EPA-230/3-76-014
      ECONOMIC IMPACTS  OF  PULP AND
     PAPER INDUSTRY COMPLIANCE WITH
        ENVIRONMENTAL REGULATIONS
                    VOLUME Hi
               Appendices to Volume I
                    MAY 1977
           U. S. ENVIRONMENTAL PROTECTION AGENCY
               Office of Planning and Evaluation
                 Washington, D. C 02460

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 ECONOMIC IMPACTS OF PULP AND
PAPER INDUSTRY COMPLIANCE WITH
   ENVIRONMENTAL REGULATIONS
                 VOLUME III

           APPENDICES TO VOLUME I

                 Prepared by:

                Claire R. Canty
                Louise M. Firth
                Fred D. lannazzi
               Nelson R. Lipshutz
                Henry R. Martin
          Peter L. Oliver, Project Leader

                     of

              Arthur D. Little, Inc.


                  Report for

         Office of Planning and Evaluation
        U.S. Environmental Protection Agency


                  June 1977

               EPA-230/3-76-014

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                          TABLE OF CONTENTS
                                                                      Page
List of Tables                                                            vii

List of Figures                                                           xiii

APPENDIX A - MILL AND PROCESS CHARACTERISTICS                   A-1

    1.    Introduction                                                   A-1
    2.    Pulpwood Raw Materials                                         A-1
    3.    Debarking and Chipping                                          A-2
    4.    Mechanical Pulping                                              A-2
    5.    Kraft Pulping                                                  A-3
    6.    Soda Pulping                                                   A-5
    7.    Sulfite Pulping                                                  A-5
    8.    NSSC Pulping                                                  A-8
    9.    Pulp Deinking                                                  A-10
   10.    Recycled Pap_erboard                                            A-10
   11.    Nonintegrated Paper Mills                                        A-14
   12.    Mill Closure Trends                                              A-14

APPENDIX B-CURRENT TECHNOLOGY CHANGES                       B-1

    1.    Pulping Systems                                                B-1
    2.    Chemical Recovery                                              B-3
    3.    Bleaching                                                     B-4
    4.    Water Reuse                                                   B-5
    5.    Papermaking                                                   B-5
    6.    Wastepaper                                                    B-6

APPENDIX C - CRITERIA FOR ASSIGNING MILLS TO PROCESS/
              PRODUCT SECTORS                                     C-1

    1.    Multiple Pulp Mills                                              C-1
    2.    Single Pulp Mills                                                C-1
    3.    Nonintegrated Paper and Paperboard Mills                          C-1

APPENDIX D - SUPPORTING DATA FOR ECONOMETRIC ANALYSIS        D-1

    1.    Determinants of Supply and Demand                               D-1
    2.    Econometric Models                                             D-6
    3.    Limitations of Econometric Analysis                               D-9
                                     in

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                  TABLE OF CONTENTS (Continued)

                                                                   Page

APPENDIX E - SUPPORTING DATA FOR COSTS OF COMPLIANCE          E-1

    E-1    AIR EMISSIONS CONTROL                                  E-4

          A.  Control Regulations                                     E-4
          B.  Cost Models, Kraft Mills                                  E-4
          C.  Cost Models, Power Boilers                               E-15
          D.  Existing Industry Aggregate Cost                           E-15
          E.  New Mills, Unit Costs for Selected Examples                  E-21

    E-2    WATER EFFLUENT CONTROL                              E-25

          A.  Control Regulations                                     E-25
          B.  Data Base — The Development Documents                   E-25
          C.  Adjustment of the Data Base                              E-33
          D.  Existing Industry Aggregate Cost                           E-36
          E.  New Mill Unit Costs for Selected Examples                   E-37

    E-3    OSHA NOISE CONTROL                                    E-39

          A.  Control Regulations                                     E-39
          B.  Cost of Compliance                                     E-40

    E-4    COMPARISON AND  DISCUSSION OF PUBLISHED COSTS OF
          COMPLIANCE WITH ENVIRONMENTAL CONTROLS            E-43

          A.  Air Emission Control Costs                               E-43
          B.  Water Effluent Control Costs                              E-46

APPENDIX F - SUPPORTING MATERIAL FOR NEW MILL COST
             MODELS                                              F-1

          1.  Basis of Cost Calculations                                F-1
          2.  Capital Requirements                                    F-32
          3.  Operating Cost Considerations                             F-33
          4.  Supplementary Uses of New Mill Models                     F-35

APPENDIX G - FIELD INTERVIEW GUIDE FOR MILL CLOSURE
             ANALYSIS                                            G-1
                                   IV

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                   TABLE OF CONTENTS (Continued)

                                                                    Page

APPENDIX G - (Continued)

    I      Description of Contact                                       G-1
    II      Identification                                               G-1
   III      Purpose of Call                                              G-1
   IV      Current Status of Mill                                         G-1
    V      Pollution Control Cost Situation                                G-2
   VI      State/Local Pollution Control Requirements                       G-2
  VII      Future Plans                                                G-2
 VIII      For Multi-Mill Companies Only                                 G-2

APPENDIX H - SUPPORTING DATA FOR CAPITAL IMPACT ANALYSIS      H-1

    1.     Flow of Funds Model                                         H-1
    2.     Aggregate External Financing Model                             H-19

APPENDIX I - SUPPORTING DATA FOR INTERNATIONAL COST
             DIFFERENCES FOR MAJOR PULP AND PAPER
             PRODUCTS                                             1-1

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                                LIST OF TABLES

Table No.                                                                    Page

  A-1    Groundwood Process — Regional Distribution, 1975                     A-4

  A-2    Unbleached Kraft Process - Regional Distribution, 1973                 A-6

  A-3    Bleached Kraft Process — Regional Distribution 1975                    A-7

  A-4    Regional Distribution of Sulfite Mills, 1975                            A-9

  A-5    Regional Distribution of NSSC Process, 1974                           A-11

  A-6    Regional Distribution of Combined NSSC-Kraft Process, 1974            A-12

  A-7    Regional Distribution of Deinked Pulp MilSs, 1975                      A-13

  A-8    Regional Distribution of Recycles Paper Board Mills, 1973               A 15

  A-9    Regional Distribution of Printing, Writing, and Related Paper
         Mills, 1975                                                          A-16

  A-10  Regional Distribution of Nonintegrated Tissue Mills, 1975               A-17

  A-11   U.S. Paper Industry Mill Closures, 1965-1974                           A-18

  E-1    Product Sectors Included in Studied Process Categories                  E-2

  E-2    State Standards for Air Emissions from Pulp Mills in Selected States       E-5

  E-3    Proposed Federal Air Emission and Monitoring Requirements for
         New Kraft Mills                                                      E-6

  E-4    Standards of Performance for New Steam Generators Having
         Capacity Greater than 250 MM Btu/Hr                                 E-7

  E-5    Control Costs for Recovery Boilers                                    E-9

  E-6    Control Costs for Lime Kiln System                                   E-11

  E-7    Control Costs for Smelt Tank System                                  E-13

  E-8    Control Costs for Digester and Multiple-Effect Evaporators               E-14
                                        Vll

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                          LIST OF TABLES (Continued)

Table No.                                                                   Page

  E-9    Control Costs for the Brown Stock Washers                            E-14

  E-10   Control Costs for Black Liquor Oxidation                             E-16

  E-11   Control Costs for Condensate Stripper                                E-16

  E-12   Control Costs for Power Boilers                                      E-17

  E-13   Summary of Air Control Unit Cost Estimates, Existing Kraft Mills       E-19

  E-14   Air Control Costs to Existing Industry by Process Sub-Category
         and Size                                                           E-20

  E-15   Summary of Air Control Cost Estimates for New Pulp Mill               E-22

  E-16   Air Control Costs, New Mill Sources, by Product Sector                 E-23

  E-17   EPA Water Effluent Guidelines, BPT (1977)                            E-26

  E-18   EPA Water Effluent Guidelines, BAT (1983)                           E-27

  E-19   EPA Water Effluent Guidelines, NSPS                                 E-28

  E-20   Comparison of the Initial and Revised BPT Water Effluent
         Guidelines for Selected Process Categories                             E-34

  E-21   Estimated Water Effluent Control Costs for the Existing Industry
         by Process Sub-Categories                                           E-38

  E-22   Summary Comparison of URS and ADL Cost of Compliance
         Estimates                                                          E-44

  E-23   Comparison of Water Effluent Control Costs for Existing Industry
         for BPT Developed by Hazen & Sawyer and ADL                       E-48

  E-24   Comparison of the BPT Water Effluent Guidelines Used by Hazen &
         Sawyer Inc., and Revised by EPA for Selected Process Categories         E-50

  E-25   Comparison of the BAT Water  Effluent Guidelines Used by Hazen &
         Sawyer Inc., and Revised by EPA for Selected Process Categories         E-51

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                          LIST OF TABLES (Continued)

Table No.                                                                  Page

  E-26   Comparison of NSPA Water Effluent Guidelines Used by Hazen &
         Sawyer Inc., and Revised by EPA for Selected Process Categories         E-52

  E-27   Comparison of Investment and Operating Cost Estimates for Water
         Effluent Control (Selected Examples)                                 E-54

  E-28   Effluent Treatment Technology for Nonintegrated Fine Paper Sub-
         category Used by Hazen & Sawyer and EPA Development
         Documents                                                       E-56

  E-29   Summary of the Technology Used by Hazen & Sawyer and ADL
         to Calculate the Aggregate Costs for BPT                             E-58

  F-1    Summary of Capital Investments and Operating Costs for New Mill
         Models                                                           F-2

  F-2    Format Used for Annual Cash Flows for the Manufacture of
         Selected Products                                                  F-3

  F-3    Summary of Capital and Operating Costs for the Manufacture of
         Unbleached Kraft Linerboard                                       F-4

  F-4    Summary of Capital and Operating Costs for the Manufacture of
         Unbleached Kraft Bag Paper                                        F-5

  F-5    Summary of Capital and Operating Costs for the Manufacture of
         NSSC Corrugating Medium                                         F-6

  F-6    Summary of Capital and Operating Costs for the Manufacture of
         Recycled Boxboard, 18 Pt. Clay Coated                               F-7

  F-7    Summary of Capital and Operating Costs for the Manufacture of
         Jute Linerboard                                                    F-8

  F-8    Summary of Capital and Operating Costs for the Manufacture of
         Bogus Medium                                                    F-9

  F-9    Summary of Capital and Operating Costs for the Manufacture of
         Gypsum Linerboard                                                F-10
                                       IX

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                         LIST OF TABLES (Continued)

Table No.                                                                  Page

  F-10   Summary of Capital and Operating Costs for the Manufacture of
         SBS Board                                                        F-11

  F-11   Summary of Capital and Operating Costs for the Manufacture of
         Bond Paper (Rolls)                                                 F-12

  F-12   Summary of Capital and Operating Costs for the Manufacture of
         Book Paper (Rolls)                                                 F-13

  F-13   Summary of Capital and Operating Costs for the Manufacture of
         Tissue Paper,  Jumbo Rolls                                         F-14

  F-14   Summary of Capital and Operating Costs for the Manufacture of
         Tissue Papers, Converted (50% Toilet, 40% Towel, 10% Napkin)         F-15

  F-15   Summary of Capital and Operating Costs for the Manufacture of
         Deinked Tissue Paper (Jumbo Rolls)                                 F-16

  F-16   Summary of Capital and Operating Costs for the Manufacture of
         Deinked Tissue, Converted (50% Toilet, 40% Towel, 10% Napkin)       F-17

  F-17   Summary of Capital and Operating Costs for the Manufacture of
         Newsprint                                                        F-18

  F-18   Summary of Capital and Operating Costs for the Manufacture of
         Recycled Newsprint                                                F-19

  F-19   Summary of Capital and Operating Costs for the Manufacture of
         Sulfite Dissolving Pulp                                              F-20

  F-20   Summary of Capital and Operating Costs for the Manufacture of
         Bleached Kraft Softwood Market Pulp                               F-21

  F-21   Summary of Capital and Operating Costs for the Manufacture of
         Southern Bleached Kraft Softwood Slush Pulp                        F-22

  F-22   Summary of Capital and Operating Costs for the Manufacture of
         Northern Bleached Kraft, Softwood Slush Pulp                        F-23

  F-23   Summary of Capital and Operating Costs for the Manufacture of
         Southern Bleached Kraft Hardwood Slush Pulp                        F-24

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                         LIST OF TABLES (Continued)

Table No.                                                                  Page

  F-24   Summary of Capital and Operating Costs for the Manufacture of
         Northern Bleached Kraft Hardwood Slush Pulp                        F-25

  F-25   Summary of Capital and Operating Costs for the Manufacture of
         Semi-Bleached Kraft Softwood Slush Pulp                            F-26

  F-26   Summary of Capital and Operating Costs for the Manufacture of
         Groundwood Slush Pulp                                            F-27

  H-1    Companies Included in Industry Composite                           H-3

  H-2   Pro-Forma Balance Sheet of the U.S. Pulp, Paper, and Paperboard
         Industry (Excluding Woodlands and Converting Operations) for the
         Period 1966-1975                                                 H-4

  H-3   Pro-Forma Operating Statement of the U.S. Pulp, Paper and Paper-
         board Industry (Excluding Woodlands and Converting Operations)
         for the Period 1966-1975                                           H-5

  H-4   Pro-Forma Sources of Funds of the U.S. Pulp, Paper and Paper-
         board Industry (Excluding Woodlands and Converting Operations)
         for the Period 1966-1975                                           H-6

  H-5   Forecast U.S.  Demand for Pulp and Paper (Excluding Dissolving
         Pulp) Under Alternative Growth Rate Assumptions Assuming 1975
         Real Prices                                                        H-11

  H-6A  Forecast Capacity of the U.S. Pulp and Paper Industry for the
         Period 1976-1985 Assuming  High Capacity Growth Rate                H-13

  H-6B  Forecast Capacity of the U.S. Pulp and Paper Industry for the Period
         1976-1985 Assuming Midrange Capacity Growth Rate                  H-14

  H-6C  Forecast Capacity of the U.S. Pulp and Paper Industry for the Period
         1976-1985 Assuming Low Capacity Growth Rate                      H-15

  H-7A  1975 Capacity of the U.S. Pulp and Paper Industry Still in Place at
         End of Year for the Period 1976-1985 Assuming Water Pollution
         Control Induced Closures do not Occur                              H-16
                                        XI

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                         LIST OF TABLES (Continued)

Table No.                                                                  Page

  H-7B  1975 Capacity of the U.S. Pulp and Paper Industry Still in Place at
         End of Year for the Period 1976-1985 Assuming Water Pollution
         Control Induced Closures do Occur                                  H-17

  H-8    Assumed Distributions and Costs of Alternative Sources of New
         Capacity in the U.S. Pulp and Paper Industry 1976-1985                H-18

  1-1     Environmental Costs Reported in 1972 OECO Survey                  1-1

  I-2     Derivation of Swedish Wood Costs                                   I-2

  I-3     Derivation of Newsprint Wood Costs                                 I-3

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                              LIST OF FIGURES

Figure No.                                                                  Page

  D-1    Demand Schedule                                                  D-1

  D-2    Marginal Cost and Average Cost                                      D-4

  D-3    Supply Curve                                                      D-4

  D-4    Intersection                                                        D-5

  E-1    Alternative Treatment Systems                                       E-30

  F-1    Definition of Slush  Pulp Cost and Allocation of Cost of Shared
         Facilities for Integrated Mill Complex (Bleached Kraft Model)           F-31

  H-1    Components of Working Capital                                      H-10
                                        Xlll

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                                   APPENDIX  A

                    MILL AND PROCESS CHARACTERISTICS
1. Introduction
     The major paper industry process steps are pulping (the separation of whole wood into a
fibrous mass) and paper making (the formation of discrete fibers into a web, or sheet of paper or
paperboard). In addition the paper-making process may include additional steps such as sizing,
coating and calendering, followed by finishing steps such as slitting, rewinding and sheeting.

     Pulping and paper making utilize four basic ingredients: fiber, water, energy and chemicals.
Wood remains the dominant fiber source, followed by wastepaper and small amounts of other
fibers such as cotton and asbestos. Water is used as a diluent for the pulping and bleaching
chemicals, washing the pulp and transporting it through the mill into the paper-making oper-
ation. All pulp and paper facilities are being pressured by increasingly stringent water pollution
control regulations to reduce their water usage rate.

     Most mills' energy needs are wholly or partially filled by purchased electricity and fuel;
however, most of the integrated  chemical pulping facilities fill a large portion of their energy
needs by burning the organic wastes from their pulping operations. Chemical requirements and
the ability to recover chemicals from process wastes depend upon the type of pulping process
employed.

2. Pulpwood Raw Materials
     Wood is delivered to the pulp mills in various forms: as logs (generally small diameter), as
chips from off-site shipping operations, and as chip, slab or sawdust residues from plywood and
sawmills. Most companies derive at least a portion of their wood from their own timberlands, but
also rely heavily upon purchased wood from private land owners or federal and state timberlands.
Pulpwood is now delivered almost exclusively by truck and rail, since water drives have become
uneconomical or unlawful.

     The industry subdivides its wood requirements into two general categories: softwood (from
coniferous or needle-bearing trees); and  hardwood (from deciduous broadleaf trees) to reflect
mainly the proportional contents of cellulosic fibers and lignin (the substance which binds the
fibers together). Both types,  however, vary  greatly in hardness  and density from species to
species.

     Softwood is used primarily in products where high strength is required; namely, for liner-
board and packaging papers, and for producing groundwood pulp. Because it is 30-100% stronger
than hardwood and traditionally in abundant supply, softwood has been the dominant pulpwood
source. Hardwood is used nearly exclusively in NSSC pulp and as a blending pulp in nearly all of
the bleached paper and paperboard products. While its shorter fiber length makes it weaker than
softwood, hardwood has the advantage of higher density and low lignin content which increases
its pulp yield for a given volume of wood.  Hardwood also provides better smoothness and opacity
than softwood — qualities which are particularly important in printing papers. Finally, hard-
woods have become more abundant and lower-cost than softwoods. For all the above reasons, the
industry has been increasing its use of hardwoods.


                                          A-l

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3.  Debarking and Chipping
     Debarking is the first process step for all round-wood pulpwood as it enters the pulp mill.
The two principal methods are steel-drum and hydraulic debarking. The barking drum (a large
open-ended steel drum about 10-12 feet in diameter and 45 feet long) is one of the oldest and still
most popular methods. The drum rotates the logs slowly, and most of the work is done by the
tumbling of logs against one another. Thus, the power requirement is minimized, but the drum
debarkers have the disadvantage of roughing the log ends, causing dirt to become imbedded
which in turn creates dirt problems in the pulping step.

     Hydraulic barkers blast off the bark under a high-pressure water jet as the log is rotated.
These are especially effective for barking the large coniferous logs found principally in the West.
However, use of the technique is likely to diminish because of its high energy requirements, water
pollution throw-off which adds to the pulp mill effluent discharge,  and because the process
requires a relatively narrow range of tree diameters for optimum efficiency.

     After debarking, the logs that are to be used for chemical and certain types of mechanical
pulping are reduced to chips by a rotating knife device. Chipping improves the rate of cooking
liquor penetration during chemical pulping  and is also required for the refiner groundwood and
thermomechanical pulping processes  which will be described later.  The added cost (mainly
energy) of chipping is avoided if the mill uses residues from lumber and plywood mills which are
generally provided in chip form. Sawdust residues from these mills can also be used as pulpwood
for certain products.

     Some thin-barked wood species can be chipped with their bark on,  and used in the dark-
colored products produced by the kraft and NSSC processes. Similarly, some of the sawmill and
plywood mill residues include a fairly high bark content which can be tolerated particularly in the
kraft pulping process. Uniformity in chip size is important in chemical pulping. Therefore, before
entering the  process the chips  are screened to separate those of desirable size from oversize
material and  sawdust. The oversize material is crushed and rescreened, and the sawdust, if it is
not suitable for pulping, is normally used for fuel.

4.  Mechanical Pulping
     Mechanical pulping is the simplest method of producing wood pulp. It consists of two
principal  physical methods  of producing groundwood pulps. In the older technology, stone
grinding, logs are ground on large grind stones. The newer technology which is gaining rapid use is
chip refining or refiner groundwood. The process converts pulp wood chips to groundwood pulp,
using attrition mills consisting of counter-rotating metal shearing discs. Refiner groundwood is
generally preferred over stone groundwood because it yields longer fibers and thus stronger paper.
Another mechanical  process, thermomechanical pulping, offers the potential of providing even
stronger pulps than refiner groundwood; this will be discussed later under  New Technology.

     Virtually all  groundwood  pulp is produced from softwood raw materials: spruce in the
Northeast, pine in the South and Douglas  fir and hemlock on the West Coast. Aspen, a  low-
density hardwood, is used for relatively small amounts of groundwood production in the North
Central region. Most groundwood is produced and consumed in integrated pulp/paper mills.

     Compared with chemical pulping, groundwood pulping requires a higher net power  con-
sumption, and it provides a shorter pulp fiber owing  to the considerable fiber damage caused by
grinding. The pulp produces a relatively weak paper that discolors easily on exposure to light. On

                                          A-2

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the other hand, groundwood provides a much higher yield, converting some 95% of the wood into
pulp, compared to about a 509c yield for the bleached draft pulp process. Another noteworthy
advantage of the  groundwood process is that it produces virtually no on-site air pollution and
generates much lower water pollution, owing to its higher pulp yield, than the chemical pulping
processes.

     Groundwood's strength problem is compensated for by blending long fiber chemical pulp
prior to the paper-making stage. Its short fiber length helps to provide a smooth printing surface
for products like  newsprint  and  uncoated groundwood  printing  papers,  the two principal
applications.

     Table A-l shows the regional and size distributions  for the U.S. groundwood mills. The
Northeast (primarily Maine) ranks second to the  South in capacity; both regions  provide an
ample supply of  softwood and relatively low-cost electricity.  It should be noted  that  these
ingredients are also plentiful in Canada, which produces roughly twice the amount of groundwood
pulp and paper as the United States. Most small  groundwood  mills are located in  the North-
eastern and North Central regions. These are engaged primarily in producing uncoated ground-
wood papers which bring a somewhat higher price  and serve smaller, more specialized markets
than newsprint. Newsprint is almost entirely produced by  the larger mills, most of which also
produce bleached kraft pulp  and hence are included under the latter process category in this
analysis.

5.  Kraft Pulping
     The kraft process represents the dominant pulping method in the United States in terms of
production tonnage. One of its chief advantages is that it can be used to pulp the entire spectrum
of wood species, including both the softwood and hardwood varieties. The process is commonly
termed the  sulfate  process because sodium sulfate traditionally has  been used as  a make-up
chemical. The kraft process employs a water solution of sodium sulfide and sodium hydroxide to
dissolve the lignin and pentasan sections of the wood while leaving the cellulose portion. Typi-
cally, over 95'r of the lignin is removed; however, the cooking liquor also insolubilizes  some of the
cellulose from the wood. These losses contribute  to a relatively low pulp yield. The  cooking
process takes place in high-temperature-batch or continuous-reactor vessels, after which the pulp
is separated from  the cooking liquor and washed.

     The waste liquor from the pulping step is fed to a kraft recovery furnace, which encompasses
incineration of the dissolved  organic chemicals and  recovery and reconstitution of the sodium
sulfide and sodium hydroxide, which are recycled to the pulping step. Incineration,  recovery of
chemicals and recycle to the  process are an economic necessity in kraft pulping because of the
high chemical loadings that are required. The incineration process, however,  creates the signifi-
cant air pollution and odor problems associated with the kraft mills. Pulp washing  and partic-
ularly pulp bleaching, if it is included, also cause a  sizable water pollution problem.

     The objective of bleaching is to produce a whiter and brighter pulp  stock by removing
residual lignins and other dark-colored residues in  the pulp. Kraft pulp  is relatively difficult to
bleach. Bleaching involves a multistage process generally employing a series of chlorine, chlorine
dioxide and  sodium  hypochlorite bleaching stages,  each of which is  followed  by a caustic
extraction step, after which the pulp is given a final wash.
                                           A-3

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                                       TABLE A-l
                  GROUNDWOOD PROCESS     - REGIONAL DISTRIBUTION, 1975

                                      No. of Mills
 Size   tpd          Northeast      No.  Central      South      West      Total


 30-100                  2               3             016


 101-350                 7               5             1          3        16


 351-800                 1               -             -          -         1
 Total                  10               8             1          4        23
                                                          (2)
                              1974  % of Capacity Tonnage
                       26.3            13.4          43.8       16.4      100.0
   Includes chemi-mechanical mills.
(2)
   Includes groundwood produced in multi-process mills   (API,  Paper,  Paperboard,
   Wood pulp capacity, 1974-1977) .


 SOURCES:   • Lockwood's Directory of the Paper & Allied Trades, 1975.
           • Industry Sources.
                                          A-4

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     Kraft pulp is used in a wide variety of paper and paperboard products including linerboard,
unbleached kraft  packaging paper, printing and writing paper, tissue, bleached paperboard and
as a blending pulp with groundwood to produce newsprint and uncoated groundwood paper.

     Table A-2 shows the size and regional distribution of mills that produce only unbleached
kraft pulp. All are integrated to the production of unbleached kraft paperboard (mainly liner-
board) and/or unbleached kraft bag and sack papers. Unbleached kraft pulp mills which also
produce  bleached kraft  pulp  were placed under  the bleached category  in this study, since
bleaching is the  most serious cause of  their water pollution problems. The table indicates a
dominant concentration of unbleached kraft mills in the South. Considering that the distribution
includes the largest mills, the total spread in mill sizes is relatively small. This pattern is caused
by the fact that the kraft pulping is a relatively new process, having been initiated in this country
in the 1930's, and that the process economics benefit importantly from large-scale operations.

     Table A-3 shows a corresponding  size distribution for  bleached  kraft pulp mills. The
bleached pulp mill category includes "complex" mills that produce unbleached kraft pulp and
other types of pulping,  along with  bleached kraft.  The  table indicates that these mills  are
somewhat smaller and are distributed more evenly than the unbleached kraft mills. A significant
amount of bleached pulp production in the  Northeast  and North Central regions  primarily
reflects the production of hardwood pulp for tissue and printing papers and market pulp. With
the exception of a few mills that produce market pulp exclusively, most of the bleached  kraft pulp
mills  are integrated  to  on-site paper  and  paperboard  production.  Such products include:
bleached paperboard, printing papers, tissue and newsprint.

6.  Soda Pulping
     Developed in 1851-1865, the soda process was the original method of chemically  pulping
wood. It  derived its name from the use  of caustic soda as the pulping reagent. The cost of the
reagent made it necessary to recover and reuse the alkali in the  residual liquor. It was sub-
sequently found that the presence of sodium sulfide, in addition to caustic soda in the cooking
liquor, allowed the pulping to proceed more rapidly and thus provide a less degraded pulp. This
discovery led to the sulfate or kraft process and to a rapid decline in the use of the soda process.

     Currently, only three U.S.  mills are employing  the soda process; they are  located in New
York, Tennessee,  and Louisiana. The Louisiana mill pulps bagasse (sugar cane), while the other
two mills use mainly hardwood pulpwood. All three mills produce printing and writing papers.

     The soda process creates water  pollution problems which are of about the same magnitude
as that of the bleached kraft pulp process. Its air pollution problems, however, are significantly
less because it requires no sulfur.

7.  Sulfite Pulping
     The acid sulfite process is also a relatively  old one, having been discovered in  1874. It
became the most  important chemical pulping process, until being overtaken by the kraft process
in 1937.

     The original calcium base process involved burning sulfur to sulfur dioxide and reacting the
gas with limestone (calcium carbonate) to form the cooking liquor. Batch digesters  lined with
acid-resistant brick are employed for the pulping, which is carried out under heat and pressure.
                                          A-5

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                               TABLE A-2

         UNBLEACHED KRAFT PROCESS - REGIONAL DISTRIBUTION,  1973
(Mills

Size tpd
200-499
500-999
1000-1399
1400-2000

Producing Unbleached Kraft Without Bleach Facilities)
No. of Mills
Northeast No. Central South West
- 4 1
- 12 1
51
4
25 3


Total
5
13
6
4
28
                                      % of Capacity Tonnage *

                                          1.2         81.5    17.1
100.0
* Includes unbleached kraft produced in multi-process mills.  American Paper
  Institute Capacity Survey 1973-1976.
SOURCES:  • Lockwood's Directory of the Paper & Allied Trades,  1975.
          • Industry Sources.
                                      A-6.

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                              TABLE A-3
          BLEACHED KRAFT PROCESS - REGIONAL DISTRIBUTION 1975
No. of Mills
1
Size tpd
150-499
500-999
1000-1600
Total

Northeast No. Central
5 5
6 2
_ _
11 7

South
6
19
21
46

West
4
8
3
15

Total
20
35
24
79
                                    1974 - % of Capacity Tonnage
                             (API, Paper, Paperboard, Wood Pulp Capacity
                              1974-1977)

                          10.7                6.1      68.9   14.3  100.0
Total Kraft Pulp Capacity.
SOURCE:  •  Lockwood's
         •  Industry Sources
                                  A-7

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     Unbleached sulfite  pulp, unlike other unbleached chemical pulps, has a relatively light
color and can be bleached by comparatively simple two- or three-stage bleach methods. On the
other hand, it produces a relatively weak pulp. Therefore, its chief applications are in bleached
printing/writing papers, tissue, and dissolving pulp. Its cooking time, final temperature, and acid
concentration are selected in relation to the final product. For example, dissolving pulp requires
cooking out most of the hemicellulose content, and this adds to the cooking time as well as to the
water effluent loadings.

     The sulfite process' chemical requirements and costs are far lower than for the kraft process;
hence sulfite liquors traditionally have been discarded without treatment. With the advent of
pollution abatement regulations, however, most sulfite pulp mills have installed chemical recov-
ery or  incineration units to either  recycle their pulping chemicals, generate  energy, or  both.
Traditionally, relatively inexpensive calcium was the only cooking liquor base  used; but recently,
sodium,  magnesium and ammonia-based liquors have  been employed, particularly in North
America and Scandinavia. These bases cost four to five times more per ton of pulp than calcium;
but  in addition to easier chemical recovery and reduced stream pollution,  these also  provide
reduced cooking time, more marketable by-products, and greater brightness.

     Currently, there are still 14 out of 30 U.S. sulfite mills  that do  not  have chemical in-
cineration or recovery  units.  Since  installation of an  incineration/recovery unit entails a large
capital expenditure which may not  be economically justifiable  in the case of a small mill, mills
without chemical recovery systems received special attention in the mill closure analysis. Four of
the above fourteen mills use a substantial amount of their sulfite liquor to produce by-products
such as road binders, or raw materials to produce vanilla, yeast, alcohol, insecticides and inks.
By-product recovery both reduces  their water pollution  loadings and  increases the revenue.
However, there is an insufficient, market for the  by-products for all sulfite mills to  reduce their
water pollution problem in this manner.

     Table A-4 shows the 1975 regional distribution of sulfite pulp mills. Two mills have closed
since 1973. Capacity is split about evenly between the West and the East, but the average mill
size is much smaller in the East.

8. NSSC Pulping
     The neutral sulfite semichemical process combines a light chemical treatment — to achieve
partial softening of the fibers — with mechanical refining to complete the fiberization. The
process is used  almost  exclusively to convert hardwood pulpwood into a  special high-yield pulp
for the manufacture of corrugating medium, the  fluting material in corrugated containers. Pulp
yield is high, 65-90% of the pulpwood, since only part of the lignin is removed. The chemical
pretreatment reduces the amount of power required  in comparison to  groundwood pulp and
increases the average fiber length and thus the strength. The NSSC process also lends itself to use
in relatively small mills, since it requires a lower  capital investment for efficient operations than
either a chemical or a groundwood pulp mill.

     The pollution problems  associated with NSSC pulping are similar to those of the sulfite
process;  however, they are not as extensive owing to the lower chemical concentrations. Tradi-
tionally,  a sodium sulfite pulping base has been used, but this is gradually being displaced by
ammonia and magnesium which can be more easily recovered. The sodium base has no economic
recovery system, although it can be fed into the kraft recovery furnace at an adjacent kraft mill.
                                           A-8

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                                  TABLE A-4
               REGIONAL DISTRIBUTION OF SULFITE MILLS.  1975
   Size  (tpd)

   80-149

   150-299

   300-499

   500-850

     Total
(No. of Mills)
Northeast North Central
0 2
1 5
1
2 1
4 8

South West
5
3
1 3
4
1 15
Total

  7

  9

  5

 _7	

 28
SOURCES:    •   Lockwood's  Directory of the Paper & Allied Trades,  1975
            •   Industry Sources
                                     A-9

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In some cases, specially designed incineration systems are employed, producing an inert ash in
substantial quantities which must be either sold or discarded. There are five NSSC mills that
have no recovery or incineration systems or that are not tied into municipal treatment systems.
These were given special attention in ADL's closure screening analysis, because investment in
chemical  incineration and recovery  systems  requires substantial capital, which may not  be
justified if the mill is marginally profitable.

     Tables A-5 and A-6 show the regional distribution of the NSSC pulp mills, all of which are
integrated to the on-site production of corrugating medium. There is a relatively even geogra-
phical distribution compared with unbleached kraft pulp, owing to the availability of hardwood
pulpwood throughout most parts of the country. As would be expected, the NSSC mills, com-
bined with kraft mills, have a much larger total scale of operation and are primarily situated in
the South and West, as is the kraft pulping industry. Regionally 46%  of all NSSC pulp is
produced  in the South, 33%  in the  North Central region, 11% in the West, and 10% in the
Northeast.

9.  Pulp  Deinking
     Deinking processes are  used to convert printed forms of wastepaper to a white  pulp
substitute. Printing papers, tissue and  newsprint constitute the major applications for deinked
pulp. Deinking is generally carried out through the use  of chemical reagents such as soda ash
liquor, lime, borax and  a  variety of others. Bleaching with chlorine and  sodium hypochloride
usually follows the deinking operation.

     The  water effluent loadings of deinking mills are quite high because of the discarded inks,
lignin and chemical reagents. The effluent, however, can be handled by conventional primary
and secondary treatment technqiues;  chemical recovery is not feasible.

     Table A-7 shows the regional distribution of deinked pulp mills. It indicates that by far the
heaviest concentration of these mills is in the Northeastern and North Central regions, where
there are  heavy concentrations of printing and  converting plants which provide most of the
wastepaper raw material for deinking. These mills provide a source of pulp (often supplemental)
close to the principal market centers for printing and writing papers, tissue and newsprint.

10.  Recycled Paperboard
     Recycled paperboard, sometimes  called combination paperboard, employs a  variety of
wastepaper grades which are generally  mixed together to form the pulp furnish. These grades
include old corrugated containers, newsprint, and mixed wastepaper grades. The paperboard is
used in a variety of applications including corrugated containerboard, folding boxboard, gypsum
wallboard liner and  a variety of smaller volume products. The repulping process consists of
beating  the  wastepaper in water,  screening off foreign material  such  as tape and wire, and
sometimes also incorporates an asphalt removal step.

     The  effluent loadings from a recycled paperboard operation are quite high because of the
extraneous material introduced by the  wastepaper and removed in the  screening and cleaning
operations. However, the nature of the product is such that it generally lends itself to a very high
degree  of water recycling, which  reduces  the  water volumes  that must be handled in the
treatment plants.
                                          A-10

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                               TABLE A-5




                REGIONAL DISTRIBUTION OF XSSC PROCESS, 1974




                             (No. of Mills)
Size:  tpd       Northeast     North Central     South     West    Total






   100-200           1               2             317






   201-450           1               7             4-12






   451-700           1               2             1                  4






     TOTAL           3              11             8         1       23
SOURCE:  Lockwood's Directory, 1975.
                                      A-ll

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                              TABLE A-6







          REGIONAL DISTRIBUTION OF COMBINED NSSC-KRAFT PROCESS, 1974




                               (No. of Mills)
Size:  tpd







   600-750






   751-1500






  1501-2250






  2251-3000






    TOTAL
Northeast     North Central     South     West     Total
                                 12
19
SOURCE:   Lockwood's Directory, 1975.
                                     A-12

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                              TABLE A-7
           REGIONAL DISTRIBUTION OF DEINKED PULP MILLS, 1975

Size (tpd)
20-99
100-399
400-800
Total

Northeast
6
7
2
15
(No. of Mills)
North Central
7
5
3
15

South West
1 1
4
_ _
1 5
                                                                    Total

                                                                      15

                                                                      16

                                                                     	5_

                                                                      36
SOURCES:   •  Lockwood's Directory 1975
           •  Industry Sources
                                  A-13

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     Table A-8 shows the regional distribution of recycled paperboard mills. It shows that the
heaviest concentration of mills are in the Northeast and  North Central regions and that the
majority of the very small mills are in the Northeast. The distribution of recycled paperboard
capacity more or less follows the population distribution.

11.  Nonintegrated Paper Mills
     Nonintegrated paper mills consist of paper machine operations which exclusively purchase
pulp produced at other  locations to  provide their fiber requirements.  Thus, the only pulp-
handling equipment prior to the refining and paper-making operations are repulping tanks to
disintegrate the baled pulp. The nonintegrated mills primarily produce printing and writing
papers, tissue papers and coarse papers, which include unbleached packaging paper and special
industrial papers.

     Water effluent loadings of the nonintegrated mills are relatively light since there is no on-
site pulping, and the pulp that they purchase is in clean condition ready for paper making. The
pollution loadings associated with the paper-making operation consist of pulp fines, plus chem-
ical treatment and pigment  losses during paper making. These can be handled by conventional
wastewater treatment methods.

     Tables A-9 and A-10 show the regional distribution of nonintegrated printing/writing and
tissue mills. (Nonintegrated coarse paper mills including special industrial paper, wet machine
board,  and molded pulp were excluded from the analysis.) It indicates that by far the heaviest
concentration of these mills are in the heavily populated Northeast and  North Central regions
where it has become uneconomical in many instances to produce pulp at the paper mill site. As is
typical of other mill distributions, the smallest nonintegrated mills are in the Northeast.

12.  Mill Closure Trends
     Table A-ll shows the number of full mill closures and the capacity removed since 1965. An
unprecedented number of closures occurred in 1970 and 1971 as the paper industry's profitability
dropped to its lowest point since World War II.

     By far the greatest number of closures  have occurred in the recycled paperboard product
sector.  Both  small  (50  tons/day)  and medium (100  tons/day) mills were affected, and  the
ownership was about equally divided between small and large firms. A combination of reasons led
to the  closures, including essentially static demand, high-cost mill sites  in densely  populated
metropolitan areas,  and obsolescence of the cylinder board process and its gradual replacement
by forming devices such as the Ultraformer and Inverformer.

     Printing and writing paper mills had the next largest closure incidence. Most of the closed
mills were not integrated to pulp, which is indicative of the general cost/price squeeze caused by
the narrowing gap between pulp and end-product prices. Closed mill owners were about equally
divided between large and small firms.

