TECHNICAL ENVIRONMENTAL
IMPACTS
of Various Approaches for
Regulating Small Volume
Hazardous Waste Generators
PURSUANT TO THE RESOURCE CONSERVATION AND RECOVERY ACT OF 1976
VOLUME I. TECHNICAL ANALYSIS
PREPARED FOR
U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF SOLID WASTE
WASHINGTON. D.C. 20460
UNDER:
CONTRACT NO. 68-02-2613. WORK ASSIGNMENT NO. 27
AND
CONTRACT NO. 68-03-2560
WORK DIRECTIVES T-5012. T 5014 AND T-5015
DECEMBER 10. 1979
TRW
ENVIRONMENTAL ENGINEERING DIVISION
-------
TECHNICAL ENVIRONMENTAL
IMPACTS
of Various Approaches for
Regulating Small Volume
Hazardous Waste Generators
PURSUANT TO THE RESOURCE CONSERVATION AND RECOVERY ACT OF 1976
VOLUME I. TECHNICAL ANALYSIS
PREPARED FOR
U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF SOLID WASTE
WASHINGTON.D.C. 20460
UNDER:
CONTRACT NO. 68-02-2613. WORK ASSIGNMENT NO. 27
AND
CONTRACT NO. 68-03-2560
WORK DIRECTIVES T-5012, T-5014 AND T-5015
DECEMBER 10. 1979
TRW
ENVIRONMENTAL ENGINEERING DIVISION
-------
KEY PROJECT PERSONNEL
Program Management and Technical Direction
M. Ghassemi
Data Analysis and Final Report
Preparation
M. Ghassemi
K. Yu
K. Crawford
B. Edmondson
S. Quinlivan
R. Scofield
Data Base Development and
Computerization
S. Quinlivan
M. Powers
B. Edmondson
J. Davi
Data Acquisition and Preparation
of Assessment Summary Sheets
K. Crawford
H. Fisher
M. Ghassemi
S. Paige
P. Painter
S. Quinlivan
G. Richard
K. Scheyer
R. Scofield
A. Takata
C. Yu
K. Yu
11
-------
CONTENTS
Page
Key Project Personnel ii
Contents for Volume II v
Figures xi
Tables xii
Preface and Acknowledgement xlv
1.0 SUMMARY 1-1
1.1 Background and Study Objectives 1-1
1.2 Study Methodology 1-1
1.3 Results and Discussions 1-5
2.0 INTRODUCTION 2-1
3.0 WASTE GENERATION PROFILES 3-1
3.1 Distributions by Waste Generation Rate Category 3-1
3.2 Distribution by SIC 3-5
3.3 Distribution by EPA Region 3-8
3.4 Distribution by Disposal Method 3-13
4.0 ANALYSIS OF TECHNICAL ENVIRONMENTAL IMPACTS OF REGULATORY
OPTIONS •. 4-1
4.1 Quantity Option 4-1
4.1.1 Impacts on Number of Generators and Waste
Quantities 4-2
4.1.2 SIC-Specific Impacts 4-2
4.1.3 Impacts on Current Disposal Practices 4-8
4.1.4 Impacts on the Capacity of Commercial Waste
Management Facilities 4-9
4.1.5 Impacts on "Dilution" of Hazardous Waste in
Subtitle D Facilities 4-10
4.1.6 Impact on Waste Transportation and Probability of
Waste Spills 4-11
4.1.7 Impacts on the Safety of Operators and the Public
at Subtitle D Facilities 4-15
4.1.8 Impacts on Sanitary Landfill Siting 4-17
4.2 Phasing Option 4-18
4.2.1 Impact on Number of Generators and Waste Quantities 4-19
4.2.2 SIC-Specific Impacts 4-19
4.2.3 Impacts on Capacity of Commercial Waste Management
Facilities 4-20
-------
CONTENTS (CONTD)
5.0 ASSESSMENT OF THE QUALITY OF DATA BASE 5-1
5.1 General Considerations 5-1
5.2 Quality of the State Data 5-2
5.3 Estimation of Waste Generation Profiles 5-2
5.4 Use of Census Data 5-13
6.0 GENERAL METHODOLOGY FOR DATA BASE DEVELOPMENT 6-1
6.1 Sources of Information Used 6-8
6.1.1 State Hazardous Waste Surveys and Data Files . . . 6-8
6.1.2 Data Files of EPA and Its Contractors 6-13
6.1.3 Trade Associations 6-13
6.1.4 Individual Establishments 6-14
6.1.5 Census Data 6-15
6.1.6 Miscellaneous Data Sources 6-15
6.2 Reduction and Computerization of State Data 6-15
6.3 Use of State Data for Estimation of Waste Generation
Profiles 6-19
6.3.1 Evaluation of Correlations Between Waste Generation
Rate and Employment 6-19
6.3.2 Use of State Data as a Representative Sample of
Generators in an SIC 6-26
6.3.3 Computer Calculation of Industry Waste Generation
Profiles ' 6-27
IV
-------
CONTENTS FOR VOLUME II
Page
Appendix A
SIC 075 Animal Services, Except Veterinary A-l
SIC 15,16 General Building Contractors and Heavy
(except for Construction Contractors A-2
"special
trade")
SIC 21 Tobacco Manufacturers A-3
SIC 23 Apparel and Other Finished Products Made from Fabrics
and Similar Materials A-5
SIC 243,2492, Hardwood Veneer, Plywood and Glued Wood Products . . A-7
2499 • •
SIC 2611,2621, Paper and Allied Products A-9
2631,2646,
2661
SIC 2642,2643, Converted Paper and Paperboard Products A-13
2645,2647,
2648,2649,265 ' .
SIC 2992 Lubricating Oils and Greases (except blenders and
compounders) A-14
SIC 3241 Cement, Hydraulic A-18
SIC 325,326,. Stone and Clay Products A-19
3274,3275,
3281,3291,
3292,3295-7,
3299
SIC 3271,3272, Concrete, Gypsum and Plaster Products A-22
3273
SIC 3312 - Blast Furnaces (including coke ovens), Steel Works
and Rolling Mills A-23
SIC 3313 Electrometallurgical Products ... A-24
SIC 333 Primary Smelting and Refinishing of Nonferrous
Metals A-25
SIC 44 Water Transportation A-28
SIC 4789 Services Incidental to Transportation, Not Elsewhere
Classified A-31
SIC 4811 Telephone Communication (wire or radio) A-33'
SIC 5012,5013, Automobiles and Other Motor Vehicles, Automotive
5014 Parts and Supplies, Tires and Tubes (Wholesale) . . A-34
SIC 5039 Construction Materials, Not Elsewhere Classified
(Wholesale) A-36
SIC 5041,5042, Sporting, Recreational, Photographic and Hobby Goods,
5043 Toys and Supplies A-37
v
-------
CONTENTS FOR VOLUME II (CONTD)
Metals and Minerals, Except Petroleum (Wholesale). .
Page
A-38
SIC 505
SIC 5063 Electrical Apparatus and Equipment, Wiring Supplies
and Construction Materials (Wholesale) A-39
SIC 5086 Professional Equipment and Supplies (Wholesale) . . A-40
SIC 514 Groceries and Related Products (Wholesale) A-41
SIC 7299 Miscellaneous Personal Services A-43
SIC 7911 Dance Halls, Studios and Schools A-45
SIC 7997 Membership Sports and Recreation Clubs A-46
SIC 8011 Offices of Physicians -. . . . . A-48
SIC 8021 Offices of Dentists A-51
SIC 8031 Offices of Osteopathic Physicians A-53
SIC 8041 Offices of Chiropractors A-54
SIC 8042 Offices of Optometrists A-56
SIC 805 Nursing and Personal Care Facilities ..." A-58
SIC 8072 Dental Laboratories A-60
SIC 8081 Outpatient Care Facilities A-62
SIC 8091 Health and Allied Services, Not Elsewhere Classified A-64
Appendix B
SIC 018 Horticultural Specialties B-l
SIC 0711,0721 Soil Preparation and Crop Services B-5
0729
SIC 0741,0742 Veterinary Services B-9
SIC 0748,8421 Landscape and Horticultural Services, Arboreta,
Botanical and Zoological Gardens B-13
SIC 1700 Construction - Special Trade Contractors B-16
SIC 2079 Shortening, Table Oils, Margarine and Other Edible
Fats B-22
SIC 2211,2221, Textile Mill Products B-25
2241,228,229
SIC 2231,225, Dyeing and Finishing of Textiles B-34
226,2272
SIC 2421 Sawmills and Planning Mills B-38
SIC 2491 Wood Preserving B-43
SIC 2499 Miscellaneous Wood Products B-48
SIC 25 Furniture and Fixtures B-52
VI
-------
CONTENTS FOR VOLUME II (CONTD)
Page
SIC 2641 Production of Coated and Glazed Paper B-56
SIC 27 Printing, Publishing, and Allied Industries B-60
SIC 281 Industrial Inorganic Chemicals B-65
SIC 282 Plastic Materials and Synthetic Resins, Synthetic
Rubber, Synthetic and Other Man-made Fibers, Except
Glass B-72
SIC 283 Drugs and Pharmaceuticals B-78
SIC 284 Soap, Detergents, and Cleaning Preparations, Perfumes,
Cosmetics, and Other Toilet Preparations B-83
SIC 2851 Paints, Varnishes, Lacquers, Enamels, and Allied
Products B-88
SIC 286 Industrial Organic Chemicals . B-92
SIC 2873 Nitrogenous Fertilizers B-96
SIC 2875 Fertilizers, Mixing Only B-100
SIC 2879 Pesticides and Agricultural Chemicals, Not Elsewhere
Classified B-103
SIC 2891 Miscellaneous Chemical Products, Adhesives and
Sealants B-107
SIC 2892,2895, Miscellaneous Chemical Products, Chemicals and Chemical
2899 Preparations, Not Elsewhere Classified Including
Explosives and Carbon Black B-112
SIC 2893 Miscellaneous Chemical Products, Printing Ink .... B-116
SIC 2911 Petroleum Refining B-120
SIC 30 Rubber and Miscellaneous Plastics Products B-126
SIC 31 (except Leather and Leather Products (except leather tanning
3111) and finishing) B-135
SIC 3111 Leather Tanning and Finishing B-138
SIC 32 Stone, Clay, Glass and Concrete Products B-143
SIC 3315,3316, Rolling, Drawing, and Extruding of Metals B-148
3317,335
SIC 332,336 Foundries B-154
SIC 3341 Secondary Smelting and Refining of Nonferrous Metals B-163
SIC 3398 Metal Heat Treating B-168
SIC 3399 Primary Metal Products, Not Elsewhere Classified . . B-174
SIC 34 (except Fabricated Metal Products, Except Machinery and .
3411,3479) Transportation Equipment B-178
VII
-------
CONTENTS FOR VOLOT^E II (CONTD)
Page
SIC 3431,3479 Enameled Iron and Metal Ware and Coating, Engraving,
and Allied Services, Not Elsewhere Classified .... B-190
SIC 3471 Electroplating and Metal Finishing B-195
SIC 351,352, Machinery, Except Electrical B-201
353,358,359
SIC 354,355, Machinery, Except Electrical B-205
356,357
36 (except Electrical and Electronic Machinery, Equipment and
3691,3692) Supplies B-209
SIC 3691,3692 Storage and Primary Batteries B-213
SIC 37 Transportation Equipment B-217
SIC 38 (except Measuring, Analyzing, and Controlling Instruments,
3861) Medical, Dental and Optical Goods, and Watches and
Clocks B-222
SIC 3861 Photographic Equipment and Supplies B-227
SIC 39 (except Miscellaneous Manufacturing Industries B-232
391,396)
SIC 3910,3960 Jewelry, Silverware, and Plated Ware, Costume Jewelry,
Novelties, Buttons, and Miscellaneous Notions .... B-236
SIC 40 (and Railroad Transportation B-241
parts of SIC
411)
SIC 41 Local and Suburban Transit and Interurban Highway
Passenger Transportation B-250
SIC 42 Motor Freight Transportation B-256
SIC 43 Postal Service B-264
SIC 45 Transportation by Air B-270
SIC 5122 Drugs, Drug Proprietaries and Druggists' Supplies
(Wholesale) B-279
SIC 5161 Chemicals and Allied Products - Chemical Wholesalers B-283
SIC 5511 Motor Vehicles (New and Used) B-287
SIC 5541 Gasoline Service Stations B-294
SIC 7215,7215, Dry Cleaning B-299
7218
SIC 7217 Carpet and Upholstery Cleaning B-308
SIC 7221,7333, Photo Processing Laboratories B-311
7395,7819
SIC 7231,7241 Barber and Beauty Shops B-316
Vlll
-------
CONTENTS FOR VOLUME II (CONTD)
Page
SIC 7261 Funeral Services and Crematories B-320
SIC 7332 Blueprinting and Photocopy Services B-324
SIC 7341,7349 Commercial Cleaning and Janitorial Services ..... B-328
SIC 7342 Disinfecting and Exterminating Services B-332
SIC 7391 Research and Development Laboratories B-337
SIC 7397 Commercial Testing Laboratories B-341
SIC 7399 Miscellaneous Business Services, Not Elsewhere
Classified B-345
SIC 751 Automotive Rental and Leasing, Without Drivers ..... B-349
SIC 7531-7535 Automotive Repair Shops B-354
SIC 7538 General Automotive Repair Shops -. . . B-358
SIC 7539 General Automotive Repair, Not Elsewhere Classified . B-363
SIC 7542 Car Washes B-368
SIC 76 Miscellaneous Repair Services B-372
SIC 7933 Bowling Alleys B-376
SIC 7948 Racing, Including Track Operation B-380
SIC 7996 Amusement Parks B-386
SIC 806 Hospitals B-391
SIC 8071 Medical Laboratories B-398
SIC 8211 Elementary and Secondary Schools B-404
SIC 8221,8222 Colleges, Universities, Professional Schools and
Junior Colleges B-407
SIC 8411 Museums and Art Galleries B-411
SIC 8922 Noncommercial Educational, Scientific, and Research
Organizations B-414
Appendix C
Section C-l Agencies, Associations and Companies Supplying Informa-
tion for Use in the TRW Study C-l
Section C-2 Items Related to Preparation of Facility Computer In-
put Data Sheets for Computerization of State Data
Base C-12
Section C-3 Samples of Completed Hazardous Waste Information
Questionnaires C-25
ax
-------
CONTENTS FOR VOLUME II (CONTD)
Page
Section C-4 Computer Calculations and Hand Plots of Industry
Waste Generation Profiles for SIC 286 C-34
Section C-5 Computer-Generated Sample Summary Sheets and Industry
Profiles for SIC's 3471 and 7342 C-42
Section C-6 Sample Raw Data Provided by States of Arizona,
California and Washington C-54
Section C-7 Selected Examples of Reported Damage Incidents Involv-
ing Small Quantities of Hazardous Waste C-61
-------
FIGURES
Figure No. Page
1-1 Estimated Number of Hazardous Waste Generators and Waste
Quantities (Metric Tons/Yr) in Various Waste Generation Range
Categories 1-6
1-2 Estimated Number of Small Generators and Associated Waste
Quantities for Various EPA Regions 1-8
1-3 Estimated Number of Small Generators Using Various Disposal
Methods and Associated Waste Quantities 1-9
4-1 Impact of Waste Exemption Cutoff on the Small Hazardous Waste
Generators 4-1
4-2 Impact of Waste Exemption Cutoff on Hazardous Waste Generators 4-4
4-3 Nonhazardous Waste to Hazardous Waste Dilution Ratios at
Subtitle D Facilities as a Function of Waste Quantity Exemption
Cutoffs 4-12
4-4 Probable Waste Spill Quantities and Hauling Accidents Involv-
ing Hazardous Wastes from Small Generators as a Function of
Waste Exemption Cutoff 4-14
5-1 Comparison of Distribution of Employment for Plants in State
Data Base with the Census Employment Data for States Covered-
SIC 0700 5-5
5-2 Comparison of Distribution of Employment for Plants in State
Data Base with the Census Employment Data for States Covered-
SIC 2800 5-6
5-3 Comparison of Distribution of Employment for Plants in State
Data Base with the Census Employment Data for States Covered-
SIC 3400 5-7
5-4 Comparison of Distribution of Employment for Plants in State
Data Base with the Census Employment Data for States Covered-
SIC 3670 5-8
5-5 Comparison of Distribution of Employment for Plants in State
Data Base with the Census Employment Data for States Covered-
SIC 3820 5-9
5-6 Comparison of Distribution of Employment for Plants in State
Data Base with the Census Employment Data for States Covered-
SIC 3910 5-10
6-1 Waste Generation Rate vs. Plant Employment for Selected
Plants in SIC 3398 6-24
6-2 Waste Generation Rate vs. Plant Employment for Selected
Plants in SIC 282 6-25
6-3 Cumulative Percentage Distribution of Plants in the Sample
State Data for SIC 3471 6-28
6-4 Cumulative Percentage Distribution of Plants in the Sample
State Data for SIC 7342 6-29
XI
-------
TABLES
Table No. Page
1-1 Estimated Number of Generators and Waste Quantities Exempted
for Various Waste Exemption Cutoffs 1-10
3-1 Estimated Number of Plants and Waste Quantities for Establish-
ments in Various Waste Generation Range Categories 3-2
3-2 Number and Waste Quantities for All Hazardous Waste Generators
in the State Data for California, Iowa, Massachusetts and
Oklahoma, by Waste Generation Category 3-4
3-3 Estimated Number of Plants and Waste Quantities for Establish-
ments in Various Waste Generation Range Categories (Manufactur-
ing SIC's) 3-6
3-4 Estimated Number of Plants and Waste Quantities for Establish-
ments in Various Waste Generation Range Categories (Nonmanu-
facturing SIC's) 3-7
3-5 Comparison of the Observed Distributions of the Small Generators
in the State Data Base with the Estimated National Distribution
for the Small Generators 3-9
3-6 Relative Contributions of Various Manufacturing industries
to the Hazardous Waste Generation Picture 3-10
3-7 Relative Contributions of Various Nonmanufacturing Industries
to the Hazardous Waste Generation Picture 3-11
3-8 Estimated Number of Generators and Waste Quantities for Manu-
facturing, Nonmanufacturing and All Industries by EPA Region 3-12
3-9 Percent Distributions of Small Waste Generators and Waste
Quantities in the State Data Base by Disposal Method .... 3-14
3-10 Estimated Total Number of Small Waste Generators and Waste
Quantities by Disposal Method 3-16
3-11 Breakdown of the Estimated Number of Small Generators Dispos-
ing Waste in Landfills and Associated Waste Quantity by Waste
Generation Range Category .... 3-17
4-1 SIC's Most Affected by a Waste Exemption Cutoff of 100 kg/mo 4-5
4-2 SIC's Most Affected by a Waste Exemption Cutoff of 500 kg/mo 4-6
4-3 SIC's Most Affected by a Waste Exemption Cutoff of 1000 kg/mo 4-6
4-4 SIC's Most Affected by a Waste Exemption Cutoff of 5000 kg/mo 4-7
4-5 Estimated Hazardous Waste Management Industry Capacity and
Demand (Million kg/mo) by EPA Region for Various Waste
Quantity Exemption Cutoffs 4-10
5-1 Selected Percentiles of Employment Distributions for State and
Census Data 5-11
5-2 Number of Firms in State Data Base and Census Data Base with
Employment Information 5-12
XI1
-------
TABLES (CONTD)
Table No.
6-1 SIC's Eliminated from Further Consideration 6-2
6-2 SIC's Containing Small Volume Hazardous Waste Generators for
Which Waste Generation Profiles Were Prepared ........ 6-5
6-3 Description of Hazardous Waste Data for Individual States in
"State Data Base" 6-9
6-4 SIC's for Which Additional Data Were Collected From Individual
Establishments Via Mailing of SIC-Specific Hazardous Waste
Questionnaires and/or Telephone Inquiries 6-16
6-5 Number of Plants and Waste Quantities in the State Data Base
for Small Generators for the States Covered 6-20
6-6 Number of Plants and Waste Quantities for All Generators (Small
and Large) in the Data Base for California, Iowa, Massachusetts
and Oklahoma 6-11
6-7 Linear Correlation Between Employment and Waste Quantity . . 6-23
6-8 Best Curve Fit for Waste Generation Within an SIC for 50 SIC's 6-30
6-9 Comparison of Numerical Integration with Midpoint Calculation
Method for National Waste Quantity (SIC 3471) 6-33
6-10 Comparison of Midpoint Calculation with Numerical Integration
Method for National Industry Waste Quantity (SIC 721) .... 6-34
Xlll
-------
PREFACE AND ACKNOWLEDGEMENT
This background document has been prepared by the TRW Environmental
Engineering Division for the Office of Solid Waste, U.S. EPA, under Contract
No. 68-02-2613 (Work Assignment No. 27) and Contract No. 68-03-2560 (Work
Directive Nos. T5012, T5014 and T5015). Those on the project staff wish to
express their gratitude to the EPA Project Officer, Mr. Robert Holloway, for
his advice and guidance during the course of the program. Special thanks are
due to a number of EPA technical and management staff, especially Mr. Steve
Lingle, Ms. Jan Auerbach and Mr. Hugh Holman, who reviewed program progress
and provided constructive suggestions and guidance in connection with the
study. .
TRW wishes to express its deepest gratitude to the various Federal, state
and local governmental agencies, past and current government contractors,
trade associations and the large number of individual establishments which
provided information for use in this study. Listings of government agencies
and contractors and trade associations which were most helpful to this pro-
gram are presented in Appendix C.
The TRW Program Manager was Dr. Masood Ghassemi who also provided techni-
cal direction and supervision for the effort. The short-term and the very com-
plex nature of the program required participation of individuals from a vari-
ety of technical disciplines; Mr. Irving Zuckerman, the General Manager of the
TRW Environmental Engineering Division, was instrumental in assuring the avail-
ability of appropriate technical talent to this program. The project is deeply
indebted to Mrs. Maxine Engen for typing numerous data request forms which were
sent to trade associations and private firms, for typing the draft, final and
interim reports and for providing all secretarial services associated with the
program.
• xiv.
