United States      Solid Waste and
            Environmental Protection  Emergency Response EPA/530-SW-91-061A
            Agency        (OS-312)          July 1991
&EPA     1987 National Biennial
            RCRA Hazardous
            Waste Report
            Executive Summary
                                 ==»=/

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                         EXECUTIVE SUMMARY
 The U.S. Environmental Protection Agency (EPA) collects and maintains information about the
 generation, management, and final disposition of the nation's hazardous waste regulated by
 the Resource Conservation and Recovery Act (RCRA).  This Report presents information for
 1987.  Data from a total of 18,660 RCRA hazardous waste sites are included in this report. Of
 these, 17,677 were generators and 3,308 were treatment, storage or disposal facilities.  Most
 sites that are treatment, storage or disposal facilities are also classified as generators.

 RCRA HAZARDOUS WASTE GENERATION

 In 1987, a total of 17,677 large quantity generators generated  approximately 238 million tons of
 RCRA hazardous waste.1   A small number of  sites accounted  for most of the quantity
 generated. The 5 largest hazardous waste generators reported more than 57 percent of the
 total generation, while the 50 largest generators reported more than 90 percent of the total.
 Only 2 percent of the sites generated more than 10,000 tons of hazardous waste, accounting
 for roughly 98 percent of the total  U.S. RCRA hazardous waste  generation. Conversely, 70
 percent of the  sites generated 100 tons or less of RCRA  hazardous waste, cumulatively
 accounting for  only  0.1 percent of the nationwide generation.  Most of the  largest RCRA
 hazardous waste generators are in the manufacturing  sector, chiefly chemicals manufacturing
 and oil refining.  These sites commonly generate large  quantities  of RCRA  hazardous
 wastewater.

 The 4 largest hazardous waste generating States 2 (Texas, New Jersey, Georgia, and Virginia)
 accounted for nearly 75 percent of the total generation. On the other hand, 23 States reported
 a  Statewide generation of less than  100 thousand tons each  (11 of which  are  below 10
 thousand  tons), collectively accounting for  only 0.2 percent of the  nationwide  generation
 (Exhibit 1).
1This quantity represents RCRA hazardous wastes that were subsequently managed in units subject to RCRA
 permitting requirements.  RCRA hazardous wastes that were managed exclusively in units exempt from RCRA
 permitting requirements are excluded from this report. See Chapter 2 for a more detailed discussion.

2'State* refers to the 50 States, District of Columbia, Guam, Puerto Rico, and Virgin Islands. For ease of reading, these
 may be referred to as "54 States."

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1987 National Biennial RCRA Hazardous Waste Report
EXHIBIT 1.   RANK ORDERING OF STATES BASED ON QUANTITY OF RCRA HAZARDOUS WASTE
           GENERATED, AND NUMBER OF HAZARDOUS WASTE GENERATORS, 1987



Rank
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54



State
TEXAS
NEW JERSEY
GEORGIA
VIRGINIA
WEST VIRGINIA
LOUISIANA
KENTUCKY
SOUTH CAROLINA
CALIFORNIA
OHIO
ALABAMA
MICHIGAN
ILLINOIS
INDIANA
MISSISSIPPI
KANSAS
OKLAHOMA
NORTH CAROLINA
TENNESSEE
NEW YORK
PENNSYLVANIA
WASHINGTON
FLORIDA
ARIZONA
ARKANSAS
UTAH
PUERTO RICO
CONNECTICUT
MISSOURI
WISCONSIN
COLORADO
MASSACHUSETTS
IOWA
MARYLAND
MINNESOTA
DELAWARE
OREGON
IDAHO
NEW HAMPSHIRE
VIRGIN ISLANDS
RHODE ISLAND
NORTH DAKOTA
MAINE
NEBRASKA
VERMONT
MONTANA
NEW MEXICO
WYOMING
SOUTH DAKOTA
HAWAII
ALASKA
NEVADA
DISTRICT OF COLUMBIA
GUAM
TOTAL
Hazardous Waste Quantity
Total
Generated
(000 tons)
52,770
47,739
39,838
35.679
12,979
12,304
5,851
4,850
3,523
3,093
3,049
2,305
1,969
1,951
1,296
1,241
1.195
928
884
778
775
581
519
470
228
226
201
187
149
148
124
91
89
76
76
25
23
17
17
15
12
11
11
9
6
6
4
3
2
1
1
1
1
<0.5
238,327