     The tissue mill closures were all nonintegrated mills that were owned by small companies.
In addition to rising pulp prices, intense competition and increasing market share concentration
on the part of the four leading producers contributed to the demise of these relatively small mills.
                                          A-14

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                            TABLE  A-3







       REGIONAL  DISTRIBUTION OF RECYCLES PAPER BOARD "TLLS, 1973




                           (No.  of Mills)
Size:   tpd     Northeast     North Central    South     West     Total
   5-49
  50-99
 100-299
 300-499
 500-1000
   Total
10
18
29
63
12
31
17
53
26
18
                                17
                    42
          86
                                                12
160
                   30.9
 v':Lockwood's  Directory.
                                  Percent of Capacity Tonnage*-
                41.4
            16.3
          11.6     100.0
SOURCE:  American Paper Institute Capacity Survey, 1973-1976.
                                A-15

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                                TABLE A-9



  REGIONAL DISTRIBUTION OF PRINTING,  WRITING.  AND RELATED PAPER MILLS.  1975




                            (Number of Mills)









  Size:   tpd          Northeast      North  Central    South    West     Total
15-49
50-249
250-1000
5
12
2
1
13
5
1-7
1 1 27
1 8
       TOTAL             19              19             2         2        42
SOURCES:   •   Lockwood's  Directory,  1975.




           •   Industry  Sources.
                                     A-16

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                               TABLE A-10
      REGIONAL DISTRIBUTION OF NONINTEGRATED TISSUE MILLS.  1975
                            (Number of Mills)
 Size:   tpd
       TOTAL
Northeast
North Central    South
    33
      11
West
Total
7-15
16-100
101-1000
7
22
4
—
7
4
2
4
3
2
3
1
11
36
12
           59
SOURCtb:  •  Lockwood's Directory, 1975.




          •  Industry Sources.
                                    A-17

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                                          TABLE A-ll
                      U. S. PAPER INDUSTRY MILL CLOSURES, 1965 - 1974
(No. Mills/Annual Capacity - Thousand Tons)


Year
1965
1966
1967


1968


1969


1970



1971

1972

1973

Recycled
Paperboard
2/51
1/23
3/87


1/32


2/47

&
8/279



5/180

5/219


Paper and Pulp
Printing
& Writing
IN/10
IN/ 14
2N/135





2N/14

*
2N/17


*
4N, 11/238

IN, 11/65

*
Mill Closures

Tissue Other

IN/5 Kraft IN/13
2N/15





2N/13 Kraft IN/53
Glassine IN/15

IN/ 8



2N/13 Kraft IN/25
Spec. Ind. IN/6
2N/26* Glassine IN/16
A
2N/24 Constr. Paper 1/42
Additional
Pulp Mill
Closures
1/21 (ite)

1/34 (ite)
1/21 (tiW)
1/21 (Soda)
2/66 (ite)
2/21 (GW)
1/14 (SC)
3/166 (ite)
3/178 (GW)

3/95 (ite)
3/63 (GW)
1/40 (SC)

3/78 (ite)




1974
3/85
1975 thru 4/ 197
 June
IN/40
             2N/185
Semi-Chem H/100
Spec. Ind. IN/5
                                                      1/105(ite)
   TOTALS 34/ 1200     16N,21/719
                              12N/104
                                      8N,11/275
                        26/923
N - Nonintegrated to pulp

I - Integrated

Kraft - Mainly unbleached papers
                              Pulp Symbols - ite - sulfite
                                             GW   groundwood
                                             SC - semi-chemical
* Excludes partial closures, and mills sold and later reopened in same grades,
Source:  American Paper Institute
                                              A-18

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     Other product sectors which experienced closures include unbleached kraft, glassine papers,
special industrial paper, corrugating medium, and construction paper. All but one of the nine
affected mills were not integrated to pulp and were relatively small mills. The mill owners were
about equally divided between small and large firms.

     Pulp mill closures where the paper mills continued to operate as nonintegrated or partially
integrated mills were only slightly less numerous than recycled paperboard mill closures. Sulfite
mills experienced the highest closure rate, with fully 14 out of the total 26 pulp mill closures since
1965. All of these mills lacked the costly chemical recovery or incineration systems which were
needed to meet state water pollution control  requirements.  Fourteen  U.S. sulfite mills still
remain that do not have recovery or incineration systems, presumably because they cannot be
economically justified and/or their state requirements do not stipulate that level of control.

     There were nine groundwood pulp mill closures since 1965. These were for the most part very
small mills that utilized relatively high cost softwood pulpwood which made them uneconomical.
ADL doubts that pollution had a significant bearing on these closures, since groundwood is the
least polluting of the pulping processes.

     The remaining  pulp mill  closures consisted of two semichemical  (NSSC) mills  and one
soda-pulp mill. These were probably pollution-related, since the processes cause significant water
pollution loadings. In the case of the NSSC mill closures, the companies shifted to a wastepaper
pulp furnish and continued to produce  corrugating medium.

     Methodical, accurate accountings have  not been made concerning the cause of the above
mill closures or what role, if any, pollution-control regulations had in the closures. Many of the
closures were undoubtedly the results solely of unfavorable economic conditions.  Conversely,
pollution-related  closures were  invariably due to  the combination of unfavorable economics
coupled with the  need to reinvest substantial amounts of capital to correct pollution problems,
and then incur a continuing higher operating cost. Therefore, the above closure-trend analysis
points to product  and process sectors that traditionally have been most vulnerable to closures and
which ADL analyzed in  particular detail to  assess the probability  of future closures in which
federal pollution control regulations are likely to be significant contributing factors.
                                           A-19

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Tl

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                                    APPENDIX B

                       CURRENT TECHNOLOGY CHANGES
     Following  is a brief discussion of pulping, bleaching and papermaking process  changes
which are either in the early stages of commercial development or in  large-scale pilot plant
operation and which have or might have a significant impact on the costs of meeting air/water
pollution regulations, or on the economics of pulping or papermaking.

1. Pulping Systems
     Oxygen Pulping.  The kraft pulping system, by far the most important chemical pulping
process, contributes appreciably to both air and water pollution. Because pollution arises partly
as a result of the use of sulfur compounds used in the process, there is a high degree of interest in
nonsulfur pulping processes. One of these approaching commercial status is oxygen pulping.

     The major incentive for the use of oxygen pulping is a reduction  in both air and water
pollution levels; since  there is  no sulfur there  are  no  malodorous organic sulfur compounds
emanating from the system  — either in air emissions or water effluent from the mill.

     A second  important incentive  for the use of oxygen pulping comes from  the potential
elimination of the chlorination stage  in the pulp bleaching system. This is important because the
conventional chlorination and subsequent alkaline extraction stages contain large quantities of
chlorine compounds and are difficult to recover and so pose a pollution problem. These  first two
stages would be replaced by oxygen pulping. The effluent from the oxygen treatment contains no
chlorine and so  can be recovered and recycled to the recovery furnace where the organic  material
is burned (energy recovery)  and the  inorganic  material is recovered in the form of fresh pulping
chemical. ADL calculations based on laboratory data indicate that capital and operating costs for
kraft and oxygen pulping will  be similar. With present technology oxygen pulp strength is lower
than that of kraft. Thus, the  major  incentives for the use of oxygen pulping technology are its
pollution abatement aspects.

     The first commercial oxygen pulp mill in the world is being constructed by Weyerhaeuser at
Everett, Washington. If pulp strength deficiencies can be corrected, the oxygen pulping process
could gain a degree of acceptance as a substitute for the kraft process that provides a means of
reducing both air and water pollution and treatment costs. Conversion of kraft to oxygen pulping
would require a major capital investment.

     Thermomechanical Pulp (TMP).  Mechanical pulp (used primarily in newsprint and other,
lower cost printing papers) is conventionally made by grinding a log  on a  grindstone or  by
subjecting chips to mechanical disintegration in a  double risk  refiner. Recently, it has been
discovered that a  superior  mechanical pulp  can be made  if the  wood is  steamed and then
disintegrated under pressure. Yields are slightly lower than for the conventional systems —
largely because  of somewhat higher dissolved wood solvents, but pulp strength values are higher.
Thus, it is usually possible to reduce the amount of blended chemical pulp needed to strengthen
the paper.
                                          B-l

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     From a pollution point of view, there will be a greater problem with TMP because of the
higher quantity of dissolved organic material in the mill effluent. Counterbalancing this is the
possibility of using lower value residue wood chips and sawdust in the TMP process. These raw
materials frequently  constitute a pollution problem.  In the  past  they have been  burned or
disposed of by  leaving them in piles to disintegrate. Pollution problems have arisen from wood
residues being washed into rivers, and other bodies of water, causing water contamination  from
leached degradation products of the wood residues and air pollution from burners.

     The TMP process is in use in several mills in North America and Europe. In addition, a
number of new installations  are on order or being installed so a fairly rapid adoption rate is
indicated.

     Polysulfide Pulping with Kraft. The normal kraft pulp yield of 42-45% can be increased to
as much as 49-52% (i.e., a 15% increase) if polysulfide is added to the conventional kraft cooking
liquor. This  advantage is particularly  important in  high wood cost  areas. The process was
developed in Norway and is being used in two or three Scandinavian mills. The extra sulfur used
in the system cannot be recovered  and  so has to be vented to the atmosphere. The result is a
significant increase in the air pollution load at the mills using polysulfide pulping.

     Recently the Mead Corp. in the United States has developed a recovery system for poly-
sulfide and has installed a commercial unit at their  Chillicothe Mill.  They are obtaining a
significant yield increase with no appreciable increase  in the air pollution load. Mead Corp. is
actively seeking licensees for their patented recovery process. In areas with very high wood costs,
the use of polysulfide pulping and recovery could prove to be attractive.

     Kraft-Hydrogen  Sulfide  Pretreatment.  When wood chips  are pretreated with hydrogen
sulfide, followed by a conventional kraft cooking liquor, a yield increase is obtained similar to, or
higher than, that from polysulfide pulping. MacMillan Bloedel in Vancouver, British Columbia,
has developed a recovery system for hydrogen sulfide pretreatment and  has extensive experience
with a large pilot plant in their Nanaimo, B.C. mill.

     MacMillan Bloedel is also actively seeking licensees for their patented pulping process. This
process is expected to have the same degree of applicability as polysulfide pulping systems.

     Nonsulfur Semi-Chemical Pulping. Most of the corrugating medium in the United States is
made with the  so-called neutral sulfite semi-chemical process (NSSC). Until recently in many
mills it was the practice to simply  discard the effluent from this pulping process to the river,
sewer, etc.

     A variety of NSSC  chemical recovery processes  have been  developed  and  many  have
obtained commercial  acceptance. Most  of the recovery systems go through a sulfide phase in a
recovery furnace (including so-called cross recovery or use of NSSC liquor for make-up chemicals
in a kraft recovery furnace) and so contribute significantly to air pollution.

     Two U.S. companies, Westvaco  and Owens-Illinois, have,  independently,  developed and
patented nonsulfur semi-chemical pulping processes. Both companies have made one commercial
installation in the United States. The  process details have not been revealed by either company.
Both, however, are actively seeking  licensees of their process.
                                           B-2

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     Green Liquor Semi-Chemical Pulping. It has been found recently that a satisfactory semi-
chemical pulp can be made with kraft green  liquor as a cooking chemical rather than neutral
sulfite liquor. The kraft green liquor is simply a solution of recovered kraft chemicals which have
not been subjected to the final recovery step  (i.e.,  conversion of carbonate to hydroxide). The
advantage is that the effluent  from the pulping process can be recovered in conventional kraft
systems. This is true also of the cross recovery of NSSC liquors with kraft recovery system but this
approach is limited by the quantity of make-up chemical required in the kraft system. When
NSSC liquor is used as a source of make-up  chemicals, the ratio of kraft with NSSC pulping
production allowed in cross recovery is about 4 kraft to 1 NSSC. As an added factor in recent
years the more strict control of atmospheric pollution from kraft mills has limited the quantity of
NSSC liquor which can be used as make-up  chemical. With  kraft green liquor semi-chemical
pulping, there is no limit on  the production of semi-chemical  pulping integrated  to a kraft
pulping and recovery unit.

     A number of NSSC mills in the United States have been converted to kraft green  liquor and
ADL expects the trend to continue.

2.  Chemical Recovery
     SCA-Billerud Recovery for NSSC. One  of the most  recent new, large, NSSC  mills con-
structed (Mead Corp.'s 600 ton/day mill in Alabama) is being built with still another modifica-
tion of  NSSC recovery — the SCA-Billerud System. In this process the  recovered organic
material from NSSC pulping is heated at elevated temperatures under conditions such that one
of the active pulping chemicals, sulfur dioxide, as well as heat and sodium values, are recovered
directly from the recovery furnace. Sulfides are not handled outside of the recovery units and so
the development of noxious sulfur compounds  is lessened. There are several such installations in
Europe  but Mead's in the first  in the United States.

     Sunoco Recovery of NSSC Pulping Liquors.  Sunoco Products  Company in  Hartsville,
South Carolina has recently announced yet another sulfite recovery system. Theirs utilizes the
fact that certain silicate and aluminate salts are strongly acidic at the temperatures encountered
in a recovery furnace and are highly insoluble in  relatively dilute water solutions.  Thus,  the
NSSC pulp  digestor effluent is combined with the silicate-aluminate salt prior to its combustion
in the recovery furnace. Sulfur dioxide is recovered directly from the furnace and sodium values
are recovered  when  the smelt from the recovery  furnace is dissolved in water and silicate-
aluminate compounds precipitate. These precipitated salts are recovered and recycled.

     Sunoco is offering to license the process to interested parties. The advantage of the Sunoco
system from the standpoint of pollution abatement lies in the recovery of sulfur dioxide directly
without going through the sulfide stage. To date the only installation is the Sunoco one although
they are said to be negotiating  with several interested pulp mills.

     Variations in Kraft Make-Up Chemicals. When kraft mills are forced to close up their
systems and retain more  of their sulfur values, the use of salt cake as a make-up chemical
becomes increasingly difficult because it provides an excess of sulfur beyond that required by the
chemistry of the pulping reaction. In addition, unwanted sulfur values are added to the system
when effluents from the tall oil recovery system and chlorine dioxide generators are added to the
kraft furnace. This has led to the substitution of caustic soda and sulfur for salt cake and other
sodium-sulfur make-up chemicals in many kraft systems. Although  the cost of the caustic is
                                           B-3

-------
somewhat higher than the salt cake, the emission of objectionable sulfur compounds from the
recovery process is considerably lessened. There already has been rapid displacement of salt cake
in kraft pulping. ADL expects that the trend towards the use of caustic in place of salt cake will
continue.

3.  Bleaching
     Oxygen.  Oxygen  is being used commercially in  pulp  bleaching as a substitute for the
chlorination and extraction stages of a conventional kraft bleaching sequence. The advantages
and results from the standpoint of pollution are similar to those experienced with oxygen pulping.
The comparative economics of oxygen and conventional bleaching are similar. Thus,  the major
incentive for oxygen pulping is pollution abatement. Because oxygen pulp strength is sometimes
lower than kraft, ADL expects that commercial use of the process will be limited unless process
changes result in pulp strength improvements.

     Replacement of Chlorine  with Chlorine Dioxide.  Kraft pulp bleaching is conventionally
carried out in four to six stages. A typical sequence would be chlorination followed by alkaline
extraction, chlorine dioxide, alkaline extraction and chlorine dioxide. The effluents from the first
two stages (chlorination and alkaline extraction) contain substantial quantities of inorganic and
organic chlorine compounds as well as nonchlorinated organics. Thus, these two effluent streams
constitute a major pollution problem for the bleached kraft industry.

     It has been found that if chlorine dioxide is added  along with chlorine in the first stage or if
dioxide is added in an initial stage followed by chlorination, the  quantity of chlorine  consumed
can be reduced. The quantity of chlorine which can  be eliminated is  directly related to the
quantity of chlorine dioxide used. In principle, it is possible to substitute all of the chlorine with
chlorine dioxide but present economics permit only a partial substitution. Chlorine dioxide has a
much greater oxidizing power per chlorine atom than chlorine and in addition the mechanism of
the chlorine dioxide action is such that chlorinated organics are not produced to the same degree
as with chlorine. Thus, the effluent from a chlorine dioxide stage is much less offensive than from
a chlorination stage.  There has been a significant trend to replacement of chlorine with chlorine
dioxide and ADL expects this to continue.

     Displacement Bleaching and Washing. One of the reasons  the bleach plant effluent is so
difficult to handle from a pollution point of view is the high dilution of the dissolved organics and
inorganics. The high dilution arises from the need to add large quantities of water to the pulp
after each bleaching stage. A recent development by the Swedish firm, Kamyr, gives a  promise of
enabling the bleach plant operator to  use  less water and discharge a considerably more concen-
trated effluent. In the Kamyr development the pulp is washed by displacement rather than by
dilution as in the conventional processing step. A number of these displacement washers are in
commercial operation in bleach plants.

     As an added refinement of the Kamyr diffusion  washing, a 150-ton-per-day pilot  bleach
plant is operating in Finland  with bleached chemicals as well as water  being added  in the
diffusion washers. The pilot plant has three stages of bleaching with washing between  each stage
carried out in a single tower. Indications are that a substantial reduction of water usage as well as
higher concentration of dissolved solids in the  mill effluent has been  achieved. At least one
commercial unit is being constructed in the United States based on the three-stage bleach, single
tower principle.
                                           B-4

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     High Consistency — Gas Phase Bleaching. Similar reductions in water consumption and
an increase in dissolved solids concentration in the mill bleach effluent can be achieved with a
high consistency press and gas phase bleaching at high consistencies. This concept has  been
developed at Paprican Laboratories-in Montreal in cooperation with Impco-Ingersol Rand. An
Impco press is used which enables the bleach plant operator to press the pulp to a solids content
of 35-409c. A bleaching chemical such as chlorine  is then applied in the gas phase. After the
reaction has taken  place the pulp is dilution washed by adding water to bring the pulp slurry to a
10c/c solids level and then repressing to the 35-40% solids level. Weyerhaeuser is operating a single
stage pilot plant on this principle. Results of the pilot plant  operation have not yet been made
public.

4. Water Reuse
     Most, if not  all, pulp and  paper mills have effected  a substantial reduction in water
consumption, or increase in water reuse, in the past several years. The pressures and constraints
on water reuse are largely social and economic in origin rather than  technical. The engineering
and chemical techniques for increased recycle of water within pulp mill, bleach plant or paper
mill are readily available.

     In  the  early days of the industry when water was extremely cheap  and there was  little
concern over water pollution, the mills made little effort to achieve a high water recycle ratio.
With increasing pressure to achieve reduction in water pollution,  the mills have applied the
available techniques to increase water reuse so as to decrease the hydraulic load on pollution
abatement facilities and thus decrease capital and operating costs.

     One of the major constraints of water reuse is  the  market-oriented factor  of consumer
acceptance. High brightness levels and dirt specifications require a certain amount of water to be
rejected from the system as a purge. The quantity of purged water  could be reduced with less
stringent consumer expectations as to brightness, dirt and other factors. Total recovery processes
for the purged water  (e.g., distillation, reverse osmosis, ion exchange, etc.) become prohibitively
expensive.

     However, more stringent effluent control regulations will cause a continuing decrease in the
net quantity of water used in pulp and paper mills through application of presently available
technology.

5. Papermaking
     High Consistency Forming. In a conventional papermaking operation the pulp fiber  is
suspended in a large quantity of water prior to formation into a continuous fibrous web. As much
as 1,000 Ibs of water per Ib of pulp is used. Recent developments have given promise of making it
possible to substantially reduce the consumption of water  in the papermaking and thus reduce
the volume of effluent from the paper machine.

     The Swedish  Cellulose Research Institute in Stockholm and the Lodding Co. of the United
States have developed paper machine  modifications which would reduce the  water used in
suspending the fibers prior to forming to 25-50 pounds per pound of pulp. The Swedish devel-
opment has been licensed to Ahlstrom in Finland and this company is installing equipment on a
commercial  machine.  The  Lodding equipment has been  installed  on  North American paper
machines with varying degrees of success. The major problem  with  both devices  appears  to be
paper quality  — especially uniformity of formation. Broad commercial use of these high con-
sistency forming developments is probably several years away.

                                          B-5

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     Dry Forming. Water effluent from papermaking operations could be eliminated completely
if air instead of water were used to convey the fibers prior to formation of the web. There are
several commercial examples of dry forming of paper — largely in the high-value specialty paper
field. Honshu Paper Co. in Japan is making cigarette filter sheets, automotive air filters and
household wipes in their patented dry forming process. A number of U.S. companies are making
absorbent sheets for disposable diapers in dry forming operations. Karl Kroyer in Denmark has a
semi-commercial  dry forming unit making sanitary tissues. In England, St. Anne's board has
installed a commercial dry forming board machine for the manufacture of recycled boxboard. At
the last report this machine was still operating on an experimental basis.

     The major impact on water pollution would come if dry forming were applicable to com-
modity grades of paper such as toilet tissues, linerboard, printing papers, newsprint, etc. As yet,
it has not been possible to reproduce economically the paper qualities found with the commercial
wet forming process with a dry forming operation. ADL expects that the development of dry
forming for commodity grades is still a number of years away.

6. Wastepaper
     Recovery from Municipal Trash. About 20% of the pulp and paper discarded in the United
States is recovered and recycled to pulp and paper manufacturing. Further additional quantities
could be collected if the demand was there, and if the collection systems were  established with
more emphasis on source separation or isolation of the discarded paper and paperboard. However,
a large portion of the discarded paper and paperboard is not recoverable because it is co-mingled
with garbage, tin  cans, bottles, plastic, as well as other nonfibrous materials, and so cannot be
recovered with conventional techniques.

     There are a  number of development programs aimed at recovery of usable fiber from
municipal trash.  One  of these processes  developed by Black Clawsen has  been subject to
extensive pilot plant and semi-commercial trials. In this wet process the entire municipal trash is
slurried in water  and  the fibers  separated in a series of screening and washing steps. The
recovered "garbage pulp" is at the low value end of the quality scale and can be used only in such
products as roofing felt. The sponsors of the project now agree that with the present economics the
most practical use for the recovered fiber is as a feedstock to a burner for heat recovery.

     A dry separation approach has been explored by the Forest Products Laboratory and others.
The entire municipal trash is reduced to uniform particle size and then the various components
separated by a series  of screens,  cyclones and  air fractionation steps. The  Forest Products
Laboratory representatives suggest that the recovered fiber be best utilized as a raw material for a
reconstituted,  resin bonded construction board product. The economics for this process appar-
ently are not yet favorable in comparison with solid wood or reconstituted wood products.
                                          B-6

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         APPENDIX C

CRITERIA FOR ASSIGNING MILLS TO
  PROCESS/PRODUCT SECTORS

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                                   APPENDIX C

   CRITERIA FOR ASSIGNING MILLS TO PROCESS/PRODUCT SECTORS

1. Multiple Pulp Mills
     Entire complex (including paper and paperboard mills) assigned to highest polluting com-
ponent, i.e.:

     •  chemical plus mechanical pulp mills — assigned to chemical
     •  chemical plus deinked pulp mills — assigned to chemical
     •  deinked plus mechanical pulp mills — assigned to deinked
     •  sulfite plus unbleached kraft pulp mills — assigned to sulfite
     •  sulfite without chemical recovery plus bleached kraft pulp mills — assigned to
        sulfite
     •  sulfite with full chemical recovery plus bleached kraft — assigned to bleached
        kraft
     •  unbleached kraft and NSSC pulp mills — assigned to combined kraft/NSSC
     •  bleached kraft plus NSSC pulp mills — assigned to bleached kraft

2. Single Pulp Mills
     Entire complex (including paper and superbond mills) assigned as follows:

     •  100% bleached or unbleached kraft pulp mills — assigned to appropriate process
        category
     •  kraft mills producing both bleached and unbleached pulp (regardless of ratio) —
        assigned to bleached kraft
     •  sulfite mills (bleached and/or unbleached) — assigned to sulfite
     •  semi-chemical and deinked mills — assigned to appropriate process category
     •  chemi-mechanical mills — assigned to groundwood
     •  refiner and stone groundwood mills — assigned to groundwood
     •  cotton fiber (rag) pulp mills and their paper mills excluded from the study
     •  groundwood mills producing molded pulp products excluded from the study
     •  defibrated pulp mills were not considered as a pulp category

3. Nonintegrated Paper and Paperboard Mills
     •  Note:  treated as integrated: paper and paperboard mills (including those listed
        separately in directories) that are connected by pipeline to a pulp mill even if the
        mills are owned by separate companies.
     •  Single product — assigned to appropriate nonintegrated product category
     •  multi product
          — single-mill — assgned to highest tonnage product category
          — multi-mill  —  treated as separate entities when available information  indicated
             that these are physically separated although located in the same community.

                                          C-l

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                                    APPENDIX D


                SUPPORTING DATA  FOR ECONOMETRIC ANALYSIS


    1.  DETERMINANTS OF SUPPLY  AND DEMAND

    a.  Product Demand
        The theory of consumer behavior states that consumers as a group will purchase more of a
    product at a lower price than at a high price, due to the diminishing marginal utility associated
    with additional units of a product. The demand schedule of quantity purchased at different levels
    of prices is downward sloping, as shown in Figure D-l.

                                       FIGURE D-l

                                    DEMAND SCHEDULE
             Price
             per
             Unit
                                        Quantity


   At price, PI, quantity Q,, is demanded. If the price increases to P2, the quantity demanded falls to
   Q2. The ratio of the percentage declined in quantity demanded to the percentage change in price
   is the price elasticity of demand:1
                              e = •
                                   AQ
AP
                                 Qi+Q2
1. If the demand curve were logarithmic or of constant elasticity, the formula for elasticity of demand can be
  represented as  QQ    p
              — x  —
              9P    Q
                                          D-l

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     The degree of elasticity depends upon the  availability of substitute  products and the
relative necessity of that product. If the number or nature of substitute products changes over
time, the slope of the demand curve can change. The long-run response to large shifts in price
may be quite different from the short-run response:
         Price
                                        Quantity


     Increases in income shift the demand schedule for a normal good. As income increases, the
demand curve shifts to the right, meaning that consumers will demand more of a good at the
same price as they had previously:
            Price
                                      Ql                Q2
                                            Quantity

     The quantity of a product demanded depends upon the price of that product (p,), the price
of substitute products (pa) and income (y):
                                                                                 (1.0)
                                         D-2

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b.  Product Supply
     The theory of the  firm postulates that an entrepreneur will purchase inputs and produce
commodities for sale in such a fashion as to maximize profit on the sale of the  good. The
production function of the firm defines the relationship between the quantity produced and the
quantity of variable inputs used in the production of goods. For example, for a firm using'only two
variable inputs,
                                         = F(x,x2)
                                                                                     (2.0)
where
            x2   =
                      quantity produced
                      variable input 1
                      variable input 2
     The total cost of production is the sum of the unit variable costs plus the fixed costs that
must be incurred regardless of the level of output. Marginal cost is the change in total cost which
occurs due to a unit change in output.
                                   C =
                                               x2 + fc
or
where
                       total cost of production
                       price of variable input Xj
                       price of variable input x2
                       fixed cost
                                                           total cost
(3.0)
                                                                                     (3.1)
                              MC   = 0i(i (q)/q   Average Variable Cost
                                                                                      (3.2)

                                                                                      (3.3)
     During the short run, the entrepreneur can maximize profits by producing goods until mar-
ginal cost equals marginal revenue (which equals market price under perfect competition). The
short-run supply curve of a  competitive firm will then be the portion of the short-run marginal
cost curve which lies above or on the average variable cost curve. The industry supply curve is the
sum of the supply curves for the individual firms. Both for the industry and for the individual
firm, the cost  of producing additional units of output increases as quantity  produced nears
capacity.

     In the paper industry, mills generally operate 24 hours per day, seven days per week. In the
short run, the capacity constraint is relatively rigid; there is a point beyond which no additional
amount of factor inputs will  produce additional output. A graphic representation of marginal cost
and average variable cost curves for this industry, and the resulting supply curve are as shown in
Figure D-2 and D-3.

                                           D-3

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                             FIGURE D-2
                   MARGINAL COST AND AVERAGE COST
  Cost of
Production
    Per
   Unit
                                 Quantity
                             FIGURE D-3
                            SUPPLY  CURVE
    Price
     Per
    Unit
MC = S
                             CAPACITY
                                                  CAPACITY
                                      Quantity
                                  D-4

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     During the long run, capacity can enter and leave the industry and therefore all inputs are
variable. The entrepreneur seeks to maximize profits in the long run by equating  long-run
marginal cost with marginal revenue. The long-run supply function is that postion of its long-run
marginal cost function which exceeds  its average  cost  curve. In  the  long-run, average  cost
includes "normal" profit, i.e.,  a rate of return commensurate with risk.

c.  Market Equilibrium
     At a given point in  time the equilibrium market price  for a  good is determined by the
intersection of  the demand and  supply schedules,  as shown  in  Figure D-4. At price, Pit the
quantity demanded is q,.  Any increase in price (shift in the supply curve) will result in a lower
quantity demanded.

                                         FIGURE D-4

                                       INTERSECTION
                                                   S
       Price
       per
       Unit
                                                    , Capacity
                                  Quantity
d.  Effect of Pollution Controls
     Because  the installation  of pollution control equipment is legislatively  mandated, the
economic decision to install it falls outside the purview of usual capital budgeting theory, and it is
useful to consider the attendant operating costs as tantamount to a tax. The cost will have two
components:

     •  A fixed component which does not vary with plant output; and
     •  A variable component, which alters the plant's marginal cost function.

     The first component is equivalent to a tax on fixed assets; the second is equivalent to a unit
tax on output. The mill's total cost function (3.0) becomes:
                                         D-5

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where t'i = the increase in variable cost due to pollution control requirements

      t2 = the increase in fixed cost due to pollution control requirements.

The mill's average variable cost and marginal cost function (3.3) become:
                                      02 (q) + t , q
                              AVC = ^— - -
                              MC   = 02 fqj + t,                                       (4.2)

and the short-run supply curve shifts upward by the amount t( .

     While a necessary condition to stay in operation is that price equal to or exceeding average
variable  cost, the mill  owner must also perceive that  he will recover the investment in the
pollution capital equipment over the remaining life of the mill (i.e., the present value of expected
future net cash flow must exceed the present salvage value of the mill). Therefore, the pre-
dominant effect of 1977  standards upon the industry supply curve is produced by plant closings,
with the  balance of the short-run effect reflecting the shift in the supply curve due to increase in
operating costs from pollution control requirements.

     In the long run, new plants will  not be constructed unless owners are able to recover their
investment plus a normal rate of return on the capital  employed. Prices must be sufficient to
recover the cost of compliance with environmental regulations. For this reason, the long-run price
effects of environmental regulations were estimated by solving for the price necessary to earn a
normal rate of return on a new mill:

     •  with the studied environmental regulations
     •  without the studied environmental regulations.

2.  ECONOMETRIC  MODELS

a.  Formulation of Models
     To identify the potential impacts, of Federal pollution control requirements, the economic
relationships described so far were combined into a model which includes:

     •  Industry supply functions
     •  Market demand functions.

     ADL also explored the use of capacity growth functions. Capacity brought on-stream in a
given year was related to capacity utilization three and four years previously (the length of time
required  to construct a pulp or paper mill during 1967-75). 2 Interest rates prevailing during the
 2. This ranges from four to six years today.
                                           D-6

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construction period, pollution control expenditures as a percentage of total expenditures, general
economic conditions and the wholesale price index for machinery  were all included as lagged
variables. (A sample equation is included in Section D-10.) However, the resulting equations
were not sufficiently reliable to be useful.

     Therefore, an alternative method of projecting capacity was used. Basically it employed a
simple extrapolation of managements' expansion plans through 1979 as compiled and published
annually by the API. Due to the long lead times required for new capacity, the industry knows
within reasonable limits the new capacity expected to come on-stream three years hence (green-
field, as well as incremental expansion). The 1970-1979 capacity growth rates for each product
sector were projected taking into account product sector market and profitability trends, and the
Chase general economic projections. Units of capacity rather than dollars of investment expendi-
ture were employed because of the high rate of relative inflation in the cost of construction of new
facilities in the 1970's. Units were then converted to capital based on the cost of constructing new
facilities in 1975 estimated from the new mill process economic models.

     Demand equations and supply equations  were specified for many of the product sectors
studied in this report. The demand equation included a macro-economic variable to represent the
income effect, the transaction price of the product and for those sectors with substitute products
(bleached board and unbleached kraft  paper), the  price of the predominant plastic substitute,
which was incorporated in the form of a ratio to the price of the product. Due to the fact that the
price of substitute  products has moved with the prices  of paper goods in the studied period
(multi-colinearity) and perhaps the use of aggregate product group price data, the elasticity of
substitution could not be measured for these products.

     For some of the product sectors and for the industry aggregate equation, the specified supply
equation did not explain a large percentage of the movement in prices. Prices of paper products
correlated best  with the price of energy. For many of the low-valued product sectors,  capacity
utilization rates were inversely  related with price — a statistical oddity rather  than a real
phenomenon.

b.  Statistical Technique
     In product sectors where variable  cost explained price movements in a consistent fashion,
the two-stage least squares statistical  technique was used to  estimate the parameters of the
demand equation. In other sectors, ordinary  least squares, with a lagged price term, was used to
estimate the parameters of the demand equation. The  equations for the individual product
sectors are part of Volume II, while equations for the aggregate of all paper and paperboard are at
the end of this Appendix.

c.  Error in Variables
     The product sector groupings used in this report were based upon similarity of process and
market. In aggregating across products  in a product group, some of the effects may have been
obscured. Also,  on the supply side, wood, labor and energy prices were paper industry aggregates
and not specific to individual products.

     Although an effort was made to use consistent data throughout the historic period, changes
in the base capacity and products classified in one grade versus another may have introduced
error to the data base.
                                           D-7

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d.  Aggregate Model Equations
     The economic equations for the aggregate of paper and paperboard appear on the following
pages. They represent the  demand equation  actually used  in  the analysis  plus attempts to
measure other relationships.

Equation 1:  Aggregate Paper and Paperboard Consumption
     This equation was developed using data from 1968 to 1975 and is the basis of the aggregate
demand forecast and estimated price elasticity of demand. As such, the intermediate-term price
impacts estimated with the funds flow model are also dependent upon the demand level and price
elasticity forecast from this equation.

     The statistics describing the equation are all statistically significant, except the coefficient
of the wage-price freeze dummy variable. The standard error of 3.389c results in a two standard
deviation error boundary of 6.6%.

Equation 2:  Aggregate Paper and Paperboard Demand (1974)
     This equation was developed using older data than Equation 1 and  does not include 1975
data. This equation was  not used in the analysis but was included to  demonstrate  that the
parameters of the underlying demand for paper appear to be changing. The coefficients of the
variables are not statistically different from Equation  1, but the coefficient  of price  is in the
borderline.
Equation 3:  Aggregate Paper and Paperboard Supply  Equation (1974)
     This supply equation,  developed on data through 1974, indicates a relationship between
price and capacity utilization such that  price increases sharply as capacity utilization increases
above practical maximum levels. When 1975 data is included, the coefficient changes sign — i.e.,
the price is inversely related to capacity utilization.

Equation 4:  Change in  Capacity
     An equation was specified with this year's growth in paper industry capacity described as a
function of economic growth in the recent past, capacity utilization (idle capacity) in the past and
the cost of capital, weighted according to the paper industry construction profile (20% in year one,
409c in each of years  two and  three). The cost of capital equipment and the  portion of total
investment in pollution control  equipment were statistically non-significant.

     The standard error of 30.9% associated with this equation would result in a two standard-
deviation range of 60.6%. When the equation was applied, it produced forecasts that were not as
responsive to capacity utilization  extremes  — high or low — as are reasonable. For example,
when capacity utilization was at or above 100%, the projected new capacity three years down-
stream was insufficient to fill the capacity  shortage gap. The probable reason for this is that
extremely high or low operating rates were not present in the development period. (The capacity
tightness of 1974 would not result in new capacity on-stream until 1977 in that model framework.)
The model could not reflect structural changes that are occurring; for example, the longer lead
time required to add capacity due to environmental impact statements, etc. The model was also
insensitive to pollution control expenditures. In short, the mathematical equation was not likely
to provide reasonable estimates of future capacity expansion, and therefore, it was not used.
                                         D-8

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3. LIMITATIONS OF ECONOMETRIC ANALYSIS
     The econometric equations were  used to  estimate future demand  for paper products
(through 1983) and the reduction in demand that will occur as a result of price increases. Based
upon the differences between Equation 1 and  Equation 2, the underlying structure of the
demand for paper products could still be changing; the full effects of the price increases of 1973-74
may not be yet fully reflected in the marketplace. The impact of this is that the forecast demand
levels may be too high.

     An upper and lower boundary forecast was made to indicate the expected variation from the
forecast due  to the equation. Additional differences from the forecast can arise from changes in
the underlying demand structure for paper and paperboard and errors in the Chase Econometric
forecast.
                                        D-9

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Equation 1:  Aggregate Paper and Paperboard Consumption
CONSUMPTION = Constant tb, Mkt. Price^, tb2 IlPt.j tb3 WPFRZ
Variable
C
Mkt.Pricej.j
HP,.,
Coefficient
11019.4
-54.42
97.53
t
6.58
4.08
8.83
                    Wage Price Freeze
                    Dummy Variable
          R2     =    .88
          DW    =   2.27
          F(3,32) =  76
          Method: Ordinary Least Squares
478.6                 1.62

  Standard Error: 3.38
  Mean Y = 14863
  Timeframe:  1968-1975
                                           D-10

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Equation 2: Aggregate Paper and Paperboard (1974)
DEMAND EQUATION:
         CONSUMPTION = 9478.65 - 28.4852 Market Price + 91».1316 HPt.2
                          + 1014.34 WAGE PRICE FREEZE
               Right Hand Variable
               Constant
               Market Price
               Index of Industrial
                Productiont.2
               Wage Price Freeze
Estimated Coefficient
     9478.65
      -28.4852

       91.1316
     1014.34
T-Statistic
 5.69886
-3.10989

20.5358
 5.58314
               R2 = .9584
               Durbin Watson = 1.6120
               F-Statistic (3,48) = 368.7
               Time Period = 1962-1974
               Method = Two-Stage Least Squares
        Standard Error = 3.1%
        Mean Value of Y= 13728.4
               IDENTITIES:
                  1. Consumption = Production - Exports + Imports
                  2. Market Price = [(Production - Exports) x Price +
                    (Import Price x Imports)] •=• Consumption
                                            D-ll

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Equation 3:  Aggregate Paper and Paperboard (1974)
SUPPLY EQUATION:
     Price = +4.05357 (ENERGY + LA«OR COST) + 1.23264 WOOD PRICE
           -6.08991 WAGE PRICE FREEZE + .158084 [!/(% IDLE CAPACITY
           xlO)8]*
               Right Hand Variable
               ENERGY + LABOR
               WOOD PRICE
               W P F
               [l/(7< IDLE CAPACITY
                xlO)8]*
Estimated Coefficient
     4.05357
     1.23264
    -6.08991

      .158084
T-Statistic
16.8683
 3.46227
 2.30255

 2.515833
               R2 = .6960
               Durbin Watson (Adj. for 0 gaps) = 1.0917
               F-Statistic (4,44) = Not available for equations
                with no constant term
               Time Period:  1962-1974, quarterly
               Method:  Ordinary Least  Squares
                   Standard Error = 3.25%
                   Mean of Y= 142.883
               "(% IDLE CAPACITY = QUANTITY)/CAPACITY
                                           D-12

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Equation 4:  Aggregate Paper and Paperboard (1974)
CHANGE IN CAPACITY EQUATION:
     Change in Capacity =   2603.67 + 13.9470 (GNPt - GNPt.g)
                        -5578.92 (% IDLE CAPACITYt.4 + % IDLE CAPACITYt.g)
                        -76.9781 WEIGHTED COST OF CAPITAL
              Right Hand Variable
              Constant
              GNPt-GNPt.8
              (% IDLE CAPACITYt.4 +
               %IDLECAPACITYt.g)
              WEIGHTED COST OF
               CAPITAL
Estimated Coefficient
     2603.67
       13.9470

    -5578.92

    -  76.9781
T-Statistic
 4.0555
-4.44841

-1.14945

 4.39268
              R2 = .470
              Durbin Watson = .6393
              F-Statistic (3,44) = 14.1917
              Method: Ordinary Least Squares
              Standard Error = 30.9%
                                         D-13

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              APPENDIX E



SUPPORTING DATA FOR COSTS OF COMPLIANCE

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                                     APPENDIX E

               SUPPORTING DATA FOR COSTS OF COMPLIANCE
     This appendix contains supporting data for deriving the costs of complying with the studied
air, water, and noise regulations. It presents the regulations on which the cost estimates are based
and describes the methodology used in the calculations.

