TOXICS USE AND HAZARDOUS WASTE
   GENERATION PRACTICES IN OREGON
               January 7, 1991
                Submitted to:

The Oregon Department of Environmental Quality
      Hazardous and Solid Waste Division
             811 SW 6th Avenue
            Portland, Oregon 97204

                     and

     U.S. Environmental Protection Agency
                  Region X
              1200 Sixth Avenue
          Seattle, Washington 98101
                Submitted by:

  Science Applications International Corporation
             8400 Westpark Drive
            McLean, Virginia 22102
   EPA Contract No. 68-WO-0025, WA No. 8
       SAIC Project No. 1-824-03-328-00

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                             TABLE OF CONTENTS

Section                                                                  Page

Executive Summary	  E-l


1.      Introduction	  1-1

       1.1   Overview of Statute and Regulation	  1-1
       1.2   Objectives of the Report	  1-3


2.      Methodology and Data Limitations 	  2-1

       2.1   Identification and Characterization of the Toxics User and
            Hazardous Waste Generator Universe in Oregon	  2-6
       2.2   Characterization of Types and Quantities of Toxic
            Substances Used and Released and Hazardous
            Wastes Generated	  2-7
       2.3   Identification of Future Growth Industries that Use Toxic
            Substances or Generate  Hazardous Wastes	  2-9

3.      Summary of Findings  	  3-1

       3.1   Identification and Characterization of the Toxics User and
            Generator Universe  	  3-1
       3.2   Types and Quantities of Toxic Substances Used and
            Released to the Environment  	  3-5
       3.3   Types and Quantities of RCRA Hazardous Wastes Generated .  .  3-26
       3.4   Characterization of Business Activities of Generators and
            Toxics Users	  3-31
       3.5   Summary of Findings	  3-35

4.      Identification of Data  Gaps and Suggestions for Collecting Better Data  4-1

       4.1   Summary of Existing Data Gaps  	  4-1
       4.2   Suggestions for Improving Existing Reporting Mechanisms  ....  4-8

Appendix A   	  A-l

       Table 1: Number of Oregon Generators that Manifest (Transport)
            Hazardous Wastes Off-Site by Industry Group  	  A-l

       Table 2: Quantity of Hazardous Generated by Industry Group  	  A-4

       Table 3: Quantity of Hazardous Generated and Manifested
       (Transported) Off-Site by RCRA Waste Code 	  A-8

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                TABLE OF CONTENTS (Continued)
Table 4: Quantity of Toxic Substances Released to Each
Medium by Industry Group	  A-10

Table 5: Composition of Releases by Industry Code  	  A-11
                               11

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                               LIST OF EXHIBITS

Exhibit                                                                   Page

E-l    The Universe of Oregon Large Toxics Users  	   E-5

E-2    Number of Oregon Toxics Users by Type of Toxics User
       and SIC Code	   E-6

E-3    Quantity of SARA 313 Toxic Substances Released and
       Hazardous Wastes Generated by Oregon Toxics Users by
       Type of Toxics User and SIC Code  	   E-9

2-1    Existing Information Sources and Data Gaps 	   2-3

2-2    Description of Analyses and Types of Data Sources Used	   2-5

3-1    Universe of Oregon Toxics Users   	   3-2

3-2    Number of Hazardous Waste Generators that Transport Waste
       Offsite by SIC Code  	   3-4

3-3    Number of Large Toxics Users by SIC Code  	   3-4

3-4    Distribution of Oregon Toxics Users and Hazardous Waste
       Generators by Region  	   3-6

3-5    Frequency of Use by SIC Code	   3-8

3-6    Classification of Toxic Substances  in 1988 Oregon TRIS Report	3-11

3-7    Ranking of Toxic Substances by Increasing Toxicity and
       Carcinogenicity	   3-14

3-8    Quantity of Chemicals Released by Type of Medium   	   3-17

3-9    Cumulative Distribution of Releases by the Quantity Released
       per Facility	   3-19

3-10a-f Releases to Media by Chemical   	   3-20

3-lla  Releases by Industry  Group: Disposition in  Millions of Pounds	   3-24

3-1 Ib  Releases by Industry  Group: Composition in Millions of Pounds  ....   3-25

3-12   Quantity of Hazardous Waste Generated and Transported
       Off-Site by SIC Code	   3-27
                                       in

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                        LIST OF EXHIBITS (Continued)

Exhibit                                                                Page

3-13    Quantity of Hazardous Waste Generated and Transported Off-Site
       by RCRA Waste Code 	  3-30

3-14    Oregon: Total Average Employment in 1988 by SIC Code	  3-32

3-15a   Oregon Manufacturing Employment 1987-1995 by SIC Code	  3-33

3-15b   Oregon Nonmanufacturing Employment 1987-1995 by SIC Code  ....  3-34

4-1     Examples of Estimating Quantities of Releases/Wastes Reduced  ....  4-6
                                      IV

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    STANDARD INDUSTRIAL CLASSIFICATION (SIC)
                CODE TRANSLATIONS

Please note that a number of the analyses in this report have
been presented by SIC Code.  This table serves as a
reference for looking up the translations to the SIC Codes
presented in this report.
SIC Code         Name of Industrial Group

 20              Food and Kindred Products
 22              Textile Mill Products
 24              Lumber and Wood Products
 25              Furniture and Futures
 26              Paper and Allied Products
 27              Printing and Publishing
 28              Chemicals and Allied Products
 29              Petroleum and Related Products
 30              Rubber and  Miscellaneous  Plastic Products
 31              Leather and Leather Products
 32              Stone, Clay,  and Glass Products
 33              Primary Metal Industries
 34              Fabricated Metal Products
 35              Machinery Except Electrical
 36              Electronic and Other Equipment
 37              Transportation Equipment
 38              Instruments and Related Products
 39              Miscellaneous Manufacturing Industries
 40              Railroad Transportation
 42              Trucking and Warehousing
 48              Communication
 49              Electric,  Gas, and Sanitary  Services
 50              Durable  Goods
 51              Nondurable Goods
 55              Auto Dealers and Service Stations
 75              Auto Repair, Services, and  Garages
 95              Administration for Environmental Quality

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                              EXECUTIVE SUMMARY


      The Oregon Legislative Assembly passed the Toxics Use  Reduction and

Hazardous Waste Reduction Act, which was signed into law on July 24,  1989.  The act
mandates toxics users (i.e., companies that use SARA1 313 toxic substances and/or

generate hazardous wastes) to develop toxics use and hazardous waste reduction plans

and to set performance goals.  The act defines toxics  use reduction as
       "in-plant changes in production or other processes or operations, products or
       raw materials that reduce, avoid, or eliminate the use or production of toxic
       substances without creating substantial new risks to public health, safety, ami
       the environment..."
and it defines hazardous waste reduction as
       "any recycling or other activity applied after hazardous waste is generated that
       is consistent with the general goal of reducing present and future threats to
       public health, safety and the environment and that results in:  (A) the
       reduction of total volume or quantity of hazardous waste generated that
       otherwise should be treated, stored, or disposed of; (B) the reduction of
       toxicity of hazardous waste that would otherwise be treated, stored, or disposed
       of; or (C) both the reduction of total volume or quantity and the reduction of
       toxicity of hazardous waste...."
       The law also requires the Department of Environmental Quality (DEQ) to
provide toxics users and generators with technical assistance and to submit two reports
to the legislature on the progress being made toward toxics use and hazardous waste
reduction, the status of technical assistance programs, and an analysis and
recommendation for program changes. The first of these reports must be submitted to
the legislature by January 1, 1991.
  SARA stands for the Superfund Amendments and Reauthorizatlon Act.

                                         E-l

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      In preparing the first report to the legislature, the DEQ has identified that one of
the objectives -- reporting on the progress made toward toxics use and hazardous waste
reduction - cannot be carried out using the existing information sources. Instead,  the
DEQ has decided to include in the first legislative report a characterization of Oregon
toxics users, which includes three groups -• large toxics users, large quantity generators,
and small quantity generators -- and a discussion of the existing data gaps that prevent
the measuring progress made toward toxics use and hazardous waste reduction.  This
characterization also may form a basis for targeting technical assistance efforts.

      This report has been prepared to characterize toxics users and hazardous waste
generators and to identify data gaps. This report is divided into four sections:
             Section 1 provides the background to this report, including a
             discussion of the Toxics Use Reduction and Hazardous Waste
             Reduction Act and associated regulations.
             Section 2 provides a detailed discussion of the data sources used for
             the analysis and the associated limitations in using the data.
             Section 3 presents the analyses of the data and major findings.
             Section 4 identifies data gaps that prevent full characterization of
             toxics users  and hazardous waste generation practices and presents
             suggestions  for modifying  existing reporting mechanisms to collect
             more appropriate data.
      A number of data sources were used to identify the potential universe of toxics
users as well as to characterize toxics usage and waste generation patterns. The data
sources  include the 1988 Toxics Release Inventory System (TRIS), the  1988 DEQ
Quarterly Reports,  and 1990 and projected business activity data from the Oregon
Executive Department. In presenting the results,  this  report takes a three-step  approach,
which can be summarized as follows:
                                        E-2

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       1.     Identification and characterization of the universe of large toxics
             users and hazardous waste generators.
                                   \
             2.     Characterization of the types of toxics substances used and
                   an estimation of the quantities of toxic substances released
                   and hazardous wastes generated.
                                            X
                   3.     Identification of future growth industries that use
                         toxic substances or generate hazardous wastes.
SUMMARY OF FINDINGS


1-     Identification of the universe of large toxics users and hazardous waste
      generators.


      The final rules promulgated by the DEQ requires the following three groups of

toxics users to complete toxics use and hazardous waste reduction plans and to complete
annual progress reports:
             Large toxics users, which are companies that meet SARA 313
             reporting requirements by using more than 10,000 pounds of a
             SARA 313 toxic substance in one year or manufacture/process
             more than 25,000 pounds of a SARA 313 toxic substance in one
             year.

             Large quantity generators (LQGs), which are companies  that
             generate in any calendar month more than 2,200 pounds of a
             Resource Conservation and Recovery Act  (RCRA)-regulated or
             State-regulated hazardous waste, more than 2.2 pounds of an acute
             hazardous waste [as specified in 40 CFR, § 251.5 (e)(l)] or more
             than 220 pounds of acute hazardous  spill debris [as specified in 40
             CFR § 261.5 (e)(2)].
                                       E-3

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             Small quantity generators (SQGs), which are companies that (1)
             generate in every calendar month more than 220 pounds but less
             than 2,200 pounds of RCRA-regulated or State regulated hazardous
             waste.
       Data were available for only a subset of large toxics users (those that use more
than 10,000 pounds or manufacture/process more than 50,000 pounds of a SARA 313
toxic substance) and for only those LQGs and SQGs that use manifests to transport
hazardous waste offsite (see Exhibit E-l).  Based on the data, an estimated 928
companies, at a minimum, will be required to complete these plans and submit progress
reports, while a subset -- the large toxics users, the LQGs, and an unknown percentage
of SQGs -- will be  required to set performance goals for reducing toxics substance use
and/or hazardous waste generation.  The 928 companies can be divided  into 207 large
toxics users, and 805 hazardous waste generators, with 84 companies that overlap
between the two groups.  Of the 805 hazardous waste generators,  120 companies are
LQG's and 685 companies  are SQGs.  Forty  percent (49) of the LQGs and 5 percent
(35) of the SQGs comprise the 84 companies that are both hazardous waste generators
and large toxics users.2  Geographically, over 90 percent of the large toxics users and
hazardous waste generators are located in the western half of the  State, concentrated
primarily in the Portland area.

       When presenting the characterization data, the 928 toxics users are grouped into
two categories:  207 large toxics users and  805 hazardous waste generators, realizing  that
84  companies straddle between these two  groups. In examining the distribution of
companies among industry  groups, the data show (see Exhibit E-2) that
             Of 207 large toxics users, over 85 percent are represented in nine
             industry groups:  lumber and wood products (36 companies),
             chemicals and allied products (30 companies), fabricated metal
             products (27 companies), primary metals (19 companies), electronic
             and electrical (17 companies),  food and kindred products (14
             companies), paper and allied products (13 companies), rubber and
             miscellaneous products (12 companies), and transportation
             equipment (11 companies).
   An unknown percentage of the SQGs also include conditionally exempt generators (CEOs) [I.e.. generators that generate less than 220 pounds of
Hazardous waste In every month ot the calendar year.] Due to the format of the DEO Quarterly Reports from which the data was extracted, it is not
possible to identify the exact number of CEQs included in the count of SQGs. Because CEGs are not required is comply with DEO Quarterly Reporting
processing, the OEQ believes the CEQs as a percentage of SQGs Is small.

                                         E-4

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                                                            Exhibit E-1
                                       The Universe of Oregon Toxics Users
                   49 companies that are large
                   toxics users and LQGs   ••-..
                   Data is available for only those
                   LQGs and SQGs that generate and
                   manifest hazardous waste off site
                                                                      Data is available for only those large toxics users that use more
                                                                   ..-  than 10,000 pounds of a listed SARA 313 substance or
                                                                      manufacture/ process more than 50,000 pounds of SARA 313
                                                                      substance during a year
                                                                                            \   35 companies that large toxics users
                                                                                                'and SQGs
Universe
   of
 Toxics
  Users
Large Toxics Users = Companies that use greater than 10,000 pounds per year of a SARA 313 toxic substance or manufacture/process
                  more than 25,000 pounds of a SARA 313 substance per year
Large Quantity Generators (LOG) = Companies that generate in one or more months during a year more than 2,200 pounds
                              of RCRA-regulated or State-regulated hazardous waste, more than 2.2 pounds of acute hazardous waste,
                              or more than 220 pounds of acute hazardous spill debris.
Small Quantity Generators (SQG) = Companies that generate in every single month during a year between 220 and 2,200 pounds of RCRA-
                              regulated or State-regulated hazardous waste.
                              (||p  Shaded area represents those companies for which characterization and release data is available
                              Source of data: 1988 Toxic Release Inventory System Reports and 1988 DEQ Quarterly Reports

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                                                   Exhibit E-2
  120
  100
M  80
                                     Number of Oregon Toxics Users
                                  by Type of Toxics User and SIC Code
Q.
o
   60
0)
£1
I
Z  40
   20
       20  22  24  25  26  27  28  29  30  31   32   33  34  35  36  37  38  39  40  42  48  49  50  51   55  75   95
                                • Large Toxics
Users
Hazardous Waste Generators
     N/A = SARA 313 does not require facilities in these industries to report
     Source: 1988 Toxic Release Inventory System Reports
           1988 DEQ Quarterly Reports

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             The 805 LQGs and SQGs that manifest and transport waste offsite
             are concentrated in five industry groups:  auto dealers and gasoline
             service stations (106 companies),  motor freight transportation  and
             warehousing (65 companies), lumber and  wood products (43
             companies), fabricated metals (41 companies), electrical and
             electronic (41  companies), and automotive repair (38 companies).
2.     Characterization of types of toxic substances used and an estimation of the
      quantities of toxic substances  released and hazardous wastes generated.

      In 1988, Oregon's large toxics users processed, manufactured, or used over 87
different SARA 313 toxic substances.3  The three most frequently used toxic substances
by large toxics users were sulfuric acid, acetone, and toluene.  Other frequently used
chemicals include ammonia, chlorine, formaldehyde, hydrochloric  acid, methanol,  methyl
ethyl ketone, xylene, and  1,1,1-trichloroethane.

      TRIS, which is the source of  data on frequency of SARA 313 toxic substance use,
does not provide data on  the quantities of these substances used  by companies. This
information is considered key for analyzing toxics use patterns in Oregon and is one of
the data gaps addressed in this report.  Though not a good indicator of quantities used,
TRIS does provide data on the quantities of toxic substances released to  the
environment from manufacturing, processing, or using  toxic substances.

      Of the 207 large toxics users,  197 companies reported releasing over 45-million
pounds of SARA 313 toxic substances  directly into the environment (i.e.,  land, air, or
water) or to other offsite  locations with nearly 50 percent of the releases  going into the
air. The data show that a variety of toxic substances are released to the  air, either
through stack or nonpoint (fugitive)  emissions. Toxic substances  that comprise the
major releases to the air include aluminum oxide, toluene, acetone, styrene, methanol,
and chlorine.  In contrast, a few toxic substances dominate releases to land, water,
publicly owned treatment works (POTW), and other off-site destinations.
  "SARA 313 toxic substances" and "toxic substances" are used interchangeably throughout this report.
                                        E-7

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      As an example, aluminum oxide comprises over 50 percent of the toxic substances
released  to land while methanol is the most dominant toxic substance released to
POTWs,  comprising over 75 percent of the total quantity of toxic substances released.

