Category: Site Investigation and Remediation

THERE IS AN EVOLVING QUESTION AS TO WHETHER PFAS IS A DRY CLEANING PROBLEM. A RECENT FLORIDA STUDY STARTED TO ANSWER THIS QUESTION. THIS ARTICLE WILL FOCUS ON WHAT PFAS ARE AND SUMMARIZE SOME OF THE FLORIDA STUDY RESULTS AND WHAT IT MIGHT SAY ABOUT DRY CLEANERS AS A SOURCE OF PFAS.   

BY: BRAD LEWIS & ROB HOVERMAN 

If you have not heard of Perfluorooctanoic Acid (PFOA), Perfluorooctyl Sulfonate (PFOS) and other perfluoroalkyl substances (PFAS) yet, you will soon. For brevity, we will refer to these groups generically as PFAS plural. PFAS are a broad group of chemicals widely used in manufacturing and found widespread in the environment. The 2019 movie Dark Waters starring Mark Ruffalo and Anne Hathaway featured one of the first and highest-profile lawsuits regarding PFAS. PFAS are emerging contaminants that the United States Environmental Protection Agency (USEPA) is attempting to regulate. Some states like Michigan, Wisconsin, Florida, and New Jersey have gotten out in front of the USEPA and have established state regulatory limits for a small number of the more commonly used compounds.  

WHAT ARE PFAS?
First, the “what”: PFAS are part of a broad chemical group first developed in the 1940s. Since then, manufacturers have introduced over 4,000 PFAS compounds into the production of consumer goods both as primary and secondary components. Some of these compounds are being phased out due to toxicity concerns; however, manufacturers are developing new fluorinated compounds like Gen X and ADONA to replace them. Many PFAS are banned from use and import in manufactured goods in the United States. 

Well known for their unique chemical properties, PFAS repel oil and water and resist temperature, chemicals, and fire. These are the attributes that make PFAS attractive and are why so many durable industrial and everyday products like non-stick surfaces, firefighting foam as a flame retardant, stain resistant fabrics, water repellent coatings, and plating demisters contain PFAS. 

The chemistry is complex because PFAS are not one chemical compound; they are a class of chemical compounds that share the common carbon-fluorine bond. The carbon to fluorine bond is one of the strongest bonds in organic chemistry, making PFAS compounds particularly resistant to degradation and therefore cleanup. Since they do not break down and they have widespread use, they are being found everywhere in the environment.   

SOURCES OF PFAS
The USEPA advisories in the May 25, The USEPA first announced PFAS health advisories in the May 25, 2016 Federal Register. Since then, numerous updates and significant research has been published by USEPA, State Agencies, and private researchers. After which, State regulatory agencies began pushing primary and secondary industries into investigate for PFAS. To date, most of the investigations and cleanups have centered on both the manufacturers of PFAS compounds and military airports. The three general sources of PFAS impact on the environment include:    

• Primary: Manufactures of PFAS Compounds  
• Secondary: Manufactures of Items with PFAS or direct use of PFAS compounds  
• Tertiary: Use/Disposal of PFAS containing products  

The manufacturers of the PFAS compounds generally include the large chemical manufacturers that have been the subject of much regulatory scrutiny and private litigation. The secondary group includes all the industrial and commercial processes that directly applied these chemicals to products or processed materials previously coated. Dry cleaners that offered the application of stain-resistant coatings containing PFAS fall within this second group but also fall within the third group.    

The third group is comprised of all consumer and commercial use and disposal of PFAS treated products. The potential for PFAS impacts to the environment from this third group is probably least understood. This third group is where dry cleaning may have its most significant exposure for PFAS impacts since dry cleaning byproducts (spent solvent, lint, still bottoms, etc.) have had contact with PFAS containing textiles.  

We know historically dry cleaners accidentally released solvents to the environment, but how much PFAS were in these spent solvents? Studies from Toronto University have shown fast fashion items contain high levels of PFAS and other contaminants at levels that cannot be coincidental. When these PFAS laden clothes are washed, PFAS can accumulate in the various waste streams and mechanical vents at dry cleaners. Additional studies show that cosmetics also contain high levels of PFAS. Clothing with cosmetics stains may also contribute to low level accumulation of PFAS in facilities that would concentrate wastes. That is to say, dry cleaners, through filtration processes, concentrate PFAS, which may then enter the environment incidentally near waste storage and vent discharge points at dry cleaning and laundry facilities.   

Learn more about testing for PFAS and the available remediation methods  

TESTING OF DRYCLEANING SAMPLES
The Florida PFAS study evaluated both virgin and spent dry cleaning products from seven (7) Florida dry cleaning facilities. Virgin cleaning products at two of the seven facilities contained detectable concentrations of PFAS. One facility had a small detection of PFAS in a dry-cleaning machine cleaner and the other facility had a more substantial detection in a virgin petroleum-based solvent mixed with soap. Some virgin dry cleaning products do contain PFAS. The take-away message for you is to ask your chemical supplier for details on what is in your incoming products.   

PFAS were detected in dry cleaning wastes (spent solvents, solids, filters) in six out of seven of the facilities tested. PFAS compounds on treated fabrics clearly come off the fabrics during the cleaning process and are concentrated in the resultant waste products. Although use of some of these compounds have been phased out years ago, you can probably expect to see this continue for a while.   

The Florida study went even further and evaluated PFAS in virgin and spent products from seven wet laundry facilities. One out of four laundry detergents contained PFAS at relatively low levels. However, PFAS were detected in every wastewater discharge sample analyzed.   PFAS clearly come from treated clothing even during a wet laundry process, although to a lesser extent than from dry cleaning. One interesting finding of the study that speaks to the ubiquitous nature of PFAS is that they were detected at low concentrations in the incoming potable water at most of these facilities.   

TESTING OF SOIL AND GROUNDWATER
In the Florida study, ten sites with known dry cleaning solvent contamination (chlorinated and petroleum based) were evaluated. Eight of these sites had undergone some level of remediation. Samples of soil and groundwater were collected and submitted for analytical testing for 28 PFAS and GenX compounds. PFAS compounds were detected in groundwater at all ten sites. While the presence of PFAS seemed to correlate to the presence of PCE there was little correlation between concentrations of PFAS and PCE. This is likely due to how these compounds behave in the environment.  

