Covino Environmental Associates Inc., Woburn, MA... Building Sciences (Asbestos, Lead, PCB's, Mercury, etc), Microbial Services (Mold), Industrial Hygiene, Indoor Air Quality & Laboratory Ventilation... Servicing The Boston Area & New England

 
Covino Environmental Associates, Inc. • 300 Wildwood Ave.Woburn MA 01801 Phone: 781.933.2555  Fax: 781.932.9402 E-Mail
The Covino Report - March 2009
   

New Lead in Air Standard to Phase In this Year

A new, tougher lead in air standard approved last fall by the U.S. Environmental Protection Agency (EPA), to be phased in starting later this year, will increase protection for at-risk populations against a variety of adverse health effects.

The revised National Ambient Air Quality Standard (NAAQS) for lead in air is 10 times tighter than the previous standard and is designed to improve health protection for at-risk groups, especially children.

Specifically, the EPA revised the level of the standard for lead from 1.5 micrograms of lead per cubic meter of air (µg/m3), averaged over three months, to 0.15 µg/m3 after determining that the existing standard, established in 1978, did not sufficiently protect the public health with an adequate margin of safety.

Based on an analysis of more than 6,000 studies published since 1990 on health and environmental effects of lead in the air, the evidence shows that adverse effects occur at much lower levels than previously thought, according to the EPA.

Between 1980 and 2007, average concentrations of lead in the air have dropped nearly 94 percent across the country. Much of this improvement occurred as a result of the permanent phasing out of lead in gasoline used in motor vehicles. However, lead continues to be emitted into the air from many types of stationary sources such as lead smelters, waste incinerators, foundries, power plants, and lead battery manufacturers and recyclers, and from non-stationary sources such as piston-engine aircraft.

According to the EPA, industrial processes, non-road equipment, and electricity generation are responsible for more than 80% of all lead emissions. Once taken into the body, lead distributes throughout the body in the blood and is accumulated in the bones. Depending on the level of exposure, lead can adversely affect the nervous system, kidney function, immune system, reproductive and developmental systems and the cardiovascular system.

The agency estimates that the revised standards will yield health benefits valued between $3.7 billion and $6.9 billion, and puts the cost of implementing the standards at approximately $150 million to $2.8 billion.

In addition to strengthening the lead standard, the EPA is improving the existing lead monitoring network by requiring monitors to be placed in areas with sources such as industrial facilities that emit one ton or more per year of lead and in urban areas with more than 500,000 people.

States are required to make recommendations for areas to be designated attainment, nonattainment, or unclassifiable by October 2009. Final designations of all attainment, nonattainment and unclassifiable areas will be effective no later than January 2012. However, the EPA intends to complete initial designations as soon as possible where data are sufficient from the existing monitoring network.

Glenn Potter, director of the Building Sciences Group at Covino Environmental Associates, said the new standard may lead cities and towns to become stricter with regard to construction and demolition work of public facilities such as bridges and roadways and repainting of water tanks, as well as of public and private buildings that may contain lead paint.

States are required to submit implementation plans outlining how they will reduce pollution to meet the standards no later than June 2013 and are required to meet the standards no later than January 2017.

LEED for Existing Buildings Requirements Updated

Building owners and operators seeking to register existing facilities as LEED certified—meaning they meet national energy and operational efficiency standards while minimizing environmental impacts—can now achieve certification more easily under revised rules.

According to the new rules enacted last fall, LEED for Existing Buildings: Operations & Maintenance (O&M) will streamline reporting, have fewer prerequisites, offer more rewards for measured environmental performance, and emphasize operations and maintenance.

As of last September 1, all projects registering for LEED for Existing Buildings must do so under the new LEED for Existing Buildings: O&M version. Projects that registered for LEED for Existing Buildings version 2.0 before that date will have the opportunity to continue their certification under version 2.0 or upgrade to LEED for Existing Buildings: O&M.

“By focusing on operations and maintenance best practices through the use of performance records, testing, analysis, and resource tracking, the LEED for Existing Buildings Rating System can be a valuable tool that enables building owners and operators to measure operations, improvements, and maintenance on a consistent scale,” said Peter von Au, Senior Industrial Hygienist, at Covino Environmental Associates.

The LEED (Leadership in Energy and Environmental Design) program, operated and managed by the U.S. Green Building Council, is the nation's de facto standard on green building design and maintenance.

The revised rating system, among other factors, focuses on:

  • Energy efficiency. There are now 50% more points for energy efficiency and new credits for energy best practices, including auditing, existing building commission, and ongoing commissioning.
  • Water efficiency. Contains double the number of points available and includes new credits for water metering and cooling tower water efficiency.
  • Green cleaning. This has been consolidated in one credit category with emphases added on achieving a comprehensive green cleaning program and use of performance metrics for cleaning effectiveness.
  • Greater emphasis on operations, maintenance, and upgrade, making for greater emphasis on operational best practices.
“High performance green buildings can significantly reduce greenhouse gas emissions and energy dependence while improving the health and productivity of occupants,” said von Au. “Most importantly, operating green can reduce building operations costs and yield significant savings for building owners and managers.”

