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Containment Buildings: What are they and how did they come to be?

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.

How do Land Disposal Restrictions and the EPA Protect Groundwater?

You may not know this but a large portion of the hazardous waste management regulatory program (including Land Disposal Restrictions or LDR) deal with the protection of groundwater. These programs are put in place to protect us from having dangerous chemicals in the water we drink. The process by which hazardous waste can contaminate the groundwater is called leaching. Waste can be leached by water filtering down through the ground and drawing the contaminants out of buried wastes. As the water continues its trajectory those wastes can be carried and introduced into the groundwater.

Treatment of Wastes

In order to avoid this potentiality, Congress decided on two primary ways to circumvent this danger. The first is by reducing a waste’s toxicity by destroying or removing the harmful contaminants. The EPA provides the following example, “many of the chemicals capable of contaminating groundwater are organic compounds. Incineration or burning can destroy these organic compounds, usually breaking them down into less dangerous byproducts like carbon dioxide and water. Thus, incineration of organic-bearing hazardous wastes can protect groundwater by destroying organic contaminants before they have a chance to enter underground water supplies. The obvious advantage of such hazardous waste treatment is that it provides a more permanent and lasting form of groundwater protection than hazardous waste containment. Structural barriers separating hazardous contaminants from groundwater may eventually break down or leak. In contrast, treatment that destroys harmful contaminants or reduces a waste’s toxicity before it enters the environment is a permanent groundwater protection solution.”

Stabilization of Wastes

This leads us into the second way Congress saw to protect groundwater; immobilizing the hazardous contaminants. Due to the fact that not all hazardous wastes can be treated to remove toxicity, EPA determined another option. The EPA sites metal elements as common types of waste which cannot be broken down via combustion and provides the following explanation of how they can be handled; “treatment techniques other than incineration…can be used for such wastes. For example, through a process called stabilization or immobilization, metal contaminants can be chemically and physically bound into the wastes that contain them.  Although this treatment method does not reduce the overall concentration of toxic metals in a hazardous waste, it does immobilize these constituents, making them less likely to leach from the waste. Reducing the mobility or leachability of hazardous constituents in a waste is another means of achieving LDR’s groundwater protection goal.”

All this said, it is important to note that the LDR rules are not the only ones in place to protect groundwater. Actually, the EPA created a tiered approach to the protection of groundwater by attempting to prevent leachability of harmful constituents at three levels: LDR, LDUs, and groundwater monitoring. If you would like us to cover the other two tiers please let us know in the comments section!

All information for this blog post was gathered from the EPA document, “Introduction to Land Disposal Restrictions.” 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.

An Introduction to Land Disposal Restrictions (LDR)

Today we are going to walk through some of the basics of Land Disposal Restriction rules.

The regulatory citations at 40 CFR § 268 controls the disposal of any waste that is placed on the land. This includes underground injection, waste piles, surface impoundments, and landfills. These regulations impact all hazardous waste through wither administrative or technical requirements.

The basis for LDR is to protect the ground water. This is achieved by the rules in 40 CFR which established concentration based standards for land disposal in addition to management/engineering controls.

There are four types of treatment standards:

  • Total waste standards (totals analysis)
  • Waste extract standards (TCLP Analysis); or
  • Specified technology standards (specify a treatment technology by five letter code rather than constituent concentration)
  • Alternative treatment standards

Concentration-based universal treatment standards (UTS) specify a single numerical treatment standard for each organic, metal, and cyanide constituent, regardless of the type of waste, that must be met prior to land disposal.

Treatment standards are based on best demonstrated available technology (BDAT). That means that the treatment standards are not health or risk-based, they are dependent upon the best available technology. It is also important to note that LDR treatment standards attach at the point of initial generation.

The “point of generation” is the point at which the waste is first generated, not the point at which it exits a management system. For characteristic wastes, each “change of treatability group” can mark a new point of generation for making an LDR determination (e.g. separation of solids in wastewater treatment).

All this said, there are some general exclusions to the LDR regulations including:

  • Conditionally Exempt Small Quantity Generators (CESQGs) – these will generate 100 kilograms or less per month of hazardous waste, or 1 kilogram or less per month of acutely hazardous waste.
  • Waste pesticides and residues that farmers dispose of on their own property.
  • Selected low volume de minimus losses and laboratory wastes discharged to land based wastewater treatment facilities.

As always, remember that this blog is not intended to serve as an all-inclusive guide to standards. It is always best to check with local government and 40 CFR for the most up-to-date information.