State Coalition for Remediation of Drycleaners Meeting

State Coalition for Remediation of Drycleaners Meeting
Vintage Plaza Hotel
Portland, Oregon
October 3-5, 2001

WELCOME AND OPENING REMARKS
Leo Henning, Kansas Department of Health and Environment
Richard Steimle, Technology Innovation Office, U.S. Environmental Protection Agency

Leo Henning, the chair of the State Coalition for Remediation of Drycleaners (SCRD), opened the meeting by thanking Dick DeZeeuw of Oregon for his role in preparing the meeting and arranging site visits. All participants and observers (see Attachment A) then introduced themselves and mentioned their affiliations. Henning followed this with a brief history of SCRD, highlighting the fact that these meetings provide an opportunity for state representatives to exchange information and experiences. In addition, these meetings benefit the U.S. Environmental Protection Agency (EPA) because the agency learns about innovative and cost-effective remedial approaches that are being used and can pass this information along to non- member states. He then introduced Richard Steimle of EPA.

Richard Steimle thanked participants for their attendance and expressed gratitude to SCRD members who have gathered information for case studies. Mr. Steimle said that EPA can apply much of the information in these case studies to remediate Superfund sites. Steimle said that seven case studies are currently posted on SCRD's Web site; each provides information on successes, mistakes, and costs that have been incurred during efforts to clean up drycleaning sites. Steimle acknowledged that it is difficult to find the time to write the case studies. For this reason, two interns were hired to assist in the effort. (The internship was offered as a joint effort between EPA and the states.) The interns helped Florida, Oregon, Kansas, and Wisconsin put together case studies. Steimle said that the internship will be extended over another 6-month period and that an additional intern may be hired. Before concluding, Steimle distributed a list of available seminars that are available through the Internet.

STATE REPORTS
A representative from each member state, except Missouri, provided a program status report and responded to questions. (Representatives from the Missouri program were unable to attend the conference.)

Alabama
George (Dave) Davis, Alabama Department of Environmental Management

Dave Davis said that Alabama has passed legislation to establish a drycleaner cleanup fund program. The Alabama Department of Environmental Management will be expected to promulgate regulations to enforce the act. Davis was hopeful that rulemaking would be completed within the next couple of months. The enabling legislation is vague, Davis said, noting that he may call SCRD members in the near future to gather regulatory input. The program is preparing a remediation assessment booklet to help site owners determine the standards they should be trying to reach with their cleanup efforts.

The drycleaner cleanup fund program's board, which sets priorities, is appointed by the Governor. The program is voluntary, and letters have been distributed to numerous drycleaners to inform them of the opportunity the program presents. Davis said that the fund program is supposed to raise $1 million by May. Current projections indicate that $950,000 will be collected, assuming that everyone honors their commitments. Davis expects that the necessary funding level will be realized, despite expected cutbacks resulting from the events of September 11. If the $1 million mark is not met, the program will be compromised. No funding is available for staffing beyond Davis and Pam Wilson, also of the Department of Environmental Management.

Florida
Doug Fitton, Florida Department of Environmental Protection

Doug Fitton reported that entry into Florida's drycleaner cleanup fund program ended in 1998. Thus, no new sites are coming into the program. In total, 1,415 sites have been listed as eligible for Florida's program. Of these, 150 sites were disallowed and 7 are pending. The reasons for disallowing sites include improper applications, lack of evidence that a drycleaner had ever existed at a site, nonpayment of taxes and/or registration fees (this was correctable), and, most common, failure to install a secondary containment system by the deadline date. Disallowed sites are being enforced at the local level.

Fitton said that work has been initiated at 250 sites, assessment is underway at 35, design is underway at 32, construction has begun at 6, active cleanup is taking place at 37, natural attenuation is being monitored at 34, and cleanup is complete at 41 sites (3 percent of eligible sites). No further action was required at 20 percent of the sites examined. The average age of the sites being worked on is 19 years; the oldest was established in 1926.

Fitton provided statistics on the average costs associated with the different phases of site remediation: the average cost per assessment was $91,000, design and source delineation costs were $49,000 per site, construction costs were $180,000, and operation and maintenance costs for the program were $60,000 per year. Fitton said that the figure for the latter is expected to rise as activity occurs at more sites. Although 41 sites have been cleaned up, none of them were large or had serious contamination. Fitton said that the Florida Department of Environmental Protection is placing an emphasis on addressing source areas; this is seen as an effective way to deal with high-concentration areas. Natural attenuation is allowed if contaminants fall below certain levels (e.g., 300 parts per billion for tetrachloroethylene [PCE]), as long as something is done to address the source. This may protract the cleanup, but it saves money by limiting the size of the application.

Fitton reported that Florida has separate monitored natural attenuation rules for petroleum, brownfields, and drycleaning. As a point of clarification, he indicated that site assessment plus design costs for engineered sites came to about $140,000.

Illinois
Pat Eriksen, Drycleaner Environmental Response Trust Fund of Illinois

Pat Eriksen noted that Illinois' fund program differs from those offered in other states by virtue of the fact that, although the cleanup is voluntary, licensing and fees are mandatory. A drycleaner must have $500,000 in liability insurance to be in the program. There are 1,440 licensed drycleaners in the state; 1,000 are eligible for benefits and 915 of these have the requisite liability insurance. Seventy sites have been assessed, at an average cost of $27,500 per assessment. Another 85 sites have submitted budgets for testing to determine if they are contaminated. Cleanup costs for those sites that have already been deemed eligible for the fund program are estimated at about $3.5 million to $3.7 million. The fund's balance is $6 million, and the annual revenue is about $2 million. Eriksen estimated that $4.5 million to $6 million would be required annually to deal with the entire cleanup. The program's sunset date is January 1, 2010.

Eriksen indicated that there has been quite a bit of political activity, much of it centered around a proposed increase in PCE fees from $3.50 to $7.00 per gallon. Newly proposed legislation is even more aggressive, calling for $14 per gallon. In response, a new drycleaner group has formed to address the proposals. This new addition brings the number of trade groups in Illinois up to four.

Current projections estimate that the program will run out of money in 18 months. Robin Schmidt of Wisconsin asked if her state's PCE distributors would capture new customers by selling their lower-taxed product in Illinois. Eriksen replied that out-of-state distributors are obligated to remit the required tax when selling to Illinois drycleaners.

