Category: Drycleaners

REGARDLESS OF HOW CONTAMINATION CAME TO BE OR CAME TO BE DISCOVERED AT YOUR DRY CLEANING SITE, THE END GAME IS TO CLEAN UP THE PROPERTY WITH THE RIGHT TOOLS AND MOVE ON WITH YOUR LIFE. HERE WE DISCUSS THE REMEDIATION OPTIONS AVAILABLE FOR DRY CLEANERS.

BY: JEFF CARNAHAN

Some questions you may consider when faced with environmental cleanup include “What does the cleanup process look like?”, “How long does it take?”, “How much does it cost?”, “What kind of inconvenience will you or your tenant have to endure during the process?”. There are many options available for use during site remediation at dry cleaning sites, but several factors need to be considered to determine which of them is best, including:

1. Types of contaminants, like perc, that need to be addressed
2. Extent of the contamination like soil impacts and/or soil, groundwater and vapor
3. Property-specific geologic conditions like clay or sand
4. Naturally occurring geochemical conditions
5. Timing limitations
6. Cost limitations
7. Property usage limitations like building occupancy

Once a clear picture has been developed regarding your specific needs, then your environmental consultant can put together a remediation plan with the various tools from their tool belt to get the job done. Each technical component of the cleanup approach will have limitations, based upon your site needs, so putting together the right tools requires some creativity and a substantial amount of attention to your business needs. If this all goes smoothly, you can get your regulatory closure and peace of mind knowing that this challenge is now in the past.

 THE CLEANUP STRATEGY AND GOAL

For environmental consultants to understand the right way to get contaminants out of the subsurface, they first need to learn how they got into the ground in the first place. Most of the time, one can consider a conceptual model consisting of a soil source area created by a spill. This can include leached contaminants to the groundwater, and then the impacts in groundwater have migrated to an extent and created a groundwater plume. Vapors can emanate from any portion of the impacted areas too.

Once the contaminants have moved through the subsurface to create these distinct reservoirs of impacts, environmental consultants can’t exactly reverse the process. Rather, they must address each reservoir independently, and a different cleanup technology might be necessary for each. It’s not uncommon for the soil source area and the groundwater source area to be actively remediated, while the downgradient plume is left to reduce naturally over time. Sometimes, all groundwater levels will reduce to acceptable levels just by removing a large percentage of the contaminants in the soil source area.

WHICH TOOLS (TECHNOLOGY) SHOULD BE USED?

The best way to decide which remedial technology is best used to address some or all the contaminants at your property is to look at their characteristics, capabilities, and limitations. Let’s look at some of those together, in order of the subsurface location of the contaminants.

USING EXCAVATION AND DISPOSAL FOR SOIL SOURCE AREA REMEDIATION

Excavation and Disposal is a common approach to remove contamination from soils above the water table in areas that have access to the ground surface. This doesn’t mean that excavation is only good for areas beneath the parking lot, or out back. Quite often, EnviroForensicsperforms surgical source area excavation activities inside buildings with active dry cleaning operations. It can be tricky, and planning is needed, both for the environmental work and to make sure that your operations aren’t interrupted, but it can be done. That being said, it is certainly easier to perform a significant excavation outside of buildings, and if the extent of impacts is limited and well-defined, it is often the fastest and easiest way to definitively remove a large amount of impacted materials from your property. Even for a sizeable excavation, we are talking about days or weeks, rather than months or years to achieve the objectives of the soil source area cleanup objectives.

USING SOIL VAPOR EXTRACTION FOR SOIL SOURCE AREA REMEDIATION

Another soil source area cleanup technology that is popular at dry cleaning properties is Soil Vapor Extraction (SVE). This technology takes advantage of the volatile properties of dry cleaning solvents and, as the name suggests. A SVE system includes a series of screened pipes that are installed in the soil, which are all piped together and connected to a high-volume, specially designed and manufactured industrial fan, or blower. When activated, air is drawn through the treatment area and extracted through the screened pipes.

