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In previous posts we have talked about containment buildings, what they are, how they came to be, and what regulations are in place for how they must be designed and built. Today we’re going to talk about what has to happen after the building has been made. What must be done operationally to keep things compliant? According to 40 CFR §264/265.1101(c), “the owner or operator of each new or existing containment building must implement operating controls and practices.” These operating controls or practices focus on four main areas: maintenance of the unit, inspection, recordkeeping, and plans for response to potential release of waste.

How a Containment Building Should be Maintained

Working from the bottom up, owners and operators of containment buildings must make sure that the floor is in good shape and free of cracks, corrosion, and/or deterioration. Additionally, if wear from movement of waste, equipment, or personnel causes any damage to surface coatings or liners, owners must make repairs as often as needed.

The EPA also set limits on how high wastes could be stacked within containment buildings. This was done in order to prevent potential releases due to wastes shifting under their own weight. According to §264/265.1101(c)(1)(ii), “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’).”

Dust control and decontamination areas round out maintenance. Dust control devices must be maintained at all openings so that no visible emissions can escape during routine operating activities. This includes times when equipment or personnel enter or exit the building. In much the same vein, decontamination areas must be constructed in the containment buildings so that no waste can be tracked out by equipment or personnel.

How to Inspect Containment Buildings and What Data to Record

According to the EPA, containment buildings have to be inspected once every seven days and all activities and results have to be recorded in the operating log. Inspections need to include an evaluation of the integrity of the unit. Additionally, there should be a 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.

How to Plan a Response to Releases

During the inspections, owners and operators should be especially vigilant about looking for leaks or releases. If one is found, the EPA instructs owners to, “remove the affected portion of the unit from service and take all appropriate steps for repair and release containment.” After doing so, “the implementing agency must be notified of the discovery and of the proposed schedule for repair.” Once repairs and cleanup are completed a qualified, registered, professional engineer must verify that the submitted plan for repair was followed.

If your company utilizes containment buildings remember these guidelines. Do you have any other advice for owners or operators? Perhaps a plan that has worked well for you in the past?  Let us know in the comments!

All information for this blog post was gathered from the EPA document, “Introduction to Containment Buildings.” As always, this blog post is not intended to be comprehensive and it is always best to check with the EPA and local government for full, up-to-date, rules and regulations.

We wrote a couple of weeks back about the design requirements of containment buildings. This included buildings needing to be fully enclosed with a floor, walls and a roof constructed of manmade materials which have, “sufficient structural strength to withstand movement of wastes, personnel, and heavy equipment within the unit,” among others. At the end of that post we noted that the design specifications for containment buildings that will hold liquid wastes are different/even more stringent.

According to the EPA, “If…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)).” Additionally the floor of the containment building needs to be sloped towards a sump, trough, or other collection device. This is done to minimize the amount of standing liquids in a containment building and to help enable liquid removal.

On top (or on bottom rather) or the building requirements, there must be a leak detection system beneath the floor to alert of any waste leaking through the primary barrier (the floor). A secondary barrier is also mandatory for liquid containing buildings just in case the primary should leak. This helps ensure that the wastes will not reach the soil, surface, or groundwater.

The EPA specifies that, “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.” That said, the costs of renovation should plans change leads the EPA to recommend installing your secondary barrier under the entire building.

The EPA provides the following table to further clarify the additional design requirements for containment buildings housing liquid wastes.

Containment Building Design Standards Liquid

 

All information for this blog post was gathered from the EPA document, “Introduction to Containment Buildings.” As always, this blog post is not intended to be comprehensive and it is always best to check with the EPA and local government for full, up-to-date, rules and regulations.

We discussed containment buildings in a previous post where we detailed what they are and how they came to be. Today we’re going to take a closer look at how containment buildings must be designed and what measures are taken to ensure protection of human health and the environment.

When the EPA wrote the standards for containment buildings they modeled them closely after those for hazardous waste tanks. Because the standards are so important to the protection of human health and the environment they are primarily regulations concerning structural soundness and measures that must be set to prevent wastes in the buildings from leaking and getting into the environment. In order to ensure these regulations and measures are met, a professional engineer must inspect and certify a containment building before it can be used.

Section 24/265.1101(a) details design standards that containment buildings must meet. These standards include needing to be fully enclosed with a floor, walls and a roof constructed of manmade materials which have, “sufficient structural strength to withstand movement of wastes, personnel, and heavy equipment within the unit.” Doors and windows don’t need to meet the standards but the building must be designed in such a way that wastes will never come in contact with them.

Controlling dust emissions is another key point. According to the EPA, “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.”

Additionally, much like wastes must be compatible with their containers, surfaces that come in contact with the wastes being stored in the containment building must be chemically compatible with the wastes.

“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.”

The table below details the standards required for containment buildings which manage no liquids. Keep checking our blog for more details about containment buildings housing liquid wastes.

Containment Building Design Standards resized 600

 

All information for this blog post was gathered from the EPA document, “Introduction to Containment Buildings.” As always, this blog post is not intended to be comprehensive and it is always best to check with the EPA and local government for full, up-to-date, rules and regulations.

Prior to the EPA’s development of the concept of containment buildings in 1992 certain heavy or bulky hazardous wastes were a serious problem for generators. Because of the issues that these wastes posed, the EPA developed standards for a new waste management unit (containment buildings). A containment building is basically a structure in which solid hazardous wastes can be stored and managed without violating LDR. It is a fully enclosed structure (meaning it has at least 4 walls, a roof, and a floor) which houses an accumulation of noncontainerized waste.

Why did EPA need containment buildings?

Before the EPA decided that containment buildings (like tanks or containers) could serve as hazardous waste management units, a collection of noncontainerized waste within a roofed structure would have been considered an indoor waste pile and as such would have been subject to regulations and standards in Subpart L of 264/265.

Because some debris wastes are better suited to storage and treatment in waste piles as opposed to in tanks or containers it made more sense to treat them in such a way. Placement of untreated debris in piles prior to it being treated, however, violated LDR regulations in part 268.

The EPA provides the following example; “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. 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.’ Managing hazardous waste in certain types of units, including landfills, surface impoundments, and waste piles, constitutes “land disposal,” which may not occur until the waste has been treated to meet LDR standards.

Circular BarrierCertain 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.”

What this all boils down to is that prior to the creation of containment buildings, there were some types of waste that were nearly impossible (or at least very difficult) to properly treat and dispose of. The idea behind containment buildings is that they break the aforementioned circular barrier and allow all hazardous waste to be handled properly.

The EPA made the decision to exclude containment buildings from the regulations imposed by LDR based on the belief that a totally closed off unit, designed in compliance with the regulations in Part 264/265 subpart DD, can provide an equal level of containment as tanks and containers. Ergo containment buildings joined the fold and can now house waste without violating LDR.

Keep checking the blog for more posts about containment buildings. So does your company utilize containment buildings? How have they helped your process? Let us know in the comments section!

All information for this blog post was gathered from the EPA document, “Introduction to Containment Buildings.” As always, this blog post is not intended to be comprehensive and it is always best to check with the EPA and local government for full, up-to-date, rules and regulations.