Percent
22.1
20.0
16.7
15.0
5.4
5.2
2.5
2.0
1.5
1.3
1.3
1.0
0.8
0.8
0.5
0.5
0.5
0.4
0.4
0.3
0.3
0.2
0.2
0.2
0.1
0.1
0.1
0.1
0.1
0.1
0.1
<0.05
<0.05
<0.05
<0.05
<0.05
<0.05
<0.05
<0.05
<0.05
<0.05
<0.05
<0.05
<0.05
<0.05
<0.05
<0.05
<0.05
<0.05
<0.05
<0.05
<0.05
<0.05
<0.05
100.0
Hazardous Waste Generators


Rank
3
10
22
23
38
19
26
17
6
8
18
7
5
12
31
29
33
9
20
1
4
14
15
25
28
40
39
11
16
13
34
2
30
24
21
42
27
44
35
54
32
51
36
41
37
47
43
50
47
47
45
46
53
52



Number
970
643
313
311
84
366
244
404
868
708
369
859
892
522
136
144
120
666
347
2,149
894
440
419
245
172
74
77
547
405
515
112
1,025
140
260
346
47
178
25
102
1
127
12
100
69
87
14
34
13
14
14
23
19
4
8
17,677


Percent
5.5
3.6
1.8
1.8
0.5
2.1
1.4
2.3
4.9
4.0
2.1
4.9
5.0
3.0
0.8
0.8
0.7
3.8
2.0
12.2
5.1
2.5
2.4
1.4
1.0
0.4
0.4
3.1
2.3
2.9
0.6
5.8
0.8
1.5
2.0
0.3
1.0
0.1
0.6
<0.05
0.7
0.1
0.6
0.4
0.5
0.1
0.2
0.1
0.1
0.1
0.1
0.1
<0.05
<0.05
100.0

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                                                                    Executive Summary
 The number of large quantity generators was more evenly distributed across the 54 States than
 was the quantity of  hazardous  waste generated (Exhibit 1).  The 4  States with  the most
 generators (New York, Massachusetts, Texas, and Pennsylvania) account for approximately 29
 percent of the sites, while the 23 States with the fewest number of generators have about 7
 percent of the sites.

 Approximately 90 percent of the RCRA hazardous waste  was wastewater.  The predominant
 type of hazardous waste generated during 1987 was corrosive waste,3 EPA waste code D002.
 This was  primarily wastewater that was either highly acidic (pH 2.0 or below) or highly basic
 (pH 12.5 or above).  The wastewater was typically neutralized before being discharged to the
 local publicly owned treatment works (POTW) or to the surface waters.
 RCRA HAZARDOUS WASTE MANAGEMENT

 In 1987, a total of 3,308 treatment, storage, or disposal facilities reported the management of
 RCRA hazardous waste in units subject to RCRA permitting requirements. As with hazardous
 waste generation, a few sites accounted for most of the hazardous waste.  The  5  largest
 hazardous waste facilities managed more than 57 percent of RCRA hazardous waste managed,
 while the 50 largest hazardous waste management facilities accounted for more than 90
 percent. These large hazardous waste facilities typically manage hazardous wastewater that is
 generated on site.  Almost 97 percent of the hazardous waste generated is managed  on site
 while only  3  percent of the  RCRA  hazardous waste generated is shipped off site for
 management.  This suggests that no more than 3 percent of the RCRA  hazardous waste
 generated is managed in commercial treatment, storage, or disposal facilities.
3See Section 2.3 for discussion of waste codes.

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 7987 National Biennial RCRA Hazardous Waste Report
Exhibit 2 presents a listing of the States, rank ordered by the quantity of RCRA hazardous waste
managed.  The exhibit also lists the number of management facilities located in each State.
Note  that the rankings  are  very similar to those for  RCRA hazardous  waste  generation
quantities in Exhibit 1. This is because most of the hazardous waste generated is managed on
site and hence in the same State.

Every State reported at least 1 treatment, storage, or disposal facility. Nearly one-third of the
States had fewer than 10 treatment, storage or disposal facilities each, whereas only 3 States
had fewer than 10 large quantity generators.  This illustrates that the  generators of hazardous
waste are more evenly distributed across the States than are the managers of RCRA hazardous
waste.  Of the 3,308 RCRA-permitted treatment, storage, or disposal facilities in 1987, nearly
one-half had only storage units, while the other half had at least one treatment or disposal unit.

