ECONOMIC IMPACT ANALYSIS OF ALTERNATIVE POLLUTION CONTROL TECHNOLOGY FOR THE WOOD PRESERVING SUBCATEGORIES OF THE TIMBER PRODUCTS INDUSTRY report to U.S. ENVIRONMENTAL PROTECTION AGENCY CONTRACT NO. 68-O1-4194 Arthur D Little, Inc. ------- DRAFT C21723 ECONOMIC IMPACT ANALYSIS OF ALTERNATIVE POLLUTION CONTROL TECHNOLOGY FOR THE WOOD PRESERVING SUBCATEGORIES OF THE TIMBER PRODUCTS INDUSTRY U.S. ENVIRONMENTAL PROTECTION AGENCY NOVEMBER 1978 Submitted by: Arthur D. Little, Incorporated Acorn Park Cambridge, Massachusetts 02140 Contract No. 68-01-4194 Arthur D Little Inc ------- DRAFT NOTICE This document is a DRAFT CONTRACTOR’ S REPORT. It includes technical information submitted by the Contractor to the United States Environ- mental Protection Agency (EPA) regarding the subject industry. It is being distributed for review and coimnent only. The report is not an official EPA publication and it has not been reviewed by the Agency. Some data in this report was received by the Technical Contractor too late for inclusion in this report (or the Technical Contractor’s report dated September 1, 1978). Therefore there may be some inconsistencies between the data in this draft report and the Technical Contractor’s draft report. The report will be undergoing extensive review by EPA, Federal and State agencies, public interest organizations, and other interest groups and persons during the coming weeks. The regulations to be published by EPA under Sections 301(d), 304(b), and 306 of the Federal Water Pollution Control Act, as amended, will be based in part, on the report and the comments received on it. Upon completion of the review and evaluation of the technical, economic, and environmental information, an EPA report will be issued at the time of proposed rule—making setting forth EPA’s preliminary conclusions regarding the subject industry. These proposed rules will include proposed effluent guidelines and standards, standards of performance, and pretreatment standards applicable to the industry. EPA is making this draft contractor’s report available to encourage broad, public participation, early in the rule—making process. The report 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 and prepared the information. It cannot be cited, referenced, or represented in any respect in any such proceedings as a statement of EPA’s views regarding the subject industry. U.S. Environmental Protection Agency Office of Water and Hazardous Materials Office of Analysis and Evaluation Washington, D.C. 20460 ------- DRAFT TABLE OF CONTENTS PAGE I. EXECUTIVE SUMM&RY I-i II. INDUSTRY CHARACTERIZATION 1 1- 1 A. INDUSTRY DEFINITION 1 1 - 1 B. TYPES OF FIRMS 1 1— 1 1. Size of Firm I l— i 2. Integration 1 1—2 3. Ownership Characteristics 11—4 C. PRODUCT DESCRIPTION 11—6 1. Type of Products 11—6 2. Market Size 11—7 3. Future Demand Growth 11—7 D. PLANT CHARACTERISTICS OF THE EXISTING INDUSTRY 11—12 1. Process Technology 11 —12 2. Product Diversification Within Plants 1 1—13 3. Size of Plants 11—14 4. Location 11—14 5. Employment 11—17 E. CHARACTERISTICS OF NEW PLANTS 11—17 1. Plants Constructed Since 1971 11—17 2. Capital and Operating Costs for New Plants 11—21 F. COMPETITIVE STRUCTURE OF THE INDUSTRY 11—24 1. Market Structure 11—24 2. Pricing Mechanism 11—26 3. Price Elasticity of Demand 11—26 C. PRICE AND COST HISTORY 11—27 1. Income and Asset Analysis 11—32 2. Investment Criteria 11—37 III. COST OF COMPLIANCE 1 1 1—1 A. PURPOSE 1 1 1—1 B. CURRENT EFFLUENT STATUS 1 1 1 — 1 C. CONTROL OPTIONS 1 1 1-1 D. COST OF COMPLIANCE FOR EXISTING INDUSTRY 11 1 —4 E. COST OF COMPLIANCE FOR NEW SOURCES 1 1 1— 11 i ------- DRAFT TABLE OF CONTENTS (cONTINUED) PAGE IV. ECONOMIC IMPACT ASSESSMENT tV—i A. ECONOMIC CHARACTERISTICS OF IMPACTED PLANTS tv—i B. ECONOMIC IMPACT ON EXISTING INDUSTRY IV-3 1. Price Impacts IV—3 2. Demand Shifts IV—8 3. Financial Impact 1V8 4. Plant Closures tVl4 5. Employment Effects IV—16 C. ECONOMIC IMPACT UPON NEW SOURCES AND CAPACITY IV-18 EXPANS IONS V. LIMITATIONS OF ANALYSIS V-i A. EPA REGULATION AFFECTING WASTE DISPOSAL V—i B • RETURN ON INVESTMENT CRITERIA V-2 C. COST VARIATIONS FROM PLANT TO PLANT V—4 D. FUTURE GROWTH IN DEMAND V-4 E. LOCAL CONDITIONS OF IMPACTED PLANTS V—5 APPENDIX A — Supplementary Discussion A—i APPENDIX B — Responses to EPA Financial 308 Survey B—i APPENDIX C — References C—i APPENDIX D - EPA Financial 308 Survey D—l ii ------- DRAFT LIST OF TABLES TABLE DESCRIPTION PAGE 1 1 -1 PRESSURE CYLINDER CAPACITY OF THE TEN LARGEST 1 1-3 WOOD PRESERVING FIRMS, 1976 1 1-2 WOOD PRESERVING PLANTS FORM OF BUSINESS 11—5 ORGANIZATION, 1976 11-3 PRESERVED WOOD PRODUCTS AND THEIR POTENTIAL 11—8 SUBSTITUTES 11-4 WOOD TREATED WITH PRESERVATIVES 11 —9 1 1-5 VALUE OF SHIPMENTS FOR THE WOOD PRESERVING 11—10 INDUSTRY 1958 TO 1976 1 1-6 DISTRIBUTION BY ANNUAL SALES VALUE 11-16 11-7 NUMBER OF PRODUCTION EMPLOYEES PER PLANT 11—19 11-8 AGE DISTRIBUTION OF WOOD PRESERVING PLANTS 11-20 11-9 PROFITABILITY OF NEW PLANTS VERSUS OLDER PLANTS 11—21 11-10 ESTIMATED FIXED CAPITAL REQUIREMENTS FOR THE 1 1—2 3 MANUFACTURE OF PRESERVED WOOD (ORGANIC TREATMENT) 1 1- 11 ESTIMATED OPERATING COSTS FOR THE MANUFACTURE OF 11—25 PRESERVED WOOD 11—12 CONCENTRATION RATIOS IN THE WOOD PRESERVING 11—26 INDUSTRY 1963—1976 1 1-13 SELECTED OPERATING RATIOS FOR THE WOOD PRESERVING 11—30 INDUSTRY: 1964 TO 1976 11-14 PRO-FORMA INCOME STATEMENTS WOOD PRESERVING PLANTS 11—34 1 1-15 WOOD PRESERVING PLANTS ASSET TURNOVER BY SALES/ 11—35 SERVICE CATEGORY 11-16 WOOD PRESERVING PLANTS DISTRIBUTION OF ASSETS BY 11—3 7 SALES AND SERVICE COMPANY 11-17 CAPITAL EXPENDITURES AND PRODUCTIVITY IN WOOD 11-39 PRESERVING INDUSTRY 11-18 TARGET RATE OF RETURN FOR INVESTMENTS MADE BY WOOD 1 1-41 PRESERVING INDUSTRY 1 1 1 —1 CURRENT DISCHARGE STATUS BY TYPE OF PROCESS 11 1—2 111-2 COST OF COMPLIANCE OPTION 1: ENHANCED BIOLOGICAL 111—5 TREATMENT 1 11—3 COST OF COMPLIANCE OPTION 2 111—6 1 1 1—4 COST OF COMPLIANCE OPTION 3 111—7 iii ------- DRAFT LIST OF TABLES (coNTINuED) TABLE DESCRIPTION PAGE 111-5 TOTAL COST OF COMPLIANCE WOOD PRESERVING INDUSTRY 111—9 INSTALLING OPTION TECHNOLOGY 111-6 TOTAL COST OF COMPLIANCE WOOD PRESERVING INDUSTRY 111—10 INSTALLING LEAST COST TECHNOLOGY 111-7 MODEL PLANTS FOR NEW SOURCE PERFORMANCE STANDARDS 111-13 111-8 COST OF COMPLIANCE NEW WOOD PRESERVING PLANTS 111-14 IV-1 LAND AVAILABILITY FOR DISCHARGING PLANTS IV—2 IV-2 PRICE INCREASES REQUIRED TO RECOVER COSTS OP IV-4 COMPLIANCE OPTION 1: ENHANCED BIOLOGICAL TREATMENT IV-3 PRICE INCREASES REQUIRED TO RECOVER COSTS OF IV-5 COMPLIANCE OPTION 2 IV-4 PRICE INCREASES REQUIRED TO RECOVER COSTS OF IV-6 COMPLIANCE OPTION 3: TOTAL RECYCLE/NO DISCHARGE IV-5 WOOD PRESERVING PLANTS PROFITABILITY WITH NO PRICE IV-9 INCREASES BEFORE AND AFTER COMPLIANCE IV-6 FORM OF BUSINESS ORGANIZATION BY DISCHARGE STATUS IV-13 IV-7 POTENTIAL PLANT CLOSURES UNDER BAT ALTERNATIVES IV-15 IV-8 WOOD PRESERVING INDUSTRY EMPLOYMENT LOSSES FROM IV-17 PLANT CLOSURES IV-9 IMPACT OF BAT REQUIREMENTS UPON LONG-RUN REVENUE IV-2O REQUIRED TO SUPPORT NEW SOURCES V-i REVENUE REQUIRED BY DISCOUNT RATE V-3 iv ------- DRAFT LIST OF FIGURES FIGURE DESCRIPTION PAGE I l —i SALES TRENDS FOR PRESERVED WOOD PRODUCTS It-li 1 1—2 WOOD PRESERVING PLANTS IN DIE UNITED STATES 1 1- 17 1 1—3 WOOD PRESERVING INDUSTRY PRICE INDICES OF RAW 11-29 MATERIALS 11-4 LIST PRICES OF SELECTED PRESERVED WOOD PRODUCTS 11-32 tv-i INVESTMENT REQUIRED FOR BAT ALTERNATIVES AS A IV-ii PERCENTAGE OF CASH FLOW V-i REVENUE REQUIREMENT AS PERCENT OF SALES BY ROR FOR V-3 SAMPLE PLANTS V ------- I. EXECUTIVE SUMMARY (Not Included in this Final Draft) I—1 DRAFT ------- DRAFT II. INDUSTRY CHARACTERIZATION A. INDUSTRY DEFINITION As defined in Standard Industrial Classification (SIC) 2491, the wood preserving industry “comprises establishments primarily engaged in treating wood, sawed or planed in other establishments, with creosote or other preservatives to prevent decay and to protect against fire and insects. This industry also includes the cutting, treating, and selling of crossties, poles, posts, and piling.” B. TYPES OF FIRNS The wood perserving industry is composed of a large number of small, privately—owned plants and a few larger establishments. Larger establishments are generally either: • Owned by companies whose major source of income is not wood preserving; e.g., Koppers, Kerr—McGee Chemical Corp., Southern Wood Piedmont Co., and International Paper Company. • Owned by companies who are primarily wood preservers; e.g., J. H. Baxter & Co., Wyckoff Co. ‘Each of these firms operates at numerous locations. There were approx- imately 302 companies and 415 wood preserving plants in the country in 1976. The Environmental Protection Agency Financial 308 Letter 1 was answered by 337 plants. 1. Size of Firm The wood preserving companies vary considerably in both sales and number of wood preserving operations. Of 302 wood preserving companies, 263 (87%) are single—plant firms, 39 (13%) are multi—plant firms. Koppers Company operates 25 plants, the other multi—plant firms operate 10 or or fewer plants. 1 Survey conducted by EPA under Section 308 of the Federal Water Pollution Control Act, as amended. Response summaries and tabulated data are in Appendices B and B. 11—1 ------- DRAFT Available information shows that total annual sales of these companies, including sales from other operations, range from less than $200,000 to over $1 billion. The wood preserving industry has a large number of small firms. However, the ten largest firms represent approximately 51% of the total industry, based upon pressure tank capacity. While actual production may not be directly correlated with pressure tank capacity because capacity utilization may vary and different products and different species of wood require varying treating times, pressure tank capacity is an indicator of production capacity. As shown in Table Il—I, Koppers Co., Inc. represented 20% of total industry capacity, while the four largest firms represented 37% of total capacity in 1976. 2. Integration Wood preserving companies tend also to vary with respect to vertical integration. Some plants are part of lumber operations or associated with a company sawmill. In such cases, the wood treating operation may be an additional service for lumber customers. In other cases, such as Koppers Company, Weyerhaeuser, and International Paper, where the company is involved in wood products and/or chemicals, the treat- ment of wood for customers Is a natural expansion of its existing resources. In a few cases, railroads and utility companies own wood treatment facilities. These plants serve as captive suppliers of poles, ties, crossarius, etc., and frequently do not sell to others. The Atchison, Topeka & Sante Fe Railway Company, Burlington Northern, Southern California Edison Company, Texas Electric Cooperatives, Inc., and Utah Power & Light are examples of this type of firm. By far the greatest number of companies, however, are not integrated back to wood; i.e., they do not own their own timberland, and they purchase wood. A number of plants treat wood for customers on a service basis only, while other plants both treat purchased wood and treat wood for customers on a service basis. 11—2 ------- DRAFT TABLE Il-i PRESSURE CYLINDER CAPACITY OF THE TEN LARGEST WOOD PRESERVING FIRMS, 1976 Total Pressure Tank Capacity Percent of Total Company ( thousand cubic feet) Industry Capacity Koppers Co., Inc. 415 20% Kerr—McGee Chemical Co. 127 6% Southern Wood Piedmont Co. 123 6% J. H. Baxter 108 5% Wyckoff Co. 73 3% Atlantic Creosoting Co., Inc. 57 3% International Paper Company 51 2% McCormick & Baxter Creosoting Co. 50 2% Crown Zellerbach Treated Wood Products 45 2% Cascade Pole Co. 34 2% All others 1,023 49% Total Industry 2,105 100% SOURCE: Arthur D. Little, Inc., estimates based upon Ernst and Ernst Wood Preservation Statistics — 1976 . 11—3 ------- DRAFT 3. Ownership Characteristics Both privately and publicly—held companies are represented in this in- dustry segment. In general, the smaller, single—plant companies are privately—held and the largest companies tend to be publicly held. There are basically two different patterns of ownership and management in the industry. In the first category are plants owned by publicly— held corporations which may or may not have wood preserving as the primary activity. These plants are managed by individuals with little or no equity in the corporation. Plants following the second pattern are owner—managed and may be proprietorships or privately held cor- porations. They may have even been owned by the seine family for several generations. Table 11—2 lists the organizational breakdown of companies in the industry as of 1976 based upon responses received from the EPA financial 308 survey. The ownership and management patterns in an industry are important for an assessment of how the industry will be impacted by pollution control costs. Profitability requirements are very different between an owner— manager and a corporation which more critically views the return on investment from one of many plants. The former may accept an increase in abatement costs as a necessity for staying in business, while the later may decide that the increased cost is not justified by the expected returns. On the other hand, a closely-held company may have difficulty obtaining capital investment funds and thus be unable to continue in operation. Among plants primarily treating with organic preservatives, 25% of the plants are owned by publicly—held corporations. Among the plants primarily treating with inorganic preservatives, only 10% of the plants are owned by pubicly—held corporations. While publicly—held corporations owned only 22% of the total number of plants responding to the EPA financial 308 survey, according to 1972 Bureau of Census statistics, publicly—held corporations accounted for 73% of the total value added of the wood pre- serving industry. 11—4 ------- TABLE 11—2 WOOD PRESERVING PLANTS FORM OF BUSINESS ORGANIZATION. 1976 Primary Total Organic Preservatives Proprietorship 23 10% Co—op 1 0 Privately—Held Corporation 158 65 Publicly—Held Corporation 59 25 241 100% Primary Inorganic Preservatives Proprietorship 5 8% Co—op Privately—Held Corporation 54 82 Publicly—Held Corporation _j 10 66 100% Total Proprietorship 31 9% Co-op 1 0 Privately—Held Corporation 230 69 Publicly—Held Corporation 72 22 Number of Respondents to Question 334 100% SOURCE: Derived from EPA 308 Financial Survey -n -I ------- DRAFT C. PRODUCT DESCRIPTION 1. Type of Products The wood preserving industry in the United States has developed based on the need for prolonging life in wooden structural products. Historically, railroads ties, utility poles, and pilings treated with creosote have been the major products of the industry. In recent years, lumber and plywood treated for fire retardancy, insect resistance, and rot resistance have experienced rapid growth. The industry’s products include: Bridges and trestles of wood, treated Creosoting of wood Cross ties, treated Flooring, wood block, treated Mine props, treated Miliwork, treated Piles, foundation and marine construction, treated Piling of wood, treated Poles, cutting and preserving Poles and pole crossarms, treated Structural lumber and timber, treated Vehicle lumber, treated Wood products, creosoted The industry can be segmented in several different dimensions correspond- ing to size, product, technology, and location. Generally speaking, the firms that are located in the South are treating mostly Southern Pine, and those in the West are treating mostly Douglas Fir. The industry uses oil—borne (organic) or waterborne (inorganic) preservatives. The products treated with oil, such as poles, piling, and railroad ties, have a distinct odor and “oiliness,” which makes them unsuitable for use where odor is objectionable. The waterborne preservatives are used for preserving plywood and lumber, and especially for treating with fire retardants. Competition is normally very keen within the wood preserving industry and price is usually the major basis of competition. A large number of suppliers 11—6 ------- DRAFT exist to serve regional markets, although some regions are served by only one or two suppliers. Some limited competition exists from other materials such as steel, concrete, and aluminum. There are advantages and dis- advantages to each type of material, in addition to price differentials. Generally the type of use dictates the type of material required. For example, treated wood piles must be used in acid soil (such as in a sanitary landf ill) because acid conditions corrode steel and concrete. Table 11—3 lists some preserved wood products and their potential substitutes. Of particular interest is the possibility of concrete railroad ties becoming a more vigorous competitor. Currently, concrete ties are being used in several locations in the United States and this use is growing. 2. Market Size Table 11—4 shows historical shipments data by product category. From 1955 to 1976 the volume of wood treated with preservatives fluctuated from a low of 213.9 million cubic feet in 1962 to a peak production of 286.4 million cubic feet in 1967. Production was 257.2 million cubic feet in 1976, the most recent year for which data are available. The industry’s historical peak production level was 356.6 million cubic feet in 1947, indicating that the long—term trend is down. The value of shipments from 1958 to 1976 are shown in Table 11—5. The value of shipments rose from $344.2 million in 1967 to $761 million in 19741, the peak year. Both 1975 ($647.7 million) and 1976 ($704 million) were below this peak level. Typically, about 85% of the value of shipments is from owned wood, with the remainder contract work. 3. Future Demand Growth Figure 11—1 depicts the historic production and future growth trend for the preserved wood products In total and for ties, poles, and timbers. During the early sixties, the demand for preserved wood products increased dramatically compared with levels existing in the fifties. Since then there have been wide swings in total annual production but discernable trends for individual product categorie3. 1 Annual Survey of Manufactures, 1967—1976. 11—7 ------- DRAFT TABLE 11—3 PRESERVED WOOD PRODUCTS AND THEIR POTENTIAL SUBSTITUTES Preserved Wood Product Potential Substitute ’ Piling In—place concrete Driven concrete Steel piling Hollow I beans Marine piling In—place concrete Driven concrete Interlocking iron sheets 2 x 4 ’s, etc. Metal studs I—Beams Prestressed walls Plywood Concrete Cinder block Sheetrock Particleb oard Fire—retardant lumber, plywood, etc. Asbestos Gypsum Metal sheets Poles Metal poles Prestressed concrete Railroad ties Concrete ties 1 Not all substitutes have been proven to be reliable. The potential for substitution is limited because material selection is often dictated by specific uses. SOURCE: Arthur D. Little, Inc. estimates. 11—8 ------- TABLE 11—4 WOOD TREATED WITh PRESERVATIVES By Product (millions of cubic feet) 1955 1956 1957 1958 1959 Crossarms 4.3 4.7 4.6 3.4 3.6 Crossties 85.9 83.2 101.5 73.9 52.1 Fence Posts 16.2 12.8 13.4 14.9 15.7 Lumber & Timbers 39.4 41.0 41.9 38.4 39.9 Piling 13.9 16.8 16.3 16.2 14.7 Poles 74.8 85.8 84.0 73.8 78.3 Switch Ties 7.3 8.1 8.1 6.7 4.5 Miscellaneous Total 3.8 3.6 4.8 5.6 5.7 248.4 257.9 274.5 232.8 214.5 1960 1961 1962 1963 1964 3.7 3.6 3.5 3.4 3.6 57.2 55.8 42.9 47.4 55.7 13.5 15.0 17.1 18.2 18.6 39.5 38.8 42.6 43.5 47.3 16.1 14.3 17.8 15.9 16.5 75.1 76.4 78.7 77.0 80.6 4.9 4.7 4.3 5.3 6.8 6.0 6.6 6.9 6.7 8.0 216.1 215.4 213.9 217.4 237.0 1965 1966 1967 1968 1969 4.9 5.5 4.6 3.3 3.2 63.7 70.4 80.4 78.5 71.3 18.4 19.7 21.0 16.5 15.7 50.3 60.4 62.2 62.6 59.6 17.8 21.1 16.6 17.4 14.7 83.9 87.1 84.3 76.2 74.4 7.5 7.8 8.3 7.9 6.4 9.2 8.6 8.9 9.4 8.2 255.7 280.6 286.4 271.9 253.5 1970 1971 1972 1973 1974 1975 1976 3.5 3.1 2.4 2.6 2.4 1.4 4.6 79.4 87.0 85.9 67.6 75.9 93.1 95.3 15.1 16.7 18.2 15.2 17.3 15.3 13.8 55.7 59.9 64.0 68.9 77.8 61.5 67.1 15.1 13.7 14.3 13.0 13.3 9.4 8.5 76.8 74.4 74.5 75.4 73.8 49.1 53.1 7.9 6.2 6.0 5.0 6.5 8.0 5.7 6.9 7.7 7.2 6.9 8.5 6.4 9.0 260.3 268.6 272.6 254.4 274.7 244.1 257.2 include wood treated with fire— 1. Data for 1966—1971 are not comparable with previous years because they retardent chemicals under each category rather than under MISCELLANEOUS. 2. WOOD BLOCKS: Data for 1957—1969 are included in MISCELLANEOUS. 3. MISCELLANEOUS: Includes all wood products treated with fire—retardant chemicals in 2.8 million cubic feet of wood were treated with fire retardants. Source: Ernst and Ernst, Wood Preservation Statistics — 1976 . 