May 4, 2012 

MEMORANDUM

SUBJECT: Meeting notes for the May 2, 2012 meeting with AF&PA 

FROM: John Bradfield 

TO: Docket EPA-HQ-OAR-2007-0544 

This memorandum summarizes the meeting between The American Forest and Paper Association 

(AF&PA) and the EPA on May 2, 2012. This meeting was requested in response to the Risk and 

Technology Review (RTR) of the National Emission Standards for Hazardous Air Pollutants (NESHAP) 

for the pulp and paper industry. The agenda for the meeting is provided in Attachment 1. 

Meeting Attendees: 

Dan Bivins-EPA/AQAD John Bradfield-EPA/SPPD 

Corey Brandt-RockTenn Nancy Clark-AF&PA 

Mike Curtis-Georgia-Pacific Rich Damberg-EPA/AQPD 

Jason DeWees-EPA/AQAD Robin Dunkins-EPA/SPPD 

Rich Garber-Boise Inc. Ryan Gesser-Georgia-Pacific 

Katie Hanks-RTI Tom Holloway-RTI 

Tim Hunt-AF&PA Ashok Jain-NCASI 

Rhea Jones-EPA/AQPD Rob Kaufman-KCPS 

Debra Lane-Rayonier (by phone) Michael Ling-EPA/AQPD 

Steve Lomax-Koch Companies Public Sector Amy Marshall-URS 

Brian Mooney-Resolute John Pinkerton-NCASI 

Paul Noe-AF&PA/AWC John Petchul-Greif Packaging 

John Piotrowski-Packaging Corp. of America Annabeth Reitter-NewPage Corp. 

Bill Schrock-EPA/SPPD Jeff Shumaker-International Paper 

Tim Smith-EPA/AQPD Sue Somers-Clearwater Paper 

Kelley Spence-EPA/SPPD Russell Strader-Boise Cascade, LLC 

Jim Taylor-MWV Peter Tsirigotis-EPA/SPPD 

Vipin Varma-NCASI Steve Woock-Weyerhaeuser 

 
Discussion Points: 

• Discussions for the first hour of the meeting followed the AF&PA slides in Attachment 2. 

• The spreadsheet used as the basis for the revised costs presented in the slides is provided in 

Attachment 3. 

• Discussions for the second hour included NAAQS status updates from EPA/AQPD staff. 

• Discussions for the third hour included a status update on wet stack PM test development from 

EPA/AQAD/MTG and a status update on the review of mills’ NEI revisions from EPA/SPPD. 

• Later discussions on SSM are tentatively scheduled for May 17.

   
Attachment 1 

Agenda – EPA/American Forest and Paper Association Meeting 

   
Agenda 

EPA/American Forest and Paper Association Meeting 

May 2, 2012 

Room C112 

Call-in # 919-541-4332

1. Open Meeting 1:00 pm – 1:05 pm 

 Introductions 

2. RTR/MACT Issues – SPPD Staff 1:05 pm – 2:15 pm 

3. NAAQS Updates – AQPD Staff 2:15 pm – 3:00 pm 

 Michael Ling, Rich Damberg, Rhea Jones 

 Tim Smith, Todd Hawes, Beth Palma 

4. Break 3:00 pm – 3:15 pm 

5. Wet Stack PM Test Development – MTG Staff 3:15 pm – 3:30 pm 

6. RTR/MACT Issues – SPPD Staff 3:30 pm – 4:15 pm 

7. Wrap/Adjourn 4:15 pm – 4:30 pm 

   
Attachment 2 

AF&PA - Pulp & Paper Residual Risk and Technology Review Proposal 

 
Pulp & Paper Residual Risk and Technology 

Pulp

& Paper Residual Risk and Technology 

Proposal

Industry Meeting with OAQ

Research Trian

g , le Park, 

May 2, 20
Agenda

Cost analyses Cost analysesExcess Emission AllowancesNext Steps/Wrap-up
Cost Estimates for Proposed Increas

Cost Estimates for Proposed Increas

Treatment Standards
Cost Considerations

What do facilities need to do to achieve 94% treatment efficiency

AF&PA Members continue to evaluate systems and refine cEach update has been provided to EPA. These costs represto

-date estimates. date estimates.

