United States
.Environmental Protection
Agency
Solid Waste and
Emergency Response
(5305W)
PB96-207 063
EPA530-R-96-025
&EPA
RCRA, Superfund & EPCRA
Hotline Training Module
Introduction to:
Containment Buildings
(40 CFR Parts 264/265, Subpart DD)
Updated July 1996
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DISCLAIMER
/
This document was developed by Booz-AUen & Hamilton Inc. under contract 68-W6-0016 to EPA. It is intended
to be used as a training tool for Hotline specialists and does not represent a statement of EPA policy.
The information in this document is not by any means a complete representation of EPA's regulations or policies.
This document is used only in the capacity of the Hotline training and is not used as a reference tool on Hotline
calls. The Hotline revises and updates this document as regulatory program areas change.
The information in this document may not necessarily reflect the current position of the Agency. This document
is not intended and cannot be relied upon to create any rights, substantive or procedural, enforceable by any
party in litigation with the United States.
RCRA, Superfund & EPCRA Hotline Phone Numbers:
National toll-free (outside of DC area)
Local number (within DC area)
National toll-free for the hearing impaired (TDD)
(800) 424-9346
(703)412-9810
(800) 553-7672
The Hotline is open from 9 am to 6 pm Eastern Standard Time,
Monday through Friday, except for federal holidays.
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CONTAINMENT BUILDINGS
CONTENTS
1. Introduction . 1
2. Regulatory Summary . r 3
2.1 Applicability : 3
.2.2 Diesign Standards ,.'. 6
2.3 Operating Standards : , 8
2.4 Inspection 10
2.5 Response to Releases .»..' : .. 10
2.6 Closure .' .' ...» '. .': 10
3. Special Issues : 11
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Containment Buildings T
1. INTRODUCTION
Since the inception of the Resource Conservation and Recovery Act (RCRA)
program, EPA has struggled to create a system of hazardous waste management that
is protective of human health and the environment, yet not prohibitive to industry.
With the advent of the land disposal restrictions (LDR) in 1986, some waste
management difficulties arose, particularly concerning bulky, large volume wastes
that are not amenable to storage in tanks and containers. Lead slags, spent potliners,
and contaminated debris are difficult to manage in tanks and containers. Instead,
these wastes were often stored and treated on concrete pads or floors in buildings.
Because this type of management would be considered land disposal, it was
prohibited without prior treatment, but no other feasible storage or treatment unit
existed. '
In 1992, EPA developed standards for a new hazardous waste management unit
called a containment building. Containment buildings, which are essentially.waste
piles enclosed in a building, facilitate management of bulky materials without
triggering land disposal and LDR. This module outlines the regulatory standards for
containment buildings managing hazardous waste. ~
When you complete this training module, you will be able to explain the regulatory
history and purpose of containment buildings.' Specifically, you will be able to:
Discuss the relationship between the land disposal restrictions and - .
containment buildings
Summarize the design and operating standards applicable to containment
', buildings
Describe the relationship between generator accumulation standards and
containment buildings.
Use this list of objectives to check your knowledge of this topic after you complete
the training session., . , v
The information in this document is not by any means a complete representation ot EPA s regulations or policies,
but is an introduction to the topic used for Hotline training purposes.
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2 - Containment Buildings
The information in this document is not by any means a complete representation of brA s regulations or policies,
but is an introduction to the topic used for Hotline training purposes.
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Containment Buildings - 3
2. REGULATORY SUMMARY
EPA chose to designate containment buildings as hazardous waste management
units to address the difficulties associated with management of bulky, large volume
hazardous wastes and the triggers for hazardous waste management requirements
in the regulations. In response to the necessity for storage and treatment of such
wastes in compliance with the land disposal restrictions, the provisions for
containment buildings were promulgated on August 18,1992 (57 FR 37194).
Regulations applicable to containment buildings are codified in 40 CFR Parts 264 and
265, Subpart DD. ' '.
2.1 APPLICABILITY
A containment building is a completely enclosed structure (i.e., possessing four
walls, a roof, and a floor) which houses an accumulation.of noncontainerized waste.