1955—1965. In 1965, D -I ------- TABLE 11-5 VALUE OF SHIPMENTS FOR THE WOOD PRESERVING INDUSTRY 1958 TO 1976 Value of Capital Shipments Expenditures Year ( $ Million) ( $ Million ) 1958 203.0 3.7 1959 218.1 (D) 1960 225.1 3.7 1961 220.1 4.1 1962 230.0 4.9 1-4 1963 247.3 5.5 1964 270.9 5.8 0 1965 279.6 11.4 1966 326.0 10.4 1967 344.2 10.7 1968 375.1 9.3 1969 386.1 13.2 1970 387.8 8.4 1971 416.9 10.4 1972 475.8 14.8 1973 557.4 11.6 1974 761.2 28.1 1975 647.7 27.5 1976 704.3 22.3 Source: U.S. Department of Co erce, Bureau of the Census, Annual Survey of Manufacturers , 1958—1976 -I ------- 300 293 110 100 90 - 80 70 6U 50. 30 20 10 IQL 60 62 64 66 68 70 72 74 76 78 80 82 84 86 88 —I I I. • $ IS • I I I • -, 60 62 64 66 68 70 72 74 76 78 80 82 84 86 88 YEAR SALES TRENDS FOR PRESERVED WOOD PRODUCTS (THOUSAND CUBIC FEET) 110 100 90. 80. 70 60 SO 40 30 20 10 60 62 64 66 68 70 72 74 76 78 80 82 84 86 88 YEAR Wood Preservina Techniques and Possible 280 270 DRAFT CROSS TIES r 2,0. 40 220 210. 200 60 62 64 66 68 70 72 74 76 78 80 82 84 86 88 YEAR YEAR 110 . TIMBER AND LUMBER I, -. 70 60 50 30 20 10 SOURCE: Historic Data — Ernst 6 Ernst data cited in The Analysis of Existiflg Substitutes , June 1977. Forecast — Arthur D. Little Inc. estimates. Il—il ------- DRAFT The annual production volumes of ties, poles and timbers also exhibit wide swings but there are definite trends in each of the major categories shown in Figure lI—i. In addition, the industry characterization 1 and other studies of the industry have concluded that the trend in individual products shown in Figure I l—i are likely to continue over the next ten years. The forecast values from 1978 through 1988 were derived by analyzing the trend in production incurred from 1963 to 1976 for each product category as well as the variation around trend. The growth rate (or decline) under- lying the trend was compared with forecast growth rates in other studies to check for reasonableness and establish a range. All other preserved wood products as a group exhibited no trend and were assumed to remain stable at about 42,000 cubic feet per year. The forecast for total preserved wood products is the sum of the individual product forecasts. The reason for doing this analysis was to identify product areas that might be declining in deinand,as well as those that are not, to assess the willing- ness of impacted plants to make an investment in pollution control expenditures given the future outlook for the products they produce. Product growth areas were also examined to gauge the extent to which they would take up the slack In the production of declining products and also to evaluate the potential for any price increase. On balance,the future outlook for preserved wood products appears good, with the decline in pole demand being offset by the increase in demand for ties and timbers. The decline in pole demand will occur as a result of slowdowns in growth of utilities and the fact that new transmission lines will be of the size requiring steel. 1 Also,the demand for poles in new urban areas is being affected by the requirement to place utility distribution lines underground. The demand for railroad ties is a result of rebuilding roadbeds, which will produce an upward trend over the next ten years, but with a leveling off point occurring as the railroad in- dustry goes from a rebuilding to a maintenance mode. The growth in demand for timbers and lumber is In part a consequence of F}IA requirements 2 for 1 Reference 4, pgs. 21—22. 2 0p. cit., p. 36. 11—12 ------- DRAFT preserved wood in home construction. While the average annual growth in timbers for 1963 to 1974 was 5.4%, a future real growth rate of 3% is forecasted to reflect the expected level of single family units to be constructed in the 1978 to 1988 period. D. PLANT CH.ARACTERISTICS OF THE EXISTING INDUSTRY 1. Process Technology Wood preserving is a two—stage process consisting of, first, precondition— ing the wood to reduce its moisture content and, secondly, treating wood with preservatives. Any one of several methods can be used to precondition, including: season- ing in large, open yards; kiln drying; pressure steaming in a retort followed by vacuum drying; heating in a preservative bath under reduced pressures (Boulton Process); or vapor drying. Pressure treatment is the most common form of processing. It is also widely recognized that this form of treatment provides a superior product to that resulting from the brush or dip application of preservative. The wood treating step can employ either a pressure or non—pressure process. Non—pressure processes use open tanks containing the preservatives in which the wood is immersed. Pressure processes are classified as either “full— cell” or “empty cell”. In the “full—cell” process, a vacuum is created in the retort and the preservative is added and forced into the wood under pressure. In the “empty—cell” process, preservative is added to the retort and forced into the wood under pressure followed by the application of a vacuum. The “full—cell” process is commonly used with aqueous solutions. The typical pressure treatment facility includes three major processing areas: • Treating cylinder or pressure vessel with the necessary pumps, tanks, and control equipment. • Boiler plant to provide for heated solution and pressurization of the cylinder. 11—13 ------- DRAFT • Seasoning and storage yard including the cylinder loading track and ancillary transportation facilities. • Support equipment such as hoists and lifts for handling timber; finishing equipment for incising, boring, blocking, framing and shaving materials; and kilns or other processing facilities for artificial seasoning of selected products. The treating cylinders are the most important component of a wood treatment plant. These steel cylinders (retorts) typically used in pressure treatment range in size from 4 to 10 feet in diameter and up to 175 feet in length. As an indication of the “charge” size held by a treating cylinder, the average charge for a 6 foot by 36 foot cylinder can be 6,000 board feet (500 cubic feet) of lumber for a facility in the Northeast. Wood preserving plants can also be categorized, based on the types of preservatives used, as follows: • plants treating with organic materials, such as pentachiorophenol, oil, and creosote solutions; • plants treating with waterborne inorganic salts principally zinc, copper, arsenic, and chromium; • plants treating with both organic and inorganic preservatives. Of the plants identified by the 1976 AWPA Wood Preservation Statistics , 49% are organic treaters, 27% inorganic, and 24% treat with both types of preservatives. 2. Product Diversification Within Plants Although there is a wide range of wood products treated within the industry, individual plants tend to concentrate on a limited range of products. Inorganic (waterborne) treaters treat mostly dimension lumber, posts, and poles for insect and rot resistance and fire retar— dancy; organic (oil—borne) plants treat primarily poles, posts, pilings, and railroad ties with some other products such as cross arms and bridge timber. Poles and ties are the major production items of organic plants whereas inorganic treaters have a greater variety of treated wood products, although volume may be smaller. 11—14 ------- DRAFT 3. Size of Plants There are no published data on individual plant capacities or production, because capacity varies with the type of wood treated and the type of treatment. For example, Douglas Fir requires a considerably larger residence time than species found in other parts of the country. Although the numbers of cylinders and types of processes are known, there is not necessarily a correlation between these and either plant capacity or pro- duction. Some industry members 1 reported that a typical 80—ft. cylinder, operating with an organic process, has an output of 30,000 to 45,000 board feet per day (based on 15,000 board feet per charge, 2 or 3 per day). Daily inorganic production may be somewhat higher due to shorter treat- ment times. Reported annual operating rates (time used for treating as a percent of total time available for treatment, not including loading and unloading time) for the industry range from 40—70%. Table 11—6 shows a distribution of plant sizes using 1976 annual sales value as a indicator of size. The plants are very uniformly distributed among the value of sales size categories shown in the table. The median plant size lies in the $0.7 to $1.2 million annual sales range. Six of the 319 plants responding to the EPA Financial 308 Letter had sales of over $11.5 million, while 25 plants had sales of less than $70 thou- sand. 4. Location Figure 11—2 shows the national distribution of wood treatment facilities. Although there are no statistics available on the geographical distri- bution of consumption, both production and consumption follow the distri- bution pattern of facilities. Plants are most heavily distributed in the Southeast region with 45% of all plants in that region. Of the plants responding to the EPA Financial 308 survey, 30% described their plant site as urban while 25% were suburban and 45% rural. 1 As reported by AWPI in private conversations. 11—15 ------- DRAFT TABLE 11—6 DISTRIBUTION BY ANNUAL SALES VALUE 1970 Sales Planta Built Plants Built ( $000) Since 1970 1970 or Earlier Total d i w It I. It 0 It 0—70 8 16 17 6 25 8 71—155 4 8 21 8 25 8 156 — 300 10 20 19 7 29 9 301 — 700 8 16 40 15 48 15 701 — 1200 5 10 45 17 50 16 1201 — 2400 5 10 37 14 42 14 2401 — 3200 5 10 21 8 26 8 Over 3200 5 10 69 25 74 23 TOTAL RESPONDING 50 100% 269 100% 319 100% SOURCE: Derived by Arthur D. Little, Inc., from EPA Financial 308 survey. 11—16 ------- FIGURE II- WOOD PRESERVING PLANTS IN THE UNITED STATES SOURCE: American Wood Preservers Association. I -I - S *GI( •f w C S E OP C S WOOD PRESERVING PLANTS IN THE UNITED STATES D m -I ------- DRAFT 5. Employment Table 11—7 shows the distribution of plants by the number of production employees per plant. The median sized plant employs 10 to 19 production workers. Two plants employ more than 125 workers, while 22% of all plants employ fewer than 3 workers. The Bureau of the Census estimated the total employment of the wood preserving industry to be 9,700 in l976 Due to increased use of materials handling equipment, employment has decreased from the peak of 12,800 in 1968. E. CHARACTERISTICS OF NEW PLI NTS 1. Plants Constructed Since 1971 Of the 337 plants responding to the EPA 308 Letter, 56 plants began oper- ation in the 1971 to 1977 period. Table 11—6 showed the size distribution of these 50 new plants based on their 1976 value of sales. The average size of new plants is smaller than the older plants, possibly suggesting that existing facilities typically expand over their production life. Comparing the plant size distribution of the new plants to the size dis— tribtulon of all plants (as shown in Table 11—6), one may determine that the new plants are smaller than all plants. The median annual sales of the new plants is $0.3 to $0.7 million, while the median annual sales of older plants is $0.7 to $1.2 million. Table 11—8 shows the age distribution of 315 plants responding to the EPA Financial 308 survey. The median age of the plants is approximately 20 years, while 55 plants were built before 1930 and 56 plants began oper- ation between 1971 and 1977, or an average of 7 per year. A majority of the plants responding were built in the 1950’s and 1960’s. The profitability of new plants versus older plants is compared in Table 11—9. The profitability of the two groups is roughly comparable. Both older plants and new plants have a median profitability after tax of 2% of sales value. ‘Reference 2 11—18 ------- DRAFT TABLE II— 7 NUMBER OF PRODUCTION EMPLOYEES PER PLANT Nuthber of Production Employees per Plant Number of Plants Percentage of Plants 1—3 73 22 4—6 39 12 7—9 26 8 10—19 56 17 20—34 55 17 35—48 27 8 49—75 36 11 76—99 8 2 100—125 6 2 Over 125 2 1 Subtotal 328 100% No Response 10 Total 337 Source: Derived by Arthur D. Little, Inc., from Environmental Protection Agency financial 308 survey. 11—19 ------- DRAFT TABLE II— AGE DISTRIBUTION OF WOOD PRESERVING PLANTS Year of Initial Operation Number of Plants Percentage of Plants Before 1930 58 17 1931 — 1940 13 4 1941 — 1950 46 14 1951 — 1960 83 25 1961 — 1970 76 3 1971 — 1977 56 17 Subtotal 332 100% No Response 5 Total 337 Source: Derived by Arthur D. Little, Inc., from Environmental Protection Agency financial 308 survey. 11—20 ------- DRAFT TABLE II- 9 PROFITABILITY OF NEW PLANTS VERSUS OLDER PLANTS 1976 Profit New Plants 1 Older Plants’ After Tax 2 Number Percentage Number Percentage Under 1% 16 37 56 25 6 14 58 25 3%—4% 7 16 47 21 5%—7% 7 16 38 17 Over 7% 7 16 26 11 Subtotal 43 100% 227 100% No Response 7 60 Total 50 287 1 New plants are those beginning operation between 1971 and 1977, while older plants began operation before 1971. 2 Profit after tax as a percentage of sales value. Source: Derived by Arthur D. Little, Inc., from Environmental Protection Agency Financial 308 Letter. 11—21 ------- DRAFT When industry capacity utilization is low, or demand growth is slow, a competitor has difficulty entering the industry. As the industry has become more automated and hence more capital intensive in recent years, the capital cost for entry, in real terms, is significantly higher now than five or ten years ago. 2. Capital and Operating Costs for New Plants Capital and operating costs were developed for model new source plants proposed by the technical contractor. Two plants sizes were selected, with each assumed to be producing one of four preserved wood products. The plant sizes are: 1. Two cylinders, each seven—foot diameter by 130 feet long. 2. Five cylinders, each seven—foot diameter by 130 feet long. The product, location and process relationships are shown below: Product Location Process A. Railroad ties South Central Boultonizing B. Southern Pine poles South Central Steaming C. Douglas Fir poles West Coast Boultonizing D. Southern Pine lumber South Central Inorganic Capital costs for each of these two facilities is shown in Table 11—10 indicating that the total installed cost for the larger facility is about $4.6 million, in comparison to $2.2 million for the two—cylinder plant. Table 11—11 summarizes the operating costs for eight operating conditions—— f our products being produced at each of the two plants. Appendix A offers supplementary tables on each of the 8 conditions. The two-cylinder plant has 25 operating, 7 maintenance and 13 supervisory and office employees, at an average annual cost of $15,000 per employee. The five—cylinder plant is assumed to have 65 operating, 17 maintenance and 33 supervisory and office personnel. Taxes and insurance are estimated at 4% of the capital cost. While maintenance and other consummable supplies, such as packaging, do vary based on the operating volume of each plan; these variations are too small to affect overall operating costs and have been assumed to be constant. 11—22 ------- DRAFT TABLE 11—10 ESTIMATED FIXED CAPITAL REQUIREMENTS FOR THE MANUFACTURE OF PRESERVED WOOD (ORGANIC TREATMENT ) Location: South, new facility or replacement value 3 Cylinder Size: 7—foot diameter, 130 feet long, 5000 cubic feet in volume Installed ’ Installed ’ Bare Cost Cost of a Cost of a of Equipment Two Cylinder Five Cylinder Per Cylinder Plant Plant ($1,000) ($1,000) ($1,000) Site Preparation 200 400 Yard Equipment 2 300 400 800 Pressure Cylinder 250 700 1,700 Storage Tanks and Pumps 100 250 400 Utilities: Boiler and Compressor 100 150 300 Primary Oil—Water Separation 4 NA 32 58 Subtotal $750 $1,732 $3,658 Engineering, Construction and Contingency at 25% 433 917 Total Fixed Capital $2,165 $4,575 1 lnstallation includes piping, instrumentation, electrical, structures, foundations, erection labor, and allocated portion of shops and offices. 2 Yard Equipment includes track and trams for cylinder loading, trimming and framing equipment, and mobile equipment. Processing is based on receipt of rough sawn wood, and specifically excludes debarking and rough sawing. 3 Acici 10% for West Coast construction cost differential. 4 For the primary oil—water separation system, 50% of the cost is included in the cost of the plant. SOURCE: Arthur D. Little, Inc., estimates based on industry interviews. 11—23 ------- TABLE 11-11 ESTIMATED OPERATING COSTS FOR THE MANUFACTURE OF PRESERVED WOOD Annual Operating Costs in Thousand Dollars for Model Plants : A—l A—2 B—i B—2 C—i C—2 D—l D—2 Wood 2,064 5,160 5,400 13,500 3,264 8,160 6,480 16,200 Preservatives 672 1,680 378 945 307 768 594 1,485 Total Raw Materials 2,736 6,840 5,778 14,445 3,571 8,928 7,074 17,685 Labor 596 1,491 596 1,491 596 1,491 596 1,491 Supplies* 132 326 132 326 132 326 132 326 Fuel and Power* 132 326 132 326 132 326 132 326 Taxes and Insurance 87 182 87 182 95 200 87 182 Total Operating Cost 3,683 9,165 6,725 16,772 4,526 11,271 8,021 20,010 Case A — Railroad ties, boultonized, South Central location, 30 hours per charge Case B — Southern pine poles, steamed, South Central location, 16 hours per charge Case C — Douglas fir poles, boultonized, West Coast location, 30 hours per charge Case D — Southern pine lumber, CCA treated, South Central location, 16 hours per charge Case 1 — 2 cylinders, each 7—foot diameter, 130 feet long, 5,000 cubic feet Case 2 — 5 cylinders, each 7—foot diameter, 130 feet long, 5,000 cubic feet *Includes 50% of the operating cost of oil—water separation. SOURCE: Arthur D. Little, Inc., estimates based on industry interviews. D -n -1 ------- DRAFT The following additional assumptions were made: • A one—product operating mode was assumed, although most facilities have variable and constantly changing mixes, depending on specific and local market conditions. • Capital requirements for the West Coast facility is estimated to be 10% greater than for the Southern plants. • Land requirements are 30 acres and 50 acres, respectively, for the two plants. • Raw wood and preservative costs are obtained from accepted, published industry references. • 40% of the cylinder volume is used for each charge, plants operating three shifts a day and 300 days per year. • While cycle time depends on wood specie, mositure content, type of process employed and degree of preservation required, the following,possibly conservative, cycle times were used: Railroad ties (Boultonized) — 30 hours Southern Pine poles (steamed*) — 16 hours Douglas Fir poles, green (Boultonized) — 30 hours Southern Pine lumber (CCA) — 16 hours F. COMPETITIVE STRUCTURE OF THE INDUSTRY 1. Market Structure Table 11—12 shows concentration ratios for the industry between 1963 and 1976. Although the industry is composed of a large number of small firms, the four largest firms had 37% of the total market in 1976, and the eight largest firms had 47% of the total market. The size of the firms various considerably. The top company has about 20% of the market, the next three companies have 5% to 6% each, and the next four about 2% each. The balance of the top 20 have market shares of 1% each and the next 30 have shares averaging about .6%. The level of concentration has not changed significantly since 1963, indicating a stable market structure. *Only when frozen 11—25 ------- DRAFT TABLE 11-12 CONCENTRATION RATIOS IN THE WOOD PRESERVING INDUSTRY 1963-1976 Percent of Value of Shipments accounted for by— — 4 8 20 50 largest largest largest largest Year companies companies companies companies 1963 34 44 64 84 1967 35 44 63 84 1970 34 NA NA NA 1972 35 44 60 78 1976 37 47 NA NA Source: 1963—1972: U.S. Bureau of Census, Annual Survey of Manufactures , 1976: Arthur D. Little, Inc. estimates. 11—26 ------- DRAFT Preserved wood is largely a connnodity market modified by transportation costs which give regional advantages to some producers. While some interregional competition exists in the industry, the cost of inbound and outbound transportation results in predominantly regional markets For some applications, a particular wood specie is preferred and wood may be shipped over longer distances in these cases; more often, a suitable wood specie may be found locally. 