Costs assume that treatment systems must meet a new trestandard of 94% without additional collection, i.e., they neeupgrade their control systems. For biological treatment systems demonstrating compliance fbio, a standard of 94% treatment efficiency translates to a standard to account for other HAPs. 

All systems require a margin to ensure compliance owidely varying conditions.
Cost Considerations (cont.)

Will CCA Mills be able to utilize this option or th d t ti f ll t? the 

demons

tration 

fall apart?

Conservative assumption of cost estimate

CCA mills will demonstrate compliance with the new condensate treatment requirements without additiocondensate collection and by implementing control upgradesCCA demonstration would have to be repeated if it viable
Conclusions of further assessment to da

ASB

-based systems in the majority of configurations emp

based systems in the majority of configurations emp

today for cluster compliance will be severely challenged thigher treatment efficiency standards over the range of conditions typ y p icall

y ex

perienced. 

CCA using WWT and particularly ASB technology will liketo comply with higher treatment efficiencies; generally no additional condensate is available for collection to offset additional condensate is available for collection to offset

efficiency with tons treated
Facility Treatment Options & 

Upgrade Assumptions

Treatment Option Number of

Units

Upgrade Assumptions

Stripper Only 43 • Mills under 96% treatment efficiency will need to upg

(25 of 43 mills; 18 units are above 96%).

• All strippers will have an increase in O&M Cost

BiologicalTreatment Only

39 • 20% of systems able to meet the proposed 94% standa

• 40% of facilities are able to upgrade their systems

• 40% of facilities choose to install

a steam stripper in ad

controls (due to upgra

d

e constrai ) nts

BiologicalTreatment

&

Stripping

9 • Six of these systems are at or below 96%. Assume

1⁄2 of 

below 96% will require upgrades to the steam strippers

• All strippers will have an increase in O&M Cost

R l ecyc

e

5 • Assume no upgra

des requi d re

d

Thermal Oxidizer

1 • Assume no upgrades required

TOTAL 97 • Assume that 84 mills are affected, which exc

thermal oxidizer and 7 biological treatment thermal oxidizer, and

7 biological treatment 

Assumed that mills can still utilize the CCA option, but will need to upgrade their control systems and redemo

compliance with CCA via an IPT. This is a conservative assumption as it is expected that several CCA Mills 

able to utilize this option under this methodology
Cost Estimate to treat to 94% : Assumptions

(No additional collection required – 10.4/6.8 lb/ODTP trea

Stripper Assumptions

More energy, trays, and steam contact areaNeed compliance margin eed compliance margin

– units with < 96% would need upgrades units with

< 96% would need upgrades

20% are integrated with evaporatorsAssume 10% downtime remains - no backup

Wastewater Treatment S

y p stem Assum

ptions

20% of existing facilities will be able to meet the proposed treatment standa40% of existing facilities will need to upgrade their systems with increased aand nutrient addition

Increase aeration by 600 hp (install eight 75 ncrease aeration by 600 hp (install eight 75-hp aerators) for each faci

hp aerators) for each faci

Added nutrients may impact water quality standards

40% of existing facilities impacted by upgrade constraints will be unable to demonstrate compliance solely with upgrades and will install steam strippers

T f d t it Types o

f up

gra

de cons

train

ts 

– F iliti tl l i ith th 9

Facilities currently complyin

g with the 9

would switch due to the need to actually be at 96% to compensate for HAPs

Residence time, nutrient loads, and solids loads limitations
Cost Estimate to treat to 94% : Strippers

(No additional collection required – 10.4/6.8 lb/ODTP t

EPA Estimate

8 stripper upgrades

AF&PA Estimate

8 28 stripper upgra

stripper upgrades pp pg 

and below)

25 Strippers (ontreatment devic

$2.7 M/each

3 Strippers for fwith dual treatmthe units at 96% the units at 96% 

below)