LEED for Existing Buildings was introduced in 2004 as a way to certify the operations and maintenance of a building and create a plan for ensuring high performance over time by institutionalizing the processes of reporting, inspection, and review over a building's life.

The revised version of LEED Existing Buildings: O&M aims to clarify the intent of the original rating system and amplify its operations and maintenance scope while reducing technical barriers to program participation, where warranted, and speed its adoption. It addresses whole-building cleaning and maintenance issues, including chemical use, recycling programs, exterior maintenance programs, and systems upgrades. It can be applied both to existing buildings seeking LEED certification for the first time and to projects previously certified under LEED for New Construction, Schools, or Core & Shell.

LEED for Existing Buildings: O&M requires buildings to be in operations for at least 12 continuous months before certifying and requires three months of operational data for an initial certification. Existing buildings undergoing substantial renovations are eligible to become certified under LEED for Commercial Interiors, Existing Buildings: O&M (upon completion of the renovation and three months of occupancy/operation) or New Construction. Re-certification of LEED Existing Buildings: O&M is required at least once every five years, though buildings can re-certify annually.

Minding Your PCBs

Although PCBs haven't been produced in the U.S. for more than three decades, the compound, known to cause harmful health effects, still exists in many products, and care must be taken when repairing, rehabilitating, or demolishing existing structures to avoid contamination.

PCBs— polychlorinated biphenyls—are mixtures of up to 209 individual chlorinated compounds, known as congeners. PCBs are either oily liquids or solids that are colorless to light yellow. Some PCBs can exist as a vapor in air and have no known smell or taste. Many commercial PCB mixtures are known in the U.S. by the trade name Aroclor. There are no natural sources of PCBs.

U.S. production of PCBs was halted in 1977 after it was discovered that they build up in the environment, with exposure leading to acne-like skin conditions in adults and neurobehavioral and immunological changes in children. PCBs are also known to cause cancer in animals.

Products made before 1977 that may contain non-liquid PCBs include caulk and grout, as well as roofing and siding materials, paints, coatings, sealants, gaskets in HVAC systems, insulation materials, carbonless copy paper, and other industrial applications. Liquid PCBs have also been used as coolants and lubricants in transformers, capacitors, and other electrical equipment because they don't burn easily and are good insulators.

PCB contamination in the workplace can occur during repair and maintenance of PCB transformers and through accidents, fires, or spills involving transformers, fluorescent lights, and other old electrical devices; and disposal of PCB materials.

“Because various PCBs do not readily break down, they may persist for a long time and can migrate through the environment, showing up in soils, sediments, plants, and air,“ says Ann Eckmann, vice president of the Industrial Hygiene Group at Covino Environmental Associates.

In water, a small amount of PCBs may remain dissolved, but most stick to organic particles and bottom sediments. PCBs also bind strongly to soil.

Under the Toxic Substances Control Act (TSCA), U.S. EPA regulations govern the approved uses, testing, labeling and disposal of items that contain PCBs. While EPA regulations do not specifically require owners to test their buildings to determine the existence/concentrations of non-liquid PCBs, improper use and/or storage of non-liquid PCB containing materials at regulated levels is a TSCA violation.

Use of PCB–containing building materials with more than 50 ppm PCB is prohibited. Once found, such materials must be reported to the regional EPA office, and removal will probably be required. In addition, removal of any surface that is contaminated due to prolonged contact with a non-liquid PCB material such as window caulk may be required. Therefore, building owners should be aware of the implications of finding non-liquid PCB building materials on their properties.

Presently, PCB-containing window caulk and associated remediation waste that may result from its removal (such as contaminated surfaces in proximity to the caulk, or soil that was contaminated during removal of the caulk) are subject to different remediation and disposal requirements under TSCA regulations.

According to an EPA source, the agency is re-evaluating these requirements to make removal of PCB-containing caulk and methods of dealing with contaminated surfaces more practical for building owners; however, a change in the requirements may be a long way off due to regulatory hurdles.

For more information, click here . Useful facts on PCB-containing caulk can be found by clicking on “PCBs in Caulk” under PCB Highlights.

PCBs and LEED Certification

Until last fall, to be LEED certified, existing buildings had to be free of PCBs or have a PCB management program in place. The new LEED for Existing Buildings: O&M (LEED-EBOM) version does not address PCBs specifically, but indicates that existing buildings must be in “compliance with all federal and state regulations” with respect to PCBs and other hazardous materials.

Since non-liquid PCB— polychlorinated biphenyls—building materials are not approved for use under the Toxic Substances Control Act of 1976 (TSCA), The question is whether “compliance with all federal and state regulations” means that to be LEED-EBOM certified, buildings must be inspected and tested to ensure that they are free of non-liquid PCB building materials.

Although the use of non-liquid PCB building materials is prohibited under current TSCA regulations, these regulations do not specifically require that building owners test window caulk or other potential non-liquid PCB building materials.

Covino is presently seeking guidance from the U.S. Green Building Council on whether the intent of the requirement for “compliance with all federal and state regulations” includes a mandate for testing and inspection of buildings for non-liquid PCBs to obtain LEED-EBOM certification.

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