The contamination in the soil transfers from within the soil itself to the circulating subsurface air, which then travels through the system to a discharge stack. Once passed into the air and exposed to sunlight, the volatile compounds are destroyed. The result is clean soil. SVE systems can be installed both inside and outside of existing buildings, and new buildings can even be constructed over the top of these systems, so access is not usually that big of a problem.

The potential usefulness of SVE depends mostly on the characteristics of the soil. Tighter materials like clay are not as conducive to SVE as sandier soils. Even in nice, sandy soils, the process can take a year or two following the installation and startup of the system. The blowers can be a little noisy, but in most situations, that can be taken care of pretty easily. SVE is a nice option because it also takes care of vapor intrusion problems at the same time it is cleaning up due to the negative pressure created in the subsurface during its operation.

USING THERMAL TREATMENTS FOR SOIL SOURCE AREA REMEDIATION

Another option for addressing contamination in the soil source area is the use of a Thermal Treatment technology. There are several alternatives available, but they all include the primary approach of heating up the subsurface to a temperature high enough to increase the volatility of the contaminant, and then capture the resulting vapors using an SVE system as described above. Thermal treatment has several advantages, such as being relatively quick and very reliable. It makes even more sense when used to treat the groundwater beneath the soil source area at the same time. The main drawback is the price because it’s usually a more costly options since so much electricity is used to create the high subsurface temperatures. Thermal is a great option if you absolutely must have a very clean site, have less than a year to do it, and you can avoid active usage of the area during the duration of the treatment. It’s possible to conduct thermal beneath buildings, but it is not usually feasible. EnviroForensics has used thermal at a dry cleaner site and the cleanup results were awesome. I wish we could use it more often.

USING IN-SITU FOR GROUNDWATER SOURCE AREA REMEDIATION

Directly beneath the soil source area, the area of highest groundwater impacts is usually found, which is referred to as the groundwater source area. When the remediation strategy involves the removal or destruction of contamination from the groundwater source area, there are many options to choose from.

In fact, the treatment of groundwater contamination is one of the most active areas of research and development in the environmental industry. Twenty years ago, it was common to install systems to pump out the contaminated groundwater, treat it at the surface, and then discharge it to a sewer. That practice didn’t really work very well, however nowadays most groundwater treatment actually takes place in the ground. When a treatment is applied in place, it is called an in-situ treatment.

In-situ Chemical Oxidation (ISCO) and In-situ Chemical Reduction (ISCR) are processes wherein chemicals are injected directly into the groundwater treatment area through drill-rods or temporary wells, where the chemical reacts with, and destroys the contaminant. It is a fairly quick process, which is good, but that also means that the effective life of the chemical injected is short.

One of the main limitations of any in-situ injection approach is that the desired chemical reaction is only able to happen precisely in the area where it is injected. You must have enough injection points to actually disperse the chemical where it needs to be. Subsurface intricacies in the geologic conditions tend to hijack your injection strategy, thereby leaving areas inadvertently untreated. This can result in disappointing initial results that lead to additional injection events, which is why second and even third injection events are often planned for the cleanup strategy. There are great products available for in-situ application in groundwater, and we have had a great deal of success using them, but you just have to manage expectations and hedge your bets.

USING IN-SITU FOR GROUNDWATER PLUME AREA REMEDIATION

The area of contamination downgradient of the source areas typically carry the lowest relative concentrations, but they may still be quite high. The Downgradient Groundwater Plume is the most likely to cross property boundaries into locations that aren’t under your control, leading to the need for an active clean up even though the contaminant levels may be low. Also, it may be necessary to lessen the risk that an impacted adjacent property owner decides to sue you. The in-situ injections I mentioned previously are a great way to treat this section of impacts since the extent of the plume may be quite large and the volume of chemicals necessary to destroy the lower levels of contaminants may not be large.

Sometimes, the contaminant concentrations in the downgradient plume are low enough that the plume starts to shrink once active remediation is conducted in the source areas. This is actually what we hope for most of the time. In this scenario, the concentrations in the downgradient plume just needs to be monitored on a periodic basis to ensure that they continue to decline. When this strategy is undertaken, it is called Monitored Attenuation. Obviously, this is a pretty cost effective and non-invasive approach, but the timeframe can get pretty long. If monitored attenuation is attempted without aggressive cleanup in the source areas, it can go on for decades and end up costing more than active remediation.

