From:		Bill Schrock/RTP/USEPA/US@EPA

To:		"Higgins, Cortney" <  HYPERLINK
"mailto:Cortney_Higgins@omb.eop.gov"  Cortney_Higgins@omb.eop.gov >

Cc:	"Frey, Nathan J." <  HYPERLINK "mailto:Nathan_J._Frey@omb.eop.gov" 
Nathan_J._Frey@omb.eop.gov >, Robin Dunkins/RTP/USEPA/US@EPA

Date:		07/19/2012 01:29 PM

Subject:	Re: Interagency Comments on Pulp and Paper RTR

Cortney - Included here is our response to your comments.  Attached is
a clean version of the preamble and reg text and a red line version
which is a comparison to the file we forwarded to you Tuesday with the
revised version.  It contains the new executive summary and the other
edits requested (we also made a minor edit to some Incorporation by
Reference language you'll see).   Also, we reviewed the cost questions
and the chart you sent us which contained a summary of the repeat
testing costs.  We have reviewed our cost estimates and verified that
they were not under-estimated, which I believe was your
concern. Essentially, we think you all counted some kraft mills with
biotreatment twice in your recalculation.  Below is a summary of costs
and how we think you arrived at your numbers.

Repeat testing costs provided for each mill in Appendix C of the RTI
cost memo were used.  However, you all may have overlooked the capital
and annualized cost columns entitled “Repeat testing” almost all the
way to the right of the table.  A revision to your recalculation is
shown below containing the correct math.  When the correct number of
mills are used, the 1st, 2nd and 4th rows of your chart change and the
bottom line subtotals match the cost estimates provided in our Cost memo
and the EIA. If this doesn't make sense to you all we can have a call to
walk through it with you all.

  

Number of mills in category 	  	Capital cost per mill every 5 years 
Subtotal of mill category capital costs every 5 years, $Millions 
Annualized capital cost per mill, $/yr 	Subtotal of mill category
annualized capital costs, $Millions/yr 

66	Kraft (97 - 40 biotreatment = 57 mills), soda (1), and semichemical
mills (8, including semichemical+secondary fiber mills) 	42000	 $2.8 
10243	0.68

40	Kraft mills using biotreatment (including stripping+biotreatment) 
28000	 $1.1 	6829	0.27

5	Sulfite mills 	14000	 $0.1 	3414	0.02

72	Mills bleaching with chlorinated compounds (e.g., ClO2) 	20000	 $1.4
	4878	0.35

  	Total 	  	 $5.4 	  	 $1.3



Bill Schrock

U.S. EPA

RTP, NC  27709

(919) 541-5032

(919) 541-3470 (fax)

