First WOW!! thank you all for your support and assistance.
Meeting with a higher level rep from the dtsc on the 25th.
In addition I have reason to believe that what we call diversion paperwork (diverted from the waste stream) exceeds what they require as "inventory". We track weights and dates on all material going into and out our of re-use departments. and can demonstrate a past history of doing so going back years. The dtsc agent did not bother to ask what sort of tracking system we might actually have before running off with a false assumption and slamming us with a class 1 violation.
If my assumptions are correct than all we have left is the "speculative acumilation" nightmare.
Speculative acumilation:
two examples of where this is actually a good thing and then how it does not apply in this case
In general this is to keep people from taking waste, collecting it into big poisonous piles and then walking off leaving the public to deal with the problem.
More specific example. When sb-20/50 came into play there was a legitimate concern about people collecting material with the expectation that the state would eventually pay for its destruction. This was a legitimate problem and as many vendors have huge material streams and if allowed to stockpile and then bill the state, would have bankrupted the new system.
I have no problem with either of the above examples.
How this is misapplied in this case.
there is a minimum value on everything that we set aside and a simple phone call could turn the whole damn collection into cash. This is at worst case bulk electronics and valued at 3-5 cents a pound but in most cases much higher value. So no big pile of nasty for the dtsc to have to deal with. (although if I were to take this option collectors would probaly curse my name for generations)
In the second example above, We are actually taking material out of the state payment system and as such saving the state money so I cannot determine how this determination is in the states best interest.
So no clean up and no state payments on this material. Whats the problem?
In fact since our various re-use projects are things that we fit in around paying the bills I cannot recall a single project that did not take at least a year. For example the beowulf cluster development is at least 10 years old. The electric vehicle project (dead van,dead electric forklift,a ups as the charging system, a buttload of ups batteries,motor controllers from old industrial milling equipment,) is over two years old and expected to roll sometime next year.
In additiion our hydrogen vehicle program (we are quite probably the only people on earth who have gotten a 1969 lincoln continental to run on hydrogen) requires huge amounts of metal hydride as a fuel storage medium. We have two options to aquire this. buy it (very expensive) or recover it from metal hydride batteries. Based on current flow will take another year before we have enough storage to be comparable to a standard gas tank. So a 460cid internal combustion engine thats cleaner than a prius (The exhaust is water) and all the information on how we did it provided to the public for free is not in the publics best interest?
And if we fail the information is still valuable and the failure would be disposed of in the proper manner so again why do we need to abandon this project after a year?
So is free commodity supercomputing and completely repurposed zero emission vehicles something that the dtsc wants to discourage? How does the state profit from this? Do I throw them away?
Tuesday, September 18, 2007
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