Author: Jeff Carnahan

Indiana Ranks High for Business and Manufacturing

Posted on by Jeff Carnahan

If you’re a business owner, Indiana is the place to be. Indiana ranked eighth in Forbes’ 2015 list, Best States for Business. In particular, Indiana is a great state for manufacturing. The state was given an A rating for manufacturing Industry Health in the Conexus Indiana 2015 Manufacturing & Logistics Report Card, scoring higher than the nearby states of Illinois, Kentucky and Ohio. To give some more concrete statistics, almost 17% of Indiana’s workforce is employed by manufacturers, and over 30% of the state’s gross product is manufacturing.

Factors that help support this great business and manufacturing climate include favorable environmental policies and legislation. In fact, Forbes ranked Indiana second for regulatory environment.

In contrast, however, a bill was proposed (H.B. 1241) in 2014 that would have prevented business owners from being able to use their commercial general liability policies to cover pollution damages and remediation costs. The bill would have allowed an insurer not to cover well-known pollutants or to define pollution in vague terms to avoid paying for cleanup.

Business owners protested the bill, contending that it would harm small and large employers alike and put jobs in jeopardy. The bill also would have hindered cities working to address environmental issues at various contaminated sites. Ultimately, the bill didn’t pass, which shows the importance that Hoosiers place on providing an ideal climate for successful businesses and manufacturers.

Manufacturers in Indiana have a great opportunity to not only be in a state that supports business and manufacturing on the whole, but also to deal with environmental liability in a way that doesn’t drain financial resources or harm their business. Because of the legislation Indiana has in place for insurance, EnviroForensics is able to locate and use old insurance policies, via our sister company PolicyFind, to pay for site investigation and cleanups, as well as associated legal fees. We are also equipped with a team of expert engineers and geologists who have extensive expertise in the remediation of soil and groundwater contamination, as well as vapor intrusion exposure issues.

To keep their businesses thriving, Indiana manufacturers should take this great opportunity to deal with any environmental issues on their properties. While Indiana law is currently favorable toward manufacturers, you never know when legislation and policies could change. Don’t miss your chance.

EnviroForensics Obtains Three No Further Action Letters for Chlorinated Solvent Sites in 2015

Posted on by Jeff Carnahan

2015 was a year of growth and success for EnviroForensics. We began construction on our new downtown Indianapolis headquarters, added 23 employees to our team, and made progress on numerous sites for our clients. We are particularly proud to announce that we obtained three No Further Action (NFA) letters for clients in the past year. Three may not seem like a very large number of closures, but keep in mind that releases of chlorinated solvents like PCE can be very complicated to assess.  Additionally, regulators scrutinize work on chlorinated solvent sites, as there are multiple exposure concerns to address on even fairly straightforward sites.

Client in San Diego, California

The first no further action determination we received was for a former dry cleaner operating as a drop-off shop in San Diego, California. The former dry cleaner was located in a tenant space in a strip mall. Corrective actions were required for the site by the San Diego County Department of Environmental Health (SDCDEH) due to the potential for vapor intrusion (VI) to occur at the dry cleaner. Because of this location, multiple parties were involved during the site investigation and remediation process. In addition, the strip mall became part of a real estate transaction during the remedial phase, which created additional objectives and time frames.

EnviroForensics was hired in 2005 by the responsible party after a Corrective Action Plan (CAP) submitted by a former consultant was approved by SDCDEH. Past operational activities had caused volatile organic compound (VOC) contamination beneath the building. The approved CAP recommended soil excavation combined with soil vapor extraction (SVE) throughout the remaining contaminated soils. Since active dry cleaning operations were occurring at the site at the time of the CAP approval, the CAP was implemented in stages to avoid disrupting business activities. An SVE system was installed in December 2007, expanded in October 2010, and retired in 2013 to prepare for the completion of the soil excavation activities.

