State Coalition for Remediation of Drycleaners Meeting

State Coalition for Remediation of Drycleaners Meeting

Holiday Inn Hotel and Conference Center

Scottsdale, Arizona

April 17-20, 2001


Leo Henning, chairperson of the State Coalition for Remediation of Drycleaners (SCRD), welcomed attendees to the meeting. Attendees included representatives from state agencies, the U.S. Environmental Protection Agency (EPA), industry, consulting firms, and academic institutions (see Attachment A).

Richard Steimle, a representative from EPA's Technology Innovation Office, provided background on the SCRD. A few years ago, he said, EPA noticed that state environmental programs were beginning to use innovative technologies to remediate drycleaner sites. To help the states exchange information on effective technologies and methods, EPA encouraged state representatives to form SCRD. Although EPA helped create SCRD and provides federal oversight to the group, SCRD is not an EPA program—it elects its own officers and sets its own goals. The National Ground Water Association (NGWA) supports SCRD by providing technical training to SCRD members and helping to fund their travel.

States currently participating as SCRD members include Alabama, Florida, Illinois, Kansas, Minnesota, Missouri, North Carolina, Oregon, South Carolina, Tennessee, and Wisconsin. While some coalition members are just starting to develop cleanup programs for drycleaners, Steimle noted, others have already tested innovative technologies at drycleaning sites and are evaluating their success. By participating in SCRD, states avoid duplicating efforts, making each other aware of the pitfalls and barriers that have already been faced. Steimle said that SCRD is open to any state interested in cleaning up drycleaner sites. More information on SCRD and its activities can be found at

Steimle said that the SCRD is collecting site profiles from its member states. Site profiles are one-page reviews that summarize site conditions at a particular drycleaning site, cleanup efforts, technologies used, remediation costs, contact information, and methods used to address challenges. Primarily, Steimle said, the profiles are being developed to help state representatives understand why specific technologies are chosen for particular sites and to learn what has worked best in different situations. Bob Jurgens of the Kansas Department of Health and Environment (KDHE), who is collecting the site profiles, asked attendees to forward site profiles to him or to upload them directly to the SCRD Web site. He said that site profiles do not have to be about cleaned-up sites only—they can also include pilot studies. To increase the number of site profiles, Steimle said, EPA will hire two interns to collect information and write up site profiles. The first intern will travel to Wisconsin, Oregon, and Kansas, spending a week in each state. The second intern will work for a year in Florida to analyze the extensive and comprehensive information that state has collected. As a result of this effort, 60 to 70 additional site profiles will be produced.



David Davis of the Alabama Department of Environmental Management (DEM) said that legislation has passed that allows the Alabama DEM to develop regulations for their drycleaner site cleanup program. The regulations should be completed within the next 6 months. The main challenge DEM faces involves funding. The agency must receive $1 million through the program's funding mechanisms by May 2002. If the money is not received by that time, the program will be closed and all contributing drycleaner participants will get their money back. The program's funding mechanism is 2% of drycleaner gross sales, with a $25,000 cap per company. The program, which is voluntary, has drawn a little more than 100 drycleaners to date. Davis also said that a board will be formed to rank the drycleaners, allocate funds, and resolve concerns that smaller businesses have expressed about getting enough money for cleanup, The board will be appointed by the governor and approved by the legislature.


Doug Fitton of the Florida Department of Environmental Protection (DEP) noted that Florida's drycleaning program has experienced financial problems this fiscal year. First, he said, the program lost a significant amount of funding this year, because the state faced a shortfall last year and needed to cut funding for many programs. Second, the program did not receive its annual installment of funding until March of this year; these monies must all be spent by the end of June. Currently, only about $25,000 is available to support the program until additional funds are received at the beginning of July. Although this past fiscal year has been difficult financially, Fitton said, it appears that the program will be fully funded next year with a $12 million budget.