Kansas
Bob Jurgens, Kansas Department of Health and Environment

Bob Jurgens distributed a handout that summarized the financial status of Kansas' drycleaner cleanup program. The program has a $2.6 million budget and is funded through June 30, 2002. Jurgens anticipates an increase in income due to the fact that chemical distributors are now expected to collect and pay surcharges instead of the state's 195 individual drycleaners. This change is expected to increase collection efficiency. The fund balance is $2.0 million, and in 2001 about $1.5 million will come into the fund. Efforts are made to maintain a $1 million balance reserve in the fund. Sixty-four sites have been accepted into the program. Of these, 20 are in the remediation process, 7 are in the monitoring phase, 10 are still being assessed, 4 are closed, and 23 are pending. Contractors perform much of the assessment and remedial work. A new contract will be awarded in April. Major new projects will not be initiated until the award is announced. Currently, excavation is occurring at one major site, and sparging at two others.

Jurgens mentioned that the state's drycleaning law requires drycleaners to have secondary containment or other pollution controls in place to be in the program. Staff members audit the facilities. In 2001, 25 facilities have been inspected. About 55%-60% were in compliance. Those that were not, remedied the situation within 90 days. Jurgens said that Kansas uses risk-based soil level numbers derived from EPA's minimum cleanup levels for groundwater. One major site in Wichita, however, has alternative cleanup levels (e.g., 14 parts per billion for PCE).

Minnesota
Dale Trippler, Minnesota Pollution Control Agency

Dale Trippler noted that the Minnesota Pollution Control Agency (MPCA) administers the state drycleaner cleanup fund program. The agency has been running a deficit. To remedy the situation, legislation was proposed that would allow MPCA to place drycleaning fee revenues into a general fund that would be available for other agency initiatives. A state drycleaning association objected to the legislation, indicating that the fees should remain for the exclusive use of the drycleaner fund program. This view prevailed and the legislation was not passed.

Since the fund program began in 1995, annual revenues of $600,000 to $700,000 have been generated. About $500,000 of this is normally spent each year. A balance of $1.5 million is currently sitting in the fund. Trippler said that MPCA has worked on 10 to 15 sites. Five or six of them are closed out; the rest are in long-term remediation, and the program is still paying out on them. Trippler said that their program recently confronted an interesting question when a site that had applied for reimbursement was found to have been cited repeatedly by county authorities for noncompliance. The state act allows the program to deny reimbursement to applicants engaged in illegal activity, but left "engaged in illegal activity" undefined. Trippler said he spent nearly a month drafting a memo defining the circumstances under which an applicant could be denied reimbursement. Robin Schmidt of Wisconsin mentioned that her state could also withhold reimbursement in such circumstances, but said that the site has to go through enforcement before the claim would be denied.

Trippler said that the fund program's efficacy is hindered by the fact that the MPCA and the Department of Revenue (DOR) have different roles and rules they must follow. Because the DOR cannot divulge who is paying and who is not, the MPCA does not have information as basic as the number of drycleaners in the state. Trippler estimates that there are 300 to 400.

North Carolina
Bruce Nicholson, North Carolina Superfund Section

Bruce Nicholson said that it has been a busy year for North Carolina's drycleaner fund program. Nonetheless, the state's general budgetary problems have prevented the hiring of new staff to support the program. As in Minnesota, drycleaner associations have successfully lobbied to prevent the legislature from allowing program funds to be used for other purposes. Three million dollars remain in the fund.

Nicholson said that new program rules were adopted in July, and that eight or nine drycleaners have applied to participate in the program. An additional 90 to 100 drycleaners are spread across various environmental programs; letters will be sent to them to notify them of the program. Nicholson said that PCE fees have increased from $5.85 to 10.00 per gallon, and petroleum solvent fees have jumped from $0.80 to $1.35. In addition, an earmarked sales tax will go into effect in July 2003. A tax credit on green technologies is available, but there have been no applications as yet. No sites have been completely cleaned up, and precise statistics on how many systems are in place are not yet available.

Nicholson emphasized that serious outreach efforts are being launched to acquaint drycleaners with the program and its rules. In addition, a memorandum of agreement has been drafted to address secondary water. The agreement indicates that this water can be evaporated after it has been treated and contaminant concentrations have been reduced to specific standards. In addition, the state contracting process is beginning, and requests for proposals are being sent out to solicit a pool of contractors.

Oregon
Dick DeZeeuw, Oregon Department of Environmental Quality

Dick DeZeeuw began by acknowledging the presence of Gary Campbell, from the board of International Fabricare Institute. DeZeeuw said that Campbell's efforts helped push through important amendments to Oregon's drycleaner cleanup fund program.

DeZeeuw said that new rules have been written to reform solvent surcharge fee structures. The new structure will go into effect January 1, 2002. It will replace the flat PCE tax that is currently costing users $30 per gallon. Under the new structure, annual fees and solvent fees will be reduced and other fees will be added. The PCE fee will be lowered to $10 per gallon, and the annual fee will be lowered from $1,000 to $500. A risk-based fee with three fee levels will exist. The lowest level will apply if PCE has not been used at a site. The next fee level will be charged if PCE was used at a site in the past, but is no longer being used. The highest fee will be charged to sites where PCE is currently being used. In addition, there is a revenue-based fee that increases as revenue increases. The legislation sunsets in 2006, at which point the law will be revisited and evaluated.

DeZeeuw said that there is currently $600,000 in the fund, which is as low as is comfortable. The program wants all sites to be assessed when they come into the program, but remediation has to be prioritized. The Oregon Department of Environmental Quality is replacing the existing method of contracting for cleanup work with one that will be less expensive and more convenient to work with on the local level.

DeZeeuw noted that 90 past and current sites have been identified in eastern Oregon, which is the least populous part of the state. He asked attendees to provide feedback on the following question: Should federal site assessment money be used to do site screening at these sites? A lively discussion ensued. The consensus was that this might have consequences as yet unforeseen and might start the program moving in a direction that could not be changed once initiated.

South Carolina
Craig Dukes, South Carolina Department of Health and Environmental Control

Craig Dukes echoed previous state reports by indicating that South Carolina is experiencing a budget shortfall, and that the administration tried to move $800,000 from their fund (which has a balance of $3 million) despite being enjoined by law from doing so.

Dukes said that the Department of Health and Environmental Control plans to dispense the $3 million fund to drycleaning sites. Currently, assessment has begun at 15 sites and is imminent at another 4; $1.66 million is committed for assessment at these 19 sites. Dukes noted that drycleaners using petroleum solvents are allowed to opt out of the fund, but that few are opting to do so.

