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Local government activities related to buildings include new construction of schools, public housing, administrative, and other government buildings; maintaining and repairing those buildings; renovating old buildings; and demolishing unusable buildings. These activities have the potential to impact the environment, and may be regulated under U.S. environmental regulations. New building construction includes clearing land, building the structure, and disposing of construction materials. Building maintenance and repair typically include the operation of boilers and cooling systems, and the application of pesticides. The renovation and demolition of buildings can involve the removal and disposal of asbestos and lead paint. Each of these activities is regulated under a section of EPA environmental regulations. More detail on the specific activities related to buildings and the respective regulations is presented below.
· Activities with aspects regulated under the CWA:
- New construction
- Maintenance and repair
· Activities with aspects regulated under RCRA:
- Maintenance and repair
- Renovation and demolition
· Activities with aspects regulated under the ESA:
- New construction
· Activities with aspects regulated under the Rivers and Harbors Act:
- New construction
· Activities with aspects regulated under the CAA:
- New construction
- Maintenance and repair
- Renovation and demolition
· Activities with aspects regulated under NEPA:
- New construction
· Activities with aspects regulated under Emergency Planning and Community Right-to-Know Act (EPCRA)/Comprehensive Environmental Response, Compensation and Liability Act (CERCLA):
- Maintenance and repair.
· Activities with aspects regulated under Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA):
- Maintenance and repair
· Activities with aspects regulated under TSCA:
- Maintenance and repair
- Renovation and demolition.
New Construction
As with the construction of roads, bridges, and tunnels, the construction of new buildings involves clearing land, building the structure, and disposing of construction materials. The impacts and regulations of these activities are similar to those discussed previously for roads, bridges, and tunnels.
Similar to road/bridge/tunnel construction wastes, most of the waste generated through building construction activities is nonhazardous solid waste. The disposal of these wastes may be regulated under a variety of federal, state, and local laws. If generated, hazardous construction wastes are regulated under the federal RCRA hazardous waste regulations. Many states and local governments have regulations regarding the disposal of nonhazardous construction and demolition debris at special construction waste landfills. Many states allow debris such as uncontaminated concrete and asphalt to be used as fill material.
Maintenance and Repair
Local governments are responsible for activities related to the maintenance and repair of buildings, including the operation of boilers and cooling systems, and the application of pesticides. These operations and how they are regulated are described below.
Indoor Air Quality - Radon
Over the past 40 to 50 years, there has been an increase in exposure to indoor air pollutants partly because of construction of more tightly sealed buildings, reduced ventilation rates to save energy, the use of synthetic building materials and furnishings, and the use of chemically-formulated personal care products, pesticides, and housekeeping supplies. In recent years, comparative risk studies performed by EPA and its Science Advisory Board have consistently ranked indoor air pollution among the top five environmental risks to public health. Radon is one particular indoor air pollutant of concern associated with this issue. Common effects of indoor air quality problems on occupants include headache; fatigue; shortness of breath; sinus congestion; coughing and sneezing; eye, nose, throat, and skin irritation; dizziness; and nausea.
Radon levels can vary from structure to structure. The average indoor radon level is estimated to be about 1.3 picocuries per liter (pCi/L), and about 0.4 pCi/L of radon is normally found in the outside air. The U.S. Congress has set a long-term goal that indoor radon levels be no more than outdoor levels. While this goal is not yet technologically achievable in all cases, most structures today can be reduced to 2 pCi/L or below. EPA recommends follow-up radon testing or mitigation in buildings with levels of 4 or more pCi/L.
At this time, local governments are not required to enforce any standards for acceptable radon levels in commercial or residential buildings, including schools. State and local governments can, if they choose, pass legislation recommending radon mitigation to owners of buildings in which the radon level is greater than 4pCi/L, however, this is presently not a required activity under the CAA or any other major environmental law.
The federal government, as well as most state and local governments, do not have regulations or established enforcement capabilities regarding indoor air quality in buildings (including schools). For some schools, assistance may be available from the local or state departments of health or environment. The federal or state OSHA office may also provide some help.
Boiler Operations
Local governments are often required to operate boilers to produce steam or electricity to heat government buildings. Boiler operations include storing fuels and boiler chemicals, operating the boiler, maintaining the boiler, and disposing of residuals from fuel burning. Storage of fuels and chemicals can impact the environment through spills that have the potential to reach groundwater or surface waters. Operating boilers may impact the environment through air emissions from fuel burning. Coal ash from fuel burning can contaminate waterways if it contains heavy metals or other toxics and is not disposed in a manner that prevents it from coming in contact with waterways or rainwater.