Fitton reported on the program's accomplishments to date. Florida has completed 186 site assessments, and 19 additional sites are currently undergoing the assessment process. Of the sites assessed, 45 are now being remediated. A number of innovative remediation technologies are being used including Hydrogen Release Compound (HRC™), Fenton's reagent, potassium permanganate, and ethanol flushing. In addition, Fitton said, a co-oxidation/co-solvent technology that uses alcohol and potassium permanganate has just been approved for one drycleaner site. Proposals have also been submitted for Oxygen Release Compound (ORC®), six-phase electrical heating, and bioaugmentation by microbial inoculants.

Fitton said that Florida has established a database to track the program's progress, accomplishments, and lessons learned. (Florida has established a new position in DEP to collect, manage, and analyze drycleaning site data.) Fitton said that he will present an analysis of Florida's drycleaning site data at the International Containment and Remediation Technology Conference and Exhibition that will be held in Orlando, Florida, this June. Abstracts of Fitton's analysis are available for review.

Davis asked whether DEP coordinates with the state Resource Conservation and Recovery Act (RCRA) program. Fitton said that Florida's legislation directs DEP to develop memorandums of understanding with the RCRA program concerning overfiling. In addition, new legislation has been proposed that would make closing a site under the drycleaning program equivalent to filing a record of closure. If this law is passed, overfiling will no longer be a concern.


Juho So and Pat Eriksen of the Drycleaner Environmental Response Trust Fund of Illinois noted that the state's program faces a funding challenge. To help determine how much additional revenue the fund requires, the state legislature has asked for an estimate of the fund's ultimate liability. Unfortunately, this will probably take more than 3 years to determine. So and Eriksen said that there is currently $6 million in the fund, and that current funding mechanisms include a $1,500 license fee and a solvent tax equaling $3.50 per gallon of perchloroethylene (PCE) and $0.35 per gallon on petroleum-based solvents. Two groups of drycleaners are currently holding discussions to identify ways to raise new revenue. Possible revenue sources discussed by the groups include charging a 2% gross receipts tax, quadrupling solvent fees, and removing license fees. A retired judge is acting as a mediator between the two groups. After 6 weeks, the groups still cannot agree on a fair method of generating new revenue. So and Eriksen also noted the following miscellaneous points:


Bob Jurgens of KDHE provided an update on the Kansas drycleaner cleanup program's accomplishments. The program annually receives approximately $1.4 million from 103 facilities. Not as many facilities are signing up as in the past, since many facilities that are owned by larger companies are becoming more centralized. In addition, eight facilities have refused to register for the program. KDHE will undertake enforcement actions against these. It is hoped that, after a fine is levied on one facility, all the other facilities will register with the program to avoid fines.

Jurgens said that 62 sites have been accepted into the state's cleanup program. About half of the sites in the program are undergoing remediation efforts. Jurgens reported that, in Kansas, traditional cleanup technologies (e.g., air sparging, soil vacuum extraction, and pump and treat) have been working better than more innovative technologies (e.g., sodium permanganate). The main problem with the innovative technologies was that, after an initial lowering of contaminant concentrations, concentrations rebounded to high levels. For example, Kansas is using permanganate technology at a site in Wichita, but is not achieving favorable results. Although technicians have been experimenting with better delivery techniques, it is getting to the point where the technology is no longer cost-effective at this site.

Jurgens discussed two other drycleaning sites in detail. At one site in Salina, Kansas, remediation efforts succeeded after KDHE removed a contaminant source. At another site in Hutchinson, Kansas—one of KDHE's biggest remediation projects—remediation efforts have been ongoing and somewhat successful with one source area below MCLs and two other areas still undergoing remediation at the source and downgradient. At this site, remediation efforts have been shut down for a year, due to a natural gas release. (Natural gas migrated under the city, emerged to the surface through old salt wells and mines, and caused extensive damage to city buildings.)

As a warning to other states, Jurgens noted that some drycleaners have asked for compensation for business that they lost while remediation efforts were ongoing at their sites. Make sure, Jurgens advised, to be very clear up front with site owners about what will happen during site assessment and remediation.

