Draft, 4/ 12/ 05; subject to change Page 1 of 10 Photoprocessing 2.0 Introduction In 1997, EPA published a " Preliminary Data Summary for the Photoprocessing Industry ( 1997 PDS).

2.1 Industry Profile Photoprocessing includes facilities in SIC codes 7221, 7335, 7336, and 7384. The 1987 SIC Code Manual defines these SIC codes as follows:

7221: Establishments primarily engaged in still or video portrait photography for the general public. Included in this classification are school, home, and transient portrait photographers. Establishments primarily engaged in commercial photography are classified in Industry 7335; those primarily engaged in video tape production other than portrait are classified in Industry 7812; and those primarily engaged in film developing and/ or print processing for the trade or for the general public are classified in Industry 7384.

7335: Establishments engaged in providing commercial photography services for advertising agencies, publishers, and other business and industrial users. Establishments engaged in still and video portrait photography are classified in Industry 7221, and those primarily engaged in mapmaking are classified in Industry 7389. Establishments primarily engaged in medical photography are classified in Industry 8099. Establishments primarily engaged in producing commercial video tape or films are classified in Industry 7812.

7336: Establishments primarily engaged in providing commercial art or graphic design services for advertising agencies, publishers, and other business and industrial users. Producers of still and slide films are classified here. Establishments primarily engaged in art, except commercial and medical art, are classified in Industry 8999; those engaged in medical art are classified in Industry 8099; and those providing drafting services are classified in Industry 7389.

7384: Establishments primarily engaged in developing film and photographic prints and enlargements. Data for retail outlets ( kiosks), which are owned and operated by photo finishing laboratories for the pickup and delivery of film, are Draft, 4/ 12/ 05; subject to change Page 2 of 10 merged with data for the laboratory which owns them and are not treated as separate establishments. Establishments primarily engaged in processing motion picture and video film for the motion picture and television industries are classified in Industry 7819.

Table 2 1 presents facility counts for the Photoprocessing Category from the U. S. Census and the 1997 PDS.

Table 2 1. Census and 1997 PDS Data SIC Code NAICS Code Number of Establishments1 Number of Establishments2 As Primary Business As Primary or Secondary Business 1997 2002 7221: Photographic Studios, Portrait 541921: Photographic Studios, Portrait 27,607 32,184 13,245 14,587 7335: Commercial Photography 541922: Commercial Photography ( except medical photography) 14,845 18,414 4,298 4,255 7336: Commercial Art and Graphic Design 541430: Graphic design services 31,476 37,264 14,582 15,828 7384: Photofinishing Laboratories 812921: Photofinishing laboratories ( except one hour) 10,430 13,171 7,055 4,723 812922: One hour photofinishing Total 84,358 101,033 39,180 39,393 Sources:

1. 1997 U. S. EPA Photoprocessing Industry PDS 2. U. S. Census Bureau.

No facilities reported to TRI in 2000, and one facility, USGS  EROS DATA CENTER in Sioux Falls, has data in the 2000 PCS. Table 2 2 lists the facility data available in the 2000 TRI and PCS. In addition, the 1997 PDS indicates that the majority of photoprocessing facilities are small in size ( less than ten employees), which exempts them from TRI reporting.

Table 2 2. Facility Counts in TRI SIC Code Number of Facilities Reporting to 2000 TRI Number of Facilities Reporting to PCS 2000 Direct Indirect Both No Reported Discharge Direct ( Major)

7221 0 0 0 0 0 Draft, 4/ 12/ 05; subject to change Table 2 2. Facility Counts in TRI SIC Code Number of Facilities Reporting to 2000 TRI Number of Facilities Reporting to PCS 2000 Direct Indirect Both No Reported Discharge Direct ( Major)

Page 3 of 10 7335 0 0 0 0 0 7336 0 0 0 0 0 7384 0 0 0 0 1 Source: PCSLoads2000 and TRIReleases2000.

2.2 Wastewater Characteristics For 2000, no TRI data are available, and PCS contains discharge information for a single facility. There is no central database containing information on indirect dischargers. However, the 1997 PDS provides information on wastewater sources and characterization. Table 2 3 summarizes photoprocessing wastewater streams and their major constituents.

Table 2 3. Aqueous Wastes from Photoprocessing Solution Constituents Prehardeners, Hardeners, and Prebaths Organic Chemicals Chromium Compounds Developers Organic Chemicals Stop Baths Organic Chemicals Ferricyanide Bleaches Ferricyanide Dichromate Bleaches Organic Chemicals Chromium Compounds Clearing Baths Organic Chemicals Draft, 4/ 12/ 05; subject to change Page 4 of 10 Fixing Baths Organic Chemicals Silver Thiocyanate Ammonium Compounds Sulfur Compounds Neutralizers Organic Chemicals Stablilizers Phosphate Sound track Fixer or Redeveloper Organic Chemicals Ammonium Compouns Monobaths Organic Chemicals Source: 1997 U. S. EPA Preliminary Data Summary for the Photoprocessing Industry Process water used in photoprocessing consists of a) film and paper wash water; b) solution make up water; and 3) area and equipment wash water. According to the PDS, photoprocessors typically discharge less than 1,000 gallons of wastewater per day. The PDS also documents 296 million square feet of film and 4,130 million square feet of paper processed per year. Table 2 4 provides information on wastewater flows associated with this industry.

Table 2 4. Total U. S. Commercial Photoprocessing Wastewater Flow for 1994 Wastestream Flow Demands ( mL/ sq. ft) Total U. S. Flow ( MGal/ year)

1994 2003 Range Average Film Paper Film & Paper Film Paper Film & Paper Developer paper: 5 30 film: 15 100 paper: 17.5 film: 57.5 4.5 19.1

 4.3 15.4

Bleach 5 30 17.5   20.4   16.7 Fix 15 100 57.5   67.2   54.8 Bleach Fix 5 30 17.5   20.4   16.7 Stabilizer 10 30 20.0   23.4   19.1 Wash ( per tank) 200 1000 600.0   700.9   571.9 Total = Developer + Bleach + Fix + Stabilizer + Three Wash Tanks 2,258 1,843 Source: 1997 PDS and 2003 Photo Manufacturers Association. Draft, 4/ 12/ 05; subject to change Page 5 of 10 2.3 Pollutant Loadings The PDS also provides an estimate of the pollutant loadings associated with this industry. For purposes of this evaluation, EPA assumed the same concentrations as the 1997 PDS ( except where noted for silver) and used the flows from Table 2 4 for 2003 flows. Table 2 5 summarizes the estimated pollutant loadings. As can be seen in Table 2 5, 99% of the toxic load associated with this industry is from silver. While the overall annual TWPE is 300,000, the TWPE per facility is less than 10. Draft, 4/ 12/ 05;

subject to change Page 6 of 10 Table 2 5. Pollutant Loadings Estimated for 1994 and 2003 Pollutants of Concern Concentration ( mg/ L) 3 Loads Before POTW Removal ( lbs/ year) TWF TWPE Before POTW % Removal ( lbs/ year) POTW % Removal4 Loads After POTW Removal ( lbs/ year) TWPE ( lbs/ year)

Range Average 1994 2003 1994 2003 % Data Source 1994 2003 1994 2003 Ammonia 20 300 160 3.02E+ 06 2.46E+ 06 0.0022 6,633 5,413 39% TRI table 1,839,156 1,500,947 4,046 3,302 Biochemical Oxygen Demand ( BOD) 200 3000 1600 3.02E+ 07 2.46E+ 07 NA NA NA NA NA NA NA NA NA Chemical Oxygen Demand ( COD) 400 5000 2700 5.09E+ 07 4.15E+ 07 NA NA NA NA NA NA NA NA NA Iron < 10 100 55 1.04E+ 06 8.46E+ 05 0.0056 5,804 4,737 83% CWT/ RREL 176,190 143,789 987 805 Silver ( ion; after recovery) 1,2 < 0.1 5 10 1.88E+ 05 1.54E+ 05 16.47 3,103,576 2,532,847 88% TRI table 22,085 18,024 363,739 296,850 Sulfates 50 250 150 2.83E+ 06 2.31E+ 06 5.60E 06 16 13 NA NA NA NA NA NA Thiosulfate 100 1000 550 1.04E+ 07 8.46E+ 06 NA NA NA NA NA NA NA NA NA Total Dissolved Solids ( TDS) 300 3000 1650 3.11E+ 07 2.54E+ 07 NA NA NA NA NA NA NA NA NA Total Kjeldahl Nitrogen ( TKN) 30 350 190 3.58E+ 06 2.92E+ 06 NA NA NA 90% I& S/ Steel POTWs 358,032 292,192 NA NA Total Suspended Solids ( TSS) < 5 50 27 5.09E+ 05 4.15E+ 05 NA NA NA NA NA NA NA NA NA Zinc < 0.75 0.75 1.41E+ 04 1.15E+ 04 0.0051 NA NA 79% TRI table 2,948 2,406 15 12 Total 1.34E+ 08 1.09E+ 08 3,116,029 2,543,010 2,398,412 1,957,358 368,787 300,969 Source: 1997 Photoprocessing Industry PDS ( Orginial data source: 1994 WEF study)

Notes: NA = No TWF available and/ or no POTW percent removal available.