2. Pricing Mechanism Pricing mechanisms appear to be quite varied. For some products (mostly lumber), wholesalers and commission firms conduct continuous pricing and bidding between the preserving plants and the final customers on the telephone. Some of the preserved lumber is sold from price lists. On the other hand, most poles, piling, and railroad ties are sold through formal bids for specific projects directly to the customer. Purchase decisions are made on the basis of price, availability, and delivery of future production, since most preservers only keep small inventories and make the products only on order. 3. Price Elasticity of Demand Demand elasticity in the wood preserving industry varies somewhat among products. The major factors governing demand are competition within the industry and the economic climate of user industries. Demand for those products with high demand growth potential (such as dimensionalized lumber) will probably not be affected by a rise in prices because growth in demand will offset declines due to price increases. Those products which are threatened by lower demand growth potential (such as utility poles) have higher price elasticity and will be less likely to pass along cost increases as increases in price. At the present time, growth of demand for railroad ties is expected to be strong because of tightened federal railroad safety regulations and the Northeast Railroad Reorganization Act. However, concrete ties are now being used for some of the replacements. Inorganically treated products (using inorganic salts), although a small portion of all treated 11—27 ------- DRAFT products, have recently had rapid growth, even up to 20% per annum, and are expected to continue at a growth rate higher than GNP as the con- struction market improves and demand for dimension lumber and plywood increases. The market f or utility poles is not expected to grow strongly, as previously discussed. It is currently nearly a replacement market and it is also threatened in the future by the requirement for underground wiring. Although there are economic and technical difficulties with underground wiring, if these are worked out they may replace wooden poles for some applications. Other products, such as construction and marine pilings, face some pressure from substitute products. In summary, it appears that although some products will have high growth rates, production for the whole industry will continue to have little long—term growth. This situation will make it difficult for producers to increase prices. G. PRICE AND COST HISTORY Figure II- 3 shows the price trend in current and constant dollars of raw materials used by the wood preserving industry. In the 1970—78 period wood preservative chemicals have shown the greatest increase in cost, followed by that of wood costs (lumber, piles, and ties), and finally labor. All of these inputs have increased at a rate greater than that of general inflation, as shown in the graph of real price increases for the chemical and wood materials. (Figure II—3B). The cost of labor in the wood preserving industry has been increasing steadily; the average payroll per worker was more than 60% higher in 1978 than in 1970, which is an annual increase of 6.2%. However, since 1970, labor as a percent of value added and per dollar of shipments has declined, as shown in Table 11—13. In fact, employment in the industry as a whole has declined, from 12,000 in 1970 to 9,700 in 1976, and the percentage of the workforce classified as production workers also declined, from 84% to 79% for the same period (shown in Table 11—17). This is principally due to the greater use of materials handling equipment in order to reduce labor costs. 11—28 ------- FIGURE 11-3 OD PRESERVING INDUSTRY PRICE INDICES OF P , W MATERL\LS DRAFT 250.0 1.... r 150 . 0 L lO0. )L. 1967 1970 1972 Values: Creosote Pen tach lorophenol Lumber Labor 1980 $3. 31/hour Creosote Pen tachiorophenol Lumber Labor Average Annual Increase 1970—78 12.6% 1967 1970 1975 SOURCES: (chemicals) Chemical Marketing Reporter (wages) Employment and Earnings , US Department of Labor, BLS (lumber) Wholesale Prices and Price Indexes , US Department of Labor, BLS (GNP. deflator) Economic Indicators , Council of Economic Advisors A. Current $: 1972 — 100 S..... I I 11.1% 13.7% / Is i • •• S.. I... — 50.0 __________ I a 1972 1975 creosote, 27c/gallon; peatachlorophenol 18c/pound; labor B. Co:tstarit $: 1972 10fl 200.0 6.2% 1970—78 3.7 6.7 0. 9 . 150.OL I S S 100.0 75.0 50.0 J / I • / 5 . S I % I— 1980 11-29 ------- DRAFT TABLE 11—13 SELECTED OPERATING RATIOS FOR THE WOOD PRESERVING INDUSTRY: 1964 TO 1976 Cost of Cost of materials materials & Value Payrolls per payrolls added as percent dollars of per dollar per of value shipments shipments employee added Year ( dollars) ( dollars) ( dollars) ( percent ) 1964 .63 .81 8,788 49 1965 .64 .81 9,050 48 1966 .63 .80 10,479 45 1967 .62 .80 11,103 46 1968 .61 .79 11,540 45 1969 .64 .81 11,818 47 1970 .63 .81 12,017 51 1971 .64 .82 13,800 48 1972 .64 .80 15,557 42 1973 .67 .80 18,446 40 1974 .63 .75 30,783 29 1975 .64 .78 24,548 38 1976 .68 .81 23,608 41 SOURCE: U.S. Department of Commerce, Bureau of the Census, Census of Manufactures , 1967, 1972, and Annual Survey of Manufacturers , 1973, 1974, 1975, 1976; and Arthur D. Little, Inc., estimates. 11—30 ------- DRAFT Naturally, the most significant raw material cost is that for wood, which represents from 40 — 75% of the selling price of the preserved wood product. The selling prices of untreated ties and piles (shown in Figure tI—3A) and lumber (shown in Figure 11—4) have respectively increased 12.4%, 8.8%, and 13.7% annually in the 1970—78 period, or faster than the rate of overall inflation. The higher rate of increase for ties versus piles is attributable in part to favorable demand levels for railroad ties. The proportion of wood cost to total sales dollars has remained roughly constant over the 1970—78 period and except for the 1974—75 recession, the combined cost of all raw materials has been a stable proportion of the sales dollar as shown in Table 11—13. Thus, producers have been able to pass on increased costs of wood in the form of increased selling prices. This relationship is apparent in the Figure 11—4 where selling prices closely track wood costs. After years of relatively constant prices, the price of major chemical preservatives, pentachiorophenol and particularly creosote oil, have increased dramatically since 1973. The price increase for these chemical preservatives over the 1970—78 period, 11.1 and 12.6% respectively, is greater than that of the final products. This indicates their increased importance as an input cost, although still a smaller portion of the total than are wood or labor. The previous discussion of potential industry growth suggests that future demand will be weaker, and the industry will have a more difficult time in passing along increased costs in the form of price increases. However, the nature of the pollution abatement cost is predominantly fixed rather than variable. A change in fixed cost represents a change in long—run average total cost, and therefore it is likely that the cost per unit of production for a larger, more efficient plant will set the maximum amount of price increase assuming the historic supply/demand balance. Since the effluent abatement cost per unit of production will be greater for smaller plants, smaller plants ------- FIGURE 11—4 DRAFT LIST PRICES OF SELECTED PRESERVED WOOD PRODUCTS 1 Price $12 I/Il 7. 11 10 9 8 6 5 4 3 2 1 I - Treated 1970 1975 Untreated Value Added in Wood Preserving Ties S/each I Average Annual Increase 12.3% 12.4% 9.4% I I 1 I Pile 2 —. 8.8% 1978 ‘List prices are given because they provide a comparable basis for analysis over an extended period of time. The majority of contracts specify prices which provide substantial discounts from list prices. 2 Piles: Points : 12” — 3 ft. from butt 7 in.; Length : 40 to 50 ft., truck lots, New York 3 Ties: 6” x 8” x 8’6”, Chicago, Red Oak, Carload lots SOURCE: Engineering News Record . 11—32 ------- DRAFT may not recover the entire cost increase through higher prices. Market factor will determine whether this cost increase may be passed along through price increases or will be absorbed by reducing profits. H. FINANCIAL PROFILES 1. Income and Asset Analysis In assessing the economic impact of an EPA regulation upon a specific industry, the impacted industry is examined on a stand—alone basis without regard to the other businesses associated with it or to resources available to the parent companies of industry plants. For this reason, it is important to have an accurate picture of the revenues and expenses associated with the plant operations in the impacted industry as well as the assets used by the plants. The source of financial profile data is the Environmental Protection Agency 308 Letter. Table 11—14 contains pro—f orma income statements developed for seven sales and service categories of wood preserving plants. Sales level categories were selected to represent the distribution of plant sales, profit and loss, and cash flow. There are sales categories in Table 11—15 that could be grouped if one were interested in the pro—f orma distribution of expenses alone. Pro—f orma income statements were developed for five categories of plants treating owned—wood products (TOWP) and two categories of plants providing a treating service only (TSO). The number of plants providing TSO represents 13% of the total respondents to the EPA Financial 308. Two sales categories were sufficient to adequately represent this group for the purpose of an economic impact assessment. Some cost elements vary with the size of plant and service offered. Wood cost as a percent of sales increases as sales increase for plants treat- ing owned—wood products. The reasons for this could be that the larger plants tend to have greater portion of their sales derived from items such as ties and poles whereas smaller plants tend to treat more specialty 11—33 ------- TABLE 11—14 PRO-FORMA INCOME STATEMENTS WOOD PRESERVING PLANTS Treating Service Plants Treating Owned—Wood Products Only Sales ($000 ) 200 700 1,800 3,500 7,500 250 1,000 7. Sales 1007. 100% 100% 100% 100% 100% 100% Wood Cost 44% 44% 55% 50% 55% 8% 252 Payroll Cost 19% 17% 13% 12% 19% 20% 19% Other Expenses 18% 17% 15% 20% 12% 39% 34% Depreciation 4% 2% 2% 2% 2% 52 2% Gross Margin 15% 20% 15% 16% 122 28% 21% G6.A 11% 12% 11% 9% 57. 11% 15% Interest 3% 2% 1% 1% 1% 2% 1% Profit Before Tax 1% 6% 3% 6% 6% 12% 6% Profit After Tax .5% 3% 2% 3% 3% 6% 4% Survey Plants 50 81 40 50 50 6 31 (327 Responses) 7. Total 1 15% 25% 12% 15% 15% 2% 11% D 113 plants (4%) had sales equally split between TSO and TOWP. SOURCE: Derived by Arthur D. Little, Inc., from Environmental Protection Agency financial 308 Letter -ri -I ------- TABLE 11-15 WOOD PRESERVING PLANTS ASSET TURNOVER BY SALES/SERVICE CATEGORY 1976 Return on Sales/Service Total Sales/ Sales/ 2 sales Total Category ($000) Plants Total Assets Net Assets Fixed Assets Capital TOWP $ 200 50 2.5 3.8 5.0 1.9% 700 81 3.0 4.7 8.0 11.1 1,800 40 3.0 4.3 10.0 8.6 3,500 50 2.5 3.1 10.0 9.3 7,500 50 2.5 3.1 8.0 9.3 TSO $ 250 6 3.0 4.0 5.0 24.0 1,000 37 5.0 8.0 10.0 32.0 LBased on 327 responses; 13 plants were equally split between TSO and TOWP. 2 Total assets less current liabilities. 3 Prof it After—Tax (Table II—14) Margin Sales/Net Assets = Turnover; Net Assets = Total Assets — Current Liability Rate—of-Return on Total Capital Margin x Turnover SOURCE: Derived by Arthur D. Little, mc, from Environmental Protection Agency Financial 308 Letter reponses. m -l ------- DRAFT lumber and timbers; ties and poles are more of a commodity product and thus price would be lower relative to cost of goods sold. Another reason is that plants with higher sales volume have a larger base over which to spread fixed cost (note that general and administra- tive expense are a lower percentage of sales for large plants) and thus can afford to have a higher ratio of wood cost to sales. As would be expected, plants primarily engaged in providing treating service only have low wood costs as a percent of sales. Margin on sale increases with sales for plants treating owned—wood products while the reverse is true for plants providing a treating service only. However, as shown in Table 11—15, sales turnover (Sales/Net Assets) decreases with sales. The net effect is that, with the exception of the smallest sales category, return on total capital (Margin x Turnover) is higher for smaller plants than for larger plants. Plants engaged in treating service only have substantially higher rates of return on total capital, as calculated in Table II—l5,than plants treating owned—wood products. This could be artificial if TSO plants have older, more fully—depreciated equipment and associated lower book values than comparably sized plants treating owned—wood products. The distribution of assets at wood preserving plants (as opposed to parent companies) was analyzed to determine working capital requirements associated with compliance investment. The distribution of assets varies with size of plant, as shown in Table 11—16. Fixed assets as a percent of total assets generally decline as sales level Increases for plants engaged in treating owned—wood products. While the reverse is true for TSO plants in Table 11—16, the variability and small total number of plants are such that the two plant sizes are not statistically different In the percentage of assets in plant and equipment. 11—36 ------- TABLE 11—16 ‘Based on 327 responses; WOOD PRESERVING PLANTS DISTRIBUTION OF ASSETS BY SALES AND SERVICE COMPANY 13 plants were equally split between TSO and TOWP. Treating Service Only $250 $1,000 35.0% 26.0% 25.0 24.0 60.0 50.0 40.0 50.0 100.0% 100.0% 1.3 751 6 37 D -n -I ‘ -I Sales Category ($000) Treating Owned—Wood Products $200 35.0% $700 35.0% $1,800 30.0% $3,500 20.0% $7,500 20.0% Accounts Receivable Other Current Assets 20.0 30.0 40.0 55.0 50.0 Total Current Assets 55.0 65.0 70.0 75.0 70.0 Fixed Assets 45.0 35.0 30.0 25.0 30.0 Total Assets 100.0% 100.0% 100.0% 100.0% 100.0% Average Value of Total Assets 270 320 617 1,805 3,710 Number of Plants in Sample 1 50 81 40 50 50 SOURCE: Derived by Arthur D. Little, Inc., from Environmental Protection Agency Financial 308 Letter data. ------- DRAFT The “other current asset” category in Table 11—16 includes inventory items. As expected, plants treating owned—wood products, with the exception of the smallest plants, have a higher percentage of assets in this item than plants engaged in treating service only. For both plant categories, accounts receivable decrease as a percent of total assets as sales increase. In recent years, over 85% of the industry’s capital expenditures have been on new machinery and equipment to reduce labor costs, as shown in column 3 of Table 11—17. This investment has resulted in a reduction of total employment and raising the level of industry productivity (shown as a real increase in value added per employee in 1967 dollars in column 7) by about 25% in the 1967—76 period. However, there are a number of firms which have not made the expenditures to reduce labor costs; their compara- tively less favorable cost structure will make the financing of major capital expenditures for pollution control especially difficult. 2. Investment Criteria As part of the Environmental Protection Agency Financial 308 Letter, wood preserving plants were asked to provide their criteria for investment in wood preserving plant and equipment. This information is used in the economic impact assessment to estimate the required price increase to recover the cost of pollution control investment. A total of 119 (35%) of the plants Indicated an investment criterion; 22% provided target internal rate—of—return values, and 6% provided payback criteria. Plants providing rates—of—return criteria represented a cross section of the wood preserving plants responding. There were too few responses to the question to subcategorize the rate—of—return by plant character- istics. However, respondents to the question were distributed similarly to the total sample with respect to sales level, current discharge status and type of preserved wood product. The distribution of target rates of return was used to represent the total industry. 11—38 ------- TABLE 11-17 CAPITAL EXPENDITURES AND PRODUCTIVITY IN WOOD PRESERVING INDUSTRY (5) (6) (7) Production VaiJ!ue Added Value Added (1) (2) (3) (4) Workers of Per Man Hrs. Per Man Hrs. of Total New New Structures and New Machinery and Total % of Total of Production Production Year Expenditures Additions to Plants Equipment Employment Employment Workers Worker (millions of (millions of current (millions of current (000s) (percent) (current $) (1967 $) current dollars) dollars) dollars) 1967 10.7 1.4 9.3 12.2 84 6.25 6.25 1968 9.3 1.4* 7 9* 12.6 84 6.58 6.03 1969 13.2 NA NA 12.1 83 6.78 5.77 1970 8.4 1.4 7.0 12.0 81 7.14 5.78 1971 10.4 .5 9.9 11.3 82 7.94 5.94 1972 14.8 2.2 12.6 11.3 81 9.35 6.35 1973 11.6 2.0 9.6 10.1 83 10.41 6.34 1974 28.1 3.9 24.2 10.6 81 17.63 9.94 1975 27.5 4.9 22.6 9.3 80 14.54 7.57 1976 22.3 2.4* 19.9 9.7 79 14.87 7.74 *Indicates the standard error is greater than 15%. NA - Means not available. SOURCE: U.S. Department of Commerce, Bureau of the Census, Annual Survey of Manufacturers——1967—1976 . -Ti -I ------- DRAFT The distribution of target pre—tax rates—of—return is shown in Table 11—18. The average and median pre—tax rates of return are in the 20—24% category. Using midpoints of the categories, the weighted average after tax rate—of— return is about 12%, assuming a 48% tax rate. The impact assessment in Chapter IV was done using the weighted average value and a sensitivity analysis was done to determine the impact of different rate—of—return on the results. (See Chapter V). 11—40 ------- DRAFT TABLE 11—18 TARGET RATE OF RETURN FOR INVESTMENTS MADE BY WOOD PRESERVING INDUSTRY Pre—Tax Rate of % of Return I! Respondents 0-4% 0 0% 5—9 2 4 10—14 7 13 15—19 11 21 20—24 8 15 25—29 12 25 30—40 8 15 40 or rire 4 7 52 100% II Distribution of Samj4e Total Respondents Plants Using Rate—of—Return Criteria: 22% 75 Plants Using Payback Criteria: 6 21 Plants Using Other Methods 7 23 Not Answering Question 65 218 100% 337 SOURCE: Environmental Protection Agency Financial 308 Survey. 11—41 ------- DRAFT III. COST OF COMPLIANCE A. PURPOSE The costs of compliance for a number of alternative BAT regulations has been developed by the EPA Technical Contractor, Environmental Science and Engineering, Inc ). The purpose of this Chapter is to summarize the costs of compliance associated with each option, review the current status of the industry, and describe the investment and operating costs that will be incurred under each alternative. B. CURRENT EFFLUENT STATUS Table 111—1 describes the current effluent status of wood preserving plants by type of process. Ten plants currently discharge into navi- gable waters (direct discharge), while 42 discharge into municipal systems (indirect discharge). Inorganic plants are currently required to be at no discharge; all remaining organic plants do not discharge. The plants that will be required to make expenditures represent a minority of the industry. In total, the 52 potentially impacted plants represent 15% of the respondents. All ten direct discharge plants are primarily steaming plants. An additional 31 plants In the organic category and 11 Boulton plants dis- charge into municipal systems. The cost of compliance developed by the EPA technical contractor were developed based upon a separate EPA TechnIcal 308 Letter as well as on plant visits and sampling data. The technical contractor was in the process of developing cost of compliance data for two of the plants at the time this report was written; therefore, the cost of compliance for those facilities was based on plants for which cost data were available. In addition, the technical contractor developed cost data for 5 plants that did not provide economic data. Costs of compliance are based upon plants for which costs were available at the time, using extrapolation for plants for which cost data were lacking. 1 Reference 1 111—i ------- DRAFT TABLE 111—1 CURRENT DISChARGE STATUS BY TYPE OF PROCESS Technical Financial Composite Indirect Discharges Contractor 308 Survey 1 / Steaming 29* 29 31 9% Boulton 11 11 11 3 Direct Discharges Steaming 10 7 10 3 No Discharge TOTAL 337 342 100 SOURCE: Environmental Protection Agency Financial 308 Survey, and follow-up calls by the EPA Technical Contractor. * Number of plants for which cost was available at the time of writing. Costs for the two additional plants were in the process of preparation. 