Prior to designation of containment buildings as hazardous waste management
units, equivalent to tanks or containers, the accumulation of noncontainerized
waste within a roofed structure would have been considered an indoor waste pile
subject to the standards codified in Subpart L of Parts 264 and 265. Because of bulky
physical dimensions or large volumes, hazardous wastes like debris are more
amenable to storage and treatment in waste piles than in tanks or containers.
1 Placement of untreated hazardous debris in waste piles, however, violates the land
disposal restrictions under Part 268. ' , .
Under LDR, hazardous waste may not be placed on the land unless it meets certain
standards that require treatment of the waste to reduce its hazardousness (for more
information on LDR, see the module entitled Land Disposal Restrictions). Before
land disposal, many wastes will be stored or treated to meet the LDR treatment
standards in tanks and containers units that, are not considered "land disposal
units." Putting hazardous waste in certain types of units (including landfills, surface
impoundments, and waste piles) does constitute "land disposal," however, which
may not occur until the waste has been treated to meet LDR standards. Certain
bulky hazardous wastes are not amenable to treatment in tanks or containers and
must be treated in waste piles. Since the definition of "land disposal" includes
placement of waste in a waste pile, doing so is prohibited unless the waste first
meets all applicable treatment standards. Thus, to perform the treatment required
before land disposal, the waste must first be land disposed. Under this scenario, the -
land disposal restrictions form a circular barrier to any management of certain
hazardous wastes (Figure 1). EPA developed the concept of containment buildings
to break this circular barrier and allow for proper handling of all hazardous waste.
The information in this document is not by any means a complete representation of EPA s regulations or policies,
but is an introduction to the topic used for Hotline training purposes.
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4 - Containment Buildings
. Figure 1
THE CIRCULAR BARRIER
TO TREATMENT OF CERTAIN HAZARDOUS WASTES
Placement of,
x Hazardous Waste in
a Waste Pile
(Land Disposal)
but treatment of certain
hazardous wastes
cannot easily be conducted
without...
cannot occur
until.
Hazardous Waste Is
Treated to
Meet LDR Treatment
Standards
EPA interprets the statutory definition of land disposal to exclude containment
buildings based on the belief that the completely enclosed unit can provide
containment comparable to that offered by tanks or containers/ when the building is
designed and operated in compliance with the regulations in Parts 264/265, Subpart
DD. Containment buildings thus join tanks and containers as hazardous waste
management units into which placement of waste does not constitute land disposal.
Containment buildings can therefore be used for treatment or storage of hazardous
waste at permitted or interim status treatment, storage, and disposal facilities
(TSDFs) as well as for temporary accumulation of hazardous wastes by a generator
before off-site management without triggering or violating any treatment
requirements under the land disposal restrictions (Figure 2).
The information in mis document is not by any means a complete representation ot bf A s regulations or policies,
but is an introduction to the topic used for Hotline training purposes.
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Containment Buildings - 5
Figure 2
CONTAINMENT BUILDINGS AND LDR
Placement of
Hazardous Waste in
Containment
Building
(Not Land Disposal)
I
Hazardous Waste Is
Treated to Meet.
LDR Treatment
Standards
i
Land Disposal in
Another RCRA
Unit
\ I /
The Circular >
Barrier Is '
Broken!
/ I \
While containment buildings were primarily developed to serve as a management
unit for hazardous debris and other bulky and high volume hazardous wastes, EPA
does not restrict their usage to these waste types. In fact> containment buildings may
be employed for storage or treatment of any nonliquid hazardous waste. Liquid or
semi-liquid wastes are typically more difficult to handle and pose an increased risk
of a release into the surrounding environment. For this reason, such wastes are
generally prohibited from management in containment buildings. Liquid wastes
include wastes which flow under their own weight to fill the container in which.
they are placed> are readily pumpable, or release such large quantities of liquid into
the unit that the liquid collection and removal system cannot prevent
accumulation. Wastes that contain free liquids but do not meet the given definition
of liquid (i.e., wastes that do not flow, are not pumpable, and do not release a
sufficiently large quantity of. liquids) may be placed in a containment building,
provided the unit conforms to several relevant design limits specified later in this
module. As an alternative, liquid wastes may be placed in tanks that are located
inside the containment building. In such cases, the building serves as secondary
The information in this document is not by any means a complete representation of EPA s regulations or policies,
but is an introduction to the topic used for Hotline training purposes.