Dukes said that solvent fees are difficult to collect. To remedy this, efforts are underway to replace the fees with a 2% drycleaner sales tax, which would be earmarked for the fund. This issue is being negotiated. Efforts are being made to retain staggered deductibles that benefit petroleum drycleaners entering the program with containment plans in place. Their deductible would be $1,000; if the deadline is missed, the deductible climbs to $25,000. Dukes stated that financial incentives are the most effective way of bringing people into the program. He said that most petroleum-based drycleaners do not think they have problems, but that potential liabilities are so great they are willing to enter the program.

Steimle commented that the deductible modification might encourage people to put in containment systems when their sites were already contaminated. Craig Dukes replied that the deductible modification was insignificant to the overall fund, but might help prevent future releases, which is a priority.

Tennessee
Steve Goins, Tennessee Department of Environment and Conservation

Steve Goins said that Tennessee has experienced significant budget cuts, and that this has affected hiring and travel. He said that Tennessee's drycleaner cleanup fund program has been in existence for 5 years. More money is being taken in than is being spent. (The fund has a balance of $5.6 million, and will receive another $400,000 to $500,000 in fees this month. Annual revenue has stabilized at $1.6 to $1.7 million despite a 30% reduction in solvent fees. The reduction has been offset mainly with the interest that the fund generates, which was $350,000 last year.)

In late September, a legislative package was submitted to change the program's fee structure. It is currently based on a drycleaner's number of full-time employees; the new legislation advocates replacing this system with a risk-based structure. Goins said that the Tennessee Department of Environment and Conservation is currently in the process of trying to define traditional and "green" solvents.

Goins said that Tennessee's drycleaner program is voluntary, and 50 sites have applied so far; 32 of these are active, and 18 are abandoned. Of the 50 sites, 34 or 35 are being assessed and 3 are closed. The program's obligation for current work is $1.6 million. Tennessee's program is a reimbursement program. A program member can also gain certification as a Certified Environmental Drycleaner. (About 300 drycleaners--30% to 40% of all drycleaners in the state--have such certification.) A site can come into the program without documentation of contamination, in which case the program does an initial basic determination to see if the site is contaminated.

Goins said that the Governor's oversight board oversees the program. Some of the board members regard the program as primarily regulatory, rather than remedial. The Tennessee Department of Environment and Conservation recently experienced a victory in promoting its remedial agenda: the agency convinced the board to require sites that participate in the program to follow best management practices (BMPs). Goins emphasized the usefulness of his agency's Compliance Calendar, an inexpensive outreach tool that includes air requirements, Resource Conservation and Recovery Act rules, and BMPs. He said the calendars are inexpensive and are popular with the drycleaners.

Wisconsin
Robin Schmidt, Wisconsin Department of Natural Resources

Robin Schmidt reported that Wisconsin has just completed its budget process, and the drycleaning fund had been left untouched. However, statutory changes, including a change in the deductible, will affect a number of drycleaners in the program. Although the fund currently has a balance of $3 million and annual revenue of $1 million, it will be close to zeroing out by the end of the year. The maximum reimbursement is $500,000 per site. There are two sites where this limit will be reached. Schmidt said that comprehensive statistics on the program will be available after a program review takes place in 2002 and is examined and commented upon by the state council overseeing the fund.

Among the statutory changes mentioned above:

Schmidt also mentioned that she wishes there were a program that combined air management requirements, hazardous waste requirements, and cleanup requirements for drycleaners, given how difficult it is for drycleaners to keep all the various requirements of different programs in mind.

SUBGROUP MEETINGS
Three Subgroups have been formed within SCRD. During the meeting, each Subgroup met in a breakout session to discuss the status of projects and future goals. Subgroup leaders were then asked to summarize what was discussed during the breakout sessions. Their summaries are presented below.

Program Development/Administration Subgroup
Chair: Doug Fitton, Florida

Fitton said that the Program Development/Administration Subgroup covered several topics during the breakout session. The group looked at their Cleanup Standards comparison table and decided to enhance it so that it includes information on whether a program's calculations are truly risk-based, as well as information on statutory rules and guideline options. The group feels that a major issue is prioritization mechanisms, and wants to have each member state give a presentation on this issue at the next meeting.

Other issues discussed by the Subgroup, and on which the group will take further action, were:

Technical Issues Subgroup
Chair: Bob Jurgens, Kansas

Bob Jurgens reported that the SCRD site profiles need additional modification. Thus, the Subgroup will contact the Oregon and Wisconsin SCRD representatives and ask for their help in obtaining the additional details. The group also took up the following issues and prospective tasks:

Outreach Subgroup
Chair: Robin Schmidt, Wisconsin

Robin Schmidt reported that activities were progressing nicely in the Outreach Subgroup. Although she feels SCRD could use its Web site even more often as an outreach tool, Schmidt said that the Web site receives thousands of "hits" a month and is operating smoothly. Steimle asked what sectors are using the Web site. While there is no way of determining this accurately, many "hits" are accounted for by commercial (i.e., ".com") entities. Schmidt said she thought that the site profiles, once more are posted, will draw more users to the site.

COALITION BUSINESS

Training Sessions
SCRD members discussed the desirability of holding only one formal training session (delivered by the National Ground Water Association [NGWA]) a year, and using the training time at the other biannual meeting for an exchange among SCRD members about their actual experiences in two to three pre-determined topic areas. This would complement the more theoretical training offered by NGWA and provide an opportunity for more in-depth discussion of practical, day-to-day issues.

Membership Issues
Henning moved that New Mexico be deleted from associate membership, as they had not participated even to the point of responding to e-mails in a year and a half. New Mexico was deleted from associate membership without a dissenting vote.

Henning then said that Louisiana, an associate member, had also had limited participation, and suggested that the new SCRD chair check with that state to determine the status of their program development and whether they are willing to participate more fully in SCRD.

With reference to states that could potentially be interested in SCRD membership, Henning noted that Texas and Utah were apparently not enacting legislation in the foreseeable future. Georgia and Arizona have expressed some interest, but neither state is seeking membership at this time.

Mission Statement
Henning said that the SCRD members have agreed to develop a mission statement. Attendees indicated that they had brought suggestions with them, and these were posted. A lively discussion ensued, at the end of which the following mission statement for SCRD was approved unanimously:

To provide a forum for states to share technical, programmatic, and environmental information to improve remediation of drycleaner sites.