111—2 ------- DRAFT C. CONTROL OPTIONS At the time of writing, costs of compliance were available individually for 50 of the 52 impacted plants identified by the economic and technical contractors. Types of compliance treatment differ somewhat by plant. The treatment subcategories used were: • Organic — Boulton Process • Organic — Steaming Process, indirect discharge • Organic — Steaming Process, direct discharge. All impacted Boulton plants are indirect dischargers. Three categories of control options were developed for indirect die— chargers (steaming process): • Option 1: Enhanced biological treatment • Option 2: Enhanced biological treatment with heavy metals removal • Option 3: Total recycle/no discharge. Under Option 1, all but three of the steaming indirect dischargers will incur additional compliance costs, while nine of eleven Boulton plants will be affected. If Option 2 (heavy metals removal) is required, eight steaming and three Boulton plants will be affected. Under Option 3, more than one method is feasible to achieve “no discharge” for some plants and the low cost option has been used in the analysis. Three control options were also developed for direct dischargers: • Option 1: Enhanced biological treatment • Option 2: Enhanced biological treatment with carbon absorption • Option 3: No discharge 111—3 ------- DRAFT Only two plants of the ten would incur additional cost under Option 1, and only one of the two would incur additional costs under Option 2. Under Option 3 (no—discharge) all ten direct discharges will incur costs. The cost of effluent monitoring were generated by the EPA and not the technical contractor. These costs will add $5,000 to $10,000 per year to operating costs. D • COST OF COI’fi’LIANCE FOR EXISTING INDUSTRY Tables 111—2 through 111—4 contain the investment and operating costs associated with each of the three levels of control. The land invest- ment has been broken out separately because it enables a comparison of the relative amount of land required for each of the control options studied. A cost of $5,000 per acre was used as the cost of land and, thus, the number of acres required for each can readily be determined. Land investment was separated from other investment in the economic impact assessment because land is not a depreciable asset and, therefore, must be treated separately. Since costs of compliance were generated for 50 individual plants, a range of costs of compliance is shown in Tables 111—2 to 111—4 for each sales category where costs of compliance apply. As can be seen from the tables, considerable variability exists from plant to plant in compliance cost. The source of variablility relates to volume of water effluent. For indirect discharge steaming plants the cost of compliance, in terms of both Investment and monitoring cost, increases with the stringency of the pollution control requirement. In contrast, for most Boulton plants, the cost of Option 3, no discharge, is lower than the cost of Option 1 or Option 2. (The obvious exception to this are the two Boulton plants who would Incur zero cost under Options 1 or 2). 111—4 ------- TABLE 111—2 O80&IIC -I0UL? Annual Operating Coat. Plant Type! Sale. COST OF C L1A1 E OPTICU 1; IBAIHZD BIOLOGICAL TRE& T - ($000) of Plant. Total NIM1e Coat Plant High Coat Plant Low Coat Plant Invea ent Other Land Inveat.ent Annual Invea nt Operating Other Coat. Total ! Inveatnent Inves ant Other Operating Total Land Inveaneant Coate I. ’ p4 I ;. ‘a $3300 I/A 1 1 68.8 0 54.2 1.0 2 $ 700 3 45.4 0.7 44.8 16.0 54.2 0.8 53.4 17.5 u U U U ieoo 4 69.1 1.1 68.1 19.2 236.3 3.9 232.4 34.3 64.1 1.0 67.2 18.3 3300 11 108.4 1.8 106.7 23.4 207.5 3.4 204.1 42.3 48.6 1.7 48.0 16.3 7500 9 117.5 1.9 115.6 3.4.2 322.3 3.8 118.4 52.5 42.6 — 42.6 4.7 hA 29 uIC-ST!A 0-D1 ? 68.8 22.8 XX U U U U U U U 53.2 13.5 U U U U U U U U 1.3 79.8 22.9 U X X U X X XX U U U 0.9 59.4 17.1 U XX U U U U U U 1.7 101.7 23.3 XX U U XX U U U U 2.8 168.4 29.0 U XX U X X 102.3 1.7 101.7 23.3 4.0 230.0 34.7 956.0 20.0 936.0 93.1 132.3 2.2 130.2 25.7 SCURCE: Environnental Science and Engineering, Inc. $ 200 700 1800 3500 7500 TOE 1 1 1 2 4 9 81.0 60.3 1 02i3 171.1 234.0 D -n -I ------- TA8LE 111-3 COST OP C(1(PLIANCE OPTION 2* ($000) Middle Cost Plant High Coat Plant Lem Coat Plant Investment Investment Investment Annual Annual Annual PLANT TYPE! Other Operating Other Operating Other Operating Sales • of Plants Total Land Inveatment Costs Total Land Investment Coats Total Land Inveatment Costa OPGAN10—STEAXING— IRECT $ 700 2 128.7 0.7 127.1 27.8 U U XX U U U U U 1800 1 166.0 1.0 165.1 33.1 U XX U XX fl fl U 3500 4 306.0 2.6 303.4 55.9 366.2 3.4 362.8 73.8 190.6 1.3 189.3 36.8 7300 1 289.1 2.0 286.7 53.6 389.1 — 389.1 65.1 XX U XX U TOTAL 8 I. . O80AMC—STEAJaNG-DIUCT N/A 1 112.8 2.0 li0.8 27.9 XX XX U U U U U U C80ANIC—IOULTON $ 100 159.1 1.7 157.5 32.1 XX XX XX XX U U U 3500 2 176.2 1.7 172.6 51.7 318.3 4.0 314.3 59.1 U XX U XX 7500 3 400.9 5.3 395.7 70.3 528.3 7.8 520.6 87.6 270.1 3.4 266.7 52.4 TOTAL 6 *Option 2: Incremental coats of heavy metals removal for organic steaming, indirect diacharger and Boulton plants were added to Option 1 coats • Costs for direct discharges represent a higher level of biological treatment than Option 1. Costs for impacted plants only. SOUR : Enviroemental Science and Engineering, Inc. -I ------- TABLE 111—4 Inve atnent Annual Other Operating __________ I of Plants Total Land Inveatnent Coat. o &NIC—STWW O-I IUCT Plant Typel Sale. ($000 ) Middle Coat Plant COST OP COMPLIANCE OPTION 3: ZERO DISCEARCE ($000) High Cost Plant low Cost Plant Inveatnent Inveat.met Annual Other Operating Other Total Lend Inveatnent Coats Total Lend Inves nt ‘4 ‘4 .4 11 10 2 31 S 1 1 Annual Operating Coats $ 700 1800 3500 7500 N/A , . TOTAL o &1Ic-sTwIING-DIREcr $ 700 1800 3500 N/A TOTAL OROANIC-BOULTON $ 200 700 1800 3500 7500 TOTAL 4 98.7 1.3 97.5 15.9 188.8 1.9 186.9 19.4 27.1 — 27.1 0.6 4 128.3 — 128.5 16.5 312.4 10.4 302.8 22.0 26.4 — 26.4 0.6 183.3 4.8 178.4 17.9 287.3 9.3 278.0 32.5 68.8 — 68.8 22.8 122.2 —— 122.2 18.0 403.4 — 403.4 34.9 78.3 0.8 77.6 15.4 72.7 — 72.7 1.6 134.9 — 134.9 3.1 27.1 — 27.1 0.6 26.4 — 26.4 0.6 X X X X ER ER ER U U X X 176.6 — 176.6 15.3 U XX XX XX XX U U ER 1 10 109.2 — 109.2 2.5 XX XX ER ER XX U XX ER 1 62.1 — 62.1 25.7 XX XX XX U XX X X U U 1 50.6 — 50.6 23.5 ER XX XX ER ER ER U U 1 71.9 — 71.9 28.4 XX XX XX ER XX U U U 92.0 — 92.0 35.8 127.0 — 127.0 23.2 XX U U U 110.4 — 110.4 42.3 178.2 — 178.2 89.2 81.6 — 81.6 31.1 2 6 11 Source: Environmental Science and Engineering, Inc. D ‘1 -I ------- DRAFT Most direct dischargers incur no cost under Options 1 and 2. However, for the two plants that are impacted, Option 1 is less costly than Option 3. For the one plant affected by Option 2, the no—discharge Option 3 is less costly than Option 2. Table 1 11—5 shows the total costs of compliance that will be incurred by the direct and indirect dischargers in the wood preserving industry. In addition, for Option 2, (heavy metals removal, for indirect dischargers; carbon absorption for direct), the cost of that component was included only for the estimated 15 plants requiring it, while all other plants impacted incur Option 1 costs. Total investment cost, based on the 42 plants evaluated will be $4.2 million for Option 1, $7.1 million for Option 2, and $6.8 million for Option 3. The total investment costs for direct dischargers under each of the three options are $128,000, $240,000, and $742,000, respectively. The cost shown in Table 111—5 are on a worse case basis, assuming plants install the control technology related to the stated option. Since “no discharge” is generally less expensive for Boulton plants and steaming plants than heavy metals removal, the six Boulton plants would presumably install the Option 3 control equipment under Option 2. Table 111—6 illustrates the total cost of compliance assuming plants will install Option 3 (no discharge) control equipment where Option 1 or 2 are more costly. Total compliance costs assuming Installation of the least cost treatment, are shown in Table 111—6. Under Option 1, indirect dischargers will incur investment costs of $3.8 million or 27% less than that of strictly applying Option 1 technology; likewise, costs under Option 2 for indirect dischargers are $4.2 million or 41% less. Costs for direct dischargers decrease only sightly, from $184,000 to $178,000 when the least cost treatment is utilized. 111—8 ------- DRAFT TABLE 111—5 TOTAL COST OP CO LIANCE WOOD PRESERVING INDUSTRY INSTALLING OPTION TECHNOLOGY (000s) Investments Annual I / Other Operating INDIRECT DISCHARGES Plants Total Land Investment Costs OPTION 1 Enhanced Biological Treatment Organic—Steaming 29 2,986 35 2,951 663 Organic—Boulton 9 2,190 40 2,150 300 TOTAL 38 5,176 75 5,101 963 OPTION 2 Heavy Metals Removal Organic—Steaming 29 3,876 35 3,841 820 Organic—Boulton 9 3,180 95 3,085 450 TOTAL 38 7,056 130 6,926 1,270 OPTION 3 Total Recycle Organic—Steaming 31 5,691 95 5,596 602 Organic—Boulton U 1,110 —— 1,110 290 TOTAL 42 6,801 95 6,706 892 DIRECT DISCHARGES OPTION 1: Enhanced Biological Treatment 2 128 1 127 35 OPTION 2: Enhanced Biological Treatment with Carbon Absorption 2 240 4 236 51 OPTION 3: No Discharge 10 742 742 43 SOURCE: Estimated by Arthur D. Little, Inc.using cost of compliance data developed by Environmental Science and Engineering, Inc. 111—9 ------- DRAFT TABLE 111—6 TOTAL COST OF COMPLIANCE WOOD PRESERVING INDUSTRY INSTALLING LEAST COST TECHNOLOGY (000s) Investment ___________________________ Annual Other Operating INDIRECT DISCHARGES Plants Total Land Investment Costs OPTION 1 Enhanced Biological Treatment OrganIc—Steaming 29 2,986 35 2,951 663 Organlc—Boulton 9 862 —— 862 340 TOTAL 38 3,848 35 3,813 1,003 OPTION 2 Heavy Metals Removal Organic—Steaming 29 3,348 35 3,314 585 Organic—Boulton 885 885 _____ TOTAL 38 4,223 35 4,199 1,035 OPTION 3 Total Recycle Organic—Steaming 31 5,690 95 5,596 602 Organic—Boulton 11 1,110 —— 1,110 290 TOTAL 42 6,880 95 6,706 892 DIRECT DISCHARGES OPTION 1: Enhanced Biological Treatment 2 128 1 124 35 OPTION 2: Enhanced Biological Treatment with Carbon Absorption 2 178 178 25 OPTION 3: No Discharge 10 742 742 43 SOURCE: Estimated by Arthur D. Little, Inc. using cost of compliance data developed by Environmental Science and Engineering, Inc. 111—10 ------- DRAFT E. COST OF COMPLIANCE FOR NEW SOURCES Costs of compliance for new sources were generated by the technical contractor for organic plants using the Boulton process and organic steaming methods. New wood preserving plants using inorganic processes are required to have zero discharge under BPT guidelines and thus were not analyzed. The treatment technology for new Boulton plants consists of: 1 • Primary gravity oil—water separation; • Flocculation followed by rapid sand filtration; and • Evaporation in cooling tower, with provisions for additional heat input through a heat exchanger. The treatment technology for a new steaming plant consists of: 2 • Primary gravity oil—water separation; • Flocculation followed by rapid sand filtration; and • Containment and spray evaporation. Cost of compliance estimates were based upon the plant types and sizes shown in Table 111—7. Two sizes of Boulton plant are shown (one with two 130’ x 7’ cylinders, and the larger with five cylinders), each treating Douglas fir poles, which require a long residence time in a retort. Costs were also developed for two sizes of organic steaming plants treating southern pine poles. Boulton plants treating southern oak railwood ties would have production rate and wastewater flows similar to those for the organic steaming plants,but the treatment technology shown for the Boulton plant. The cost of compliance with the new source treatment technology is shown in Table 111—8 for each model plant. The compliance investment and operating costs reflect only one half of the cost of primary oil—water separation and the remainder has been included in the new plant baseline data described 1 Reference 1 “I—il ------- DRAFT in Chapter II and included in Chapter IV. The total cost of primary oil—water separation is also shown in Table 111-8; these costs differ by size of plant but not by treatment method. 111—12 ------- DRAFT TABLE 111—7 MODEL PLANTS FOR NEW SOURCE PERFORMANCE STANDARDS Design Production Wastewater Cubic Feet/ Product Flow Plant Type Day Type ( Gal. / Day) Boulton Process Plant A 3,200 Douglas Fir 4,000 Poles Plant B 8,000 10,000 Organic Steaming Plants Plant C 6,000 Southern Pine 2,500 Poles Plant D 15,000 7,000 SOURCE: Environmental Science and Engineering, Inc. 1 11—13 ------- DRAFT TABLE 111—8 COST OF COMPLIANCE NEW WOOD PRESERVING PLANTS Model Total Operating Acres of Land Plant Type Investment Cost Required Boulton Plant A’ $163,530 66,260 1.0 Boulton Plant B ’ 227,560 99,260 1.5 Organic Plant C’ 274,140 73,640 2.0 Organic Plant D 1 437,750 105,300 .8 Total Requirement Primary Oil—Water Separation 2—Cylinder Plant 80,000 8,000 5—Cylinder Plant 113,500 9,500 ‘Half the investment and operating cost of primary oil/water separation has been excluded. SOURCE: Environmental Science and Engineering, Inc. 111—14 ------- DRAFT IV. ECONOMIC IMPACT ASSESSMENT This chapter discusses the results of the economic impact assessment of the costs of complying with the BAT options studied. It also contains a description of plants that will be required to install or modify equipment (thus incurring higher costs of operation) to comply with the studied control options,and compares these plants with those that cur- rently have self—contained or no discharge. A. ECONOMIC CHARACTERISTICS OF IMPACTED PLP NTS As described In Chapter III, only 15% of the plants in the wood preserv- ing industry will be impacted by the BAT alternatives studied because the remaining 85% of the industry is currently not discharging a liquid waste into navigable water or into a municipal system. The impacted plants were compared with the balance of the industry in several areas important to determining the impact of the alternatives on the industry: • Sales • Process • Profitability • Profit Mix • Location With the exception of plant sales, size, and location, impacted plants are not significantly different from non—impacted plants. (See Tables A—li through A—l4 In Appendix A.) In general, plants impacted by BAT requirements are larger than non—impacted plants. Impacted plants also tend to be more highly concentrated in urban areas than the no discharge plants (71% versus 21%) which are more likely to be found in a suburban area, as shown in Table IV—i. The impacted plants located In urban areas account for nearly all of the respondents which cited a lack of available adjacent land for an effluent treatment system (18 out of 42 Impacted respondents). Hence, land availability does not appear to be a problem In suburban or rural locations. IV-l ------- TABLE P1-i LAND AVAILABILITY FOR DISCHARGING PLANTS DISCHARGING PLANTS No Land Availability - Discharge Type of Available Unavailable No Answer Total Plants Location II % II % II % 1! Urban 12 52 21 95 5 50 38 60 60 21 Suburban 7 30 0 0 2 20 9 16 76 27 Rural 4 18 1 5 2 20 7 13 146 52 NoAnswer —— —— —— —— 1 10 1 2 —— —— Total 23 100% 22 100% 10 100% 55 100% 282 100% % of Total Sample (337 Respondents) 7% 7% 3% 16% 84% SOURCE: EPA Financial 308 Letter. NOTE: This table includes three plants as “DISCHARGING PLANTS” which the EPA has learned are “No Discharge” plants. m -•1 ------- DRAFT B. ECONOMIC IMPACT ON EXISTING INDUSTRY The economic impacts of the compliance costs for each studied alternative were analyzed with respect to: • Price impacts • Demand reduction/shifts • Financial effects • Plant closures, and market structure A discussion of the sensitivity of the economic impact assessment to assumptions used is contained in Chapter V, Limitations of Analysis. 1. Price Impacts The question of potential long—run price impacts resulting from the control alternatives studied was addressed by estimating the long—run price increases associated with the costs for each control alternative. The term “long—run price increase” is used to describe that price increase necessary to recover all coats associated with a control option, including a normal rate—of— return on investment. As discussed in Chapter II, the rate—of—return on investment used was the average value found for the plants responding to the rate—of—return criteria question posed in the EPA financial 308 Letter. Chapter V contains a discussion of the sensitivity of the results to rate— of—return criteria. Rather than allocate compliance costs and impact among the wood preserving industry’s products, an estimate was made of the revenue required for the plant to recover the total cost of compliance. Tables IV—2 through IV—4 contain the revenue required to recover the costs associated with each of the con- trol options studied. 1 Since the costs of compliance were developed by plant, the required revenue for each option is shown for middle cost, high cost, and low cost plants in each category. The relative increase in revenue required to recover compliance costs varies with size of plant. In Tables IV—2 through EV—4, the X’s indicate that there are no relevant LSee Chapter III for a discussion of the components of each control option. IV—3 ------- TABLE IV-2 PRICE INCREASES REQUIRED TO RECOVER COSTS OF COMPLIANCE OPTION 1: ENHANCED BIOLOGICAL TREATMENT PLANT TYPE! MIDDLE COST IMPACT HIGH COST IMPACT LOW COST IMPACT Sales ($000) 11 Plants $000 % Revenue $000 % Revenue $000 % Revenue INDIRECT STEAMING $ 700 3 36.7 5% 439 6% X X X X 1800 4 54.1 3 137.5 8 54.1 3% 3500 11 75.1 4 139.8 8 42.3 1 7500 9 88.2 1 207.4 3 36.7 1 N/A 2 N/A N/A xx xx xx xx TOTAL 29 BOULTON $ 200 1 59.4 30% xx xx xx xx 700 1 41.0 6 xx xx xx xx 1800 1 70.8 4 xx xx xx xx 3500 2 110.2 3 xx xx 70.8 2% 7500 4 151.5 2 618.2 8 85.6 1 TOTAL 9 D DIRECT STEAMING $3500 1 56.4 2% X X xx xx xx Not Available 1 41.1 XX X X xx xx xx TOTAL 2 Source: Arthur D. Little, Inc. estimates .INI -I ------- TABLE IV-3 PRICE INCREASES REQUIRED TO RECOVER COSTS OF COMPLIANCE OPTION 2 PLANT TYPE! MIDDLE COST IMPACT HIGH COST IMPACT LOW COST IMPACT Sales ($000) 1/ Plants $000 % Revenue $000 % Revenue $000 %Revenue INDIRECT— HEAVY METALS $ 700 2 $88.4 13% $265.8 38% XX XX 1800 1 107.8 6 XX XX XX XX 3500 4 167.9 5 200.0 6 124.2 4% 7500 1 185.1 2 247.0 3 XX XX TOTAL 8 BOULTON $ 200 0 XX XX XX XX XX XX 700 1 103.8 15% XX XX XX XX 1800 0 XX XX XX XX XX XX 3500 2 113.5 3 219.8 6% XX XX 7500 3 257.9 3 340.3 5 173.7 2 TOTAL 6 DIRECT-CARBON ABSORPTION 1 78.4 XX XX * Shown for plants impacted by Option 2, only, assuming installation of Option 2 treatment technology. Source: Arthur D. Little, Inc. estimates 111 -1 ------- TABLE IV-4 PRICE INCREASES REQUIRED TO RECOVER COSTS OF COMPLIANCE OPTION 3: TOTAL RECYCLE/NO DISCHARGE PLANT TYPE/ MIDDLE COST IMPACT HIGH COST IMPACT LOW COST IMPACT Sales ($000 ) i /Plants $000 % Revenue $000 % Revenue $000 % Revenue INDIRECT— STEAMING $ 700 4 54.2 8% 135.2 19% 41.5 6% 1800 4 69.5 4 146.9 8 XX XX 3500 11 97.8 3 154.6 4 55.5 2 7500 10 68.8 1 191.6 3 51.6 1 Not Available 2 N/A N/A XX XX XX XX TOTAL 31 BOULTON $ 200 1 48.0 24% XX XX XX XX 700 1 43.9 6 XX XX XX XX 1800 1 66.4 4 XX XX XX XX 3500 2 57.5 2 88.0 3 XX XX 7500 6 75.1 1 114.9 2 61.0 1 a’ TOTAL 11 DIRECT $700 5 23.7 3 44.2 6 8.8 1 1800 1 8.6 <1 XX XX XX XX 3500 1 75.7 2 XX XX XX XX Not Available 3 9.7 N/A 35.7 N/A 4.9 NIA TOTAL 10 Source: Arthur D. Little, Inc. estimates D -I ------- DRAFT plants in that sales/control option category. Also, monitoring costs used in the analysis were $5,000 and $10,000 per plant per year, as sug- gested by the Environmental Protection Agency; since EPA has not finalized its requirements, these costs are likely to change. The revenue required to recover compliance costs can be viewed as the average price increase across all products required by a plant in a given sales category. Obviously,small plants have a higher revenue requirement due to the fact that compliance costs for a given option are disproportionately higher for small plants than for large plants. Since only 15% of the plants in the industry will be impacted by the regu- lation, the price increases expected from the regulation are likely to range from 0% to that for the larger plants. The rationale for this is the fact that the wood preserving industry is competitive and while the industry demand curve for most preserved wood products is relatively in- elastic, the demand curve facing individual firms is quite elastic. There are some factors and circumstances which may enable these plants to obtain price increases to recover cost including: • The impacted plants are generally larger than the industry average • Impacted plants may be in isolated geographic markets • The general price level inflation in the U.S. (6—8% per year) may facilitate partial cost recovery. Prices of preserved wood products have outpaced general price inflation during the 1970’s. Given “customary”, inflation related, price increases of 6—8%, impacted wood preservers may be able to recover an additional 1—2% of increased cost associated with pollution control. Also, larger plants are often associated with multi—plant companies which have some market power and may be able to obtain a price increase to recover a portion of the cost of compliance. Finally, plants in locations where there are few or no competing firms may be able to raise prices, limited by the cost of transporting products from the nearest plant that is not impacted. IV-7 ------- DRAFT 2. Demand Shifts The future growth rates in the demand for preserved wood products affect the ability of impacted plants to obtain price increases. Plants pre- dominantly producing poles will be unlikely to obtain higher prices for this product than the industry in the face of a declining demand. Shifting from poles to other products will increase capacity for other products which will,in turn, further inhibit the impacted firms’ ability to increase price. While the selection of preserved wood versus steel or concrete materials is predominantly based upon structural requirements, this could change for railroad ties in the future. If concrete ties prove out technically and can be produced economically, a portion of the market expansion fore- cast for ties could be captured by concrete substitutes, especially if the life cycle costs become more competitive. While this may not be a factor until the mid—1980’s, that would coincide with the deadline for BAT compliance and would further prevent the impacted plants from recover- ing costs of compliance through price increases. 