The study did identify four sites where it appears there was PFAS entering the site from an off-site source. Again, given PFAS widespread use and their propensity to not degrade, this is not entirely unexpected. However, even at these four sites, there was evidence of PFAS contribution due to the releases of dry cleaning products.   

Similar results were seen in soil samples collected and submitted for laboratory analysis.  Although all the soil sample detections were below levels deemed safe by Florida for direct exposure, they were above levels that have the potential to impact groundwater above safe levels.   

Dry cleaners inadvertently introduce PFAS compounds through the chemicals they use. Going forward it’s important that dry cleaners document the PFAS content of incoming chemicals from your suppliers and if possible avoid PFAS containing products. What is clear is that the dry cleaning process itself introduces PFAS into your waste streams by extracting them off of the stain-resistant garments. How big of a problem this will be for the dry cleaning industry is unknown as the science and regulatory framework surrounding PFAS is evolving.   

RESPONDING TO REGULATORY REQUESTS
Should someone ask you to sample for PFAS compounds at your site, what should your response be? First and foremost, your response should be a cautious one made with input from a qualified consultant and potentially legal counsel. It should be clear under what authority the demand is being made and what some of the ramifications might be should PFAS be found on your property. If the decision is made to proceed, you will want to consider:  

1. What PFAS compounds am I being asked to sample for? 
2. What analytical methods will be acceptable to the entity asking for these results? 
3. To what criteria will the results be compared to? 
4. Are there other sources of PFAS surrounding my property? 
5. Will my consultant control the accidental introduction of PFAS into environmental samples?   
6. What are the consequences of not responding?  
7. Is any of this data confidential? 

THE CONSEQUENCES OF A RELEASE
Currently, it is difficult to say what will be required should you discover a release. One thing that is certain is that the cleanup of a PFAS release, to likely very low cleanup standards, will not be easy. The amount of research into PFAS cleanup being conducted at this time by commercial and private companies is staggering. Promising interim technologies are being developed by the not-for-profit Batelle research organization and others. It is likely that the best solution will present itself in a technology yet unknown to us at this time.  

Because of PFAS chemical structure, they are recalcitrant and do not lend themselves to many of the chemical and biological processes traditionally employed to remediate dry cleaning solvent plumes. Research is being conducted but as of now, there are few in place options for soil and groundwater remediation. The physical removal of the compounds from soil and groundwater is, for now, likely the best remediation option. Excavation of soil and the pumping and treating of groundwater are two ways of physically removing PFAS from the environment. Physical removal of these compounds creates waste products that need ultimate disposal. Heat destruction of these waste products offers promising results; however, the temperatures required are difficult to achieve and economically unsustainable. 

Find out why PFAS are so difficult to remediate, and why they’re known as “forever chemicals” 

CONCLUSIONS
The Florida study indicates that PFAS may well be an issue at drycleaner cleanup sites. Prior to implementing any sampling efforts that may put you in the liability hot seat, make sure you are thoroughly engaged with a consultant and legal counsel that can outline your options.   

The USEPA will within the next two years establish certain PFAS as a hazardous substance, which will make it easier for them to regulate. Without the hazardous substance designation from the EPA, investigations and remediation vary by State. PFAS sampling is more expensive than traditional environmental sampling and because the remedial options are limited and the regulatory framework is still up in the air, your long-term costs and liabilities are difficult to predict.  

Contact us with your questions about PFAS 

As seen in Cleaner & Launderer

Brad Lewis, CHMM, Principal Scientist
Brad Lewis is a detailed-oriented and collaborative environmental professional with over 24 years of environmental consulting experience. Brad has a Master’s Degree in Environmental Science and is a Certified Hazardous Material Manager (CHMM) with expertise that covers a variety of projects ranging from due diligence, environmental compliance, Brownfields, underground storage tank, and chlorinated hydrocarbon investigations and cleanups.  Because of his strong analytical chemistry background, Brad has implemented many innovative site investigation strategies including the use of mobile laboratory, and immuno-assay to characterize sites. Brad is a member of the Midwestern States Environmental Consultants (MSECA) organization and took part in MSECA’s work group advising the Indiana Department of Environmental Management (IDEM) on revisions to the Remediation Program Guide. 

Brad manages large chlorinated hydrocarbon sites with large, deep, groundwater plumes that impact overburden, bedrock, and surface water resources.  To these projects he brings a keen understanding of contaminant fate and transport and an ability to develop a thorough conceptual site model.  This includes development of 2-dimensional and 3-dimensional visualizations of site lithology, hydrogeology and plume characteristics. 

He provides strategic planning of the technical and regulatory approach on most EnviroForensic projects.  This includes evaluation of new and innovative remedial technologies and changing regulatory and business climates. Brad facilitates communications between the responsible party, project managers, counsel, regulators, and the affected residences.    

Rob Hoverman, LPG, Northern Midwest Regional Director
Rob Hoverman is the Northern Midwest Regional Director and a registered professional geologist with more than 19 years of professional environmental services with a focus on contaminated site management. Rob currently serves as senior project manager for several projects in Indiana and Wisconsin.  His diversified professional experience includes research, scoping and budgeting, project management, data analysis and interpretation for both hazardous and non-hazardous substances, including compounds such as chlorinated solvents, petroleum-related constituents, as well as metals. Rob has managed numerous investigation and remediation projects regulated by state programs, and his responsibilities involved every aspect of projects from proposal preparation through project closure, regulatory negotiations and stakeholder communications.  Beyond technical evaluation and interpretation duties include obtaining contract approval, job initiation, budgetary analysis, budget tracking, and subcontractor contracting and management. Rob has also served as technical support for numerous vapor intrusion including soil gas, sub-slab, indoor air sampling and mitigation.  As the Regional Director for EnviroForensics, Rob maintains momentum and resources for Wisconsin projects.   

LEARN WHY THE EPA MIGHT SOON PUT IN PLACE NEW RESTRICTIONS TO PCE AND TCE UNDER THE TSCA

BY: R. SCOTT POWELL, PE AND NICHOLAS HILL, LPG

The U.S. Environmental Protection Agency (U.S. EPA) is currently assessing additional restrictions to the most common chemicals in the drycleaning industry: perchloroethylene (PCE) and trichloroethylene (TCE). Here we will review why risk management for these chemicals is being re-evaluated and how their management could potentially be affected.

