Enforcement in New England

Adequate Hazardous Waste Storage for Inspection

This statement has been developed to provide Pfizer Inc with Regional EPA guidance to facilitate future compliance at the Groton, Connecticut facility.

What guidelines should be followed for drum stacking and pallet configurations?

• Stacking

  All drums must be stacked no higher than two-tiers high in order to facilitate proper inspection of containers pursuant to 40 C.F.R. § 265.174 and RCSA § 22a-449(c)-105(a)(1). This policy applies to fifty-five gallon steel or fiber drums, 30 gallon and 20 gallon fiber drums and any other drum in hazardous waste storage areas. In accordance with CTDEP’s draft memorandum dated January 4, 1993, entitled Secondary Containment and Aisle Space for Hazardous Waste Container Storage Areas, "[t]his stacking height may be exceeded if a fabricated rack storage system is being used to hold the containers. These racks must be constructed to safely hold the weight of the maximum number of containers and a means must be provided to adequately inspect each container (i.e. lift truck, etc.). This means must be available for use at any time by inspectors from regulatory agencies."

• Pallets

  Fifty-five gallon drums and 30 gallon drums should be limited to four drums per pallet. Twenty-gallon fiber drums can be stored with eight drums per pallet, provided that sufficient aisle space is maintained between stacks of pallets to allow for inspection of the center two drums on the pallet. See the attached diagram for an illustration of allowable drum storage configurations. If Pfizer uses drums other than the ones mentioned above in the future, Pfizer may wish to contact Region I or CTDEP to determine the appropriate storage configuration. If CTDEP makes a different determination with respect to storage configurations, Pfizer should obtain such determination in writing.