Steps to Safe PCB Abatement Activities

An abatement strategy should be developed based on the results of the sampling plan. This strategy may require assistance from your Regional PCB Coordinator as well as state environmental and health agencies.

Classification of Removed Materials with PCBs

You will need to determine the type of PCB waste you are removing then determine your disposal option prior to commencing the abatement activity, because you may be required to notify EPA before you begin work. PCB-contaminated caulk is generally considered PCB bulk-product waste. If your abatement plan states that you intend to dispose of the PCB caulk and any contaminated building materials together, you may dispose of all the materials as a PCB bulk product waste even if the PCB caulk becomes separated from the adjacent contaminated building materials during remediation. On the other hand, if you remove the PCB-containing caulk and dispose of it separately from the surrounding building material, any PCB contaminated building material is considered a PCB remediation waste. EPA realizes that the PCB caulk may need to be separated during removal from adjacent contaminated building materials due to the presence of other hazardous materials or may accidentally be separated during the removal process.

Descriptions and details on the disposal options are discussed in Abatement Step 3. Some of these procedures have requirements for notification and certification. They are described the section titled Notifications to EPA May Be Required Prior to Starting a Project.

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Abatement Prioritization

Abatement activities should be prioritized based on the information collected during the building material characterization and classification steps, and based on the following priority drivers:

• PCB Concentrations and Condition - Materials with the highest PCB concentrations should receive a high priority, as they pose the greatest potential for direct exposure and release of PCBs to indoor air. A release of PCB contaminants into the air, or off-gassing, is especially likely in locations with direct sunlight. Compared to other building materials, caulk will generally have the highest concentrations of PCBs. Caulk with lower concentrations that is not intact and is peeling, brittle, cracking or visibly deteriorating also has a high potential for release of PCBs and also poses a potential to contaminate sand or soil or to be ingested.
• Accessibility - Materials contaminated with PCBs that are easily accessible by building occupants should receive a higher priority when evaluating the need for removal because of the potential for direct exposure. Note that, in addition to the accessibility of the contaminated material to the abatement workers, the accessibility rating should take into account the potential for building occupants to contact PCB-containing building material directly (dermal or ingestion) or indirectly via the air handling system (inhalation).
• Occupancy - PCB-containing materials in locations that have a higher rate of occupancy should receive a higher priority when evaluating the need for removal because of the increased potential for direct exposure. However, consideration should be given to the need for the safe, continued use of portions of the building during removal and clean-up activities. For example, conducting the abatement in phases could allow for partial occupancy of a building. The phasing sequence should consider the physical layout of the building to determine if the removal and clean-up areas and occupied spaces are sufficiently separated.
• Interim Measures -- In some cases, interim maintenance measures, such as temporary encapsulation (i.e., covering materials with plastic and securing with duct tape), can reduce or eliminate exposure to PCB-containing building materials until they can be scheduled for abatement. As noted above, PCB-containing caulk typically has the highest PCB concentrations and will be given a higher priority for removal over other building materials. Masonry, wood, brick, and other building materials contaminated with PCBs typically contain lower concentrations of PCBs. Thus, these PCB-contaminated materials typically pose a lower potential for exposure than caulk and should be dealt with accordingly.

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Notifications to EPA May Be Required Prior to Starting a Project

Depending on the method you choose for disposal of contaminated wastes and cleanup debris, you may be required to submit documentation to obtain approval from EPA prior to starting your removal or abatement project. Please view Abatement Step 3 for your disposal options.

The decision for how to manage PCB contaminated substrate may be subject to a variety of site-specific facts. The appropriate EPA regional office and regional PCB coordinator can be consulted as necessary for assistance with making these decisions. For example, property owners have identified instances where PCB caulk contained high levels of other hazardous constituents such as asbestos. Similarly, there are cases where PCB paint has been found to contain high levels of leachable metals. In these scenarios, care must be taken to fully characterize the waste to determine the appropriate disposal option.

Abatement Plan

An Abatement Plan, including a cleanup plan, should be prepared prior to commencing any actions at a building. The self-implementing procedures for removal or abatement of PCB-contaminated building materials from which PCB caulk has been removed (i.e., PCB remediation waste) require that an abatement plan be prepared (40 CFR section 761.61(a)(3)(C)) and submitted as part of the notification and certification requirements described in Notifications and Certifications for Remediation Waste section below. The plan must include a description of the removal and abatement schedule, disposal technology and approach. The cleanup approach described in the plan should identify the following:

• Proposed cleanup levels.
• Removal and abatement procedures.
• Verification sampling procedures.
• Waste storage and handling procedures.
• Disposal options.

