From: Robert Fricke (firstname.lastname@example.org)
Date: Fri, 9 Aug 2002 09:32:12
I have done five Part Bs for TSDFs in MA & RI and they always used the single-pallet wide row with aisles on each side. Drum labels must face out. Your example of 4x4 may not be acceptable because you may not be able to see the labels or inspect for leaks adequately.
Flammable drums cannot be stacked inside. Certain corrosives, chlorinated solvents and combustibles can be stacked two pallets high depending on agency policy. Generally, space limitations and the NFPA reqs are used to make the determination. Non-liquid waste drums depending on waste toxicity and empties can be stacked according to a negotiated height limit.
The requirements apply to both indoor and outdoor storage. Although different stacking limits may be used depending on quantity, space and remoteness from operations/public.
All this is federal policy and state policy/regs. The regs are generally performance oriented and really don't spell out specific storage criteria.
The buffer zone requirement for ignitable and reactives is 50 feet or (15 meters) from the property line regardless of whether they are inside or outside. One client had reactives stored in a explosion proof building 47 feet from the property line. (By the way, 15 meters is only 49 feet plus.) MA wouldn't go for it. So the client moved the reactives to the far side of the building which was over 50 feet from the property line. Its not the building, but the distance that determines storage location.