United States
Environmental
Protection Agency
Solid Waste and
Emergency Response
(5305W)
EPA530-R-99-045
PB2000-101 885
February 2000
RCRAf Superfund & EPCRA
Hotline Training Module
Introduction to:
Containment Buildings
(40 CFR Parts 264/265, Subpart DD)
Updated October 1999
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DISCLAIMER
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 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 ofthe Hotline training and is not used as a reference toolon Hotlinecalls.
The Hotline revises and updates this document as regulatory pro gram areas change.
The information in this docume nt may not necessarily reflect the current position of the Agency. This document is
not intended and cannot be relied upon to create any rights, subs tan live 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) (800) 424-9346
Local number (within DC area) (703) 412-9810
National toll-free for the hearing impaired (TDD) (800) 553-7672
The Hotline is open from 9 am to 6 pm Eastern Time,
Monday through Friday, except for federal holidays.
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CONTAINMENT BUILDINGS
CONTENTS
1. Introduction 1
2. Regulatory Summary 2
2.1 Applicability 2
2.2 Design Standards 5
2.3 Operating Standards : 8
2.4 Inspections 9
2.5 Response to Releases 9
2.6 Closure 10
3. Special Issues : 11
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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 LDR 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.
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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2 - Containment Buildings
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 LDR, the provisions for containment buildings were promulgated on
August 18,1992 (57 FR 37194). Regulations applicable to containment buildings are
codified in 40 CFR Part 264/265, 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 Part 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.
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Containment Buildings - 3
Figure 1
THE CIRCULAR BARRIER
TO TREATMENT OF CERTAIN HAZARDOUS WASTES
Placement of
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 Part 264/265, Subpart DD. Containment
buildings thus join tanks, containers, and drip pads 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 LDR
(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.
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4 - Containment Buildings
Figure 2
CONTAINMENT BUILDINGS AND LDR
Placement of
Hazardous Waste in
Containment
Building
(Not Land Disposal)
Hazardous Waste Is
Treated to Meet
LDR Treatment
Standards
I
Land Disposal in
Another RCRA
Unit
\
The Circular
' Barrier Is ~
. Broken!.
While containment buildings were primarily developed to serve as management units
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
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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Containment Buildings - 5
secondary containment for the hazardous waste tank and must comply with all
applicable secondary containment provisions in Subpart J of Part 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.
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 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 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
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
compatible with that waste. Incompatible wastes that could cause unit failure cannot be
placed in containment buildings.
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)
§§264/265.1101(c)(l)(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)
• Must be structurally sound and chemically
compatible with waste
§§264/265.1100(a)
§§264/265.1101(a)(4)
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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Containment Buildings - 7
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 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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8 - Containment Buildings
Figure 4
ADDITIONAL DESIGN CRITERIA FOR
CONTAINMENT BUILDINGS MANAGING LIQUIDS
Regulated
Portion of
Unit
Design Criteria (if liquids are present)
Citations
Primary
Barrier
Must be sloped toward liquid collection device
§§264/265.1101(b)(2)(i)
Liquid
Collection
System
• Must allow for removal of waste for proper
RCRA management
§§264/265.1100(c)(3)
§§264/265.1101(b)(2)
Leak Detection
System
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)
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 and 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 and 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 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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Containment Buildings - 9
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 and operator 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 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.
2.4 INSPECTIONS
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.
2.5 RESPONSE TO RELEASES
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.
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
2.6 CLOSURE
At closure of a containment building, all applicable provisions in Subparts G and H of
Part 264/265 must be followed. More information on the closure requirements can be
found in the module entitled Closure and 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 Hotline 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:
• 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. TSDFs
operating indoor waste piles under the regulations in Part 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 Part 264/265, Subpart DD, would be applicable.
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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