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:
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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.
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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.
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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.
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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
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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.
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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
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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.
-------
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.
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
_
-
-
-
.
-
-10
"HA
43
f ~ '
18
11 (Sf
^ 5 [']
JlfHt
15
_ rt < r .{
o :i;
41
f~?
>f:
23
41
(^~
^:
18
(*Tl
R
N
11
fH4iffi!j
65
iC
4
15
m
pill
24
32
.<=
::f:
FP
10
';::
6
38
fn
>>
x: ! 12
' 'r~l
^ III
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
_
-
14
f!
l"T?
se
i
5
1
f=j3
13
47
.^
*
[xtJ
iU
i
ni
fxl)
12
<=s
f:
j
1=1)1^11
19
27
-------
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
15
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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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F Wastes
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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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Exhibit 3-14
Oregon: Total Average Employment
in 1988 by SIC Code
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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
rt 60
CO
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iE 50
80
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Z 10
-Q-
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)
-aB-
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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.
4-8
-------
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
-------
APPENDIX A
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
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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
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