# 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 mee ting was requested in response to the Risk and

Technology Review (RTR) of the National Emissi on 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 Amer ica 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 basi s 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 revi ew of mills’ NEI revisions from EPA/SPPD.

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

# Attachment 1

Agenda – EPA/American Forest a nd 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 ProposalPulp & Paper Residual Risk and Technology ReviewPulp&PaperResidualRiskandTechnologyReviewProposalIndustry Meeting with OAQPSResearch Triangle Park,NC,May 2, 2012AgendaCost analysesCostanalysesExcess Emission AllowancesNext Steps/Wrap-up2Cost Estimates for Proposed IncreasedCostEstimatesforProposedIncreasedTreatment StandardsCost ConsiderationsWhat do facilities need todo to achieve 94% treatmentefficiencyAF&PA Members continue to evaluate systems and refine costs.Each update has been provided to EPA. These costs represent upto-date estimates.dateestimates.Costs assume that treatment systems must meet a new treatmentstandard of 94% without additional collection, i.e., they need toupgrade their control systems.For biological treatment systems demonstrating compliance usingfbio, a standard of 94% treatment efficiency translates to a 96%standard to account for other HAPs.All systems require a margin to ensure compliance overwidely varying conditions.4Cost Considerations (cont.)Will CCA Mills be able to utilize this option or willth d t ti f ll t?thedemonstrationfallapart?Conservative assumption of cost estimatesCCA mills will demonstrate compliance with the newcondensate treatment requirements without additionalcondensate collection and by implementing control systemupgradesCCA demonstration would have to be repeated if it is stillviable5Conclusions of further assessment to dateASB-based systems in the majority of configurations employedbasedsystemsinthemajorityofconfigurationsemployedtoday for cluster compliance will be severely challenged to meethigher treatment efficiency standards over the range ofconditions typicallyexperienced.y pCCA using WWT and particularly ASB technology will likely failto comply with higher treatment efficiencies; generally noadditional condensate is available for collection to offsetadditionalcondensateisavailableforcollectiontooffsetefficiency with tons treated6Facility Treatment Options &Upgrade AssumptionsTreatmentOption NumberofUnitsUpgradeAssumptionsStripper Only 43•Millsunder96%treatment efficiencywillneedtoupgradetheirunits.(25of43mills18unitsareabove96%).;•AllstripperswillhaveanincreaseinO&MCostBiologicalTreatmentOnly39•20%ofsystemsabletomeettheproposed 94%standard•40%offacilitiesareabletoupgradetheirsystems•40%offacilitieschoosetoinstallasteamstripperinadditiontocurrentl(ddi )controsuetoupgraeconstrantsBiologicalTreatment&Stripping9•Sixofthesesystemsareatorbelow96%.Assume1⁄2oftheunitsatorbelow96%willrequireupgradesto thesteamstrippers.•AllstripperswillhaveanincreaseinO&MCostR l5Adecyce•ssumenoupgradesrequiredThermal Oxidizer1•AssumenoupgradesrequiredTOTAL 97•Assume that 84 mills are affected, which excludes recycle,thermal oxidizer and 7 biological treatment systemsthermaloxidizer,and7biologicaltreatmentsystems Assumed that mills can still utilize the CCA option, but will n eed to upgrade their control systems and redemonstrate compliance with CCA via an IPT. This is a conservative a ssumption as it is expected that several CCA Mills will not be

