First time poster, long time lurker, and colleague of the deceased weressl.
If this is posted in the incorrect forum section, please move it for me.
I recently received the following question with a picture from one of our sites.
Are we required, or is there a RAGAGEP that would require us to order our drum carts with Sd (Static Dissipation) wheels?
So... Some background.
The drums as pictured, when they have material, are sealed and moved to the location as seen. This is in an unclassified location. No transfers take place in this area, and the drums are bonded and grounded using listed clamps.
Normal procedure is as follows:
The drums are disconnected from the grounding system wheeled into a CI, D2 area, and reconnected to the grounding system. The drum is opened, flammable material is transferred, the drum is sealed back up, disconnected from the grounding system, wheeled over to the unclassified location, and grounded.
First thought was to treat this as a normal tank, but it isn't.
My first stop was at NFPA 30 to determine if this is somehow a "portable container" and not a "drum".
Drums are too small:
188.8.131.52 Portable Tank. Any vessel having a liquid capacityover 60 gal (230 L) intended for storing liquids and not
intended for fixed installation.
The hazard that I think needs to be protected against would be static discharge while in the C1, D2 area while connecting the grounding clamp. But alas, since this condition only exists during abnormal conditions, so there should, in theory, be no flammable material to ignite under normal circumstances.
I know the easy answer is to install Sd wheels, but I want to understand the "why"?
I am interested in hearing your thoughts.