-------
1.0 SUMMARY
1.1 BACKGROUND AND STUDY OBJECTIVES
Section 3002 of the Resource Conservation and Recovery Act of 1976 (RCRA)
requires the EPA Administrator to promulgate regulations governing the genera-
tors of hazardous wastes. Such regulations, which were proposed by EPA on
December 18, 1978, contained a provision for conditional exemption of the
"small" generators, defined as those producing and disposing of less than
100 kg/mo of hazardous waste. The proposed 100 kg/mo "cut-off" level was
based on very limited survey data indicating that, at least for the manufactur-
ing industries, an exemption cut-off of 100 kg/mo should allow for the control
of 99.6 to 99.9% of potentially hazardous waste while at the same time exclud-
ing about 60% of the generators. Acknowledging the difficult issue of bal-
ancing the need to protect human health and the environment with the need to
hold the adminstrative and economic burden of waste management within reason-
able and practical limits, the preamble to the proposed regulations suggested
alternative regulatory approaches and solicited comments and ideas on these
approaches.
This background document on small volume hazardous waste generators pre-
sents the results of a data collection and analysis effort aimed at (a) devel-
oping a more comprehensive data base for addressing the issue of small gen-
erators and (b) evaluating the technical environmental impacts associated
with various waste quantity cut-off levels, using the data base developed.
1.2 STUDY METHODOLOGY
An industry-by-industry ("SIC-by-SIC") assessment approach was used to
develop composite national and EPA regional profiles for small volume hazard-
ous waste generators. For analysis purposes, a waste generation rate of 5000
kg/mo was considered as a probable upper limit for defining "small" generators.
All SIC's listed in the "Standard Industrial Classification Manual" were
individually examined and those which could be readily identified as non-
generators of hazardous wastes (e.g., SIC 64, Insurance Agents, Brokers and
Service) were eliminated from further consideration. (Also eliminated, per Dec-
ember 18, 1978 proposed regulations, were farmers and retailers, except gasoline
service stations.) This preliminary "screening" was followed by a more de-
tailed evaluation leading to the elimination of a number of additional SIC's
1-1
-------
on the basis of being nonhazardous waste generators, large generators or
generators of wastes covered under other regulations.
Based on the December 18, 1978 proposed guidelines and regulations, a
waste would be considered hazardous if it appears on the EPA1s "list" of haz-
ardous wastes or if it meets certain ignitability, corrosivity, reactivity or
toxicity criteria. EPA is to periodically revise and update its "list" of
hazardous wastes as new data become available on the characteristics of various
wastes and the environmental significance of various waste components. Nearly
all the wastes appearing on the EPA's December 18, 1978 list of hazardous
wastes are from the manufacturing industries, many of which have been the sub-
ject of some previous industry studies. A large number of industries reviewed
in the present study, particularly those in the nonmanufacturing segment, how-
ever, fall into the least studied industries for which little or no waste
characteristics data were available from any previous studies. Accordingly,
in the present study considerable technical and engineering judgment had to be
exercised in determining whether or not wastes which were not "listed" or
wastes for which data on ignitability, corrosivity, reactivity and toxicity
were not available should be considered hazardous.
In line with the main objective of this study, which was primarily to
develop a comprehensive data base for use by EPA in developing regulations,
a much broader spectrum of wastes were considered as "potentially" hazardous
than those currently designated as hazardous by EPA and appearing on the Dec-
ember 18, 1978 EPA's list of hazardous wastes. The consideration of a waste
as potentially hazardous for the purpose of this background document does not
imply a decision or an impending decision by EPA for the inclusion of the
waste on its "list" of hazardous wastes.
In the present study, a waste was considered as potentially hazardous if
it was judged to (a) possess characteristics similar to (or to contain compon-
ents of) the listed wastes or (b) contain constituents which, based on the pub-
lished literature data for pure substances, would meet the hazardous waste cri-
teria for toxicity, reactivity, corrosivity, etc. Because of certain unique
features of waste oil (a "listed" hazardous waste) and waste oil generators
(e.g., large number of generators, fuel value of waste and existence of a
waste oil re-refining industry), which warrant separate and special regulatory
considerations, waste oil and waste oil generators were excluded from the pre-
sent analysis.
1-2
-------
The SIC's determined to contain small generators were subjected to an in-
depth evaluation culminating in the development of a waste generation profile
for each SIC or SIC group. Each profile consists of estimates, on a national
or EPA regional basis, of the number of generators and waste quantities in 13
waste generation range categories (less than 100 kg/mo; 100 to 200 kg/mo, 200
to 300 kg/mo, etc. up to 1000 kg/mo; 1000 to 2000 kg/mo; 2000 to 5000 kg/mo;
and greater than 5000 kg/mo). The profiles for individual SIC's were then
aggregated to develop overall national or EPA regional profiles for the small
generators. The data collected and the analysis results for individual SIC's,
including waste generation profiles, specific wastes produced and the treat-
ment/disposal methods used, are contained in "assessment summary sheets" pre-
sented as Appendices A and B in Volume II of this report.
The primary information sources used for the SIC-by-SIC assessments and
for developing waste generation profiles include hazardous waste surveys con-
ducted by various states; data files of EPA (primarily Office of Solid Waste
and the Effluent Guidelines Division) and its contractors; trade associations;
samples of individual establishments in each SIC; and the Bureau of Census
1976 data on the number and geographic distribution of establishments in each
SIC. All 50 states and 10 EPA Regional offices were contacted for data on
hazardous waste generators; where pertinent data existed and could be made
available to this study such data were obtained. The evaluation of the state
data led to the selection of 20 states whose data on small generators consti-
tute the "state data base" for this study. These 20 states are Alaska, Arizona,
California, Connecticut, Georgia, Iowa, Kansas, Kentucky, Maine, Massachusetts,
Minnesota, Mississippi, Missouri, New Hampshire, New Mexico, New York, Oklahoma,
Rhode Island, Texas and Washington. The state data base, which was subsequently
computerized and used for the development of many of the waste generation pro-
files (largely for the manufacturing SIC's), covers a total of 2553 establish-
ments in 366 2-, 3- and 4-digit SIC's.
A very large number of trade associations were contacted for information
on hazardous waste generation and management practices of their member firms
and for assistance in obtaining such information from individual establishments.
A total of 74 trade associations were able to provide assistance or useful
information to the program. Of the very large number of establishments which
were contacted (mainly by telephone), 342 provided data or general information
1-3
-------
on the nature of their operation, waste quantities produced and/or disposal
methods employed.
Several options were investigated for estimating the number of generators
in various waste generation rate categories and associated waste quantities
for an SIC. The use of a "per-emplbyee" waste generation rate was investi-
gated and ruled out because of lack of both employment and waste quantity
data for individual plants in many SIC's and because of a lack of correlation
between employment and waste generation quantities for plants for which both
information items were available. In this study, except for very limited cases
where "per-employee" or "per unit production capacity" waste generation data
were used to estimate waste quantities (because of the lack of other data),
the waste generation profile for an SIC was estimated by projecting the ob-
served distribution of the waste generation rates for the plants in the state
data base, or for the plants for which data were obtained from other sources,
to the nation as a whole (or to an EPA region).
The extension of a number of generators and amount of waste from the
"sample" to the nation assumes that the establishments in the sample are repre-
sentative of the national situation with regard to waste generation within any
given SIC, an assumption which is considered reasonable in light of the nature
of the data base. The state data base which provided the sample information
for many SIC's represents more than 20 separate and independent survey opera-
tions, each for a distinct and non-overlapping portion (state or geographic
portions within states) of the whole (nation). Since the composite data base
for the nation is based on such a large number of independent data elements,
it is reasonable to assume representativeness of hazardous waste generation
in the U.S.
The following procedure was used for extending the data in a sample to the
nation or EPA region. The monthly waste generation rates for establishments
in the sample were rank ordered and cumulative percentages of the number of
plants generating waste quantities less than indicated rates were calculated.
These data were then plotted on normal-probability and lognormal-probability
papers to obtain the line of best fit. The distribution indicated by the line
of best fit was then applied to the census data on total number of establish-
ments in the nation (or in an EPA region) for an SIC, with allowances made for
the estimated fractions of plants which, based upon the survey results for New
1-4
-------
York, Massachusetts and Iowa, were considered "zero" generators and. "large"
generators. The total waste quantity associated with establishments in a waste
generation rate category was then calculated by multiplying the number of
establishments in the category by the "mid-point" waste generation rate for
that category. A computer program was developed and used to carry out the
distribution analysis based on samples and the profile calculations. The com-
puter-calculated overall national profiles for the small generators were
adjusted downward to allow for the estimated number of generators which recycle
wastes and the estimated waste quantities recycled. The percentage of small
generators employing waste recycling and the percentage of waste from small
generators which are recycled were estimated based on the aggregated state
data and the information collected from other sources.
The data base developed and used in this study represents the most com-
prehensive data base currently available on hazardous waste generation in the
U.S. Even though the procedure for estimating national profiles of hazardous
waste generators has not been used in any related previous EPA-sponsored
studies, in the few cases where other estimates were available for comparison,
the estimates obtained in this study are generally in reasonable accord with
the other estimates.
1.3 RESULTS AND DISCUSSIONS
Profiles of Small Generators of Hazardous Waste
The generators producing 5000 kg/mo or less of hazardous wastes are esti-
mated to number close to 722,000 and to generate a total of 1.4 million metric
ton/yr of wastes. These generators account for 94.7% of the total number of
generators and 2.3% of the total waste quantity produced. Figure 1-1 is a
graphical presentation of the estimated number of generators and waste quanti-
ties associated with various waste generation range categories. As shown in
the figure, while the smaller generators account for very high percentages of
generators, their contributions to the total quantity of hazardous waste pro-
duced in the nation are very small. Thus, while the generators producing 100
kg/mo or less of hazardous waste account for 74% of the total number of gen-
erators, the waste produced by these generators amounts to less than 0.3% of
the total waste produced nationally.
1-5
-------
o
o
o
o^
«*r
VO
LEGEND:
NUMBER OF GENERATORS AND PERCENTAGES
WASTE QUANTITIES AND PERCENTAGES
<100
100- 200- 300- 1*00- 500- 600- 700- 800- 900- 1000- 2000- >5000
1 200 ' 300 ' 400 I 500 ' 600 ' 700 ' 800 ' 900 ' lOOb' 2000 ' 5000J '
WASTE GENERATION RANGE CATEGORY, KG/MO
Figure 1-1. Estimated Number of Hazardous Waste Generators and Waste
Quantities (Metric TonsAr) in Various Waste Generation Range
Categories (the Relative Percentages are Given in Parentheses)
1-6
-------
An estimated 17% of all generators are in the manufacturing SIC's; the
waste produced by these generators account for about 96% of the total waste.
Establishments in the nonmanufacturing industries account for 83% of all gen-
erators and 4% of the total waste. The small generators (i.e., generators
producing less than 5000 kg/mo of hazardous waste) in the manufacturing indus-
tries account for 13% of all small generators and 47% of waste produced by all
small generators (compared to 87% and 53%, respectively, for the small gen-
erators in the nonmanufacturing industries). The average waste generation
rate for the small generators in the manufacturing and nonmanufacturing sec-
tors are 576 and 98 kg/mo, respectively, in the small generator category, the
major contributing SIC's in the nonmanufacturing segment are SIC's 17 (Construc-
tion-Special Trade), 55 (Automobile Dealers and Gasoline Service Stations), 72
(Personal Services), and 75 (Automotive Repair Services); these SIC's collec-
tively account for 79% of the small generators and 78% of the waste in the
nonmanufacturing sector. The major contributing SIC's in the manufacturing seg-
ment are SIC's 27 (Printing and Publishing), 34 (Fabricated Metal Products),
and 35 (Machinery, Except Electrical), which collectively account for 58% of
the small generators and 47% of the waste in the manufacturing sector.
Figure 1-2 presents the distribution of the number of small generators
and associated waste quantities among the 10 EPA regions. As indicated by the
data, EPA Regions II, IV, V and IX have the greatest number of small generators
and produce the largest waste quantities.
Figure 1-3 presents the estimated number of small generators using various
waste disposal methods and the estimated quantity of waste handled by each dis-
posal method. These estimates indicate that on an aggregate level, 96% of the
estimated 722,000 small generators which dispose of waste by methods other
than recycling use landfills for waste disposal and that 79% of the estimated
1.4 million metric ton/yr of wastes generated by the small generators is dis-
posed of in landfills.
Technical Environmental Impact Analysis
The technical environmental impact analysis has consisted primarily of
(a) estimating the number of plants, waste quantities and SIC's likely to be
affected by the application of various waste exemption cut-offs and (b) eval-
uating, as a function of waste exemption cut-off, the potential impacts on
current waste disposal practices, capacity of commercial waste management
1-7
-------
Figure 1-2. Estimated Number of Small Generators and Associated Waste Quantities for Various EPA Regions
(waste quantities, given in parenthesis, are in 10-* metric ton/year)
-------
LEGEND:
NUMBER OF SMALL GENERATORS
WASTE QUANTITY, METRIC TONAR
Figure 1-3. Estimated Number of Small Generators Using Various Disposal
Methods and Associated Waste Quantities
1-9
-------
facilities, waste transportation and probability of spills, safety of land-
fill operators and sanitary landfill siting.
The estimated number of generators and waste quantities which would be
exempted from full regulations are shown in Table 1-1 for exemption
cut-offs ranging from 100 kg/mo to 5000 kg/mo. Since the greatest number of
small generators are in the very small waste generation rate category, a waste
cut-off level of 100 kg/mo would exclude 78% of the small generators (75% of
all generators) and 10% of the waste from small generators (0.23% of waste
from all generators). As the cut-off level is raised, the increase in the
percentage of the generators excluded becomes less dramatic while the increase
in the percentage of the waste excluded becomes more significant. Thus, a
1000 kg/mo cutoff would entail exclusion of 96% of the small generators (91%
of all generators) and 46% of the waste from small generators (1.0% of waste
from all generators).
TABLE 1-1. ESTIMATED NUMBER OF GENERATORS AND WASTE QUANTITIES EXEMPTED FOR
VARIOUS WASTE EXEMPTION CUTOFFS
Waste
Exemption
Cutoff
kg/mo
100
200
300
400
500
600
700
800
900
1000
2000
5000
Generators Exempted
Number
563,000
621,000
647,000
662,000
672,000
679,000
684,000
688,000
692,000
695,000
710,000
722,000
% of Small
Generators
78.0
86.0
89.6
91.7
93.1
94.0
94.7
95.3
95.8
96.3
98.3
100
% of All
Generators
73.9
81.5
84.9
86.9
88.2
89.1
89.8 •
90.3
90.8
91.2
93.2
94.7
Waste Quantity Exempted
Metric
Ton/Yr
140,000
244,000
323,000
385,000
440,000
485,000
525,000
564,000
600,000
635,000
914,000
1,388,000
% of Waste
from Small
Generators
10.0
17.6
23.3
27.7
31.7
34.9
37.8
40.6
43.2
45.7
65.8
100
% of All
Waste
0.23
0.40
0.53
0.63
0.73
0.80
0.87
0.93
0.99
1.0
1.5
2.3
1-10
-------
Since the great majority of the smaller generators are in the service
industries, these industries would be impacted to a much greater extent by
lower exemption cutoffs than the manufacturing industries. Example of indus-
tries with all establishments in the less than 100 kg/mo waste generation rate
category are Horticultural Specialties (SIC 018), Construction-Special Trade
Contractors (SIC's 1711, 1742, etc.), Funeral Services and Crematories (SIC
7261 and Barber and Beauty Shops (SIC's 7231 and 7241).
At each waste exemption cutoff, the generators not exempted would be re-
quired to dispose of waste in hazardous waste management facilities meeting
RCRA Subtitle C requirements, whereas those exempted would dispose of wastes in
facilities meeting RCRA Subtitle D requirements. Based on published estimates
of the capacities for existing commercial hazardous waste management facilities,
it appears that severe capacity deficits exist in EPA Regions VIII (which cur-
rently has no commercial hazardous waste management facilities), VI, IV and I,
«
even if the exemption cutoff is placed at as high as 5000 kg/mo. Hazardous
waste management facilities in EPA Regions V, VII, IX and X would have more
than adequate capacities to handle hazardous wastes from all generators with-
in their respective boundaries, irrespective of the waste exemption cut-off
level. The diversion of wastes from small generators to Subtitle D facilities
would have an insignificant impact on site capacity requirements for such
facilities. The co-disposal of hazardous waste with the larger volume of non-
hazardous waste at Subtitle D facilities may provide a sufficiently high "dilu-
tion" of hazardous waste to minimize potential adverse disposal impacts of
such wastes. On an aggregate level, co-disposal of 1.4 million metric ton/
yr of hazardous waste from small generators (i.e., if the waste exemption cut-
off is placed at 5000 kg/mo) with 132 million metric ton/yr of municipal re-
fuse which is estimated to be produced nationally would represent a 94 fold
dilution of hazardous waste.
Regulations requiring the small hazardous waste generators to segregate
hazardous waste from nonhazardous refuse and to dispose them in Subtitle C
facilities would entail transportation of hazardous waste from small genera-
tors in more "concentrated" form and over longer distances, thus increasing
the probability of transportation accidents involvina hazardous wastes and
the "severity" of the impacts associated with such accidents. The lowering
of exemption cutoff from 5000 kg/mo to 100 kg/mo is estimated to increase
the probable number of hazardous waste related transportation accidents by
1-11
-------
120 accidents per year and the quantity of waste involved in such accidents
by 474 metric ton/yr. A decrease in the extent of self-hauling and an in-
crease in demand for services of commercial waste haulers would be expected
with the lowering of waste exemption cutoff.
As long as the hazardous waste containers are properly labeled, the diver-
sion of hazardous waste from small generators to RCRA Subtitle D facilities
should not present special safety hazard to operators of such facilities, pro-
vided that the operators of such facilities are trained in identifying incom-
patible wastes and in proper handling of flammable and explosive wastes.
Indeed, with the implementation of RCRA the net quantity of hazardous waste
which would enter Subtitle D facilities would be expected to decrease, since
hazardous wastes from large generators which currently enter such facilities
would be diverted to Subtitle C facilities.
The acceptance of hazardous waste from small generators in Subtitle D
facilities is not expected to be a major issue in public opposition to siting
such facilities, as long as the public can be presented with convincing evi-
dence on the adequacy of the proposed design and controls and the capabilities
of the operating agency to operate the site properly.
The lowering of exemption cutoff would increase the number of generators
which would be covered under RCRA Subtitle C regulations. This can have a
significant impact on the resources required for administration and enforce-
ment of RCRA. These impacts, which are primarily of an economic nature and
are being addressed in a separate economic study, suggest the desirability of
"phasing" of regulations to allow time for the development of necessary re-
sources for administrating and enforcing RCRA for small generators. The "phas-
ing" option is essentially an extension of the "quantity" option and, except
for some phasing of the impacts, would entail the same impacts as those dis-
cussed above in connection with the "quantity option."
1-12
-------
2. INTRODUCTION
The Office of Solid Waste (OSW) of the U.S. Environmental Protection
Agency (EPA) is responsible for promulgating a number of regulations for the
control of hazardous waste under Subtitle C of the Resource Conservation and
Recovery Act of 1976 (RCRA). Section 3002 of the Act requires the EPA Adminis-
trator to promulgate regulations establishing standards for persons generating
wastes identified or listed as hazardous. The regulations would establish
certain requirements for record keeping and reporting by the waste generators.
On December 18, 1978 EPA proposed regulations governing waste generators
(40 CFR Part 250, page 58946). One of the issues raised in the preamble to
the proposed regulations involved the desirability of regulating the "small"
volume hazardous waste generators in a manner that would balance the need to
protect human health and the environment from the adverse impact of potential
mismanagement of small quantities of hazardous waste with the need to hold
the administrative and economic burden of management of these wastes under
RCRA within reasonable and practical limits.
Under the proposed December 18, 1978 regulations, persons who produce and
dispose of less than 100 kilograms (approximately 220 pounds) of hazardous
waste in any one month would be considered small volume hazardous waste gen-
erators and exempted from certain reporting and record keeping requirements,
provided that the waste is disposed of in an approved waste disposal facility.
The proposed 100 kilograms per month "cut-off" level has been based on limited
survey data indicating that, at least for the manufacturing industries (SIC's
2C-39), this cut-off point should allow control of an extremely high quantity
(99.6 to 99.9 percent) of potentially hazardous waste while at the same time
excluding a very high number (60%) of the generators.
Although the Agency proposed a 100 kg/mo cutoff, it realized that there
are a number of alternative means of regulating small generators. The Agency
suggested several alternatives in the preamble to the December 18, 1978 pro-
posed regulations and asked for comments on these and any other methods.
Those methods include raising or lowering the cutoff, phasing from a high
cutoff to a low cutoff, and developing various cutoffs depending on degree
of hazard.
The overall objectives of this study have been (a) to develop the tech.-
nical data base, which has been unavailable heretofore, for proper address-
ing of the issue of the small generators and (b) using the developed data
2-1
-------
base to evaluate the technical environmental impacts associated with the vari-
ous options for regulating small generators.* The development of the data
base has consisted of developing the following profiles for the small genera-
tors:
• distribution of number of generators by waste generation quantity
range, disposal method and EPA region
• waste quantity distribution by waste generation quantity range,
disposal method and EPA region
• contributing Standard Industrial Classifications (SIC's) and their
relative contributions
• relative contribution of small generators to the national hazardous
waste generation picture
• relative volume of wastes from small generators in comparison with
nonhazardous wastes disposed to sanitary landfills.
The technical environmental impacts analysis has consisted primarily of
(a) estimating the number of plants, waste quantities and SIC's likely to be
affected by the application of a waste generation rate cut-off (e.g., 0 kg/mo,
100 kg/mo, 1000 kg/mo, etc.) to all hazardous wastes and (b) evaluating, as
a function of waste exemption cut-off, the potential impacts on current waste
disposal practices, disposal facility capacity requirements, waste transpor-
tation and probability of spills, disposal site safety considerations and
sanitary landfill siting. For analysis purposes, .the small generators ad-
dressed in this study have been those producing less than 5000 kg/mo of haz-
ardous wastes."!"