Jurgens said that drycleaning facilities are inspected for environmental compliance. This year KDHE has seen a significant increase in environmental compliance compared to the last round of inspections—from 75% to 80% not compliant down to only 25% not compliant. KDHE suspects that the state's outreach and technical assistance efforts are responsible for the improved compliance rates. These efforts involved distributing a newsletter, working with drycleaner trade associations, and collaborating with the state small business environmental assistance program to promote pollution prevention and secondary containment.

Henning mentioned that Kansas just completed a strict monitored natural attenuation (MNA) policy. The policy states that if a site has MNA as a chosen remedy, the site owner must own all of the property that has been impacted by the release or must get a letter from all entities that will be impacted by that remedy. Also, the site owner must develop a contingency plan, which must be approved by KDHE, that outlines what will be done at the site if MNA fails. The state also requires a performance bond for the site, in case the owner cannot pay for remediation in the future. (KDHE's major concern is that owners are choosing MNA as a remedy, going out of business or bankrupt, and then not having any funds to use a more aggressive remedy.) The state holds the bond until remediation is completed.


Harold Ethridge of the Louisiana Department of Environmental Quality (DEQ) said that drafting the state's drycleaner cleanup program has proceeded more slowly than DEQ anticipated. The program will probably not come into being until 2003. The slowdown has occurred because DEQ is in the process of reorganizing itself and is shifting to a paperless office. Once the program is developed, Louisiana will make registration in the program mandatory. DEQ will enforce this requirement by fining——or bringing felony charges against—solvent distributors that deliver solvents to unregistered drycleaners. Ethridge said that the Louisiana government does not know exactly how many drycleaning sites are in the state, but that some data—provided by a now-defunct air quality program that tracked drycleaners using PCE—indicate that 620 drycleaners are in the state. Ethridge assumes that the real number is probably twice as large, noting that some drycleaners are using non-PCE solvents and are not required to report to the state, and that some that are using PCE are probably not reporting as required.

Drycleaners in Louisiana and in neighboring Mississippi are part of a joint trade association that is beginning to look at ways to address remediation issues. Ethridge will recommend to the association an environmental fee on gross receipts that will be passed on to their customers. He will not act as a negotiator between the association and the state legislature.


Dale Trippler from the Minnesota Pollution Control Agency provided an update on the state's drycleaner fund program. Minnesota, he said, is spending $300,000 on cleanups each year. Revenue is close to $700,000, and the state continues to build up the fund. The program handles between 5 and 10 sites at a time. Currently, four large sites are being remediated; this number should increase over time.

Trippler said that his agency is considering a reorganization plan that might lump the drycleaner fund into a more general remediation fund. Drycleaners in the state are upset with this plan, because they will need to continue to pay fees at the same rate as before. If the drycleaner fund were left alone, they would soon be able to pay reduced fees by using the interest gained on the unspent balance of the fund to offset their annual and product fees. Another looming crisis for the state drycleaner program, Trippler said, is that the state government might shut down on July 1 due to a budget dispute between the governor and legislature.


Tim Eiken and Jim Belcher from the Missouri DNR said that Missouri established a drycleaner cleanup program in August 2000. The DNR is currently drafting regulations for the program. Fee collection has already been initiated. Sources of revenue include an annual registration fee for all active drycleaners ($500, $1,000, or $1,500 depending on the amount of PCE used) and a solvent surcharge fee ($8 per gallon of PCE and $0.80 per gallon of petroleum-based solvents) that is paid and reported by solvent distributors and suppliers on a quarterly basis. Eiken and Belcher suspect that two-thirds of the program's revenue will come from solvent surcharge fees and one-third will be generated by registration fees. A database was used to identify drycleaners that are expected to pay into the fund. The database listed drycleaners that are required to report solvent use to the state air pollution control program. The air pollution database listed 350 drycleaners, but Missouri estimates that there are close to 600 drycleaners. As the registration process continues, more revenue will be added to the cleanup fund, which currently holds $100,000.

The program should be up and running by late 2002. The law that established the drycleaning program states that no employees may be hired and no drycleaner funds may be spent until July 2002. At that point six full-time employees will be hired to initiate site assessments.