The final disposition of almost 80 percent of the RCRA hazardous waste, most of it wastewater,
was physical,  chemical, or biological treatment.  Thirteen percent of the RCRA hazardous waste
was injected into underground wells at 85 sites located in 12 States.  Again, most of this was
wastewater.  About 1 percent, or 3 million tons, of the total waste managed was disposed in
136 landfill facilities, while 0.4 percent, or 1 million tons, was managed by incineration at 305
facilities. Exhibit 3 shows the quantities of RCRA hazardous  waste  landfilled, incinerated,  or
injected into underground wells, in each State. The remainder was disposed by other methods
or recycled.

HAZARDOUS WASTE IMPORTS AND EXPORTS, BY  STATE

About 3 percent (8 million tons) of the RCRA hazardous waste generated in the United States in
1987 was shipped off site for management. Forty-six  percent of this quantity, or 4 million tons,
was transported to a different State for management,  while the remaining 54 percent, 4 million
tons, was managed in the same State in which it was generated. Exhibit 4 shows that Ohio
imported more than any other State,  roughly  486,000 tons.  Pennsylvania was the leading
exporter, sending more than 330,000 tons to other States for  management. Fourteen States
exported more than  half  of the RCRA hazardous waste generated inside their borders, while
more than half of the total quantity managed in 9 States originated elsewhere.

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                                                                 Executive Summary
 EXHIBIT 2.   RANK ORDERING OF STATES BASED ON QUANTITY OF RCRA HAZARDOUS WASTE
            MANAGED, 1987




Rank
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54




State
TEXAS
NEW JERSEY
GEORGIA
VIRGINIA
WEST VIRGINIA
LOUISIANA
KENTUCKY
SOUTH CAROLINA
CALIFORNIA
OHIO
ALABAMA
MICHIGAN
INDIANA
ILLINOIS
KANSAS
MISSISSIPPI
OKLAHOMA
NORTH CAROLINA
NEW YORK
TENNESSEE
FLORIDA
ARIZONA
PENNSYLVANIA
UTAH
WASHINGTON
PUERTO RICO
CONNECTICUT
ARKANSAS
COLORADO
MISSOURI
OREGON
WISCONSIN
IOWA
MASSACHUSETTS
IDAHO
MARYLAND
RHODE ISLAND
VIRGIN ISLANDS
NEVADA
MINNESOTA
NEBRASKA
NEW MEXICO
DELAWARE
MONTANA
WYOMING
HAWAII
NORTH DAKOTA
ALASKA
MAINE
GUAM
DISTRICT OF COLUMBIA
NEW HAMPSHIRE
SOUTH DAKOTA
VERMONT
TOTAL
RCRA Hazardous Waste
Quantity1
Total
Managed
(000 tons)
49,293
47,782
39,751
35.654
12,342
11,935
5,775
5,237
4,603
3,089
2,986
2,275
2,080
2,035
1,268
1,230
1,111
901
669
643
476
452
350
285
251
185
136
106
96
82
75
73
47
42
41
27
18
15
12
12
11
7
6
4
2
1
1
1
1
<0.5
0
0
0
0
233,476


Percent
21.1
20.5
17.0
15.3
5.3
5.1
2.5
2.2
2.0
1.3
1.3
1.0
0.9
0.9
0.5
0.5
0.5
0.4
0.3
0.3
0.2
0.2
0.1
0.1
0.1
0.1
0.1
<0.05
<0.05
<0.05
<0.05
<0.05
<0.05
<0.05
<0.05
<0.05
<0.05
<0.05
<0.05
<0.05
<0.05
<0.05
<0.05
<0.05
<0.05
<0.05
<0.05
<0.05
<0.05
<0.05
0.0
0.0
0.0
0.0
100.0
Treatment, Storage, or
Disposal Faculties


Rank
1
10
17
21
33
7
16
15
7
3
18
6
11
2
32
28
25
14
13
25
19
25
4
35
23
29
12
22
29
9
40
5
24
34
47
29
38
53
45
20
40
37
40
48
40
36
45
38
40
51
53
49
51
49



