Prepublication issue for EPA libraries
         and State Solid Waste Management Agencies
    ASSESSMENT OF INDUSTRIAL HAZARDOUS WASTE PRACTICES,

               RUBBER AND PLASTICS INDUSTRY

                        Appendices
     This report (SW-l63c.4) describes work performed
for the Office of Solid Waste under contract no. 68-01-3194
     and is reproduced as received from the contractor.
    The findings should be attributed to the contractor
           and not to the Office of Solid Waste.
             Copies will be available from the
          National Technical Information Service
                U.S. Department of Commerce
               Springfield, Virginia  22161
          U.S. ENVIRONMENTAL PROTECTION AGENCY

                          1978

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This report was prepared by Foster D. Shell, Inc., Florham Park,
New Jersey, under Contract No. 68-01-3194.

Publication does not signify that the contents necessarily reflect the
views and policies of the U.S. Environmental Protection Agency, nor
does mention of commercial products constitute endorsement by the
U.S. Government.

An environmental protection publication (SW-163c.4) 1n the solid waste
management series.

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                      TABLE OF CONTENTS


                          APPENDICES


Appendix                                Title


   A                     Program Methodology
   B                     Protocols Used And Results
                         Obtained In Analysis Of Waste
                         Stream Samples
                         Hazardous Waste Contractors And
                         Service Organizations
                         Detailed Definition Of The Plastics
                         And Rubber Industry — SICs 282 and 30
                              111

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              APPENDIX A  —  PROGRAM METHODOLOGY
     The approach  selected  to  assess  industrial  hazardous waste
practices in the rubber  and plastics  industry  centered  around  three
major tasks:

               Data collection

               Data analysis and  application of  economic
               modeling  techniques

               Definition of potentially  hazardous  waste.

     Each of these elements are discussed below.  Overall study
logic is provided  in Exhibit A-l, at  the  end of  the appendix,
followed by a task definition  in  Exhibit  A-2.


1.   DATA COLLECTION

     As noted in Volume  I — Executive  Summary,  the data
requirements for this  study were  obtained essentially from  four
sources.

               Review  of published  information

               Data collected  during  our  previous work  for
               government agencies  on the rubber and plas-
               tics industry

               Information  obtained from  trade association
               participation

               Information  obtained from  personal contact
               and visits to the  various  plants  and corpor-
               ate offices  of  companies classified  in
               the industry and to  waste  disposal firms
               handling  hazardous wastes.

     Of the above  information  sources, direct  industry contacts
proved to be most  useful in providing the detailed  data require-
ments.  Because almost all  facilities visited  varied significantly
in the manner in which wastes were  generated and disposed of,  the
same questions could not be asked of  all  the individuals contacted.
Instead, questions were tailored  for  each situation.

     However, as a guide to the types of  questions  and probes
used to collect data, a data acquisition  form  is provided as
Exhibit A-3, following Exhibit A-2.
                            A-l

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     As can be seen from Exhibit A-3, industry representatives
were generally asked questions regarding:

               Plant type, size, locations, etc.

               Processing methods

               Waste stream generation

               Waste properties

               Treatment and disposal methods

               Costs for treatment and disposal of potentially
               hazardous wastes.

     In addition, the representatives were asked if they would
supply the Study Team with waste samples for analysis in our
laboratories.  The results of the sampling program are described
in Appendix B .and in the body of the report.

     Exhibit A-4, following Exhibit A-3, tabulates significant
production processes used in SICs 282 (Plastic Materials and
Synthetic Industry) and SIC 30  (Rubber Production Industry).
As presented by the exhibit, there are approximately 100 com-
mercially significant processes.  During the data collection
phase of this study, more than 60 field trips were made.  A
field trip is defined as a visit to a plant site.  However,
in many cases, visits were actually made to a plant complex
using more than one major process.  Therefore, processes
observed significantly exceeded field trips completed and
provided coverage of most relevant processes in use at the
time of the study.  Exhibit A-5, following Exhibit A-4,
provides a breakdown of contacts by groups visited.  In addition,
to the field trips, between 200 and 250 telephone calls were
made to industry representatives to supplement data.

     Exhibit A-6, following Exhibit A-5, provides the distribu-
tion of waste samples obtained and analyzed.  Note that the purpose
of the spot sampling program was to provide evidence of the reli-
ability of assumptions made concerning the general composition
of the wastes and the concentrations of related components.
                             A-2

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2.   DATA ANALYSIS

     Data analysis generally  involved:

               Definition of  processes  used  to manufacture
               materials

               Estimate of waste  streams  and wastes  gener-
               ated from each unit  operation by waste  type
               and quantity

               Classification of  wastes into non-hazardous
               and potentially  hazardous  categories

               Determination  of waste disposal methods,  their
               adequacy and their costs

               Estimating the quantity  of potentially  hazardous
               wastes to be disposed of by state  and EPA regions
               and nationwide for the year 1974,  1977  and 1983.

     Estimates of potentially hazardous wastes to be disposed of
on a geographic basis were made by:

               Developing hazardous waste factors (as  the
               weight of hazardous  waste  per weight  of
               product produced)  for a  typical process
               type in a representative plant.

               Multiplying these  factors  by  the volume of
               production in  a  given geographic area.

               Adding wastes  produced by  geographic  area to
               arrive at national numbers.

     Current production values  and  plant  location were obtained
from data, industry-supplied  information, other published litera-
ture and professional judgments.

     To obtain projections of potentially hazardous  wastes to be
disposed of in the years 1977 and 1983  industry production was
estimated through a computer-based  economics model,  known as
INFORUM — Interindustry Economic Research Project of  the Uni-
versity of Maryland.

     The INFORUM model uses input-output  (I/O) analysis  to
make long-term forecasts of the American  economy.  I/O analysis
is based on the concept that  the  outputs  on  production of one
industry can be translated into inputs  or consumption  in other
industries.  The model uses 200 industry  groupings or  sections
to cover the entire economy.
                             A-3

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     The modeling process involves an estimation of consumption,
investment, employment and export and import functions for each
sector, using, various alternative scenario assumptions about
government expenditures, cost of capital, import/export restric-
tions and various technological developments.  The forecasts
proceed year-by-year for a decade into the future.

     The value of wastes is estimated from the projected value
(deflated to constant dollars) of material consumption and final
production in each industry for selected years and from the
waste generation factors calculated for typical processes.  Based
on an anlysis of projected versus actual production and consumption
as actual data becomes available, it is known that the INFORUM
model provides a reasonably accurate means for estimating economic
conditions.
                              A-4

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3.   DEFINITION OF POTENTIALLY HAZARDOUS WASTES

     Under the time and budgetary constraints of the project, it
was, of course, impossible to carry out detailed original toxi-
cological, chemical, biological and other investigations to deter-
mine the potential hazard from the literally thousands of chemical
substances in these industries which may become wastes.  Instead,
we relied on several published sources which are compendia of
much of the required information.  These sources are:

               Reference 1 — Dangerous Properties of
               Industrial Materials  (4th Ed.) N. Irving Sax,
               Van Nostrand New York: Reinhold Company, 1974.

               Reference 2 — Clinical Toxicology of
               Commercial Properties  (3rd Ed.) Gleason,
               Gosselin, Hodge and Smith, Baltimore:  The
               Williams & Wilkins Co., 1969.

               Reference 3 — A Study of Hazardous Waste
               Materials, Hazardous Effects and Disposal
               Methods, Booz, Allen Research, Inc., United
               States Environmental Protection Agency  (Contract
               #68-03-0032), Cincinnati, Ohio:  1972.

     The following paragraphs detail the parameters which were used
in determining if a waste as defined in the study may be potentially
hazardous.

     3.1  Toxic Substances Were Defined On The Basis Of Oral
          Toxicity

          The following toxic effects may occur in an acute form
     or chronic form or both, and may jeopardize the health and
     welfare of humans and the safety and propagation of terrestrial
     or aquatic life forms:

               Oral toxicity

               Inhalation toxicity

               Dermal penetration toxicity

               Dermal irritation reaction

               Aquatic toxicity

               Phytotoxicity.

          For the pupose of this study, oral toxicity was accepted
     as the basis for defining a toxic substance because much more
     data is generally available to support published conclusions
     based on this parameter.
                             A-5

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     References 1 and 2 above were chosen as the primary
sources determining if the wastes contain toxic materials.
Two works were chosen for use because many substances needed
to be categorized.