$2.9 M/each for i t t d it in

tegra

te

d units

$5.8 M/each for units
Cost Estimate to treat to 94% : Biological Treatment

(No additional collection required – 10.4/6.8 lb/ODTP t

EPA Estimate

7 systems (at or below

AF&PA Estimate

7 systems (at or below 39 systems (all wit

94%)

39 systems (all wit

biological treatmen

7 systems will not any upgrades any upgrades16 systems will requpgrades16 systems will hav

tt t 

Assumed no new strippers

conver

t

to s

team s

Capital cost of strip$7 4M/ h Capital costs for WWTS 

range from $1 – 4 M/each

$7.4M/eac

h

Capital Cost of WW$ / 0.5 M each
Cost Estimate to treat to 94% : O&M Costs

(No additional collection required – 10.4/6.8 lb/ODTP t

Strippers – Costs for all existing strippers (52 units)

Increased energy / /y $ / : 10 MMBtu

/hr x 8390 hr/yr x 

$

3/MMBtu

Increased maintenance to maintain efficiency: one additional outagyear at $100K

Strippers – Costs for new strippers (16 units)

Increased energy : 100 MMBtu/hr x 8390 hr/yr x $3/MMBtu x (1-6

Assume 60% energy recovery

Increased maintenance to maintain efficiency: two outages per yea$100K

Biological Treatment Systems (16 units)

Increased energy: $0.4M/year/facility Maintenance costs for aerators: $220K/year/facility Maintenance costs for aerators: $220K/year/facilityCost for chemicals only (nutrient): $60K/year/facility
Cost Estimate to treat to 94%

(No additional collection required – 10.4/6.8 lb/ODTP t

Number

of Units

Affected

Capital Costs

($M)

Annual 

Capital 

Costs 

($M)

Annual

Energy

Costs ($M)

($M)

Stripper Upgrade 28 $97 $9 $7 Current Strippers 24 ‐‐ -- $6 New Strippers 16 $115 $11 $16 WWTS Upgrades 16 $10 $1 $6 [WWTS Upgrades - EPAFlow Based]

[16] [$56] [$5] [$--1] 

Nutrient Addition 16 ‐‐ ‐‐ 

TOTAL 84 $222 [268] $21 [25] $35 [29] 

1 Note that O&M costs incl de ene g costs fo EPA methodolog1. Note that O&M costs include energy costs for EPA methodolog
Cost Estimate to treat to 94% -

(No additional collection required)Comparison of AF&PA and EPA Estimates for WWTS

Number of Capital Costs Annual Annual 

Units

Affected

($M) Capital 

Costs 

($M)

Energy

+

O&M

Costs

($M)

EPA 16 $56 $5 $3 AF&PA 16 $10 $1 $9 

EPA t ti t d b d th d t d 16 t i th t ti EPA cos

ts estima

te

d

base

d on the nee

d

to up

gra

de 16 sys

tems usin

g the cos

t equatio

identified by EPA:Capital costs ($) = 5.9749 x MGD0.8228 x 1,000,000

O&M costs ($) = 0.2546x MGD0.6969 ($) x 1, , 000 000

Average MGD for systems from ICR Data is 25 MGD. For a 2% treatment efficiency uincrease in flow would be 0.54 MGD based on the following EPA equation for increaseFlow Increase = MGD * (94/92) MGDFlow Increase

= MGD

* (94/92) - MGD
Cost Estimate to treat to 94% : Costs not Included or 

Conservative Assumptions(No additional collection required)

Strippers

Costs for new Strippers assumes that the facility htreatment device to burn stripper off-gases (SOGsBoilers are not always suitable for these gases and Boilers are not always suitable for these gases and

facilities prefer to incinerate SOGs in a thermal ox

With higher efficiencies, it may be necessary to inspare preheaters Costs for these units are not inspare preheaters. Costs for these units are not inAssumes that facilities will only need one additionashutdown to maintain existing units at a higher efAssumes 10% downtime allowance remains. Costbackup strippers are not included.
Cost Estimate to treat to 94% : Costs not Included or 

Conservative Assumptions(No additional collection required)

Wastewater Treatment Systems

Assumed cost for each 75 Assumed cost for each 75-hp aerator (installed) at $60K This is on the low 

hp aerator (installed) at $60K. This is on the low 

other members have purchased 50-hp aerators at $55K each (without anciequipment or installation costs).

