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IFC EVALUATION BRIEF

6725 162nd Pl SW Lynnwood, WA 98037 www.AEGISengineering.com (425) 745-4700 phone (206) 801-5797 fax

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PSC ENVIRONMENTAL – TACOMA

HAZARDOUS MATERIAL STORAGE

IFC EVALUATION BRIEF

December 20, 2010 Revised May 10, 2011

for:

PSC ENVIRONMENTAL SERVICES 18000 72nd Ave S, Ste. 217

Kent, WA 98032

Site Location: 1701 E Alexander Ave

Tacoma, WA 98421-4106

PSC ENVIRONMENTAL – TACOMA HAZARDOUS MATERIAL STORAGE December 20, 2010 IFC Evaluation Brief Revised May 10, 2011

INTRODUCTION

PSC Environmental Services (PSC) has retained AEGIS Engineering to assist in addressing outdoor storage of hazardous material containers at the PSC facility in Tacoma.

PROJECT CONDITIONS The PSC Tacoma facility receives hazardous materials from various sources via semi-trailers, shipped based on federal Department of Transportation (DOT) regulations (DOTr). PSC receives these materials and verifies the hazard classification during check-in prior to moving the containers in storage. PSC accumulates stored materials until a sufficient quantity of common materials exists to ship as a single consolidated load or waste is treated onsite. Hazardous materials in closed containers are currently received and stored on an open 9,000 square-foot concrete pad situated near the center of the property. In response to State of Washington Department of Ecology (DOE), PSC is working to establish a separate check-in area for receiving apart from the location where the materials are stored. The existing South Container Storage Area (SCSA) and new check-in area are shown in Figure 1.

FIGURE 1: PORTION OF PSC TACOMA SITE PLAN HIGHLIGHTING

SOUTH CONTAINER STORAGE AREA AND NEW CHECK-IN AREA

SOUTH CONTAINER STORAGE AREA

NEW CHECK-IN AREA

N


With these project improvements, PSC is seeking to establish a check-in area with a two-bay semi-trailer dock separate from the container storage area and provide weather protection over the SCSA and check-in containment cells . This report seeks to identify a strategy to address IFC criteria pertaining to the storage of hazardous materials at the PSC Tacoma facility with these anticipated improvements.

CONTAINER MANAGEMENT OPERATIONS SUMMARY PSC receives various quantities of hazardous materials and collects the mixed shipments until sufficient quantities are acquired, at which time the materials are loaded onto semi-trailers to leave the site. This report addresses planned operations upon implementing the identified improvements. CHECK-IN Containers are offloaded from semi-trailers and placed in a containment cell. Like-labeled containers are placed in common isolated containment cells; incompatible materials are placed in another cell. A representative sample of each type of material indicated is collected to ensure that the container labeling is accurate. Except for this brief exercise, containers remain closed. Containers remain in check-in no more than 24 hours, and then are moved to the SCSA after receiving the laboratory results. SOUTH CONTAINER STORAGE AREA Storage onsite is generally temporary, while uncommon materials may be stored up to one (1) year before sufficient quantities are collected to fill an outgoing shipment. Stored material is located on the northern portion of the SCSA. Materials are stored in rows; materials defined by DOTr to be incompatible are not stored in the same row.

CODE REFERENCES As indicated above, current handling and storage of hazardous materials at the PSC facility in Tacoma is based on DOT, EPA and DOE regulations. Storage and handling of hazardous materials regulated by the IFC is generally addressed in Chapter 27; outdoor storage of flammable and combustible liquids in IFC Section 3404.4. Specific provisions are provided in the IFC to address other hazard classes as well.


INTERNATIONAL FIRE CODE Section 2701.1.1 of the IFC specifically addresses potential conflicts with other codes, statutes or ordinances pertaining to hazardous materials:

The provisions of this chapter are waived when the fire code official determines that such enforcement is preempted by other codes, statutes or ordinances. The details of any action granting such a waiver shall be recorded and entered into the files of the code enforcement agency.

