PCBs: Public Pools:

Keeping Kids Swimming

Presented by: Ileen Gladstone, P.E., LSP, LEED AP Vice President & Senior Practice Leader

Overview

PCBs in Swimming Pools

Regulatory Process

Case Studies

Where are PCBs Found?

• Need to know prior to pool maintenance,

renovations, or replacement.

• Caulk in pool expansion joints, concrete

decking expansion joints, and surrounding

auxiliary structures.

• Paint used to coat pool surfaces.

• Mastic-like materials behind pool gutters.

• Adjacent concrete.

• Soils.

Potential Exposure Pathways

• Direct contact with decking materials.

• Direct contact with pool materials.

• Pool water.

• Construction workers during

maintenance, renovation, or

replacement.

TSCA Compliance

• Prohibition of the use of PCB products at levels > 50 ppm, as

well as the building materials that those products have

contaminated.

• Testing not required, but if PCB concentrations are detected in

the materials above the regulatory limit, then the regulations

require the removal and proper disposal of those materials.

• Once removal is initiated, PCBs must be cleaned up to less than

1 ppm in the remaining materials, unless a deed restriction is

placed on the property.

• PCB-remediation waste is managed at its "as-found" PCB

concentration and it is characterized based on in situ sampling

rather than post-excavation or demolition composite samples

collected from waste piles and roll-off containers.

Disposal

• Waste PCBs > 50 ppm disposed of at a TSCA-permitted PCB

disposal facility or a federally-permitted hazardous waste landfill

in accordance with TSCA manifesting, reporting, and record

keeping requirements.

• Waste with PCBs < 50 ppm PCBs may be disposed of at TSCA-

permitted facility, a hazardous waste landfill, a permitted state-

municipal solid waste landfill or a state non-municipal non-

hazardous waste landfill.

• Unless it is assumed that all materials have concentrations of

PCBs greater than 50 ppm, TSCA provides for a very intensive

and prescriptive testing program to ensure that wastes

containing greater than 50 ppm do not end up in a solid waste

landfill.

Maintenance, Renovation, or

Replacement

• PCB remediation affects the schedule, planning, and

costs.

• Needs to be coordinated with the Capital

Improvement Program; often done prior to renovation

or reconstruction of the pools or integrated into

design package.

• General contractors for pool construction are typically

not experienced, equipped, or trained to conduct the

remediation; therefore, it may need to be performed

by a specialty contractor.

Maintenance, Renovation, or

Replacement

• The in situ characterization and cleanup plan

approval process can take months, which must be

factored into a total project schedule.

• Conducting characterization in the fall, once the

swimming season has ended in temperate climates,

will likely provide sufficient time for a spring

construction project.

• Once PCBs greater than 50 ppm are discovered at a

pool, the EPA may not allow its use until remediation;

therefore, conducting characterization in the late

winter or spring may result in closure of a pool over

the summer season.

Case Studies

• Shine Memorial Pool, Worcester

• Senator Casey Memorial Pool, Milford

• Allied Veterans Memorial Pool, Everett

Shine Memorial Pool

• Self-Implementing Cleanup Plan with a deviation for

verification sampling frequency.

• Remediated main and tot swimming pools and

decking surrounding pools prior to demolition.

• Remediated soil behind gutters and beneath decking

expansion joints.

• Re-graded the Site and constructed a zero-entry pool

and surrounding decking.

• Encapsulated impacted portions of pavilion and filter

building walls.

Shine Memorial Pool Pool Remediation

• Removal of: • Paint coating the pools;

• Gutters and a portion of the

pool walls from beneath the

gutters;

• Concrete adjacent to the

main pool expansion joints;

and

• The water seal behind the

main pool expansion joints.

• Dust Monitoring at Site

Perimeter.

Shine Memorial Pool Deck and Soil Remediation

• Removal of decking

adjacent to the pool

gutters and decking

expansion joints.

• Excavation of the PCB-

contaminated soil beneath

the decking expansion

joints and behind the pool

gutters

• PCB containing waste

paint chips disposed of on

Site along with the

comingled soil.

• Dust Monitoring.

Shine Memorial Pool Encapsulation and Post Remediation

• Coating the lower portions of

walls of the pavilion and the

filter building.