     Because certain  factors and assumptions are common to all three types of regulations, a
brief generalized approach and summary of the common  cost bases/assumptions used in the
analysis are presented below. The studied regulations (for air, water, and noise) are discussed
separately in Appendices E-l, E-2 and E-3 respectively.

     The studied regulations for air and water control are dissimilar for the existing industry and
new industry capacity; accordingly, it is convenient to separate the information for the existing
industry from that  for new capacity. The noise regulations, in  contrast, are the same for both
existing and new industry capacity, but different methods of analysis were used to estimate the
corresponding costs of control; therefore,  we maintained the existing/new industry approach in
presenting the supporting data for this proposed regulation.

     Note that all  cost estimates are reported in mid-1975 dollars without further escalation
during the studied period.

     As mentioned in Chapter HI of this report, the economic impact of compliance is measured
in terms of the associated cost for an individual product or product sector. However, the studied
regulations apply to the manufacturing processes, not the products. Thus, converting the cost of
compliance from a specified process  basis to an individual product basis is a necessary first step.
A further complication is that a given product can often be made by more than one process or
combination  of processes, and the cost of compliance for these alternative methods may differ
significantly. The process-to-product conversion therefore requires considerable judgment as to
which manufacturing process is most likely to be used.

     Table E-l lists the process categories to which the EPA water effluent control regulations
apply and  the related product sectors used in the economic impact analysis. The tabulated
numbers are  percentages of the total process tonnages represented by  the applicable product
sectors. For example, the regulations (and their associated costs) for the unbleached kraft process
category would apply to both the unbleached kraft paperboard and the unbleached kraft paper
product sectors. Accordingly, the cost of compliance derived for the existing industry related to
the unbleached  kraft process  category  must be divided between the  paperboard and paper
sectors, in this case  by a ratio of 86 to 14.

     The table also shows that most products can be made by more than one process. The total
costs of compliance for a given product therefore consist of the applicable portions of the costs for
each related process.
                                          E-l

-------
                                                                    TABLE E-l
                                             PRODUCT SECTORS INCLUDED IN STUDIED PROCESS CATEGORIES
\. Product Unbl
^\Sector Kraft Unbl. NSSC
Process ^*^. Paper- Kraft Corru.
Category ^^-^ board Paper Medium
Unbl. Kraft 86.0 14.0
NSSC - - 100.0
Unbl.Kraft/NSSC 58.5 21.8 19.7
Recycled Paperboard -
Const. Paper _ _ _
Bleached Kraft 11.9 7.3
Sulfite -
Dissolving Sulfite -
Soda -
De-Inked - -
Groundwood -
N/I Tissue -._._-
N/I Fine -
(Percentage of process category tonnage)
Bl. Bl. Pkg.
Recycled Board Printing & Ind.
Paper- Const. & & News- Conv.
board Paper Bristols Writing Tissue print Paper
_ _ _ _
_ _ _ _
_ _ _ _ _ _
100.0 - - - -
100.0 - - - - -
19.3 17.9 4.4 7.6 3.7
- 43.2 31.5 15.8 9.5
- - - -
100.0 -
64.6 18.9 16.5
- - 40.6 - 28.3
- - - 100.0
- - - 100.0 -
Bl.
Unc. Kraft Dissolv-
GW Mkt. ing TOTAL
Paper Pulp Pulp
- - - 100.0
- - - 100.0
- 100.0
- 100.0
- 100.0
1.5 23.0 3.4 100.0
100.0
100.0 100.0
- 100.0
- 100.0
31.1 - - 100.0
- 100.0
100.0
Source:  Arthur D. Little, Inc., estimates., derived from information initially obtained from the American Paper Institute
         and National Council of Air & Stream Improvement.

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     Note that the bleached kraft process is used to make unbleached kraft products. This
apparent anomaly is not an error; several mills produce both bleached and unbleached products.
In the cost calculations,  all mills that make a combination of products are included in those
process categories with the higher costs for compliance.

     In a similar manner, costs of compliance for the studied air regulations are also first
developed on a process category and transformed to individual product sectors. However, the
transformation is much simpler than for water control, since all processes except kraft have the
same costs. In general, mills using the kraft process have air control costs that are an order of
magnitude greater.

     The cost to a given mill for compliance with OSHA noise regulations is associated with the
type and number of manufacturing steps that it uses. Thus, it is immaterial whether a kraft or
sulfite manufacturing process is used for pulp production, but it is important to identify whether
the mill is integrated or nonintegrated, because this is related to the type and number of process
steps that must be  controlled. Hence, although OSHA noise regulations are not prescribed by
process category, the process/product transformation analysis is a convenient method of estimat-
ing and allocating the cost of compliance.

     The  percentage  of process category used in the manufacture of the individual product
sectors may vary from year to year because new capacity for one process may replace or add to the
capacity of a different process used in a studied product sector. The percentages shown here are
for the in-place facilities during the early 1970 period.
                                           E-3

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                                   APPENDIX E-1

                            AIR EMISSIONS CONTROL
A.  CONTROL REGULATIONS

1.  Existing Industry
     Under the Clean Air Act, as amended in 1970, air quality standards have been established
for  the whole country. Each state is required to adopt and submit implementation plans to the
Administrator of the Environmental Protection Agency for its emission reduction strategy and
enforcement thereof to achieve national standards for particulates, sulfur oxides, nitrogen oxides,
hydrocarbons, and carbon monoxide.

     These State Air Quality Implementation Plans (SIPs) apply both to recovery boilers (used
in the kraft and sulfite pulp manufacturing processes) and to power boilers used for steam and
power generation. Further, SIP regulations vary widely from state to state, as shown in Table E-2.
Since deriving costs of compliance on a state-by-state basis would be prohibitively expensive,
ADL selected current SIP standards for a single state — Oregon — as the basis for deriving costs
of compliance. Oregon was chosen because:

     •  its requirements are stated more explicitly;
     •  its requirements are more stringent than those of other key producing states; and
     •  its requirements (hence the associated costs) may become  applicable to  other
        states in the near future.

2.  New Mills
     The Environmental Protection Agency is planning to establish air pollution control stand-
ards for new kraft pulp mills. These standards, given in Table E-3, are at the proposal stage and
are  likely to be approved (possibly with some modifications).

     The EPA also established air pollution control standards for new steam-generating boilers
(Table E-4). These limit the emissions of particulates, sulfur dioxide, and nitrogen oxides. The
standards for steam generating boilers are applicable to power boilers in the kraft pulp industry,
as well as to other power boilers with capacities of more than 250 million Btu/hr.

B.  COST MODELS, KRAFT MILLS
     Particulate emissions from the kraft process occur primarily from the recovery furnace, the
lime kiln, and the smelt dissolving tank. These emissions, which are caused mainly by the carry-
over of solids plus sublimation and condensation of the inorganic chemicals, consist principally of
sodium salts, but include some calcium salts from the lime kiln.

     The characteristic  odor of the kraft mill  is caused largely by the emission of hydrogen
sulfide. The major source is the direct contact evaporator, in which sodium sulfide in the black
liquor reacts with carbon  dioxide in the  furnace exhaust. The lime  kiln is  another potential
source, since a similar reaction occurs involving residual sodium sulfide in the lime mud. Lesser
amounts of hydrogen sulfide are emitted with the noncondensible off-gases from the digesters and
multiple-effect evaporators.

                                          E-4

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                                                                          TABLE E-2

Partlculate Matter
Ib/ton ADP Opacity
OREGON
Tnt-nl f
Recovery Boiler 4
Cmrtl t- Tanlr fl 1 ^ -•••- -
Lime Kilna 1 (•

ALABAMA


T -f mo V-t In 1 /..._.. 	
CTou *y-Eam <
FLORIDA
Total f 40



GEORGIA




MAINE




WISCONSIN
Total < 	
Recoveiy Bullet < • • • • -
Smell Tank < — • - - •• ••
Liuie Kiln * • •

STATE STANDARDS FOR AIR EMISSIONS FROM PULP MILLS IN SELECTED STATES
(Items left blank are not specified in the regulations)
Kraft Pulp Mills Sulfite Pulp Mills
Sulfur Dioxide Total Reduced Sulfur Particulate Sulfur Dioxide
ppm • Ib/ton ADP ppm Ib/ton ADP Ib/ton ADP ppm
> 20
300 0.45b 15b 4 800
> 0 °C 40° < >
> 0 2K

., , , t / ^>
/ p • 1 ?
> T .? < >
\ f >

/
/ \
^ e *
» 1 7 S i N-

V
V
>
N.
•v
\.
N
•y
> ^ / )
> / t >
U AO « (
... f j ^ )
\
\
^ ~ -e 1 I EC / . "i
> 0.5 17.5 < '
^
•)
>

NOTES:
SOURCE:
   Noncondensibles from digester, multiple-effect evaporator, and steam or air stripping are burned in lime kiln
   Will drop on July 1, 1978 to0.3lb/ton and  10  ppm
 C Will drop on July 1, 1978 to 0.1 Ib/ton and  20  ppm

"Preliminary Background Information for Standards of Performance
 for Pulp and Paper Industry,"  EPA, August 1975
 Ib/min/ton of unbleached pulp charged to digester
eexpressed as H,S (total TRS only)
r              i
 Ib/each 3,000 Ib black liquid solids fed to furnace
8lb/min/ton of unbleached pulp charged to digester

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                                                                        TABLE E-3
PROPOSED FEDERAL AIR EMISSION AND MONITORING REQUIREMENTS FOR NEW KRAFT Mil LS
Total Reduced Sulfur Partlculate Matter
Recovery Furnace
System
Lime Kiln
Smelt Tank
Brown Stock
Washer System
Black Liquor
Oxidation Systen
Condensate Strip-
ping System
Digester System
Multiple-Effect
Evaporator
System
Ppma
5b
5b
5
,5b
5b
5b
5b
Ib/T ADP R/kR ADP R /dscf g/dscm Ib/T ADP g/kg ADP Opacity
0.15
0.025
0.025
0.01
0.01
0.01
0.01
0.01
0.075
0.0125
0.0125b
0.005
0.005
0.005
0.005
0.005
0.044 O.lb
0.067 gas 0.15 gas
0.13 oil 0.30b oil
0.052 0.119
2.0 1.0 35
0.55 0.275 None
1.07 0.536 None
0.3 0.15b None





Monitoring
Requirements Comments
Opacity, TRS & 02
TRS & 0
TRS & 02
TRSC or Temperature
TRSC or Temperature
TRSC or Temperature
TRS° or Temperature
TRSC or Temperature
Partlculate & TRS corrected to 8% 02
Particulate & TRS corrected to 10% 0~
Partlculate & TRS corrected to 10% 02
Fresh water will insure compliance
Likely to be utilized as combustion
air in the recovery furnace
Likely to be utilized as combustion
air In the recovery furnace
Likely to be oxidized in the lime kiln
Likely to be oxidized in the lime kiln
Likely to be oxidized in the lime kiln
  By volume, dry basis, 4 hr average
b Indicates quantities and units used to specify limits In recommended  standard

0 In most instances, monitoring will not be required, since these sources will be oxidized in the lime kiln or recovery furnace.
  If they are oxidized in separate incinerators or power boilers, only the temperature and oxygen content will be monitored.
  Source:  Arthur D. Little, Inc., estimates

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                               TABLE E-4

          STANDARDS OF PERFORMANCE FOR NEW STEAM GENERATORS
             HAVING CAPACITY GREATER THAN 250 MM BTU/HR
      Particulate - 0.18 g/MM cal (0.1 Ib/MM Btu)

                  - Opacity3 less than 20%
     SO,
   1.4 g/MM cal (0.8 Ib/MM Btu)
   for liquid fuel

   2.2 g/MM cal (1.2 Ib/MM Btu)
   for solid fuel
     NO
°- 0.36 g/MM cal (0.2 Ib/MM Btu)
   for gaseous fuel

 - 0.54 g/MM cal (0.3 Ib/MM Btu)
   for liquid fuel

 - 1.26 g/MM cal (0.7 Ib/MM Btu)
   for solid fuels except lignite
                                                       Measured as NO.
 Failure to meet this requirement because of the presence
 of uncombined water is not a violation of the opacity
 standard.
Source:  EPA, "Standard Support Document for i'ulp and Paper,"
         Draft, December, 1974
                                    E-7

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     The kraft process odor also results from an assortment of organic sulfur compounds, all of
which have extremely low odor thresholds. Methyl mercaptan and dimethyl sulfide are formed in
reactions with the wood component lignin. Dimethyl disulfide is formed through the oxidation of
mercaptan groups derived from the lignin.  These compounds are emitted from many points
within a  mill;  the main sources,  however,  are the digester/blow tank systems and the direct
contact evaporator.

     The cost to achieve various levels of control is presented for each of the affected facilities for
three sizes of kraft mills: 500, 1000, and 1500 tons of air dried pulp per day. The credit represents
the value of recovered salt cake.

     The cost of air pollution per ton of pulp is calculated on the basis of 325 operating days per
year.

1.  Recovery Boiler
     There are two  types of recovery boilers: (1) conventional recovery boilers  and (2)  non-
contact boilers. The conventional  recovery furnace system employs a direct contact  evaporator,
using the hot flue gas from the furnace to evaporate water from  the black  liquor  feed to the
furnace. The direct contact evaporator removes some of the particulates from the  flue gas. In
addition, the physical properties  of the particulate are somewhat different  from those of the
noncontact furnace case.  Because of these factors, the electrostatic precipitator  (ESP) on the
noncontact furnace must be larger (and more expensive)  to achieve the same exit particulate
concentration.

     Capital costs, annual costs, and credits for recovered particulate are shown in Table E-5 for
three different cases:  (1) economic recovery,  (2) particulate emission control to  meet state
standards, and  (3) particulate emission control to meet federal standards.

     Since the  particulate is a valuable material (mainly salt cake), it is economical to recover
the particulate emissions up to a certain level; beyond this, the value of the additional particulate
recovered is not enough to justify the additional investment. (That  is, the incremental return on
the incremental investment drops below the acceptable level for that company.) ADL has used an
economic recovery level of 97.59c control efficiency, which is based on a survey of existing control
devices  on recovery furnaces.1

     The capital cost of the ESP is based upon the recent quotations and cost information given
in the IGCI report.2

     The credit for recovered particulate is calculated on the assumption that all the particulate
is salt cake valued at $35/ton. The  air pollution control  cost is actually the incremental cost of the
particulate device over that of the device used for economic recovery. The  incremental capital
cost, the incremental operating cost, and the incremental operating  cost per ton of pulp are given
in Table E-5.
1. "Particulate Matter Reduction Trends In the Kraft Industry," Technical Bulletin No. 32, National Council of the Pulp
  and Paper Industry for Air and Stream Improvement, Inc., April 4, 1967.
2. Air Pollution Control Technology and Costs in Eight Selected Industries," Industrial Gas Cleaning Institute, EPA
  Contract No. 68-02-1091, Draft Report, 1974.
                                           E-8

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                                    TABLE E-5

                       CONTROL COSTS FOR RECOVERY BOILERS *
           (Credits based on a value of $35/ton for recovered chemicals)
                                                      MILL SIZE (tpd)
                                            500
 ECONOMIC RECOVERY (97.5%)
    Conventional Boiler + ESP

      Capital Cost, $
      Gross Annual Operating Cost, $
      Credits, $/yr

    Noncontact Boiler + ESP

      Capital Cost, $
      Gross Annual Operating Cost, $
      Credits, $/yr

 STATE STANDARDS (99%)
    Existing Conventional Boiler + ESP

      Capital Cost, $
      Gross Annual Operating Cost, $
      Credits, $/Yr

    Existing Noncontact Boiler + ESP

      Capital Cost, $
      Gross Annual Operating Cost, $
      Credits, $/Yr

 FEDERAL STANDARDS (99.7%)
    New Conventional Boiler + ESP

      Capital Cost, $
      Gross Annual Operating Cost, $
      Credits, $/Yr

    New Noncontact Boiler + ESP

      Capital Cost, $
      Gross Annual Operating Cost, $
      Credits, $/Yr
 1,836,000
   459,000
  (612,000)
 2,720,000
   571,000
(1,198,000)
 2,040,000
   510,000
  (623,000)
 3,022,000
   635,000
(1,216,000)
 2,448,000
   563,000
  (621,000)
 3,400,000
   714,000
(1,225,000)
                    1,000
 2,783,000
   696,000
(1,225,000)


 4,122,000
   866,000
(2,397,000)
 3,092,000
   773,000
(1,246,000)
 4,580,000
   962,000
(2,434,000)
 3,710,000
   853,000
(1,243,000)
 5,153,000
 1,082,000
(2,451,000)
                 1,500
 3,550,000
   888,000
(1,835,000)


 5,258,000
 1,104,000
(3,595,000)
 3,944,000
   986,000
(1,868,000)
 5,842,000
 1,227,000
(3,649,000)
 4,733,000
 1,089,000
(1,864,000)
 6,573,000
 1,380,000
(3,676,000)
 Source:   Arthur D. Little, Inc., estimates
*  Total installed cost based upon recent price quotation for ESP and
   on 1974 EPA air regulations for economic recovery level.
                                        E-9

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     The methods used to reduce TRS emissions from the conventional recovery furnaces are
close monitoring and  control of the process variables and  oxidation  of the black liquor to
eliminate the compounds that cause TRS emissions when the black liquor contacts the furnace
flue gas in the direct contact evaporator. No costs are assessed for the required closer control of
the process variables.

     The control technique for reducing TRS emissions is inherent in the basic design of the non-
contact furnace system. A direct contact evaporator is not used; its function is achieved by any of
several methods, such as increasing the economizer section to recover more heat from the flue gas,
adding a steam-heated concentrator to evaporate water from the black liquor, or using com-
bustion air heated by  the furnace flue gas  to evaporate water from the black liquor in an air
contact evaporator. In general, less heat is recovered from the noncontact furnace flue gases than
from conventional furnace flue gases; as a result noncontact furnace flue gases are about 120°F
hotter than those from conventional furnaces. The odor control cost is the combined cost of the
incremental loss of heat energy in the flue gas  and  the incremental  operating cost of the
noncontact furnace over the operating cost of the conventional furnace. These costs are not
included in Table E-5.

2.  Lime Kiln
     The most  common type of  particulate control device  for the  lime  kiln is  the venturi
scrubber. As in the recovery boiler, a certain amount of recovery is economically favorable. For
the lime  kiln, the economic recovery level is assumed to be achieved with a venturi scrubber at
37.5 cm  (15 inches) of water pressure drop.3 Two other venturi scrubbers with higher pressure
drops are also considered as alternatives. Capital cost estimates were based on recent quotations
and on a study done for EPA by the Industrial Gas Cleaning Institute.4

     The cost attributed to air pollution control is the cost difference between the scrubber with
the 37.5-cm pressure drop and the higher powered scrubbers. (Table E-6).

     Proper process conditions such as the cold-end temperature, the oxygen content in the kiln,
the sulfide content in  the lime mud, and the pH and sulfide content of the  scrubbing water are
necessary to reduce TRS emissions from the lime kiln. Cold-end temperature control is a well-
defined process  for controlling TRS emissions. The costs given  in Table E-6 are based on
increasing the cold-end temperature from 350°F to 450°F.

     Scrubbing with a caustic solution will absorb some of the TRS emission from the lime kiln.
For most mills  the caustic is part of the  ordinary makeup caustic to the mill, and no cost is
associated with this alternative.
3.  EPA, Air Regulations, 1975.
4.  "Air Pollution Control Technology and Costs in Seven Selected Areas," Industrial Gas Cleaning Institute, EPA
   Contract No. 68-02-0289, December 1973.
                                          E-10

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                                   TABLE E-6
                       CONTROL COSTS FOR LIME KILN SYSTEM
                                                       MILL SIZE  (tpd)
                                             500
               1,000
             1,500
Economic Level
Venturi Scrubber (37.5 cm WG)
   Capital Cost, $
   Gross Annual Operating Cost, $
   Credits, $/Yr
Existing Mill
Venturi Scrubber (50 cm)
   Capital Cost, $
   Gross Annual Operating Cost, $
   Credits, $/Yr
 87,000       123,000      156,000
 41,600        77,000      111,000
(63,600)     (127,200)    (190,800)
155,000       235,000      300,000
 52,600        98,200      141,000
(65,800)     (131,600)    (197,400)
New Mill
Venturi Scrubber (75 cm)
   Capital Cost, $
   Gross Annual Operating Cost, $
   Credits, $/Yr
196,000       297,000      379,000
 66,500       124,000      178,600
(66,200)     (132,400)    (198,600)
Process Control Cost
   Annual Operating Cost, $
   Cost per ton, $
 17,500
  0.108
38,300
 0.118
60,300
 0.124
  Based on the fuel cost to increase the cold-end temperature 100°F
Source:  Arthur D. Little, Inc., estimates
                                       E-ll

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3.  Smelt Dissolving Tank
     Three control techniques are presented in Table E-7 for the smelt dissolving tank. Demis-
ters are  used to achieve an economic recovery level. Their cost, based on the Sirrine report,6
includes the  mesh pad and a water spray system. A credit of $35/ton is assigned to the recovered
paniculate. The weight of the recovered material is based on the emission factor given in the MRI
report,6 using a collection efficiency of 80fc for the mesh pad.

     A packed tower with associated fan, liquid circulation pump, and control  is used as an
alternative control device  for the smelt  dissolving tank.  Credits for recovered paniculate are
calculated in the same manner as for the  demister, except that the recovery efficiency is 96' '<..

     The other alternative device considered in Table  E-7 is an orifice scrubber with associated
fan, liquid circulation pump, and  control. Its cost is based on recent quotations. The collection
efficiency of the orifice scrubber (20-25 cm WG) is at least 979c.

     The control technique for reducing TRS emissions from the smelt dissolving tank is to use
fresh water in the scrubber. No control costs are presented for control of TRS emissions, since this
feature can be designed into a new mill at essentially no cost.

4.  Digesters and Multiple-Effect Evaporators
     The vent gas streams from the digesters and the multiple-effect evaporators are similar and
contain TRS compounds. These gases present an  odor problem.  Since it is common practice to
treat the combined emissions  from both  facilities, the control costs are estimated accordingly.
The costs presented in Table E-8 assume  incineration in the lime kiln. The system consists of the
necessary piping and blowers to collect the gas streams and delivery piping and controls to inject
the gases into the  lime kiln. The spare incinerator would handle  the gases when the lime kiln is
not operating.

     The digester affects the cost of the control system. The control costs for both cases (batch or
continuous digester, and  multiple-effect evaporator), based on the Sirrine report, are shown in
Table  E-8.

5.  Brown Stock Washers
     The gas from the brown stock washers is a relatively large stream with a low concentration of
TRS. The only control technique is incineration in the recovery  furnace. Cost estimates by the
EPA are given in Table E-9. The control equipment consists of the necessary piping and controls
to inject the gases  into the recovery furnace and hoods,  connecting piping, and controls to collect
the gases.

6.  Black Liquor Oxidation  System
     One method  of reducing  TRS emissions from conventional  recovery furnaces is to oxidize
the black liquor; this eliminates the compounds that cause TRS emissions when the black liquor
contacts the furnace flue gas in the direct contact evaporator.
 5. "Control of Atmospheric Emissions in the Wood Pulping Industry," Environmental Engineering Inc., and J.E. Sirrine
   Company, EPA Contract No.  CPA-22-69-18. March 1970.
 6. MRI Report, EPA Contract CPA-22-69-104, "Handbook of Emissions. Effluents, and Control Practices for Stationary
   Particulate Pollution Sources," November  1970.

                                           E-12

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                                   TABLE E-7
                     CONTROL COSTS FOR SMELT TANK SYSTEM
                                        500
                                                  MILL SIZE  (tpd)
                  1,000
                   1,500
Economic Level
Mesh Pad (80%)
   Capital Cost, $

   Gross Annual Operating Cost, $

   Credits,3 $/yr

Existing Mill
Packed Tower (max. 96%)

   Capital Cost, $

   Gross Annual Operating Cost, $

   Credits,3  $/yr

New Mill
Orifice Scrubber (97%)

    Capital Cost, $

    Gross Annual Operating Cost, $

    Credits3, $/yr
 21,000

  4,100

(11,400)




 77,000

 19,700

(13,600)
 25,000

  4,700

(22,700)




121,000

 34,000

(27,300)
 31,000

  5,700

(34,100)




153,000

 46,000

(40,900)
117,000
50,000
(13,800)
160,000
74,600
(27,600)
195,000
101,200
(41,400)
  Based on recovered particulate at $35/ton
Source:  Arthur D. Little, Inc., estimates
                                          E-13

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                                 TABLE E-8
        CONTROL COSTS FOR DIGESTER AND MULTIPLE-EFFECT EVAPORATORS
        (Based on incineration in the lime kiln; costs include  evap-
                     orator and separate incinerator)
Batch Digester
    Capital Cost, $
    Annual Operating Cost, $
    Cost per Ton, $
Continuous Digersters
    Capital Cost, $
    Annual Operating Cost, $
    Cost per ton, $
                                    500
162,000
 35,000
  0.216

102,000
 25,000
  0.155
                                               MILL  SIZE  (tod)
                1000
235,000
 54,000
  0.165

156,000
 39,500
  0.121
                  1500
318,000
 73,5.00
  0.151

205,000
 54,000
  0.110
Source:  Arthur D. Little, Inc., estimates
                                 TABLE E-9
                 CO?!TROL COSTS FOR THE BROWN STOCK WASHERS
                       (Based on incineration in the
                             Recovery Furnace)
                                  	MILL SIZE  (tpd)
                                     500
                1000
                 1500
   Capital Cost, $
   Annual Operating Cost, $
   Cost per ton, $
164,000
 29,500
  0.182
252,000
 46,000
  0.142
318,000
 58,000
  0.119
Source:  Arthur D. Little, Inc., estimates
                                     E-14

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     The black liquor may be oxidized to reduce TRS emissions from the recovery boiler. The
effluent gases from oxidation with air represent an emission source. (No emissions are generated
when black liquor is oxidized with oxygen.) If  the  recovery boiler is  a new source, federal
regulations would require treatment of the gases. The control method is to incinerate the gases in
the recovery furnace. Since  the off-gas  stream  has a high  moisture content, a  condenser is
necessary. The control costs are shown in Table E-10.

7.  Condensate Stripper
     In mills that have condensate  strippers, the TRS compounds vented from  them can be
controlled by incineration. The cost estimates shown in Table E-ll are based on a system that
includes a fan, duct, seal pot, and flame arrestor. The  duct begins at the overhead condenser on
the stripper and ends at the point where it connects with the noncondensible gas heater that leads
to the lime kiln and the spare incinerator.

C. COST MODELS, POWER BOILERS
     Bark boilers, or combination boilers (bark and  oil, or bark and coal) are used as power
boilers in the pulp industry. The emissions from a bark boiler are primarily particulates (bark
char, fly ash, and sand). Unlike most other  stacks on a kraft mill, no significant gaseous air
pollutants are emitted, and unlike most coal-fired boilers, there is no S02 problem, since there is
little or no sulfur in the bark.

     The S02 problem in the combination boilers will depend on the fraction of the coal or oil
used in the boiler and the sulfur content of the fuel. No S02 control systems are installed in  the
pulp industry, so the cost of such systems is not discussed here.

     Bark fly ash,  unlike most fly ash, is primarily unburned carbon. Collected and reinjected, it
can increase boiler efficiencies from 1% to 4%.

     The air pollution control system for boilers consists of a mechanical collector followed by an
electrostatic precipitator or scrubber. The cost of a mechanical collector is not included,  since  the
char collected from the mechanical collector is recycled and the recovery is considered economic,
rather than attributed to pollution control.

     The cost of electrostatic precipitators for bark boilers and combination boilers of different
capacities is given in Table  E-12. The cost  for  the bark boilers was obtained from the IGCI
report,7 and the cost for the combination boilers was obtained from recent quotations. The boiler
having a rated steam capacity of 350,000 Ib/hr was for a 600-tpd (bleached) air-dried pulp mill.

D. EXISTING INDUSTRY AGGREGATE COST
     The total incremental cost to the existing industry to rise from the 97.5% economic recovery
level to the SIP standard of 99.0% recovery was estimated in three broad  areas: (1) controls for
kraft pulp mills,  (2) controls for power  boilers,  and  (3)  the  early retirement of existing kraft
recovery boilers.
 7. "Air Pollution Control Technology and Costs in Nine Selected Areas," EPA report 63-02-0301 by Industrial Gas
   Cleaning Institute, September  1972.
                                          E-15

-------
                                TABLE E-10
                 CONTROL COSTS FOR BLACK LIQUOR OXIDATION

                                                   MILL SIZE (tpd)
                                          500           1.000        1.500
Air Oxidation
   Capital Cost, $                      333,000       484,000      649,000
   Annual Operating Cost, $             113,000       168,000      231,000
   Cost per ton, $                        0.695         0.517        0.474
Control of Offgases (New Sources)
   Capital Cost, $                      175,000       267,000      347,000
   Annual Operating Cost, $              47,000        78,000      107,000
   Cost per Ton, $                        0.290         0.239        0.220

Source:  Arthur D. Little, Inc., estimates
                                 TABLE E-ll
CONTROL
(Based
; Cost,
COSTS FOR CONDENSATE
STRIPPER

on incineration in lime kiln)
MILL SIZE (tpd)
500
13,000
$ 4,700
0.029
1,000
18,600
5,800
0.018
1,500
23,000
6,700
0.014
   Capital Cost, $
   Annual Operatin;
   Cost per Ton, $


Source:  Arthur D. Little, Inc., estimates
                                     E-16

-------
                                  TABLE E-12
BARK BOILER

  ESP (99%)

     Capital Cost, $
     Annual Operating Cost, $

  ESP (99.7%)

     Capital Cost, $
     Annual Operating Cost, $
  ESP (99%)
     Capital Cost, $
     Annual Operating Cost, $

  ESP (99.7%)
     Capital Cost, $
     Annual Operating Cost, $
CONTROL COSTS FOR POWER BOILERS
Rated Steam
100,000
366,000
st, $ 91,000
440,000
st, $ 110,000
k, 2/3 Oil) 250,000
880,000
st, $ 220,000
1,062,000
st, $ 266,000
Load, Ib/hr
300,000
736,000
184,000
886,000
221,000
350,000
1,080,000
270,000
1,300,000
325,000
Source:  Arthur D. Little, Inc., estimates
                                       E-l'

-------
1.  Controls for Kraft Pulp Mills, Summary
     Air control units costs for existing kraft mill models were estimated previously by process
step and are summarized in Table E-13. Note that a conventional recovery boiler is assumed.

2.  Power Boiler Controls for Other Categories
     The average unit cost for power boiler controls in other process categories was not estimated
on  an engineering  basis,  because  such an estimate would  require a mill-by-mill  survey to
determine applicable standards and approximate costs. The cost calculated for the kraft cate-
gories was assumed to apply.

3.  Retirement of Recovery Boilers in Kraft Categories
     It is standard industry practice  to operate kraft recovery boilers considerably above their
nominal  capacity, but stringent SIP standards for removal  of particulates and TRS usually
cannot be met under these conditions. Thus, the imposition of SIP standards generally requires
the addition of incremental recovery boiler capacity, or the replacement of existing capacity with
a larger unit, so that boilers may be operated near their nominal capacity without loss of pulping
capacity in the mill.

     ADL did not attempt mill-by-mill engineering estimates for this item. Its total industry cost
estimates include a capital allotment for premature recovery boiler replacement based on total
capacity, to acknowledge that this is a legitimate and significant expense in complying with  SIP
regulations. The total cost for this item is estimated at 20% to 25(r of the total replacement value
of recovery boilers in the kraft categories.

4.  Expenditures Through 1974
     According to industry reports,  about one third of all mills were in compliance in  1974. This
was interpreted as meaning that one third of the total capital investment for compliance with  SIP
standards (including the economic recovery  level) had been made by 1974. ADL distributed
capital and operating costs by assuming that all mills had achieved the economic recovery level,
and that additional expenditures would be proportional to capacity throughout the kraft cate-
gories. This rough approximation is probably adequate  for estimating total industry costs  and
costs by major process and product sectors, and for the total industry to achieve compliance with
SIP standards.

     ADL further assumed that 80% of the incremental  cost of compliance will be expended in
the period 1975 to 1977 and 20% thereafter.  It is apparent that  uniform compliance with  SIP
standards will not be achieved by 1977; however, the 80/20 percentage distribution over  the
studied time period is only an  approximation.

5.  Summary Control Costs
     Costs of compliance with SIP standards are aggregated by major kraft process category and
mill size  in Table E-14. They are allocated into major process subcategories used in this study.
(See Table III-7.) Note that the operating costs indicated are for operation and maintenance
(O&M) only; as required for the impact analysis methodology, depreciation and cost of capital
are excluded. The process-to-product  transformation discussed previously was applied to estab-
lish the cost of compliance by product sector (Table  III-8). Recall that the costs for SIP standards
were developed incrementally  from .the assumed 97.5% "economic level of recovery"; these costs
would be appreciably different had another economic recovery level been assumed.


                                        E-18

-------
                                                                       TABLE E-13
W
SUMMARY OF AIR CONTROL UNIT COST
ESTIMATES, EXISTING KRAFT MILLS
(thousands of dollars)
Mill Size, Bleached Tonnage


Item
SIP STANDARDS
Particulates:
1 Smelt Tank
Lime Kiln
Power Boiler
Recovery Furnace
TRS:
Digester & Evaporators
Washers
Condensate Stripping
Recovery Boiler (B.L. Oxidation)
Total Process Controls for
SIP Level (99.0%)
Economic Level of
Particulate Recovery (97.5%)
Recovery Boiler3
Lime Kiln
Smelt Tank
Total Economic Level (97.5%)
Increments for Additional Process
Controls to SIP Standards
(by difference)
Total Cost to SIP $/annual ton
Bleached
Unbleached
Total Economic Level, $ /annual ton
Bleached
Unbleached
Increment to SIP Level, $/annual ton
Bleached
Unbleached
Additional Increment for early
retirement of recovery boiler3
Estimated at $4.0 MM for 800 tpd
Bleached Kraft:
Bleached
Unbleached
500


Capital


77
155
1,056
2,040

162
164
13
333
4,000


1,836
87
21
1,944


2,056

23.2
19.5

11.3
9.5

11.9
10.0




15.0
12.0
tpd
Annual
Operating
(O&M)


(6)
(35)
106
(429)

10
-
-
63
(291)


(429)
(35)
(11)
(475)


184

(1.7)
(1.4)

(2.8)
(2.3)

1.1
0.9




-
-
1000


Capital


121
235
1,600
3,092

235
252
19
484
6,038


2,783
123
25
2,931


3,107

17.5
14.7

8.5
7.1

9.0
7.6




15.0
12.0
tpd
Annual
Operating
(O&M)


(12)
(68)
160
(946)

19
-
-
95
(752)


(946)
(68)
(22)
(1,036)


284

(2.2)
(1.8)

(3.0)
(2.5)

0.8
0.7




-
—
1500


Capital


153
300
2,041


318
318
23
649
7,746


3,550
156
31
3,737


4,009

15.0
12.6

7.2
6.1

7.8
6.5




15.0
12.0
tpd
Annual
Operating
(O&M)


(18)
(101)
204


26
-
-
134
(1,228)


(1,473)
(101)
(33)
(1,607)


379

(2.4)
(2.0)

(3.1)
(2.6)

0.7
0.6




-
• "*
     a Recovery boiler apportionment to SIP and federal levels was used as the basis for allocating combination (bark and oil) power boiler costs.
       Source:  Arthur D. Little, Inc., estimates.

-------
                                                                           TABLE E-14
m
to
AIR CONTROL COSTS TO EXISTING INDUSTRY BY PROCESS SUB-CATEGORY AND




(thousands
Economic Level
for Process Controls
Process Category
Bleached Kraft
Small
Medium
Large
Sub-Total
Unbleached Kraft Small
Medium
Large
Sub-Total
Kraft/NSSC
Small
Medium
Large
Sub-Total
Other Categories
TOTAL
1977
Capacity
(000 tpy)
920
8,330
17.170
26,420
960
3,560
4,240
8,760
470
780
3,710
4,960
26.830
66,970
Capital
10,396
70,805
123.624
204,825
9,120
25,276
25,864
60,260
4,465
5,538
22,631
32,634
_
298,000
Annual
Operating
(O&M)
(2,576)
(24,990)
(53,227)
(80,793)
(2,208)
(8,900)
(11.024)
(22,132)
(1,081)
(1,950)
(9,646)
(12.677)
_
(115,000)
of dollars)

Economic Level to SIP Level
for Process Controls
Capital
10,948
74,970
133,926
219,844
9,600
27,056
27,560
64,216
4,700
5,928
24.115
34,743'
107.000
426,000
Annual
Operating
(O&M)
1,012
6,664
12.019
19,695
864
2,492
2,544
5,900
423
546
2.246
3,215
10.700
39,500
SIZE

Recovery
Boiler
Retirement
Capital
13,800
124,950
257.550
396.300
11,520
42,720
50.880
105,120
5,640
9,360
44.520
59,520
-
560,000b


Total Economic Level
to SIP Standards
Capital
24,748
199,920
391,476
616,144
21,120
69,776
78.440
169,336
10,340
15,288
68.635
94,263
107.000
986,000b
Annual
Operating
(O&M)
1,012
6,664
12.019
19,695
864
2,492
2,544
5,900
423
546
2.246
3,215
10.700
39,500
Estimated Expenditures
through 1974
Bleached Kraft
Unbleached Kraft
Kraft/NSSC
Other
TOTAL EXPENDITURES

NET TOTAL



204,825
60,260
32,634
298,000
—
(80,793)
(22,132)
(12,677)
(115,000)
—
90,000
26,000
14,000
130,000
296,000
8,000
2,400
1,300
11,700
28,000b
-
-
560,000
90,000
26,000
14,000
130,000
860,000b
8,000
2,400
1,300
11,700
28,000b
         Recovery boiler apportionment to SIP and federal levels was used as
         the basis for allocating combination (bark and oil) power boiler costs.

         Rounded off
        Source:  Arthur D. Little, Inc., estimates.

-------
E.  NEW MILLS, UNIT COSTS FOR SELECTED EXAMPLES
     To estimate new mill manufacturing costs, ADL adapted the air control cost estimates
prepared for kraft process sources  and combination boilers. Table  E-15  is a summary of the
control costs for new kraft mill sources (excluding power boiler) for 500 and 1000 tons per day. The
costs for the studied 800-tpd bleached kraft pulp mill and a 1000-tpd unbleached kraft pulp mill
were extrapolated from these base cost estimates by use of the 6/10 factor. New mill sources were
based on a conventional recovery boiler with black liquor oxidation for TRS control.