Similar language is provided in IFC Section 3401.2 regarding flammable and combustible liquids:

This chapter shall not apply to liquids as otherwise provided for in other laws or regulations or chapters of this code.

WASHINGTON ADMINISTRATIVE CODE The subject operation at the Tacoma PSC facility has been based on Washington Administrative Code (WAC) Title 173 Chapter 303, “Dangerous Waste Regulations,” regulated by DOE. Current practice at the facility is in accordance with the WAC, permitted and approved by DOE. While the WAC utilizes the term “solid waste,” this definition encompasses liquids and compressed gases, such as may be present at the subject site (WAC 173-303-016(3)). WAC 173-303-630(8)(b) specifically requires that:

The owner or operator must design, operate, and maintain ignitable waste and reactive waste (other than reactive waste which must meet [WAC 173-303-630(8)(a)]) container storage in a manner equivalent with the International Fire Code. Where no specific standard or requirements are specified in the International Fire Code, or in existing state or local fire codes, applicable sections of the NFPA Pamphlet #30, “Flammable and Combustible Liquids Code,” must be used. The owner/operator must also comply with the requirements of WAC 173-303-395(1)(d).

Referenced WAC 173-303-395(1)(d) states the following:

At least yearly, the owner or operator must inspect those areas of his facility where ignitable or reactive wastes are stored. This inspection must be performed in the presence of a professional person who is familiar with the International Fire Code, or in the presence of the local, state, or federal fire marshal. The owner or operator must enter the following information in his inspection log or operating record as a result of this inspection:

(i) The date and time of the inspection; (ii) The name of the professional inspector or fire marshal;


(iii) A notation of the observations made; and (iv) Any remedial actions which were taken as a result of the inspection.

Smaller containers of a common classification may be combined in a single larger container per WAC 173-303-161, referred to as a “lab pack,” including specific inner and outer container restrictions and appropriate quantity of absorbent material within the lab pack, among other conditions, in accordance with DOT Hazardous Materials Regulations (HMR; 49 CFR Section 173.12), which is based on EPA regulations. With this prescribed secondary containment, the DOT provides an exception permitting the lab pack to mingle with other containers, regardless of compatibility. Other combinations of containers can occur as loose packs, similar to lab packs though without the absorbent material, and over packs, such as a container within a crate or multiple containers banded together on a pallet.

PROJECT REFERENCES

As noted above, the IFC contains provisions to provide for other local codes or regulations to preempt the IFC in certain instances. However, applicable sections of WAC 173-303 Dangerous Waste Regulations refers back to the IFC and local fire official. Therefore, it is reasonable to conclude that where prescriptive requirements of the WAC are present, this regulatory language may supersede similar provisions of the IFC. However, where the IFC prescribes restrictions that are not present in the WAC, the more restrictive language of the IFC should be applied. The following section addresses provisions of the IFC for reference with regard to outdoor storage of hazardous materials by PSC in Tacoma. PROJECT APPLICATION The PSC facility in Tacoma receives a variety of hazardous materials, sorts the material, and stores it until it is shipped offsite. While the materials are being shipped, they are subject to DOT regulations. This analysis seeks to address how the solid and liquid material, once onsite, can be managed to address the provisions of the IFC. Two primary areas of the PSC facility in Tacoma are addressed in this analysis:

1. New Check-In Area and Weather Protection 2. South Container Storage Area and Weather Protection

These areas are identified on the site plan in Figure 1.


Color-coding is shown in the SCSA map and throughout this report to assist in differentiation between materials. As hazardous materials identified by DOT and IFC provisions are classified using different standards, and the materials at the facility are classified based on DOT regulations, when more than one hazard classification is provided, this evaluation seeks to address the more restrictive IFC provisions for the more hazardous classifications in an effort to encompass the majority of the material received by PSC and maintain a reasonable level of protection based on the intent and purpose of the IFC based on the practicality of the facility to implement the identified conditions.