• Collecting soil, concrete, and

wipe verification samples.

• Dust monitoring at the

perimeter of the Site.

• Deed restriction.

• Long-term Monitoring Plan.

Coated Portion of Wall

Shine Memorial Pool Remediation Waste

• 137 tons of PCB-impacted material

(concrete, soil, and stainless steel

gutter) > 50 ppm PCBs disposed at a

hazardous waste landfill.

• 17 tons of concrete and 26 tons of paint

chip-impacted soil < 50 ppm PCBs were

disposed of at a non-municipal solid

waste facility.

Senator Casey Memorial Pool

• Self-Implementing Cleanup Plan

approved, completed as Risk-Based

Cleanup.

• Remediated main and tot swimming

pools and concrete decking.

• Two-phase cleanup, including Interim

Remedial Measure.

Senator Casey Memorial Pool Initial Remediation

• Removed paint from the surfaces of the main and tot pools.

• Removed caulk from the main pool and decking expansion

joints.

• Removed approximately 1.5 inches of concrete from both sides

of the main pool expansion joints to a depth of 1.5 inches.

• Pools were re-painted and the expansion joints were

reconstructed.

• PCB -impacted concrete in the main and tot pools remained,

and soil beneath the decking expansion joints were impacted

with PCBs from the caulk.

• Impacted concrete and soil could not be remediated before the

summer swimming season.

Senator Casey Memorial Pool Interim Remedial Measures

• To open the pool for the summer season,

EPA required implementation of an Interim

Measure.

• Goal: Eliminate the potential exposure

pathway to PCBs on accessible surfaces.

• Coating the main and tot pool surfaces.

• Collecting wipe samples from the coated

surfaces.

• Collecting two rounds of pool water samples.

Senator Casey Memorial Pool Final Remediation

• Concrete decking adjacent

to expansion joints.

• Concrete decking adjacent

to the pool gutters.

• Grout between the gutters

and the pool walls.

• Stainless steel gutters.

• The tot pool shell.

• The tot pool railing.

• Soil from beneath the

decking expansion joints

and from behind the

gutters.

Senator Casey Memorial Pool Final Remediation

• Collected soil and concrete verification samples.

• Performed dust monitoring at Site perimeter during remediation.

• Contractor unsuccessfully attempted to remove paint and

underlying PCB-impacted concrete from the main pool.

• Remediation strategy changed to meet the schedule for

reconstructing and opening the pool in time for the summer

2010 swimming season.

• Constructed new pool shell over the existing pool shell, thereby

encapsulating the existing PCB-impacted concrete shell with a

new concrete shell ranging in thickness from 6 to 8 inches.

• Deed restriction required.

Allied Veterans Memorial Pool

• Risk-Based Cleanup Plan.

• Pools, decking, and bath house

constructed in the late 1960s.

• Additional decking areas were

constructed in 2000 and 2008.

• PCBs present in caulking, concrete, and

paint.

• Utility tunnel surrounds the pool.

Allied Veterans Memorial Pool Sample Locations

Allied Veterans Memorial Pool Risk-Based Cleanup Plan

• Underlying PCB-contaminated paint is classified as “excluded product.”

• Remove and replace caulking in the main pool and original decking

expansion joints.

• Coat the interior surfaces of the expansion joints prior to installing the

new caulking.

• Caulking removed from the decking expansion joints will be disposed of

as a greater than 50 ppm PCB-bulk product.

• Coat concrete adjacent to the original decking expansion joints.

• Coat the lower portion of the bath house wall.

• Maintain existing cap, which consists of decking and caulking, over soil.

• Perform long-term monitoring and maintenance of the coating and cap.

• Record a deed restriction.

PCBs: Public Pools:

Keeping Kids Swimming

Presented by: Ileen Gladstone, P.E., LSP, LEED AP Vice President & Senior Practice Leader

PCBs: Public Pools:

Keeping Kids Swimming

Presented by: Ileen Gladstone, P.E., LSP, LEED AP Vice President & Senior Practice Leader

PCBs: Public Pools:

Keeping Kids Swimming

Presented by: Ileen Gladstone, P.E., LSP, LEED AP Vice President & Senior Practice Leader