     Note that incremental costs  (capital and operating)  are shown for the upgrading from
"economic level" to SIP standards and from SIP standards to federal regulations. This differs
from the presentation of the summary cost estimates for new mills (Table  111-12), where the
incremental cost reported is that from "economic level" to federal requirements.

     While the total cost for treating air emissions is a relatively "hard" number (i.e., within the
accuracy of pre-engineering cost estimates, the  increment ascribed to the "economic level" and
subsequently  to  the various standards is more arbitrary. The value of chemicals and makeup
chemicals used at any given installation could vary widely; and thus has a profound effect upon
the "economic  level" of control. As noted, ADL used EPA's estimate  of  97.5%  particulate
recovery as the "economic level"; obviously, if a smaller percentage were used, the incremental
capital and operating costs of compliance would be substantially greater.

     Table E-16 summarizes air control costs (including power boiler) for new mills producing
the specific product grades selected for economic modeling. Air control costs  have been treated
the same as all  other pulp mill costs; that is, a portion of total pulp mill cost is allocated to a
paper or board product in direct proportion to the percentage of pulp mill output used by that
product. (See Section  Ig of Appendix F.)
                                         E-21

-------
                                                                  TABLE E-15
                                            SUMMARY OF AIR CONTROL COST ESTIMATES FOR NEW PULP MILL
                                                             (thousands of  dollars)
rn
NJ
Economic
Level (97.5%)
Item
A. 1000 tpd Bleached Kraft
Recovery Boiler
Lime Kiln
Smelt Tank
Digester & Evaporators
Black Liquor Oxidation
Brown Stock Washers and
Condensate Stripping
Capital

2,780
120
30
-
-

-
Annual Oper-
ating (O&M)

(9A6)
(68)
(22)
-
-

-
Increment from Eco. Level
to SIP Standards (99%)
Capital

310
120
90
160
270

270
Annual Oper-
ating (O&M)

_
-
10
16
38

-
Increment from SIP to
Federal Standards (99.7%)
Capital

620
60
40
-
-

-
Annual Oper-
ating (O&M)

_
15
35
-
-

-
                                       TOTAL
2,930
(1036)
1,220
64
720
50
          B.   500 tpd  Bleached Kraft
             Recovery  Boiler
             Lime Kiln
             Smelt Tank
             Digester  & Evaporators
             Black Liquor Oxidation
             Brovn Stock Washers and
                        Condensate Stripping

                                       TOTAL
1,840
90
20
-
-
-
(429)
(35)
(ID
-
•
-
200
70
60
100
180
180
-
-
5
10
21
-
410
40
40
-
-
-
-
6
25
-
—
-
1,950
(475)
  790
36
490
                                                                       31
             Source:   Arthur D.  Little, Inc., estimates

-------
                                     TABLE E-16
AIR CONTROL COSTS,
NEW MILL SOURCES, BY
PRODUCT SECTOR
(thousands of dollars)
Economic Increment to
Level (97.5%) SIP Standards (99%)
Product and
Capacity Capital
Unbleached Kraft Liner
1000 tpd
Pulp Mill 2,800
Power Boiler
TOTAL 2,800
Integrated to 800 tgd
Unbleached Kraft:
• :>Kraft Bag Paper, 230 tpd
Pulp Mill 700
Power Boiler
TOTAL 700
Semi-Chemical Corrugating
Medium, 450 tpd
Pulp Mill
Power Boiler
TOTAL
Integrated to 800 tpd
Bleached Kraft:
• -Market. Pulp, 800 tpd
Pulp Mill 2,600
Power Boiler
TOTAL 2,600
• SBS Board, 500 tpd
Pulp Mill " 1,600
Power Boiler
TOTAL 1,600
• Bond Paper, 300 tpd
Pulp Mill 1,000
Power Boiler
TOTAL 1,000
• Book Paper, 300 tpd
Pulp Mill 1,000
Power Boiler
. TOTAL 1,000
• Tissue, 163 tpd
Pulp Mill 500
Power Boiler
TOTAL 500
• Newsprint, 550 tpd
Pulp Mill (140 tpd Kraft) 500
Power Boiler
TOTAL 500
Sulflte Dissolving Pulp
550 tpd
Pulp Mill
Power Boiler
TOTAL
Annual Oper-
ating (Q&M)
(930)
(930)
(210)
(210)
(830)
(830)
(490)
(490)
(300)
(300)
(300)
(300)
(160)
(160)
(150)
(150)
-
Capital
1,100
900
2,000
310
250
560
900
900
1,060
1,160
2,220
690
830
1,520
370
500
870
370
580
950
190
250
440
120
500
620
900
900
Annual Oper-
ating (O&M)
60
90
150
10
25
35
90
90
55
116
171
40
83
123
20
50
70
20
58
78
20
25
45
13
50
63
90
90
Increment
Standards
Capital
650
200
850
190
50
240
200
200
640
240
880
410
170
580
230
100
330
230
120
350
110
50
160
80
100
180
200
200
to Federal
(99.7%)
Annual Oper-
ating (O&M)
50
20
70
10
5
15
20
20
45
24
69
30
17
47
10
10
20
10
12
22 .
10
5
15
7
10
17
20
20
All Other Products
                         No  federal  air  control  costs




                                             E-23

-------
                              TABLE E-16  (cont'd)


          AIR CONTROL COSTS, NEW MILL SOURCES. BY PRODUCT SECTOR
                             (thousands of dollars)
                                    Increment to SIP Standards
                                                    Annual
                                                    Operating
                                    Capital	(O&M)
                                                               (1)
RECYCLED PAPERBOARD

    Recycled Boxboard, 400 tpd
    Jute Linerboard, 330 tpd
    Bogus Medium, 330 tpd
    Gypsum Linerboard, 400 tpd
300
300
200
300
70
60
50
60
RECYCLED NEWSPRINT, 330 tpd
200
40
DEINKED TISSUE, 76 tpd
100
10
(1)
   Standards and costs apply to SIP requirements for power boilers.
   There is no economic particulate recovery level. There are no
   applicable federal standards for these mills.
                                  E-24

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                                    APPENDIX E-2

                           WATER EFFLUENT CONTROL
A.  CONTROL REGULATIONS
     The Federal Water Pollution Control Act Amendment of 1972 states: "It is the national goal
that the discharge of pollutants into navigable waters be eliminated by 1985." Working toward
this goal incrementally, EPA has promulgated and proposed two interim levels of water effluent
control  —  one for the existing industry and the other for new sources. An additional, more
stringent level of control will have to be imposed beyond these interim objectives to achieve the
1985 goal.

1.  Existing Industry
     Water effluent guidelines based on the Best Practical Control Technology Currently Avail-
able (BPT) were promulgated for 1977. Table E-17 summarizes the specified limits of BOD and
suspended  solids by process  categories. Note that the specifications indicate a maximum dis-
charge for  a single day and  for a 30-day average. Wherever the maximum daily discharge is
specified, it is about 1.7 times greater than the 30-day average level; this reflects the fact that
occasional large discharges can be tolerated, because they tend to be balanced by low levels on
other days when averaged over a month.

     Note also that color removal is not specified for the BPT level of control. A more stringent
control level — Best Available Technology Economically Achievable (BAT)  — was proposed for
1983. These regulations (Table E-18) would reduce  the permissible amount of BOD and sus-
pended  solids by about 50% and also require color removal in certain categories.

2.  New Mills
     New Source Performance Standards (NSPS) were proposed for all new plant construction.
In most categories, these regulations are less stringent in BOD and suspended solids removal than
the BAT regulations. Further, unlike the  BAT regulations proposed for existing mills,  color
removal is  not specified. Table E-19 presents the  specific  requirement for  each of the studied
process  subcategories. Again, note that the daily permissible level of discharge is higher than the
30-day average.
B.  DATABASE — THE DEVELOPMENT DOCUMENTS1
     ADL was not retained to develop engineering cost estimates for compliance with the studied
regulations; it was expected to rely upon unit cost data published in the EPA Development
1. The "Development Documents" referred to in this appendix include the following

     •  "Development Document for Advanced Notice of Proposed or Promulgated Rule Making for Effluent
        Limitations Guidelines and New Source Performance Standards for the Bleached Kraft, Groundwood,
        Sulfite, Soda, Deink, and Non-Integrated Paper Mills Segment of the Pulp, Paper and Paperboard
        Point Source Category," EPA 440/1-75/047, August 1975.
     •  "Development Document for Interim Final and Proposed Effluent Guidelines and Proposed New
        Source Performance Standards for the Bleached Kraft, Groundwood, Sulfite, Soda, Deink and Non-
        Integrated Paper Mills Segment of the Pulp, Paper, and Paperboard Point Source Category," Vol. 1,
        EPA 440/1-76/047-a, January 1976.
     •  "Development Document for Effluent Limitations Guidelines and Standards of Performance: Pulp,
        Paper, and Paperboard Industry," draft report to EPA by Wapora, Inc., June 1973.
     •  "Development Document for Effluent Limitations Guidelines and Standards of Performance: Builders'
        Paper and Board Industry," draft report to EPA by Wapora, Inc., June 1973.

                                           E-25

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                                   TABLE K-17
EPA WATER

Process Subcategory
Unbleached Kraft
NSSC Medium
Sodium Base
Ammonia Base
Unbleached Kraft /NSSC
Recycled Paperboard
Construction Paper
Bleached Kraft
BCT Kraft
Fine Kraft
Dissolving Kraft
Market Kraft
Sulfite
Dissolving Sulfite
Soda
Deinked
Groundwood
C-M-N Paper
Chemi-Mechanical
Therrao-Mechanical
Fine Papers
N/I Tissue
N/I Fine
EFFLUENT GUIDELINES
(Ib/ton)
BOD5
Max.
30-Day
Avg.
4.0
10.0
10.0
7.0
2.0
5.0
12.7
9.4
25.9
14.2
30.4
45.4
11.5
14.0
8.4
7.0
5.2
• 7.5
9.4
8.4
, BPT (1977)

Limit
Max.
Day





21.5
15.8
43.9
24.1
51.5
77.0
19.5
23.8
14.2
11.9
8.8
12.7
15.8
14.2

TSS
Max.
30-Day
Avg.
6.0
10.0
10.0
7.0'
2.0
3.0
20.6
14.7
31.1
20.6
42.3
52.5
16.6
25.3
14.0
11.8
8.9
12.9
9.3
8.5

Limit
Max.
Day





45.2
32.1
68.1
45.2
92.8
115.1
36.4
55.4
30.7
25.8
19.4
28.2
20.5
18.7
pH for all subcategories shall be between 6.0 to 9.0.




Source:  EPA Development Documents
                                      E-26

-------
                                     TABLE E-18
EPA WATER
EFFLUENT
GUIDELINES, BAT
(1983)
(Ib/ton)
Process Subcategory
Unbleached Kraft.
NSSC Medium
Sodium Base
Ammonia Base
Unbleached Kraft/NSSC
Recycled Paperboard
Construction Paper
Bleached Kraft
BCT Kraft
Fine Kraft
Dissolving Kraft
Market Kraft
Sulfite
Dissolving Sulfite
Soda
De inked
Groundwood
C-M-N Papers
Chemi-Mechanical
Thermo-Mechanical
Fine Papers
N/I Tissue
N/I Fine
BOD
Limi
Max
30-Day
Avg.
2.0
3.5
3.5
3.5
1.0
2.5
5.7
3.8
10.9
6.7
12.9
16.7
4.8
5.0
3.5
2.5
2.2
3.3
4.0
2.5
t
Max.
Day





11.8
8.0
22.5
13.8
26.6
34.6
10.0
10.4
7.3
5.2
4.5
6.9
8.3'
5.2
TSS -
Limit .Color
Max.
30-Day
Avg.
3.0
5.0
5.0
3.5
1.0
1.5
3.7
3.1
6.9
4.5
6.3
8.1
3.1
4.8
2.6
2.4
1.3
2.4
1.9
1.3
Max.
Max. 30-Day Max.
Day Avg . Day
12.0
12.0
7.0
8.0
-
-
8.1 130 260
6.7 130 260
15.2 250 500
9.9 190 380
13.8
17.7
6.7 130 260
10.6
5.8
5.3
2.8
2.0
4.2 -
2.8 -
pH for all subcategories shall be between 6.0 tind.9.0.
Dashes indicate that color removal is not required.
Source:  EPA Development Documents
                                      E-27

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                                       TABLE E-iy
EPA WATER EFFLUENT GUIDELINES, NSPS
(Ib/ton)




Process Subcategory
Unbleached Kraft
NSSC Medium
Sodium Base
Ammonia Base
Unbleached Kraft/NSSC
Recycled Paperboard
Construction Paper
Bleached Kraft
BCT Kraft
Fine Kraft
Dissolving Kraft
Market Kraft
Sulfite
Dissolving Sulfite
Soda
Deinked
Groundwood
C-M-N Papers
Chemi-Mechanical
Thermo-Mechanical
Fine Papers
N/I Tissue
N/I Fine

Limi£
Max
30-Day
Avg.
3.5

5.0
5.0
4.5
1.5
4.0

5.7
3.8
10.9
3.7
8.2
16.7
4.8
7.5

3.3
2.5
5.2
3.3
4.0
2.5



Max.
Day








11.8
8.0
22.5
7.6
17.0
34.6
10.0
15.6

7.3
5.2»
10.7
6.9
3.3
5.2
TSS
Limit
Max .
30-Day
Avg .
5.0

6.0
6.0
6.0
1.5
2.5

7.2
6.1
14.0
5.2
7.9
16.1
6.].
7.2

5.2
4.8
4.0
4.8
3.7
2.4



Max.
Dav








15.9
13.4
30.7
11.3
17.3
35.3
13.4
15.9

11.2
10.6
8.8
10.6
8.5
5.3

Color
Max.
30-Day Max.
Avg. Day;
25

20
20
22
. - •
-

-
-
-
— —
-

-
-

'-
_
-
- —
-
*
pH for all subcategories  shall be bL'tiv.^c-n 6.0 ..;H: 9.0.




Dashes indicate that  color  removal is not required.




Source:  EPA Development  Documents
                                       E-28

-------
Documents  — i.e., pre-engineering cost estimates developed for sample mills  — to calculate the
total cost to the entire industry, or to major sectors of the industry. ADL's task included reviewing
and modifying the published data to put all cost estimates on a comparable basis. Below is a brief
description of the key points that pertain to these unit cost data  as presented in the  EPA
Development Documents.

1.  Industry Categorization
     The Development Documents characterized the U.S. pulp and paper industry in terms of
various pulping and nonintegrated papermaking process categories. In some instances  (e.g.,
bleached kraft) the categories are further divided into sub-categories. Typical small, medium,
and large plant sizes are selected within each of these categories and subcategories to indicate
how the scale of operations  affects the cost of effluent  control. Thus, a range of hypothetical
models is obtained which represents typical sizes of individual pulping or papermaking processes.
Mills in the industry are then aggregated by these selected pulping and papermaking processes
for cost calculations. The detailed rationale for categorization is contained in Section IV of the
Development Documents.

     Of course, many mills in the industry utilize more than one pulping  process and produce
more than a single grade of paper or paperboard. These "combination" mills  were placed in the
process category with the most offensive effluent characteristics.

2.  Specified Standards
     The Development Documents specified the three levels of effluent control previously identi-
fied (BPT, BAT, and NSPS). The rationale for selecting the three levels of effluent limitations is
presented in Chapters IX through XI of the Development Documents.

3.  Treatment Technology
     The Development Documents use an engineering approach to specify the effluent control
treatment technology; that is, the specifications are based on  typical water effluent character-
istics including total flow, TSS (total suspended  solids), and BOD6 (five-day biological oxygen
demand). A "treatment train" is proposed for each subcategory to meet each level of control.
Both internal (process modification) and external  ("end of pipe") control measures are used.

     In general, the technology selected for BPT and BAT is sequential; that is, BAT can be met
by adding items to the treatment train selected for BPT. Primary and secondary treatments with
supplementary solids removal are  specified to meet the BPT guidelines  for all subcategories
except nonitegrated fine paper and tissue. Two alternatives, an aerated stabilization basin (ASB)
or activated sludge (AS), are included to accomplish secondary treatment.

     To achieve BAT guidelines, secondary treatment and media filtration are required for all
subcategories,  plus minimum lime treatment for color removal in the  kraft, NSSC, and soda
subcategories.  Figure  E-l  is  a generalized flow diagram for external treatment  alternatives as
shown in the Development Documents. Internal treatment methods, such as felt hair removal
and re-use of vacuum pump seal water, are primarily process modifications that reduce the water
effluent load and/or pollutants. These process changes often result in cost savings through
economies in materials and/or energy; thus, it is difficult to state unequivocally that a particular
item is mainly a process improvement or an  effluent control step. In the Development Docu-
ments, capital costs for all  items  listed as internal control  technology (except sulfite liquor


                                           E-29

-------
 Spill Storage
                                        Mill Raw
                                         Waste
    screening  ) >
  LAJ
Coarse
Screening
	  |	Alternatives	1	
                      Stationary
                      Screen
                         Traveling
                          Screen
    Suspended   1
    Solids       )
    Removal     j

    Sludge to Disposal
   BOD Removal
                                                    Alter not ives
                      Sedimentation
                         Lagoon
                          Clarifier
                                                   LA:.
 Filtration or
Flotation Unit
                        Aerated
                    Stabilization Basin
                             Alternatives \^
                               T— -i— 
-------
incineration and recovery) were  charged to effluent control; however, it  was assumed that
operation and maintenance charges were offset by material and energy savings. It was assumed
that heat and chemical recovery associated with sulfite liquor recovery would pay back the initial
investment in sufficiently short time to make the installation attractive; hence, the costs associ-
ated with this internal treatment step were not included as part of the treatment costs. A detailed
discussion of the various external and internal alternatives is presented in  Section VIII of the
Development Documents.

4.  Cost Models, General
     The Development Documents used the cost model  approach to develop engineering cost
estimates for compliance. Water conditions were postulated for "representative" mills according
to plant size and manufacturing process. In most of the subcategories, three sizes of models
(small, medium, and large) were specified on the basis of the treatment trains selected.

     For each model, cost curves and resultant unit costs were then developed, based on "model"
effluent  treatment  facilities  sized for  several flow capacities. The Development Documents
postulated  certain unit processes, yard piping layouts, methods and materials of construction,
site and soil characteristics,  unit construction costs, and operational practices for each of the
"model" treatment facilities. Daily peaking factors were applied in the cost  development to
account for day-to-day variations in effluent from the "model" mills.

     Costs were also  estimated separately for treatment trains using  an  aerated  stablization
basin (ASB) or activated sludge (AS) for biological treatment. Although activated  sludge typi-
cally costs about 50% to 80% more than ASB, some mills may  desire or need activated sludge for
increased efficiency during cold weather or because insufficient land is available for an ASB.

     The cost of land for the treatment facilities or for the disposal of residual solid waste is not
included in  the estimates. Land requirements for various treatment technologies,  however, are
tabulated in the Development Document. These requirements are based on sludge disposal to an
on-site lagoon for BPT and on dewatering and offsite landfill disposal for BAT.

     In some instances, land  may not be available for the disposal of sludge. In that event, this
sludge would have to be incinerated at the plant site. The cost of this step was not estimated in
the Development Documents.  ADL "guesstimates" that in those installations requiring  in-
cineration, the capital investment requirement would increase by 10-30% of the unit cost.

     Both capital and operating costs were estimated for external treatment.  Capital  costs
include the  traditional expenditures for such items as mechanical and electrical equipment,
instrumentation,  yard  and process piping, earth-work, unit construction, site preparation and
grading, equipment installation and testing, and engineering. However, as stated previously, only
capital costs were included for internal process control; direct operating costs were assumed to be
offset by savings, so that only the capital-related items — depreciation and cost of capital —
were included in the operating costs associated with internal control. Items such as electrical
equipment, instrumentation, process piping, site preparation, and engineering were included as a
percentage of the base capital costs, which vary  for each applicable control technology. A 15%
contingency was also included with each control technology to cover miscellaneous work items
not included in the estimates.
                                          E-31

-------
     Operating costs include: (1)  operation and maintenance costs, which are "the sum of the
annual costs for operating labor, maintenance labor, energy requirements, and chemicals" and
(2) depreciation and cost of capital at 15% of total capital. Note that maintenance materials are
not included.

5.  Cost Models, Existing Mills
     The costs for internal and  external treatment are shown separately for (1)  treatment
facilities in place as of the end of 1973,  (2) BPT water effluent control, and (3) BAT water
effluent control. A different estimating procedure is used for internal and external controls: the
cost of internal treatment facilities in place is calculated by estimating a percentage of each item
which corresponds to the percentage of mills in a category that are presumed to have installed
that item by 1973; the cost of external treatment facilities in place is calculated by postulating a
treatment train that includes some items  and excludes others for a typical mill. Thus, the 1973
internal  estimates are  intended to correspond to a category average, but not necessarily to a
typical mill model. Conversely,  1973 external estimates are intended to correspond to a typical
mill model.

     The estimates of in-place effluent treatment facilities used as the data base in  the Devel-
opment Documents appear to understate the extent of  the treatment installed by the paper
industry through 1973. For example, no external treatment facilities were assumed to be in place
in unbleached kraft, NSSC medium, unbleached kraft/NSSC, recycled paperboard, construction
paper, or nonintegrated tissue and fine categories. Actually, most of the mills in these categories
already have some level of secondary treatment.

     The other process categories were presumed  to have only primary treatment. Again, many
mills in these other categories already have some degree of biological treatment. Thus, while
those mills with secondary treatment may have to modify or supplement their existing facilities
to meet  the BPT and  BAT regulations, in general the basic assumption in the Development
Documents regarding the level of in-place facilities tends to overstate the incremental costs to
achieve BPT control levels.

     About 130 mills are tied into municipal treatment. In general, these are nonintegrated paper
or paperboard mills that make tissue, recycled paperboard, or construction paper. The Devel-
opment  Documents assumed that no investment and/or operating costs would be incurred by
these mills for waste treatment.

6.  Cost Models, New Mills
     NSPS guidelines for new mills meet some, but not all, of the BAT control requirements that
apply to  existing mills. While the internal technologies and costs are the same as for BAT, color
removal is  not required by NSPS as part of the external treatment; hence, the costs are not the
same. Note, however, that whereas the listed costs for BPT and BAT are incremental to those of
the treatment facilities assumed to be in place through 1974, the cost for NSPS is the total cost for
internal and external treatment. Hence, the cost for NSPS is greater than the incremental costs
for BPT plus BAT, even though the requirements  are not as stringent.

     Since a 10-year permit is written for  a new source, the cost of the transition from NSPS to
BAT will not be incurred until  after 1986, which is beyond the time period considered in this
study.
                                         E-32

-------
7. Variability of Cost Models
     The model approach is useful in assessing overall industry costs or aggregate costs for
subcategories containing a large number of mills.  However, in applying the cost estimates to
individual mills or small subcategories, one must  consider the possible variations in required
technology and/or site-specific costs. The following comments on cost variability are quoted from
the Development Documents:

     "It should be recognized that actual treatment costs vary widely from mill to mill,
     depending upon the design and operation of the production facilities and local condi-
     tions.  Furthermore,  effluent  treatment costs reported by the industry vary greatly
     from one installation to another, depending upon bookkeeping procedures. The esti-
     mates of effluent volumes and treatment methods described in this section are in-
     tended to represent those of  the subcategories covered by this report.  However, the
     industry is extremely heterogenous, in that almost every installation has some unique-
     ness which could be of importance in assessing effluent treatment problems and their
     associated costs.
     "It should be remembered that actual external treatment costs may vary significantly
     from mill to mill,  depending upon  the  climate, topography, soil conditions,  unit
     locations, and the design and operation of the  particular waste treatment facility."

C. ADJUSTMENT OF THE DATA BASE

1. Industry Categorization
     The ascribing of mills to a process category is not a  precise analytical exercise. As men-
tioned, with the exception of kraft with NSSC  pulping, each cost model in the Development
Documents represented a single process; in practice, however, many mills employ more than one
pulping or papermaking process. Accordingly, designating a mill as belonging in a certain process
category (and hence implicitly in  a product sector for economic  impact analysis) is somewhat
arbitrary.

     ADL used the same process categories as those identified in the Development Documents to
categorize the industry, but used a somewhat different rationale for assigning  mills to those
categories.  The criteria that were  applied in  grouping mills  by category are described in
Appendix B.

2. Revised Standards
     Since the unit cost estimates reported in the original Development Documents were pre-
pared, EPA has revised the studied regulations. In  general, the overall permissible level of BOD
discharge has been increased  by about  20-30% and the overall suspended solids discharge
increased by about 25-40% beyond the level initially reported and used as the basis for engineer-
ing cost estimates. Table E-20 compares  the  initial and revised BPT regulations for selected
process categories. (The revised regulations are contained in the updated Development Docu-
ment of January  1976.) While the revised regulations are,  in some categories,  significantly less
stringent (particularly with reference to suspended solids removal), the same unit costs based
upon the more stringent regulations were published in January 1976 by EPA and used by ADL
for the revised regulations.
                                         E-33

-------
                                TABLE E-20
COMPARISON OF THE INITIAL AND REVISED
WATER EFFLUENT

Process Subcategoey
Bleached Kraft
BCT Kraft
Fine Kraft
Dissolving Kraft
Market Kraft
Sulfite, Paper Grade
Dissolving Sulfite (low
Soda
De inked
Groundwood
C-M-N Paper
Chemi-Mechan ic a 1
Thermo-Mechanical
Fine Papers
N/I Tissue Paper
N/I Fine Paper
GUIDELINES FOR SELECTED
(Ib/ton)

BOD
Limit
Initial

12.7
9.4
25.9
14.2
30.4
alpha) 45.4
11.5
14.0

8.4
7.0
5.2
7.5
9.4
8.4
PROCESS

Maximum

Revised

13.9
11.4
26.7
15.8
39.2
44.7
14.4
18.9

8.9
14.1
10.0
8.0
12.5
8.5
BPT
CATEGORIES

30-day Average
TSS
Limit
Initial

20.6
14.7
31.1
20.6
42.3
52.5
16.6
25.3

14.0
11.8
8.9
12.9
9.3
8.5




Revised

30.2
24.8
38.6
31.7
48.0
54.8
26.8
28.4

15.8
20.9
18.4
14.6
10.0
11.8
Source:  EPA Development Documents
                                 E-34

-------
3. Treatment Technology
     ADL has not made an in-depth analysis of the methods of treatment specified for achieving
the prescribed levels of effluent control. In general, however, as the cost models are based upon
treatment methods that  are actually  used to achieve the prescribed levels of treatment, the
specified "treatment trains" appear to  be appropriate for deriving cost estimates.

     The "model" treatment facilities may prove inadequate or  insufficient to meet the pre-
scribed  level in certain mill situations.  Site-  and mill-specific  cost estimates  are obviously
preferable in such cases. Thus, while it is not the intent of either the Development Documents or
the industry analysis prepared by ADL to identify and evaluate every site- and process-specific
situation, the studies provide (a)  a reasonable method of assessing  total cost to the industry, and
(b) a convenient point of departure for evaluating specific situations that may be at variance
with the sample cost models.

4. Cost Models, General
     The effluent control  cost estimates published in the Development Documents are expressed
in second-quarter  1974 dollars.  To adjust these to mid-1975 dollars, ADL increased  both  in-
vestment and operating costs by 20%. The increase in investment is significantly higher than that
reported in typical  engineering cost indices, but specific information on cost increases in the pulp
and paper industry indicates that the  value ADL used is more appropriate. ADL believes that
this would also apply to pollution control equipment at paper mill sites, particularly new mill
installations. The  increase in operating  costs is a weighted average of estimated increases in
individual cost items, which range from 10% on labor to 60% on chemicals.

     In  addition to revising the  Development Document cost data  to mid-1975 dollars, ADL
added the following operating cost items, which were excluded from the Development Document
but are (ADL believes) legitimate effluent control operating charges:

     •  Factory overhead and general administration at 12% of the estimated direct labor
        cost for pollution abatement. The Development Document operating costs include
        overhead for direct labor supervision only.
     •  Professional administration for monitoring and reporting, including relations with
        regulatory agencies, estimated at an essentially fixed cost of $23,000 per installa-
        tion, regardless of size or category. The Development Document estimates include
        the direct costs of measuring,  sampling, analysis, and compilation of data.
     •  Insurance and local property taxes at l-'/4%  of total investment. This figure is
        somewhat lower  than is typical  of pulp and paper facilities,  and reflects  the
        probability that  some level of local property tax relief will be allowed for effluent
        control installations and process modifications.
     •  Maintenance materials at 1%  of total investment.

     The aforementioned refinements did not affect the estimated total capital costs and added
about 5% to the annual operating cost estimates given in the Development Documents.

5. Cost Models, Existing Mills
     As noted previously,  ADL believes that the level of in-place treatment facilities stipulated
in the Development Documents and used as the basis for determining incremental costs is grossly


                                          E-35

-------
understated. More specifically, the Documents assume no external treatment facilities what-
soever in mills in the unbleached kraft, NSSC medium, unbleached kraft/NSSC medium, and
recycled paperboard and construction paper process categories. Production from mills in these
categories constitutes about 50% of the entire industry capacity. Furthermore, the Documents
assume only primary treatment facilities in place through 1973 in the rest of the industry. ADL
believes that both assumptions grossly understate the level of in-place treatment facilities.  In
ADL's opinion, practically all mills have primary treatment and about  one third have some
degree of secondary treatment. Thus, while mills with secondary treatment may need to expand
and/or supplement existing facilities to achieve BPT regulations, ignoring the existence of such
facilities leads to overstating the incremental need for treatment.

     For purposes of this study, ADL has modified the reported data base and assumed that the
mills in the unbleached kraft, NSSC, unbleached kraft/NSSC, recycled paperboard, and con-
struction paper categories have (at a minimum) primary treatment. Since the capital investment
for primary treatment constitutes about 25% of the incremental cost for compliance with BPT,
ADL has effectively reduced the investment requirement derived from the cost models appearing
in the Development Documents by that amount. Further, since the production from mills in these
process categories comprises about 50% of the industry capacity, the total industry's derived cost
to meet BPT regulations is reduced by about 12.5% (25% x 50%).

     In calculating the investment  and operating costs for  industry  sectors, ADL (like the
Development Documents) assumed that no charges were incurred by mills tied into municipal
treatment systems. As a result, the aggregate, average cost for the industry sector understates the
cost  for mills with on-site treatment facilities. To illustrate the range of cost to a particular mill,
however, ADL lists the maximum and minimum values.

6. Cost Models, New Mills
     Based on industrial practice, ADL selected new mill examples for the various categories that
are somewhat different from the "typical" mills in the Development Documents. The effluent
control costs for the mill sizes reported  in the Development Documents  were adjusted to the
representative pulp processes. In those cases where the unit size or "typical" size papermaking
process is significantly smaller than the pulping operation, the capital and  operating costs
associated with pulp manufacture are reduced in proportion  to the size of the papermaking
operation. In this manner, costs of compliance  are reported  on  a finished-product basis for
subsequent economic analysis but take into account the economies achieved in a larger pulping
(process) operation.

D.  EXISTING  INDUSTRY AGGREGATE COST
     To develop total investment and operating costs by process category,  it is necessary  to
estimate total capacity by process category. Based on published mill data, year-end 1974 capacity
was totaled  by category, mill size, and mills known to be on municipal treatment. The assign-
ment of mills to categories is not precise;  most large mills are complex, in terms of both products
and pulping processes, and they could fit more than one category. To project the capacity of the
existing industry  to 1977 and 1983, ADL assumed certain capacity retirement rates, based on
experience,  for each category. This includes  tonnage retired  due to water effluent pollution
regulations,  obsolescence, and all other economic or technical  reasons.  No capacity retirement
was assumed among mills using municipal treatment.
                                          E-36

-------
     In calculating the aggregate costs, ADL specified the following conditions and assumptions:

     (1)  No additional treatment costs will be incurred by mills already on municipal
         treatment through BAT. All other mills will use the standard internal and external
         treatment technologies specified in the Development Documents.
     (2)  In the unbleached kraft,  NSSC, unbleached kraft/NSSC, construction paper,
         sulfite (paper grade), soda, and groundwood categories, all mills will use ASB
         biological treatment.
     (3)  In the recycled paperboard, dissolving sulfite, deinked, nonintegrated tissue, and
         nonintengrated fine paper categories, 50% of the capacity will use ASB and 50%
         activated sludge for biological treatment.

     For a given category, the costs for BPT and BAT were calculated by size. The average cost
per ton by size was multiplied by the corresponding tonnage in that size range. The 1977 and 1983
capacities were used to  compute the incremental costs of compliance  with BPT and BAT
respectively. Table E-21 summarizes the investment  and operating cost thus calculated.

     Compliance with the BPT requirements will require about $2.3 billion in capital costs for
the existing industry  as a  whole,  and  annual  operating costs  will total $250 million. BAT
regulations will cost an  additional  $1.4 billion in capital costs plus  $153 million in  annual
operating costs. Any capital investment for replacement or net new additional capacity that may
be built after 1974 is not included, and operating costs exclude depreciation and cost of capital.
BPT (1977) costs are incremental from the year-end 1974 level; BAT (1983) costs are incremental
from BPT.

     As noted previously, the cost of land was not included in the Development Documents. ADL
estimates that the cost of land for on-site treatment facilities would be about $25 million, or less
than 1% of the total capital requirement.

     Land availability was cited in the ADL mill closure analysis as a key factor in a mill's ability
to comply with the environmental regulations.

     If there  were indications that a mill would be  unable to obtain land for on-site effluent
treatment, or tie into a municipal sewer, it was classified  as a pollution-related closure. (See
Chapter  V.)

E.  NEW MILL UNIT COSTS FOR SELECTED  EXAMPLES
     Unlike the aggregate cost estimates prepared for the existing industry, aggregate costs for
new industry capacity were not derived in this report,  because the results of the economic impact
analysis influence the amount of the new capacity. Accordingly, it is appropriate to present only
the unit cost for selected examples.

     The effluent control regulations for NSPS and the estimating procedure for deriving the
associated cost of compliance have been described in an earlier section of this Appendix.
                                         E-37

-------
                                                           TABLE E-21
                        ESTIMATED WATER EFFLUENT CONTROL COSTS FOR THE EXISTING INDUSTRY BY PROCESS SUB-CATEGORIES
Tota
1 Sector Capacity
1974 Year-End 1977 1983
No.
Process Sub-Category & Size (t?d) Mills
Unbleached Kraft-small 01-599 7
Bed. 600-999 13
large 1000+ 9
0-199
NSSC (Sodium & Ammonia Base)-, nail 3
200-399 ced. 9
400+ Urge 10
Unbleached Kraf t/SSSC-small 0-999 2
med. 1000-1499 2
large 1500+ 6
Paperboard from Waste Paper-snail ~ 54
100-299 med. 87
300+ large 19
Builders' Paper & Roofing Felt-
• small 0-49 12
Bed. 50-99 30
large 100+ 26
BCT Kraft - small 0-399 2
Bed. 400-999 12
large 1000+ 27
Pine Kraft - small 0-399 5
Bed. 400-999 17
large 1000+ 7
Dissolving Kraft - med. 400-999 2
large 1000+ 2
Market Kraft - small 0-399 2
Bed. 400-999 4
Sulfite - aed. 0-299 9
large 300+ 13
Dissolving Sulfite - large 300+ 5
Soda - medium 200+ 3
Delnked - small 0-149 19
Bed. 150-399 12
large 400+ 6
Groundvood C-H-N - small 0-199 5
Bed. 100-299 6
large 300+ 10
Chemi-Hechanical - small 0-199 1
Bed. 200-449 2
large 450+ 1
H/I Tissue - very small 0-24 17
small 25-70 23
medium 71-219 15
large 220+ 4
N/I Pine - small 0-59 10
medium 60-179 17
large 180+ 14
000 000 000
tpy tpy tpy
960 960 960
3,560 3,560 3,560
4,240 4,240 4,240

150 100 100
950 810 660
2,170 2,170 2,170
470 470 470
780 780 780
3,710 3,710 3,710
1,120 960 630
4,720 4,640 4,600
2,830 2,830 2,830

120 120 80
640 640 580
1,400 1,400 1,400
190 190 190
3,100 3,100 3,100
13,000 13,000 13,000
500 500 500
.3,900 3,860 3,730
3.400 3,400 3,400
560 560 560
770 770 770
230 230 230
810 810 810
600 460 360
2,600 2,530 2,470
910 910 800
290 190 190
480 450 350
940 940 870
1,000 1,000 1,000
110 80 50
390 310 - 200
1,900 1,900 1,600
60 60 60
200 200 200
190 190 190
80 70 60
320 310 270
670 670 650
600 600 600
120 90 80
560 500 400
1,700 1,700 1,700
Municipal
Treatment
1974 to 1983
No.
Kills

_
_

1
1
2
_
_
-
24
47
6

4
17
10
_
-
-
1
-
-
.
-
_
-
1
-
-
5
1
1
1
-
-
1
-
-
8
8
5
-
4
4
2
000
tpy

_
„

50
70
470
_
_
-
530
2,500
900

40
340
540
_
-
-
120
.
-
_
-
_
-
50
-
-
160
70
150
20
.
-
60
-
-
40
100
190
-
50
160
200
Capital Costs
S Millions
ai'T
38
101
98

3
32
56
14
18
74
28
104
55

4
10
20
12
125
411
20
133
91
30
34
13
35
45
171
71
10
35
64
45
6
19
68
-
10
7
5
24
29
20
4
16
46
3A1
25
67
61

3
26
66
9
12
46
2
35
17

1
7
16
8
99
328
17
114
82
23
26
10
26
15
77
27
8
4
12
10
1
6
30
-
4
3
2
10
18
14
2
8
37
Effluent Control Costs
Onerntlni: (~vi . ('-:,''}c
S Millions/Year
BPT
3.3
8.5
8.5

0.2
2.2
3.2
1.2
1.6
6.7
3.2
11.3
5.4

0.4
1.0
2.0
1.0
12.4
48.1
2.0
16.6
12.6
3.9
4.9
1.3
4.0
5.0
22.8
9.3
1.2
4.5
9.0
7.0
0.6
1.7
6.8
-
0.9
0.8
0.8
2.9
2.9
1.7
0.5
1.9
4.4
EAT
3.4
9.6
10.2

0.1
0.8
1.5
1.2
1.8
7.8
0.2
3.8
2.1

0.1
0.7
1.5
0.9
10.9
32.5
1.6
11.9
6.8
3.1
3.7
1.2
2.4
1.6
7.7
3.4
0.7
0.7
1.8
1.6
0.1
0.6
3.0
-
0.5
0.3
0.3
1.5
2.3
1.6
0.3
1.0
4.2
S/Ton
BPT
3.4
2.4
2.0

4.1
2.9
1.9
2.5
2.0
1.8
7.4
5.3
2.8

4.5
3.3
2.3
5.3
4.0
3.7
5.3
4.3
3.7
7.0
6.3
5.7
4.9
12.3
9.0
10.2
6.5
15.4
10.4
8.2
7.6
5.5
3.6
6.5
4.6
4.0
25.3
13.8
6.1
2.9
13.5
5.7
2.9
Ire3t.:ud S/'
1AT
3.5
2.7
2.4

1.7
1.3
0.9
2.5
2.3
2.1
2.3
l.B
1.1

3.6
2.7
1.8
4.5
3.5
2.5
4.2
3.2
2.0
5.5
4.8
5.2
3.0
5.3
3.1
4.2
3.7
3.6
2.2
1.9
4.0
3.0
1.9
3.6
2.3
1.8
14.1
8.8
4.9
2.6
9.1
4.1
2.8
Ion Total Sector Capacity
BPT
3.4
2.4
2.0

2.0
2.7
1.5
2.5
2.0
1.8
3.3
2.4
1.9

3.0
1.6
1.4
5.3
4.0
3.7
4.0
4.3
3.7
7.0
6.3
5.7
4.9
10.9
9.P
10.2
6.5
10.0
9.6
7.0
5.7
5.5
3.6
-
4.6
4.0
11.4
9.4
4.3
2.9
5.6
3.8
2.6
BA1
3.5
2.7
2.4

1.0
1.2
0.7
2.5
2.3
2.1
0.2
0.8
0.7

1.8
1.2
1.1
4.5
3.5
2.5
3.2
3.2
2.0
5.5
4.8
5.2
3.0
4.4
3.1
4.2
3.7
2.0
2.1
1.6
2.4
3.0
1.9
-
2.3
1.8
5.0
5.6
3.5
2.6
3.8
2.5
2.5
                           561
                                 68,000 66,970 65,160  154    6,810   2,254  1,414   250.2
                                                                                        153.0
                                                                                                4.2
                                                                                                       2.6
                                                                                                                     3.7
                                                                                                                            2.3
Notes:
       aAssumes  that none of the capacity on municipal treatment as of end of 1974 would retire or close;
        no additional tonnage would be added on municipal  treatment.
        No additional capital or operating costs are Included for mills on municipal  treatment.  Primary treatment assumed  to
        be in place In 1974 for the existing Industry, with the exception of nonlntegrated fine and tissue categories, where
        no treatment is assuemd to be in place.