The storage of liquid boiler fuel (e.g., heating oil) may be regulated under the Spill Prevention, Control and Countermeasures (SPCC) program of the CWA, which may require a facility to develop spill prevention plans. The storage of chemicals may be regulated under EPCRA or Section 112(r) of the CAA (risk management plans), requiring the development of emergency plans and reporting based on the quantity of chemicals stored. In the event of a chemical spill, local governments are required to follow the emergency notification procedures provided under EPCRA or CAA Section 112(r). Disposal of residuals, such as coal ash, may be regulated under RCRA, depending on the metals or other toxics contained in the ash. Air emissions from the boiler may be regulated under the CAA which requires the local government to obtain a permit and meet emissions standards depending on the heat output of the boiler and date of boiler construction.
Cooling Systems
Local governments operate cooling systems to maintain temperature in government buildings. Cooling systems may be used for overall building temperature management and for food storage in cafeterias. Cooling systems contain refrigerants, such as chlorofluorocarbons (CFCs) or ammonia. If released, CFCs have the potential to harm the environment because they are ozone-depleting substances. Maintenance of cooling systems is regulated under the CAA. Maintenance is required to be conducted by certified personnel who are using certified equipment and following specified guidelines for reclaiming CFCs. The storage and use of ammonia may require reporting under EPCRA or CAA Section 112(r).
Pesticide Application
Maintaining buildings includes applying pesticides to eliminate vectors (e.g., insects, rodents) that spread disease, and plants and insects that can harm the structural integrity of the building. Frequently used pesticides include herbicides, insecticides, fungicides, and plant growth regulators. Pesticides are also used on building exteriors for aesthetics. Improper application of pesticides indoors can harm human health, causing respiratory and skin infections, and even death. Improper outdoor application can cause health problems in humans, while also destroying flora and fauna and contaminating groundwater and surface water supplies through infiltration and runoff. See Section III.B. for detailed description of pesticide management activities.
Renovation and Demolition
Renovation and demolition of buildings can impact the environment as materials that may have previously been trapped within the building structure become exposed to the environment.
Two activities with the potential to significantly impact human health and the environment are the removal and disposal of asbestos and the removal and disposal of lead paint.
Asbestos
Buildings owned by local governments may very well contain asbestos or asbestos-containing materials (ACM). Used for insulation and as a fire retardant, asbestos and ACMs can be found in a variety of building construction materials, including pipe and furnace insulation materials, asbestos shingles, millboard, textured painted and other coating materials, and floor tiles. When encapsulated, asbestos fibers do not impact human health or the environment. However, during renovation or demolition, asbestos fibers may be released. If inhaled or ingested, asbestos fibers can cause respiratory damage. Renovation and demolition activities are regulated under the CAA, which requires local governments to contact EPA prior to renovation or demolition, use only accredited trained personnel and appropriate equipment for asbestos removal, and follow specified procedures for asbestos disposal.
Asbestos is recognized as the greatest environmental concern to schools. If a local government owns or operates a school building constructed or insulated with asbestos, particularly if renovations or demolitions occur that release fibers, then indoor air quality can be impaired and people might suffer severe respiratory and other health problems. Local governments operating schools could face enforcement actions pertaining to asbestos-related violations.
In October 1986, Congress passed the Asbestos Hazard Emergency Response Act (AHERA), which required EPA to establish a comprehensive regulatory framework within which local governments would inspect, manage, plan, and conduct operations and maintenance (O&M) activities and appropriate abatement responses to control ACM in schools. To this end, EPA promulgated the asbestos-containing materials in schools rule in October 1987.1
Many states and local governments have since developed comprehensive asbestos management/control programs, and/or abatement contractor certification programs. In addition, EPA National Emission Standard for Hazardous Air Pollutants (NESHAP) for Asbestos regulate asbestos emissions during building demolition or renovation and the transport and disposal of asbestos waste. Also according to federal regulations, school building owners are supposed to inspect school buildings for friable and nonfriable asbestos materials, including reviewing building records, inspecting and sampling materials, and mapping the locations of confirmed or suspected asbestos locations.
Buildings built in the sixties are more likely to have asbestos-containing sprayed- or troweled-on friable materials than other buildings. EPA banned the use of asbestos containing materials in the 1970s.
Lead-Based Paint
Lead-based paint is typically found on building interiors and exteriors for buildings constructed prior to 1978. During renovation and demolition, the activity of paint removal has the potential to impact human health and the environment as fibers, dust, and paint chips are released. Paint chips and dust can cause indoor air contamination during renovation, and soil contamination from demolition or improper disposal. Assessment of lead-based paint hazards and removal of lead-based paint is regulated under TSCA. Disposal of any building materials contaminated by lead-based paint is regulated under RCRA.
1 U.S. EPA, EPA Study of Asbestos-Containing Materials in Public Buildings, A Report to Congress, Washington, D.C., February 1988, p. 1.
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