     The most serious deficiency of the literature for
the purposes of the project is that it is nearly all occu-
pationally or laboratory oriented.  The result is that
toxic effects documented are responses to higher concentrations
than levels which may be expected to accrue from deposition
of relatively small quantities of these substances in land-
fill.  Since few epidemiological facts are available, infor-
mation developed on the basis of occupational or laboratory
exposure was substituted.

     The two references selected as our primary toxicological
data base use different scales for rating a substance's
toxicity:

          Exhibit A-7, following Exhibit A-6,
          presents the toxicity rating scale
          for Reference 1.

          Exhibit A-8, following Exhibit A-7,
          presents the scale for Reference 2.

     In the determination of a waste constituents' toxicity,
a conservative approach was chosen, since information contained
in the reference may be based on more unknown factors than
known ones.  Therefore, any substance having a toxicity rating
2 (moderate) or above including U  (unknown) in Reference 1;
and 3 (moderate) and above, in Reference 2, was considered
toxic in the context of this study.  Wastes containing such
substances in either the pure form or combined with other
materials were considered potentially hazardous.

3.2  The Potential For Flammability, Explosivity And
     Reactivity/Corrosivity Of The Wastes Was Ranked

     Human health and welfare, as well as animal and vege-
tation, may be exposed to hazardous situations involving
flames and/or explosions caused by some substances.  Other
adverse effects may occur as a result of rapid or violent
chemical reactions of substances.  Flame, explosion or
reactions produce heat which causes many compounds to
emit highly toxic fumes or to react more vigorously with
oxidizing materials.  Some compounds can react rapidly
with ground water, for example, to produce toxic or
flammable vapors.  Acids may be produced by reactions,
and heat generated by flame or reaction may itself be a
serious hazard to many ecosystems.
                         A-6

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     Just as there are levels of toxicity, there are
degrees of flammability, explosivity and reactivity.  To
judge the potential hazard of the wastes in terms of these
factors,-we relied heavily on Reference 3 where many sub-
stances have been ranked as to their potential hazard
capacity in this area.

     In addition, information contained in the other two
references was taken into account.  Also, any waste substance
with a flash point of 38°C  (100°F) .or higher  (as measured
by the Tag Open Tester), where known, were deemed potentially
hazardous.  This is the limit which has been made by the
Department of Transportation to designate hazardous flammable
solvents which require a red warning level.

     The hazards rating criteria for flame explosion and
reaction/corrosion in soil from Reference 3 is presented in
Exhibit A-9, following Exhibit A-8.  Any waste containing
substances having a rating above 2  (moderate hazard) includ-
jng U (unknown) was considered to be potentially hazardous.

     If any constituent of a waste stream met the criteria
described above as hazardous for any of the categories, the
waste was considered potentially hazardous.  Spot sampling
of the waste (described in Appendix B) was used to confirm
assumption on the presence of potentially hazardous compon-
ents in the wastes.
                        A-7

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                                                                                                                     EXHIBIT  A-l
                                                                                                                     STUDY  LOGIC
        L ANALYSES TO BE PERFORMED-
          II.  WASTE DISPOSAL PRACTICE-
                                                               RUBBER AND PLASTICS INDUSTRIES
            •  INDUSTRY CHARACTERIZATION;  TASK 1
              WASTE CHARACTERIZATION
              AND SCREENING:  TASK 2
              TREATMENT AND DISPOSAL
              TECHNOLOGY CHARACTERIZATION;
              TASK 3

              COST ANALYSIS OF DISPOSAL
                    TECHNOLOGY;  TASK 4
oo
        Notei- (1)  Wastes destined for release
                  to air or water at plant site
                  are viewed to be outside
                  the scope of thli study.
              (2)  Includes industry waste quantifi-
                  cation on state and national levels.
                  (wet and dry basis)
        Source; Snell review and analysis of study
               requirements.
          Wastes Destined For Land Disposal*1) <2>
          . Wastes whose physical properties are
            typified by
            • solid
            . liquid
            - sludge phases
          . Wastes directly generated from manu-
            facturing processes
          . Wastes produced by air or water pollution
            control procedures
   HAZARDOUS WASTES
Especially those containing;
asbestos,  arsenic, beryllium,
cadmium, chromium, copper,
cyanides, lead, mercury,
halogenated hydrocarbons,
pesticides, selenium, zinc
and carcinogens, including
those which are radioactive.
                                                               I
                                  DESIRED OUTPUTS
                                INDUSTRY DESCRIPTION
                                -  Plants and locations
                                •  Distribution of number of flrms and plants
                                •  Distribution of plant rite as a function
                                   of employees
                                •  Manufacturing process distribution
                                -  Location distribution
                                -  Age distribution
                                •  Product line

                                METHODS OF WASTE TREATMENT
                                AND DISPOSAL
 POTENTIALLY HAZARDOUS
         WASTES
I.e., those which might be
suspected to cause a reaction
and form a hazardous substance.
                                                             WASTE DISPOSAL METHODS INCLUDING:
      Burial: deeper surface
      Chemical and biological
      detoxification
      Lagoonlng
      Recovery and reuse
      Deep well injection
   .  Mine disposal
   .  Open burning
   .  Incineration
   .  Open dumping
   .  Combinations of
      the above
   .  Ocean dumping
•  Detailed waste description and
   disposal methodology
-  Process changes necessitated by
   reduction in hazardous waste
   production
-  Levels of proficiency for disposal based
   on survey
   .'. Level I - techniques presently
             employed
   ,. level n - best technology
              currently employed
   .. Level HI» technology necessary
               to provide adequate
               health and environmental
               protection = developing
               technology beyond Level n
COSTS OF ADEQUATE DISPOSAL
-  Investment costs
-  Operating costs

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                                                                                                                     EXHIBIT  A-2

                                                                                                                  TASK DEFINITION
               Task                Description

                 1.         Industry Characterisation

                 2.         Waste Characterization and Screening

                 2.1        .  Develop material balance around each 4 digit SIC sector and engineering material balances for the individual processes
                               of commercial significance *wlOO

                 2.9        .  Develop hazardous materials priority list by process based on the substances Identified in 2.1 and review with Project Officer

                 2.8        .  Rank processes for potential for production of wastes destined for land disposal

 I                2.4        .  Develop priority decision model to screen out 20 processes (for budget purposes) for detailed studies in Tasks 3 and 4s
vo
                                •  Use the following parameters

                                  .. Hazard potential related to materials consumed based on Task 2.2
                                  .. Process potential for producing wastes destined for land disposal,  based on Task 2.3
                                  .. Prevalence, based on Task 1, related to output, number of plants and average size

                                •  Assign scores to these parameters and aggregate with hazard potential given highest weight

                                •  The higher the aggregate score, the  higher the priority

                                •  The 20 processes with the highest scores will be studied In depth after the Project Officer's approval

                 2.5         .  Develop detailed engineering material balances and definition of practices around the 20 processes to be studied further
                               and characterize wastes using sampling and analysis where required

                 8.          Treatment and Disposal Technology Characterization for the 20 Priority Processes from Task 2

                 4.          Cost Analysis of Disposal  Technology for the 20 Priority Processes from Task 2
               Source:   Foster  D.  Snell  Inc.

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                                                           EXHIBIT A-3(l)
                                               CONDENSED INTERVIEWEE FORM

                   DATA .ACQUISITION FORM

                             For

                  EPA Contract No. 68-01-3194

       Assessment Of Industrial Hazardous Waste Practices
              In The Rubber And Plastics Industry


      Foster D. Snell, Iric. is conducting this survey to provide data base
regarding:

                 What process.industrial wastes are generated (industrial
                 waste is defined as any waste other than direct
                 emissions to air or water effluents, where air and
                 water treatment residues and other solids or liquids
                 destined for land disposal are included) .

                 In what quantities and from what specific process
                 steps are these  wastes generated.

                 How they are treated and disposed of.