Most of our clients store and use PCE and TCE in their daily operations, so when the U.S. EPA sends out notices that they will be evaluating the health risks of these chemicals under the Toxic Substance Control Act (TSCA), we pay special attention on behalf of our clientele. TSCA has banned most uses of polychlorinated biphenyls (PCBs) and significantly restricted asbestos and lead-based paint, which has led to their general discontinuation in market use. This has also led to a significant increase in disposal management efforts and costs for chemicals included in TSCA restrictions. The outcome of the U.S. EPA assessment in the next two years could significantly change the production, storage, transport, use, and disposal of cleaning products that contain PCE and TCE.

WHAT IS TSCA?
TSCA was initially established in 1976 as the nation’s primary chemicals management law and provided the U.S. EPA with authority to require reporting, record-keeping, testing, and restrictions of specific chemical substances that were determined to pose a risk to human health or the environment.

A brief history of TSCA:

• Title I: The initial act in 1976 concentrated on chemical inventory, expectations that industry would lead testing of manufactured chemicals, banned most uses of polychlorinated biphenyls (PCBs), and significantly restricted mercury. 
• Title II: In 1986, the Asbestos Hazard Emergency Response Act was amended to TSCA to require schools to test for asbestos and development management plans. Though TSCA does not provide a ban on asbestos, the known health hazards and negative connotation of asbestos-containing materials (ACM) were sufficient to prompt an industry trend to avoid asbestos-containing products and for facilities to abate ACMs when found.  
• Title III: In 1988, the Radon Program Development Act was amended to TSCA to provide states financial and technical support in monitoring and controlling radon.   
• Title IV: In 1992, the Residential Lead-Based Paint Hazard Reduction Act was amended to TSCA. Again, this title did not ban lead-based paint, but promotion of negative health effects and guidelines for protecting the public from lead-based paint was sufficient to change the paint supply market.  
• Title V: In 1990, the Asbestos School Hazard Abatement Reauthorization Act was amended to TSCA set up State programs to provide technical assistance to schools in developing environmental health programs to address contaminants and hazardous substances encountered in school building construction.   
• Title VI: In 2010, the Formaldehyde Standards for Composite Wood Products Act was amended to TSCA. This title restricted the emissions concentration of formaldehyde from processed lumber products, changing the internal process within the industry but not affecting the end sales and products generated.  

As demonstrated in Titles I, II, IV, and VI above, rules enacted under TSCA can have variable effects on their relative industries. In addition to the major Title sections reviewed above, there have been numerous small amendments to TSCA that have added restrictions to chemicals in various industries.  

PCE AND TCE RISK MANAGEMENT UNDER TSCA
The most recent TSCA amendment in June 2016 required the identification and assessment of high-priority chemicals. The chemical risk assessment process consists of three steps: prioritization, risk evaluation, and risk management. In December 2016, PCE and TCE were identified by the U.S. EPA as high-priority chemicals for review under the TSCA. The U.S. EPA released the Risk Evaluation for Trichloroethylene (TCE Risk Report) in November 2020, and the Risk Evaluation for Perchloroethylene (Ethene, 1,1,2,2-Tetrachloro-) (PCE Risk Report) on December 20, 2020. The U.S. EPA is currently assessing an applicable and appropriate risk management approach for both compounds.

The health risks identified in the PCE Risk Report and TCE Risk Report list acute exposures including neurotoxicity and chronic exposures including neurotoxicity, kidney, liver, immune system and developmental effects, and liver cancer. The PCE Risk Report reviewed 61 conditions of use and identified 59 that represent an unreasonable risk of injury to human health based on those health risks. Similarly, the TCE Risk Report reviewed 54 conditions of use and identified 52 that represent an unreasonable risk of injury to human health based on those health risks. In general, the conditions of use included: manufacturing, import, processing, repackaging, recycling, degreasing, lubricants, adhesives, paints, coatings, automotive care products, metal and stone polishes, welding, textile processing, furniture manufacturing, foundry application, and various dry cleaning-related uses.

WHAT’S NEXT FOR PCE AND TCE RISK MANAGEMENT?
The U.S. EPA’s next step will be to initiate risk management actions for these identified conditions of use to reduce or eliminate the risks. The U.S. EPA has initially identified the following categories where regulations could possibly be implemented to reduce risks through operational prohibition or limitation:

• Manufacturing
• Processing
• Distribution
• Use
• Disposal

The upcoming risk management action consists of Environmental Justice Consultations for PCE and TCE with the U.S. EPA on on June 16, 2021 and July 6, 2021. These consultations will be opportunities for stakeholders to express environmental justice concerns. The U.S. EPA will also have additional consultations with small businesses and state and local governments in the future.

TSCA has been used to limit or eliminate the production, importation, use, and disposal of more than 83,000 chemicals, including polychlorinated biphenyls (PCBs), radon, asbestos, various solvents, and lead-based paint. These past restrictions have had various secondary effects on businesses, notably increasing environmental management and disposal costs. Beyond the potential changes to solvent use in the drycleaning industry, new TSCA rules could affect the environmental management costs associated with contaminated media (concrete, soil, groundwater, and vapors) from the accidental release of solvents, even if a facility changes to cleaner alternatives. 

The future limits on PCE are undefined at this time but could be similar to the near-total ban that was applied to PCBs and asbestos, or the U.S. EPA could place limited restrictions on the use or concentration of PCE; there are also various other restriction potentials that could be applied. The U.S. EPA has up to two years following the release of the risk reports to address, by rule, the identified risks. Therefore, draft regulations for TCE should be anticipated in November 2022, and draft regulations for PCE should be anticipated by December 2022.

Contact us to learn more about our regulatory compliance services.