WHEN IT COMES TO DESIGNING AN APPROPRIATE REMEDIATION FOR YOUR DRY CLEANING PROPERTY, CONSULTANTS HAVE A LARGE TOOL BELT. THERE DOES NEED TO BE A VERY FRANK, FACE-TO-FACE DISCUSSION ABOUT THE PRACTICAL AND REASONABLE IMPLICATIONS OF REMEDIAL IMPLEMENTATION, HOWEVER. DON’T BE AFRAID TO ASK YOUR CONSULTANT ABOUT THE STRATEGY TO MAKE SURE THAT YOU ARE GETTING THE CLEANUP YOU WANT.

Contact EnviroForensics, the dry cleaning industry’s most trusted environmental consultant.

As seen in Cleaner & Launderer

---

Jeff Carnahan, President at EnviroForensics
Jeff Carnahan, LPG, has 20+ years of environmental consulting and remediation experience. His technical expertise focuses on the investigation and interpretation of subsurface releases of hazardous substances for the purpose of evaluating and controlling the risk and cost implications. He has focused on being a partner with the dry cleaning industry for the past decade, and he’s a frequent contributor to the national dry cleaning publication Cleaner & Launderer. He is an industry leader in understanding that environmental risk includes not only cleanup costs, but also known and unknown third-party liability.

LEARN HOW TO NAVIGATE THE ENVIRONMENTAL INVESTIGATION PROCESS

BY: STEPHEN HENSHAW, PG

For years dry cleaners have suspected that they might have an environmental problem, but have been afraid to find out whether they do or not. It’s completely understandable why dry cleaners would be afraid of collecting soil and groundwater samples at their site. Of course, the biggest reason for not looking into the environmental conditions at your site or sites is opening Pandora’s Box. Simply stated, the cost of an environmental cleanup could cause financial hardships and sleepless nights.

SO, WHAT TRIGGERS AN ENVIRONMENTAL INVESTIGATION? 

Sometimes you can control the situation, but most of the time you can’t. Below are five events that can trigger an environmental investigation at a dry cleaning site.

1. YOU’RE SELLING YOUR BUSINESS OR PROPERTYIf you want to sell your business or property, due diligence is required during business and property transactions to determine if the operating business and/or property carries any potential environmental liability including hazardous waste contamination, lack of permits, permit violations, and compliance deficiencies. Understanding these conditions allows the buyer to evaluate potential limitations, liabilities, and risks associated with the property. Often times, due diligence at a dry cleaner is going to uncover environmental problems. Due Diligence will start with a Phase I Environmental Site Assessment (ESA) to identify if there’s any likelihood of contamination. For most dry cleaners, a Phase II ESA will be required, which includes collecting samples of soil, groundwater or building materials to analyze for various contaminants
2. YOU’RE REFINANCING YOUR PROPERTYIf you’re refinancing your property, your bank is going to require a Phase I ESA, which is the formal process that assesses the real estate for potential risk of environmental contamination. Again, for most dry cleaners, a Phase II ESA will be required.
3. YOU’RE RETIRING WITH PLANS TO HAND OFF YOUR BUSINESS TO YOUR CHILDREN OR GRANDCHILDRENIf you want to retire and hand off your business to your children or grandchildren, there’s a high probability that contamination may be lurking beneath your building due to decades of dry cleaning operations. Since you’re passing the business onto family, you’ll want to conduct environmental due diligence to make sure they are protected from liability.
4. YOUR NEIGHBOR IS SELLING OR REFINANCING THEIR PROPERTY, WHICH REQUIRES AN ENVIRONMENTAL INVESTIGATIONIf your neighbor is selling or refinancing their property, they’ll conduct real estate due diligence. Their environmental investigation may uncover a commingled plume that may lead to you. This will lead to conducting your own environmental due diligence process.
5. YOU PURCHASED A PROPERTY AT TAX SALEIf you want to buy a property, which used to house a dry cleaner or any other commercial operation, you’re going to have to conduct real estate due diligence if you want to avoid taking on the environmental liability yourself.