The soil excavation activities included the removal of dry cleaning and steam pressing equipment, clothing racks, and piping to facilitate the indoor soil excavation. Geotechnical and structural engineers were brought in to assess the soil excavation plan. After remedial activities were finished, several rounds of indoor air samples were completed to mitigate any vapor intrusion pathways.

In February 2015, the SDSCEH issued a Case Closure Summary Letter to the site, allowing for the pending real estate transaction to be completed.

Client in Elkhart, Indiana

Another NFA determination was achieved for a client of ours in Elkhart County, Indiana. TCE was detected during a commercial property transaction in the groundwater on our client’s property. Never having used TCE in any of their operations, our client was perplexed.

Subsurface investigations begin in 2014, consisting of widespread soil and groundwater testing. Although TCE was found in the groundwater, no traceable sources were discovered on the site. We were able to provide several lines of evidence that showed the contamination was from an unknown up gradient source. In response, the Indiana Department of Environmental Management (IDEM) issued an NFA letter to the site in July, 2015.

Client in Jasper, Indiana

The third NFA letter we obtained was for a dry cleaner client in Jasper, Indiana. Our client began their operation in 1997 after converting the property from an ice cream parlor. Although there had been no evidence from historical records that dry cleaning operations had been conducted at the site prior to our client purchasing it, PERC contamination was found in soil and groundwater samples beneath the building in late 2012. Investigation and site characterization was performed, and in January 2014, we concluded that minimal chlorinated concentrations in soil and in the initial water-bearing zone were only located on a small area beneath the site.

We were able to prove that the contaminants were not migrating through groundwater or preferential pathways to offsite receptors or the river by using several lines of evidence. We requested that IDEM approve Site Characterization and recommended the site seek an Environmental Restrictive Covenant. In May 2015, IDEM issued a NFA letter to the site. Our client was looking to sell the business, and with this NFA status will be able to move forward and finalize the sale.

Is Your Environmental Due Diligence Really Diligent Enough?

Posted on by Jeff Carnahan

Today’s savvy buyer of commercial and industrial real estate will always perform environmental studies, and even testing, as part of the due diligence process prior to completing a real estate transaction.  If a financial lender is involved, it’s a must. Due diligence most often starts with a Phase I Environmental Site Assessment.  If the assessment points to potential subsurface impacts from past onsite or nearby operations, a subsurface investigation (or Phase II investigation) is generally necessary to confirm site conditions.  The Phase II consists of a limited sampling event designed toward the specific concerns identified in the Phase I.  Phase II projects are often performed within a constrained budget established by the buyer, or being paid for by a seller who wants to spend as little money as possible, who hopes that the concerns identified in the Phase I are unfounded.  Phase II investigations are typically seen as high-level presence/absence assessments rather than complete quantitative investigation of the extent of any identified impacts.  In essence, a Phase II is utilized to metaphorically check a box “Yes” or “No” as an answer to whether or not a subsurface release has occurred from each identified historical concern.  For the Phase I and Phase II process to be successful indicators of the environmental conditions of subject properties, it is important for the consultant performing the due diligence activities to understand the how many different types of past operations could potentially result in releases. Additionally, due diligence professionals must have adequate expertise with designing minimal work plans, that will still answer the important questions related to getting the transaction deal done.

When performing Phase II assessments at properties involving a current or former dry cleaning or manufacturing facility with impacts from past usage of chlorinated solvents (i.e. PCE or TCE), a specific expertise is required. Releases of TCE and PCE can be difficult to detect with a limited investigation since these contaminants may migrate downward from a surface source in very narrow pathways that are hard to find.  A truly experienced environmental professional can also identify hidden areas where chlorinated solvents may have been released due to an intimate knowledge of historical solvent use and disposal practices.  There can never be enough existing information about site geology and the configuration of potential contaminant migration pathways prior to conducting a Phase II, if the consultant has not done sufficient research and planning on surrounding geological conditions, or doesn’t have significant industry knowledge of the contaminant behaviors. If borings are not placed in the appropriate locations or are not advanced deep enough to detect these sometimes sneaky contaminants, you might get a “clean” environmental report, when you actually have a problem that just went undetected due to an inadequate investigation.