      In comparison  to the 45-million pounds released by large toxics users,  LQGs and
SQGs generated and  manifested a total of 82-million pounds of hazardous waste offsite
during 1988.  These generators transport various types  of federally and State-regulated
hazardous wastes offsite.  K wastes (wastes generated from specific sources) account for
the largest quantity of hazardous waste generated, all of which are generated (13,700
tons or 27.4-million pounds) by the primary  metal industry.  The next largest group of
wastes are the D wastes (wastes that exhibit one of the four hazardous waste
characteristics), followed by X wastes, which are State-regulated wastes.

      The data also show that for some industries an inverse relationship exists between
the number of companies in an industry group and the quantity  of toxic substances
released  or hazardous wastes generated.  In other words, certain industry groups contain
a large number of facilities that release relatively small quantities of toxic substances or
likewise  generate relatively little hazardous waste. In contrast, there are other industries
that contain few facilities which release and/or generate large quantities of toxic
substances or hazardous wastes (see Exhibit E-3).  For example, industries such as the
auto dealers  and service stations (SIC 55), motor freight transportation and warehousing
(SIC 42), the automotive repair (SIC 75), and the lumber and wood products (SIC 24)
industries are each represented by a large number of generators but generate relatively
little hazardous waste. The largest quantities of hazardous wastes are generated by
primary metals (SIC 33), transportation equipment (SIC 37), instruments and related
products  (SIC 38), and electronic and electrical equipment (SIC 36) industries.

      Similarly, certain industries contain a relatively large number of large toxics users
but release relatively  small quantities of SARA 313 toxic substances to the environment.
Lumber  and  wood products (SIC 24), chemical and allied products (SIC 28),  and
fabricated metal products (SIC 34) industries are comprised of a large number of toxics
                                        E-8

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                                              Exhibit E-3

                        Quantity of SARA 313 Toxic Substances Released and
                        Hazardous Wastes Generated by Oregon Toxics Users
                                 by Type of Toxics User and SIC Code
    40
    30
ra
QC.Q
  •
to

a
    10
         20  22  24  25  26   27  28  29  30  31  32  33  34  35  36  37  38  39  42  48  49   50  51  55  75  95
                                        SARA 313 Toxic Substances
        N/A = SARA 313 does not require facilities in these industries to report

        Source: 1988 Toxic Release Inventory System Reports
             7988 DEO Quarterly Reports
                                                                  Hazardous Wastes

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users (greater than 25 companies) but release a relatively small quantity of toxic
substances to the environment. The major releasers of SARA 313 toxic substances are
the pulp and paper industry and the primary  metals industry. Because no data exist on
the quantities of toxic substances used, it is not known to what degree an inverse
relationship exists between the number of companies and quantities of toxic substances
used in these industry groups.
3,     Identification of future growth industries that use toxic substances or generate
       hazardous wastes.
       Projections into 1995 show that the majority of manufacturing industries (SIC
Codes 20 to 39) are expected to remain fairly stable.  The only manufacturing industries
expected to show any high growth are the machinery products (SIC 35) and electronics
and electrical products (SIC 36) industries.  These industries are shown to be users of
toxic substances or generators of hazardous  waste, and therefore, increases are expected
in the  quantities of toxic substances released or hazardous wastes generated if no
reduction techniques or procedures are implemented.

       The Oregon Executive Department projects, however, high growth for certain
nonmanufacturing industry sectors (all other SIC Codes).  Specifically, economic growth
is projected for the trade industry (SIC 50-58), the services industry (SIC 70-89), and the
transportation and communication industry (SIC 40-49).  It is not known  to what degree
businesses in these industry groups will contribute to toxics use and releases in the
future.  Businesses in the trade and service  industries are -not required to supply data on
SARA 313 toxic substance uses and releases. Businesses  in the transportation and
communications industries are required to report use and release information, but in
1988 no large toxics users in this industry group reported  using SARA 313  toxic
substances. There are, however, hazardous  waste generators in these three industry
groups, and it is expected that increased growth among these generators will lead to
larger  quantities of hazardous wastes  generated by these industries if no hazardous waste
reduction procedures and techniques  are implemented.
                                        E-10

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      SUMMARY OF DATA GAPS AND POTENTIAL DATA COLLECTION
              MECHANISMS FOR FILLING INFORMATION NEEDS
      Major data gaps prevent the DEQ from fully characterizing the current universe
of large toxics users and hazardous waste generators and effectively measuring toxics use
and hazardous waste reduction. Specifically, the data gaps are as follows:
      1.    The data are incomplete for developing an accurate count of large
            toxics users and hazardous waste generators.
      2.    The data are incomplete on the quantities of toxic substances used
            by toxics users.
      3.    The data are incomplete for describing chemical use and waste
            releases from smaller facilities.
      4.    The format of the TRIS data for quantities of releases under 1,000
            pounds does not permit an accurate estimate of the quantities of
            toxic substances released to the environment.
      5.    The data are incomplete for measuring progress made toward toxics
            use reduction and hazardous waste reduction.
      Section 4 discusses these data gaps in more detail and provides suggestions for
modifying current reporting mechanisms to collect better data for DEQ's purposes.  As
discussed in Section 4, minor modifications to the TRIS reporting form (form R) would
result in collecting types of information needed to bridge DEQ's data gaps, particularly
points 1 and 2 above.  Furthermore, the final rule requires toxics users to submit annual
progress reports which provide additional  information to fill  in DEQ's data gaps.
Specifically, the reports require the universe of toxics users to provide information on
the types and quantities of SARA 313  toxic substances used  and hazardous wastes
generated.  The annual progress reports also allow toxics users to report on their toxics
use and hazardous waste reduction efforts.
                                      E-ll

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                               1.  INTRODUCTION

1.1    OVERVIEW OF STATUTE AND REGULATION

      In an effort to encourage industry to implement pollution prevention measures,
the  Oregon Legislative Assembly passed the Toxics Use Reduction and Hazardous
Waste Reduction Act that was signed into law on July 24, 1989.  The act provides a
nonregulatory approach to encourage industry to shift its focus from pollution control to
pollution prevention (i.e., promote reduction in using toxic chemicals and producing
hazardous wastes). Specifically, the act states that the most appropriate approach to
pollution prevention is to

            Provide technical assistance to toxics users and generators
            Require  toxics users to develop plans for reducing toxic substance
            use and hazardous waste generation and  to develop measurable
            performance goals
            Survey and monitor the use of toxic substances and the generation
            of hazardous wastes.

      The act gives the Oregon Department of Environmental Quality (DEQ) the
authority to provide technical assistance to toxics users and hazardous waste generators
and to develop guidelines for preparing toxic use reduction and hazardous  waste
reduction plans.  The act also gives the DEQ the authority to require large toxics users,
LQGs, and SQGs to develop and implement reduction plans as well as to submit
periodic progress reports.  In addition, the DEQ is required to submit a report to the
State Legislative Assembly on the status of implementing the act. In the report, the
DEQ must discuss the status of the technical assistance program, the progress being
made toward reducing quantities of toxic substances used and hazardous wastes
generated, and an analysis and recommendations for program changes. The  DEQ must
submit a report by January 1, 1991, and then another  report by January 1,  1993.
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      In response to the statute, the DEQ promulgated a final rule on August 20, 1990,
that required three groups of facilities - large toxics users, LQGs, and SQGs -- to
complete toxics use and hazardous waste  reduction plans (also referred to as reduction
plans).  Specifically,  the rule requires all large toxics users and LQGs to develop and
implement a reduction plan by September 1, 1991, and all SQGs to develop and
implement a plan by September 1, 1992.  In keeping with the statute's intent, the first
group (large toxics users) is defined as

      "any facility that is required to comply with Section 313 of Title HI of the
      Superfund Amendments and Reauthorization Act (SARA) of 1986."

Under SARA 313, companies that manufacture or process more than 25,000 pounds of a
listed SARA 313  toxic substance in a calendar year or use more than 10,000 pounds of a
listed toxic substance in a calendar year must report.

The second group, LQGs, is defined as
       "any facility that (1) generates in any one calendar month more than 2,200
      pounds of RCRA-regulated and State-regulated hazardous waste or more than
      2.2 pounds of an acute hazardous waste [as specified in 40 CFR § 251.5
       (e)(l)J, or more than 220 pounds of acute hazardous waste spill debris las
      specified in 40 CFR § 261.5(e) (2)].
Finally, the third group, SQGs, is defined as
       "any facility that (1) generates in every calendar month no more than 2,200
       pounds of RCRA-regulated or State-regulated hazardous waste but greater
       than 220 pounds.
Conditionally exempt generators (CEGs) (i.e., facilities generating less than 220 pounds
per month) are exempt from the rule's requirement to develop reduction plans. In the
final rules, these three groups are referred to as "toxics users."
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      In addition to developing toxics use and waste reduction plans, the rule specifies
certain toxics users and hazardous waste generators to develop measurable goals for
reducing toxic substance use and hazardous waste generation.  The development of
performance goals is limited to a subset of toxics users:
             A user of a listed SARA 313 toxic substance in quantities greater
             than 10,000 pounds per year
             A user of a toxic substance comprising more than 10 percent of the
             total quantity of toxic substances used and is in quantities greater
             than 1,000 pounds  per year.
             A LQG that generates a hazardous waste comprising more than 10
             percent (by weight) of the total hazardous wastes generated in a
             year.
The rule also requires large toxic users and LQGs to complete annual progress reports
with the first submittal by September 1, 1992, for the 1991 calendar year and SQGs to
complete annual progress reports with the first submittal by September 1, 1993, for the
1992 calendar year.

1.2    OBJECTIVES OF THE REPORT

      As stated in the previous  section, the two DEQ reports to the Legislative
Assembly must cover the status of the technical assistance program as well as the
progress Oregon toxics users and generators are  making toward reducing toxics use and
waste generation.  In preparing the first report, the DEQ has little information available
for  assessing the progress being made by industry toward reduction. This is due  to the
fact that existing reporting mechanisms do not provide adequate data for the State to
evaluate such progress and the fact that data from forthcoming progress reports will not
be available until September 1992 at the earliest.  The DEQ, therefore, made a
decision to analyze the existing data in order to characterize the Oregon toxics users and
generators to the extent permitted by the data, and then to identify the existing data
                                        1-3

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gaps that prevent assessing the progress being made toward toxics use and hazardous
waste reduction.

      This report was prepared in response to the DEQ's two objectives mentioned
above.  This report first analyzes the existing data to identify and characterize Oregon
toxics users and hazardous waste generators and to identify the types and quantities of
toxic substances used and hazardous wastes generated  in the State.  Next it identifies
existing data gaps that prevent evaluating the progress of toxics use and  hazardous waste
reduction in the State and proposes alternative approaches to collecting  such data.

      The remainder of this report is divided into four sections.  Section 2 describes the
methodology that was taken to collect and analyze the data available on toxics use and
hazardous waste generation in Oregon.  Section 2 also summarizes the quality of the
data, including any caveats or limitations of which the  reader of this report should be
aware.  Section 3 presents the results of the analysis. Section 4 summarizes the data
gaps in  existing reporting  mechanisms and proposes alternative ways of measuring toxics
use and waste reduction.
                                         1-4

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                  2.  METHODOLOGY AND DATA LIMITATIONS


      This section describes the methodology that was used to analyze the data and the
limitations of the data in interpreting findings. The primary data sources used for the

analyses include the following:


             The 1988 Toxic Release Inventory System (TRIS), an information
             system developed to  support SARA 313 reporting requirements, was
             used  to identify and  characterize large toxics users, identify types of
             toxic  substances used, and estimate quantities of toxic substances
             released to the environment;

             The 1988 DEQ Quarterly Reports, a State reporting mechanism,
             was used to identify  hazardous waste generators that manifest
             hazardous  waste (i.e., wastes generated and transported offsite) and
             the quantities and types of hazardous wastes transported off site;
             and

             The Oregon Covered Employment  and Payrolls by Industry and
             County Report and the Oregon Economic and Revenue Forecast
             (Oregon Business Data) data were  used to identify growth patterns
             among industries.


      Other sources that were examined for this effort but were not used include the

1987 Hazardous Waste Biennial Reports, the 1986 Hazardous Waste Generator Survey,

the Hazardous Waste Data Management System (HWDMS), and the Oregon State  Fire

Marshall Hazardous Substance Employer Survey (referred to as SARA 312 reports).


      The  1987 Biennial Reports  for Oregon initially were considered for identifying

the numbers of hazardous waste generators and quantities and types of hazardous wastes
generated.  This source was not used because problems were encountered with the

information system used to manage the data. Specifically, the reports generated by  the

information system indicated that there was no hazardous waste generated and managed

onsite in Oregon.   Because DEQ knows that  the State does have generators that  manage

hazardous waste onsite, the Biennial Reports were not used for the analysis  in this
                                       2-1

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report.  The Generator Survey, which also was considered a source for identifying
hazardous waste generation patterns, was not used because only non-Confidential
Business Information (CBI) data was available, which resulted in data being available
for only nine facilities -- too few observations for using in any type of analysis to
characterize generators statewide.

      HWDMS was initially examined  to identify the universe of hazardous waste
generators -- LQGs, SQGs, and CEGs -- in  Oregon. However, the DEQ determined
that HWDMS did not represent accurately the universe because it contained a number
of one-time notifications from  generators, many of which may not be generating
hazardous waste.

      The SARA 312 Reports were examined for information on the quantities of toxic
substances used by Oregon companies.  Though the SARA 312 Reports do provide such
quantitative information, the format prevents the data from being easily analyzed.
Specifically, the quantitative data is presented in ranges and in various units of
measures, depending on whether the substance is in a liquid, gas, or solid state.
Furthermore, the SARA 312 Reports cover all chemical substances requiring a Material
Safety Data Sheet, which far exceeds the scope of SARA 313 listed toxic substances.
The database that was used to manage  the  SARA 312 Reports could not be
programmed easily to present the data  in format for analysis and therefore this source of
information was not used.  Exhibit 2-1 summarizes  the content of the existing
information sources and their data gaps with regard to the analysis, while Exhibit 2-2
shows the types of analyses conducted and how the selected data sources were used to
support each analysis.
                                        2-2

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Name of Infor-
 mation Source
                                                         Exhibit 2-1.

                                          Existing Information Sources and Data Gaps
        Type of
   Facilities Covered
   Types of Data Collected
 Agency Receiving
    Information
Significant Data Gaps
     for Analysis
1988 Toxic
Release
Inventory
System (TRIS)
The Oregon
State Fire
Marshall
Hazardous
Substance
Employer
Survey (SARA
312 Reports)

1987 Hazardous
Waste Biennial
Reporting
System
"Large Toxics Users"
Companies in SIC groups
20 through 39 which
manufacture/process
more than 50,000 pounds
per year of a SARA 313
listed substance or use
more than 10,000 pounds
of a SARA 313 listed
substance per year.
Companies that generate,
use, store, or dispose of
any hazardous material
in quantities greater than
500 pounds, 55 gallons,
or 200 cubic feet and for
which a MSDS is
required.

LQGs companies that
generate greater than
2,200 pounds of
hazardous waste in any
one calendar  month or
generate greater than 2.2
pounds of acute
hazardous waste, or 220
pounds of nctue
hazardous spill debris.
(See page  1-2 for full
definition.)
Facility identifying information
Name of POTWs and other off-
site locations receiving toxic
substances transferred as waste
Toxic substances identifying
information
Activities and use of toxic
substances
Maximum amount of substances
on-site any time during calendar
year
Quantity of substances released
during calendar year by media
or off-site location
Methods and efficiency of waste
stream treatment
Type of waste minimization
activities.

