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 Sampson 
Date: 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 
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nk you.=0D

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