Scott Powell, PE, Senior Project Manager
R. Scott Powell is a Senior Project Manager with over 20 years of environmental consulting experience. Powell’s expertise covers a wide variety of projects ranging from due diligence, LUST/petroleum, hazardous material remediation, asbestos, lead-based paint, remedial actions, to remedial systems. He manages complex relationships fostering the cohesive involvement of several parties on multiple sites with co-mingled contaminant plumes requiring the implementation of remedial solutions for chlorinated solvents, hazardous materials, and petroleum hydrocarbon impacts. He has extensive experience with environmental regulatory compliance, including Clean Water Act (CWA), Comprehensive Environmental Response Compensation Liability Act (CERCLA), Resource Conservation Recovery Act (RCRA), Superfund Amendments and Reauthorization Act (SARA), and Toxic Substance Control Act (TSCA). Powell manages negotiations with state and federal regulatory agencies, provides litigation support in matters concerning environmental issues, and acts as a third-party reviewer of work performed by others.

Nicholas Hill, LPG, Senior Project Manager
Nicholas Hill has 12+ years of experience with environmental consulting for investigation and remediation projects regulated by state programs, primarily involving chlorinated solvent and petroleum impacts. Hill’s experience as a Senior Project Manager includes research, preparation of work plans and reports, project and budget management, geologic and hydrogeologic data collection, data analysis and interpretation, feasibility study, design, and implementation of various remediation technologies to treat soil, groundwater, and vapor contamination, and coordination of regulatory closure. Hill has implemented and reported numerous Phase I environmental site assessments in accordance with ASTM standards. In addition, Hill has assessed vapor intrusion exposure conditions through soil and sub-slab vapor and indoor air sampling and conducted oversight and monitoring of vapor mitigation system installation.

INSIGHTS FROM THE WISCONSIN DEPARTMENT OF NATURAL RESOURCES’ EARLY REGULATION EFFORTS OF THE EMERGING CONTAMINANT AND THE IMPLICATIONS FOR DRYCLEANERS

BY: JEFF CARNAHAN

It’s time for an update on PFAS. In the January 2020 edition of the Cleaner & Launderer, I discussed an emerging contaminant group called fluorosurfactants, otherwise known as perflouoroalkyl substances or PFAS, in the article subtitled “PFAS is New Bad Guy in Town.” As a refresher, PFAS are a wide group of engineered chemicals originally created to lower the surface tension of water. This led to their use in commercially available water-proofing chemicals, which some dry cleaners used as a part of their service to customers. Additionally, retail versions of the waterproofing products became available to consumers. Environmental regulators hypothesize that during the commercial cleaning process, some of the PFAS from waterproofed garments and materials enter the waste solvent solution. As such, they postulate that anywhere an environmental release of drycleaning solvent to the subsurface has happened, the presence of PFAS is also possible because materials treated with related products may have been cleaned at the facility. Further, the drycleaning operations that actually performed waterproofing or leather treating are more suspect of potentially having contamination directly from garment treatment spills. I recommend rereading the January 2020 article, because I also presented the state of regulations at that time, and especially how they were impacting dry cleaners.

Read “Emerging Contaminant Alert for Dry Cleaners: PFAS is the New Bad Guy in Town!”

DEVELOPING PFAS REGULATION AT THE STATE LEVEL: WISCONSIN
I sat down with Rob Hoverman, EnviroForensics Northern Midwest Regional Director located in our Wisconsin office, to talk about how the State of Wisconsin is currently addressing the potential for PFAS to be associated with environmental releases of Perc and other solvents at drycleaner sites. Rob is one of our subject matter experts on PFAS issues and is currently embroiled in this issue on behalf of our Wisconsin drycleaner clients. Wisconsin is one of the states on the leading edge of PFAS regulations, and they don’t seem to be excluding anyone from the regulation process. We’re looking at this from merely a reporting standpoint, so that we can keep you informed as the PFAS regulation process develops across the country.

ESTABLISHING PFAS SCREENING LEVELS
For a chemical to be regulated, there needs to be an established concentration that provides a threshold by which to evaluate its release to the environment. These are commonly called screening levels. If the contaminant of concern is present at a concentration less than the screening level, then there likely is no need for cleanup action to be taken. If the contaminant is present at a concentration greater than the screening level, then the release needs to be addressed. The way this typically works is that the federal United States Environmental Protection Agency (U.S. EPA) creates a draft screening level based upon developing human-health based exposure studies. Once finalized, the Regional U.S. EPA offices, and subsequently, individual States use those screening levels to propose and adopt their own screening levels that are at least as stringent as the federal screening levels.

With federal screening levels still in draft form (and likely to be as such for many years), can state screening levels for PFAS be enforced? Without federal oversight and a uniform approach, the varying regulatory programs indicate the necessity to define risk, balance costs, and determine predictable remedial outcomes. This scenario is very similar to the conundrum we faced with vapor intrusion regulations ten years ago. Lack of finality at the federal level forces the states to move on their own accord using the methods they feel make the most sense. When emerging contaminants, or exposure pathways in the case of vapor intrusion, first come to light, the regulators may have a tendency to be more conservative out of an abundance of caution. I think we may be seeing some of this now with PFAS.

COMPLICATIONS FROM EARLY REGULATORY GUIDANCE ON PFAS
1. PFAS screening levels haven’t been finalized
In our case study of Wisconsin, the Wisconsin Department of Natural Resources (WDNR) asserts authority as defined by state statute to require the development of site-specific cleanup standards by a responsible party (e.g. the drycleaner). This, in effect, creates a situation where the state regulator serves its primary objective to protect human health and the environment from this emerging contaminant (i.e. PFAS) by demanding that sites with known releases of other contaminants assess potential use, potential release whether a primary release or secondary release associated with contamination as described above. Ultimately the WDNR can require testing for the presence of PFAS. Then, it is up to the responsible party to establish a cleanup objective using screening levels that haven’t been finalized. It’s truly a difficult and frustrating scenario.

2. PFAS compounds are costly to sample and analyze
Partly due to its newness, sampling and analyzing for the presence of PFAS is expensive; especially as compared to the cost of sampling and analyzing for Perc. The current list of PFAS compounds is at 36 and has changed continually since regulation began. The act of collecting samples costs several hundred dollars per sample and requires a minimum of three analyzed laboratory samples, which includes one field sample and two analysis blanks, per the currently accepted U.S. EPA test method. The extra quality assurance samples, like the blanks, are necessary because PFAS in groundwater have been found to be so ever-present in the environment and the extremely common nature of PFAS in clothing, personal care goods, common commercial and household goods, and food containers.