Company identifying
information
Quantities of chemical
substances on hand and used on-
site during year
Method of storage and degree of
chemical hazard.
Company identifying
information
Types and quantities of
hazardous wastes generated
Quantities of hazardous wastes
managed on-site versus
quantities of wastes transported
off site
Types of methods employed to
manage hazardous wastes
Quantities of hazardous wastes
minimized.
EPA-Headquarters
State Fire Marshal
DEQ
  1988 TRIS does not
  provide data on
  large toxics users
  that manufacture
  between 25,000 and
  50,000  pounds of a
  SARA  313 listed
  substance during a
  year; however data
  on this group of
  toxics users will be
  provided in 1989.
  No data on
  quantities of SARA
  313 listed substances
  manufactured,
  processed, or used
  onsite.

  Quantities reported
  in ranges and in
  various units of
  measure.
  Difficult to access
  information on one
  chemical.
  No data on SQGs or
  CEGs
  Low response on
  waste minimization
  questions
  Problems with
  information system
  that generates
  reports; indicates no
  hazardous waste
  managed on-site.

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                                                       Exhibit 2-1.

                                   Existing Information Sources and Data Caps (continued)
 Name of Infor-
 mation Source
        Type of
   Facilities Covered
   Types of Data Collected
Agency Receiving
   Information
Significant Data Gaps
     for Analysis
1988 DEQ
Quarterly
Reports
Hazardous
Waste Data
Management
System
(HWDMS)
Oregon Personal
Income by
Major Source
and Earnings
Industry (1969-
1989)

1988 Oregon
Covered
Employment
and Payrolls by
Industry and
County

1990 Oregon
Economic and
Revenue
Forecast
LQGs and SQGs that
manifest and transport
hazardous waste offsite.
LQGs, SQGs, CEGs
Businesses in SIC groups
01 through 66.
Businesses in SIC groups
01 through 99 subject to
Oregon's Employment
Division Law.
Businesses in SIC groups
20 through 97
Company identifying
information
Types and quantities of
hazardous wastes transported
offsite.
DEQ
Company identifying
information
Status as generator
DEQ
Total earnings by SIC which
includes labor, returns to capital,
and returns to natural resources.
Number of employees and wages
by SIC and by county.
Bureau of
Economic Analysis
Number of employees by SIC
Personal income
Housing starts
Population growth.
State Employment
Division of the
Department of
Human Resources
Oregon Executive
Department
   Incomplete data on
   hazardous generators
   that:
   Manage waste on-
   site
   Recycle waste off-
   site
   Export waste out of
   state.

   Out-dated
   information;
   includes companies
   which do not
   generate
   Under represents
   CEGs.

   Does not include
   projected earnings
   data.
   Does not include
   projected
   employment.
   No significant data
   gaps.

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                                   Exhibit 2-2.

              Description of Analyses and Types of Data Sources Used

Section      Type of Analyses   Data Source Used for Analyses

3.1          Identification and Characterization
            of Universe:

                  Number of Large Toxics Users   1988 TRIS contains large toxics
                                                 users (use greater than 10,000
                                                 pounds per year of a SARA 313
                                                 or manufacture/process more
                                                 than 50,000 pounds of substance
                                                 per year).

                  Number of Hazardous Waste     1988 DEQ Quarterly Reports
                  Generators (LQGs and SQGs)
                  Location and SIC Code of
                  Large Toxics Users

                  Location and SIC Code of
                  Generators

                  Business Activities of Users
                  and Generators
1988 TRIS


1988 DEQ Quarterly Reports


Oregon Business Data
3.2    Identification and Quantification of
      Toxic Chemicals Used and Released

                  Types of Chemicals Used and    1988 TRIS
                  Frequency of Use

                  Releases of Chemicals into the   1988 TRIS
                  Environment by Media and Type
                  of Chemical

3.3    Identification and Quantification of
      Hazardous Waste Generated and Transported Offsite
                  Total Quantities of Waste
                  Generated and Transported
1988 DEQ Quarterly Reports
                  Quantities of Waste Generated   1988 DEQ Quarterly Reports
                  by RCRA Waste Code
                                      2-5

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      The data were analyzed using a three-step approach:
       1.     Identification and characterization of the universe of toxics
             users and hazardous waste generators.
                                    r , i  ^ ,
             2.     Characterization of the types of toxic substances used and an
                   estimation of the quantities of toxic substances released and
                   hazardous wastes generated.
                                           \
                   3.    Identification of future growth industries that use toxic
                         substances or generate hazardous wastes.
      This three step approach provides the DEQ with an initial characterization of the
toxics user universe. Furthermore, it presents  the data in such a manner that DEQ can
begin to identify industries that should  receive technical assistance.   The sections that
follow provide a more detailed description of how the data sources were used to conduct
each type of analysis and the restrictions in interpreting the results.
2.1    IDENTIFICATION AND CHARACTERIZATION OF THE TOXICS USER AND
      HAZARDOUS WASTE GENERATOR UNIVERSE IN OREGON
      The first step in the analysis was to identify the universe of Oregon  large toxics
users and hazardous waste generators (LQGs and SQGs), referred to collectively as toxics
users, that are subject to the development and implementation of the toxics use  and
reduction plans and the subset of toxics users that must set performance goals for reducing
quantities of toxics used and wastes generated. After estimating the number of large toxics
users and hazardous waste generators in Oregon, available data were then used to describe
the large toxics users and hazardous waste generators by location and industry groups.
                                        2-6

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      The 1988 TRIS data base and the 1988 DEQ Quarterly Report were used to identify

the toxics users in Oregon.  The TRIS data base contains large toxic users that use a SARA

listed toxic substance in quantities greater than 10,000 pounds per year or manufacture (or

process) more than 50,000 pounds per year  of SARA chemical substance.  The DEQ

Quarterly Reports,  on the other hand, were used to count the number of LQGs and SQGs

in the State that  generated and manifested hazardous waste offsite.


      Although  these information sources provide the best available data for identifying

the universe of Oregon toxic users subject to  the rule, the  numbers presented in Section

3.1 should still be viewed as an estimate for the following reasons:


            The 1988 TRIS data base contains responses from 207 companies that
            manufacture/process a listed SARA 313 substance in quantities greater
            than 50,000 pounds per year. An amendment to SARA 313 lowers the
            limit for reporting which requires companies that manufacture/process
            in quantities greater than 25,000 pounds per year to report.  The final
            rule promulgated by the DEQ defines large toxics users according to
            the SARA 313 amendment.  Consequently, the  1988 TRIS database
            is likely to be an underestimation of the total number of large toxics
            users. It should,  however, be noted that the 1989 TRIS database will
            account for companies that manufacture/process between 25,000 and
            50,000 pounds of a listed substances and therefore the 1989 database
            can be used in the future to update the estimates  in this report.

            The 1988 DEQ  Quarterly Reports only represent those LQGs and
            SQGs that generate and manifest hazardous wastes offsite.   The
            Quarterly Reports do not capture hazardous waste generators that
            generate and manage waste onsite, recycle waste offsite, or transport
            waste out of State. Nevertheless, the 1988 Quarterly Reports serve as
            a good indicator of active hazardous waste generators.
2.2    CHARACTERIZATION OF TYPES AND QUANTITIES OF TOXIC SUBSTANCES
      RELEASED AND HAZARDOUS WASTES GENERATED
      The next step ideally would be to conduct an analysis by industry group in which

quantities and types of toxic substances used in a process are identified and then tracked
                                      2-7

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through to the quantities appearing in the resulting waste stream.   Given the available
data, this type of analysis is impossible to conduct for several reasons:
             The TRIS data base and the SARA 312 reports were the available
             sources  for identifying types and quantities of toxic substances by
             facilities in each industry group.  Although TRIS provides information
             that  identifies types and  frequencies of toxic  substances  used by
             industry group, it does not provide any information on the quantities
             used during a month or year.  The TRIS data base does provide data
             on the quantities of toxic substances release but this information
             cannot be used to infer the quantities of toxic substances used.  The
             SARA 312 Reports, on the other  hand,  provide  quantitative-use
             information. However, as pointed out, the data are reported in ranges
             and in three units of measure and cover  a much  larger scope of toxic
             substances than  required  by SARA 313 or  the  DEQ's  final rule.
             Because the data base used  to  manage the  SARA 312 Reports is
             cumbersome to use, the SARA 312  Report quantity data were not
             used.

             The only data available for calculating quantities of hazardous waste
             generated were  the 1988  DEQ  Quarterly Reports and  the 1988
             Biennial  Reports.   Both  of these  sources lacked  information on
             quantities of  hazardous  waste  generated  and managed onsite.
             Therefore, data were available only on  the RCRA regulated wastes
             managed offsite.
      The evaluation of the data sources revealed that the 1988 TRIS data base provides

the best overview of onsite industry activities as they relate to the frequency of use of toxic

substances and resulting releases to  the  environment while the 1988  DEQ  Quarterly

Reports provide the most appropriate data for describing types and quantities of hazardous

wastes generated. Therefore, these sources of information serve as the focus of the analysis

to describe toxics-use patterns and releases as well as hazardous waste generation patterns.

The use of both information sources, however, still does not provide the type of data for

a "flow-through" analysis; i.e., identifying toxic substances used in a process and tracking the

substances through  to releases.  This is primarily due to the fact that the toxic substances

listed under SARA 313 do not correspond with the list of hazardous constituents in RCRA

wastes.
                                        2-8

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      Section 3.2 discusses the frequency of chemicals  used and the total quantities
released to the environment. To present the frequency data in a more meaningful manner,
the types of chemicals used are classified in three ways:  (1) by type of compound (e.g.,
volatile organic compound,  semi-volatile  organic compound,  inorganic compound), (2) by
level of toxicity as ranked by the Registry of Toxic Effects of Chemical Substances (1985-
1986), and (3) an indicator of carcinogenicity as identified by  EPA. These classification
schemes, though not perfect, are  designed  to provide readers with some  type of rough
measure - other than volume ~ for identifying and ranking toxic substances of concern.
2.3    IDENTIFICATION OF FUTURE  GROWTH INDUSTRIES THAT USE TOXIC
      SUBSTANCES OR GENERATE HAZARDOUS WASTES
      The next step was to identify those future growth industries where increases in toxic
substance releases and hazardous waste generation could  occur versus those  industries
whose growth is expected to remain stable or decrease. The assumption being made is that
there is a positive relationship between a firm's business activities and the quantities of
toxic substances used and hazardous wastes generated. As the level of business activities
increase, the quantities of toxic  substances released and hazardous wastes  generated
correspondingly  increase.   This  relationship does  not  take into  account changes in
technology and procedures resulting in toxics use and hazardous waste reduction. For this
reason, it is useful in indicating those industries where toxics use and waste generation may
increase if reduction techniques are not implemented.

      Industry employment data from 1987 projected through 1995 was used as  a proxy
for measuring the level of business activities in industry groups.  Current and projected
employment data were available through the  Oregon Covered Employment and Payrolls by
Industry and County Report and the Oregon Economic and Revenue Forecasts. Employment
was not an ideal proxy for measuring the level of business activities because a number of
industries may increase output without changing the level of employment.  Other proxies,
such as industry earnings, were considered more appropriate for measuring business activity
or output.  The  State,  however, does not publish projected earnings data and therefore
employment data, for which projects were available, were selected as the proxy.
                                       2-9

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3.1    IDENTIFICATION AND CHARACTERIZATION OF THE TOXICS USER AND
       GENERATOR UNIVERSE
3.1.1   Identification of the Universe

       As a first step in characterizing toxics users, it is essential to identify the large toxics
users and hazardous waste generators that will be impacted by DEQ's final rules.  Exhibit
3-1 depicts the relationship between the groups of toxics users -- large toxic users, LQGs
and SQGs - and the estimated number in each group for which  characterization data are
available.

       At a minimum, an estimated 928 companies meet the rule's requirements to develop
toxics use and hazardous waste reduction plans.  The 928 companies  can be  divided into
207 large toxics users and 805 hazardous waste generators, with 84 companies  that overlap
between the two groups. Of the 805 hazardous waste generators,  120 companies are LQGs
685 companies are  SQGs.4  Forty percent (49) of the LQGs and 5  percent (35) of the
SQGs comprise the 84  companies  that are both hazardous waste generators and large
toxics users.

       It  is  expected  that  the  number  of  companies in  each of  these groups  is
underrepresented.  As pointed  out  in Section  2, the  1988 TRIS data, which  was  used to
estimate the number of large toxics  users, does not reflect companies that manufacture or
process  listed substances in  quantities between 25,000 and 50,000 pounds  per year.
Furthermore,  the number of LQGs and SQGs include only those companies that generate
and manifest  (transport) hazardous waste offsite.  Therefore, the 941 companies can  be
viewed as a lower bound estimate of the number of toxics users required to complete toxics
use and  hazardous waste reduction plans.

       These 928 companies also will need to complete annual progress reports. The large
toxics users and LQGs  must submit annual progress  reports by September 1992, and the
SQGs must submit reports by September 1993.  A subset of these companies also will need
to develop performance goals.  Based on the  existing data sources, it was impossible to
identify accurately and count the subset of toxics users that would need to  develop
   An unknown percentage of SQGs also include conditionally exempt generators (CEQS) (i.e. generators that generate less than 220 pounds of
hazardous waste In every month of the calendar year.] Due to the format of the DEQ Quarterly Reports from which trie data was extracted, It is not
possible to identify the exact number of CEGs included in the count of SQGs. Because CEGs are not required to comply with OEQ Quarterly Reporting
processing, the DEO believes that CEGs as a percentage of SQGs is small.

                                         3-1

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                                                            Exhibit 3-1
                                       The  Universe of Oregon Toxics Users
                   49 companies that are large
                   toxics users and LQGs
                   Data is available for only those
                   LQGs and SQGs that generate and
                   manifest hazardous waste off site
                                                                     Data is available for only those large toxics users that use more
                                                                     than 10,000 pounds of a listed SARA 313 substance or
                                                                     manufacture/ process more than 50,000 pounds of SARA 313
                                                                     substance during a year
                                                                                   'V	\   35 companies that large toxics users
                                                                                                and SQGs
Universe
   of
 Toxics
  Users
Large Toxics Users = Companies that use greater than 10,000 pounds per year of a SARA 313 toxic substance or manufacture/process
                 more than 25,000 pounds of a SARA 313 substance per year
Large Quantity Generators (LOG) = Companies that generate in one or more months during a year more than 2,200 pounds
                              of RCRA-regulated or State-regulated hazardous waste, more than 2.2 pounds of acute hazardous waste,
                              or more than 220 pounds of acute hazardous spill debris.
Small Quantity Generators (SQG) = Companies that generate in every single month during a year between 220 and 2,200 pounds of RCRA-
                              regulated or State-regulated hazardous waste.
                              ijp  Shaded area represents those companies for which characterization and release data is available
                              Source of data: 1988 Toxic Release Inventory System Reports and 1988 DEQ Quarterly Reports

-------
performance goals. However, enough information is available to estimate the range inthe
number of companies that would need to comply with performance goals.  As specified
under the law, the following groups of toxics users must set performance goals: (1) a toxics
user of a listed toxic substance in quantities greater than 10,000 pounds in a calendar year,
(2) a toxics user  of a substance in quantities of greater than 1,000 pounds in a calendar
year that constitutes 10 percent or more of the total toxic substances used in a year, and
(3) a LQG  that generates  a  hazardous waste comprising at least 10 percent of the total
waste generated.  Based on this criteria, all 207 large toxics users, LQGs, and a percentage
of SQGs must set performance goals.

      For the purposes of the analysis that follows, the 941 toxics users are analyzed
according to two groups -- 207 large toxics users and 805 hazardous waste generators --
realizing that 84 of the companies straddle between two groups.  These 84 companies are
believed to be regulated highly, and it would be interesting to analyze toxics use and waste
generation patterns separately for this group of toxics users.  But due to the limitations of
the data and resources available for this report, analyzing the 84 companies separately was
not possible.

