verse nature of repair and replacement activities typically undertaken at petroleum refineries.

Table D-3 lists repair and replacement and other activities specific to kraft mills that are periodically undertaken. Both the structure of Table D-3 and its contents were provided by representatives of International Paper, Inc., in response to an information request from the committee. Table D-3 lists approximately 90 repair and replacement activities that are periodically undertaken in a kraft mill. For each activity, the table provides an estimate of how frequently the activity occurs, an estimate of how likely the activity is to occur within the specified time interval, and the relative cost of the activity. The relative cost of the activity is presented as a percentage of the replacement cost of the major process component with which the activity is associated. For example, repairing or replacing the boiler safety relief valves (Table D-3) is estimated with near certainty to be an annual activity at a kraft mill, with an estimated cost that is less than 5% of the replacement cost of the entire boiler. Although the list of activities in Table D-3 is not certified as exhaustive, it serves to illustrate a variety of repair and replacement activities that may be undertaken in pulp and paper manufacturing facilities.

The repair and replacement activities presented here are expected to have different frequencies and costs across various industrial sectors, production facilities, and types of process units because many factors, such as equipment design and operating conditions, affect the frequency and cost of those activities (R. Bessette, Council of Industrial Boiler Owners, November 10, 2004, letter to committee).

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