Points of contacts in responding to  the attached data acquisition inquiry are:

                 Mr. Joel M. Kushnir, Survey Coordinator or
                 Mr. Stephen F.  Nagy, Research Director
                 Foster D.  Snell, Inc.
                 Hanover Road
                 Florham Park, New Jersey   07932
                 (201)-377-6700


Name/Title of Contact	.
Company Address/Phone Number
Snell Interviewer                                    Date
Visit        	            Phone Interview
                                A-10

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                                                  EXHIBIT A-3(2)
1.   BRIEF PROCESS DESCRIPTION

     a.   Products

     b.   Plant Location and Age

     c.   Plant Capacity/Average Capacity Use

     d.   Major Process Steps  (including receiving and
          shipping)

     e.   Material Balances  (emphasizing solid waste
          generation)
2.   WASTE GENERATION RATES BY OPERATION
Source

  a
  b
  c
Type of Waste
       Quantity
(Per  Unit Of Production)
3.   WASTE CHARACTERIZATION  (see list on next page and fill
     in appropriate data)
Source/Type
of Waste

  a
  b
  c
     Physical
  Characteristics
          Chemical
       Characteristics
Sampling(Ask if they would let us visit.  Can we take represen-
Comments    tative samples?  Note possible arrangement).
                               A-ll

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                                                      EXHIBIT A-3(3)

CHECKLIST FOR PHYSICAL/CHEMICAL ANALYSIS DATA

                              General
                              Chemical
Physical                     Categories                Specific Chemicals

                               Plants
                               Rubber

4.   ON-SITE TREATMENT AND DISPOSAL PRACTICES

                    Treatment      Are There
Type of Waste/   And/Or Disposal   Alternate  	Cost
Source	   Technology Used    Methods?  Capital* Operating Maintenanc«

     a
     b
     c
Overall (Ask for comments on operating procedures, personnel
         training, etc.)

*Indicate year of investment.

5.  OFF-SITE TREATMENT AND DISPOSAL PRACTICES*

                    Treatment     Are There
Type of Waste/   And/Or Disposal  Alternate  	Cost
Source	   Technology Used   Methods   Capital** Operating Maintenance
    a
    b
    c
Overall (Enter general comments here)
* Please note whether plant or private contractor is removing,
  treating or disposing the wastes.
**Indicate year of investment.

6.   TREATMENT AND DISPOSAL SERVICE EVALUATION

          Who is contractor?
          Why was he chosen?
          What does he do with your wastes? (Type of facility:
          municipal or sanitary landfill, etc.)
          Do you have criticism of his procedures?

7.   OPINION ON CONTROL LEVELS I, II, AND III  (Ask by type of waste
     and control technology;include cost factors)

     Level I  - Prevalent Treatment and Disposal Practices
     Level II — Best Available Disposal Practices
     Level III — Environmentally Adequate Disposal Practices
     Trends — Are you looking into alternate methods?  Do you
     expect an increase or decrease in wastes to be disposed of
     due to process changes, local regulations, etc.?

8.   WHO ELSE SHOULD WE CONTACT?
     Thank you
                                  A-12

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                                                                                   EXHIBIT A-4(l)
                                                                    TABULATION  OF SIGNIFICANT  PROCESSES
                                                                               IN SICs  282  AND  30
  SIC
       Industry

Plastics Materials and Resins
/MM
                Synthetic Rabbet (vulcanlt-
                able elastomers)
Cellulosic Man-Made nbers
                Organic nbers,
                Noo-Cellulostc
                Tires and Inner Tubes
 The Major Categories
From Which 20 Processes
   Win Be Screened
For Tasks 8 and 4 Study

.  Thermosetting
  •  Alkydi
  •  Polyesters
  -  Phenolic and other
     tar resins
  -  Arnlno resins
.  Thermoplastics
  -  Polyethylene and
     copolymers
  •  Polypropylene
  •  Styrene resins
  •  Vinyl resins
  -  Others*3*

.  S-type rubber
.  Butyl rubber
.  Stereo polybutadiene
  elastomers
.  OthersP)

.  Rayon
.  Acetate fibers

.  Nylon
.  Acrylic and Modacrylic
.  Polyester

.  Tires
.  toner Tubes
     Comments

Candidates listed in this
category represent 89$ of
all tbermosetting plastics
and resin materials produced
in 1972.


Candidates listed in this
category represent 77$ of
all thermoplastics produced
in 1972.
                                                         These study candidates
                                                         represent 67$ of 1973
                                                         domestic synthetic rubber
                                                         production.
   Approx.  H0.
 Of Commercially
Significant Processes
                                                                                                        40
                                15



                                 5


                                10
                                                         Industries classified under SICs
                                                         3011, 3021, 3031 and 3069
                                                         probably have a lower relative
                                                         hazard potential In their wastes
                                                         compared to the others on the
                                                         list.

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                                                                                                                           EXHIBIT  A-4(2)
H
it*
                       3081
Rubber Footwear
                       3031
                       3069
Reclaimed Rubber
Fabricated Rabbet Products
N.E.C. (Including plaidc
note and belting,  SIC 3041)
        The Major Categories
       Prom Which 80 Piocssui
          Will Be Screened
       For Talks 8 and 4 Study

       .  Canvas footwear
       .  Waterproof footwear
                                                                                                    Comments
                                                                                       Approx. No.
                                                                                     Of Commercially
                                                                                    Significant Processes
       Reclaimed rubber
       Rubber and plastics belts
.  Wattes produced by indus-
  tries clarified in SICs 3011.
  3021 and 3069 are similar.
  Compounding ingredients
  are the likely potential
  hazards In their watte streams.

The digester process Is the major
process in this SIC, representing
46.6°fo of production volumn in
1973.
       Rubber hose and tubing
       Sponge and foam rubber goods
       Rubber floor and wall
        covering
       Mechanical rubber goods.
        n.e.c.«>
       Rubber heels and soles
       Druggist and medical sundries
       Other rubber goods, n.e.c/ '
       Fabricated rubber products,
        n.e.c., n.s.k.* *
TOTAL*6)
                                                                                                                                20
                                                                                                                               103
                       Notes;
                       (1) Bated on Snell experience with, previous study projects on the rubber and plastics Industry.
                       (2) Based on responses obtained from telephone interview campaign. Visits will be to those plants in a position to provide meaningful
                           Information as assessed by the telephone interviews.
                       (3) These will be studied only if they are shown to produce especially hazardous wastes.
                       (4) These classifications are "catchalls" for a wide variety of miscellaneous products.  By and large, the major process found here is molding.
                       (5) Of the iota]  telephone toaiviewt to be made 20% will be of industry organizations, 10% will be of waste disposal firms and the remainder
                           of the industries themselves.  Approximately 10 visits will be to industry organizations, S to disposal firms and 70 to plants.
                       Source:  Foster D. Snell, Inc.

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                                                      EXHIBIT  A-5
                                                 DISTRIBUTION  OF FIELD
                                                   TRIPS  COMPLETED
Group Visited
. Plants (1)
SIC 2821
SIC 2822
SIC 2823
SIC 2824
SIC 3011
SIC 3031
SIC 3041
SIC 3069
. Waste Disposal Facilities
. Industry Associations
. Government Agencies
Totals
Field Trips
Allocated

20
12
6
6
6
3
4
5
5
10
0









70

10
85
                                                         Field Trips
                                                          Performed
                                                              19

                                                              13

                                                               2

                                                               7

                                                               8

                                                               1

                                                               4

                                                              10
                                                              10

                                                               9

                                                               5
64


10

_9

_5
88
(1) A'field trip is defined as a visit to a plant site.  However, in many cases
     visits were actually made to a plant complex where more than one major
     process exists.  Therefore, processes observed exceeded field trips
     completed.
(2)  Associated with the field trips were between 200 and 250 telephone calls
     to industry representatives for obtaining appointments and data.

Source:  Foster O. Snell, Inc.
                              A-15

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                                                                   EXHIBIT A-6
                                                          WASTE SAMPLING AND ANALYSIS  BY STANDARD
                                                              INDUSTRIAL CLASSIFICATION (SIC)
                                                                           Hunter Of
                 SIC                     Number of Samplci Obuiaad               Sample* Analysed

                 2621                               8                            6
                 2822                               4                            4
                 2823                               2                            2
                 2824                              16                            9
                 SOU                               4                            4
                 8021                               2                            2
                 3031                               3                            3
                 8041                               4                            4
                                                 -5-                          JL

                          To«i                    48                           39
NOTE:  The  sampling program  provides spot evidence of the reliability of assumptions
       made concerning the general composition of the wastes  and the concentrations
       of selected components.
Soagca:  Fertar D. tort. *«

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                                                 EXHIBIT A-7
                                        TOXIC HAZARD RATING SCALE FOR
                                                REFERENCE 1
Toxicity
 Rating                            Definition

   0             NONE:   (a)  No harm under any conditions (b)  Harmful
                 only under unusual conditions or overwhelming dosage.

   1             SLIGHT:   Causes readily reversible changes which
                 disappear after end of exposure.

   2             MODERATE:   May involve both irreversible and reversible
                 changes not severe enough to cause death or permanent
                 injury.

