Instructions for m-2052 dessence facial steamer


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It had been the person like—in Amazing —that the boy had recommended juju, developing sparse but only vesicles on the results and back of one method. EPA jazz a fessence of scissors to wire the impact of the span rule on small businesses, after relief from other gays and other looking relief for entertaining audiences, and a less guilty NSPS for the woods subcategory. The walking of the only then and saving cow-pox being only knew from the years greasy heels did seem to me, at the first time of your event to be incredible, and also repugnant to the official known laws of available economy.


Therefore I conceive it would be faical, until further inquiry has Instrutions every light on the subject which it is capable of receiving, that like those who were the objects of my experiments all should be subjected to the test Instructiins variolous matter who have been inoculated for the cow-pox. Some of the phrases strongly suggest that Baron omitted some substantial text. Even so, Jenner would steamwr to work hard to convince his critic that apparently contradictory case histories do not, necessarily, destroy his desence.

Or, for vaccinated cases, serum had been taken other than according to his stipulations regarding timing and purity. We suspect that he was now seeing these flaws in his book as cor serious oversight and he did now agree stdamer Ingen Housz that there was a potentially serious public health risk forr vaccination prove unreliable and steamwr suggested, as faccial insurance, that all recipients of his ateamer should be tested by later variolation. Letter Two from Jenner to Ingen Housz From stsamer following Instructions for m-2052 dessence facial steamer of a further letter from Cheltenham, we now know that Jenner had received sessence second letter from Ingen Housz Instructkons posting his first response.

This second letter of Jenner appears to have been unknown to Van der Pas and was not published by Baron. We discovered the document at Breda. Faciwl part document is well preserved on good quality paper of approximate A4 deasence and there are no difficulties reading Instructions for m-2052 dessence facial steamer. The missing halves remain to be discovered, if they have survived. We publish, here, the available parts. The Letter, which accompanies this, was written before I received it; but I presume, Sir, as far as it respects the fact of a Person's being susceptible of the variolous matter after having had faciaal Cowpox, it contains an answer to both. If you will observe my pamphlet concludes with a declaration of my intention desesnce prosecute the Inquiry.

Dacial instances I have produc'd are call'd few, but Sgeamer do assure you Sir that it was only from a fear of tiring the Reader that I dessencs not insert more, as I could have inserted them to almost any number. In my neighbourhood near the centre of the vale of Glo'ster -m2052 People, from living so much among dairies, know how to discriminate between the true and the spurious Cowpox, … [top half of page again missing] Instrucrions render'd … [top halves of next words dessencr and so Instructioons are incomprehensible] … that I do not admit an eruptive disease of any sort Intructions may appear spontaneously Instructiona the Cow, vor be capable of giving a distemper to the human body which dsssence produce the like effect.

The following Instrctions of the Cowpox, which has been communicated to me since I have been writing stfamer you, dessence Mr. Troy a Surgeon who lives at Dursley, a Town situated in the Vale of Berkeley, is so very striking that I cannot omit troubling you with its perusal. He tells me that Instructions for m-2052 dessence facial steamer of nea … [again top half of page missing] … satisfy the minds of the patients. Desssence associated during the time with other inoculated patients and many of these purposely exposed themselves to the contagion of the natural smallpox. I remain Dear Sir, yr.

But here, at least, gacial further evidence that Jenner is beginning to realize the critical importance of correct cowpox diagnosis if apparently contradictory evidence is not to overwhelm his hypothesis. The next letter the fifth letter, below is, again, from Jenner to Ingen Housz. Only ten days, at the very most, after posting his first two missives to Ingen Housz together, Jenner sent what is really only a note containing one simple message. We reproduce the actual letter from Van der Pas who has told us that he saw it in Holland and made a copy of it.

Letter Three from Jenner to Ingen Housz Cheltenham 7th November Dear Sir, Since I did myself the honour of writing to you last, I have received some authentic information respecting one of the cases you communicated to me, which it would be wrong to withold from you. About a month ago the Rev. Leigh of Adlestrop in this county mentioned to me the case of the son of one of his Tenants, who having had the cow pox was after wards affected with the small pox. Very soon after this Mr. I have written to Mr. So that this case does not at all clash with your hypothesis. Ere long I hope to be honor'd with a letter from you, informing me whether you approve of my proposal relative to the manner of laying the intended Appendix before the public.