1. The value range < 0.1  5 is low compared to the concentration ranges presented in Table 7.3, for 95 percent silver recovery, combined wastestream ( combined with wash water), of 5 20 mg/ L. The value of 10 mg/ L has been taken to be more realistic.

2. The TWF value is for silver as taken from the TRIReleases2000. mdb database.

3. 2003 concentrations are assumed to be the same as 1994 concentrations. Concentration values from 1994 WEF study.

4. POTW removal values are from the TRI Calculations 2002 database, the POTW removals table, where available. Values were supplemented using POTW Removals from the CWT and Iron and Steel Rulemakings. Draft, 4/ 12/ 05; subject to change Page 7 of 10 2.4 On Site Treatment Technologies and Pollution Prevention Activities The 1997 Preliminary Data Summary includes a detailed discussion of control and treatment technologies. These include source reduction, water reduction, and silver recovery technologies. Table 2 6, which is reproduced from the PDS, provides a comparison of various silver recovery and management systems. According to the PDS, silver recovery is almost always practiced to some extent. The most common methods are metallic replacement and electrolytic recovery.

Table 2 6. Silver Recovery Technologies Technology Advantages Disadvantages Metallic Replacement Can achieve 99% recovery;

Can be used for all silver rich solutions;

Low capital and operating and maintenance costs;

Simple operation Must be replaced on schedule;

Tendency to channel and cause concentrated silver discharge; efficiency diminishes with use;

High smelting and refining costs;

effluent not suitable for re use Electrolytic Recovery Can achieve 90% recovery;

No additional chemicals released; fix solution can be recycled;

Moderate capital costs Low refining costs Cannot achieve 5 mg/ L;

Not suitable for silver poor solutions Precipitation Can attain 0.1 mg/ L Little maintenance Low to moderate capital costs High smelting and refining costs;

complex operation;

operation costs vary from moderate to high;

treated solution not suitable for reuse Evaporation/ Distillation Can reduce wastes up to 90%

Virtually zero overflow of silver High energy requirements;

Moderate to high capital cost Reverse Osmosis Efficiently recovers silver from dilute silver wastestreams;

Reduces effluent volume significantly;

No water treatment chemicals required;

Purified water is recyclable Capital and O& M Costs vary significantly;

Frequent maintenance of membranes and pumps;

works best with dilute solutions Draft, 4/ 12/ 05; subject to change Page 8 of 10 2.5 Code of Management Practice for Silver Dischargers ( Silver CMP)

Virtually all discharging photoprocessors discharge indirectly to POTWs. Many POTWs have stringent silver limits in their NPDES permits or need to reduce metals concentrations in biosolids. POTWs have identified photographic facilities as a whole as a major source of silver. In an attempt to provide photoprocessing facilities and POTWs with a cost effective alternative to numeric limits and monitoring, in 1997, AMSA, the Silver Council and two industry groups for the Photographic industry developed a " Code of Management Practices for Silver Dischargers" ( Silver CMP). The Silver CMP provides recommendations on control technologies and management practices for controlling silver discharges to POTWs, and encourages pollution prevention technologies such as water conservation. The recommended practices are defined by a minimum recovery of silver from silver rich processing solutions ( e. g. 90%, 95%, and 99%). The minimum recovery and recommended practices vary with the size of the photoprocessor, defined by flow volume of silver rich solution and wash water. Four POTWs documented loadings reductions of 20% to 52% over historical baselines after CMP implementation.

2.6 Multimedia Environmental Releases In addition to silver laden wastewater, photoprocessors generate solid and hazardous waste. Sludge from photoprocessing silver recovery is usually contract hauled as hazardous waste ( D011) ( RCRA In Focus). Photoprocessors may also generate hazardous waste from acid regenerants, system cleaners, and photographic activators ( D002), dichromate based cleaners ( D007).

2.7 Industry Trends The use of digital photography and digital printing increased in the U. S. from 2002 to 2004. In 2002, digital cameras were owned by 18 percent of adults ( Market Research). In 2003, digital cameras were owned in 30  50 percent of U. S. households ( Photo Industry Reporter). In 2004, shipments of digital still cameras in the U. S. grew by roughly 30 percent ( Business Week Online), indicating digital camera use in 60  80 percent of U. S. households. Digital photography should decrease the discharge of silver laden wastewater associated with silver halide printing.

Contrarily, pictures from digital cameras can still be printed using silver halide technology, for better quality. Although this is not currently an identified trend, film manufacturers have incentive to establish this trend, to keep their part of the market share ( Business Week Online). Draft, 4/ 12/ 05; subject to change Page 9 of 10 2.8 References Association of Metropolitan Sewerage Agency ( AMSA) and the Silver Council, " Code of Management Practices for Silver Dischargers;" http:// www. p2pays. org/ ref/ 02/ 01994. pdf as accessed on January 25, 2004 Business Week Web Page Article: http:// europe. businessweek. com/ investor/ content/ jan2005/ pi2005017_ 1178_ pi044. htm as accessed on January 25, 2004.

Connecticut Department of Environmental Protection Web Page.

Enviro$ en$ e Web Page.

Illinois Waste Management and Resource Center. Printing Industry Pollution Prevention Notebook. 1977. Available at http:// www. wmrc. uiuc. edu/ main_ sections/ info_ services/ library_ docs/ manuals/ printing/ toc. htm accessed on October 27, 2004.

Massachusetts Office of Technical Assistance Web Page.

Market Research Web Page Article: http:// www. marketresearch. com/ map/ prod/ 826065. html as accessed on January 25, 2004.

Photo Reporter Web Page Article: http:// www. photoreporter. com/ 2003/ 11 17/ features/ digital_ 2003. html as accessed on January 25, 2004.

Photo Marketers Association International Web Page. http:// www. pmai. org.

U. S. EPA Office of Solid Waste. RCRA In Focus. 2000.

U. S. EPA Office of Water. Preliminary Data Summary for the Photoprocessing Industry. 1997. Draft, 4/ 12/ 05; subject to change Page 10 of 10 U. S. EPA Office of Water. Guidance Document for the Control of Water Pollution in the Photographic Processing Industry. April 1981. EPA 440/ 1 81/ 082 9.


MEMORANDUM TO: 304( m) Record ( EPA Docket Number OW 2003 0074)

FROM: Bob Southworth, ERG DATE: October 29, 2003 SUBJECT: Assignment of SIC Codes for the Nonferrous Metals Manufacturing Point Source Category ( 40 CFR Part 421)

This memorandum discusses the Standard Industrial Classification ( SIC) codes for facilities in the subcategories for the effluent limitations guidelines and standards for the Nonferrous Metals Manufacturing Point Source Category ( 40 CFR Part 421). It reviews the primary SIC codes for the nonferrous metals manufacturing ( NFM) industry, lists the subcategories in the Part 421, and presents the SIC code assigned to each subcategory for the review of pollutant loads for the nonferrous metals manufacturing industry that was conducted during the development of the 2004/ 05 304( m) plan.

There are 31 subcategories in the effluent limitations guidelines and standards for the nonferrous metals manufacturing industry. Although facilities with different SIC codes can perform operations subject to Part 421, the primary SIC codes for facilities subject to the NFM effluent limitations guidelines and standards are:

A portion of SIC Code 2819 NEC  Inorganic Chemicals, Not Elsewhere Classified;

SIC Code 3331  Primary Smelting and Refining of Copper;

SIC Code 3334  Primary Production of Aluminum;

SIC Code 3339  Primary Smelting and Refining of Nonferrous Metals, Except Copper); and

SIC Code 3341  Secondary Smelting and Refining of Nonferrous Metals.

SIC Code 2819 includes several operations covered by Part 421, including the production of bauxite, refined; alumina; uranium, slug ( radioactive); liquid metals; and several metals, inorganic. ERG used discharge/ release data from the 2000 Permit Compliance System ( PCS) and 2000 Toxic Release Inventory ( TRI) databases along with data available on the Internet to determine which facilities in SIC Code 2819 performed operations covered by Part MEMORANDUM October 29, 2003 Page 2 421. The following facilities with SIC Code 2819 listed below are known to perform NFM manufacturing operations:

ALCOA World Alumina in Texas ( TRI);

ALCOA World Alumina in Florida ( TRI);

ALCOA World Chemicals in Arkansas ( TRI);

U. S. Enrichment Corp in Kentucky ( TRI and PCS);

U. S. Enrichment Corp in Ohio ( PCS); and

Reynolds Metals Co in Arkansas ( PCS).

