[Sqg-program] FW:CHAZSQG Generator Status Field Change 10_13_03

Emery, Charles sqg-program@lists.dep.state.fl.us
Thu, 16 Oct 2003 10:10:40 -0400


I like what Jack has said in his 10/15/03 reply to Gus, last paragraph.
Everyone should reread that. I also like what Glen indicated, I think it =
was
Glen, that it would be better to rate a facility at what it mostly =
likely
would be as opposed to some abnormal occurrence which raised its status.
Having said that please be careful in assuming the 12 month averaging of =
a
facilities monthly generation rate is the way to do things. It is not. =
Some
industries clearly have seasonal periods of increase waste generation =
and are
clearly SQG's 3-6 months out of the year and then revert back to being a
CESQG the remainder of the time. I'm not sure how the data base should =
rate
them, but I know from a regulatory point of you we would rather see the
facility meet the SQG requirements all year round even thought they dip =
below
the threshold amount of 100 kg (220 pounds) in a month. It is better to =
be
safe versus sorry.

-----Original Message-----
From: Perrigan, Glen=20
Sent: Wednesday, October 15, 2003 3:57 PM
To: SQG Program Listserver
Subject: [Sqg-program] FW:CHAZSQG Generator Status Field Change 10_13_03


I am passing this thread statewide to SQGers since you guys may have an
opinion. If you do lets hear it by responding to this thread. Read below =
for
details...

Issue: Should it be assumed, when entering wastes into chazsqg, that =
wastes
are mostly generated in the same month or are mostly generated in =
different
months. This will have a bearing on the generator status which is based =
on
the wastes codes you add to the system.


=20
-----Original Message-----
From: Griffith, John=20
Sent: Wednesday, October 15, 2003 10:23 AM
To: 'Agustin Olmos'; bobsny528@alltel.net; Gorton, Donna; Perrigan, Glen
Cc: Herb@coj.net; HSMITH@coj.net; Jtinsman@coj.net;
Juta_Karibo@doh.state.fl.us; mundy@ncfrpc.org; =
golmos@ns1.co.alachua.fl.us;
firemarshal@putnam-fl.com
Subject: RE: Generator Status Field Change 10_13_03


Gus,

I see your point, but as there are 12 months in a year - therefore 1/12
chance of the two high monthly amounts falling in the same month, the
probabilities favor separate months. My method assumes the county's =
ability
to manually correct the 8%(1/12) discrepancy by increasing the status =
level
(CESQG->SQG->LQG) without being able to reduce it and under-report the =
status
as based on annual averaging.=20

If I assume concurrent monthly totals and allow counties to reduce the
status, they will have to reduce the status more often (92% probability =
based
on not expecting Safety-Kleen and a lab pack in the same month).  This
requires allowing Counties to reduce status based on this probability =
and
increase based on waste in storage, etc., while simultaneously checking =
for
annual averaging limits. It's just more complex programming based on, I
think, a less likely scenario. All in all, the probability of a site =
actually
changing either way is pretty small and generally doesn't affect our
statewide counts significantly either way, so I went for the less =
complicated
way of doing things.

If I hear that it is more likely that the two monthly amounts do fall in =
the
same month, and a majority wants to do it the other way, I'm surely =
willing
to discuss it.  But based on an Ivory Twin Tower mathematical analysis, =
I'm
thinking -- default to the most probable (lower) status.  Anyway, when =
you
guys see somebody subjecting themselves to more regulation based on not
understanding the consequences of their benign actions, I'm hoping you =
are
counseling them to change their ways and become better environmental =
citizens
by more carefully managing their generation in the future.=20

Jack Griffith
Florida Department of Environmental Protection
MS 4555
2600 Blair Stone Road
Tallahassee FL, 32399-2400
850-245-8748



-----Original Message-----
From: Agustin Olmos [mailto:Gus@smtp.co.alachua.fl.us]=20
Sent: Wednesday, October 15, 2003 9:26 AM
To: bobsny528@alltel.net; Gorton, Donna; Perrigan, Glen; Griffith, John
Cc: Herb@coj.net; HSMITH@coj.net; Jtinsman@coj.net;
Juta_Karibo@doh.state.fl.us; mundy@ncfrpc.org; =
golmos@ns1.co.alachua.fl.us;
firemarshal@putnam-fl.com
Subject: Re: Generator Status Field Change 10_13_03


I think we are missing the point here.  I don't think the argument is =
about
how to calculate the generator status (I agree with Jack) or how is done =
in
the field (in most cases probably dividing by 12 as Bob suggested).  The
point, or at least my point, was to get an agreement on the default set =
up of
the database.  Unless I am missing something, (and it would not be the =
first
time) the database can either assume that all HW streams entered are
generated in the same month (may overestimate the generator status of =
the
facility) or it can assume that all the HW stream are generated in =
different
months (current set up, may underestimate the generator status of the
facility).  Either way could be wrong depending on specific conditions.  =
I
rather overestimate as a default, but that works for me because of the =
way my
inspection program
is set up.   Gus


>>> "Bob Snyder" <bobsny528@alltel.net> 10/14/03 10:24AM >>>
MessageI heartily agree with Jack.  While technically, as I understand =
RCRA,
a facility generating LQG quantity in a month would be subject to LQG
standards for that month, it would be way off track to change their =
staus for
5 years or force a change of status submittal to EPA and 1) possibly =
cause
even more and 2) damage the credibility of the SQG program even further =
with
RCRA.