WHAT IS A PHASE I ENVIRONMENTAL ASSESSMENT?

The first step in the due diligence process is performing a Phase I Environmental Site Assessment (ESA), which is an evaluation of recent and historical activities at and near the property to identify potential or existing environmental contamination liabilities. A Phase I ESA may be required by a bank or other lending institution during financing processes, or it could be recommended by your attorney or other business advisors.

THE PHASE I ENVIRONMENTAL SITE ASSESSMENT PROCESS

The consultant conducting the Phase I ESA will inspect the site for signs of staining, evidence of spills, stressed vegetation, determination of underground and above ground tanks, secondary containment, violations, and operating practices. They will evaluate records at the fire department, local health department, state environmental agencies, and federal EPA, to determine whether fires or chemical spills were reported on the property or on neighboring properties.

This review would also evaluate what businesses are operating in the near vicinity that could cause environmental impacts and could impact the subject site. A Phase I doesn’t include actual subsurface samples such as soil, soil gas, or groundwater. However, there is a standard that must be followed under the American Standard for Testing and Materials or ASTM, which now includes determining whether indoor vapor intrusion is likely.

WHAT HAPPENS AFTER THE PHASE I ESA? A PHASE II. 

If the Phase I ESA identifies a reasonable potential that soil and groundwater may be impacted, the consultant will suggest that a Phase II ESA be conducted.

The thing about conducting a Phase I ESA on real estate that has a dry cleaner is that, because of the history of dry cleaning operations, a Phase II investigation is nearly always required. In other words, one can be certain that if the real estate has an active or historical dry cleaner on the site and it is being considered for refinancing or purchasing, follow-up soil, soil gas or groundwater samples will be required.

A Phase II is a step further in the process of determining whether a dry cleaner has affected a piece of property. The Phase II is also referred to as a “subsurface investigation” and includes the actual collection of a series of subsurface (soil, groundwater) samples to determine whether the property has been impacted by chemicals that pose a risk to human health or the environment. This is where the costs start to add up when chemicals are identified.

Other items out of your control that can trigger environmental investigations include:

• Contamination showing up in municipal or private drinking water wells;
• Contamination showing up beneath neighboring or downgradient properties; and
• Regional investigations conducted under the direction of state or federal regulatory agencies.

These triggers can mean perchloroethylene (PERC) has been identified in the groundwater and because PERC is a common dry cleaning solvent focus is put on dry cleaners both past and present. We have seen situations where the perc levels in municipal drinking water wells and immediately set out to identify all dry cleaners that operated within a mile radius of the well over the past 50 years. With a little digging, it is fairly easy to identify the address, name and period of time that a dry cleaner has operated at a location. We have seen the states pursue a retired couple that operated a dry cleaner for just two years from 1958 through 1959.

WHY WOULD YOU WANT TO OPEN “PANDORA’S BOX”?

While no one wants to be the bearer of bad news, it’s important that all dry cleaners understand how investigations are triggered and what to expect once they are triggered. For this reason, we always talk about finding the businesses or property owner’s old comprehensive general liability (CGL) insurance policies first before the environmental investigation begins.

Old CGL policies may be the most valuable piece of paper you could ever have. Historical CGL policies written before 1985 or 1986 do not have absolute pollution exclusion language in them and therefore may be used to defend the insured against claims. A claim is what an “injured” party can bring against a business or individual that owned or operated a business that is found to have any amount of responsibility for the contamination found in the subsurface, typically the groundwater.

When confronting issues like this it’s important to have knowledge of the situation, process, and your options.

WHAT ARE OTHER POINTERS DRY CLEANERS NEED TO KNOW ABOUT?

Our goal is to educate you about the environmental arena. Here are seven things you should know and do to be proactive and avoid surprises:

1. Understand how investigations are triggered.
2. Understand that your old insurance policies or those that you bought your businesses from may be worth millions of dollars.
3. Be aware of your surroundings and what drilling activities are happening in your neighborhoods.
4. Know your rights by reviewing your lease agreements.
5. Find your old insurance policies and store them securely.
6. Store information regarding the individuals that operated at your location before you did.
7. Seek a qualified environmental consultant for assistance.
8. Talk to an insurance archeologist.

