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._Frey@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 comment 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 period, 

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/yr 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 using 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., ClO2)

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:
Maximum 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 mills 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., ClO2) 

$20,000 $1,460,000 $4,878 $356,094 

Total $7,214,000 $1,759,398 

Minimum 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

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., ClO2) 

$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 Analyst

OMB/OIRA/NRE

202.395.7856

chiggins@omb.eop.gov