New York

Jim Harrington, of the New York State Department of Environmental Conservation, said that New York is starting to pay close attention to drycleaning sites. To date, however, no drycleaner cleanup program has been established. Harrington said that New York has started cleaning up drycleaning sites that are listed on the state's inactive hazardous waste site list. This list includes sites that must be cleaned up because they pose a significant threat. Other drycleaning sites are being addressed through a voluntary cleanup program.

New York is undertaking a study to determine the number of drycleaner sites in the state—there are probably more than 7,000 active drycleaners in New York—and to map the locations of sites that have the potential to impact the state's 18 primary aquifers. This mapping effort is being undertaken to determine which sites pose the most risk. To complete this study, Harrington has accessed a number of sources including the New York Department of Health and Air Pollution Control program, and hired a consultant to search through the yellow pages. The main challenge has been determining the locations of historical sites. Harrington asked attendees to share lessons learned if they had conducted similar studies. Bruce Nicholson of the North Carolina Superfund Section suggested that Harrington work with a drycleaner trade association to obtain additional information. Fitton suggested talking with solvent suppliers, since they have lists of drycleaner clients. Craig Dukes of the South Carolina Department of Health and Environmental Control (DHEC) suggested using the Internet to look through city directories.

Harrington said that New York has experienced some problems with innovative technology, noting that the difficulties are not always technical in nature. At one site, he said, a feasibility study identified in-well air stripping as an appropriate and cost-effective remedy, but this remedial strategy had to be abandoned because the state did not receive enough bids from contractors interested in deploying the technology. (In New York, if a contract does not receive three bidders, a different technology must be used.) Harrington said that other states need to be aware of this issue. He also mentioned a problem at another site: dealing with rebounding contaminant concentrations after using permanganate as a cleanup technology.

North Carolina

Nicholson and Lisa Taber of the North Carolina Superfund Section reported that steps are being taken to operationalize North Carolina's drycleaning cleanup program. The state Environmental Management Commission recently adopted rules that define the structure of the program. The program will be voluntary, and sites will need to petition the state to join the program. After receiving a petition package, the state will certify the site and site assessments can begin. Remediation will begin in 2003.

Revenue for the program is already being generated—$900,000 per year, although this amount will multiply due to an upcoming increase in the PCE solvent tax (from $5.85 to $10 per gallon). An additional influx of $8 million per year will be realized starting in 2003, when a sales tax on drycleaning begins to be earmarked to the drycleaning fund.

In other news, Nicholson said, the drycleaning program is working with the state RCRA program to develop an approach that will provide relief on some cleanups and waste handling. Also, the state legislature is considering a bill that might require a uniform risk-based approach for all remediation programs, including the drycleaning program. The state's chemical industry is in support of this bill. Nicholson asked for advice from other states that have developed risk-based rules.


Dick DeZeeuw from the Oregon DEQ distributed a fact sheet describing the current status of the state's drycleaner program. The fact sheet showed that revenue generated from fees has been flat for a few years, at about $700,000. It also showed that in the first two years of the program most of the fund was spent on program development and administration while in the last three years the majority of money was spent on cleanup. In fiscal year 1999 the program spent more money than it received. This happened partly because the number of sites being cleaned up increased and partly because of increased costs from the state Department of Revenue (which incurred additional costs for dealing with the Y2K problem) and a change in the law that allowed fees to be paid quarterly instead of annually. Due to budget constraints, the program had to prioritize its sites, and for the first time is putting sites on hold—ten, to be exact. To date, the program has cleaned up seven sites. Six other sites are being assessed, and another four are undergoing remediation.

DeZeeuw said that Oregon's legislature is considering a bill that will make several major changes to the drycleaning program. The bill would change the fee structure, require DEQ to develop a list of all sites eligible to be cleaned up, and clarify much of the language that has proven to be difficult to administer. Drycleaners are in support of the bill. The Oregon DEQ supports many of the changes, but it does not support the new fee structure that is proposed because DEQ fears it will reduce revenue.