And to remember the story of Pandora’s Box… Zeus had given Pandora a box and told her not to open it, but she did anyway. And even though all evils subsequently unknown to man escaped from the jar, at the very bottom of the jar there lay hope.

No matter your situation, we’re ready to find the best solution for you. Contact us today.

---

As seen in Cleaner and Launderer

Stephen Henshaw, CEO at EnviroForensics & PolicyFind has over 30+ years of experience and holds professional registrations in numerous states. Henshaw serves as a client manager and technical manager on complex projects involving contaminated and derelict properties, creative litigation, deceased landowners, tax liens, non-performing banknotes, resurrecting defunct companies and cost recovery. Henshaw’s expertise includes a comprehensive understanding of past and current industry and waste handling practices and the fate and transport of chlorinated solvents in soil and groundwater. He has served as a testifying expert for plaintiffs and defendants on high profile cases involving causation and timing of releases, contaminant dispersion, allocation, damages, past costs, and closure estimates. He has a strong knowledge of state and federal regulations, insurance law, RCRA, and CERCLA. He has managed several hundred projects including landfills, solvent and petroleum refineries, foundries, metal plating shops, food processors, dry cleaners, wood treating facilities, chemical distribution facilities, aerospace manufacturing facilities, and transporters and provides strategy instrumental in funding projects and moving them to closure.

TAKE COMMAND OF YOUR ENVIRONMENTAL CONTAMINATION AND SAVE YOURSELF A LOT OF STRESS AND MONEY 

BY: DRU CARLISLE

There is a stigma that goes along with environmental contamination. Unfortunately, this stigma makes business owners fearful of addressing their environmental contamination. This often results in either avoiding the problem or pretending the problem doesn’t exist, but environmental contamination won’t go away on its own. Therefore, it’s important to address environmental contamination head-on.

For over ten years, I’ve spoken with hundreds of dry cleaners across the country about their environmental issues and I’ve heard every concern surrounding the topic of investigation environmental contamination and cleaning up environmental contamination. Those concerns don’t vary much across the board. If I have heard the phrase “I don’t want to open that can of worms” once, I’ve heard it a thousand times, and due to the high costs of environmental cleanups and the involvement of state regulatory agencies, it’s understandable why some might want to stick their head in the sand.

I’ve built relationships with drycleaners nationwide – some who have become clients and others who are still not ready to actively investigate the possibility of environmental contamination. I feel that it is my duty to explain why environmental agencies, consultants and engineers are not looking to put business owners or property owners in a pickle or a bind; in fact, looking into and addressing environmental issues, especially proactively, are not bad things. In fact, it’s time to consider looking at it in a new light.

Learn how to turn an environmental cleanup into good public relations for your business.

We’ve helped hundreds of dry cleaners, manufacturers, and chrome platers and metal finishers navigate their environmental concerns with little to no out-of-pocket costs to them. Our goal is to help our clients get out of a challenging situation without a large financial burden. We understand how challenging this process can be for business and property owners and have successfully helped our clients navigate through these often uncharted waters. Want to hear what our clients think? Hear from our dry cleaning clients and get an inside perspective on their environmental challenges.

PCE AND TCE ENVIRONMENTAL CONTAMINATION

We’ve had a lot of success cleaning up properties impacted with PCE and TCE, and our clients have had their own successes as well, in that they are having their environmental liabilities turned back into assets.

That is to say that their once contaminated property, which had little to no resale value, is now worth what it would be clean and unencumbered. You see, we are looking out for our clients and are the experts many have come to trust as the experts who wear the white hats. How do we do this?

• We are the experts who help get funding in place through the use of old insurance policies so that our clients don’t face financial ruin; the experts who clean up environmental contamination to the highest standard possible and return blighted properties and businesses to their fair market value; and
• the experts who handle every point of our clients’ environmental cleanups from start to finish on our clients’ behalves so that they are free to run their businesses, enjoy retirement, live their lives without worrying about what is around the next corner of their project.