An environmental due diligence investigation is only as good as the expertise that goes into the planning.  Although all parties involved in a real estate transaction hope for the best during the due diligence process, no one wins if existing contamination isn’t identified. This is especially true for properties where chlorinated solvents may have historically been used.  Sites impacted with chlorinated solvents typically can be exponentially more expensive to cleanup than other types of contamination.

Long Term Stewardship is Focus of Recent Environmental Events

Posted on by Jeff Carnahan

Long Term Stewardship, or LTS, is the most recent hot topic in the business of environmental claims, and understanding it is extremely important for constraining long-tail cleanup costs. In site cleanup and closure strategies that focus on risk-based concepts, the elimination of human health pathways is the determining factor for closure.  Often, closure plans include intentions to manage exposure through a series of institutional controls designed to limit future land use, although no provisions are in place to ensure that they are maintained following regulatory closure. Recent developments in environmental policy at the State and Federal regulatory levels are promoting the creation of guidelines requiring the need for specific LTS plans describing the monitoring and assessment activities to be performed.  Due to the potential for extremely long time periods over which LTS must be performed, the associated costs are high.  High enough, frequently, that monetary decisions are made to remove a larger amount of contamination during initial cleanup activities to limit the breadth or length of LTS requirements. With increased regulation of post-closure LTS activities, it has become, and will remain, extremely important to quantify LTS costs prior to finalizing remedial strategies.

Two recent industry events provided a special emphasis on this issue, as business owners, regulators, environmental consultants and insurance carriers attempt to fully understand how to quantify and evaluate the impact of LTS costs.  This evaluation is extremely important during the planning stages of site cleanup activities. The 2015 Annual Conference of the Federation of Environmental and Toxic Tort Issues (FETTI), held October 7-9, 2015, invited four environmental industry experts to discuss the issue. Attorney David R. Gillay (Barnes & Thornburg) presented legal considerations, Theresa Evanson (WDNR Remediation & Redevelopment) presented some challenges faced while exploring LTS issues in Wisconsin, Sherri Estes (U.S. EPA) discussed the Federal perspective, and Jeff Carnahan (EnviroForensics) presented a detailed analysis of how LTS costs and active remediation costs are balanced during remedial planning.

A seminar presented on October 22, 2015 by the Midwestern States Environmental Consultants Association (MSECA) also focused on LTS issues.  Representatives from the Indiana Department of Environmental Management and the U.S. EPA were on hand to present information and lead LTS discussions. The message delivered by the agency representatives was that LTS requirements will definitely be regulated in the near future, both at the State and the Federal level.  As presented in another case study by Jeff Carnahan, there are many times where larger upfront capital expenditures, in the form of active remediation, will reduce overall project costs and shorten timeframes when upcoming LTS requirements are considered.

 

About the Author:

mainjeffJeff Carnahan, L.P.G.
Vice President, Chief Technical Officer

866-888-7911
jcarnahan@enviroforensics.com

Jeff Carnahan is a Licensed Professional Geologist (LPG) with over 17 years of environmental consulting and remediation experience.  Mr. Carnahan’s expertise has focused on the investigation and interpretation of subsurface releases of hazardous substances for the purpose of evaluating and controlling the risk and cost implications to his clients.  While managing sites ranging in size from retail gas stations and dry cleaners to large manufacturing facilities, Mr. Carnahan has amassed extensive experience working with releases of chlorinated solvents within voluntary and enforcement cleanup programs for various State agencies and the U.S. EPA. Throughout his career Mr. Carnahan has provided technical support to the legal community regarding the cause, origin, transport and potential cost of environmental releases. Additionally, Mr. Carnahan has over 13 years of experience in the investigation and mitigation of vapor intrusion issues and leads the VI Assessment Team at EnviroForensics. His experience and insight make Mr. Carnahan uniquely qualified to advise his clients on potential environmental liability issues and cost implications.