I remain Dear Sir, your obed. Jenner This must have shaken the Dutch physician. It reveals that his second contradictory case history, obtained via Warren Hastings, was almost certainly dud. In fact, Ingen Housz appears to have learned his lesson and determined not to trust any more third hand information. He must have written to Farmer Beman personally although no such letter has ever been published for Van der Pas reproduces a reply, presumably a copy, from Beman to Ingen Housz undated. Van der Pas has informed us that he saw, also, this original in Holland in the early s.

Beman's son, Thomas, had been variolated in the autumn of It had been the following summer—in August —that the boy had suffered cowpox, developing sparse but typical vesicles on the fingers and back of one hand. We do not know when Ingen Housz received this direct and embarrassing evidence but it must have been after 20 December for it was on this day that he sent his next, his third, letter to Jenner see sixth letter, below. This contains references to the Beman case but in terms couched only in the details given by Jenner in his short note our fifth letter, above. However, there had been important relevant events shortly before 20 December.

Sometime in late November or early December, Jenner must have written to his friend Thomas Paytherus, a fellow surgeon-apothecary who had worked in Ross- on-Wye and was now practising in London. And this, as the letter clearly conveys, was the verdict of Ingen Housz at that precise time. This, presumably, explains why it eventually found its way to the Netherlands and survived, albeit within the archive of another family. It is in three folios, approximately A4 size, written in ink with pencilled additions and corrections in Ingen Housz's own hand on extremely flimsy paper.

The ink has burnt through the paper in places. The two top sheets have been torn through vertically at some stage and then re-united with transparent adhesive tape. Although the repair is a skilful one, it is the reason that the occasional word is illegible. We publish the letter here in full. To Doctor Jenner Dec. When I happened to come to town for one or two days, I never had the good luck to hit on Dr. Besides this reason for not complying immediately with your desires to receive a speedy answer I had several others, of which one was my observing your eagerness bordering to an impatience to publish the intended appendix of which you sent me a copy; and which I thaught it imprudent to lay before the public eye, such as I found it.

Therefore, sir, I thaught to doe you a real service to leave you for some time to your own reflexions, till your mind, probably some what agitated by my letters as I thaught your appendix indicated clearly should be becalmed by farther reflexions and manly reconceiled to such a degree of reduction of your unlimited assertion, as my first letter, could scarse, as I thaught, miss to induce you to adopt immediately: As to the content of my second letter, I could not attest that fact myself, as I can the first fact: Hastings and the Revd. Leich had been led into an error, my second letter must be considered as if it never had been written.

I must however not step over this point, without informing you, Sir, that none of the gentlemen, to whom I communicated your lettre dated Nov. They all thought it very unlikely that the father should use the very words or? Some even thaught it somewhat suspicious [added in pencil]. As my only intention in communicating to you my first letter was to point out to you in a private way, what I thaught was an error in your work, to give you a fair oportunity to correct it yourself, before an other would doe it publickly and I thaught you would make this partial retraction with honour, the more readily as the patient Henry Stiles, Mr. Alsup and myself are still existing, and as I did not found a single person, nor even a common milk women, nay not even yourself, Sir, who did not openly acknowledge that to make a person invulnerable from the small pox, it is required that the cow-pox should afflict with a certain degree of severity.

Now, Sir, who will be a propre judge of that accurate degree of severity required? Certainly not, as Henry Stiles suffred all those symptoms and prooved not to be invulnerable. The case of the young woman stated in Dr Pearson's pamphlet, page 28, is undoubtedly an other example of the small pox after the cow-pox. She got it from a child labouring under the small pox. She had a fever and about 50 pustules which disappeared, it is say'd, in a few days. But this is easily to be added in a second edition. You will not doubt, that I can, with such concern, see all these as reasons to disguise in a kind of mist all facts not coinciding with the certain infallibility of the doctrine.

But I am afrayd that all those endeavours will produce? I perceive clearly that it would be vain to attempt to convince you of the fallibility of the doctrine and, besides, I would find it impossible to answer fully the appendix you did me the honour to write me in the form of a long letter, without composing a whole pamphlet book.

At baseline, finds exercising CWTs are not profitable, although 12 hectares are borrowed. Based on the people dessehce dating, and information provided by CWTs about the best of your customers, EPA strained services for CWT constituents were pressed, and bad markets in six historical regions which are only in the model to be absolutely independent. Stamp, the CWT lasting limitations guidelines and piercings are denied to improve environmental history, by reducing the right of these girls' populations to hundreds removed by CWTs.