      C Operating costs Include:
            raw  material and chemicals;  -  operating labor;  - maintenance labor and supplies;
            energy;   - factory overhead and administration;      -  local taxes and  Insurance

      d  Tonnage  treated equals total  capacity minus  capacity  on municipal treatment<
                                                           E-38

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                                   APPENDIX E-3

                              OSHA NOISE CONTROL


A.  CONTROL REGULATIONS
     The regulations promulgated for existing industry  and new mills by the Occupational
Safety and Health Administration primarily concern noise level and personal safety. From the
standpoint of cost for compliance, noise far outweighs personal safety. Thus, in examining the
cost impact of environmental regulations, ADL has dealt only with the noise aspects of OSHA
requirements.

     The present regulation (Occupational Safety and Health Act of 1970) imposes restrictions
on worker exposure (on a time-weighted basis) to noise levels  greater than 90 dBA.  It gives
preference to the following methods of compliance:

     (I) Engineering controls, which either reduce the noise at the point of origin or modify
        the work area so as to reduce the level of noise in that area; and/or
     (2) Administrative controls, which reduce the worker's exposure to noise by limiting
        the length of time he is exposed to it.

If these methods,  either singly or in combination, are not feasible or fail to achieve the desired
degree of noise reduction, a third method may be used:

     (3) Personal protection, i.e., the use of hearing protective devices. In its practical
     application, the law has permitted the use of personal protective devices more freely
     than the above would imply.

     OSHA proposed various revisions to the 1970 law in the Federal Register of October  24,
1974. In essence, these call for the following:

     (1) Maximum feasible use of engineering and administrative controls before supple-
        mentation by personal protective devices;
     (2) A hearing conservation program, which would include  audiometric testing of  all
        production workers exposed to noise levels above 85 dBA;
     (3) Monitoring of the sound levels in working areas and measurement of the exposure
        of individuals exposed to a time-weighted average of 85  dBA or more;
     (4) Maintenance of records for (3) above and for calibration of the instruments used.

     For purposes of this analysis, ADL examined the  cost of  compliance with  the proposed
regulations.
                                        E-39

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B.  COST OF COMPLIANCE

1.  Introduction
     The main operating areas and  functions in an  integrated pulp and paper mill that are
characterized by high noise levels include the following:

     (1)  Wood Room

     •   chipper
     •   wood and chip unloading

     (2)  Pulp Mill

     •   washer
     •   screening and cleaning
     •   bleach plant

     (3)  Paper Mill

     •   refiner room
     •   "broker" beaker
     •   paper machine (wet end and dry end)
     •   winder

     (4)  Coating and Finishing

     •   coater
     •   finishing (converting)

     (5)  Auxiliary

     •   power boiler and turbine room
     •   recovery boiler

     Obviously, not all integrated pulp and paper mills have all of these functions, and some use
equipment with even higher noise levels (e.g., a debarking drum in the wood room). Furthermore,
many mills have more than one paper and/or board machine to a single wood room and pulp mill.
Hence, estimating the cost of bringing one facility  to a permissible noise level or protecting a
single production worker from overexposure is a complex, site-specific task, particularly when it
is recognized that compliance may be achieved by more than one method.

     Since neither the present nor the proposed standards specify a desired ratio of engineering to
administrative controls, the associated costs are arbitrary and subject to considerable variation,
not only from plant to plant but even  within each process step.
                                          E-40

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     In view of the complexity of the problem and the numerous alternatives that one can select
to bring a facility into compliance, it is not surprising that cost estimates are judgmental and that
different  sources vary widely.

2. Existing Industry, Aggregate Costs
     ADL was not retained to develop engineering cost estimates for compliance with  OSHA
noise regulations; instead, it relied upon available sources. The following two sources deal  with
these cost estimates:

     •  A study1 prepared by Bolt, Beranek & Newman Inc., (BBN) for the U.S. Depart-
         ment of Labor; and
     •  Correspondence between ADL and the American Paper Institute (API)

     After reviewing these documents, ADL elected to adjust and use the API estimate (see Sec-
tion  III-F-2). In a study that it made in 1974, the API estimated that the cost of compliance with a
90-dBA level would be about $2  million (expressed in 1975 dollars) for  an existing 500-tpd
integrated pulp  and paper mill.  The estimate assumes that compliance would be achieved by
reduction of noise "in  the workplace." Accordingly, the estimate includes costs  for relocating
instruments and controls associated with each of the process steps previously  identified.

     More recently, API conducted a company survey and estimated that the existing industry
would  have to invest some $516  million to comply with the proposed 90-dBA regulation.  This
figure, which does not include the cost of facilities already in place, applies to all sectors within
the 2600  SIC code — pulp, paper, and board manufacturing and converting.

     Since the present study did  not include converting nor the manufacture  of certain types of
building  products (e.g.,  hardboard and particleboard), the full $516 million did not apply.
Keeping  in mind that the excluded sectors had fewer than the average number of workers and
process steps per mill,  ADL assumed that they would incur 25% of the total investment. The
remainder, about $400  million, was applicable to the studied sectors.

     To allocate this incremental  $400  million into various process categories, ADL took the
position that the capital costs for compliance are more closely  related to type and number of
installations  than to the  number of production workers.  It was first estimated that  the  in-
vestment for  compliance  by an integrated pulp and paper mill would be about three times that
of a  nonintegrated  paper or  board mill. Since there are  about 300  integrated mills and 260
nonintegrated mills, the incremental cost per mill was calculated as follows:

                    300(3x) + 260x = 400 x  10"
                         x =* $350,000 for a nonintegrated mill
                        3x = $1 million for an integrated mill

     In this study, ADL assumed that 80% of these expenditures would be required through 1977
and the remainder between 1977 and 1983. As with the studied air and water regulations,  costs
associated with new mills were handled separately.
1. "Economic Impact Analysis of Proposed Noise Control Regulation," Report No. 3246, Contract No. DOL-J-9-F-6-
  0019, April  21, 1976.
                                         E-41

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     With regard  to operating costs, API  has estimated  $25-868 and $20-840  per worker for
monitoring and audiometric testing respectively. ADL used the low end of the range  — 825 per
production worker for  monitoring and $20 per production worker for audiometric testing. In
addition to these charges, ADL assumed 5% of capital investment for maintenance labor and
supplies and 12.09% for capital recovery.

3.  New Mills, Unit Costs
     The new-mill cost models developed by ADL were based primarily on an 800-tpd bleached
kraft pulp mill, with a single paper machine for a given  product (Appendix F).  Lacking any
information regarding  cost for compliance with OSHA noise regulations for new mills, ADL
adjusted the capital cost for the 500-tpd existing integrated pulp and paper mill model developed
by API (mentioned previously) to $3 million for the larger size and to reflect ADL's opinion that,
presented with the option of using either administrative controls or building sufficient "engineer-
ing control" into a new mill to comply with noise regulations, a producer would elect to take the
latter route. Although  administrative control is a much less  capital-intensive method of com-
pliance, it is subject to subsequent modification by OSHA in the event the mill is found to be in
violation.  Rather than  risk being faced with the high costs of mill modification, most producers
would choose to equip their new mills with adequate "engineering controls" initially.  Of the $3
million for OSHA noise control, ADL further assumed that $2 million applied to the pulp mill and
the remaining $1 million to each paper/board machine, because more  process steps are involved
in the pulping process.  Also, operating costs of $100,000 per year were included for maintenance,
record keeping, monitoring of sound levels,  audiometric testing  of workers,  and calibration of
instruments. Operating costs for small, nonintegrated recycled-paper mills were assumed to be
slightly  lower ($70,000 per year).

     These capital and operating costs are order-of-magnitude only.
                                          E-42

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                                  APPENDIX E-4

 COMPARISON AND DISCUSSION OF PUBLISHED COSTS OF COMPLIANCE
                      WITH ENVIRONMENTAL CONTROLS
     There are few published estimates on costs of compliance with the studied air, water, and
OSHA noise regulations. For purposes of this discussion, the costs were divided into two discrete
areas:  (1) costs associated with air and water controls, and (2) cost of compliance for OSHA
noise control. Below is a detailed discussion on each area.

     In its report to API,1 URS Research Company cited the costs of compliance with the studied
air and water regulations which were initially estimated by Hazen &  Sawyer and NCASI
respectively. Both original sources developed  (or reported) estimates for the existing industry.
The costs of compliance for new capacity built during the studied period were estimated at 15% of
production-related capital requirements. Table E-22 summarizes the costs reported in the URS
report and compares them with those given in this report.

     For the period of 1974 to 1983, URS reported $8.7 billion capital requirements for both water
and air controls, while ADL estimated $6.6 billion, some $2.1  billion less than URS. These
estimates include costs for both existing industry and new  and replacement capacity. The more
in-depth comparisons on air and water control are made separately below, since they come from
different sources.

A.  AIR EMISSION CONTROL COSTS
     ADL/EPA and URS/NCASI  disagree significantly on the cost to the  existing industry for
compliance with air regulations, particularly  for the 1978-1983  period. Since  the URS report
contains no information to support the estimates or to explain the methodology used  in deriving
them, ADL cannot be sure of the reasons for the variances. They appear to be the assumptions
(hence related costs) associated with:

     •  required level of control for the existing industry, and
     •  capitalized maintenance and replacement of capacity.

     NCASI obtained information on the existing industry by a mill survey, estimated the costs
for  the 1974 to 1977 period, and extrapolated them to the  1978 to 1983 period.  ADL  derived its
estimates empirically from the costs associated with each major segment of the industry; the
reasonableness of the result was assessed by  comparing it with the reported  industry survey
estimate after making allowances for costs reported separately in the ADL cost analysis. ADL
staff also discussed the estimates reported by URS  with  NCASI representatives and thereby
obtained a verbal description of the methodology that URS used.

     Implicit in the mill/company survey approach is the difficulty of differentiating between
investment requirements for replacement and/or incremental expansion on the one hand and
costs associated with environmental regulations on the other. Typically, when a mill or company
1. "The Economic Impacts on the American Paper Industry of Pollution Control Costs," report by URS Research
  Company to the American Paper Institute, September 1975.
                                       E-43

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                                                          TABLE  E-22
                                SUMMARY  COMPARISON OF URS AND ADL  COST OF  COMPLIANCE ESTIMATES
                                           (Capital investment  reported  in mid-1975 dollars)
                                                                    URS
m
    Reporting  Period  (year-end)

     1974 - 1977
     Existing Industry
     New Plus Replacement Capacity
                        Total Period
     1974 - 1983
Existing Industry
New Plus Replacement Capacity
                    Total Period
Capacity
Period-end
(Million Tons)
68
5
73b
66e
23
89b
Capital Investment
(SBillion)
Air
1.0
	 Not
1.0
2.4
Air & Watei
Not
Applicable
Water
2.2C

2.2
3.9
r Combined
Not
Applicable
Total
3.2

3.2
6.3
2.4
8.7
Capacity
Period-end
(Million Tons)
67
5
72d
65e
21
86f
Capital Investment
(SBillion)
Air
0.7
Air & We
Not
Applicable
0.9
Air & Wat*
Not
Applicable
Water
2.2
iter combin
Not
Applicab
3.6
jr combined
Not
Applicabl
Total
2.9
ed 0.5
3.4
le
4.5
2.1
6.6
e
                                                                                                                  ADL
   3 URS reported costs in 1974 dollars, which ADL converted to mid-1975 dollars using a factor of 1.2
   b URS reported total year-end capacity of 74 and 92 million tons for 1978 and 1984 respectively.  ADL adjusted to 73 and 89 million year-end
     capacity tons to reflect capacities for 1977 and 1983 respectively.
   C Water control costs account for 69 million tons as reported by Hazen & Sawyer, Inc.
   d Capacity estimates reported by API - Paper, Paperboard, Wood Pulp Capacity 1974-1977, October 1975, pp. 13-17.
   6 URS and ADL both assumed retirement of about 2 million tons from year-end 1977 to 1983.
     Corresponds to "medium growth" for the industry based upon Chase Econometric Forecast Model.  (Note low and high growth estimates
     correspond to 82 and 89 million tons respectively.)

-------
makes a major capital  expenditure, it includes provisions for replacing obsolete equipment,
increasing capacity, and environmental control. The apportionment of the capital budget into
these categories is inherently qualitative and arbitrary.  Hence,  without implying any covert
motives to the respondents of the NCASI survey, there is an inherent imprecision in information
derived via industry survey for  cost analysis. For the above reason, ADL derived its estimates
empirically and thereby gained  some insight regarding possible areas of cost variances. The key
areas described below may have contributed to the variances between the two estimates.

1.  Level of Control
     State Air Quality Implementation  Plan (SIP) standards apply to  the existing industry;
federal regulations do not. Further, SIP requirements vary significantly from  state to  state;
hence, a given type and size of mill can have greatly different costs of compliance, depending on
its location.

     Even though many states presently do not have regulations as stringent as those of Oregon,
ADL used that state's SIP standards (which require 99%  particulate recovery) to calculate the
existing industry's cost of compliance. ADL assumed that state regulations would not become
progressively stringent over the time period to 1983, but  rather, that the current Oregon state
regulations would be more broadly applied to those states that presently have less stringent
regulations.  However, if the SIP regulations were to become as  stringent as the new source
standards, an additional $1.4 billion would  be required to bring the industry from SIPs to new
source control level. This would  reduce the difference between the cost estimates significantly.

     The URS (NCASI) estimates did not specify what regulations were used in deriving the cost
estimates or whether more stringent controls — beyond those assumed through  1977 —  would
apply in the 1978 to 1983 period. Judging from its magnitude, however, one would suspect that
the estimate for the existing industry's expenditures from  1978 to 1983 includes provision for the
application of more stringent regulations.

2.  Capitalized Maintenance/Replacement Cost
     Major capital expenditures are occasionally budgeted entirely for environmental controls.
More frequently, however, they are primarily for the building of grassroots facilities, replacement
of existing capacity (capitalized maintenance), or incremental expansion of existing mills, and
only a portion of the investment goes into environmental control. Unfortunately, it is difficult to
generalize on  the amount that  is necessary for compliance with environmental regulations in
relation to the expenditures for enlarging capacity or increasing the efficiency of the process.

     On the basis of reported historical data, ADL made a rough estimate of capitalized mainte-
nance as a percentage of reported total capital expenditures. This was done by subtracting the
reported amounts spent for  environmental controls and  incremental  expansion (based  on an
average replacement value) from the total capital expenditures reported by the industry. Thus
calculated, capitalized maintenance amounts to only 0.67% of the total, which is unrealistically
low. It indicates that the reported historical capital expenditures for environmental controls
include some capitalized maintenance charges. This is not to imply intentional misrepresentation
of the allocation of reported  capital budgets as much as to acknowledge the inherent difficulty
and judgmental nature of the allocating procedure.
                                          E-45

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     For cost estimating purposes, ADL has shown separately the capital investment associated
with:

     •  capitalized maintenance to maintain the existing industry at rated capacity; and
     •  investment requirements for new capacity, regardless of whether that new capacity
        is to replace existing capacity or add net additional capacity.

Hence,  by deriving the cost  of compliance empirically, ADL has attempted  to avoid the in-
appropriate allocation of industry  expenditures.

     Table ffl-6 (see Chapter  IE) summarizes the derived capital cost for air emission control for
the existing industry using the Oregon SIP standards. The estimate of SI.3 billion includes costs
for (a) those mills using the kraft  process, (b) power boiler controls for other process categories,
and (c)  earlier retirement of recovery boilers in the kraft process categories. As stated, these costs
were derived empirically. The methodology and supporting data are included in Appendix E-l of
this report.

     Deducting the reported industry expenditure of some SO.4 billion from the derived estimate
results in  an  incremental cost of  $0.9 billion in additional capital for the existing industry  to
achieve the 99.0'c particulate recovery required by the Oregon standards.2 Obviously, if more
rigid standards were postulated, the incremental cost would be significantly higher.

By way of comparison, the incremental air emission control cost reported  by NCASI (Table E-22)
for the existing industry amounts to some $2.4 billion (mid-1975 dollars). On the assumption that
perhaps 85c/c  of this total is associated with  the kraft process, the resultant $2.0 billion corre-
sponds to some $16 million for each of the 127 existing kraft mills in the  industry. This figure
appears to be much too high for the incremental cost of compliance; it must include provision for
other capital requirements,  such as incremental new capacity or capitalized maintenance items,
which are  shown separately  in the  ADL cost analysis.

B.  WATER EFFLUENT CONTROL COSTS

1. Summary
     Few studies have been made  of the capabilities and cost of technology used by the pulp and
paper industry  to meet the requirements of the Federal Water Pollution  Control Act Amend-
ments of  1972. They include the report by Hazen  &  Sawyer,  Inc. (H&S) to the National
Commission on Water Quality, EPA Development Documents, and the MBO study that ADL is
presently undertaking for EPA. Both H&S and the Development Documents estimated the costs
of various options for achieving pollution abatement levels on a "cost-model" basis,  but  only
H&S aggregated the costs to the existing industry to achieve the 1977 (BPT) effluent limitations.
ADL has modified and used the unit costs derived in the Development Documents to estimate the
aggregate costs to the existing industry for compliance with  BPT and BAT  regulations.
2. This estimate does not include capital expenditures for fuel conversion. The conversion of power boilers from oil to
  coal or from natural gas to oil or coal would add significantly to the derived cost.
                                         E-46

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      For the existing industry to be in compliance with BPT in 1977, H&S estimated a capital
 cost of $2.03 billion  (in mid-1973 dollars); this amount, which included land costs and annual
 operating and maintenance costs of $104 million, was in addition to that spent as of the end of
 1972. When adjusted to a base comparable to ADL's (i.e., after subtracting the cost of land and
 investment in 1973 and 1974, and converting to 1975 dollars), these figures correspond to $2.19
 billion and $140 million respectively (Table E-23). ADL estimated these incremental costs (in
 1975 dollars) at $2.25  billion  for capital (excluding land costs)3  and $250 million for annual
 operating and maintenance in 1974-1977.

     On the basis used  in Table E-23, the capital requirements estimated by H&S and ADL
differ by less than 2%;  however, the methodologies that were  used differed considerably with
respect to:

     •  scope
     •  basic engineering cost estimates,  and
     •  the methodology used in calculating the aggregate costs

The water effluent guidelines stated in the H&S report are more stringent than those in the EPA
Development Documents. H&S also  stated that the technology for BPT described in the EPA
Development Documents cannot achieve compliance with the proposed guidelines and therefore
assumed the addition of mixed-media filters in a third of the integrated pulp and paper mills;
hence, its basic engineering costs for the entire treatment train are higher than those used in the
Development Documents. However, as stated in Appendix E-2, the average costs for in-place
treatment facilities used in the Development Documents are  low; this fact increases  the in-
cremental costs that appear there. Coincidentally,  they are comparable to those of H&S in an
aggregate manner.

     With regard to operating and maintenance costs, the chief reason for the great variance is
the different way in which costs and  savings associated with in-process changes are ascribed to
plant improvement versus pollution control.

     A more detailed discussion of the variance in each of the areas mentioned above follows.

2.  Scope
     H&S accounted for a total 598 mills, corresponding to the 1972 year-end industrial capacity
of some 69  million tons; this included all  paper, paperboard, sulfite pulp, and bleached  market
pulp except wet machine board and construction paper and board.

     ADL,  on the other  hand, accounts for a total of 561 mills, corresponding to a 1974 year-end
industrial capacity of 68 million tons. This includes all  paper,  paperboard, sulfite  pulp, and
bleached market pulp except special industrial paper, construction board,  and wet machine
board.
 3.  Land costs would have added approximately $25 million to the capital costs estimated by ADL.
                                           E-47

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                            TABLE E-23


COMPARISON OF WATER EFFLUENT CONTROL COSTS FOR EXISTING INDUSTRY
	FOR BPT DEVELOPED BY HAZEN & SAWYER AND ADL	
                         (1975 dollars)
                                             o
                               Hazen & Sawyer             ADL
CAPITAL ($Million)
     Total Incremental from end      2,740
          of 1972

     Land Included                      20

     Total Incremental from end
       of 1972, less land            2,720

     Total spent in 1973 and 1974b     530
     Total Incremental from end
         of 1974                     2,190               2,250
OPERATING & MAINTENANCE ($Million/yr)

     Total Incremental from end
        of 1972                        140.6

     Total Incremental from end
        of 1974                                           250.2
  Hazen & Sawyer reported the costs in mid-1973 dollars.
  ADL escalated them to mid-1975 dollars, using a factor
  of 1.35.
  Costs reported in NCASI Special Report No. 76-05 are
  escalated to mid-1975 dollars.
                              E-48

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3.  Engineering Cost Estimates
     The basic source used by ADL for water effluent control cost estimates is the Development
Documents. Below is a comparison of this source with the H&S study.

a. Sub categorization
     H&S developed water effluent control costs for 14 process subcategories, excluding con-
struction paper and board. The Development Documents divided the industry into 22 process
subcategories.

b.  Water Pollution A batement Levels
     H&S selected five pollution abatement levels for existing mills. Level I was described as
achieved by the technology proposed by EPA for BPT but does  not  meet the BPT effluent
limitations. Level II is equivalent to BPT. Level  HI is that which is judged necessary to comply
with the EPA limitations promulgated or under consideration for 1983; it is equivalent to BAT as
suggested  by EPA,  except  for color  removal. Level IV is  equivalent to  Level  III plus  color
removal.  Level  V reflects the application of economically and environmentally feasible tech-
nological alternatives that are available or  likely to become available in the foreseeable future
and could approach or achieve elimination of the discharge of all pollutants.

     The Development Documents promulgated three pollution abatement  levels  — BPT for
1977, BAT for 1983, and NSPS. NSPS limitations are less stringent than those of BAT.

     The Level II, Level IV, and NSPS specified by H&S appear to be  more stringent than the
BPT, BAT, and NSPS promulgated by EPA Development Documents. Tables E-24, -25, and -26
compare these guidelines for selected process categories.

c. Approach
     Both sources estimated costs on the basis of average waste water effluent characteristics.

     Hazen & Sawyer developed the costs for total treatment trains to  achieve various levels of
control and then adjusted these costs to reflect the existing treatment facilities, first for primary
treatment and then for secondary treatment.  Since it used a building-block approach in going
from one level to the other, it obtained considerable flexibility and could postulate many options.

     The Development Documents estimated the incremental costs for each  subcategory based
on the average effluent treatment  facilities  in place as of 1973. Two sets of costs — one for an
aerated stabilization basin (ASB)  and the  other for activated sludge (AS) — were developed,
giving the user a choice between the two.

d. External Treatment Technology
     To arrive at Level I, H&S selected two alternatives for the integrated pulp and paper
subcategories — ASB or AS. For  the nonintegrated subcategories,  it used either dissolved air
flotation or coagulation/clarification. To meet the BPT (Level II) guidelines, H&S added mixed-
media filters to a third of the mills in all the integrated pulp and paper subcategories. Level III
was accomplished by adding mixed-media filters in the rest of the industry and using in-process
effluent reduction technology. Level IV was achieved by minimum lime treatment, maximum
lime treatment, microlime  plus activated  carbon, or ultrafiltration in addition to Level III


                                        E-49

-------
                              TABLE E-24
COMPARISON OF THE BPT WATER EFFLUENT GUIDELINES USED BY
HAZEN & SAWYER INC. AND REVISED BY EPA FOR SELECTED PROCESS CATEGORIES
Maximum 30-day Average
Process Subcategory
Bleached Kraft
BCT Kraft
Fine Kraft
Dissolving Kraft
Market Kraft
Sulfite, Paper Grade
Dissolving Sulfite (low
alpha)
Soda
Deinked
Groundwood
C-M-N Paper
Chemi -Mechanical
Thermo-Mechanical
Fine Papers
N/I Tissue
N/I Fine Paper
BOD5
H&S

9.0
9.0
16.0
16.0
36.5
53.0
14.2
10.9

8.2
16.0
8.2
8.2
8.0
6.8
(Ib/ton)
Limit
EPA
Revised

13.9
11.4
26.7
15.8
39.2
44.7
14.4
18.9

8.9
14.1
10.0
8.0
12.5
8.5
TSS
H&S

21.2
21.2
21.2
21.2
37.9
37.9
38.0
26.0

14.9
14.9
14.9
14.9
7.4
9.4
(Ib/ton)
Limit .
EPA
Revised

30.2
24.8
38.6
31.7
48.0
54.8
26.8
28.4

15.8
20.9
18.4
14.6
10.0
11.8
Sources:  EPA Development Documents & Hazen & Sawyer Report
                                 E-50

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                                       TABLE E-25


                   COMPARISON OF THE BAT WATER EFFLUENT GUIDELINES USED BY
           HAZEN & SAWYER INC. AND REVISED BY EPA FOR SELECTED PROCESS CATEGORIES
                                               Maximum 30-day Average
BOD (Ib/ton)
Limit
Process Subcategory
Bleached Kraft
BCT Kraft
Fine Kraft
Dissolving Kraft
Market Kraft
Sulfite, Paper Grade
Dissolving Sulfite (low alpha)
Soda
De inked
Groundwood
C-M-N Paper
Chemi-Mechanical
Therrao-Mechanical
Fine Papers
H&S

3.2
3.2
5.8
5.8
7.0
10.4
4.4
5.0

2.8
5.4
2.8
2.8
EPA
Revised

6.0
5.1
11.6
7.1
17.8
20.1
5.1
5.2

3.7
7.8
4.2
3.5
TSS (Ib/ton)
Limit Color (Ib/ton)
H&S

5.4
5.4
5.4
5.4
5.8
-
6.7
6.6

3.3
3.3
3.3
3.3
EPA
Revised H&S

4.1 202
3.5 202
7.9 202
5.2 202
6.0
6.9
3.5 202
5.4

2.9
3.3
2.9
2.7
EPA
Revised

130
130
250
190
-
• -
130
-

_
-
-
-
N/I Tissue Paper

N/I Fine Paper
1.9
1.2
4.3
2.7
3.2
1.9
2.2
1.4
Sources:  EPA Development Documents & Hazen & Sawyer Report
                                            E-51

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                               TABLE E-26
COMPARISON OF NSPA WATER EFFLUENT GUIDELINES USED BY
HAZEN & SAWYER INC. AND REVISED BY EPA FOR SELECTED PROCESS CATEGORIES
Maximum 30-day
Process Subcategory
Bleached Kraft
BCT Kraft
Fine Kraft
Dissolving Kraft
Market Kraft
Sulfite, Paper Grade
Dissolving Sulfite (low alpha)
Soda
Deinked
Groundwood
C-M-N Paper
Chemi-Mechanical
Therao-Mechanical
Fine Papers
N/I Tissue Paper
N/I Fine Paper
BOD5
H&S

3.2
3.2
5.8
5.8
7.0
10.4
4.4
5.0

2.8
5.4
2.8
2.8
1.9
1.2
(Ib/ton)
Limit
EPA
Revised

7.4
5.1
12.2
5.3
9.3
22.3
6.3
7.8

4.0
7.8
4.6
3.8
4.3
2.7

H&S

5.4
5.4
5.4
5.4
5.8
-
6.7
6.6

3.3
3.3
3.3
3.3
3.2
1.9
Average
TSS (Ib/ton)
Limit
EPA
Revised

5.0
7.5
16.7
5.8
5.8
20.0
8.6
8.0

6.3
6.6
6.3
6.0
4.4
2.8
Sources: EPA Development Documents & Hazen & Sawyer Report
                                    E-52

-------
treatment in bleached kraft and soda subcategories; minimum lime treatment was specified in
the unfleached kraft, NSSC, and unbleached kraft/NSSC subcategories. Level  V was reached by
supplementing Level IV with activated carbon in all subcategories.

     The Development Documents proposed a specific "treatment train" for each subcategory.
In general, primary and secondary treatments with supplementary solids removal were specified
to meet  the BPT guidelines for all subcategories except nonintegrated fine paper and tissue.
Secondary treatment included ASB or AS. To achieve BAT guidelines, secondary treatment and
media filtration were required  for all subcategories, plus  minimum  lime treatment for color
removal  in the appropriate subcategories. The technology  for complying with NSPS would be
similar to that for BAT, except that minimum lime treatment would not be needed.

e. Internal Treatment Technology
     In general, the internal treatment technologies used in both studies  are quite similar,
although both sources acknowledge that they are not necessarily the most widely accepted by the
industry, nor the most cost-effective. Internal treatment items are primarily process modifica-
tions, which often result in cost savings through economies in materials and/or energy; thus, it is
difficult  to state unequivocally that a particular item is mainly a process improvement or an
effluent control step. In the Development Documents, capital costs for all items listed as internal
control technology4 were charged to effluent control, but  it  was assumed that operation and
maintenance charges were offset by material and energy savings. On the other hand, H&S showed
net savings for all subcategories except dissolving sulfite.

/.  Water Effluent Control Costs
     According to their selected technologies, H&S and EPA developed water effluent control
costs for  each subcategory for the levels described previously.  Operation and maintenance costs
developed by H&S did not include fixed charges — cost of money, depreciation, insurance, taxes,
etc.; the Development Documents included  depreciation and interest at 15% of capital expendi-
ture but  omitted factory  overhead and general administration, professional administration for
monitoring and reporting, insurance, local property taxes, and maintenance materials.

     Table E-27 compares the investment and operating cost estimates for water effluent control
from both studies by the  use of selected examples. Note that  the variance of the costs based on
similar technology (e.g., Level I of H&S and BPT of the Development Documents for unbleached
kraft)  is  within the precision of engineering estimates.  However, the  total cost of Level I plus
Level II, which the  H&S  study reports will be required to meet BPT, is in all cases significantly
higher than the EPA estimate.

     The possible reasons for such variances are:

     •  the different technology required  to achieve compliance; e.g.,  the inclusion of
        mixed media filters for a third of integrated mills to meet BPT requirements, and
        different internal treatment  specified in  the nonintegrated fine  paper  sub-
        category — see Table E-28;
     •  the  different apportionment of costs  and  savings  associated with  in-process
        changes between plant improvements and pollution control.
4.  Except sulfite liquor Incineration and recovery.
                                          E-53

-------
TABLE E-27
COMPARISON OF INVESTMENT AND
Mill Level
Size of
Process Sector . (tpd) Control
1. Unbleached Kraft 1300
(Aerated Stabilization Level I „
Basin) Level II
TOTAL BPT
Level III2
Level IV2
w TOTAL BAT
1
2. Unbleached Kraft 1300 .
(Activated Sludge) Level I
Level II
TOTAL BPT
Level III3
Level IV
TOTAL BAT
3. Dissolving Sulfite
(Aerated Stabilization 600
Basin) Level I ,
Level II
TOTAL BPT
Level III2
Level IV2
TOTAL BAT
Basis : -
Source
OPERATING COST ESTIMATES FOR WATER EFFLUENT CONTROL
(SELECTED EXAMPLES)
All estimates reported In mid-1975 dollars
Comparison for existing mills
All costs are incremental
Assumes existing mills have no external treatment
: Hazen & Sawyer Source: EPA Development Document
Investment ($Million( Operating Cost ($/Tonj
Inter- Exter-
nal nal
3.15 9.76
2.59
3.15 12135
0.79
4.27
5.06
3.15 14.29
2.59
3.15 16.88
0.94
4.27
i - 5.21
3.71 15.41
3.44
3.71 18.85
1.89
1.89
Dep &
Total O&M Int Total
12.91 1.89 . 1.89
2.59 0.22 0.22
15.50 2.11 2.11
0.79 0.10 0.10
4.27 0.79 0.79
5.06 0.89 0.89
0
17.44 2.84 w 2.84
2.59 0.22 o 0.22
20.03 3.06 ^ 3.06
o
0.94 0.16 n 0.16
4.27 0.79 0.79
5.21 0.95 Q 0.95
ss
19.12 6.78 6.78
3.44 0.65 0.65
22.56 7.43 7.43
1.89 0.60 V 0.60
1.89 0.60 0.60
Investment ($Mlllion) Operating Cost($/Ton)
•Dep.
Inter- Exter- &
nal nal Total O&M Int. Total
NOT APPLICABLE
3.76 9.44 13.20 1.4 4.35 5.75
NOT APPLICABLE
2.29 3.19 5.48 1.65 1.81 3.46
NOT APPLICABLE
3.76 11.91 15.67 1.93 5.17 7.10
NOT APPLICABLE
2.29 3.19 5.48 0.18 1.81 1.99
NOT APPLICABLE
0.92 17.59 18.51 7.83 13.24 21.07
NOT APPLICABLE
2.18 3.46 5.64 2.80 4.08 6.88

-------
                                                                             TABLE E-27  (Cont'd)
m
Mill Level
Size of
Process Sector (tpd) Control
4. Dissolving Sulfite 600
(Activated Sludge) Level I .
Level II
TOTAL BPT
Level III3
Level I\P
TOTAL BAT


5. NOnintegrated Fine *
Paper 100
Level IJ
Level II
TOTAL BPT

Level III5
Level IV
TOTAL BAT
Source
Investment
Inter- Exter-
nal nal

3.71 28.20
3.44
3.71 31.64
3.60
— —
3.60




0.11 1.93
— —
0.11 1.93

0.56 0.30
— —
0.56 0.30
: Hazen

Total

31.91
3.44
35.35
3.60
—
3.60




2.04
—
2.04

0.86
—
0.86
& Sawyer

Operating Cost ($/Ton)
Dep
O&M Int

11.97 *
0.65
12.62
1.12
— ,
&
Total

k. H-97
0.65
12.62
1.12
—
1.12 o 1.12
w
<=>


5.07 <
D
J
-> 5.07
- 85 —
5.07
-4
5.07
H
(7.08) ° (7.08)
—
(7.08)
—
1 (7.08)
Source :
Investment
Inter- Exter-
nal nal

NOT
0.92 21.89
NOT

2.18 3.46




NOT

0.42 1.19

NOT

0.16 0.64
EPA Development Document

Total

A P
22.81
A P

5.64




A P

1.61

A P

0.80
Operating Cost
Dep &
O&M Int

PLICABLE
9.61 16.32
PLICABLE

2.80 4.08




PLICABLE

3.19 6.81

PLICABLE-

2.12 3.45
($/Ton)
Total


25.93


6.88






10.00



5.57
       FOOTNOTES
( )  Denotes Savings
                         Hazen & Sawyer has reported the costs in mid-1973 dollars.  ADL escalated them to mid-1974 dollars using a factor of 1.125.
                        2
                        5
   Treatment Options 1-1, II-l, III-l and IV-la as specified by Hazen &  Sawyer, are used as the specified technology ia
   comparable to that of the EPA Development Document-

   Treatment Options 1-2, II-2, III-2 and  IV-2a as specified by Hazen & Sawyer are used as this specified technology is
   comparable to that of the EPA Development Document.
  4                                                                                           \
  Different effluent treatment processes are  employed by  the two sources  (See  Table E-28)

   Treatment  Options 1-3 and III-3 as specified by Hazen & Sawyer are used.

-------
                                                                      TABLE E-^28

                                          EFFLUENT TREATMENT TECHNOLOGY FOR NONINTEGRATElf FINE PAPER SUBCATEGORY
                                                  USED BY HAZEN & SAWYER AND EPA DEVELOPMENT DOCUMENTS
            Effluent Treatment
                Technology
                                                  Source:
                                                        !

                                         Abatement Level:
                                                  Option:
              Hazen &  Sawyer
                                    EPA
                              Development Document
BPT
I
1 -
3
I
- 4
BAT
III
III-3
III-4
V -
EOD * BPT BAT
V
3
V
-4
m
Internal Technology Items

   1.  Internal spill containment
   2.  In-process effluent containment
       (stock preparation & paper machine
       effluent collection & treatment)
   3.  Alarms on chemical tanks
   4.  Paper nachiae flotation saveall
   5.  Paper machine high pressure showers
   6.  Cooling water segregation & re-use
   7.  Felt hair removal
   8.  Vacuum pumps seal water re-use
   9.  Paper mill stock spill collection system

External Technology Process

   1.  Preliminary
   2.  Pump station
   3.  Primary Clarifier
   4.  Sludge Lagoon
   5.  Aerators
   6.  Aerated stabilization basin
   7.  Vacuum filters
   8.  Monitor
   9.  Outfall
  10.  Diffuser
  11-  -Black liquor lagoon
  12.  Mixed media  filtration
  13.  Dissolved air flotation
  14.  Activated Car-bof.
                                                                                                 x
                                                                                                 X
                      X
                      X
                 X
                 X
                 x
                 X
                                                                           X
                                                                           X
X

X

X
                                                                                    X


                                                                                    X
X

X
X

X

X
X
X
X
X
                                                                                                  X
                                                                                                  X
                               X
                               X
                               X
                                                                                                                                   X

                                                                                                                                   X

                                                                                                                                   X


                                                                                                                                   X
                                                                                                                                   X
X
X

X
X
                                                X
                                                X
                                                X

                                                X
                                                X
                                                X
                                                          X

                                                          X

                                                          X

                                                          X

                                                          X
                                                          X
X
X

X
X
X
X
X
X
X

X
X
X
                *  EOD -  Elimination of Pollutant Discharge

-------
     Recall that these unit costs are for the entire (internal plus external) treatment facility
without any deduction for in-place facilities through 1974. Because EPA understates the level of
in-place treatment facilities through 1974, a larger net increment of capital is required to meet
BPT regulations.

     Both H&S and the Development Documents tabulated land requirements for each external
waste water treatment component, but only H&S calculated the attendant costs. These were
based on $5000/acre for AS, $3000/acre for ASB, and $20,000/acre for dissolved air flotation or
coagulation/clarification.