able to utilize this option under this methodology7Cost Estimate to treat to 94% : Assumptions(No additional collection required – 10.4/6.8 lb/ODTP treatment)Stripper AssumptionsMore energy, trays, and steam contact areaNeed compliance marginunits with < 96% would need upgradeseedcompliancemargin–unitswith<96%wouldneedupgrades20% are integrated with evaporatorsAssume 10% downtime remains - no backupWastewater Treatment System Assumptionsp20% of existing facilities will be able to meet the proposed treatment standard40% of existing facilities will need to upgrade their systems with increased aerationand nutrient additionIncrease aeration by 600 hp (install eight 75-hp aerators) for each facilityncreaseaerationby600hp(installeight75hpaerators)foreachfacilityAdded nutrients may impact water quality standards40% of existing facilities impacted byupgrade constraints will be unable todemonstrate compliance solely with upgrades and will install steam strippersT f d t itF iliti tl l i ith th 92% tiTypes ofupgrade constraints–Facilities currently complyingwiththe92%optionwould switch due to the need to actually be at 96% to compensate for otherHAPsResidence time, nutrient loads, and solids loads limitations8Cost Estimate to treat to 94% : Strippers(No additional collection required – 10.4/6.8 lb/ODTP treatment)EPA Estimate8 stripper upgradesAF&PA Estimate28 stripper upgrades(96%8stripperupgradespp pg (and below)25 Strippers (onlytreatment device)$2.7 M/each3 Strippers for facilitieswith dual treatment (1/2 ofthe units at 96% andtheunitsat96%andbelow)$2.9 M/each for noni t t d itintegratedunits$5.8 M/each for integratedunits9Cost Estimate to treat to 94% : Biological Treatment(No additional collection required – 10.4/6.8 lb/ODTP treatment)EPA Estimate7 systems (at or belowAF&PA Estimate39 systems (all with7systems(atorbelow94%)39systems(allwithbiological treatment)7 systems will not requireany upgradesanyupgrades16 systems will requireupgrades16 systems will have tott t tiAssumed no newstrippersconvertto steam strippersCapital cost of strippers:$7 4M/ hCapital costs for WWTSrange from $1 – 4M/each$7.4M/eachCapital Cost of WWTS:$0.5 Meach/10Cost Estimate to treat to 94% : O&M Costs(No additional collection required – 10.4/6.8 lb/ODTP treatment)Strippers – Costs for all existing strippers (52 units)Increased energy: 10 MMBtu/hr x 8390 hr/yr x$3/MMBtu/ /y $ /Increased maintenance to maintain efficiency: one additional outage peryear at $100KStrippers – Costs for new strippers (16 units)Increased energy : 100 MMBtu/hr x 8390 hr/yr x $3/MMBtu x (1-60%)Assume 60% energy recoveryIncreased maintenance to maintain efficiency: two outages per year at$100KBiological Treatment Systems (16 units)Increased energy: $0.4M/year/facilityMaintenance costs for aerators: $220K/year/facilityMaintenancecostsforaerators:$220K/year/facilityCost for chemicals only (nutrient): $60K/year/facility11Cost Estimate to treat to 94%(No additional collection required – 10.4/6.8 lb/ODTP treatment)NumberofUnitsAffectedCapitalCosts($M)AnnualCapitalCosts($M)AnnualEnergyCosts($M)AnnualO&MCosts($M)($M)StripperUpgrade 28 $97$9$7 $3CurrentStrippers 24‐‐--$6 $3New Strippers 16 $115 $11 $16 $3WWTSUpgrades 16 $10$1$6 $3[WWTS Upgrades - EPAFlow Based][16] [$56] [$5] [$--1] [$31]NutrientAddition 16‐‐ ‐‐$1TOTAL84 $222[268]$21 [25]$35[29] $14[14] 1 Note that O&M costs incl de ene g costs fo EPA methodolog12

1

. Note that O&M costs incl u de ene r g y costs fo r EPA methodology



### .Cost Estimate to treat to 94% -(No additional collection required)Comparison of AF&PA and EPA Estimates for WWTSNumberofCapitalCostsAnnualAnnualTotalAnnualUnitsAffected($M)CapitalCosts($M)Energy+O&MCosts($M)Costs($M)EPA 16 $56 $5 $3 $8AF&PA 16 $10$1$9 $10EPA t ti t d b d th d t d 16 t i th t tiEPAcosts estimatedbasedonthe needto upgrade16systems usingthe costequationsidentified by EPA:Capital costs ($) = 5.9749 x MGD0.8228x 1,000,000O&M costs($)= 0.2546x MGD0.6969x 1,000000($),Average MGD for systems from ICR Data is 25 MGD.For a 2% treatment efficiency upgrade, theincrease in flow would be 0.54 MGD based onthe following EPA equation for increased flow:Flow Increase = MGD * (94/92)MGD13FlowIncrease=MGD*(94/92)-MGDCost Estimate to treat to 94% : Costs not Included orConservative Assumptions(No additional collection required)StrippersCosts for new Strippers assumes that the facility has atreatment device to burn stripper off-gases (SOGs).Boilers are not always suitable for these gases andBoilersarenotalwayssuitableforthesegasesandfacilities prefer to incinerate SOGs in a thermal oxidizer.With higher efficiencies, it may be necessary to installspare preheaters Costs for these units are not includedsparepreheaters.Costsfortheseunitsarenotincluded.Assumes that facilities will only need one additional 5 dayshutdown to maintain existing units at a higher efficiency.Assumes 10% downtime allowance remains. Costs forbackup strippers are not included.14Cost Estimate to treat to 94% : Costs not Included orConservative Assumptions(No additional collection required)Wastewater Treatment SystemsAssumed cost for each 75-hp aerator (installed) at $60K This is on the low side asAssumedcostforeach75hpaerator(installed)at$60K.Thisisonthelowsideasother members have purchased 50-hp aerators at $55K each (without ancillaryequipment or installation costs).Costs are for traditional aerators and notfor directional or improved mixing unitsthatwouldbehigher incost.at ou d be g e costCost for increased aeration does not include costs for extended supply power, motorstarters, or costs to build new Motor Control Centers (MCCs).Assumed that WWTS will not need additional retention time to meet higher standards(no need for dredging or raising dikes)(noneedfordredgingorraisingdikes).Did not include costs to comply with nutrient standards (if applicable to the facility andif impacted due to increased nutrient addition.)Clean Condensate AlternativeAssumed that CCA facilities could still utilizethis compliance option (no capital cost tocollect HVLC systems)Did not include costs to conduct an updated CCA compliance demonstration15Cost Estimate for ASB ConversionsEstimates to convert existing ASB systems to ASTTypical costs around $30 M -$35 MRange of costs from $24 M - $54 ME ti t th f ll iEstimates assumethefollowing:Existing footprints can be used (no need to install concretebasins)No need for primary treatment upgrades (can be as much as$10 M – $15 M)Assumes that the system will not require diffused or bubbledair (assumed that surface aerators are adequate)16Cost Estimate to treat to 94% : Comparison(No additional collection required – 10.4/6.8 lb/ODTP treatment)EPAEstimate AF&PAEstimateNumberofFacilitiesAffected 15 84Capital Cost($M) $36 $223AnnualizedCapital Cost($M) $4.1 $21AnnualO&MCosts($M$0.15 $47)Annualized Cost($M) $4.25 $68/$$CostTon(Using4092tons/yr)1,00016,70017Cost Impact SummaryUpdated costs reflect additional analysis of compliance optionsand strategiesRefined ASB upgrade and energy costs are lower because at acertain point, facilities will install strippers rather than upgradethe WWTSOverall the O&M costs are lowerNew steam strippers will require over $100 million in added capital costsStill 84units affected (down from 91 previously estimated)farStill84unitsaffected(downfrom91previouslyestimated)–more than 15 units EPA assumedOverall conclusion regarding cost impacts is unchangedHigh cost impacts and higher cost effectiveness ($16K/ton)Achieves marginal methanol reductions in largely rural areas.18Excess Emission AllowancesExcess Emission AllowancesSurvey of Industry venting practices underwaySurvey questions shared with EPA for feedbackSurveyquestionssharedwithEPAforfeedbackWork Practices during venting eventsIndustry group working on compiling information on workpracticesDrafting up language related to emission minimization plans20