The plan must also contain options and contingencies to be used if unanticipated higher concentrations or wider distributions of PCBs are found, or other obstacles force changes in the cleanup approach.

Notifications and Certifications for Remediation Waste (40 CFR section 761.61(a)(3))

When conducting abatement activities for PCB-contaminated building materials from which PCB caulk has been removed by the self-implementing procedures or risk-based disposal option under 40 CFR section 761.61(c), you must submit the appropriate notifications to the EPA, as described below.

Self-Implementing Procedure

The person in charge of the cleanup or building owner must notify the following people of the planned action in writing at least 30 days prior to removal and abatement of building materials contaminated with PCBs using the self-implementing procedure:

• The EPA Regional Administrator.
• The director of the state or Tribal environmental protection agency.
• The director of the county or local environmental protection agency where the cleanup will be conducted.

Within 30 calendar days of receiving the notification, the EPA Regional Administrator will respond in writing approving of the self-implementing cleanup, disapproving of the self-implementing cleanup, or requiring additional information. If the EPA Regional Administrator does not respond within 30 calendar days of receiving the notice, it may be assumed that the plan is complete and acceptable and the cleanup may proceed according to the submitted plan. Once cleanup is underway, any changes from the notification must be provided to the EPA Regional Administrator in writing no less than 14 calendar days prior to implementation of the change.

Risk-Based Disposal Approval

You must submit and an to EPA under the risk-based disposal option to sample, cleanup or dispose of building materials contaminated with PCBs materials from which PCB caulk has been removed in a manner other than described under 40 CFR section 761.61(a). Each application must contain the information described in the notification requirements outlined in 40 CFR section 761.61(a)(3). EPA may request other information necessary to evaluate the application. EPA will issue a written decision on each application for a risk-based method and will approve an application if the Agency finds that the method will not pose an unreasonable risk of injury to health or the environment. It is recommended that you contact your Regional PCB Coordinator to discuss the necessary requirements under the risk-based option.

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The following information provides an overview of various tools and methods available for removal and abatement of caulk and related building materials. Generally tools should be selected that minimize dust and heat.

Factors to Consider when Selecting Appropriate Tools and Methods

It is important to evaluate the location and accessibility of the caulk to select the most appropriate tools. It is important to consider materials properties before choosing the right tool to remove old caulk. Check whether the caulk is hard and brittle (aged and weather-exposed caulks frequently seen in exterior areas) or elastic and soft (primarily in areas protected from sunlight and weather, and located indoors). Furthermore, the material and condition of the adjoining structures (smooth or rough joint faces) play a role in the selection of tools. The following list includes most frequently encountered materials of adjoining structures:

• Concrete.
• Sandstone.
• Bricks.
• Polystyrene (with plaster layer).
• Wood.
• Metals (e.g., window frames).

The anticipated dust and heat generation plays an important role in selecting the right tools and methods for removal. If your tools or work methods generate high heat (temperatures exceeding 212° F.), there is the risk that the PCBs may be released into the air and workers or building occupants may breathe in PCB gases. More comprehensive protective measures are necessary for methods that generate moderate to heavy amounts of dust or heat.

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Typical Tools and Methods for Removal Activities

Manual tools are primarily used for smaller joint lengths or when the joints are difficult to access for structural reasons. The summary of suggested tools and methods page provides a summary of the typical manual tools and methods used for removal activities. Advantages of manual processes compared to electromechanical methods include: 

• A lower volume of fine dust.
• The absence of heat development.
• Lower expenditures for personal and environmental protection.

Utility knives are particularly suitable for manual processes, provided the caulk is not too hard or brittle. Soft caulk, especially indoors and in external areas without weather or sun exposure, can be quickly and efficiently removed with a utility knife. Hard or brittle caulk is mainly found in exterior areas, especially in places with sun exposure. Hard or brittle caulk may have to be broken or chiseled out with ripping chisels, crowbars, hammers and chisels. Depending on the condition of the caulk and the surrounding materials, the joint faces can be reworked by shaving and scraping with a putty knife, scraper or wire brush.

Electromechanical tools have ergonomic advantages over most manual methods, as they are better suited for projects with many joints and semi-soft to hard and brittle caulk. Electrical joint cutters with rotating blades (also known as oscillating knives) have proven especially useful in these situations. Generally, electromechanical procedures generate higher volumes of dust and more heat, which requires more complex protective measures (personal and environmental protection) than manual methods. Some electromechanical tools may have limited applications (e.g., jigsaw), or are unsuitable because they produce significant amounts of dust or high heat. The summary of suggested tools and methods page provides a summary of the typical electromechanical tools and methods used for removal activities.