Pollutant loads for these facilities are included in the pollutant loads for the NFM manufacturing point source category.

The following table presents the SIC codes assigned to facilities in each of the subcategories for the nonferrous metals manufacturing point source category. As shown, one subcategory was assigned to SIC code 2819, four subcategories to SIC code 3331, one subcategory to SIC code 3334, 13 subcategories to SIC code 3339, and 12 subcategories to SIC code 3341.

SIC Codes Assigned By Subcategory Subcategory SIC Code SIC Code Name Bauxite Refining 3331 Primary Smelting and Refining of Copper Metallurgical Acid Plants1 3331 Primary Smelting and Refining of Copper Primary Aluminum 3334 Primary Production of Aluminum Primary and Secondary Germanium and Gallium2 3339 Primary Smelting and Refining of Nonferrous Metals, Except Copper Primary and Secondary Titanium3 3339 Primary Smelting and Refining of Nonferrous Metals, Except Copper Primary Antimony 3339 Primary Smelting and Refining of Nonferrous Metals, Except Copper Primary Beryllium 3339 Primary Smelting and Refining of Nonferrous Metals, Except Copper Primary Columbium and Tantalum 3339 Primary Smelting and Refining of Nonferrous Metals, Except Copper Primary Copper Smelting 3331 Primary Smelting and Refining of Copper Primary Electrolytic Copper Refining 3331 Primary Smelting and Refining of Copper Primary Lead 3339 Primary Smelting and Refining of Nonferrous Metals, Except Copper MEMORANDUM October 29, 2003 Page 3 Subcategory SIC Code SIC Code Name Primary Molybdenum and Rhenium 3339 Primary Smelting and Refining of Nonferrous Metals, Except Copper Primary Nickel and Cobalt 3339 Primary Smelting and Refining of Nonferrous Metals, Except Copper Primary Precious Metals and Mercury 3339 Primary Smelting and Refining of Nonferrous Metals, Except Copper Primary Rare Earth Metals 3339 Primary Smelting and Refining of Nonferrous Metals, Except Copper Primary Tungsten 3339 Primary Smelting and Refining of Nonferrous Metals, Except Copper Primary Zinc 3339 Primary Smelting and Refining of Nonferrous Metals, Except Copper Primary Zirconium and Hafnium 3339 Primary Smelting and Refining of Nonferrous Metals, Except Copper Secondary Aluminum 3341 Secondary Smelting and Refining of Nonferrous Metals Secondary Copper 3341 Secondary Smelting and Refining of Nonferrous Metals Secondary Indium 3341 Secondary Smelting and Refining of Nonferrous Metals Secondary Lead 3341 Secondary Smelting and Refining of Nonferrous Metals Secondary Mercury 3341 Secondary Smelting and Refining of Nonferrous Metals Secondary Molybdenum and Vanadium 3341 Secondary Smelting and Refining of Nonferrous Metals Secondary Nickel 3341 Secondary Smelting and Refining of Nonferrous Metals Secondary Precious Metals 3341 Secondary Smelting and Refining of Nonferrous Metals Secondary Silver 3341 Secondary Smelting and Refining of Nonferrous Metals Secondary Tantalum 3341 Secondary Smelting and Refining of Nonferrous Metals Secondary Tin 3341 Secondary Smelting and Refining of Nonferrous Metals Secondary Tungsten and Cobalt 3341 Secondary Smelting and Refining of Nonferrous Metals MEMORANDUM October 29, 2003 Page 4 Subcategory SIC Code SIC Code Name Secondary Uranium 2819 Smelting or Refining of Uranium ( NFM Portion of Inorganic Chemicals SIC Code)

1 ERG assigned the Metallurgical Acid Plants Subcategory to SIC Code 3331. According to Dan Edelstein of the U. S. G. S. Minerals Division, metallurgical acid recovery is done mostly for primary smelting. Also, according to the Technical Development Document for the nonferrous metals manufacturing effluent limitations guidelines and standards, it is more often associated with copper, zinc, lead, and molybdenum.

2 ERG assigned the Primary and Secondary Germanium and Gallium Subcategory to SIC Code 3339, because ERG was unable to separate the secondary facility pollutant loads from the primary facility pollutant loads.

3 ERG assigned the Primary and Secondary Titanium Subcategory to SIC Code 3339 because ERG was unable to separate the secondary facility pollutant loads from the primary facility pollutant loads.


INTEROFFICE MEMORANDUM RESEARCH TRIANGLE INSTITUTE December 17, 2003 To: Project Files From: Kristin Parrish Subject: Air Pollution Control Device Vendor Information The U. S. Environmental Protection Agency ( EPA) proposed standards for the Plywood and Composite Wood Products ( PCWP) National Emission Standards for Hazardous Air Pollutants ( NESHAP) on January 9, 2003. During the public comment period, EPA received two comments stating that there are not enough add on air pollution control device ( APCD) vendors to allow all sources to comply with the NESHAP by the three year compliance date. 1,2 One commenter claimed that " over two thirds" of the vendors who installed the regenerative thermal oxidizers ( RTO) and regenerative catalytic oxidizers ( RCO) included in the MACT floor determination have gone bankrupt in the past four years. 1 The purpose of this memorandum is to document the information collected regarding incineration based control device vendors in order to investigate and address the vendor availability concerns.

A list of APCD vendors was compiled by examining the MACT survey results; 3 advertisements, articles, and directories in Panel World magazine; 4 and several online pollution abatement directories. 5,6,7 The number of incineration based control devices designed and installed by each vendor according to the MACT survey is presented in Table 1. The companies listed in the MACT survey or referenced in Panel World generally are those with experience with the PCWP industry. These companies are listed in Table 2. Companies not included in Panel World or the MACT survey results are listed in Table 2 only if a specific reference to an installation at a PCWP facility was found. Any other companies found to manufacture and install incineration based control devices that could be used by the PCWP industry were listed in Table 3.

* For the purpose of this analysis, a " vendor quality rating" was assigned to each of the vendors listed in Tables 2 and 3 based on a scale from zero to three. The purpose of the rating system is to aid in determining, based on the available information, each vendor's ability to supply the PCWP industry with multiple incineration based control devices at the same time. Factors taken into account for each vendor include frequency of advertisements in Panel World, submission of articles about control device technology to Panel World by vendor employees, documented experience designing and installing control devices, size of the company and number of locations, number and variety of products, and main focus of the company. For example, a large company that focuses solely on incineration based APCD and has multiple RTO and RCO models is likely to be capable of handling several orders from the PCWP industry simultaneously, 2 while a smaller company that designs RTO but focuses on products to control emissions of nitrogen oxides and has no prior experience with the PCWP industry is more likely to handle only one RTO order at a time.

A review of journal articles and Internet webpages identified at least 10 incineration based control device vendors currently in operation that have experience installing controls at PWCP facilities and that appear to be capable of handling multiple installation requests simultaneously. These companies are indicated by a vendor quality rating of 3 in Table 2. Six other companies have experience with the industry, but it is unclear if they have the ability to handle the same number of simultaneous orders as the 10 top quality vendors. These six companies were given a vendor quality rating of 2 or 2.5 in Table 2. The remaining vendors listed in Table 2 received vendor quality ratings ranging from 0 to 1.5 depending on available information. About 12 additional companies have experience manufacturing and installing incineration based controls, but they do not have experience with the PCWP industry. These companies are listed in Table 3 and received vendor quality ratings ranging from 1.5 to 2.5 depending on their perceived ability to supply multiple control devices to the PCWP industry.

As shown in Table 1, 11 different vendors were responsible for installing the 89 incineration based control devices listed in the MACT survey results. Four of these eleven vendors went out of business in the last few years but were all purchased or otherwise acquired by another company. Three of these vendors, REECO, Salem Engelhard, and Smith Engineering, were acquired by two of the 10 top quality vendors mentioned above: Dürr Environmental, Inc. and Pro Environmental, Inc. The fourth vendor, Geoenergy International, was recently purchased by A. H. Lundberg Associates, Inc., an environmental technology company with experience in pollution control for the pulp and paper industry. The Geoenergy Division of Lundberg Associates is one of the six companies with a vendor quality rating of 2 or 2.5; it did not receive a rating of 3 mainly because the division is still relatively new and its full capacity is not yet known. A fifth company that installed four of the RTO reported in the MACT survey, Wheelabrator, is still operating, but incineration based control devices are not present in the list of products on their website. Instead, the company appears to be focusing on mist eliminators and scrubbers.