3.1.2  Characterization of Generators  and Toxics Users by SIC Code and Location

      Based on the 1988 Oregon DEQ Quarterly Reports, 805 Oregon hazardous waste
generators manifested (i.e., transported) waste offsite in 1988.  Exhibit 3-2 displays the
number of hazardous  waste generators  that transport waste offsite for a subset of industry
groups while Appendix A, Table 1 provides the number of hazardous waste generators  for
all industry groups. In 1988, five industry groups each contained over 40 hazardous waste
generators.  The auto  dealers and service stations industry (SIC 55) had the largest number
of hazardous  waste generators with  106  facilities.  There were 65 hazardous  waste
generators in  the motor freight transportation  and warehousing  industry (SIC 42),  43
generators in the lumber and wood products industry (SIC 24), and 41 generators each in
the fabricated metal products industry (SIC 34) and the electronic and electrical equipment
industry (SIC  36).  Several other industry  groups in the  State had between 30 and 40
hazardous waste generators; however, the average number of facilities  by  industry  group
was 12.9 when SIC 00 (unknown; 119 facilities) was not included.
                                        3-3

-------
                              Exhibit 3-2
              Number of Hazardous Waste Generators that
                  Transport Waste Off-site by SIC Code
I£U
100
CO
1 80
a.
E
o
0 60
o
o3
g 40
Z
20

n
_
-
-
-
.

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-
-10

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18
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    50
       20 22 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 42 48 49 50 51  55 75 95
                                     SIC Code
      Source: 1988 DEQ Quarterly Reports

                               Exhibit 3-3
                 Number of Large Toxics Users by SIC Code
_
-










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-------
       In  1988, 19 industry groups represented the 207 toxics users in Oregon.  Nine of
these industry groups accounted for over 85 percent of the large toxics users.  The lumber
and wood products industry (SIC 24) had the largest number of large toxics users, with 36
facilities in 1988.  Other industry groups with a large number of large toxics users in 1988
include the chemicals and allied products industry (SIC 28), the fabricated metal products
industry (SIC 34), the primary metal  industries (SIC 33), and the electronic and electrical
equipment industry (SIC 36).  Two of the industry groups -- lumber and wood products
and fabricated metal products ~ which contain large  numbers of large toxics users also
exhibit  the largest number of generators.  Exhibit 3-3 shows that  the other 10 industry
groups each had less than 10 toxics users in  1988.

       Exhibit 3-4 illustrates that the majority of the large toxics users, LQGs, and SQGs
are located in the northwestern corner of Oregon.  Fifty-two percent of the large toxics
users, 69 percent of the LQGs, and 61 percent of the SQGs are located in the  northwest
region of  the State encompassing Clackamas, Clatsop, Columbia, Multnomal, Tillamook,
and Washington counties. Furthermore, over 90 percent  of all large toxics users, LQGs,
and SQGs reside in the western third of the State.
3.2   TYPES AND QUANTITIES OF TOXIC SUBSTANCES USED AND RELEASED
      TO THE ENVIRONMENT
3.2.1  Major Toxic Substances Used by Toxics Users

      Of the 87 toxic substances reported under TRIS (SARA 313), the toxic substances
used  most  frequently  by  large  toxics  users  include acetone,  ammonia, chlorine,
formaldehyde, hydrochloric  acid, methanol, methyl ethyl ketone, sulfuric acid, toluene,
xylene, and 1,1,1-trichloroethane.  Sulfuric acid,  acetone, and  toluene, the three most
commonly used toxic substances, are used at 52 facilities, 40 facilities, and 38 facilities,
respectively.  The paper  and  allied products industry (SIC 26), the fabricated metal
products  industry (SIC 34), and the electronic and electrical equipment industry (SIC 36)
use sulfuric acid most frequently, while the lumber and wood products industry (SIC 24)
and the chemicals and allied products industry (SIC 28) use acetone and toluene most
frequently.
                                        3-5

-------
417
                             Exhibit 3-4
Distribution of Oregon Toxics Users and Hazardous Waste Generators
                             by Region
                     LQGs 0 SQGs D Large (TRIS) Toxics Users
        Source: 1988 Oregon DEQ Quarterly Reports and 1988 Toxic Release Inventory System Reports

-------
Exhibit 3-5 details the frequency of use of each toxic substance reported under SARA 313
by industry group.

       When examining industry release data, it is important to realize that many factors
should be considered in targeting  specific  wastes for toxics use or hazardous waste
reduction efforts. Such factors as toxicity, environmental persistence, and/or mobility might
be the factors of  greatest concern when  establishing  a priority for reducing the use or
release of specific toxic substances or hazardous wastes. Physical/chemical nature, toxicity,
and carcinogenicity are three indicators of the priority  that might be assigned in targeting
toxic substances for reduction efforts.

       Such factors as environmental persistence and mobility are directly related to the
physical  and chemical  properties of the  constituent.   Exhibit 3-6  classifies  the  toxic
substances identified by TRIS by generic chemical groupings.  These groupings provide
general insight to the nature of the compounds.  For example, volatile  organic compounds
are likely to migrate to the atmosphere when discharged to the environment.

       Exhibit 3-7 ranks the toxic substances identified by the TRIS data by increasing
level of toxicity.   The LD^, for rats  has  been used as the indicator of  toxicity for this
ranking.  LD^0 (lethal dose) refers to the dose of compound needed to kill 50 percent of
the study population.  Mammalian lethal dose numbers are commonly used by EPA as a
measurement of the hazard  that a chemical poses to human health and the environment.
The LD value for  a compound can be used as an input parameter  for a disposal scenario
model  that can be used to predict unacceptable exposure concentrations.

       Exhibit 3-7 also indicates whether the identified toxic substance  is carcinogenic.
These  data are  based upon EPA  determinations through  animal  studies  regarding
carcinogenicity  in  humans.   Toxicity and  carcinogenicity  are not analogous; there are
important differences between the two.  Most importantly, a carcinogen does not display
a threshold or an experimentally derived dose-response curve, which means that any
                                        3-7

-------
          Exhibit 3-5
Frequency of Use By Chemical Per SIC Code

Sulfuric acid
Acetone
Toluene
Ammonia
Xylene (mixed isomers)
Methanol
Formaldehyde
1.1.1-trichloroethane
Hydrochloric acid
Chlorine
Methyl ethyl ketone
Phosphoric acid
Freon113
Aluminum oxide
Nitric acid
Copper
Glycol ethers
Styrene
Phenol
Chromium
Trichloroethylene
Chromium compounds
Copper compounds
Dichloromethane
Manganese
Methylenebis(phenylisocyanate)
Bhylene glycol
Hydrogen fluoride
Zinc (fume or dust)
Catechol
Lead compounds
Zinc compounds
Aluminum (fume or dust)
Barium compounds
Nickel
Methyl isobutyl ketone
20
1
0
0
7
0
0
0
0
1
7
0
2
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
22
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
24
1
8
12
6
8
3
15
1
1
0
8
2
0
0
0
3
0
0
4
1
D
2
3
0
0
1
0
0
2
0
0
1
0
0
0
1
25
0
0
1
0
1
0
0
0
0
0
1
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
26
10
7
2
7
0
12
3
2
4
8
0
5
0
0
1
1
1
0
1
1
0
1
1
0
0
0
1
0
1
7
0
0
0
1
0
0
27
0
0
0
0
0
0
0
2
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
28
6
8
11
5
7
8
8
4
4
1
4
2
0
0
1
0
5
4
6
0
0
2
1
2
0
1
4
0
0
0
1
0
0
2
0
2
29
0
0
1
0
1
1
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
1
0
0
0
0
1
0
0
0
0
30
1
3
0
0
0
0
0
1
0
0
0
0
0
1
0
0
0
4
0
0
3
0
0
5
0
2
0
0
0
0
0
0
0
0
0
0
31
1
0
0
1
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
1
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
32
0
0
0
0
0
0
0
0
0
0
0
0
0
1
0
0
0
0
0
0
0
0
0
1
0
0
0
0
0
0
0
1
0
1
0
0
33
6
3
0
3
0
0
0
2
3
4
1
0
4
11
4
4
2
0
1
6
3
4
2
1
7
1
1
5
2
0
2
1
5
1
3
1
34
11
0
6
1
5
1
0
2
4
2
4
2
0
1
3
2
0
0
0
1
3
1
1
0
2
1
0
0
1
0
0
2
1
0
1
1
35
1
0
2
0
2
0
0
3
2
0
0
1
3
1
1
0
0
0
0
0
0
0
0
2
0
2
0
0
0
0
0
0
0
0
0
0
36
11
2
0
3
2
1
1
2
3
0
0
2
7
0
3
3
3
0
0
1
2
0
2
0
0
0
1
2
0
0
2
0
0
1
0
0
37
1
6
2
0
2
1
0
4
0
0
3
1
0
0
0
0
1
4
0
1
0
1
0
0
1
1
1
1
0
0
1
0
0
0
1
0
38
1
3
2
0
0
1
0
2
1
0
1
0
2
0
1
1
1
0
0
0
1
0
1
0
0
0
0
0
1
0
0
0
0
0
0
0
39
1
0
Q
0
0
0
0
0
0
0
0
0
0
0
0
0
0
1
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
51
0
0
0
0
1
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Q
0
0
0
0
0
Total
' »
» *°
"-' 1$
33
s|i£$
V 28
$&i&
""'25
" >23
22
"' '-22
17
\v-:'|^
is
H*S''H
v,, ^
i ^ 1$;
13
,,1jfc'
, - —

12
11
" t|1
11
,x10
9
*
8
T
7
$
6
e
6
*
5

-------
     Exhibit 3-5 (cont.)




Frequency of Use By Chemical Per SIC Code

Nickel compounds
Cyanide compounds
Pentachlorophenol
N-butyl alcohol
Butyl benzyl phthalate
Naphthalene
Ammonium sulfate
Chlorine dioxide
Anthracene
Dibenzofuran
Ammonium nitrate
Asbestos (friable)
Tetrachloroethylene
Arsenic compounds
Chloroform
Lead
Methyl methacrylate
Toluene-2,4-Diisocyanate
Arsenic
Manganese compounds
Vinyl acetate
Butyl acrylate
Biphenyl
Epichlorohydrin
Cobalt compounds
1 ,2,4-trimethylbenzene
Phthalic anhydride
Ethylbenzene
Dibutyt phthalate
Toluene-2,6-Diisocyanate
NA
Benzene
Polychlorina.ted biphenyls
Vanadium (fume or dust)
20
0
0
0
0
0
0
0
2
0
0
0
0
0
0
0
1
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
22
0
0
0
0
0
0
1
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
24
0
0
5
0
0
4
2
0
4
3
1
0
0
3
0
0
0
0
2
0
0
0
2
0
0
0
0
0
0
0
0
0
0
0
25
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
26
0
0
0
0
0
0
0
2
0
0
1
0
0
0
3
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
1
0
27
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
28
0
0
0
0
1
0
0
0
0
0
1
1
0
0
0
0
2
1
0
0
2
2
0
2
0
1
1
0
1
0
1
0
0
0
29
0
0
0
0
0
0
0
0
0
0
0
1
0
0
0
0
0
0
0
0
0
0
0
0
0
1
0
1
0
0
0
1
0
0
30
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
1
0
0
0
0
0
0
0
0
0
0
0
1
0
0
0
0
31
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
32
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
33
4
2
0
1
3
0
1
0
0
0
0
0
1
0
0
1
0
0
0
2
0
0
0
0
2
0
0
0
0
0
0
0
0
0
34
1
2
0
1
0
0
0
0
0
0
0
0
1
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
1
35
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
36
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
1
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
37
0
1
0
1
0
0
0
0
0
0
0
1
0
0
0
0
1
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
38
0
0
0
1
0
0
0
0
0
0
0
0
1
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
39
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
51
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Total
*
5
s
4
' 4
4
, 4
4
4
3
3
3
'' 3
3
„ a
3
* >
2
"' '*,
2
2
2
*
2
; *
2
1
1
, 1
1
1
1
1
1

-------
                                                Exhibit 3-5 (cont.)



                                           Frequency of Use By Chemical Per SIC Code

Silver compounds
Methyl acrylate
Antimony
Mercury
Titanium tetrachloride
Di(2-ethy)hexy1) phthalate
Cumene
Dacabromodiphenyl oxide
Propylena
Cyclohexane
Dimethyl phthalate
Maleic anhydride
Compound beta (solid)
Isopropyl alcohol
Antimony compounds
2,4-D
4,4'-methylenebis(2-chloroanillne)
Total:
20
0
0
0
0
0
0
0
0
0
0
0
0
0
1
0
0
0
22
22
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
1
24
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
109
25
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
3
26
0
0
0
0
0
0
0
0
1
0
0
0
0
0
0
0
0
85
27
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
2
28
0
1
0
0
0
0
0
0
0
0
1
1
0
0
0
0
0
118
29
0
0
0
0
0
0
1
0
0
1
0
0
0
0
0
0
0
11
30
0
0
0
0
0
1
0
1
0
0
0
0
0
0
1
0
1
26
31
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
3
32
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
4
33
0
0
0
0
1
0
0
0
0
0
0
0
1
0
0
0
0
112
34
0
0
0
1
0
0
0
0
0
0
0
0
0
0
0
0
0
66
35
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
20
36
0
0
1
0
0
0
0
0
0
0
0
0
0
0
0
0
0
56
37
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
37
38
1
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
22
39
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
2
51
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
1
0
2
Total
W<$
1
'4; J*!?
1
$&
t
^ *$
i
\ >
1
*• /, *
*<,-!
1
i ^
1
'«\^l
1
*vv: 1
701
Source:  1988 Toxic Release Inventory System Reports

-------
                                    Exhibit 3-6

            Classification of Toxic Substances in 1988 Oregon TRIS Report


VOLATILE ORGANICS:                                             CAS No.

Non-halogenated. Non-aromatic compounds:
      Acetone                                                       67-64-1
      Butyl acrylate                                                  141-32-2
      n-Butyl alcohol                                                 71-36-3
      Cyclohexane                                                   110-82-7
      Formaldehyde                                                  50-00-0
      Isopropyl alcohol                                               67-63-0
      Methanol                                                      67-56-1
      Methyl acrylate                                                 96-33-3
      Methyl ethyl ketone (2-butanone)                                78-93-3
      Methyl isobutyl ketone (4-methyl-2-pentanone)                    108-10-1
      Methyl methacrylate (methyl 2-propenoate)                        80-62-6
      Propylene                                                     115-07-1
      Vinyl acetate                                                  108-05-4

      Halogenated. Non-aromatic compounds:
      Chloroform                                                    67-66-3
      Dichloromethane                                               75-09-2
      Epichloroethylene (l-chloro-2,3-epoxypropane)                    106-89-8
      Freon 113 (l,l,2-trichloro-l,2,2-trifluoroethane)                    76-13-1
      1,1,1-Trichloroethane                                            71-55-6
      Tetrachloroethylene                                            127-18-4
      Trichloroethylene                                               79-01-6

      Non-halogenated. Aromatic compounds:
      Benzene                                                       71-43-2
      Biphenyl                                                       92-52-4
      Catechol  (2-hydroxyphenol)                                    120-80-9
      Cumene  (isopropyl benzene)                                    98-82-8
      Ethylbenzene                                                  100-41-4
      Naphthalene                                                    91-20-3
      Styrene                                                       100-42-5
      Toluene                                                      108-88-3
      1,2,4-Trimethylbenzene                                          95-63-6
      Xylenes (mixed isomers)                                       1330-20-7

      Halogenated. Aromatic compounds:
      2,4-D   (2,4-dichlorophenoxyacetic acid)                          94-75-7
      4,4'-Methylenebis(2-chloroaniline)  (MBOCA)                    101-14-4
                                    3-11

-------
                              Exhibit 3-6 (continued)

            Classification of Toxic Substances in 1988 Oregon TRIS Report

SEMIVOLATILE ORGANICS:                                       CAS No.