Joint faces usually have to be cleaned after the removal of the old caulk to install the new, high-quality caulking. The removal of the caulk containing PCBs should be as complete as possible with no visible residue remaining. The selection of tools and methods for cleaning/reworking joint faces is primarily based on structural requirements and consideration of protective measures. Additionally, the material properties of the adjoining structures must be taken into account to ensure that the joint faces are not damaged. Tools with beating, striking, or pronounced abrasive effects are not suitable for working on sensitive adjoining structures, such as limestone, plaster-covered insulation, wood, or metal parts.

Dry ice blasting is an effective method to treat joint faces. It is primarily reserved for major restoration projects because of the complex protective measures it requires. In the case of smooth, non-porous surfaces such as metal (e.g., unpainted window frames), glass, ceramic materials or tiles that are not to be removed and disposed of, the surface should first be cleaned with a rag dipped in solvent (e.g., acetone). You should observe the following protective measures when working with solvents:

• Solvent-resistant gloves.
• Increased air exchange with sufficient fresh air supply.
• Compliance with workplace limit values.
• Measures to prevent fire and explosion.

In addition, used solvent and/or cleaning rags may be subject to regulation under federal or authorized state hazardous waste regulations.

Data from individual restoration projects have shown that PCBs spread from the caulk into adjoining structures (e.g., brick, wood, or concrete) over time. Consequently, it is highly likely that the material adjoining the PCB-containing caulk at the joint face is contaminated. In many cases of caulk contaminated with PCBs at > 1,000 ppm, several millimeters of the adjoining concrete contained PCB contamination in a concentration range of several hundred to several thousand ppm. As previously discussed, the adjoining materials contaminated with PCBs are typically characterized as PCB remediation wastes. PCB bulk product waste must be handled in accordance with 40 CFR section 761.62, while PCB remediation waste must be handled in accordance with 40 CFR section 761.61. Refer to Abatement Step 3 for more information.

Under certain situations, it may be more practical to separate PCB-contaminated parts of the building materials from adjacent PCB-free materials in the area of the joint faces. This can be done with electromechanical tools such as circular saws, slot mills with diamond blades or with maximum pressure blasting methods. In such cases, the material separation should include sufficient safety spacing from the non-contaminated building parts and suitable measures to contain the dust volume and retain the blasting materials.

Take note that PCB contaminated building materials are considered PCB bulk product waste when the PCB caulk is still attached, while PCB contaminated building materials are considered PCB remediation waste when the PCB caulk has been separated from the building materials and disposed of separately. If your abatement plan states that you intend to dispose of the PCB caulk and any contaminated building materials together and the PCB caulk becomes separated from the adjacent contaminated building materials during remediation, you may still dispose of all the materials as a PCB bulk product waste.

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Protective Measures

The need for protective measures primarily depends on the volume of dust generated by the particular work method. It is best to select tools and methods that generate the lowest possible dust volume to limit protective measures needed. Protective measures should provide the following:

• Direct personal protection (workers).
• Protection of building users and third parties (e.g. passers-by).
• Safeguard the potential for spreading PCB contamination (cross-contamination) to surrounding areas of the abatement project.

An integral step in implementing protective measures is to assign a containment area for each distinct abatement area. The containment area size and construction should be proportionate to the activities that will be conducted (i.e., amount of dust generation expected). Containment structures should be constructed within the containment area at each location where abatement is performed and in a manner that prevents airborne dust from spreading outside the abatement area. For example, a containment structure can be constructed of poly sheeting draped over existing building features and/or support frames built specifically for the containment area. The containment area should be maintained under negative air pressure by installing an induced draft fan equipped with high efficiency particulate air (HEPA) filters to prevent dust particles from being carried out of the containment area. The filtered exhaust from the fan should be routed outside the containment area and vented outside of the building. Dust monitoring outside the containment structures may be warranted when significant dust is produced by the abatement activities.

Dust aspiration techniques can be used to reduce the amount of dust created from tools/methods that can generate higher dust volumes, such as grinders, cutters, saws, and slot mills as identified on the summary of suggested tools and methods page. These techniques are efficient methods for reducing the amount of dust that can spread through the containment area and can significantly reduce the amount of dust in the breathing zone of the worker using the tool. Affixing a dust collector nozzle (connected to an industrial vacuum with HEPA filters) to the working end of the electromechanical tool is an example of a dust aspiration technique. The figure below illustrates examples of dust aspiration techniques.