3. Financial Impact It is unlikely that the impacted plants as a group will be able to recover the costs of complying with BAT regulations through higher prices. If they elect to install the pollution control equipment, profitability is likely to decline. Table IV—5 shows the impact of increased operating costs and investment upon profitability in the absence of price increases. The analysis considered the impact on operating costs due to out—of—pocket expenditures; i.e., while potential interest payments on debt are included as a cost, the total cost of capital is not included in the figures in Table IV—4. Also, the lowest—cost means of achieving compliance was used in the Table IV—l5; i.e., if Option 3 is less expensive than Option 2 for a plant, it is assumed the plant will install Option 3. IV-8 ------- TABLE IV-5 WOOD PRESERVING PLANTS PROFITABILITY WITH NO PRICE INCREASES BEFORE AND AFTER COMPLLANCE Sales ($000) $200 $700 $1,800 $3,500 $7,500 Precompliance Profit Before Tax (% Sales) 1% 6% 3 6% 7% _____________ Post—Coiup]i ance Profit Before Tax _________ OPTION/PLANT TYPE Middle Low Middle Low Middle Low Middle Low Middle Low Value Value Value Value Value Value Value Value Value Value Option 1 Steaming—Indirect XX XX 3% 1% 4% 5% 4% 6% Boulton* (14%) —— 2 —— 1 —— 5 —— 6 —— Steaming Direct** XX XX XX XX XX XX 5% XX XX Option 2 Steaming Indirect* XX XX 3% 1% 1% —— 5% 4% 7% 6% Bou lton* XX XX 2 —— XX XX 5 —- 6 —— Steaming_Direc.t** XX XX XX XX XX XX XX XX XX XX Option 3 Steaming—Indirect XX XX 3% 1% 1% 5% 4% 7% 6% Boulton (14%) —— 2 —— 1 5 —— 6 —— Steaming—Direct XX XX 4 5 3 4 XX XX * Option 3 cost of compliance used where less expensive than Option 1 or Option 2. ** Sales data not available. SOURCE: Arthur D. Little, Inc. estimates m -I ------- DRAFT Since the costs of compliance are relatively higher for small plants, small firms will suffer the greatest decline in profitability as a result of compliance. The small plants with lowest sales volume would be in a negative profit situation under all of the control options studied. Plants in the other sales categories would suffer a decline in profitability but would still be profitable under each alternative. The average plant with sales from $700,000 to $3.5 million would not be subject to as great a reduction in profitabiity. Further, any price increases the impacted plants are able to obtain would mitigate the re- duction in profitability for small and medium size plants. However, as discussed above, price increases that do occur (barring a tight market) will reflect the cost structure of the larger plants. Even with price increases, many plants with less than $1.8 million in sales are likely to become unprofitable if they make the compliance expenditures. Reduction in profitability is not the only financial impact of the regu- lation. If one were to assume that all impacted plants could recover the pollution control expenditures through price increases, it is still likely that a number of impacted plants would be unable to finance the required investment. Figure IV—l depicts the investment required for each of the control options studied relative to cash flow. For small plants in the $700,000 category, the investment required for all options studied exceeds annual plant cash flow for all but one plant. Even for larger plants, the studied alternatives require investment exceeding a single year’s cash flow, Considering the fact that a portion of the plant’s cash flow must be used for expenditures other than associated with BAT regulations, impacted plants will not generate sufficient cash flow to self—finance compliance with these regulations. tV—b ------- FIGURE IV—l INVESTMENT REQUIRED FOR BAT ALTERNATIVES AS A PERCENTAGE OF CASH FLOW Direct Option 1: 500 Option 3: ‘ Direct Option 1: Investment Option 3: LI as_a 400 Percent of Cash Flow . 300 0 0 0 200.. a. . • Do • © DO LI •. C 100. U • • © • @ 0 Q : o 13 D •1 1 30 13 o c i SALES CATEGORY 700 1,800 3,500 7,500 200 700 1,800 3,500 7,500 ($000) “— — ________________ -——-- - PLANT TYPE ORGANIC - STEAMING ORGANIC - BOULTON SOURCE: Arthur D. Little, Inc. estimates. -I ------- DRAFT This statement can be placed in perspective by referring to the discussion of financial characteristics in Chapter II. The impacted plants generate an annual cash flow equivalent to approximately 4% of sales.’ Table 11-5 indicated that about 3% of sales is reinvested to maintain industry assets, leaving about 1% of sales for dividends, retained earnings, and other purposes. Wood preservers would be required to accumulate four years cash flow in excess of maintenance investment requirements to have available the equivalent of one year’s cash to Invest in pollution control. There- fore, any plant with a pollution control investment requirement in excess of one year’s cash flow will probably have to obtain external financing between 1979 and 1983 to fund pollution control expenditures if BAT reg- ulations are required in 1984. Assuming a plant is viable——i.e., prices will eventually increase to cover the BAT investment expenditures——a plant will be required to seek f in— ancing from a parent company or the financial community. As seen in Table IV—6, the wood preserving Industry is dominated by privately—held corporations (78% of all plants) and a minority of plants (22%) are pub- licly—held. Many of the privately—held corporations and proprietorships are one—plant corporations and effectively the plant and corporate cash flows are one and the same. Plants that will be impacted by BAT regula- tions are similar in form of ownership to the industry overall, with 36 (58%) of the direct and indirect dischargers organized as privately—held corporations. It is more likely that the privately—held corporations will require ex- ternal financing to a greater extent than the publicly—held corporations. In either case, it is less likely that the financial community or parent corporations would be willing to make investments in financially—nonviable plants. Based on the financial criteria, any but the larger impacted plants would make the investment required to satisfy BAT requirements. LBased upon responses to the EPA Financial 308 Survey. IV—12 ------- TABLE IV-6 FORN OF BUSINESS ORGANIZATION BY DISCHARGE STATUS Primarily Discharging Plants Total Plants Organic Preservatives Number Percent Number Percent Proprietorship 1 ‘27 23 10% Co—op 1° 1 0 Privately—held Corporation 27 53 158 65 Publicly—held Corporation . 2. 45 25 Total 50 100% 241 100% Total Proprietorship * * 31 9% Co—op * * 1 0 Privately—held Corporation 36 58 230 69 Publicly—held Corporation 62 100% 334 100% NOTE: Totals do not add due to non—response on one question. This table includes three plants as “DISCHARGING PLANTS” which the EPA has learned are “No Discharge” plants. SOURCE: Derived from EPA Financial 308 Survey. -n -I ------- DRAFT 4. Plant Closures The impacted wood preserving plants (especially the small ones) will be unable to fully recover costs through price Increases. Further, a number of plants will have cash flow shortfalls relative to pollution control investment requirements. These factors point to the likelihood of plant shutdowns in the wood preserving industry. An evaluation of whether or not a plant will shut down rather than make the investment required to comply with pollution control regulations is imprecise. In the first place, the evaluation is made externally to the corporate environment and without knowledge or consideration of corporate goals and objectives. Secondly, the evaluation is based on financial criteria and,while they are based upon industry data and a distribution of wood preserving plant rate—of—return criteria, the criteria may not reflect the actual parameters that will be used in the individual decision—making process, especially since few plants provided Information on financial decision criteria. With those caveats in mind, the analysis indicates that a iumber of plants are likely to shut down rather than make the investment required for compliance. Table IV—7 shows the number of plants impacted by the BAT alternatives studied that are likely to close down rather than make the required compliance investments. The closure candidates can be characterized as having: • Low Sales • Low Profitability • Negative Cash Flow The profitability and cash flow of each discharging plant, derived from the EPA Financial 308 Letter, was used as the basis for the plant closure evaluation. The change in operating cost and relationship of investment required to cash flow was examined under each control option. In this analysis plants were assumed to install the least costly treatment technology that would achieve compliance, and thus Option 3 (no discharge) costs were used if less costly than Options 1 or 2 costs. IV— 14 ------- DRAFT TABLE IV-7 POTENTIAL PLANT CLOSURES UNDER BAT ALTER}TATIVES Probability of Closure PLANT TYPE/ Total Option 1 Option 2 Option 3 SALES Plants High Moderate High Moderate High Moderate ORGANIC- STEAMING— INDIRECT $700 4 2 1 1 1 2 1800 4 1 1 1 1 2 1 3500 11 1 3 4 1 5 2 7500 10 —— 1 N/A 2 -- - - - - -- - - - - TOTAL 31 2 6 6 3 8 6 ORGANIC-STEAMING-DIRECT $700 5 —— —— 2 2 All Others _ -— -— —- —- 10 2 2 ORGANIC-BOULTON $200 1 1 1 1 700 1 1 1 —— 1 1800 1 —— —— —— —— —— 3500 2 — — —— —— 1 — 1 7500 6 —— —— — — — — —— — — TOTAL 11 1 1 1 2 1 2 *Assuming inorganic total recycle option will apply, regardless of organic options. Source: Arthur D. Little, Inc. Estimates ‘v—is ------- DRAFT If a plant could finance the pollution control investment from cash flow and maintain a positive profit margin in the absence of price increases then the plant was judged likely to remain open. A plant was designated as a high probability of closure where required investment was on the order of 200% of annual cash flow and/or post—compliance profit margins would be negative. Plants judged to have a moderate probability of closure were those whose investment was 100% to 200% of annual cash flow but which would still have a positive profit after tax. Since compliance costs fall disproportionately on smaller plants, plants with low sales volumes are more highly impacted. Under the control options studied, up to 12 plants with sales under $3.5 million would be unlikely to make the investment in control equipment for financial reasons——i.e., the plant is likely to incur operating losses as a result of compliance costs or be unable to finance the investment. Under Option 1, a total of 3 indirect discharge plants have a high probability of closure and an additional 7 plants have a moderate probability of closure. Under Option 3 (no discharge) 11 plants would most likely close down and a potential shut down of 10 others could occur. 5. Employment Effects Table IV—8 shows the impact on the employment in the wood preserving industry due to plant closures under the three compliance options. The decrease in the number of production workers due to plants with a high probability of closure under each of the options are 68, 136, and 308, production workers (0.9%, 1.8%, and 4.0% of the industry total) respectively. The estimated loss in production employment if both plants with high and moderate probabilities of closure were to shut down are 219, 335, and 618 workers, respectively, or a reduction of 2.9%, 4.4%, and 8.0% in production worker employment for the industry as a whole. IV—l6 ------- DRAFT TABLE IV—8 WOOD PRESERVING INDUSTRY EMPLOYMENT LOSSES FROM PLANT CLOSURES CONTROL OPTION/CLOSURE PROBABILITY 1 2 3 Moderate High Moderate High Moderate High Steaming 137 54 158 122 215 253 14 14 41 14 41 14 Direct 0 0 0 0 54 41 Total Decrease in Production Workforce 151 68 199 136 310 308 Combined Moderate and High 219 335 618 % Reduction for Industry High Probability Only 0.9% 1.8% 4.0% Moderate plus High 2.9% 4.4% 8.0% SOURCE: Based upon 7,700 production workers in 1976, Department of Commerce, Bureau of Census, Annual Survey of Manufacturers: General Statistics . Plant production employment data from EPA Financial 308 survey. IV—17 ------- DRAFT C. ECONOMIC IMPACT UPON NEW SOURCES AND CAPACITY EXPANSIONS 1. Potential for New Plants The wood treating industry is not capital intensive compared with the average manufacturing industry; the sales turnover ratios for existing plants in 1976 was found to range from 3.0 to 10.01 or more while the ratio of sales to assets for most process industries is on the order of 1.0 to 2.5.2 While considerable excess capacity exists among existing plants, based upon maximum operating capacities, transportation and other factors make it likely that new capacity will be built in growing regions (e.g., the South) before excess capacity is fully utilized in others. While most new capacity may take the form of Incremental expansion (e.g., the addition of a new retort at an existing site), some 17% (or 56 out of 338) of the respondents to the financial 308 letter indicated that their wood treating plant have begun operation since 1970. 2. Impact Upon New Plants As described in Chapter II, a number of new wood preserving plant models were developed to evaluate the impact of new source performance standards. Process economic models were developed for four different plant types: • Boulton plants treating Douglas fir poles in the Northwest; • Organic steaming plants treating southern pine poles; • Boulton plants treating oak railroad ties in the South; • Inorganic plants treating southern pine lumber. Two plant sizes were created for each type: one with two cylinders and one with five (See Chapter II). As mentioned in Chapter III, existing standards for new inorganic plants will have no incremental costs of compliance from BAT revisions. Further, costs of compliance for Boulton 1 Financial 308 letter. 2 Based on data from FTC—SEC, Quarterly Financial Reports . IV—18 ------- DRAFT plants treating oak railroad ties were not generated by the technical contractor. Table IV—9 depicts the baseline revenues on each model plant as well as the incremental revenue required to recover costs of compliance (where available). The model plants are large by industry standards, with production and revenue levels at the upper end of the spectrum. The revenue required to recover costs of compliance in the long run is similar to that for existing plants for Option 3 in the higher sales categories displayed in Table iV—2 through IV—4 which is the no discharge option. The cost of pollution control equipment per se would not appear to hinder the addition of new capacity. If the existing industry BAT requirements are defined as Option 1, then it is possible that incremental expansion will be favored as a means of - capacity expansion, especially given the incremental land requirements of a no discharge new source standard. IV—19 ------- DRAFT TABLE IV-9 IMPACT OF BAT REQUIREMENTS UPON LONG-RUN REVENUE REQUIRED TO SUPPORT NEW SOURCES Revenue Required Annual Baseline for BAT Plant Type/ Production Revenues Compliance Costs Product ( 000 Cubic ft.) ( $000) ( $000) % Baseline A. Boulton/Douglas Fir $ 960 $ ? i834 $154 2% Poles B. Boulton/Douglas Fir 2,400 19,328 226 1 Poles C. Steaming/Southern 1,800 11,345 198 2 Pine Poles D. Steaming/Southern 4,500 28,082 298 1 Pine Poles E. Boulton/Oak R.R. 960 6,487 Not Available Ties F. Boulton/Oak R.R. 2,400 15,962 Not Available Ties C. Inorganic/Southern 1,800 13,413 Not Available Pine Lumber H. Inorganic/Southern 4,500 33,276 Not Available Pine Lumber SOURCE: Arthur D. Little, Inc. estimates. IV—20 ------- DRAFT V. LIMITATIONS OF ANALYSIS The results of economic impact assessment are subject to certain lintita— tions. The factors to which the results are sensitive or which limit their application include: 1. EPA regulations which affect waste disposal; 2. Return—on—investment criteria; 3. Cost variation from plant to plant; 4. Future growth in demand; 5. Local conditions of impacted plants. Consideration of the first item was beyond the scope of the technical contractor’s or economic contractor’s work. It is discussed here because the economics contractor has developed information in conjunction with another study that could potentially be useful to the EPA in its eval- uation of the alternatives studied. Items 2 through 5 are limiting factors in every analysis of this type, but the importance of these factors in influencing the results of a study varies from case to case, and thus requires discussion. A. EPA REGULATION AFFECTING WASTE DISPOSAL Subtitle C of the Solid Waste Disposal Act, as amended by the Resource Conservation and Recovery Act of 1976 (RCRA), creates a regulatory frame- work to control hazardous wastes. Section 3004 addresses standards for owners and operators of hazardous waste treatment, storage and disposal facilities. The regulation impacts the analysis of alternative control options since it specifies the technical and monitoring requirements for each disposal method, as well as restrictions on disposal of waste by method. These in turn, may limit the application of some of the control options studied, or result in higher costs for an alternative than indicated by the technical contractor in this report. Further, wood preserving plants which dispose on—site (28%) may be impacted, in that the current method of disposal may no longer be environmentally adequate. V-i ------- DRAFT The application of both no—discharge and discharge options studied in this report will be affected by RCRA regulations. The lagoons associated with enhanced biological treatment and the impoundment associated with spray evaporation will both be considered methods of hazardous waste disposal or storage, and thus plants will be required to monitor ground- water and surface water as well as to install leachate collection and monitoring systems. A leachate collection and monitoring system is not included in the cost of compliance. Assuming the two aerated lagoon cells combined, or an impoundment, are analogous to small landfills (5,000M 3 /year) In size, then the incremental compliance cost per plant could be as follows: 2 Initial Investment: $129,000 Annual Operating Costs: $ 42,200 Another source of additional cost are monitoring requirements. The cost of analysis for soil and water samples would be on the order of $60,000 per year. Consideration of whether or not the sludge and effluent of wood pre- serving plants were hazardous wastes was beyond the scope of the technical contractor’s report, 1 although it was discussed in the draft report. For off—site disposers, the costs of disposal are expected to double or triple as a result of Section 3004.2 Therefore, that component of the technical contractor’s operating cost (amounting to about 3% of operating costs) will be two to thime times as high, but this cost component will not change the results of the economic impact assessment. B. RETURN ON INVESTMENT CRITERIA Table V—i illustrates that the use of a higher or lower target rate of return than the median value (12%) produces noticeably higher or lower required revenue to cover cost of compliance. Table V—i compares the revenue increase requirement for the low and high ROR scenarios for the sampled plants. The change In requirement from 12% to 5% is relatively iReference 1. 