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Do You Have Hazardous Waste? Should You Be Using A Containment Building?

Hazardous Waste Containment BuildingsWhat is a Containment Building?

Hazardous Waste Containment buildings are designed and constructed of man-made materials with the strength to be self-supporting. They have walls, a floor, and a roof and are waste management units similar to tanks, containers, and drip pads since placement of waste in them does not constitute land disposal (which would trigger, as a result, compliance with the land disposal restrictions (LDRs)). Containment buildings are used to store bulk waste that is difficult to store in containers or tanks. Hazardous waste in the containment buildings must be treated to meet LDR treatment standards before its land disposal. Containment buildings can also be used as hazardous waste treatment units for any method of treatment except thermal treatment processes.

Below is a partial list of what is typically stored in the containment buildings… 

  • Lead from lead-battery plates
  • Lead slags
  • Spent potliners from aluminum production
  • Contaminated soil
  • Although primarily used as management units for hazardous debris and other bulky and high-volume hazardous wastes, containment buildings can be used for storage or treatment of any nonliquid hazardous waste.

Containment Buildings Rules for Large Quantity Generators (LQGs)

Large quantity generators (LQGs) (persons 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.

LQGs using containment buildings must…

  • 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

Containment Building Rules for Small Quantity Generators (SQGs)?

Small quantity generators (SQGs) (persons 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 on-site accumulation of hazardous waste in the containment building to the LQG restriction of 90 days.

Need someone to help you with your hazardous waste?  We deal with these issues every day.  Contact Us (859-689-9222) to get more information about how we can help.

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