Costs are for traditional aerators and not for directional or improved t at ou d be g e cost hat would be hi

g

h

er in cost.

Cost for increased aeration does not include costs for extended supply powstarters, or costs to build new Motor Control Centers (MCCs).Assumed that WWTS will not need additional retention time to meet higher (no need for dredging or raising dikes) (no need for dredging or raising dikes).Did not include costs to comply with nutrient standards (if applicable to the if impacted due to increased nutrient addition.)

Clean Condensate Alternative

Assumed that CCA facilities could still utilize this compliance option (no capcollect HVLC systems)Did not include costs to conduct an updated CCA compliance demonstratio
Cost Estimate for ASB Conversions

Estimates to convert existing ASB systems to AS

Typical costs around $30 M -$35 M

Range of costs from $24 M - $54 M

E ti t th f ll i E

stima

tes assume the 

following:

Existing footprints can be used (no need to install conbasins)No need for primary treatment upgrades (can be as m$10 M – $15 M)Assumes that the system will not require diffused or bair (assumed that surface aerators are adequate)
Cost Estimate to treat to 94% : Comparison

(No additional collection required – 10.4/6.8 lb/ODTP t

EPA Estimate AF&PA 

Number of Facilities Affected 15 

Capital Cost ($M) $36 

Annualized Capital Cost ($M) $4.1 

Annual O&M Costs ( ) $M $0.15 

Annualized Cost ($M) $4.25 Cost

/Ton (Using 4092 tons

/yr)

$1,000

$1
Cost Impact Summary

Updated costs reflect additional analysis of compliance oand strategiesRefined ASB upgrade and energy costs are lower becauscertain point, facilities will install strippers rather than upthe WWTS

Overall the O&M costs are lowerNew steam strippers will require over $100 million in added capital 

Still 84 Still 84 units affected (down from 91 previously estimate

units affected (down from 91 previously estimate

more than 15 units EPA assumed

Overall conclusion regarding cost impacts is unchanged

High cost impacts and higher cost effectiveness ($16K/ton) Achieves marginal methanol reductions in largely rural areas.
Excess Emission Allowances
Excess Emission Allowances

Survey of Industry venting practices underwaySurvey questions shared with EPA for feedback Survey questions shared with EPA for feedbackWork Practices during venting events

Industry group working on compiling information on wpracticesDrafting up language related to emission minimization 
Attachment 3 

Cost Estimate for Increased Collection and Treatment 
Current Treatment Options for Kraft Condensate

Mills

Number of

Units

Stripping 43

Biological Treatment 39

Biological Treatment & Stripping 9

Recycle 5

Thermal Incinerator 1

CCA 6 38

CCA (dependent upon condensates or clean water

substitution) 6 34

Assumptions Units Notes

Stripper Capital Cost (Stand‐Alone Unit) $           7,400,000 $ 3

Stripper Upgrade (Integrated Unit) 5,800,00 $            0 $ 28

Stripper Upgrade (Stand‐Alone Unit) $           2,900,000 $ 27

New/Replaced Stripper Energy Rating 100 MMBtu/hr 1

Stripper Hours of Operation 8390 hrs/yr 7

Energy Cost 3 $/MMBtu 8

Incremental Energy Required for Stripper for

Treatment Increase only 10 MMBtu/hr 9

Stripper Energy Recovery 60 % 34

Additional Stripper Maintenance Costs for Existing

Strippers $               100,000 $/yr 11

Cost to Upgrade Aeration at WWTS (Assume

addition of 600 hp ‐ eight 75‐hp aerators) $               480,000 $ 33

Cost to Install 75 hp Aerator $                 60,000 $ 33

Power Cost 0.07 $                     hp/hr 3 ‐ ($0.10/kWh)

Annual Maintenance Cost for WWTS Upgrades $               220,000 $ 30

Nutrient Costs 60,00 $                 0 $/yr 15

Wastewater Treatment System Hours of Operation 8,76 $                   0 hrs/yr 35