My intention is not to downplay the process because there is no denying the fact that environmental cleanup is a huge deal. They are very expensive, they take a long time to complete, and they require a high level of trust between the business owner and the environmental consultant that the project will be taken care of as efficiently, professionally, and economically as possible.

Get our five tips for hiring an environmental consultant and download our interview questionnaire.

I do understand, and fully respect, the concerns of prospective clients who are frightened of taking the leap into the unknown. A proactive approach is by far the most beneficial approach for the Potentially Responsible Party and/or the business owner because they can be in control of the situation rather than being reactive to a situation like a lawsuit from their neighbor.

UNPACKING THE ENVIRONMENTAL INVESTIGATION AND CLEANUP PROCESS

If you’ve read the Cleaner & Launderer column “The Environmental Corner”, you’ve read articles on a number of topics ranging from how historical insurance policies can be used to pay for cleanups to technical issues on how contamination can create vapors that can impact neighboring properties through vapor intrusion. The latter of the two topics is the key to all successful environmental cleanups and conversely, is also what usually confuses people the most.

Vapor intrusion concerns are often associated with environmental investigation and remediation projects Brownfields sites, dry cleaners, gas stations, commercial buildings, multi-unit residential, schools and large buildings. These concerns can impact public health and property values so they aren’t to be taken lightly or slowly. The earlier the vapor intrusion concern is discovered, investigated and remedied the better it’ll be for everyone involved.

To learn more about the environmental investigation and environmental cleanup process, read our 101 series: Environmental Investigations 101: Understanding PCE Contamination and Environmental Cleanup 101: Understanding what to expect during the remediation process.

FINDING THE FUNDS TO PAY FOR ENVIRONMENTAL INVESTIGATION AND CLEANUP

Another area where business and property owners find challenges is finding the funds to pay for the environmental investigation and cleanup. Some opt to pay out-of-pocket because they don’t know there are other funding options available.

Old Commercial General Liability insurance policies, and by “old,” I mean policies that pre-date an Absolute Pollution Exclusion, which in most states is before ~1986, can pay for your environmental investigation and cleanup.

You’re probably asking yourself, “Wait, I can use my old insurance policies to pay for my environmental cleanup?”. Right now is when we can add “too good to be true” as another one of those phrases I hear so regularly, but dependent upon a few criteria it is true, and it’s why we encourage people to locate their old policies and store them in a fireproof storage box. There is a service for locating lost insurance policies, called Insurance Archeology if you are in need of assistance in finding yours.

I do stress that a proactive approach to all things environmental is truly the most beneficial way to go, for any business or property owner with a possible environmental liability on their hands. Waiting for someone to discover your contamination and pin it on you is a recipe for disaster, and anyone who has been in that position, which is becoming a more and more common occurrence, will tell you that it is not a pleasant one to be in.

Understand the difference between proactive or reactive when dealing with environmental contamination.

If you are ill-prepared when an environmental issue is placed in your lap, it could mean thousands of dollars, in some instances, tens of thousands, of out-of-pocket costs. A proactive approach means that you are in command of the situation and by being in front of the issue, you will save yourself a lot of stress and money. Don’t leave environmental contamination for your family and loved ones, or even strangers, to deal with.

Consult with us, it’s free and it’s confidential.

---

Dru Carlisle, Director of Drycleaner Accounts
For over 10 years, Dru has helped numerous business and property owners facing regulatory action, navigate and manage their environmental liability. Dru has vast experience in assisting dry cleaners in securing funding for their environmental cleanups through historical insurance policies. Dru is a member of numerous drycleaning associations in addition to serving on the Midwest Drycleaning and Laundry Institute (MWDLI) advisory council and on the Drycleaning & Laundry Institute Board (DLI) as an Allied Trade District Committee Member.

THE ENVIRONMENTAL CLEANUP PROCESS CAN BE CHALLENGING FOR DRY CLEANERS BECAUSE IT’S TYPICALLY A ONCE IN A LIFETIME EXPERIENCE–SIMILAR TO BEING CURED OF A MEDICAL DIAGNOSIS.

