What Construction Companies Need to Know About PCBs
What are PCBs?
PCBs, or Polychlorinated Biphenyls, are man-made organic chemicals that were manufactured in the US from 1929 until 1979, when their production was banned. They consist of two phenyl rings (rings of six carbon atoms each) with chlorine attached to one or more of the carbon atoms. The type of PCB, or congener, depends on how many chlorine atoms are attached to the phenyl rings.
PCBs were widely used in industrial and commercial applications during the time of manufacture because of their practical properties. PCBs are non-flammable, hydrophobic (meaning they don’t dissolve in water), chemically stable, have a high boiling point, and work well as electric insulators. Unfortunately, some of these properties are also why PCBs were banned and continue to be an environmental problem around the world.
While PCBs do not bind with water molecules, they do bind with fats and oils. PCBs that were released into the environment became embedded in sediments and the fat tissues of animals. This allows PCBs to be stored for extended periods of time in the environment. Also, because PCBs are chemically stable, they don’t break down easily and thus remain in the environment and the food chain for extended periods of time. For obvious reasons, those at the top of the food chain tend to have more PCBs found in their fat tissues.
PCBs were manufactures under a variety of trade names, most commonly, Aroclor. Some other common trade names are (for a complete list, visit the EPA’s website):
What are the Health Risks?
Many studies have been completed to determine the health effects of PCBs on those who work with them or have been exposed to them through the environment. According to an assessment done by the EPA in 1996, PCBs are “probable human carcinogens”. The EPA found conclusive evidence that PCBs cause cancer in animals. Although some studies could not demonstrate a direct link between PCBs and cancer in humans, the International Agency for Research on Cancer, the National Toxicology Program and OSHA all agree with the EPA’s conclusion that PCBs may cause cancer in humans.
Besides cancer, PCBs have been shown to cause a number of other health effects. PCBs can affect the immune system, the endocrine system, the reproductive system, and the nervous system. Immune effects include a decrease in the size of the thymus and a decreased resistance to certain viruses and infections. Reproductive effects shown in animals include a reduction in birth weight, conception rates and live birth rates, as well as reduced sperm count. In humans, studies showed a decrease in birth weight and also in gestational age. Neurological effects in both humans and animals consist of learning deficits, visual recognition and short-term memory deficits. Endocrine effects include decreased thyroid hormone levels which are necessary for growth and development. PCBs have also been shown to have effects on the skin, eyes and liver, as well as increased blood pressure.
Although there is some debate over the effects of PCBs on human health, there is a large body of evidence that supports the ideas that PCBs cause significant carcinogenic and non-carcinogenic illnesses.
How Are PCBs Present at Construction Sites?
Construction companies should be aware of the presence of PCBs at their jobsites and should have processes in place for how to deal with them. But how do you know if PCBs are present at your jobsite?
PCB wastes tend to be found in one of two ways at construction sites: they are dug up during excavating or they are found in a building that is scheduled for demolition. The most common occurrence is the latter. The property or building owner should have a list of all items that contain PCBs. However this is not always the case. There may be no records available or PCB items may not be properly labeled. It shouldn’t be assumed that because there are no records there are no PCB wastes. Because PCBs are difficult to locate and identify, it probably makes the most sense to hire a consultant that specializes in environmental engineering, remediation or sampling. This should be done before demolition begins to avoid accidental release of PCBs into the environment.
According to the EPA, the most common types of PCBs found at construction sites are:
- “Mineral-oil filled electrical equipment such as motors or pumps
- Capacitors or transformers
- Plastics, molded rubber parts, applied dried paints, coatings or sealants, caulking, adhesives, paper, Galbestos, sound-deadening materials, insulation, or felt or fabric products such as gaskets
- Fluorescent light ballasts
- Waste or debris from the demolition of buildings and equipment manufactured, serviced or coated with PCBs
- Waste containing PCBs from spills, such as floors or walls contaminated by a leaking transformer”
All of these items would have been manufactured prior to July 2, 1979.
What are the Responsibilities of the Generator?
The generator of PCB wastes is not the manufacturer. Rather, the generator is considered the person who owns the material. It is the responsibility of the generator to take the necessary steps required to locate and properly dispose of all PCB wastes. However, it should be noted that there may be multiple parties involved in the handling of PCB wastes and all may be liable if proper procedures are not followed.
The first step in proper handling of PCB waste is to label all PCB-containing materials or equipment that will be disturbed. There are two EPA-approved labels that you can use. After labeling, you will need to determine the PCB concentration of each item. There are two ways to do this; assume the worst case scenario (greater than or equal to 50ppm) and have the material properly disposed of or hire a company to take and analyze samples of the material so that it can be properly disposed of if necessary.
Your next step is to notify EPA of the PCB wastes you are disposing. You will need to fill out a Notification of PCB Activity Form and EPA will give you an identification number. You will also need to be sure that whoever is hired to transport the material from the site and the company that will dispose of the waste have one of these PCB Activity ID numbers.
The construction site can store PCB materials for disposal for up to 30 days in a temporary storage area, or for up to a year in a permanent PCB storage location. There are strict requirements for how these storage locations must be set up and for how the PCBs can be stored in them. Check with the EPA to determine what the exact requirements are.
In order to dispose of PCB waste, you will need to find an approved PCB waste disposer. In order to transport the waste, fill out a Hazardous Waste Manifest which you can get from the transporter or from the state. Keep a copy for your records. Once the waste arrives at the disposal company, they will sign the manifest and return a copy to you.
Depending on the type of equipment or material, PCB wastes are disposed of in a number of ways. PCB wastes can be incinerated, disposed of in a high efficiency boiler, disposed of in a chemical waste landfill after proper treatment, disposed of as municipal solid waste or disposed of in a scrap metal recovery oven. Again, the type of disposal depends on the type of PCB waste.
Why Should Construction Companies Worry About PCBs?
Obviously there are a number of moral and ethical implications of ignoring proper handling and disposal of PCB wastes. As stated before, the effects of PCBs on the environment and the health of those who are exposed to them can be terrible and long-term. The safety of your workers, the public and the environment are put at risk if construction companies choose to ignore federal regulations regarding the PCBs.
Besides the moral and ethical issues, the cost to your company could be astronomical. Fines could reach up to $32,500 per day for non-compliance and that doesn’t include legal fees, lost time due to delays, loss of permits and loss of future business due to a tarnished reputation.
It makes sense to cover all angles before beginning a construction project. This includes foreseeing and having processes in place for possible environmental threats. Even though PCBs were banned over thirty years ago, they are still a threat to the environment and the public health today. They should not be forgotten or overlooked.