IDEM Approves the Use of the U.S. EPA VI Attenuation Factors

Posted on by Jeff Carnahan

Today, the Indiana Department of Environmental Management (IDEM) has announced the approval of the use of the updated EPA VI attenuation factors presented in the recently released U.S. EPA Final VI Guidance. In general, the U.S. EPA attenuation factors are based on more recent scientific studies and are less conservative.  This allows a greater concentration of contaminant vapor to exist in the subsurface without fear of a completed vapor intrusion exposure pathway.  This change is effective immediately, and will have a significant impact on the VI investigative and mitigation process in Indiana.

As you are aware, the United States (U.S.) Environmental Protection Agency (EPA) released their Final Vapor Intrusion (VI) Guidance Documents, “OSWER Technical Guide for Assessing and Mitigating the Vapor Intrusion Pathway from Subsurface Vapor Sources to Indoor Air” and “Technical Guide for Addressing Petroleum Vapor Intrusion at Leaking Underground Storage Tank Sites” in June of this year. This was thirteen years in the making and includes extensive updates from the 2002 Draft Guidance document. One of the most notable guidance updates includes the recommended vapor attenuation factors for risk-based screening of the vapor intrusion pathway. Given the size of the EPA Guidance Documents, it will most likely take some state regulatory agencies a good deal of time to digest and implement changes to state-specific VI guidance documents. A few select states, like Indiana and Wisconsin, are ahead of the curve in adopting portions of the guidance by issuing short memos and/or addendums to their VI Guidance Documents.

About the Author:    

meganhamiltonmain-137x137Megan Hamilton
Director of Vapor Intrusion and Risk Assessment

866-888-7911
mhamilton@enviroforensics.com

 

Ms. Hamilton has over fifteen years of experience in environmental regulatory oversight and consulting, with a focus on risk assessment and vapor intrusion expertise. Her diversified professional experience includes research, policy development, technical writing, public outreach, vapor intrusion investigation and remediation, data analysis and interpretation, human health risk assessment, and conceptual site model analysis. Ms. Hamilton served as a technical, scientific, and risk assessment policy resource for the Indiana Department of Environmental Management’s (IDEM) Office of Land Quality for nine years. She also served as the coordinator and team leader for the IDEM Vapor Intrusion Workgroup for six years and is the main author of the current Indiana Vapor Intrusion Guidance. She has helped design and implement numerous vapor intrusion investigations for chlorinated and petroleum contaminated sites throughout Indiana.  Ms. Hamilton is experienced in evaluating human health risk assessments, as well as vapor intrusion risk assessments for sites regulated by all of IDEM’s remediation programs, including:

  • Brownfields Program
  • Leaking Underground Storage Tank Program
  • RCRA Program
  • State Cleanup Program
  • Voluntary Remediation Program

Ms. Hamilton develops, helps implement, and oversees the VI investigations and mitigation for all of EnviroForensic’s projects. She is also the main contact for risk communication issues and community outreach development. Ms. Hamilton has presented at several National Conferences, is a member of the National EPA VI Science Advisory Committee, and currently serves on the Board of Directors for the Midwestern States Environmental Consultants Association (MSECA).

 

New U.S. Clean Water Rule Put on Hold by the U.S. Court of Appeals for the 6th Circuit

Posted on by Jeff Carnahan

Friday, October 9, the U.S. Court of Appeals for the 6th Circuit issued an order to put a hold on a new federal water rule. The rule, finalized in May by the Environmental Protection Agency and the U.S. Army Corps of Engineers and published in June, expanded the EPA’s jurisdiction of the Waters of the United States to dry creek beds, prairie wetlands and other areas not previously subject to federal control under the Clean Water Act.

18 states have challenged the new standards. Opposition has come from property owners and businesses who did not previously have to abide by CWA standards, which regulate the release of pollutants into U.S. waters and quality standards for surface waters. They argue the rule is overreaching, and there is concern that it could apply to ditches and small isolated bodies of water.