MATERIAL COMPATIBILITY

Hazardous materials at this site are segregated per DOTr (49 CFR 177.848 - Segregation of Hazardous Materials) standards and the IFC. 49 CFR 177.848 separates materials into 9 distinct classes. The following classes are stored at the facility: Class 2 (compressed gases), Class 3 (flammable liquids), Class 4 (flammable solids), Class 5 (oxidizers), Class 6 (toxic liquids & solids), Class 8 (corrosives), Class 9 (miscellaneous). The DOTr classification is not an exact correlation to the IBC/IFC definition for incompatible material storage. DOTr compatibility is used for segregation of materials; pile arrangement is per the IFC.

CHECK-IN AREA Material received at the Tacoma PSC facility is typically staged in the check-in area no more than 24 hours before being moved into storage. While in the check-in area, samples of shipments will be taken and observed to confirm the declared material. Due to the variety of materials and containers often present in a single shipment, the receiving area is anticipated to contain multiple hazardous materials at one time. While in transit, these materials are managed in accordance with DOT regulations. When received by the PSC facility in Tacoma, these materials are sorted in the check-in area in preparation for storage onsite. Therefore, applying DOTr provisions to the transient use of the check-in area should be reasonable, and consistent with IFC Section 2701.1.1. In order to provide a reasonable degree of separation and segregation between the materials, the check-in pad will be divided by curbing to create 4 containment cells, each with an independent sump. At any given time, each cell will contain only compatible DOT labeled containers. Due to the inherent variety of shipments, the material classification stored in a given cell may vary depending on the characteristics of a given shipment.


Figure 2 illustrates the general concept for the layout of the new check-in area. Two semi-trailers would simultaneously be accommodated on the loading ramp, backed up to the truck dock. Received containers would be moved along the truck dock to the check-in cells, shown shaded. Each circle indicated in a check-in cell represents a standard 55-gallon drum, with a total of 40 drums per pod. Each check-in row is a minimum 2.5 feet from the curb on either side, the minimum DOTr aisle width. This results in more than twice the minimum DOTr aisle width between rows in adjacent pods, providing an increased degree of safety beyond that prescribed by DOTr.

FIGURE 2: NEW CHECK-IN AREA PLAN LAYOUT

42 ft

45 ft 26 ft

16 ft

Note: Only the drum Storage area (45x42 ft) is to be covered.

64 ft


FIGURE 3: SOUTH CONTAINER STORAGE AREA CONFIGURATION

WEATHER PROTECTION The shaded area in Figure 2 illustrates the extent of a noncombustible weather protection canopy structure, covering an area 45 feet by 42 feet, or 1,890 square feet. Section 414.6 of the IBC addresses weather protection for sheltering outdoor hazardous material. Based on a frontage increase in accordance with Section 506.2, as referenced in the exception to Section 414.6.1.3, the allowable area of weather protection where all four sides are provided with at least 30 feet of open space is 2,625 square feet. Based on the frontage space surrounding the new check-in area, a single weather protection structure should be acceptable to protect this outdoor area.

SOUTH CONTAINER STORAGE AREA Following check-in, containers would be moved to the appropriate location in the SCSA. This outdoor storage area is divided into containment cells providing segregation and physical separation of stored materials. Cells 1-4 have 30-inch separation between rows. Cell 5 has 5-foot separation between piles and 30-inch minimum from walls and curbs. The entire 150 x 60 foot area is to be provided with weather protection. Figure 3 illustrates the divisions of containment cells within the storage area:

Peroxides/Oxidizers Toxics Acids/Alkalis Flammables

Drum Jail

Consolidation

Area

150 ft

30 ft 30 ft 30 ft 60 ft

19 ft

Cell #1 #2 #3 #4 #5

Note: The entire 150 x 60 ft. area is to be provided with weather protection.