3. Drycleaners face possibility of denial of regulatory closure without PFAS assessment
According to Rob Hoverman, one of the most troublesome developments from the WDNR has been an actual denial of a regulatory closure request due to having not sampled for PFAS in groundwater at the site after reaching the remedial objectives for a release of Perc. We have some drycleaner clients who are in no hurry to receive such denials, so they’re postponing their closure request altogether until the PFAS regulatory scenario develops further. Not an ideal situation for the regulated community or the regulators.

POSSIBLE GOOD NEWS FOR DRYCLEANERS WORRIED ABOUT PFAS
There may be some reasonable news here, in that what the WDNR is asking for is an assessment of the potential for there to have been a release of PFAS along with any other release from a drycleaner operation. If we want to focus on waterproofing products as the primary source of potential PFAS problems, then a concise explanation of the operational history of a drycleaning business over the years is step one. Making a demonstration that waterproofing was not performed at the location may be sufficient to serve as that assessment. If waterproofing and other treatment services were offered, then the assessment will likely need to consist of sampling. WDNR representatives recently suggested that the current line of thinking as to the occurrence of PFAS at sites with Perc releases to the environment is correlated to mishandling of still bottoms or used filters. The logic is that since PFAS compounds are not volatile, the distillation and filtering process would have concentrated and PFAS that came from garments treated with waterproofing products within the still bottoms. As such, there could also be a reasonable argument to be made against actual sampling during a PFAS assessment if the subsurface Perc data indicates that the release originated from some source other than still bottoms.

KEEPING OUR EYES ON THE PFAS REGULATORY BEAT
As the regulation of PFAS continues to coalesce over the coming months and year, I’ll provide periodic updates in this article. Stay tuned to the Environmental Corner in 2021 for up-to-date reports on how State regulators are reacting to this important issue for dry cleaners.

Contact us if you have questions about PFAS.

As seen in Cleaner & Launderer

Jeff Carnahan, President
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 been a partner of the drycleaning industry for the past decade and is a frequent contributor to the national drycleaning 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.

IN THE PAST, I HAVE TALKED A LOT ABOUT WHAT LEADS TO THE DISCOVERY OF CONTAMINATION, AND WHAT TO DO IF, OR WHEN, YOU LEARN THAT CONTAMINATION HAS BEEN DISCOVERED AT YOUR SITE OR A PROPERTY. BUT WHAT I HAVEN’T DONE BEFORE, IS PRESENT A SYSTEMATIC PROCESS OF WHAT STEPS SHOULD BE UNDERTAKEN WHEN PERC CONTAMINATION IS FOUND. GETTING IT RIGHT IS IMPORTANT BECAUSE YOUR LEGAL SECURITY, YOUR MONEY, AND YOUR REPUTATION ARE ON THE LINE.

BY: JEFF CARNAHAN

To start, I’ll walk through the three important areas to become familiar with when addressing environmental contamination. Also, if you’re interested in this topic area, check out our webinar with Cleaner and Launderer on “how to respond when you find perc contamination”.

UNDERSTANDING THE REGULATORY DEMANDS

If an environmental contamination problem has come to light and you’ve been notified, there are regulations, rules, and laws in effect that require you to respond. Congress passes the laws that govern the United States, but Congress has also authorized EPA and other federal agencies to help put those laws into effect by creating and enforcing regulations. The EPA, in turn, has given each state the authority to implement and enforce their regulations within their area of jurisdiction, so long as the state regulations are at least as stringent as the federal regulations. A similar process exists in Canada between the federal and provincial environmental regulating agencies.

When an environmental release of hazardous substances has occurred onto or beneath the ground surface, these regulations require that the parties that may have caused or contributed to that contamination are responsible for investigating the nature and extent of the release. There are many nuances involved in determining who may become considered a potential responsible party, and who may ultimately be required to clean up the contamination, as I’ve discussed in recent articles. This question of rightful responsibility, if potentially contested, really belongs in the realm of legal liabilities, and an attorney should be consulted. The process for complying with the regulatory agencies is a bit less complex, although there are many nuances and an experienced environmental consultant will be needed to interface with the agency on your behalf.

So, when you first learn that there has been a release of hazardous materials, such as chlorinated or petroleum dry cleaning solvents, the first thing you’ll need to do is quickly find a consultant or an environmental attorney to make sure that you follow the required process for your state. Commonly, there is a reporting process that must be followed, and there are well-defined timelines that must be met. Once the contamination has been reported to the agency, your case will receive a number, which will be used throughout your regulatory process. You may be given an option to enter a voluntary cleanup program, or you may be required to remain in an enforcement program. Those who take the option to perform investigation and cleanup in a voluntary program usually are allowed more freedom in process and timing and may be eligible for a greater degree of indemnification at the close of the process after cleanup is complete. Enforcement programs may take longer since the agency remains involved in every step, and approvals may take a while. There are other regulatory vehicles that may come into play, such as agreed orders or enforcement orders, when higher levels of assurance are needed by you as the responsible party or the agency.

Each agency has its own personality and may create its own frustrations for you. Bottom line, however, is that if an environmental release has been identified and you want to put it behind you, involvement of the regulatory agency will be necessary. The mission of environmental agencies is to protect human health and the environment. If you keep that in mind and let that be the basis for dealings with the agency, you may be able to have a better understanding of their actions. You may also need to remind certain people within the agency of the scope and limits of their own mission at times to keep them from overreaching their boundaries. That’s specifically what most environmental consultants are good at, so look to them to lead these conversations.

UNDERSTANDING THE LEGAL LIABILITIES

There are many legal issues that may arise soon after you discover environmental contamination, for which you may be responsible. The very first of which is, are you potentially responsible. Since this question is a matter of environmental laws, an environmental attorney should help you answer that. If you are a single owner who has operated at a site where nobody else has, then it may not really be an applicable question. However, if there have been multiple operators and landowners at the contaminated site and you are just one of them, there are some legal matters to address. That’s just the tip of the iceberg when it comes to involving an environmental attorney on your behalf.

