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From: Yaritza Brinker <YBrinker**At_Symbol_Here**FELE.COM>
Subject: Re: [DCHAS-L] solvent drums
Date: Apr 26, 2019 14:20 UTC
Reply-To:
ACS Division of Chemical Health and Safety
In-Reply-To: Re: [DCHAS-L] solvent drums
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
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