BY: JEFF CARNAHAN

For those who don’t frequently deal with environmental cleanup (also known as remediation), the reasoning, objectives, and process can be a bit of a black box. It’s not dissimilar to how most of us feel about a medical procedure. Here are three things people usually feel before embarking on a medical procedure:

1. We must rely on the expertise and knowledge of others to even know there is a specific problem;
2. We trust that the healing procedure being proposed will fix the problem
3. We don’t really know what the procedure will be like, but we know that it might hurt.

The medical analogy is a particularly good analogy for the environmental investigation and cleanup process. Previously, I’ve discussed Environmental Investigations 101: Understanding PCE Contamination and how the collection of subsurface samples and the application of scientific principles result in a picture of what the contamination is, where it is, and how bad the problem is. In the medical analogy, this would be the phase consisting of seeing the doctor with the evidence you have that there might be a problem, getting tests completed like an MRI or a biopsy, and receiving the diagnosis.

Upon hearing that a problem exists, the anxiety can start to take hold for the patient because questions arise, for which the answers are unknown. Some questions may include:

1. What can be done about it?
2. Is there a cure?
3. How long will this take to cure?
4. Does my doctor know what they are doing?
5. How much is this going to cost?!
6. Will my insurance cover it?

These questions represent the unknown, and the unknown can be terrifying. Any doctor will tell you that some people are so afraid of these questions that they’d rather not even know if they have a problem, and foolishly never seek a medical exam. Any doctor will tell you if you think you have a problem…find it and fix it. You’ll live a longer and happier life. With the medical analogy in mind, I’d like to focus this article back on the environmental remediation process to answer as many questions as possible for you, to eliminate the unknowns, and to alleviate the associated anxiety.

THE FEASIBILITY STUDY – WHAT’S THE CURE?
So, let’s say that from the environmental investigation your dry cleaner site has just been diagnosed with a nasty case of contamination by hazardous chemicals. Since the goal of your environmental practitioner is to ensure that the problem gets fixed, there first needs to be an assessment of all the potential cleanup technologies that could be used alongside the specific characteristics of your site. Questions that need to be answered include:

1. Are any people currently being exposed to the contamination?
2. What amount of contaminant may safely remain after cleanup and still be suitable for future planned land use (i.e. what are appropriate cleanup objectives)?
3. How will each potential remedial technology interact with the exact type of soils and geologic materials beneath your site?
4. How will the naturally occurring geochemistry of soils and groundwater interact with any potential treatment chemicals?
5. How long would each remediation technology take to reach the cleanup objectives if implemented?
6. What are the comparable unit costs per measure of contaminant removed from the ground for each anticipated technology?

Ultimately, the question to be answered is, What is the best and most cost-effective cleanup technology to meet our objectives? This process is called a Feasibility Study and it determines which cleanup approach is the most feasible.

Read about a former dry cleaning site that we cleaned up in 120 days with thermal technology.

During the feasibility study, as the business or property owner, you’ll need to make sure to speak up and let your consultant know if there are any limitations that they should be considering for the cleanup approach. For example, parking areas that absolutely must remain clear during business hours, areas of the building that cannot be disturbed no matter what, or even simple things like traffic flow patterns for your drive-through lane. We have done work for a lot of dry cleaners, so we always think to ask about these kinds of things, but not every remediation engineer does. All your business considerations could have a significant impact on which cleanup technology can be implemented. If your building is located directly over the area of soil contamination, a common remedial technology could be demolition and excavation. While this may make perfect sense to the remediation engineer, having your building torn down in order to dig a big hole may not exactly fit into your business operation plans. The bottom line here is to speak up early in the process and make sure your business needs are heard before the project begins.

INITIAL CLEANUP ACTION – THE SURGERY
Once the appropriate cleanup objectives and remediation technology have been decided, there are a few steps to go through before work can begin. Typically, but not always, the regulatory agency will want to look at your remediation plan and have a chance to comment on it, or even to approve it. Once the agency has given the head-nod, an important point to remember is that you want to have the money conversation before you send the plan to the regulatory agency. Just like you always want to check whether or not your insurance will cover your medical procedure before you get it done. I talk about the cost of cleanup and funding alternatives a lot, so I’m going to skip that conversation, for‌ ‌now, other than to say that the money talk is the very first talk that you should have way before the investigation process even begins.