The U.S. Court of Appeals for the 6th Circuit has granted a nationwide stay against the rule. The stay allows for more consideration of these issues and to determine whether this is a proper exercise of executive power. The 6th Circuit is still deciding whether it has the authority to handle these challenges or if they must first be reviewed at the district court level.

Wisconsin Governor Scott Walker Designates October Manufacturing Month in Wisconsin

Posted on by Jeff Carnahan

EnviroForensics believes that Wisconsin’s manufacturers are a pillar of the state’s success.  Wisconsin has a thriving manufacturing sector, employing nearly 450,000 workers and contributing $50 billion to the state’s economic input.

Wisconsin Governor Scott Walker has recently designated the month of October as Manufacturing Month. Manufacturing Month will showcase Wisconsin’s manufacturing sector and its importance to the state’s economy. It will also present manufacturing as a successful career path. This coincides with Manufacturing Day on October 4th, a nationally-recognized day sponsored by the national Manufacturing Extension Partnership, the National Association of Manufacturers and the Fabricators and Manufacturers Association.

Manufacturing Month will be comprised of scheduled events that discuss best practices in workforce training, programs that are available to employers and workers, and ways to advance dialogue to address current workforce challenges.

Manufacturing Month will celebrate how vital manufacturing is to the economy. As we recognize the value of manufacturing, it’s also important to discuss the maintenance of manufacturing sites, which can be subject to environmental contamination. Many historical manufacturing operations, such as parts degreasing and metal finishing, used chlorinated solvents and heavy metals, which may have been spilled and migrated into the soil and groundwater, and ultimately to indoor air in the form of vapor intrusion (VI).

EnviroForensics is committed to helping businesses address environmental contamination. In addition to fixing environmental problems, we also specialize in finding the funding necessary to clean up contamination. We have pioneered the process of locating and leveraging old insurance policies to pay for site investigation and cleanups, as well as legal fees. Our team of expert engineers and geologists have extensive expertise in the remediation of soil and groundwater contamination as well as Vapor Intrusion (VI) issues.

EnviroForensics is celebrating Manufacturing Month from our office located in Waukesha, Wisconsin. We are here to help with any environmental contamination issues facing businesses in the manufacturing sector. For more information, call 866-888-7911 or fill out this manufacturers assessment form.

Risk-Based Site Closures Should Include Remediating the Source Area

Posted on by Jeff Carnahan

In the past number of years, regulatory agencies have come to consider risk-based site closures an acceptable cleanup strategy. The old-school approach relied upon a standard set of exposure assumptions expressed through default cleanup criteria that were applied to every site. This meant that they had to be conservative enough to be protective of human health and the environment in every possible site setting. While this provided clear guidelines, it was not always practical or even possible for these standards to be met, and many times the default criteria were overly conservative. Because of this, more and more state regulatory agencies have come to accept risk-based closures.

A major difference between risk-based closure and the traditional approach is that risk-based closure is based on site-specific exposure conditions. The primary objective of risk-based closures is preventing human or ecological exposure at unacceptable health levels, and because of this, it is possible that soil and groundwater cleanup may not even be necessary if the levels of contamination do not pose a risk to human health or the environment. However, if contamination is left in place a series of institutional and engineered controls are necessary to ensure that site conditions at the time of closure remain constant.

Following the issuance of documents officially recognizing risk-based cleanup approaches, the environmental consulting and legal community jumped on the opportunity to apply these methods as a cost saving measure. For example, consultants will argue that if contaminated groundwater is not being used for drinking water, there should be no drinking water exposure pathway; or because no one would be coming into physical contact with the contaminated water, there should be no dermal contact exposure pathway.

While this may seem to make sense, it is not an argument that is easy for regulatory agents to support. If all contaminated sites were handled this way, little to no cleanup would occur and contaminant conditions would continue for decades. This leaves little confidence to regulatory agents that the site’s long-term risks will be managed. Additionally, as the regulation of institutional and engineered controls becomes more stringent, the cost of these long term stewardship efforts is beginning to rival the cost of actual cleanup activities.