The environmental rules and regulations are very closely linked with the law. Any time a matter of law is involved, so should an attorney. Your environmental consultant cannot and should not give advice related to the law. They can help you adhere to regulations, but not laws. As such, relying on your consultant to assist with regulations at a lower price, and have your attorney help with true legal matters at a typically higher price is the normal combination. Conversely, attorneys aren’t in the business of making scientific recommendations regarding the actual investigation and cleanup of the contamination, so that’s another reason why both environmental consultants and attorneys are needed.

It’s common for your environmental attorney to also assist you in understanding other aspects of legal liability outside of regulatory issues that you may have because of the contamination. For example, if the contamination at your site has crossed the property line, there may be trespass issues, and potentially human exposure liabilities to assess and attend to. By allowing your attorney to guide you during the investigation and cleanup process, you’ll have someone watching your back and making sure you don’t expose yourself to liabilities accidentally. You will want a specialized environmental attorney who has much experience with these types of matters. A general business practitioner is likely not experienced enough with these matters to give you sound advice.

UNDERSTANDING THE FINANCIAL BURDENS

The third component of getting started with handling your environmental contamination problem has to do with money. The investigation and cleanup process ranges from expensive to very expensive, so having a hard look at a financial strategy is of paramount importance. The legal advice and work costs money, the investigation and cleanup process itself costs money, the agency is likely to charge you fees for their oversight, and heaven forbid, there could even be penalties involved if you get behind the eight ball. The really bad news here is that lack of funding doesn’t constitute an avenue for forgiveness of a responsible party’s ownership of the liability to investigate and clean up the contamination. Given a demonstration of financial hardship to the agency, you could qualify for various forms of aid, however. Some agencies work with state-run financial entities that may be able to provide you with a low-interest loan, but that may not be a great alternative. The first action is to evaluate all your business assets to make sure that you aren’t leaving any stones unturned. Of course, look at your old commercial general liability (CGL) policies. If you know that you bought these policies but can’t find them, hire an insurance archeologist to help recreate your old insurance portfolio. If you are in a state with favorable case law, you could be covered for the investigation costs, cleanup costs, and your environmental attorney costs.

Work with your environmental consultant to determine the potential financial burden that you may be facing. They will be very cautious about giving you an estimate because until the investigation phase of the work has been completed it will be difficult to quantify a dollar amount. Therefore it’s important to have various options for funding readily available. Contamination can be very tricky, especially chlorinated solvent releases such as tetrachloroethylene (Perc), which tend to hide the true magnitude until a full evaluation has been conducted. The investigation process alone can cost a few hundred thousand dollars. Over my decades of environmental work, it’s common to see an average cost of over one million dollars for a drycleaner site where a release of Perc has occurred. Granted, I’ve seen regulatory closures attained for less than five hundred thousand dollars, but I’ve also seen drycleaner cleanups cost into the tens of millions of dollars. It just depends on how long ago the release happened, and how bad it was.

Hiring a consultant who has performed numerous drycleaner site cleanups is critical since they can help you understand the potential cost more than others. A good one should also be familiar with other potential funding resources that may be available to you. Everyone understands that small business, and even larger ones, may have a hard time with the financial burden of environmental investigation and cleanups. Don’t panic until you’ve explored all avenues.

These three areas – regulatory, legal and financial – are all important when you’re faced with environmental contamination. Whether you expected it or not, you could be on the hook for the cleanup. By following the advice given in this article, you’ll be well on your way to addressing environmental contamination responsibility with a sense of calm for your legal security, your financial plans and your reputation. Both your pocketbook and the future value of your property will thank you and you can rest assured that you took every step you could to get the best outcome possible.

Contact us today to address your environmental contamination.

As seen in Cleaner and Launderer

Jeff Carnahan, President
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 been a partner of the drycleaning industry for the past decade, and is a frequent contributor to the national drycleaning 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.

THREE METHODS TO DETERMINING WHEN PERC WAS RELEASED AND IF THERE ARE OTHER RESPONSIBLE PARTIES TO SHARE IN THE LIABILITY

BY: JEFF CARNAHAN

Let’s get technical. With the recent and anticipated increases in the number of drycleaner businesses and properties changing hands, we’re seeing an increase in environmental issues needing to be addressed. It’s rare for a single operator to have occupied a drycleaning business property through the years, especially as far back in time as the 60’s or 70’s. If environmental contamination is discovered at a property with a history of drycleaning operations, every one of the corporate entities that conducted business at that location is subject to claims of the release(s) that occurred during their time at the property.

WHO IS RESPONSIBLE FOR A PERC TEST, INVESTIGATION, AND CLEANUP?

Can Perc releases be accurately age dated? The answer isn’t a straightforward yes. It can be extremely difficult to tell exactly when an environmental release occurred, but there are scientific methods available to help bracket a range of dates when it was likely. There are three ways to pinpoint when a perc release has occurred. I’ll explain this by using tetrachloroethylene (PCE), also known as Perc, contamination in the groundwater as an example.

1. DETERMINING THE AGE OF THE PERC RELEASE

One way to determine the relative age of a release is by evaluating the breakdown products of Perc. The process goes like this: trichloroethene (TCE)  dichloroethane (DCE)  vinyl chloride (VC)—these are known as “daughter products”, which come from decaying Perc. Perc is considered a recalcitrant compound, meaning it is pervasive in the subsurface environment and doesn’t break down easily under natural conditions. When Perc is released into a typical groundwater environment, where an ample amount of oxygen is present, it generally breaks down very, very slowly, if at all. We have seen groundwater plumes of Perc that are over 50 years old that haven’t degraded at all. Significant natural breakdown of Perc only occurs in groundwater when there is very little oxygen, and the microorganisms that thrive in those anaerobic conditions are abundant. These are the factors that can equate to the degradation of Perc to TCE, DCE, and VC. The longer the plume has existed under these optimal conditions for breakdown, the more daughter products there are. The sequence can be illustrated by the following sequence based on relative proportions of these compounds:

As mentioned, using the ratio of breakdown products to Perc is not singularly a reliable method for estimating the age of the Perc release in groundwater where there is plenty of oxygen.

