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

Agustin Olmos sqg-program@lists.dep.state.fl.us
Thu, 16 Oct 2003 11:18:27 -0400


I think we all agree with what Jack and Glen said.  My question was only
regarding the default setting for the database. I think you can argue
either way on the percent probabilities and I have no understanding on
the programming difficulties involved. My reason to suggest the higher
default is based on a regulatory point of view.  Like Charles said: 
better safe than sorry.  I can see merit on both options but if we are
taking votes, my vote is for the higher default.  Gus

>>> Charles.Emery@dep.state.fl.us 10/16/03 10:10AM >>>
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 
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.


 
-----Original Message-----
From: Griffith, John 
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. 

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. 

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] 
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 ----- 
  From: Griffith, John 
  To: Perrigan, Glen ; Gorton, Donna 
  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 
  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 
    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. 

    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


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




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