Cell #6

Cell #7

Cell #8

60 ft


Heavy dashed lines ( ) indicates walls of 2-hour fire-resistance-rated construction extending to a height of 14 feet, situated upon curbing to confine a spill within a single cell. Walls extend 30 inches vertically and horizontally beyond the pile limits of the

stored material. In the consolidation area (Cell 7), this perimeter wall will extend on the east

side at least 30 inches to the north beyond the limit of the protected cell, and along the south wall at least 30 inches to the west beyond the containment curbing of the protected cell.

Double lines ( ) between incompatible material classes indicate noncombustible partitions extending 18 inches above and beyond storage, situated upon curbing to confine a spill within a single cell.

Dark dotted lines ( ) indicate curbing only to confine a spill within a containment cell.

The colored shading in Figure 3 and Table 1 corresponds to the different stored materials. Table 1 outlines the hazard classification and maximum material quantity to be accommodated in each cell. Each of the subject commodities is addressed in a subsequent section.

WEATHER PROTECTION The existing storage pad is to be provided with weather protection. Section 414.6.1.3 limits the area of a weather protection element to 1,500 square feet. Therefore, to cover the entire 9,000 square-foot area, 6 canopies would be necessary. Section 414.6.1.2 discusses separation requirements to lot lines, public ways, and buildings or means of egress, but does not specifically prescribe a distance to other weather protection. The intent of limiting the area of weather protection can be considered to prevent excessive accumulation of products of combustion in the event of a fire beneath the weather protection. In order to provide weather protection for the PSC Tacoma facility SCSA, the use of multiple canopy roofs, each with a maximum area of 1,500 square-feet is proposed. Where the edges of weather protection canopies align, vertical offset of the abutting canopies will provide a clear area of at least 4 feet, consistent with the minimum dimension per IBC Section 910.3 for smoke and heat venting. These 6 weather protection roof elements will be supported by a common Type II-B noncombustible frame in order for columns to align with the 5 bays present in the existing concrete foundation.


CONTAINER STORAGE NOTES HAZARD CLASSIFICATION

CELL ARRANGEMENT CAPACITY

(DRUM EQUIVALENTS) IFC

CLASSIFICATION

IFC

DOT Allowable Quantity

IFC Ref.

1 1 pile, 1 row,

min. 30-inch aisles Up to 162 drums

89,100 lbs.

Organic Peroxides

and Oxidizers 100,000 lbs. 3904.2.3 5.1, 5.2, 9

2 1 pile, 2 rows,

min. 30-inch aisles

Up to 162 drums <1200 cu. ft.

per row.

Combined <2400 cu. ft.

Toxic 2500 cu. ft.

per pile 3703.2.4 2.2, 2.3, 6.1, 9

3 2 piles in 2 rows,


17,820 gal. Acids

n/a 3104.2

8a, 9

4 1 pile, 1 rows,


8,910 gal. Alkalis 8b, 8c, 9

5

9 piles, min. 5-foot aisles,

30-inches from walls and curbs

36 drums (1,980 gal.)/pile Combined 324

drums total

Flammable liquids

2,200 gal. per pile

3404.4.2

2.1, 3, 4.1, 4.2, 9 36 drums

(<2,388 cu. ft.)/pile Flammable solids

5,000 cu. ft. per pile

3604.2.2

6

Consolidation Area

Maximum 4 open containers during

transfer of material Varies- up to 4 drums max. Compatibles Varies

7

1 pile, 1 row Up to 20 drums/lab packs Compatible with Cell 6 Varies

8

Drum Jail

4 piles, min. 30-inch aisles

Up to 16 drums, 880 gal. or 8,800 lbs. (maximum 4 drums/pile)