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6 - Containment Buildings
containment for the hazardous waste tank and must comply with all applicable
secondary containment provisions in Subpart J of Parts 264/265. .
In addition to storage, containment buildings can be used for treatment of
hazardous waste by generators or TSDFs. Any method of treatment may be
employed except for thermal treatment processes.
As discussed, above, liquid hazardous wastes may not be placed in containment
buildings for storage or treatment. When required as part of treatment to meet LDR,
however, the addition of liquids is permissible under certain conditions. .If
treatment of a hazardous waste requires the addition of liquids, such treatment
must be conducted in designated "liquid-proof" areas within the unit, and any :
excess liquids must be removed as soon as practicable to preserve the integrity and
effectiveness of the unit and the secondary containment system. v
2.2 DESIGN STANDARDS
The performance standards for most hazardous waste management units vary
depending on whether the unit is permitted or is operating under interim status. In
the regulations for containment buildings, however, EPA promulgated the same
design and operating criteria for both permitted and interim status units.
EPA wrote the standards for containment buildings to parallel those provided for
hazardous waste tanks.' Design standards comprise a significant portion of the
Subpart DD regulations, and are crucial to protection of human health and the
environment. These standards primarily consist of requirements for structural
soundness and specific measures to prevent infiltration of Waste into the unit or
migration into the adjacent environment. Because of the importance of such
standards, before use, a professional engineer must certify that the unit is
satisfactorily designed and installed according to the specifications discussed below.
Sections 264/265.1101(a) of the regulations detail the design standards to which the
building itself must conform. The containment building must be completely
enclosed with four walls, a floor, and a roof. The floor, walls, and roof must be
constructed of man-made materials possessing sufficient structural strength to
withstand movement of wastes, personnel, and heavy equipment within the unit.
Doors and windows need not meet these standards, but the building must be
strategically designed with interior walls and partitions to ensure that wastes do not
come into contact with them. Dust control devices, such as air-lock doors or
negative air pressure systems (which pull air into the containment building), must
be used as necessary to prevent fugitive dust from escaping through these building
exits. All surfaces in the containment building that come into contact with waste
during treatment or storage must be chemically compatible with that waste.
Incompatible wastes that could cause unit failure cannot be placed in containment
buildings.
The inform^ttoniinfiirSocumenrisixot by anylneansacomplete representation of EPA's regulations or policies,
but is an introduction to the topic used for Hotline training purposes.
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Containment Buildings - 7
The remaining containment building design standards establish a system of barriers
between hazardous wastes in the unit and the surrounding environment. The floor
of the containment building is considered the unit's primary barrier, since it is the
first measure used to prevent wastes from being released into the ground beneath
the building. Construction materials vary with the type of wastes to be managed in
the containment building, but concrete floors are typical. If liquids are not managed
in the containment building, no further design criteria are applicable. Figure 3
summarizes the standards required for containment building design if no liquids
are to be managed in the unit.
Figure 3 .
CONTAINMENT BUILDING DESIGN STANDARDS
Regulated
Portion of
Unit
Design Criteria (if.no liquids are present)
Citations
Building
Must be constructed of man-made materials
, Must provide sufficient structural strength to
prevent unit failure
Must be completely enclosed
(floor/walls/roof)
Must have a decontamination area for
personnel, equipment and vehicles
§§264/265.1100(a)
§§264/265.1101(a)(2)
§§264/265.1101(a)(l)
§§264/265.il01(c)U)(iii)
Doors/Windows
Must be placed so as not to come into contact
with waste
Must have dust controls to minimize fugitive
emissions
§§264/265.1101(a){2)(ii)
§§264/ 265.1101(a)(2)(i)
Contact Surfaces
Must be chemically compatible with waste
§§264/265.1101(a)(2)
Primary Barrier
(floor)
Must be constructed of man-made material
, (typically concrete)
Mustjie structurally sound and chemically
compatible with waste
§§264/265.1100(a)
§§264/265.1101(a)(4)
If, however, the containment building is used to manage hazardous wastes
containing free liquids or if treatment to meet LDR treatment standards requires the
addition of liquids, the unit must be equipped with a liquid collection system, a leak
The information in this document is not by any means a complete representation ofEPA's regulations or policies,
' but is an introduction to the topic used for Hotline training purposes.