Next Meeting
There were several suggestions for the site of the next meeting, which is to take place in late March or early April of 2002. Henning asked that each suggestion have some justification, such as a central location and/or accessibility to interesting sites to visit. Votes were taken to determine the three most likely sites, and the finalists were Kansas City, Nashville, and Orlando.

Election
Lisa Appel of South Carolina proposed that the term of office for the SCRD chair be extended from 1 year to 2. Henning suggested that Subgroup chairs also serve for 2 years. This was amended so that current Subgroup chairs would serve from the date of this meeting until the spring of 2003, and then new chairs elected in spring of 2003 would serve for 2 years after that. The membership then voted unanimously to approve the extensions of the terms for Coalition chair and subgroup chairs.

Henning then asked for nominations for a new chair. Dick DeZeeuw (of Oregon) was nominated and accepted. There were no other nominations, and DeZeeuw was unanimously voted as the chair of SCRD for the next 2 years. Fitton and Schmidt were asked to continue as chairs of the Program Development/Administration and Outreach Subgroups, respectively. They accepted.

CASE STUDIES

Public Meeting Experiences--Curry's Cleaners, Georgetown, South Carolina, and Market Place Site, Hilton Head, South Carolina
Craig Dukes, South Carolina Department of Health and Environmental Control

Dukes discussed his experiences at public meetings that were held regarding two different sites in South Carolina. (His presentation is included as Attachment B.) Dukes said that public meetings must be held to inform area residents and any other interested parties of proposed actions at a site, a process adopted from the Superfund regulations. The first meeting concerned a small drycleaning site, Curry's Cleaners, with an estimated cost of remediation of $18,000. A legal notice of the meeting was posted in the newspaper 2 weeks in advance. Residents within a quarter mile of the property were provided with a complete set of plans of the proposed activity. Dukes said he found two Web sites particularly useful for the latter activity, www.infospace.com and www.referenceusa.com (which can be used through libraries to find resident addresses within a quarter mile of a given location). Dukes mentioned that one of the hardest things was to tell the site owners that a public meeting had to be held. Site owners dislike the publicity of maintaining a contaminated site. For this reason, it is important to tell them that the meeting is required by law. Dukes also shared several other points gleaned from his experiences with Curry's and Market Place:

Curry's Cleaners, a small shop in a strip mall, opened for business in 1968. A small area behind the store showed high levels of PCE, though the contaminated area was only 320 square feet. After all the required public announcements were made and the required notices were sent out, the public meeting--the first under the program--was held. The attending staff members, contractors, property owners, and interested industry people numbered 13; they were met by two local citizens. The meeting went well.

The Market Place site in Hilton Head was the subject of Dukes's second public meeting. This is an old site at a shopping center near a high-end residential neighborhood. Although no difficulties have been encountered, Dukes noted that the feasibility study was not entirely comprehensive, and that the agency selected a remedy for the site that the study did not stress very much. Dukes said he expected that the area's residents, being relatively wealthy, would have more time to involve themselves with the issue of remediation at a site so close to their properties. However, when the meeting was held, only three residents appeared. They had one question, and it was easily satisfied. The written comment period ended with the program receiving only one comment, a question about C-sparging. A few comments and questions relating to other environmental issues were also received. Dukes said that although he is not completely enamored with the current procedure, since the estimated cost of a public meeting is about $10,000, he does not anticipate any changes in the process in the near future.

KMnO4 Injection and Co-oxidation--Butler Cleaners Site, Jacksonville, Florida
Doug Fitton, Florida Department of Environmental Protection

Doug Fitton presented information about the Butler Cleaners site (see Attachment C) and reminded his audience that they had discussed this site before. Potassium permanganate (KMnO4) has been injected at the site. This has led to significant reductions in measured PCE, followed by anomalous spikes after each injection.

The objectives at the site were typical:

Fitton presented maps of the site and adjoining areas showing several monitoring wells, two of which were slant wells designed to measure contamination under the building. Significant PCE contamination was found at one monitoring well, MW111, at the small source area near the rear door of the building. Between October 26, 1999, and August 2, 2000, there were four injections of KMnO4. In the first two of these, 10,000 gallons each of a 7.7-gram-per-liter solution were injected into the aquifer; in the next two, 10,000 gallons each were injected in wells at 10- to 15-foot depths. A total of about 2,500 pounds of potassium permanganate was used in the four injections.

Fitton presented a graph showing the pattern of contamination levels found at well MW111 over the course of the four injections. The initial injection resulted in a steep decline in contamination; however, the second injection was followed, after 2 or 3 months, by a rebound to nearly double the PCE concentration found originally. The third injection was then performed, and another steep decline to undetectable levels occurred, followed by another rebound (less robust than the first). The fourth and final injection followed the same pattern: a decline to undetectable levels, followed by a precipitous increase in the concentration of contaminant.

These results demanded further assessment, so the team first looked at the downgradient dissolved-phase plume, which ran between two monitoring wells and off the site. However, the contaminant levels were below natural attenuation default criteria, so this would not be the focus of the remedy. Next, extra borings were done that confirmed earlier lithological data. Fitton pointed out that subtle lithological changes may hold dense nonaqueous-phase liquid (DNAPL) up in a particular stratum and prevent it from being found down in the clay, as one might expect from a traditional model.

The team decided to do another test injection using tertiary butyl alcohol (TBA) as a co-oxidant to increase the efficacy of the KMnO4. TBA was chosen because bench-scale tests showed that it did not degrade the KMnO4 in solution at as great a rate as ethanol. Under budgetary and time pressures, the team performed the injection in May 2001. They preheated the solution to 110 degrees to increase the solubility of the permanganate. In addition, the formation was preheated by flooding it with 130-degree water. One thousand gallons of the TBA/KMnO4 solution was injected. The post-test measurements showed that PCE was lowered a mere 200 parts per billion (ppb), from 6,800 ppb before the test to a post-test level of 6,600 ppb. Recent sampling also indicated yet another rebound of PCE.

Fitton reported that, when hypotheses were considered as to why the injections apparently did not work, the best hypothesis seemed to be that the nonaqueous-phase liquid area extended further upgradient than had been thought, and that when the cosolvent was extracted (as required), the contamination was drawn back to the sampling well along with degradation products.

Fitton said that the treatment works in theory, but it clearly has not had a positive result up to this point. The remediation team will sink more wells to see if there is another source area that is confounding their results, and do another injection. He said their "takeaway message" was: Delineate your source area.