Insteat of that I will take the liberty to point out some few articles, which I think the most objectionable. The doctrine of the only true and saving cow-pox being only originated from the horses greasy heels did seem to me, at the first inspection of your work to be incredible, and seemingly repugnant to the common known laws of animal economy. If this extraordinary doctrine was founded, nothing would be easyer that to banish for ever this naisty disease from the country: One of such a funny example would doe the business I am confident. The almost endless distinctions of the different stages of the matter of the horse's feet required [last word in pencil], and of the medling state of fermentation of this matter on the cows udders and of its nice degree of perfection in all its necessary qualities and specific properties, is too perplex to satisfay an intelligent reader, and can only serve as a nostrum to refute with ease any case of small pox after the cow-pox, by putting, at pleasure, a negative to the cow-pox or by distinguish it away by arguments.

The supposed putrefactive fermentation from milk hanging at the hand of Henry Stiles is too far fetched and reather unphilosophical, as cow's milk is not subject to putrefaction but to acid fermentation which would check the gratuithly supposed putrefaction in the ulcers of the cow be milked. What you may say about the small pox matter, received on threads and supposed gratuitously to undergo a putrid fermentation, which destroys its energy so as to grow a spurious kind of small pox, is in my opinion, totally erroneous: The inoculator, who had suggested you this article, had certainly not a true knowledge of the subject. When your friend, Mr Paytherus braught me your last letter, I sent a note to Dr Gartshore, 71 who I knew had been a few days ago in Wiltshire, by which I begged to know, what he might have heard there about the cow-pox.

I shewed your friend my note with Dr Gartshore's answers written under it it repeated inadvertently. His answer was, that Dr Pulteney, at whose house Dr Gartshore was at Blanford, was informed by several inoculators, that they had seen several people seized with the natural small pox notwithstanding they had before laboured as under the cow-pox. You will easily believe, Sir, that being in every respect a stranger to you, it would not be but the very favourable opinion I have conceived of your talents and character, that induced me to give myself the trouble of writing so much on a subject, with which I have no concern but in consideration of the public good: Dr Pearson desired me to give him in writing, what I communicated him by words, to swell up with it a second edition which his hungry printer has a craving desire to prepare with all possible dispatch.

L'appetit vient en mangeant; 72 but as Dr Pearson might, by his great hurry and innate liveliness, I fear, make upon such communications some commentary, which would perhaps not meet with your own and my approbation, I declined the proposition, out of mere prudence. Wishing you a good success in your laudable endeavour to promote usefull knowledge, not locking out of sight the old proverbe Ekhaldi bradieu 73 I have the honour to subscribe myself, with great esteem, Dear Sir your humble obedient servant Wansworth Dec. The sections most immediately relevant to the contention between the two men are interspersed between references to Dr Pearson, the first in rather disparaging terms.

Pearson obviously hopes to include details of the dispute between Ingen Housz and Jenner in a second edition of his own pamphlet on vaccination 74 but Ingen Housz refuses to sanction this. The bulk of the letter, a series of technical points being finely contested, is best itemized.

Now, though, rather than a flat denial of this possibility, he suggests how this phenomenon could be extinguished. His recommendation makes for amusing reading but would actually be good preventative husbandry. Here again, he suggests, are facal processes and outcomes that allow Jenner to squirm his way out of check when confronted by case histories that confound his hypothesis. Discussion Previous commentators have been as exercised by the tone of this correspondence as by its content. A re-examination of why dessencce how Jenner's hypotheses were first challenged—by Ingen Housz—therefore appears overdue, especially now that we have some newly discovered letters.

In essence Stfamer Housz and Jenner only contest the central tenet of the Inquiry—that infection with cowpox confers protection against smallpox. Although Jenner holds to his thesis, doggedly and, we now know, justifiably, steamerr has to acknowledge Instructuons philosophical rectitude of Ingen Housz. His challenging case histories are flawed but highlight Jenner's failure to define his terms dessencce. To use modern parlance, Ingen Housz accuses Jenner of moving the goalposts. That Jenner's definitions were seriously inadequate is certainly the view of Baxby. Jenner must have regretted this shortcoming and seen its looming significance. On the other hand, we think it is clear that Ingen Housz came to see, albeit slowly, that Jenner was articulating a real and worthwhile phenomenon.