# Attachment 3

Cost Estimate for Increase d Collection and TreatmentCurrent 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 ) 7,400,00 0 $ $ 3

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

Stripper Upgrade (Stand

‐ Alone Unit ) 2,900,00 0 $ $ 27

New/Replaced Stripper Energy Ratin g 100 MMBtu/hr 1

Stripper Hours of Operatio n 8390 hrs/yr 7

Energy Cost 3 $/MMBtu 8

Incremental Energy Required for Stripper for

Treatment Increase only 10 MMBtu/hr 9

Stripper Energy Recover y 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/h r 3

‐ ($0.10/kWh )

Annual Maintenance Cost for WWTS Upgrade s 220,00 0 $ $ 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 condensate s 3,000,00 0 $ $ 13

Cost to convert collection compliance approach

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

Capital Recovery Facto r 0.094 32

ASBs that will covert to Strippers 40% 31

ASBS that will upgrad e 40% 31

ASBS that will need no upgrade s 20% 31

Increase Treatment Efficeincy to 94% with no Requirement for Additional Collectio n

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 $ 9,155,60 0 $ 7,000,00 0 $ 2,800,00 0 $ 18,955,60 0 $

New Stripper Installation (WWTS Conversion ) 16 115,440,00 0 $ 10,851,36 0 $ 15,700,00 0 $ 3,120,00 0 $ 29,671,36 0 $

Current Strippers (Energy Only ) 24

‐ $

‐ $ 6,000,00 0 $ 2,400,00 0 $ 8,400,00 0 $

Aeration 21 16 10,000,00 0 $ 940,00 0 $ 6,114,36 2 $ 3,400,00 0 $ 10,454,36 2 $

Nutrient Addition 21 16

‐ $

‐ $

‐ $ 900,00 0 $ 900,00 0 $

HVLC Collection to Single Treatment Devic e 24 0

‐ $

‐ $

‐ $

Total Cost 222,840,00 0 $ 20,946,96 0 $ 34,814,36 2 $ 12,620,00 0 $ 68,381,32 2 $

84

Increase Treatment Efficeincy to 94% with Increase Collection Requirement s

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 $ 9,155,60 0 $ 7,000,00 0 $ 2,800,00 0 $ 18,955,60 0 $

New Stripper Installation (WWTS Conversion ) 16 115,440,00 0 $ 10,851,36 0 $ 15,700,00 0 $ 3,120,00 0 $ 29,671,36 0 $

Current Strippers (Energy Only ) 24

‐ $

‐ $ 6,000,00 0 $ 2,400,00 0 $ 8,400,00 0 $

Aeration 21 16 10,000,00 0 $ 940,00 0 $ 6,114,36 2 $ 3,400,00 0 $ 10,454,36 2 $

Nutrient Addition 21 16

‐ $

‐ $

‐ $ 900,00 0 $ 900,00 0 $

HVLC Collection to Single Treatment Devic e 22 34 510,000,00 0 $

‐ $

‐ $

‐ $

Total Cost 732,840,00 0 $ 20,946,96 0 $ 34,814,36 2 $ 12,620,00 0 $ 68,381,32 2 $ 

## 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% standar d

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 increas e

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

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 efficienc y

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 efficienc y

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 MG D

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 201 0

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 carefull y

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 membe r

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). Not e

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 ventin g 7,500,000 $ $ 25

Stripper Capital Cos t 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 MGD 0.8228 

# x 1,000,000

O&M costs ($)

= 0.2546x MGD 0.6969 

# 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 Facilit y 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