      Non-halogenated. Non-aromatic compounds:
      Ethylene Glycol                                              107-21-1

      Halogenated. Non-aromatic compounds:
      None

      Non-Halogenated. Aromatic compounds:
      Anthracene                                                   120-12-7
      Butyl benzyl phthalate                                          85-68-7
      Dibenzofuran                                                 132-64-9
      Dibutyl phthalate                                              84-74-2
      Di(2-ethylhexyl) phthalate  (DEHP)                             117-81-7
      Dimethyl phthalate                                            131-11-3
      Methylenebis(phenylisocyanate)                                 101-68-8
      Phenol                                                       108-95-2
      Toluene-2,4-diisocyanate                                       584-84-9
      Toluene-2,6-diisocyanate                                        91-08-7

      Halogenated. Aromatic compounds:
      Decabromodiphenyl oxide                                     1163-19-5
      Pentachlorophenol                                             87-86-5
      Polychlorinated biphenyls (PCBs)                              1336-36-3

      Acid anhydrides:
      Maleic anhydride                                              108-31-6
      Phthalic anhydride                                             85-44-9


INORGANICS:

      Strong acids:
      Hydrochloric acid                                            7647-01-0
      Nitric acid                                                   7697-37-2
      Phosphoric acid                                              7664-38-2
      Sulfuric acid                                                 7664-93-9

      Stong bases:
      Sodium hydroxide                                            1310-73-2
                                     3-12

-------
                              Exhibit 3-6 (continued)

           Classification of Toxic Substances in 1988 Oregon TRIS Report

INORGANICS (continued):
      Heavy metals:
      Aluminium
      Antimony
      Arsenic
      Chromium
      Copper
      Lead
      Manganese
      Mercury
      Nickel
      Vanadium
      Zinc

      Inorganic compounds:
      Aluminium oxide
      Ammonia
      Ammonium nitrate
      Ammonium sulfate
      Asbestos
      Chlorine
      Chlorine dioxide
      Hydrogen fluoride
      Titanium tetrachloride

      Unknown:
      Trade secret
 7429-90-5
 7440-36-0
 7440-38-2
 7440-47-3
 7440-50-8
 7439-92-1
 7439-96-5
 7439-97-6
 7440-02-0
 7440-62-2
 7440-66-6
 1344-28-1
 7664-41-7
 6484-52-2
 7783-20-2
 1332-21-4
 7782-50-5
10049-04-4
 7664-39-3
 7550-45-0
                                     3-13

-------
                       Exhibit 3-7
Ranking of Toxic Substances by Increasing Toxicity and Carcinogenicity
Toxic Substance
FREON113
DI(2-ETHYLHEXYL) PHTHALATE
CYCLOHEXANE
1 ,1 ,1-TRICHLOROETHANE
BENZENE
MANGANESE
DIBUTYL PHTHALATE
METHYL METHACRYLATE
ANTIMONY
DIMETHYL PHTHALATE
TOLUENE-2.6-DJISOCYANATE
TOLUENE-2.4-DIISOCYANATE
ACETONE
METHANOL
ISOPROPYL ALCOHOL
TOLUENE
STYRENE
AMMONIUM NITRATE (SOLUTION)
ETHYLENE GLYCOL
PHTHALIC ANHYDRIDE
TRICHLOROETHYLENE
ETHYLBENZENE
8IPHENYL
TETRACHLOROETHYLENE
AMMONIUM SULFATE (SOLUTION)
VINYL ACETATE
METHYL ETHYL KETONE
BUTYL BENZYL PHTHALATE
SULFURIC ACID
DICHLOROMETHANE
METHYL ISOBUTYL KETONE
PHOSPHORIC ACID
CUMENE
POLYCHLORINATED BIPHENYLS
HYDROGEN FLUORIDE
NAPHTHALENE
CATECHOL
1 ,2,4-TRIMETHYLBENZENE
BUTYL ACRYLATE
HYDROCHLORIC ACID
4,4'-METHYLENEBIS(2-CHLOROANILINE)
FORMALDEHYDE
N-BUTYL ALCOHOL
LD50
(PPM)
43000
30700
12705
10300
10000
9000
8000
7872
7000
6800
5800
5800
5800
5628
5045
5000
5000
4820
4700
4020
3670
3500
3280
3005
3000
2920
2737
2330
2140
2136
2080
1530
1400
1295
1278
1250
1084
1000
900
900
880
800
790
Carcinogenic
+
+
+
No
Yes
No
No
+
No
+
+
+
No
+
+
No
+
+
+
+
Yes
No
+
+
+
+
No
Yes
+
Yes
+
+
+
Yes
+
+
+
+
+
+
Yes
Yes
+
                      3-14

-------
                                 Exhibit 3-7 (continued)
Toxic Substance
SODIUM HYDROXIDE (SOLUTION)
ANTHRACENE
MALEIC ANHYDRIDE
2,4-D
AMMONIA
PHENOL
CHLORINE
CHLORINE DIOXIDE
METHYL ACRYLATE
EPICHLOROHYDRIN
PENTACHLOROPHENOL
VANADIUM (FUME OR DUST)
XYLENE
CHLOROFORM
TITANIUM TETRACHLORIDE
METHYLENEBIS(PHENYLISOCYANATE)
PROPYLENE
LEAD
ALUMINUM (FUME OR DUST)
CHROMIUM
ALUMINUM OXIDE
ARSENIC
NITRIC ACID
MERCURY
ASBESTOS
ZINC (FUME OR DUST)
COPPER
NICKEL
DECABROMODIPHENYL OXIDE
DIBENZOFURAN
LD50
(PPM)
500
430
400
370
350
317
293
292
277
90
27
10
7.71
3.8
0.46
0.178
*
*
A
*
A
*
*
*
*
*
*
*
*
*
Carcinogenic
+
No
+
+
+
+
+
+
+
Yes
+
No
No
Yes
•f
+
+
Yes
+
Yes
+
Yes
+
No
Yes
+
No
Yes"'
Yes
No
* No available LD50 data.
+ Chemical has not been evaluated by the U.S. Environmental Protection Agency for
  carcinogenici ty
** by inhalation; unknown for oral route
Source: The Registry of Toxic Effects of Chemical Substances, 1985-1986.
                                 3-15

-------
dose of a carcinogen poses a risk to health.  Conversely, a toxicant must surpass a certain
threshold before its effect is toxic.

       Of the three most commonly used toxic substances, acetone and toluene have been
determined by  EPA not to be human carcinogens.  To  date, sulfuric acid has  not been
evaluated for carcinogenicity by EPA.  Sulfuric acid is the most toxic of the three most
frequently used toxic substances with an LD^ of 2,140 ppm. Toluene and acetone are less
toxic with LD^0s of 5,000 ppm and 5,800 ppm, respectively. For SARA 313 substances that
were evaluated for toxicity, methylenebis (phenylisocyanate) was the most toxic substance
(LD^j  = 0.178) used by Oregon facilities.  Nine facilities used this toxic substance and
released approximately 7,200 pounds of the substance into the environment (0.016 percent
of the  total quantity of toxic substances released in 1988).

       Both Exhibit 3-6 and 3-7 indicate the type of factors that might be used to target
compounds by  the potential  hazard  that each poses based on  physical/chemical nature,
toxicity,  and carcinogenicity.   These three groupings are not  intended to provide  a
comprehensive  description of these compounds.  To develop a comprehensive description
would  require the study of additional  factors and would depend on the nature of the toxic
substance,  the environmental  media  impacted, and the nature of the problem  currently
caused by the contaminant.  For example, such factors as partition coefficients (Henry's
Law constant),  toxicity to aquatic  life, and,  anaerobic  degradation mechanisms  might be
important considerations when ranking chemicals that are discharged to surface waters
and commonly  accumulate in river and lake sediments.

3.2.2   Quantities of Toxic Substances Released to the  Environment

       As illustrated in Exhibit 3-8, large  toxics users released over 45-million pounds of
toxic substances5 to various media in 1988.  Note again that the large  toxics users  are
represented by  those facilities that reported under SARA 313 for 1988, which includes
  Includes quantities of released toxic substances reported under SARA 313 only.

                                        3-16

-------
                                           Exhibit 3-8

                                Quantity of Chemicals Released
                                       by Type of Media
    Fugitive Air
Stack Air
Water
  Underground Injection    On-Site
                   Management Unit

Type of Media
POTW    Other Off-Site Location
Source: 1988 Toxic Release Inventory System Reports

-------
only users of greater than 10,000 pounds of a toxic substance per year and manufacturers
and processors of more than 50,000 pounds per year.

      The largest quantity  of toxic substances was released as  stack or point-source air
emissions and represents 34 percent of the total quantity of toxic substances released to
the environment in 1988.  Additionally, large quantities of toxic substances were released
to onsite land management units and  other offsite  locations, discharged to  a  POTW, or
released as fugitive air (nonpoint source  air) emissions.   However, only an estimated
337,000 pounds of toxic substances (<1  percent of the total  quantity released) were
discharged to  streams or  water  bodies;  virtually  no  toxic substances were injected
underground.

      On a company basis, a small percentage of companies account for the  majority of
toxic substances released to the environment. Exhibit 3-9 illustrates this skewed distribution
of releases. As shown in the exhibit, approximately 9 percent of the companies account for
over 80 percent of the total releases into the environment. This distribution is important
to note in terms of the minimizing volumes  of releases into the environment because toxics
use and waste reduction practices implemented among the subset of very large toxics users
can result in  significant reduction in the volume of environmental releases.

      Exhibit  3-10a  through 3-10f show the toxic substances that contributed most
significantly to the releases for each medium. Of the stack and point-source air emissions,
22 percent of the total  quantity of toxic substances released to this medium was methanol,
17 percent was acetone, and 8 percent was toluene.  Aluminum oxide, toluene, and acetone
were the toxic substances released in the largest quantities as fugitive air emissions and
contributed 19  percent, 15 percent, and 11 percent to  the total  quantity released  to this
medium, respectively.  Aluminum oxide represented 62 percent of the total  releases to
onsite  land,  while methanol and  ammonia  represented 19 percent  and 12 percent,
respectively.  Aluminum oxide also was the largest contributor to toxic substance releases
to other offsite locations (59 percent) with zinc compounds also  contributing significantly
(22 percent)  to offsite releases.  Forty-four percent of the total releases to
                                        3-18

-------
                                                          Exhibit 3-9
                                            Cumulative Distribution of Releases
                                            by the Quantity Released per Facility
         c
         o
         Q.
         o
            60
             50
            40
\o
             30
         
-------
                            Exhibit 3-10
                Releases to Media by Chemical
                                                        A.   Fugitive Air
3. Stack Air
    Methanol
    Acetone
    Toluene
    Chlorine
    Chlorine Dioxide
    Ammonia
    Methyl Ethyl ketone
    Trichloroethylene
    Styrene
    Aluminum Oxide
    Xylene
    Dichloromethane
    Freon 113
    Chloroform
    Other
                                                              Aluminum Oxide
                                                              Toluene
                                                              Styrene
                                                              Acetone
                                                              1,1,1, Trlchloroethane
                                                              Methanol
                                                              Freon 113
                                                              Formaldehyde
                                                              Methyl Ethyl Ketone
                                                              Trlchloroelhylene
                                                              Methyl Isobutyl Ketona
                                                              Other
                             3-20

-------
                      Exhibit 3-10(cont.)
               Releases to Media by Chemical
                                                           C.  Land
                                                          [•:;:;] Aluminum Oxide

                                                          fcyj Ammonia

                                                          [\] Methanol

                                                             Other
D. Other Off-Site
    Aluminum Oxide

    Zinc Compounds

    PCB's

    Zinc

    Lead Compounds
\\ Cyanide Compounds

    Other
                                   3-21

-------
                      Exhibit 3-10(cont.)
              Releases to Media by Chemical
                                                   E.  Water
                                                  H2] Sodium Hydroxide
                                                  ££] Catechol
                                                  f\] Ammonia
                                                  0 Zinc
                                                  [J Formaldehyde
                                                  ^ Acetone
                                                  (3 Aluminum Oxide
                                                  • Other
   F.  POTW
   ^ Methanol
   5$ Other
Source: 1988 Toxic Release Inventory System Reports
                             3-22

-------
water consisted of sodium hydroxide.  Several other chemicals, including catechol and
ammonia, also contributed significantly to the discharges to water. Discharges to POTWs
were primarily methanol  (87  percent) with  the remainder  of the discharges comprising
small quantities of several other chemicals.

3.2.3         Contribution to  Releases by Industry Group

      Of the 45-million pounds of toxic substances released to the environment in 1988,
30,900,000 pounds (68 percent of the total releases) were released by two industry groups.
The primary metal industries (SIC 33) released 17,160,000 pounds of toxic  substances (38
percent of the  total releases); the paper and allied products industry (SIC  26) released a
total of 13,700,000 pounds (30 percent of the total releases).  Exhibit 3-1 la displays the
quantities of toxic substances  released by each industry group of interest  as well as the
disposition of these releases. (See Appendix A, Table 4 for data on specific  media releases
from industry groups.)

      Of the releases by  the  primary metals industries, 48  percent were to other offsite
locations, 29 percent were to onsite land management units, and  14 percent were fugitive
or nonpoint source air emissions.  Forty-six percent of the releases by the paper and allied
product industry were discharges to POTWs; 32 percent were stack or point-source air
emissions.  Nine percent of the releases by this industry were fugitive or nonpoint source
air emissions.  The instruments and related products industry (SIC 38) also contributed
significantly to releases to the environment in 1988.  An  estimated  94  percent of the
releases by this industry were  stack or point-source air emissions.

      Exhibit 3-1 Ib shows, by industry group, the major toxic substances that  made up
the releases  in  1988.   (See Appendix A, Table 5, for specific data on releases of toxic
substances by industry groups.)  The releases  by the  primary metals industry in  1988
consisted  mainly of aluminum oxide,  68 percent of  the total quantity released by this
industry was  aluminum oxide.  Additionally, zinc compounds contributed to 11 percent of
the total releases from this industry group.  For the paper and allied products
                                        3-23

-------
N)
                                                          Exhibit 3-11 a
                                                 Releases by Industry Group:
                                              Disposition in Millions of Pounds
                    20    22    24    25   26    27    28    29   30    31    32    33    34    35    36    37    38   39    51
                        Fugitive Non-Point Source
                        Air Emissions

                        Releases to Land
Stack or Point Source
Air Emissions

Discharges to POTWs
Discharges to Streams or
to Water Bodies

Other Off-Site Location
Underground Injection
                     Source: 1988 Toxic Release Inventory System Reports

-------
                               Exhibit 3-11 b
                        Releases by Industry Group:
                     Composition in Millions of Pounds
CM
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i Acetone
2 Aluminum oxide
.1 Ammonia
4 Ammonia sulfate
') Benzene
b Chlorine
/ Chlorine dioxide
6 Chloroform
9 Chromium
10 Cyclohexane
1 1 Oichloromethane
12 Ethylene glycol
13 Formaldehyde
14 Freon113
15 Glycol ether
16 Hydrochloric acid
1 T l&opropyl alcohol
19 Lead compounds
19 Melhanol
20 Methyl ethyl Ketone
21 Methyl Isobutyl
22 Nitric acid
23 Phosphoric acid
?4 Polychlorlnated blphenyls
25 Styrene
26 Sullurlc acid
27 tetrachloroethylene
26 Toluene
29 Trichloroethylene
30 Xylene
31 Zinc (fume or dust)
3? Zinc comoounds
33 1.1.1-Trlchloro«th*ne
3« 2.4-O


0 Other
  20   22  24   25   26   27  28   29   30   31   32   33   34  35   36   37   38  39   51

                                           Sic Codes

Source: 1988 Toxic Release Inventory System Reports

-------
industry, toluene, formaldehyde, acetone, and xylene made up 28 percent, 18 percent, 17
percent, and 12 percent,  of  the  total releases by this  industry, respectively.   For the
instruments and related products industry, 50 percent of the total releases in 1988 consisted
of acetone, 13 percent were toluene releases, 13 percent were methyl ethyl ketone releases,
and 9 percent were methanol releases.

3.3    TYPES AND QUANTITIES OF RCRA HAZARDOUS WASTES GENERATED

      As  explained earlier, the TRIS data base provides information on the types of toxic
substances used  and quantities released into  the environment by 207  large toxics users,
Little information is available on small and large quantity hazardous waste generators that
are not  large toxics users but will be subject to the rule's requirements to develop toxics
use and waste reduction plans and submit annual reports.  When examining the data
sources, the DEQ Quarterly Reports provided the most reliable information on quantities
of hazardous waste generated and manifested (transported) offsite by 805 LQGs and SQGs.
The data  from  the reports provide a  picture of  the types and quantities of  RCRA and
State-regulated  hazardous wastes  released by smaller  facilities (i.e., facilities other than
large toxics users).  The important point to note  with the DEQ Quarterly Report data is
that facilities that treat, store, dispose or recycle hazardous wastes onsite are not captured.
Additionally, releases to the air or discharges under a National Pretreatment Discharge and
Elimination System (NPDES) permit or POTW (i.e., releases not regulated under RCRA)
are not  encompassed.  Therefore, the quantities  of RCRA wastes identified in  the DEQ
Quarterly  Reports represent a subset of the total quantity of hazardous wastes generated
by LQGs and SQGs.

