From: Ray Cook <raycook**At_Symbol_Here**APEXHSE.COM>
Subject: Re: [DCHAS-L] solvent drums
Date: Wed, 24 Apr 2019 08:34:04 -0500
Reply-To: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**PRINCETON.EDU>
Message-ID: 978BF4D5-9294-4FB1-BEF3-1D36804231F6**At_Symbol_Here**
In-Reply-To <2092188078.2200710.1556110029817**At_Symbol_Here**>

As I recall, there are two key points here:

The SPCC regs only apply here if the liquids can reach waters of the US and 

the aggregate amount of storage is at least 1320 gallons in containers of 55 gallons or more.  

If the liquids cannot reach a watercourse or a drain leading to one, it doesn't apply. If less than the amount specified, it also doesn't apply.

Having said that, adequate provisions to address any anticipated spill to keep it an "incidental" spill will keep you out of HAZWOPER reponse mode and also assure minimal disruption and enhance personnel safety.

Kindest Regards,

Ray Cook, MS, CIH 2000-2016
CSP ret.
I Cor 1:18
In omnia paratus
Sent from my iPhone

On Apr 24, 2019, at 7:47 AM, Monona Rossol <0000030664c37427-dmarc-request**At_Symbol_Here**> wrote:

Ralph, I think I've tracked it down.  And Cornell may have the hazmat law right, but when the spill can get to water, it comes under the Clean Water Act (CWA) instead.  I THINK I tracked down the start of this issue in the following:

CWA:  The Spill Prevention Control and Countermeasures (SPCC) rule - 40 CFR 112.7
(c) Provide appropriate containment and/or diversionary structures or equipment to prevent a discharge as described in =A7 112.1(b), except as provided in paragraph (k) of this section for qualified oil-filled operational equipment, and except as provided in =A7 112.9(d)(3) for flowlines and intra-facility gathering lines at an oil production facility. The entire containment system, including walls and floor, must be capable of containing oil and must be constructed so that any discharge from a primary containment system, such as a tank, will not escape the containment system before cleanup occurs....

The wording in the SPCC is vague, so the next stop was to go to the EPA's "SPCC Guidance for Regional inspectors."  And there you see in Chapter 4 the calculations for containment and berms all based on the 110%.  Now just how that happened is most likely in some letter of interpretation somewhere.  But this is the procedure that the EPA INSPECTORS follow.

And for above ground storage tanks, the 110% rules has been adopted by local regulators just about everywhere I looked, and the original impetus usually was a response to an environmental disaster.  One example:

The discovery of leaking underground storage tanks in the Silicon Valley in the early 1980's led the Santa Clara County Fire Chief's Association to create a task force to develop a Model Hazardous Materials Storage Ordinance (HMSO) which reads:

The required volume of secondary containment specified in the HMSO regulation is dependent upon the number of primary containers being stored. Where only one vessel will be present, the ordinance requires that the secondary containment system be of sufficient capacity to contain 110% of the volume of the primary container. ...  Where multiple primary containers are stored, the ordinance requires the secondary containment system be designed to contain whichever of the following is greater: 1) 150% of the volume of the largest container being stored: or 2)10% of the aggregate internal volume of all the primary containers..

CANADIAN =E2=80=98s adopted similar rules for Aboveground Storage Tank Secondary Containment Maintenance (per the Technical Standards and Safety Act, 2000, S. O. 2000, c. 16):
Secondary containment shall be inspected on a regular basis, not less than once per week, to ensure the removal of any accumulated surface water, snow, drums, portable containers, objects or product that would reduce the fluid volume capacity to provide a volume of liquid at least 10% greater than the volume of the tank, or a volume of liquid not less than the volume of the largest tank plus 10% of the aggregate volume of all the other tanks, or 10% greater than the volume of the largest tank, whichever is greater (dike with more than one tank).

Bunds should be sized to hold 110% of the maximum capacity of the largest tank or drum. This will allow some latitude for the addition of foam during response to the emergency. 

The next step is not a clear, but it seems that local regulators picked up this best practice and applied it to any regulated liquid in almost any amount.  I have multiple examples in the Massachusetts and Rhode Island areas where the rules are set to avoid exceeding the incredibly strict limits set by the Narragansett Bay (water) Authority.  But many schools across the country have the same 110% policy. 

TEMPLE UNIVERSITY'S policy does it best in cool flow chart and bullet points:
• Secondary containment for a single container will be 110 percent of the primary container.
• Secondary containment for multiple containers will be 150 percent of the largest containers volume or 10 percent of the aggregate volumes of all the containers, whichever is greater.

SUMMARY, When Ralph first asked this question, I didn't know where it all started.  I just knew that the code checker on almost every building I've planned (over 80) would come up with this same 110% figure when asked to find the local code applicable to containment.  Now, maybe, I've found  the origin in the Clean Water Act for oil spills.  But today it is in the EPA compliance directive and has spread to local rules and is applied as best practice to any regulated liquid that could spill to water including ground water here and abroad. 