In the long run, it is best to actively remediate source areas and create a long-term monitoring strategy. This is the approach used by EnviroForensics, and we have obtained more regulatory closures of sites contaminated with dry cleaning solvents in the last five years than any other company. President and CEO, Stephen Henshaw, further details this approach in his article “Risk-Based Site Closures Should Include Remediating the Source Area” (as seen in the March 2014 issue of Cleaner & Launderer).

Dealing with the Perception of Risk: The Value of Having an Effective Communications Plan

Posted on by Jeff Carnahan

One of the issues that arises when dealing with an environmental investigation on your property, in addition to the obvious concern regarding the potential contamination itself, is the way that contamination can affect your, or your company’s, public image. The reflexive reaction may be to hide the issue as much as possible, but doing so can have negative ramifications in the long run. The best strategy typically includes creating a communications plan that explains the situation and allows you to stay in front of the issue.

If your site does have contamination, you will likely be required to monitor neighboring sites, as well. In this case, a communications plan would come in extremely handy.  Handouts could be presented to the owners and tenants of these sites in order to inform and outline the sampling process and provide any health risk details, request site access to off-site buildings, and establish timelines for action if contamination exists. If VI sampling or monitoring will need to occur at homes and buildings located over a larger area, such as an entire neighborhood, a more formal communications plan is advised that would likely also include a group information meeting.

In his article “Dealing with the Perception of Risk: The Value of Having an Effective Communications Plan” (as seen in the October 2013 issue of Cleaner & Launderer), Stephen Henshaw, President and CEO of EnviroForensics, explains the importance of an effective communications plan for businesses dealing with environmental investigations. He lists several elements that such a plan should have, including:

  • Establishing the protocol of informing off-site property owners and occupants of the sampling results,
  • Approaching off-site property owners and occupants to inform them of the process being undertaken and request access to their property or building to conduct additional sampling,
  • Sharing the results with the parties,
  • Explaining any existing exposure concerns,
  • Proposing any necessary exposure mitigation or elimination measures that would be undertaken to protect the affected people.

Ultimately, a strong communications plan in these circumstances will allow you and your company to explain the situation to those who will be affected and will provide opportunities for discussions between the parties at risk and a technical expert and/or regulator. It is best to be forthright with and transparent to the community, avoiding any perception by individuals or the media as being calculating or deceptive. This may not always be the most comfortable or easiest approach, but it will pay off in the end.

EnviroForensics’ Use of HAPSITE Technology Allows for More Accurate Vapor Intrusion Inspection

Posted on by Jeff Carnahan

Correctly assessing the Vapor Intrusion (VI) exposure pathway is a complex process, which is rarely straight forward. When VI does occur at or near hazardous material cleanup sites, it rarely results in a constant stream of contaminants into the breathing zone.  Rather, there are many variables that affect the way vapors move from the subsurface into a structure.  Daily and seasonal temperature fluctuations result in variable pressures within and beneath buildings that change VI conditions. The amount of precipitation that falls also affects vapor intrusion rates, and can at times temporarily stop it altogether.  Building foundation and construction details can affect the pathway that intruding vapors may take once beneath or inside a structure, thereby resulting in a distribution of indoor air contaminants that aren’t intuitively consistent with predictive VI rules of thumb. Complicating things even more is the fact that numerous household products contain the same chemicals that we are trying to assess from below ground contamination.  Taking into account all of these variables to determine if a human inhalation exposure is in existence, or may be in existence at some time during the year, is a highly detailed and specialized process.

Fortunately, the VI team at EnviroForensics maintains a line of highly specialized, field-based, analytical instrumentation that can be used to tease out the necessary details during VI assessments. One of the most highly developed instruments in our arsenal is a portable Gas Chromatograph/Mass Spectrometer, named HAPSITE. The HAPSITE was originally designed by its manufacturer for the U.S. Military and is designed to deliver real time qualitative and quantitative, laboratory-quality results for air samples in the field. The HAPSITE has the capability of identifying and measuring specific volatile organic compounds as low as the parts per trillion (ppt) range. The HAPSITE instrument can be calibrated to measure the ions specific to the contaminants of concern (COCs) at the Site.

