Project Planning and Review

Policy

The University of Chicago Project Planning and Design Review Policy for General Constructions has been developed to provide guidance to project managers and other design professionals involved in new constructions, renovations, or demolitions. This policy is intended to provide awareness for environmental health and safety considerations that may apply to the project and should be reviewed during the planning and design phase.

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Purpose

The University of Chicago sees a need for continual expansion through new constructions and modernization of existing buildings. The construction, renovation, or demolition of building structures requires complex decision making and communication from multiple parties. A review of this policy and the Project Planning and Design Review Checklist during the project planning and design phase will help to ensure that environmental health and safety considerations are not overlooked and can be addressed well in advance of the project start date. This policy is not intended to be all-inclusive and does not cover all regulatory or code requirements.

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Scope

The first priority in all construction, renovation, and demolition project activities are the health and safety of employees, the public and protection of the environment.

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Responsibilities

Facilities Service Capital Project Delivery is responsible for:

  • Submitting a completed Project Planning and Design Review Checklist to Environmental Health and Safety prior to starting a new project;
  • Inviting Environmental Health and Safety to attend project design meetings;
  • Providing all necessary information requested by Environmental Health and Safety; and
  • Communicating environmental health and safety requirements to all outside contractors.

Environmental Health and Safety is responsible for:

  • Providing regulatory guidance to Project Managers during all phases of a project;
  • Attending project kickoff meetings;
  • Reviewing "Project Planning and Design Review Checklist" completed by Project Management; and
  • Ensuring the timely submittal of all permit applications, notifications, and any other required documentation to the regulatory agencies that are discussed in this policy.

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Environmental

Air Emissions Equipment

Because the University is included in the Environmental Protection Agency's Title V Clean Air Act Permitting Program, all air emission sources on campus, including the Medical Center, must be installed and operated in compliance with the University's Title V operating permit.

Construction and air operating permits are required for emissions sources that are considered significant sources.  A fee is associated with the construction permit and the value is dependent upon the quantity of the units and their pollution potential.  Construction permits must be obtained from the Illinois Environmental Protection Agency (IEPA) prior to any construction activites related to the installation of new significant sources (e.g. concrete pads for generators or boiler tie-ins) and operating permits are required prior to placing new significant sources into operation.

Natural gas boilers operating at greater than 2.5 MMBTU/hr, fuel oil boilers or fuel oil and natural gas combination boilers operating at greater than 1.0 MMBTU/hr, emergency generators with engine larger than 1,118 kW, and non-emergency generators larger than 112 kW are considered significant sources and require a construction and operating permit.  Any other emission sources, such as non-steam sterilizers, that emit regulated air pollutants, in the absence of air pollution controls, at a rate greater than 0.1 lbs/hr or 0.44 tons/year are also considered significant sources.

Combustion units and other emission sources that do not exceed the thresholds for significant sources are considered insignificant sources and do not require a construction or operating permit.  However, these units must be added to the University's emission source inventory per our permit requirements.

Construction permits may also be required for any projects that make modifications on existing significant sources.  Environmental Health and Safety must be informed of any modifications to existing significant sources so that they may determine if construction and adjustments to existing operating permits are required to commence the project.

Because the IEPA's permit application review process can be longer than six months, it is essential for Environmental Health and Safety to review installations of new or modifications to existing air emission sources during the project design and planning phase so that the permitting process can be planned into the project schedule and unforseen delays during the project can be avoided.  Evironmental Health and Safety shall oversee the application of construction and operating permits to the IEPA.

For further information, please review the following Environmental Health and Safety policies: Title V Air Permit Policy, Greenhouse Gas Emissions, and Emergency Generators.

Asbestos

Environmental Health and Safety shall manage all aspects of asbestos abatement associated with any construction, renovation or demolition project. All asbestos-containing material (ACM) material that will be removed or could be potentially disturbed by construction, renovation, or demolition activities must be abated by a licensed asbestos abatement contractor. All building material that is suspect for containing asbestos should be treated as ACM until proven otherwise by laboratory analysis. Samples of suspect material shall only be collected by Environmental Health and Safety.