The study has relied primarily on existing available information with
the hazardous waste survey and documentation results from some 20 states com-
prising the major portion of the data base. Other sources of information used
have included data files of EPA and its contractors, trade associations, indivi-
dual establishments and census data on distribution of establishments by SIC,
employment size category and state. An SIC-by-SIC assessment approach has
*The evaluation of the economic impacts of various regulatory options has
been the subject of a parallel study, the results of which arc presented in
a separate report: "Economic Impacts of RCRA Approaches to the Regulation
of Generators of Small Volumes of Hazardous Wastes," prepared for EPA by
Temple, Barker and Sloane, Inc., December 1979.
^The December 18, 1978 regulations (40 CFR Part 250, page 58946) proposes a
100 kg/mo as the exemption cutoff for small generators and refers to a sug-
gested alternative cutoff level of 1000 kg/mo. A 5000 kg/mo generation rate
for definina small generators was selected here to allow examination of even
higher exemption cutoff levels.
2-2
-------
been used in developing composite profiles for the small volume hazardous
waste generators.
This report is prepared in 2 volumes. Volume I, Technical Analysis, pre-
sents and discusses the results obtained and conclusions reached and describes
the data base developed and the study methodology. Volume II consists of
three Appendices containing support data including "assessment summary sheets"
for the SIC's reviewed.
2-3
-------
3. WASTE GENERATION PROFILES
This section presents the composite profiles for small volume hazardous
waste generators (i.e., generators producing less than 5000 kg/mo of hazardous
waste) based on individual profiles for those SIC's judged to contain small gen-
erators. The assessment summaries for individual SIC's (or SIC groups) are pre-
sented in Volume II, Appendix B- Because of certain unique features of waste
oil (a "listed" hazardous waste based on toxicity considerations) and waste
oil generators (e.g., large number of generators, fuel value of waste oil,
existence of a waste oil re-refining industry, etc.), which warrant special and
separate regulatory considerations, waste oil generators and waste oil quanti-
ties have been excluded from the analysis here and the profiles presented are
for the "non-oil" hazardous wastes.
3.1 DISTRIBUTIONS BY WASTE GENERATION RATE CATEGORY
Table 3-1 presents data on estimated number of generators and waste
quantities in the U.S. for various waste generation rate categories. As shown
by the data in the table, the generators producing 5000 kg/mo or less of haz-
ardous wastes are estimated to number close to 722,000 and to generate a total
of 1.4 million metric ton/yr (116 million kg/mo) of wastes. These generators
account for 94.7% of the total number of generators and 2.3% of the total waste
quantity produced. The data also indicate that while the smaller generators
account for very high percentages of generators, their contributions to the
total quantity of hazardous waste produced in the nation are very small. Thus,
while the generators producing 100 kg/mo or less of hazardous waste account for
74% of the total number of generators, the waste produced by these generators
amounts to less than 0.3% of the total waste produced nationally.
The estimates shown in Table 3-1 for the "more than 5000 kg/mo" and the
"total" categories also include estimates for manufacturing SIC's which were
determined in this study to be large generators. Since these SIC's were not
individually assessed, the estimates for these SIC's are those reported in
previous studies. The total estimated national hazardous waste generation of
61 million metric ton/yr (5.1 billion kg/mo) shown in Table 3-1 is in reasonable
agreement with other reported estimates considering the significantly different
bases for these estimates.
3-1
-------
TABLE 3-1. ESTIMATED NUMBER OF PLANTS AND WASTE QUANTITIES FOR
ESTABLISHMENTS IN VARIOUS WASTE GENERATION RANGE CATEGORIES
Waste Generation ,
Ranqes (kq/mo)
less than 100
100 - 200
200 - 300
300 - 400
400 - 500
500 - 600
600 - 700
700 - 800
800 - 900
900 - 1000
1000 - 2000
2000 - 5000 •
more than 5000
U.S. Total
Establishments
Number
563,127
57,587
26,210.
14,847
10,099
6,905
5,176
4,248
3,554
3,107
15,473
11; 292
40,130
761,755
% Total
73.9
7.6
3.4
.2.0
1.3
0.9 '
0.7
0.6
0.5
. 0.4
2.0
;;1.:5
5.3 4
100 5
Waste Quantity
kg/mo
11,697,922
8,638,130
6,549,970
5,196,450
4,544,660
3,797,220
3,364,700
3,186,250
3,020,550
'.2, 952, 080
>3,21Q-,000
39,520,000
,941,031,60
,056,709,53;
1
% Total
0.23
0.17
0.13
0.10
0.09
0.07
0.07
0.06
0.06
0.06
|0.46
0. 78
3 97.7
1 100
1
3-2
-------
Based on industry assessment studies conducted by EPA/OSW, the hazardous
waste produced by 15 major hazardous waste producing manufacturing industries
is estimated at 28.8 million metric ton/yr (2.4 billion kg/mo).* That esti-
mate, however, is considered low since it did not include all the manufactur-
ing and any of the nonmanufacturing industries.''' A more recent estimate
indicates a waste production rate of 47.5 million metric ton/yr (4 billion
kg/mo) for the manufacturing industry.* This estimate, however, is derived
by the application of an estimated "per-employee" waste generation rate to
the employment in various industries. The estimates obtained in the present
study are based on an SIC-by-SIC analysis using actual plant-by-plant survey
data collected in state surveys supplemented by additional data collected in
this study, assuming that the "sample plants" for an SIC are in aggregate
representative of all plants in that SIC (see Sections 5 and 6).
Table 3-2 presents the percentage distributions of number of generators
and waste quantities for establishments included in the surveys conducted by
states of Massachusetts, Iowa, California and Oklahoma. The data in this
table indicate that for the generators surveyed, only about 0.2% of the hazard-
ous waste is produced by the small generators (less than 5000 kg/mo) which
account for 82% of the generators. These surveys, however, do not include any
representation of many of the nonmanufacturing SIC's. For some nonmanufac-
turing SIC's which are included (primarily in the California sample), the
coverage of establishments is less than "representative." The overrepresenta-
tion of the establishments in the manufacturing industries in the four state
samples is primarily responsible for the shift in the distribution of the
number of generators and waste quantities toward the larger generators (com-
pared to the data shown in Table 3-1 which are derived from compositing SIC-
by-SIC results).
As discussed in detail in Section 5, the aggregate data presented in Table
3-1 are the sum total of estimates for individual SIC's (or SIC groups). For
a number of SIC's covered in the state data, some of the establishments respond-
ing to the state surveys had reported "zero" hazardous waste generation. In
*Solid Waste Facts, A Statistical Handbook, U.S. EPA, OPA 113/8, August 1978
^Based on the estimates in this study, hazardous waste produced by the non-
manufacturing industries would be very small compared to that produced by
the manufacturing industries.
^Subtitle C, Resource Conservation and Recovery Act of 1976, Draft Environ-
mental Impact Statement; U.S. EPA, January 1979.
3-3
-------
TABLE 3-2. NUMBER AND WASTE QUANTITIES FOR ALL HAZARDOUS WASTE GENERATORS IN THE STATE
DATA FOR CALIFORNIA, IOWA, MASSACHUSETTS AND OKLAHOMA, BY WASTE GENERATION CATEGORY
WASTT
u>
GENERATION
RAKGtS
KG/MO
iOO-200
200-300
£00-600
600-700
700-800
800-900
900-ii/UO
> 5000
TOTAL
cSTABLISHMeNTS
NUMBIR PcRCtNT
360
IOC
67
35
22
22
16
17
12
96
es
197
33,S
9,3
6.2
3^3
2.»:
2.C
1V5
1.6
1.1
9.1
8.2
18.3
WASTE
KG/MO
11714.
14627.
16248.
13762.
15630.
11826.
14C69.
14565.
11413.
142306.
295174.
252204975.
QUANTITY
PERCENT
.0
.0
.0
.0
.0
.0
.0
.0
.0
".1
.1
99,8
1075
100.0
252778661.
100.0
-------
estimating waste generation profiles for such SIC's allowance was made for the
"zero" generators (i.e., the estimated total number of generators was deter-
mined by subtracting the estimated number of "zero" generators from the total
number of establishments). Since it is very likely that most industrial opera-
tions (especially those in the manufacturing SIC's) produce at least some haz-
ardous wastes (e.g., as a result of plant quality control programs, equipment
maintenance, etc.), and since it is conceivable that the respondents to the
state surveys may have disregarded such small quantities of "incidental" wastes,
the number of very small generators may be somewhat higher than those shown in
Table 3-1. if it is assumed that the reported "zero" generators in the manu-
facturing industries indeed belong to the less than 100 kg/mo category, the
estimated number of generators in this category and the estimated total number
of generators would increase by 150,000. This would increase the percentage of
the number of generators in the less than 100 kg/mo category from the 74% shown
in Table 3-1 to 78%.
3.2 DISTRIBUTION BY SIC
Tables 3-3 and 3-4 present the aggregated waste generation profiles for
the manufacturing and nonmanufacturing industries. Based on the data in these
tables, establishments in the manufacturing industries account for 17% of all
generators and 96% of the total waste; establishments in the nonmanufacturing
industries account for 83% of all generators and 4% of the total waste. The
small generators (i.e., generators producing less than 5000 kg/mo of hazardous
waste) in the manufacturing industries account for 13% of all small generators
and 47% of waste produced by all small generators (compared to 87% and 53%,
respectively, for the small generators in the nonmanufacturing industries).
Also, while in the nonmanufacturing industries small generators account for
very high percentages of both the waste generating establishments and the waste
quantity (99% and 8%, respectively), in the manufacturing industry the small
generators account for a smaller (but still large) percentage (74%) of the
generating establishments but a very low percentage (1.1%) of the waste pro-
duced. Based on the data in Tables 3-3 and 3-4, the average waste generation
rate for the small generators in the manufacturing and nonmanufacturing sectors
are 576 and 98 kg/mo, respectively.
3-5
-------
TABLE 3-3. ESTIMATED NUMBER OF PLANTS AND WASTE QUANTITIES FOR
ESTABLISHMENTS IN VARIOUS WASTE GENERATION RANGE CATEGORIES
(MANUFACTURING SIC'S) .
UAC+-** fi#*npT*a
-------
TABLE 3-4. ESTIMATED NUMBER OF PLANTS AND WASTE QUANTITIES FOR
ESTABLISHMENTS IN VARIOUS WASTE GENERATION RANGE CATEGORIES
' ' (NONMANUFACTURING S1C'S)
Waste Generation
Ranges (kq/mo)
less than 100
100 - 200
200 - 300
300 - 400
400 - 500
500 - 600
600 - 700
700 - 800
800 - 900
900 - 1000
1000 - 2000
2000 - 5000 •
more than 5000
U.S. Total
Establishments
Number
519,537
48,196
20,206
10,674
6,805.;
4,163
2,799
2,310
1,718
1,300
6,168
' 4,354
6,752
634,982
% Total
81.9
7.6
3.2
.1.7
1.1
0.66
0.44
0.36
0.27
0.20
0.97
: 0,69
1.1
100
Waste Quantity
kg/mo
9,594,417
7,229,430
5,048,970
3,735,900
3,062,160
2,289,320
1,819,350
1,732,500
1,460,300
• 1,235,380
9,252,000'
15,239,000
144,998,912
206,697,639
1
% Total
4.6
3.5
2.4
1.8
1.5
1.1
0.88
0.84
0.71
0.60
4.5
7.4
70.2
100
i
3-7
-------
Table 3-5 compares the actual distributions for the manufacturing and non-
manufacturing establishments covered in the state data base for the small gen-
erators, with the estimated distributions calculated from the data in Tables
3-3 and 3-4. As noted by data in these tables, the observed distributions for
the establishments in the aggregate state sample differ from those calculated
using the SIC-by-SIC appraoch. While the establishments in the state data for
a given SIC may be representative of all establishment in that SIC, in aggregate
the state data cannot provide an accurate representation of the distribution of
generators and waste quantities since various SIC's are not represented in the
state sample in proportion to their nationwide total number of establishments.
It has been for this reason that an SIC-by-SIC approach using both the state
data and the census data (on the number of establishments in various SIC's) has
been used in this study to develop the waste generation profiles (see Sections
5 and 6).
Tables 3-6 and 3-7 present data on the estimated relative contributions of
various SIC groups to the total number of generators and waste quantity for the
manufacturing and nonmanufacturing industries, respectively. In the small gen-
erator category, the major contributing SIC's in the nonmanufacturing segment
are SIC's 17, 55, 72, and 75, which collectively account for 78% of the small
generators and 53% of the waste in the nonmanufacturing sector. The major
contributing SIC's in the manufacturing segment are SIC's 27, 34 and 35, which
collectively account for 60% of the small generators and 48% of the waste in
the manufacturing sector.
3.3 DISTRIBUTION BY EPA REGION
Table 3-8 summarizes the estimated number of generators and waste
quantities in various waste generation range categories for EPA Regions I
through X,* including a breakdown by manufacturing and nonmanufacturing indus-
tries. The data in this table indicate that EPA Regions II, IV, V and IX
have the greatest number of small generators in both the manufacturing and non-
manufacturing industry segments.
*See Figure 1-2 for the states covered by each EPA region.
3-8
-------
TABLE 3-5. COMPARISON OF THE OBSERVED DISTRIBUTIONS OF THE SMALL GENERATORS IN THE STATE DATA BASE WITH
THE ESTIMATED NATIONAL DISTRIBUTIONS FOR THE SMALL GENERATORS
Waste
Generation
Range, kg/mo
0-100
100-200
200-300
300-400
400-500
500-600
600-700
700-800
800-900
900-1000
1000-2000
2000-5000
Nonmanufacturing Establishments
Number of Generators (%)
State Data*
56
12
6.0
3.2
2.5
1.1
1.4
0.7
1.4
1.1
7.1
8.1
Estimated
National''"
83 .
7.7
3.2
1.7
1.1
0.66
0.44
0.37
0.27
0.21
0.98
0.69
Waste Quantities (%)
State Data*
3.5
3.6
3.1
2.3
2.4
1.2
2.0
1.2
2.5
2.1
22
54
Estimated
National''"
15
12
8.2
6.1
5.0
3.7
2.9
2.8
2.4
2.O
15
25
Manufacturing Establishments
Number of Generators (%)
State Data*
32
10
6.7
5.8
4.9
2.6
3.3
3.3
2.2
1.5
13
14
Estimated
National^
47
10
6.4
4.5
3.5
2.9
2.5
2.1
2.0
1.9
10
7.4
Waste Quantities (%)
State Data
1.3
1.9
2.0
2.4
2.7
1.7
2.6
3.0
2.3
1.7
23
55
Estimated
National*
3.9
2.6
2.8
2.7
2.8
2.8
2.9
2.7
2.9
3.2
26
45
U)
10
*The small generators in the state data for which waste quantity data are available cover 283 nonmanufactur-
ing establishments and 1827 nonmanufacturing establishments, producing waste quantities totalling 133,000
and 1,510,000 kg/mo, respectively. (These numbers do'not include discharges to POTW's or waste oils.)
Calculated from the data in Table 3-3.
+ . f
"'"Calculated from the data in Table 3-4.
-------
TABLE 3-6. RELATIVE CONTRIBUTIONS OF VARIOUS MANUFACTURING INDUSTRIES TO THE HAZARDOUS
WASTE GENERATION PICTURE
Industry
SIC 22 - Textile Mill Products
24 - Lumber and Wood, Except Furniture
25 - Furniture and Fixtures
26 - Paper and Allied Products
27 - Printing a'nd Publishing
28 - Chemicals and Allied Products
29 - Petroleum Refining
30 - Rubber and Misc. Plastics
31 - Leather and Leather Products
32 - Stone, Clay, Glass and Concrete
33 - Primary Metal Industries
34 - Fabricated Metal Products
35 - Machinery, Except Electrical
36 - Electrical and Electronic
37 - Transportation Equipment
38 .- Measuring Instruments
39 - Miscellaneous Manufacturing
TOTAL
Small Generators
Number
2,000
2,100
4,90.0
2QQ
23,000
4,400
240
1,700
590
2,600
2,400
14,000
18,000
5,000
3,200
2,400
5,200
92,000
Waste, 106 kg/mo
1.5
0.54
3.5
0.23
5.8
4.5
0.27
0.93
0.39
1.4
1.8
7.1
12
3.0
4.5
1.7
2.9
52
All Generators
Number
2,500
2,500
4,900
1,100
27,000
7,100
500
3,100
770
2,600
, 4,000
17,000
25,000
7,800
6,600
3,400
6,500
120,000
Waste, 106 kg/mo
150
4.7
3.5
260
39
1500
71
25
18
1.4
440
220
410
120
1300
83
58
4700
U)
I
-------
TABLE 3-7. RELATIVE CONTRIBUTIONS OF VARIOUS NONMANUFACTURING INDUSTRIES TO THE HAZARDOUS
WASTE GENERATION PICTURE
Industry
SIC 018
07
17
40
41
42
43
45
51
55
72
73
75
76
79
80
82
84
89
- Horticultural Specialties
- Agricultural, Landscape and
Horticultural Service
- Construction - Special Trade
- Railroad Transportation
- Local and Suburban Transit
- Motor Freight Transportation
- U.S. Postal Service
- Transportation by Air
- Wholesale Trade - Nondurable
Goods
- Automotive Dealers and Gasoline
Service Stations
- Personal Services
- Business Services
- Automotive Repair Services
- Miscellaneous Repair Services
- Amusement and Recreation Serv.
- Health Services
- Educational Services
- Museums, Art Galleries, Botanical
and Zoological Gardens
- Miscellaneous Services
TOTAL
Small Generators
Number
5,000
24,000
150,000
550
4,800
0
250
3,100
3,800
98,000
190,000
30,000
53,000
25,400
6,900
11,000
23,000
1,200
1,180
630,000
Waste, 106 kg/mo.
0.03
3.5
2.2
1.5
0
0.08
2.4
0.30
18
8.1
3.9
4.8
13
0.06
2.3
1.1
0.09
0.25
62
All Generators
Number
5,000
26,000
150,000
1,700
4,800
500
250
3,300
3,800
98,000
190,000
31,000
53,000
25,400
6,900
11,000
23,000
1,800
1,200 .
637,000
Waste, 106 kq/mo
0.03
56
2.2
43
1.7
3.0 .
0.08
3.4
0.4
18
36
5.7
4.8
28
0.06
3.4
1.1
0.09
0.25
207
u>
I
-------
TABLE 3-8. ESTIMATED NUMBER OF GENERATORS AND WASTE QUANTITIES FOR MANUFACTURING, NONMANUFACTURING AND ALL
INDUSTRIES BY EPA REGION
EPA
Region
I
II
III
IV
V
VI
VII
VIII
IX
X
U.S.
TOTAL
Nonmanufacturing
No. of Generators,
103
Small
37
76
69
100
128
66
37
20
76
22
628
All
37
76
70
100
130
67
37
20
76
22
635
Waste Quantity,
106 kg/mo
Small
4.0
7.0
7.0
10
12
7.0
4.0
2.0
7.0
2.0
62
All
10
21
23
31
43
20
14
6.0
31
8.0
207
Manufacturing
No. of Generators,
ID3
Small
7.0
14
8.0
11
22
8.0
4.0
3.0
12
3.0'
93
All
10
19
10
16
31
11
6.C
3.C
17
4
127
Waste Quantity,
106 kg/mo
Small
4.0
8.0
4.0
7.0
13
5.0
3.0
1.0
7.0
2.0
54
All
328
653 :
402
746
1073
465
23.0
146
643
164
4850
All Industries
No. of Generators,
103
Small
45
90
77
110
150
74
41
22
88
: 25
722
All
47
95
80
116
160
77
43
24
93
26
762
Waste Quantity,
106 kg/mo
Small
8.0
15
11
17
25
11
6.0
4.0
15
4.0
116
All
338
674
425
777
1116
485
244
152
674
172
5157
GO
I
-------
The regional profiles summarized in Table 3-8 have been developed in a
manner similar to that used in the development of national profiles (e.g.,
Table 3-1) assuming the 20-state "national" data base for an SIC and the
supplementary data obtained in this study from selected establishments are
also representative of the establishments in that SIC on a regional level.*
The regional waste generation profiles were estimated from the national profile,
assuming that for each SIC, the number of plants in a given waste generation
range category in a region is proportional to the ratio of the total number
of plants in that region to the total number of plants in that SIC in the U.S.
This implies that for each region and SIC the ratio of the generators in a
given size range to the total number of generators in that size range in the
U.S. is the same for all waste generation range categories.
The regional waste quantity estimates shown in Table 3-8 for the manu-
facturing industries compare reasonably well with another regional estimate
which uses employment as a basis for estimating waste quantity for plants in
an SIC.^ No regional estimates are available from other sources on the number
and waste quantities for the small generators in the manufacturing industries
and the small and large generators in the nonmanufacturing industries for com-
parison with the estimates shown in Table 3-8.
3.4 DISTRIBUTION BY DISPOSAL METHOD
Table 3-9. presents the percentage distribution of the small generators
in the state data base using various waste disposal methods and the quantity
of waste handled by each disposal method.^ As shown by the data in the table,
Direct estimation of profiles for a region based on the state data for that
region was not possible for all regions because of lack of data for states
in all regions (no data were available in the state data base for any of the
states in Regions VIII, V and III).
tsubtitle C, Resource Conservation and Recovery Act of 1976, Draft Environ-
mental Impact Statement, U.S. EPA, January 1979; this reference presents the
following estimates for regional waste quantities are for the manufacturing
industries :
EPA Region: I II III IV V VI VII VIII IX X
Waste quantity, 106 kg/mo: 203 599 459 587 992 401 181 39 282 77
the establishments covered in the state data base, 40% did not disclose
waste disposal method. The percentage shown in Table 3-9 are for those dis-
closing the waste disposal method.
3-13
-------
landfill disposal* is used by the largest percentage (51%) of the small genera-
tors and the largest percentage (46%) of the total waste is also handled by
this method. Next to landfill, recycling is the most prevalent disposal method.
The percentage of generators using other disposal methods and the percentage of
waste handled by such methods are 26% and 33%, respectively.