2 Reference 5. V—2 ------- TABLE V—i REVENUE REQUIRED BY DISCOUNT RATE ($000s) DRAFT Revenue Required (1) 12% Discount Rate (2) 5% _.L % Change (3) 20% Change 5 3 —40% 39 30 —23 52 73 75 52 —31 113 117 89 59 —22 121 75 108 78 —28 156 100 173 118 —32 258 119 178 130 —27 255 96 FIGURE V—i REVENUE REQUIREMENT AS PERCENT OF SALES BY ROR FOR SAMPLE PLANTS 10 a) c j (a 1-i a) ..-I 0 ) 0) 0 ) SALES VOLUME ($000s) U 0 x o ROR = 20% o ROR 12% XROR 5% 0 0 0 0 x 0 o 0 0O o 0 x 0 x 1000 xx 2000 3000 4000 x 5000 6000 7000 8000 V- 3 ------- DRAFT constant for most sample plants, a decrease of 25%. There is more vari- ation in the change of requirements from 12% to 20%, the average being an increase of 120%. Figure V—2 shows that there is relatively little variation in the revenue requirement as a percent of sales due to ROR target. The requirement seems to be higher for either plants of smallest size or after very large plants with high expenditures, but even these requirements are less than 10% of sales. The bulk of the increases In revenue to maintain target ROR are within the 1—5% range; on the average, they differ 1% point by ROR scenario. Therefore the economic impact assessment is Insensitive to the return on investments. C. COST VARIATIONS FROM PLANT TO PLANT In any study of this type, the costs of compliance estimated by the technical contractor will overstate or understate the costs applicable to an individual plant by virture of plant—specific conditions. The technical contractor indicated that cost estimates could vary for an individual plant between 75% and 150% of the costs for the control options presented in Chapter III. Sources of the cost difference could include usable treatment in place, land availability, cost of controls and addi- tional plant—specific conditions which apply. The cost of compliance Is based upon land cost/acre and this cost will vary considerably depend- ing upon the plant location (see responses to Question 7f In Appendix C). Those plants with lower costs will be less severely impacted by the alternatives studied. In addition to the understatement of compliance cost caused by EPA regulations on hazardous waste, there could be plant— specific conditions (e.g., terrain) which contribute to higher costs. Plants with higher costs will be more severely impacted by the regulation. D. FUTURE GROWTH IN DEMAND If the future growth forecast for railroad ties and timbers does not materialize or if the rate of decline in poles is greater than forecast, the number of potential closure candidates will increase. If, on the V- 4 ------- DRAFT other hand, demand growth is greater by virtue of a strong housing market growth and accellerated repair of railroads, then the number of plant closures will be fewer than indicated. This happens because the supply/ demand balance is such that high cost plants (including plants impacted by the regulation) determine price and therefore can recover costs of pollution control investment. E. LOCAL CONDITIONS OF IMPACTED PLANTS The analysis of plant closures in Chapter IV is subject to the limitations of any plant closure analysis (described in Chapter IV). In addition, local market conditions of some impacted plants will determine to a significant extent whether a plant will shut down rather than comply with a regulation. For example, if an impacted plant were in a market area where there were virtually no competing firms, it may be able to increase its price and recover the cost of installing control equipment, limited by the cost of transportation of the closest competing firm. This would also be the case if all the plants in an area were required to make equivalent expenditures to comply with pollution control require- ments. Local conditions could produce a worse impact than described in Chapter IV, if for example, most of the firms in the area are not impacted and thus the impacted plant would have very little chance in recovering costs of a pollution contol. V- 5 ------- DRAFT APPENDIX A SUPPLEMENTARY DISCUSSION 1. Industry Characterization 2. Pro Forma New Source Models 3. Characteri3tiCs of Impacted and Non—Impacted Plants ------- DRAFT A-i. INDUSTRY CHARACTERIZATION (Supplement to Chapter II) Product Diversification It is primarily the largest companies in the industry which produce a wide range of products. Most firms in the industry operate only one plant. In these cases, the plant produces organically treated products or inorganically treated products, although some single plant firms produce both organically and inorganically treated products. Furthermore, smaller firms tend to specialize on particular preserved wood products. For example, a firm may produce only preserved railroad ties or posts or pilings or dimensional lumber. For many of the smaller firms, wood preserving is a service offered by a company in the lumber and wood products business. Imports and Exports Import and export statistics do not distinguish preserved wood products from other wood products. However, piling, utility poles, and railway crossties are likely to be preserved when imported or exported. Table A—i and A—2 show U.S. imports and exports of these products for the period 1970 through 1977. Imports, primarily from Canada, have been in the range of $10 million to $15 million per year in recent years. Exports, primarily to wood poor regions such as the Middle East and Japan, have totaled $20 million to $35 million in recent years. It is estimated that 10% to 15% of the U.S. production of utility poles are exported. With this exception, imports and exports do not constitute a sizeable portion of any other preserved woo 1 markets. A-l ------- TABLE A-i U. S. IMPORTS OF PRESERVED WOOD PRODUCTS 1 Timber, Poles, Piling, Posts, and Other Wood in the Rough Railroad Ties Total Value 2 Quantity Value 2 Value 2 ($1,000) (MBF) ($1,000) ($1,000) . 1970 7,733 8,418 717 8,450 1971 8,633 3,363 385 9,018 1972 9,369 7,924 757 10,126 1973 8,654 11,308 1,505 10,159 1974 15,069 13,916 2,566 17,635 1975 9,868 12,475 2,625 12,493 1976 10,615 8,164 2,314 12,929 1977 10,011 7,367 1,370 11,381 ‘U.S. import statistics do not distinguish preserved wood products from other wood products, but the products shown are predominantly preserved wood products. D Values shown are f.a.s. (free alongside ship) values. Source: U.S. Department of Commerce, Bureau of the Census, U.S. Imports - Schedule A, Commodity by Country , FT 135. -n -I ------- TABLE A-2 U.S. EXPORTS OF PRESERVED WOOD PRODUCTS 1 Railway Crossties & Railway Crossties & Year Piling Utility Line Poles Mine Ties—Softwood Mine Ties—Hardwood Total Quantity Value 2 Quantity Value 2 Quantity Value 2 Quantity Value 2 Value 2 (LFT) ($1,000) (Nuniber) ($1,000) (MBF) ($1,000) (MBF) ($1,000) ($1,000) 1970 5,055,702 1,935 160,526 5,526 4,052 353 11,626 2,065 9,879 1971 3,119,931 1,646 71,717 2,385 4,343 509 7,486 1,320 5,860 1972 2,231,276 1,355 102,869 3,935 6,027 1,131 11,568 1,937 8,358 1973 3,210,603 1,931 151,661 6,631 4,209 631 4,979 858 10,051 1974 7,802,427 5,730 169,602 12,163 33,113 3,900 21,617 3,977 25,770 1975 4,104,573 4,090 202,012 15,872 28,224 3,196 47,319 9,636 32,794 1976 2,599,684 2,251 298,439 16,350 15,903 1,859 1.5,003 3,242 23,702 1977 3,096,484 3,124 250,936 16,708 9,355 1,015 9,855 2,423 23,270 0 ‘U.S. export statistics do not separate preserved wood products from other wood products, but the products shown are predominantly preserved wood products. 2 Values shown are f.a.s. (free alongside ship) values at U.S. port. Source: U.S. Department of Commerce, Bureau of the Census, U.S. Exports — Schedule B, Commodity by Country , FT 410. -I ------- A-2. PROaFORMA NEW SOURCE MODELS A-4 DRAFT ------- __ DRAFT ESTIMATED OPERATING COSTS FOR THE MANUFACTURE OF PRESERVED WOOD - ORGANIC TREATMENT Cylinder Size: 2 cylinders, each 7’ diameter x 130’ long, 5000 cubic feet Capital Cost: $2,165,000 (1978) Location: South Central Production: 2000 cubic feet per charge; 30 hours per charge (Boultonizing) 3 shifts per day, 300 days per year. Product: 960,000 cubic feet per year of Railroad Ties Thousand Units Per Dollars Per Dollars Item Units Unit Cost Cubic Foot Cubic Foot Per Year Raw Materials: Wood Cubic feet $2.15 1.0 2,15 2,064 Creosote Gallons $0.70 1.0 0.70 672 Total Raw 2.85 2,736 Materials Processing: Labor, Operating Man hours $6.00 0.324 311 Labor, Maintenance Man hours $6.50 0.090 86 Mace Supplies 0.090 86 Consumable Supplies 0.046 46 Fuel and Power 0.135 132 Plant Overhead 50¼ of Labor 0.207 199 Taxes and Insurance 4% of Capital 0.090 Total Processing 0.982 943 Total Cost, F.O.B. Plant 3.832 3,683 Source : Arthur D. Little, Inc., estimates based on industry interviews. A-5 ------- __ DRAFT PLANT A-2 ESTiMATED OPERATING COSTS FOR THE MANUFACTURE OF PRESERVED WOOD — ORGANIC TREATMENT Cylinder Size: 5 cylinders, each 7’ diameter x 130’ long, 5000 cubic feet Capital Cost: $4,557,000 (1978) Location: South Central - Production: 2000 cubic feet per charge; 30 hours per charge (Boultonizing) 3 shifts per day, 300 days per year. Product: 2,400,000 cubic feet per year of Railroad Ties Thousand Units Per Dollars Per Dollars Item Units Unit Cost Cubic Foot Cubic Foot Per Year Raw Materials: Wood Cubic feet $2.15 1.0 2.15 5,160 Creosote Gallons $0.70 1.0 0.70 1,680 Total Raw 2.85 6,840 Materials Processing: Labor, Operating Man hours $6.00 0.012 0.324 778 Labor, Maintenance Man hours $6.50 0.003 0.090 216 Maintenance Supplies 0.090 216 Consumable Supplies 0.046 110 Fuel and Power 0.135 326 Plant Overhead 50% of Labor 0.207 497 Taxes and Insurance 4% of Capital 0.075 182 Total Processing 0.967 2,325 Total Cost, F.O.B. Plant 3.817 9,165 Source : Arthur D. Little, Inc., estimates based on industry interviews. A—6 ------- __ DRAFT PLANT B—i ESTIMATED OPERATING COSTS FOR THE MANUFACTURE OF PRESERVED WOOD - ORGANIC TREATMENT Cylinder Size: 2 cylinders, each V diameter x 130’ long, 5000 cubic feet Capital Cost: $2,165,000 (1978) Location: South Central Production: 2000 cubic feet per charge; 16 hours per charge (Steaming) 3 shifts per day, 300 days per year. Product: 1,800,000 cubic feet per year of Southern pine poles Thousand Units Per Dollars Per Dollars Item Units Unit Cost Cubic Foot Cubic Foot Per Year Raw Materials: Woc d Cubic feet $3.00 1.0 3.00 5,400 Pentachloro— phenol Pounds $0.42 0.5 0.21 378 Total Raw Materials 3.21 5,778 Processihg: Labor, Operating Man hours $6.00 0.173 311 Labor, Maintenance Man hours $6.50 0.048 86 Main ten ance Supplies 0.048 86 Consumable Supplies 0.024 46 Fuel and Power 0.072 132 Plant Overhead 50% of Labor 0.111 199 Taxes and Insurance 4% of Capital 0.048 87 Total Processing 0.524 947 Total Co’st, F.O.B. Plant 3.734 6,725 Source : Arthur D. Little, Inc., estimates based on industry interviews. A- 7 ------- __ DRAFT ESTIMATED OPERATING COSTS FOR THE MANUFACTURE OF PRESERVED WOOD — ORGANIC TREATMENT Cylinder Size: 5 cylinders, each 7’ diameter x 130’ long, 5000 cubic feet Capital Cost: $4,557,000 (1978) Location: South Central - Production: 2000 cubic feet per charge; 1.6 hours per charge (Steaming) 3 shifts per day, 300 days per year. Product: 4,500,000 cubic feet per year of Southern pine poles Thousand Units Per Dollars Per Dollars Item Units Unit Cost Cubic Foot Cubic Foot Per Year Raw Materials: Wood Cubic feet $3.00 1.0 3.00 13,500 Pentachioro— phenol Pounds $0.42 0.5 0.21 945 Total Raw Materials 3.21 14,445 Processing: Labor, Operating Man hours $6.00 0.173 778 Labor, Maintenance Man hours $6.50 0.048 216 Maintenance Supplies 0.048 216 Consumable Supplies 0.024 110 Fuel and Power 0.072 326 Plant Overhead 50% of Labor 0.111 497 Taxes and Insurance 4% of Capital 0.041 182 Total Processing 0.517 2,325 Total Cost, F.O.B. Plant 3.727 16,770 Source : Arthur D. Little, Inc., estimates based on industry interviews. A-8 ------- TABLE A-7 PLANT C-i ESTiMATED OPERATING COSTS FOR THE MANUFACTURE OF PRESERVED WOOD — ORGANIC TREATMENT DRAFT Cylinder Size: Capital Cost: Location: Production: Product: Raw Materials: Wood Pentachioro— phenol Total Raw Materials Processing: Labor, Operating Labor, )la in tenance Maintenance Supplies Consumable Supplies Fuel and Power Plant Overhead Taxes and Insurance Total Processing Total Cost, F.O.B. Plant Source : Arthur D. Little, Inc., estimates based on industry Item Units Per Dollars Per Thousand Dollars Cubic Foot Cubic Foot Per Year 2 cylinders, each 7’ diameter x ].30’long, 5000 cubic feet $2,382,000 (1978) West Coast 2000 cubic feet per charge; 30 hours per charge (Boult0 d) 3 shifts per day, 300 days per year. 960,000 cubic feet per year of Douglas fir poles Units Unit Cost __________ ___________ Cubic feet $3.40 1.0 Pounds $0.42 0.75 ____ Man hours $6.00 Man hours $6.50 50% of Labor 4% of Capital _____ 3.40 3,264 0.32 307 3.72 3,571 0.324 31]. 0.090 86 0.090 86 0.046 46 0.135 132 0.207 199 0.099 95 0.991 955 4.711 4,526 interviews. A-9 ------- TABLE A-8 PLANT C—2 ESTIMATED OPERATING COSTS FOR THE MANUFACTURE OF PRESERVED WOOD — ORGANIC TREATMENT Cylinder Size: 5 cylinders, each 7’ diameter x 130’ long, 5000 cubic feet Capital Cost: $5,013,000 (1978) Location: West Coast Production: 2000 cubic feet per charge; 30 hours per charge (Boultonized) 3 shifts per day, 300 days per year. Product: 2,400,000 cubic feet per year of Douglas fir poles Thousand Units Per Dollars Per Dollars Item Units Unit Cost Cubic Foot Cubic Foot Per Year Raw Materials: Wood Cubic feet $3.40 1.0 3.40 8,160 Pentachioro— phenol Pounds $0.42 0.75 0.32 768 Total Raw Materials 3.72 8,928 Processing: Labor, Operating Man hours $6.00 0.324 778 Labor, Maintenance Man hours $6.50 0.090 216 Maintenance Supplies 0.090 216 Consumable Supplies 0.046 110 Fuel and 326 Power 0.135 Plant Overhead 50% of Labor 0.207 497 Taxes and Insurance 4% of Capital 0.084 200 Total Processing 0.976 2,343 Total Coit, 4.696 11,271 F.0.B. Plant Source : Arthur D. Little, Inc., estimates based on industry interviews. A-l0 ------- TABLE A—9 PLANT D-l ESTIMATED OPERATING COSTS FOR THE MANUFACTURE OF PRESERVED WOOD - ORGANIC TREATMENT Cylinder Size: 2 cylinders, each 7’ diameter x 130’ long, 5000 cubic feet Capital Cost: $2,165,000 (1978) Location: South Central Production: 2000 cubic feet per charge; 16 hours per charge (Steaming) 3 shifts per day, 300 days per year. Product: 1,800,000 cubic feet per year of Southern pine lumber Thousand Units Per Dollars Per Dollars Item Units Unit Cost Cubic Foot Cubic Foot Per Year Raw Materials: Wogd Cubic feet $3.60 1.0 3.60 6,480 CCA Pounds $1.00 0.33 0.33 594 Total Raw Materials 393 7,074 Processing: Labor, Operating Man hours $6.00 0.173 311 Labor, Maintenance Man hours $6.50 0.048 86 Maintenance Supplies 0.048 86 Consumable Supplies 0.024 46 Fuel and Power 0.072 132 Plant Overhead 50% of Labor 0.111 199 Taxes and Insurance 4% of Capital 0.048 Total Processing 0.524 947 Total Cost, F.O.B. Plant 4.454 8,021 Source : Arthur D. Little, Inc., estimates based on industry interviews. A-li ------- ___ DRAFT ESTIMATED OPERATING COSTS FOR THE MANUFACTURE OF PRESERVED WOOD — ORGANIC TREATNENT Cylinder Size: 5 cylinders, each 7’ diameter x 130’ long, 5000 cubic feet Capital Cost: $4,557,000 (1978) Location: South Central Production: 2000 cubic feet per charge; 16 hours per charge (Steaming) 3 shifts per day, 300 days per year. Product: 4,500,000 cubic feet per year of Southern pine lumber Thousand Units Per Dollars Per Dollars Item Units Unit Cost Cubic Foot Cubic Foot Per Year Raw Materials: Wood Cubic feet $3.60 1.0 3.60 16,200 CCA Pounds $1.00 0.33 0.33 1,485 Total Raw a . J .7J LI , Materials Processi g: Labor, Operating Man hours $6.00 0.173 778 Labor, Maintenance Man hours $6.50 0.048 216 Maintenance Supplies 0.048 216 Consumable Supplies 0.024 110 Fuel and Power 0.072 326 Plant Overhead 50% of Labor 0.111 497 Taxes and Insurance 4% of Capital 0.040 182 Total Processing 0.516 2,325 Total Cost, F.0.B. Plant 4.446 20,010 Source : Arthur D. Little, Inc., estimates based on industry interviews. ------- DRAFT A—3 CHARACTERISTICS OF IMPACTED AND NON-IMPACTED PLA}iTS (Supplement to Chapter IV) The impacted plants were compared with the balance of the industry in several areas important to determining the Impact of the alternatives on the industry. TableA—il depicts the distribution of wood preserving plants by sales level, type of preservative, and current water effluent status. As described in Chapter III, direct discharge plants predominantly use organic preservatives. Additionally, they are larger, with 55% of the direct discharge plants in the highest sales category compared with 14% of the “no discharge” plants in the organic category. Indirect discharge plants in the organic category also tend to have a higher sales volume than the average “no discharge” plant in the industry ($3.8 million versus $2.1 million). A-13 ------- LABLE A-li SALES LEVEL MID PRESERVATiVE CATEGORY DRAFT BY CURRENT WATER EFFLUENT STATUS Indirect Dis charge II No Discharge/ Other Total II ¼ Direct Discharge II ¼ 6 54% 1 10 2 18 2 18 11 100% 1 5 4 11 17 38 3% 13 10 29 45 100% Sales ($000) ORGAN IC* Under $300 $30 1—$ 1, 200 51,201—52 ,400 $2 ,401—$4 ,800 Over $4,800 TOTAL INORGAN IC Under $300 $301—Si, 200 $1, 201—52,400 $2, 401—$4 ,800 Over $4,800 TOTAL TOTAL Under $300 5301—51,200 $1,201—$2 ,400 $2,401—$4 ,800 Over $4,800 —— —— 3 75% —— — — 1 25 —- —— 4 100% 1! 42 58 26 31 27 184 20 23 9 4 3 59 62 81 35 35 30 243 23% 32 14 17 14 100% 34% 39 15 7 5 100% 26% 33 14 14 13 100% 43 69 31 44 46 233 23 23 10 4 3 63 66 92 41 48 49 296 18% 29 13 19 21 100% 36 36 16 6 6 100% 22 31 14 17 16 100% 6 1 2 2 11 54% 10 18 18 100% 4 10% 5 12 5 12 11 26 17 40 42 100% TOTAL *piaflt3 classified according to predominant category of preservative used. NOTE: Totals in this and following tables may not add to number of responses (337) as some respondents did not answer every question. This table includes three plants as “DISCHARGING PLANTS” which the EPA has learned are “No Discharge” plants. SOURC: EPA Financial 308 Letter. A- 14 ------- DRAFT Table A—i2 contains the distribution of wood preserving plants by pro- fitability and discharge status. Indirect dischargers’ profit before tax is comparable to the “no discharge” group. Direct discharge and Boulton plants, though few in number, are less profitable than all plants in their industry and other plants at comparable sales levels. A lower cash flow than average is generally associated with lower profitability. Analysis of historic data 1 and other reports on the wood preserving industry 2 led to the conclusion that poles are a declining product. Table A—].3 contains the distribution of direct and indirect discharge plants by the portion of their sales derived from treating poles. Seven- teen plants that will be impacted by the BAT alternatives derive under 30% of their sales from poles while 6 plants have between 30 and 70% of their sales derived from poles. Twenty impacted plants derive over 70% of their sales from poles. Since the name and location of respondents to the Environmental Protection Agency Financial 308 Letter were unknown in this analysis, the plant loca- tions cannot be directly ascertained. Therefore, the origin of the pre- dominant portion of wood treated has been used as a proxy for location. As seen in TableA—14, wood origin for discharging plants is distributed similarly to that for “no discharge” plants and it is dispersed over all regions. ‘Reference 2 2 Reference 3,4 A-15 ------- TABLE A—12 PROFIT BEFORE TAX BY CURRENT WATER EFFLUENT STATUS 1976 Profit Before steaming Tax as a Percent Direct Indirect Boulton No Discharge Total** ofSales % % % II % II Under 1% 4 58% 4 15% 3 43% 64 28% 76 28% = : :: :: : 9% — 12% 8 31 34 15 45 16 Over 12% 2 8 30 13 33 12 TOTAL 7 100% 26 100% 7 100% 229 100% 273 100% 4 Not broken out to prevent disclosure of confidential information. *Inc].udes five inorganic plants currently not in compliance with BPT. SOURCE: Derived by Arthur D. Little, Inc., from Environmental Protection Agency Financial D 308 Letter. -n -I ------- DRAFT TABLE A-l3 PORTION OF TOTAL SALES CONTRIBUTED BY POLES AND PILINGS IN PLANTS USING ORGANIC PRESERVATIVES* Discharging No Discharge % of Sales in Plants Plants Total Poles 6 Pilings % I JL _L Under 30% 17 39% 36 32% 53 34% 31—70% 6 14 30 27 36 24 Over 70% 20 47 45 41 65 42 Total Respondents 43 100% 111 100% 154 100% *None of the impacted plants in the inorganic category derived more than 30% of their sales from poles. SOURCE: Derived by Arthur D. Little, Inc., from Environmental Protection Agency Financial 308 Letter. A-17 ------- DRAFT TABLE A-14 WOOD ORIGIN BY CURRENT WATER EFFLUENT STATUS Impacted Plants Total I! % __ __ Northeast 1 2 15 4% Northwest 8 15 65 20 Southeast 31 57 146 45 Southwest 7 13 39 12 Midwest 4 7 40 12 Other 4 6 24 7 TOTAL 55 100% 330 100% SOURCE: Derived by Arthur D. Little, Inc., from Environmental Protection Agency Financial 308 Letter data. A-18 ------- APPENDIX B RESPONSES TO EPA FINANCIAL 308 SURVEY DRAFT ------- DRAFT RESPONSES TO EPA FINANCIAL 308 SURVEY * 1/ 70 Total Mailed 601 —— Total Responses 451 less duplicates 27 —— Net Responses 424 87.1% Total Applicable Responses 337 69.2% Total Non—Applicable Responses 87 —— No Answer 150 30.8% *Based on sum of “Total Applicable” and “No Answers” (487) Source: Arthur D. Little, Inc., analysis. B—i ------- APPENDIX C REFERENCES DRAFT ------- DRAFT REFERENCES 1. Revised Technical Review of Best Available Technology, Best Demon- strated Technology and Best Demonstrated Technology and Pretreatment Technology for the Timber Products Point Source Category , report to the Environmental Protection Agency, Project No. 78—052, September 1, 1978. 