Abatement projects where greater than 260 linear feet or 160 square feet of ACM are removed require a notification to be submitted to the IEPA ten business days before that planned starting day. Abatement projects where greater than three linear feet or three square feet of ACM are removed require a notification to be submitted to the IDHA within two business days. The ten business-day notification is required for abatement projects inside of schools where greater than three linear feet or three square feet of ACM are removed. Notifications will be completed and submitted by the abatement contractor.

For further information, please review Environmental Health and Safety's Asbestos Policy.

Lead

All paint and surface finishes in buildings constructed prior to 1978 should be considered lead-based until proven otherwise by laboratory analysis. Samples submitted to a laboratory must be collected by a Lead Inspector or Risk Assessor that is licensed by the Illinois Department of Public Health (IDPH).

Environmental Health and Safety shall be involved with all lead abatement projects to ensure compliance with IDPH requirements.

The City of Chicago requires certain dust minimization measures to be employed when sandblasting, grinding, and chemical washing of the outer surfaces of buildings, facilities, or other structures that are coated with lead-based paint. See "Air Pollution Control for Project Activities" section of this policy for further details.

For further information, please review Environmental Health and Safety's Lead Policy.

Universal Waste

Wastes such as fluorescent light bulbs, mercury-containing devices (thermostats, boiler switches, etc.), PCB-containing ballasts, and certain types of batteries are specially regulated wastes defined as universal wastes by the US EPA. These items are not permitted to be mixed and disposed with regular garbage or construction debris and must be segregated and transported by a permitted waste transporter to a waste treatment facility that is permitted to receive these wastes.

Environmental Health and Safety will coordinate the disposal of these types of wastes to ensure compliance with applicable US EPA and IEPA regulations.

Hazardous Waste Management

Certain waste materials are regulated by the US EPA as "hazardous wastes." Hazardous wastes are any waste materials that are flammable, corrosive, toxic, or specifically listed under the Resource Conservation and Reduction Act (RCRA) regulations.

Contact Environmental Health and Safety to review any wastes generated during project activities that are not construction debris. Environmental Health and Safety will determine if the hazardous waste requirements under RCRA apply to the waste generated by a project.

Oil-Containing Equipment

Depending on the contents and volume, underground (UST) and above-ground (AST) storage tanks may be regulated by the Illinois Office of the State Fire Marshal (OSFM). The OSFM requires construction permits for AST's containing flammable and combustible liquids or LP-gas tanks and are used for dispensing fuels, greater than 110 gallons of capacity for bulk liquids, and single LP-gas tanks greater than 2,000 gallons or multiple LP-Gas tanks greater than 4,000 gallons totals capacity.

The OSFM regulates UST's that contain petroleum or hazardous substances that are defined in the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA). A permit is required by the OSFM for the installation or removal of UST's.

Installation of equipment or tanks, both AST's and UST's, that have the capacity to contain more than 55 gallons of oil will require the University's Spill Prevention, Control, and Counter-measurement (SPCC) Plan to be updated. Examples of materials that are considered "oils" include: petroleum, fuel oil, diesel, gasoline, oil-based coolants and lubricants, hydraulic oil, and non-petroleum oils.

For further information, please review Environmental Health and Safety's Spill Prevention, Control and Countermeasurement (SPCC) Plan.

Air Pollution Control for Project Activities

The City of Chicago requires a "Notice of Intent to Demolish" to be submitted to and approved by the City of Chicago Department of Environment at least ten business days prior to commencement of demolition. The Notice submitted to the City must contain plans for asbestos and dust control measures. Demolition contractors must follow the safeguards listed under 11-4-2170 (b) of the Municipal Code of Chicago.

An "Architectural Surface Cleaning Permit" from the City of Chicago is required to perform sandblasting, grinding, or chemical washing of any building, facility, structure, statue, or other architectural structure. If the work is to be performed on painted surfaces, the City requires a determination of whether the paint is lead-based (greater than 0.5% lead by weight). If the paint is determined to be lead-based then a dust minimization plan for the project must be developed and approved by a licensed lead risk assessor.

The general contractor for the project shall obtain any required permits and submit any require notifications.

For more specific requirements, please review the following chapters of Municipal Code of Chicago: 11-4-2170 – Demolitions and Renovations: Permit and Notification Requirements; Performance Standards for Asbestos Abatement; Control and Disposal of Dust and Debris and 11-4-2180 – Sandblasting, Grinding And Chemical Washing Of Buildings, Facilities, Or Other Structures: Permit And Notification Requirements; Performance Standards For Lead Paint Abatement; And Disposal Of Debris.