     Arthur D. Little has used the Development  Document unit cost estimates with certain
adjustments, namely:

     •  Conversion from mid-1974 to mid-1975 dollars;
     •  Addition of operating costs that increase  the Development Document operating
        and maintenance costs on the order of 5%;
     •  Adjustment of technology in place in some process categories for internal  con-
        sistency and to reasonably approximate the portion of total capital requirements
        expended through 1974.  (ADL assumed that all Phase I subcategories have
        primary treatment; the Development Documents show no treatment in place for
        those subcategories).

4. Methodology Used in  Calculating  Aggregate Costs
     Like ADL, H&S used models of representative mills. H&S developed two models for each of
six subcategories; the other eight subcategories were represented by one model each. Three cost
levels were estimated for each mill model, corresponding to the treatment facilities assumed to be
in place (no treatment, primary treatment,  or secondary treatment). For a given subcategory,
H&S aggregated the mills by size and then by level of in-place treatment. To obtain the aggregate
cost for that subcategory, investment and  operating costs for each cost level represented by the
mill model within a size category were multiplied by the number of mills with the corresponding
level of in-place treatment in  that size category, assuming certain technology to be employed.
Hence, the aggregate costs were based on the number of mills.

     Table E-29 summarizes the assumption made by H&S and ADL with regard to the types of
external waste water  treatment used in each subcategory. The differences were a source of
variation in the overall cost estimates, as each treatment process requires a different investment.
For example, the investment associated with AS is about 50-80% more than that with ASB.

     ADL used the cost models from the Development Documents, which were based on average
in-place treatment facilities. In most of the 17 process subcategories used  by ADL, cost models
were developed for small, medium, and large size categories. To arrive at an aggregate cost for a
given subcategory, ADL multiplied the average cost per ton for that category by the correspond-
ing tonnage in that size range. Thus, these total aggregate costs are based on tonnage.
                                         E-57

-------
                             TABLE E-29
SUMMARY OF THE TECHNOLOGY USED BY HAZEN & SAWYER AND
CALCULATE THE AGGREGATE COSTS FOR BPT
Subcategory
Unbleached Kraft
NSSC - Sodium
- Ammonia
%AS/%ASB
Hazen & Sawyer
25/75
50/50
0/100
Unbleached Kraft/NSSC 25/75
Recycled Paperboard 25/75
Construction Paper Not Included
BCT Kraft
Fine Kraft
Dissolving Kraft
Market Kraft
Sulfite

50/50

50/50
Dissolving Sulfite 50/50
Soda
De-inked
33/67
50/50
Groundwobd C-M-N 1 ?s/7S
Chemical Mechanical GWJ
N/I Fine Tissue
N/I Fine
Coarse Paper
% Fl*/% Cl*
50/50
50/50
50/50
ADL TO

ADL
0/100
0/100.
0/100
50/50
0/100

0/100

0/100
50/50
0/100
50/50
0/100
%AS/%ASB
50/50
50/50
Not Includt
* Fl = Flotation




  Cl - Coagulation/Clarification
                                     E-58

-------
      APPENDIX F

SUPPORTING MATERIAL FOR
 NEW MILL COST MODELS

-------
                                   APPENDIX F

           SUPPORTING MATERIAL FOR NEW MILL COST MODELS
     This appendix describes the development of the cost models for selected pulp, paper, and
paperboard manufacturing operations and presents the supporting data on which they are based.
Table F-l is an overall summary of the capital and operating costs. Tables F-2 through F-26
summarize the capital and operating costs for each model.

     Both the capital and operating costs consist of two discrete parts:

     •  Costs related to the direct manufacturing process: These were derived from earlier
        work performed by ADL for EPA.1 Investment and operating cost schedules ap-
        pearing in the  latter report were updated and modified to meet the objectives of
        this study.
        Note that Tables F-3 through F-26 are only summaries  of the original cost sched-
        ules. The source document went into considerably greater detail and also included
        material balances, energy balances,  manning tables, and cost sensitivity curves.
        These should be consulted by those who wish to study the derivation of the capital
        and operating costs or to determine the effect of changes in selected parameters.
        The costs of complying with OSHA noise regulations are shown separately and
        included with  the direct manufacturing cost. As mentioned in Chapter III, the
        OSHA costs were estimated by ADL on the basis of information obtained from the
        American Paper Institute.
     •  Costs related to the studied environmental regulations: Cost estimates for water
        control were obtained from the Development Documents. Those for air control
        were obtained  from published and unpublished EPA documents. In each case,
        ADL updated and adjusted the original data to  put it on a basis and time period
        comparable to  those used in this study.

1.  BASIS OF COST CALCULATIONS

a.  Boundary Limits
     The operations included in the new mill models extend from the delivery of fiber to the mill
to the delivery of rolls of paper or paperboard to the user.

b.  Monetary Base
     All costs apply to the end of the second quarter of 1975. Because of the uncertainty of future
prices, all of the analyses are based on mid-1975 dollars with no escalation for further inflation.

c.  Units of Measurement
     English units (e.g., short tons)  have been used throughout.
1. Arthur D. Little, Inc., "Analysis of Demand and Supply for Secondary Fiber In the U.S. Paper and Paperboard
  Industry," prepared for Office of Solid Waste Management Programs, EPA, Contract No. 68-01-2220, March 1975.
                                         F-l

-------
                                                          TABLE F-l
SUMMARY OF CAPITAL INVESTMENTS AND OPERATING COSTS FOR NEW MILL MODELS




Mill Capacity
Product Sector and Selected Model
Unbleached Kraft Paperboard:
Kraft Linerboard
Unbleached Kraft Paper:
Kraft Dag Paper
NSSC Corrugating Medium:
Corrugating Medium
Recycled Paperboard:
Recycled Boxboard
Jute Linerboard
Bogus Medium
Gypsum Linerboard
Construction Paper:
None
Bleached Board & Bristols:
Bleached Paperboard (SBS)
Printing & Writing Paper
Bond Paper
Book Paper
Tissue:
Tissue Papers
Tissue Papers
Newsprint:
Newsprint
Newsprint
Bleached Pkg. & Ind. Conv:
None
Uncoated Croundwood Papers
None
Dissolving Pulp:
Dissolving Pulp
Bleached Paper Pulp:
Bleached Market Pulp
Slush Pulp*
Bleached Kraft SW Slush Pulp
•i ii M I* ii
Bleached Kraft HW Slush Pulp
ii M sw ti ii
Semi-bleached Kraft SW Slush
fiynnnHunnH Slush PulD
Process Category
Unbleached Kraft
Unbleached Kraft
NSSC Pulping
Recycled Paperboard
ii ii
it ii
ii ii
Construction Paper
BCT Km ft
Fine Kraft
Fine Kraft
BCT Kraft
Non-int. from Wastepaper
Fine Kraf t/Groundwood
De-inking
_
_
.Dissolving Sulfite
Kraft Market Pulp
(Southern)
(Northern)
(Southern)
(Northern)
Pulp
Pulp
1000
800
450
400
330
330
400
-
800
800
800
800
1,240
-
_
550
800
800
800
800
800
800
440
Paper
1000
230
450
400
330
330
400
-
500
300
300
163
. 76
550
330
-
-
550
800
-
TOTAL
Capital
Investment
($Mlllion)
148.7
65.3
67.7
57.8
39.1
32.1
49.8
-
144.8
96.7
94.8
70.9
28.4
120.5
55.9
-,
-.
161.6
184.0
125.0
125.0
116.0
116.0
120.0
23.0
DELIVERED
MANUFACTURING COST
Operating Cost ($/annual ton)
Capital
O&M Recovery Total
118.7
154.6
143.4
185.5
155.5
143.2
157.4
-
219.8
272.1
288.9
528.5
610.8
168.8
176.7
-
-
229.6
180.6
103.1
116.4
115.8
150.5
125.5
72.3
52.2
104.1
52.7-
52.9
43.4
35.7
45.6
-
106.2
117.0
114.7
159.4 •
137.4
77.9
60.4
-
-
102.9
80.7
-
170.9
258.7
196.1
238.4
198.9
178.9
203.0
-
326.0 .
389.1
403.6
687.9
748.2
246.7
237.1
-
-
332.5
261.3
103.1
116.4
115.8
150.5
125.5
72.3
Cost to be transferred to the integrated paper/board mill, excludes environmental control costs.

-------
                                                    TABLE F-2
                      FORMAT USED FOR ANNUAL CASH FLOWS FOR THE MANUFACTURE OF SELECTED PRODUCTS

Basis:  Product Grade
        Production Capacity
        Integrated to Pulp Mill
        Total Fixed Capital3, Plant and Buildings
UFfcKAilJNU ihAK ' ~7
CASH FLOW YEAR /

uapaciuy v"uu cpyj
Fixed Capital,3 (.pillion)
Plant Equipment 16 years
Buildings 33 years
Working Capital ($million)
Total Delivered Operating Costs
($nillion/yr) , excl. Deprec.
Direct Mfg. + Cost of Sales
(excl. environmental & OSHA)
Environmental Control (air and
water)
OSHA (noise)



(20% of
total)
f
s
\
0






(40% of
total)
7cor»
0

0

K
D
O


(at 20%
of 1+2)

0



y to end
12 to end
s.
/
0

0
>
\
\.

      Includes an allocation of pulp mill total capital requirements
      Derived on the basis of 80% of cap'y.in 1st operating year and 100% thereafter.

-------
                                  TABLE  F-3

          SUMMARY OF CAPITAL AND OPERATING COSTS FOR THE MANUFACTURE OF
                          UNBLEACHED  KRAFT LINERBOARD
BASIS:  Process:    Continuous  Kraft  Pulping
        Production: 1000  tons/day;  345,000  tons/year
        Mill Location: Southeast
CAPITAL REQUIREMENTS
$Million
1.  Excluding Environmental Cost

    Direct Manufacturing Process
    OSHA Regulations

    Total Fixed Capital
    Total Working Capital (3 month? delivered cost)

2.  Plus Environmental Control Cost
     121
       3
     124
      10
Water Control -

Internal
External
Air Control - Economic Level
6..
12. -
2.J
Environmental Level
2.<
TOTAL FIXED CAPITAL 148."

OPERATING COSTS


TOTAL WORKING CAPITAL 10

Fiber Cost
Other Raw Materials
Hourly Labor
Supplies
Energy
Factory Overhead
Capital-related '•' (less capital recovery)
Sub-total, Factory Cost
GS&A
Freight Out
Total
OSHA Regulations
Total
Delivered Cost
•
Delivered Cost
Environmental
, Direct Mfg.
, excluding Federal
Regulations
Water Control Regulations (external control only)
Air Control Regulations - Economic Recovery
Environmental Control
Total Delivered Cost j(excl. capital
recovery)
$/Ton
41.9
4.5
11.4
9.9
6.9
4.8
7.9
87.3
7.3
20.9
115.5
0.3
115.8
5.0
(2.7)
0.6
118.7
$000/Year
14,460
1,550
3,930
3,410
2,380
1,660
2,720
30,110
2,520
7,210
39,840
100
39,940
1,740
(930)
229
40,970
 Source: Arthur D. Little, Inc., estimates
                                            F-4

-------
                                  TABLF. F-4

          SUMMARY OF CAPITAL ANT) OPERATING COSTS FOR THE MANUFACTURE OF
          	UNBLEACHED KRAFT BAH PAPER	


BASIS:  Process:        Integrated to Unbleached kraft-pulping
        Production:     230 tons/day; 75,900 tons/year
        Mill Location:  Southeast
CAPITAL REQUIREMENTS	
1.  Excluding Environmental Cost

    Direct Manufacturing Process
    OSILA Regulations

    Total Fixed Capital
    Total Working Capital  (3 monthl? delivered cost)

2.  Plus Environmental Control Cost
$Million
     57
      2
    59
      3
Water Control

Air Control -



OPERATING COSTS
Fiber Cost
- Internal. 1.
External 3.
Economic Level 0.
Environmental Level 0.
TOTAL FIXED CAPITAL 65.
TOTAL WORKING CAPITAL 3


Other Raw Materials
Hourly Labor
Supplies
Energy
Factory verhead
Capital-related

GS&A
Freight Out




(less capital- recovery)
Sub-total, Factory Cost


Total Delivered Cost, Direct Mfg.
OSHA Regulations
Tot

t
a.l Delivered Cost (excl. capital
recovery)
Water Control Regulations (external, control only)
Air Control Regulations - Economic Recovery

Environmental Control
Total Delivered Cost
$/Ton
65.5
13.5
13.5
7.8
10.3
4.8
9.2
124.5
7.3
18.8
150.6
0.4

151.0
5.7
(2.8)
0.7
154.6
$000/Year
4,960
1,030
1,030
590
780
360
700
9,950
550
1,430
11,430
30

11,460
430
(210)
50
6
2
7
8
3



















11,730
 Source: Arthur D. Little,  Inc., estimates
                                           F-5

-------
                                  TABLE F-5

          SUMMARY OF CAPITAL AND OPERATING COSTS FOR THE MANUFACTURE OF
                              NSSC CORRUGATING MEDIUM
BASIS:  Process:
        Production:
        Mill Location:
NSSC Pulping, Sodium Base
450 tons/day; 155,300 tons/year
Southwest
CAPITAL REQUIREMENTS
                                             $Million
1. Excluding Environmental Cost
Direct Manufacturing Process
OSHA Regulations
Total Fixed Capital
Total Working Capital (3 month?1 delivered cost)
2. Plus Environmental Control Cost
Water Control - Internal
External
Air Control - Economic Level
Environmental Level
TOTAL FIXED CAPITA!.
TOTAL WORKING CAPITAL
OPERATING COSTS
Fiber Cost
Other Raw Materials
Hourly Labor
Supplies
Energy
Factory Overhead
Capital-related (less capital recovery)
Sub-total, Factory Cost
GS&A
Freight Out
Total Delivered Cost, Direct Mfg.
OSHA Regulations
Total Delivered Cost, excluding Federal
Environmental Regulations
Water Control Regulations (external control only)
Air Control Regulations - Economic Recovery
Environmental Control
Total Delivered Cost, (excl. capital
recoverv")
$/Ton
33.3
19.2
17.5
7.3
16.7
8.2
7.3
109.5
7.3
14.6
131.4
0.6

132.0
10.7
-
0.7

143.4

50
3
53
5

3
10.6
_
1.1
67.7
6
$000/Year
5,170
2,980
2,720
1,130
2,600
1,270
1,130
17,000
1,130
2,270
20,400
100

20,500
1,660
-
110

22,270
 Source: Arthur D. Little, Inc., estimates
                                           F-6

-------
                                  TABLE F-6

          SUMMARY OF CAPITAL AND OPERATING COSTS FOR THE MANUFACTURE OF
          	_^ RECYCLED BOXBOARD. 18 PT. CLAY COATED
BASIS:  Process:
        Production:
        Mill Location:
Secondary Fiber Pulping
400 tons/day; 132,000 tons/year
North Central
CAPITAL REQUIREMENTS
                                              $Million
1. Excluding Environmental Cost
Direct Manufacturing Process
OSHA Regulations
Total Fixed Capital




Total Working Capital (3 months delivered cost)
2. Plus Environmental Control Cost
Water Control - Internal
External
Air Control - Economic Level
'Environmental Level


OPERATING COSTS
Fiber Cost
Other Raw Materials
Hourly Labor
Supplies
Energy
Factory Overhead
Capital-related (less capital recovery)





TOTAL FIXED CAPITAL
TOTAL WORKING CAPITAL








Sub-total, Factory Cost
GS&A
Freight Out
Total Delivered Cost, Direct
OSHA Regulations •


Mfg.

Total Delivered Cost, excluding Federal
Environmental Regulations
Water Control Regulations (external control
Air Control Regulations - Economic Recovery
only)

Environmental Control
Total Delivered Cost (excl.
capital recovery)
$/Ton
65.6
14.2
16.1
11.5
23.1
13.1
8.7
152.3
12.4
15.7
180.4
0.5
180.9.

4.1
—
0.5
185.5













49.
1
50.
" 6

1.
5.

0.
57.
6

7

7


7
1

3
8

$000/Year
8
1
2
1
3
1
1
20
1
2
,650
,880
,120
,520
,050
,730
,150
,100
,640
,070










23,810

23




24
70
,880

540
—
70
,490







*0perating costs for water control  (less depreciation and interest) are essentially
 all for external control.  Operation and maintenance for internal control nets
 Source: Arthur D. Little, Inc., estimates
                                          F-7

-------
                                  TABLE F-7

          SUMMARY OF CAPITAL AND OPERATING COSTS FOR THE MANUFACTURE OF
                                   JUTE LINERBOARD
BASIS:  Process:        Secondary Fiber Pulping
        Production:     330 tons/day;  109,000 tons/year
        Mill Location:  North Central
CAPITAL REQUIREMENTS
$Million
1.  Excluding Environmental Cost

    Direct Manufacturing Process
    OSHA Regulations
    Total Fixed Capital
    Total Working Capital (3 month's delivered cost)

2.  Plus Environmental Control Cost

    Water Control - Internal
                    External

    Air Control - Economic Level
                  Environmental Level
   .31.7
    1
   32.. 7
    4
    1.5
    4.6
    0.3
OPERATING COSTS
Fiber Cost
Other Raw Materials
Hourly Labor
Supplies
Energy
Factory Overhead
TOTAL FIXED CAP IT
TOTAL WORKING CAP 11
$/Ton


•



Capital-related (less capital recovery)

GS&A
Freight Out
Total
OSHA Regulations
Total
Sub-total, Factory Cost


Delivered Cost, Direct Mfg.
«
Delivered Cost, excluding Federal
Environmental Regulations
Water Control Regulations (external control only)
Air Control Regulations - Economic Recovery

Total

Environmental Control
Delivered Cost, (excluding
capital recovery)
60.4
16.5
9.6
4-.6.
24.8
6.5
6.5
128.5
7.3
13.8
150.°
0.6
150.6
4.4
-
0.5
155.5

AL 39.1
AL *
$000/Year
5,580
1,800
1,050
490
2,700
710
710
14,040
800
1,500
16,340
70
16,410
480
-
60
16,950



















 Source: Arthur D. Little, Inc., estimates.
                                           F-8

-------
                                  TABLE F-8

          SUMMARY OF CAPITAL AND OPERATING COSTS FOR THE MANUFACTURE OF
                                    BOGUS  MEDIUM
BASIS:  Process:        Secondary  Fiber Pulping
        Production:     330  tons/day;  109,000  tons/year
        Mill Location:  North  Central
CAPITAL REQUIREMENTS
$Million
1. Excluding Environmental Cost
Direct Manufacturing Process
OSHA Regulations

Total Fixed Capital
Total Working Capital (3 tnonttt? delivered cost)
2. Plus Environmental Control Cost
Water Control - Internal
External
Air Control - Economic Level
' 'Environmental Level
TOTAL FIXED CAPITAL
TOTAL WORKING CAPITAL
OPERATING COSTS
Fiber Cost

Other Raw Materials

Hourly Labor
Supplies
Energy
Factory Overhead
Capital-related (less capital recovery)
Sub-total, Factory Cost
GS&A
Freight Out
Total Delivered Cost, Direct Mfg.
OSHA Regulations «
Total Delivered Cost, excluding Federal
Environmental Regulations
Water Control Regulations (external control only)
Air Control Regulations - Economic Recovery
Environmental Control
Total Delivered Cost, (excl. capital
recovery)
$/Ton
62.0
3.6
8^
K
• \J
4.1
28.2
6.3
5.2
118.0
7.3
12.5
137 . 9
0.6
138.5

4.4
—
0.4
143.2

•24.8
1
25.8

4

1.5
4.6
_
0.2
32.1
4
$000/Year
6,760
1QO
•J 7 \J
QAO
y*+\j
440
3,070
690
570

12,860.
800
1,360
15,020
70
15,090

480
— '
50
15,260
                                                                               ally
 Source: Arthur D. Little, Inc., estimates.
                                          F-9

-------
                                  TABLE F-9

          SUMMARY OF CAPITAL ANT) OPERATING COSTS FOR THE MANUFACTURE OF
          	EYPSUM LTNERBOARH	
BASIS:  Process:        Secondary  Fiber  Pulping
        Production:     4QO  tons/day;  132,000 tons/year
        Mill Location:  North  Central
CAPITAL REQUIREMENTS
$Million
1.  Excluding Environmental Cost

    Direct Manufacturing Process
    OSHA Regulations

    Total Fixed Capital
    Total Working Capital (3 month? delivered cost)

2.  Plus Environmental Control  Cost

    Water Control - Internal
                    External

    Air Control - Economic Level
                  Environmental Level
    41.7
     1
    42.7
     5
     1.7
     5.1
     0.3
OPERATING COSTS
Fiber Cost
Other Raw Materials
Hourly Labor
Supplies
Energy
Factory Overhead
TOTAL FIXED CAPITAL 49'8
TOTAL WORKING CAPITAL 5
$/Ton $000/Year






Capital-related (less capital recovery)

GS&A
Freight Out
Total
OSHA Regulations
Total

Sub-total, Factory Cost


Delivered Cost, Direct Mfg.
f
Delivered Cost, excluding Federal
Environmental Regulations
Water Control Regulations (external control only)
Air Control Regulations - Economic Recovery

Total
Environmental Control
Delivered Cost, (excl. capital
60.1
5.0
14.7
10.3
21.0
12.0
7.2
130.3
10.0
12.0
152.3
0.5
152,8


4.1
0.5
157.4
7,930
660
1,940
1,370
2,770
1,590
950
17,210
1,320
1,580
20,110
70
20,180


540
60
20,780
 Source: Arthur D. Little, Inc., estimates.
                                          F-10

-------
                                  TABLE F-10

          SUMMARY OF CAPITAL AND OPERATING COSTS FOR THE MANUFACTURE OF
                                   SBS BOARD
BASIS:  Process:
        Production:
        Mill Location:
Integrated to Bleached Kraft Pulp
500 tons/day; 165,000 tons/year
Southeast
CAPITAL REQUIREMENTS
                                              $Million
1. Excluding Environmental Cost
Direct Manufacturing Process
OSHA Regulations
Total Fixed Capital
Total Working Capital (3 month*? delivered cost)
2. Plus Environmental Control Cost
Water Control - Internal
External
Air Control - Economic Level
Environmental Level












TOTAL FIXED CAPITAL
TOTAL WORKING CAPITAL
OPERATING COSTS
Fiber Cost (Slush pulp: 0.42 ton HW; 0.63 ton SW)
Other Raw Materials
Hourly Labor
Supplies
Energy
Factory Overhead
Capital-related (less capital recovery)
Sub-total, Factory Cost
GS&A
Freight Out
Total Delivered Cost, Direct Mfg.
OSHA Regulations •
Total Delivered Cost, excluding Federal
Environmental Regulations
Water Control Regulations (external control only)
Air Control Regulations •"• Economic Recovery
Environmental Control
Total Delivered Cost, (excl. capital •
recovery)
$/Ton
116.
16.
9.
7.
8.
3.
5.
168.
13.
31.
213.
0.
214.
7.
(3.
0.
219.

4
5
3
9
9
9
9
7
6
4_
7
4
1
9
0)
8
8














123
2
125
9

4
12
1
2
144

9






.1
.0
.6
.1
.8


$000/Year
19
2
1
1
1


27
2
5
35

35
1


36
,190
,720
,540
,300
,470
640
970
,830
,240
,180
,250
70
,320
,300
(490)
130
,260

















 Source: Arthur D. Little, Inc., estimates.
                                           F-ll

-------
                                  TABLE  F-ll

          SUMMARY OF CAPITAL AND OPERATING COSTS FOR THE MANUFACTURE OF
          	              BOND  PAPER (ROLLS)
BASIS:  Process:       Integrated  to  Bleached  Kraft  Pulp
        Production:    300  tons/day;  100,000 tons/year
        Mill Location: Northeast
CAPITAL REQUIREMENTS
1.  Excluding Environmental Cost

    Direct Manufacturing Process
    OSHA Regulations

  •  Total Fixed Capital
    Total Working Capital (3 months delivered cost)

2.  Plus Environmental Control Cost
$Million
     84
      2
     86
      7
Water Control - Internal
External
Air Control - Economic Level
Environmental Level
2.
6.
1.
1.
TOTAL FIXED CAPITAL 96-
TOTAL WORKING CAPITAL 7
OPERATING COSTS $/Ton $000/Year
Fiber Cost (Slush Pulp: 0.473 ton HW; 0.473 ton SW)
Other Ra Materials
Hourly Labor
Supplies
Energy
Factory Overhead
Capital-related (less capital recovery)
Sub-total, Factory Cost
GS&A
Freight Out
Total Delivered Cost, Direct Mfg.
OSHA Regulations
Total Delivered Cost, excluding Federal
Environmental Regulations
Water Control Regulations (external control only)
Air Control Regulations -. Economic Recovery
Environmental Control
Total Delivered Cost, (excluding
capital recovery)
126.3
18.3
11.5
15.1
15.0
5.4
9.2
200.8
35.0
31.0
266.8
0.4
267.2
7.0
(3.0)
0.9
272.1
12,630
1,830
1,150
1,510
1,500
540
920
20,080
3,500
3,100
26,680
40
26,720
700
(300)
90
27,210
1
4
0
2
7

 Source: Arthur D. Little, Inc., estimates.

                                          F-12

-------
                                  TABLE F-12

          SUMMARY OF CAPITAL AND OPERATING COSTS FOR THE MANUFACTURE OF
          	:	BOOK PAPER  (ROLLS)	
BASIS:  Process:      Integrated to Bleached Kraft Pulp
        Production:   300 ton/day;  100,000 ton/year
        Mill Location: Northeast
CAPITAL REQUIREMENTS
1.  Excluding Environmental Cost

    Direct Manufacturing Process
    OSHA Regulations

    Total Fixed Capital
    Total Working Capital (3 month? delivered cost)

2.  Plus Environmental Control Cost
$Million
   82
    2
    84
     7
Water Control - Internal 2.1
External 6.4
Air Control - Economic Level 1.0
•Environmental Level 1.3
TOTAL FIXED CAPITAL 94.8
TOTAL WORKING CAPITAL 7
OPERATING COSTS
Fiber Cost (Slush Pulp; 0.70 tons SW; 0.17 tons HW)
Other Raw Materials
Hourly Labor
Supplies
Energy
Factory Overhead ,, . .
Capital-related (less caPltal recovery)
Sub-total, Factory Cost
GS&A
Freight Out
Total Delivered Cost, Direct Mfg.
OSHA Regulations
Total Delivered Cost, excluding Federal
Environmental Regulations
Water Control Regulations (external control only)
Air Control Regulations - Economic Recovery
Environmental Control
Total Delivered Cost, (excl. capital
recovery)
$/Ton
107.1
47.0
11.7
16.6
19.0
6.3
9.9
217.6
35.0
31,0
283.6
0.4
284.0

7.0
(3.0
0.9
288.9
$000/Year
10,710
4,700
1,170
1,660
1,900
630
990
21,760
3,500
3,100
28,360
40
28,400

700
(300)
90
28,890


















 Source: Arthur D. Little, Inc., estimates.
                                           F-13

-------
                                  TABLE F-13

          SUMMARY OF CAPITAL AND OPERATING COSTS FOR THE MANUFACTURE OF
          	TISSUE PAPER. JUMBO ROLLS	
BASTS:  Process:        Integrated to Bleached Kraft Pulp
        Production:     150 tons/day; 49,500 ton/yr
        Mill Location:  Northeast
CAPITAL REQUIREMENTS
                        $Million
1.  Excluding Environmental Cost

    Direct Manufacturing Process
    OSHA Regulations

    Total Fixed Capital
    Total. Working Capital (3 month? delivered cost)

2.  Plus Environmental Control Cost

    Water Control - Internal
                    External

    Air Control - Economic Level
                  Environmental Level
                           48
OPERATING COSTS
  TOTAL FIXED CAPITAL

TOTAL WORKING CAPITAL

           $/Ton
                                                                    $000/Year
                                                           138.8
                                                             9.9
                                                            15.2
                                                             9.6
                                                             5.3
                                                             6.9
                                                            11.5
                                                           197.2
                        6,870
                          490
                          750
                          480
                          260
                          340
                          570
                        9,760
Fiber Cost  (Slush Pulp; 0.52 ton  HW; 0.52 ton  SW)
Other Raw Materials
Hourly Labor
Supplies
Energy
Factory Overhead
Capital-related (less capital recovery)
                           Sub-total, Factory Cost

GS&A
Freight Out

               Total Delivered Cost, Direct Mfg.

OSHA Regulations

               Total Delivered Cost, excluding Federal
                     Environmental Regulations

Water Control Regulations  (external control only)
Air Control Regulations - Economic Recovery
                        •  Environmental Control

               Total Delivered Cost,  (excluding
                                 capital recovery)

  *Interim product costs for  environmental control are shown with the final
   product.
 Source: Arthur D. Little, Inc., estimates.

                                         F-14

-------
                                  TABLE  F-14

          SUMMARY OF CAPITAL AND OPERATING COSTS FOR THE MANUFACTURE OF
           TISSUE PAPERS. CONVERTED  (50% TOILET. 40% TOWELt 10% NAPKIN)
BASIS:  Process:
        Production:
        Mill Location:
2 Line Converting
163 tons/day; 53,800 tons/year, packaged
Northeast
CAPITAL REQUIREMENTS
1.  Excluding Environmental Cost

    Direct Manufacturing Process
    OSHA Regulations

  •  Total Fixed Capital
    Total Working Capital (3 montHS delivered cost)

2.  Plus Environmental Control Cost
                                              $Million
                                                   63
                                                    2
                                                   65
                                                    7
Water Control - Internal 1.2
External 3.6
Air Control - Economic Level 0.5
Environmental Level 0.6
TOTAL FIXED CAPITAL 70.9
TOTAL WORKING CAPITAL 7
OPERATING COSTS
Fiber Cost (Jumbo rolls, 0.933 ton net).
Other Raw Materials
Hourly Labor
Supplies
Energy
Factory Overhead
Capital-related (less capital recovery)
Sub-total, Factory Cost
GS&A
Freight Out
Total Delivered Cost, Direct Mfg.
OSHA Regulations •
Total Delivered Cost, excluding Federal
Environmental Regulations
Water Control Regulations (external control only)
Air Control Regulations - Economic Recovery
Environmental Control
Total Delivered Cost. (excl. capital
recovery)
$/Ton
184.0
—
34.4
43.7
6.1
19.5
6.1
293.8
160.0
69.0
522.8
0.4
523.2

7.2
(3.0)
1.2

528.5
$000/Year
9,900
-
1,850
2,350
330
1,050
330
15,810
8,610
3,710
28,130
20
28,150

390
(160)
60

28,440




















 Source: Arthur D. Little,  Inc., estimates.

                                          F-15

-------
                                  TABLE F-15

          SUMMARY OF CAPITAL AND OPERATING COSTS FOR THE MANUFACTURE OF
          	DEINKED TISSUE PAPER (JUMBO ROLLS)	
BASIS:  Process:
        Production:
        Mill Location:
Secondary Fiber, Deinking
70 ton/day; 23,000 ton/year
Northeast
CAPITAL REQUIREMENTS
    Excluding Environmental Cost

    Direct Manufacturing Process
    OSHA Regulations

    Total Fixed Capital
    Total Working Capital  (3 month^ delivered cost)

2.  Plus Environmental Control Cost

    Water Control - Internal
                    External
                                              $Million
                                                 17
    Air Control - Economic Level
                  Environmental Level
OPERATING COSTS
                        TOTAL FIXED CAPITAL

                      TOTAL WORKING CAPITAL

                                 $/Ton
$000/Year
Fiber Cost
Other Raw Materials
Hourly Labor
Supplies
Energy
Factory Overhead
Capital-related  (less capital recovery)

                           Sub-total, Factory Cost

GS&A
Freight Out

               To.tal Delivered Cost, Direct Mfg.

OSHA Regulations           •

               Total Delivered Cost, excluding Federal
                     Environmental Regulations

Water Control Regulations  (external control only)
Air Control Regulations - Economic Recovery
                          Environmental Control

               Total Delivered Cost,   (excl.
                                capital recovery)
                                  345.1
   4,380
     430
     950
     520
     670
     610
     380

   7,940
*Interim product costs for environmental control are shown with the final product.
  Source: Arthur D. Little,  Inc., estimates.

                                          F-16

-------
                                  TABLE F-16

          SUMMARY OF CAPITAL AND OPERATING COSTS FOR THE MANUFACTURE OF
          DEINKED TISSUE. CONVERTED (50% TOILET, 40% TOWEL.  10% NAPKIN)
BASIS:  Process:
        Production:
        Mill Location:
1 Line Converting
76 ton/day; 25,000 tons/year
Northeast
CAPITAL REQUIREMENTS
1.  Excluding Environmental Cost

    Direct Manufacturing Process
    OSHA Regulations

    Total Fixed Capital
    Total Working Capital (3 months delivered cost)

2.  Plus Environmental Control Cost

    Water Control - Internal
                    External
    Air Control - Economic Level
                  Environmental Level (SIPs)
                                              $Million
                                                   23.9
                                                    1
                                                   24.9
                                                    4
                                                    0.4
                                                    3.0
                                                    0.1
OPERATING COSTS
TOTAL FIX
TOTAL WORK1
Fiber Cost (Jumbo rolls, 0.933 ton net)
Other Raw Materials
Hourly Labor
Supplies
Energy
Factory Overhead
Capital-related (less capital recovery)
Sub-total, Factory Cost
GS&A
Freight Out
Total Delivered Cost, Direct Mfg.
OSHA Regulations
Total Delivered Cost, excluding Federal
Environmental Regulations
*
Water Control Regulations (external control only)
Air Control Regulations - Economic Recovery
Environmental Control (SIPs)
Total Delivered Cost. (excl. capital
recovery)
:ED CAPII
NG CAPIl
$/Ton
322.0
34.4
43.2
6.0
19.6
6.8
432.0
103.0
61.0
596.0
2.8
598.8
11.6
0.4
610.8
'AL 28.4
'AL *
$000/Year
8,050
860
1,080
150
490
170
10,800
2,580
1,520
14,900
70
14,970
290
~io
15,270
 Source: Arthur D. Little, Inc., estimates.
                                          F-17

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                                  TABLE F-17

          SUMMARY OF CAPITAL AND OPERATING COSTS FOR THE MANUFACTURE OF
          	NEWSPRINT           	
BASIS:  Process:
        Production:
        Mill Location:
Integrated to Semi-Bleached Kraft and Groundwood
550 ton/day; 187,000 ton/year
Northeast
CAPITAL REQUIREMENTS
                                              $Million
1.  Excluding Environmental Cost

    Direct Manufacturing Process
    OSHA Regulations

    Total Fixed Capital
    Total Working Capital (3 month1*? delivered cost)

2.  Plus Environmental Control Cost
                                                   108
                                                     2
                                                   110
                                                     8
Water Control - Internal 2.
External 7.
Air Control - Economic Level 0.
Environmental Level 0.
TOTAL FIXED CAPITAL 120.
TOTAL WORKING CAPITAL 8
OPERATIN^ COSTS
Fiber Cost (Slush pulp: 0.778 ton GW; 0.257 ton kraft)
Other Raw Materials
Hourly Labor
Supplies
Energy
Factory Overhead
Capital-related (less capital recovery)
Sub-total, Factory Cost
GS&A'
Freight Out
Total Delivered Cost, Direct Mfg.
OSHA Regulations
Total Delivered Cost, excluding Federal
Environmental Regulations
Water Control Regulations (external control only)
Air Control Regulations - Economic Recovery
• Environmental Control
Total Delivered Cost, (excl. capital
recovery)
$/Ton
88.5
2.2
7.0
8.7
13.4
2.9
7.8
130.5
13.1
20.9
164.5
0.5
165.0

4.2
(0.8)
0.4
168.8

$000/Year
16,550
410
1,300
1,630
2,510
540
1,460
24,400
2,450
3,910
30,760
100
30,860

780
(150)
80
31,570

 Source: Arthur D. Little, Inc., estimates.

                                          F-18

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                                  TABLE F-18

          SUMMARY OF CAPITAL AND OPERATING COSTS FOR THE MANUFACTURE OF
          	"    	RECYCLED NEWSPRINT	
BASIS:  Process:
        Production:
        Mill Location:
Secondary Fiber Pulping
330 tons/day; 112,000 tons/year
Northeast
CAPITAL REQUIREMENTS
1.  Excluding Environmental Cost

    Direct Manufacturing Process
    OSHA Regulations

    Total Fixed Capital
    Total Working Capital (3 month? delivered cost)

2.  Plus Environmental Control Cost

    Water Control - Internal
                    External

    Air Control - Economic Level
                                              $Million
                                                 41.8
                                                  1
                                                 42.8

                                                  5

                                                  1.6


                                                 11.3
Environmental Level (Sirs)
TOTAL FIXED CAPIT
TOTAL WORKING CAP 11
OPERATING COSTS $/Ton
Fiber Cost
Other Raw Materials
Hourly Labor
Supplies
Energy
Factory Overhead
Capital-related (less

GS&A
Freight Out
Total
OSHA Regulations
Total







capital related) .
Sub-total, Factory Cost


Delivered Cost, Direct Mfg.
•
Delivered Cost, excluding Federal
Environmental Regulations
Water Control Regulations (external control only)
Air Control Regulations - Economic Recovery

Total
Environmental Control
Delivered Cost, (exc'l. capital
TP^f* ^.ITQV^T \
53.7
12.0
12. €
11.6
33.0
8.0
8.5
138.8

13.0
12.5
164,3
0.6
165.0

11.3
-
0.4
176.7
0.2
AL 55.3
AL 5
$000/Year
6,010
1,350
1,340
1,300
3,700
900
950
15,550

1,460
1,400
18,410
70
18,480

1,270
-
40
19,790
 Source: Arthur D. Little, Inc., estimatRs-

                                          F-19

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                                  TABLE F-19

          SUMMARY OF CAPITAL AND OPERATING COSTS FOR THE MANUFACTURE OF
          	SULFITE  DISSOLVING PULP	


BASIS:  Process:        Bleached Magnesium Base  Sulfite;  Cont. Pulping with Chemical
        Production:    550  ADT tons/day;  190,000 tons/year              Recovery
        Mill Location: Northwest
CAPITAL REQUIREMENTS
$Million
1. Excluding Environmental Cost
Direct Manufacturing Process
OSHA Regulations
Total Fixed Capital
Total Working Capital (3 monthl? delivered cost)
2. Plus Environmental Control Cost
Water Control - Internal
External
Air Control - Economic Level
Environmental Level
TOTAL FIXED CAPITAL
TOTAL WORKING CAPITAL
OPERATING COSTS
Fiber Cost
Other Raw Materials
Hourly Labor
Supplies
Energy
Factory Overhead
Capital-related (less capital recovery)
Sub-total, Factory Cost
GS&A
Freight Out
Total Delivered Cost, Direct Mfg.
OSHA Regulations •
Total Delivered Cost, excluding Federal
Environmental Regulations
Water Control Regulations (external control only)
Air Control Regulations - Economic Recovery
• Environmental Control
Total Delivered Cost, (excl. capital
recovery)
$/Ton
79.8
23.0
23.1
13.5
4.2
8.3
15.5
167.4
13.6
31.4
212.4
0.5
212.9

16.1
-
0.6
229.6

130
3
133
10

3.5
24.0
«.
1.1
161.6
11
$000/Year
15,160
4,370
4,390
2,570
790
1,580
2,950
31,810
2,580
5,970
40,360
100
40,460

3,060
—
110
43,630
 Source: Arthur D. Little, Inc., estimates.
                                         F-20

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                                  TABLE F-20

          SUMMARY OF CAPITAL AND OPERATING COSTS FOR THE MANUFACTURE OF
                        BLEACHED KRAFT  SOFTWOOD  MARKET  PULP
BASIS:  Process:
        Production:
        Mill Location:
Continuous Kraft Pulping, CEDED Bleaching
800 ADT/day; 276,000 ADT/year
Southeast
CAPITAL REQUIREMENTS
                                              $Million
1. Excluding Environmental Cost
Direct Manufacturing Process
OSHA Regulations
' Total Fixed Capital
Total Working Capital (3 montWff delivered cost)
2. Plus Environmental Control Cost
Water Control - Internal
External
Air Control - Economic Level
Environmental Level
TOTAL FIXED CAPITAL
TOTAL WORKING CAPITAL
OPERATING COSTS
Fiber Cost
Other Raw Materials
Hourly Labor
Supplies
Energy
Factory Overhead
Capital-related. (less capital recovery)
Sub-total, Factory Cost
GS&A
Freight Out
Total Delivered Cost, Direct Mfg.
OSHA Regulations •
Total Delivered Cost, excluding Federal
Environmental Regulations
Water Control Regulations (external control only)
Air Control Regulations -• Economic Recovery
Environmental Control
Total Delivered Cost, : (excl. capital
Tror^mrcrtrv}
$/Ton
51.6
25.8
15.8
11.9
8.0
4.7
12.7
130.5
13.6
31.4
175.5
0.4
175.9

6.9
(3.0)
0.8
180.6

155
3
158
12

5.2
15.1
2.6
3.1
184.0
12
$000/Year
14,240
7,120
4,360
3,290
2,200
1,300
3,510
36,020
3,760
8,660
48,440
100
48,540

1,900
(830)
230
49,840



















 Source: Arthur D. Little, Inc., estimates.
                                           F-21

-------
                                  TABLE F-21

          SUMMARY OF CAPITAL AND OPERATING COSTS FOR THE MANUFACTURE OF
                   SOUTHERN BLEACHED KRAFT SOFTWOOD SLUSH PULP
BASIS:  Process:        Continuous Kraft Pulping; CEDED Bleaching
        •Production:     800 ADT/day; 276,000 ADT/Year
        Mill Location:  Southeast
CAPITAL REQUIREMENTS
                        $Million
1.  Excluding Environmental Cost

    Direct Manufacturing Process
    OSHA Regulations

  '  Total Fixed Capital
    Total Working Capital (3 montlW delivered cost)

2.  Plus Environmental Control Cost

    Water Control - Internal
                    External
                             125
    Air Control - Economic Level
                  Environmental Level
OPERATING COSTS
  TOTAL FIXED CAPITAL

TOTAL WORKING CAPITAL

           $/Ton
$000/Year
Fiber Cost
Other Raw Materials
Hourly Labor '
Supplies
Energy
Factory Overhead
Capital-related  ' (less capital recovery)

                           Sub-total, Factory Cost

GS&A
Freight Out

               Total Delivered Cost, Direct Mfg.