TABLE 3-9. PERCENT DISTRIBUTIONS OP SMALL WASTE GENERATORS AND WASTE QUANTITIES
IN THE STATE DATA BASE BY DISPOSAL METHOD*
Disposal Method
Landfill
Incineration
Lagoon
Deep well injection
Landspreading
Others
Recycle
Total, %
Generators
On site
2.9
1.5
2.6
0.1
5,8
6.6
2.6
22.1
Offsite
48.4
2.6
0.3
2.2
1.2
2.8
20.4
77.9
Total
51.3
4.1
2.9
2.3
7.0
9.4
23
100
Waste Quantity
Ons ite
3.4
1.6
3.9
0.3
5.0
6.1
2.3
22.6
Offsite
42.4
5.0
0.5
5.6
2.1
2.8
19.0
77.4
Total
45.8
6.6
4.4
5.9
V'.l
8.9
21.3
100
*0f the establishments that reported waste disposal methods, 12% did not dis-
close whether onsite or offsite disposal facilities were used. The percentages
shown in the table assume the same onsite/offsite distribution for establish-
ments which did not indicate onsite/offsite as for establishments which re-
ported using the use of one or the other method.
The percentage of the small generators using on-site disposal and the
percentage of the waste handled at on-site facilities is 22% and 23% each
*
(see Table 3-9) . In general, it is more economical and more convenient for
*The respondents to the state surveys who have indicated waste disposal via
landfilling, have referred to the disposal site/method by a variety of names
including "sanitary" landfills, "industrial" landfills, "county dump" "state-
approved" landfills and "municipal" landfills. Except in some states (e.g.,
California and Texas) where a landfill classification system exists and the
use of certain landfills designated specifically for hazardous waste dis-
posal (e.g., Class I landfills in California) was indicated by a survey
respondent, it is believed that the majority of landfills referred to in the
state surveys are sanitary landfills which may or may not meet the sanitary
landfill design requirements proposed under RCRA Section 4004.
3-14
-------
the small generators to dispose of waste at off-site facilities than to carry
out on-site waste disposal. By use of off-site waste disposal facilities the
small generators would benefit from the economy of scale and waste management
expertise associated with off-site disposal operations.
Assuming that' the state data shown in Table 3-9 are representative of
the disposal practices for the small generators in the manufacturing SIC's
and that the small generators in the nonmanufacturing SIC's largely use land-
fills for waste disposal, estimates have been made of the number of small
generators in the U.S. using various disposal methods and of the quantity of
waste handled by each disposal method. These estimates are shown in Table
3-10. The estimates in this table indicate that on an aggregate level, 96%
of the estimated 722,000 small generators which dispose of waste by methods
other than recycling use landfills for waste disposal and that 79% of the
estimated 116 million kg/mo of wastes generated by the small generators is
disposed of in landfills. Table 3-11 presents the estimated breakdown by
waste generation range category for the small generators using landfills
and for the associated waste quantities. As with the waste generation pro-
files for the small generators, the largest percentage of the small genera-
tors using landfills are in the less than 100 kg/mo waste generation rate
category whereas the largest percentage of the waste disposed of in landfills
are from the generators in the larger waste generation rate categories.
*Except for the generators using deep well injection, which may be overrepre-
sented in the state data base by plants from Oklahoma (a state in which this
disposal practice is more prevalent than in other states), this assumption
appears reasonable. To date the disposal practice employed by waste genera-
tors has been primarily a function of local and state regulations which
have varied widely among states, with most states having no specific regu-
lations for small generators. The 20 states which comprise the state data
base represent a spectrum of waste management regulations and in aggregate
waste disposal practices reported by plants in these states should be repre-
sentative of the national picture.
3-15
-------
TABLE 3-10. ESTIMATED TOTAL NUMBER OF SMALL WASTE GENERATORS AND WASTE
QUANTITIES BY DISPOSAL METHOD*
Disposal Method
Landfill
Incineration
Lagoon
Deep well injection
Landspreading
Others
Recycle
Total
Number of Generators
690,000
5,000
3 ',000
8,000
11,000
5,000
99,000
819,000+
Waste Quantities, million kg/mo
92
6
3
4
5
6
30
146f
*The estimates shown in this table have been obtained in the following manner:
the percentages shown for the "total" columns in Table 3-9 were applied to
the calculated profiles for manufacturing SIC's. All nonmanufacturing gen-
erators were assumed to dispose of waste by landfilling, except generators
in SIC's 55, 751 and 7538 which were assumed to employ both recycling (40% of
the generators and waste quantities) and landfilling (60% of the generators
and waste quantities) for waste disposal.
^These total values differ from the estimates for the small generators in Table
3-1 by amounts corresponding to the estimates for the "recyclers" (i.e.,
99,000 establishments and 30 million kg/mo).
3-16
-------
Table 3-11. BREAKDOWN OF THE ESTIMATED NUMBER OF SMALL GENERATORS
DISPOSING WASTE IN LANDFILLS AND ASSOCIATED WASTE QUANTITY
. • BY WASTE GENERATION RANGE CATEGORY*
tjae^A f^ATi^T"At*i r»n
Panges (kq/mo)
less than 100
100 - 200
200 - 300
300 - 400
400 - 500
500 - 600
600 - 700
700 - 800
800 - 900
900 - 1000
1000 - 2000
2000 - 5000 •
core than 5000
U.S. Total
Establishments
Number
550,000
55,000.
23,000 .
14,000 :
10,000 •
5,000
4,000 '.
4,000
2.000
2,000
12,000
9,000
~ .
690,000
% Total
80
7.9
3.4'
•2.0
1.4
0.8
0.6
0^6
0.3
• 0.3
1.7
-1.4
—
100
Waste Quantity
106 kq/mo
10
8.-1
5.8
4.8
4.2
2.9
2.7 ..
3.0
1.7
1.9
16 ' .
31.
•-- ' ;.'
92
% Total
10
8.8
6.3
5.2
4.5
3.2
2.9
3.3
1,2
2.0
18 '
34
100
*These.estimates have been -obtained in a manner similar to"that used .to
obtain the estimates shown in Table 3-10 (see footnotes to that table)'
assuming that (a) the observed distributions of.the generators using
landfill disposal ^nd of the waste quantities disposed of in landfills
in the state data are in aggregate representative of .the landfill dis-
posal pattern in the manufacturing SIC's, and (b) -all nonmanufacturing
small generators use landfill disposal, except generators in SIC's 55,
. 751 and 7538 for which it was assumed that 60% of the generators in
each range.category use landfills. . '
3-17
-------
4. ANALYSIS OF TECHNICAL ENVIRONMENTAL IMPACTS OF REGULATORY OPTIONS
A number of options are conceivably available to regulate small genera-
tors including:
(1) Quantity Option - Generators that produce or accumulate for disposal
hazardous waste in quantities not exceeding a set amount ("cut-
off") are exempt from the manifest requirements of Section 3002
and the waste is exempt from the management requirements of Sec-
tion 3004.
(2) Phasing Option - Same as the quantity option, except that the cut-
off is initially set at a high level but reduced in subsequent
years to accommodate limited state and Agency administrative
resources in the first years of the regulatory program.
(3) Degree of Hazard Option - Cutoffs are set for waste streams or
classes of waste depending on the degree of hazard of the waste.
(4) Reduced Administrative Requirements Option - Generators beneath
the cutoff are regulated under Subtitle C, but their administra-
tive and/or technical requirements are reduced.
(5) State Regulation Option - Generators beneath the cutoff are not
regulated under Subtitle C where they are regulated in an approved
manner by state regulations.
The environmental impacts of the Quantity and Phasing Options are ana-
lyzed here. The economic and administrative impacts of these two options
and the impacts of the Reduced Administrative Requirements Option are ana-
lyzed in the Economic Impacts Study.
The Degree of Hazard and State REgulation Options are not specifically
analyzed although the data base developed in these studies can be used to
some extent to analyze those options.
4.1 QUANTITY OPTION
A review of the reported damage incidents involving hazardous waste*
indicates that a number of such incidents have involved very small quantities of
hazardous waste, which may suggest the desirability, of strict control of all
hazardous waste (irrespective of quantity). Although from the standpoint of
protection of human health and environment a regulation system providing for
*A summary of the reported cases of damage involving hazardous_wastes is
contained in the following reference: Subtitle C, Resource Conservation and
Recovery Act of 1976, Draft Environmental Impact Statement; U.S. EPA, January
1979. Selected examples of damage cases involving small quantities of haz-
ardous waste are presented in Appendix C.
4-1
-------
such a strict control of all hazardous waste may be desirable, it is essential
to strike a balance between the need to protect the environment and the neces-
sity to hold the economic burden within practical and reasonable limits.
As discussed in Section 3.1, there are an estimated total of 722,000 gen-
erators in the less than 5000 kg/mo waste generation rate category. These
generators, which account for 94.7% of the total number of the generators in
the U.S.,produce 1.4 million metric- ton/yr (116 million kg/mo) of hazardous
waste, or 2.3% of the total hazardous waste produced nationally.
4.1.1 Impacts on Number of Generators and Waste Quantities
Figure 4-1 presents plots of the percentages of the small generators
(less than 5000 kg/mo waste generation rates) and associated waste quantities
which would be excluded from a conditional exemption type regulation system
as a function of waste quantity exemption cutoff. Similar plots expressing
the data as percentage of all generators and the total quantity of waste from
all generators are presented in Figure 4-2. The plots in Figures 4-1 and 4-2
are constructed from the data in Table 3-1. The plots in Figure 4-1 are a
demonstration of the so-called "80-20" rule, which in this particular case
indicates that 80% of the waste from small generators is generated by 13% of
such generators. Since the greatest number of small generators are in the
very small waste generation rate category, a waste cut-off level of 100 kg/mo
would exclude 78% of the small generators (74% of all generators) and 10% of
the waste from small generators (0.23% of waste from all generators). As the
cut-off level is raised, the increase in the percentage of the generators
excluded becomes less dramatic while the increase in the percentage of the
waste excluded becomes more significant. Thus, a 1000 kg/mo cutoff would
entail exclusion of 96% of the small generators (91% of all generators) and
46% of the waste from small generators (1.1% of waste from all generators);
at a 4000 kg/mo cutoff the number of small generators and associated waste
quantities excluded are, respectively, 99% and 91% of the values for small
generators and 94% and 2% of the values for all generators.
4.1.2 SIC-Specific Impacts
Tables 4-1, 4-2, 4-3 and 4-4 list the SIC's which would be most affected
by waste exemption cut-off levels of 100, 500, 1000 and 5000 kg/mo, respec-
tively. The listed SIC's or SIC groups are those for which about 90% of the
4-2
-------
I
U)
NUMBER OF GENERATORS
500 1000 1500 2000 2500 3000 3500 4000 4500
HAZARDOUS WASTE EXEMPTION CUTOFF, KG/MO
FIGURE 4-1. IMPACT OF WASTE EXEMPTION CUTOFF ON THE SMALL HAZARDOUS WASTE GENERATORS
5000
-------
100
to
w
a-
^—t
I
w
500
1000
1500 2000 2500 3000 3500
HAZARDOUS WASTE EXEMPTION CUTOFF, KG/MO
4000
4500
5000
FIGURE 4-2,. IMPACT OF WASTE EXEMPTION CUTOFF ON HAZARDOUS WASTE GENERATORS
-------
TABLE 4-1. SIC'S MOST AFFECTED BY A WASTE EXEMPTION CUTOFF OF 100 KG/MO*
018 - Horticultural Specialties
078,0783,8421 - Landscape and Horticultural Services, Botanical and
Zoological Gardens and Arboreta
1721 - Painting, Paper Hanging and Decorating Contractors
1711,1742,1751,1752,
1761,1795 1799 - Construction-Special Trade Contractors
2421 - Sawmills and Planing Mills
5122 - Drugs, Drug Proprietaries and Druggists Sundries (Wholesale)
7215 - Coin-Operated Dry Cleaners
7217 - Carpet and Upholstery Cleaners
7231,7241 - Barber and Beauty Shops
7261 - Funeral Services and Crematories
7332 - Blueprinting and Photocopying Services
7399 - Miscellaneous Business Services, Not Elsewhere Classified
7531-35 - Auto Body, Paint, Upholstery Shops
7542 - Car Washes
7933 - Bowling Alleys
7948 - Horse Tracks
7996 - Amusement Parks
8211 - Elementary and Secondary Schools
8411 Museums
8922 - Noncommercial Educational, Scientific and Research Organizations
*SIC's listed are those for which about 90% of the generators produce less
than 100 kg/mo of potentially hazardous waste; many of these SIC's do not
produce waste which is hazardous according to the proposed Subtitle C regu-
lations, notwithstanding any quantity considerations; inclusion of a poten-
tially hazardous waste in the data base for this study does not imply that
the Agency intends to regulate that waste; SIC groupings are those used in
the preparation of combined assessment summaries presented in Appendix B
of Volume II.
4-5
-------
TABLE 4-2. SIC'S MOST AFFECTED BY A WASTE EXEMPTION CUTOFF OF 500 KG/MO*
All SIC's listed in Table 4-1 plus the following additional SIC's
0741,0742 - Veterinary Services
43 - U.S. Postal Service
5541 - Gasoline Service Stations
7216 - Dry Cleaning Plants
7341,7349 - Commercial Cleaning and Janitorial Services
7342 - Disinfecting and Exterminating Services
751 - Auto Rental and Leasing
7538 - Automotive Repair Garages
7539 - Radiator and Carburetor Shops
8071 - Medical Labs
*SIC's listed are those for which about 90% of the generators produce less
than 500 kg/mo of hazardous waste; SIC groupings are those used in the
preparation of combined assessment summaries presented in Appendix B of
Volume II.
TABLE 4-3. SIC'S MOST AFFECTED BY A WASTE EXEMPTION CUTOFF OF 1000 KG/MO*
All SIC's listed in Tables 4-1 and 4-2 plus the following additional SIC's
41 - Passenger Transport Vehicles
4511 - Air Transportation, Certified Carriers
4583 - Airport Terminal Services
7397 - Commercial Testing Laboratories
806 - Hospitals
*SIC's listed are those for which about 90% of the generators produce less
than 1000 kg/mo of hazardous waste; SIC groupings are those used in the
preparation of combined assessment summaries presented in Appendix B of
Volume II.
4-6
-------
TABLE k-k. SIC'S MOST AFFECTED BY A WASTE EXEMPTION CUTOFF OF 5000 KG/MO*
All SIC's listed in Table 4-1, 4-2 and 4-3 plus the following additional SIC's
2079 - Fats and Oils Manufacture
2111,2221 - Broad Woven Fabric Mills :
2241,228,229 - Narrow Fabric, Yarn and Thread, and Miscellaneous Textile
Mills
2291 - Felt Goods
2500 - Wood and Metal Furniture
2840 - Soaps and Detergents
2873 - Nitrogenous Fertilizers
2875 - Fertilizers, Mixing Only
2879 - Pesticides and Agricultural Chemicals Preparation
3100 - Leather Products (except tanning and finishing)
32 - Stone, Clay, Glass and Concrete Products
3320 - Iron and Steel Foundries
3398 - Metal Heat Treating
3399 - Miscellaneous Primary Metal Products
3410 - Metal Cans and Shipping Containers
3440 - Fabricated Structural Metal Products
3450 - Screw Machine Products, Nuts, Bolts, Rivets and Washers
4582 - Airports and Flying Fields
5161 - Chemical and Allied Products - Chemical Wholesalers
5511 - Motor Vehicle Dealers
7221,7333,7395,7819 -.Photoprocessing
7391 - Research and Development Laboratories
76 - Miscellaneous Repair Services
8221,8222 - Colleges, Universities, Professional Schools and Junior
Col leges
*SIC's listed are those for which about 90% of the generators produce less
than 5000 kg/mo of hazardous waste; SIC groupings are those used in the
preparation of combined assessment summaries presented in Appendix B of
Vo1ume II.
4-7
-------
generators would be exempted from full Subtitle C regulations if the cutoff
is placed at the indicated levels. Since the small volume generators are con-
centrated in the service industries (see discussion in Sections 3.2 and 3.3),
essentially no manufacturing SIC's appear in the SIC list in Table 4-1 and only
one SIC (SIC 2421) appears in the SIC list for the 500 kg/mo cutoff (Table 4-2).
4.1.3 Impacts on Current Disposal Practices
As discussed in Section 3.4, landfilling, landspreading, incineration
and recycling are the most prevalent disposal practices currently used by the
small generators. Perhaps with the exception of some offsite recycling and
incineration which may be carried out at facilities meeting Subtitle C require-
ments, the current disposal practices used by small generators by and large do
not meet the Subtitle C requirements. For example, "landspreading" disposal
method, as currently employed, consists largely of discharges on the nearest
open ground or "drainage" area; landfills which are reportedly used are the
common sanitary landfills and "dumps," some which at best may meet only the
Subtitle D requirements. If it is assumed that currently only about 10% to
20% of the small generators use disposal methods which would meet Subtitle C
requirements, at any waste quantity exemption cutoff from 80% to 90% of the
small generators not exempted would be impacted by any requirement for dis-
posal in Subtitle C facilities. The smaller percentage impact would perhaps
be associated with the larger waste generation rate categories (e.g., 2000-
5000 kg/mo) since most of the small generators which may currently use dis-
posal methods consistent with Subtitle C requirements are expected to be in
these larger waste generation rate categories •
Figure 4-1 presents the estimated percentages of small hazardous waste
generators and waste quantities subject to Subtitle C disposal regulations
as a function of waste quantity exemption cutoff.* At a "zero" kg/mo waste
quantity exemption cutoff, all generators would be required to dispose of
waste in Subtitle C facilities; at a 5000 kg/mo cutoff no small generators
would be required to dispose of waste in Subtitle C facilities, but instead
all small generators would be required to dispose of waste in facilities
*The ordinance values shown in Figure 4-1 are actually the percentages of
small generators and waste quantities exempted; the percentages of genera-
tors and waste quantities not exempted and hence subject to RCRA Subtitle C
disposal regulations are obtained by subtracting the ordinance values shown
from 100.
4-8
-------
meeting at least Subtitle D requirements. Assuming that overall about 90%
of the small generators currently dispose of waste in facilities which do
not meet Subtitle C requirements and that the wastes associated with such
disposal practices amount to about 90% of the wastes from small generators,
the estimated number of small generators and waste quantities which would be
impacted by a requirement for disposal at Subtitle C facilities would be
650,000 and 1.2 million metric ton/yr (104 million kg/mo) at 0 kg/mo cutoff;
143,000 and 1.1 million metric ton/yr (94 million kg/mo) at 100 kg/mo cutoff;
24,000 and 0.67 million metric ton/yr (56 million kg/mo) at 1000 kg/mo cut-
off; and 5200 and 0.11 million metric ton/yr (9 million kg/mo) at 4000 kg/mo
cutoff.
4.1.4 Impacts on the Capacity of pommercial Waste Management Facilities
The lowering of the waste quantity exemption cutoff for small generators
would result in an increase in the number of such generators which would be
regulated under Subtitle C of RCRA. Since many of the small generators which
currently dispose of waste onsite may lack the necessary financial and techni-
cal resources to conduct onsite disposal in compliance with RCRA regulations,
it is anticipated that an increasing number of such generators may find it more
convenient to use offsite facilities for waste disposal. This will undoubtfully
create a demand for additional capacity at existing offsite disposal facilities
or for new facilities.
Table 4-5 presents the estimated available hazardous waste management
industry capacity and capacity deficit by EPA region for waste quantity exemp-
tion cutoffs of 0, 100, 500, 1000 and 5000 kg/mo. As noted in the table, the
total national available capacity of offsite facilities to receive hazardous
waste is estimated at 518 million kg/mo which is 26% less than the required
capacity for the disposal of hazardous wastes from large generators destined
for disposal at offsite facilities. Except for EPA Regions V, VII, IX and X
which have an excess capacity, a capacity deficit exists at all EPA regions
even when the waste quantity exemption cutoff is placed at as high a level as
5000 kg/mo. The capacity deficit is most severe in Regions VIII (which has
currently no hazardous waste management facility), VI (73% deficit), IV (90%
deficit) and I (90% deficit). Regions V, VII, IX and X which have excess
capacity for a waste cutoff of 5000 kg/mo would continue to maintain their
overcapacity for all cutoff levels.
4-9
-------
TABLE 4-5. ESTIMATED HAZARDOUS WASTE MANAGEMENT INDUSTRY CAPACITY AND DEMAND
(MILLION KG/MO) BY EPA REGION FOR VARIOUS WASTE QUANTITY EXEMPTION
CUTOFFS
EPA
Region
I
II
III
IV
V
VI
VII
VIII
IX
X
National
Total
Capacity "1"
5
46
32
8
206
39
26
0
69
77
518
Capacity Demand for Various Cutoff Levels*
5000 kg/moi"
49
59
76
84
175
179
19
9
42
10
702
1000 kg/mo
53
66
81
92
188
184
22
10
50
12
758
500 kg/mo
55
69
83
94
193
186
23
11
52
13
779
100 kg /mo
56
72
86
99
199
189
25
12
55
14
808
0 kg/mo
57
74
87
101
201
190
25
12
57
14
818
*The capacity demands assume that the wastes from all small generators not
exempted will go to off-site waste management facilities; and that only a
fraction (17% on the national level) of the waste from large generators are
taken to off-site landfills (see the following footnote).
1"The estimates of available capacity and the demand associated with the 5000
kg/mo cutoff are from the following reference: Foster D. Snell, "Potential
for Capacity Creation in the Hazardous Waste Management Service Industry,"
NTIS Report PB-257-187, 1976. Although the Reference does not refer to a
5000 kg/mo cutoff, it is assumed that the data in the reference are for
"large" generators which would correspond roughly to the generators pro-
ducing more than 5000 kg/mo; the waste quantities are significantly less
than the estimated total quantity of hazardous wastes produced regionally
since most of the hazardous waste produced by large generators are dis-
posed of in onsite facilities. On an aggregate national level, only about
17% of waste from large generators are disposed of in off-site facilities.
4.1.5 Impacts on "Dilution" of Hazardous Waste in Subtitle D Facilities
The exemption of small generators from full Subtitle C regulations enables
generators to dispose of their wastes in facilities that meet the requirements
of Section 4004 of RCRA (i.e., Subtitle D facilities).