Soil

Depending on the history of the site for past contamination, whether actual or potential, soil that will be permanently removed from the site may need to be certified as uncontaminated before it can be landfilled or used as clean fill at another site. Certifying soil as uncontaminated would require collecting soil samples and submitting them to a laboratory for analysis. Environmental Health and Safety shall provide oversight for this process.

For further information, please review Illinois Administrative Code Title 35, Part 1100 – Clean Construction or Demolition Debris Fill Operations.

Stormwater

The USEPA and the City of Chicago have specific requirements for the management of storm water discharges for both construction activities and for the design and layout of new constructions.

For construction activities: when more than one acre of land is disturbed, a storm water discharge permit is a requirement per the USEPA National Pollution Discharge Elimination System (NPDES) program.  The project must apply for coverage under a General Permit for Storm Water Discharges from Construction Activities.  Application for coverage is made by preparing a Storm Water Pollution Prevention Plan (SWPPP) and submitting a complete Notice of Intent (NOI) to the Illinois Environmental Protection Agency (IEPA).

The City of Chicago requires a stormwater management plan to be submitted to and approved by the City of Chicago Department of Environment for construction activities that disturb more than 15,000 square feet of land, create an at-grade impervious surface of more than 7,500 square feet, or results in any discharges of stormwater into any waters or separate sewer system. For more specific requirements, please review the following chapters of Municipal Code of Chicago: 11-18 – Stormwater Management.

The general contractor for the construction site shall ensure compliance with SWPP requirements for both the USEPA and the City of Chicago, and provide oversight for attaining any required stormwater discharge permits.

For new constructions: applicability of the SWPP regulations are based on types of operations inside of the building. Buildings covered by these regulations should be designed so that a "No Exposure Certification" can be obtained from the US EPA. This certification would eliminate certain requirements, such as annual monitoring of stormwater discharges, associated with maintaining compliance with a stormwater discharge permit.

Wastewater

The Metropolitan Wastewater Reclamation District of Greater Chicago (MWRD) requires a "Facility Classification Questionnaire" to be completed for new buildings that will discharge water into their sewers or sewage works system. This is required for all new buildings that will be owned by the University. Facilities Services shall complete and submit the questionnaire.

Wastewater from certain processes or that contain certain chemicals may require a permit in order to discharge into the sewer. Environmental Health and Safety shall review all new non-domestic wastewater discharges. Environmental Health and Safety shall also review how water is planned to be used during construction activities.

Radiation Safety

The use of radiation-containing equipment during construction activities and the removal of radiation equipment from areas that will be renovated or demolished shall be coordinated with the Radiation Safety Office.

Most smoke detectors contain Americium and certain exit signs may contain Tritium. Both of these are radioactive materials, and have special waste disposal requirements. The Radiation Safety Office coordinates the disposal of radioactive wastes.

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Health and Safety

Fire Safety During Construction Activities

Hot work and impairments of fire-suppression and fire-detection systems significantly increases the risk of fires on construction and renovation sites.

Hot work permits shall be obtained from Environmental Health and Safety prior to performing welding, metal grinding, soldering, brazing, and any other type of hot work. Submit a work request to Environmental Health and Safety for a hot work permit at least 24 hours in advance of a hot work job.

Red tag permits shall be obtained from Environmental Health and Safety prior to shutting down fire-sprinkler and fire-detection systems. The red tag requirement applies to whole-building and section-specific impairments. For renovation projects, the sprinklers and piping should be drained and capped only in the areas of work. The intent of the red tag permit is to provide fire detection and suppression to the rest of the building that are outside of the area affected by renovation activities.

The fire-containment capabilities of walls, floors, or ceilings are impaired by penetrations because they provide a path for fires and smoke to travel through during major fire events. Penetrations into building separations must be filled prior to allowing the space to be occupied. These penetrations can include: openings around pipes and conduits, temporary holes through the wall, etc.

The construction contractor must have a site-specific fire safety plan that includes: procedures for reporting emergencies and conducting evacuations from their work site, ensuring adequate routes of emergency egress, and a fire prevention plan.

For further information please review the policies under Environmental Health and Safety's Fire Safety program.