OSHA Regulations
               Total Delivered Cost, excluding  Federal
                     Environmental Regulations

Water Control Regulations  (external control only)
Air Control Regulations -  Economic Recovery
                           Environmental  Control

               Total Delivered Cost,   (excl.
                               capital recovery)
             51.6
             28.0
             11.9
              6.5
              2.9
              3.6
             11.3
            115.8
14,240
 7,730
 3,290
 1,790
   800
   990
 3.120
31,960
  *Interim product costs for environmental control are shown with the

   final product.

  Source:  Arthur  D.  Little,  Inc.,  estimates.
                                         F-22

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                                  TABLE F-22        .

          SUMMARY OF CAPTTAL AND OPERATING COSTS FOR THE MANUFACTURE OF
          	NORTHERN BLEACHED KRAFT. SOFTWOOD SLUSH PULP	
BASIS:  Process:       Continuous Kraft Pulping, CEDED Bleaching
        Production:    800 ADT/day; 276,000 ADT/year
        Mill Location: Northeast
CAPITAL REQUIREMENTS
$Million
1.  Excluding Environmental Cost

    Direct Manufacturing Process
    OSHA Regulations
               *
  •  Total Fixed Capital
    Total Working Capital (3 month*!? delivered cost)

2.  Plus Envirorimental Control Cost

    Water Control - Internal
                    External

    Air Control - Economic Level
                  'Environmental Level
    125
OPERATING COSTS
Fiber Cost
Other Raw Materials
Hourly Labor
Supplies
Energy
Factory Overhead
Capital-related '. (less

GS&A
Freight Out
Total
OSHA Regulations
Total

TOTAL FIXED CAPIT
TOTAL WORKING CAPIT
$/Ton






capital recovery)
Sub-total, Factory Cost

•
Delivered Cost, Direct Mfg.
•
Delivered Cost, excluding Federal
Environmental Regulations
Water Control Regulations (external control only)
Air Control Regulations -' Economic Recovery

Total

Environmental Control
Delivered Cost, (excl.
83.0
28.5
10.4
6.5
7.2
3.6
11.3
150.5


*







capital recovery
AL
AL
$000/Year
22,910
7,860
2,870
1,790
1,990
990
3,120
41,530


*








   *Interim product costs for environmental control are shown with the final product,
  Source:  Arcnur U.  Lli.de, Inc.,  estimates.
                                          F-23

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                                        TABLE  F-23

                SUMMARY OF CAPITAL ANT) OPERATING  COSTS FOR THE MANUFACTURE OF
                           SOUTHERN BLEACHED KRAFT HARDWOOD SLUSH PULP
      BASIS:   Process:        Continuous Kraft Pulping, CEDED Bleaching
              Production:     800 ADT/day; 276,000 ADT/year
              Mill Location: Southeast
      CAPITAL REQUIREMENTS	
      1.  Excluding Environmental Cost

          Direct Manufacturing Process
          OSHA Regulations

        '  Total Fixed Capital
          Total Working Capital (3 month? delivered cost)

      2.  Plus Environmental Control Cost

          Water Control - Internal
                          External

          Air Control - Economic Level
                        Environmental Level
OPERATING COSTS
                                                TOTAL FIXED CAPITAL

                                              TOTAL WORKING CAPITAL

                                                         $/Ton
                                                                      $Million
                                                                          116
                                                                          $000/Year
Fiber Cost
Other Raw Materials
Hourly Labor
Supplies
Energy
Factory Overhead
Capital-related    (less capital recovery)
                                                                 42.2
                                                                   .3
                                                                   .5
                                                           26.
                                                           10.
                                                            6.2
                                                            3.7
                                                            3.5
                                                           10.7
                                 Sub-total, Factory Cost
                                                          103.1
11,650
 7,260
 2,890
 1,710
 1,030
   970
 2.950

28,460
      GS&A
      Freight Out
                     Total Delivered Cost, Direct Mfg.

      OSHA Regulations

                     Total Delivered Cost, excluding Federal
                           Environmental Regulations

      Water Control Regulations  (external control only)
      Air Control Regulations - Economic Recovery
                                Environmental Control

                     Total Delivered Cost,    (excl.
*Interitn product costs for environmental control are shown with the final product.
        Source:  Arthur  D.  Little,  Inc.,  estimates.
                                                 F-24

-------
                                  TABLE  p_24

          SUMMARY OF CAPITAL AND OPERATING COSTS FOR THE MANUFACTURE OF
          	    NORTHERN BLEACHED KRAFT HARDWOOD ST.ITSH PTTT.P	
BASIS:  Process:
        Production:
        Mill Location:
Continuous Kraft Pulping; CEDED Bleaching
800 ADT/day; 276,000 ADT/year
Northeast
CAPITAL REQUIREMENTS
1.  Excluding Environmental Cost

    Direct Manufacturing Process
    OSHA Regulations

  •  Total Fixed Capital
    Total Working Capital (3 montlfff delivered cost)

2.  Plus Environmental Control Cost

    Water Control - Internal
                    External

    Air Control - Economic Level
                  'Environmental Level
                                              $Million
                                                   116
OPERATING COSTS
                         TOTAL  FIXED  CAPITAL

                       TOTAL  WORKING  CAPITAL

                                  $/Ton
$000/Year
Fiber Cost
Other Raw Materials
Hourly Labor
Supplies
Energy
Factory Overhead
Capital-related     (less  capital  recovery)

                            Sub-total,  Factory  Cost

GS&A
Freight Out

               Total  Delivered  Cost, Direct  Mfg.

OSHA Regulations            •

               Total  Delivered  Cost, excluding Federal
                      Environmental  Regulations

Water Control  Regulations  (external control only)
Air Control Regulations - Economic  Recovery
                           Environmental Control

               Total  Delivered  Cost,  ;   (excl. capital
                                           recovery),
                                    52.6
                                    26.3
                                     9.8
                                     6.2
                                     7.8
                                     3.0
                                    10.7
                                   116.4
14,520
 7,260
 2,700
 1,720
 2,150
   830
 2.950

32,130
     *Interim product  costs for environmental control are shown with
      the  final  product.
  Source:  Arthur D.  Little,  Inc., estimates.
                                            F-25

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                                   TABLE F-25

            SUMMARY OF CAPITAL AND OPERATING COSTS FOR THE MANUFACTURE OF
                        SEMI-BLEACHED KRAFT SOFTWOOD SLUSH PULP
BASIS:  Process:        Continuous Kraft Pulping; CED Bleaching
        Production:     800 tons/day,; 276,000 tons/year**
        Mill Location:  Northeast
CAPITAL REQUIREMENTS
                                                       $Million
1.  Excluding Environmental Regulations

     Direct Manufacturing Process
     OSHA Regulations

     Total Fixed Capital
     Total Working Capital (3 months delivered Cost)

2.  Plus Effluent Control Cost
     Water Control


     Air Control
Internal
External

Economic Level
Environmental Level
                                                        120
Total Fixed Capital
Toal Working Capital
OPERATING COST ITEM $/Ton
Fiber Cost
Other Raw Materials
Hourly Labor
Supplies
Energy
Factory Overhead
Capital Related (less capital recovery)
Sub-total, Factory Cost
GS&A
Freight Out
Total Delivered Cost, Direct Mfg.
OSHA Regulations
Total Delivered Cost, excl. Federal
Environmental Regulations
Water, Control Regulations
Air Control Regulations - Economic Recovery
Total Del'd cost, (excl. capital
recovery)
75.8
15.2
10.4
6.5
3.2
3.6
10.8
125.5
*
$000/Year
20,920
4,200
2,870
1,790
880
990
2,980
34,630
*
-
  * Interim product costs for environmental control are shown with the final product.


 ** Semi-bleached kraft to newsprint only; remainder of production fully bleached.

Source:  Arthur D. Little, Inc., estimates.
                                           F-26

-------
                                     TARLE F-26

             SUMMARY OF CAPITAL AND OPERATING COSTS FOR THE MANUFACTURE OF
                               GROUNDWOOD SLUSH PULP
   BASIS:  Process:       Stone Groundwood
           Production:    440 ADT/day; 150,000 ADT/year
           Mill Location: Northeast
   CAPITAL REQUIREMENTS
                        $Million
   1.  Excluding Environmental Cost

       Direct Manufacturing Process
       OSHA Regulations

     •  Total Fixed Capital
       Total Working Capital  (3 montliTT delivered cost)

   2.  Plus Environmental Control Cost

       Water Control - Internal
                       External
                            23
       Air Control - Economic Level
                     'Environmental Level
   OPERATING COSTS
  TOTAL FIXED CAPITAL

TOTAL WORKING CAPITAL

           $/Ton
$000/Year
   Fiber Cost
   Other Raw Materials
   Hourly Labor
   Supplies
   Energy
   Factory Overhead
   Capital-related      (less capital recovery)

                               Sub-total,  Factory Cost

   GS&A
   Freight Out

                  Total. Delivered  Cost, Direct Mfg.

   OSHA Regulations            •

                  Total Delivered  Cost, excluding  Federal
                        Environmental  Regulations

   Water Control  Regulations  (external control only)
   Air Control Regulations  - Economic  Recovery
                              Environmental  Control

                  Total Delivered  Cost.  j(excl. capital
                                           recovery)
             35.9
              1.9
             11.3
              2.1
             11.6
              5.7
              3.8
             72.3
 5,390
   280
 1,700
   310
 1,740
   850
   570
10,840

   *
*Interim product costs for environmental control are shown with the final product.
     Source:  Arthur D.  Little,  Inc.,  estimates
                                                 F-27

-------
d.  Selection of Products
     The specific paper and paperboard products considered in the models were selected from
the principal product  sectors. The selection was based  upon the relative importance of the
product in its sector from a tonnage standpoint.

e.  Mill Characteristics
     All cost models relate to new  mill installations that typify good technical practice in 1975.
No model represents the cost of an  actual mill.

     A typical scale of operation was assumed in all the models. A relatively large capacity was
used for virgin  fiber  pulping, one considered economical by 1975 standards but not the largest
possible. For papermaking operations  integrated to  virgin pulping, ADL selected the largest
practical size for a single machine, which  is typical of current installations. For nonintegrated
secondary fiber operations, a single  machine capacity smaller than the  largest practical was
selected; this is representative of the  existing industry, since economic availability of secondary
fiber rather than machine size is the limiting factor in plant capacity.

     Mill capacity was defined on  a  daily  tonnage basis,  and annual capacity was obtained by
multiplying this tonnage by net operating days per year. The latter are total days of actual mill
operation after  subtracting scheduled down-time for holidays and estimated maintenance shut-
downs. Seven paid holidays were allowed, and it was assumed that the mill would operate on
three of them. Another seven days were allowed  for scheduled  maintenance shutdowns. Of the
remaining 354  on-stream days,  it was estimated that commodity grades (newsprint, board
products, corrugating medium, and market pulp) would have a total productive operation of 340
to 345 days. For noncommodity grades, ADL estimated 330 productive  days to reflect more
frequent cleanup and grade changes.

     Plant  locations  are consistent with existing  paper industry patterns.  For products where a
number of geographic areas could be considered typical, the models are concentrated in one area
to emphasize fiber furnish and product grade as  the primary variables in  cost and profitability
estimates.

     A large portion of the kraft  pulp sector is located in the Southeast, where  costs differ
considerably from those in other areas. The typical models for bleached kraft paper grades are
located in the Northeast, but bleached softwood and hardwood kraft pulp models have also been
prepared for the Southeast to indicate the  influence  of plant  location  on  the  cost of these
products.

f.  Nature and Precision of Specified Conditions
     To prepare cost estimates, ADL  postulated the operating and marketing conditions for each
model. Some conditions are affected by plant location, such as the cost of fuel and power, the cost
of virgin and secondary fiber, and the  availability  of virgin fiber as roundwood or chips and can be
clearly defined. Other conditions are affected by plant size;  for example, whether it is more
economical to generate or to purchase power. These conditions also are amenable to analytical
analysis. Some  conditions can vary considerably  from one mill to another for the same product
and capacity, and thus are more difficult to define. Such conditions include: manning require-
ments, maintenance, utility consumption, chemical  usage, fiber yield, and  factory overhead.
Selling price, sales expense, general administration costs, and freight (as affected by the distribu-
tion of customers) are all influenced by individual company characteristics.

                                           F-28

-------
     The models are based on the use of a single paper machine; however, the same amount of a
product could be made on two or more smaller machines at significantly different cost. Thus,
while every effort has been made to select typical conditions, different but equally valid assump-
tions can be made.

     In addition to variations from the conditions specified, there is an inherent lack of precision
in estimating present costs, or updating historical costs, when economic conditions are fluctuat-
ing rapidly.

     One of the key variables is scale of operation (plant capacity). All capacities in the models
are based on the use of a single machine.

     The variability of each major production and cost item, and the treatment of these items, is
as follows:

     (1)  Product Mix. A single typical product grade or simplified product mix is used in
         each model. Most mills  in  the  studied categories  and size  ranges (with the
         exception  of sulfite dissolving pulp) make a  variety of product  grades  with
         different selling prices. The  selection of an "average  value"  single product or
         simplified  grade structure is hypothetical but adequate for estimating an ex-
         ample of a category.
     (2)  Fiber Furnish and Other Raw Materials. The exact fiber furnish  and other raw
         materials requirements are  determined  by product specifications. Thus,  cost
         estimates for these items  are simplified to the same extent that product mix is
         simplified. In addition, fiber furnish and cost for a particular product can  vary
         because of mill specifics, such as  geographic variation in cost and availability of
         wood species, corporate integration to timberlands, intra-company pulp transfer,
         and accessibility of waste paper. The cost estimates  are reasonable examples
         based on selected products  and  specified  mill conditions. In interpreting and
         using these examples, however, one must consider possible variations in  product
         lines, mill conditions, and actual  costs under specified conditions.
     (3)  Sales and Freight Costs. ADL has estimated sales and freight costs as a function
         of the specific product quantity produced and sold on the open market.  Consid-
         eration should be given  to  variability that results from actual product  mix,
         corporate integration forward to intermediate consumers or converters,  and the
         location of markets.
     (4)  Operating  and Packaging Supplies. Costs for operating and packaging supplies
         are estimated for specific processes and products. They do not vary significantly
         except for consumer products (e.g., tissue papers), for which packaging materials
         are a major and quite variable cost component for different products, or for the
         same product packaged in different ways.
     (5)  Direct Labor and Factory Overhead. ADL estimated direct labor  and factory
         overhead costs on the basis of a normal manpower complement for the specified
         product and process. Manpower  requirements are a function  of production per
         paper machine as well as total mill output. Wages and labor efficiency can  vary
         because of geographic location or  individual mill differences. In addition  to these
                                          F-29

-------
          inherent  variations, many  overhead costs  and some labor positions are dis-
          cretionary.  However, only the inherent variability of wages, salaries,  and effi-
          ciency need be considered. Major reductions in discretionary costs could be made
          only through specialized production arrangements or markets, or at the sacrifice
          of  product  quality  control and overall technical  competence. None of these
          conditions is consistent with the long-range viability of a mill selling on the open
          market.
     (6)   Energy Consumption. Steam and power usage has been estimated on the basis of
          normal requirements for the process and selected product at the rates prevailing
          for the specified location. Geographic variation in rates for fuel  and  power is
          significant, and mill-to-mill variations in consumption are considerable. On-site
          power generation, an option for mills with high steam consumption,  radically
          affects purchased power costs.
     (.7)   Maintenance  Materials and Labor. ADL estimated maintenance  materials, la-
          bor, and upkeep reinvestment at levels which maintain long-range viability of an
          installation. Items  included in this category are those normally expensed by a
          firm. Capitalized  maintenance for replacing and/or modernizing a facility is.
          discretionary and shown separately on an industry aggregate basis. (Appendix F-
          4.)
     (8)   Effluent Control Costs. ADL used the updated Development Document data as
          the basis for effleunt control costs in  all cases. As discussed in Chapter IV,  the
          Development  Document estimates  are reasonable but are subject to wide  varia-
          tion from mill-to-mill.

g.  Slush Pulp Cost
     Virgin-fiber kraft pulp is the basis for several paper and board grades as well as for market
pulp. Because any combination of drying and papermaking operations may be integrated to kraft
pulping,  papermaking capacity for a given  product  is independent of pulp mill capacity. To
obtain economies of scale, the pulp mill is  generally much larger than  a single papermaking
operation and typically supports two or more paper machines.

     For this reason, it was most convenient to develop a total factory operating cost for bleached
kraft slush pulp as a raw material input to a papermaking operation.  This base-level slush pulp
cost was  related to a particular pulp mill capacity (800 ADT/day in the case of bleached kraft)
and includes  wood preparation, pulping, and bleaching (where applicable). It  was  determined by-
subtracting the converting and capital costs allocated to pulp drying from the total factory
operating cost in the 800-ADT virgin market-pulp models.

     The cost estimates for the  papermaking operation include all the supporting  operations,
such as stock preparation,  papermaking, and roll finishing. Associated with the slush pulp are the
principal utilities (steam and power generation,  water supply, and effluent treatment) related to
pulp drying.  The  investment  and operating costs for shared facilities are allocated between the
pulping  and  papermaking operations in proportion to their respective use  of the utilities, as
indicated in Figure  F-l.

     In addition to sharing physical facilities integrated papermaking operations also have the
benefit of sharing many of the costs included with factory overhead. An overhead schedule was
developed for an 800-ADT/day market pulp mill to provide the basis for factory overhead costs on
all models integrated to  bleached kraft pulping.

                                           F-30

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                              Slush Pulp Transfer Cost,
                              Including Allocated Portion
                              of Shared Facilities
                            All Other Costs for Paper, Board, or
                            Market Pulp Model, Including Allocated
                            Portion of Shared Facilities Proportional
                            to Slush Pulp Usage
                    Steam, Power, Water
                              Effluent
Power Boiler
Turbine Generator
Water Supply
Effluent Treatment
Other Shared
Facilities
                                 Steam, Power, Water
                                                                                    Effluent
                                             Capacity - 800 ADT/Day
71
OJ
                 Pulp Mill
                 Includes Wood
                 Preparation,
                 Pulping, and
                 Bleaching
                 (if applicable)
Slush
Pulp
               Capacity - 800 ADT/Day
                                                      Pulp Dryer or
                                                      Paper or Board
                                                      Machine Includes
                                                      Stock Preparation, Paper-
                                                      Making, and Roll Finishing
                                                                                                                               Product
                                                  Capacity — Varies With Each Model
                                       Other Unspecified On-Site
                                       Use for Balance of Pulp
                                       Mill Capacity
                                 FIGURE  F-1   DEFINITION OF SLUSH PULP COST AND ALLOCATION OF COST
                                                OF SHARED FACILITIES FOR  INTEGRATED MILL COMPLEX
                                                (BLEACHED KRAFT MODEL)

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     To calculate the operating costs for a product made on a paper machine smaller than a
corresponding pulp mill, ADL transferred the total operating cost of "slush pulp" to the paper-
making operation. Slush pulp costs (fiber, labor, utilities, etc.) are treated as a raw material item
in the papermaking  operating schedule. Similarly, to calculate  the total investment for the
manufacture of a studied product, an apportioned amount of the pulp mill investment (propor-
tional to pulp usage)  is added to the estimated investment for the papermaking operation.

     Finally, virgin groundwood pulp at 440 ADT/day and semi-bleached kraft softwood pulp at
800 ADT/day are the bases for several paper and board grades.  ADL used the same technique of
developing a slush pulp transfer cost to an integrated papermaking operation. To obtain total
capital requirements, the pulp mill investment associated with the quantity transferred to the
papermaking operation was added to the investment for the paper mill.

2!  CAPITAL REQUIREMENTS

a.  Total Fixed Capital
     Total fixed capital is the total of physical plant cost and other  fixed capital costs.  In the
previously  referenced source document, a capital cost  schedule  was developed for each mill
model. These estimates were based upon published and in-house information. We  believe the
estimates have a precision of + 25% to - 10%; thus, while they are not suitable for making an
investment decision,  they are adequate for cost comparisons and useful as the basis of estimating
capital requirements  to support industry expansion.

     Capital costs for woodlands operations are not included in any  of the estimates. Where a
woodlands position exists, its capital and operating costs as well as its profitability are reflected
in the cost of wood as delivered to the mill site.

     (1)  Physical Plant Cost. The physical plant cost consists of the direct plant cost plus
          the estimated costs of construction supervision and  overhead, engineering, and
          allowance  for contingencies. Direct plant cost is the installed cost of buildings,
          purchased  equipment, and site work, excluding the cost of land. Each element in
          the cost schedule includes purchased equipment and building materials, piping,
          instrumentation, electricals, structures, foundations, and associated labor costs.
     (2)   Other Fixed Costs. ADL also estimated the additional capital cost items that are
          normally associated with a new  venture but not included in  the physical plant
          cost — spare parts, pre-startup and startup costs, project  management, etc.
          Note,  however,  that  interest accruing on borrowing during the  construction
          period is not included in the estimated capital costs.

b.  Working Capital
     Experience has  demonstrated that the working capital required for raw materials, goods in
process, inventory, and accounts receivable  (less  accounts payable)  is generally equivalent to
three months' production at total factory cost.

c.  Capital Call-Down Schedule
     Table F-2 shows the capital call-down schedule for the  construction of new  mills. This
schedule  was used  in the economic impact analysis (Chapter  VI), to postulate  the  timely
                                          F-32

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commitment of capital and the subsequent capital call-down for meeting the industry's need for
new capacity. The table also indicates the simplified startup schedule (80% of full production in
the first year of operation) used in calculating annual sales revenue.

3.  OPERATING COST CONSIDERATIONS

a.  Raw Material Requirements
     Raw material costs include all raw materials for manufacture, auxiliary materials such as
chemicals for water and effluent treatment, and net credit for any by-product recovery.

     (1)  Fiber Cost.  Requirements for pulpwood or other cellulosic raw materials were
         developed via  a  material balance  that took into account such factors as wood
         densities, pulping yields, and process losses. The total factory operating cost of
         slush pulp  was considered a raw material cost for any papermaking operation
         integrated to a pulp mill that could provide furnish for more than one product
         line.
     (2)  Other Raw Materials. The material balance also provided estimates of the  pul-
         ping and papermaking chemical requirements. ADL used typical fresh chemical
         makeup rates  to pulping and bleaching operations  but accounted only for the
         fiber output from  these operations.  Chemical losses were  assumed equal to
         chemical makeup rates minus any by-product recovery, and  no attempt  was
         made to postulate internal chemical recovery and recycling.

     Most of the papermaking chemicals become part of the product. ADL thus accounted for
papermaking chemical losses  and, by difference, for the additives recovered with the finished
sheet.

     The material balance included other chemical raw materials such as detergents, slimicides,
antifoam agents, retention aids, pitch control agents, and water softening agents (or ion exchange
resins) for boiler feedwater treatment. These materials are used in small quantities,  but when
aggregated they constitute  an identifiable component of the manufacturing cost.

     All chemical costs are combined under "Other Raw Materials" and reported as a single unit
per ton of product. Mill records and ADL experience were used to estimate the total cost.

b.  Conversion
     Conversion includes all factory labor (direct and indirect),  supplies, energy, and expenses
other than raw materials or capital-related items.

     (1)  Labor, Hourly. Labor requirements for many of the models are based on in-house
         information pertaining to actual mill practice; others are based on more thorough
         pre-engineering cost studies that ADL has prepared for various product areas. A
         man-year is assumed to consist  of 2068 man-hours  (47  weeks at 44 hours).
         Holidays and vacations are included in fringe benefits at 32% (included in hourly
         rate).
         For new plants, the  cost of maintenance labor is often estimated as a percentage
         of plant investment; about 2% is typical for pulp and paper manufacture. How-
         ever, ADL  chose to develop a manning table to estimate this cost, specifically
         excluding  any labor associated  with capital  improvement  or replacement
         projects.
                                         F-33

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     (2)   Supplies (Operating, Maintenance, and Packaging). Operating supplies include
          replaceable parts such as felts, wires, lubricating oil and grease, rags, and fuel
          (for fork lift trucks). Units and unit costs for this entry are not meaningful. In-
          house mill records  and  industry records provide  the most  reliable source of
          information on the cost for the various pulp and paper grades.
          Maintenance  supplies in pulp and paper manufacture typically cost about the
          same as maintenance labor; they were estimated at 1.5% to 2% of physical plant
          cost.
          Packaging supplies  also vary widely among the  paper grades selected  for eco-
          nomic analysis. For example, linerboard requires only a core, plugs, and steel
          strapping; the total cost for these supplies is $0.50-$1.00 per ton. The supplies
          used in packaging  tissue, however, which included printed  folding boxes and
          corrugated containerboard, cost about $50 per ton. For most commodity grades,
          where packaging supplies are a  minor item, a single entry is shown based on
          industry practice. For tissue, including packaging supplies, ADL separately esti-
          mated the cost of converting from jumbo rolls to packaged product.
     (3)   Energy. The unit requirements for fuel and power were derived by  an energy
          balance. Only the portion of the total steam requirement which is generated from
          fossil fuel  represents an actual cost; the  portion obtained by burning  bark or
          black liquor is transferred from the pulp mill at no charge.
          Whenever total steam requirements for a product (including the combination of
          pulping and the forming for integrated operations) exceeded the equivalent of
          5000 kw of power, the cost of an extraction turbine generator was included in the
          estimated  capital requirements.  All smaller operations  were assumed to  use
          power purchased from external sources.
          ADL did not explore the economics of generating power vs. purchasing power for
          each model. The minimum 5000  kw for on-site power represents an average for
          second-quarter 1975 conditions; this minimum would vary from one location to
          another, depending  on regional and local power costs, specific conditions of the
          mill, and the capital cost of generating facilities.
          Since the  capital, labor, and chemical treatment  costs for water supply were
          included in the estimates, no purchase costs were  included for water.
     (4)   Factory Overhead. Factory overhead includes on-site management; salaried su-
          pervision;  the salaries of office clerical, technical, and laboratory staff; on-site
          office and laboratory supplies and expense; and  personal expenses. It excludes
          off-site overhead, such as corporate administration and sales expense, which are
          shown as separate nonfactory costs. Factory overhead is expressed as  a percent-
          age of total direct and indirect labor, excluding maintenance labor.

c. Capital-Related Costs
     (1)   Capital Recovery. Capital recovery is the amount required to repay  the initial
          investment plus the  cost of capital, distributed uniformly over the expected life of
          the project. A value of 12.1% of  the fixed capital requirement was used as the
          capital recovery rate. (See Chapter VI for derivation of capital recovery rate.)
     (2)   Local Taxes and Insurance. Local taxes on new facilities are typically 2 to 2 l/i % of
          new investment, a contribution to operating cost which can be derived readily.

                                           F-34

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d.  Cost of Sales
     (1)  General Sales and Administrative  Costs. General administration includes all
         allocated corporate (nonfactory) costs, such as central engineering, purchasing,
         research, corporate management and legal staff, and office overhead. This cost is
         affected by corporate structure, size of the operation, and value of the product,
         and ranges typically from about 3% to 10% of the total factory cost. (This cost
         varies widely, however, and is strongly dependent upon the marketing character-
         istics of the individual product. ADL relied upon its experience to select a typical
         cost for this item for each of the studied paper and paperboard products.)
         Sales expense for commodity products, such as linerboard, newsprint, or bag
         paper, is significantly less than that for retail-oriented products such as tissue,
         printing paper,  and writing paper.  Moreover, there is a wide variation within
         each major category, reflecting the costs associated with marketing brand-name
         or private-label  products. ADL used its judgment to select an appropriate value
         from within the  range of costs experienced by the industry.
     (2)  Freight Out.  The cost of shipping the finished product has been estimated for
         individual  products.  Variations in  freight rates reflect differences in product
         value, the industry practice of exchanging some board grades between manufac-
         turers,  or  distribution patterns based on paper grades and mill size. Again,
         general industry averages were used.

4. .SUPPLEMENTARY USES OF NEW MILL MODELS
     In addition to showing how the costs of compliance are related to direct manufacturing
costs, the new mill models provide a convenient data base for estimating two other key inputs
required in the economic  impact analysis: (a) the capitalized  maintenance required for the
existing industry, and (b) the capital investment required to build additional industry capacity.
These items are not germane to Chapter  HI, which pertains only to the costs of compliance; they
are used in Chapter VI, which deals with the industry's capital needs during the studied period.

a.  Capitalized  Maintenance
     Capitalized maintenance for rebuilding or replacing existing equipment constitutes a major
portion of a mill's or corporation's budget.  These  capitalized expenditures are over and above
routine maintenance costs, which are expensed and appear as part of the operating cost sched-
ules. The expenditures may constitute a significant percentage  of the industry's total capital
budget; thus, it is essential to make a reasonable estimate of them.

     As a starting point, the average normal life of pulp and paper equipment, given only routine
expensed maintenance, is about 40 years. This means that on average, 21/2% of existing capacity
becomes mechanically  obsolete each year. The current high rate of research and commercial
development  should  increase the rate of technical and economic obsolescence;  thus an overall
average of 3% of existing capacity becoming obsolete  each year for  technical or mechanical
reasons (and without further investment) is reasonable over the studied period in this report.

     The estimated 3% obsolescence constitutes the total requirement  of the industry's tonnage
if capitalized maintenance is not provided to rebuild or replace existing capacity.  However,
capacity retirement over this period was estimated at about ¥2% per year;  hence, capitalized
                                          F-35

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maintenance associated with the assumed requirements must be deducted from the estimated
capital requirement. Therefore, the remaining 2'/2% (roughly 1.7 million tons) must be replaced
each year if the industry is to remain at the assumed capacity.2

     Basing the replacement cost solely on the new mill cost models would overstate the capital
requirement. If we assume that the costs associated with new grassroots plants can be reduced by
some 25% by a mix of new machines at existing sites and other improvements, the replacement
rate is further reduced from 2'/2% to  2% of the cost of a new mill. This is not a reduction in
replacement tonnage; it is simply a reduction in capital requirements.

     Hence, for estimating the  annual capitalized maintenance associated with replacing 21 •>'"<
of the industry capacity, ADL used  2% of the  capital costs of the corresponding  new  mill
model(s). The  resultant  estimate corresponds to about $900 million, or  about  $13 per ton of
industry process capacity. Note that these estimates are predominantly for maintaining produc-
tive equipment, but do  include a proportional share (based on the new mill cost model) of
capitalized maintenance on air and water control equipment.

b.  Capital  Investment for  Additional Capacity
     The industry  does  not build  all its additional  capacity in the form  of new grassroots
facilities; much capacity is added by incremental expansion of existing equipment or the installa-
tion of new machines at existing sites. Accordingly, to estimate the industry's capital require-
ments for additional capacity, it is necessary to postulate: (a) how much additional capacity will
be obtained by each method  and (b) the capital requirement associated with each of the methods
used. These two considerations  are further discussed below.

     (1)   Relative Importance of Methods for Adding Capacity
     In  1968, a year of rapid capacity expansion typical of the 1965-1970 period, new capacity
amounted to some 2.8 million tons per year, with

     —  49% new grassroots facilities,
     —  22% new machines at  existing sites, and
     —  28% other incremental expansion.

     More recently, API has projected an average expansion rate  of 1.5  million tons per year
through the period of 1976 to 1978. This increase will be achieved as follows:

     —   7% new grassroots facilities,
     —  45% new machines at  existing sites, and
     —  48% other incremental expansion.

     The rate of new grassroots construction in 1976 to 1978 is low because of rapid escalation in
capital requirements and restricted availability of new mill sites. Conversely, the rate  in 1968
reflected a period of rapid expansion in the South to utilize the wood resources and mill sites that
were readily  available then. Because of the lower unit cost for incremental expansion of an
existing machine, it is the route preferred by industry. However, ADL does not believe that the
industry can indefinitely maintain the high (48%) level achieved in the 1976-1978 period.
2. The net industry capacity (after Vi% per year retirement) was estimated at 61.8 million tons for 1977 and 60.0 million
  tons for 1983; see Tables 111-1 and -2.


                                           F-36

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     The extent to which the output of existing machines can be increased is finite and subject to
emerging technology. ADL believes that the level experienced in 1968 is more representative of
long-range opportunities for incremental expansion of existing machines.

     Accordingly, for purposes of estimating industry capital requirements (Chapter VI), ADL
believes the following expansion schedule is reasonable:

     1976-1979:  —  10% new grassroots facilities,
                —  40% new machines at existing sites, and
                —  50% other incremental expansions.

     After 1979:  —  25% new grassroots facilities,
                 —  50% new machines at existing sites, and
                 —  25% other incremental expansions.

     The expectation that half of all additional capacity  will be obtained by the installation of
new machines at existing plant sites is consistent with present plans and also with projections of
continuously improving wood yields from existing commercial forests through improved manage-
ment, growing, and harvesting techniques.

     (2)   Unit Cost for Additional Capacity
     The new mill models provide a  convenient point for estimating the costs of the previously
listed methods of expansion. New grassroots construction clearly is the most expensive of the
three methods. It is not unreasonable to postulate that a 15-20% saving would be achieved by
adding a new machine at  an existing site and  utilizing existing common facilities such as
administration buildings, laboratory  facilities, machine shop, stores, and shipping and receiving
areas.

     Similarly, compared with the cost of new grassroots  facilities, incremental expansion of an
existing machine would require perhaps 30-40% as much capital. Obviously, these estimates are
imprecise and vary widely among individual mills. Nevertheless, for overall "Industry averages,"
ADL believes the following are reasonable comparisons of capital cost for adding new capacity via
the alternative techniques:

       % of New Grassroots Capital Cost             Method
                         100                   New grassroots facility
                          85                   New machine at existing site
                          35                   Other incremental expansion

Based upon the percentage mix of the alternatives previously  identified for 1976-1979,  the
weighted average cost for replacement or additional industry capacity is about $450 per annual
ton. The average cost for new capacity increases after 1977, since ADL believes the number of
opportunities to increase capacity via the more economical incremental expansion at existing
sites will decline in relation to  the more costly new grassroots facilities and new machines.

     If the capital costs for new grassroots facilities were used alone, the figure would be $650 per
annual ton. Applying these capital cost estimates to the existing industry's 68.97 million  tons of
capacity results in a replacement cost of $30 billion and $45 billion, respectively.


                                          F-37

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     These estimates are presented only for purposes of information and for documentation of the
approximate capitalized maintenance  costs stated in Subsection 4.a. The detailed capital re-
quirements used in the impact analysis are estimated on the basis of separate calculations and
projections for each product sector derived above and thus may differ slightly from the overall
industry averages.
                                          F-38

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       APPENDIX G

FIELD INTERVIEW GUIDE FOR
 MILL CLOSURE ANALYSIS

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                                    APPENDIX G

           FIELD INTERVIEW GUIDE FOR MILL CLOSURE ANALYSIS


                                                                                Date:_

 I.  Description of Contact1

      —  name and title of person contacted:
      —  company:
      —  location of subject mill and process/product category:

II.  Identification

      —  of interviewer —  of Arthur D. Little, Inc.

III.  Purpose of Call

     We are currently doing a study for the EPA on the economic impact of Federal pollution
     regulations on the pulp and paper industry. In this study, we must screen those mills where
     we have questions on their ability to meet EPA water effluent control guidelines stipulated
     for 1977 and 1983.  I am calling you to obtain your insight and judgment concerning the
     future viability of your        mill(s). [identify]
     The information  that you contribute to our study will be combined with other inputs in
     statistical summaries. It will not be identified specifically with your mill or company.

IV.  Current Status of Mill

      —  daily capacity: Pulp	; Products	•__
      —  pollution control
      —  equipment in-place:
      —  age of mill:
      —  number of employees: Production	; Administrative:	
      —  how well has mill been maintained?
      —  are there any exceptional economic conditions facing the mill?
      —  operating cost advantages/disadvantages:
          • raw material supply arrangements
          • energy costs
          • production efficiencies
          • other
 1. .Contacts should be as highly placed as possible. Ideally, the president of small (one-mill) companies and the
    corporate officer of large (multi-mill) companies should be contacted.
                                           G-l

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  V. Pollution Control Cost Situation3

     —  Does existing water pollution control equipment comply with 1977 EPA stand-
         ards;  1983 EPA standards?
     —  If the  answer above is negative, what is required to achieve full compliance?
     —  How much will it cost?
     —  Where will the required capital come from; at what anticipated interest rate?
     —  What  financial impact do you expect on:
         —  mill operating costs
         —  mill profitability
     —  Have  you tried to justify this  pollution  control expenditure  on a return-on-
         investment basis?
     —  Is there any possibility of municipal treatment tie-in? At what cost?