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8 - Containment Buildings
detection system, and a secondary barrier (§§264/265.1101(b)). The floor should be
sloped toward a sump, trough, or other liquid collection device to minimize
standing liquids in the containment building and to facilitate liquid removal. A
leak detection system must be constructed immediately beneath the unit's floor to
indicate any failure in the integrity of the floor and subsequent release of waste at
the earliest practicable time. A secondary barrier such as a liner must be constructed
around the unit to contain and to allow for rapid removal of any wastes escaping
the primary barrier before such wastes reach adjacent soils, surface water, or
groundwater. As with the unit floor, the secondary barrier must be structurally
sound and chemically resistant to wastes and liquids managed in the containment
building. In buildings where only certain areas are delineated for management of
liquid-containing wastes, these secondary containment standards are mandatory
only for "wet areas," provided waste liquids cannot migrate to the "dry areas" of the
containment building (§§264/265.1101(d)).' In view of the high cost of remediation,
however, EPA recommends that the entire unit be provided with secondary
containment to guard against unanticipated releases. Figure 4 summarizes the
additional design criteria for containment buildings used to manage liquids.
2.3 OPERATING STANDARDS
The owner or operator of each new or existing containment building must
implement operating controls and practices (§§264/265.1101(c)). Containment
building operating standards focus primarily on maintenance and inspection of the
unit, recordkeeping requirements, and provisions for response to releases of
hazardous waste.
As a matter of good housekeeping, the owner/operator of the unit must maintain
the floor so that it is free of significant cracks, corrosion, or deterioration. Surface
coatings or liners that are subject to wear from movement of waste, personnel, or
equipment must be replaced by the owner/operator as often as needed. EPA placed
certain limitations on how high hazardous waste may be piled within containment
buildings to ensure that no releases will occur should wastes slide under their own
weight. If the outer walls of the containment building are used to support the piles
of waste, hazardous waste cannot be piled higher than the portion of the wall that
meets the required design standards (also known as "containment walls"). If a
containment building has stalls or "crowd walls" that are used to segregate
hazardous wastes and these crowd walls prevent waste from contacting the
containment walls at any time, EPA does not limit the height of the piles of waste,
as long as the owner/opera tor can assure that the waste will always be contained
within the building's containment walls.
Dust control devices must be maintained at all openings to prevent visible
emissions from the unit under routine operating or maintenance activities,
including times when vehicles and personnel enter or exit the unit. A
decontamination area must be constructed within the containment building, and
The information in this document is not by any means a complete representation ot bfA s regulations or policies,
but is an introduction to the topic used for Hotline training purposes.
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Containment Buildings - 9
Figure 4
ADDITIONAL DESIGN CRITERIA FOR
CONTAINMENT BUILDINGS MANAGING LIQUIDS
Regulated
Portion of
Unit
Primary
Barrier
Design Criteria (if liquids are present)
Must be sloped toward liquid collection
device
Citations
§§264/265.1101(b)(2)(i)
Liquid
Collection
' System
Leak Detection
System
Must allow for removal of waste for proper
RCRA management
§§264/265.1100{c)(2)
. §§264/265.1101(b)(2)
Must detect release of waste at earliest
practicable time
§§264/265.1100(c)(3)
§§264/265.1101(b)(3)
Secondary
Barrier
Must be structurally sound and chemically
resistant to the waste
\ ,
Must contain and allow for removal of
accumulating wastes
Is required only for "wet .areas" within the
unit (recommended for both "wet" and "dry
. areas")
§§264/265.1101 (b)(3)(iii)
'§§264/265.1101(b)(3)
§§264/265.1101(d)
site-specific decontamination procedures must be followed as necessary to prevent
waste from being tracked out of the unit on personnel or equipment. Examples of
possible decontamination activities include washing vehicles and equipment prior
to leaving the building, dedicating vehicles for use only within -the unit, and
requiring employees to wear paper or cloth booties and coveralls which can be
removed before exiting the containment building. Under this controlled
environment, wastes and associated rinsate can be collected for proper waste
management. , »
The information in this document is not by any means a complete representation of EPA s regulations or policies,
but is an introduction to the topic used for Hotline training purposes.