The Enviroforensics VI team consists of a certified HAPSITE operator. When operated in ‘survey’ mode, the HAPSITE instrument provides real-time data, depicted as an on-going line graph on the front panel display of the instrument.  We use this survey mode during VI assessments to find specific points in a structure where vapors may be entering the indoor air. We have found that cracks in floors and walls, floor drains, pipe chases, interior wall spaces and attics are all important features to explore. Background sources, such as those common household products mentioned earlier, can also be found hiding in closets, drawers, basement corners, etc. When an area of concern is located, the HAPSITE is switched to ‘run’ mode. This sampling mode collects an air sample that is analyzed by the instrument with laboratory quality, in a short period of time.  This type of real-time analysis allows for adjustments to be made in the field and provides comprehensive conclusions with fewer mobilizations and sampling events.

During any VI assessment, the main line of regulatory thought is that if VI is occurring at any time during the day or year, that worst case exposure condition is used to calculate the occupant’s potential risk. By using highly-specialized instrumentation, such as the HAPSITE, the EnviroForensics VI team greatly improves the odds that we can interpret all of the variables that are part of VI assessments and properly report true exposure conditions.

About the Authors:

meganhamiltonmain-137x137Megan Hamilton
Risk Assessor and Vapor Intrusion Specialist

866-888-7911
mhamilton@enviroforensics.com

Ms. Hamilton has over fifteen years of experience in environmental regulatory oversight and consulting, with a focus on risk assessment and vapor intrusion expertise. Her diversified professional experience includes research, policy development, technical writing, public outreach, vapor intrusion investigation and remediation, data analysis and interpretation, human health risk assessment, and conceptual site model analysis. Ms. Hamilton served as a technical, scientific, and risk assessment policy resource for the Indiana Department of Environmental Management’s (IDEM) Office of Land Quality for nine years. She also served as the coordinator and team leader for the IDEM Vapor Intrusion Workgroup for six years and is the main author of the current Indiana Vapor Intrusion Guidance. She has helped design and implement numerous vapor intrusion investigations for chlorinated and petroleum contaminated sites throughout Indiana.  Ms. Hamilton is experienced in evaluating human health risk assessments, as well as vapor intrusion risk assessments for sites regulated by all of IDEM’s remediation programs, including:

  • Brownfields Program
  • Leaking Underground Storage Tank Program
  • RCRA Program
  • State Cleanup Program
  • Voluntary Remediation Program

Ms. Hamilton develops, helps implement, and oversees the VI investigations and mitigation for all of EnviroForensic’s projects. She is also the main contact for risk communication issues and community outreach development. Ms. Hamilton has presented at several National Conferences, is a member of the National EPA VI Science Advisory Committee, and currently serves on the Board of Directors for the Midwestern States Environmental Consultants Association (MSECA).

mainjeffJeff Carnahan, L.P.G.
Vice President, Chief Technical Officer

866-888-7911
jcarnahan@enviroforensics.com

Jeff Carnahan is a Licensed Professional Geologist (LPG) with over 17 years of environmental consulting and remediation experience.  Mr. Carnahan’s expertise has focused on the investigation and interpretation of subsurface releases of hazardous substances for the purpose of evaluating and controlling the risk and cost implications to his clients.  While managing sites ranging in size from retail gas stations and dry cleaners to large manufacturing facilities, Mr. Carnahan has amassed extensive experience working with releases of chlorinated solvents within voluntary and enforcement cleanup programs for various State agencies and the U.S. EPA. Throughout his career Mr. Carnahan has provided technical support to the legal community regarding the cause, origin, transport and potential cost of environmental releases. Additionally, Mr. Carnahan has over 13 years of experience in the investigation and mitigation of vapor intrusion issues and leads the VI Assessment Team at EnviroForensics. His experience and insight make Mr. Carnahan uniquely qualified to advise his clients on potential environmental liability issues and cost implications.