Learn more about what makes cleaning up Perc spills so expensive

2. DETERMINING HOW FAR THE PERC RELEASE HAS TRAVELED

Another approach is to determine the horizontal extent of the contaminated groundwater plume. In general, the groundwater velocity multiplied by the amount of time since the release occurred equals the distance traveled. Fundamentally, if you know the velocity of the groundwater and the distance the groundwater plume has traveled, you should be able to mathematically determine the amount of time that has passed since the release entered the groundwater. Clearly, it is much more complicated than that and it takes a seasoned hydrogeologist to perform those calculations. Often, a computer model of groundwater conditions needs to be created to account for the vast multitude of variables that come into play.

3. DETERMINING WHO IS RESPONSIBLE FOR THE PERC RELEASE

The age dating approaches are useful if you are trying to determine when a release of Perc happened at a single property and get a feel for who was operating at that time. A more complicated scenario is when one is trying to determine the age of a Perc release when it has merged with another release from a different property. This is known as a comingled plume. In this scenario, scientists may rely on evaluating the presence of differing chemical isotopes within the Perc found in the distinct groundwater plumes. To understand this approach, the scientist must have information on the original product that the drycleaner used over specific time periods. Different manufacturers of Perc had unique product formulas from their competitors and recycled Perc would have a very different formula from virgin Perc. Under this set of facts, the isotopic analysis, or fingerprint of the product, can be useful.

Find out how environmental forensics can help determine who is liable for a contaminant release

In comingled plume studies, the isotopic fingerprint of each source is established using these methods. In theory, this is not too difficult and would require just a couple of samples in the source area and at the leading edge of the plume. However, in actuality age dating a plume is more complex. As mentioned above, a precondition is that we know the isotopic fingerprint of the Perc product that was used at a given time and location versus the isotopic fingerprint of the Perc product used at a different time and location. If one is trying to establish the age of a release at the same site, we need to know the date when the Perc products that were used switched from one to another.

FIND AN ENVIRONMENTAL CONSULTANT THAT UNDERSTANDS PERC

These three approaches help the investigation process move forward and allow drycleaners to pinpoint when a Perc release happened. As with many things in life, there’s ambiguity, especially to an untrained eye. This is why it’s so important to find an environmental consultant who understands the complexity that comes with environmental work at drycleaning businesses. They will be able to guide you through this investigation with clear goals knowing which challenges may arise and which challenges that can be avoided.

As always, we’re here to support our friends in the drycleaning community and want to see the best outcome for you no matter your situation.

Learn more about how we can assist you through the environmental investigation and cleanup process. Fill out our contact form.

As seen in Cleaner and Launderer

Jeff Carnahan, President
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 been a partner of the drycleaning industry for the past decade, and is a frequent contributor to the national drycleaning 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.

BE PROACTIVE BY CONTACTING AN INSURANCE ARCHEOLOGIST AND AN ENVIRONMENTAL CONSULTANT

BY: DRU CARLISLE

We understand that most people are unhappy when environmental issues pop up. This can happen when a Phase I Environmental Site Assessment (ESA) has uncovered Recognized Environmental Conditions (RECs), you’ve received a demand letter from an environmental regulatory agency, or you’re aware that you most likely have contamination. Back in the day, many industrial solvents and chemicals used in operations like dry cleaning and manufacturing were not known to be hazardous, so regulations were different than they are today. Even newer industrial operations can have minor hazardous leaks and spills causing environmental impacts that will need to be addressed when they are discovered. Depending on the past business operations at certain properties, sometimes environmental issues are inevitable. Fortunately, there are steps you can take to protect yourself and potentially minimize your out of pocket expenses.

In this blog, we’ll dive into effective strategies to address environmental issues.

BE PROACTIVE WITH INSURANCE ARCHEOLOGY

It’s never too early to prepare for the potential challenges associated with environmental issues; whether it’s finding funds to cover the expenses through insurance archeology or finding the right partner to lean on for support. This is why it’s important for drycleaners, industrial launderers and textiles, and manufacturers to be proactive and assemble their available resources before an environmental issue is discovered.

LOCATE YOUR OLD POLICY INFORMATION AND BUSINESS RECORDS

Business owners that search for their old comprehensive general liability (CGL) insurance policies before an environmental investigation begins will have an important step taken care of because these policies can be used to help pay for resolving environmental liabilities.

Historical CGL policies, once located and leveraged, typically cover the costs of your legal defense and will pay on your behalf of damages if you are found liable—up to the limits of your policy. Historical CGL policies are valuable assets that may be worth millions of dollars and depending on your situation and the state in which you conduct business, the out-of-pocket environmental cleanup costs may be minimal.

If locating your old policy information and business records proves to be too difficult to do on your own, you can bring in an experienced insurance archeologist to help find your old policy information, put together a corporate history and coverage chart for your company and property.  Insurance Archeologists utilize a number of methods for tracking down evidence of policies, whether your own, or past owners or operators.

Learn more about our insurance archeology services 

TAKE CHARGE OF YOUR ENVIRONMENTAL INVESTIGATION WITH AN ENVIRONMENTAL CONSULTANT

Since contamination devalues a business and a cleanup can take some time to do, it’s smart to act sooner than later, like when you’re ready to sell or pass on your business to the next generation. And now that you know how to find your old policy information and business records, it’s time to start strategizing with environmental experts to prepare for an environmental investigation.

DETERMINE THE RIGHT CONSULTANT FOR YOUR ENVIRONMENTAL STRATEGY

Experience matters and choosing an environmental expert with the right background and knowledge to guide you as you prepare your environmental strategy is crucial. Find environmental experts with significant experience in your industry. For example, drycleaners and industrial launders and textiles should look for experts with proven chlorinated solvent experience while manufacturers should look for experts with proven polychlorinated biphenyl (PCB) or hexavalent chromium experience.

The strategy may include an environmental investigation, a vapor intrusion assessment or maybe even an environmental remediation if contamination is found. It’s hard to know exactly what to expect when the process starts but having an experienced environmental consultant with expertise in your industry can make a big difference. They’ll have a better sense of what to expect at your business and will be there to help you navigate the decisions you’ll need to make to move forward with your environmental strategy.

While cleanup strategies are personal for each business, the overall steps are similar. A smart strategy begins with 1) finding what coverage is available, 2) determining the extent of contamination, and 3) implementing a site-specific cleanup plan.