   3             HIGH:  May cause death or permanent injury after very
                 short exposure to small  quantities.

   U             UNKNOWN:  No information on humans considered valid
                 by authors.
Source: Dangerous Properties of Industrial Materials, 4th Ed.
        N. Irving Sax, Van Nostrand Reinhold Company.
        New York, 1974.
                               A-17

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                                                EXHIBIT  A-8

                                        TOXIC HAZARD RATING SCALE FOR
                                                REFERENCE 2
Toxicity
 Rating
Definition
                 Practically non-toxic
                 Slightly toxic
  Probable Lethal Dose (Human)
Mg/Kg     For 70 Kg Man (150 Ibs)

above      more than 1 quart
15 gm/Kg
                       5-15
           between 1 pint and 1 quart
                 Moderately toxic


                 Very toxic


                 Extremely toxic


                 Super toxic
                       500 - 5     between 1 ounce and 1 pint
                                   (or lib.)

                       50 - 500    between 1 teaspoonful
                                  and one ounce

                       5-50      between 7 drops and
                                  1 teaspoonful

                       less than 5  a taste (less than 7 drops)
Source:  Clinical Toxicology of Commercial Products (3rd Ed),
        Gleason. Gosselin, Hodge and Smith, The Williams 6
        Wilkins Co.. Baltimore. 1969.
                                  A-18

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                                                   EXHIBIT A-9
                                        FLAME, EXPLOSION AND REACTION/
                                        CORROSION HAZARD RATING SCALE
                                        FOR REFERENCE 3  (In Soil)
FER/C
Rating
   U
                 Definition

MINIMAL:  Generally stable substances. Very limited
potential for reaction or combustion.  No toxic fumes
or vapors associated with any reactions or combustions
that may occur.

MODERATE: Can readily undergo violent chemical change
with rapid release of energy. but will not detonate explo-
sively or react violently  except under very special circum-
stances  such as heating under confinement. Can ignite
and burn rapidly or react to produce harmful, though not
lethal, vapors  and fumes if exposed to modest increase of
temperature or if moisture is encountered.

SEVERE: Readily capable of detonation and explosive
decomposition or reaction at normal ambient temperatures
and pressures. Will detonate as result of mechanical shock
or local  thermal shock.  Reacts readily with own oxides
or with other oxidizing materials.  Can ignite spontaneously
and/or react violently if exposed to moisture in soil.
Ignition or reaction can produce lethal vapors, fumes, etc.

Unknown
FER/C = Flame, Explosion and Reaction/Corrosion
Source: A Study of Hazardous Waste Materials. Hazardous Effects and
        Disposal Methods.  Booz, Allen Applied Research, United States
        Environmental Protection Agency (Contract #68-03-0032),
        Cincinnati, Ohio, 1972.
                                 A-19

-------
APPENDIX B  — PROTOCOLS  USED AND RESULTS OBTAINED IN ANALYSIS
                 OF WASTE STREAM  SAMPLES
      This appendix presents the protocols used and the results obtained in
the analysis of waste stream samples generated by the rubber and plastics
industry.  Spot samples were taken under the supervision of Sneil personnel
at the points of generation of the wastes.

1.    ANALYTICAL PROTOCOLS
      The detailed protocols are presented in the following paragraphs with
reference to standard tests where warranted.

      (1)   Total Solids

            The test was performed in accordance with the "Standard Methods
      For the Examination of Water and Waste Water", APHA, 13th Edition.
      1971, pp. 288-290.

      (2)   Water Content

            By Toluene Distillation Method — adopted from "Official
      Methods of Analysis of the Association of Official Analytical Chemists".
      12th Edition,  1975, p. 129.

      (3)   Ash Residue

            The sample is weighed into a porcelain crucible and ashed on
      a Meeker Burner at 600°C.  After ashing, the residual weight is deter-
      mined and the percent ash calculated. The residue is used for
      emission spectroscopy semi-quantitative determination.

      (4)   Emission Spectroscopy

            A known amount of the ashed material is intimately mixed with
      100 mg. of carbon powder followed by addition of 3 ml. of aqua regia
      All of the material is evaporated to dryness and gently ignited.  The
      resulting mixture is transferred to an electrode and D.C. arced tc
      completion.  A series  of standards in a carbon matrix are run along
      with the sample and semi-quantitative results  are obtained for each
      element employing a Jarrel-Ash Model 3.4 Meter Ebert Emission
      Spectrograph. The results are then calculated fx-om known standards
      and are expressed in  semi-quantitative manner.
                               B-l

-------
(5)   Atomic Absorption Spectroscopy

      The samples are digested with nitric acid, filtered and the fil-
trate diluted with water.  The resulting solution is then aspirated into
the flame of an atomic absorption spectrophotometer.  Known standards
are used for calibration of the instrument and for quantitative deter-
mination of the element in question.

(6)   Organic Chlorides

      The Parr Bomb Oxygen Combustion method followed by micro-
coulometry is employed for the determination of organic chlorides.

(7)   Phenols

      The determinations are performed in accordance with
Method D. for phenols in "Standard Methods for the Examination of
Water and Waste Water", APHA. 13th Edition, 1971, pp. 507-508.

(8)   Vinyrchloride  Monomer (VCM)

      There is no official method for this determination and recently
possible interferences from acetaldehyde, resulting from copolymeri-
zation of VCM and vinyl  acetate, has been reported.  The protocol
used by Foster D. Snell  is as follows:

Solid  Samples — A representative portion of the sample is ground to a
fine powder.  Two grams of this powder is digested for 6 hours with
40 ml of tetrahydrofuran (THF).  The digestion product is centri-
fuged and the supernatant subjected to gas chromatographic analysis
under the following conditions:  The gas chromatograph is a Perkin-
Elmer 900. The column is 8' x 1/8" O.D. packed with 20% DC 550.  The
carrier  gas is nitrogen flowing at 30 ml/min. The column is operated at
60°C until emergence of THF.  The temperature is then raised to
150°C and held  for 10 minutes, and then lowered slowly.

Calculations —  A standard is prepared containing  0.5 x 10~^ micro-
grams of vinyl chloride monomer in THF . A 5  1 inj ection at an
attenuation factor of 1  x  4 gives a peak height of 120 mm with a retention
time of 0.75 minutes.

The peak height of the extracts, corrected for the appropriate atten-
uation factor, is used  to determine the sample concentration.
                         B-2

-------
2.    ANALYTICAL RESULTS

      The analytical results for the waste samples obtained from the plant visits
and tested by Foster D. Snell, Inc. are presented in the attached Tables.

                  TABLE B-l — Tests performed on waste samples
                  obtained from plants in SIC 282, Plastic Materials
                  and Synthetics Industry.

                  TABLE B-2 — Tests performed on waste samples
                  obtained from plants in SIC 30, Rubber Products
                  Industry.
                              B-3

-------
                                                                                                                           TABLE B-l
                                                                                                              ANALYTICAL RESULTS OF WASTE SAMPLES
                                                                                                              OBTAINED IN SIC 282, PLASTIC MATERIALS
                                                                                                                 AND SYNTHETICS INDUSTRY
Product

Isoprene
Nylon 6-6
SBR
SB!*3*
Chlorinated Poly-
  ethylene
 Chlorinated Poly-
  ethylene
Polyvinyl Acetate
Nylon 6-6

Nylon 6-6
Nylon 6-6
Polyisoprene
Phenolic Resins
  i
Chlorinated Poly-
  ethylene
Chlorinated Poly-
  ethylene
Polyvinyl Chloride
Waste Description

Incinerator Ash
Warehouse Sweepings
Plant Sweepings
Catalyst Sludge
Spent Alumina(4)
Incinerator Ash

Floor Washes

Product Waste
Biological Sludge
 (Irrigation)
Biological Sludge
Waste Nylon Salt
Wastewater Sludge
Phenolic Residue

Filter (New)

Used Filter

Reactor Waste (Emulsion)

A«ML
57.9
4.8
57.5
13.2
77.5
92.5
-
m
Trace
Trace
Trace
1.1







64.2
2.8

As j^ ja Co Cr
ED E
E
D E
F E

CD C
D E
E

F

F E


E C
E C


F
D C C
E E

Cu
E
F
E
E
E
D
E
F

F

F


E
E

F

D
D

Mn_
D
E
D
E

D
B
E

F

F






F
D
F

Mp_ JM_
E D
F E
' D
C
E
E E
E







D
D



D E
F D
i ^on
Pb
E
E
E
F

D
E


F

F


E
E



A
E
item -——————«
Sb Sn JV Zn Hjf2
E D 0.1
F E 0.4
D 1.2
1.8
E 0.4
E E D 2.1
E E 0.4
_
E 0.4
F 0.5
0.1
E 0.2


