Memorandum for the Docket
December 7, 2015
Teleconference call with Paula Cantor (Ohio), Hope Wright (Illinois), Cpan Lee (ORCR), Kathy Lett (ORCR) and Jim O'Leary (ORCR)
Subject: SQG Re-notification
The above participated in a teleconference call to discuss concerns associated with the Agency's proposed rule requiring SQGs to re-notify every two years one month prior to when LQGs and TSDFs must submit their Biennial Reports.
While both Paula and Hope saw the need for requiring SQGs to re-notify, both expressed concerns about the feasibility and effectiveness of the proposal. 
Hope said a higher priority would first be for Illinois to clean up their existing data base of SQGs before initiating any re-notification process. They have SQGs going back into the 1980s. She also expressed concerns about initiating any new efforts without obtaining additional EPA financial support since state resources are declining. Hope also believes the Agency should wait until E-manifest becomes operational because every state will then have the ability to cross-walk manifest data with their Site ID data to identify "operational" SQGs from generators no longer SQGs. That would include summing the volumes of waste for all manifested data by a facility to determine if they fell within the SQG volume range or were really LQGs. She mentioned Michigan already doing this because they collect manifest data. Hope also suggested EPA send out a mailing/email to all SQGs to update their Site ID form and send the form into their state for processing. 
Paula mentioned that it was still a worthwhile endeavor and a few positive things they could do, such as having the state advertise that SQGs must now re-notify, asking their TSDFs to help in making their SQG customers aware of this new requirement (if finalized). For new SQGs, make them aware they will be required to re-notify. They also expect lots of notifications as a result of the Pharms rule; i.e., LQGs becoming CESQGs or SQGs.
Jim O'Leary also brought up the idea of using the BR's Waste Received (WR) form where TSDFs identify every generator they receive waste from, and then cross-walk that information over to the Site ID form to identify their generator status. From this, the states could focus on "outliers" or those SQGs in a state's data base who did not manifest any HW during the reporting year. This approach would not so much focus on explicit re-notification as much as identifying inactive SQGs. Hope thought this approach would require more work than basic re-notification since her data base is old with lots of inactive facilities. Paula expressed concerns too.    

        