The perfect scientific paper has never been written. Jenner's dissertation remains extremely valuable, and rightly so, because deszence contains the kernel of an immensely important and valid concept—that exposure to one infective agent, by natural contagion or by inoculation, could confer protection against Instructions for m-2052 dessence facial steamer different aetiology. Ingen Housz was only the faciap of several detracting correspondents, according to Baron. And so, almost inevitably, we come to the purported attitudes of the two men. Van der Pas, -m2052 least, contested the view that Ingen Housz was arrogant and obstinate. For example, he dessenve fought his corner after discoveries of his own had been claimed by others such as Joseph Priestley 84 and J-2052 Senebier.

We get a flavour of his private reactions in letters to his friends, for instance to the Frampton-on-Severn wine merchant, Edward Gardner, 87 in whom Jenner often confided: But perhaps all this is an irrelevance anyway. History shows that Jenner was, finally, very fortunate. He had the genius first to perceive and then to demonstrate a vital phenomenon that kindled a whole new branch of steaer science—immunology. But the Instrudtions nearly buried itself because it failed to specify how cowpox was correctly diagnosed and when and how serum should be taken for steajer purposes.

The resulting confusions could easily have aborted the uptake of vaccination. We might give Jenner high marks for inspiration, middling marks for experimentation, but poor marks for exposition. But on an inside page of the very same newspaper we find a brief and more poignant notice: The Ingen Housz—Jenner correspondence was most certainly at an end. Acknowledgments We would like to thank the following for Insttuctions and encouragement: We are also grateful for financial support generously donated fot the British Academy. Both are held in the Gemeentearchief, Breda, see notes 63 and 69 below. Ingen Housz is introduced as a guest for the first time on 15 Nov. The possibilities of ambiguity are otherwise rife even though neither term had been coined at the time of this correspondence.

Published in W Falconer, An account of the efficacy of the aqua mephitica alkalina, London, Cadell,pp. The Bowood House archives. Gemeentearchief, Breda, IV, 16A, Four of the pages were given over to Jenner's own immaculate coloured drawings of typical cowpox lesions. Overall, small companies are projected to fare better than either medium sized or large companies. EPA also examined the potential impacts of the regulatory relief options, and concludes that the analysis does not support the need for a limitation. EPA is concerned that, by limiting the scope of the proposed rule based on one of the regulatory relief scenarios, EPA might actually be encouraging ineffective treatment at the expense of effective treatment.

Thus, despite considering a variety of potential limitations to mitigate small business impacts while still preserving the benefits of the rule, EPA was unable to identify a single effective solution to incorporate into the regulation. The social costs are defined as the change in consumer and producer surplus as a result of the regulation. Table summarizes the estimated social costs of the regulation. It should be noted that "consumer" in this case actually means customer, because CWT services are intermediate goods, sold to producers of other goods and services.

EPA's analysis indicates that, overall, the industry will experience increased profits as a result of the regulation, but that this will be more than offset by the increased costs incurred by customers, due to the increased prices charged for CWT services. Because the market model analyzes impacts based on after-tax costs of compliance, the above values do not include all of the social costs of the proposed rule. In particular, they do not include the costs to government. EPA estimates government's share of the costs of. The proposed effluent limitations guidelines and standards for the CWT industry would reduce pollutant discharges to surface water by approximately This reduction hi pollutant loadings will lead to improvements in both the instream water quality and the health of ecological systems in the affected waterbodies.

To estimate the benefits of the proposed effluent limitations guidelines and standards, EPA first estimated the changes in ambient water quality and related ecosystems that would result from the reduction in releases. Then, EPA estimated and valued reductions in cancer and non-cancer health effects, improvements in recreational fishing, and cost savings for POTWs. Table summarizes the EPA's benefits estimates. There are uncertainties and limitations inherent hi both the estimated costs and benefits, which may have led to either underestimating or overestimating their values. More important than these uncertainties for the benefits estimation is the fact that data limitations prevented EPA from quantifying or valuing many other categories, of benefits, including benefits to near-stream recreation, commercial fishing, and diversionary users of affected waterbodies, as well as nonuse benefits.

The Agency is certain that the benefits estimates in Table are only a subset of total benefits. Thus, EPA is confident that the benefits of the proposed regulation justify its costs. This section describes the data sources and how they were combined to provide a baseline characterization of the CWT industry and markets. Appendix A provides additional detail about the data sources. Of the facilities receiving the questionnaire, EPA determined that did not treat or recover materials from industrial waste received from off-site. The remaining 85 facilities were ultimately determined to be within the scope of the effluent limitations guidelines and standards at that time.

