July 31, 2000

MEMORANDUM

TO: Peggy Vyas, EPA

FROM: Steven Brown, Margaret James, and Gary Light

SUBJECT: SQG Up-Date

____________________________________________________________________________

This memorandum presents the results of our effort to resolve several ambiquous categories of 

SQGs identified in our May 18 memorandum. To gain insights on these “potential SQGs”, we 

contacted the following individuals as per our memorandum:

¢ Ms. Beth McDonough, Massachusetts (6/14/00);

¢ Mr. Robert Finkel, Pennsylvania (6/15/00);

¢ Ms. Hope Wright, Ilinois (6/15/00);

¢ Mr. Richard Johnson, New Jersey (6/16/00); 

¢ Mr. Ernie Robbins, New York (6/19/00); 

¢ Ms. Beverly Allen, EPA (6/21/00); and

¢ Mr. Les Ott, EPA (7/10/00).

The remainder of this memorandum is organized by category of potential SQG. For each 

category of potential SQG, we summarize the defining characteristics of the group, report the 

insights gained from our calls, and recommend whether and how we think the group should be 

included in the final SQG count.

1. RCRIS- Only SQGs (Groups A and D)

As explained in our May 18 memorandum, RCRIS contains 142,561 generators who 

notified as the end 1996 as SQGs, but who do not appear in the 1997 BRS as 

generators who manage waste on site or ship wastes off site according to Waste 

Receipt data. These generators are identified as Group A in the May 18 memo. RCRIS

identifies an additional 7,020 such facilities that notified to RCRIS in 1997. These are 

Group D generators. All told, there are 149,581 RCRIS-only SQGs. As we have 

discussed during our recent series of conference calls, there are several plausible 
explanations for these facilities. Some of these explanations, if true, would suggest that

these facilities be counted and others suggest that they not be counted:

¢ Plausible explanations that suggest that these facilities should not be counted 

include (1) that they never generated or stopped generating hazardous waste 

because their business plans changed or they went out of business; (2) that the 

wastes they generated turned out not to be RCRA hazardous wastes; or (3) that 

these generators are actually CESQGs who never renotified as to their change in 

status.to be real. 

¢ Plausible explanations that suggest that these facilities should be counted include 

(1) that they only generate wastes that are managed in on-site wastewater treatment

systems that are exempt from RCRA permitting, and (2) that they only generate 

wastes that are managed in recycling units that do not require RCRA permits. 

1.1 Results of Calls

As might be expected, our calls were far from conclusive with respect to these potential 

explanations. Everyone we spoke to indicated that it is quite possible that facilities 

submit a notification form and then never show up in BRS because the information on 

the notification form is based on what facilities anticipate doing. If in fact they do not 

generate any waste or generate only exempted waste when they originally thought that 

they would be a SQG, then they will not show up in BRS. Thus, some of these facilities 

may not actually generate any waste despite the fact that they notified RCRIS.

As we speculated in our May 18 memo, our telephone conversations confirmed the 

wide variation among states in the percentage of RCRIS generators subject to the 

Federal RCRA program is in part because some States have systematically sought to 

determine the status of RCRIA-Only generators while other States have not. Some 

States are updating their RCRIS generator information with the latest 3010 notification 

information and others are not. For example, Mr. Johnson and Ms. McDonough 

indicated that NJ and MA are regularly reviewing 3010 forms and working with their EPA

Region to input the data into RCRIS. RCRIS shows that in NJ and MA, 84 percent of 

New Jersey’s RCRIS-only SQGs and 47 percent of Massuachussets’ are not subject to 

the RCRA program (see Attachment 2 from May 18 memo). However, both Mr. Johnson

and Ms McDonough noted that because facilities frequently do not renotify when their 

RCRA status changes (e.g., they go out of business), their RCRIS data still probably 

overstates the actual universe by up to 20 percent.

Unlike in New Jersey and Massachusetts, Ms. Wright from Illinois made it clear that her 

state and her region are not entering renotification information into RCRIS. In fact, she 

reported that EPA Regional staff do not want the updated 3010 forms. Thus, RCRIS 

information from this area rarely gets updated. Her insight is consistent with RCRIS 

data showing that only 300 of Illinois’ 8,313 RCRIS-only SQGs are not subject to the 

RCRA program (i.e., facilities are not being purged when they go out of business or 

otherise no longer generate federal hazardous waste). Based on the RCRIS data, it 
appears that most other midwest states are not updating their generator information 

either. 