Number
670
108
60
42
24
130
64
71
130
196
52
131
103
226
26
29
34
77
79
34
51
34
193
18
38
27
94
39
27
111
8
134
37
21
6
27
9
1
7
46
8
13
8
5
8
15
7
9
8
2
1
4
2
4
3,308


Percent
20.3
3.3
1.8
1.3
0.7
3.9
1.9
2.1
3.9
5.9
1.6
4.0
3.1
6.8
0.8
0.9
1.0
2.3
2.4
1.0
1.5
1.0
5.8
0.5
1.1
0.8
2.8
12
0.8
3.4
0.2
4.1
1.1
0.6
0.2
0.8
0.3
<0.05
0.2
1.4
0.2
0.4
0.2
0.2
0.2
0.5
0.2
0.3
0.2
0.1
<0.05
0.1
0.1
0.1
100.0
1 Quantity managed only by storage is excluded.

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7987 National Biennial RCRA Hazardous Waste Report
 EXHIBIT 3.    QUANTITY OF RCRA HAZARDOUS WASTE LANDFILLED, INCINERATED, OR
             INJECTED IN UNDERGROUND WELLS, 1987



State
ALABAMA
ALASKA
ARIZONA
ARKANSAS
CALIFORNIA
COLORADO
CONNECTICUT
DELAWARE
DISTRICT OF COLUMBIA
FLORIDA
GEORGIA
GUAM
HAWAII
IDAHO
ILLINOIS
INDIANA
IOWA
KANSAS
KENTUCKY
LOUISIANA
MAINE
MARYLAND
MASSACHUSETTS
MICHIGAN
MINNESOTA
MISSISSIPPI
MISSOURI
MONTANA
NEBRASKA
NEVADA
NEW HAMPSHIRE
NEW JERSEY
NEW MEXICO
NEW YORK
NORTH CAROLINA
NORTH DAKOTA
OHIO
OKLAHOMA
OREGON
PENNSYLVANIA
PUERTO RICO
RHODE ISLAND
SOUTH CAROLINA
SOUTH DAKOTA
TENNESSEE
TEXAS
UTAH
VERMONT
VIRGIN ISLANDS
VIRGINIA
WASHINGTON
WEST VIRGINIA
WISCONSIN
WYOMING
TOTAL

Quantity
Landfilled
(tons)
318,303
66
56
769
483,840
0
2,896
0
0
0
0
0
0
24,958
210,721
451,906
5,000
0
39,621
271,430
0
0
0
282,824
0
239
336
0
0
11,804
0
174.417
0
80.427
0
0
317,592
26.378
71,817
2,498
80,276
0
137.103
0
4,240
126,476
74,037
0
0
0
3,213
0
0
5
3.203,248

Quantity
Incinerated
(tons)
4,347
0
617
18,547
101,506
36
40,699
552
0
652
2,993
0
3
14,747
40,315
76,059
2.783
2,022
46,322
105,268
0
6,054
2,181
14,251
0
0
1.753
0
0
0
0
38.272
30
29,278
12.571
1,281
87.174
816
0
70.610
459
0
25.844
0
32,709
210.844
1,606
0
0
651
160
17,392
6,954
0
1,018,358
Quantity
Injected into
Underground Wells
(tons)
0
0
0
35,967
0
0
0
0
0
411,605
0
0
0
0
646,972
402,530
0
1,212,860
13,068
9,781,726
0
0
0
362,175
0
775,543
0
0
0
0
0
0
0
0
0
0
1.419.353
1,027,134
0
0
0
0
0
0
0
13,984,949
0
0
0
0
0
0
0
0
30,073,882

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                                                                   Executive Summary
 EXHIBIT 4.    RCRA HAZARDOUS WASTE GENERATION, IMPORTS, EXPORTS, AND
             MANAGEMENT, BY STATE, 1987