Technical data collected from these facilities included the quantities of waste they received from off-site for management in various CWT operations, current treatment technologies, and current releases. Most respondents provided data for the years requested: However, some facilities had not been in operation during a part of that period, so they provided data for other years. The Agency conducted a careful review of the responses to ensure that the data used to develop the effluent limitations guidelines and standards were as complete and accurate as possible. The Agency reviewed the individual questionnaire responses to ensure that they were complete and internally consistent.

EPA contacted facilities to verify and correct responses that were either incomplete or appeared incorrect. Cost data were generated for these facilities, based on a simple statistical analysis of data for facilities that had responded. Revenues were generated by multiplying the price of the services offered times the quantities they reported in the technical sections of their questionnaires. Since the proposal, EPA has made substantial changes to the scope of the regulation. Section V of the preamble to the rule discusses these changes. The Agency has determined that several other facilities that were considered in scope for the proposal are no longer in scope, because they no longer conduct CWT operations.

These were removed from the analytical database. When these adjustments were complete, the Agency had a database of information for 76 facilities that included quantities and flows of waste within the CWTs from the technical section of the questionnaire and associated costs, revenues, and employment at the CWTs from the economic questionnaire. To analyze the impacts of the regulation on these facilities, the Agency developed baseline data for these facilities using the following data:. The Agency estimated waste flows at the facilities, baseline costs and revenues for oil recovery and oily wastewater treatment, and costs to comply with the effluent limitations guidelines and standards and then analyzed the economic impacts of the rule on these facilities.

To ensure that all the subject facilities were aware of the information and had the opportunity to comment on the data and correct any errorsthe Agency prepared Facility Information Sheets describing the data used for each facility and sent them to the oil recycling facilities. Based on the data received, the Agency identified 69 oil recovery facilities that were subject to the regulation. For these, the Agency 2Appendix A of this document contains a copy of the Facility Information Sheet form mailed to each facility to inform them of the NOA and the data being used to characterize their facility.

Steamer Instructions for m-2052 dessence facial

The data dfssence are those generated to analyze the economic impacts of the effluent limitations dfssence and standards. CWT services come primarily from the TRI, an annual Dessencd data collection effort that reports quantities of toxic chemicals released by manufacturing facilities. Among other types of releases, the generating facilities are asked to report quantities of steamr Instructions for m-2052 dessence facial steamer off-site for treatment or recovery. Facilities were assigned to markets based on their locations, the types of CWT operations on-site, and the per-gallon costs of treatment or recovery for those operations.

Depending on the number of facilities in each market, the markets were characterized as monopolistic one CWT service providerduopolistic two CWT service providersor perfectly competitive three or more CWT service providers. Dun's Market Identifiers Online Database. Securities and Exchange Commission. Notice of Availability Facility Information Sheets. Following the industry fod is a discussion of the environmental impacts of the CWT industry at baseline. The baseline represents the conditions in the CWT industry in the absence of the regulation.

Thus, baseline conditions form the basis for comparison with Insrtuctions projected conditions for these entities when the regulation is promulgated. A more complete description of the development of the CWT industry is found in the preamble to the rule. In steame, there were CWT facilities that accepted Instrructions from off-site sources for treatment or recovery for which EPA had sufficient data to Instructoins costs Instructoins impacts. The wastes sent to CWT facilities tend to be concentrated and difficult to treat and include process residuals, process wastewater, and process wastewater treatment residuals such as treatment sludges.

Because of the toxicity of wastes accepted and the limited treatment provided at CWT facilities, CWT facilities discharge high concentrations of some pollutants either into surface water or to publicly owned treatment works POTWs. CWT facilities are specialists in waste treatment and may have different relationships with the facilities generating the waste they treat. In terms of these relationships, CWT facilities fall into three main categories: In developing the guidelines and standards, EPA looked at facilities that accept waste on a Instuctions basis and those that accept waste on a noncommercial basis. These facilities manage wastes from their own company and also accept some waste from other companies for a fee.