As noted previously, the estimated quantity of hazardous waste produced
by the small generators in the less than 5000 kg/mo waste generation rate
category amounts to only 2.3% of the total quantity of hazardous waste produced
nationally. The impact on site capacity requirement would be very small if all
4-10
-------
hazardous wastes from the small generators are diverted to Section 4004 faci-
lities and co-disposed with nonhazardous waste. The total amount of municipal
refuse which is currently produced in the nation is estimated at 132 million
metric ton/yr (11 billion kg/mo).* Thus, on an aggregate level co-disposal
of 1.4 million metric ton/yr (115 million kg/mo) of hazardous waste from
small generators with 132 million metric ton/yr of municipal refuse (i.e.,
if the waste exemption cutoff is placed at 5000 kg/mo) represent a 94 fold
"dilution" of hazardous waste and such a high dilution ratio should minimize
adverse impacts associated with the disposal of hazardous wastes in RCRA
Section 4004 facilities. A much higher "dilution" would be expected for
lower waste quantity exemption cutoffs. Thus, as shown in Figure 4-3, dilu-
tion ratios of 210, 300 and 940 would be expected from waste quantity exemp-
tion cutoffs of 1000, 500 and 100 kg/mo, respectively.
Although on an overall and national level, the dilution of hazardous
waste with nonhazardous waste at sanitary landfills may be at an acceptable
level, an acceptable dilution level may not be attainable at all landfills
(e.g., at some of the landfills serving heavily industrialized areas or at
onsite landfills used by industry for co-disposal of hazardous and nonhazard-
ous wastes "fy . Adequate data are currently unavailable to identify and inven-
tory specific landfills in which an acceptable dilution ratio may be
unattainable.
4.1.6 Impact on Waste Transportation and Probability of Waste Spills
Commercial hazardous waste management facilities meeting RCRA Subtitle
C requirements are considerably fewer in number than sanitary landfills (Sub-
title D facilities). Regulations requiring the small hazardous waste genera-
tors to segregate their waste from nonhazardous refuse and to dispose of them
in Subtitle C facilities would thus entail transporting hazardous waste from
*Solid Waste Facts, A Statistical Handbook, U.S. EPA, OPA 113/8, August 1978
^Only a very small percentage of the small generators use onsite landfills;
based on the state data only 4% of the small generators , accounting for 2% of
the waste, dispose of hazardous waste in onsite landfills. No data are avail-
able on the quantity of nonhazardous waste disposed of in these onsite land-
fills.
4-11
-------
900
800
600 -
a
400
200
1000
2000 3000 4000
EXEMPTION CUTOFF, KG/MO
5000
FIGURE 4-3. NONHAZAREOUS WASTE TO HAZARDOUS WASTE DILUTION RATIOS AT
SUBTITLE D FACILITIES AS A FUNCTION OF WASTE QUANTITY
EXEMPTION CUTOFFS
4-12
-------
.small generators in more "concentrated" form and over longer distances.*
This increase in transportation distances and the more "concentrated" nature
of the waste loads would increase the probability of transportation acci-
dents involving hazardous wastes and the "severity" of the impacts associ-
ated with such accidents.
The hazardous waste related transportation accidents have been estimated
at one waste spill per 37,500 metric ton of waste hauled and 8.9 truck-relat-
ed accidents per million miles of hauling distance. Based on these esti-
mates and the assumptions of (a) 14.5 metric ton/truck load and (b) 150 miles
hauling distance per load, the probable increases in the number of hazardous
waste related accidents and in the spill waste quantities have been estimated
as a function of the hazardous waste quantity exemption cutoff.* These esti-
mates which are shown in Figure 4-4 indicate probable increases in waste
spill quantities of 42,000, 33,000 and 27,000 kg/mo and probable increases
in the number of accidents per month of 10, 8 and 7 when the waste exemption
cutoff is placed at 100, 500 and 1000 kg/mo, respectively. It should be
noted that if waste from small generators is to be disposed of in Subtitle
D landfills, spills and accidents involving hazardous waste can still be
expected, although significantly smaller quantities of waste would be involved
*Under existing DOT regulations, any material meeting DOT criteria that is
shipped interstate, or shipped intrastate by an interstate carrier, is sub-
ject to DOT's packaging, labeling, marking, placarding and shipping paper
requirements. Therefore, any waste, whether potentially hazardous or haz-
ardous as regulated under RCRA Subtitle C, and without any quantity exemp-
tion (except combustible liquids, i.e., RCRA Section 3001 ignitables with
a flash point between 100°F and 140°F, in quantities of 110 gallons or less)
must comply with DOT regulations if shipped as indicated. However, hazard-
ous waste regulated by RCRA Subtitle C are not regulated under existing DOT
regulations if (a) they are shipped intrastate by an intrastate carrier, or
(b) they do not meet DOT criteria. (Subtitle C hazardous wastes that do
not meet DOT criteria are the toxic and toxic organic wastes; carcinogenic,
mutagenic and teratogenic wastes; and infectious wastes.) On May 25, 1978
DOT proposed an amendment specifically requiring compliance for intrastate•
transport and for EPA-regulated hazardous waste not meeting DOT criteria.
'''U.S. EPA, Subtitle C Resource Conservation and Recovery Act of 1976, Draft
Environmental Impact Statement, January 1976.
^These increases are above those expected from the transportation of hazard-
ous waste from large generators to off-site disposal facilities. Using
these same bases, the probable number of accidents and associated waste
quantities expected from the transportation of 702 million kg/mo of hazard-
ous waste from large, generators (see Table 4-5) are estimated at 65 acci-
dents/month and 271,000 kg/mo of waste.
4-13
-------
0 1000 2000 3000 4000 5000
WASTE EXEMPTION CUTOFF, KG/MO
Figure 4-4. Probable Waste Spill Quantities and Hauling Accidents Involving
Hazardous Wastes from Small Generators as a Function of Waste
Exemption Cutoff
4-14
-------
in individual incidents and hence potential damage from such incidents would
probably be of lower "severity."
At the present time hazardous wastes are transported to off-site dis-
posal facilities by the waste generators themselves, by the operators of the
waste management facilities or by "for-hire" transporters. With the imple-
mentation of RCRA, self-hauling is expected to decline because of the stricter
requirements placed on waste transporters (i.e., requirement for record keep-
ing and use of manifest). The decline in the extent of self-hauling would ".
increase the demand for hauling services or commercial haulers and waste dis-
posal companies. At the present time commercial haulers and waste disposal
companies reportedly operate at 75%-80% and close to 100% of their waste
hauling capacity, respectively.* Thus, only the waste disposal companies,
and not the for-hire waste haulers may be able to absorb some of the increased
demand for waste hauling.^
4.1.7 Impacts on the Safety of Operators and the Public at Subtitle D
Facilities
Exemption of the small generators from Subtitle C requirements is condi-
tional upon the premise that the exempted generators would dispose of their
wastes in facilities which would meet at least the Subtitle D requirements.
Since Subtitle D facilities are primarily for the disposal of nonhazardous
waste, the diversion of hazardous wastes from small generators to these faci-
lities can present some threat to the safety of the operating personnel at
these facilities and commercial refuse collection truck drivers and the gen-
eral public who bring waste to these facilities for disposal. Any explosion
or fire which may stem from handling of hazardous waste at these facilities
can also be damaging to equipment and property and can adversely affect the
pollution containment capability of these facilities.
The EPA background data on the reported damage cases involving haz—
ardous wastes does not provide sufficient quantitative data to determine
*Arthur D. Little, Inc., Characterization of Hazardous Waste Transportation and
Economic Impact Assessment of Transportation Regulations, EPA SW-170C, 1979.
tstricter RCRA requirements on hazardous waste transportation may also result
in a decline in the self-hauling of hazardous waste by large generators and
hence place a significantly larger demand for the services of commercial
haulers.
£e.g., use of water for fire fighting can result in excessive leachate forma-
tion and groundwater contamination (see summary of reported damage cases
involving hazardous waste mismanagement, presented in Appendix C).
4-15
-------
whether or not a correlation exists between the quantity of hazardous waste
handled in a sanitary landfill and the probability of the occurrence of an
accident or the severity of the resulting accident. Many of the accidents
which have involved loss of life or injury to the facility operators or
damage to equipment and property have resulted from disposal of unmarked
containers containing explosives and flammable wastes which were "run over"
by the disposal equipment operated by the "unsuspecting" equipment operators.
Such accidents could have been avoided had the facility operators been made
aware of the nature of the waste via proper container labeling and waste
documentation systems. Many sanitary landfills which have made special pro-
visions for handling limited quantities of hazardous waste, have an excel-
lent record of safe operation; in many such landfills, an isolated section
of the landfill is specifically set aside for the disposal of hazardous
wastes, which is also carried out by specially trained personnel.
As long as the hazardous waste containers are properly labeled and the
hazardous characteristics of the wastes are revealed to the disposal faci-
lity operator, the diversion of even all hazardous wastes from small genera-
tors (i.e., at a waste exemption cutoff of 5000 kg/mo) to Subtitle D faci-
lities should not present special safety hazard to the operators or the
Subtitle D facilities, provided that the operators are trained in identify-
ing incompatible wastes and proper handling and disposal procedures for
flammable and explosive wastes. With the implementation of RCRA, the net
quantity of hazardous waste which would enter sanitary landfill facilities
is expected to decrease since hazardous wastes from large generators which
currently enter sanitary landfills would be diverted to Subtitle C facili-
ties.
4-16
-------
4.1.8 Impacts on Sanitary Landfill Siting
Concern has been expressed that promulgation of regulations exempting
some generators from having to comply with RCRA Subtitle C disposal require-
ments will increase the public's awareness that hazardous wastes are being
disposed of in Subtitle D sanitary landfills and thereby exacerbate siting
difficulties. Due to a great deal of recent publicity, public awareness of
the consequences of inadequate disposal of hazardous wastes is fairly high.
Even with this high level of concern, the presence of hazardous wastes has
not arisen as an issue in recent sanitary landfill sitings, despite the fact
that it is known, at least by informed individuals, that many sanitary land-
fills also accept some hazardous waste. The factors which are most commonly
cited in opposition to new sanitary landfill sites, and which are considered
to result in reduced property values, are potential for water pollution, spread
of insects and rodents, blowing papers, odors and heavy truck travel on local
roads.* The preliminary results from an on-going EPA-sponsored study of
citizen opposition toward siting of hazardous waste management facilities
indicate that some of these same factors are cited by the opposition to hazard-
ous waste landfills, although opposition is generally more vigorous and the
concern is more strongly expressed over the possible inability of the proposed
control systems to abate leachate formation and water pollution control.
Based on the above-listed issues which are most commonly raised by oppon-
ents to sanitary and hazardous waste landfills, it is believed that exemption
cut-off would be inconsequential for those cases where the public can be pre-
sented with convincing evidence that controls proposed for a site will pro-
tect the environment and the public health and where the local landfill opera-
ting agency has a good operating record. If the public is not convinced of
the adequacy of the controls and the ability of the proposed operating agency
to operate the site properly, waste exemption cut-off level may become a more
important issue especially in those cases where the volume of hazardous waste
admitted to a site would become noticeable (in relation to nonhazardous waste)
at higher exemption cut-offs. Agencies attempting to gain public acceptance
for new sanitary landfills could emphasize the improved design and control
*Massey, D. T., "Attitudes of Nearby Residents Toward Establishing Sanitary
Landfills," Economics, Statistics, and Cooperative Service, U.S. Dept. of
Agriculture ESCS-03, January 1978, NTIS PB-278-905.
4-17
-------
systems for RCRA Subtitle D facilities and the reduced volume of hazardous
waste which would be admitted to such landfills under the RCRA regulations.
4.1.9 Impact on Resources for Administration and Enforcement of RCRA
As the hazardous waste quantity exemption cutoff is lowered for the
small generators, a greater number of the generators would be subjected to
regulations under RCRA, thus increasing the burden on the limited resources
currently available for administering and enforcing RCRA. Based on the
estimates presented in Table 3-1, on an aggregate national level generators
producing less than 5000 kg/mo and less than 100 kg/mo of hazardous waste
account for 94.7% and 74% of the hazardous waste generators, respectively.
The significant decrease in the number of generators which would be regulated
under RCRA as the waste quantity exemption cutoff is lowered (see Figure 4-1)
would suggest that perhaps a "phasing option" whereby the exemption cutoff
is initially placed at a high level but is lowered in subsequent years may
allow time for the development of necessary resources for administering
and enforcing RCRA for small generators. Unless such resources are devel-
oped, the regulation of and compliance monitoring for a very large number
of small generators may divert attention from the control of large genera-
tors which collectively account for an estimated 97.7% of all hazardous
waste produced nationally.
The resources required for the administration and enforcement of RCRA
for small volume hazardous waste generators as a function of waste exemption
cutoff is being addressed in-depth by the "Economic Contractor" and will not
be considered here.
4.2 PHASING OPTION
The phasing option for regulating the small generators initially places
the exemption cutoff at a high level, but reduces the cutoff in steps in sub-
sequent years. The objective of the phasing option is to allow time for regu-
latory and enforcement agencies to gradually build up the necessary manpower
and administrative machinery for regulating all small generators which are to
be ultimately regulated. The phasing option may also provide the commercial
hazardous waste transportation and disposal industries with additional time
to expand their capacities in order to meet the added demand due to the imple-
mentation of the new regulations. Under the phasing option, the small gen-
erators may also be given additional time to develop resource recovery and/or
4-18
-------
implement in-plant changes to reduce hazardous waste production. The phasing
option is essentially an extension of the "quantity option" and, except for
some "phasing" of the impacts, the impacts and considerations discussed in
Section 4.1 in connection with the quantity option would apply. In the
following discussion only the more pronounced impacts are highlighted. For
analysis purposes, an initial cutoff of 5000 kg/mo with subsequent cutoffs
of 1000 kg/mo after three years and 100 kg/mo after five years are assumed.
4.2.1 Impact on Number of Generators and Waste Quantities
Based on the data in Table 3-1 and assuming that (a) current number of
small generators and the relative percentages of small generators and waste
quantities in various waste generation rate categories remain nearly the same
over the next five years; and (b) the total estimated waste quantity for the
generators in each category increases at a rate of 2% per year (following the
anticipated general industry growth rate) over the next five years, the number
of small generators and waste quantities which would be covered in the first
year, after three years and after five years are as follows:
Number and % of Small Waste Quantity Covered
Generators Covered million kg/mo
First year (5000 kg/mo cutoff) 0 (0%) 0 (0%)
After 3 years (1000 kg/mo cutoff) 27,000 (3.7%) 67 (54%)
After 5 years (100 kg/mo cutoff) 158,000 (22%) 115 (90%)
Since 95% of the small generators in the less than 5000 kg/mo waste genera-
tion rate category produce less than 1000 kg/mo of waste, only a small per-
centage (3.7%) of such generators would be under regulation after three years
of the phased regulation program. However, since most of the waste is from
the larger generators, the waste quantity which would be under regulation in
the fourth and fifth year of the program account for 46% of the waste which
would be ultimately regulated.
4.2.2 SIC-Specific Impacts
SIC's which would be most affected by the implementation of a 1000 kg/mo
cutoff after three years are those listed in Table 4-4 (excluding SIC's in
Tables 4-1, 4-2 and 4-3 which are also listed in Table 4-4 by reference).
After five years, establishments which would be subject to the 100 kg/mo
exemption would be largely in the SIC's listed in Table 4-1.
4-19
-------
4.2.3 Impacts on Capacity of Commercial Waste Management Facilities
Based on the data presented in Table 4-5, at a 5000 kg/mo exemption cut-
off (the initial exemption cutoff), the existing hazardous waste management
facilities in EPA Regions I, II, III, IV, VI and VIII would be deficient in
capacity to handle the large quantity of hazardous waste which is produced.
Unless there is a significant expansion in the capacity of commercial hazard-
ous waste management facilities, such deficits will continue and become even
more severe after three years and after five years when the exemption cut-off
level is lowered to 1000 kg/mo and 100 kg, respectively.*
*Based on a 1975 study (Foster D. Snell, "Potential for Capacity Creation in
the Hazardous Waste Management Service Industry," NTIS Report PB-257-187,
1976), no near-term expansion of the commercial hazardous waste management
industry is anticipated.
4-20
-------
5. ASSESSMENT OF THE QUALITY OF DATA BASE
5.1 GENERAL CONSIDERATIONS
The SIC's considered as generators of hazardous and potentially hazard-
ous wastes are estimated to cover more than 760,000 establishments. Identi-
fication and detail characterization of the small generators in such a large
number of diverse SIC's through an in-depth study of each SIC or SIC group
would require an enormous budget and considerable time, neither of which
were available to this program nor could be justified. Accordingly, although
some limited surveys were conducted in this study, the study had to rely on
the existing available data, consisting primarily of previous state hazard-
ous waste surveys and industry studies.
In constructing the data base for this study, every attempt has been
made to identify and eliminate data inaccuracies and to incorporate all reli-
able existing information. In general, unless there were reasons to question
the accuracy of certain data, it has been assumed that all data collected
through state surveys and previous industry studies or made available to this
study by trade associations and individual establishments are accurate and
reliable.
The data base upon which the estimates presented in this document are
based represents the most comprehensive data base currently available on haz-
ardous waste generation in the U.S. Even though the procedure used in this
study for estimating the profiles of hazardous waste generators on a national
level has not been used in any previous studies, in the few cases where the
data from other sources were available for comparison, the estimates obtained
in this study are in reasonable agreement with the other estimates.
As discussed in detail in Section 6, an SIC-by-SIC assessment approach
has been used in developing a national composite picture of the small genera-
tors and waste quantities. With this approach, the accuracy of the aggregate
estimates are determined by the accuracy of the estimates for the individual
SIC's which in turn is determined by the quality of the data base for the
individual SIC's. The assessment summaries presented in Appendix B (Volume
II) describe the data base and its quality for each assessment.
5-1
-------
The state data and the census data have been the two major sources of
information for SIC-by-SIC assessment. A brief discussion of some inherent
limitations of these data and of the procedure used to estimate waste genera-
tion profiles based on these data follows.
5.2 QUALITY OF THE STATE DATA
Where information on hazardous waste generation types and quantities was
available from previous state surveys, this information was compiled into a
state data base giving an aggregate picture for 20 states, and representing
establishments in some 90 2-digit, 3-digit and 4-digit SIC's.
Because of differences in the state survey methodologies (e.g., type of.
questionnaire used and its "wording," definition and criteria for hazardous
waste, selection of specific facilities to be surveyed, extent of responses
received and degree of "cross-checking" of responses), there is a variation
in the data from different states. For some states, for example, the hazard-
ous waste types and quantities reported for some establishments do not include
sludges resulting from the treatment of process wastewaters. Had such wastes
been taken into account, the total hazardous waste quantities for a number
of such plants would have exceeded the 5000 kg/mo generation rate upper "cut-
off" point used in this study for the small generators. 1"
The number of establishments in a 4-digit SIC covered by state data
varies from as low as one (e.g., for SIC 2873) to as many as 69 (for SIC
3471). For the establishments covered, there is also some variation in the
extent of coverage of various desired data elements. Thus, while 'for most
plants information is available on waste quantity and generic class (e.g.,
solvent, sludges, etc.), for many plants data are lacking on the specific
type of waste (or waste composition) and on the specific disposal methods
used (for many plants the disposal method is merely described as contract
hauling without identifying the actual disposal operation at the ultimate
disposal site). Data from some large states (e.g., NY, CA and TX) include
*See Section 6.0 and Table 6-3 for a description of the survey data for indivi-
dual states; see Appendix C for sample completed survey forms for Arizona,
Washington and California.
"••Where such "obvious" errors in reporting could be identified in the state
data for establishments in a given SIC, such data points were hot included
in the data base.
5-2
-------
employment which was used to estimate a per employee waste generation rate
for some SIC's. Only for a very limited number of plants waste disposal costs
are reported and no sales data are given for any of the plants covered.
Because of its coverage of a large number of diverse establishments, and
despite some of its inherent limitations, the aggregated data from the 20
states provided a broad and "representative" data base for extrapolation to
the national level (see Section 5.2 below). Considering the extensive man-
power and time which have been expended by various states in compiling and
analyzing survey results, and the budgetary and schedule constraints of this
program (which could not permit an independent survey approaching the breadth
and depth of coverage of aggregated state surveys), the use of the aggregared
state survey data was very compelling. The data from the states of New York,
California, Iowa, Texas and Massachusetts represent approximately 41% of the
total number of small generators in the state data base. Compared to data
for other states, the data for these states are generally more recent and
have been obtained through surveys and/or hazardous waste documentation
systems which are considered very comprehensive and less biased toward the
large generators. The Iowa survey was specifically simed at smaller companies;
of the 329 establishments whose responses were considered adequate, 286 or
87% of the establishments would be classified as small volume hazardous waste
generators. Similarly, high percentages of the establishments covered by the
data from .California, New York and Massachusetts are small volume hazardous
waste generators (71%, 55% and 43%, respectively).
5.3 ESTIMATION OF WASTE GENERATION PROFILES
The estimation of profiles of waste generators for many SIC's involved
projection of observed distribution of establishments in the aggregated state
sample to the nation (or an EPA region) as a whole. The extension of the
number of generators and amount of waste from the sample data base to the
nation is based upon the assumption that the aggregated state data is repre-
sentative of the national situation with regard to waste generation within
any given SIC. This is a reasonable assumption, considering that the aggre-
gated data base consists of a large number of independent data elements.
In generalizing from a sample or subset to a universe, consideration must
be given to the nature by which the sample elements are selected. Where the
information is obtained in a single survey, usual practice is to manage the
5-3
-------
sample selection on a strictly random basis so that statistical sampling
theory based upon the probability of selection can be applied. In this case,
sample information was obtained by more than 20 separate and independent sur-
vey operations, each for a distinct and non-overlapping portion (state or geo-
graphic regions within states) of the whole (nation). In a number of cases,
the actual procedures used within a state are not known to have involved
random selection. However, since the composite data base for the nation is
based upon such a large number of independent data elements, it is reasonable
to assume representativeness of hazardous waste generation in the U.S.
