Document 0qjdkbQQ5j0agQBz1Laxrn21R

DRAFT "General Economic Questions" Answers to EPA: 1) - Location of PCB Production Plant - Sauget, Illinois - Production Capacity - 55-60MM lb/yr. - Shipments - 30-50MM lb/yr. during last 3 years - Employment - 25-30 persons directly employed and 30 others in support functions. Intermediate unit involves 47 employees - Supplementary Points! - The PCB Unit is one component of a large complex, the W. G. Krummrich Plant, employing over 1,000 persons. - He formerly had a second PCB Production Plant of comparable size at Anniston, Alabama, and total shipments were approximately 100MM lb/yr. prior to discontinuance of "open System" applications. 2 & 3)There are two areas in the Plant which are currently involved in handling PCB'8. These are the Production Unit and the Incinerator. The following flows apply to those two areas; water flow for the complex is much larger, but the remainder originates in areas unrelated to PCB's. (Thousands of Gallons Per Day) PCB Production Area Incinerator Average 245 190 Low 100 14 High 500 250 Per Unit Produced 2.25 gal/lb. - Docs not include rain run off 000A133 PCB-ARCH0743210 2 4) Discharge from the units Involved Is to the general sewer system of the complex, thence to the Sauget Village Treatment Plant which discharges to the Mississippi River at mile 178.1 above the Ohio. The following data Is from the U.S. Geological Survey for St. Louis mile 180.0: Average flow 174,500 cubic feet per second (111 years) Minimum flow 1972 68,600 cubic feet per second gage 0.08 ft. Maximum flow 1972 408,000 cubic feet per second gage 25.00 ft. Minimum recorded flow 18,000 cubic feet per second gage - 6.1 ft. Maximum recorded flow 1,019,000 cubic feet per second gage +38.00 ft. At this point the river is 1600 feet wide and varies in depth from 15 to 25 feet at zero gage. Hie average flow represents & gage height around 11 feet. - Ambient concentration of PCB's - Because the river is so large compared to PCB discharges, no serious attempt has been measure ambient level. The following spot samples support the contention that such a program would be fruitless: Date Location PCB's mg/1. PPb 10/30/72 Jefferson Baracks Bridge (Below Plant) <0.0001 <0.10 12/13/72 Chain of Rocks Bridge (Above Plant) 0.00022 0.22 12/12/72 N. of 111. River (Above C.O.R. Bridge) 0.00019 0.19 5) -Source of the Pollutant - The manufacture of PCB's involves no direct contact of water with the product stream. However, water Is used in the process for Indirect cooling and quenching the exhaust of stream ejectors for process vacuum. There is also a scrubber on a small air 0004139 PCB-ARCH0743211 3 stream containing HC1 which is contaminated with small amounts of PCB's. Any leaks or spills are contained by a system of curbs and sumps, but the slight solubility of PCB's in water allows some of any such spill to reach the sewer. In the incinerator area, the hot flue gas from the incinerator is quenched and scrubbed with water to remove HCl and the water is sewered. Firebox operating conditions are controlled to prevent any PCB's from reaching the water etream; the small amount of PCB's in the effluent from the area is believed to result from runoff from leaking drums of returned product which have been encountered in the past. 6) -Substitutes for the Pollutant - Not really a relevant question, since the purpose of these facilities is manufacture of PCB's. Monsanto is working toward replacement products but it is most un likely that any such product could be manufactured in this equipment. 7) -Estimated Treatment Cost - No treatment technology has been developed to the point that a commercial installation could be confidently designed to reach proposed effluent requirements, therefore the following data describes a conceptual approach. Capital - $300,000 each for two systems, does not include incinerator ($800,000) 0 & M - $120,000 - $150,000/yr. Annual - Assume a ten year writeoff - $180,000-$210,000 per year. 8) -Cost of Abatement - about 0,5c/lb. if proven feasible. 0004135 l PCB-ARCH0743212 A 9) -Profitability slightly better than average for the chemical Industry. Annual sales - about $10M Value of Assets - $11M Cash Flow - $1 - $2M Capital Expenditures under $0.5M/yr. 10) -Ability to raise prices Is controlled by cost performance in applications. Only truly competitive products would be Imported PCB's. Discharge at our producing unit would be eliminated, however, control at user's plants would still be required. Plant closure criteria include recovery of cost of capital and allowance for small margin for risk factors. No salvage value Is predicted. Cost of decontamination and proper disposal will generate costs not normally encountered in dismantling idle facilities. Ability to raise capital, cost of capital, etc., are all influenced by conditions prevalent at the time capital is required. 0004136 PCB-ARCH0743213 ATTACHMENT A General Economic Questions For each plant: (1) location, production capacity, annual shipments, and employment (2) total water usage - quantity per day - quantity per unit of production . - give both the average and the range _ (3) water usage for only those waste streams containing the pollutant in question 1 .... ' - quantity per day - quantity per unit of production - give both the average and the range (4) receiving water body data (stream flow, lake size, etc.) at the point of discharge - ambient concentration of the pollutant (upstream and downstream) (5) source of the pollutant (part of the process, contaminant in raw materials, etc.) (6) substitutes for the pollutant (process changes, less contaminated raw materials, etc.) - are there process changes, less contam. raw mat., etc, which will reduce pollutant load? . (7) estimated treatment costs - investment - 0 &M . - annual (investment plus 0 & M) (8) cost of abatement . . - estimated treatment costs per unit of production . - cost of substitutes (see (6)) alternative processes or raw materials. (9) financial data - profitability on investment and sales . - annual sales - value of assets (fixed and current) ., - cash flow , - capital expenditures 000*137 ! I PCB-ARCH0743214 2 economic impact . . - ability to raise prices - price of competitive products (including imports) - availability of competitive products (including imports) - threat of plant closure - criteria for closure - cutoff in profitability, cash flow, etc. below which the plant will close . - salvage value of the plant - ability to raise capital - how would this investment be financed (debt, equity, pollution control bonds, etc.) _ - the cost of capital . - period of repayment - planned capital expenditures over the period of repayment I 0004136 PCB-ARCH0743215