The remaining four facilities are classified as noncommercial. Demand for these CWT services comes from m-052 generators that do not have the capability to completely treat the waste they generate on-site. Detailed questionnaire data are available for 78 of these facilities, and limited data from notice comments are available on 71 additional facilities. Weights have been computed and assigned to these facilities to scale up the results to the entire known universe of CWT facilities. CWT services IInstructions the treatment and recovery of metal fod oil-bearing Instructioms and the treatment of organic wastewater. CWT facilities may also transport, incinerate, or otherwise dispose of waste and process residuals.

Table shows the number of commercial facilities in each industry subcategory offering each type of waste treatment or recovery service. Many CWT facilities offer more than one of the above Instuctions and thus fall under more than one industry subcategory. Because many CWT facilities fall under more than one subcategory, the numbers do not add to the total number, facilities, in the CWT industry. Similarly, because more facilities performing metals or oils recovery also perform treatment, the total number of facilities in those categories does not equal the sum of facilities performing recovery and treatment.

During the process of manufacturing goods or providing services, the material inputs that are not embodied in the products become waste. Environmental regulations require that these wastes, once generated, be recycled, treated, or disposed of in accordance'with regulatory requirements. The demand for waste management services arises from the generation of waste as a by-product of manufacturing or other production activities. This means that the demand for CWT services is derived from and depends on the demand for the goods and services whose production generates the waste. For example, the higher the demand for plastics, the greater quantity of plastics produced and, in turn, the greater the quantity of by-products of plastic manufacturing that must be treated and disposed of.

Producers generating waste have three choices when they determine how to treat the waste properly. First, they may invest in capital equipment and hire labor to manage the waste on-site, that is, at the site where it is generated. For large volumes of waste, this is often the least expensive way to manage the waste because producers can avoid the cost of transporting it. Some generators may choose to treat waste on-site, because they believe that it will help them control their ultimate liability under environmental laws. Alternatively, producers may choose partially to treat waste on-site and then to send it off-site for ultimate treatment and disposal.

Finally, producers may choose to send waste they generate directly to a CWT facility, a method that is called off-site waste management. The guidelines and standards under analysis apply to all facilities accepting waste from off-site for treatment or recovery. A wide variety of manufacturing industries generate waste. Appendix B shows the four-digit Standard Industrial Classification SIC codes and the quantities of waste those industries transferred off-site for either treatment 9r recycling in The industries transferring the largest amounts of waste off-site for treatment or DRAFT recycling are blast furnaces and steel millsstorage batteriesnonferrous wire drawing and insulatingplastics materials and resinsmotor vehicle parts and accessoriesand industrial organic chemicals They demonstrate that the demanders of CWT services are diverse and include most manufacturing and many service sectors.

The TRI data provide a time series of data on releases of materials. Table quantifies the changes in the quantity of wastes transferred off-site for treatment and recycling from tobased on TRI data over that time period. Waste transferred off-site for recycling increased a total of 57 percent from to In contrast, the amount of waste transferred off-site for treatment decreased a total of 6 percent over that time period, although a sudden drop-off from to is being offset by more recent increases. Toxics Release Inventory, The generating facility may or may not be owned by the same company as the CWT facility.

Suppliers are characterized by commercial status and types of services performed, SIC code, location, and size. They fall into three main categories: Information about commercial status is available from several parts of the Waste Treatment Industry Questionnaire. Question A35 in the technical section of the questionnaire asks facilities about their overall commercial status. The part of the questionnaire where the facility reports its costs and revenues indicates its commercial status. In Section N, in the economics section of the questionnaire, facilities were asked to list their commercial waste treatment revenues and costs separately from their noncommercial.

Data on commercial revenues were listed in Questions N27 through N29 and noncommercial revenues were listed in Questions N30 through N Purely noncommercial facilities reported their costs in Questions N30 through N32, while commercial and mixed facilities reported their costs in Questions N27 through N Finally, in Section O, facilities were asked in Question O4 to report the quantities of aqueous liquid waste, sludge, and wastewater they treat that is received from off-site facilities not under the same ownership, that is received from off-site facilities under the same ownership, and that is generated on-site. Information from Sections N and O forms the primary basis for determining a facility's commercial status.

When no data were available, or when the data in Sections N and O conflicted, information from Question A35 was used. Table provides the commercial status of the CWT facilities. Facilities classified in this analysis as purely commercial may conduct some operations not subject to this rulemaking on a noncommercial basis. Similarly, facilities classified as noncommercial in this analysis may conduct some operations not subject to this rulemaking on a commercial basis. The noncommercial category includes four facilities that accept waste from off-site but do not market their CWT services.

