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In order for Kraft pulp and paper mills in the United States to meet the Environmental Protection Agency’s (EPA) proposed Cluster Rule compliance implementation schedule, unprec-edented construction and engineering workforce levels must be achieved. This paper defines the costs and total work-hours associated with the individual projects required for compli-ance with the Cluster Rule. Results indicate that in addition to the financial impact on the pulp and paper industry (esti-mated as 13 billion dollars), an estimated 188 million con-struction work hours and 23 million engineering hours will be required to implement Cluster Rule compliance projects. This paper also analyzes the historical trends of the construction, engineering, and pulp staff engineering workforces, along with historical trends in vendor equipment procurement and tech-nical support resources in an effort to set realistic expectations for a Cluster Rule implementation schedule.
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