Abatement Step 1: Prepare an Abatement Strategy
Table of Contents
Based on the results of the sampling plan, an abatement strategy should be developed. This strategy may require assistance from your Regional PCB Coordinator and state environmental and health agencies.
- Classification of Removed Materials with PCBs
- Abatement Prioritization
- Notifications to EPA May Be Required Prior to Starting a Project
Classification of Removed Materials with PCBs
You will need to determine the type of PCB waste you are removing and 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.
Please see Current Best Practices for PCBs in Caulk Fact Sheet - Removal and Clean-Up of PCBs in Caulk and PCB-Contaminated Soil and Building Material for a discussion of the classification of removed materials with PCBs.
Descriptions and details on the disposal options are discussed in Abatement Step 3. Some of these procedures have requirements for notification and certification; these are described under "Notifications" below.
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.
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.
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 and obtain approval from EPA prior to starting your removal or abatement project. Please see Abatement Step 3 for your disposal options.
The decision on 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 instance, 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.
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 761.61(a)(3)(C)] and submitted as part of the notification and certification requirements described in "Notifications and Certifications" 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 proposed cleanup levels, removal and abatement procedures, verification sampling procedures, waste storage and handling procedures, and disposal options. The plan also 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 part 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 part 761.61(c), you must submit the appropriate notifications to the EPA, as described below.
Self-Implementing Procedure -- At least 30 days prior to removal and abatement of building materials contaminated with PCBs using the self-implementing procedure, the person in charge of the cleanup or building owner must notify the following people of the planned action in writing:
- The EPA Regional Administrator
- The Director of the state or tribal environmental protection agency, and
- 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 -- 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 part 761.61 (a) you must submit and application to EPA under the risk-based disposal option, an application must be submitted to EPA. Each application must contain the information described in the notification requirements outlined in 40 CFR part 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 EPA 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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