Maybe the objective of the SQG program needs to be re-examined.  I =
hardly
think the goal of the creators was to base everything on a monthly basis =
in a
5-yearly program.  This is not RCRA and maybe for County purposes, =
simply
dividing the yearly total by 12 makes more sense.

Isn't a part of the present problem a need to be more consistent with =
the
RCRA database?  Changing an SQG to LQG for 1 or 2 months activity will =
not
help obtain consistency.

Bob S.
  ----- Original Message -----=20
  From: Griffith, John=20
  To: Perrigan, Glen ; Gorton, Donna=20
  Cc: firemarshal@putnam-fl.com ; bobsny528@alltel.net ;
Juta_Karibo@doh.state.fl.us ; Jtinsman@coj.net ; Herb@coj.net ;
HSMITH@coj.net ; golmos@ns1.co.alachua.fl.us ; mundy@ncfrpc.org=20
  Sent: Tuesday, October 14, 2003 9:41 AM
  Subject: RE: Generator Status Field Change 10_13_03


  If somebody generates 120 lbs in July and 120 lbs in August, that does =
NOT
make them an SQG. Get over it people!  We do need to allow Counties to
increase the Generator status in the sequence CESQG ->SQG
->LQG but not decrease the status (below the computed status). If they
show SQG annual waste (or single monthly) I don't want them to be able =
to put
them down as CESQG without deleting or re-working wastes to make them
NON-HAZ. The computed status is designed to set the absolute bottom =
limit for
the generator status, while allowing for the possibility for occasional
bumping up. Status is computed for the MONTH anyway, so putting a site =
down
as LQG because 2 of their wastes got dumped on the same day in one year =
out
of 5 is an incorrect assessment of the situation. DEP wouldn't make them
re-notify, and the SQG program shouldn't show them as having an =
incorrect
status for 5 years by default. If a county wants to look at it =
differently,
then we can let them, but it would be w! rong.

  Jack Griffith
  Florida Department of Environmental
  Protection
  MS 4555
  2600 Blair Stone Road
  Tallahassee FL, 32399-2400
  850-245-8748



    -----Original Message-----
    From: Perrigan, Glen=20
    Sent: Monday, October 13, 2003 11:59 AM
    To: Gorton, Donna; Griffith, John
    Cc: Joe Guidry (firemarshal@putnam-fl.com); BOB SNYDER
(bobsny528@alltel.net); Juta Karibo (Juta_Karibo@doh.state.fl.us); Jean
Tinsman (Jtinsman@coj.net); Herbert Wilson (Herb@coj.net); Harry Smith
(HSMITH@coj.net); Gus Almos (golmos@ns1.co.alachua.fl.us); Dwayne Mundy
(mundy@ncfrpc.org)
    Subject: Generator Status Field Change 10_13_03


    Donna,

    Can't recall if I called you on this. Received some feedback from =
some
users on the waste amounts entered and its interaction with the =
generator
status field. Assume you add 2 wastes. The amounts (max monthly amount) =
for
each waste do not exceed the CESQG status (<220lbs/mo). However when =
added
together the combined wastes would exceed the CESQG status and would =
move the
status to SQG. This assumes that the waste is generated in the same =
month.
This is not always the case. The program currently assumes the waste was
generated in different months and does not change the Status from CESQG =
to
SQG. The status field cannot be overwritten.=20

    The county person should be able to update the status field if =
needed
(from CESQG to SQG, etc). Also a note similar to the one you give when=20

    Second it was the consensus of the people in the meeting (NE =
District SQG
Roundtable) that it should be assumed that the waste is generated in the =
same
month and thus the generator status field should automatically change =
based
on the wastes entered. I talked to Jack G about this and his feeling is =
the
opposite. I will talk to the counties on this issues and get a statewide
consensus unless Jack can convince me otherwise.

    So now the only change I am asking is that the generator status =
field be
allowed to be overwritten by the the user if needed. I will get back =
with you
on the other issue later. Comments and suggestions from the county folks =
cc
in this email are welcome. Thanks.

    Glen Perrigan=20
    FDEP, Hazardous Waste Management Section=20
    2600 Blair Stone Road  MS-4555=20
    Tallahassee, Florida 32399-2400=20
    Florida Department of Environmental Protection=20
    850-245-8749 Fax:  850-412-0528=20
    E-mail: glen.perrigan@dep.state.fl.us=20
    Website:   www.dep.state.fl.us/waste=20




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