* To determine the worst case cost of the PCWP NESHAP, mill by mill cost analyses were developed for the PCWP industry, assuming that RTO would be used for compliance. 8 The millby mill analyses reflected the population of PCWP facilities, process units, and APCD as of April 2000. In these cost analyses, it was estimated that 205 RTO would be installed to comply with the PCWP NESHAP. These analyses did not account for the various compliance options in the PCWP NESHAP ( e. g., production based compliance options, emissions averaging) that will reduce the estimated number of APCD needed. These analyses also did not account for use of other MACT controls, such as RCO, biofilters, or incineration in an onsite combustion unit. Thus 205 RTO is a worst case estimate of the number of RTO needed as of April 2000. Since April 2000, the estimated number of RTO needed has been reduced by 35 because of facilities installing MACT APCD and plant closures. 9 Thus, the worst case number of RTO ( or other APCD) estimated to be needed over the next 3 years for MACT compliance is 170. There are 30 vendors 3 listed in Tables 1 and 2 with vendor quality ratings of 1.5 or higher. If all of these vendors designed and installed the same number of RTO, each vendor would be responsible for less than six APCD over 3 years.

References 1. Public Comment from T. G. Hunt, Senior Director, Air Quality Programs, American Forest & Paper Association, Washington, DC. March 7, 2003. Comments of the American Forest & Paper Association, Inc.: National Emission Standards for Hazardous Air Pollutants; Plywood and Composite Wood Products; Proposed Rule.

2. Public Comment from T. DeVore, Plant Environmental Manager, Collins Products LLC, Klamath Falls, OR. February 26, 2003. Re: NESHAP: Plywood and Composite Wood Products; Proposed Rule.

3. Memorandum from D. Bullock, K. Hanks, and B. Nicholson, MRI to M. Kissell, EPA/ ESD. April 28, 1999. Summary of Responses to the 1998 EPA Information Collection Request ( MACT Survey)  General Survey.

4. D. Knight, Editor in chief, Panel World. Published bi monthly by Plywood & Panel World, Inc., Montgomery, AL, managed by Hatten Brown Publishers, Inc. Issues from January 2000 to present online at http:// www. panelworldmag. com.

5. Air Pollution Control Equipment Directory: A Database of 770 Leading Manufacturers of Air Pollution Control Equipment. Oxidizers: Thermal. Thomas Publishing, 2003. http:// www. airpollutioncontrol ez. com/ airpollutioncontrol/ 0030629_ 0025586_ 1. html 6. Green Pages: The Global Directory for Environmental Technology. Air Pollution Control: Vapour Recovery Processing. ECO Services International, 1994 2003. http:// eco web. com/

7. Institute of Clean Air Companies: Members. November 2003. http:// www. icac. com/

8. U. S. EPA. Background Information Document for Plywood and Composite Wood Products NESHAP. Office of Air Quality Planning and Standards, Research Triangle Park, NC 27711. EPA 453/ R 01 004, September, 2000.

9. K. Hanks and K. Parrish, RTI, to Project Files. December 16, 2003. Changes in the population of existing plywood and composite wood products plants and equipment between April 2000 and November 2003.

C:\ dmautop\ temp\ dwcgi 7150 1077818919 969023000. wpd 4 Table 1. Incineration Based Air Pollution Control Devices Reported in Non Confidential Responses to the MACT Survey APCD Vendor Number of Installations Callidus Technologies 1 Dürr Environmental, Inc. ( DEI) 12 Engelhard Corp. 1 Geoenergy International Corp. * 1 Huntington Environmental Systems ( HES) 7 Process Combustion Corporation 1 Regenerative Environmental Equipment Co. ( REECO) * 16 Salem Engelhard * 8 Smith Engineering * 36 United McGill ( McGill AirClean) 2 Wheelabrator 4 Total number of installations 89 Installations by APCD vendors that closed / changed ownership 61 Percentage of installations by APCD vendors that closed / changed ownership 69%

* Indicates companies that closed and were acquired by another vendor 5 Table 2. Air Pollution Control Device Vendors with PCWP Industry Experience Company Contacta Last Website Updateb Sourcec Products of Interestd Additional Informatione Vendor qualityf Advanced Environmental Systems, Inc. 2440 Oldfield Point Rd.

Elkton, MD 21921 1 800 220 5330 aesinc. com 2000 ( listed in several directories,

incl. PW 2003 and other online directories,

some updated daily) PW RTO, RCO, Recuperative Thermal Oxidizer, Recuperative Catalytic Oxidizer  Established 1992  " Cerfoam   , our own ceramic heat transfer media,

provides ultra high heat recovery efficiencies with one of the lowest pressure drops of any media, minimizing operating costs... Self cleaning " bakeout" feature eliminates organic particulate buildup. Random packed Cerfoam media offers more open area for high resistance to particulate fouling."

 " Equipment manufactured and pre assembled in AES'

40,000 ft2 manufacturing facility."

 "` Flameless' systems generate little or no NOx emissions.

There is no ` flame' during normal operation." 3 Adwest Technologies,

Inc. 1175 North Van Horne Way Anaheim, CA 92806

2506 714 632 9801 adwestusa. com No date given ( GP entry updated May 2003) APCE GP RTO  have experience putting RTO on veneer dryer; do design,

engineering, fabrication and installation of specialized RTO systems  " Since 1987, Adwest Technologies has provided over 550 RTO systems for volatile organic compound ( VOC),

hydrocarbon and hazardous air pollutants ( HAPS). Adwest's technical personnel have over 520 man years of cumulative thermal oxidizer and VOC abatements sales, design,

applica tion, controls, fabrication, and installation experience. Single Source Turnkey RTO Installation:

Adwest provides initial application selection, system layout, design engineering, electrical design, project management, inhouse RTO fabrica tion, on time shipment through onsite system installation, RTO startup and commissioning. We can provide ground, rooftop,

mezzanine or platform mounting, indoors or outside in cold or warm weather climates." 3 Table 2, continued Company Contacta Last Website Updateb Sourcec Products of Interestd Additional Informatione Vendor qualityf 6 Allied Blower & Sheet Metal Ltd. 12224 103A Ave.

Surrey, BC Canada 604 930 7000 alliedblower. com No date given ( listed in PW 2003 directory and online directories  also had a convention booth in March 2003) PW TO and biofiltration  Established 1974  specializes in pneumatic conveying,

removing dust and residues, and air handling equipment  " Gas and VOC Cleaning Systems: Gas laden air, such as press exhaust and dryer gases, must be cleaned. Working closely with Geoenergy, a U. S. based engineering technology company, Allied supplies and installs electrostatic precipitators thermal oxidizers and bio filtration units to meet environmental requirements."

** Unclear if Allied Blower is still working with Geoenergy since the company went bankrupt and then restarted 1 ( b/ c of unknown situation w/ Geoenergy

Baxter Air Engineering 12625 NE Woodinville Dr. Woodinville, WA 98072 8722 425 486 6666 baxair. com Oct. 6,

2003 PW TO, incineration and after burner systems  Established 1979; appear to handle sales for manufacturers of filters and blowers  " Baxter Air Engineering has been in business for over 20 years, with over 50 years of combined air handling experience."

 Process Combustion Control is one manufacturer that Baxter represents  see separate entry NR  not an APCD designer Table 2, continued Company Contacta Last Website Updateb Sourcec Products of Interestd Additional Informatione Vendor qualityf 7 Callidus Technologies ( CB& I Callidus) 7130 T S. Lewis Ave.,

Suite 335 Tulsa, OK 74136 5488 cbiepc. com/ cbi callidus No date given ( exhibitor in June 2003;

CB& I press releases found from Nov. 2003) RTI Variety of TO types, CO  One Callidus TO found in MACT General Survey  Fume Thermal Oxidizers: " Destruction efficiency can range from 90 to 99 percent. Because they contain very little organics, a preheat exchanger downstream of the oxidizer is used to reduce fuel consumption by preheating the incoming fume stream. A catalytic incinerator may be used if the or ganic level is fairly low and the fume stream is free from dust or any substance poisonous to the catalyst."

 Professionally affiliated with Engineered Wood Research Foundation & Particleboard Medium Density Fiberboard Institute 2  seem to specialize in NOx controls CECO Environmental  CECO Abatement Systems Division 5201 Walnut Ave., Ste 1 Downers Grove, IL 60515 630 493 0624 cecoenviro. com/ cecoabat ement. html No date given ( press release from Nov.

4, 2003 found) APCE RTO, RCO,

TO, CO  CECO Abatement is the " latest edition to the CECO Environmental family."

