From: Richard Palluzi <000006c59248530b-dmarc-request**At_Symbol_Here**LISTS.PRINCETON.EDU>
Subject: Re: [DCHAS-L] Advice on modular hazardous waste storage buildings
Date: Fri, 13 Dec 2019 06:11:20 -0500
Reply-To: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**Princeton.EDU>
Message-ID: 007c01d5b1a6$0c950d40$25bf27c0$**At_Symbol_Here**



I installed several of these for sample storage of hydrocarbons. In general they worked well with a few issues.


For drum storage we had to get a module with garage type doors on the side so that a forklift could pull up to load and unload pallets of drum(s). Trying to load them through the drawer required an expensive platform and never worked well.


Also, the manufacturers to save costs only design the units to be ventilated when occupied which they assume is less than an hour a day. That, in my opinion, is a violation of the spirit of NFPA 30 (although not the letter due to a bit  of poor wording) and GEP. You can easily deal with that by just requiring the exhaust to always be on. If the module is heated or cooled, however, which might be necessary for lighter or heavier hydrocarbons, then you need to get the manufacturer to install a larger heating tor cooling system. (usually only cooling is a big issue.)


If you have any other questions, please eel free to contact me.


Richard Palluzi



Pilot plant and laboratory consulting, safety, design,reviews, and training


Richard P Palluzi LLC

72 Summit Drive

Basking Ridge, NJ 07920




From: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**PRINCETON.EDU> On Behalf Of Reinhardt, Peter
Sent: Wednesday, December 11, 2019 9:30 AM
Subject: [DCHAS-L] Advice on modular hazardous waste storage buildings




I’m looking for advice on on-site storage facilities for 55-gallon drums of waste solvents.


At Yale, EHS collects waste solvents from labs and commingles them into 55 gallon drums. We need a new place to store these drums prior to shipment. Every year, Yale ships about 700 55-gallon drums of waste solvents to commercial disposal facilities. (About a third are not flammable).


Facilities has proposed that we purchase a modular drum storage building for storing drums of flammable solvents. These are much less expensive than constructing a permanent hazardous waste facility. Here’s what we are considering:


This modular building can be purchased to meet H-1 occupancy building codes. They are conditioned, have blow-out panels and fire suppression, and have a reservoir for secondary containment and fire flow containment.


Please let me know if you have any experience with these buildings--pros, cons, tips, etc. I’ve never seen one in person, so I am a little concerned. We asked our vendor about these (they encounter them when serving other customers) and did tour a small version of this modular unit. This has made me concerned about the effects of wear-and-tear, and the awkwardness of waste handling.


This will be a RCRA less-than-90-day accumulation area, serving a large contiguous area of campus. Solvents are commingled in one location, and will be transported by truck to this modular building. We will probably store some labpacks in the building as well.


One of my concerns is structural quality and durability. It takes decades for Yale to build new hazardous waste management space, so this building needs to last 20, maybe 30 years.


Operations will be exposed to the weather--rain, snow, wind, etc. We can avoid using it during a blizzard, but waste handlers, the fork lift, and the drums themselves are exposed to the weather when the doors are open to move waste in and out of the building.


The drums will need to be palletized and manipulated with a fork lift. In the unit, the palletized drums will be stacked two high and eight deep. The fork lift will also be necessary for moving the drums from our truck into the building, and moving the drums from the building to the commercial disposal service’ semi-trailer. Currently, we do not palletize any of our hazardous waste, and we don’t use a forklift.


There might be other concerns that I am unaware of. Or perhaps you’ve found that these concerns are less of a worry that I anticipate. If you have experience with this, I would very much appreciate your observations and advice.




Peter A. Reinhardt (he/him/his)

Director, Office of Environmental Health & Safety

Yale University

135 College St., Suite 100

New Haven, CT   06510-2411

(203) 737-2123



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