2. Annual Survey of Manufactures , U.S. Department of Commerce, various years. 3. The Analysis of Existing Wood Preserving Techniques and Possible Substitutes , report to the U.S. Environmental Protection Agency, Contract No. 68—01—4310, The MITRE Corporation, June 1977. 4. Wood Preservation Statistics , 1976, Ernst and Ernst. 5. Trend Impact Analysis Study of the Wood Preserving Market , Dow Marketing Research Reports, February 1976. 6. Economic Impact of Section 3004 of the RCRA upon Hazardous Waste Management Facilities , draft report to the U.S. Environmental Protection Agency, Office of Solid Waste, March 1978. 7. Subpart D, Standards for Owners and Operators of Treatment, Storage, and Disposal Facilities, Resource Conservation and Recovery Act , draft regulations, U.S. Environmental Protection Agency, Hazardous Waste Management Division, September 1978. C—i ------- APPENDIX D EPA FINANCIAL 308 SURVEY DRAFT ------- DRAFT 308 QUESTIONNAIRE WOOD PRESERVING Company Code #______________ (for EPA use) NOTE: Upon receipt by EPA, this page will be separated from the remainder of the questionnaire so that data processing and use of the data is conducted on a coded basis by its contractor. i. Name of Plant ii. Plant Site Address Street City State Zip iii. Name of Respondent* iv. Address of Respondent Street City State Zip v Telephone of Respondent vi. Parent Company vu. Total number of wood treating wood plants owned by parent viii. Is this plant engaged in treating wood products? Yes 0 Continue with Questionnaire No 0 Do not fIll out the questionnaire but return after completing this page, through Question viii with a cover letter describing the nature of your business. ix. To assert your claim of confidentiality, please check off the box corresponding to the questions, which, in the company’s opinion, require confidential treatment. 10 50 100 140 180 220 260 20 70 lID 150 190 230 3 0 80 12 0 16 0 20 0 24 0 4 0 90 13 0 17 0 21 0 25 0 *Person to be contacted in case of questions. D- 1 ------- DRAFT 308 QUESTIONNAIRE WOOD PRESERVING Company Code ______________________ (for EPA use) A. GENERAL INFORMATION 1. What is the form of business organization of this plant? Proprietorship or Partnership 0 Co-op 0 Privately-held Corporation D Publically-held Corporation 0 2. Is this wood treating plant a stand-alone operation or part of a multi-plant complex at this location? Stand-alone 0 Multi-plant complex 0 3. Approximately what percent of total sales at this complex or plant was from wood treating inFY l976? ____% 4. Is this plant at an urban, suburban, or rural location? Urban 0 Suburban 0 Rural 0 5. What year did the wood treating plant begin operation? D— 2 ------- DRAFT B. EFFLUENT INFORMATION 6. How does this plant dispose of liquid process waste’ a. Discharge into navigable water £3 b. Discharge into municipal sewer 0 c. Disposed on plant site 0 d. Disposed off plant site 0 e Process waste is recycled (no discharge) £3 f. This plant does not generate liquid process waste 0 g. Other 0 Please specify IF THE ANSWER TO QUESTION 6 IS (c), (d), (e), OR(f), YOU MAY OMIT ANSWERS TO THE FOLLOWING QUESTIONS 7,10,20, 21b, 22,25 7.a If you do not discharge liquid process waste into a municipal sewer, do you have the option to connect Yes 0 No 0 Don’t Know 0 b. If you do have the option to connect to a municipal sewer, what is the initial capital mvestment cost 1 $ ___________________ Don’t Know 0 c. If you discharge any wood treating process waste into a sewer system, on what basis are your sewer charges made? Flat annual fee 0 Gallon of effluent 0 Other 0 Please Specify d. If you discharge into a municipal sewer, what were your total sewer charges in 1976? $ _________ e If you discharge liquid process waste into navigable waters, do you have an NPDES permit? Yes 0 No 0 Don’t Know £3 f. Do you own or have available for purchase about one acre of land at or adjacent to this facility that could be used for an effluent treatment system? YesD NoD If yes, what is the current market value per acre? $ ______________ C. SALES AND PRODUCT MIX 8. Fiscal year 1976 wood treating plant sales (thousands of dollars). Under 70 0 301-700 0 1,801-2,400 0 4,801-7,200 0 71-155 0 701-1,200 0 2,401-3,200 0 7,201-11,500 0 156-300 0 1,201-1,800 0 3,201-4,800 D More than 11,500 0 D- 3 ------- DRAFT 9. Which of the following product types are treated at this plant Treated As a percent of Plant Sales Treated Wood Products at Plant Under 10 11-30 31-50 51-70 71-90 Over 90 a. Orgamc (Oil or Dual Oil and Salt Treatment) (1) Railroad Ties 0 0 0 0 0 0 0 (2) Pilings, Poles 0 0 0 0 0 0 0 (3) Timber, Lumber, andOther 0 0 0 0 0 0 D b. Inorganic (Salt Based) (1) Pilings, Poles 0 0 0 0 0 0 0 (2) Timber, Lumber, andOther D 0 0 0 0 0 0 10 a. Are any changes (other than normal business fluctuations) planned in production process or product mix? Yes 0 No 0 (If No, Go to Part D) b. Process change towards More Organic 0 More Inorganic 0 Less Organic 0 Less Inorganic 0 c. Product Mix Change More Ties 0 More Poles 0 More Other 0 Less Ties 0 Less Poles 0 Less Other 0 d. Other, please specify nature of change D. PLANT CAPACITY AND PRODUCTION 11. What is your peak design capacity (or peak capacity as modified)? ______________________ cu. ft. Cubic Feet/24 hour periodt 12.a. What region of the country is the origin of most of the wood treated at this facility? Northeast 0 Southeast 0 Midwest 0 Northwest 0 Southwest 0 Other 0 b. Is the wood mostly: Hardwood 0 or Softwood 0 1f unable to calculate peak (design) capacity by the formula shown in “DEFINITIONS” attach a separate sheet describing the radius and length of each cylinder. D-4 ------- DRAFT 13 Typical number of production days per 1-40 50 60 70 14. Number of weeks at each shift level (total should add to 52 weeks): No. of Weeks a. ________________ at 0 shifts (shut down or no wood preserving) b. ________________ at I shift c. ____________________ at 2 shifts d. _________________ at 3 shifts e. __________________ at 4 shifts 52 Weeks TOTAL OF (a)+(b)+(c)+(d)+(e) 15. 1976 Production (Thousands of cubic feet) 16. Typical number of production workers in 1976: 1-3 0 7-9 0 20.34 0 49-75 D 100-125 0 4-6 0 10-19 0 35-48 0 76-99 0 Over 125 0 17. This facility is primanly engaged in (a) treating service only (TSO), and or (b) treating owned wood products for sale to others Approximate Percent of Sales Under 10 10-25 26-50 51-75 Over 75 a. Treating Service Only 0 0 0 0 0 b. Treating Owned Wood Products 0 0 0 0 0 18. What proportion of owned wood is from company-owned timberland? Approximate Percent of Owned Wood Supply None 1-24 2549 50-74 75.100 0 0 0 0 0 D-5 ------- DRAFT E. FINANCIAL STATEMENT 19. Revenue and Expenses Check the box for each item which most closely approximates your 1976 fiscal year expenses as a percent of sales. Cost as a Percent of Plant Sales Under 10- 16- 22- 29- 39- 49- Over 10 15 21 28 38 48 60 60 a.WoodCost 0 0 0 0 0 0 0 0 b. Other Materials Cost 0 0 0 0 0 0 0 0 c.PayrollCost 0 0 0 0 0 0 0 0 Under 1 1-2 3-5 6-8 Over 8 d. Depreciation 0 0 0 0 0 Under 10 11-15 16-25 26-30 Over 30 e.GrossMargin 0 0 0 0 0 Under 1 1-5 6-10 11-15 Over 15 f. General andAdministrative Cost 0 0 0 0 0 Under 1 1-4 5-8 9-12 Over 12 g. Interest Expense 0 0 0 0 0 Under 1 1-4 5-8 9-12 Over 12 h. Profit Before Tax 0 D 0 0 0 Under 1 1-2 3-4 5-7 Over 7 i. Profit After Tax 0 0 0 0 0 20. How representative was this plant’s 1976 profit before tax experience versus the average for 1971-1975? About the same 0 Better than Average 0 Worse than Average 0 D-6 ------- DRAFT 21. Factors related to Revenues and Expenses a. Fixed Costs: If the plant faces lease, rental or mortgage commitments beyond 1976, (for build- ings or equipment), indicate the average annual charges and the year the commitments expire. Leases! Wood Debt Rental 0 Contracts 0 Payment 0 Other* 0 (1) Average AnnualCharge: $_________ $__________ $__________ $___________ (2) Commitment Expires: 19 19 19 19 (if other commitments attach separate sheet) b. What Depreciation Method is Used: Equipment Buildings (1) Book Basis: Straight-Line 0 0 Double-Declining Balance 0 0 Sum of Year’s Digits 0 0 Other 0 0 (Please Specify) (2) Tax Basis: Straight Line 0 0 Double-Declining Balance 0 0 Sum of Year’s Digits 0 0 Other: 0 0 (Please Specify) (3) Pollution Control Equipment Amortization: Accelerated Over 5 Years 0 Same method as other equipment 0 22. Unusual Production Costs Are there any circumstances peculiar to this plant which result in unusual production costs? Yes 0 NoD If Yes, please descnbe: D-7 ------- DRAFT 23. Historical/Annual Cost of Pollution Control and Other Environmental Regulations: Don’t Know None Fiscal Year Ending 1975 1976 (1) Water Pollution Regulations: (a) Annual Operating Costs 0 0 $_________ $ (b) Annual Depreciation Charges 0 0 $_________ $_________ (2) Solid Waste Disposal (including waste water sludge and wood waste, con- tract hauling): (a) Annual Operating Costs 0 0 $_________ $ _________ (b) Annual Depreciation Charges 0 0 $ _________ $ _________ (3) Other Environmental Regulations Air OSHA Affecting Production Processes and Production Costs 0 0 (Please Specify) (a) Annual Operating Costs 0 0 $ _________ $ _________ (b) Annual Depreciation Charges 0 0 $ __________ $ _________ (4) Other Administrative Costs: Environmental department, research, litigation, consultants, additional administrative costs. 0 0 S _________ $ __________ 24. Value of wood treating plant Assets and Liabilities (as of the end of the most recent fiscal year). a. Net Fixed Assets (Gross Fixed Assets less cumulative depreciation) $ _______________ Don’t Know 0 b. Total Assets: (Net Fixed Assets, Cash receivables, inventory, other assets) $ _________________ Don’t Know 0 c. What was the value of this wood treating plant’s accounts receivable? $ d. What was the value of this wood treating plant’s accounts payable? $ e. Current Plant Debt (i.e., debt maturing in current year or payable on demand). $ 1. Long-Term Plant Debt (debt maturing beyond the current year (1977]) $ g. Total Plant Liabilities (long-term debt, accounts payable, deferred taxes, other debt, etc.) $ D-8 ------- DRAFT 25. Capital Investment Criteria for the Plant a. What investment criteria do you use? Return on Investment (ROl) 0 Pay back 0 Discounted Cash Flow 0 Other 0 b. If you use return on investment criteria: (1) What is the target internal pre-tax rate of return on capital required for investment in this plant? (2) At what RO! would you consider plant shutdown? ______________________________ c. If you use pay back period criteria, what is the required payback period for investment? years d. What is the current long term interest rate you must pay for new capital? percent per year 26. Capital Investment for the Plant (not including capitalized operating or maintenance expenses). (1) (2) (3) Other Environmental Total Capital Water Pollution Regulation (State or Federal) Investment Control Impacting Production Processes (Actual) 197 1-76 S _________ S _________ $ __________ (Planned) 1977 $ _________ S _________ $ _________ D—9 ------- STRAIGHT TABULATION OF WOOD PRESERVING INDUSTRY RESPONSES DRAFT A. GENERAL INFORMATION 1. What is the form of business organization of this plant? Number Percent 31 9.28 1 .30 230 68.86 72 21.56 334 100.00 operation or part of Proprietorship or Partnership Co—op Privately—held Corporation Publically—held Corporation _____ Total 2. Is this wood treating plant a stand—alone a multi—plant complex at this location? Number 268 67 335 Stand—alone Multi—plant complex Total Percent 80.00 20.00 100.00 D—1O ------- DRAFT 3. Approximately what percent of total sales at this complex or plant was from wood treating In FY 1976? 0 1—9 1O— 9Z 20—29 30—3 41 —4 I I I I I I 11 211 101 51 61 5 £ 3.2971 6.2311 2.967! 1.4841 1.7ROT I.4b4 I I I I I 1 21 10 5 6 5 0.297 6.231 2.967 1.484 1.78J 1.4 34 6O—69 70—7° t d0—R9 90—99 £ I 1 I I I 1 171 21 151 221 581 number I i.J451 0.5931 4.etS II 6. 28I 17.2111 percentage I I I I I I 17 15 22 number 5.J4t 0.593 4.451 6.528 17.211 percentage Na ROW 10O ANSWER SUMS I I I I I5 I 201 337 I 45.1941 5.9351 100.000 I I I 155 20 337 45.994 5.935 100.000 D-11 ------- DRAFT 4. Is this plant at an urban, suburban, or rural location? Number Percent Urban 98 29.38 Suburban 85 25.22 Rural 153 45.40 Total 336 100.00 5. What year did the wood treating plant begin operation? t FUR t 1930 i931—1940 1941—1950 L951—1’ 60 I I 1 1 I 1 581 131 461 831 number 1 17.4561 3.8461 13.o09 1 24.5561 percentage I I I I I 59 11 46 17.45o 3.8’,6 13. 09 24.556 NO R0.4 1961—1970 1971—1977 OTHER ANSWER SUMS I I I I 761 561 I .1 337 number 22.4851 16.5681 I 1.4791 100.000 percentage I I I I 76 56 5 337 number 22.485 i6.56R 1.479 100.000 percentage D- 12 ------- DRAFT B. EFFLUENT INFOBMATION 6. How does this plant dispose of liquid process waste? Number Percent Direct discharge 10 2.9 Indirect—steaming 30 7.8 Indirect—Boulton 10 2.7 Disposed on plant site 98 26.2 Disposed off plant site 18 4.8 No discharge (recycled) 126 33.8 No liquid waste 60 16.1 Inorganic 5 1.3 Other 7 1.9 No entry 9 2.4 Total 337 100.0 IF THE ANSWER TO QUESTION 6 is (c), (d), (e) OR (f), YOU MAY OMIT ANSWERS TO THE FOLLOWING QUESTIONS: 7, 10, 20, 2lb, 22, 25 7.(a) If you do not discharge liquid process waste into a municipal sewer, do you have the option to connect? Number Percent Yes 2 6.67 No 19 63.33 Don’t Know 9 30.00 Total 30 100.00 D-13 ------- DRAFT 7 (b) If you do have the option to connect to a municipal sewer, what is the initial capital investment cost? 5,00J— 10,000— 15,000— 0,000- 0—5,000 10,000 15,000 20,000 25,000 I I I I I I I I 1 1 I I I number I I 0.296 1 I I percentage 0.2 6 25 ,00 J- 30,000— 35,000— 40,000— 45,000— ) jfl,0J0 35,000 ‘tO, 000 45,J00 50,000 50 ,000 I I I I I I I I 1 1 1 I number I I I I I I percentage I I I I I I NO ROW DONT N0W ANSWER SUMS I I I I I II 3251 337 number I 3.2541 96.4 0L 100.000 percentage I I I 11 325 337 number 3.254 96.450 100.000 percentage 7.(c) If you discharge any wood treating process waste into a sewer system, on what basis are your sewer charges made? Number Percent Flat annual fee 7 17.07 Gallon of effluent 21 51.22 Other 13 31.71 Total 41 100.00 D- 14 ------- DRAFT 7. (d.) If you discharge into a municipal sewer, what were your total sewer charges In 1976? $___________ 7.(e) If you discharge liquid process waste into navigable waters, do you have an NPDES permit? Number Percent Yes 10 62.50 No 4 25.00 Don’t Know 2 12.50 Total 16 100.00 D- 15 ------- DRAFT 7• (f)DO you own or have available for purchase about one acre of land at or adjacent to this facility that could be used for an effluent treatment system? 500— I,00 )— J,5C0— 2,000— 0—500 1,000 1.,50 0 2,00 ?,50 0 I I 1 I I I— I 21 11 21 21 21 number I 0.592 1 0.2 6I 0.5 2I 0.5’ 2I .59 T percentage i I I I I I— 2 1 2 2 2 number 0.592 0.296 0.59? 3.5 2 percentage ,5Cu— 3,000— 3,5( 0— 4,030— 4,5 0U— > ,0fl’j 1, 0C . ,, 000 4,500 5,000 5,000 • I I I 1 I I i I I 1 2 1 2 1 12 I number I 1 0.5921 0.c921 3.8461 percentage • 1 I I I I I 3 2 2 13 number 0.592 0.592 3.846 percentage NO R0i O LAND A ’:SWER SUMS I I I 1 321 2771 337 number I .467I 31.953I 10U.0OL percentage I I 1 3 277 337 number 9..,67 ioo.ooo percentage D- 16 ------- DRAFT C. SALES AND PRODUCT MIX 8. Fiscal year 1976 wood treating plant sales (thousands of dollars). Number Percent Under 70 25 7.86 71 — 155 25 7.86 156 — 300 29 9.12 301 — 700 48 15.09 701 — 1,200 50 15.72 1,200 — 1,800 21 6.60 1,801 — 2,400 21 6.60 2,401 — 3,200 26 8.18 3,201 — 4,800 24 7.55 4,801 — 7,200 30 9.43 7,201 — 11,500 13 4.09 More than 11,500 6 1.89 Total 318 100.00 9. Which of the following product types are treated at this plant: a. Organic (Oil or Dual Oil and Salt Treatment) (1) Railroad Ties Number Percent Under 10 35 34.65 11 — 30 19 18.81 31—50 7 6.93 51 — 70 10 9.90 71 — 90 10 9.90 Over 90 20 19.80 Total 101 100.00’ D- 17 ------- DRAFT (2) Pilings. Poles Number Percent Under 10 23 15.43 11 — 30 30 20.13 31 — 50 21 14.10 51 — 70 15 10.07 71 — 90 25 16.78 Over 90 35 23.49 Total 149 100.00 (3) Timber, Lumber, and Other Number Percent Under 10 64 30.77 11 — 30 48 23.07 31 — 50 33 15.86 51 — 70 14 6.73 71 — 90 19 9.13 Over 90 30 14.42 Total 208 100.00 9b. Inorganic (Salt Based) (1) Pilings, Poles Number Percent Under 10 33 70.21 11 — 30 11 23.40 31—50 0 .00 51—70 0 .00 71—90 1 2.13 Over 90 2 4.25 Total 47 100.00 (2) Timber Lumber, and Other Number Percent Under 10 13 9.92 11 — 30 26 19.85 31 — 50 13 9.92 51—70 6 4.58 71 — 90 14 10.68 Over 90 _ji 15.04 Total 131 100.00 D—18 ------- DRAFT Number Percent 9c. Other 1 100.00 lOa. Are any changes (other than normal business fluctuations) planned in production process or product mix? Number Percent Yes 11 8.21 No 123 91.79 Total 134 100.00 lOb. Process changes towards: Number Percent More Organic 1 10.00 Less Organic 6 60.00 More Inorganic 3 30.00 Less Inorganic 0 . 00 Total 10 100.00 lOc. Product Mix Change Number Percent More Ties 2 33.33 Less Ties 0 .00 More Poles 0 .00 Less Poles 0 .00 More Other 4 66.67 Less Other 0 . 00 Total 6 100.00 D—19 ------- DRAFT D. PLANT CAPACITY AND PRODUCTION 12a. What region of the country is the origin of most of the wook treated at this facility? Number Percent Northeast 15 4.55 Northwest 65 19.75 Southeast 146 44.37 Southwest 39 11.85 Midwest 40 12.16 Other 7.29 Total 329 100.00 12b. Is the wood mostly: Number Percent Hardwood 62 18.84 Softwood 267 81.16 Total 329 100.00 13. Typical number of production days per week? Number Percent 1 — 4 days 32 9.79 5 days 252 77.06 6 days 26 7.95 7 days 17 5.20 Total 327 100.00 D— 20 ------- DRAFT 14. Nrlber of weeks at each shift level (total should add to 52 weeks): at 0 shifts (shut down or no wood preserving) 0—9 10—19 20—29 30—39 I I I I I 1 2811 121 10! 6! number 1 83.1361 3.5501 2.959! 1.7751 percentage I I I I I 281 12 10 6 number 83.136 3.5 0 2.959 1.775 percentage POUR ROW 50—62 DATA SUMS I I I 11 11 271 338 number o.29 6r 0.2961 7.9831 100.000 percentage I I I 1 1 27 338 number 0. 96 0.296 7.988 ioo.ooo percentage D—2 1 ------- DRAFT 14. Number of weeks at each shift level (total should add to 52 weeks): (cont) at 1 shift 0—9 10—19 2U—29 I I I I I 9b1 101 111 number I 30.8681 3.215! 5.46b1 percentage I i r 9 i 10 17 number 30.868 3.215 5.46o percentage 3O—3 1 40—49 5Q—S SUMS I I I 161 191 1531 311 number 5.1451 .109T 49.1 161 100.000 percentage i I I 16 19 153 311 number 5.145 6.109 49.196 103.300 percentage D-2 2 ------- DRAFT 14. Number of weeks at each shift level (total should add to 52 weeks): (cont) at 2 shifts 0—9 10—19 2u—29 I I I I I 2611 1.91 8! number I 83.9231 6.109 1 2.5721 percentage I I I I 261 1.9 d number 83.923 6.109 2.572 percentage 30—3 40—’t 9 50—52 SLiMS I I I 5! ‘tI 141 311 number 1.6uRI 1.28b 1 4.5021 IflO.000 percentage ——1 I I 5 14 311 number 1.608 1.286 4.502 100.000 percentage D—23 ------- DRAFT 14. Number of weeks at each shift level (total should add to 52 weeks): (cont) at 3 shIfts 0—9 10—19 20-29 I I I I I 2311 41 number I 74.2771 1. 