Installation of HVLC System with Single Treatment

Device $         15,000,000 $ 19

Cost to collect additional condensates $           3,000,000 $ 13

Cost to convert collection compliance approach

from lb./ton to 65% $           1,000,000 $ 13

Capital Recovery Factor 0.094 32

ASBs that will covert to Strippers 40% 31

ASBS that will upgrade 40% 31

ASBS that will need no upgrades 20% 31

Increase Treatment Efficeincy to 94% with no Requirement for Additional Collection

Notes

Number of

Units

Affected Capital Cost

Annualized

Capital Cost

Annual Energy

Cost

Annual

Maintenance

Cost

Total

Annualized

Cost

Stripper Upgrade 20, 29 28 97,400,00 $           0 $         9,155,600 $     7,000,000 $          2,800,000 $    18,955,600

New Stripper Installation (WWTS Conversion) 16 115,440,00 $        0 $      10,851,360 $   15,700,000 $          3,120,000 $    29,671,360

Current Strippers (Energy Only) 24 $                         ‐ ‐ $                      $     6,000,000 $          2,400,000 $      8,400,000

Aeration 21 16 10,000,00 $           0 $            940,000 $     6,114,362 $          3,400,000 $    10,454,362

Nutrient Addition 21 16 $                         ‐ ‐ $                      ‐ $                  $             900,000 $        900,000

HVLC Collection to Single Treatment Device 24 0 $                         ‐ ‐ $                      ‐ $                 

Total Cost $       222,840,000 $      20,946,960 $   34,814,362 $       12,620,000 $   68,381,322

84

Increase Treatment Efficeincy to 94% with Increase Collection Requirements

Notes

Number of

Units

Affected Capital Cost

Annualized

Capital Cost

Annual Energy

Cost

Annual

Maintenance

Cost

Total

Annualized

Cost

Stripper Upgrade 20 28 97,400,00 $           0 $         9,155,600 $     7,000,000 $          2,800,000 $    18,955,600

New Stripper Installation (WWTS Conversion) 16 115,440,00 $        0 $      10,851,360 $   15,700,000 $          3,120,000 $    29,671,360

Current Strippers (Energy Only) 24 $                         ‐ ‐ $                      $     6,000,000 $          2,400,000 $      8,400,000

Aeration 21 16 10,000,00 $           0 $            940,000 $     6,114,362 $          3,400,000 $    10,454,362

Nutrient Addition 21 16 $                         ‐ ‐ $                      ‐ $                  $             900,000 $        900,000

HVLC Collection to Single Treatment Device 22 34 510,000,00 $        ‐ 0 $                  ‐ $                       ‐ $                 

Total Cost $       732,840,000 $      20,946,960 $   34,814,362 $       12,620,000 $   68,381,322

ATTACHMENT 5

Cost Estimate of Proposed Rules Changes to 40 CFR 63 Subpart S

Condensate Collection & Treatment

18 units reproted treatment efficiencies above 96% ‐ these units will only incur additional energy and  

O&M costs

25 units will require upgrades as well as additional energy and O&M costs

Description of Assumptions on how units are affected by the proposed

increase in treatment to 94% (no additional collection required).

20% of systems (7) able to meet the proposed 94% standard

40% of systemts (16) are able to upgrade their systems and comply

40% of systems (16) will choose to install a steam stripper

Three systems are above 96% treatment.  Assume 1/2 of the remaining units will require updgrades

to steam strippers.

