Once simple drum handling now an environmental process.

It wasn't too many years ago that 55 gallon drums and plastic chemical containers were in great demand and disposal was a minor problem. They made excellent trash barrels, storage bins, planters, containers for castings and even stoves to warm winter construction workers. Pickup by drum reconditioners was usually a phone call away. But these uses are fast fading. All too often now these familiar containers are graphically depicted in the environmentally-sensitive press as symbols of dangerous chemical waste storage receptacles, usually abandoned in illegal, polluting dump sites.

Until recently, drum disposal was a minor problem handled inexpensively and quickly. But this, too, is no longer the case, as national attention focuses ever more critically on the problems caused by improper disposal of potentially hazardous materials.

Response by the Casting Industry Supplier's Assn. (CISA) to the needs of many foundries purchasing chemical products in 55 gallon drums or plastic containers has been to prepare recommendations for handling empty drums and semi-bulk containers in the most environmentally sensitive manner.

The object of responsible drum management, according to CISA'S guidelines, is to provide an empty steel drum with market value for the steel drum reconditioner. The North American Barrel and Drum Association (NABADA) has over 272 reconditioners registered with the Department of Transportation (DOT) that pick up an estimated 42 million steel drums per year. included in this pickup load are millions of pounds of potentially toxic residues which they neutralize or destroy in compliance with EPA regulations. Heretofore this has not been a problem.

However, fewer and fewer drum reconditioners can accept the added liability of transporting and processing empty drum residues which might be considered hazardous. This reluctance is creating problems for foundries that do not meet the "empty" definition and federal regulations for transportation.

Questions of regulation for the release of chemical residues into the environment from containers such as drums are answered by the Comprehensive Environmental Response, Compensation and Liability Act, commonly known as CERCLA, or the Superfund. This act established a broad definition for hazardous substances, regulations for their disposal and strict, retroactive, joint-and-several liability standards for improper handling and disposal.

In addition, the Superfund Reauthorization Act (SARA) redefined a release of contaminants to include abandonment or discarding of barrels, containers and other closed receptacles containing any hazardous substance, pollutant or contaminant.

Recommendations

CISA, in response to the needs of many foundries purchasing chemical products in 55 gallon drums, has issued specific recommendations for handling empty drums.

* Disposition-preparation for proper

shipment, meeting closure and labeling

requirements, with plugs reinserted,

lock rings refastened and labels

not removed or destroyed.

* Certification-empty drum certification,

a document a foundry can

use to confirm that drums are empty

and properly prepared for transportation

to demonstrate compliance with

the Hazardous Materials Transportation

Act.

Users AUDIT-NABADA audit form

to help foundries identify the applicable

regulatory requirements.

Plant Review-audit for the drum

reconditioner to assure compliance

with all federal, state and local government

requirements.

A good operating practice for drum emptiers is to maintain in place all drum labeling. Safety practices and precautionary measures indicated on labels should be observed, particularly directions for complete draining, proper closure, storage and return.

Complete emptying is the key to responsible drum management. For most products, drums must be emptied to one in. or less of bottom residue. Secondary use of containers for other storage uses could lead to cross contamination and become a serious problem.

Handling Solutions

A solution to the handling of 55 gallon drums could be the substitution of portable bulk tanks or semi-bulk containers, but many of the problems with drums also are associated with portable bulk tanks. To prevent contamination of products shipped in returnable tanks and to eliminate unnecessary repairs or cleaning, the following procedures should be followed:

* Keep portable tanks sealed until placed in service with feed mixers or tanks. Do not open hatch or do routine unloading.

* As soon as tanks are empty or taken out of service, all tank openings must be closed. The hatch must be properly latched and bungs and screw plugs must be screwed into discharge valves. All threads should be kept clean because exposure to air can cause solidification of contained material, making it difficult to replace or remove bungs and plugs and require significant cleaning. Tanks need to be kept dry and stored indoors. Avoid temperature extremes and follow specific product storage requirements provided by suppliers.

* All foreign material should be kept away from tanks.

* Portable tanks should not be shipped back to the supplier with any pipe fittings, couplings or other apparatus attached. They create potential for breakage and leakage. Hatches and valves must be closed tightly and all parts of the container must be in place.

* Care should be taken when moving tanks with a forklift truck. Certain portable tanks are constructed so that lifting must be done opposite the discharge valve location. Metal shields adjacent to these valves are nonload bearing and will be damaged if struck or an attempt made to lift under them. The ultimate answer to these problems, a complete bulk system that eliminates the need for semi-bulk containers or drums, is close at hand, forced in part by strict container handling regulations.

Essential Considerations

Managing the entire life-cycle of a consumable product to ensure not only safe product applications, but also the health and safety of workers who use the product, and the community where the product is used, are the environmental concerns of foundry suppliers.

Product planning and design are the necessary first steps. There is a need to develop and design products that perform to users'expectations. At the same time, consideration must be given to the waste by-products of production, inherent hazards of a new material, the potential for product misuse and regulatory requirements covering the composition and use of the product. It is far easier to consider these issues before the product is manufactured by the supplier or used by the casting producer.

Environmental Responsibility

It is important for foundry customers to understand that the day may be coming when foundries will face trade-offs between product performance, productivity and environmental acceptability. CISA companies have been wrestling with this problem for several years, and the situation doesn't seem to be easing, based on anticipated future regulations.

Safe raw material storage and handling is the responsibility of the product manufacturer as well as the foundry, both of which are covered by either federal, state or local regulations and permitting processes.

Packaging, admittedly, is becoming more of a problem for supplier and user alike. Containers must be sturdy and leak resistant. Regulations govern all materials that can be stored or shipped in any given type of container. Disposition of the old stand-by tighthead 55galdifficult, particularly in the lighter metal gauges.

The trend is toward using bulk storage at the foundry, or portable bulk tanks that can be shuttled between supplier and user.

The distribution or transport of foundry supplies raises some interesting issues. According to the Chemical Manufacturers Association Distribution Code of Management Practices, carrier selection and certification is an important consideration relating to various aspects of carrier performance and safety. In addition, the interstate Commerce Commission states that, if the material is classified as hazardous, it can be hauled only by carriers who meet certain requirements. and local regulatory authorities do not have unreasonable expectations, the foundry industry can overcome the difficulties in handling drum and bulk consumable products satisfactorily.