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.

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                                      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

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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

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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

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                                                                  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

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                       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

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                                                                      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

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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

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                      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

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                                                 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

-------
                                     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

-------
                                    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

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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

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