State
ALABAMA
ALASKA
ARIZONA
ARKANSAS
CALIFORNIA
COLORADO
CONNECTICUT
DELAWARE
DISTRICT OF COLUMBIA
FLORIDA
GEORGIA
GUAM
HAWAII
IDAHO
ILLINOIS
INDIANA
IOWA
KANSAS
KENTUCKY
LOUISIANA
MAINE
MARYLAND
MASSACHUSETTS
MICHIGAN
MINNESOTA
MISSISSIPPI
MISSOURI
MONTANA
NEBRASKA
NEVADA
NEW HAMPSHIRE
NEW JERSEY
NEW MEXICO
NEW YORK
NORTH CAROLINA
NORTH DAKOTA
OHIO
OKLAHOMA
OREGON
PENNSYLVANIA
PUERTO RICO
RHODE ISLAND
SOUTH CAROLINA
SOUTH DAKOTA
TENNESSEE
TEXAS
UTAH
VERMONT
VIRGIN ISLANDS
VIRGINIA
WASHINGTON
WEST VIRGINIA
WISCONSIN
WYOMING
TOTAL
Hazardous Waste Quantity

Total
Generated
(000 tons)
3,049
1
470
228
3,523
124
187
25
1
519
39,838
<0.5
1
17
1,989
1,951
89
1,241
5,851
12,304
11
76
91
2,305
76
1.296
149
6
9
1
17
47,739
4
778
928
11
3,093
1.195
23
775
201
12
4,850
2
884
52,770
226
6
15
35,679
581
12,979
148
3
238,327
Imports

Amount
(000 tons)
285
0
0
52
29
2
43
<0.5
0
17
8
0
<0.5
35
241
454
5
44
85
330
0
16
18
193
12
29
61
<0.5
0
11
0
193
5
86
36
<0.5
486
42
62
222
0
15
147
<0.5
38
173
73
0
0
33
8
11
20
0
3,620
Percent of
Quantity
Managed
9.6
0.0
0.0
48.0
0.6
2.4
31.3
0.1
0.0
3.5
<0.05
0.0
0.9
85.5
11.9
21.9
10.8
3.4
1.5
2.8
0.0
60.2
42.4
8.5
102.5
2.3
74.6
0.0
0.0
96.5
0.0
0.4
72.7
12.8
4.0
9.4
15.7
3.8
82.3
63.4
0.0
81.5
2.8
-
5.8
0.4
25.6
0.0
0.0
0.1
3.4
0.1
27.1
0.0
1.6
Exports

Amount
(000 tons)
58
<0.5
20
66
225
21
83
18
1
59
85
<0.5
<0.5
3
197
165
31
16
139
157
8
72
143
183
24
97
129
1
12
1
16
151
3
123
82
11
275
26
10
333
3
17
36
2
62
232
12
6
0
42
71
39
17
1
3,584
Percent of
Quantity
Generated
1.9
24.6
4.2
28.9
6.4
17.3
44.2
73.3
101.4
11.4
0.2
24.4
29.9
15.1
10.0
8.5
35.3
1.3
2.4
1.3
73.9
94.1
157.5
7.9
31.1
7.4
86.5
15.3
136.3
81.0
92.1
0.3
79.6
15.9
8.8
96.1
8.9
2.2
43.2
42.9
1.7
134.9
0.7
116.8
7.1
0.4
5.2
94.8
0.0
0.1
12.3
0.3
11.7
40.6
1.5

Total
Managed1
(000 tons)
2,986
1
452
108
4,603
96
136
6
0
476
39,751
<0.5
1
41
2,035
2,080
47
1,268
5,775
11,935
1
27
42
2,275
12
1,230
82
4
11
12
0
47,782
7
669
901
1
3,089
1,111
75
350
185
18
5,237
0
643
49,293
285
0
15
35.654
251
12,342
73
2
233,476
1 Quantity managed only by storage is excluded.

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7987 National Biennial RCRA Hazardous Waste Report
A State is a net importer if the total imports were greater than total exports.  The largest net
importer of RCRA hazardous waste was  Indiana, with net imports of about 290,000 tons.
California was the largest net exporter, shipping about 196,000 tons more waste out of State
than it received. Sixteen States were net importers; 37 were net exporters.
WASTE MINIMIZATION

Hazardous and  Solid  Waste  Amendments (HSWA)  mandated the  collection  of  waste
minimization information from all  RCRA large quantity generators and treatment, storage, or
disposal facilities. This information was available from 7,716 sites in 37 States.  These sites
represent 42 percent of the sites that filed a hazardous waste report in 1987, and account for 20
percent of the RCRA hazardous waste generated  in the United States.  The information
presented here cannot  be considered to be representative of nationwide waste minimization
practices, but it does provide insights on activities at the sites that filed reports.

Waste minimization programs were created or expanded by 64 percent of the sites that filed
waste minimization reports.  The manufacturing industry represented 69 percent of those sites
in 1986-1987.