-
m

i.e*<5)

D C
E C

'«?>
16
15
4.0
3.0
1.5
185
1.0
„
1.5
5.0
1.0
1.5


.
-






Organic
CA*' Cl Other
0.9
1.0
> 5 1750
0.4
0.2
3.4
0.1
.
0.1
0.2
0.1
0.1
210 Phenols «•
8.84$
-
-
VCM<*
35 ppm
0.4
0.1


Aery lie-Modacry lie    Wastewater Sludge
Polyester             Sludges
Polyester             Dust Collector Dust
Polyester             Floor Sweepings
(1)  file results are semi-quantitative except where noted otherwise, and are coded as follows, on an "as is" basis:
    A = >105 ppm }  B = 10*-10S ppm ; C ° 108-10* ppm ; D => 10^-103ppm ;  E * 10-100 ppm ;  F » 1-10 ppm ;  Blank =<1 ppm.
(2)  By atomic absorption in ppm.
(3)  This corresponds to a highly proprietary variant of the product/process and may not be typical of the more conventional processes.
(4)  From Butadiene drying columns.
(5)  Chemical Assay.
Source:   Foster D.  Snell,  Inc.'

-------
                                                                                                                     TABLE  B-2

                                                                                                        ANALYTICAL RESULTS OF WASTE SAMPLES
                                                                                                 OBTAINED FROM VARIOUS PLANTS IN SIC 30, RUBBER
                                                                                                                    PRODUCTS INDUSTRY
Main
Plant Product

Tire
Tire
Tire
Footwear
Footwear
Footwear

Reclaim
Reclaim
Hose
Belt
Belt
Hose
Misc. Rubber
Misc. Rubber
Misc. Rubber
Misc. Rubber
Misc. Rubber

Waste Description

Dust from collector
• Floor sweepings
Wet dust collector sludge
Warehouse sweepings #1
Warehouse sweepings #2
Compounding room
sweepings
Used NSW reclaim oil
Virgin NSW reclaim oil
Scrap yam
Skivings
Discard fiber
Scrap trim
Warehouse sweepings
Dust collectors
Reject stock
Flashings
Waste oils
Water
Soluble
(ft)
1.21
0.76
0.10
1.27
1.85
4.84

X
X
0.38
0.57
1.03
1.41
0.95
1.57
1.29
0.21
X
Water
Content
(ft)
.
-
NA
NA
NA
NA

90ft
Oft
NA
NA
NA
NA
NA
NA
NA
NA
Oft

Ash ft

57.1
96
10.4
57
68
53.2

3.7
.08
0.37
15.7
3.1
1.9
58.5
34.3
39.4
42.4
0.28

As B

E
E

E
E
E

E



E



E
E


Ba

D
D

C
C
C




E


C
C
C
C


Co

D

E
E
E
E







E
E
E
E


Cr

E
E

E
E
E

C





E
E
E
E


Cu

E
E

E
D
E

D


E


E
E
E
E


Mn

D
E

D
D
E

C



E

D
D
E
E

i content*
Mo Ni

D
D

E

E

E



E



E
E


Pb

D
D
E
D
D


C


E


D
D
D
D


Sb Sn

E
E

E
E
E







D
D
E
E


V Zn Hg*2)

E B
E C
C
E C
E C
B 0.5

0.5

C
C
C
D
1.0
0.7
B
B
D 0.1

Pb^ Co*2' Cl
(organic)





72 2.5 612

3.8 1.0 580





1.0 0.6 450
15 2.5


3.8 1.0
NA = Not Applicable    X - Not Performed
(1)  The results arc semi-quantitative except where no:
      A = >105 ppm ;  D = 104 - 10  ppm ;  C = 103 -
(2)  By atomic adsorption in ppm.
noted otherwise,  and are coded as follows, on an "as is" basis:
             D = 102 - 103 ppm ; E = 10-100 ppm ; Blank = < 10 ppm
  A
10  ppm
Source.-  Foster D. Snell, Inc.

-------
   APPENDIX C  — HAZARDOUS WASTE CONTRACTORS AND SERVICE
                       ORGANIZATIONS
      Table C-l, beginning on the following page, is a list of hazardous
waste contractors and service organizations available to the rubber and
plastics industry. The table provides the following information:

                 Name of organization

                 Address

                 Type of service provided.
                              C-l

-------
                                                                                                                                TABLE C-l
                                                                                                                                          (1)
                                                                                                                   IDENTIFIED HAZARDOUS WASTE CONTRACTORS
                                                                                                                              AND SERVICES OFFERED
 i
to
        Company
 REGION I
 The Crago Company, Inc.
 Safety Projects and Engineering, Inc.
 Silresim Chemical Corp.
 Motuvate Laboratories, Inc.
 Eastern Smelting and Refining

 REGION II
 Cheni Trol Pollution Services,  Inc.
 Chemical Waste Disposal Corp.
 Frontier Cltemical Waste Process, Inc.
 Pollution Abatement Services
 Recycling Laboratories
 Modem Transportation Co.
 Cltemical Control Corp.
 Astro Pak
 Mariscl lac.
 Scientific Inc.
 Rollins Environmental Services
'Scientific Chemical Processing, Inc.
 Chemical Waste Disposal, Inc.
• Cacss Environmental Services,  Inc.
 National Converters, Inc.

. REGION in
 Rollins Environmental Services
 American Recovery Corp.
 American Recovery Corp.
 Pottstown Disposal Service
 Siildn Metal Industries, Inc.
 die m-Line
 U.S. U«dlities Corp.
 Liquid V.a?u: Disposal of Virginia
                                              Address

                                       P.O.  Box 409, Gray. ME
                                       3 Maiden St. WestQuiney, MA
                                       86 Tanner St., Lowell, MA
                                       270 Talbot Ave., Dorchester, MA
                                       37 Bubier St., Lynn,  MA
1550 Balner Road, Model City, NY
4219 19th Ave., Astoria, NY
4626 Royal Ave.,  Niagara Falls. NY
East Seneca St. Oswego, NY
112 Harrison Place, Syracuse,  NY
75 Jacobs Ave., 'Kearny. NJ
23 South Front St., Elizabeth, NJ
1056 Route 1,  Edison. .NJ
125 Factory Lane, Middlesex, NJ
17 East Second St., Scotch Plains, NJ
Bridgeport, NJ
216 Patterson Plank Rd., Carlstadt, NJ
2550. Front St.,  Elizabeth, NJ
253 River Drive. Passaic, NJ
420 Chestnut St., Union, NJ
                                       One Rollins Plaza, Wilmington, DE
                                       2001 BenUll Ave., Baltimore. MD
                                       901 Recovery Road,  Baltimore, MD
                                       Route 20,  Sell Road,  Pottstown, PA
                                       P. O.  Box 708, Lewistown, PA
                                       P.O.  Box 545, Phoenixville. PA
                                       407 Mall Circle Dr., Monroeville, PA
                                       4822 Cnaniherlagnc Ave., Richmond,  X
                                         VA
CT
X
X
X
X
X
x •
X
X

X
X
X
X
X
X
X
X
X
X
X
X
X
X

X
X
X
NE BI


X
X
X
X X

X

X
X
X
x.
X
X
X
X
X

X
X X
X
J\ A

X
X
X X
PR OR FS FU AS CS IN
,

XX X
X
X
X X X X XX
X
XXX X
X
X X

X X



XXX X
X
X X


X X X X X
X X
x

X

X
LA


X
•

X
X
X



X
X
X
X
X
X
X
X
X
X
X
X
X

X
X
RR
X

X
X
X
X
X
X

X

X

X

X
X
X

X
X
X
X

X

X

-------
                                                                                                                              TABLE C-l    (2)
 I
eo
           Company
    REGION IV
    Liquid Waste Disposal,  Inc.^
    Nuclear Engineering Co., inc.
    Petioltte Cotp.
    Destructo-Chemway Coip.
    Wasteplex,  Inc.
    Browning-Ferris Industries
    Lanham Waste Control Inc.

