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Subject: [DCHAS-L] CSB Provides Guidance on Accidental Release Reporting Rule

Date: Sep 2, 2022 12:22 UTC

Author: CHAS membership <membership**At_Symbol_Here**DCHAS.ORG>

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Subject: Re: [DCHAS-L] Hats in lab

Date: Sep 2, 2022 18:14 UTC

Author: Amber Wise <amber.wise**At_Symbol_Here**GMAIL.COM>

From: Jeffrey Lewin <jclewin**At_Symbol_Here**MTU.EDU>

Subject: Re: [DCHAS-L] Acetone recycling system recommendation

Date: Sep 2, 2022 12:44 UTC

Reply-To: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**Princeton.EDU>

Message-ID: <CAEwQnqj2dP1CuU5BcZZ-0yKHxgBaokiOqY91he+qQqLQ1csQQg**At_Symbol_Here**mail.gmail.com>

In-Reply-To: <DM6PR05MB39791E124FBFB397DC1079EEFA789**At_Symbol_Here**DM6PR05MB3979.namprd05.prod.outlook.com>

Demystify: 
I don't have recommendations for a system, but will note if you haven't already, you need to discuss this with your University's hazardous waste managers....1) confirm you do not need a treatment permit (in MIchigan, at least, you do not - but some states may have stricter rules than the minimum federal rules). and 2) you need to discuss how you count these solvents in your monthly waste generation - especially if you are in a designated Small Quantity Generator or Very Small Quantity Generator status.

As an example, here is a subset of Mi rules:

2.7.9a On-site Solvent Recycling
Facilities that use large volumes of solvents should consider recycling the used solvents on-site.
See Chapter 12.1.4.d for information on solvent pollution prevention options. It is not necessary
to obtain a hazardous waste permit to recycle solvents at the site of generation, but there are
requirements to operate a solvent distillation unit or still at the site where the used solvents are
generated. If recycling on-site generated solvents:
• Manage the solvents both prior to and after recycling under the appropriate hazardous or
liquid industrial by-products regulations depending on the type of solvent.
• Keep a log of the amount of waste treated on-site. This amount needs to be included when
calculating the company’s hazardous waste generator status (see sample calculation below).
These logs can also be helpful to document how you handled your waste when you want to
sell your business and a Baseline Environmental Assessment is being done (see Chapter 7).
How do I calculate the amount of hazardous waste generated from a recycling still?
The following scenario is given as an example on how to count the used solvent reclaimed through
a recycling unit when determining your generator status. The original solvent is counted once
during the calendar month, plus any additional solvent added during the month, and any
generated still bottoms. The count starts new every calendar month. Counting waste is addressed
in Rule 205(5) of the Part 111 rules.

[see the link above for detailed description of how to count the waste generation]

Jeff



On Thu, Sep 1, 2022 at 5:16 AM Loren E Yeager <loren.yeager**At_Symbol_Here**northwestern.edu> wrote:

Does anyone have a recommendation for an acetone recycling system?

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--
Jeff Lewin
Director of Chemical Laboratory Operations
Research Integrity Office
Laboratory Operations
205 Lakeshore Center 
Michigan Technological University

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