The RCRIS-only SQG information from New York and Pennsylvania both suggest that 

large portions (97% in New York and 80% in Pennsylvania) are not subject to Federal 

RCRA requirements. Neither Mr. Robbins of New York nor Mr. Finkel of Pennsylvania 

could explain the generator information from their state. However, Mr Robbins 

expressed the view that RCRIS information was of little value because it is outdated and

because so many generators are not included in the database (see below).

Ms. Allen and Mr. Ott from EPA noted that the information provided by the states is 

consistent with their experience. They said that the quality of RCRIS data is 

undermined because most states do not have renotification requirements, lack program 

interest, and/or do not have adequate resources to up-date RCRIS. Mr. Ott, who 

worked on RCRIS data issues for the WIN initiative, said that the major outcome of his 

work with WIN was that a renotification requirement would be needed to improve the 

data quality of RCRIS. Both he and Ms. Allen suggested that, were possible, we rely 

more on BRS because its data quality is generally better. 

. Recommendation Regarding RCRIS-Only SQGs

Based on our follow-up research, it is clear that many RCRIS-only SQGs are no longer 

operating as hazardous waste generators, either because they went out of business or 

significantly curtailed hazardous waste generation, and therefore should not be counted 

in EPA’s estimate. It is also clear that some generators in this group have been 

confirmed, and likely do not appear in BRS because they are not subject to BRS 

reporting (e.g., the generate only recyclable materials or manage all of there wastes in 

exempt wastewater treatment systems on-site). Therefore, we recommend including a 

portion of these facilities in your estimate.

To determine the portion to include in the estimate, we recommend using data and the 

experience of Massachusetts and New Jersey. Their combined efforts to up-date the 

RCRIS data found that 31 percent of the RCRIS-only SQGs were legitimate. They also 

suggested that only 80 percent of these are legitimate if one considers that some 

generators don’t renotify. Taken together, these insights suggest that approximately 25 

percent of the RCRIS-only SQGs should be counted. This equates to 40,327 SQGs.

2. BRS-Only SQGs (Groups C4 and C8)

Treatment and disposal facilities that receive waste from off-site are required to identify 

the facilities, including SQGs, from which they receive wastes. This information is 

reported on form WR. Because SQGs are not required to submit Biennial Reports, one 

way to identify potential SQGs from BRS is to identify generators who appear on WR 

forms but do not submit IC forms. After conducting this analysis as reported in our May 

18, memo, we further checked to determine how much waste these potential BRS 

SQGs ship off site (by adding up all of the quantities attributed to them on WR forms) 
and checking their status in RCRIS. In taking these additional steps, we identified 

54,013 facilities that ship less than 13.2 tons, the amount that would necessarily make 

them and LQGs for at least part of the year, but that are not in RCRIS as SQGs. These 

“BRS-Only” SQGs include 46,095 facilities that ship less than 1.32 tons, the amount that

would necessarily make them SQGs (not CESQGs) for at least part of the year (Group 

C4). BRS-Only SQGs also include 12,134 facilities that ship more than 1.32 tons 

(Group C8). As with the RCRIS-only SQGs, there are a wide variety of plausible 

explanations for why these facilities appear in BRS but not in RCRIS:

1. The primary plausible explanations that suggest that these facilities should not be 

counted are that (1) the incorrect ID number was reported for a legitimate facility that

is counted elsewhere or (2) that the facility is a temporary generator. It is also 

possible that these facilities should not be counted because they are CESQGs, but 

this does not explain why they are not in RCRIS. 

2. Plausible explanations that suggest that these facilities should be counted include 

(1) that RCRIS in not up to date, or (2) that the facily’s ID number did not follow 

EPA’s guidelines and could not be entered in RCRIS.

2.2Results of Calls

As noted above, many of the contacts we spoke to report that RCRIS is not necessarily 

up to date, however none could provide any quantitative basis on which to estimate the 

extent to which RCRIS data quality contributes to the problem. However, we were able 

to gain insights regarding why legitimate facilities might not show up in RCRIS.

