United States      Solid Waste and
          Environmental Protection Emergency Response
          Agency	(5305W)	
                         November 1997
RCRA, Superfund & EPCRA
    Hotline Training Module
             Introduction to:
                   Containment Buildings
                 (40 CFR Parts 264/265, Subpart DD)
                     Updated July 1997

This document was developed by Booz- Allen & Hamilton Inc. under contract 68-WO-0039 to EPA. It is
intended to be used as a training tool for Hotline specialists and does not represent a statement of EPA

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 Time,
                          Monday through Friday, except for federal holidays.

                    CONTAINMENT BUILDINGS


1.  Introduction	  1

2.  Regulatory Summary	  3
   2.1 Applicability	  3
   2,2 Design Standards	  6
   2.3 Operating Standards	  8
   2.4 Inspections	10
   2.5 Response to Releases	10
   2.6 Closure	10

3.  Special Issues	11
                                                                            il ,*.


                                                             Containment Buildings -1
                           1.  INTRODUCTION

Through the inception of the Resource Conservation and Recovery Act (RCRA)
program, EPA has created a system of hazardous waste management that is
protective of human health and the environment, yet not overly burdensome 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 (e.g., lead slags, spent
potliners, and contaminated debris). 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

     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.
  The information in this document is not by any means a complete representation of EPA s regulations or policies,
                 but is an introduction to trip topic used for Hotline training purposes.

2 - Containment Buildings
   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.

                                                             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
264/265, Subpart DD.

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 264/265.  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.
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.

4 - Containment Buildings
                                   Figure 1
                          THE CIRCULAR BARRIER
                                 Placement of
                              Hazardous Waste in
                                  a Waste Pile
                                (Land Disposal)
  but treatment of certain
     hazardous wastes
 cannot easily be conducted
cannot occur
                             Hazardous Waste Is
                                  Treated to
                             Meet LDR Treatment
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 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.

                                                              Containment Buildings - 5
                                    Figure 2
                                  Placement of
                               Hazardous Waste in
                               (Not Land Disposal)
                               Hazardous Waste Is
                                 Treated to Meet
                                 LDR Treatment
                                Land Disposal in
                                 Another RCRA
                                   The Circular
                                    Barrier Is 	

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.

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.

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 virtually 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
  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.

                                                                   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
     Portion of
   Design Criteria (if no liquids are present)
  Must be constructed of man-made materials

  Must provide sufficient structural strength to
   prevent unit failure

  Must be completely enclosed

  Must have a decontamination area for
   personnel, equipment, and vehicles



   Must be placed so as not to come into contact
   with waste

   Must have dust controls to minimize fugitive
                                                                 264/265.1101 (a)(2)(ii)
   Contact Surfaces
   Must be chemically compatible with waste
8 - Containment Buildings
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
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.

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")
(264/265.1101(c)(l)(ii)). 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/operator can assure that the waste will always be
contained within the building's containment walls.
  The information in this document is not by any means a complete representation of EPA's regulations or polices,
                 but is an introduction to the topic used for Hotline training purposes.

                                                                 Containment Buildings - 9
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

                                      Figure 4
     Portion of
    Design Criteria (if liquids are present)
  Must be sloped toward liquid collection
  Must allow for removal of waste for proper
   RCRA management
   Leak Detection
*  Must detect release of waste at earliest
   practicable time
   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


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
  The information in Otis 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.

10 - Containment Buildings

Containment buildings must be inspected at least once every seven days, with all
activities and results recorded in the operating log (264/265.1101(c)(4)). 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.

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.

At closure of a containment building, all applicable provisions in Subparts G and H
of Parts 264/265 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 aocument 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.

                                                            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

      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(a)(l)(iv), 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 use of 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.

                but is an introduction to the topic used for Hotline training purposes.

12 - Containment Buildings
  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.