DeZeeuw said that indoor air quality is becoming more relevant as a pathway of concern at drycleaning sites in Oregon. He asked if other states were encountering this and whether it might be a useful topic for discussion at future SCRD meetings. The Oregon DEQ has detected airborne PCE and suspects that it comes from contaminants in ground water or soil that exceed risk-based levels. DeZeeuw noted that subsurface contamination at active facilities is difficult to distinguish from releases from drycleaning machines as the source of indoor air concerns.

Kevin Parrett, also of the Oregon DEQ, spoke about results obtained using HRC™ technology at drycleaning sites in the state. Parrett said that Regenesis markets the technology and provided free field demonstrations. These demonstrations were at three sites, which had contamination levels ranging from low to very high. At each site, HRC™ was injected in a grid area, and remediation took about a year to complete. Even at the most highly contaminated site, PCE concentrations were lowered significantly, sometimes to nondetect. There was a corresponding increase in dichloroethylene (DCE) and vinyl chloride. Although Regenesis claims that the results prove that HRC™ is effective at these sites, Oregon DEQ plans to monitor the sites over the next few years to determine whether rebounding will occur. At a minimum, Parrett said, the results show that HRC™ is effective at reducing contaminants on an interim basis until a more permanent remedy can be implemented.

Harrington asked if the Oregon DEQ identified the source of the PCE contamination at the sites that were remediated with HRC™. Parrett said that at the most contaminated site, the source is probably residual dense nonaqueous-phase liquid (DNAPL) along the sewer line. Although Regenesis says HRC™ can eliminate DNAPL sources, the Oregon DEQ is not sure whether this has happened. Juho So expressed concern that HRC™ creates more toxic compounds, such as vinyl chloride. Even though an HRC™-treated site might meet the standard for a no-further-remediation letter, So said, it would ultimately be more toxic. Parrett responded that the vinyl chloride concentration increased at the most contaminated site (up to a few thousand parts per billion), but no buildup of vinyl chloride was detected in the air. In this case, since the shallow aquifer beneath the site is not designated for beneficial use, and people living near the site are drinking municipal water, the increases in vinyl chloride concentration were not a public health concern. In time, Parrett believes, the vinyl chloride will naturally attenuate. He did note that if vinyl chloride is at the edge of a plume, ORC® could be injected to address the contaminant.

South Carolina

Dukes said that his state's drycleaning fund is receiving less revenue than in the past from solvent fees. He believed this is because drycleaners are either using solvents more efficiently or going out of business. At this rate, Dukes expects the program to go bankrupt in 3 or 4 years. To avoid this, the South Carolina DHEC is talking to participating drycleaners about changing the program's funding structure. In addition, Dukes is meeting with South Carolina drycleaners that use petroleum-based solvent to try and convince them to join the fund. Some of these drycleaners have shown some willingness to join, but in exchange, have asked DHEC to push the legislature to divert money they pay in sales tax to their fund fees. There is a lawsuit already filed against the state regarding the sales tax; the drycleaners might drop that lawsuit in exchange for the diversion of the tax to the fund.

Dukes cited another development that will have a dramatic impact on drycleaners: many South Carolina drycleaners located in strip malls will have to close up or move, because one of the largest real estate holders of strip malls in the state is no longer willing to renew drycleaner leases. Fitton mentioned that something similar happened in Florida as well. Dukes said that DHEC hopes to begin assessing 10 drycleaning sites per year. To date, assessments have been completed for five sites; remedial decisions will soon be completed for three of these.


James Gilbert and Steve Goins of the Tennessee Department of Environment and Conservation (DEC) reported on their state's drycleaner program. Currently, funds can be used to clean an entire site if the spill is caused by drycleaner solvents. (The deductible for cleanup is 25% for abandoned sites and 5% to 15% for active sites, depending on their size.) Thirty-three sites are in the initial investigation phase; Gilbert and Goins expect at least three of these sites to be remediated by next year. Fifty additional sites are already in the cleanup phase of the drycleaning program. The program recently was reviewed at a sunset hearing and has been extended through June 30, 2007.

