A containment building is a totally enclosed, self-supporting structure with walls, a floor, and a roof that is used to store hazardous waste. It is designed and constructed of man-made materials with sufficient strength to be self-supporting.

A containment building is, itself, the waste management unit and is not just a building in which waste piles are stored. It is similar to tanks, containers, and drip pads in that they are all hazardous waste management units into which placement of waste does not constitute land disposal (which would trigger, as a result, compliance with the land disposal restrictions (LDRs)). Of course, the hazardous waste stored in the containment building must be treated to meet LDR treatment standards before its land disposal.

Containment buildings are typically used to store large amounts of bulk hazardous waste that are difficult to store in containers or tanks. Although primarily used for bulky and high-volume hazardous wastes, they can also be used for storage or treatment of any non-liquid hazardous waste.

In addition, containment buildings can be used as hazardous waste treatment units (for any method of treatment except thermal treatment processes), but the primary purpose of containment buildings is to store large amounts of hazardous waste before the waste is disposed of, recycled, recovered, treated, or transported off-site.

Containment Buildings Rules for LQGs

Large quantity generators (LQGs), facilities generating 1,000 kilograms (kg) or more of hazardous waste a month, may accumulate hazardous waste in containment buildings without a permit before treatment or disposal of the waste, provided they comply with RCRA’s 90-day accumulation rule for on-site accumulation of hazardous waste in containment buildings. The generator accumulation rule requires LQGs using containment buildings to:

  • Comply with the design, operation, and closure standards for containment buildings.
  • Obtain certification from a qualified professional engineer that the building conforms to the design specifications.
  • Prepare a written description of the procedures used to ensure that wastes remain in the containment building for no more than 90 days.
  • Prepare a written description of the waste generation and management practices for the facility showing that they respect the 90-day limit.
  • Maintain documentation that these procedures are followed.

Permit Exemption for LQGs

A LQG storing hazardous waste onsite in compliance with RCRA’s 90-day accumulation rule may use containment buildings and be exempt from RCRA’s containment building permit requirements, although the rules relating to the design, operation, and closure of containment buildings would still be applicable.

Containment Buildings Rules for SQGs

Small quantity generators (SQGs), facilities generating more than 100 kg but less than 1,000 kg of hazardous waste a month, may use containment buildings to accumulate hazardous waste, but only if they comply with the rules applicable to LQGs. This would require complying with the LQG personnel training, biennial report, and contingency plan requirements and would limit the onsite accumulation of hazardous waste in the containment building to the LQG restriction of 90 days. Essentially, you become a LQG.

Containment Building Design Standards

These standards focus on surface areas, a primary barrier, doors and windows, and, for buildings managing hazardous wastes containing free liquids, a liquid collection system and a secondary containment system. Certification that the facility has been properly designed is also required.

Surface Areas: such as walls, floors, and ceilings, must meet the following criteria:

  • They must be constructed of man-made materials.
  • They must have sufficient strength and thickness to be self-supporting and to support the waste contents, personnel, and equipment.
  • Surfaces that come in contact with hazardous wastes must be chemically compatible with the hazardous waste in the building.
  • Building design standards must be recognized by professional organizations generally recognized by the industry (e.g., the American Concrete Institute and the American Society of Testing Materials).

Primary Barriers: such as a geomembrane covered by a concrete surface, must meet the following criteria:

  • Constructed within the building to prevent the migration of hazardous constituents into the barrier.
  • The primary barrier must be made of material that can withstand the movement of personnel, waste, and equipment during the operating life of the containment building and be appropriate to the physical and chemical characteristics of the waste being managed.

Doors and Windows:

  • Must be placed so as not to come into contact with waste.
  • Must have dust controls to control fugitive dust emissions so that the doors and windows (and any other openings such as vents or cracks) exhibit no visible emissions. This state of no visible emissions must be maintained effectively at all times during routine operating and maintenance conditions, including when vehicles and personnel enter and exit the containment building.

Decontamination Area:

  • Must be designated within the containment building to decontaminate equipment, vehicles, and personnel.

Design Certification:

  • A qualified professional engineer must certify that the containment building has been designed and constructed in compliance with the containment building standards.

Managing Hazardous Waste Containing Free Liquids: such as liquids that readily separate from the solid portion of waste under ambient temperature and pressure. The presence of free liquids can be determined by the paint filter test, a visual examination, or other appropriate means. Although containment buildings may not be used to manage liquid hazardous waste, hazardous waste containing free liquids may be managed in a containment building, providing they meet the following criteria:

  • Must have design features that are in addition to those required for all buildings.
  • These additional requirements used to manage hazardous wastes containing free liquids are also necessary if treatment to meet land disposal restrictions (LDRs) treatment standards requires the addition of liquids.

Primary Barrier:

  • The design and construction of the primary barrier must prevent migration of hazardous constituents into the barrier.
  • The primary barrier must be sloped to drain liquids to the liquid collection system.

Liquid Collection System:

  • The containment building must have a liquid collection system that detects, collects, and removes, at the earliest practicable time, liquids accumulated on the primary barrier.
  • The liquid collection system must be designed and constructed of materials that minimize the accumulation of liquid on the primary barrier.

Secondary Containment System:

  • Must include a secondary barrier designed and constructed to prevent migration of hazardous constituents into the primary barrier.
  • Must include a leak detection system and must be capable of detecting and collecting waste that migrates into the primary barrier at the earliest practicable time.
  • In buildings where only certain areas are delineated for management of wastes containing free liquids, secondary containment is only required for these areas. However, measures must be taken to prevent the release of liquids or wet materials into areas without secondary containment, and the facility’s operating log must have a written description of the operating procedures used to maintain the integrity of areas without secondary containment. In view of the high cost of remediation, the EPA recommends that the entire containment building be provided with secondary containment to guard against unanticipated releases.

For more information, call Ralph Carito at Total Environmental & Safety (Total) at 908-442-8599 or email at rcarito@TotalEnviron.com