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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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

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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.

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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