Depending on the selection of tools, PCB gases and dust are likely to be released to air when working on an abatement project. Therefore, workers should use suitable protective measures (personal protection gear) when working with dust-generating methods or tools. These protection measures should prevent PCBs from getting into the body through inhalation, ingestion, and/or by absorption through exposed skin.

The following protective measures are generally applicable, and should be considered when handling materials containing PCBs:

Occupational Protective Measures

• Gloves and skin protection - Chemical-resistant gloves and Tyvec^® coveralls are the standard personal protective equipment (PPE). Chemical-resistant gloves made of nitrile butadiene rubber are particularly protective. Pay particular attention to the type of gloves and how long gloves can be used when working with solvents (e.g. for cleaning non-porous surfaces). Only certain gloves are suitable for working with particular solvents, and how long gloves can be used with that solvent (breakthrough time) differs.
• Eye protection - All workers should wear safety glasses or protective goggles for all removal, abatement, and sampling activities.
• Respiratory protection - Consider using an air-purifying respirator (OSHA/National Institute for Occupational Safety and Health approved) with combination organic vapor and HEPA cartridges when working with dust generating activities or solvents.
• Worker hygiene - Eating, drinking and smoking should be prohibited in the work site. Showers and separate changing cabins for work clothing and everyday clothing should be provided for work involving dust generation.

Protective Measures for Third Parties and the Environment

It is important to prevent PCB-contaminated dust from contaminating the immediate surroundings (i.e. adjoining rooms for interior projects and directly adjoining areas of exterior projects) to protect third parties and the environment during abatement projects. PCBs can stay in the environment for long periods and can be a source of exposure to building occupants. Consider the following protective measures for third parties and the environment when handling materials containing PCBs:

• Adequately construct a containment area to minimize the spread of PCB dust to other surrounding areas and to make sure proper control requirements are followed (i.e., removal of used PPE prior to exiting the control area).
• Properly store removed PCB-contaminated materials directly at the place of removal. Materials should be placed in tightly-locking, stable containers (e.g., fiber drums or polyethylene buckets with polyethylene lining).
• Regularly clean the work area, including tools and machinery, with an industrial vacuum and HEPA filter and/or mopping to remove particles.
• Properly dispose of contaminated protective clothing (e.g., gloves and protective suits), filters of aspiration devices, and cleaning aids in the containment area.

In addition to these generally applicable protective measures, consider conducting air sampling in the vicinity of the containment area to assess whether PCB-contaminated dust is escaping the containment area and impacting nearby clean areas. The air sampling should be conducted using the procedures discussed testing and characterizing suspect materials in the section. Consider the following when determining if air sampling should be conducted during abatement activities

• Amount of dust generated by the activities.
• Location of abatement activities.
• Duration of dust-generating activities.
• Size of the area being remediated.
• Concentration of PCBs in the material being remediated.
• Effectiveness of the containment area structure.

Heating, Ventilating and Air Conditioning (HVAC)

The HVAC system should be shut down and remain off until PCB abatement is complete. The abatement areas should be isolated from the HVAC system if this is not possible. During the preliminary assessment of PCB contamination levels, sampling should be conducted in all areas/rooms/units serviced by the HVAC system to determine the spread of contamination. Sampling results should also be noted in the cleanup plan.

Hire contractors who specialize in cleaning ventilation systems to clean HVAC systems, as they have specialized tools and training to ensure thorough cleanup. It is important to remember that not all ventilation system ducts can be cleaned. For example, some ducts are lined with fiberglass or other insulation, which can release fiberglass into living areas if damaged during cleaning. Also, flexible ductwork frequently has a porous inner surface and, in most cases, cannot be economically cleaned. For this reason, the ductwork should be discarded and replaced after the ventilation system is cleaned.

If it is determined that the HVAC system can be cleaned, it should be conducted early in the abatement process. Once cleaned, the HVAC system should be sealed at all openings to prevent potential recontamination. At a minimum, when approaching a ventilation system constructed of non-porous materials, ventilation contractors should:

• Perform a walk-through of the structure to establish a specific plan for decontamination of the ventilation system.
• Follow safety and health procedures in accordance with OSHA regulations and guidelines as well as other applicable state or local worker safety and health regulations to protect workers and others in the vicinity of the structure during the decontamination process.