Even though the assumption of representativeness of the "state" data
seems reasonable, an indirect measure of the scope and bias Of the composite
data base was devised so that any indications of non-representativeness
might be detected. The technique involves using employment, a variable inde-
pendent of waste quantity for which data are available for many plants in the
state data base as well as available on a national basis. Employment, since
it is uncorrelated with waste quantity, cannot be used to give an accurate
prediction of amount of hazardous waste. However, employment does have the
same asymetric distribution (log normal) as waste quantity, and can give
introspection into the scope of the composite "state" data.
The U.S. Bureau of Census publishes, for each SIC and state, the number
of establishments in each of nine employment-class-sizes, from "1-4 employees"
to, and including "more than 1000 employees." A similar tabulation of state
data into these nine classes was made for the responses which included employ-
ment figures. To arrive at a reasonable comparison of the composite sample,
the state employment distribution was compared, for each SIC, with the Bureau
of Census employment data totalled for those states which were included in the
state data base. The comparison was made on the basis of cumulative percent-
age distribution calculated for the upper limit of each employment class.
The results of this comparison of cumulative percentage distributions,
for selected SIC's, are given in Figures 5-1 throuah 5-6. These figures are
the lognormal plots of number of employees per firm and the percentage of
plants having an indicated number of employees or fewer. Where employment
is lognormally distributed in the universe (census data) or the sample
(state data) that relationship plots as a straight line. This line can be
used to estimate the fraction of plants within any employment size range.
5-4
-------
1000
5 10 15 20 30 kO 50 60 70 80 90 95
PERCENTAGE OF PLANTS HAVING INDICATED NUMBER OF EMPLOYEES OR FEWER
Figure 5-1. Comparison of Distribution of Employment for Plants in State
Data Base with the Census Employment Data for States Cqvered-
SIC 0700
5-5
-------
1000
2 5 10 15 20 30 i»0 50 60 70 80 90
PERCENTAGE OF PLANTS HAVING INDICATED NUMBER OF EMPLOYEES OR FEWER
Figure 5-2. Comparison of Distribution of Employment for Plants in State
Data Base with the Census Employment Data for States Covered-
SIC 2800 '
5-6
-------
1000
100
o
Q.
o
CC
UJ
CD
•s.
2 5 10 15 20 30 1*0 50 60 70 80 90
PERCENTAGE OF "LANTS HAVING INDICATED NUMBER OF EMPLOYEES OR FEWER
Figure 5-3. Comparison of Distribution of Employment for Plants in State
Data Base with the Census Employment Data for States Covered-
SIC 3400
5-7
-------
1000
5 15 20 30 40 50 60 70 80 85 90 95
PERCENTAGE OF PLANTS WITH INDICATED NUMBER OF EMPLOYEES OR FEWER
98
Figure 5-4. Comparison of Distribution of Employment for Plants in State
Data Base with the Census Employment Data for States Covered-
SIC 3670
5-8
-------
1000
100
o
UJ
m
5 10 15 20 30 40 50 60 70 80 85 90 95
PERCENTAGE OF PLANTS WITH INDICATED NUMBER OF EMPLOYEES OR FEWER
98
Figure 5-5. Comparison of Distribution of Employment for Plants in State
Data Base with the Census Employment Data for States Covered-
SIC 3820
5-9
-------
1000
Figure 5-6.
10 15 20 30 2,0 50 60 70 80 90 95 98
PERCENTAGE OF PLANTS WITH INDICATED NUMBER OF EMPLOYEES OR FEWER
Comparison of Distribution of Employment for Plants in State
Data Base with the Census Employment Data for States Covered
SIC 3910
5-10
-------
Inspection of the graphs (Figures 5-1 through 5-6) reveals that universe
(census) data is quite closely lognormally distributed over the range of firm
sizes (all points near the straight line). Also, the data from the composite
sample approximates the lognormal distribution, since there is very little
scatter of those points about their line. Both lines being roughly parallel
means that sample and census data have approximately the same variability.
Since the comparison is made on a percentage basis, a perfectly represen-
tative sample would plot a coincident line with the census data. In most cases,
however, the state data line is offset from the census plot in the direction
to show that the fraction of firms with few employees would be underestimated
by the composite state data.
The employment distribution statistics in Table 5-1 compare the medians,
first quartiles and third quartiles of the census data with the composite state
data. Inspection of the information given in this table reveals the bias of
the state data toward firms with larger employment than would be expected
from a random sample of firms from those states.
TABLE 5-1< SELECTED PERCENTILES OF EMPLOYMENT DISTRIBUTIONS FOR STATE AND
CENSUS DATA
SIC
0700
2800
3400
3670
3820
3910
1st Ouartile*
Census
Data
1
3
3
4
3
1
State
Data
1
20
23
90
60
34
Median*
Census
Data
2
11
11
15
12
5
State
Data
2
52
62
220
140
84
3rd Quartile*
Census
Data
5
33
34
55
47
16
" State
Data
6
135
165
550
315
210
*lst quartile - 25th percentile; median = 50th percentile;
3rd quartile - 75th percentile
As a further characterization of the state data base, Table 5-2 lists,
for the same six SIC's presented above, the number of firms with employments
information, with hazardous waste quantity information and those reporting
both employment and waste quantities. Also included in Table 5-2 is the samp-
ling fraction, a percentage of the total number of plants (in the census of
5-11
-------
stated represented in the "state" data base) for which employment informa-
\
tion was reported.
TABLE 5-2. NUMBER OF FIRMS IN STATE DATA BASE AND CENSUS DATA BASE WITH
EMPLOYMENT INFORMATION
SIC
0700
2800
3400
3670
3820
3910
Census*
Data
18,775
5,065
13,484
1,894
936
1,941
State Data Base
Employment
Reported
23
228
335
67
18
58
Waste
Quantity
Reported
41
297
403
93
19
63
Both
Employment and
Waste Quantity
23
206
318
65
18
54
Total
41
304
412
93
19
66
Saitvple :
Fraction"''
(%)
0.12
4.50
2.48
3.53
1.92
2.98
*Number of plants in states which were included in the state data base.
"''Ratio of number of plants in state data base reporting employment to
number of plants in census data, expressed as percentage.
If it were true that hazardous waste quantities were positively corre-
lated with employment, then the net result of using the composite state data
base would be to underestimate the number of very small waste generators
and overestimate the number of larger waste generators. However, with no
significant correlation between employment and waste, it appears safe to
conclude that the state data base is missing information about firms which
are small employers, rather than to conclude that it is not representative
on the basis of waste generation information.
Inferences from the composite data base to the national or regional pic-
ture are made on the basis of the assumption of representativeness of this
data. This project draws its conclusions about the waste generation within
each SIC by (1) fitting an appropriate mathematical curve to the cumulative
distribution of a representative sample of waste generators and the quanti-
ties of hazardous waste they generate, and (2) using this fitted curve in
conjunction with census data to estimate an industry profile of hazardous
waste generation. Since no assumptions are made as to the random nature of
the observations, use of formal statistical inferential techniques which are
commonly applied to samples obtained by random selection such as calculation
of confidence limits for parameters of distributions would not be applicable
to the estimated waste generation profiles.
5-12
-------
5.4 USE OF CENSUS DATA
•
For many SIC's the census data on distribution of establishments by
employment size and state have been used in the estimation of the industry
waste generation profiles. In the census data, tabulations for a given SIC
cover only those establishments for which the listed SIC is the "primary"
SIC. Under this system, each establishment is "counted" only once (under
the SIC corresponding to its primary business activity). Because of this,
the total number of establishments indicated for an SIC may be less than the
total number of establishment engaged in that business activity. However,
since all establishments are "counted," the total number of establishments
covered by the census data for all listed SIC's corresponds very nearly to
the actual total number of establishments, although the number of listed
establishments for some individual SIC's may be less than the actual number
of establishments engaged in the business activities corresponding to those
SIC's.
The above-mentioned limitation of the census data stems from the fact
that activities carried out by some establishments fall into more than one
SIC category. This data limitation, however, does not materially affect the
estimated waste quantities for an SIC when the estimate is based on the use
of the state data where establishments (and waste quantities) are identified
by their primary SIC's. Furthermore, in this study the waste generating
establishments and not waste generating activities per se have been of
interest and the classification of an establishment as a small or large gen-
erator has been based on the total hazardous waste quantity produced by the
establishment (i.e., generated at the plant site as a result of all activi-
ties of the establishment).
Early in this study, a number of SIC's were judged to generate wastes of
a non-hazardous nature and hence were eliminated from further consideration.
In a hypothetical case that some establishments having such SIC's as primary
SIC's generate small quantities of hazardous wastes as a result of activities
associated with their secondary SIC's, such establishments would be omitted
in any count of the small generators based on the census data. The nature
of activities associated with the nonhazardous waste generating SIC's, how-
ever, indicates that it is not very likely that a significant number of
establishments in such SIC's are also engaged in secondary activities pro-
ducing hazardous waste.
5-13
-------
Some SIC's (especially those involving the "not elsewhere classified" sub-
groups) cover a range of business" activities with only those establishments
engaged in one or some of the business activities producing potentially haz-
ardous wastes. Since the census data generally do not provide a breakdown of
the number of establishments by the type of business activity within an SIC,
the census data could not be used for the estimation of waste generation pro-
files for a subclassification within a 4-digit SIC; in some cases, data from
other sources (e.g., published industry studies or individual establishments)
were substituted for the census data.
The census data on the number and employment size distribution of estab-
lishments in an SIC are based on Federal income tax reporting information.
For some SIC's (e.g.", SIC 8211, Elementary and Secondary Schools) the census
data on the number of establishments was found to be lower than those from
other sources (e.g., Department of Health, Education and Welfare for SIC 8211),
presumably due to the tax exempt status of some of the establishments. For
these SIC's, information from other sources which could be considered more
accurate was used instead of the census data.
5-14
-------
6. GENERAL METHODOLOGY FOR DATA BASE DEVELOPMENT
An SIC-by-SIC assessment approach was used in developing composite pro-
files for the small volume hazardous waste generators. Based on the type of
activities associated with the operation of establishments in an SIC, all
SIC's listed in the "Standard Industrial Classification Manual"* were exam-
ined; those SIC's which could be readily identified as non-generators of
hazardous wastes were eliminated from further consideration. Examples of
the SIC's eliminated are SIC 0781, Landscape Counselling and Planning; SIC
60, Banking; SIC 64, Insurance Agents, Brokers, and Service. Also excluded
were retailers^ (except gasoline service stations, SIC 5541, and motor
vehicle dealers, SIC 5511) and farmers. Those suspected of generating haz-
ardous wastes were identified and subsequently examined in some detail using
the information sources described in Section 6-1. This examination led to
the elimination of an additional number of SIC's from further consideration
on the basis of being nonhazardous waste generators, large hazardous waste
generators or generators of wastes covered under other regulations. A list-
ing of these SIC's and assessment summary sheets for them are presented in
Table 6-1 and Appendix A, respectively.
Based on the December 18, 1978 proposed guidelines and regulations, a
waste would be considered hazardous if it appears on the EPA1s "list" of haz-
ardous wastes or if it meets certain ignitability, corrosivity, reactivity or
toxicity criteria. EPA is to periodically revise and update its "list" of
hazardous wastes as new data become available on the characteristics-of various
wastesand the environmental significance of various waste components. Nearly
all the wastes appearing on the EPA's December 18, 1978 list of hazardous
wastes are from the manufacturing industries, many of which have been the sub-
ject of some previous industry studies. A large number of industries reviewed
in the present study, particularly those in the nonmanufacturing segment, how-
ever, fall into the least studied industries for which little or no waste
characteristics data were available from any previous studies. Accordingly,
*Standard Industrial Classification Manual, Executive Office of the President,
Office of Management and Budget, 1972.
tThe proposed December 18, 1978 regulations (40 CFR Part 250, page 58946) ex-
cludes retailers (except gasoline service stations and motor vehicle dealers)
from Subtitle C regulations, provided that their wastes are disposed of in an
approved disposal facility.
6-1
-------
TABLE 6-1. SIC'S ELIMINATED FROM FURTHER CONSIDERATION
SIC
075
Industry Category/Subcategory
Animal Services, Except Veterinary
15,16 General Building Contractors and Heavy
(except for Construction Contractors
"special
trade")
21
23
243,2492,
2499
2611,2621,
2631,2646,
2661
2642,2643,
2645,2647,
2648,2649,
265
2992
3241
325,326,
3274,3275,
3281,3291,
3292,3295-7,
3299
3271,3272,
3273
3312
3313
333
44
4789
4811
Tobacco Manufacturers
Apparel and Other Finished Products Made from
Fabrics and Similar Materials
Hardwood Veneer, Plywood and Glued Wood Products
Paper and Allied Products
Converted Paper and Paperboard Products
Lubricating Oils and Greases (except blenders and
compounders)
Cement, Hydraulic
Stone and Clay Products
Basis for
Elimination*
N
N
N
N
N
L/N
N
Concrete,Gypsum and Plaster Products
Blast Furnaces (including coke ovens), Steel Works
and Rolling Mills
Electrometallurgical Products
Primary Smelting and Refinishing of Nonferrous
Metals
Water Transportation
Services Incidental to Transportation, Not
Elsewhere Classified
Telephone Communication (wire or radio)
L
L.
L/N/R
N
L
L
L/N
L
N
R
*L = large hazardous waste generators; N = nonhazardous waste Generators;
R = covered or will be covered under other regulations.
6-2
-------
TABLE 6-1. CONTINUED
Basis for
Elimination
SIC Industry Category/Subcategory
5012,5013, Automobiles and Other Motor Vehicles, Automotive
5014 Parts and Supplies, Tires and Tubes (Wholesale) N
5039 Construction Materials, Not Elsewhere Classified
(Wholesale) N
5041,5042 Sporting, Recreational, Photographic and Hobby Goods,
5043 Toys and Supplies
505 Metals and Minerals, Except Petroleum (Wholesale) N
5063 Electrical Apparatus and Equipment, Wiring Supplies
and Construction Materials (wholesale) N
5086 Professional Equipment and Supplies (Wholesale) N
514 Groceries and Related Products (Wholesale) N
7299 Miscellaneous Personal Services N
7911 Dance Halls, Studios and Schools N
7997 Membership Sports and Recreation Clubs N
8011 Offices of Physicians N
8021 Office of Dentists N/R
8031 Osteopathic Physicians N
8041 Offices of Chiropractors N
8042 Offices of Optometrists N
805 Nursing and Personal Care Facilities N
8072 Dental Laboratories N
8081 Outpatient Care Facilities _ N
8091 Health and Allied Services, Not Elsewhere Classified N
6-3
-------
in the present study considerable technical and engineering judgment had to be
exercised in determining whether or not wastes which were not "listed" or
wastes for which data on ignitability, corrosivity, reactivity and toxicity
were not available should be considered hazardous.
In line with the main objective of this study, which was primarily to
develop a comprehensive data base for use by EPA in developing regulations,
a much broader spectrum of wastes were considered as "potentially" hazardous
\
than those currently designated as hazardous by EPA and appearing on the Dec-
ember 18, 1978 EPA's list of hazardous wastes. The consideration of a waste
as potentially hazardous for the purpose of this background document does not
imply a decision or an impending decision by EPA for the inclusion.of the
waste on its "list" of hazardous wastes.
In the present study, a waste was considered as potentially hazardous if
.it was judged to (a) possess characteristics similar to (or to contain compon-
ents of) the listed wastes or (b) contain constituents which, based on the pub-
lished literature data for pure substances, would meet the hazardous waste cri-
teria for toxicity, reactivity, corrosivity, etc. Because of certain unique .
features of waste oil (a "listed" hazardous waste) and waste oil generators
(e.g., large number of generators, fuel value of waste and existence of a
waste oil re-refining industry), which warrant separate and special regulatory
considerations, waste oil and waste oil generators were excluded from the pre-
sent analysis. . ...
For SIC's determined to contain small volume hazardous waste generators,
data were compiled on or estimates were made of the general nature of the in-
dustry, number and geographic distribution of plants, characteristics of haz-
ardous wastes produced; waste treatment, storage and disposal practices em-
ployed; current disposal cost, alternative disposal methods, number of waste
generators in various waste generation rate categories and quantities of waste
produced by generators in each category. Where it could be justified on the
technical ground and/or where adequate data were not available for a specific
SIC, similar SIC's were combined and addressed collectively as a group. A
listing of SIC's and SIC groups containing small generators and the assessment
summary sheets for them are presented in Table 6-2 and Appendix B, respectively.
The SIC-by-SIC data were then aggregated to develop overall profiles for the
6-4
-------
TABLE 6-2. SIC1S CONTAINING SMALL GENERATORS OF HAZARDOUS OR POTENTIALLY
HAZARDOUS WASTE FOR WHICH WASTE GENERATION PROFILES WERE PREPARED
SIC
018
0711,0721,0729
0741,0742
0748,8421
1700
2079
2211,2221,2241,
228,229
2231,225,226,
2272
2421
2491
2499
25
2641
27
281
282
283
284
2851
286
2873
2875
2879
2891
2892,2895,2899
2893
Industry Category/Subcategory
Horticultural Specialties
Soil Preparation and Crop Services
Veterinary Services
Landscape and Horticultural Services, Arboreta, Botanical
and Zoological Gardens
Construction - Special Trade Contractors
Shortening, Table Oils, Margarine and Other Edible Fats
and Oils, Not Elsewhere Classified
Textile Mill Products
Dyeing and Finishing of Textiles
Sawmills and Planing Mills
Wood Preserving
Miscellaneous Wood Products
Furniture and Fixtures
Production of Coated and Glazed Paper
Printing, Publishing, and Allied Industries
Industrial Inorganic Chemicals
Plastic Materials and Synthetic Resins, Synthesis Rubber,
Synthetic and Other Man-made Fibers, Except Glass
Drugs and Pharmaceuticals
Soap, Detergents, and Cleaning Preparations, Perfumes,
Cosmetics, and Other Toilet Preparations
Paints, Varnishes, Lacquers, Enamels, and Allied Products
Industrial Organic Chemicals
Nitrogenous Fertilizers
Fertilizers, Mixing Only
Pesticides and Agricultural Chemicals, Not Elsewhere
Classified
Miscellaneous Chemical Products, Adhesives and Sealants
Miscellaneous Chemical Products, Chemicals and Chemical
Preparations, Not Elsewhere Classified Including Explosives
and Carbon Black
Miscellaneous Chemical Products, Printing Ink
6-5
-------
TABLE 6-2. CONTINUED
SIC
2911
30
31 (except
3111)
3111
32
3315,3316,3317,
335
332,336
3341
3398
3399
34 (except 3411
and 3479)
3431,3479
3471
351,352,353,
358,359
354,355,356,
357
36 (except 3691
and 3692)
3691,3692
37
38 (except 3861)
3861
39 (except 391
and 396)
3910,3960
40 (and parts
of SIC 411)
41
42
43
Industry Category/Subcategory
Petroleum Refining
Rubber and Miscellaneous Plastics Products
Leather and Leather Products (except leather tanning and
finishing)
Leather Tanning and Finishing
Stone, Clay, Glass and Concrete Products
Rolling, Drawing, and Extruding of Metals
Foundries
Secondary Smelting and Refining of Nonferrous Metals
Metal Heat Treating
Primary Metal Products, Not Elsewhere Classified
Fabricated Metal Products, Except Machinery and Transpor-
tation Equipment
Enameled Iron and Metal Ware and Coating, Engraving, and
Allied Services, Not Elsewhere Classified
Electroplating and Metal Finishing
Machinery, Except Electrical
Machinery, Except Electrical
Electrical and Electronic Machinery, Equipment and Supplies
Storage and Primary Batteries
Transportation Equipment
Measuring, Analyzing, and Controlling instruments, Medical,
Dental and Optical Goods, and Watches and Clocks
Photographic Equipment and Supplies
Miscellaneous Manufacturing Industries
Jewelry, Silverware, and Plated Ware, Costume Jewelry,
Costume Novelties, Buttons, and Miscellaneous Notions
Railroad Transportation
Local and Suburban Transit and Interurban Highway Passenger
Transportation
Motor Freight Transportation
Postal Service
6-6
-------
TABLE 6-2. CONTINUED
SIC
45
5122
5161
5511
5541
7215,7216, 7218
7217
7221,7333,7395,
7819
7231,7241
7261
7332
7341,7349
7342
7391
7397
7399
751
7531-7535
7538
7539
7542
76
7933
7948
7996
806
8071
8211
8221,8222
8411
8922
Industry Category/Subcategory
Transportation by Air
Drugs, Drug Proprietaries and Druggists' Supplies (Wholesale)
Chemicals and Allied Products - Chemical Wholesalers
Motor Vehicles (New and Used)
Gasoline Service Stations
Dry Cleaning
Carpet and Upholstery Cleaning
Photo Processing Laboratories
Barber and Beauty Shops
Funeral Services and Crematories
Blueprinting and Photocopying Services
Commercial Cleaning and Janitorial Services
Disinfecting and Exterminating Services
Research and Development Laboratories
Commercial Testing Laboratories
Miscellaneous Business Services, Not Elsewhere Classified
Automotive Rental and Leasing, Without Drivers
Automotive Repair
General Automotive Repair Shops
General Automotive Repair, Not Elsewhere Classified
Car Washes
Miscellaneous Repair Services
Bowling Alleys
Racing, Including Track Operation
Amusement Parks
Hospitals
Medical Laboratories
Elementary and Secondary Schools
Colleges, Universities, Professional Schools and Junior
Colleges
Museums and Art Galleries
Noncommercial Educational, Scientific, and Research
Organizations
6-7
-------
small volume generators. These overall profiles are presented and discussed
in Section 3.
6.1 SOURCES OF INFORMATION USED
The following is a listing and a brief description of the major informa-
tion sources used for the SIC-by-SIC assessment of the small generators situa-
tion. The specific source(s) of data used in the assessment of an SIC or
group of SIC's are identified in the assessment summary sheets presented in
Appendices A and B.
