Construction, Demolition and Renovation
Matters Related to Environmental Health & Safety
This information is directed to MU Planning, Design & Construction, as well as contractors working for MU. It intends to inform PD&C and contractors of any project-related item or issue for which MU Environmental Health & Safety (EHS) bears responsibility for assistance, management, and/or oversight. These will typically consist of environmental permitting, waste determination and management, hazardous building material surveys, and environmental record keeping and reporting.
MU EHS shall be the main point of contact with all environmental regulatory agencies, including Missouri Department of Natural Resources, Environmental Protection Agency, Missouri Department of Conservation, US Army Corp of Engineers, City of Columbia, Boone County.
EHS Program Areas and Contacts Relevant to PD&C Project Management
Environmental Affairs (EA)
EA-Asbestos/Building HazMat; EHS Contact: Scott Campbell; (573) 882-5031
- Asbestos and hazardous building material surveys, bid language and estimates
- Asbestos or unexpected hazardous building material discovered during renovation or demolition
EA-Environmental Compliance; EHS Contact: Ted Haeussler; (573) 882-3950
- Above and Underground Storage Tank installation/disturbance/removal
- Air permitting (e.g., fuel-burning systems)
- Air pollutant emitting equipment (e.g., ethylene oxide sterilizers)
- Blasting air compliance
- Flood plain/jurisdictional water determinations
- Land disturbance permitting and SWPPP approval
- Large quantity chemical storage (e.g., 100 gallons or more)
- On-site wastewater treatment systems
- Restriction on land use (e.g., former chemical or animal burial sites, USTs)
- Stormwater considerations (e.g., BMPs)
EA-HazMat Services/Technical Operations; EHS Contact: Chris Pearman; (573) 882-2303
- Disposal by EHS of materials in bid (incl. containerization and labeling)
- Potential new hazardous waste generation sites
Fire Marshal; EHS Contact: Shawn McGruder; (573) 884-9209
- Blasting for demolition or excavation
- Fire alarm suppression system disturbance
Laboratory Safety; EHS Contact: Jeff Evers; (573) 882-7018
- Chemicals or contamination discovered during renovation or demolition of laboratories
- Laboratory large quantity chemical storage (e.g., 100 gallons or more)
- Relocation of existing researchers
- Safety equipment installation
Radiation Safety; EHS Contact: Cade Register; (573) 882-7018
- New radiation emitting equipment installation
- Past (e.g., for surveys) or planned future use (e.g., for design considerations) of radioactive materials
Items of Concern (alphabetical list)
Active radioactive material use [Radiation Safety]:
Some locations may require advance planning to deal with potential radiation exposure. Please contact EHS Radiation Safety 60 days in advance.
Addition of new, or modification/removal of fuel-burning systems [EA-Environmental Compliance]:
Most fuel-burning systems require a construction permit prior to installation. This includes modification or removal of incinerators, boilers, and generators. Contact EHS Environmental Compliance no less than 6 months in advance of planned construction/installation as the permit application process can take several months.
Air pollutant emitting equipment installation [EA-Environmental Compliance]:
New air pollutant emitting equipment (spray painting equipment, parts washers, ethylene oxide sterilizers, and kilns) may require a permit prior to installation. Contact EHS Environmental Compliance as soon as possible, but no less than 6 months in advance of planned construction/installation, for a regulatory determination. The permit application process can take several months.
Asbestos containing material discovered during demolition or renovation [EA-Asbestos/Building HazMat]:
EHS Environmental Affairs must be notified IMMEDIATELY. Stop work until it has been cleared by EHS Environmental Affairs.
Blasting demolition (air compliance) [EA-Environmental Compliance]:
MU Campus air permit restricts the amount of particulate matter (dust) that can leave MU property. Contact EHS Environmental Compliance for questions.
Blasting demolition (safety) [Fire Marshal]:
EHS must be notified prior to contractors using explosives. Missouri State Statute 319.339 requires any person using explosives within Missouri to notify the Division of Fire Safety at least two business days in advance of first using explosives at a site where blasting has not been previously conducted. The law also requires that the person using explosives notify the appropriate fire protection official of the jurisdiction where blasting will occur, which may be a city fire department, fire protection district, or volunteer fire protection association.
Disposal by EHS of materials in bid [EA-HazMat Services/Technical Operations]:
EHS HazMat Services must be notified 7 days prior to beginning work which will result in materials specified in bid to be disposed of by EHS HazMat Services such as florescent lamps. Coordinate collection/removal with EHS HazMat Services prior to commencement of activities.
Fire alarm or suppression system disturbance [Fire Marshal]:
All plans must comply with current fire code regulations. Include Assistant Fire Marshal in planning meeting invites.
Flood plain/jurisdictional water location [EA-Environmental Compliance]:
Contact EHS as soon as possible for permit application or jurisdictional waterway determination when projects may impact flood plains or Waters of the State/U.S.
Hazardous building material survey/abatement (cost consideration) [EA-Asbestos/Building HazMat]:
Asbestos or other hazardous building material abatement may affect total construction costs depending on overall budget. Contact EHS Environmental Affairs as soon as possible to request a preliminary hazardous building material survey.