Communications About the Job and Site Security

Clear communication with all affected groups (e.g., building occupants, workers, building owners, and community members) is necessary to create a safe working environment. Site security measures should also be implemented to prevent unauthorized access to the containment areas.

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Suggested Work Area Decontamination Methods

Following the abatement activity and break down of the containment area, the entire area should be vacuumed with an industrial HEPA vacuum and wiped with wet rags to remove any dust from surfaces within the area. All wastes collected or created (e.g., used rags) should be placed in a container or wrapped in plastic and transported to the disposal storage area. You must then conduct a visual inspection of the decontaminated area to determine if additional decontamination is warranted (i.e., if the area is still dusty). The HEPA vacuum should also be decontaminated or disposed of.

Collect wipe samples from surfaces within the subject area after the decontamination is considered complete. Collect a sufficient number of wipe samples within the subject area to ensure that the area was fully decontaminated. The number and location of samples should be determined in accordance with 40 CFR part 761 subpart O (bulk wastes and porous surfaces) or subpart P (non-porous surfaces) with a minimum of three samples collected from each type of bulk PCB remediation wastes. You should collect samples from horizontal surfaces where dust is most likely to accumulate.

The subject area is considered sufficiently decontaminated if conducted in accordance with 40 CFR section 761.79. If the standard of 10µg/100 cm2 is not met for all of the wipe samples, additional decontamination procedures must be performed within the entire subject area and additional wipe samples must be collected. These procedures will be repeated until the 10µg/100 cm2 standard has been achieved.

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After the materials within the containment area have been removed and broken down, all the materials that will be disposed should be contained (e.g., wrapped in poly sheeting or placed in a drum), and immediately transported to a designated storage area. Disposal methods are determined based on the regulatory material classification previously discussed in Abatement Step 1. All applicable provisions for storing, packaging, transporting, manifesting, recordkeeping and disposing in the PCB regulations must be adhered to.

How Do I Dispose of My PCB-Containing Caulk and Attached Building Materials?

The disposal of PCB-containing caulk and any attached PCB-containing building materials is regulated under 40 CFR section 761.62. (Note: If your abatement plan states that you intend to dispose PCB caulk and any contaminated building materials together and the PCB caulk becomes separated from the adjacent contaminated building materials during remediation, you may still dispose all the materials as a PCB bulk product waste. Under this provision, PCB bulk product waste must be disposed using one of the following methods:

• Performance-based disposal - allows for disposal of PCB bulk product waste using the following methods:
  • Toxic Substances Control Act (TSCA) incinerator
  • TSCA chemical waste landfill
  • RCRA hazardous waste landfill
  • TSCA approved alternate disposal method
  • TSCA regulated decontamination procedures
  • Facility with a coordinated approval issued under TSCA (disposal under this option does not require you to obtain approval from EPA)
• Disposal in solid waste landfills
  • PCB bulk product waste may be disposed of in non-hazardous waste landfills as permitted by states. Disposal under this option does not require EPA approval. However, EPA recommends that you check state regulations, which may prohibit or limit disposal of PCB bulk product waste in solid waste landfills. EPA also recommends that you determine prior to shipment that the landfill is willing and able to accept the PCB waste. Anyone sending PCB bulk product waste to a non-hazardous waste landfill permitted by a state must send written notice to the landfill prior to shipment of the waste stating that the waste contains PCBs at greater than 50 ppm (review 40 CFR section 761.62(b)(4)(ii)). This guidance document does not replace or supersede any (sampling) requirements that the receiving facility may deem necessary to determine acceptance of the waste into its facility. Additionally, this guidance does not supersede state requirements which may be more stringent than those mandated by the federal government for management of this debris
• Risk-based option
  • The risk-based option allows for a site-specific evaluation of whether PCB bulk product waste may be disposed of in a manner other than under the performance based disposal option or the solid waste disposal landfill option. Disposal of PCB bulk product waste under this option requires EPA approval, and requires you to demonstrate that the disposal will not present an unreasonable risk of injury to health or the environment.
• Disposal as daily landfill cover or road bed. (40 CFR section 761.62(d))

NOTE: Resampling caulk waste is not necessary for a performance-based disposal, disposal in a solid waste landfill or disposal as a daily landfill cover or road bed, but may be necessary when implementing the risk-based disposal option. However, sampling methods described in 761.62 were not designed for waste caulk material. Consult your Regional PCB Coordinator for alternative methods if you select this disposal option.