In response to questions from the meeting attendees, Fitton said that high concentrations of KMnO4 are more effective in degrading PCE. He said loading calculations indicated that 450 pounds of KMnO4 should destroy 290 pounds of PCE. He also said that for a site to be considered clean, it must either be clean for two consecutive quarters or for 1 year after remediation, with monitoring on a quarterly basis.

PRESENTATIONS ON BIOREMEDIATION TECHNOLOGIES

Introduction--Approaches Used To Stimulate In Situ Biological Dechlorination
Greg Sayles, U.S. EPA

Greg Sayles provided an overview of in situ biological degradation processes. (His presentation is included as Attachment D.) He started by making the following point: certain microbes can convert PCE into a harmless product (i.e., ethylene). Sayles said that biological remediation can occur under aerobic conditions, but that his presentation would focus on anaerobic reductive dechlorination processes in ground water. These involve the step-wise replacement of chlorine atoms with hydrogen atoms. PCE has four chlorine atoms; ethylene has none. When hydrogen (H2) interacts with PCE, the chlorine atom is cleaved and replaced with one hydrogen atom. In the process, PCE is converted to trichloroethylene (TCE) and the free chlorine reacts with the remaining hydrogen atom to form hydrochloric acid. Successive reductive dechlorination reactions take place until all of the chlorine atoms are stripped from the contaminant molecule, leaving ethylene as the final product. The process is summarized as follows:

PCE TCE 1,2-Dichloroethylene (1,2-DCE) Vinyl Chloride (VC) Ethylene

Problems arise when the reductive dechlorination process "stalls out" before reaching completion. Some of the compounds along the reductive dechlorination chain--vinyl chloride, in particular--are more toxic than the parent PCE molecule. "Stall out" occurs if (1) insufficient hydrogen atoms are available or (2) dehalorespiring bacteria are outcompeted by methanogenic bacteria. (Dehalorespirers use hydrogen to facilitate reductive dechlorination processes. Methanogens compete for the same hydrogen source, but use it to promote methanogenesis, which leads to methane formation. Some methanogens convert PCE to TCE or DCE, but they are unable to facilitate the process beyond this point.)

Sayles discussed strategies that have been developed to stimulate reductive dechlorination in the dissolved phase of ground-water plumes. Amendments can be added, he said, to enhance contaminant degradation and prevent "stall out." These amendments may include one, or both, of the following:

Sayles described the steps involved in successful stimulated bioremediation projects: (1) collecting data for basic site characterization, (2) performing microcosm tests in the laboratory, (3) conducting field pilot tests, and (4) introducing amendments at the full-scale level. He provided the following tips to help regulators determine whether data sets generated at the microcosm, pilot, and full-scale stages are of good quality. For microcosm-level data, he said, it is important to make sure that (1) controls were included, (2) site-specific aquifer sediments were used, (3) moles of PCE+TCE+DCE+VC+ethylene+ethane were conserved with time, (4) moles of chlorine match volatile organic compound data, (5) ethylene and ethane measurements are included, and (6) substrate depletion is observed. When reviewing pilot and full-scale data, he continued, regulators should look at (1) conservation of moles down to the flow path, (2) the formation of ethylene and ethane, (3) the generation of the proper moles of chlorine, (4) substrate depletion down to the flow path, and (5) consistent performance over time.

Sayles concluded by providing information about organizations that perform bioremediation research. These include the Remediation Technology Development Forum's Bioremediation Consortium (see www.rtdf.org) and the Interstate Technology Regulatory Cooperation (ITRC) Work Group (see www.itrcweb.org). He encouraged attendees to attend the Accelerated Bioremediation of Chlorinated Solvents course that is being offered in Tampa, Florida, in December 2001, or to participate in ITRC's Internet training program. He also listed documents (see Attachment D) that provide useful information.

Cl-out™ Bioremediation at Drycleaners
Mike Saul, Cl Solutions

Mike Saul described the Cl-out™ product. (His presentation is included as Attachment E.) Saul said that Cl-out™ facilitates PCE breakdown in situ by enhancing cometabolic reactions that occur under aerobic conditions. Cl-out™ consists of a "consortium" of naturally occurring microbes, all of which thrive under contaminated conditions and are capable of reducing chlorinated solvents. Saul noted that concern has been expressed about adding nonindigenous microbes to sites. In response to this criticism, he noted that: (1) microbes are transported to new environments all the time, (2) Cl-out™ is free of pathogens, (3) no harmful byproducts are associated with Cl-out™, and (4) adding Cl-out™ is no more dangerous than spilling beer or yogurt on a site. Saul described the mechanisms involved with the Cl-out™ degradation process. When Cl-out™ and 100% dextrose are injected into a contaminated subsurface, three things happen: (1) the cometabolism of dextrose prompts the conversion of PCE to TCE, (2) monooygenase is formed, and (3) this enzyme breaks TCE's double carbon bond, leaving the molecule vulnerable to other breakdown reactions that eventually lead to complete contaminant destruction.

Cl-out™ is available in liquid or freeze-dried form, Saul said, noting that the latter is cheaper and easier to handle. Freeze-dried Cl-out™ is placed in bags and shipped in drums. When site owners are ready to initiate remediation activities, the Cl-out™ bags are unfolded, placed in the drum, filled with water, and left overnight so the bacteria can become active. Dextrose is then added and the Cl-out™ solution is injected into the ground. Natural diffusion is relied upon to transport Cl-out™ through the subsurface. Thus, the technology is most effective in permeable areas and is not appropriate for use in subsurfaces with clay layers. The microbes perform most effectively when dissolved oxygen concentrations are at least 1 milligram per liter. Reinoculation is recommended on a 30-day cycle.

Saul said that Cl-out™ has mostly been used at large industrial sites, but that it has been applied at some small drycleaner sites as well. He presented results for the following sites:

Saul concluded by summarizing the advantages associated with Cl-out™. He stressed that the technology (1) does not require capital equipment; (2) facilitates complete contaminant destruction; (3) does not create harmful byproducts; (4) can be used across a variety of applications (e.g., at hot spots, near property lines); (5) does not generate residual soil, water, or air wastes; and (6) can be used as an augmentation for other technologies, such as monitored natural attenuation, soil vapor extraction, or pump-and-treat systems. He agreed to compile a package of case studies and to distribute these to SCRD members.

Bioremediation of Chlorinated Solvents Using Bioavailable Enhancement Technology (BET)™
Jennifer Martin, North Wind Environmental, Inc.