 Has experience with wood products industry, particularly MDF and OSB plants  " CECO Environmental Corp. is North America's largest independent air pollution control company. Through its five subsidiaries, CECO provides a wide spectrum of air quality services and products." ( From www. cecofilters. com/ ip20030505A. html) 3 Table 2, continued Company Contacta Last Website Updateb Sourcec Products of Interestd Additional Informatione Vendor qualityf 8 Crawford Industrial Group ( CIG) 9101 Parkers Landing Orlando, FL 23825 1 800 228 0884 crawfordequipment. com For additional information, please contact: Rick Reimlinger July 2,

2003 PW TO, Thermal Recuperative Oxidizers,

RTO, CO  PW Mar 2003, Supply Lines, p. 45: " The technologies offered by CIG are designed, manufactured, and tested at its Orlando fabrication facility. In December 2001,

HillStreet Capital purchased the assets of Crawford Equipment and Engineering Co., founded in 1977, and Steadman Fabrica tors, forming Crawford Industrial Group LLC... CIG has also added a number of experienced professionals to strengthen its position in the air pollution control products market... These new employees came from Geoenergy International Corp. following its closure."

( No confirmation on CIG's website)

 " At Crawford Industrial Group we specialize in building from the ground up an abatement system that will not only satisfy the new EPA regulations but will comply with your companies financial needs as well." 3 Table 2, continued Company Contacta Last Website Updateb Sourcec Products of Interestd Additional Informatione Vendor qualityf 9 CTP Air Pollution Control Schmiedlstrasse 10 A 8042 Graz Austria 43 316 4101 ctp. at No date given ( attending conference in Dec.

2003) PW multiple RTO models, multiple RCO and CO models  Established 1985  " More than 17 years experience in design, erection,

commissioning and maintenance of air pollution control systems, turn key installations and components."

 " Technology: Our engineers were pioneers in several cata lytic and thermal oxidation processes... Several processes invented by CTP engineers and patented include Honey comb block technology, compact RTO, compact catalytic oxidiser, high efficient rotary concentrator adsorption in cluding regeneration, modular adsorption systems, RENOX, air to air heat exchangers for temperature up to 600

C and oxidation and reduction catalysts."

 American sales handled by McGill AirClean Corp.

probably uses CTP as a subcontractor  " Experience example: Wood Industry; Product: Particle board production; Emission source: Wood chip dryer; RTO 3 bed System, 378.000 kg/ h" NR  see McGill AirClean Table 2, continued Company Contacta Last Website Updateb Sourcec Products of Interestd Additional Informatione Vendor qualityf 10 Dürr Environmental Inc. ( DEI) 40600 Plymouth Rd.

Plymouth, MI 48170 734 459 6800 durrenvironmental. com at least May 6,

2003 ( member ICAC as of Nov. 2003) RTI,

PW ICAC all styles of TO and CO ( regenerative,

recuperative,

direct fired),

custom and standard  12 Dürr RTOs found in MACT General survey  Established 1970, over 11,000 world employees  PW Sept 2002 Ad, pp. 32 33: " Dürr Environmental supplies more air pollution control systems than any other man ufacturer because of our inherent capability to offer solution to all abatement applications."

 PW Sept. 1999, p. 26: Dürr " has a number of systems in veneer, plywood plants, and structural and decorative panel mills throughout N. America."

 With recent acquisition of Process Emission Systems of Engelhard Corp. and REECO, expertise has expanded to " nearly every aspect of emission control for all major indus tries"  just moved into 35,000 sq. ft. facility that houses " design, engineering, field support, project management, marketing, sales, and administrative functions staffs."

 Provides support for Dürr, REECO, and Salem Engelhard systems 3  claims to be largest vendor E & E Services Inc. 710 Ridge Rd.

Lyndhurst, NJ 07071

3224 201 460 4940 epluseservices. com No date given ( listed in PW 2003 directory) PW Service & maintenance of burners, RTO,

TO, CO " E + E Services provides New Systems, Upgrades,

Maintenance and Services for all types of Air Pollution Control Equipment. We're the only company servicing all oxidizers: Catalytic, Regenerative, and Thermal."

Perform maintenance checks, fix problems, install new catalysts, move equipment, upgrade equipment  Have new units, have to contact company for details 1.5  sounds better for service than for new units Table 2, continued Company Contacta Last Website Updateb Sourcec Products of Interestd Additional Informatione Vendor qualityf 11 EISENMANN Corporation 150 Dartmoor Dr.

Crystal Lake, IL 60014

8799 815 455 4100 eisenmann. de/ englisch/ No date given ( planned to appear at trade show May 13,

2003) PW RTO, Recuperative thermal oxidizers, CO,

Rotary concentrators  PanelWorld Jan 2003 Directory/ Buyers' Guide, pp. 23,

41: Established 1951; " EISENMANN originated the ` Valveless' Regenerative Thermal Oxidizer ( VRTO) which offers continuous compliance, a 24/ 7/ 365 service guarantee, and lowest cost of ownership for all VOC abatement needs. The VRTO C, their newest technology,

is a pre assembled, skid mounted design."

 " EISENMANN is one of the world's leading suppliers for surface finishing systems, material flow automation,

environmental technology, and ceramics firing technology.

The company was founded in 1951 and was initially involved in the areas of wood drying systems and paint lines.

EISENMANN has a total of about 2800 employees worldwide and more than half of these are engineers in the fields of planning, project management, design, and control engineering. "

 " RTO  Energy efficient purification in a single vessel with a patented rotary distributor. Recuperative thermal oxida tion  Durable technology with integrated heat recovery. Catalytic oxidation  Systems with standard or custom catalysts. Rotary concentrators  provided with solvent recovery or thermal treatment." 2.5  company is very diverse control technology one of many product lines Table 2, continued Company Contacta Last Website Updateb Sourcec Products of Interestd Additional Informatione Vendor qualityf 12 Engelhard Corp. 101 Wood Ave. S.

Iselin, NJ 08830 0770 1 800 631 9505 engelhard. com May 2002 ( press releases found from Nov. 18,

2003)

( member ICAC as of Nov. 2003) RTI PW RCO  One Engelhard RCO found in MACT General Survey  " Engelhard has long been a leader in the development of highly active, robust and selective catalysts and related tech nologies for the destruction of volatile organic compounds ( VOCs). While there are a number of methods to abate VOC emissions, catalytic incineration has become a leading choice because it can be more versatile and economical that other approaches. Our VOCat ® catalysts control emissions of hydrocarbons ( HCs) and other volatile organic com pounds ( VOCs) from a wide variety of industrial processes, including chemical processes, paint systems, food proces sing, printing, electronics, and soil and groundwater cleanup systems. Engelhard also offers RCA rotor concentrators, which allow users to reduce the capital and operating cost of removing VOCs from dilute,

high volume air streams." 1.5  primaril y catalytic media vendor Epcon Industrial Systems, Inc. P. O. Box 7060 The Woodlands, TX 77387 1 800 447 7872 epconind. com June 22,

2003 ( member ICAC as of Nov. 2003) ICAC Thermal oxidizers: afterburners, recuperative,

catalytic, regenerative,

heat exchange systems Est. 1976, supplied over 1,300 systems, does own manufacturing serves wood panel manufacturing, composite materials pulp and paper, and wood processing industries;

wood furniture manufacturing; " offers a full range of oxidizers for emission control with both recuperative and regenerative systems. The recuperative oxidizers can be thermal or catalytic. The heat exchanger is a major component of the oxidizer systems. Its proper function is essential for efficient operation. All welds are thoroughly tested by visual and dye penetrant inspections." 2 Table 2, continued Company Contacta Last Website Updateb Sourcec Products of Interestd Additional Informatione Vendor qualityf 13 Geoenergy International Corp. A. H. Lundberg Associates, Inc.

13201 Bel Red Road Bellevue, WA 98005 425 283 5070 can access website via lundbergassociates. com or geoenergy. com 2003 RTI PW RTO, RCO  1 Geoenergy RTO found in MACT General Survey  Clients included Hardel Mutual Plywood, Trus Joist MacMillan, & Willamette ( for controls to meet consent decree) when open  PW ads: started w/ full page, diff. full page May 01,

changed to half page May 02, last ad appeared July 02  PW July 2003  A. H. Lundberg Associates in Bellevue,

WA, " leader in industrial process and environmental technology bought Geoenergy property in December 2002,

hired founders S. Jaasund & G. Raemhild along with other key engineers  full page add in PW  Same Geoenergy products provided by new company,

including GeoTherm RTO, GeoCat RCO, and E Tube WESP  PW Nov. 2003  Geoenergy's bankruptcy due to lawsuit with former employee, not because the company itself was failing  projects that were in progress at time of bankruptcy were all completed  dealing with the same customers now that they did before  claim products are capable of meeting MACT standards 0 when closed 2.5 currently Table 2, continued Company Contacta Last Website Updateb Sourcec Products of Interestd Additional Informatione Vendor qualityf 14 Huntington Environmental Systems ( HES) 707C W. Algonquin Rd.