Revenue for the drycleaning fund has leveled off in recent years, although there is currently $5.8 million in the fund. Gilbert and Goins believe that the decrease in revenue is due, in part, to the fact that drycleaners are using PCE more efficiently.

The Tennessee DEC is proposing a number of changes to the state legislature. These will address a number of issues, including expanding the definition of drycleaning solvents to include alternative drycleaning technologies and changing the annual registration fee to a flat fee, a fee based on solvent usage, an environmental fee, or a sales tax diversion rather than basing it on the number of full-time employees working at a facility. Tennessee DEC will also try to address the fact that, as time goes by, it becomes more cost-prohibitive for inactive or abandoned sites to join the program. (There is no cutoff for when inactive or abandoned sites can join the program, but the amount that must be paid to join increases more than $2,000 each year. The current cost to join the program is $12,000.)

Gilbert and Goins also discussed some non-legislative ways to improve the effectiveness of the program. To increase environmental compliance among drycleaners, DEC developed a compliance calendar that incorporates air, hazardous waste, and best management practices requirements. Drycleaners can hang the calendar above their machines and use it as a checklist. Drycleaners have expressed positive feedback for the calenders. In addition, the state's cleanup program is beginning to shift its focus from the facility owner/operator to the property owner, since owner/operators are not as concerned about legal and economic ramifications as property owners. The program can identify property owners by requiring drycleaner sites to list the property owner on their registration form. As a result of this shift in focus, Gilbert and Goins believe, they will capture more sites in the program.

Gilbert and Goins mentioned a dilemma—possibly a major one—that their program faces. The state has established a new ground-water classification rule that eliminates default value for ground water. Before the rule, all ground water was considered drinking water. Now, all ground water must be classified under one of five classifications—pristine drinking water, general use, limited use, site-specific impaired, and unusable. Although the rule was established to help remedial programs develop site-specific standards for sites under remediation, the current wording of the rule implies that the applicant must pay the cost of classifying the ground water. This could mean that the state drycleaning fund must reimburse drycleaner applicants who undertake a ground-water classification study, which could include an entire risk assessment that could cost hundreds of thousands of dollars.

Another major recent challenge is that the oversight board for the program, which is appointed by the legislature, would like the Tennessee DEC to begin shutting down facilities that are not adhering to best management practices or other requirements of the drycleaning program. Drycleaners, on the other hand, believe it is not in the state's power to say what they need to do operationally. Currently, the drycleaning program is supposed to provide assistance with cleanup and liability protection only, but the legislature believes remediation money should not be given to drycleaners that are not trying to prevent pollution in the first place. Tennessee DEC believes that shutting drycleaners down is contrary to the statutes and regulations developed to implement the drycleaning program; DEC has told the oversight board that the statutes need to be changed before they will undertake such action. Another side to this issue is that the Tennessee drycleaning program includes a certified environmental drycleaner requirement, part of which requires all new drycleaning facilities to have an employee with this type of certification. The problem is that to receive the certification from the International Fabricare Institute (IFI) and other organizations, an employee needs to have worked for a drycleaner for 1 year. As a result, new drycleaning facilities are having a difficult time finding employees who can meet the certification requirement, and are thus not in compliance with the law. Accordingly, the oversight board wants the Tennessee DEC to shut them down.

Responding to a question from Nicholson, Gilbert and Goins said that best management practices are only enforced through the certified environmental drycleaner requirement for new facilities, for facilities that are in the program for remediation investigation, and when the program receives a report of illegal disposal. DeZeeuw said that Oregon got high rates of compliance with best management practices by visiting each site, leaving a checklist at each one, asking owners/operators to send back a completed checklist, and following up with phone calls.


Robin Schmidt of the Wisconsin Department of Natural Resources (DNR) said that the state drycleaning program has received 18 applications for reimbursement. Before this application may be submitted, a site investigation must be completed, a remedy selected, and a schedule made for implementing that remedy. Some of the 18 applications are for sites that have incurred past costs. Applications for past costs were limited to 60 days after the effective date of the rule that established the program. Before an applicant can spend any reimbursement money, they must submit a notification form saying that they will submit their costs to the agency. When the program receives such a form, it must assess the site's eligibility.