6.1.1 State Hazardous Waste Surveys and Data Files
In connection with their hazardous waste management programs a number
of states, most ^notably California and Texas, have compiled extensive data
on hazardous waste generation within their states. Some other states have
conducted special hazardous waste surveys in recent years to develop the frame-
work for establishing state hazardous waste management regulations and pro-
grams. In connection with this program all 50 states (and the 10 EPA regions)
were contacted for information on hazardous waste generators; where pertinent
data existed and could be made available to this study, such data were ob-
tained. The data from the following 20 states constitute the State Data Base
for this study: Alaska, Arizona, California, Connecticut, Georgia, Iowa,
Kansas, Kentucky, Maine, Massachusetts, Minnesota, Mississippi, Missouri,
New Hampshire, New Mexico, New York, Oklahoma, Rhode Island, Texas and
Washington. A brief description of the data for each of these states is pre-
sented in Table 6-3.
Data from the states of Iowa, Massachusetts and New York (and from Rhode
Island for some SIC's) were used in estimating the relative percentages of
large generators, small generators, reported "nongenerators" and average waste
generation rate for large generators for many SIC's.* The small and large gen-
erators data for the states of California, Iowa, Massachusetts and Oklahoma
were used to assess the small generator situation in these particular states
based on actual survey data, and to compare the situation with the estimated
national picture.
*For analysis purposes, the "small" generator was defined in this study as
one producing less than 5000 kg/mo and the large generator as one producing
more than 5000 kg/mo of hazardous waste.
6-8
-------
TABLE 6-3.
State
Alaska
Arizona
California
Connecticut
Georgia
Iowa
DESCRIPTION OF HAZARDOUS WASTE DATA FOR INDIVIDUAL STATES IN "STATE
DATA BASE"
Description
No HW survey done by state, but preliminary survey conducted by
EPA Region X in 1977. Three survey forms returned; of the
responding firms only one firm is SVHW generator.
Two mailed industrial solid waste surveys conducted by State
Department of Health Services in 1974, 1975. Total of 976 manur
facturers contacted; 517 firms (approximately 31% of total firms
in the subject SIC's in state) responded. 27% are SVHW genera-
tors. Survey emphasis on 14 2-digit SIC's (22, 24, 26-30, 33-39).
Firms were selected randomly to insure a minimum representation
of 50% of all manufacturers within the 14 SIC groups.
On-going HW survey conducted by State Dept. of Health Services.
Collected data represent 7 northern counties (Fresno, Kern,
Kings, Merced, Modesto, Stanislaus and Tulare) and San Diego
County. Statistical sampling techniques were used to select a
representative sample of the most predominant manufacturing and
non-manufacturing SIC's in the subject counties. Of the 578
firms responding to the survey, 409 or 70% are SVHW generators,
and 90 (16%) are LVHW generators, with the remaining 79 (14%)
providing insufficient data. Data were collected in 1977-78
and were computerized by the state.
HW survey conducted by General Electric Corp. in 1973 and mailer/
interview surveys conducted by State Dept. of Environmental Pro-
tection, Solid Waste Management Programs in 1976. Approximately
100% of firms in 12 manufacturing SIC's (22, 28, 29, 30, 31, 33,
34-39) were contacted, representing approximately 75% of all
industrial establishments in the state. Of the 5,261 plants
contacted, 1,752 responded. Information on 350 (20% of those
contacted) was made available to TJW; of these, 101 firms (30%)
are SVHW generators.
No state survey conducted per se, but information on waste gen-
eration for 500 plants on file with State Dept. of Natural Re-
sources, Environmental Protection Division. Limited data made
available to TRW. Based on limited inspection of the data,
approximately 11 plants were determined to be SVHW generators.
Confidential survey on selected SIC's thought to be major sources
of hazardous waste performed in 1977 by local college under the
auspices of State Dept. of Environmental Quality, Air and Land
Quality Division. Statistical methods used to select represen-
tative samples of firms within each SIC. To maintain confiden-
tiality, survey was truncated at those SIC's having less than 4
plants within the state. Total of 434 responses received; of
these 286 (66%) are SVHW generators, and 43 (10%) are LVHW gen-
erators, and 105 (24%) provided insufficient data. Responses
represent about 1% of the total number of companies in the
state. Results indicate 89% of hazardous waste generated in
SIC's 28 and 33 (71% from SIC 28, 18% from SIC 33).
6-9
-------
TABLE 6-3. CONTINUED
Description
Initial survey of HW generators conducted in 1977; second survey
performed in early 1979 by State Dept. of Health and Environment,
Solid Waste Management Section. Survey covered 100% of all firms
in 11 manufacturing SIC's (27-30, 33-39), plus a smaller sample
selected at random of other firms in non-manufacturing SIC's.
Approximately 2500 questionnaires mailed; 60% response received.
Of the responses, only 112 firms determined to be SVHW generators.
In addition to waste generation information, data on employment
are included for each facility surveyed.
Kentucky Survey conducted in fall of 1977 by State Dept. of Natural Re-
sources and Environmental Protection, Hazardous Materials Section.
Over 3804 companies were sent survey forms, including all firms
listed in state manufacturers directory, plus additional non-
manufacturing firms listed in telephone directories. Of the 1575
survey forms returned, only 71 firms (5%) were determined to be
SVHW generators, representing 43 4-rdigi.t SIC's. The rema.ijiing
plants indicated no waste was generated, returned incompleted
survey forms, or generated wastes in excess of 5000 kg/mo.
Maine HW survey conducted in 1978 by SCS Engineers for State Dept. of
Environmental Protection, Solid Waste Management Division. Infor-
mation was solicited from 103 firms in 12 2-digit SIC classifica-
tions (i.e., 22, 26, 28, 30, 31, 33-36, 38, 49, 80), representing
52% of the total firms in these SIC's in the state, based upon
the state market directory. The firms were selected based on
the results of a preliminary survey conducted by the state in
1976-77. Emphasis in the 1978 survey was placed on larger HW
generators. Responses were received from 98 plants; of these,
41 were determined to be SVHW generators. In addition to waste
generation information, data on employment also provided.
Massachusetts Survey performed by GCA for State Dept. of Environmental Manage-
ment, Bureau of Solid Waste Disposal in 1975-76. Approximately
600 plants surveyed in 15 major manufacturing 2-digit SIC codes.
All firms in these SIC codes listed in the Massachusetts Indus-
trial Directory having more than 500 employees were contacted;
all oil companies having more than 100 employees were contacted.
A few randomly selected plants having fewer than 100 employees
were also included in the survey. Non-manufacturing establish-
ments were not included in the survey. Responses were received
from 418 plants. Of these, 179 (43%) are SVHW generations, 68
(16%) are LVHW generators, with the remaining 171 (41%) provid-
ing insufficient information.
Minnesota Survey conducted for Minnesota Pollution Control Agency by
Battelle Pacific Northwest Labs in conjunction with the Minnesota
Association of Commerce and Industry in 1976. Survey forms were
mailed to all (5568) manufacturing firms listed in the Minnesota
Directory of Manufacturers; of these, 15% responded, represent-
ing 21% of the state's manufacturing employment. Of the 835
6-10
-------
TABLE 6- 3. CONTINUED
State
Description
Minnesota firms responding, 103 were determined to be SVHW generators
(continued) with the remainder being large generators or reporting no waste.
In addition to waste generation information, data on waste
handling/disposal costs and employment were provided in some
cases.
Mississippi
Missouri
New Hampshire
New Mexico
New York
A "door-to-door" survey of "special wastes" was conducted by
the State Board of Health, Division of Solid Waste Management
and Vector Control, 1974. Data were made available to TRW on
a limited basis, and were collected for approximately 15 SVHW
generators representing 14 4-digit SIC codes. In addition to
waste generation information, data on waste handling/disposal
costs were provided in some cases.
Industrial waste survey conducted in 1978-79 by State Dept. of
Natural Resources covering the pre-selected number of approxi-
mately 480 plants (10% of the industrial base of the state).
Approximately 45% of the industries surveyed fall into SIC's
10, 28, 29, 30, 33, 34, 35 and 36, with the remainder falling
into the other major manufacturing SIC's. Companies in the sub-
ject SIC's were selected based primarily on size, i.e., 100% of
all firms having greater than 100 employees were surveyed, plus
smaller numbers of firms having fewer than 100 employees. In
the non-manufacturing SIC's, only SIC's 10 and 16 were included
in the survey. About 60% response was received; of the 288
plants for which responses were received, 124 were determined
to be SVHW generators. The survey addressed selected SIC's
thought to be major waste sources. Data on employment also
collected from each facility surveyed.
Mail/visit survey conducted of SIC's 14-39 by State Dept. of
Health and Welfare, Bureau of Solid Waste. Approximately one
third of the subject industries in the state were contacted.
Of those firms responding to the survey, 131 were determined
to be SVHW generators.
Preliminary results received from HW survey conducted in spring
of 1979 by State Environmental Improvement Division, Solid Waste
Management Unit. Less than 25% of potential generators surveyed,
based on state manufacturing directory. Emphasis placed on
mining and manufacturing SIC's. Of 20 preliminary responses
received, 5 were determined to be SVHW generators.
Survey conducted by State Dept. of Environmental Conservation,
Division of Solid Waste Management in major manufacturing SIC's.
Survey was conducted on a county-by-county basis, with emphasis
placed on firms with the largest employment in each county.
Survey covered approximately 1100 firms, representing 25% of
the state industrial facilities. Of the firms responding,
approximately 500 (55%) were determined to be SVHW generators.
In addition to manufacturing firms, a few select non-manufactur-
ing establishments (e.g., utility companies, R&D laboratories)
were also included in the study.
6-11
-------
TABLE 6-3. CONTINUED
State
Description
Rhode Island
Oklahoma On-going survey performed by State Dept. of Health, Industrial
and Solid Waste Division, utilizing mailed questionnaires, tele-
cons and on-site visits. Pre-survey conducted in 1978 in which
100% (3,500)., of industrial firms in state directory of manufac-
turers and products were contacted. Additional 1500 non-manu-
facturing companies (e.g., beauty parlors, laundries) and manu-
facturing firms listed in telephone directories also contacted
by mail. Based on the results of the pre-survey, approximately
700 firms determined to be hazardous waste generators and re-
surveyed. To date, responses received from 450 firms (64%
response rate). information on 300 firms computerized and
made available to TRW; the remaining 150 firms in the process
of computerization. Of the 300 firms for which data were
available, 141 (61%) are SVHW generators; 89 or 39% are LVHW
generators; the remaining plants report generation of no haz-
ardous waste. Information on employment also provided.
Survey of select Rhode Island manufacturing firms conducted in
1975-77 by State Dept. of Environmental Management, Solid Waste
Management Programs. 100% of all firms in SIC's 22, 28, 29, 30,
31, 33-36 and 39 surveyed; no non-manufacturing plants contacted.
Approximately 68% response rate received (1,156 firms). Of the
firms responding, approximately 187 determined to be SVHW gen-
erators; the remainder are LVHW generators, or report generating
no hazardous waste. Information on employment included for all
plants surveyed.
Survey of all industrial firms disposing of hazardous wastes con-
ducted in 1978 by State Dept. of Water Resources. Information
is computerized and contained in plant registration files and
in regularly updated activity report files. Data on approxi-
mately 1300 made available to TRW. Of these, 111 plants were
determined to be SVHW generators; the remainder are either LVHW
generators, or provided insufficient data. Information on
employment included for all plants surveyed.
Washington Mail/interview survey conducted in 1974 by State Dept. of Ecology
on SIC's 20, 22-24, 26-29 and 32-35. The method of stratified
significant random sampling from stratified industrial groups
was employed. Total of 600 firms contacted; 450 responses
received. Of the responses, only 99 firms (22%) provided data
on waste quantity and type. Of these, 7 (7%) are SVHW genera-
tors, and 5 (5%) are LVHW generators; the remainder of the plants
report generating no hazardous waste. Information on employment
and disposal costs also provided.
Texas
6-12
-------
Although the state of New Jersey has recently completed a state hazard-
ous waste survey, the raw plant-by-plant survey data were not available to
this program. The "manifest" information indicating the quantity of hazard-
ous waste removed from a facility by commercial haulers for disposal in land-
fills (which in many cases is the same as the quantity of hazardous waste pro-
duced at the facility), however, was available to the program and was included
in the state data base for certain SIC's.
6.1.2 Data Files of EPA and Its Contractors
In recent years the Office of Solid Waste (OSW) of the U.S. EPA has spon-
sored several "contractor" studies of hazardous waste management practices in
a number of major manufacturing industries. Although these studies generally
address larger plants, their results and the support raw data were very help- <
ful in providing process information and waste characteristics data and in
identifying additional data sources.
In developing regulations pursuant to the provisions of various Federal
Water Pollution Control laws, the Effluent Guidelines Division (EGD) of EPA
has conducted numerous industry studies (including actual plant surveys) and
has developed an enormous data base on a large number of manufacturing and
some service industries. All EGD published "development documents" were
examined and discussions were held with a large number of EGD technical staff
and EGD contractors. In addition raw data files for some 12 industry cate-
gories were reviewed.
Although the emphasis of EGD efforts has been on wastewater aspects and
not solid waste management, the EGD data were very helpful in that for some
industries they provided information obtained through actual surveys on the
size and geographic distribution of plants and on production processes employed.
6.1.3 Trade Associations
Using the "Encyclopedia of Associations" (13th Ed., Gales Research Com-
pany, Detroit, Michigan, 1979) as a guide, a very large number of trade asso-
ciations were contacted. The type of information sought included activities
performed and waste generation and disposal practices by members, results of
pertinent surveys (if any) conducted by the associations of their members,
size and geographic distributions of plants and industry experts and specific
plants which could be contacted for data acquisition.
6-13
-------
The types of responses received from trade associations varied greatly.
Many associations indicated that information on hazardous waste quantities
and waste management practices are generally non-existent, particularly for
the smaller plants which usually do not belong to a trade association and that
such information could be obtained through actual plant-by-plant surveys.
Some trade associations offered to conduct a survey of their members, but
indicated that the results of such surveys could not be made available on time
for use in this program. A number of trade associations provided listings of
representative plants and assisted in data acquisition from individual estab-
lishments via mailing of questionnaires (see Section 6.1.4). Overall, of the
large number of trade associations contacted, 74 were able to provide assist-
ance or useful information to the program.
6.1.4 individual Establishments
Using the listings in state manufacturing directories and business and
technical directories (e.g., Dun and Bradstreet Middle Market Directory,
Stanford Research Institute Directory of Chemical Producers and telephone
directories for various cities), and membership listings and plant contacts
provided by trade associations, a number of individual establishments were
contacted by telephone for information on activities performed and waste
generation and disposal practices. For most SIC's for which assessment
summary sheets were prepared, more than 3 individual establishments were con-
tacted. The type of responses received varied from "no information available"
to submittal of important relevant information. For some industries for which
no other previous studies had been conducted, the data acquired from individ-
ual establishments provided the sole information source for industry
assessment.
In addition to the telephone contacts mentioned above, information was
solicited for a number of industries via mailing of specially designed haz-
ardous waste information request forms to several individual establishments
and via telephone interviews with a larger number of establishments. The
selection of specific industries for this purpose were primarily based on
the need for the collection of additional data (e.g., due to lack of data or
apparent conflict in the existing data) and the willingness of the individ-
ual establishments to respond to a formal request for hazardous waste infor-
mation. The industries to whom such information requests were directed, the
6-14
-------
rationale for selection of such industries and the type of responses re-
ceived are presented in Table 6-4. Two examples of the completed hazardous
waste information request forms (for dry cleaning and wood preserving indus-
tries) are shown in Appendix C.
Of the very large number of establishments which were contacted (both by
telephone and via mailing of information request forms), 342 provided data
or general information on the nature of their operation, waste quantities
produced and/or disposal methods employed.
6.1.5 Census Data
A number of information sources were examined for data on number, size
and geographic distribution of plants. The Bureau of Census County Business
Patterns data (herein referred to as the census data) were determined to
be most suitable for use in the program. The census data provides statistics
for the number of establishments, employment and payroll by SIC (2-, 3- and 4-
digit primary SIC's) and county locations. The census data, which are based
mainly on information supplied by various establishments in connection with
social security and Federal income tax reporting systems, are considered by
many to be significantly more reliable (especially for the small establish-
ments) than the information appearing in many business directories which are
derived from "research type" voluntary surveys.
The 1976 census data were acquired on magnetic tape and entered into an
on-line disk storage system for computer data retrieval and manipulation.
Except for a few cases where it is noted, the census data were the sole source
of information on national and regional (EPA Regions) distributions of estab-
lishments in an SIC (or group of SIC's).
6.1.6 Miscellaneous Data Sources
In addition to those mentioned above, several information sources were
consulted in connection with this program. These sources include industry
experts, published literature (e.g., use of Medline and Toxline data bank
searches for information on waste quantities and disposal practices in the
health services industry) and various local, state and Federal agencies.
6.2 REDUCTION AND COMPUTERIZATION OF STATE DATA
Because of the voluminous nature of the state data, a computer program
was employed to process the state data on small hazardous waste generators.
6-15
-------
TABLE 6-4. SIC'S FOR WHICH ADDITIONAL DATA WERE COLLECTED FROM INDIVIDUAL ESTABLISHMENTS VIA MAILING
OF SIC-SPECIFIC HAZARDOUS WASTE QUESTIONNAIRES AND/OR TELEPHONE INQUIRIES
sic
Industry Category/Subcategory
Data Acquisition Method
No. of Responses
Rationale for Selection of SIC; Comments
15,16,
17
242
Construction industry
Saw mills and planing mills
2491
Wood preserving
I
I-1
CTi
251
281
2842-4
Household furniture
Industrial inorganic
chemicals
Specialty cleaning, deter-
gents and toilet prepara-
tions
Industry-specific information
requests were mailed to 20 estab-
lishments selected from the Los
Angeles area telephone directory.
Follow-on telephone calls were
also made.
Using Dun and Bradstreet Middle-
Market Directory, 11 firms were
selected and contacted by tele-
phone .
American Wood Preservers Institute
(AWPI) provided TRW a list of 25
representative establishments
from which TRW selected 10 specific
plants to whom questionnaires were
mailed. The selection of plants
from AWPI list emphasized geographic
distribution and firms which used
inorganic arsenic as preserving
agent.
Using Dun and Bradstreet Middle-
Market Directory, 9 firms were selec-
ted and surveyed via telephone and/
or mailing of questionnaires.
Using the SRI Directory of Chemical
Producers, 50 plants were selec-
ted from those plants determined to
be potentially small generators;
questionnaires were mailed to these
plants.
Soap and Detergent Association and
Cosmetics Association assisted TRW
in identifying a number of repre-
sentative plants; questionnaires
were mailed to 9 such plants.
1 (written) .
2 (telephone)
11
1 (written)
4 (telephone)
No data (in state files or elsewhere)
were available for this industry
No data (in state files or elsewhere)
were available for wastes from treating
of wood with pentachlorophenol. Industry
sources had indicated that the majority
of sawmills which treat wood would be
small hazardous waste generators.
Most establishments in this industry
were believed to be small generators
and wastes produced considered rela-
tively hazardous.
A very large number of primarily small
generators are included in this SIC; no
state data were available for household
wood furniture manufacturers.
Some establishments in this SIC produce
highly hazardous wastes (e.g., mercury-
bearing wastes).
Very limited data were available in the
state data files for plants: in these SIC1
-------
TABLE 6-4. CONTINUED
sic
Industry Category/Subcategory
Data Acquisition Method
No. of Responses
Rationale for Selection of SIC; Comments
2892
Explosives
I
M
~J
2992
3398
34,35
348
3484
Lubricating oils and greases
Metal heat treating
Fabricated metals products;
machinery except electrical
Ordnance and accessories,
except vehicle and guided
missiles
Small arms
3592,
3694,
3714
Auto parts and accessories
A list of about 15-20 establish-
ments was obtained from the U.S.
Bureau of Alcohol, Tobacco and
Firearms; questionnaires were
mailed to 9 of those establishments
which indicated a willingness to
participate in study.
Using Dun and Bradstreet Middle-
Market Directory, 17 firms were con-
tacted by telephone
The Metal Treating Institute (MTI)
conducted a survey of its members
(135 establishments) for TRW. A
questionnaire was mailed to MTI for
its review and mailing.
Fabricating Manufacturers Associa-
tions provided TRW with names of
representative establishments of
which 5 were contacted via telephone
A list of 20 establishments
was obtained from the U.S. Bureau
of Alcohol, Tobacco and Firearms;
questionnaires were mailed to 9
establishments willing to participate
in the survey.
A list of 20 establishments
was obtained from the U.S. Bureau of
Alcohol, Tobacco and Firearms; ques-
tionnaires were mailed to 9 establish-
ments willing to participate in the
survey.
A list of 25 representative firms was
obtained from Automotive Service
Industry Association (ASIA). Question-
naires were sent to 9 establishments
selected from the list.
15
32
No data were available in state data
files; explosives were considered to
present unique disposal problem! there
are a very large number of small genera-
tors in this SIC.
The state data covered only two plants
in this SIC; the 4-digit SIC appeared to
be the only industry subcategory in SIC
29 group having a significant number of
small generators.
Data from state data files and industry
sources appeared to conflict. A large
number of plants are covered by SIC 3398
and most were believed to be small genera-
tors.
SIC's 34 and 35 cover a broad range of
products; a very large number of firms
are included with most firms being small
generators.
No data were available in state files;
explosives waste presents unique disposal
problems; there are a large number of
small generators in this SIC.
No data available in state files; some of
the wastes generated are unique to this
industry.
SIC's cover a broad range of products;
a very large number of firms are included
with most firms being small generators
-------
TABLE 6-4. CONTINUED
sic
Industry Category/Subcategory
Data Acquisition Method
No. of Responses
Rationale for Selection of SIC; Comments
363
3843
3951
721
Household appliances
Dental equipment and
supplies
Pens, mechanical pencils and
parts
Laundry, cleaning and
garment services
O>
7341,
7349
Commercial cleaning and
janitorial services
Association of Home Appliance Manufac-
turers (AHAM) mailed a TRW questionnaire
to representative member firms.
The American Dental Trade Association
(ADTA) supplied TRW with a list of
20 representative plants; TRW mailed
questionnaires to 12 of these plants.
Writing Instrument Manufacturers Associ-
ation (WIMA) has provided TRW with a
list of a number of representative
plants. A questionnaire was mailed to
7 plants; 2 others were surveyed by
telephone.