There were four waste minimization program components: written policies, employee training
programs, employee incentives, and waste minimization auditing. In 1987, 78 percent of the
sites that submitted waste minimization reports indicated that they had in place at least one of
the four program components.  Exhibit 5 shows the percent of sites that implemented each of
these four components.  Site-wide  or process-specific waste  minimization  audit was the
predominant waste minimization program component taking place at 63 percent of sites.
                                         8

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                                                                       Executive Summary
   EXHIBIT 5.  PERCENT OF  SITES THAT IMPLEMENTED VARIOUS COMPONENTS
               OF A WASTE  MINIMIZATION  PROGRAM.  1987

      Components
   Waste minimization
   auditing (site—wide
   or process specific)
   Employee training
   program
   Written policy
   Employee Incentives
                                                     41
                                     21
                 0       10


    Note: Multiple responses were allowed
    Reference: WMI 2,4,5
20
        30       40

           Percent
                         50
                                  60
70
Exhibit   6  shows  that  the  most  frequent   source  reduction  activity  was  better

housekeeping/better operating practices (27%).  Reformulation or redesign of a product was

the least  common (3%) source reduction approach.  Several  factors were cited by waste

minimization  reporters as  delaying  or  preventing the implementation  of source reduction

opportunities, the most frequent being technical limitations of the process (33%) and a lack of

technical information (32%), shown in Exhibit 7.

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7987 National Biennial RCRA Hazardous Waste Report
      EXHIBIT 6.  PRIMARY SOURCE REDUCTION ACTIVITIES APPLIED TO RCRA
                   HAZARDOUS WASTE MINIMIZED, 1987


      Source Reduction Activities


   Better housekeeping/better
   operating practices
   Process or procedure modifica-
   tion/substitution (including
   closed—loop recycling)


   Equipment or technology
   modification/substitution


   Modification/substitution of
   input or raw material
   Waste stream segregation
   Other source reduction activity
   Reformulation or redesign
   of product
   Reference: WMII II F
                                                25
                                               10
                             15

                          Percent
                                                                 20
                                                                          25
    EXHIBIT 7.   FACTORS DELAYING OR PREVENTING IMPLEMENTATION  OF
                  SOURCE REDUCTION OPPORTUNITIES  FOR WASTE
                  MINIMIZATION REPORTERS, 1987
      Limiting factors


  Technical limitations of
  the process
  Lack of technical
  information
  Concern that .product
  quality may decline
  Economically unfeasible
  Insufficient capital
  Other factors
  Permitting burdens
                                          30
                                     27
                                  25
                                                      20
   Note: Multiple responses
   Reference: WMI 7a-g
 5       10


allowed
                                            15     20      25

                                           Percent of respondents
35
        40
                                              10

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                                                                           Executive Summary
Exhibit  8  presents  the  most  frequently  cited  factors  that  delayed  or  prevented  the
implementation of on-site or off-site recycling opportunities.  These were economic infeasibility
(31%)  and concern that product quality might decline (27%).   Technical  limitations  of the
production process which inhibited shipment off site accounted for only 9 percent of factors

cited.


Despite these factors, 48  percent of waste minimization  projects involved some  recycling
activity.  In 1987, approximately 42 percent of sites reported identifying new opportunities for
recycling, while about 33 percent of sites implemented  them.   EPA waste codes  common
among these recycled organic wastes include D001, F001, F002, F003, and F005.
      EXHIBIT 8.  FACTORS THAT DELAYED  OR PREVENTED IMPLEMENTATION OF
                   ON-SITE OR OFF-SITE RECYCLING OPPORTUNITIES, 1987
          Percent of sites reporting
                  B     C     D     E     F     G     H
                                       Limiting Factors

  Note: Multiple responses were allowed.   Reference: WMI 9a-l
                                           LEGEND
    A.  Economically infeasible
    B.  Concern that product quality may decline
    C.  Lack of technical information
    D.  Market for materials not identified
    E.  Technical limitations of production processes
       inhibit on-site recycling
    F.  Other factors
G.  Insufficient capital
H.  Permitting burdens
I.   Lack of permitted off-site facilities
J.   Technical limitations of production processes
    inhibit shipment off site
K.   Financial liability provisions
L   Requirements to manifest wastes
                                             11

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