3 units require stripper upgrades as well as additional energy and O&M costs

6 units will only incur additional energy and O&M costs for steam strippers

Assume unit is not affected  (no additional collection required)

Assume unit is not affected  (no additional collection required)
ATTACHMENT 5

Cost Estimate of Proposed Rules Changes to 40 CFR 63 Subpart S

Condensate Collection & Treatment

Notes

1.  Based on typical steam requirements at mills that currently have steam strippers.

2.  Assume recycle and thermal incinerator mills will not be affected by treatment increase.  Only affected by collection increase

4.  Assumes Mills that treat only with WWTS will require "New Strippers."  Mills that have strippers are included in the upgrade/replacement categories

5.  Mills that only treat with WWTS and do not install strippers will require WWTS improvements

6.  Note that CCA Mills are a subset of Mills that have another form of treatment.

8.  URS Memo to AF&PA, " Cumulative Cost Burden Analysis of Air Regulations Potentially Impacting the Forest Products Industry", August 2011

9.  Assumes energy requirement for additional stream is 10% of an existing unit, based on a need for a sustained increase of 2% treatment efficiency

10.  Mills will need to have an annual outage for stripper maintenance (10 days)

13.  Based on estimate from member company.  Costs does not include additional sampling, permitting, etc

14.  Will need to increase aerator hp by 25% to achieve an additional 2% in treatment efficiency

15.  Assume add Nutrients (Nitrogen and Phosphorus containing nutrients 1/quarter for upsets at a cost of $15 K/quarter

16.  Costs developed by Rich Lowe, URS Corporation, January 2012

17.  Assumes dredging material to allow for another day of retention time based on average flow of 19.2 MGD

18.  Average wastewater flow from ICR Data collected from NCASI

27.  Stripper upgrade costs based on cost from a AF&PA member facility for an upgrade to a non‐integrated stripper in 2010

34.  Based on typical energy recovery offsets from strippers.

35.  Wastewater treatment system run at all times.

28.  Assumed that the cost to upgrade an integrated stripper is double to upgrade a stand‐alone unit.  It is unknown if it is even possible to upgrade an

integrated stripper, or if another stripper would need to be installed.  These costs are a best estimate given the limited time for analysis.

EPA did not include any information  in the record describing  how EPA expected mills to comply with the new standards.  Therefore, AF&PA carefully

examined what would be  necessary to comply with the proposal.  It should be noted that all cost estimates in these comments are based on the best

information available  given the limited time to gather data during the 60 day comment period. These are based on conservative estimates of upgrades and

number of units affected  and not detailed mill by mill engineering estimates. Even with these caveats, the estimates are an order of magnitude higher than

EPA’s.  These estimates are somewhat different from those presented to OAQPS on January 12, 2012 as  AF&PA made further  refinements and gained more

information from member companies.  

24.  For increased treatment from 92% to 94% only for Phase I (no increase in collection), assume that all CCA Mills will be able to comply if only upgrade

their treatment devices.

23.  Assumes that all Mills that utilize the lb./ODTP collection approach will convert to the 65% collection approach.  Conversion based on cost from member

company.  Note that data was not available to determine the O&M costs for these systems.

11.  Assume must shutdown stripper for maintenance one additional time per year to maintain increased treatment efficiency.  Hydroblasating is

approximately $50K plus labor, materials, etc. (5 days)

20.  Based on EPA estimates of systems that will need to be upgraded, Memo from RTI to EPA, November 17, 2011, "Cost and Environmental and Energy

Impacts for Subpart S Risk and Technology Review.  Assumed all mills with only Stripper Treatment or stripper/recylce at or below 96% (23 mills) will need

upgrades.  Of the 6 mills with stripping/bio  ‐ 1/2 will need to upgrade their stripper.

22.  Assume all CCA Mills will need to install HVLC controls (assumes all CCA mills using lb./ODTP treatment approach at 4% vent allowance remains).  Note

that data was not available to determine the O&M costs for these systems.  From EPA's information, it appears the CCA approach for 4 mills will not be

affected.

21.  Based on all biological treatment systems requiring upgrades to meet 94% treatment, which equates to an Fbio for methanol of 96%.  Assume these

mills will need to increase aeration and nutrient addition.

12.  Assumes that existing WWTS have the electric capacity to install additional aerators (no new Motor Control Centers) and dredging will not be necessary

for installation.

19.  Cost ranges from $10‐20MM.  Assumes that 4% vent allowance remains and and the facility has an existing treatment device available to accept HVLC

gases.  One member notes that collection only of HVLCs from 2 washers cost approximately $16M.