When you have gotten the green light to get started on the remedial action, things will start to move quickly because it’s go-time. Typically, when remediation work begins, there will be a flurry of activity for two weeks to a month while the initial work is completed. Remedial strategies commonly consist of an aggressive contaminant reduction effort, followed by a long period of monitoring to see how it has worked. During the initial treatment, there may be drill rigs, dump trucks, trailers, and people all over your site, and things could even be a bit messy.

Your environmental consultant should have provided you with a detailed schedule of events and they should keep you informed during the process so that you know exactly what to expect. You’ll need that information to keep your customers informed. I have had many clients actually take this time to post signage explaining to their customers that the business is doing their part to clean up an old environmental problem, demonstrating their commitment to their community and customers.

Are you looking for an environmental consultant? Read 5 Considerations When Selecting an Environmental Consultant for Dry Cleaners.

POST-REMEDIAL MONITORING – THE FOLLOW-UP VISITS
After the initial cleanup effort is undertaken, things will slow down a lot. Monitoring of soil gas and groundwater conditions will need to be performed on a regular, routine quarterly basis for at least a year or so as the contaminant plume reacts to the aggressive, upfront cleanup effort. So, every three months your consultant will come back and collect the monitoring samples, and then they will be gone again. As mentioned previously, it is important to stay involved in the process so that you know how things are going. If you aren’t interested in the scientific details of the remediation monitoring results, at least understand the current conditions as concentrations of the contaminant should start lowering and getting closer to the cleanup objectives. When contaminant levels do reach the closure objectives, if all has gone according to plan, you get to start another monitoring period so that the regulatory agency has confidence that there won’t be a rebound or any remaining post-treatment contaminant in the future.

You can see how the environmental cleanup process gets a reputation for taking a long time because it does. Even after the bulk of actual cleanup activities are completed, there are likely at least two to three years of post-remedial monitoring that needs to happen. Fortunately, routine monitoring isn’t as disruptive as the initial cleanup action, but every few months you will get a reminder that you aren’t quite out of the woods yet, and that can be frustrating. Another thing to make sure you talk to your consultant about: There will be one or more drums of purge water generated during groundwater sampling that will probably need to be stored behind your building for a couple of weeks after each sampling event. Your consultant will label it and manage for its disposal, but there will need to be a short wait while analytical data comes back from the lab and removal can be arranged. If it’s in the way or takes too long to be picked-up, say something.

REGULATORY CLOSURE – CURED
When follow-up monitoring results show that contaminant concentrations have been reduced and have stayed that way, your consultant will submit all the results to the regulatory agency and ask for case closure. Sometimes this is called a No Further Action status. This is one last time to be patient because most regulatory agencies could take anywhere from two to six months to make this determination and set you free.

The site remediation process can be long, taxing and scary, but hopefully, these insights will give you a little bit of an insider’s perspectives on what to expect. Sometimes consultants and attorneys forget that even though they deal with this process every day, you don’t. Ask them to take the time to explain things to you in detail and help you understand what it will look like from your perspective and your customers’ perspectives. As commonly said, knowing is half the battle.

If you are going through the cleanup process and you have questions, or just want to bounce something off me, drop me an email at jcarnahan@enviroforensics.com. I’d be more than happy to have a conversation with you. I’m here to help.

Contact EnviroForensics, the dry cleaning industry’s most trusted environmental consultant.

As seen in Cleaner & Launderer

---

Jeff Carnahan, President at EnviroForensics
Jeff Carnahan, LPG, has 20+ years of environmental consulting and remediation experience. His technical expertise focuses on the investigation and interpretation of subsurface releases of hazardous substances for the purpose of evaluating and controlling the risk and cost implications. He has focused on being a partner with the dry cleaning industry for the past decade, and he’s a frequent contributor to the national dry cleaning publication Cleaner & Launderer. He is an industry leader in understanding that environmental risk includes not only cleanup costs, but also known and unknown third-party liability.