Due diligence is mostly thought of in terms of new property acquisition. However, avoiding environmental liability, costly fines, and even jail time in extreme cases, can come into play during other phases of the ownership cycle. If you own or are considering purchasing property with existing structures you may want removed, building demolition requires informed planning and carries regulatory consequence if certain conditions are not met. Many of these same factors are in play if you prefer to renovate or decommission a facility.
[su_heading size=”18″ align=”left”]Building Demolition[/su_heading]
When building demolition is planned, a number of environmental issues can arise. In many industrial and manufacturing facilities, process and production equipment must be decommissioned. This requires a thorough understanding of the processes and knowledge of all raw materials, intermediates, finished products and waste streams.
Prior to building demolition, buildings should be surveyed for building materials that may require removal or special handling procedures. These include: asbestos, lead Paint, mold, PCB-containing electrical components, mercury-containing light tubes, switches, and thermostats, underground storage tanks (USTs), above-ground storage tanks (ASTs), refrigerants, and other remaining miscellaneous chemicals/products.
Surveys for some of these regulated building materials require qualified personnel who are licensed to perform this type of work. Accreditation’s, certifications and other requirements for performing asbestos and lead inspections are specified by federal, state and local regulations. A pre-demolition survey is usually destructive and requires sampling of suspect materials. Accredited building inspectors should perform such activity. The age of the building does not preclude it from survey requirements.
Following the completion of the building materials survey, the owner may contract with a qualified environmental, health and safety (EHS) consultant to develop abatement or remediation bid documents, including contract documents, technical specifications and drawings. These documents should be clear and concise. They should also follow industry standards such as those developed by the Construction Standards Institute. This approach allows owners to obtain “apples-to-apples” bids from various contractors, which can improve quality and control project costs.
During remediation, a qualified EHS professional should provide oversight to ensure compliance with applicable regulations and contract documents. At the completion of the project, clearance inspections and sampling should be conducted, as necessary.
Project records should be used to document the procedures followed (they should be retained by the owner). This documentation is helpful when the property is ready to be sold.
[su_heading size=”18″ align=”left”]Building Renovation[/su_heading]
If structures are scheduled for renovation, similar surveys are often performed. In the case of renovation, it is crucial for EHS professionals to understand the complete scope of the project. They should attend design meetings in order to completely understand how the renovation will impact all areas of the building. If the EHS professional is included in the early stages of the planning and design process, significant schedule delays and material impacts can be minimized. For example, if the electrical engineer for the project indicates that new conduit must be installed above the ceiling, the EHS professional can recommend preferred areas for the conduit to be installed (in order to minimize impacts to ACM).
The cost of removing materials such as asbestos is often lower during renovation, since interior demolition may increase the accessibility of the ACM. EHS professionals should review the short-term and long-term costs of leaving regulated building materials in place. When these materials remain in place, an O&M program can be developed and implemented.
[su_heading size=”18″ align=”left”]Conclusion[/su_heading]
The redevelopment of properties often involves planning and integration of environmental remediation activities. EHS professionals can assist developers, redevelopment agencies and owners, as well as facility operators, in mitigating the environmental impacts that often go hand in hand with these efforts. Understanding and managing EHS-related issues throughout the life of a property facilitates compliance with regulations, reduces potential liabilities and leverages property values.
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