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.10 - Containment Buildings
2.4 INSPECTIONS
Containment buildings must be inspected at least once every seven days, with all
activities and results recorded in the operating log. Such inspections involve
evaluation of unit integrity and visual assessment of adjacent soils and surface
waters to detect any signs of waste release. Data from monitoring or leak detection
equipment should also be considered.
2.5 RESPONSE TO RELEASES
" , . i
If a release is discovered during an inspection, the owner or operator must remove
the affected portion of the unit from service and take all appropriate steps for repair
and release,containment. The Regional Administrator must be notified of the
discovery .and of the proposed schedule for repair. Upon completion of all necessary
repairs and cleanup, a qualified, registered, professional engineer must verify that
the plan submitted to the Regional Administrator was followed. This verification
need not come from an independent engineer!
2.6 CLOSURE
At closure of a containment building, all applicable provisions in Subparts G and H
of Parts 264 and 265 must be followed. More information on the closure
requirements can be found in the module entitled Closure/Post-Closure. Beyond
these guidelines, §§264/265.1102 require removal or, decontamination of all
associated waste residues, contaminated soils, and contaminated system
components and equipment (e.g., inner and outer building walls, filters used in dust
control systems, forklifts, and other vehicles used in the building). If it is
determined that not all contaminated soils can be removed or decontaminated, the
unit will be considered a landfill for purposes of closure, post-closure, and financial
responsibility, and must follow the closure requirements in §§264/265.310.
Although closure as a landfill may be necessary, the containment building
regulations do not specifically mandate preparation of contingent landfill closure
and post-closure plans. \
The information in this document is not by any means a complete representation of EPA s regulations or policies,
but is an introduction to the topic used for Hotlii
tline training purposes.
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Containment Buildings -11
3. SPECIAL ISSUES
Containment buildings may be used for temporary accumulation. .Under the
regulations in §262.34(a)(l)(iv), a generator may accumulate hazardous waste in a
containment building for up to 90 days without requiring a permit, provided he or
she:
./ v
Complies with the technical standards in Part 265, Subpart DD ,'
\
Obtains certification from a professional engineer that the building
conforms to the design standards specified in §265.1101 ;
Prepares a written description of the procedures used to ensure that
wastes remain in the unit for no more than 90 days
Maintains documentation that those procedures are followed.
As stated in §262.34, generator accumulation containment buildings are exempt
from most of the closure and financial assurance requirements in Part 265, Subparts
G and H. Nevertheless, after the useful life of the building has expired, generators
must close the unit in compliance with §§265.111 and 265.114. These sections relate
to the closure performance standard, and disposal or decontamination of
equipment, structures, and soils.
Since §262.34(d) does not include a provision for these units, all generators of more ,
than 100 kilograms of waste per month who manage wastes in containment .
buildings must comply with the requirements applicable to large quantity generators
in §262.34(a). Consequently, small quantity generators using containment, buildings
do not have the 180 days of accumulation time customarily afforded to a small
quantity generator's tanks or containers. The maximum generator accumulation
time period in containment buildings is 90 days. Generators using containment ,
buildings must also comply with the large quantity generator requirements for
personnel training, development of a full contingency plan, and biennial reporting.
Conditionally exempt small quantity generators, however, are not subject to either
the containment building management standards or the time limit of 90 days.
Another special issue concerns converting a waste pile into. a containment building.
Treatment, storage, or disposal facilities operating indoor waste piles under the
regulations in Parts 264/265, Subpart L, may convert those units to containment
buildings by completing a few administrative actions. For permitted waste piles, the
conversion to containment building status is accomplished through submittal of a
permit modification. Interim status waste piles may be converted to containment
buildings 'only after receiving approval from the Agency and submitting a revised
permit application. After the conversion, only the standards in Parts 264/265,
Subpart DD, would be applicable. , -_
eans a competereprentatiOToFEPA's regulations or policies,
but is an introduction to the topic used for Hotline training purposes.
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