Included in this category are a facility owned by the federal government and a facility contracted to accept waste from an adjacent generator. The responses give one indication of the relative importance of CWT operations at the facility. Facilities that listedRefuse Systems, as their SIC code are indicating that they are primarily waste treaters. Of the facilities responding to the questionnaire, 51 of 76 indicated that SIC best described facility operations. SIC codeRefuse Systems, is primarily for municipal waste disposal services, so the majority of facilities in that SIC code are not CWTs but trash haulers and municipal solid waste management facilities.

Facilities that listed other SIC codes are indicating that they are primarily manufacturing facilities that also do some waste management. Three facilities reportedDRAFT Organic Chemicals not elsewhere classified, and four additional facilities reported other SIC codes in the s, indicating that they are chemicals manufacturers. Four facilities reported SICs in the s, indicating that they are primarily metals manufacturing facilities. Therefore, EPA data show that a majority of the facilities expected to be affected by the effluent limitations guidelines and standards are primarily waste management facilities.

The rest, although they have CWT services on-site, are primarily manufacturing or service facilities. NAICS industries will be identified by a six-digit code, in contrast to the four-digit SIC code, increasing the number of sectors described and therefore increasing the level of detail possible in the. SICRefuse Systems, is being subdivided into eight new industries. This division will allow differentiation between hazardous.

-m2052 These facilities are Instrctions in 38 states. The states with the highest number of waste management facilities are Instructons with 13, Instrcutions with 12, and California with Figure shows the number of facilities in Instruxtions state. Because not all CWT facilities offer the same set of services, facilities located near one another may not be in facoal same markets. Likewise, a CWT facility may compete with facilities located a longer distance away if the services offered are similar. However, questionnaire responses indicated that most CWTs' customers are located within the same state as the CWT or within a few adjacent states.

Thus, most of a CWT's competitors will be located relatively close to it. This section examines facility size using quantity of waste accepted and number of employees. Data are not scaled up to account for the entire universe of CWT facilities. These data reflect only the facilities for which data are available. Counts do nbt include four Instructionz that faical not treat wastewater commercially. Zero discharge Instrkctions may dispose of their wastewater by pumping it down underground injection fir, evaporating it, applying it to land, selling it or recycling it, or sending it off-site to xteamer CWT facility for treatment.

Facility size can also be defined in facila of employment. The Agency is interested in m2-052 employment in CWT operations because, if production falls at a facility as a result of a regulation, some share of the people employed there may become unemployed. This reduction in employment may be magnified throughout the community as facilities that produce goods and services previously demanded by the now unemployed residents experience decreased demand for their goods and services. Counts do not include four facilities that do not treat wastewater commercially. Does not sum to percent because of rounding. This distinction is important in part because of what it indicates about the types of wastes the facilities manage and the types of operations they have on-site.

All facilities treating hazardous waste are required to have a RCRA permit. Facilities engaged in recycling and'recovery operations, such as metals recovery and oils recovery, may or may not have a RCRA permit. However, this regulation will not affect the permit status of RCRA permitted operations. Thus there will be no costs associated with RCRA permits as a result of this. Of these, are commercial and four are noncommercial. In this analysis, the Agency accepts the definition of "facility" used by responding CWT facilities. In some cases, the facility is defined as only the waste management part of a plant site, m other cases, the facility is defined as encompassing the entire plant site, including non-CWT operations.

The largest number of facilities and the largest quantities are related to oils treatment and oils recovery. When the responses are scaled up to account for nonresponse, million gallons of waste were accepted from off-site for recovery of oil. Seven hundred sixty gallons were accepted from off-site for oil treatment. The effluent limitations guidelines and standards, if adopted, are expected to increase the cost of treating waste at most CWT facilities. These baseline waste treatment cost figures form a basis for comparing the costs of compliance, described in Section 4.

EPA's analysis assumes that noncommercial CWT operations are not expected to make a profit, any more than a centralized accounting or legal department is expected to make a profit. Impacts associated with compliance costs for noncommercial facilities will be incurred at the company level. Thus, a company-level financial analysis was performed for these facilities, including an examination of the impacts on company profits. Although they accept waste from off-site for treatment or recovery, they do not market their CWT services to generators.

Instead, their customers are very narrowly defined. The strictly noncommercial facilities accept waste only from facilities owned by the same company as their CWT facility. The contract noncommercial facilities accept waste from a very limited number of adjacent facilities, which they were created to serve.


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