    REGION V
                                        Address
                                  CT    NE
BI
Chem Met Services
Environmental Waste Control, Inc.
Liquid Disposal Company
Nelson Chemicals Co.
Prenco Manufacturing Co.
Pollution Controls Corp.
Erieway Pollution Control
Koski Construction Co.
Systems Technology Corp.
Hyon Waste Management Services
Nuclear Engineering Co., Inc.
Waste Management, Inc.
American Recovery Corp.  -
Conservation Chemical Company
Seymour
American Chemical Service
Approved Chemical Treatment
Ohio Liquid Disposal, Inc.
Chem-Line
Browning-Ferris of Ohio
Rodgers Laboratories
Waste Research and Reclaimatlon
   Company, Inc.
Chem Dyne Corp.
                                  P.O. Box 19063. Louisville, KY      X      X
                                  Box 7246, Louisville, KY            X
                                  CalvertCity, KY site                      X
                                  P. O. Box 667, Cason St., Belmont, NC  X      X
                                  P. O. Box 396, Jamesboro, TN       XX
                                  Georgia,  BFIslte                   XX
                                  Georgia,  BFI site                   X*      X
18550 Allen Road, Wyandotte. MI    X      X
26705 Michigan Ave.. Inkster, MI    X      X
3901 Hamblin Road, Utica, MI             X
12345 Schaefer Highway, Detroit. MI X     ' X
Stephenson Hwy, Madison Heights, Ml
1821 University Ave.,St. Paul.MN   X
33 Industry Drive, Bedford, OH       XX
5841 Woodman Ave., Ashtabula, OH  X      X
Baxter Road, Franklin, OH                 X
11700 Stony Island Ave.,Chicago,IL X      X
Ohio Nuclear Site
900 Jorie Blvd., Oak Brook,  IL      X      X
Riley Rd., East Chicago, IL          X
Box 6066, Gary,  IN                XX
500 North Broadway, Seymour, IN    X
P.O.  Box 190,  Griffith, IN         X
3755 Linden Ave., Grand Rapids, MI  X      X
504 Liberty Street,  Fremont,  OH     X      X
Box F, Lisbon, OH                  XX
1901 So.-Pine St.,  Warren,  OH     X      X
413 So. 6th St.,  Milwaukee, WI     X      X
Route 3, Eau Claire, WI            X      X

230 Northland Blvd.,Cincinnati,OH  X      X
                                                                                      X
                                                                                      X
PR

X

X
X
X
—Service to Industry*"—'
 OR     FS     FU    AS
                                                                                                                              cs
                                                                                            X
                                                                                            X
       X
       X
       X
       X
       X
       X
                                                                                                   X
                                                                                                   X
                    X

                    X
              X

              X
                                                                                               IN
                                                                                               X
                                                                                               X
                                                                                               X
                                                                                               X
                                               X
                                               X
                                               X
                                               X
                                               X
                                         X
                                         X
                                                                                                                                     X
                                                                                                                                     X
                                                                                                                                     X
                                   X

                                   X

                                   X
                                                      LA
                                                      X
                                                      X

                                                      X
                                                     • x
                                                                                                                                            X
                                                                                                                                            X
                                          X
                                          X
                                          X
                                          X

                                          X
                                          X
                                          X
                                          X
X
X
X
X
X
X
       RR

       X
       X
       X
       X
       X
       X
       X
                                                      X
                                                      X
X
X
X
X
X
X
X
X
X
X

-------
                                                                                                                                  TABLE C-l   (3)
O
 i
       Company

 REGION VI
 Rollins Environmental Services
 U.S. Pollution Control,  Inc.
 Dioecology Systems,  Inc.
 Browning-Ferris Inc.
 Malone Service Company
 Petroll te Corp.
• Sonic International
 Texas Ideologists, Inc.
 Texas liquid Disposal Co.
 Sheridan Disposal Service, Inc.

 REGION VII
 Conservation Chemical Co.
 Monsanto Corp.
 Findett Corporation
 Wheeling Disposal Services
 BF1 of Kansas City, Inc.

 REGION VIII
      Denvcit Clean-Up Services, Inc.

      REGION IX
      Casmalia Disposal Site
      Chancellor and Ogden. Inc.
      Environmental Protection Corp.
      Fresno County Dept, of Public Works
      Hollister Disposal Site
      Industrial Tank Co.
      County of I.os Angeles Site
      Palos Verdes Landfill
      Calahasa Landfill
      Oniar 'tenderlm*, Company
      •Richmond  !-";;r.itaiy Service
      Srx Pie/o OOUHY Site
                                               Address
                                         Baton Rouge, LA, Rollins Site
                                         5024 South Quaker, Tulsa OK
                                         4100 East Jefferson, Grand Prarie, TX
                                         300 Fannin Bank Bldg., Houston.TX
                                         P.O.  Box 709, Texas City,  TX
                                         Box 2546,  Houston, TX
                                         P. O.  Box 47088, Dallas,  TX
                                         Robston, TX
                                         511 West Texas, Midland, TX
                                         Box 42, llempsted,  TX
                                        215 W.  Perilling Rd., Kansas City. MO X
                                        800 North Lindbergh, St.  Louis, MO
                                        Elm Point Rd..  St. Charles, MO     X
                                        1805 So. 8th St., St. Joseph, MO    X
                                        Kansas City, MO, BFT Site          X
                                   3001 Walnut Street. Denver, CO
                                   P.O. Box 5275, Santa Barbara,  CA
                                   3031 East 1 Street, Wilmington, CA
                                   1801 Oak St.,  Baketsfield, CA
                                   4499 E. Kings Canyon Rd., Fresno CA
                                   Hollister. CA
                                   210 Berellesa St., Mardney,  CA
                                   1955 Workman Hill Rd., Whittier.CA
                                   P.O. Pox 1236,  Chula Vista, CA    X
                                   1224 Ncvin Rd., Richmond, CA      X
                                   5555 Overland Road, San Diego, CA
CT
X
X
X
X
X

X
X
X "

NE BI
X X
X
X X
X X
X
X X
X
X

X
— — — - service to ,
PR OR FS
X X
1
X X
XXX

X

X

X
inausny ———.——...
FU AS CS IN
X
X
X
X
X
X

X
X
X
LA
X
X
X
X
•x
X
X
X
X

RR
X
X
X
X
X
X

X
X
X
X

X
                                  X
                                  X
                                   X
                                   X
                                   X
                                   X
                                   X
                                   X
                                   X
                                   X
                                   X
                                   X
                                   X
                                  X
X

X

-------
                                                                                                                                 TABLE C-l   (4)
           Company

     REGION IX (continued)
     Ventura  Cty.Dept. of Public Works
     Nuclear Engineering Co., Inc.
     liquid Waste Management
     Roberts liquid Disposal

     REGION X
O
en
     Wes Con, Inc.
     Chemical Processors, Inc.
     Nuclear Engineering Co,,  Inc.
     Resource Recovery Corp.
     Western Processing Co., Inc.
       Address
597 East Main St., Ventura. CA
Box 156,  San Ramon, CA
9100 De Gormo, Sun Valley, CA
14708 Studebaker Rd., Norwalk.CA
245 Third Ave.  E., Twin Falls, ID
5501 Airponway, So.,Seattle, WA
Beatty, NV, Nuclear Engineering Site X
5501 Airponway, So., Seattle, WA
7215 South 196th St., Kent, WA     X
CT ME BI


X
X

X
X
X
PR OR BS FU AS CS IN LA
X
X
X
X
X
XXX
X
x x
• RR





X

X
     (1)  Abbreviation Code:
            CT     Collection and Transport
            ME     Neutralization
            BI      Biological
            PR     Precipitation
            OR     Oxidation-Reduction
            FS     Floculation- Sedimentation
              FU     Filtration
              AS     Ammonia Stripping
              CS     Carbon Sorptton
              IN     Incineration
              LA     Landfill
              RR     Resource Recovery
     Source!   Foster D. Snell, Inc.

