Building decommission requires environmental review.
To begin with, many materials incorporated into older buildings that were once considered safe - even state-of-the-art - are now known to be harmful to the environment and human health.
Accordingly, Federal and State environmental regulations, as well as most property transfer contracts, require an owner to separate out and properly dispose of these materials before or during the demolition process.
Prevalent contaminants found in older buildings and around their sites include asbestos, PCB oils, lead-based paint and petroleum products. The best way to determine which elements may be of concern at a particular site is to conduct a thorough environmental survey. A typical contaminant survey - including sampling, testing and reporting - takes about four to eight weeks, dependent upon the size and complexity of the site. If environmental problems are encountered, preparation of remediation documents would be necessary in order to mitigate and abate concerns.
Relatively innocuous building materials can also be subject to regulations. For both regulatory and economic reasons, recyclables are typically source separated by type and from other solid waste. Recyclables such as concrete and brick require very little processing, are relatively inexpensive to dispose of and can often be reused on site. In the past, bricks were often salvaged whole and re-used.
While the cost of labor prohibits cracking mortar off old bricks today, many demolition contractors find it very cost effective to crush the used brick and concrete and re-use them as processed aggregate in pavement subgrades or as compacted fill. Other recyclables include such items as steel, aluminum, copper, and glass that, though not appropriate for fill, possess significant value to specialty recycling and salvage facilities.
What cannot be recycled is considered solid waste. Disposal fees for these materials are substantial, ranging up to $130 per ton and more in the New York metropolitan area. Such non-recyclable materials include general demolition debris such as plaster, wood and unwanted metals. These materials must be brought to a transfer station and/or certified solid waste landfill. State waste flow regulations often play a big role at this point, so it is important to check with the State to see how specific waste should be handled.
Materials classified as hazardous waste must be disposed of in a hazardous waste landfill, at extremely high cost. This includes materials with high levels of contamination of lead, chromium or petroleum. A word of warning may be in order here. Owners who ignore disposal requirements or leave compliance to their contractor's discretion do so at their own risk. If any material is dumped at an illegal site, and that site is later put on a Superfund list, the owner may be held liable for the costs of cleaning up the landfill site.
Underground fuel storage tanks and related piping on the property also have to be removed and the soil and groundwater around them checked for contamination from leaks. If contamination is detected, it must be cleaned up. If the property is being transferred to a new owner, the sales agreement will typically assign the risk of undetected tanks or leaks to the seller or reduce the selling price accordingly, so it behooves the seller to undertake a thorough investigation.
Similarly, PCB-containing oil must be drained from power transformers and the oil and transformers must be properly disposed of. If PCB oil has leaked into site soils, the contaminated soil will have to be addressed. Fluorescent lights should also be examined before demolition to determine if their ballasts are the PCB-containing type.
Lead Paint Regulations
A gray area in the current regulations concerns the disposal of lead-based paint (LBP). Though it is not yet mandated to remove LBP from buildings prior to demolition/renovation, federal regulations do govern its exposure to workers and ultimate disposal. Federal regulations impose special disposal requirements where lead concentrations exceed 5 ppm. The issue here is what and how to measure.
Almost any paint containing detectable lead will have a concentration exceeding 5ppm (the EPA threshold) resulting in hazardous waste classification, a very expensive disposal choice. But in demolition debris, paint is not disposed alone. Its adherence to a wall, door or windowsill makes it part of a complete component to be disposed of, which when tested as a composite, will often not exceed 5ppm. The testing approach becomes a critical step in carefully classifying the material. Because of the economic hardship and shear magnitude of demolition debris being potentially classified as hazardous, the EPA has shown interest in composite sampling for LBP.
Meanwhile, New York City and several other states are proposing LBP regulations. The EPA, moreover, is expected to issue new regulations specifically addressing LBP in early 1995. Building owners should keep a close eye on this area over the next few years.
Keeping Costs Down
The radical changes in disposal requirements have had a major impact on demolition projects. An important decision an owner now has to make, for example, is whether to issue bid specifications separately for material removal work, or to include that work in the demolition contractor's bid.
The problem with the first option is that it may be difficult for a removal specialist to locate all the regulated material while the structure is still intact. If, after the wrecking ball starts swinging, the demolition contractor then finds asbestos on vertical pipe runs or soil contamination under a slab, the job stops and the contractor is apt to tack on a big extra for removing the material. For this reason, many owners prefer putting a demolition contractor with hazardous removal experience in charge of the entire project.
The cost of disposing of demolition material continues to rise. Tipping fees for disposal of demolition debris, for example, that currently run $130/ton in the New York metropolitan area (excluding trucking) used to be $50/per ton during the mid-1980s. In addition, landfill space has continued to shrink.
Fees for disposing of contaminated materials such as asbestos are also substantial. These materials typically are disposed of at licensed state landfills which are increasingly out-of-state - Maryland, Virginia and Pennsylvania as well as some mid-western states. In addition, an owner must be aware that tipping fees can rise significantly during the course of a project, and courts have recently ruled in favor of contractors who seek to pass these costs on to owners.
In summary, demolishing a building is no longer a simple task left to the "demo" contractor to handle. Dealing with environmental concerns through comprehensive assessments and proper disposal management has become increasingly critical to the successful completion of a project. An owner or property manager must be well prepared and knowledgeable of the site from all aspects long before the first wall crumbles. If not, the potential cost and liability exposure can be extraordinary and, in the end, result in the demise of the project before a foundation is ever put in place.
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|Title Annotation:||supplement: Energy & the Environment|
|Publication:||Real Estate Weekly|
|Date:||Sep 21, 1994|
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