a
Values
are
rounded
b
MACT
I
Mills
include
kraft,
sulfite,
soda,
and
semi­
chemical
operations.
MACT
III
Mills
include
mechanical,
non­
wood,
and
secondary
fiber
operations.

c
One­
time
activity.
In
out
years,
after
initial
compliance
date,
assume
that
5%
of
mills
affected
as
a
result
of
unexplained
exceedances.

d
Performed
by
all
mills.
(
155
MACT
I
Category
Mills,
338
Stand­
alone
MACT
III
category
mills)

Assume
all
MACT
I
category
mills
will
be
afftected
by
this
rule.
Assume
the
only
MACT
III
category
mills
that
will
be
affected
by
this
rule
are
the
stand­
alone
m
(
Available
information
estimates
that
only
2%
of
stand­
alone
MACT
III
category
mills
have
chlorine
bleaching
processes
(
2%
of
338
=
7,
After
initial
compliance
Total
number
of
mills
affected
by
this
rule
is
155
+
7
=
162
e
Estimated
that
66.7%
of
mills
will
use
a
recovery
boiler,
power
boiler,
or
lime
kiln
for
control
of
pulping
vents.
There
are
140
non­
sulfite
pulping
mills.
(
66.7%
of
f
Estimated
that
33.3%
of
mills
will
use
incineration
for
pulping
lines
(
16.7%
will
provide
acceptable
design
specs
(
24),
and
16.7%
will
conduct
performance
tests
g
Estimate
includes
test
plan,
test
report,
and
parametric
montioring
setup.
Method
308
tests
for
pulping
lines
and
method
26A
tests
for
bleaching
lines.

Assumed
costs
for
emissions
testing
of
$
12,000
for
method
308
and
$
8,500
for
method
26A
h
Estimate
includes
test
plan,
test
report,
and
parametric
monitoring
setup.
Method
304
and
305
are
for
wastewater
streams.

Assumed
costs
for
testing
of
$
9,500
for
method
304,
and
$
14,000
for
method
305.

i
Assume
that
all
14
sulfite
pulping
mills
will
conduct
performance
tests.

j
87
MACT
I
category
mills
have
bleaching
lines.
90%
will
provide
acceptable
performance
specs
or
previous
test
results
(
78),
10%
will
conduct
performance
test
Assume
2
percent
of
stand­
alone
MACT
III
category
mills
have
bleaching
lines
(
2%
of
338=
7).
90%
will
provide
acceptable
performance
specs
or
previous
tes
10%
will
conduct
performance
tests
(
1).

k
Estimated
that
each
kraft
mill
has
one
pulping
wastewater
control
device.
Of
the
123
kraft
mills,
32
already
have
steam
strippers
in
use,

and
of
the
32,
all
are
assumed
to
conduct
condensate
segregation
and
performance
tests.
Of
the
91
mills
without
control,
40
will
use
biotreatment
control
and,
51
will
install
steam
strippers.
Facilities
installing
new
steam
strippers
are
assumed
to
perform
initial
condenstate
segregation
and
performance
tests.

Facilites
installing
new
biotreatment
control
will
perform
initial
performance
tests.

l
Estimated
that
each
kraft
mill
has
one
pulping
wastewater
control
device.
Assumed
33%
will
use
biotreatment.
(
33%
of
123
=
40)
Per
footnote
"
c,"
5
%
of
40
m
Assume
sulfite
mills
will
monitor
gas
scrubber
parameters
and
use
Water­
8
Model
for
emission
estimates.

n
Assumed
that
15%
of
performance
tests
are
failed
and
need
to
be
repeated.
o
Initial
and
annual
activity.
Assumed
that
EPA
is
notified
each
year
of
the
testing.
Assumed
2/
3
of
all
MACT
I
mills
have
positive
pressure
points
in
their
vent
sys
and
will
have
to
test
using
method
21
(
2/
3
x
155
=
103).
Assumed
purchase
of
service
cost
for
method
21
test
of
$
2,500.

p
Assume
that
25%
of
all
kraft
mills
are
still
required
to
submit
compliance
strategy
reports
(
25%
of
123
kraft
mills
=
31
affected
kraft
mills)
in
order
to
comply
by
q
Assumed
that
15%
of
all
affected
mills
during
any
one
quarter
will
be
required
to
submit
an
exceedance
report
in
addition
to
the
summary
report.
(
15%
of
162
r
EPA
must
be
notified
of
all
tests
including
repeat
performance
tests.
((
155
x
.05
=
8)
8
x
1.15
x
3
=
28)
(
see
footnotes
c
and
q)

s
Assumed
15%
of
all
affected
mills
conduct
construction
or
reconstruction
per
year.
(
15%
of
155
=
23)

t
Total
cost
/
3