6I 1.60 5I percentage I I I I 231 4 5 number 74.277 l.2d6 t.ooa percentage ROW 30—39 40—49 50—52 SUMS I I I 51 71 591 311 number 1.6381 2.2511 L .97lI 1 0.000 percentage I I I 5 7 311 number 1.608 2.251 1 8. 7 l ioo.ooo percentage D-24 ------- DRAFT 14. Number of weeks at each shift level (total should add to 52 weeks): (cOnt) at 4 shIfts 0—9 10—19 20—29 I I I I. I 3071 21 I number I 98 .l1’sI O.6’i31 1 percentage I I I 1 307 2 number 9d.714 0.643 percentage R 0 30—39 40—49 50—52 SUMS I I I I 1 21 311 number I I 0.6 t3I ir,o.000 percentage — I I I 2 311 number (1.6t3 ioo.ooo percentage D—2 5 ------- DRAFT 15. 1976 Production (Thousands of cubic feet). 250 ,000— 0 250,00C 00,0O0 I I I I I i oi s i number 1 1 35.61 1 16.6171 percentage I i £ I 12C 56 number .35.61 16.617 percentage 50U.U00- 750,J03— > NO 750,030 1, 0J.000 i.uOO,000 ANSWER I I I I 301 171 5 I 551 number R.902 1 .044I 17.7511 16.3201 percentage I I I I 30 number e.9o2 5.044 17.751 16.320 percentage RJW SUMS I I 337 number I 100.030 percentage I 337 number ioo.ooo percentage D-26 ------- LJKAFT 16. Typical number of production workers in 1976: Number Percent 1—3 73 22.32 4—6 39 11.93 7—9 26 7.95 10 — 19 56 17.12 20 — 34 55 16.92 35 — 48 27 8.26 49 — 75 35 10.70 76—99 8 2.45 100 — 125 6 1.83 Over 125 2 . 61 Total 327 100.00 17. This facility is primarily engaged in (a) treating service only (TSO), and/or (b) treating owned wood products for sale to others: a. Treating Service Only Number Percent Under 10 134 52.55 10 — 25 49 19.22 26 — 50 30 11.76 51 — 75 14 5.49 Over 75 28 10.98 Total 256 100.00 b. Treating Owned Wood Number Percent Products Under 10 21 6.80 10 — 25 20 6.47 26 — 50 17 5.50 51 — 75 39 12.12 Over 75 212 68.61 Total 309 100.00 D- 27 ------- DRAFT 18. What proportion of owned wood is from company—owned timberland? Number Percent None 256 77.81 1 — 24 59 17.93 25—49 3 .91 50—74 2 .61 75 — 100 9 2.74 Total 329 100.00 E. FINANCIAL STATEMENT 19. Revenue and Expenses a. Wood Cost Number Percent Under 10 17 5.67 10 — 15 10 3.34 16 — 21 10 3.34 22 — 28 15 5.02 29 — 38 49 16.39 39 — 48 59 19.73 49 — 60 69 23.08 Over 60 70 23.41 Total 299 100.00 b. Other Materials Cost Number Percent Under 10 65 21.60 10 — 15 74 24.50 16 — 21 72 23.92 22 — 28 44 14.62 29 — 38 27 8.97 39 — 48 13 4.32 49—60 1 .33 Over 60 5 1.66 Total 301 100.00 D-28 ------- DRAFT c. Payroll Cost Number Percent Under 10 103 33.66 10 — 15 102 33.23 16 — 21 45 14.71 22 — 28 36 11.76 29 — 38 13 4.24 39—48 4 1.30 49—60 1 .33 Over 60 2 . 65 Total 306 100.00 d. Depreciation Number Percent Under 10 59 19.22 10 — 15 117 38.11 16 — 21 85 27.69 22 — 28 26 8.47 29 — 38 20 6.51 39—48 o .00 49—60 o .00 Over 60 o . 00 Total 307 100.00 e. Gross Margin Number- Percent Under 10 102 33.33 10 — 15 53 17.32 16 — 21 87 28.43 22 — 28 27 8.82 29 — 38 37 12.09 39—48 0 .00 49—60 0 .00 Over 60 0 . 00 Total 306 100.00 D—2 9 ------- DRAFT f. General and Administrative Number Percent Cost Under 10 18 6.10 10 — 15 88 29.83 16 — 21 31.52 22 — 28 48 16.27 29 — 38 48 16.27 39—48 0 .00 49—60 0 .00 Over 60 0 . 00 Total 295 100.00 g. Interest Expense Number Percent Under 10 171 59.37 10 — 15 84 29.01 16 — 21 24 8.33 22 — 28 5 1.73 29—38 4 1.38 39—48 0 .00 49—60 0 .00 Over 60 0 . 00 Total 288 100.00 h. Profit Before Taxes Number Percent Under 10 68 23.53 10 — 15 83 28.72 16 — 21 61 21.11 22 — 28 46 15.92 29 — 38 31 10.73 39—48 0 .00 49—60 0 .00 Over 60 0 . 00 Total 289 100.00 D- 30 ------- DRAFT 1. Profit After Tax Number Percent Under 10 76 27.84 10 — 15 63 23.08 16 — 21 56 20.51 22 — 28 45 16.42 29 — 38 33 12.04 39—48 0 .00 49—60 0 .00 Over 60 0 . 00 Total 273 100.00 20. How representative was this plant’s 1976 profit before tax experience versus the average for 1971—1975? Number Percent About the Same 70 40.69 Better than Average 36 20.93 Worse than Average 66 Total 172 100.00 D- 31 ------- 21. Factors related to Revenues and Expenses DRAFT a. Fixed Costs: If the plant faces lease, rental or mortgage commit- ments beyond 1976, (for buildings or equipment), indicate the average annual charges and the year the commitments expire. (1) Average Annual Charge: $ Leases/Rental 25,000— 50,000— 0 25,000 50,000 75,000 I I 1 I I 2471 oRI 101 41 11 73.3771 20.11 I 2.9 ,1 1.1831 U.29 I 1 I I I I— 247 66 10 4 1 73.077 20. IIR 2.959 1.1d3 J.2 9 o I0f ,000— 1?5,000— 150,000— 175,000— 200,000— 225,000— 125,000 150,000 175,000 200,000 225,000 250,000 • I I I I I I 31 2! 31 I I I 0.8e3RI 0.592! 0.88R1 I I I 1 T I I I I 3 0.888 > 250,000 I I I I I I I RUW S U 11 S 335 number 100.0i O percentage 33P number 100.000 percentage I I 1——— 75 ,00’ — 100,000 I- number percentage number percentage 3 0.888 2 0.592 number percentage number percentage D-3 2 ------- DRAFT 21. Factors related to Revenues and Expenses (cont) a. Fixed Costs: If the plant faces lease, rental or mortgage commit- ments beyond 1976, (for buildings or equipment), indicate the average annual charges and the year the commitments expire. Wood Contracts (1) Average Annual Charge; ____________ 2S,’ltJ O— SO,OOJ— 0 25,Ou0 5tJ, 00u 7c,030 l00,00 ) I I I I I I 1 3251 51 IT 1 31 number I 9 .1541 1.4791 J .c Q 6 J I O.o8 T percentage I I i 325 1 3 number 96.15 1.479 0.2ge o.a a percentage 130,000— I?5,30J— 150,000— 175,000— 200,000— 2?5,000— l ,0u0 1 0,303 175,000 200,000 225,000 250,003 I I I I I I £ 11 31 1 1 1 number I 0. 961 fl.88P 1 I I I percentage I I I I I I 1 number 0.296 0.888 percentage 250,000 SU 1S I I I I 338 number I I 100.000 percentage I I 338 number 100.000 percentage D-3 3 ------- DRAFT 21. Factors related to Revenues and Expenses (cont) a. Fixed Costs: If the plant faces lease, rental or mortage commit- ments beyond 1976, (for buildings or equipment), indicate the average annual charges and the year the commitments expire. Debt Payment (1) Average Annual Charge: $__________ < 2 ,000- 50,000— 75,000— 0 25,000 53, 00J 75,000 100,000 I I I I I I I 2571 311 241 111 2 lnumber i 75.03b1 9.1721 (.1011 3.2541 J.’ 21percentage I I I T I I 257 31 2’i Ii 2 number lo.036 9.172 7.101 3.254 percentage 1U0,000— 125,000— 150,000- 175,300— 200,000— 2?5.300— 126,030 150,003 175,000 200,000 225,000 250,300 I I I I I I 51 II 31 I ii I number l.47Q 1 0.29b1 0.9881 1 0.216 1 1 percentage I I I I I I 5 1 3 1 number 1.47q 0.206 0.888 0.296 percentage > pow 250,000 sU 1S I —1 1 .3! 333 number I 0.d981 100.000 percentage I I 33 number i.388 100.000 percentage D-34 ------- DRAFT 21. Factors related to Revenues and Expenses (cont) a. Fixed Costs: If the plant faces lease, rental or mortgage commit- ments beyond 1976, (for buildings or equi inent), indicate the average annual charges and the year the commitments expire. Other (1) Average Annual Charge: $_________ ( 5,CW0— 50,uOO— () 25,030 5 ,O0U 75,000 100, OflO i i i I £ I I 3331 21 I 11 T number I 9a.5211 0.5921 T 0.? 61 I percentage I I I I I I 333 2 i number 9d.521 0.5)2 0.?96 percentage 100,000— 1?5,000— 150,0J0— 175,000— ?O0,000— 225,000— 125,000 15u,J0Q 175,030 200,000 225,000 250,O0 ,) I I I I I I 1 r i number r percentage I I I I I > 250,000 SUMS I I I 338 number I 0.592 1 100.000 percentage I I 33 number 0.592 100.000 percentage D- 35 ------- DRAFT 21. Factors related to Revenues and Expenses (cont) a. Fixed Costs: If the plant faces lease, rental or mortgage commit- ments beyond 1976, (for buildings or equipment), indicate the average annual charges and the year the commitments expire. Leases/Rental (2) Commitment Expires: 19 3EFO AFTtR Nfl c fli 1985 1995—1995 1995 ANSWI.R SUMS I I I I I 1 551 141 41 2b51 338 number 1 1 .2721 4.1zt 21 I..1P31 78.40?1 lO .00u percentage I I I I 1 55 14 4 265 33 number 16.272 4.142 1.183 78.402 103.000 percentage D—36 ------- DRAFT 21. Factors related to Revenues and Expenses (cOnt) a. Fixed Costs: If the plant faces lease, rental or mortgage commit- ments beyond 1976, (for buildings or equipment), indicate the average annual charges and the year the commitments expire. Wood Contracts (2) CommItment ExpIres: 19 BEFORE ITLR NO r(O 1985 1985—1995 1995 ANSWER SUMS £ I I I I 1 ill I I 3271 336 number 1 3.2541 1 1 96.7461 1OJ.OOL) percentage I I I I 11 327 338 number 3.254 96.746 100.OOu percentage D—37 ------- DRAFT 21. Factors related to Revenues and Expenses (cont) a. Fixed Costs: If the plant faces lease, rental or mortgage commit- ments beyond 1976, (for buildings or equipment), indicate the average annual charges and the year the commitments expire. Debt Payment (2) CommItment Expires: 19 AFTER NO q O4 1985 1 9 85 —19 5 1 5 ANSWER SUMS I I I I I I 541 201 3! 2611 3 a number 1 15.9161 5.9171 0.8RdI 77.2111 io .ooo percentage I 1 I I I 54 20 261 338 number 15.976 5.917 ).8Rt 77.219 100.000 percentage D-38 ------- DRAFT 21. Factors related to Revenues and Expenses (cont) a. Fixed Costs: If the plant faces lease, rental or mortgage commit- ments beyond 1976, (for buildings or equipuent), indicate the average annual charges and the year the commitments expire. Other (2) CommItment Expires: 19 BEFORE AFTER \ O RO . 1985 1985—1995 1995 ANSWER SU I I I I 1 1 61 ii I 3 11 33t number 1 1.7751 0.2961 1 97.9 ?91 i0 J.O00 percentage I I 1 I I o 1 331 335 number 1.175 0.296 97.929 100.000 percentage D- 39 ------- DRAFT b. What Depreciation Method Is Used: Equipment Buildings (1) Book Basis Number Percexit Number Percent Straight—Line 109 73.65 121 87.60 Double—Declining 35 23.65 13 9.48 Balance Sum of Year’s Digits 2 1.34 2 1.46 Other 2 1.35 2 1.46 Total 148 100.00 137 100.00 Equipment Buildings (2) Tax Basis Number Percent Number Percent Straight—Line 81 52.26 99 72.26 Double—Declining 68 43.87 31 22.63 Balance Sum of Year’s Digits 4 2.58 4 2.92 Other 2 1.29 3 2.19 Total 155 138 100.00 (3) Pollution Control Equipment Amortization Number Percent Accelerated Over 13 11.92 5 Years Same method as 96 88.08 Other Equipment Total 109 100.00 22. Unusual Production Costs——Are there any circumstances peculiar to this plant which result in unusual production costs? Number Percent Yes 17 9.77 No 157 90L23 Total 174 100.00 D-40 ------- DRAFT 23. Historical/Annual Cost of Pollution Control and Other Environmental Regulations (1) Water Pollution Regulations a. Annual Operating Costs Number Percent Don’t Know 145 63.60 None 83 36.40 Total 228 100.00 b. Annual Depreciation Number Percent Charges Don’t Know 125 57.07 None 94 42.93 Total 219 100.00 (2) Solid Waste Disposal (including waste water sludge and wood waste, contract hauling ) a. Annual Operating Costs Number Percent Don’t Know 134 56.07 None 105 43.93 Total 239 100.00 b. Annual Depreciation Number Percent Charges Don’t Know 126 51.63 None 118 48.37 Total 242 100.00 (3) Other Environmental Regulations Affecting Production Processes and Production Costs Number Percent Air 49 40.83 OSHA 33 27.50 Both 38 31.67 Total 120 100.00 D-41 ------- DRAFT a. Annual Operating Costs Number Percent Don’t Know 129 64.82 None 70 35.18 Total 199 100.00 b. Annual Depreciation Number Percent Charges Don’t Know 122 58.94 None 85 41.06 Total 207 100.00 (4) Other Administrative Costs: Environmental department, research litigation, consultants, additional administrative costs. Number Percent Don’t Know 126 59.43 None 86 40.5.1 Total 212 100.00 D-4 2 ------- DRAFT 24. Value of wood treating plant Assets and Liabilities (as of the end of the most recent fiscal year). a. Net FIXED ASSETS (Gross FIXED ASSETS less cumulative depreciation). $_____________ 0 1 2 3 4 I i i I I I L 861 ‘t?I 321 151 171 25.’,4 tI 12.4261 9.4671 4.4381 5.03U1 I I I I I I 86 ‘i2 32 15 17 25.444 12.426 9.467 4.438 5.030 1 , 00 q p000— 5 6 7 8 2,000,000 I I I I I L i i 41 71 41 31 191 .254I 1.1831 2.0711 1.1P3 1 1.18 1 1 5.6211 i r I I I 11 4 4 19 1.183 2.071 L.1A3 1.183 5.621 > i . 0 k0 , 2,000,000 ANSWER SUMS I I I 1 71 901 337 I 2.0711 26.6 7I 100.000 I I 1 7 90 337 2.071 26.627 100.000 D-4 3 ------- DRAFT 24. Value of wood treating plant Assets and Liabilities (as of the end of the (cont) most recent fiscal year). b. Total Assets: (Net FIXED ASSETS, Cash receivables, Inventory, other assets) $_____________ 0 1 2 3 4 I I I I I I 1 32! 261 P;T Ill 22! 1 9.467! 7.6921 . 21I .254I 6.5091 I 1 I I 1 I 32 26 l 11 22 9.467 7.6?2 5.621 3.254 6.509 1 ,000 ,000— 3 6 7 8 9 2,000,000 I I I I I I 7 ! d l 71 81 31 35! 2.0711 2.3671 2.0711 2.367! 0.8 iRI 10.3551 i I I I I 7 a 7 8 3 35 2.071 2.367 2.071 2.367 0.Rd 3 10.355 > i JO RO 2,000,000 ANSWER SUMS I I I I 401 1191 332 1 12.130! 35.2071 100.000 I I I 40 11 337 12.130 35.207 100.000 D-44 ------- DRAFT 24. Value of wood treating plant Assets and Liabilities (as of the end of the (cont) most recent fiscal year). c. What was the value of this wood treating plant’s accounts receivable? $_______________ ?5,.J0U— 5r,OCJO— 25,000 5’ ,0O 7 ,,O00 100,000 I I I I 1• I 471 181 23! 181 I 13.905! 5.3251 o.8 05 1 5.3251 I I I I I. 47 1 23 18 13.905 5.325 ó.8fl5 5.32c 00,000— 1 5,000— ) NO i fl,J 125,000 150,000 150,000 ANSWER SUMS I I I I 1*1 131 Q8 1 1061 337 ‘t.1 42 I 3.R46 1 ? . 0I 31.3611 103.000 - I I I I 14 13 98 l0& 337 4.142 3.846 29 , 2 qo 31.361 100.000 D-45 ------- DRAFT 24. Value of wood treating plant Assets and Liabiflties (as of the end of the (cont) most recent fiscal year). d. What was the value of this wood treating plant’s accounts payable? $_____________ 25,00U— 50,OCjC— 75,003— 25,000 50,0u0 75,00u 100,0)0 I I I I I 1 681 28L 141 151 I 20.11 1 8.2ts41 ‘t.142 1 4.4381 I I I I I 2. i’. 15 20. l lb B.2ø’i .142 4.438 100.00 )— 1 5,0 J0— ) Nr 125,000 150,C00 150,00 ANSWER SUMS I I I 1 li i 41 701 1271 337 3.bA’1 1.1i3 1 20.4141 37. 74I 100.003 I 1 I I 13 ‘I 70 127 3 7 3. i4b 1.183 2U.414 37.574 100.300 D—46 ------- DRAFT 24. Value of wood treating plant Assets and Liabilities (as of the end of the (cont) most recent fiscal year). e. Current Plant Debt (i.e., debt maturing In current year or payable on demand) $_____________ 25,C0i— 0,000— ,u00— 25,00tJ 50,OJO 75, 00 100,300 I I I I I I 5JT 241 121 81 I 14.7931 7. lu l l 3.5 01 2.3S7I I I I I 50 4 U 1’..793 7.101 2.3b7 10u,Jr10_ i c,ouo— 125,300 150,0J0 L5O ,UO ) ANSWER SUMS I I I I 91 II 471 1b61 33? .663T ( .‘96I lj.9r I 5c.’2c1 iOO.0 0 0 I I I I 9 1 47 186 337 2.663 0.296 l3. O5 55.325 103.003 D—41 ------- DRAFT 24. Value of wood treating plant Assets and Liabilities (as of the end of the (cont) nost recent fiscal year). f. Long-Term Plant Debt (debt maturing beyond the current year [ 1977]) $_____________ 0 2 3 4 I I I I 1 I 1 651 251 51 71 91 1 19.2311 7.3961 1.4791 2.’7l1 2.66. T 1 I I I I I 65 25 19.231 7.3 6 1.47’ 2.071 2. 63 1,000,000— 6 7 9 2,000,000 z i I I I 51 1 11 1 1 21 J.47q1 1 0.2961 1 I 0.5 21 I I 5 1 2 1.479 0.29 O.5 2 > NO 2,000,000 ANSWER SUP’S I I I I 11 2171 .37 I J.29 1 54 .4z171 100.J0U I I I 1 217 337 3.296 64.497 100.000 D-4 8 ------- DRAFT 24. Value of wood treating plant Assets and Liabilities (as of the end of the (cont) most recent fiscal year). g. Total Plant Liabilities (long-term debt, accounts payable, deferred taxes, other debt, etc.) $_____________ 0 1 3 4 I I I I I I 1 631 291 1 JI 141 91 1 18.6391 .5 OL 5.3751 4.1’t?1 2. f3T 1 I I I I I 63 29 18 14 9 18.639 8.5 0 4.14? 2.663 1,000 ,000— 6 1 8 2,000,000 I I I I I I 81 5! 41 31 21 131 2. 1671 1.4791 1.1d31 0.8881 0. 92I 3.8461 I I I I I I R 5 4 3 2 13 2.367 1.479 1.183 0.888 fl. 92 3.84b > NM ROW 2,000,030 ANSWER SUMS I I I I 41 1651 337 I 1.1831 49.1L21 1OU.J0O 1 I I 4 165 337 49.112 ICU.L) OJ D—49 ------- DRAFT 25. Capital Investment Criteria for the Plant a. What investment criteria do you use? Number Percent Return on Investment (ROt) 75 63.02 Payback 21 17.64 Other 23 19.34 No Answer 218 ______ Total 337 100.00 D-50 ------- DRAFT 26. Capital Investment Criteria for the Plant (cont) b. If you use return on investment criteria: (1) What Is the target Internal pre—tax rate of return on capital required for investment In this plant?___________ 0—4% 5—9 1 .)—14 15 — 19% 20—Z4 i I T I 21 71 111 81 1 0.5921 2.’)711 3.2541 2.3671 I I I I I I 2 7 11 8 0.592 2.071 3.254 2.3 7 50 . OR 3¼)—34 35—39% 40—444 45—49% GREATER I I I I I I 121 d l 1 3! I 11 3.R46 1 2.367r 1 0.8881 1 0.2961 1 i I I I I 12 8 3 3. 8 ’tó 2.36? 0.888 0.29b NOT APPLIC ANSWER SUMS I I I 1 2651 201 3fl 1 78.4021 5.9171 100.000 I 1 265 20 33 78.’,02 5. 17 100.U0O D-51 ------- DRAFT 26. CapItal Investment Criteria for the Plant (cont) b. If you use return on Investment criteria: (2) At what ROl would you consider plant shutdown?____________ O—4 5—9 lu—14 t 15—19 ?024 I I I I I_——— I I 51 81 61 9 1 71 1 1.4791 2.3671 i.17 ..I l.77 L 2.367! I I I I I I 5 6 6 7 2.367 1.775 l.77 2.3 7 50 OR 30—34 35-39 40—’t4. 4 —4 (.,REATER I I I I I I 1 1 11 1 1 11 1 1 0.2961 1 1 O.2°6 1 i i I 1 0.296 0.2 6 NOT NO RO APPLIC ANSWER SUMS I I I I 2651 3 I 37 I 7 8.40fl 11.2431 100.000 I I I 265 38 s37 78.402 11.2’,3 100.000 D-52 ------- DRAFT 26. Capital Investment Criteria for the P’ant (cont) c. If you use payback period criteria, what Is the required payback period for Investment? years 2 YRS 2 3 4 5 £ I I I I I I 11 21 21 21 61 0.296! 0.c921 O.5°2! C.5921 2.0711 I I I I I 1 2 2 2 0.296 0.592 .i.592 0.592 2.071 > 6 7 8 q 10 tO YRS I T I I I I I I I I 31 31 I I I I 0. d I O.o88I I I I I I I 3 3 0.8d8 NOT NO ROw APPLIC ANSWER SUMS I I I I 3171 ii 337 1 93.7871 0.2961 ICO.U00 I I I 317 1 337 93.787 0.296 100.000 D—5 3 ------- DRAFT 26. CapItal Investment Criteria for the Plant (cont) d. What is the current long term Interest rate you must pay for new capital? percent per year ( 7% 7 3 9 10 I I I I I 1 I 31 11 liT 201 251 I 0.88B1 0.2961 3.5501 7.396! I I I I 1 I 3 I Ii 2C 25 0.888 0.216 3.550 5.917 7 .3q5 P lO Raw 11 12 > l? ANSWER SUMS I I I I 31 51 171 2 2I 337 0.8681 1.4791 5.0301 74.55b1 100.000 I I I I 3 5 17 2S2 337 0.888 1.479 5.030 74.556 100.000 D-54 ------- DRAFT 26. Capital Investment for the Plant (not Including capitalized operating (cont) or maintenance expenses). (1) Total Capital Investment (Actual) 1971-76 $______________________ ZERO 250,00’J— ENIRY 1—25C,JCO 50fl,00() I i I 1 1 1131 561 I I J3. ,i2i 1(,.568 1 I I I I 113 56 16.568 0O,00J— 753,003— 40 750,00 1.,tJOO, 000 ANSWER I I I I 241 341 I I IPI 7.1011 IP.355 1 I 3?.544 1 I I I I 34 110 7.101 10.355 32.544 I 0w S U MS I 1 337 I 1 j0.0O0 I 337 100.000 D—5 5 ------- DRAFT 26. Capital Investment for the Plant (not including capitalized operating or (cont) maintenance expenses). (1) Total Capital Investment (Planned) 1977 $_______________________ LERO ENTRY ii 1 2 I I I I I 1 3! 931 32!- 91 I 3.38 1 7.5ISI 9.4 7! 2.6631 1 I I I 1 3 9 32 9 0.a88 27.515 9.467 2.663 ROW 3 SUMS I 1 I 131 1 18d 1 337 3.8461 1 55.o?1I 100.000 I I I 13 183 337 3.846 5.621 100.000 D—56 ------- DRAFT 26. CapItal Investment for the Plant (not including capitalized operating or (COflt)maintenance expenses). (2) Water Pollution Control (Actual) 1971-76 $__________________ L E RJ ENTRY 0 1 2 I I I I I I 1 1011 161 11 I 1 29.8821 4.1341 0.2961 I I I I £ 101 16 1 29.882 ‘i. 134 0.296 NJ ROW 3 ANcWER SUMS I I I 51 1 2151 337 1.4791 1 63.609! 100.000 I I I 5 215 337 1.479 63.60i 100.000 D-5 7 ------- DRAFT 26. Capital Investment for the Plant (not including capitalized operating or (cont) maintenance expenses). (2) Water Pollution Control (Planned) 1977 $_______________________ LERO ENTRY 0 1 2 I I 1 I I I 31 671 31 1 I 19.8221 0.d U1 I I I I I I 3 67 3 0.t388 19.822 0.a88 NO ROW 3 Ar SWER SUMS I I I 1 1 1 2641 339 J.29o1 I 7ES. IOTT 100.000 I 1 I 1 2 ’4 33R 0.296 78.1’ 7 100.OUO D-5 8 ------- DRAFT 26. Capital Investment for the Plant (not including capitalized operating or (cont) maintenance expenses). (3) Other Environmental Regulation (State or Federal) Impacting Production Processes (Actual) 1971-76 ________________ ZERO ENTRY 0 1 2 I I I I I I II 431 31 11 1 0.2961 1?.722 1 O. 388T 0.2961 I I I I I 1 3 1 0. 96 12.722 0.888 0.296 ROW 3 ANSPJER SUMS I I I LI I 289! 338 0. 9à1 I 8 .503I 100.000 I I I 1. 2R9 338 0.296 .503 100.000 D-59 ------- DRAFT 26. Capital Investment for the Plant (not Including capitalized operating or (cont) maintenance expenses). (3) Other Environmental Regulation (State or Federal) Impacting Production Processes (Planned) 1977 $_____________________ ZERO ENTr(Y U I I I I I I I 5! 261 21 1 I 7.6121 u.5921 I I I I I I 5 26 1.47) 7.692 0.59 NU ROW 3 A S FR SUMS I I I 11 1 3041 338 J.293 1 I 9.94II 100.0U I 1 I 1 304 338 89.941 100.000 D-60 ------- |