.
o
c
UJ
«
09
C
o
o
£
U
*
'Presently treatment of the sugarcane beetle is recom-
mended in neither Florida, Louisiana, nor the USDA
"Guidelines for the Use of Insecticides." In the past,
chlordane rather than endrin was recommended for use
on sugarcane beetles in Louisiana.
52
-------
TABLE 11-13
ENDRIN ALTERNATES
s
^5
B
Pest a
Armyworm
Army Cutworm
Cutworms
Fall Army worms
Pale Western Cutworms
_e
1
UJ
*
*
*
#
#
Endosulfan
«
Parathion
*i
*i
Toxaphene
#
#
Trichlorfon2
#
#
#
1. Except on rye.
2. Recommended on wheat in Kansas.
Note: This table should not be considered all-inclusive, It is based on data from Velsicol, the
USDA "Guidelines for the Use of Insecticides," and State Extension Services recommenda-
tions in Kansas and Oregon.
-------
APPENDIX III
REPRESENTATIVENESS OF THE ADL TELEPHONE SURVEY
Table III-l shows the distribution of formulators who make endrin and toxaphene
formulations by total volume of all formulations and number of label registrations. Shown
in parentheses is the distribution of firms contacted by ADL in the telephone survey.
TABLE 111-1
DISTRIBUTION OF FORMULATOR PLANTS IN ADL'S TELEPHONE SURVEY
COMPARED TO DISTRIBUTION OF PLANTS ACCORDING TO
PRODUCTION LEVEL AND LABEL REGISTRATION
Total Production of All Formulators (million Ib/yr)
c_j.:_
Label
Registrations
1-10
10-20
20-30
30-40
40-65
65-100
>100
Note 1: Plain numbers indicate plants with registration for pesticide indicating intent to formu-
late in 1975.
Note 2: Numbers in parentheses indicate plants in ADL's telephone survey.
Source: Distribution information supplied by EPA.
Endrin
<1
2
5(3)
Formulators
1-10 >
4
12(4)
3
1(1)
3
-
2(2)
>10
-
1
-
KD
1
4(1)
Toxaphene
<0.1 0.1-1
5 9(1)
5(2)
2
1
4(1)
-
Formulators
1-10
10(1)
15(4)
8(1)
2(1)
10(1)
4
4(4)
>10
_.
-
3(1)
-
5(1)
6
6(2)
Tables III-2 and III-3 show the distribution of endrin and toxaphene production by
formulators related to the number of plants surveyed.
55
-------
TABLE 111-2
DISTRIBUTION OF ENDRIN PRODUCTION BY FORMULATORS
RELATED TO THE NUMBER OF PLANTS SURVEYED (1975)
Endrin
Projected Output, 1975 Number of
(million Ib) Plants Surveyed
1-10 7 4
11-25 11 3
26-50 3 1
51-100 8 1
101-200 6 2
201-300 2 1
301-400 1 0
401-500 0 0
501-750 1 0
39 12
Source: Distribution information supplied by U.S. Environmental
Protection Agency.
TABLE 111-3
SIZE DISTRIBUTION OF TOXAPHENE PRODUCTION BY
FORMULATORS RELATED TO THE NUMBER OF
PLANTS SURVEYED (1975)
Toxaphene
Projected Output. 1975 Number of
(million Ib) Plants Surveyed
1-10 6 1
11- 25 10 3
26-50 9 1
51- 100 92
101- 200 11 2
201- 300 9 2
301- 400 6 1
401- 500 5 0
501- 750 12 3
751-1000 4 1
1001-1500 7 2
1501-2000 6 1
2001-3000 2 1
30014000 1 0
4001-5000 1 0
5001+ 1 0
99 20
Source: Distribution information supplied by U.S. Environmental
Protection Agency.
56
-------
BIBLIOGRAPHIC DATA
SHEET
1. Report No.
EPA-230/3-76-016
2.
4. Title and Subtitle
Economic Impact Assessment of Proposed Toxic Pollutant
Effluent Standards for Manufacturers and Formulators of
Aldrin-Dieldrin. DDT. Endrin. and Toxaphene
3. Recipient's Accession No.
5. Report Date
May 1976
6.
r(s)
Anon.
8. Performing Organization Rept.
No.
rforming Organization Name and Address
Arthur D. Little, Inc.
Acorn Park
Cambridge Mass. '02140
10. Project/Task/Work Unit No.
.11. Contract/Grant No.
68-01-1902
12. Sponsoring Organization Name and Address
Office of Planning and Evaluation
U.S. Environmental Protection Agency
Washington, D. C. 20460 -.
13. Type of Report & Period
Covered
Proposal
14.
IS. Supplementary Notes
stracts An assegsment Of the economic impact of proposed toxic pollutant effluent
standards for the manufacturers and formulators of Aldrin-Dieldrin,DDT, Endrin, and
Toxaphene (Section 307(a) of the Fed. "Water Poll. Cont. Act) was performed, based on
abatement cost data supplied by EPA. It was concluded that there will be no
significant adverse economic impact upon prices, sales, profitability, employment, o
the end use markets for these pesticides. In aggregate, compliance will require
additional investment in treatment facilities of $O.S - 1.1 million with annualized
total costs of $0.5 -0.7 million. The impact on prices will be potential increases
of no greater than 2.3%. . .
The assessment includes descriptions of firms, plants, and markets for these
pesticides; investments and operating .costs for the abatement technologies; evaluatian
of pricing for these products and potential adverse impacts.
17. Key Words and Document Analysis. 17o. Descriptors
Economic Analysis
Water Pollution
Pesticides
I7b. Identifiers/Open-Ended Terms
Toxic Pollutant Effluent Standards
Federal Water Pollution Control Act
17c. COSATI Field/Group
18. Availability Statement
Release Unlimited
19. Security Class (This .
Report)
UNCLASSIFIED
20. Security Class (This
^UNCLASSIFIED
21. No. of Pages
62
22. Price
FORM NTIS-3S (REV. 10-731 ENDORSED BY ANSI AND UNESCO.
THIS FORM MAY BE REPRODUCED
USCOMM-DC 82eS-F>74
------- |