Arlington Heights, IL 60005 847 545 8800 huntington1. com 2000 ( member ICAC as of Nov. 2003) RTI PW ICAC RTO, RCO,

ECONABATOR ® Catalytic Oxidation for HAP and other VOCs  6 HES RTO and 1 RCO in MACT General Survey  PanelWorld Sept. 1998, p. 55: makes an RTO without the traditional heat exchanger, 2003 BD: est 1975  " HES is a wholly owned subsidiary of MPM Technologies, Inc. in Spokane, WA. Over the past thirty years, Huntington Environmental Systems has had an enviable reputation for engineering expertise, quality products, and service. Emis sion control equipment goes through constant development. Industry leaders like HES continue to push the state of the art with new and upgraded models. Huntington nurtures their relationships by offering start up supervision, custom ized maintenance contracts,

and emergency service at night or on weekends." 3 Lantec Products, Inc 5302 Derry Ave, # G Agoura Hills, CA 91301 818 707 2285 www. lantecp. com No date given ( exhibition in Oct.

2003, case study from 2003) PW media for RTO and RCO  PW Sept. 01 p. 17  makes Multi Layer Media ( MLM)

used in RTO & retrofits  constructed using chemical porcelain available in 3 densities, reduces pressure drop and plugging. " MLM has also passed a nearly 2 year test in an RTO canister at an oriented strand board plant. Dryer exhaust passed through a well maintained cyclone and wet ESP... The MLM 200 bed showed a pressure drop of 9"

initially, which increased to 12 13" before washing  vs.

20" initially and 30" before washing when the same canister had been packed with saddles."

 Also make ceramic saddles for VOC removal in RTOs,

available in 5 sizes; and catalyst substrates for RCOs NR  media only Table 2, continued Company Contacta Last Website Updateb Sourcec Products of Interestd Additional Informatione Vendor qualityf 15 McGill AirClean 1779 Refugee Rd.

Columbus, OH 43207

2119 614 443 0192 mcgillairclean. com 2003 ( member ICAC as of Nov. 2003,

attended Chem Show in Nov. 2003) RTI PW GP ICAC RTO  new and used units  2 McGill RTO found in MACT General Survey  Subsidiary of United McGill; United McGill est. 1951,

McGill AirClean open over 30 years  " Mobile RTO Testing  We can use one of our mobile RTOs to test emissions at your facility and demonstrate the effectiveness of our technology. Those tests will allow us to gather the data needed to size a full scale RTO to solve your VOC problem economically. Construction  As part of our complete turnkey service, we handle all the construction work involved with our air pollution control systems. We have extensive experience with large air pollution control projects. Our field engineers can remain on site after the air pollution control system has been installed to instruct your personnel in starting, testing,

operating, and maintaining the equipment. We can work with you to monitor the perfor mance of the system."

 Customers include Champion, Georgia Pacific, James River Paper, International Paper, Louisiana Pacific,

Temple Island, and Weyerhaeuser Company/ Willamette Industries 3 Table 2, continued Company Contacta Last Website Updateb Sourcec Products of Interestd Additional Informatione Vendor qualityf 16 MEGTEC Sys. Box 5030 De Pere, WI 54115 5030 920 336 5715 megtec. com Nov 18,

2003 ( based on Careers section)

( member ICAC as of Nov. 2003) PW ICAC catalytic incineration controls,

various RTO models, several recuperative thermal oxidizer models  Established 1969  " MEGTEC was formed in 1997 through the merger of MEG with TEC Systems. Our skill base has since been enhanced through the licensing of zero speed splicer technology from Butler Automatic and the acquisition of Thermo Wisconsin, AMAL/ Enkel and the air emission control division of Wolverine Corporation. The industries we serve have, in no small part, been defined by the capabilities MEGTEC and its predecessors developed. No other supplier offers as complete a selection of VOC oxidation technologies as MEGTEC. With more than 2,000 installations worldwide, we have both the industry experience and regulatory knowledge to design the optimum solution for you." 3 Table 2, continued Company Contacta Last Website Updateb Sourcec Products of Interestd Additional Informatione Vendor qualityf 17 Pro Environmental ( PEI) 10134 6th St. Ste K Rancho Cucamonga, CA 91730 909 989 3010 pro env. com July 2003 ( based on Industry News section) PW RTO, RCO,

TCO ( dual mode operating capability),

recup. and direct fired oxidizers,

capture systems,

catalyst retrofits, secondary heat recovery,

single can oxidizer, packaged TO,

PTE  M E C subsidiary, only a few years old  " Pro Environmental, Inc., has acquired the ownership of the Smith Engineering intellectual properties. Smith Engineering whose doors closed in August 2001, was a company specializing in air pollution abatement systems.

Through its ownership of this intellectual property, PEI has full ac cess to, and the right to use, all existing Smith designs and drawings, domestic and foreign patents, and trademarks. In cluded in the property are all Smith contract files containing the details of Smith's installations  which number over 2,000. PEI, a full service company, is positioned to support the users of Smith equipment. PEI can provide supply spare parts, maintenance and service,

repair and upgrade of the existing equipment, as well as the design and supply of new systems."

 Commissioned by Boise Cascade Corporation ( BCC) in July 2003 to add TCO to Elgin plywood and RTO to La Grande PB  Elgin installation part of consent decree; BCC switched from Geoenergy to PEI to cover their consent decree when Geoenergy went out of business. 3 Table 2, continued Company Contacta Last Website Updateb Sourcec Products of Interestd Additional Informatione Vendor qualityf 18 Process Combustion Control ( PCC) 5460 Horning Road Pittsburgh, PA 15236

2822 412 655 0955 www. pcc sterling. com No date given ( attended a conference May 13,

2003) RTI PW TO  PW Jul 98 p. 26: PCC supplied 1 TO to Willamette Malvern MDF  same one in MACT survey  Established 1969; " While we are the market leader in cus tom designed combustion systems and products such as ther mal oxidizers and air heaters, our expertise also includes ad vanced low emission systems, multi staged low NOx incin eration, high intensity combustion and many other purpose engineered applications to meet our customers' unique re quirements. PCC has in house conceptual and detailed de sign capabilities fully supported by testing facil ities. With over 1,000 major installations worldwide and the ability to draw on a wide range of products and technologies from our parent and licensor companies, our customers are assured of receiving the most reliable and proven systems available in the industry." 2 Regenerative Environmental Equipment Co. ( REECO) RTI 16 REECO RTO found in MACT General Survey closed, bought by Dürr Ross Air Systems PO Box 310 Somerville, NJ 08876

0310 732 356 4555 rossairsystems. com No date given ( reps attended Fall 2003 NCCA meeting) PW RTO ( 5 can, 3

can, double can, single can), catalytic thermal oxidizers  PW Sept. 1998, p. 66: makes an RTO with a purging system  " Ross Air Systems has been designing and installing systems to control emissions from ovens, dryers, coaters,

roast ers and similar emitters of VOC's for over 30 years.

Today, Ross Thermal Oxidizers are among the most efficient con trol systems available."

 One client is International Paper 2 Table 2, continued Company Contacta Last Website Updateb Sourcec Products of Interestd Additional Informatione Vendor qualityf 19 Salem Engelhard RTI  Dürr's website is a little misleading about whether they ac quired Salem Engelhard or Engelhard Corp.  in one place they say they bought REECO and Engelhard, but the site says elsewhere that they provide service for Salem Engel hard systems  Engelhard Corp. still exists as a separate company, Salem Engelhard is the company that Dürr bought  2 SE RTO and 6 RCO found in MACT General Survey bought by Dürr Smith Engineering Co. RTI PW  35 Smith RTO and 1 TCO found in MACT General Survey  Acquired by PEI, former customers include G P, Temple

Inland, Hood Industries, multiple others  PanelWorld Sept. 1998, p. 56: built first RTO on hardboard press in 1991  PanelWorld Sept. 1999, p. 22: used Sud Chemie Prototech's PRO* RCO catalyst on a TCO installed at G P OSB in Brookneal, VA  operates as RTO or RCO closed, bought by PEI Thermal Engineering Corp. Box 868 Columbia, SC 29202

0868 1 800 331 0097 tecinfrared. com No date given PW  Established 1961  Website focuses on infrared heating for grills and other applications  mentions industrial equipment, but no details 0.5 Table 2, continued Company Contacta Last Website Updateb Sourcec Products of Interestd Additional Informatione Vendor qualityf 20 Western Pneumatics Box 21340 Eugene, OR 97402 0452 541 461 2600 westernp. com No date given ( listed in several directories,

incl. PW and online lists, some updated Nov 2003) PW GP RTO, RCO,

Thermal oxidizers,

VOC/ HAP capture &

collection systems  Established 1982  PW Sept. 1998, p. 63: has installed press enclosures for G P and Willamette  " The company would prefer to help the RTO designers/ manufacturers with their designs and installation strategies."