      An estimated 82-million pounds (41,000 tons) of hazardous waste were generated
and transported offsite during 1988. Seven industry groups accounted for over 85 percent
of the hazardous waste generated  and  transported.  Exhibit 3-12 displays the quantities of
RCRA hazardous wastes generated and transported offsite for a subset of industry groups,
while Appendix A, Table 2 shows  the quantities  of hazardous waste generated  and
manifested by all industry groups.  The primary  metals industry (SIC 33) generated and
transported nearly 40-million pounds of hazardous waste offsite.  This accounts for nearly
                                       3-26

-------
                                           Exhibit 3-12
                       Quantity of Hazardous Waste Generated and
                              Transported Off-Site by SIC Code
                                    Primary
                                    Metal
                                                        Electronic
                                                        & Electrical
                                                        Equipment
                                                              Transportation
                                                              Equipment
                                                                             Administration of
                                                                             Environmental
                                                                                Quality
                                                                    Instruments
                                                                    & Related Products
                                                                    f
                                 Fabricated:
                                 Metals
Chemicals
& Allied Products
                                                                          Electric, Gas, & Sanitary
 20  22  24  25  26  27  28   29   30   31   32  33  34  35  36  37  38   39   42   48   49  50  51  55   75   95

                                           Industries (by Sic Code)

Source: 1988 DEQ Quarterly Reports

-------
half of the total quantity of hazardous waste manifested in Oregon in 1988.  The other six

industry  groups  generated  and transported significantly smaller  (but still  substantial)

quantities of waste. The breakdown of these quantities follows:


             The  transportation equipment industry generated 9.8-milIion  pounds of
             hazardous wastes (SIC 37).

             The  instruments and related products industry generated 6.4-million
             pounds (SIC 38).

             The electronic and electrical equipment industry generated 6.3-million
             pounds (SIC 36).

             The  electric, gas, and sanitary industry generated 3.2-million pounds
             (SIC 49).

             The chemical and allied products industry generated 2.4-million pounds
             (SIC 28).
In addition to the seven  industry groups that accounted  for  over  85 percent of the

hazardous waste that was generated and transported in 1988, a large quantity (2.3-million
pounds) of hazardous waste was transported offsite by the administration of environmental

quality (SIC 95) industry group. This quantity of hazardous waste is likely to be the result

of emergency response cleanups and other waste management activities conducted by the
State.


      Six  types of Federal- and State-regulated hazardous wastes  are generated  and

transported offsite:
             D wastes, which  exhibit at least one  of  the four hazardous waste
             characteristics and are listed under 40 CFR 261.21-261.24

             F wastes, which are from nonspecific sources and listed as hazardous
             under 40 CFR 261.31

             K wastes,  which are hazardous wastes from specific sources and are
             listed under 40 CFR 261.32

             P wastes, which are specific discarded commercial chemical products,
             manufacturing chemical intermediates, or off-specification commercial
             chemical products identified as acutely hazardous wastes and listed
             under 40 CFR 261.33
                                        3-28

-------
             U wastes, which  are specific  discarded  commercial  chemical products,
             manufacturing  chemical  intermediates,  or  off-specification  commercial
             chemical products identified as toxic wastes and listed under 40 CFR 261.33
             X wastes, which  are  State-regulated  solid wastes that  include
             nonindustrial solid waste, polychlorinated biphenyls (PCBs), pesticide
             wastes, out-of-state regulated wastes, and lab packs.

       Exhibit 3-13 shows that K wastes were the largest type of RCRA waste generated
and shipped offsite (13,700 tons) in Oregon in 1988. (See Appendix A, Table 3 for the
quantities of each  RCRA waste generated.)  Interestingly, K061  and K088,  which are
produced only by the primary metal industry (SIC 33), accounted  for nearly all of the K
wastes generated.   The next largest group  of wastes generated is  the  D wastes (10,500
tons), which are generated by a variety of industry groups. The largest quantity of D waste
generated is D002 (a solid waste exhibiting  the characteristic of corrosivity, but not listed
as a hazardous waste), which is generated by the electronic and electrical equipment  (SIC
36) and the instruments and related products industries (SIC 38). The next largest group
of hazardous waste generated is State-regulated wastes. The primary State-regulated waste,
i.e., nonhazardous industrial waste (X004), accounts for over 75 percent  of the total State-
regulated wastes generated and transported  offsite.  Very little U wastes and P wastes are
produced and transported offsite.

       Because the SARA 313 toxic substance release information is from larger toxics
users  and the hazardous waste  generation information from the DEQ Quarterly Reports
represents a range of business sizes, direct comparisons between the analyses presented in
this section with the analyses in Section 3.2 cannot be made. However, a few observations
can be made about industries that are major large toxics users  and generators. With the
exception of the  paper and  allied products industry,  the industries  that  release major
volumes  of 313 toxic substances to the environment generally coincide with the industries
that are  the major  generators of hazardous waste.  The largest generator  of  hazardous
waste in  Oregon in  1988 was the primary metals industry (SIC 33), which released a  total
of 17,158,004 pounds of SARA 313 toxic substances to the environment, the second-largest
release by industry.  Similarly, the chemicals and allied products (SIC 28), electronic and
electrical equipment (SIC 36), transportation equipment  (SIC 37),  and instruments and
                                        3-29

-------
U)
                                                     Exhibit 3-13

                               Quantity of Hazardous Waste Generated and Transported
                                            Off-Site by RCRA Waste Code
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                           D Wastes
                                                  F Wastes
                                                               K Wastes
                                                                           U Wastes
                                                                                             P Wastes
                                                                                                      X Wastes
                                                        Types of RCRA Wastes
                    Source: 1988 DEO Quarterly Reports

-------
related products (SIC 38) industries all manifest relatively large quantities of waste as well
as release major quantities of SARA 313 toxic substances to the environment.  In contrast,
the paper and allied products  industry, which is  the largest releaser of SARA 313 toxic
substances to the environment, manifests relatively little hazardous waste.  This  likely is
due to the fact that the pulp and paper industry predominantly releases wastes to the air
and water and therefore is not RCRA regulated and generates relatively little manifested
RCRA and State-regulated hazardous waste.
3.4   CHARACTERIZATION OF BUSINESS ACTIVITIES OF GENERATORS AND
      TOXICS USERS
      Next, this report examines trends in economic activities, as measured by the number
of employees, to identify projected growth in waste  generating activities.   Exhibit 3-14
shows the total average employment in Oregon in 1988 for each industry group of interest.
Note that the employment figures in this and following exhibits include all businesses in
that industry group, not only toxics users and hazardous waste  generators.  Five industry
groups had individual total average employments of over 20,000 employees in 1988. The
lumber and wood products industry (SIC 24) employed an average of 70,000 people in 1988
and was the largest employer of any industry group.  The other four industries employing
over 20,000 people in  1988, mostly in nonmanufacturing  industries,  include the durable
goods industry (SIC 50), the auto dealers and service stations industry (SIC 55),  food and
kindred products manufacturing (SIC 20), and the trucking and warehousing industry (SIC
42).

      Exhibits 3-15a and 3-15b illustrate Oregon employment trends in the manufacturing
and nonmanufacturing industries, respectively, between 1987 and 1995. The data, gathered
from the  September 1990 Oregon Economic  and Revenue Forecast, project that of the
manufacturing industries, the machinery and electrical and electronic industries (SIC 35
and SIC 36) will undergo high  growth through 1995, reaching an estimated 40,000 people
employed in 1995.  Conversely,  the lumber and wood products industry (SIC 24) is expected
to shrink significantly between now  and 1995, decreasing  its  number of employees from
68,100 in 1987 to an  estimated 58,000 in 1995.
                                       3-31

-------
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                                            Oregon: Total Average Employment

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                  20  22  24   25  26  27  28  29   30  31  32  33  34   35  36  37  38  39  42   48  49  50  55  75

                                                             SIC Code
                 Source: Oregon Covered Employment and Payrolls, 1988

-------
                                         Exhibit 3-15a

                             Oregon Manufacturing Employment
                                    1987-1995 by SIC Code
   80
   70
M


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                                                                                                80

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                                                                                                70
                                                                                                60
                                                                                                50
                                                                                                40
                                                                                                30
                                                                                                20
                                                                                                10
      1987
                 1988
1989
1990
1991

Year
1992
1993
                                                                                 1994
                                                                                            1995
       Lumber and Wood (24)
         Instruments (38)
                                  Metals (33,34)


                                Food and Kindred
                                  Products (20)
                           Machinery (35,36)  Transportation Equipment (37)
                           Paper and Allied
                            Products (26)
                                     Printing & Publ. (27)
                                                         \J
      Source: Oregon Covered Employment and Payrolls. 1988

-------
                                          Exhibit 3-15b
                           Oregon Nonmanufacturing Employment
                                    1987-1995 by SIC Code
   400
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   300
   200
   100
      1987
               1988
1989       1990
                                                                                                400
                                                                                                300
                                                                                               - 200
                                                                                                100
1991       1992      1993      1994       1995
     Year
           Construction (15-17)
                                      Mining (10-14)
                                Transportation/Communication (40-49)
        Trade (50-58)
                           Finance, Insurance (60-67)
                               Services (70-89)
                                Government (91 -97)
                                   -a—B-
      Source: Oregon Covered Employment and Payrolls, 1988

-------
The data show more predominantly, however, that a number of manufacturing industries
are projected to  maintain or slightly  increase the  level  of  economic  activity.   Those
industries relevant to toxics use and hazardous waste generation include the primary metal
and fabricated  metal products industries (SIC 33  and 34), the transportation equipment
industry (SIC 37), the instruments and related products industry (SIC 38), the food and
kindred products  industry (SIC 20), the paper and allied products industry (SIC 26), and
the printing and publishing industry (SIC 27).  The implications of the trends in economic
growth in manufacturing industries is that the electrical and electronics industry, a major
generator of waste, and the machinery  industry can be seen in the future as releasing an
increasing  percentage   of toxic  substances  and  hazardous  wastes,  if  no  reduction
technologies are implemented.

      Of the nonmanufacturing industries, the data suggest  that several  industries will
experience  significant growth as indicated by employment levels. These industries include
the trade industry (SIC 50-58),  the services industry (SIC 70-89),  and the transportation
and communication industries (SIC 40-49).  Because some of the  companies included  in
these  industry groups are hazardous waste generators (see Exhibit 3-3), increased growth
may contribute to a larger quantity of hazardous wastes being  generated  and transported.
The number  of employees in the services industry is expected to reach 344,500 by 1995.
This projection represents a 40-percent increase from 1987 in the number of employees
for this industry. The trade industry and the transportation and communication industries
are expected  to  increase their  number  of employees by  24 percent and  18 percent,
respectively. As a result of the increased growth in the nonmanufacturing industries, wastes
generated from these industries may begin to account for a larger percentage of the total
waste generated.

3.5   SUMMARY OF FINDINGS

      An estimated 928 companies have been identified as toxics  users,  including LQGS
and SQGs, that will be impacted by the Toxics  Use Reduction  and Hazardous Waste
Reduction  program. These 928 companies will be required  to develop and  implement
                                       3-35

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toxics use reduction and hazardous waste reduction plans and a subset of these facilities
will be required to  set performance goals for reducing toxics usage and waste generation.


      Though the  available  information  sources  do  not provide  data  to describe

comprehensively all three groups (large toxics users, LQGs, and SQGs), enough data are

available to begin characterizing toxics users as well as describing toxics  use  and waste

generation patterns. The major findings based on the data can be summarized as follows:
             The majority of the toxics users and hazardous waste generators (90
             percent) are  located in the  western  half  of  Oregon,  primarily
             concentrated around the Portland area.

             The industries that collectively account for a large number of toxics
             users and hazardous waste generators are lumber and wood products
             (SIC 24), chemicals and allied products (SIC 28), primary metals (SIC
             33), fabricated  metal products (SIC 34),  electrical  and electronic
             products (SIC 36), transportation and warehousing (SIC 42), and auto
             dealers and service stations (55).

             Industry groups vary with respect to the quantities of toxic substances
             released and hazardous wastes generated.   While  several industry
             groups contain a large number of toxics users  (e.g. lumber and wood
             products, transportation and warehousing, and auto dealers and service
             stations), these same  businesses release relatively small quantities  of
             toxic substances or generate little waste. This has implications for
             technical assistance in that technical assistance targeted toward certain
             businesses  must be appropriate for small operations.

             The industries that release major quantities of SARA 313 toxic substances to
             the environment can be, but are not necessarily, the industries that generate
             and transport large quantities of hazardous  waste.' For example, the  paper
             and allied  products industry  (SIC 26) is the largest releaser of SARA 313
             toxic substances but it generates and  transports  relatively  little hazardous
             waste.  In contrast, the primary  metals industry (SIC  33) releases large
             volumes of SARA 313 toxic substances as well as large volumes of hazardous
             waste. Similarly, the chemicals and allied products (SIC 28), electronic and
             electrical equipment (SIC 36), transportation  equipment (SIC 37), and the
             instruments and related products (SIC 38) industries release relatively large
             volumes of toxic substances and generate large  quantities of hazardous waste.

             The three  major SARA 313 toxic substances  used by Oregon large
             toxics users in 1988 are sulfuric acid, acetone, and toluene.
                                        3-36

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The largest quantities of toxic substances (34 percent) are released as stack
or  point-source air emissions, followed by 22 percent  released to offsite
locations, 16 percent released as nonpoint emissions, 15 percent to POTWs,
and 13 percent to onsite land-management units.

Of RCRA waste types  generated and transported offsite, K wastes
account  for the  largest  volume,  with nearly all of the waste  type
generated by the primary metals industry.

Projections  into 1995  show that the  majority  of manufacturing
industries are expected to remain fairly stable. The only manufacturing
industries expected  to  show any high  growth are  the machinery
products (SIC 35), and electronic and  electrical products (SIC 36)
industries.  These industries are shown  to be  releasers  of toxic
substances or generators of hazardous waste; therefore, increases are
expected  in the quantities of toxic substances released or wastes
generated if no  reduction technologies are implemented.

High growth is  projected for certain  nonmanufacturing  industry sectors
containing industries that generate hazardous waste; therefore, an increasing
percentage of waste generated can be expected to come from those industries.
                           3-37

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            4. IDENTIFICATION OF DATA GAPS AND SUGGESTIONS
                           FOR COLLECTING BETTER DATA
4.1    SUMMARY OF EXISTING DATA GAPS

       The data presented in this report are a first step toward providing the DEQ with
the information needed to characterize the  existing universe  of toxics users.  However,
major data gaps exist, preventing the DEQ from fully characterizing the current universe
of toxics users and hazardous waste generators and preventing an effective measurement
of toxics use reduction and hazardous waste reduction.  Specifically, the data gaps can be
described as follows:

1.     Incomplete representation of companies for developing an accurate count of the
       large toxics users and hazardous waste generators in Oregon.

       To target technical assistance and recognition programs to large toxics users  and
hazardous wastes generators, the DEQ  must have some knowledge about the universe of
users and generators.   According to the act passed  by  the  Legislative  Assembly,  the
technical assistance should extend beyond large toxics users, LQGs,  and SQGs to cover
CEGs. As pointed out, the universe described in section 3.1 is based on either incomplete
data or information sources that are likely to provide underestimated counts of large toxics
users and hazardous waste generators. Efforts need to be taken to update the current list
of generators and to identify more accurately the overlap between the generator universe
and the large toxics user universe.

2.     Incomplete data on quantities of toxic substances used.

       Thus far-, the data sources used for this report have emphasized heavily the "output"
side  of the  production process; i.e., chemical releases and waste generation.   DEQ's
mission, however, is to examine toxics use as  well as hazardous waste generation.  TRIS
provides  information  on the  frequencies of toxic substances  used in manufacturing or
                                       4-1

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processing a product but does not provide data on the quantities of toxic substances used.
The DEQ Quarterly Reports do not provide any information on the types or quantities of
toxic substances used in manufacturing or processing that are associated with hazardous
waste generation.  The DEQ may want to re-examine the SARA 312 Reports or other data
sources, such as  the Comprehensive Assessment Information Rule (CAJR) Reports for
information on quantities of chemicals used as inputs. Specifically, the State Fire Marshal's
Office  is designing a new information system to manage the data from the SARA 312
Reports. This new system may allow the DEQ to more easily query for quantitative use
information on SARA 313 listed toxic substances.