Incompatibles located on separate containment trays

Varies

TABLE 1: SUMMARY OF MATERIAL HAZARD CLASSIFICATIONS AND CONFIGURATION IN CONTAINMENT CELLS


CLASS 9 Class 9 represents the DOT material classification for miscellaneous not otherwise classified materials. Class 9 materials may be stored in any cell, with the exception that combustible Class 9 materials will not be stored in a cell with oxidizers. ORGANIC PEROXIDES AND OXIDIZERS Organic Peroxides and Oxidizers will be stored together in Cell 1. Organic peroxides and oxidizers are not classified as incompatible materials, based on DOT compatibility. Class 4 oxidizers in excess of 2 pounds and Class I organic peroxides in excess of 20 pounds will not be stored at PSC-Tacoma, unless in a lab pack. Materials stored at Tacoma are first received at the PSC Kent facility. Based on receivables at Kent, approximately 2% of the storage in this cell will be organic peroxides (14 drums of organic peroxides processed in one year at Kent). Organic peroxides are regulated by IFC Chapter 39 and oxidizers are regulated by IFC Chapter 40. Storage of oxidizers and organic peroxides is located in the most remote end on the north side of the SCSA near the center of the property, thus providing the required 50-ft separation to buildings, lot lines, public streets, etc. in accordance with IFC Tables 3904.1.2 and 4004.1.2, as referenced by Sections 3904.2.3 and 4004.2.1, respectively.

ORGANIC PEROXIDES IFC Section 3904.2 requires storage of organic peroxides in accordance with Sections 2701, 2703, 2704 of the IFC. IFC Section 2703.9 prescribes separation of incompatible materials by a noncombustible partition extending not less than 18 inches above and to the sides of the stored material. Organic peroxides are separated from the Toxics (Cell 2) by a 2-hour wall along the southern side of the Cell 1, exceeding this requirement. Based on annual processing at the Kent facility, approximately 2% of the storage is anticipated to be organic peroxides. Anticipating less than 5 drums of organic peroxides being stored in this cell, a maximum storage height of 10-foot as prescribed for oxidizers will be adhered to allowing for 3 drum high mixed storage of organic peroxides and oxidizers.


OXIDIZERS As noted above, Class 4 oxidizers in excess of 2 pounds will not be stored at PSC-Tacoma, unless in a lab pack. IFC Section 4004.2.3 states that oxidizer storage arrangements must comply with Tables 4001.7(1) through 4004.1.7(4). As noted above, a 2-hour fire-resistive separation will be provided between Cell 1 and the adjacent Cell 2. This level of protection is based on the 2-hour construction prescribed for Class 3 oxidizer cutoff storage rooms per Footnote c of IFC Table 4004.1.7(3). Therefore, Table 4004.1.7(3) for Class 3 oxidizers is utilized and the maximum pile height of 10-foot (for cutoff storage rooms and detached buildings) will be adhered to. Anticipating less than 5 drums of organic peroxides being stored with up to 162 drums in this cell, a maximum storage height of 10-foot as prescribed for oxidizers is applied for the combined storage. As outdoor storage, Footnote (a) of IFC Table 4004.1.7(3) should be applicable with regard to minimum 2-foot separation from walls; Footnote (b) of Table 3904.1.7 also permits 2-foot separation to noncombustible walls. As this outdoor storage is open on at least two sides of the containment cell, this limited separation to a wall is reasonable. Actual separation will be at least 2.5 feet based on DOTr aisle widths. TOXICS Toxics will be stored in Cell 2. Aisles between rows are 30-inch as indicated in accordance with DOT regulations. Toxic materials are regulated by IFC Chapter 37. Outdoor storage of highly toxic solids and liquids is addressed with IFC Section 3703.2. The distance from the storage to the edge of the nearest street exceeds 20 feet, as prescribed by IFC Section 3703.2.3.1. The location of the toxic material storage area is northwest of the modular office building, such that a 20-foot separation as prescribed by IFC Section 3703.2.3.1 is provided. Section 3703.2.4 identifies a maximum pile size of 2,500 cubic feet. Based on the quantity indicated in the storage plan, less than 2,400 cubic feet of storage is accommodated by both rows in Cells 2 (162 drums x 2 rows x 55 gal/drum x 0.134 cu.ft./gal = 2,388 cu.ft.). Therefore treating these two rows as one storage pile is within the limits of Section 3703.2.4. As noted above under ORGANIC PEROXIDES AND OXIDIZERS, a 2-hr fire wall separates the Toxics pile from the Peroxides & Oxidizers to the north. Incompatible materials in the cell to the south (Corrosives) will be separated in accordance with IFC Section 2703.9.8 by a noncombustible partition extending not less than 18 inches above and to the sides of the stored material.