-------
Appendix .D.    DETAILED DEFINITION OF THE PLASTICS AND RUBBER
               INDUSTRY —- SICs 282 AND 30
     Exhibits D-l through D-9 present a detailed definition
for each of the industry segments of SIC 282 and SIC 30.
                             D-l

-------
                                                          EXHIBIT  D-l(l)
                                                        DEFINITION OF SIC 2821
SIC 2821 PLASTICS MATERIALS. SYNTHETIC RESINS, AND NONVULCANIZABLE
          ELASTOMERS
       Establishments primarily engaged in manufacturing synthetic resins,
plastics materials, and nonvulcanizable elastomers.  Important products of
this industry include: cellulose plastic materials; phenolic and other tar
acid resins; urea and melamine resins;  vinyl resins;  styrene resins;  alkyd
resins;  acrylic resins; polyethylene resins;  polypropylene resins; rosin
modified resins;  coumarone-indene and petroleum polymer resins;  and  mis-
cellaneous resins including polyamide resins, silicones, polyisobutylenes,
polyesters, polycarbonate resins, acetal resins, fluorohydrocarbon resins;
and casein plastics.  Establishments primarily engaged in manufacturing
fabricated plastics products or plastics film,  sheet, rod, nontextile mono-
filaments and regenerated cellulose products, and vulcanized fiber are
classified in Industry 3079. whether from purchased resins or from resins
produced in the same plant.  Establishments  primarily engaged in compounding
purchased resins are also classified in Industry 3079.  Establishments primar-
ily manufacturing adhesives are classified in Industry 2891.
     Acetal resins
     Acetate, cellulose (plastics)
     Aciyllc resins
     Aery lonitrile-butadiene-sty rene resins
     Alcohol resins, polyvinyl
     Alkyd resins
     AUylrcshs
     Butadiene copolymers, containing less
       than 50<$ butadiene
     Carbohydrate plastics
     Casein plastics
     Cellulose nitrate resins
     Cellulose propionate (plastics)
     Coal tar resins
     Condensation plastics
     Coumarone-indene resins
     Cieiol-furfural resins
     Cresol rains
     Dlcyandiamlne resins
     Dlisocyanate resins
     Elastomers, nonvulcanizable (plastics)
     Epichlorohydrin bisphenol
     Epichlorobydrin diphenol
     Epoxy resins
Ester gum
Ethyl cellulose plastics
Ethylene- vinyl acetate resins
Fluorohydrocarbon resins
Ion exchange resins
lonomcr resins
Isobutylene polymers
Ugnin plastics
Melamine resins
Methyl acrylate resins
Methyl cellulose plastics
Methyl methacrylate resins
Molding compounds, plastics
Nitrocellulose plastics (pyroxylin)
Nylon resins
Petroleum polymer resins
Phenol-furfural resins
Phenolic resins
Pbenoxy resins
phthalic alkyd resins
Phtbalic anhydride resins
Polyacrylonitrilc resins
Polyamide resins
Polycarbonate resins
                                    D-2

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                                                                            EXHIBIT D-l(2)
      Polyesters
      Polyethylene resins
      Polyhexamethylenediarnine adipamide reMns
      Polylsobuiylenes
      Polymerization plastics, except fibers
      Polypropylene  resins
      Polystyrene resins
      Polyurethane resins
      Polyvinyl chloride resins
      Polyvinyl halide resins
      Polyvinyl resins
      Protein plastics
      Pyroxylin
      Resins, phenolic
      Resins, synthetic: coal tar and non-coal ur
      Rosin modified resins
      Silicone fluid solution (fluid for sonar transducers)
      Silicone resins
      Soybean plastics
      Styrene resins
      Styrene-acrylonltrile resins
      Tar acid resins
      Urea resins
      Vinyl resins
Source:       1972 Standard Industrial Classification Manual
                                          D-3

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                                                               EXHIBIT  D-2
                                                         DEFINITION OF  SIC 2822
SIC 2822  SYNTHETIC RUBBER (VULCANIZABLE ELASTOMERS)
       Establishments primarily engaged in manufacturing synthetic rubber
by polymerization or copolymerization. An elastomer for the purpose of this
classification is a rubber-like material capable of vulcanization,  such as
copolymers of butadiene and styrene, or butadiene and acrylonitrils, poly-
butadienes , chloroprene rubbers, and isobutylene-isoprene copolymers.
Butadiene copolymers containing less than 50% butadiene are classified in
Industry 2821. Natural chlorinated rubbers and cyclized rubbers are con-
sidered as semifinished products and are classified in Industry 3069.
      Aciylate type rubbers
      Acrylate-butadiene robbers
      Acrylic rubbers
      Adiprene
      Butadiene-aerylonltrlle copolymers
        (over 50% butadiene)
      Butadiene rubbers
      Butadiene-stymie copolymers
       (over SQfy butadiene)
      Butyl rubber
      Chlorinated rubbers, synthetic
      Chloroprene type rubbers
      Chloroculfonated polyethylenes
      Cyclo rubbers, synthetic
      EPDM polymers
      Elastomers, vulcanizable
        (synthetic rubber)
      Epichlotohydrin elastomers
      Estane
      Ethylene-propylenc rubbers
      Fluoro rubbers
      Fluorocarbon derivative rubbers
      Hypalon
      Isobutylene-isoprene rubbers
      Isocyanate type rubber
                            Isoprene rubbers, synthetic
                            Neoprene
                            Nitrile-butadiene rubbers
                            Nltrile-chloroprene rubbers
                            Nitrile type rubber
                            N-type rubber
                            Polybutadienes
                            Polyethylenes,  cblorosulfonated
                            Polyisobutylene-isoprene elastomers
                            Poryisbbutylene (synthetic rubber)
                            Polymethylene rubbers
                            Polysulfides
                            Pyddlne-butadiene copolymers
                            Pyridine- butadiene rubbers
                            Rubber synthetic
                            Sllicone rubbers
                            S-type rubber
                            Stereo regular elastomers
                            Styrene-butadlene rubbers
                              (50
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                                                                EXHIBIT  D-3
                                                         DEFINITION OF SIC 2823
SIC 2823  CELLULOSIC MAN-MADE FIBERS
       Establishments primarily engaged in manufacturing cellulosic fibers
(including cellulose acetate and regenerated cellulose such as rayon by the
Viscose or cuprammonium process)  in the form of monofilament, yarn, staple
or tow suitable for further manufacturing on spindles, looms,  knitting machines
or other textile processing equipment.  Establishments primarily engaged in
manufacturing textile glass fibers are classified in Industry 3229.
     Acetate fibers
     Cellulose acetate monofilamem. yam,
       staple, or tow
     Cellulose fibers, man-made
     Cigarette tow, cellulosic fiber
     Cuprammonium fibers
     Fibers, cellulose man-made
     Fibers, rayon
     Horsehair, ardclficial;  rayon
     Nitrocellulose fibers
                           Rayon primary products: fibers, straw,
                             strips, and yam
                           Rayon yar, made in chemical plants
                             (primary products)
                           Regenerated cellulose fibers
                           Triacetate fibers
                           Viscose fibers, bands, strips, and yarn
                           Yam, cellulosic: made in chemical
                             plants (primary products)
Source:
1972 Standard Industrial Classification Manual
                                      D-5

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                                                              EXHIBIT D-4
                                                           DEFINITION OF SIC 2824
   SIC 2824  SYNTHETIC ORGANIC FIBERS. EXCEPT CELLULOSIC
         Establishments primarily engaged in manufacturing synthetic organic
   fibers. except cellulosic (including those of regenerated proteins, and of
   polymers or copolymers of such components as vinyl chloride, vinylidene
   chloride, linear esters. vinyl alcohols, acrylonitrile, ethylenes,  amides,
   and related polymeric materials)in the form of monofilaraent. yarn, staple
   or tow suitable for further manufacturing on spindles, looms, knitting machines
   or other textile processing equipment.  Establishments primarily engaged in
   manufacturing textile glass fibers are classified in Industry 3229.
        Acrylic fibers
        Aciylonitdle fibers
        Arddex fibers
        Casein fibers
        Elastoinedc fibers
        Fibers, man-made: except cellulosic
        Fluorocarbon fibers
        Horsehair, artificial: nylon
        linear esters fibers
        Modacrylic fibers
        Nylon fibers and bristles
        Olefin fibers
        Organic fibers, synthetic: except
          cellulosic
Polyester fibers
Polyvinyl ester fibers
Polyvinylidene chloride fibers
Protein fibers
Saran fibers
Soybean fibers ( man-made textile
  materials)
Vinyl fibers
Vinylidene chloride fibers
Yam. organic man-made fiber
  except cellulosic
Zein fibers
Source:  Tne 1972  Standard Industrial Classification Manual.
                                        D-€

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                                                     EXHIBIT D-5
                                                 DEFINITION OF SIC 3011
SIC 3011  TIRES AND INNER TUBES
      Establishments primarily engaged in manufacturing pneumatic casings,
inner tubes, and solid and cusion tires for all types of vehicles, airplanes,
farm equipment, and children's vehicles; tiring; and camelback, and tire
repair and retreading materials.  Establishments primarily engaged in
retreading tires are classified in Industry 7534.
       Camelback for tire retreading            Tires, cushion or solid rubber
       Inner tubes; airplane, automobile,         Tiring, continuous lengths:  rubber,
         bicycle, motorcycle, and tractor         with or without metal core
       Pneumatic casings (rubber tires)
       Tire sundries and tire repair materials.
         rubber
Source:  1972 Standard Industrial Classification Manual
                                 D-7

