http://shrinkster.com/17b4

Not the answer, but it appears that the DOE interpretation of 40CFR says
annual logs must be maintained for 3 years after disposal of PCB laden
material.  This sounds like an awfully short time to me though, but I'm
assuming it's based on the fact the reports are filed annually with the EPA,
so they would have the info for longer periods of time.

I recall when I worked for a public utility, our guidance was to retain
records related to potential employee exposure to PCBs for an 'indefinite
period' in the event of medical issues arising related to those employees
after they had separated.

Tough to assign indefinite in a schedule or an ERMS though... so I'm
assuming they elected to use permanent.

And yep, it's not an easy read, but here's where the regs are and I'd
recommend the city attorney give 'em a looky-see  http://shrinkster.com/17b6
 If you haven't been preparing these annual reports they call out, it might
be a good idea to make contact with someone and throw yourself on their
mercy sooner rather than later.

Larry
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