Jennifer Martin described BET™, a technology developed by Idaho National Engineering and Environmental Laboratory (INEEL) that is used to remediate chlorinated solvents. (Her presentation is included as Attachment F.) She said that high concentrations of sodium lactate are injected into the subsurface as part of the BET™ process. This substrate facilitates biodegradation by (1) acting as an electron donor and stimulating anaerobic reductive dechlorination in a plume's aqueous phase, and (2) enhancing the solubility of TCE so that it partitions out of source zones and enters the aqueous phase, where it mixes intimately with electron donors and degrades to ethylene via reductive dechlorination processes. Expanding on the latter, Martin said that BET™ can be used to treat complex source areas. Other innovative technologies, such as thermal techniques, chemical oxidation, and flushing, can do the same, but are typically associated with higher cost and risk.

Martin said that sodium lactate is not the only substrate that can be used in bioremediation projects. She said that the following factors should be considered when trying to determine which substrate is appropriate to use at a particular site: cost, longevity, desired radius of influence, vertical extent of the contamination, the aquifer's buffering capacity, the remoteness of the site, the substrate's demonstrated performance, and any potential impacts that the substrate is expected to have on the microbial community. She also listed some of the considerations that come into play when trying to identify an effective way to deliver substrates to the subsurface. These include: the volume requiring treatment, aquifer permeability, ambient flow rates, aquifer dispersivity, potential for preferential flow, viscosity and solubility of the donor solution, and transport characteristics.

Martin described a field test that was performed using BET™ at an INEEL site. The site, used as a disposal area between the 1950s and 1972, received organic and inorganic waste, low-level radioactive waste, and sanitary sewage. All of these waste streams were injected into the Snake River Plain Aquifer via injection well TSF-05. A 3-kilometer-long TCE plume has formed under the site. In 1996, a pump-and treat system was installed to address the contamination surrounding well TSF-05. The site's Record of Decision (ROD), however, suggested testing other technologies to determine whether the pump-and-treat system could be augmented or replaced by a more innovative technology. BET™ is one of the innovative technologies being tested at the site. A demonstration project is being conducted along a 500-foot-long section of the site's source area. In January 1999, high sodium lactate concentrations (1,140 liters of 60% sodium lactate) were injected in the source area on a weekly basis. After each injection, potable water was flushed through the injection well at 76 liters per minute for a 1-hour period. The test zone was monitored regularly. The monitoring results led investigators to cut back on the quantities of sodium lactate that were injected. In February 1999, the solution was lowered to 30%. In March, the percentage was lowered to 6%; in June, it was lowered to 3%. Even with these reductions, sufficient lactate buildup was observed. Thus, a moratorium was placed on injections: no injections were made between September 8, 1999, and February 2000. Monitoring results collected in October 2000 indicate that TCE has been driven to nondetect in some areas, and has decreased by half in others. Martin concluded the following: (1) BET™ accelerated mass transfer of TCE from the source area to the aqueous phase, where it could be biodegraded; (2) complete biodegredation of TCE and its daughter product were observed within a 40-mile radius of well TSF-05; and (3) $15 million could be saved by replacing the site's pump-and-treat system with BET™ (to address the source area) and natural attenuation (to address the dissolved-phase plume).

Before closing, Martin indicated that BET™ has also been tested at other sites, including Seal Beach Site 40, a drycleaning site in Nebraska, and the Distler Brickyard Superfund site. Projects are also pending in Washington, Tennessee, Massachusetts, and Missouri. Attendees expressed interest in learning more about the drycleaning site; Martin agreed to send SCRD members a contact name.

Hydrogen Release Compound (HRC™)
Presentations relating to the HRC™ technology are included as Attachment G.

Overview of the Technology
Jack Peabody, Regenesis, Inc.
Jack Peabody described the HRC™ technology, noting that it has been applied at 220 sites, and that a book has been written about the technology. He encouraged attendees to contact him for a copy.

Peabody said that HRC™ stimulates reductive dechlorination processes by acting as an electron donor. The HRC™ product is based on a three-carbon glycerol polylactate ester structure. When hydrated, HRC™ releases lactic acid, which is then metabolized by microbes to form other organic acid intermediates. Hydrogen is released as a byproduct, and this is used to fuel the reductive dechlorination of chlorinated hydrocarbons. The lactic acid is released in small quantities over a 9- to 18-month period. The slow release mechanism favors dehalorespirers over methanogenic bacteria. Peabody said that HRC™ has mostly been used to address dissolved phase plumes, but that some efforts are underway to utilize the technology in source areas.

Peabody discussed the delivery method used for HRC™: direct push technologies are used to introduce the material to the subsurface, high-pressure injection (1,000 to 2,000 psi) is used to create subsurface fractures, and HRC™ then travels via advective and diffusive flow. The technology can be used across a wide variety of site conditions, including areas characterized by clays or fractured bedrock. It can also be used to clean up areas as deep as 100 to 150 feet.

Peabody said that HRC™ has been used at some drycleaning sites, including Hayden Island Cleaners, Sunset Square Cleaners, Springdale Cleaners, and Majestic Cleaners. The results generated at the Hayden Island site have been presented at a Battelle conference. They indicate that HRC™ is about 67% cheaper than other technologies.

HRC™ Pilot Study: Springdale Cleaners
Kevin Parrett, Oregon Department of Environmental Quality

Kevin Parrett described the HRC™ pilot study conducted at the Springdale Cleaners. The site, which has been used as a drycleaner since the 1960s, is contaminated with PCE. (The contaminant leaked to the environment through the floor drain and sewer lines.) Efforts are underway to remediate the shallow aquifer, which extends 20 feet below ground surface and is characterized by a silty sand. No drinking water sources have been impacted by the site's contamination. There has been some concern about the potential for PCE to volatilize into buildings. Air samples are being collected to determine whether this concern is warranted. Some contaminants have been detected, but it is impossible to tell whether these contaminants are being emitted from the subsurface or from ongoing daily operational practices.

Parrett said that HRC™ was injected into the subsurface in two locations:

Bio-Rem H-10 and Its Effect on Drycleaning Solvents
Tom McCurdy, Bio Rem USA, Inc.

Tom McCurdy described the H-10 product, noting that it can be used to degrade chlorinated solvents in situ. The product, a proprietary blend of micronutrients and microbes, contains no pathogens or trace contaminants. Once injected into the subsurface, H-10 interacts with indigenous dissolved oxygen. In the process, chlorinated solvents are mineralized through a series of microbe-assisted chemical reactions. The microbes remain active until contaminants disappear.