       The CAIR Reports, a reporting mechanism under the Toxic Substance Control Act
(TSCA), require manufacturers, processors, and importers of  19 TSCA listed chemical
substances to provide detailed information on the substance used, the processes that use
or produce the substance, and the resulting waste streams. Ten of these TSCA listed
substances are also SARA 313 toxic  substances and  they are as follows:  acetamide,
phenanthrene, toluene-2,6-diisocyanate,  benzenamine, pyrene,  hydrazinecarboxamide,
toluene-2,4-diisocyanate, disulfide, chlorine, and toluene diisocyanate. Though CAIR covers
a limited subset of SARA 313 substances, the data from this source may be used to
supplement existing DEQ information. Furthermore, future iterations of CAIR reporting
may cover additional SARA 313 substances; thereby increasing the usefulness of the data
for characterizing Oregon toxics use patterns.

       In  addition  to  re-examining   the SARA  312  data and  the CAIR  Reports,
modifications to the TRIS Reporting Form also can serve as a mechanism for collecting
quantitative use data. Modifications to the TRIS Reporting Form are discussed in section
4.2.
                                       4-2

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3.    Incomplete data to describe toxic substance use and hazardous waste generation
      from smaller facilities  (e.g.. toxics users of less than 10.000 pounds per year  and
      small and conditionally exempt generators).
      The TRIS data provide a more complete picture of toxic substance use and releases
for the large toxics users, which includes a subset of large generators. These large toxics
users also are likely to be the most regulated facilities  (e.g., generate RCRA regulated
wastes, discharge under a NPDES permit, etc.) and may be subject to frequent reporting
requirements.  Toxic substance use and waste-release patterns for smaller facilities, on the
other hand, are less complete.  The DEQ Quarterly Reports,  the  source used to cover
LQGs and SQGs, contain data for only those generators that manifest hazardous waste.
The Quarterly Reports also do not provide any information  on the types of chemicals used
in the production  or manufacturing processes  that  produce  the  hazardous wastes.
Furthermore, little or no chemical use and release information is available for toxics users
of less than 10,000 pounds per year (including CEGs).  Although large toxics users are of
concern due  to the  volume of chemicals  used and released,  more complete  data are
available on this group.  The DEQ may, therefore, consider putting some efforts toward
collecting data on the LQGs and SQGs that are not large toxics users and on CEGs and
other small toxics users to develop a more comprehensive picture of usage and generation
patterns.   By having more knowledge of these smaller type facilities,  the  DEQ will  be
better able to target technical assistance.

      No available  source of information is ideal for collecting data on smaller-sized
facilities; however, the DEQ may want to re-examine the following  sources:
             The Hazardous Waste Biennial Reports - The DEQ may want to consider
             administering Biennial Reports in the future to SQGs as well as LQGs. By
             doing so, the DEQ will be able to (1) more accurately identify the universe
             of SQGs and (2) characterize hazardous waste generation patterns of smaller
             facilities.   Secondly,  the  DEQ  may want to consider administering the
             Biennial Report Form that collects identifying information (facility name and
             address and  generator status) to CEGs.   This would enable the DEQ to
             develop a more accurate count of CEGs.
                                       4-3

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             The SARA 312 Reports - As pointed out, a new information system is being
             developed for managing the SARA 312 Reports. If the new system provides
             more flexible searching routines,  the DEQ may be able to identify small
             toxics users (i.e., less 10,000 pounds per year)  of SARA 313 substances and
             to estimate quantities of toxic substances used by these smaller facilities.
4.     Format of the data  that do not permit an accurate estimate of the quantities of
      toxic substances released to the environment
      The TRIS report form allows respondents to enter releases with  less than 1,000
pounds  per month  as  point estimates  or a range (e.g.,  1-499, 500-999), while releases
greater  than 1,000 pounds are entered as point estimates.  Prior to entry into the TRIS
data base, all range  estimates are converted to a specific point estimate using the midpoint
of the range. It is not known to what degree the quantitative-release estimates presented
in section 3.2 are over- or underestimated. Because all large quantities were entered as
point estimates, the estimated totals of releases to the environment may  not be affected
greatly by  using midpoints of ranges.  When breaking down the  totals  and examining
releases by  toxic substances, however, small quantities of releases  are  more sensitive to
using midpoints of ranges  when representing  point  estimates.    For the purpose  of
estimating releases  to the environment, collection of point estimates rather than  ranges
would enable the DEQ to provide a more accurate picture of releases on a toxic substance
basis.
5.     Incomplete data for measuring progress made toward toxics use reduction and waste
      minimization.
      The above four data gaps directly impact the DEQ's  ability to accurately identify
the number of toxics users and generators and to characterize toxic substance use and
hazardous waste generation patterns. In order to go one step further and measure toxics
use and  hazardous waste reduction, additional data are required.   The  type  of  data
required  depends  on  the approach that the DEQ takes  to measure toxics  use  and
hazardous waste reduction. A common approach, as used in the Hazardous Waste Biennial
Reports and the TRIS Reports, is for the facility to  report the total quantity of a toxic
                                        4-4

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substance released or hazardous waste generated during the reporting year and the previous
year.  Using the facility's production ratio to account for any effects of the business cycle
on waste generation or toxic substance releases, the quantity of the waste/toxic substance
reduction during the reporting year would then be calculated.   Exhibit 4-1 provides
examples of estimating the quantity and percentage of a release that is reduced, using the
above approach.  These reporting mechanisms either provide the facilities with the option
to report reduction information or requires  only those facilities that have achieved toxics
release or hazardous waste reductions to report.  The result is that too few facilities have
provided this type of toxics release or hazardous waste reduction information through these
two reporting mechanisms and often times the data provided have been incomplete. The
data currently available through these two reporting mechanisms, therefore, cannot support
any reduction analyses.

      If the DEQ were to conduct its own data collection and use the above method for
estimating quantities of a toxic substance or hazardous  waste reduced,  it would need to
request  the following information from  companies for each  toxic substance or hazardous
waste minimized:
             Quantity of the selected toxic substance used or hazardous  waste
             generated during the reporting year
             Quantity of the selected toxic substance used or hazardous  waste
             generated during the previous year
             The number or quantity of the product produced during the reporting
             year that is associated most closely with the toxic substance release or
             hazardous waste generation
             The number or quantity of  the product produced during the previous
             year that is associated most closely with the toxic substance release or
             hazardous waste generation.
      There are, however, measurement problems associated with this approach used by
TRIS and the Biennial Reports in that reduction of a toxic substance or hazardous waste
cannot be appropriately measured at the facility level.  As reported by the National
                                        4-5

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                                    Exhibit 4-1.
        Examples of Estimating Quantities of Releases/Wastes Reduced

         Quantity of lead released during 1988 = 700 pounds.
         Quantity of lead released during 1987 = 500 pounds.

         The number of lead acid batteries produced during 1988  = 300.
         The number of lead acid batteries produced during =  150.
Calculation #1

a) Production ratio =  # of batteries produced in 1988
                    # of batteries produced in 1987

                 =  m  -  2
                    150

b)Quantity of waste in 1988 if
  reduction did not occur      =  1987 quantity x the production ratio

                            =  500 x 2 = 1000 pounds of lead

c) Quantity of waste reduced   =  1988 quantity before reduction
                               1988 quantity after reduction
d) Percent of waste reduced
                            =  1000 - 700 = 300 pounds of lead reduced

                            =      1988 quantity reduced    x 100 percent
                               1988 quantity before reduction

                            =   300 x 100 percent = 30 percent
                               1,000
Calculation #1

a) Normalized waste amount for 1987   =
                                          Quantity of release during 1987
                                      Number of batteries produced during 1987

                                            3.3
b) Normalized waste amount for 1988
                                      150

                                          Quantity of release during 1988
                                      Number of batteries produced during 1988

                                   =  TOQ = 2.3
                                      500

c) Percent of waste minimized  =  1988 wasteiproduct ratio - 1987 waste:product ratio x 100
                                      1987 waste: product ratio

                            =  2.3 - 3.3 x 100 percent  = 30%
                                 3.3
                                        4-6

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Academy of Sciences (NAS) in its 1990 report, Tracking  Toxic Substances at Industrial
Facilities:  Engineering  Mass Balance Versus Materials Accounting, waste  reduction  is
measured best  at the production unit level because some  quantities of waste minimized
may be masked when examined at the facility level. Conversely, a toxic substance release
reported as minimized at the facility level actually may not be minimized at the production
unit level.  Furthermore,  the current reporting systems do  not  suggest to  facilities a
standardized way of calculating  the production  ratio, which can lead  to problems when
comparing across facilities.

       To measure toxic substance/hazardous waste reduction at the production unit level,
the DEQ would need to collect the following types of information:

             Definition of a production unit
             Number and  types of production units per facility
             Types and quantities of inputs for each of the production units  at a
             facility
             Numbers and/or quantities of products produced from each production
             unit
             Types (individual toxic substances or wastes) and quantities of releases to all
             media from each production unit.

       Exhibit 4-1 shows equations that can be applied to each production unit and used
to calculate the decrease  (or increase)  in  a chemical or group of  chemical  releases.
Although this method may be more accurate, the effort needed by facilities to report waste
reduction data on a production unit level is likely to be too  time consuming and resource-
intensive. Furthermore, the NAS report warns that summing this data to the facility level
will mask results and the efficiency gained in measuring at the production unit level would
be lost. Also, production units change over time; thereby making reduction analyses across
time more difficult.  Taking into consideration these constraints, the DEQ  will need to
examine  the ability of Oregon toxics users to report at the production unit level and the
resources needed to analyze these data.

                                        4-7

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4.2    SUGGESTIONS FOR IMPROVING EXISTING REPORTING MECHANISMS


      Both Federal  and State reporting mechanisms were  examined for approaches to

improve the types of data  collected  for characterizing toxics use and waste generation

practices and  for measuring  toxics  use  and hazardous  waste reduction in Oregon.

Approaches for each level of reporting are given below.


4.2.1. Improvements to Federal Reporting Mechanisms


      The TRIS Form  R requests a variety of data, ranging from company identifying

information to toxic substances used  and released into the environment.  In comparison

to other Federal reporting mechanisms, TRIS remains the most comprehensive in providing

data on chemical inputs into the production process as well as toxic  substance releases.

Form R was examined  in light of the data gaps identified in the previous section,  two

modifications were identified to  help the characterization  of the toxics use and release

patterns. These  modifications are as  follows:
             Request information on the total quantity of the toxic substance used
             in the production process during the reporting period. Currently the
             form only requests a range for the quantity of the  toxic substance
             onsite at any time during the reporting year.  The quantity of a toxic
             substance onsite does not provide the type of information needed for
             developing a baseline for measuring waste minimization.  Instead, the
             quantity of a toxic substance used in manufacturing  or processing a
             product can  be used to gauge toxics  use  patterns and  serve as a
             measure for examining the relationship between, the chemical inputs
             and releases  in a production process.

             Request point estimates only for quantities of releases. As mentioned
             earlier, Form R allows the  respondent to specify a range for releases
             under 1,000 pounds per year.  To describe  more accurately releases,
             particularly for  smaller  volumes of chemicals, the form should be
             modified to allow only for point estimates.
       Modifications in regard to collecting more accurate toxics use and release reduction

data were not addressed because they would require extensive revisions to the TRIS report

or to other Federal reporting mechanisms. This issue, instead, is addressed in the following

section on modifications to State-reporting mechanisms.


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4.2.2   Improvement to State Reporting Mechanisms

       The primary reporting mechanism for the State is the annual progress reports that
are to be submitted by large toxics users, LQGs, and SQGs starting in September  1992.
The rules currently require this group of toxics users to report on progress made in regards
to each performance goal established, any amendments to the reduction plan, name, CAS
numbers and annual quantities of toxic substances used, waste codes and annual quantities
of hazardous wastes generated, and a narrative summary explaining the quantities used and
generated. Furthermore, toxics users  will need to provide information  on  the location of
the facility, SIC codes, EPA  identification number, and a Toxic Release Inventory (TRI)
identification number. Facilities  are given the option to provide a production  index for
hazardous waste/toxic substance requiring a performance goal.

       These data, collected through the Annual Progress Reports,  are at the facility level
and likely will be difficult  to analyze across  facilities  due to variations in  production
processes that use  toxic  substances and generate hazardous wastes  and variations in
estimation methods.  Furthermore, a comparison of an individual facility's data across time
may also be difficult due to changes in products from year to year.  Product changes will
have an effect on the quantities of toxic substances used and hazardous wastes generated
which  cannot be  identified through  a  facility  production index.  The  DEQ should
investigate the feasibility of collecting data on the quantities of toxic substances used and
wastes generated by production unit through the Annual Progress Reports. Section 4.1
discusses how this would allow for a more accurate estimation method of quantities of toxic
substances and hazardous wastes  reduced.  However, this method  is  extremely  resource-
intensive for facilities to implement.  An  alternative to requesting this information on the
Annual Progress Reports is to select a sample of facilities submitting Annual Progress
Reports and to conduct a case study using the  more detailed approach.
                                        4-9

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APPENDIX A

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                                 Table 1

                  Number of Oregon Generators that Manifest (Transport)
                     Hazardous Wastes Off-Site by Industry Group
SIC CODE
00
13
14
16
17
20
22
24
25
26
27
28
29
30
32
33
34
35
NUMBER OF
INDUSTRY GROUP COMPANIES
Unkown
Oil and Gas Extraction
Mining and Quarrying of Nonmetals
Heavy Construction
Construction - Special Trade
Food and Kindred Products
Textile Mill Products
Lumber and Wood Products
Furniture and Fixtures
Paper and Allied Products
Printing and Publishing
Chemical and Allied Products
Petroleum Refining and Related
Industries
Rubber and Misc. Plastic Products
Stone, Clay, Glass, Concrete Products
Primary Metal Industry
Fabricated Metal Products
Industrial and Commercial Machinery
119
1
2
7
2
10
1
43
2
11
5
18
2
3
4
15
41
23
Source: 1988 DEQ Quarterly Reports
                                         A-l

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                                Table 1

                  Number of Oregon Generators that Manifest (Transport)
                    Hazardous Wastes Off-Site by Industry Group
36
37
38
39
40
41
42
43
44
45
47
48
49
50
51
52
53
54
55
Electronic and Electrical Equipment
Transportation Equipment
Instruments and Related Products
Miscellaneous Manufacturing Industries
Railroad Transportation
Local and Suburban Transit and Inter-
urban Highway Passenger Transportation
Motor Freight Transportation and
Warehousing (Trucking/Maintenance
Services)
US Postal Service
Water Transportation
Air Transportation
Transportation Services
Communications
Electric, Gas, Sanitary Services
Wholesale Trade - Durable Goods
Wholesale Trade - Nondurable Goods
Building Materials, Hardware, Garden
Supplies, Mobile Home Dealers
General Merchandise Stores
Food Stores
Automotive Dealers and Gasoline
Service Stations
41
18
11
3
3
7
65
1
1
3
7
15
24
32
8
1
2
1
106
Source: 1988 DEQ Quarterly Reports

                                          A-2

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                                 Table 1

                  Number of Oregon Generators that Manifest (Transport)
                     Hazardous Wastes Off-Site by Industry Group
59
67
72
73
75
76
80
82
86
87
89
91
92
94
95
96
97

Miscellaneous Retail
Holding and Investment Offices
Personal Services
Business Services
Automotive Repair
Miscellaneous Repair Services
Health Services
Educational Services
Membership Organizations
Engineering, Accounting, Research
Management Services
Services, NEC
Executive, Legislative, and General
Government
Justice, Public Order and Safety
Administration of Human Resource
Programs
Administration of Environmental
Quality
Administration of Economic Programs
National Security
Total
2
1
2
4
38
5
9
15
8
2
2
13
1
1
12
17
11
805
Source: 1988 DEQ Quarterly Reports


                                          A-3

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                                          Table 2