Hazardous building materials survey [EA-Asbestos/Building HazMat]:
Buildings may contain hazardous materials that could potentially be hazardous waste when removed or discarded. Hazardous building materials include, but are not limited to, asbestos, lead, mercury, polychlorinated biphenyls (PCBs), chlorofluorocarbons, and radioactive sources. They can be found in buildings of any age or condition. The most common hazardous materials encountered during demolition and renovation projects are asbestos containing materials or lead paint and objects contaminated by lead paint. The uncontrolled disturbance of such materials can result in dangerous overexposures or improper, or illegal, disposal. Therefore, EHS Environmental Affairs or an approved contractor must complete a Hazardous Material Building Survey identifying all hazardous materials before beginning a renovation or demolition project. EHS Environmental Affairs will determine the proper disposal of any known hazardous building materials.
Laboratory: Chemicals or contamination discovered during demolition or renovation [EA-HazMat Services/Technical Operations]:
EHS must be notified IMMEDIATELY. Stop work until it has been cleared by EHS. This could include labware, potential chemical containers, chemical contamination, etc.
Laboratory: Large volume chemical storage included in scope [Laboratory Safety]:
Contact EHS when planning to store large quantities of chemicals. A large volume of chemicals is defined as 30 total gallons or more in any type.
Land disturbance greater than 1 acre [EA-Environmental Compliance]:
If the project will disturb one or more acres, a land disturbance permit must be obtained through EHS. Permits issued for off campus locations may require a filing fee. Contact EHS Environmental Compliance to start the permitting process and for information on developing a Stormwater Pollution Prevention Plan (SWPPP).
Land use restrictions/legacy environmental issues [EA-Environmental Compliance]:
Several sites on and off campus have restrictions in place or are known to have legacy contamination. If the project involves any of the following locations: Sinclair Farm; South Farm; Pickard Hall; University Garage and surrounding areas including parking lots; and the EHS Resource Recovery Center; contact EHS Environmental Compliance as soon as possible as these issues can take significant time to mitigate.
Legacy radioactive material use [Radiation Safety]:
Several labs on and off campus have legacy radiation contamination and access may be restricted. Contact Michael Stornello (email@example.com) for the most recent legacy radiation lab list. If a location IS ON the legacy radiation list, contact EHS Radiation Safety for further assistance. Always consult with EHS Radiation Safety if unexpected radiation signage/labels are encountered.
New above ground storage tank or emergency generator installation [EA-Environmental Compliance]:
New tanks and generators may require a permit prior to installation. Contact EHS Environmental Compliance as soon as possible, but no less than 6 months in advance of planned construction/installation, for a regulatory determination. If needed, the permit application process can take several months.
New on-site wastewater treatment system installation [EA-Environmental Compliance]:
The installation of waste treatment systems such as septic systems or aerobic digesters require the submittal of a filing fee plus an hourly review fee. If the project involves the installation of an on-site treatment system, contact EHS Environmental Compliance as soon as possible as the permitting process can take up to six months.
Oil-filled equipment removal [EA-Environmental Compliance]:
Contact EHS HazMat Services when removing oil-filled equipment. EHS must approve of the management and disposal methods of any oil-filled equipment and contents. Some oil-filled equipment being removed or demolished (e.g., elevator equipment, transformers, door closers) will require special handling and/or disposal, including potential removal of the oil.
Oil-filled equipment/storage tank installation [EA-Environmental Compliance]:
Designs must be in compliance with the Spill Prevention, Control, and Countermeasure (SPCC) regulations promulgated by the EPA. There may be a fee if the new addition triggers modification to the associated Spill Prevention, Control and Countermeasures Plan (SPCCP). Contact EHS Environmental Compliance when an oil-filled equipment/storage tank exceeding 55 gallons is being installed. For more information on oil-filled equipment/storage tank installation, contact EHS Environmental Compliance.
Planned radiation usage [Radiation Safety]:
Notify EHS Radiation Safety as soon as possible if X-ray or laser equipment installation will take place.
Planned radioactive material use [Radiation Safety]:
Contact EHS Radiation Safety as soon as possible when planning for radioactive material (RAM) usage. All proposed uses of RAM must be approved by the Radiation Safety Committee, which can take a significant amount of time. The current NRC license limits the use of RAM to the main areas of the contiguous campus and Women and Children's Hospital.
Potential contamination discovered during excavation [EA-HazMat Services/Technical Operations]:
EHS HazMat Services must be notified IMMEDIATELY. Stop work until it has been cleared by EHS. This includes unexpected discovery of discolored soil, tanks or piping suspected of containing anything other than water.
Potential for new hazardous waste generator site [EA-HazMat Services/Technical Operations]:
Contact EHS HazMat Services if a new lab will potentially generate hazardous waste. Operations at locations not on the contiguous campus that may generate hazardous wastes may become new hazardous waste generator sites that must be registered with the state by EHS, and may have specific waste storage requirements.
