## From: "Higgins, Cortney " < Cortney _Higgins@omb.eop.gov> To: Bill Schrock/RTP/USEPA/US@EPA Cc: Robin Dunkins/RTP/USEPA/US@EPA, "Frey , Nathan J."

<Nathan_J._Fre y@ omb.eop.gov > Date: 07/17/2012 05:23 PM Subject: Interagency Comments on Pulp and Paper RTR

Hi Bill, Attached is a redline document with comments on the pulp and paper RTR preamble submitted for review. Additionally , we received the following c omment on the cost estimates

– can you explain the discrepancy? I’ll be out of the office starting this Friday (7/19) and will return on Monday , 7/23. If you have any questions or want to send back responses to the redline document during that time perio d, please send to Nathan (copied on this email) and copy me. Regards, Cortney Question about the Repeat Testing Cost estimate: Using the RTI cost impact memo, p.14, Table 9 as the basis for the estimating testing costs, it was not possible to replicate the costs estimates from the memo (on p.16 of the RTI cost impact memo as $5.4M capital costs, $1.3M/y r annualized costs). That table didn’t include the number of mills in each of the 4 categories listed, so I counted the **number of mills in each category** u sing Appendix C, p.48

- 56, of that same memo:

- **106** kraft, soda, and semichemical mills (including semichemical+secondary fiber mills) **or 103**  kraft, soda, and semichemical mills (NOT including semichemical+secondary fiber mills)

- **44** kraft mills using biotreatment (including those using stripping+biotreatment) **or 40**  kraft mills using biotreatment (NOT including those using stripping+biotreatment)

- **5** sulfite mills

- **73** mills bleaching with chlorinated compounds (e.g., ClO 2 

## ) I then multiplied the number of mills in each category by the testing cost per mill to get a maximum and minimum estimate for repeat testing costs:**Ma xim**  **um case**

Number of mills in category Capital cost per mill every 5 years Subtotal of

mill category capital costs every 5 years Annualized

capital cost per mill, $/yr Subtotal of mill

category annualized capital costs, $/yr 106 Kraft, soda, and semichemical mills (including semichemical+secondary fiber mills) $ 42,000 $4,452,000 $ 10,243 $1,085,758

44 Kraft mil ls using biotreatment (including stripping+biotreatment) $28,000 $1,232,000 $6,829 $300,476

5 Sulfite mills $14,000 $70,000 $3,414 $17,070 73 Mills bleaching with chlorinated compounds (e.g., ClO 2 ) $20,000 $1,460,000 $4,878 $356,094

**Total $7,214,000**  **$1,759,398 Minim** **um case** 
Number of mills in category Capital cost per mill every 5 years Subtotal of

mill category capital costs every 5 years Annualized

capital cost per mill, $/yr Subtotal of mill

category annualize d capital costs, $/yr 103 Kraft, soda, and semichemical mills $42,000 $4,326,000 $10,243 $1,055,029 40 Kraft mills using biotreatment $28,000 $1,120,000 $6,829 $273,160 5 Sulfite mills $14,000 $70,000 $3,414 $17,070 73 Mills bleaching with chlorinated compounds (e.g., ClO 2 ) $20,000 $1,460,000 $ 4,878 $ 356,094

**Total $6,976,000**  **$1,701,353** 

## This estimated range of $7.0

- 7.2M in total capital costs of retesting is higher than the $5.4M stated in the memo. This range is also higher than the $5.9M in total capital costs for the entire rule (including reporting and recordkeeping costs of $0.5M) that is stated in the final rule p.26.

________________________________________________ Cortney Higgins Policy Anal ys t OMB/OIRA/NRE 202 .395.7856 chiggins@omb.eop.gov