 " Western Pneumatics Environmental, a Division of Western Pneumatics, Inc., one single source for your complete air pollution control system, including Engineering studies, RTOs, RCOs, Thermal Oxidizers, WESPs, VOC/

HAP Capture & Collection Systems, installation, start up and service. Our engineering staff has over a century of direct RTO, RCO, and WESP technology design,

application and installation... Western Pneumatics Environmental offers unparalleled design competence, project management, engineering, manufacturing, quality control,

safety, installa tion, and start up under one roof. Western Pneumatics Environmental will continue to offer aroundthe clock manufacturing capabilities for quick parts orders and 24 hour technical service through its service technicians located throughout the United States."

 Western Pneumatics Environmental Services ( WPES), a division of Western Pneumatics Install, Inc., does troubleshooting of existing environmental systems, repair and replacement of environmental equipment, as well as the startup of new equipment  can provide 24 hour 7 days a week service to support urgent needs by phone or modem, or a service technician can be on site usually within 24 hrs. 3 Table 2, continued Company Contacta Last Website Updateb Sourcec Products of Interestd Additional Informatione Vendor qualityf 21 Wheelabrator 441 Smithfield Street Pittsburgh, PA 15222

2292 412 562 7300 wapc. com 2003 ( member ICAC as of Nov. 2003) RTI GP no incinerationbased controls found on site 4 Wheelabrator RTO found in MACT General Survey still exists, but they seem to be focusing mainly mist eliminators, ESP, scrubbers, and SCR, not on incinerationbased controls 0.5 a All web addresses follow " http:// www." For example, the full web address for Advanced Environmental Systems, Inc., is http:// www. aesinc. com.

b Website update noted in an attempt to determine which companies are still operating. Those that have recently updated their website are likely still in business. A listing in one or more current directories does not necessarily indicate that a company is still operating; if a date for the last update was found, it is listed.

c Source codes: PW: Panel World RTI: Listed as an APCD vendor in MACT survey APCE: Air Pollution Control Equipment directory GP: Green Pages  The Global Directory for Environmental Technology ICAC  Institute of Clean Air Companies d Abbreviations for control devices:

RTO= regenerative thermal oxidizer RCO = regenerative catalytic oxidizer TO = thermal oxidizer, CO = catalytic oxidizer TCO = thermal catalytic oxidizer PTE = permanent total enclosure e Quotes and information from company websites unless otherwise cited.

f Vendor quality rating system:

3 = vendor with PCWP industry experience and the capability to handle multiple APCD orders simultaneously 2 = vendor with smaller capacity or less experience with PCWP industry 1 = minor vendor capable of supplying a minimal number of APCD at one time 0 = no APCD manufactured NR = not rated 22 Table 3. Air Pollution Control Device Vendors with Little or No PCWP Industry Experience Company Contacta Last Website Updateb Sourcec Products of Interestd Additional Informatione Vendor qualityf Air Preheater Company P. O. Box 372 3020 Truax Rd.

Wellsville, NY 14895

0372 1 800 828 0444 airpreheatercompany. com Sept. 18,

2003 APCE RTO, Direct

Flame Recuperative Oxidizer,

Catalytic Recuperative Oxidizer  " The Air Preheater Company has been the world leader in heat recovery equipment and technology for over 75 years."

 Manufacturing facilities in Concordia, Kansas, and Wellsville, New York 2 Alliance Corporation 1014 East South Street,

Unit " B" Anaheim, CA 92805 714 563 3131 alliancecorp. com No date given ( entry updated by GP Oct. 29,

2002; several online directories) GP RTO ( 2 & 3 bed models)  Founded as oxidizer service company, it became " clear that end users were suffering from neglect by their original equipment manufacturers. Though Alliance has since evolved into a manufacturer at the urging of our customers we have remained and will always remain a service company."

 " Every oxidizer we build is tailored to the specific air pollution control needs of your process and facility. Our oxidizer designs have been proven in both domestic and international market places. Alliance Corporation is a low profile company dedicated to building the best RTOs in the industry. While others might go to great lengths and overhead burden to promote their companies through ad vertising, trade shows, etc., we have chosen instead to quietly focus on our products and service and to rely primarily on referrals as our source of business. While our approach may not encourage the most rapid growth, it does ensure that we maintain an outstanding reputation with our steadily growing customer base by offering exceptional value." 2.5 Table 3, continued Company Contacta Last Website Updateb Sourcec Products of Interestd Additional Informatione Vendor qualityf 23 American Environmenta l International,

Inc. 725 West University Dr.

Arlinton Heights, IL 60004 847 342 8600 aei inc. com No date given ( in several current online directories) APCE Direct Flame Thermal Incineration, CO  Established 1981, " American Environmental International Inc. ( AEI) is fast becoming the premier environmental control and resource recovery equipment supplier to industrial markets."

 " With 99%+ control efficiency, thermal incinerator is guaranteed in writing to comply with the most stringent regulations anywhere in the world. With state of the art temperature controller, combined with the highest quality flame safety equipment, it will run dependably and with virtually no maintenance."

 " The exclusive engineering features of the high efficien cy ` Traveling Bed Filter' and the high performance heat exchanger in the catalytic oxidizers have been proven in over a hundred installations of thermal incineration units, carbon bed adsorption units and condenser/ filter units where they have been in use for a number of years. We use the ADCAT catalyst manufactured by Advanced Cat alyst Systems, Inc.

( ASC), a New Jersey corporation. AEI and ACS bring together over a 100 years of experience in catalytic engineering and pollution control technology for a major advancement in VOC control technology." 2 Table 3, continued Company Contacta Last Website Updateb Sourcec Products of Interestd Additional Informatione Vendor qualityf 24 Anguil Environmenta l Systems,

Inc. 8855 N. 55th Street Milwaukee, WI 53223 414 365 6400 anguil. com 2002 ( member ICAC as of Nov. 2003) APCE GP ICAC Catalytic Recuperative Oxidizer,

Thermal Recuperative Oxidizer, Rotor Concentrator/

Oxidizer, RTO,

RCO, Refurbished/

Used Equipment  Established 1978  U. S. Chamber of Commerce " Blue Chip" award winner:

" One of the best managed companies in America"

 " Anguil is a fiscally sound industry leader with over 1200 successful installations. Anguil is not a division of a large corporation, unlike most competitors. This allows us to tailor a solution to meet your exact regulatory require ments; it allows us to develop turnkey, single source re sponsibility; and it provides an unbiased equipment choice that results in the highest compliance at the lowest price for our customer. Anguil's professional staff of engineers and agents hails from a broad range of industries giving them first hand knowledge of your particular process. Anguil strives to provide innovative pollution control technology including process analysis, engineering, equip ment manufacturing, installation and post sale 24 hour service."

" The Anguil Rotor Concentrator/ Oxidizer is designed to adsorb Volatile Organic Compounds ( VOCs) from a high volume, low concentration airstream and to oxidize the VOCs in a reduced volume, high concentration process stream. The high volume airstream is passed through a rotor concentrator wheel where the VOCs are adsorbed in the bed, purifying the high volume air. This high volume air is then exhausted to atmosphere. The concentrator wheel rotates continuously, transporting adsorbed VOCs into a desorption section. This low volume, high VOCladen air is then processed by an oxidizer. The operational cost of the oxidizer is substantially reduced via this con centration process." 2.5, could be 3 except for lack of experience with this industry Table 3, continued Company Contacta Last Website Updateb Sourcec Products of Interestd Additional Informatione Vendor qualityf 25 Catalytic Products International 980 Ensell Road Lake Zurich, IL 60047

1557 847.438.0334 cpilink. com No date given ( on a list of exhibitors updated Nov. 11,

2003) APCE CO, TO, RTO,

other catalystbased controls " Catalytic Products International, Inc. ( CPI) was founded in 1967 as a precious metal catalyst supplier. CPI developed 14 patents for various precious metal catalysts.

Armed with a firm background in process chemistry and system mechanics, CPI evolved into a worldwide leader in the supply of high quality air pollution control systems." 2.5 The CMM Group, LLC P. O. Box 5903 2071 C Lawrence Drive De Pere, WI 54115 5903 920 336 9800 thecmmgroup. com Feb 8, 2002 ( article by employee published Feb 1,

2003) APCE CO, RTO, Recuperative Thermal Oxidizers  " The CMM Group   does not offer pre designed `

standard equipment that you must try to adapt into your operation. Instead, we utilize our knowledge and experience to provide custom designed air pollution control systems and industrial web dryers that are best suited to fulfill your needs."

 Details & diagrams of each type of control device 2 ComEnCo Systems Inc. 60 Pippin Rd. Unit 46 Concord, Ontario CANADA L4K 4M8 905 738 6118 comenco. com No date given ( exhibitor in Oct.

