Month: March 2010

Special Inspections Required for New Buildings by The International Building Code

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It has been our experience that a large number of developers, building owners and architects are unaware of the requirements that are imposed by the International Building Code (IBC) that has been adopted by all 50 states.  CEC has had to inform many of our clients about the requirements for Special Inspections. Chapter 17 stipulates that Special Inspections (inspections by a qualified third party) are not discretionary and are required in order to obtain a certificate of occupancy for additions and new commercial construction. There is a separate IBC Code for one- and two-family dwellings.  Failure to obtain Special Inspections could put obtaining an occupancy permit at risk.  The IBC states that it is unlawful to occupy any building in violation of any provision of the code.

 The IBC specifies that procurement of these Special Inspections is the responsibility of the owner or the design professional in responsible charge of the project acting as the owner’s representative. The Special Inspections are not to be provided by the contractor performing the construction because it puts an inspector hired by the contractor in a conflict of interest. Special Inspections may include inspections/testing of soils and earthwork, foundations, reinforced concrete, reinforced masonry, structural steel, welds, high strength bolts, etc. Special Inspections are more detailed and comprehensive than traditional construction monitoring/testing and are required to be performed by trained and certified inspectors.  The International Code Council (author of the IBC) tests and certifies Special Inspectors.  Special Inspectors are certified for specific types of construction activities only after completing courses of study and testing. 

 Owners and cost estimators should note that properly conducted Special Inspections for a project cost more than traditional inspections. This is because the Special Inspector must be onsite longer to complete the code-required inspections and testing. Based on experience with Special Inspection costs in the Carolinas where Special Inspections have been required for over 10 years, costs can vary from between 1 to 2 percent of the construction cost, depending on the size of the project, the complexity of the structure, and the required Special Inspections.  Although more costly to perform, a well-executed Special Inspections program can provide increased value by reducing the risk for potential litigation due to poor structure performance or failures, increasing the quality of construction, and improving records of the construction processes.  These benefits can easily offset the cost increase over traditional inspections. 

 If you have any questions about the IBC Special Inspections, how they may impact an upcoming project, and how you can meet the IBC requirements, contact Jeffrey Woodcock, P.E. ( or Micah Sayles ( at 800-365-2324.

Clean Air Act Information Collection Request for Coal and Oil-Fired Electric Utility Steam Generating Units

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The U.S. Environmental Protection Agency (EPA) has initiated work to develop emissions standards for power plants under Clean Air Act (CAA) Section 112.  Pursuant to EPA’s authority under Section 114 of the CAA, EPA’s Office of Management and Budget (OMB) approved and issued an Information Collection Request (ICR) on December 24, 2009 requiring all US power plants with coal-or oil-fired electric generating units to submit emissions information for use in developing the proposed emissions rule for air toxics. The ICR requests owners/operators of all coal- and oil-fired electric utility steam generating units provide information that will allow EPA to assess the emissions of hazardous air pollutants (HAP) from each such unit. This information will be used by the Administrator of EPA in developing National Emission Standards for Hazardous Air Pollutants (NESHAP) under CAA Section 112.

The facilities that received the ICR were selected based on the definition of an electric steam generating unit under the CAA Section 112(a)(8) which “defines an electric utility steam generating unit as any fossil fuel-fired combustion unit of more than 25 megawatts that serves a generator that produces electricity for sale.  A unit that cogenerates steam and electricity and supplies more than one-third of its potential electric output capacity and more than 25 MWe output to any utility power distribution system for sale is also considered a utility unit.”

The ICR is composed of two major components. The first component is a survey issued to all coal- and oil-fired electric utility steam generating facilities listed in the 2007 version of the Department of Energy’s (DOE) Energy Information Administration’s (EIA) Forms 860 and 923, “Annual Electric Generator Report,” and “Power Plant Operations Report,” respectively. The survey requires the facility to self report specific information such as:

  •  identification and confirmation of existing generating unit,
  • the unit design, operations,
  • fuel analysis; and,
  • emissions data.

This ICR survey solicits data for the most recent 12 months of fuel analysis and emissions test data for all tests conducted since January 01, 2004.  The first component of the ICR is due to EPA within 90 days of receipt of the ICR.

EPA selected a limited number of facilities to complete the second component of the ICR. The second component was designed to collect sufficient information for EPA to evaluate whether specific HAPs can be addressed in future regulations through the use of surrogates and to validate the performance of specific type facilities.  This component will require a limited number of facilities to conduct emissions testing for specific HAPs in accordance with EPA approved sampling and analytical protocols. Coal-fired and oil-fired units that are required to conduct stack testing must conduct emissions testing for one to four different categories of HAPs.  These categories of HAPs are mercury and non-mercury metallic HAP (e.g., As, Pb, Se), acid gas HAP (e.g., HCl, HF, HCN), non-dioxin/furan organic HAP (e.g. volatiles, semi-volatiles, carbon monoxide, formaldehyde) and dioxin/furan organic HAP (e.g. dioxin/furans and PCB’s). The testing requires the performance of three emission test runs at the appropriate sampling location utilizing approved sampling protocols with specified sampling volumes and specific analytical techniques for each parameter. In conjunction with the emissions testing, each facility responding to the second component of the ICR is required to collect and analyze three fuel samples from the fuel fed to the boiler during each stack test.

The results of the emissions tests and the fuel analyses are required to be submitted to the EPA electronically along with PDF copies of all supporting documentation through EPA’s Electronic Reporting Tool (ERT) system.  The selected facilities are required to conduct emissions testing and submit the emission results and fuel analysis data within eight months of receipt of the ICR. The EPA has established an ICR website,, where responses to questions, updates to specific information and copies of the ICR can be found.

It should be noted, that units have been identified to the best of the Agency’s ability for the purpose of this ICR action only.  The receipt of the ICR for information or testing does not constitute a final Agency applicability determination for a facility related to the rule under development.  Similarly, units not receiving an ICR may ultimately be determined to be subject to the final rule.  Specific applicability definitions will be developed during the rulemaking process and will be subject to notice and comment.  EPA has negotiated a draft Consent Decree that calls for the proposed rule no later than March 16, 2011 and a final rule no later than November 16, 2011.

If your facility has been affected by the ICR, or if you have any questions regarding the sampling, analysis or reporting under the second major component of the ICR, please contact Frank Stevens at 866-250-3679 or through email at