CORROSIVES Corrosives will be stored with acids in Cell 3 and alkalis in Cell 4. Aisles between rows are 30-inch as indicated in accordance with DOT regulations. Corrosive materials are regulated by IFC Chapter 31. The distance from the storage to the edge of the nearest street or building exceeds 20 feet, as prescribed by IFC Section 3104.2.2. The area surrounding an outdoor storage area or tank will be kept clear of combustible materials and vegetation for a minimum distance of 25 feet in accordance with IFC Section 2704.11. Incompatible material cells to the north (Toxics) and south (Flammables) will be separated in accordance with IFC Section 2703.9.8 by a noncombustible partition extending not less than 18 inches above and to the sides of the stored material. FLAMMABLE MATERIALS Storage of flammable liquids and solids occurs in Cell #5. Standards utilized by DOT to classify flammable liquids differ from IFC provisions. The maximum pile size is based on the allowable quantity of 2,200 gallons per pile for Class IB liquid, which provides for up to forty (40) 55-gallon drums per pile, and should account for the majority of flammable liquids stored. As noted in Figure 3, flammable material piles will be limited to 36 drums per pile, and separated by 5-foot aisles.

FLAMMABLE LIQUIDS

While the storage quantity is based on Class IB liquids, a maximum pile height of 10 feet with 5-foot aisle spacing is provided, which is consistent with the more restrictive IFC provisions for Class IA flammable liquids.

FLAMMABLE SOLIDS Pile limitations for outdoor storage of flammable solids are presented in IFC Section 3604.2. The minimum separation of 20-feet prescribed by IFC Section 3604.2.1 is achieved with the designated cell location relative to the office building and Consolidation Area activities, and a 2-hour wall to the north providing separation to Cell #4. A 2-hour wall on the south side of the containment cell separates the flammable material storage from the containment cells to the south, including the consolidation area and drum jail.


A maximum pile size of 5,000 cubic feet is prescribed by IFC Section 3604.2.2, while the total volume indicated in the designated pods is less than 2,400 cubic feet of material, based on the following calculation: 36 drums/pile x 9 piles x 55 gal/drum x 0.134 cu.ft./gal = 2,388 cu.ft. Therefore, the entire storage of flammable materials can be reasonably stored in accordance with more restrictive flammable liquid provisions. CONSOLIDATION AREA While the remainder of the storage pad consists of closed storage containers, Cells 6 and 7 are utilized for consolidating compatible materials.

FLAMMABLE LIQUID (gallons) ORGANIC PEROXIDE (pounds) Class IA 10 Class I 2 Class IB 15 Class II 20 Class IC 20 Class III 50 Combination IA, IB and IC

30 Class IV Class V

100 Unlim.

COMBUSTIBLE LIQUID (gallons) OXIDIZER (pounds) Class II 30 Class 4 0.25 Class IIIA 80 Class 3 4 Class IIIB 3,300 Class 2 100 Class 1 Unlim. WATER REACTIVE (pounds) Class 3 1 TOXIC (pounds)

Class 2 10 Highly Toxic 3 Class 1 Unlim. Toxic 125

FLAMMABLE SOLID 50 pounds CORROSIVE 1,000 pounds

TABLE 2: IFC QUANTITIES FROM TABLES 2703.1.1(3) AND TABLE 2703.1.1(4)

Cell 6 of the consolidation area involves the transfer of like-kind material to consolidate partially-filled containers to fill a common container (or lab pack). Plant operating policy limits the maximum number of containers/lab packs open at a time to four. This allows for one lab pack which may contain several different types of materials to be consolidated into their separate designated drums.