McCurdy said that Bio Rem USA, Inc., has used bioremediation technologies in Canada, Eastern Europe, and 25 U.S. states. The technology has mostly been used to address sites contaminated with petroleum products (e.g., gasoline and crude oil). Some efforts have been initiated, however, to deploy the technology at drycleaning sites. McCurdy described one such site, noting that it was located in Long Island, New York. Prior to treatment, PCE was present at 67 ppb, TCE was detected at 8,000 ppb, and DCE was recorded at relatively high concentrations as well. All of these concentration fell below 2 ppb within 7 months of the application of H-10 to the subsurface. These results suggest that H-10 has strong potential as a remedial tool at small drycleaning sites. McCurdy expressed interest in working with SCRD members to explore this application more extensively.

McCurdy provided information about H-10's merits, noting that the product can be used across a wide temperature (38 to 120 degrees Fahrenheit) and pH (5 to 9) range, can tolerate salinity levels up to 6%, and can be used across a wide variety of soil types (e.g., loose sands to tight clays). In addition, H-10 exhibits remedial properties toward more than 200 hydrocarbon compounds, including a variety of chlorinated solvents. Also, the technology can be used in conjunction with other treatment methods, requires no on-site equipment or excavation, and can be used without disrupting business operations. McCurdy said that costs associated with H-10 application range from $6,000 to $30,000. Cleanup is guaranteed: if cleanup standards are not met, Bio Rem USA, Inc., reimburses site owners.

McCurdy explained the steps that are taken when an H-10 application is implemented. First, consultants define the plume, collecting information about the plume's contaminant concentration distribution, the plume's vertical and horizontal extent, soil strata and confining layers, and soil permeability. This information is used to determine how the H-10 product should be applied and how much needs to be injected. A permit is then obtained to approve the subsurface injection. Once the injection takes place, consultants monitor the site regularly to evaluate the treatment's performance.

Blacks's Drycleaner - Site Demonstrations of Bioremediation Injections
Bruce Gilles, Oregon Department of Environmental Quality

SCRD members went on a field trip to Black's Drycleaner on the afternoon of October 4. Before going, Bruce Gilles provided background information about the site and the bioremediation pilot projects that have been initiated there.

The site has been used as a drycleaning facility since the 1950s. Stoddard was used as a cleaning solvent until 1958, at which time facility operators switched to PCE. Soil contamination has been detected throughout the site; investigators believe it entered the environment via side-door dumping, underground storage tank leaks, and spills near the drycleaning machines. Some of the contaminants extend beyond the site's footprint, and lie beneath an apartment building. The neighbors are furious about the contamination, and many public meetings have been held to determine what should be done to remediate the situation.

Gilles said that the Oregon Department of Environmental Quality is currently involved with the site. The agency has three objectives: (1) address immediate source areas, (2) appease community members, and (3) collect performance data to evaluate final remedies. As part of the latter objective, Gilles said, two bioremediation pilot tests have been established. One of the tests is evaluating Cl-out™; the other is analyzing BET™.

After Gilles completed this introduction, the attendees were escorted to buses and taken to the Black's Drycleaner site. This concluded the formal portion of the meeting. Henning thanked all of the attendees for their participation.


 

Attachment A: Final Attendee List
State Coalition for Remediation of
Drycleaners (SCRD) Meeting

Hotel Vintage Plaza
Portland, Oregon
October 3-5, 2001

 

 

Lisa Appel
South Carolina
Department of Health &
Environmental Control
2600 Bull Street
Columbia, SC 29201
803-896-4060
Fax: 803-896-4001
E-mail: appellr@columb34.dhec.state.sc.us

Marc Biondi
Research Attorney
Hazardous Waste
Management Branch
Georgia Department of Environmental Protection
205 Butler Street, SE
Floyd Tower East
Suite 1462
Atlanta, GA 30334
404-657-8600
Fax: 404-657-0807
E-mail: marc_biondi@dnr.state.ga.us

Gary Campbell
International Fabricare Institute
Campbell Cleaners
Corvallis, OR

George (Dave) Davis
Chief, Environmental Assessment Section
Alabama Department of Environmetnal Management
1400 Colliseum Boulevard
Montgomery, AL 36130-1463
334-271-7755
Fax: 334-270-5631
E-mail: gdd@adam.state.al.us

Dick Dezeeuw
Oregon Department of Environmental Quality
811 Southwest 6th Avenue
Portland, OR 97204
503-229-6240
Fax: 503-229-6954
E-mail: dezeeuw.dick@deq.state.or.us

Craig Dukes
South Carolina Department of Health & Environmental Control
2600 Bull Street
Columbia, SC 29201
803-896-4057
Fax: 803-896-4001
E-mail: dukescv@columb34.dhec.state.sc.us

Pat Eriksen
Administrator
Drycleaner Environmental Response Trust Fund of Illinois
814 Pierce Street
P.O. Box 9400
Sioux City, IA 51102
712-252-4041
Fax: 712-252-5974
E-mail: hpe@willconsult.com

Doug Fitton
Bureau of Waste Cleanup
Florida Department of Environmental Protection
2600 Blair Stone Road
Tallahassee, FL 32399-2400
850-488-0190
Fax: 850-922-4368
E-mail: douglas.fitton@dep.state.fl.us

Bruce Gilles
Oregon Department of Environmental Quality
2020 SW 4th Avenue
Portland, OR 97201
503-229-6662
E-mail: Bruce.A.Gilles@state.or.us

Elaine Glendening
Oregon Department of Environmental Quality
811 SW 6th Avenue
Portland, OR 97204
503-229-6015
E-mail: glendening.elaine@deq.state.or.us

Steve Goins
Program Manager, Superfund Division, Dry Cleaner Environmental Response Program
Tennessee Department of Environment & Conservation
401 Church Street
L&C Annex - 4th Floor
Nashville, TN 37243-1538
615-532-8599
Fax: 615-741-1115
E-mail: sgoins@mail.state.tn.us

Leo Henning
Section Chief, Bureau of Environmental Remediation Assessment & Restoration
Kansas Department of Health & Environment
Forbes Field - Building 740
Topeka, KS 66620
785-296-1914
Fax: 785-296-4823
E-mail: lhenning@kdhe.state.ks.us