3.  Based on cost estimate for stand‐alone stripper installation for member company in 1998 dollars adjusted to 2012 dollars.  Note that the cost assumes

that the facility has a treatment device that can accept stripper off‐gases and a new unit (i.e., thermal oxidizer) is not required.

7.  Based on the Stripper being down 15 days/yr.  With need to sustain a higher treatment efficiency, it will be necessary to clean preheaters or install spare

preheaters (equipment that will foul) in additional to the annual outage.

32.  RTI Memo "Costs and Environmental and Energy Impacts for Subpart S Risk and Technology Review," from Thomas Holloway, Katie Hanks and Corey

Gooden to EPA, November 17, 2011.

33.  Based on $50 K for aerator, Cable at $14/ft + $5/foot to install at an average length of 1000 feet.  This costs does not include costs for extended supply

power, motor starters, or coststo build new MCCs.

30.  An AF&PA member company calculated high level estimates for four facilities.  This was the average cost for aeration upgrades at those facilities.  Note

this estimate is not refined given the time to respond to EPA's comments.

29.   Based on a limited survey of AF&PA members, it is assumed that 10 of the currently installed strippers (52 total) are integrated rather than stand‐alone

units.  For these cost estimates, it is assumed that if upgrades are required, 20% of the units will be integrated and 80% of the units will be stand‐alone.

31.  Assume that 20% of existing WWTS can achieve 94% treatment consistently, 40% of systems will need upgrades, and 40% of systems cannot achieve

and will need to install steam strippers.
Assumptions Units Notes

HVLC Redundant Controls 5,000,000 $           $ 24

Install redundant collection/control systems to eliminate venting $          7,500,000 $ 25

Stripper Capital Cost $          7,400,000 $ 3

Notes

Number of

Units Affected Capital Cost

HVLC Redundant Control Costs 24 97 500,000,000 $                 

Redundant LVHC/HVLC Collection Systems 25 97 700,000,000 $                 

Back‐up Strippers 26 52 400,000,000 $                 

TOTAL $              1,600,000,000

Notes

25.  Redundant collection systems necessary to eliminate venting.  The cost per facility during MACT I Phase I was $5‐10 M.

26.  Assumes that all facilities with a stripper will need to install a back‐up stripper for control.

EPA did not include any information  in the record describing  how EPA expected mills to comply with the new standards.  Therefore,

AF&PA carefully examined what would be  necessary to comply with the proposal.  It should be noted that all cost estimates in these

comments are based on the best information available  given the limited time to gather data during the60 day comment period. These

are based on conservative estimates of upgrades and number of units affected  and not detailed mill by mill engineering estimates. Even

with these caveats, the estimates are an order of magnitude higher than EPA’s.  These estimates are somewhat different from those

presented to OAQPS on January 12, 2012 as  AF&PA made further  refinements and gained more information from member companies.

24.  Assumes all units will need to have a backup incineration device and this device is available (i.e., no  new incinerator, oxidizer, etc.)

ATTACHMENT 5

Cost Estimate of Proposed Rules Changes to 40 CFR 63 Subpart S

Elimination of Excess Emission Allowances
Capital costs ($) = 5.9749 x MGD0.8228 x 1,000,000

O&M costs ($) = 0.2546x MGD0.6969 x 1,000,000

Average Total Flow of WWTS 25 MGD Based on average flow from ICR Data

Increase in Flow for 92‐94% 0.54 MGD Calculated

Single Facility Total Impact

Capital Costs 3,617,750 $         $        56,436,898

O&M Costs 166,459 $            $          2,596,758

ATTACHMENT 5

Cost Estimate of Proposed Rules Changes to 40 CFR 63 Subpart S

Wastewater Treatment System Upgrade Costs Using EPA Methodology

Memo from RTI to EPA, November 17, 2011, "Cost and Environmental and Energy Impacts for Subpart S Risk and

Technology Review" contains the following equations on page 3 for estimating capital and O&M costs for systems that will

need to upgrade their WWTS.  Note that O&M costs include labor, chemicals, materials and energy.

Where MGD =

Total MGD of WWTS x (Proposed treatment efficiency standard/Current treatment efficiency standard) ‐ Total MGD of

WWTS