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Abatement Step 4: Prepare and Maintain Documentation
Table of Contents
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
- Photographs
- Transport and Treatment/Disposal Certifications
- Abatement Report
- Where Can I Get More Information about PCBs in Caulk
Field Notes
A daily log of on-site activities should be maintained and may include such items as:
- 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 containments
- 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
Manifests and/or bills of lading for the transportation, treatment, and disposal of regulated waste materials and certifications of the treatment of the wastes, if necessary, 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 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:/p>
- 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 below:
- Five years for Bulk PCB Remediation Wastes cleaned up and disposed of according to the self-implementing procedures of 40 CFR 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 761.62(b).
Where can I Get More Information about PCBs in Caulk?
For more information on how to properly test for and address PCBs in caulk, contact the Regional PCB Coordinator for your state.
In addition, see EPA's PCBs in Caulk Web page.
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