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Hazardous wastes that are bulky in physical dimensions or have large volumes are more amenable to storing and treating in waste piles than in tanks or containers. However, placing untreated hazardous debris in waste piles violates land disposal restrictions. Containment buildings are the solution.
The Environmental Protection Agency (EPA) chose to allow containment buildings as hazardous waste management units to address the difficulties associated with the management of bulky and large-volume hazardous wastes. Containment buildings aren’t restricted to handling these types of waste; they can be used to store or treat any nonliquid hazardous waste without violating land disposal restrictions.
Scope
Owners and operators of facilities that store or treat hazardous waste in containment buildings must meet the design, operation, closure, and post-closure requirements of 40 CFR 264, Subpart DD, and 265, Subpart DD.
Containment buildings can be used to:
- Treat or store hazardous waste at permitted or interim status treatment, storage, and disposal facilities; and
- Temporarily accumulate hazardous wastes by a generator before off-site management.
Regulatory citations
- 40 CFR 264–265, Subpart DD — Containment buildings
- 40 CFR Part 268 — Land disposal restrictions
Key definitions
- Containment building: A completely enclosed structure (i.e., possesses four walls, a roof, and a floor) that houses an accumulation of non-containerized waste.
Summary of requirements
The design and operating standards for containment buildings are virtually the same for permitted and interim status units.
The standards primarily consist of requirements for structural soundness and specific measures to prevent infiltration of waste into the unit and migration into the adjacent environment. Before a containment building is used to store hazardous waste, a professional engineer must certify that the unit is designed and installed according to the regulations.
Building design standards. The design standards to which the containment building must conform include:
- Being completely enclosed with walls, a floor, and a roof made of materials with sufficient structural strength (Doors and windows do not have to meet this requirement but must have walls and partitions to keep wastes from coming into contact with them.);
- Using dust control devices (e.g., air-lock doors, negative air pressure systems) to prevent fugitive dust from escaping; and
- Having chemically compatible surfaces in the building that come into contact with waste during treatment or storage.
The other design standards require a system of barriers between the hazardous wastes and the surrounding environment.
Liquid waste standards. Because liquid and semi-liquid wastes are typically more difficult to handle and pose an increased risk of release into the surrounding environment, these wastes are generally prohibited from management in containment buildings.
Wastes are considered liquid when they:
- Flow under their own weight to fill the container they’re placed in,
- Are readily pumpable, or
- Release such large quantities into the unit that the liquid collection and removal system cannot prevent accumulation.
Wastes that contain free liquids but don’t meet the given definition of a liquid (i.e., wastes that don’t flow, aren’t pumpable, and don’t release a sufficiently large quantity of liquids) may be placed in a containment building, provided that the unit conforms to design limits, which include a:
- Primary barrier,
- Liquid collection and removal system, and
- Secondary containment system and leak detection system.
Alternatively, liquid wastes may be placed in tanks located inside a containment building. In this case, the building serves as secondary containment for the hazardous waste tank and must comply with all applicable secondary containment provisions in Subpart J of Parts 264 and 265.
Operational standards. Owners or operators of all containment buildings must:
- Use controls and practices to ensure containment of the hazardous waste within the unit;
- Obtain and keep on-site a certification by a qualified professional engineer that the containment building design meets the regulations;
- Repair promptly any condition that could lead to or has caused a release of hazardous waste, in accordance with the procedures outlined in 264.1101(c)(3)(i)–(iii); and
- Inspect and record data in the facility operating record at least once every seven days to detect signs of releases of hazardous waste.
Secondary containment standards. The owner or operator of a containment building that contains both areas with and without secondary containment must:
- Design and operate each area in accordance with the requirements in 264.1101(a)–(c)/265.1101(a)–(c),
- Take measures to prevent the release of liquids or wet materials into areas without secondary containment, and
- Maintain in the facility’s operating log a written description of the operating procedures used to maintain the integrity of areas without secondary containment.