Institute of Industrial Launderers (IIL)
and International Fabricare Institute
(IFI) identified a number of
members who agreed to respond to a TRW
survey. Questionnaires were mailed to
18 of the members identified by ILI and
IFT.
Seven firms, selected from Los Angeles
area telephone directory, were telephone
interviewed.
(written)
(telephone)
21*
SIC 363 covers a broad range of products;
a very large number of firms are included
with most firms being small generators.
The state data covered only one plant in
this SIC; this SIC is one of two 4-digit
SIC's in the SIC 38 group suspected of pro-
ducing hazardous chemical waste; ADTA was
the only identifiable trade association in
SIC 38.
SIC 3951 is one of the two major hazardous
waste producing subcategories in SIC 39
(the other is SIC 391); no data available
in the state files on this SIC, WIMA was
the only identifiable trade association
in SIC 39.
A very large number of establishments are
covered by the industry and all establish-
ments were believed to be small generators.
No data were available in state files or
elsewhere for firms in this SIC. A large
number of small generators are believed
to be covered by these SIC's.
*A few of the multiple-plant companies completed questionnaires for more than one of their operating plants.
-------
The data on large generators for four states (California, Iowa, Massachusetts
and Oklahoma) were also processed and included in the computerized state data
base.
A "facility computer input data sheet (FCIDS)" format with a total of 89
possible entry items and utilizing codes for waste characteristics and treat-
ment/disposal methods (see Appendix C) was designed and used for entering data
on individual plants into the computer. The computerized data management
system enabled ready information retrieval by such parameters as SIC's, number
of facilities generating specific wastes or waste quantities or practicing
specific disposal methods. All raw data were examined and any definite inac-
curacies (e.g., in classifying a waste as hazardous or nonhazardous) was .
eliminated before entering the data into the computer.
The computerized state data base for small (less than 5000 kg/mo) gener-
ators covers 2553 establishments in 366 2-, 3- and 4-digit SIC's. An overall
summary of this data base is provided in Table 6-5, so that waste oil gener-
ators can be addressed separately, the information in Table 6-5 covers three
categories of generators: those producing waste oils as the only wastes,
those producing waste oils as one or more of the several waste streams, and
those producing non-oil hazardous wastes. Similarly, to enable exclusion of
waste generators discharging to publicly owned treatment works (POTW's) from
those using other disposal methods, waste disposal information shown in Table
6-5 covers generators discharging all or some of their wastes to POTW's and
generators using other disposal methods. Information similar to those shown
in Table 6-5 are provided in Table 6-6 for all reported generators (small and
large) for California, Iowa, Massachusetts and Oklahoma. For about 63% of the
plants covered in the state data base, no waste disposal information were
available. Data on the percentage of plants using various disposal methods and
waste quantities handled by the reported disposal methods are presented in Sec-
tion 3.4.
6.3 USE OF STATE DATA FOR ESTIMATION OF WASTE GENERATION PROFILES
6.3.1 Evaluation of Correlations Between Waste Generation Rate and Employment
One approach which was investigated for the estimation of number of gen-
erators and corresponding waste quantities for an SIC was the use of a "per-
employee" waste generation rate. Sufficient evidence in the available data
6-19
-------
TABLE 6-5. NUMBER OF PLANTS AND'WASTE QUANTITIES IN THE STATE DATA BASE FOR SMALL GENERATORS FOR THE
STATES COVERED
AK
AZ
CA
CI
GA
1A
KS
KY
MA
Mfc
HN
HO
MS
. Nh
NK
NY
CK
ft I
TX
• WA
All Plant* (oil an4
Ma-Oil MMtM) t
NO OTY
1 10.0
137 26544.7
416 211676.0
101 34232. J
12 26640.0
278 1321*0. 4
96 7606*.. 1
71 66182.0
183 141451.1
41 30690.7
103 76216.0
116 134625. 0
15 15641.1
126 69585.9
5 2e4C.O
3*5 327222.0
157 192366.5
170 62671.8
101 1(2043.0
7 301C.O
Plant* Producing oil
aa tha Only Wa*ta
M" OTY
0 0.0
5 1000.0
17 ?190".n
10 ^l^.O
0 0.0
1 12.0
7 *95P.O
10 8*07.0
35 ll'i'S.O
1 '740.0
7 26P»».0
18 11472.0
1 0.0
?3 3313.0
3 ?«40.0
44 16«"»0.0
11 1?74S.O
26 13073.0
5 4731.0
0 0.0
Plant* Producing
Oil aa ona of thair
Waata* or aa thair
Only Naata
>" C1Y
0 b.C
10 40i5.0
f-4 J29i.i,.C
14 3657.0
0 C.C
8 2663. C
17 12ii5.C
?1 i.5(,2C.t
°» fil47t.t
n 102^5.3
?7 11C32.0
?« 2774C.O
0 O.C
50 K1Z1.G
1 2640. C
112 31V55.C
44 33164. C
30 1E665.0
8 S004.C
0 C.C
All Plaata (non-oil
vaataa)
NC OTY
1 IC.t
124 24915.7
365 176767. t
9C 3C575.0
12 2664C.C
272 125277.4
£4 6350
-------
TABLE 6-6. NUMBER OF PLANTS AND WASTE QUANTITIES FOR ALL GENERATORS (SMALL AND LARGE) IN THE DATA BASE
FOR CALIFORNIA, IOWA, MASSACHUSETTS AND OKLAHOMA
STATE
CA
1A
hA
CK
AJJ. Plants 1011 ana
nan-oil wastes) '
NO OTV
498 1542609972.6
320 8350520.4
2t9 6574334.3
219 i3537??64.f
Plant* prooucing oia
as the Only Haste
MH OTY
40 348710.0
1 1?.0
37 ? 03 67.0
13 161?78.0
Oil, w MM of tbaiz
Hastss or as their
Only Waste
Kin . 0 1 Y
70 446351. C
9 2663.0
l?0 33P43t.C
^4 S?fc6t4.C
All Plants (non-oil
wastes)
NO OTY
444 1542163621. t
314 6347657.4
207 6235896.3
203 234373610.5
Plants Discharviag
all Hastes to POIW
NO CTY
74 164943695.6
25 13321.1
7 74716.0
1 0.0
Mants Diuchargtoi
all or so»» of
their waste to POTH
hC OTY
112 197169676.2
83 5727676.2
19 917473.0
7 141132.0
Aupiati^ry.
T»3 olirfcaitii lo
POTW's)
NC OTY
424 1345420296.6
295 2622644.2
242 5656661.3
216 235231132.5
cn
i
to
-------
was not found to justify pursuing the "per employee" waste generation rate
approach in calculating total hazardous waste quantity. This method pre-
sumes, of course, a strong association between total waste quantity to dis-
charge for a plant and the number of persons employed in that facility.
Although there was considerable data on employment and much data on waste
quantity by plant, only eleven SIC's had data for both variables. These
eleven SIC's were analyzed and the results of this linear correlation ana-
lysis are given in Table 6-7. "Scatter diagrams" for two of the investi-
gated cases (SIC's 282 and 3398) are shown in Figures 6-1 and 6-2. SIC 3398
is indicative of the only significant correlation between employment level
and waste quantity found in this study.
Of the eleven SIC's analyzed for linear correlation, ten were judged to
have these variables uncorrelated and one (SIC 3398) was found to show highly
significant positive correlation. These conclusions were based upon a test
of the hypothesis of zero correlation between waste quantity and employment
for the particular SIC. If, in fact, no correlation were to exist in that
particular industry, a sample correlation coefficient (Pearson's r) calcu-
lated from a random sample of that industry, would not differ from zero
except due to chance or sampling variations. The critical values of r given
in Table 6-7 indicate the amount of sampling variation allowed for r when
there is no correlation between waste quantity and employment. Therefore,
when a sample correlation coefficient, r, deviates from zero by more than
the critical value, the conclusion is that employment and waste quantity are
correlated.
Unfortunately, even though one SIC was found to have significant corre-
lation between these variables, the fraction or percentage of the total vari-
ation of waste quantity that is explained by the linear correlation with
employment was too low to give credence to per-employee method of waste
quantity prediction. The use of an average or a median per-employee waste
generation rate was also investigated for some SIC's and determined to yield
inaccurate estimates. For example, for SIC 282, the use of the median per-
employee waste generation rate (obtained by dividing the median of the plant
waste quantities by the median of the plant employment sizes) resulted in
estimates which indicated that all plants in this SIC would generate less
than 5000 kg/mo, an inaccurate assertion based on actual survey data and
results of pervious industry studies.
6-22
-------
TABLE 6-7. LINEAR CORRELATION BETWEEN EMPLOYMENT AND WASTE QUANTITY
SIC
282
2891
2893
3398
3479
355
359
3662
7218
7391
753
Sample Size
n
24
6
7
32
12
16
5
32
18
4
12
Calculated
Correlation
Coefficient, r
-0.02
0.14
-0.31
0.54
-0.284
0.186
-0.49
0.341
0.339
-0.57
0.31
Critical Value of r for
Significant Correlation
0.388
0.811
0.754
0.449*
0.576
0.497
0.878
0.349
0.468
0.950
0.576
Conclusion
No correlation
No correlation
No correlation
Highly signi-
ficant*
No correlation
No correlation
No correlation
No correlation
No correlation
No correlation
No correlation
Percentage^
Explained
Variation, lOOr
29.2
N)
U)
*This critical value is chosen to reject the hypothesis of no correlation at a significance level of 1%;
all others shown are at the 5% level.
^Percentage of the total variation of waste quantity that can be explained due to its linear correlation with
number of employees.
-------
en
i
10
140- -
w
100- -
8 4
60- -
tf
w
1000
2000 3000
WASTE AMOUNT (KG/MO)
4000
FIGURE 6-1. WASTE GENERATION RATE VS. PLANT EMPLOYMENT FOR SELECTED PLANTS IN SIC 3398
-------
Ul
JbU
280
«
»
, *
^
jlT"
JJJ
20 j* ,,_ .
m
^
^
*
t
i
-------
Because of the above findings, the use of a per-employee waste genera-
tion rate for estimation of the distribution of number of establishments and
corresponding waste quantities by waste generation rate category has been
limited in this study to only a few SIC's which were not covered in the state
data base and for which no data other than estimates of the total SIC employ-
ment and waste quantities or estimates of employment and waste quantities for
one or two establishments (contacted in this study) were available.
6.3.2 Use of State Data as a Representative Sample of Generators in an SIC
A second approach which was investigated and used in this study for the
estimation of waste generation profiles for most SIC's was to project the
observed distribution of establishment in the aggregated state sample to the
nation as a whole (or to an EPA Region). The extension of a number of genera-
tors and amount of waste from the sample data base to the nation is based upon
the assumption that the aggregate state data is representative of the national
situation with regard to waste generation within any given SIC, an assumption
which is considered reasonable in light of the nature of the data base (i.e.,
an aggregate of a large number of "independent" data elements - see Section 5,
Assessment of. the Quality of Data Base) .
The following procedure was used for extending the data in a state sample
to the nation or EPA Region. The monthly waste generation rates for establish-
ments in the state sample were rank ordered and cumulative percentages of the
number of plants generating waste quantities less than indicated rates were
calculated.* These data were then plotted on normal-probability and lognormal-
probability papers to obtain the line of best fit. The distribution indicated
by the line of best fit was then applied to the census data on total number of
establishments in the nation (or in an EPA region) for an SIC, with allowances
made for the estimated fractions of plants which, based upon the survey results
for New York, Massachusetts and Iowa, were considered "zero" generators and
"large" generators. The total waste quantity associated with establishments
in a waste generation rate category was then calculated by multiplying the
number of establishments in the category by the "mid-point" waste generation
rate for that category. As described in Section 6.3.3, a computer program was
*Where additional plant-by-plant waste generation quantities were available
from other sources (e.g., the data collected in this study via contacts with
individual establishments), such data were added to the state sample prior
to distribution analysis.
6-26
-------
developed and used to carry out the distribution analysis based on state
samples. Example plots of sample state data for SIC's 3471 and 7342 are
shown in Figures 6-3 and 6-4, respectively.
6.3.3 Computer Calculation of Industry Waste Generation Profiles
A computer program (INDPROF, acronym for Industry Profile) was developed
and used with the TRW time-shared (TRW/TSS) computer system to carry out the
numerous calculations associated with the use of the state and census data
to estimate the number distribution of generators in various waste generation
rate categories and the associated waste quantities.
Output of Program INDPROF
Output of program INDPROF consists of two reports: industry waste gen-
eration profile, included in the SIC-by-SIC assessment summaries presented in
Appendix B, and "Sample Summary Report" providing statistical data and other
information for evaluating the qualities of the data base and the calculated
outputs. Example sample summary reports for SIC's 3471 and 7342 are pro-
duced in Appendix C.
The industry waste generation profile consists of a tabulation of esti-
mated number of establishments and corresponding hazardous waste quantities
where each of these variables are tabulated for each EPA region and for the
U.S., against waste generation rate (kg/mo) in ranges of 1 to 1000 (by 100's),
1000-2000; 2000-5000, and >5000 kg/mo. The profile also provides calculated
national totals and totals by EPA region.
The Sample Summary Report consists of several outputs. One output is a
cumulative distribution of waste generation data (total waste quantity to dis-
charge) for each plant in the sample data base, cumulated for the same ranges
as in the Industry Waste Generation Profile Report. Additional output from
the Sample Summary Report is a tabulation of ranked waste quantities, logarith-
mic transformations, and calculated cumulative percentage plotting positions
for the input data.
Also produced by the Sample Summary Report are sample statistics, e.g.,
averages and standard deviations for both original (untransformed) data and
logarithmic data, as well as 50th and 84th percentile estimates of the waste
quantity distribution and measures of the goodness of fit of the sample data
6-27
-------
:o,ooo
10
10 20 30 »»0 50 60 70 80 90
PERCENTAGE OF PLANTS WITH WASTE GENERATION RATES
LESS THAN THE INDICATED VALUES
95
Figure 6-3. Cumulative Percentage Distribution of Plants in the Sample
State Data for SIC 3471
6-28
-------
5 10 20 40 60 80 95
PERCENTAGE OF PLANTS WITH WASTE GENERATION RATES
LESS THAN THE INDICATED VALUES
Figure 6-4. Cumulative Percentage Distribution of Plants in the Sample
State Data for SIC 7342
6-29
-------
to a normal, lognormal or exponential distribution to assist in the verifica-
tion of the computational work where required. These statistics are produced
such that fitting of either a normal distribution a normal distribution of
waste quantities or lognormal distribution can be done.
Fifty SIC waste quantity profiles were reviewed and audited for goodness
of fit of each of three models; lognormal, normal, and exponential distribu-
tions of waste quantity. Of these, only three SIC classifications were best
fit with the normal distribution. For the remainder, the lognormal distribu-
tion more frequently was the better model to represent waste generation than
the exponential model. To give further insight into the nature of choice
of the proper model to be used in curve fitting waste quantity distributions,
goodness of fit was classified by 1-digit, 2-digit, 3-digit and 4-digit SIC's.
These are given in Table 6-8.
TABLE 6-8. BEST CURVE FIT FOR WASTE GENERATION WITHIN AN SIC FOR 50 SIC'S
Number (%)
Exponential Lognormal Normal
1-digit SIC (XOOO) 1 (100) 0 (00) 0 (00)
2-digit SIC (XXOO) 5 (85) 1 (17) 0 (00)
3-digit SIC (XXXO) 6 (35) 11 (65) 0 (00)
4-digit SIC (XXXX) 6 (23) 17 (64) 3 (12)
18 29 3
The information contained in Table 6-8 indicates the value of the expon-
ential distribution in waste quantity analysis at the aggregate SIC'level.
This study indicates that, at the lower (3- or 4-digit SIC) or purest indus-
trial classification levels, the lognormal curve provides the best model for
waste generation distribution. The transition from lognormal to exponential
is shown in Table 6-8 to be directly related to the degree of aggregation of
industrial classifications. Table 6-8 suggests that the exponential distri-
bution may result from summing the generation rates of dissimilar lognormal
distributions.
An important aspect of the choice of the model, especially for environ-
mental decision makers, is to keep in mind a fundamental distinction of these
two theoretical models, i.e., the exponential model presumes a modal genera-
tion rate of zero, while the lognormal allows for a modal generation rate
greater than zero waste quantity.
6-30
-------
Input to Program INDPROF
Input to program INDPROF consists of a number of SIC-specific information
items which are fed to the system for a given SIC or SIC group and waste gen-
eration data which are retrieved by the computer from the state data base.
The SIC-specific information includes the following:
(a) SIC number. May be specified as an inclusive range of SIC
numbers for aggregating purposes.
(b) Total number of establishments for this SIC in the U.S. or EPA
region. This is obtained from the Bureau of Census tape.
(c) Percent of (b) estimated to be zero quantity hazardous waste
generators.*
(d) Percent of (b) estimated to be large volume hazardous waste
generators and the estimated average waste quantity produced by
a large generator.*
The SIC information (a) is processed with TRW/TSS editor program into an
input control file for INDPROF. During the execution of INDPROF, the program
will prompt for items (b), Co), and (d) to be. supplied interactively.
Waste generation data in most cases is obtained by retrieval from the
state data base. For each SIC or SIC group, waste quantities to discharge
are retrieved and saved in on-line storage for pre-processing prior to INDPROF
run.
Pre-processing of waste generation data consists of right-justification
of waste quantity data, subtraction of waste oils and wastes discharged to
sewers, and sorting of the data in ascending order with computer system
utility program SORTC. This processing produces file IPDATA.
Computational Sequence of Program INDPROF
The following is the sequence of computations involved in program INDPROF.
(a) For a given SIC (or group), INDPROF tabulates sample waste quantities
and number of establishments according to waste generation rate
intervals.
*The percentages of "zero" and "large" generators and the average hazardous
waste production rate for large generators are based on survey results from
the states of New York, Iowa and Massachusetts (see Section 6.1.1).
'''Generators which discharge to sewers are considered to be regulated by other
ordinances and effluent guidelines regulations and hence are not addressed
in this study. Also not addressed are waste oil generators (see Section
3.0) .
6-31
-------
(b) Totals, averages, and standard deviations are computed for
sample waste quantity data and log transformed sample waste
quantities.
(c) The estimated number of small generators nationally (or in an EPA
region) is computed from the total number of establishments less
number of zero generators less number of large volume generators.
(d) The estimated number of small generators is allocated to the waste
generation rate intervals through the use of cumulative percentages
of a fitted normal or lognormal distribution obtained in (b).
v '
(e) Estimation of total national hazardous waste quantity for each SIC
is accomplished by computing total waste quantity for each waste
generation rate interval for that SIC and summing.
The intervals at each extreme end of the generation rate distribu-.
tion were given special treatment.
i) For the lower end (0-100 kg/mo), total waste quantities
were calculated by the product of the median waste genera-
tion rate (for plants in the state data base in this cate-
gory) and the estimated number of generators nationally.
Where the observed sample median did not differ appreci-
ably from the midpoint of this interval, the midpoint
(50 kg/mo) was used.
ii) For plants in the "greater than 5000 kg/mo" waste genera-
tion rate category, the estimated national hazardous waste
quantity was obtained by multiplying the estimated number
of plants by the average waste quantity for large generators
as reported in the New York, Massachusetts, Iowa and Rhode
Island surveys (see Section 6.1.1).
With special treatment given to each extremity of the waste genera-
tion distribution in each SIC, the balance of national hazardous
waste quantity was computed by the summing the products from multi-
plying estimated number of firms nationally and midpoints of each
generation rate interval. For those intervals in or near the center
of the distribution, or where the distribution is approximately uni-
form within the interval, use of the midpoint in calculating national
waste quantities is proper for the accuracy that is implied by these
data. Where the generation rate distribution is not approximately
uniform within an interval, a bias in national waste quantities for
that interval is introduced by using the midpoint.
The-degree of bias introduced through use of midpoints of waste
generation intervals was(investigated for several SIC's. For
example, total waste quantities for SIC 3471 and SIC 721 wore com-
puted by interval nic!?oints and by numerical integration of the
waste quantity curve. A comparison of these results are given in
Tables 6-9 and 6-10.
6-32
-------
TABLE 6-9. COMPARISON OF NUMERICAL INTEGRATION WITH MIDPOINT CALCULATION
METHOD FOR NATIONAL WASTE QUANTITY (SIC 3471)
Waste
Generation
Ranges
0 - 100
100 - 200
200 - 300
300 - 400
400 - 500
500 - 600
600 - 700
700 - 800
800 - 900
900 - 1000
1000 - 2000
2000 - 5000
>5000
Total
Number of
Generators
992
392
226
150
108
82
65
53
44
37
189
132
618
Waste Quantity (kg/mo)
Midpoint
Calculation
49,600
58,800
56,500
52,500
48,600
45,100
42,250
39,750
37,400
35,150
283,500
462,000
12,545,400
13,756,550
Numerical
Integration
43,764
56,661
55,744
52,215
48,455
45,034
42,002
39,320
36,935
34,803
266,175
404,749
12,545,400
13,671,256
% Difference
13.3
3.8
1.4
0.6
0.1
0.1
0.6
1.1
1.3
1.0
6.5
14.1
0.0
0.62
6-33
-------
TABLE 6-10. COMPARISON OF MIDPOINT CALCULATION WITH NUMERICAL INTEGRATION
METHOD FOR NATIONAL INDUSTRY WASTE QUANTITY (SIC 721)
Waste
Generation
Ranges
0 - 100
100 - 200
200 - 300
300 - 400
400 - 500
500 - 600
600 - 700
700 - 800
800 - 900
900 - 1000
1000 - 2000
2000 - 5000
>5000
Total
Number of
Generators
1969
325
175
115
84
65
52
43
36
31
177
161
0
3233
Waste Quantity (kg
Midpoint
Calculation
98,450
48,750
43,750
40,250
37,800
35,750
33,800
f
32,250
30,600
29,450
265,500
563,500
0
1,259,850
Numerical
Integration
52,947
46,733
42,969
39,907
37,439
35,393
33,655
32,150
30,828
29,650
250,844
510,331
1,142,846
/mo)
% Difference
85.9
4.3
1.8
0.9
0.9
1.0
0.4
0.3
-0.7
-0.7
5.8
10.4
10.2
6-34
------- |