VI. State/Local Pollution Control Requirements

     —  Beyond  EPA  requirements, what state/local air and water pollution control re-
         quirements exist?
             *
     —  What  additional economic  impact  will state/local requirements have on your
         operations?

VII. Future Plans

     —  What  plans do you have to invest further in:
          •  pollution  control equipment
          •  expansion
          •  mill maintenance
     —  Are there any  plans to shift product  mix?
     —  Will executing these plans achieve full compliance with EPA standards?
     —  Are there any  plans to curtail operations?                               .
          •  partial
          •  complete  closure
          •  if complete closure is foreseeable, what is your estimate of mill salvage value?

VIII.  For Multi-Mill Companies Only

     —  Are there plans to shift  capacity and/or personnel from this mill to other mills in
         the company?

     —  Are there other mills in your company (beyond those that we have discussed) that
         you think may have difficulty complying with EPA pollution control standards?
2. Interviewer should have • copy of EPA effluent standards by process sector, since It may be necessary to compare
  current and stipulated effluent loadings.
                                           G-2

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        APPENDIX H

SUPPORTING DATA FOR CAPITAL
      IMPACT ANALYSIS

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                                    APPENDIX H
            SUPPORTING DATA FOR CAPITAL IMPACT ANALYSIS
1. FLOW OF FUNDS MODEL
a. Model Equations
     The basic equation underlying the analysis of capital requirements is the valuation model
                                   N    CFt       (Final Equity - UCAN)
                      Initial Equity = 2 	 +	              (1)
                                  t=l  0+0*            0+r)N
where
       r      =  required rate of rate of return on equity
       CFt    =  cash flow to equity in period t
       N     =  number of periods in analysis (=8)
       UCAN  =  Uncommitted cash assets (i.e., accumulated cash in excess of operating
                 requirements not yet distributed to stockholders) held at end of period N.
     The cash flow to equity in each period is defined as
                 CFt = PtQ, - COEt + Dt - DAt - AWCt - INVt -  INTt - TAXt                 (2)
where
        Pt        =  product price in period t
        Qt        =  product sales volume in physical units in period t
        COEt     =  cash operating expense in period t (exclusive of interest and taxes)
        Dt        =  new debt raised in period t
        DAt      =  debt amortized in period t
        AWCt     =  net increase in working capital in period t = WCt - WCt.,
        WCt      =  OCBt + INVENTt + RECt - PAYt
        OCBt     =  operating cash balance held in period t
        INVENTt  =  inventories held in period t
        RECt     =  accounts receivable held in period t
        PAYt     =  accounts payable accrued through period t
        INVt     =  capital  investment in period t
                                           H-l

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       INTt      = interest paid in period t
       TAXt     = Federal income tax payable in period t
                 = TPt., +TIt-TPt
       TPt       = Federal income tax payable at end of period t
                 = aTIt
       TIt       = Federal income tax incurred in period t
                 = T (PtQt = COEt - DEPt - INTt - TXCFt) - TXCRt
       T         = Federal income tax rate = 48%
       DEPt     = depreciation deduction for tax purposes taken in period t
       TXCFt    = tax loss carryforward utilized in period t
                 = investment tax credit utilized in period t
     The model treats Pt as control variable and sets the value of Pt to satisfy equation (1).
Further, flow of funds balance implies that
                                CFt = DIVt + AUCAt - Et                                (3)
where
        DIVt      =  dividends paid in period t
        AUCAt    =  increase in uncommitted cash assets in period t
        Et        =  new equity raised in period t
     Consequently, the model also calculates external financing, through the equation
         EFt =  Dt  + Et
              ='  AWCt + INVt + DAt + DIVt - (PtQt - COEt - INTt - TAXt) - (-AUCAt)        (4)
that is, as the difference  between required outlays of funds and  the  funds available from
operations or from the liquidation of uncommitted cash assets.
b.  Parameters and Assumptions
(1) Parameter Values Based on Financial Analysis
     The first step in estimating the paramaters of the equations described above was a financial
analysis of the 32 companies listed in Table  H-l. As was described in Chapter VI, the historic
statements were adjusted to eliminate woodlands and converting operations and other businesses
extraneous to primary pulp  and paper manufacturing, and then were normalized to total primary
pulp and paper sales  volume. Tables H-2, H-3, and H-4 present the resulting estimated balance
sheets, operating statements, and sources of funds for the U.S. primary pulp and paper industry
for the period 1966-1975.
                                           H-2

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                                TABLE H-l

                  COMPANIES INCLUDED IN INDUSTRY COMPOSITE
Bergstrom Paper Company
Brown Company
Chesapeake Company
Clevepak Corporation
Consolidated Papers
Crown Zellerbach
Federal Paperboard Company
Fibreboard Corporation
Fort Howard Paper Company
Glatfelter Company
Great Northern Nekoosa Corporation
Hammermill Paper Company
Hudson Pulp and Paper Corporation
Inland Container Corporation
International Paper Company
Kimberly-Clark Corporation
Longview Fibre Company
Mead Corporation
Mosinee Paper Corporation
OlinKraft
Pentair Industries
Potlatch Corporation
St. Regis Paper Company
Scott Paper Company
Sonoco Products Company
Sorg Paper Company
Southland Paper Mills
Stone Container Corporation
Union Camp Corporation
Westvaco Corporation
Whippany Paper Board Company
                                  H-3

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                                                         TABLE H-2
s
.U
                           PRO-FORMA BALANCE SHEET  OF THE U.S. PULP, PAPER, AND  PAPERBOARD  INDUSTRY
                                       (EXCLUDING WOODLANDS AND  CONVERTING OPERATIONS)
                                                   FOR  THE PERIOD 1966-1975
                                                 (Millions of Current  Dollars)
    ASSETS
Cash
Receivables
Inventories
  Total Current Assets
Gross Plant
Accumulated Depreciation
  Net Plant
Other Assets
  Total Fixed Assets
      Total Assets

LIABILITIES AND EQUITIES
Accounts Payable
Miscellaneous Accruals
Short-Term Debt
Current Portion of Long-
  Term Debt
   Total Current Liabilities
Long-term Debt
Deferred Taxes
   Total Liabilities
Equity
   Total Liabilities
     and Equities
1975
1,153
1,795
2,251
5,199
18,701
(8,500)
10,151
1,457
11,608
16,807
996
832
174
168
2,402
5,021
1,013
8,436
8,371
1974
1,422
1,878
2,438
5,738
17,593
(8,518)
9,075
1,640
10,715
16,453
737
775
238
102
2,448
4,636
971
8,055
8,398
1973
1,
1,
1,
4,
15,
(7,
7,
1,
9,
13,




1,
4,

6,
7,
347
672
799
818
495
871)
624
534
158
976
657
571
61
80
766
103
822
691
285
1972
807
1,593
1,655
4,055
14,888
(7,518)
7,370
1,317
8,687
12,742
578
472
75
84
1,352
3,840
710
5,902
6,840
1971
411
1,451
1,779
3,641
14,487
(7,136)
7,351
1,380
8,731
12,373
526
425
132
88
1,260
3,738
656
5,654
6,719
1970
434
1,517
1,820
3,771
14,573
(7,021)
7,552
1,426
8,978
12,749
541
439
282
134
1,481
3,650
639
5,770
6,979
1969
488
1,493
1,662
3,643
13,801
(6,587)
7,214
1,307
8,521
12,164
507
440
401
106
1,566
3,103
605
5,274
6,890
IS

•68
525
1,284
1,535
3,344
13,523
(6,
7,
344)
179
1,240'
8,
11,




1,
3,

4,
6,
419
763
NA
NA
NA
NA
266
230
494
990
773
1967
423
1,093
1,409
2,925
12,325
(5,754)
6,571
948
7,519
10,444
NA
NA
NA
NA
1.0C4
2,738
444
4,186
6,358
1966
480
1,030
1,343
2,853
11,142
(5,372)
5,770
791
6,561
9,414
NA
NA
NA
NA
905
2,046
361
3,312
6,102
                                 16,807
16,453  13,976  12,742  12,373  12,749  12,164  11,763  10,444   9,414

-------
                                                TABLE H-3

                PRO-FOKMA OPERATING STATEMENT OF THE U.S. PULP, PAPER AND PAPERBOARD INDUSTRY
                             (EXCLUDING WOODLANDS AND CONVERTING OPERATIONS)
                                         FOR THE PERIOD 1966-1975
                                       (Millions of Current Dollars)


                       1975    1974    1973    1972    1971    1970    1969    1968    1967    1966
Sales

Cost of Goods
Sold

General, Selling
and Administrative
Expense

Depreciation

  Pre-Tax Operating
  Income
15,633  17,564  13,684  11,701  10,685  10,427  10,335   9,523   8,844   8,712


11,234  12,516   9,847   8,652   7,973   7,424   7,424   6,840   6,206   6,020



 1,747   1,818   1,617   1,470   1,404   1,361   1,264   1,137   1,038     979

   899     842     745     707     696     675     640     615     570     533
 1,753   2,368   1,475     872     612     744   1,007     931  ..1,030   1,180

-------
                                                       TABLE H-4
ffi
ON
                      PRO-FORMA SOURCES OF FUNDS OF THE U.S.  PULP,  PAPER AND PAPERBOARD INDUSTRY
                                    (EXCLUDING WOODLANDS AND  CONVERTING OPERATIONS)
                                                FOR THE PERIOD 1966-1975
                                              (Millions of  Current  Dollars)
      Internal Operations

      Long-term Debt Issued

      Equity Securities
      Issued

         Total External
         Financing
                               1975    1974    1973    1972     1971     1970    1969    1968    1967
   69
32
                        107
42
34
         57
                         25
                                         22
994
          863
619
453
486
741
       220
                       622
                                               613
                                                                        1966
1,889   2,199   1,611   1,196   1,012   1,084   1,213   1,148   1,083   1,125

  925     829     587     346     444     707     163     597     591     514
                                                         71
585
      Total Funds Generated    2,883   3,062   2,230   1,649   1,498   1,825   1,433   1,770   1,696   1,710

-------
     The historic analysis was used to estimate:

         Initial balance sheet structure,
         Manufacturing costs of the existing industry,
         Behavior of GS&A expenses,
         Behavior of the working capital accounts, and
         Dividend and tax payment policy.

     (a) Initial Balance Sheet Structure
     The initial values of the accounts are set forth in the 1975 column of Table H-2. In addition,
the analysis indicated that the depreciation charges on existing net plant were well approx-
imated on  a 10-year  straight-line basis for book purposes,  and  on an  8-year straight-line
basis for tax purposes. The embedded cost of existing debt averaged  7%. ADL used a debt
amortization schedule for the period 1976 to 1980 corresponding to the 32-company compos-
ite, and used  a level amortization rate for  the period 1981 to  1983  corresponding to  the
average rate between 1976 and 1980 of 7% per annum of non-current long-term debt existing
at the end of 1975.

     (b) Manufacturing Cost of Existing Industry
     As was mentioned in the text, changes in real operating costs rendered the use of regression
methods to  split the  fixed and  variable components of existing  plant  manufacturing costs
inappropriate.  Hence, ADL performed the following  algebraic analysis to determine  cost
parameters,  based  only on 1975  manufacturing  cost (i.e., cost of  goods sold, in the 1975
column of Table H-3):

     Let the underlying cost equation of the existing industry be

                                C/0/G/S7S =fxC75 +vxP7S

where

       C/0/G/S7S =  cost of goods sold during 1975
       f         =  unit fixed cost per ton of installed capacity

       C7S       =  capacity in place at end of 1975
       v        =  unit variable cost per ton of product produced

       P7s       =  tonnage produced during 1975

Define

       K         = unit total cost of goods sold in 1975

                     C/6/G/S75        f
                       P75         OR75
where

                     P7S
       OR75     = 	 = operating rate in 1975

                                           H-7

-------
Let
                  =  operating leverage factor
                    fixed component of C/O/G/S at full production
                          total C/O/G/S at full production
                     f + v

     Now assume $ is the same for the existing industry as for an average of new mill models
weighted by 1975 production in  each sector.1 Then the  unit fixed and variable manufacturing
costs can be computed as
                                              K
                                         1 ~
                                      fl-0)OR7S

and
                                                 + 1
                                   v = •
                                                  + 1
                                      (1 -cY)OR7S

     (c) Behavior of General, Selling, and Administrative Expenses
     General, Selling, and Administrative Expenses tend to track generally with the average
level of sales volumes, but cannot be adjusted rapidly to sales volume fluctuations, and so they
each have a significant fixed component. Therefore, ADL estimated these expenses using a
simple regression equation based on current dollar values. The equation used was

          GS&A = 310 * 0.0917 x Sales (S million current)
                         (t  = 8.86)
          R2 = 91 '•;.
          F  = 78.5
          D.W. = 0.75

and while the residual serial correlation is significant, the fit is adequate for present purposes.

     (d) Behavior of Working Capital Accounts
     The definition of working capital used in this analysis excludes the component of short-term
financing corresponding to miscellaneous accruals. This definition is conservative in that it may
slightly overstate the permanent financing needs of the industry. ADL used a narrow definition,
because the miscellaneous accrual account has behaved peculiarly over time and thus could not
be forecasted reliably.
1. The fixed component of cost in the new mill models presented in Appendix F was identified as:
      15% of fiber cost                          100% of capital related charges
      50% of labor                              25% of water effluent and air emission
      50% of energy                                control operating expenses
     100% of factory overhead                      75% of OSHA noise control expenses

                                          H-8

-------
     Figure H-l presents the historic behavior of the working capital accounts. The current asset
accounts are cyclical, and so were estimated at their dollar-weighted average levels of:

     •  Operating cash balance =  27 days cash operating  cost (excluding interest and
        taxes),
     •  Receivables = 46 days sales, and
     •  Inventories = 55 days sales.

     Accounts payable exhibited a sudden jump in 1975, after a long period of stability. ADL has
assumed that this shift represents a shift in the terms of trade credit, and has forecasted accounts
payable using the 1975 value of:

     •  Accounts payable = 28 days cash operating cost.

This assumption has no material impact on any results presented.

     (e) Dividend and Tax Payout Policy
     Because dividend payout and  tax payment scheduling are determined at the corporate
level, ADL based its assumptions on the behavior of the unadjusted 32-company composite. For
the composite, dividend payout  averaged 40% of after-tax income over the historic period, and
taxes payable averaged 40% of taxes incurred; therefore, these values were used throughout the
analysis.

(2) Parameter Values Based on Demand Forecasts
     The only parameter directly dependent on the demand forecast is quantity produced. The
first step in  the  production forecast is an initial econometric forecast of U.S. pulp, paper and
paperboard  demand  (excluding dissolving pulp)  based on the aggregate model equation  (1)
presented in Appendix  G,  assuming 1975 prices and an overall level of macroeconomic activity
corresponding to one of the Chase Econometric scenarios. Table  H-5 presents the three initial
demand forecasts used in the study. Demand is then converted to  production through the
equation

                          Production = (0.93 x Demand) + 1367

which represents an  assumed net import level of 7% of consumption and  a constant rate  of
production of dissolving pulp.

     The demand and production forecasts are then iteratively adjusted to reflect the impact of
forecast price changes as described in the text.

(3) Parameters  Values Based on Capacity Forecasts
     The model  parameters directly dependent on capacity forecasts are: the levels of capital
investment for incremental expansion, replacement and  major maintenance, and the weights
used to determine average manufacturing costs.  The basic unit capital and operating cost
parameters  have been discussed  above  in this Appendix and in Appendix F.  Therefore,  it
remains only to present the actual capacity forecasts and the adjustment factors used to account
for the three possible modes (i.e., grassroots, new machines, and improvements) of introducing
incremental  and  replacement capacity.

                                         H-9

-------
Days of Cash
Cost
Days of Sales
Days of Sales
Days of Cash
Cost
                                         COMPONENTS OF WORKING CAPITAL
                       66    67
75
                                               H-10

-------
                                                 TABLE  H-5

                     FORECAST  U.S.  DEMAND  FOR PULP AND  PAPER  (EXCLUDING DISSOLVING PULP)
                     UNDER ALTERNATIVE GROWTH RATE ASSUMPTIONS ASSUMING 1975 REAL PRICES
                        LOW GROWTH
MIDRANGE GROWTH
HIGH GROWTH-


Year

1976
1977
1978
1979
1980
1981
1982
1983
Average Growth
1976-1983
1974-1983
Index of
Industrial
Production

125.5
136.8
134.1
131.1
139.6
153.7
164.5
173.4
(%/Year)
4.7
3.9
Pulp and
Paper
Demand
(000 Tons)
59,500
63,908
62,854
61,685
65,000
70,501
74,715
78,187

3.8
1.9
Index of
Industrial
Production

125.5
136.8
135.6
132.5
139.6
153.7
164.5
173.4

4.7
3.9
Pulp and
Paper
Demand
(000 Tons)
59,500
63,908
63,440
62,230
65,000
70,501
74,715
78,189

3.8
1.9
Index of
Industrial
Production

125.5
136.8
140.0
144.0
153.7
164.5
173.4
180.7

5.3
4.5
Pulp and
Paper
Demand
(000 Tons)
59,500
63,908
65,157
66,717
70,501
74,715
78,187
81,035

4.5
2.3
 Chase Econometrics CEQ Forecast


2Chase Econometrics Forecast, assuming increased Federal spending to mitigate recession in 1978-1979

o
 Chase Econometrics Forecast, assuming no recession in 1978-1979

-------
     (a) Capacity Levels
     Tables H-6A through H-6C present the assumed year-end capacities for each of the major
product sectors for each of the three capacity growth rate scenarios considered, which correspond
to the growth-rate ranges presented in Table IV-17. Tables H-7A and H-7B present the assumed
year-end values (for each of the product sectors) of capacity which was included in the industry as
of the end of 1975 — that is still in place. Table H-7A presents these values assuming no water
effluent control standards are  in effect, so that only normal retirements occur. Note that Ta-
bles H-6 and H-7 incorporate  some additional detail on product sector growth and retirement
rates over  that presented in the main  text. The tables also include a sector labeled "Mis-
cellaneous Products," which has been introduced as  a balance item,  and is treated as behaving
like a weighted average of all other sectors excluding dissolving pulp.

     (b) Adjustments for Alternative Sources of New Capacity
     Table H-8 presents distributions of new capacity (incremental plus replacement) installed
in the "grassroots," new-machine, and on-site improvement modes used in the analysis,  and the
relative capital costs compared to the new mill models used for each mode. Relative capital costs
were determined by engineering estimation; the model distributions were based on the following
considerations:

     In 1968, a year of rapid capacity expansion typical of the period, new capacity amounted to
some 2.8 million tons per year,  with:

                   49% new grassroots,
                   22% other new machines, and
                   28% other improvements.

For the period 1976 to 1978, the API has announced an average expansion rate of 1.5 million tons
per year, with:

                     7% new grassroots,
                   45% other new machines, and
                   48% other improvements.

     The high rate of "other improvements" from 1976 to 1978 is probably typical of what the
industry prefers, but it is doubtful whether this can be sustained indefinitely. The opportunities
for  improvement of existing machines  are finite and subject  to emerging technology. ADL
believes that the 28% level of 1968 is more representative of long-range opportunities for machine
improvement,  and  therefore has projected  25% of expansion beyond  1979 to  be  through
improvements.

     The low  rate of new  grassroots  expansion  from 1976 to 1978  is indicative of the  rapid
escalation in capital requirements and the restricted availability of new mill sites. Conversely,
the rate in 1968 represented a period of rapid expansion in the South to utilize then readily
available wood resources and mill sites. ADL  believes that an intermediate level for new grass-
roots capacity, estimated at 25% of total expansion, is consistent with industry requirements and
capabilities in the long run.
                                         H-12

-------
                                                      TABLE H-6A
Unbleached Kraft
Linerboard
Unbleached Kraft
Bag Paper
NSSC Corrugating
Medium
Recycled Boxboard
Jute Linerboard
Bogus Medium
Gypsum Linerboard
SBS Board
Bond Paper
Book Paper
Tissue
De-inked Tissue
Newsprint
Recycled Newsprint
Dissolving Pulp
Miscellaneous
Products
       TOTAL
                                  FORECAST CAPACITY OF THE U.S.  PULP AND PAPER INDUSTRY
                              FOR THE PERIOD 1976-1985 ASSUMING HIGH CAPACITY GROWTH RATE
                                                     (thousand tons)
                            1976     1_977_    1978^    1979     1980     1981    1982     1983    1984
                                                                         1985
L6,320
4, SAO
4,760
2,500
979
3,215
2,656
5,280
4,581
7,869
4,140
420
3,619
381
1,820
5,790
16,870
4,540
4,910
2,500
987
3,243
2,679
5,360
4,680
8,040
4,231
429
3,691
389
1,820
5,760
17,330
4,550
4,945
2,500
994
3,267
2,699
5,560
4,812
8,268
4,267
433
3,737
393
1,820
5,785
18,210
4,630
5,300
2,500
1,024
3,366
2,780
5,760
5,053
8,681
4,358
442
3,827
403
1,820
6,093
19,140
4,720
5,670
2,500
1,054
3,464
2,862
5,960
5,308
9,119
4,449
451
3,927
413
1,820
6,415
20,120
4,800
6,080
2,500
1,086
3,567
2,947
6,160
5,571
9,571
4,539
461
4,026
424
1,820
6,751
21,150
4,890
6,500
2,500
1,117
3,671
3,032
6,380
5,850
10,049
4,639
471
4,126
434
1,820
7,104
22,220
4,970
6,970
2,500
1,150
3,779
3,121
6,600
6,142
10,552
4,730
480
4,227
445
1,820
7,471
23,360
5,060
7,460
2,500
1,183
3,887
3,211
6,830
6,449
11,079
4,830
490
4,334
456
1,820
7,857
24,550
5,160
7,990
2,500
1,217
3,999
3,304
7,074
6,772
11,633
4,939
501
4,551
479
1,820
8,280
68,870  70,130  71,360  74,247  77,272  80,423  83,733  87,177  90,805  94,769

-------
                                                 TABLE H-6B
Unbleached Kraft
Linerboard
Unbleached Kraft
Bag Paper
NSSC Corrugating
Medium
Recycled Boxboard
Jute Linerboard
Bogus Medium
Gypsum Linerboard
SBS Board
Bond Paper
Book Paper
Tissue
De-inked Tissue
Newsprint
Recycled Newsprint
Dissolving Pulp
Miscellaneous
Products
       TOTAL
                            FORECAST CAPACITY OF THE U.S. PULP AND PAPER INDUSTRY
                      FOR THE PERIOD 1976-1985 ASSUMING MIDRANGE CAPACITY GROWTH RATE
                                              (thousand tons)
                           1976    1977    1978    1979    1980    1981    1982    1983    1984    1985
16,320
4,540
4,760
2,500
979
3,215
2,656
5,280
4,581
7,869
4,140
420
3,619
381
1,820
5,790
16,870
4,1-40
4,910
2,500
987
3,243
2,679
5,360
4,680
8,040
4,231
429
3,691
389
1,820
5,760
17,330
4,550
4,945
2,500
994
3,267
2,699
5,560
4,812
8,268
4,267
433
3,737
393
1,820
5,785
18,023
4,610
5,240
2,500
1,017
3,342
2,761
5,730
5,005
8,598
4,340
440
3,809
401
1,820
6,031
18,744
4,680
5,550
2,500
1,040
3,417
2,823
5,900
5,209
8,948
4,403
447
3,890
410
1,820
6,287
19,490
4,740
5,873
2,500
1,064
3,497
2,889
6,080
5,413
9,300
4,476
454
3,963
417
1,820
6,549
20,274
4,810
6,219
2,500
1,089
3,577
2,955
6,260
5,630
9,671
4,549
461
4,044
426
1,820
6,824
21,080
4,880
6,590
2,500
1,113
3,657
3,021
6,450
5,855
10,058
4,621
469
4,126
434
1,820
7,109
21,930
4,950
6,974
2,500
1,139
3,741
3,090
6,640
6,089
10,461
4,694
476
4,207
443
1,820
7,405
22,805
5,020
7,386
2,500
1,163
3,821
3,156
6,840
6,333
10,879
4,766
484
4,289
451
1,820
7,710
68,870  70,130  71,360  73,667  76,068  78,525  81,108  83,782  86,559   89,423

-------
                                                  TABLE H-6C
Unbleached Kraft
Linerboard
Unbleached Kraft
Bag Paper
NSSC Corrugating
Medium
Recycled Boxboard
Jute Linerboard
Bogus Medium
Gypsum Linerboard
SBS Board
Bond Paper
Book Paper
Tissue
De-inked Tissue
Newsprint
Recycled Newsprint
Dissolving Pulp
Mis cellaneous
Products
        TOTAL
                            FORECAST CAPACITY OF THE U.S. PULP AND PAPER INDUSTRY
                        FOR THE PERIOD 1976-1985 ASSUMING LOW CAPACITY GROWTH  RATE
                                                (thousand tons)
                           1976    1977    1978    1979    1980    1981    1982    1983    1984    1985
16,320
4,540
4,760
2,500
979
3,215
2,656
5,280
4,581
7,869
4,140
420
3,619
381
1,820
5,790
16,870
4,540
4,910
2,500
987
3,243
2,679
5,360
4,680
8,040
4,231
429
3,691
389
1,820
5,760
17,330
4,550
4,945
2,500
994
3,267
2,699
5,560
4,812
8,268
4,267
433
3,737
393
1,820
5,785
17,830
4,600
5,120
2,500
1,100
3,319
2,741
5,670
4,957
8,515
4,331
439
3,791
399
1,820
5,960
18,350
4,640
5,300
2,500
1,027
3,375
2,788
5,780
5,106
8,771
4,394
446
3,845
405
1,820
6,140
18,880
4,690
5,480
2,500
1,043
3,427
2,831
5,900
5,259
9,034
4,458
452
3,909
411
1,820
6,324
19,430
4,730
5,670
2,500
1,060
3,483
2,877
6,018
5,417
9,306
4,539
461
3,963
417
1,820
6,515
19,990
4,780
5,870
2,500
1,077
3,539
2,924
6,140
5,579
9,584
4,594
466
4,026
424
1,820
6,708
20,570
4,830
6,080
2,500
1,094
3,596
2,970
6,260
5,746
9,872
4,667
473
4,090
430
1,820
6,909
21,170
4,880
6,290
2,500
1,111
3,652
3,017
6,390
5,919
10,168
4,739
481
4,144
436
1,820
J7,H4
68,870  70,130  71,360  73,002  74,687  76,417  78,206  80,021  81,907  83,831

-------
                                                         TABLE H-7A
ac
• i
o\
Unbleached Kraft
Linerboard
Unbleached Kraft
Bag Paper
NSSC Corrugating
Medium
Recycled Boxboard
Jute Linerboard
Bogus Medium
Gypsum Linerboard
SBS Board
Bond Paper
Book Paper
Tissue
De-inked Tissue
Newsprint
Recycled Newsprint
Dissolving Pulp
Miscellaneous
Products
     TOTAL
                              1975 CAPACITY OF THE U.S. PULP AND PAPER  INDUSTRY  STILL  IN  PLACE
                                          AT END OF YEAR FOR THF. PERIOD  1976-1985
                               ASSUMING WATER POLLUTION CONTROL INDUCED CLOSURES DO NOT OCCUR
                                                        (thousand tons)
                             1975
                               1976
1977
1978
1979
1980
1981
1982
1983
                                                                                                     1984
1985
14,824
4,510
4,568
2,500
941
3,090
2,553
5,120
4,442
7,630
4,048
411
3,549
374
1,821
5,780
14,824
4,510
4,535
2,453
935
3,072
2,538
5,120
4,433
7,617
4,048
411
3,520
370
1,821
5,749
14,824
4,510
4,535
2,453
935
3,072
2,538
5,120
4,433
7,617
4,048
411
3,520
370
1,821
5,749
14,824
4,510
4,505
2,430
932
3,063
2,530
5,120
4,425
7,603
4,047
411
3,487
367
1,776
5,719
14,824
4,510
4,475
2,407
930
3,054
2,523
5,120
4,417
7,589
4,046
410
3,453
364
1,735
5,676
14,824
4,510
4,445
2,384
927
3,045
2,516
5,120
4,409
7,575
4,046
410
3,422
360
1,727
5,648
14,824
4,510
4,415
2,361
924
3,036
2,508
5,120
4,401
7,561
4,045
410
3,389
357
1,719
5,620
14
4
4
2

3
2
5
4
7
4

3

1
5
,824
,510
,385
,339
921
,028
,501
,120
,393
,547
,044
410
,358
353
,711
,594
14,824
4,510
4,385
2,339
921
3,028
2,501
5,120
4,393
7,547
4,044
410
3,358
353
1,711
5^594
14,824
4,510
4,356
2,295
916
3,010
2,497
5,120
4,386
7,534
4,043
410
3,327
350
1,703
5,574
14,824
4,510
4,327
2,252
911
2,993
2,483
5,120
4,379
7,521
4,042
410
3,296
347
1,693
5,554
                            66,161   65,955   65,955   65,749   65,534   65,368   65,201   65,038   65,038   64,845  64,661

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                                                  TABLE H-7B
Unbleached Kraft
Linerboard
Unbleached Kraft
Bag Paper
NSSC Corrugating
Medium
Recycled Boxboard
Jute Linerboard
Bogus Medium
Gypsum Linerboard
SBS Board
Bond Paper
Book Paper
Tissue
De-inked Tissue
Newsprint
Recycled Newsprint
Dissolving Pulp
Miscellaneous
Products
        TOTAL
                       1975 CAPACITY OF THE U.S. PULP AND PAPER INDUSTRY STILL IN PLACE
                                   AT END OF YEAR FOR THE PERIOD 1976-1985
                          ASSUMING WATER POLLUTION CONTROL INDUCED CLOSURES DO OCCUR
                                                (thousand tons)
                          1975    1976    1977    1978    1979    1980    1981    1982
                                                                 1983
1984
1985
14,824
4,510
4,568
2,500
941
3,090
2,553
5,120
4,442
7,630
4,048
411
3,549
374
1,821
5,780
14
4
4
2

3
2
5
4
7
4

3

1
5
,824
,510
,535
,453
935
,072
,538
,120
,433
,617
,048
411
,520
370
,821
,749
14,824
4,510
4,411
2,422
931
3,060
2,528
5,120
4,328
7,436
4,041
410
3,520
370
1,821
5,722
14,824
4,510
4,381
2,399
929
3,051
2,520
5,120
4,320
7,422
4,041
410
3,487
367
1,776
5,692
14,824
4,510
4,351
2,376
926
3,042
2,513
5,120
4,312
7,408
4,040
410
3,453
364
1,735
5,649
14,824
4,510
4,321
2,353
923
3,033
2,506
5,120
4,304
7,394
4,039
410
3,422
360
1,727
5,621
14,824
4,510
4,291
2,330
920
3,024
2,498
5,120
4,296
7,380
4,039
410
3,389
357
1,719
5,593
14,824
4,510
4,261
2,308
918
3,015
2,491
5,120
4,288
7,366
4,038
410
3,358
353
1,711
5,567
14,824
4,510
4,261
2,220
907
2,981
2,463
5,120
4,211
7,233
4,030
409
3,330
350
1,711
5,232
14,824
4,510
4,232
2,176
902
2,964
2,448
5,120
4,203
7,221
4,029
409
3,299
347
1,703
5,212
14,824
4,510
4,203
2,133
897
2,947
2,434
5,210
4,196
7,208
4,028
409
3,268
344
1,695
5,192
66,161  65,955  65,454  65,249  65,033  64,867  64,700  64,538  63,792  63,599  63,498

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                                         TABLE H-8

                    ASSUMED  DISTRIBUTIONS AND  COSTS  OF ALTERNATIVE
           SOURCES OF NEW CAPACITY IN  THE U.S. PULP AND  PAPER  INDUSTRY
                                         1976-1985
                     Percent  of Total Incremental
 Source of           and Replacement Capacity           Applicable Percent  of New
New Capacity       1976 - 1979       1980 - 1985        Mill Model Capital Cost


"Grassroots"             10                 25                         100


New Machines             40                 50                          85
On-Site
Improvements             50                 25                          35
       The remaining 50% of expansion through new machines at existing plant sites is consistent
   with present plans and also with projections of continuously improving wood yields from existing
   commercial forests  through  improved management, growling, and  harvesting  techniques.  In
   effect, the present expansion through new machines is typical of new grassroots expansion. While
   this may be desirable, it is not typical of historical  industry characteristics, and cannot  be
   sustained because of finite limits on the opportunities for expansion.

   (4) Depreciation and Tax Assumptions
       As has been mentioned above, existing industry depreciation was estimated on a straight-
   line basis, over ten years for book purposes and over eight years for tax purposes. Depreciation for
   incremental expansion, replacement, and major maintenance was calculated assuming a 16-year
   average depreciable life. Book charges were made on a straight-line basis; tax charges were made
   using a double-declining-balance basis, with a switch-over to straight-line in the first year in
   which the straight-line charges would exceed the double-declining-balance charge. In  addition,
   all equipment was assumed to be eligible for a 10% investment tax credit. The tax credit was
   applied as  a direct offset to income taxes, subject to the restriction that the credit not reduce
   taxable income  by more  than  50%. Unused  investment  credits were carried forward  for a
   maximum of five years.

       ADL did not use the alternative depreciation option for pollution control equipment of a
   five-year, straight-line write-off with no investment tax credit. The use of this option would have
   slightly decreased the effective tax rate and thus have slightly decreased the forecast external
   financing burden. A recent change in the Federal income tax code — which allows the option of
   using both a five-year, straight-line write-off and a 5% investment tax credit — would reduce the
   forecast external financing burden somewhat more.
                                          H-18

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(5)  Future Debt Cost Assumption
     The estimation of future interest rates on long-term debt is subject to many of the same
problems as is the estimation of future equity costs. Professor Pogue's analysis assumes that the
risk-free rate for the period 1976 to 1983 will average about 7.8%. It is difficult to determine the
premium over this rate that the debt market will demand from the industry, or what portion of
the rate is attributable to inflationary expectations. For this analysis, ADL assumed an interest
rate on new debt of 9.5%, which has been typical of new corporate issues over the last few years.
The results of the analysis are not very sensitive to this assumption.

2.  AGGREGATE EXTERNAL FINANCING  MODEL
     To forecast the total level of external financing in the  private sector of the U.S. economy
over the period 1976 to 1983, ADL developed a simple regression model based on annual data for
the period 1955 to  1985. The structural equation was  based on current dollars,  which is partic-
ularly appropriate for such an analysis; forecast current dollar results were then adjusted by the
GNP implicit price deflator to a 1975 dollar basis.

     The current-dollar estimating equation was

                 EXFIN = 4.58 + 0.836 GPDINR - .86 x  PROFIT - 2.57 x INT

                   (t= )   (2.2)  (11.5)         (6.1)           (3.9)

                 R2    = 96%
                 D.W.  =2.0
                 s.e.e.  =14%
where
        EXFIN


        GPDINR


        PROFIT

        INT
= Corporate Issues of long-term debt, preferred stock, and common
  stock in billions of current dollars

= Gross private domestic investment in non-residential structures
  in billions of current dollars

= Total corporate after-tax profits in billions of current dollars

= Interest rate on prime commercial paper.2
      The  quality of the fit  is very good: the  percentage  of variation explained is high;  all
 coefficients have the expected signs; all coefficients are significant;  and serial correlation of
 residuals is absent.
 2. The commercial paper rate was used as a proxy for the rate on long-term debt because no long-term debt interest-
   rate forecasts were available from Chase Econometrics. However, since the long-term and short-term rates tend to
   move together, ADL believes this technique is valid.
                                            H-19

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           APPENDIX I

SUPPORTING DATA FOR INTERNATIONAL
 COST DIFFERENCES FOR MAJOR PULP
       AND PAPER PRODUCTS

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                             TABLE 1-1

         ENVIRONMENTAL COSTS REPORTED IN 1972 OECD SURVEY
Basis:  December 1970 Dollars/Metric Ton and Exchange Rates,
        Reported 1970/Projected 1975 Costs.
Products and Cost Components

Sulfite Pulp

Water - Internal
      - External

Air

  TOTAL
United States
   2.96/14.14

    .51/3.87
Canada
                 0.48/5.17  I
Sweden
                               2.59/9.25
   3.47/18.01    0.62/11.22
0.54/4.84

0.08/1.21     0.28/0.51

              2.87/9.76
Kraft Pulp and Paper

Water - Internal
      - External

Air

  TOTAL
                    - /0.63
1.45/6.11
.76/5.69
2.21/11.80
0.02/2.83 j
0.01/1.56
0.03/5.02
.31/1.22
1.64/5.25
Newsprint

Water - Internal
      - External

Air

  TOTAL
- / -
0.91/3.75
- / -
0.05/1.38 1
0.28/1.15 j
0.18/1.02
f 3.61/4.78
0.01/0.08
   0.91/3.75
 0.51/3.55
 3.62/4.86
SOURCE:  "Pollution by the Pulp and Paper Industry," Organization for

         Economic Cooperation and Development, Paris, 1973.
                                 1-1

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                              TABLE 1-2

                   DERIVATION OF SWEDISH WOOD COSTS



                      Northern Sweden 1974/1975
                                         (August-July season)
              Average wood cost for pine and spruce.

              120 Sw. Cr./meter solid wood umber bark

       Conversion Units:
                                   3
                      .363 cunits/m

                      4.50 Sw Cr/$
Sw Cr/
      m
Sw Cr/m"
116
4.5
.363
                 Southern Sweden 1974/1975 Wood Cost



1
Spruce
106
117
<571 /„,,„-! *•
Pine
104 .
115
120 v
Birch
88
98
1
                                                   solid m
                                                (over bark)
                                                 (10% bark)
                                               (under bark)
4.5
.363
                                          $73/cunit
Sw Cr/m   x  5.15  =  Sw Cr/metric ton AD bleached sulfate

             5.15 m /AD Metric Ton pulp

            .363  x  5.15  x .907  -  1.81 cunits/AD short Ton pulp

                       3
            at 24 lb/ff
                     1800
          Bleached yield = 1'.81x2400 = 41%
SOURCE:  Arthur D.  Little, Inc., estimates.
                                    1-2

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                              TABLE 1-3

                  DERIVATION OF NEWSPRINT WOOD COSTS
U.S. Southeast
1974       $20/BD'ton @ 32 Ib/ft  »  $30.70/AD ton newsprint

                    =  62.5 ft3/BD ton

           $20  x  100  =  $32.00/cunit
                  62.5
1975       Escalate @ 12% =  $36/cunit wood cost

           Wood cost in newsprint  =

                     30.70 x 1.12  =  $34.38
U.S. North West and Canada

1975 Costs  -  $46/cunit  logs and chips

                2400 Ib (BD) cunit

            "^  $38.33/BD  ton

               $22/cunit  sawdust

               2400 Ib (BD)  cunit

            ~  $18.33/BD ton

Wood Balance - BDT to produce 1000 ADT newsprint

      Sawdust      77  x  18.33   =   1411.4
Chips (refiner) - 308  x  38.33   =  11805.6
Logs (stone)   -  385  x  38.33   =  14757
Logs (Kraft)   -  562.5 x 186.8 = 195x 38.33 =  7474
                           540
Chips (Kraft)   -  562.5 x 186.8 = 195x 38.33 =  7474
                           540
\ average cost/
      AD ton newsprint
         42.92
   SOURCE:  Arthur D. Little, Inc., estimates.
                                   1-3

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