The first reason why BRS generators do not show up in RCRIS is that temporary 

generators, indicated by a P in their ID#, are given an ID# but are never entered into 

RCRIS by many states. Interviewees from IL, NY, and NJ all confirmed that this is 

common practice. Thus, it appears that P IDs are not ongoing generators and could 

thus be given broken out from the base SQG list. Of the 54,013 SQGs/CESQGs that 

RCRIS has no record of, Margaret identified 4,986 P generators. Ms. Allen said that 

RCRIS can accept P generators, but that it was likely that states never entered them 

into RCRIS and instead kept track of temporary generators separately.

The second reason why BRS generators do not show up in RCRIS is that some states 

are issuing ID#s that do not meet EPA standards and thus never get entered into 

RCRIS. Ms. McDonough of IL and Mr. Robbins of NY were especially helpful on this 

issue. They explained that EPA procedures require that all SQGs have an EPA 

approved ID#. However, some states (and many TSDs/transporters) also require 

CESQGs or generators of state-only waste to get an EPA ID# anyway, and some states 

give them off-spec ID#s (i.e., numbers not meeting the EPA-approved format of three 

letters followed by numbers). Mr. Robbins indicated that some states are also giving out

off-spec ID#s for SQGs and LQGs despite EPA procedures. Furthermore, he noted that

the check-digit routine for ID#s did not work properly for WR forms in 1997. This 
problem allowed certain off-spec numbers into BRS. However, some states, such as 

Illinois, have addressed this problem by manually screening the data. Nearly everyone 

we spoke to considered this to be one of their biggest problems with the WR forms. 

Thus, many SQGs, and even some LQGs, showing up on the WR forms will never get 

into RCRIS. Second, the check-digit routine that was used to verify EPA ID#s on the 

1997 WR form did not work properly. Thus, WR typos were not caught. This problem 

should be addressed in the 1999 BRS. 

Finally, Mr. Robbins indicated that he thinks that many of the EPA ID#s that were issued 

a long time ago when EPA was using HWDMs (the precursor to RCRIS) never made it 

into RCRIS. However, Ms. Allen confirmed that the old ID numbers did get into RCRIS, 

that none were ‘lost’ in the conversion from HWDMs to RCRIS. She also commented 

that many legitimate EPA ID#s have strings of zeros in them, as the numbers were 

given out sequentially starting at zero.

Unfortunately, our efforts to contact Safety Kleen were unsuccessful, and none of our 

state contacts could comment on the extent to which CESQGs are reported separately 

on WR forms. 

2.2 Recommendations Regarding BRS-Only SQGs

Given the problems noted above with respect to EPA ID numbers, we recommend counting the 

Group C8 generators, except those whose ID numbers clearly indicate that the facility is a 

temporary generator. We recommend not counting group C4 facilities on the grounds that they 

are likely to be either CESQGs, or erroneous ID numbers.

1. Recommended SQG Count Summary

In our memorandum of May 18, we presented several categories of potential SQGs 

based on the information available on them from RCRIS and BRS. Exhibit 1 presents 

updated count for each of the categories and subcategories discussed in our May 18 

memorandum and what we recommend doing with the category in light of the additional 

information obtained from our telephone inquiries. Updated diagrams showing the 

breakdown of categories and subcategories are attached. As indicated in Exhibit 1, our 

best estimate of the actual number of federally regulated RCRA SQGs operating in 

1997 is 113,879.

3.1 Limitations

The two greatest uncertainties in this analysis remain (1) how many RCRIS-only SQGs 

manage wastes on-site and are not subject to BRS reporting, and (2) how many of the 

facilities that ship less than 1.32 tons are CESQGs versus partial-year SQGs.
Exhibit 1

Summary of Recommended SQG Count

Category Number In Category Number to be 

counted

Rationale for 

Number to be 

counted

Group A 137,208 34,011 Portion confirmed by

NJ and MA data 

(See Section 1.2)

Group B 67,271 67,271 BRS and RCRIS 

agree

C1 7,836 0 Likely CESQG

C2 3,450 0 Likely CESQG

C3 3,043 0 Likely CESQG

C4 42,449 0 Likely CESQG or 

Typo (See Section 

2.2)

C5 1,430 1,430 BRS supercedes 

RCRIS

C6 1,797 1,797 BRS supercedes 

RCRIS

C7 989 989 BRS supercedes 

RCRIS

C8 6,578 6,578 BRS supercedes 

RCRIS

D 7,020 1,740 Portion confirmed by

NJ and MA data 

(See Section 1.2)

E 63 63 BRS supercedes 

RCRIS

F 4,986 0 Temporary 

Generators

Total 284,120 113,879