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                                                          EXHIBIT  D-6
                                                     DEFINITION OF SIC 3021
SIC  3021  RUBBER AND PLASTICS  FOOTWEAR
        Establishments primarily  engaged in manufacturing all rubber and
plastics footwear,  waterproof fabric upper footwear,  and  other fabric upper
footwear having  rubber or plastic soles vulcanized to the  uppers.   Establish-
ments primarily  engaged in manufacturing rubber, composition, and fiber
heels,  soles,  soling strips, and related shoemaking and repairing  materials
are classified in Industry 3069;  plastic  soles  and  soling strips in Industry 3079.
     Arctics, rubber or rubber soled fabric
     Boots, plastics
     Boots, rubber or rubber soled fabric
     Canvas shoes, rubber soled
     Footholds, rubber
     Footwear, rubber or rubber soled fabric
     Gaiters, rubber or rubber soled fabric
     Galoshes, plastics
     Galoshes, rubber or rubber soled fabric
     Overshoes, plastics
                                Overshoes, rubber or rubber soled fabric
                                Pacs: rubber or rubber soled fabric
                                Sandals, rubber
                                Shoes, plastics soles molded to fabric uppers
                                Shoes, rubber or rubber soled fabric uppers
                                Shower sandals or slippers, rubber
Source:
1972 Standard Industrial Classification Manual
                                     D-8

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                                                EXHIBIT D-7
                                       DEFINITION OF THE RECLAIMED
                                         RUBBER INDUSTRY SIC 3031
SIC 3031 RECLAIMED RUBBER
      Establishments primarily engaged in reclaiming rubber from scrap
rubber tires. tubes, and miscellaneous waste rubber articles by processes
which result in devulcanized, depolymerized or regenerated replasticized
products containing added ingredients.  These products are sold for use as
a raw material in the manufacture of rubber goods with or without admixture
with crude rubber or synthetic rubber.  Establishments primarily engaged
in the assembly and wholesale sale of scrap rubber are classified in trade
industries.
                     i
     Reclaimed rubber (reworked by
      manufacturing processes)
Source:
1972 Standard Industrial Classification Manual
                                D-9

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                                                        EXHIBIT  D-8
                                                   DEFINITION OF THE RUBBER
                                                   AND PLASTICS HOSE AND
                                                   BELTING INDUSTRY ,  SIC 3041
       SIC 3041 RUBBER AND PLASTICS HOSE AND BELTING
       Establishments primarily engaged in manufacturing rubber and
plastics hose and belting, including garden hose.  Establishments pri-
marily engaged in manufacturing rubber tubing are classified in
Industry 3069;  plastic tubing in Industry 3079; and flexible metallic
hose in Industry 3599.
         Air brake and air line hate, rubber or       Heater hose, plastics
           rubberized fabric                     Heater hose, rubber
         Automobile hose, plastics               Hose:  cotton fabric, rubber lined
         Automobile hose, rubber                Pneumatic hose:  air brake, air line.
         Belting: conveyor, elevator, trans-         etc. - rubber or rubberized fabric
           mission, etc. - rubber                 Vacuum cleaner hose,  plastic
         Fire hose, rubber                      Vacuum cleaner hose,  rubber
         Garden hose, plastics                   V-belts, rubber or plastic
         Garden hose, rubber
Source:   1972 Standard Industrial Classification Manual
                                   D-10

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                                                           EXHIBIT D-9(l)
                                                      DEFINITION OF SIC 3069
SIC 3069  FABRICATED RUBBER PRODUCTS, NOT ELSEWHERE CLASSIFIED
       Establishments primarily engaged in manufacturing industrial and
mechanical rubber goods, rubberized fabrics and vulcanized rubber  clothing
and miscellaneous rubber specialties  and sundries.   Establishments  primarily
engaged in rebuilding and retreading tires are classified in Industry 7534;
and gaskets and packing in Industry  3293.
     Acid bottles,  rubber
     Air supported rubber structures
     Aprons, vulcanized rubber and
       rubberized fabric; mitse
     Dags, rubber or rubberized fabric
     Balloons,  advertising and toy: rubber
     Balloons,  metal foil laminated
       with rubber
     Balls,  rubber:  except baseballs, basket-
       balls,  footballs, golf and tennis
     Bath sprays, rubber
     Bathing caps and suits, rubber
     Battery boxes, jars,  and parts:
       hard rubber
     Bibs, vulcanized rubber and rubberized
       fabric:  mitse
     Bottles, rubber
     Boxes, hard rubber
     Brake lining, rubber
     Brushes,  rubber
     Bulbs for medicine droppers, syringes.
       atomizers, sprays:  rubber
     Bushings,  rubber
     Capes, vulcanized rubber and
       rubberized fabric:  mitse
     Caps,  rubber
     Castings,  rubber
     Chlorinated rubbers, natural^
     Cloaks, vulcanized rubber and
       • rubberized fabric: mitse
     Clothing,  vulcanized rubber and
       rubberized fabric: mitse
     Combs, hard rubber
 Culture cups, rubber
 Cycle rubbers, natural
 Dress shields, vulcanized rubber and
   rubberized fabric:  mitse
Druggists' sundries, rubber
 Erasers: rubber or rubber and
   abrasive combined
 Fabrics, rubberized
 Finger cots,  rubber
 Flooring, rubber: tile or sheet
 Foam rubber
 Fountain syringes, rubber
 Friction tape, rubber
 Fuel tanks, collapsible:  rubberized
   fabric
 Funnels, rubber
 Gloves: surgeons', electricians',
   household, etc. —  rubber
 Grips and handles, rubber
 Grommets, rubber
 Gutta percha compounds
 Hair curlers, rubber
 Hairpins,  rubber
 Handles, rubber
 Hard rubber products
 Hard surface floor coverings: rubber
 Heels, boot and shoe: rubber,
   composition, and fiber
 Jar rings,  rubber
 Laboratory sundries:  cases,  covers,
   funnels, cups, bottles, etc. — rubber
 Latex, foamed
 Life jackets:  inflatable,  rubberized fabric
                                      D-ll

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                                                                   EXHIBIT D-9(2)
        Life rafts,  robber
        Liner strips, rubber
        Mallets, rubber
        Mats and matting  bath, door. etc. -
          rubber
        Mattress protectors, rubber
        Mattresses, pneumatic:  fabric coated
          with rubber
        Medical sundries, rubber
        Mittens, rubber
        Molded rubber products
        Mouthpieces  for pipes, cigarette
          holders, etc. - rubber
        Nipples, rubber
        Orthopedic sundries, molded  rubber
        Pacifiers,  rubber
        Pads, kneeling  rubber
        Pants, baby:  vulcanized rubber and
          rubberized fabric - mitse
        Pillows, sponge rubber
        Pipestems and bits,  tobacco:  hard
          rubber
        Platens, except printers   solid or covered
          rubber
        Plumbers  rubber goods
        Pontoons, rubber
        Pump sleeves,  rubber
        Rods, hard rubber
        Rolls, except printers':  solid  or
          covered rubber
        Rubber bands
        Rubber covered motor mounting rings
          (rubber  bonded)
        Rubber heels, soles,  and soling strips
  Rug backing compounds,  latex
  Separators, battery:  rubber
  Sheeting, rubber or rubberized fabric
  Sheets, hard rubber
  Sleeves, pump:  rubber
  Soles, boot and shoe  rubber  composition
    and fiber
  Soling strips,  boot and shoe  hibbcr.
    composition, aifS'Jfaer
  Spatulas, rubber
  Sponge rubber and sponge rubber products
  Stair  treads, rubber
  Stationers' sundries^  rubber
  Stoppers, rubber
  Teething rings, rubber
  Thermometer cases,  rubber
  Thread, rubber-  except fabric covered
  Tile, rubber
- Top lift sheets, rubber
  Top roll covering, for textile n-.ill
    machinery  rubber
  Toys,  rubber
  Trays, rubber
  Tubing, rubber
  Type, rubber
  Urinals, rubber
  Valves,  hard rubber
  Wainscoting, rubber
  Washers, rubber
  Water bottles, rubber
  Weather strip, sponge rubber
  Wet suits, rubber
Source:  1972 Standard Industrial Classification Manual
                                                                             yol691
                                                                             SW-163C.4
                                         D-12

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