From: Yaritza Brinker <YBrinker**At_Symbol_Here**FELE.COM>
Subject: Re: [DCHAS-L] solvent drums
Date: Fri, 26 Apr 2019 14:20:55 +0000
Reply-To: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**PRINCETON.EDU>
Message-ID: DM5PR05MB330636EBC20F86E63214A6E3AD3E0**At_Symbol_Here**DM5PR05MB3306.namprd05.prod.outlook.com
In-Reply-To <20190425095754.4a1b7c747c75ab54f90280e9d8251945.d80c89211c.wbe**At_Symbol_Here**email05.godaddy.com>


Thank you for everyone's input on this. We are a small quantity generator and drums are the largest containers we have. We're storing inside, the building has fire suppression, drains are far away� etc.  After doing a quick review of the regulations all of you have pointed out, it appears that as long as all of the exceptions are met, then passive spill containment is not required. This looks to me like an oversight in regulations, but maybe there's an explanation that evades me. We are buying spill containment platforms anyway.

 

Thank you all very much for all your guidance!

 

Yaritza Brinker

260.827.5402

 

From: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**PRINCETON.EDU> On Behalf Of mail**At_Symbol_Here**ECHELONENVIRONMENTAL.NET
Sent: Thursday, April 25, 2019 12:58 PM
To: DCHAS-L**At_Symbol_Here**PRINCETON.EDU
Subject: Re: [DCHAS-L] solvent drums

 

** External Email **

Hello All,

 

in regards to the questions about spill containment:  No hazardous waste generator is subject to 264.175 (as referenced below) if they abide by the "conditions of exemption" for their generator status, whether they are small or large quantity genrator.  Note - this is the federal regulation.  States may have more stringent requirements.

 

if a small quantity generator operates within the limitations of 262.16, then 264 is not applicable

If a large quantity generator operates within the limitations of 262.17, then 264 is not applicable

(this is according to the NEW generator requirements that MOST states have adopted.  these are fondly called the Hazardous Waste Generator Improvement Rule, or HWGIR)

see 40 CFR part 262 at    https://www.ecfr.gov/cgi-bin/text-idx?SID=b4168f1943b01aca5b52db9849c2b99c&mc=true&node=pt40.28.262&rgn=div5

 

 

That being said, it is a good idea to have spill containment, because "Spills Happen".

 

Ron Harvey

Echelon Environmental

843-599-0330

https://www.linkedin.com/in/ronharvey/

 

 

Take the Quick Compliance Assessment

Learn the 19 common compliance mistakes that most businesses make.

http://www.EchelonCompliance.net/QCA

 

See the Echelon School of EHS Management

Showing Safety Managers how to comply with the OSHA rules

https://the-echelon-school.teachable.com/

 

-------- Original Message --------
Subject: Re: [DCHAS-L] solvent drums
From: ILPI Support <info**At_Symbol_Here**ILPI.COM>
Date: Wed, April 24, 2019 6:03 am
To: DCHAS-L**At_Symbol_Here**PRINCETON.EDU

Ah, the dangers of late-night surfing.  My bleary eyesI read it this way:

 

capacity to contain (10% of the volume of containers) or (the volume of the largest  container)

 

But you pointed out it's:

 

capacity to contain 10% of (the volume of containers) or (the volume of the largest  container)

 

I agree with your assessment after re-reading an contriving a pallet with three 54-gallon drums and one 55 gallon.  Obviously, a 5.5 gallon sump won't cut it there.

 

Good catch on the rule being RCRA/waste.  Which is all the platforms claim to comply with, apparently.

 

Rob

 

 ======================================================

Safety Emporium - Lab & Safety Supplies featuring brand names

you know and trust.  Visit us at http://www.SafetyEmporium.com

esales**At_Symbol_Here**safetyemporium.com  or toll-free: (866) 326-5412

Fax: (856) 553-6154, PO Box 1003, Blackwood, NJ 08012

 

 

 

On Apr 24, 2019, at 8:47 AM, Mark Ellison <Mark**At_Symbol_Here**TANKTRAILERCLEANING.COM> wrote:

 

Rob,

 

I deal with 55 gallon drums all the time.  My interpretation of that reg is that I need a 55 gallon sump, since it must contain 10% of the total volume or the volume of the largest container (a 55 gallon drum, in this case).  Please correct me if I am wrong.

 

Mark Ellison

 

 

From: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**PRINCETON.EDU> On Behalf Of ILPI Support
Sent: Tuesday, April 23, 2019 10:24 PM
To: DCHAS-L**At_Symbol_Here**PRINCETON.EDU
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 https://www.law.cornell.edu/cfr/text/40/264.175 

 

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

 

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   Interactive Learning Paradigms, Incorporated (ILPI)

Training, environmental/occupational health & safety consulting

Ph: (856) 449-8956, Fax: (856) 553-6154, sales**At_Symbol_Here**ilpi.com

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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.

 

Monona


-----Original Message-----
From: ILPI Support <info**At_Symbol_Here**ILPI.COM>
To: DCHAS-L <DCHAS-L**At_Symbol_Here**PRINCETON.EDU>
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: 

 

            http://www.safetyemporium.com/04313

            http://www.safetyemporium.com/04312

 

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

 

            http://www.safetyemporium.com/04302

 

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.

 

Rob

 

 ======================================================

Safety Emporium - Lab & Safety Supplies featuring brand names

you know and trust.  Visit us at http://www.SafetyEmporium.com

esales**At_Symbol_Here**safetyemporium.com  or toll-free: (866) 326-5412

Fax: (856) 553-6154, PO Box 1003, Blackwood, NJ 08012

 

 

 

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.

  

Dan

    


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
To: DCHAS-L**At_Symbol_Here**PRINCETON.EDU
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

PZAVON**At_Symbol_Here**Rochester.rr.com

 

 

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
To: DCHAS-L**At_Symbol_Here**PRINCETON.EDU
Subject: [DCHAS-L] solvent drums

 

Hello,

 

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?

 

Thanks,

Yaritza Brinker

 




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