                       Quantity of Hazardous Waste Generated by industry Group
SIC Code
00
13
14
16
17
20
22
24
25
26
27
28
29
30
32
33
34
Industry Group
Unknown
Oil and Gas Extraction
Mining and Quarrying of
Nonmetals
Heavy Construction
Construction - Special
Trade
Food and Kindred Products
Textile Mill Products
Lumber and Wood Products
Furniture and Fixtures
Paper and Allied Products
Printing and Publishing
Chemical and Allied
Products
Petroleum Refining and
Related Industries
Rubber and Misc. Plastic
Products
Stone; Clay, Glass, and
Concrete Products
Primary Metal Industry
Fabricated Metal Products
Quantity of Hazardous
Waste Generated (in pounds)
2,058,000
2,080
6,040
13,780
5,880
24,580
1,320
1,218,000
5,040
619,020
24,140
2,379,080
246,940
396,640
118,580
39,853,760
3,347,060
Quantity of Hazardous
Waste Generated (in tons)
1,029.00
1.04
3.02
6.89
2.94
12.29
0.66
609.00
2.52
309.51
12.07
1,189.54
123.47
198.32
59.29
19,926.88
1673.53
Source: 1988 DEQ Quarterly Reports
                                             A-4

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                                           Table 2
                        Quantity of Hazardous Waste Generated by Industry Group
SIC Code
35
36
37
38
39
40
41
42
43
44
45
47
48
49
50
51
Industry Group
Industrial and Commercial
Machinery
Electronic and Electrical
Equipment
Transportation Equipment
Instruments and Related
Products
Misc. Manufacturing
Industries
Railroad Transportation
Local and Suburban Transit
and Interurban Highway
Passenger Transportation
Motor Freight Transportation
and Warehousing
US Postal Service
Water Transportation
Air Transportation
Transportation Services
Communications
Electric, Gas, Sanitary
Services
Wholesale Trade - Durables
Wholesale Trade - Nondurables
Quantity of Hazardous
Waste Generated (in pounds)
360,580
6,309,980
9,883,580
6,372,320
4,780
181,540
34,620
460,920
3,740
1,320
10,540
1 68,840
63,480
3,261 ,020
388,640
113,280
Quantity of Hazardous
Waste Generated (in tons)
180.29
3,154.99
4,941 .79
3,186.16
2.39
90.77
17.31
230.46
1.87
0.66
5.27
84.42
31.74
1.630.51
194.32
56.64
Source: 1988 DEQ Quarterly Reports
                                            A-5

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                                           Table 2




                       Quantity of Hazardous Waste Generated by Industry Group
Quantity of Hazardous Quantity of Hazardous
SIC Code Industry Group Waste Generated (in pounds) Waste Generated (in tons)
52
53
54
55
59
67
72
73
75
76
80
82
86
87
89
91
92
Building Materials, Hardware,
Garden Supplies, Mobile Home
Dealers
General Merchandise Stores
Food Stores
Automotive Dealers and
Gasoline Service Stations
Misc. Retail
Holding and Investment
Offices
Personal Services
Business Services
Automotive Repair
Misc. Repair Services
Health Services
Educational Services
Membership Organizations
Engineering, Accounting,
Research, Management Services
Services, NEC
Executive, Legislative, and
General Government
Justice, Public Order, and
Safety
19,720
6,620
140
321 ,340
5,320
1,900
2,080
286,120
81 ,520
29,580
25,100
917,660
208,700
880
10,420
50,220
17,780
9.86
3.31
0.07
160.67
2.66
0.95
1.04
143.06
40.76
14.79
12.55
458.83
104.35
0.44
5.21
25.11
8.89
Source: 1988 DEQ Quarterly Reports




                                                 A.-6

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                                            Table 2




                        Quantity of Hazardous Waste Generated by Industry Group
SIC Code
94
95

96

97

Industry Group
Administration of Human
Resource Programs
Administration of
Environmental Quality
Administration of
Economic Programs
National Security
Total
Quantity of Hazardous
Waste Generated (in pounds)
460

2,329,920

1 32,220
1 1 ,600
82,398,420
Quantity of Hazardous
Waste Generated (in tons)
0.23

1,164.96

66.11
5.80
41,199.21







Source: 1988 DEQ Quarterly Reports
                                             A-7

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                 Table 3:
Quantity of Hazardous Waste Generated and Manifested
    (Transported) Off-site by RCRA Waste Code

RCRA Waste
Code
D001
D002
D003
D004
D005
D006
D007
D008
D009
D010
D013
D014
D016

F001
F002
F003
F005
F006
F008
F009
F011
F019

K001
K061
K088


Transported
(Tons)
1,761.92
3,092.98
46.92
85.12
1,796.26
948.05
1,495.25
1,244.33
0.78
11.14
7.50
39.25
35.39

764.89
357.26
698.45
102.65
2,643.94
3.21
17.37
0.03
51.20

212.80
7,192.56
6,236.93


Transported
(Pounds)
3,523,840
6,185,960
93,840
170,240
3,592,520
1,896,100
2,990,500
2,488,660
1,560
22,280
15,000
78,500
70,780
Total D Wastes:
1 ,529,780
714,520
1 ,396,900
205,300
5,287,880
6,420
34,740
60
102,400
Total F Wastes:
425,600
14,385,120
12,473.860
Total K Wastes:
Totals by
RCRA Waste
Code (Pounds)













21.129,780









9.278,000



27,284,580
Source: 1988 DEQ Quarterly Reports
                         A-8

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                 Table 3:
Quantity of Hazardous Waste Generated and Manifested
    (Transported) Off-site by RCRA Waste Code

RCRA Waste
Code
U051
U060
U080
U121
U122
U134
U151
U188
U190
U210
U226
U228
U239

P108
P020
P039

X001
X002
X003
X004
X005
X006
X007


Transported
(Tons)
1.36
0.62
0.82
0.05
0.66
0.19
1.56
2.06
2.90
0.69
0.13
52.00
0.50

0.40
0.57
0.25

188.46
1 ,664.67
38.01
6,327.42
1.31
3.12
207.13


Transported
(Pounds)
2,720
1,240
1,640
100
1,320
380
3,120
4,120
5,800
1,380
260
104,000
1,000
Total U Wastes:
800
1,140
500
Total P Wastes:
376,920
3,329,340
76,020
12,654,840
2,620
6,240
414,250
Total X Wastes:
Totals by
RCRA Waste
Code (Pounds)













127,080



2,440







16,860,230
Source: 1988 DEQ Quarterly Reports
                           A-9

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                                                               Table 4
                                  Quantity of Toxic Substances Released to Each Medium by Industry Group
SIC Code
20
22
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
51
Fugitive or
Non-point Air
Emissions
94,541
0
1,205,076
19,969
1,193,543
16,140
654,391
3,923
626,019
1,000
750
2,370,341
198,873
101,104
137,442
725,027
27,128
201 ,375
2,480
Stack or Point-
Source Air
Emissions
10,000
0
1 ,243,475
0
4,384,058
5,746
1 ,838,302
3,750
667,563
250
44,820
1 ,407,382
275,181
260,552
257,321
735,273
3,434,479
0
0
Discharges to
Water Bodies
1,000
0
2,839
0
210,325
0
5,029
501
10,054
0
0
106,134
500
0
393
0
0
0
0
Underground
Injection
0
0
0
0
0
0
1
0
0
0
0
0
0
0
0
0
0
0
0
Releases to
Land
257,488
0
10,092
0
580,113
0
169
0
0
0
0
4,921 ,657
0
0
0
5,400
0
0
0
Discharges to
POTWs
16,629
12,000
250
0
6,367,418
0
6,388
1,000
1
72,800
250
63,053
49,625
0
336,612
225
150,144
0
0
Releases to
Other Off-Site
Location
0
0
105,571
0
982,477
851
49,764
66
23,257
17,500
99,300
8,289,437
60,673
121,900
330.778
187,026
40,121
0
540
I
I—•
o
        Source: 1988 Toxic Release Inventory System Reports

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              Table 5



Composition of Releases by Industry Code
SIC Code
20



22
24




























Toxic Substance
Ammonia
Phosphoric Acid
Isopropyl Alcohol
Chlorine Dioxide
Chlorine
Ammonia Sulfate
Toluene
Formaldehyde
Acetone
Xylene
Ammonia
Methanol
Methyl Ethyl Ketone
Methyl Isobutyl Ketone
1,1,1-Trichloroethane
Phenol
Naphthalene
Dibenzofuran
Pentachlorophenol
Anthracene
Copper
Ammonium Nitrate
Arsenic
Zinc
Copper Compounds
Phosphoric Acid
Hydrochloric Acid
Chromium Compounds
Methylenebis
Chromium
Sulfuric Acid
Ammonium Sulfate
Biphenyl
Arsenic Compounds
Zinc Compounds
Quantity Released
341 ,329
16,629
16,000
4,200
1,500
12,000
727,975
464,062
443,486
298,340
150,341
145,557
143,600
92,000
30,300
27,100
13,030
9,990
8,516
6,117
1,496
750
671
659
542
502
500
500
500
250
250
250
211
55
3
               A-ll

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Table 5 (continued)
SIC Code
25


26






















27
28
















Toxic Substances
Methyl Ethyl Ketone
Toluene
Xylene
Methano!
Chlorine
Toluene
Chloroform
Chlorine Dioxide
PCBs
Ammonia
Acetone
Zinc
Sulfuric Acid
Catechol
Formaldehyde
Glycol Ethers
Chromium
1,1,1-Trichloroethane
Ammonium Nitrate
Copper
Chromium Compounds
Phenol
Hydrochloric Acid
Propylene
Copper Compounds
Barium Compounds
1,1,1-Trichloroethane
Methanol
Ammonia
Acetone
Formaldehyde
Styrerie
Xylene
toluene
MetHyf Ethyl Ketone
Dichloromethane
Phenol
Chlorine
Dimethyl Phthalate
Ammonium Nitrate
1 ,2,4 Trimethylbenzene
Hydrochloric Acid
Glycol Ethers
Epichlorohydrin
Quantity Released
9,646
9,022
1,301
8,872,930
875,278
778,000
750,721
640,255
590.482
252.392
248,255
176,000
156,860
118,881
102,317
64,000
23,730
22,300
12,000
1 1 ,950
9,800
6,383
4.650
250
250
250
22,737
1,033,815
594,878
235,417
159,419
110,945
98,793
85,624
51,777
42;767
36,216
34,800
15,610
15,600
6,538
5,401
2,964
2,564
              A-12

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Table 5 (continued)
SIC Code
28 (cont.)



















29










30












Toxic Substance
Ethylene Glycol
1,1,1 Trichloroethane
Vinyt Acetate
Nitric Acid
Maleic Anhydride
NA
Sulfuric Acid
Methyl Isobutyl Ketone
Barium Compounds
Butyl Acrylate
Methyl Methacrylate
Phthalic Anhydride
Chromium Compounds
Dibutyl Phthalate
Methyl Acrylate
Copper Compounds
Toluene-2,4-Diisocyanate
Lead Compounds
Methylenebis
Butyl Benzyl Phthalate
Cyclohexane
Benzene
Toluene
Xylene
Ethylene Glycol
Methanol
Cumene
Ethylbenzene
1 ,2,4-Trimethylbenzene
Asbestos
Zinc Compounds
Trichloroethylene
Dichloromethane
Styrene
Acetone
Di(2-ethylhexyl)Phthalate
1 ,1 ,1-Tricholorethane
Sulfuric Acid
Methylenebis
Decabromodiphenyloxide
Antimony Compounds
Aluminum Oxide
Toluene-2,6-Diisocyanate
Toluene-2,4-Diisocyanate
Quantity Released
2,540
2,310
2,000
1,800
1,525
1,500
1,438
1,402
1,107
1,000
1,000
750
534
500
500
500
250
250
9
1
2,423
1,750
1,250
750
750
750
500
500
500
66
1
484,692
435,222
237,725
106,754
28,264
11,451
10,160
5,826
3,650
2,150
500
250
250
              A-13

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Table 5 (continued)
SIC Code
31


32



33
























Toxic Substance
Ammonia
Chromium
Su If uric Acid
Aluminum Oxide
Dichloromethane
Zinc Compounds
Barium Compounds
Aluminum Oxide
Zinc Compounds
Zinc
Lead Compounds
Trichloroethylene
Freon113
Chromium Compounds
Methyl Isobutyl Ketone
Glycol Ethers
Cyanide Compounds
Manganese
Hydrogen Fluoride
Chlorine
1,1,1-Trichlorothane
Ammonia
Compound Beta
Barium Compounds
Nickel Compounds
Cobalt Compounds
Lead
Hydrochloric Acid
Aluminum
Copper Compounds
Acetone
N-Butyl Alcohol
Quantity Released
70,150
20,900
500
97,020
43,800
2,400
1,900
11,583,923
1,807,750
494,450
363,250
358,258
347,171
261 ,882
205,950
197,326
191,947
178,350
158,858
151,720
135,450
1 22,500
1 01 ,327
95,250
63,958
51 ,403
43,750
36.590
32,305
30,895
26,918
19,600
              A-14

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Table 5 (continued)
SIC Code
33 (cont.)













34




















35






Toxic Substance
Methyl Ethyl Ketone
Chromium
Phenol
Manganese Compounds
Dichloromethane
Nitric Acid
Butyl Benzyl Phthalate
Nickel
Tetrachloroethytene
Copper
Sulfuric Acid
Methylenebis
Titanium Tetrachloride
Ethylene Glycol
Trichloroethylene
Toluene
Xylene
Methyl Ethyl Ketone
1,1,1-Trichlorethane
Sulfuric Acid
Tetrachloroethylene
Copper Compounds
Methyl Isobutyl Ketone
N-Butyl Alcohol
Hydrochloric Acid
Nitric Acid
Zinc Compounds
Cyanide Compounds
Chlorine
Copper
Manganese
Methanol
Zinc
Phosphoric Acid
Ammonia
Freon 1 1 3
1,1,1-Trichloroethane
Aluminum Oxide
Dichloromethane
Hydrochloric Acid
Xylene
Toluene
Quantity Released
17,000
15,650
11,850
11,511
8,000
6,931
6,872
6,700
6,177
3,376
1,493
913
500
250
125,744
107,324
98,699
62,479
51 ,643
49,975
34,900
14,250
14,048
11,976
4,011
3,969
3,050
750
750
500
250
250
250
24
10
117,802
108,712
73,500
66,250
42,000
40,413
34,879
              A-15

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                  Table 5 (continued)
SIC Code
Toxic Substance
Quantity Released
     36
Sulfuric Acid
Acetone
FreonHS
Glycoi Ethers
Hydrochloric Acid
Ammonia
Nitric Acid
Methanol
1,1,1-Trichloroethane
Xylene
Lead Compounds
Trichloroethylene
Copper Compounds
Hydrogen Fluoride
Ethylene Glycoi
Formaldehyde
Phosphoric Acid
Copper
Chromium
Antimony	
           353,133
           206,840
           135,648
            49,259
            48,348
            44,326
            37,328
            35,050
            30,585
            22,774
            21,845
            21,197
            15,500
            14,060
            13,413
             6,950
             3,691
             2,535
                42
                22
     37
Styrene
Acetone
1,1,1-Trichloroethane
Toluene
Methyl Ethyl Ketone
Xylene
Chromium Compounds
N-Butyl Alcohol
Cyanide Compounds
Methanol
Ethylene Glycbl
Asbestos
Glycoi Ethers
Methyl Methacrylate
Manganese
Chromium
Nickel
Hydrogen Fluoride
Sulfuric Acid
           500,157
           358,141
           293,361
           211,211
           168,690
            39,364
            22,584
            14,965
            11,233
            11,032
             9;40b
             5,400
             2,116
             1,980
             1,772
               750
               750
                25
                20
                              A-16

-------
                   Table 5 (continued)
SIC Code
38












39
51

Toxic Substance
Acetone
Toluene
Methyl Ethyl Ketone
Freon 113
Glycol Ethers
N-Butyl Alcohol
1 ,1 ,1 -Trichloroethane
Trichloroethylene
Copper Compounds
Tetrachloroethylene
Hydrochloric Acid
Sulfuric Acid
Nitric Acid
Styrene
Xylene
2,4-D
Quantity Released
1,824,213
470,532
468,105
197,252
154,864
90,500
53,799
26,858
26,500
8,429
250
250
250
201 ,375
2,480
540
The shaded area includes those chemicals comprising
the "Other" category in Figure 3-11b

Source: 1988 Toxic Release Inventory System Reports
                             A- 17

-------