Only 20 containers of compatible materials would be present in the Consolidation Area (Cell 7) at a given time, inherently limiting the quantity present in and around the use area. Class 4.3 - Dangerous When Wet materials could be received and consolidated in lab packs in Cell 6, and the lab packs stored in Cell 7 for return shipping. Class 3 Water Reactive materials would not be processed at this facility. DRUM JAIL From check-in, containers with non-conforming lab results are moved directly to a remote corner of the SCSA, referred to as “drum jail,” waiting further testing to determine the material characteristics. Up to 16 containers are accommodated in drum jail, where they are typically resolved in 48 hours, but may be held for up to 15 days to resolve a discrepancy before moving the container into storage at the facility or shipping it out. As the drum jail containment cell, Cell 8, has a single sump, containment pallets will be used to achieve segregation from spills. Separation of incompatible materials within drum jail will be based on DOTr 30-inch aisles. Two-hour walls separate Cell 8 from adjacent containment cells (Cell 5 and Cell 7) as well as the PSC office building near the southeast corner of the SCSA. Containers in the drum jail are remotely located from property lines and public ways, such that perimeter walls should not be required. SUMMARY AEGIS Engineering has completed an evaluation of DOTr and IFC provisions for storage of hazardous materials at the PSC facility in Tacoma. Incompatible materials are stored in separate rows in accordance with DOTr criteria (attached), with piles in the South Container Storage Area (SCSA) arranged in accordance with IFC provisions. Storage at the check-in pad is segregated in accordance with DOTr provisions. Where check-in is unable to verify the subject material, the containers will be moved for temporary holding in Cell 8, “Drum Jail,” and segregated on containment pallets in accordance with DOTr. Based on perimeter frontage around the check-in pad, the proposed weather protection for this new area should be acceptable based on IFC and IBC provisions. At the SCSA, the existing 9,000 square-foot area may be provided with 1,500 square-foot adjacent weather protection canopies where separation is provided between each in accordance with IFC smoke and heat venting provisions.


The consolidation area in Cell 6 presents a unique challenge due to the strict application of the definition for in-use hazardous materials. To accommodate PSC operations and overcome the practical difficulty presented by IFC provisions, a maximum of 2 containers may be open at one time in the consolidation cell to accommodate material transfer operations. Feel free to contact me for clarification of the information presented at 425-745-4700 or by e-mail at [email protected]. Prepared by: Reviewed by: AEGIS ENGINEERING, PLLC AEGIS ENGINEERING, PLLC Travis E. Allen, P.E Brian C. Thompson, P.E. Attachment

PSC ENVIRONMENTAL – TACOMA Page A-1 HAZARDOUS MATERIAL STORAGE December 20, 2010 IFC Evaluation Brief Revised May 10, 2011

Fire Protection ▪ Building Code

Consult ▪ Design ▪ Engineer

49 CFR 177.848 SUBPART C— DOTR HAZARDOUS MATERIAL SEGREGATION CHART

The letter “X” in the table indicates that these materials may not be loaded, transported, or stored together in the same transport vehicle or storage facility during the course of transportation.

The letter “O” in the table indicates that these materials may not be loaded, transported, or stored together in the same transport vehicle or storage facility during the course of transportation unless separated in a manner that, in the event of leakage from packages under conditions normally incident to transportation, commingling of hazardous materials would not occur. Notwithstanding the methods of separation employed.

The „„*‟‟ in the table indicates that segregation among different Class 1 (explosive) materials is governed by the compatibility table in paragraph (f) of this section.

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