Bob Jurgens
Kansas Department of Health & Environment
Forbes Field - Building 740
Topeka, KS 66620
785-291-3250
Fax: 785-296-4823
E-mail: bjurgens@kdhe.state.ks.us

Perry Kelso
Ecology & Environment, Inc.
1950 Commonwealth Lane
Tallahassee, FL 32303
850-574-1400
Fax: 850-574-1179
E-mail: pkelso@ene.com

William Linn
Environmental Engineer
Bureau of Waste Cleanup
Florida Department of Environmental Protection
2600 Blair Stone Road
Tallahassee, FL 32399-2400
850-488-0190
Fax: 850-922-4368
E-mail: william.linn@dep.state.fl.us

Jennifer Martin
Hydrogeologist II
North Wind Environmental, Inc.
P.O. Box 51174
Idaho Falls, ID 83405
208-528-8718 x.147
Fax: 208-528-8714
E-mail: jmartin@nwindenv.com

Tom McCurdy
Technical Representative
Bio Rem USA, Inc.
P.O. Box1506
Cherry Hill, NJ 08034
856-810-3402
Fax: 856-810-3402
E-mail: tomm@biorem.com

Bruce Nicholson
Head, Special
Remediation Branch
North Carolina
Superfund Section
401 Oberlin Road - Suite 150
Raleigh, NC 27605
919-733-2801
Fax: 919-733-4811
E-mail: bruce.nicholson@ncmail.net

Mark Ochsner
Hydrogeologist
Ecology & Environment, Inc.
333 SW Fifth Avenue - Suite 608
Portland, OR 97201
503-248-5600
E-mail: mochsner@ene.com

Edward Patnode
Administrative Specialist
Hazardous Waste Division
Oregon Department of Environmental Quality
811 SW 6th Avenue
Portland, OR 97204
503-229-6783
Fax: 503-229-6977
E-mail: patnone.ed@deq.state.or.us

Kevin Parrett
Project Manager/
Environmental Scientist
Northwest Region
Oregon Department of Environmental Quality
2020 SW Fourth Avenue
Suite 400
Portland, OR 97201
503-229-6748
Fax: 503-229-6945
E-mail: parrett.kevin@deq.state.or.us

Jack Peabody
Western Regional Manager
Regenesis
220 Devonshire
Pleasant Hill, CA 94523-2079
925-944-5566
Fax: 925-944-5625
E-mail: jack@regenesis.com

Lance Peterson
Vice President
North Wind Environmental, Inc.
P.O. Box 51174
Idaho Falls, ID 83405
208-528-8718 x.170
Fax: 208-528-8714
E-mail: lpeterson@nwindenv.com

Cathy Rodda
Hydrogeologist
Remediation & Redevelopment
Wisconsin Department of
Natural Resources
101 North Ogden Road
P.O. Box 208
Peshtigo, WI 54157
715-582-5048
Fax: 715-582-5005
E-mail: RoddaC@dnr.state.wi.us

Mike Saul
Vice President
CL - Solutions
11231 Cornell Park Drive
Cincinnati, OH 45242
513-247-0404
Fax: 513-489-2533
E-mail: MTS@CL-SOLUTIONS.COM

Gregory Sayles
Chemical Engineer
National Risk Management Research Laboratory
U.S. Environmental
Protection Agency
26 West Martin Luther
King Drive (420)
Cincinnati, OH 45268
513-569-7607
Fax: 513-569-7105
E-mail: sayles.gregory@epa.gov

Randy Schademann
Hydrogeologist
Ecology & Environment, Inc.
6405 Metcalf
Cloverleaf Building 3
Overland Park, KS 66202
913-432-0670
E-mail: rschademann@ene.com

Robin Schmidt
Remediation and Redevelopment
Wisconsin Department of Environmental Resources
P.O. Box 7921
101 South Webster Street
Madison, WI 53707
608-267-7569
Fax: 608-267-7646
E-mail: schmirr@dnr.state.wi.us

Juho So
Drycleaner Environmental Response Trust Fund of Illinois
1000 Tower Lane - Suite 140
P.O. Box 7380
Bensenville, IL 60106-7380
800-266-0663
Fax: 630-741-0026
E-mail: jso@willconsult.com

Richard Steimle
Technology Innovation Office
U.S. Environmental
Protection Agency
401 M Street, SW (5102G)
Washington, DC 20460
703-603-7195
Fax: 703-603-9135
E-mail: steimle.richard@epa.gov

Scott Stupak
North Carolina
Superfund Section
401 Oberlin Road - Suite 150
Raleigh, NC 27605
919-733-2801 x.241
Fax: 919-733-4811
E-mail: scott.stupak@ncmail.net

Dale Trippler
Principal Planner
Policy and Planning Division
Minnesota Pollution
Control Agency
520 Lafayette Road, N
St. Paul, MN 55155-4194
651-297-8483
Fax: 651-297-8676
E-mail: dale.trippler@pca.state.mn.us

Cliff Walkey
Oregon Department of Environmental Quality
2146 NE 4th Street - Suite 104
Bend, OR 97701
541-388-6146 x224
Fax: 541-388-8283
E-mail: Cliff.Walkey@deq.state.or.us

Pam Wilson
Environmental
Assessment Section
Hazardous Waste Branch
Land Division
Alabama Department of Environmental Management
P.O. Box 301463
Montgomery, AL 36130-1463
224-271-7756
Fax: 334-270-5631
E-mail: pwilson@adem.state.al.us

        Technical and Logistical Support Provided By:

Andrea Auerbach
Eastern Research Group, Inc.
110 Hartwell Avenue
Lexington, MA 02421
781-674-7272
Fax: 781-674-2906
E-mail: aauerbac@erg.com

Cheryl Joseph
National Ground Water Association
601 Dempsey Road
Westerville, OH 43081
800-551-7379
Fax: 614-898-7786
E-mail: cjoseph@ngwa.org

Andreas Lord
Eastern Research Group, Inc.
110 Hartwell Avenue
Lexington, MA 02421
781-674-7381
781-674-2851

Carolyn Perroni
Environmental Management Support, Inc.
8601 Georgia Avenue
Suite 500
Silver Spring, MD 20910
301-589-5318
Fax: 301-589-8487
E-mail: carolyn.perroni@emsus.com

 

Attachments B through G

Attachments B through G are available on the Internet. To view these attachments, visit the SCRD home page at http://www.drycleancoalition.org, click on the "Members" button, then click on the "Meetings" button. The attachments will be available as part of the October 2001 meeting summary.