Recycling solvent for reuse actually keeps you out of the TSDF category. I f you are treating it for other purposes, then you are considered a TSDF. The RCRA Orientation manual explains this pretty well. It can be found at the following link: http://www.epa.gov/epawaste/inforesources/pubs/orienta t/rom31.pdf Hope this helps! Judy Morgan, MS, REM VP, Director of Technical & Regulatory Affairs Environmental Science Corporation 12065 Lebanon Rd |Mt. Juliet, TN 37122 Office 615-773-9657| Mobile 615-347-5418 jmorgan**At_Symbol_Here**envsci.com |www.envsci.com -----Original Message----- From: DCHAS-L Discussion List [mailto:DCHAS-L**At_Symbol_Here**list.uvm.edu] On Behalf Of Cr ooks, Steven Sent: Thursday, March 19, 2009 6:33 AM To: DCHAS-L**At_Symbol_Here**LIST.UVM.EDU Subject: Re: [DCHAS-L] Procuring Acetonitrile Sounds like potentially viable minimization and addressing a supply issue. It also sound a lot like "treatment".... Curious to know if operator is a TSDF and how others have grappled with the "treatment" interpretation for those who are only LQGs. Steve Crooks, MS, CIH, CSP Mgr., Occupational Health & Environment RTI International Occupational Health and Environment Bldg 11 203B 3040 Cornwallis Road POB 12194 Research Triangle Park, NC 27709-2194 TEL 919.316.3910 FAX 919.541.1222 =A0 -----Original Message----- From: DCHAS-L Discussion List [mailto:DCHAS-L**At_Symbol_Here**list.uvm.edu] On Behalf Of Li st Moderator Sent: Wednesday, March 18, 2009 11:00 AM To: DCHAS-L**At_Symbol_Here**LIST.UVM.EDU Subject: Re: [DCHAS-L] Procuring Acetonitrile From: Carolyn SampsonDate: March 18, 2009 10:41:27 AM EDT (CA) Subject: RE: [DCHAS-L] Procuring Acetonitrile We started capturing our waste and distilling it several years ago as a cos t savings so we have inadvertently protected ourselves at least a little. We use a simple benchtop still (located in a hood). You need to account fo r the water content. (84% acetonitrile, 16% water) Also, depending on your sensitivity needs, you can simply re-use the waste. That causes a baseline shift, of course, but you can sometimes deal with that for a short while. Good luck! Carolyn Carolyn J. Sampson, Ph.D. Environmental Manager & Chemical Hygiene Officer Division of Innovation, Te chnology and Quality General Mills, Inc. =0D Notice: This communication and any attached files may contain privileged or other confidential information. If you have received this in error, please contact the sender immediately via reply email and immediately delete the message and any attachments without copying or disclosing the contents. Tha nk you.=0D
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