Radiation emitting equipment installation [Radiation Safety]:
EHS Radiation Safety must be notified as soon as possible if X-ray or laser equipment installation will take place and was not previously identified.
Relocation of existing researchers [Laboratory Safety]:
Contact EHS Lab Safety if current research operations need to be relocated. Depending on number of operations and material quantities, this may require up to 60 days advance notice for such assistance.
Safety equipment installation [Laboratory Safety]:
Notify EHS prior to installing safety eyewashes and showers. All safety showers and eyewashes must comply with ANSI Z358.1. Drench hoses are prohibited.
Stormwater Pollution Prevention Plan (SWPPP) development and adherence to Land Disturbance Permit [EA-Environmental Compliance]:
If the project will disturb one or more acres, in addition to obtaining a Land Disturbance Permit from EHS Environmental Compliance, a Stormwater Pollution Prevention Plan (SWPPP) must be completed and approved by EHS Environmental Compliance. No land disturbance may begin without an approved SWPPP. Contact EHS Environmental Compliance for information on developing a Stormwater Pollution Prevention Plan (SWPPP).
Stormwater features/concerns [EA-Environmental Compliance]:
Consultants shall evaluate the implementation of structural stormwater Best Management Practices (BMP) for all proposed new construction or redevelopment activities on campus. Stormwater management systems shall be designed for new developments that mimic pre-development runoff conditions to the maximum extent practicable at the site level. Redevelopment projects shall incorporate stormwater BMPs consistent with the pollutants of concern (e.g., nutrients, bacteria, volume, etc.). For more information on BMPs and stormwater runoff planning, contact and work with EHS Environmental Compliance early in the design process.
Underground storage tank installation/disturbance/removal [EA-Environmental Compliance]:
Storage tank disturbance and removal have specific closure and notification requirements. If the project involves the removal or other disturbance of an underground storage tank, contact EHS Environmental Compliance as soon as possible as the closure and notification process can take several months.
Utility/infrastructure: Large volume chemical storage included in scope [EA-Environmental Compliance]:
EHS Environmental Compliance needs to be aware of the planned storage of large quantities of chemicals; for example, installation of any tanks or areas designed for storage of multiple containers of chemicals. For utility/infrastructure projects, contact EHS Environmental Compliance if 100 gallons or more are expected to be stored.
Demolition or renovation projects can create several different categories of waste or waste-like materials:
- Materials that may be recovered and re-used or used for a different purpose
- Waste materials that cannot or will not be reused or re-purposed
- Hazardous Wastes, asbestos-containing materials, Universal Wastes
Occupants must be made aware that all removable, potentially hazardous materials/wastes must be properly managed prior to leaving the space. Some of these may be managed through UM Surplus Property. Any others must be managed through MU EHS.
Hazardous and Universal Wastes
Universal Wastes (UW) are a subset of Hazardous Wastes that has relaxed management requirements to promote recycling/recovery. Identified UW can be managed by contractors in coordination with MU EHS.
MU does not use the allowance for pesticides in the Missouri rule.
Hazardous Wastes (HW) are defined by EPA regulation, and exhibit one or more of the hazardous characteristics of ignitability, corrosivity, toxicity, or reactivity; very specific disposal requirements necessitate MU EHS management of all HW. The department responsible for the space is responsible for requesting pickup by EHS of any potential Hazardous Wastes.
Other Regulated Wastes can be those regulated by EPA, but not as Hazardous Waste (per definition). These may be regulated under rules outside the Resource Conservation and Recovery Act, or by Missouri state legislation. These include:
- Light ballasts containing (or assumed to contain) PCBs
Special Waste in Missouri consists primarily of petroleum or other contaminated soil, various ashes, industrial process waste and sludge, but can include a variety of wastes.
Solid Wastes will usually consist of typical construction/demolition wastes or items or materials not destined to be recycled or reclaimed.
Non-Waste Materials (Potentially Waste-like) can consist of the following:
- Clean fill: State-defined as "uncontaminated soil, rock, sand, gravel, concrete, asphaltic concrete, cinderblocks, brick, minimal amounts of wood and metal, and inert (non-reactive) solids approved by rule or the department for fill, reclamation or other beneficial use."; some materials may require analysis for determination.
- Recycle/reclaim (by contractor or MU): can include most types of e-waste, scrap metals, some devices or appliances.
- Reusable (salvage by MU): can include any number of building materials or equipment/devices.
- University surplus: anything allowable for resale at University Surplus Property; can include most types of e-waste, scrap metals, office items, etc.
For further information, see DNR publication Managing Construction and Demolition Waste (PUB2045).
Coordination with EHS - Waste Management
- Identify all UW and HW affecting a project, or approve of appropriate contractors to perform this.
- Determine appropriate packaging and labeling of all UW and HW and communicate that directly to the contractors.
- Provide containers for UW and HW, and remove those from the site as necessary.
Any coordination on waste management should be arranged with the MU EHS HazMat Services/Technical Operations by email or by phone at 573-882-3736.