February 9, 2016
Memorandum to the Docket
From: Jim O'Leary
Subject: Telephone conversation with David Case, Environmental Treatment Council (ETC)
On February 4, 2016 Cpan Lee and I had a telephone conversation with David Case of ETC to better understand his concerns about modifying the Biennial Report (BR) to require LQGs to report all hazardous wastes generated in the reporting year. Currently, BR regulations focus on hazardous waste generated and shipped off-site during the reporting year. This has the potential impact of LQGs not reporting wastes generated between October 1 and December 31 of the reporting year since LQGs have up to 90 days to accumulate hazardous waste on-site before sending off-site to a permitted TSDF. 
Currently, TSDFs use manifest data to provide information to LQGs to complete BR submissions, if not actual BR submission reports.
   
  

