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NK CUP? a hair raising issue?
- Subject: NK CUP? a hair raising issue?
- From: email@example.com
- Date: Thu, 5 Apr 2001 11:25:16 -0500
- Delivered-To: firstname.lastname@example.org
- Delivered-To: email@example.com
- List-Name: p2tech
- Organization: K-State Research & Extension
- Reply-To: firstname.lastname@example.org
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
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
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
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?
Any input/support on this issue will be appreciated.