Date: Thu, 19 Mar 2009 10:58:54 -0500
Reply-To: Judy Morgan <JMorgan**At_Symbol_Here**ENVSCI.COM>
Sender: DCHAS-L Discussion List <DCHAS-L**At_Symbol_Here**LIST.UVM.EDU>
From: Judy Morgan <JMorgan**At_Symbol_Here**ENVSCI.COM>
Subject: Re: Procuring Acetonitrile
Comments: To: "Crooks, Steven"
In-Reply-To: A<57BB782DA0EE7D4E9DA4C42A2C3FEFC43703F7**At_Symbol_Here**RTPWEXC17.RCC_NT.RTI.ORG>

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:

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** | 

-----Original Message-----
From: DCHAS-L Discussion List [mailto:DCHAS-L**At_Symbol_Here**] 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

-----Original Message-----
From: DCHAS-L Discussion List [mailto:DCHAS-L**At_Symbol_Here**] 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 J. Sampson, Ph.D.
Environmental Manager & Chemical Hygiene Officer Division of Innovation, Te
chnology and Quality General Mills, Inc.

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