Confined Spaces

A confined space is a space that is large enough and configured for a person to enter and perform work, has limited means of entry or exit, and is not designed for continuous occupancy. A permit-required confined space is a confined space that contains or has the potential to contain a hazardous atmosphere, contains materials that could engulf an entrant, has an internal configuration that could trap an entrant, and/or contains any other serious health or safety hazard.

Entry permit shall be obtained from Environmental Health and Safety prior to entering a permit-required confined space. Submit a work request to Environmental Health and Safety to issue a confined space entry permit at least 24 hours prior to the entry.

For further information, please review Environmental Health and Safety's Confined Space Program.

Fall Protection

During construction activities, workers must be provided fall protection if they are exposed to falls greater than six feet. Means of fall protection include guard rails, fall arrest systems, or work-positioning systems.

Scaffolds that are 20 feet or higher must be assembled by an outside contractor. Permits from the City of Chicago are required for scaffolds that are 80 feet or higher.

When designing new constructions, consideration must be given for providing fall protection to employees that are required to perform work on the roof (maintenance, cleaning, etc.). This can be achieved by configuring rooftop units at least ten feet away from leading edges, installing guardrails around the perimeter of the roof, or installing anchor points to which workers can attach fall restraint or fall arrest lanyards. Environmental Health and Safety shall provide guidance for selecting the best type of fall protection method.

For further information, please review the following Environmental Health and Safety policies: Fall Protection, and Scaffold Safety.

Traffic Control/Public Safety During Construction Activities

Construction sites can be disruptive to the flow of pedestrian and vehicular traffic. Pedestrians and vehicles must be provided safe passage around the construction site. Traffic around the site must be protected against construction activities. The layout of the construction site should also provide access to emergency response vehicles (ambulances, fire trucks, etc.).

Construction activities can be noisy and generate nuisance dusts in the surrounding areas. Noisy activities should be planned around the needs of neighboring building occupants. Barriers may need to be installed to minimize the amount of nuisance dust that escapes from the construction site.

For more specific requirements, please review the following chapters of Municipal Code of Chicago: 13-124 – Safeguards During Construction – Building Safety Requirements and 13-128 – Use of Public Property.

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New Construction/Renovation Design

Fire and Life Safety

New constructions and renovations must be designed in compliance with the most current fire and buildings codes of the City of Chicago. The city codes include requirements for fire-rated walls, number of exits, etc. These new areas should also have sufficient coverage by fire detection, alarm, and suppression systems. Please review the following chapters of the Municipal Code of Chicago for these specific requirements: 15-8 – Fire-resistive Requirements, 15-12 – Fire-resistive Materials and Construction, and 15-16 – Fire Protection Equipment.

Submit layout drawings of all new constructions and renovations to Environmental Health and Safety for review. Upon review of the drawings, Environmental Health and Safety can verify that life safety has been adequately designed into the new layout. Per the requirements of the University's insurance policy, Environmental Health and Safety will also submit life safety, fire sprinkler, mechanical, and roof layout drawings to the insurance provider for their review. The insurance provider requires a review of any changes to the layout plan during any phase of the project.

Elevators must be designed and installed in compliance with Chapter 18-30 – Elevators, Escalators, Moving Walks, Dumbwaiters, Material Lifts, Platform Lifts, Stairway Chairlifts, Conveyors and Related Equipmentof the Municipal Code of Chicago. New elevators must be issued a Certificate of Compliance by the City of Chicago Department of Buildings Inspections prior to placing it into operation.

Chemical Storage Areas

Areas designated for storage of hazardous chemicals should be secure from public access.

Areas that store corrosive chemicals, such as acids or bases, should be provided with emergency showers and eyewashes. Examples of such places are chemical storage rooms, mechanical rooms, etc.

Any special requirements for the storage of flammable chemical will depend on the specific chemicals and amount that will be stored. Provide Environmental Health and Safety with an inventory of all chemicals that are intended to be stored in the area. Please review the following chapters of the Municipal Code of Chicago for specific requirements for storage of flammable materials: 15-24 – Flammable Liquids, 15-26 – Fume and Flammable Compressed Gases, and 15-28 – Hazardous Materials and Combustible Solids.

Compressed gas cylinders and cryogenic liquids pose asphyxiation hazards when stored in confined areas.

Reviewed: October 2012

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