I suggest all CHOs ask for copies of their school's industrial waste water permit to see which substances are regulated by your local POTW and need to be kept out of sink and floor drains, and then check all of the local codes before setting policy for containment.  Or follow best practices like this 110% rule for regulated stuff and you can't go wrong.


-----Original Message-----
From: ILPI Support <info**At_Symbol_Here**ILPI.COM>
Sent: Wed, Apr 24, 2019 6:14 am
Subject: Re: [DCHAS-L] solvent drums

I have no expertise in EPA regs (and I'm quite sure that if there was a federal regulations version of Jeopardy that Monona would be the Ken Jennings of that genre), but Mr. Google tells me 

264.175(b)(3) The containment system must have sufficient capacity to contain 10% of the volume of containers or the volume of the largest  container, whichever is greater.  Containers that do not contain  free liquids need not be considered in this determination;

So if you have four 55 gallon drums = 220 gallons, you meet that requirement with a 22 gallon sump.  As paragraph (b)(3)(5) discusses periodic removal of accumulated leaked material, I presume the intent of the code here is not meant to contain a catastrophic total failure of all 4 drums, but the sorts of incidental leaks and spills that might occur from time to time.  Obviously, there may be other regs that might apply.

Rob Toreki

   Interactive Learning Paradigms, Incorporated (ILPI)
Training, environmental/occupational health & safety consulting
Ph: (856) 449-8956, Fax: (856) 553-6154, sales**At_Symbol_Here**
Lab & safety supplies?  Visit

On Apr 23, 2019, at 7:37 PM, Monona Rossol <0000030664c37427-dmarc-request**At_Symbol_Here**LISTS.PRINCETON.EDU> wrote:

I've always wondered how you figure those meet the EPA containment criteria of holding 110% of the volume of whatever is stored on the containment tray.  

I was at a big movie location where they also modified the stunt cars.   They had HUGE deep trays underneath that clearly could hold 110% of the volume of those 55 gallon drums of used oil and the like.  But the pictures below show trays that obviously couldn't do that.


-----Original Message-----
From: ILPI Support <info**At_Symbol_Here**ILPI.COM>
Sent: Tue, Apr 23, 2019 6:15 pm
Subject: Re: [DCHAS-L] solvent drums

Is cost your impracticability concern or is it because those pallets will transfer in and out as is?  Because Eagle and others make forkliftable spill containment pallets.  Disclaimer: these items are on my company's web site:

They also make budget basins which can go on top of a pallet:

Note: We are behind on updating the pricing on our spill pallet line (most all of those prices will be adjusted lower) so if anyone is budgeting and needs more accurate numbers please contact me off list.


Safety Emporium - Lab & Safety Supplies featuring brand names
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On Apr 23, 2019, at 2:52 PM, Dan Nowlan <dnowlan**At_Symbol_Here**BERRYMANPRODUCTS.COM> wrote:

We've certainly seen mangled and pierced drums before, but it's thankfully a rare occurrence and usually done at the hands of freight companies!
Drum containment solutions can be impractical if you have more than a few drums or have space constraints.  We have limited storage in our outside (covered) containment area and have to store some stuff inside.  Flammables, biocides, chlorinateds, SARA 313s, particularly environmentally hazardous chemicals (NP-9, for instance), etc. go in the containment area.  (Mineral acids and bases would, too, but we don't use any.)  Combustibles, petroleum and silicone oils, lubricant additives, and other less hazardous chemicals go in the warehouse on pallets.  It may not be ideal, but it's the best we can do, given our space limitations, and the fire marshal and insurance company seem to be OK with it.

From: ACS Division of Chemical Health and Safety [DCHAS-L**At_Symbol_Here**PRINCETON.EDU] on behalf of Peter Zavon [pzavon**At_Symbol_Here**ROCHESTER.RR.COM]
Sent: Tuesday, April 23, 2019 13:32
Subject: Re: [DCHAS-L] solvent drums

Not that there is a RULE, but I would always store in spill containment and ground if at all possible.
We had a fork lift once puncture a drum when trying to pick it up for a move.  Perhaps you don't run fork trucks near your drums, or are not supposed to at any rate, but there are other ways of initiating a spill, including a faulty or damaged drum not noticed on receipt.
Peter Zavon, CIH
Penfield, NY

From: ACS Division of Chemical Health and Safety [mailto:DCHAS-L**At_Symbol_Here**PRINCETON.EDU] On Behalf Of Yaritza Brinker
Sent: Tuesday, April 23, 2019 2:15 PM
Subject: [DCHAS-L] solvent drums
Our new unopened drums are stored on a wood palette until they are needed. A colleague recently suggested that new unopened drums should be stored on a spill containment platform instead of the palette. However, I have visited plenty of facilities where new unopened drums are stored directly on the concrete floor. Is there a rule on this? Where can I find it?
Also, there's some debate as to whether or not new unopened drums need to be grounded while in storage?
Yaritza Brinker

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