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Environmental Products and Drum Equipment

Key excerpts of pertinent Codes and Regulations

EPA 40 CFR 264.175:  www.epa.gov
Containment. (a) Container storage areas must have a containment system that is designed and operated in accordance with paragraph (b) of this section, except as otherwise provided by paragraph (c) of this section.
(b) A containment system must be designed and operated as follows:

(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.

Uniform Fire Code, 1997 Edition**  www.icbo.org
8003.1.3.4 Containment pallets: When used as a substitute for spill control and secondary containment for outdoor storage in accordance with the exception in Section 8003.1.3.1, containment pallets shall comply with the following:
1. A liquid-tight sump accessible for visual inspection shall be provided.
2. The sump shall be designed to contain not less than 66 gallons (249.8L)
3. Exposed surfaces shall be compatible with material stored, and
4. Containment pallets shall be protected to prevent collection of rainwater within the sump.

OSHA 29CFR 1910.106 (e)(2)(iii):  www.osha.gov
Separation and protection. Areas in which flammable or combustible liquids are transferred from one tank or container to another container shall be separated from other operations in the building by adequate distance or by construction having adequate fire resistance. Drainage or other means shall be provided to control spills. Adequate natural or mechanical ventilation shall be provided.

DOT 49 CFR 173.3 (c) Salvage Drums:  www.dot.gov
Packages of hazardous materials that are damaged, defective or found leaking and hazardous materials that have spilled or leaked (including used sorbents) may be placed into a metal or plastic removable head drum that is compatible with the lading and shipped for repackaging or disposal under the following conditions: 1. Except as provided in paragraph (c)(7) of this section, the drum must be a UN 1A2, 1B2, 1N2 or 1H2 tested and marked for Packing Group III or higher performance standards for liquids or solids and a leakproofness test of 3 psi.

EPA 40 CFR 261.23(a)(6):  www.epa.gov
In a report prepared for EPA by the Office of Solid Waste and Emergency Response, it was noted that aerosol cans would be a RCRA hazardous waste because they demonstrate the hazardous characteristic of reactivity. When an aerosol can is depressurized (vented) to atmospheric pressure using Justrite's Aerosolv, the danger from reactivity (40 CFR 261.23(a)(6)) is thereby removed. Hence, one has taken a hazardous waste to a non-hazardous state.

OSHA 29CFR 1910.106(d)(4)(v):  www.osha.gov
Storage in inside storage rooms. In every inside storage room there shall be maintained one clear aisle at least 3 feet wide. Containers over 30 gallons capacity shall not be stacked one upon the other. Dispensing shall be by approved pump or self-closing faucet only.

OSHA 29CFR 1910.106(e)(2)(iv)(d):  www.osha.gov
Flammable or combustible liquids shall be drawn from or transferred into vessels, containers, or portable tanks within a building only through a closed piping system, from safety cans, by means of a device drawing through the top, or from a container or portable tanks by gravity through an approved self-closing valve. Transferring by means of air pressure on the container or portable tanks shall be prohibited.

OSHA 29 CFR 1910.106(d)(2)(ii):  www.osha.gov
Emergency venting. Each portable tank shall be provided with one or more devices installed in the top with sufficient emergency venting capacity to limit internal pressure under fire exposure conditions to 10 p.s.i.g., or 30 percent of the bursting pressure of the tank, whichever is greater. The total venting capacity shall be not less than that specified in paragraphs (b)(2)(v)(c) or (e) of this section. At least one pressure-activated vent having a minimum capacity of 6,000 cubic feet of free air (14.7 p.s.i.a. and 60º F) shall be used. It shall be set to open at not less than 5 p.s.i.g. If fusible vents are used, they shall be actuated by elements that operate at a temperature not exceeding 300º F.

**Portions of this work are reproduced from the 1997 edition of the Uniform Fire Code™, copyright©1997, with the permission of the publisher, the International Conference of Building Officials (ICBO). ICBO assumes no responsibility for the accuracy or the completion of summaries provided therein.

The Clean Air Act Amendments of 1990 have mandated Hazardous Organic National Emission Standards for Hazardous Air Pollutants, known as the HON Rule. EPA encourages control of these " fugitive emissions."

EPA 40 CFR 264.173: Management of containers.  www.epa.gov
(a) A container holding hazardous waste must always be closed during storage, except when it is necessary to add or remove waste.
(b) A container holding hazardous waste must not be opened, handled, or stored in a manner which may rupture the container or cause it to leak.

OSHA 29 CFR 1910.106(e)(6)(ii):  www.osha.gov
Grounding. Class I liquids shall not be dispensed into containers unless the nozzle and container are electrically interconnected. Where the metallic floorplate on which the container stands while filling is electrically connected to the fill stem or where the fill stem is bonded to the container during filling operations by means of a bond wire, the provisions of this section shall be deemed to have been complied with.

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