2003) APCE GP Packaged CO and TO Oxidizers the first equipment category listed and the only one described in detail, but no experience with plywood industry. 1.5 Table 3, continued Company Contacta Last Website Updateb Sourcec Products of Interestd Additional Informatione Vendor qualityf 26 Cycle Therm Inc. 123 South Third St.

Allentown, PA 18108 610 432 9490 cycletherm. com 2001 ( GP entry updated May 12,

2002, exhibition in Oct.

2003) GP RTO  Founded in 1995 by its president, Richard Greco. " Mr.

Greco has been designing thermal oxidizers since 1965 with emphasis in RTO design since 1978. Founder and former president of Huntington Energy Systems, Mr.

Greco has published numerous papers and articles dealing with RTO design and interfaceholds. In addition,

Mr. Greco currently holds 7 U. S. and foreign patents pertain ing to Regenerative Thermal Oxidizers which have been applied worldwide to over 200 RTO system applications."

 RTO specialty engineers have over 40 years of application experience, "... fabrication done by certified welders with 200 RTO unit experience." 1.5 Glenro Inc. 39 McBride Ave.

Paterson, NJ 07501 1799 glenro. com Aug. 2003 APCE RTO, recuperative thermal oxidizers, and recuperative catalytic oxidizers  " Effective use of primary and secondary heat recovery has resulted in oxidizers that operate with high energy efficiency, while requiring a comparatively low capital investment."

 Make a lot of other products, including infrared heaters,

ovens, dryers, etc. 1.5 Johnson Matthey, Catalytic Systems Division ( Corp. HQ)

460 East Swedesford Road Wayne PA 19087 610 971 3114 Contact: Kathy Bynum jmcsd. com Nov. 2003 ( member ICAC as of Nov. 2003) ICAC RCO  " Johnson Matthey is a specialty chemicals company focused on its core skills in catalysts and precious metals.

It is organized into four operating divisions: Catalyst &

Chemicals, Pharmaceutical Materials, Precious Metals and Colours & Coatings."

 Mentions wood / paper / fiber as an industry that can benefit from RCO 1 Table 3, continued Company Contacta Last Website Updateb Sourcec Products of Interestd Additional Informatione Vendor qualityf 27 Monsanto Enviro Chem Systems, Inc. 14522 South Outer Forty Road St. Louis, MO 63017 314 275 5700 enviro chem. com/ default.

html 2000 ( GP entry updated May 7,

2003)

( Sept. 2003 technical brief found) APCE GP 1 RCO model  Has existed for " over 75 years, with over 800 plants built in 56 countries around the world."

 " Two chamber design, high destruction efficiency with patented purge system, extremely reliable poppet type switching valves, fully automatic operation." 1 NAO Inc. 1284 East Sedgley Ave.

Philadelphia, PA. 19134 nao. com July 22,

2002 ( listed in numerous current directories,

registered as a TankFarm vendor as of Nov 25,

2003) APCE Incinerators, TO,

& Vapor control  Established 1912  " Unsurpassed safety plus maximum destruction removal efficiency ( DRE), no visible flame, no smoke,

no objec tionable noise, no odor, all systems designed &

manufac tured to ISO 9001 quality standards. NAO thermal oxidi zers, fume incinerators and vapor control units [ provide] ultra safe, dependable operation, minimal maintenance. Permanent installations in loading terminals, chemical/ petrochemical, pharmaceutical, pulp and paper plants, and other process industries. NAO also maintains the world's largest fleet of portable thermal oxidizers for emergency response/ backup pollution solutions" 2 Table 3, continued Company Contacta Last Website Updateb Sourcec Products of Interestd Additional Informatione Vendor qualityf 28 Süd Chemie Prototech 32 Fremont Street Needham, MA 02494 781 444 5188 scprototech. com Only date given is 2001 planning to attend conference in Dec.

2003; associate member of ICAC as of Nov. 2003) APCE RCO, various catalyst products  " Süd Chemie Prototech Inc. is a member of the Süd Chemie Group ( Munich, Germany). Long known as a leader in the development and production of environmental catalysts for air pollution control, Prototech was purchased by United Catalysts Inc.( UCI) in 1992. ( UCI is now Süd Chemie Inc.). Süd Chemie Prototech produces high quality precious metal based catalysts on a variety of catalyst supports including ceramic and metal monoliths, activated alumina spheres, saddles and reticulated foam ceramic. These catalysts are primarily used for the de struction of volatile organic compounds ( VOC's), hydro carbons, nitrogen oxides and carbon monoxide." 1.5 Table 3, continued Company Contacta Last Website Updateb Sourcec Products of Interestd Additional Informatione Vendor qualityf 29 Turner EnviroLogic,

Inc. 3439 S. W. 11th Street Deerfield Beach, FL 33442 1 800 933 8385 www. tenviro. com No date given ( listed in A& WMA 2003 Mega Buyers Guide) APCE TO, RTO ( 2+

chamber),

catalyst layer can be added Info on which type of oxidizer is appropriate for each situation, including situation in which exhaust has very low concentration of VOCs  example of thermal oxidizer installed on gasoline tanker loading facility described 2 a All web addresses follow " http:// www." For example, the full web address for Air Preheater Company is http:// www. airpreheatercompany. com.

b Website update noted in an attempt to determine which companies are still operating. Those that have recently updated their website are likely still in business. A listing in one or more current directories does not necessarily indicate that a company is still operating; if a date for the last update was found, it is listed.

c Source codes: PW: Panel World RTI: Listed as an APCD vendor in MACT survey APCE: Air Pollution Control Equipment directory GP: Green Pages  The Global Directory for Environmental Technology ICAC  Institute of Clean Air Companies d Abbreviations for control devices:

RTO= regenerative thermal oxidizer RCO = regenerative catalytic oxidizer TO = thermal oxidizer, CO = catalytic oxidizer TCO = thermal catalytic oxidizer PTE = permanent total enclosure e Quotes and information from company websites unless otherwise cited.

f Vendor quality rating system:

2.5 = top quality vendor for industries served, no experience with PCWP industry ( maximum rating for this category)

2 = vendor with smaller capacity 1 = minor vendor capable of supplying a minimal number of APCD at one time 0 = no APCD manufactured Table 3, continued 30


[Federal Register Volume 87, Number 67 (Thursday, April 7, 2022)]
[Notices]
[Page 20400]
[FR Doc No: 2022-07431]

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DEPARTMENT OF ENERGY

Federal Energy Regulatory Commission

[Docket No. ER22-1505-000]

WEB Silver Maple Wind, LLC; Supplemental Notice That Initial
Market-Based Rate Filing Includes Request for Blanket Section 204
Authorization

    This is a supplemental notice in the above-referenced proceeding of
WEB Silver Maple Wind, LLC's application for market-based rate
authority, with an accompanying rate tariff, noting that such
application includes a request for blanket authorization, under 18 CFR
part 34, of future issuances of securities and assumptions of
liability.
    Any person desiring to intervene or to protest should file with the
Federal Energy Regulatory Commission, 888 First Street NE, Washington,
DC 20426, in accordance with Rules 211 and 214 of the Commission's
Rules of Practice and Procedure (18 CFR 385.211 and 385.214). Anyone
filing a motion to intervene or protest must serve a copy of that
document on the Applicant.
    Notice is hereby given that the deadline for filing protests with
regard to the applicant's request for blanket authorization, under 18
CFR part 34, of future issuances of securities and assumptions of
liability, is April 21, 2022.
    The Commission encourages electronic submission of protests and
interventions in lieu of paper, using the FERC Online links at http://www.ferc.gov. To facilitate electronic service, persons with internet
access who will eFile a document and/or be listed as a contact for an
intervenor must create and validate an eRegistration account using the
eRegistration link. Select the eFiling link to log on and submit the
intervention or protests.
    Persons unable to file electronically may mail similar pleadings to
the Federal Energy Regulatory Commission, 888 First Street NE,
Washington, DC 20426. Hand delivered submissions in docketed
proceedings should be delivered to Health and Human Services, 12225
Wilkins Avenue, Rockville, Maryland 20852.
    In addition to publishing the full text of this document in the
Federal Register, the Commission provides all interested persons an
opportunity to view and/or print the contents of this document via the
internet through the Commission's Home Page (http://www.ferc.gov) using
the ``eLibrary'' link. Enter the docket number excluding the last three
digits in the docket number field to access the document. At this time,
the Commission has suspended access to the Commission's Public
Reference Room, due to the proclamation declaring a National Emergency
concerning the Novel Coronavirus Disease (COVID-19), issued by the
President on March 13, 2020. For assistance, contact the Federal Energy
Regulatory Commission at [email protected] or call toll-free,
(886) 208-3676 or TYY,<PHONE_NUMBER>.

    Dated: April 1, 2022.
Debbie-Anne A. Reese,
Deputy Secretary.
[FR Doc. 2022-07431 Filed 4-6-22; 8:45 am]
BILLING CODE 6717-01-P