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NK CUP? a hair raising issue?



P2tech:
I'm feeling very out-of-touch because I just heard about this and 
would like to know what everyone else is doing about it in their 
states:
I just discovered that a nationally known solvent service provider 
(i'll just nickname:NK) is proposing a "continuous use program, CUP" 
for their solvent services program for some businesses (large users 
using select solvent) here in Kansas.  The program will allow 
cleaning solvent users to send the product back to this NK as a raw 
product NOT a hazardous waste.  NK will then use ALL of this solvent 
as a wash up material for ALL of their equipment at their facility 
and then THEY will declare it a waste.  Which means the business user 
does not have to claim this solvent towards their monthly hazardous 
waste generation rates!
I have three very major concerns here:  
number one: my state regulators told me EPA was supporting this 
activity at the national level, and possibly Region VII also
number two that this service will be mostly for large businesses 
using a "quality" solvent, which seems to be a discriminatory 
practice against smaller businesses that are not offered this 
opportunity or may be out of their service area for this opportunity
number three is that in Kansas a generator has to count his solvent 
poundage (a reusable, raw product also?) every time it goes into a 
still for recycle, towards their hazardous waste monthly generation 
rate!
a fourth concern is that the state will lose business revenues from 
decreased hazardous waste generations fees charged through our 
biennial reporting/fee collection program, which may affect some 
technical assistance program funding.
This activity will also reduce a businesses commitment to reduce 
hazardous material use, not to mention, what else might get put in 
that solvent before it leaves their facilities...
The Kansas regulatory authority is currently trying to make a 
decision whether or not to allow this practice in Kansas. I was told 
yesterday that many states have already approved this and some have 
not. If the NK company truly uses the solvent as a raw material it is 
a legal manuever under RCRA regulations, however, after working in 
the oil refining industry for 10 years I have some doubts about a re-
refining processors' ability to use truly utilize that much solvent 
for parts/equipment washup procedures. I would like to see the 
operational plans that quantify and verify that this company will be 
able to wash this much equipment on a daily basis, with the amount of 
solvent that could eventually be brought into this program.

Is there anyone out there in P2-Land fighting this? (Or am I the only 
one that sees this as a slap in the P2-Face?) Doesn't this activity 
seem like it will undo what many of us have been working to do for 
years or am I just having a really bad day? Does anyone know of a 
legal angle to fight this activity?

I feel this practice will promote irresponsible use/waste of solvent, 
create an unfair business advantage to "large, high quality" solvent 
users (does this equate to large businesses?), and will be 
discriminatory to businesses not using NK services or recycling 
solvents onsite themselves and having to count it as a hazardous 
waste. 

If you have worked with your state to prevent this program from being 
accepted would you please email me directly?  Or if you know what 
organization (departments and department head names) NK has been 
working with at the national level and Regional levels, could you 
please forward their contact information to me?

Sherry Davis 
Any input/support on this issue will be appreciated.