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How Do I Dispose Remaining PCB-contaminated Building Materials if PCB Caulk has been Removed?

Disposing masonry, wood, bricks and other building materials contaminated with PCBs from which PCB caulk has been removed and is separately disposed of from the surrounding building material is regulated under 40 CFR section 761.61. The following options can be used to manage PCB remediation wastes:

Self-implementing cleanup and disposal

The self-implementing option links determining cleanup levels with the expected occupancy rates of the area or building where the contaminated materials are present. The disposal requirements for the self-implementing option vary based on the type of contaminated material and concentration of PCBs in the materials, among other things. Contact your PCB Regional coordinator if you elect to use this disposal option.

Performance-based disposal

The performance-based option allows for disposal or decontamination of the contaminated materials in a TSCA chemical waste landfill; a TSCA incinerator; through a TSCA approved alternate disposal method; under the TSCA regulation's decontamination procedures; or in a facility with a coordinated approval issued under TSCA. Disposal under this option does not require you to obtain an approval from EPA.

Risk-based cleanup and disposal

The risk-based option allows for a site-specific evaluation of whether the PCB-contaminated building materials may be cleaned up or disposed of in a manner other than the alternatives provided under the self-implementing or the performance based disposal options. Disposal of these materials under this option requires you to obtain approval from EPA and demonstrate that the disposal will not present an unreasonable risk of injury to health or the environment.

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How Do I Dispose of My Cleanup Debris?

Wastes generated during the cleanup activities described in the Leave the Work Area Clean section must also be properly disposed of. Non-liquid cleaning materials and PPE waste at any concentration, including rags, mops, gloves, Tyvec suits and similar materials resulting from cleanup activities, must be disposed of in an appropriate waste facility (i.e., state municipal solid waste, state non-municipal non-hazardous waste, federal hazardous waste landfill, or a federally approved PCB disposal facility -- view section 761.61(a)(5)(v)). Waste water produced during the job from mopping, wet cleaning or misting may be regulated for disposal. Follow the decontamination procedures for water at 40 CFR section 761.61(a)(4)(iv) if you know the concentration of PCBs in waste water. Assume the waste water to be regulated and dispose of the water in a TSCA approved facility (40 CFR section 761.61(b)(1)) if you do not know.

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Disposal Facilities

• TSCA-approved disposal facilities.
• Contact your state environmental agency to find a solid waste disposal facility that will accept PCB-containing a caulk.

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The contractor should perform documentation of the field activities on a daily basis during the abatement project. Following completion of the remedial action, the contractor should prepare an abatement report. The following subsections describe the documentation that should be completed during the project:

Field Notes

A daily log of on-site activities should be maintained and may include the following such items:

• Daily health and safety meetings.
• Personnel and equipment on site.
• Field procedures and observations.
• Removal, abatement, containment, and decontamination progress.
• Sample locations with selection criteria, samples collected, analyses performed, and sample handling.
• Telephone or other instructions.
• Health and safety issues.
• Health and safety monitoring data, including dust monitoring outside containment.
• Estimate of wastes generated and stored.
• Waste transporter information.

Photographs

Daily photographs should be taken of representative activities, such as removal and abatement work, containment structures, decontamination, sampling, and waste handling and storage. Copies of selected photographs with appropriate captions should be included in the abatement report.

Transport and Treatment/Disposal Certifications

If necessary, manifests and/or bills of lading for the transportation, treatment and disposal of regulated waste materials, as well as treatment of the waste certification must be obtained from the transporter and from the treatment/disposal facility. Copies of these forms must be included in the abatement report, and records must be maintained in accordance with the requirements as specified in 40 CFR part 761 subpart K (PCB Waste Disposal Records and Reports).

Abatement Report

An abatement report should be prepared upon completion of all remedial activities and include the following information:

• Site description.
• A description of field procedures.
• Confirmation of sample locations and analytical results for all characterization and verification samples collected.
• A photographic record of the removal and abatement, containment structures, and decontamination.
• Dust monitoring data.
• Waste transport and treatment disposal information.
• Copies of waste manifests and bills of lading.

The abatement report and accompanying backup information must be kept on file for a period of three to five years from the date that the abatement activities were completed, as described in the following information:

• Five years for Bulk PCB Remediation Wastes cleaned up and disposed of according to the self-implementing procedures of 40 CFR section 761.61(a).
• Three years for PCB Bulk Product Wastes removed and disposed of in a solid waste landfill according to the provisions of 40 CFR section 761.62(b).