There’s no need to face environmental liabilities or demand letters on your own. Business owners can take proactive steps to get in the driver’s seat and protect their assets with the support of insurance archeologists and environmental consultants. We strongly believe there shouldn’t be a financial barrier to performing meaningful environmental restoration work and that insurance policy coverage for environmental liabilities should be honored by the carriers.

Do you have questions about environmental investigations? Contact us today.

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.

EVERYONE IS MAKING TOUGH DECISIONS RIGHT NOW ABOUT WHAT TO SPEND MONEY ON, AND WHAT CAN WAIT. IN THIS ARTICLE, I’LL WALK YOU THROUGH WHAT CAN WAIT AND WHAT CANNOT WAIT EVEN IN OUR CURRENT COVID-19 BUSINESS ENVIRONMENT.   

BY: JEFF CARNAHAN 

The EPA and many State environmental agencies have issued statements providing loose guidance related to the potential availability of some slack in regulations due to COVID-19  and the financial stress that it has put on many responsible parties who are in a cleanup program. If you are in a position where there is a known release of hazardous substances from your operations or previous operations at your site, there are decisions that need to be made about whether or not to proceed with various aspects of the environmental investigation and cleanup process. Some things can wait, and some just cannot.   

 ENVIRONMENTAL CONTAMINATION ISSUES THAT CANNOT WAIT 

There is an adage that says, “Do whatever you want, so long as it doesn’t hurt anyone”. With environmental contamination issues, there is often the possibility that others could be put in harm’s way from exposure to hazardous substances. The work related to investigating and eliminating a direct exposure to contamination should be top priorities, and it really can’t be put on hold. Here are three scenarios where environmental cleanup shouldn’t wait: 

1. VAPOR INTRUSION ASSESSMENT

At sites where a subsurface release of volatile organic compounds (VOCs) such as PCE, TCE, or Benzene has occurred, the potential for vapor intrusion most likely exists at nearby buildings. If there are residences, daycare facilities, schools, or medical care facilities close by, that threat carries an even higher urgency. Whereas many investigations that include soil or groundwater sampling are measuring a potential exposure, vapor intrusion assessments measure actual exposure situations. If vapor intrusion is actually occurring at a building, the occupants are breathing the contamination directly. The VOCs mentioned above are all carcinogenic to some degree and are highly regulated. Exposure scenarios where their levels are identified at concentrations higher than risk-based screening levels are strictly enforced by regulatory agencies. If you are the responsible party for a release of VOCs and the vapor intrusion exposure pathway hasn’t been ruled out, appropriate sampling of the inhalation exposure pathway at nearby structures should not be delayed. If it is confirmed that levels of VOCs in the indoor air at sampled buildings are higher than the regulated levels, immediate actions to protect the occupants, such as the installation of a sub-slab depressurization system, will also be required.  

2. GROUNDWATER SAMPLING IN DRINKING WATER WELL PROTECTION AREAS

It is not uncommon for releases of contamination to migrate into the groundwater, and then become mobile and transport downgradient. Since groundwater is a valuable drinking water resource in many areas, the potential exists for contamination to make its way into potable water supply wells. Like vapor intrusion assessments, the sampling of groundwater for the presence of contamination within a well-head protection area is an assessment of a direct exposure for those who may drink that water. This type of exposure scenario, if likely or probable, is one where there should not be delay in making a determination if your release is impacting others. The timing is unfortunate, but sampling of the ingestion exposure pathway in this situation will be strictly mandated by regulatory agencies.  

3. SURFACE SOIL SAMPLING WITHIN INHABITED AREAS

One factor that allows subsurface soil sampling at contamination sites to proceed at a calculated pace is that many times the impacts are well below the ground surface. When this is the situation, the likelihood of people coming into contact with the hazardous substance is pretty low and may be limited to construction workers who may be digging in the area. When contamination appears to be present at the ground surface in a location that is frequented by people, especially children, the potential for direct contact with that soil is much higher. While this threat is less common than vapor intrusion or groundwater ingestion exposure, if your site fits into this scenario, be prepared for the regulators to demand that investigation and exposure mitigation measures be carried out, with little to no leniency.  

ENVIRONMENTAL CONTAMINATION ISSUES THAT CAN WAIT 

If you’ve already advanced your site investigation and/or remediation process past the point where you know whether there is a threat of an ongoing exposure, you can probably get some concurrence from the regulators to slow things down a bit. Here are two scenarios where environmental work could be postponed: 

1. POST-REMEDIAL ACTION MONITORING

Typically, after a cleanup action has been implemented, say a source area soil excavation or a groundwater cleanup, there is a period of time during which routine quarterly, semi-annual or annual groundwater monitoring is required to demonstrate that the project was successful. Sometimes the cleanup mark can be missed, and it isn’t known until post-remedial monitoring shows a rebound in contaminant concentrations. Although any delay in the performance of this monitoring has the effect of prolonging the amount of time until you get your regulatory closure, if it is necessary to route the funding to other, more critical business efforts, it is likely that you can get the relief you need. 

2. CLEANUP ACTIVITY IF ONLY YOUR PROPERTY IS IMPACTED

If you are involved in an environmental investigation and cleanup, and you have already shown through sampling that the extent of contamination doesn’t extend beyond your own property boundaries, it is also likely that you can put off cleanup for a period of time. Of course, if conditions were to arise in the meantime that involve the potential sale or refinancing of your property, the issue would once again be at the forefront and most likely the work would need to move forward to complete the deal.   

When economic conditions turn sour, as they are now, business leaders look to save cash on things that don’t absolutely need to happen right now. There are some situations, as we’ve discussed, where environmental projects may be delayed for a period of time to help out. Keep in mind, however, that as long as there is an environmental condition at your property that has not been closed through a regulatory program, your business and your property will never have its full value. Perhaps now is the time to seize the day and protect your assets’ value If this is your goal, it makes sense to keep the project moving.  

Contact us today to review your environmental investigation and remediation priorities. 

_____________________________________________________________________________ 

As seen in Cleaner and Launderer  

Jeff Carnahan, President 
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 been a partner of the drycleaning industry for the past decade, and is a frequent contributor to the national drycleaning 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.