Schmidt noted that there have been many problems with sites being eligible for reimbursement. For example, some drycleaner owners and operators have died during the process of determining eligibility. Since the law states that only the drycleaner owner/operator may receive reimbursement, the person's estate is ineligible to receive these funds. This requirement also causes problems for individuals who discover that they have purchased a property that has been contaminated by a drycleaner. To get reimbursed for remediation efforts, the individual must find the original drycleaner owner/operator and get them to sign an agreement to submit a joint application; the new owner often finds it very difficult to contact the original owner/operator, who may have retired and moved away.

The cleanup fund has a balance of $3.5 million that has accumulated over the past 4 years. The program takes in about $1 million per year; it may spend only a certain amount each year. Sites are coming into the program at a modest pace. The state law is written to place the onus on the drycleaners to push for increased funds for cleanup. The requirement for a site investigation and cleanup is separate from the availability of funding for reimbursement. In response to a question from Harrington on the percentage of reimbursement, Schmidt said the program has a sliding-scale deductible. For the first $200,000 of costs incurred, there is a $10,000 deductible; between $200,000 and $400,000 in costs incurred, there is a $10,000 deductible plus 8% of costs incurred over $200,000. The total amount of reimbursement per site may be no more than $500,000. Schmidt reported that site cleanups have had reasonable costs—$20,000 to $50,000 for site investigations, for example—and it seems that the program's cost controls are working.

The Wisconsin DNR is trying to make statutory changes to the program to streamline it and eliminate confusing language; by doing this, DNR hopes to reduce administrative nightmares and address some of the more complicated issues through DNR rules. However, they have received a warning from the legislature not to make further changes in the future.

Schmidt is working with the Governor's council to conduct an assessment of the drycleaning program. Since assessors need to look at costs and program effectiveness, Schmidt approached her management team to ask whether project managers could be required to complete site data summary sheets. These sheets would capture information on many parameters, including contaminant source, major types of contaminants and their concentrations, media, soil characteristics, remedies selected, costs per remedy, and lessons learned. Although Schmidt's management team said this would need to be voluntary, project managers have been happy to complete the summary sheets and are generally doing a great job; however, they have not yet provided Schmidt with good information on lessons learned. Schmidt will develop a database to facilitate sorting and analysis of the data.

Schmidt also mentioned a tour she took of a new Hangers™ facility that professes to use an environmentally sound drycleaning process and therefore refuses to pay a license fee to the drycleaning program. She was very impressed with the facility, and is not sure how to collect a fee. The cleaning process uses carbon dioxide, compressed air, wet cleaning, and citrus-based spotting agents. The facility also uses a closed-loop system that reclaims and recycles spent detergent. No chemicals are stored on site, and Schmidt did not notice any routes of exposure. Occasionally, clothes are sent off site for cleaning with PCE. The Wisconsin DNR would consider supporting a statutory change that would allow the facility to pay a reduced fee. Industry has not supported that concept to date. Taber noted that the detergents used by Hangers™ are probably petroleum-based and might still be a contaminant. The ingredients in the detergent are proprietary; Taber recommended obtaining permission to learn what is in the detergent before making a decision about collecting fees.


Chemical Oxidation Overview (and Permanganate Research)

Bob Siegrist, Colorado School of Mines and Environmental Science and Engineering

Bob Siegrist provided an academic overview of in situ chemical oxidation, the principles and practices associated with this remediation technology, and highlights from recent research and development concerning the use of permanganate as an in situ chemical oxidation method. He defined in situ chemical oxidation as the delivery of chemical oxidants into the subsurface (usually) to transform constituents of concern, thereby reducing the mass, mobility, and/or toxicity of the original contaminants. In the process of oxidizing target chemicals, the oxidant itself becomes reduced. Siegrist said that in situ chemical oxidation is a relatively new remediation technology. Only in the last four years have guidance documents and survey reports been written on this subject, and interest is growing rapidly. Some of these reports are available online, such as a Groundwater Currents article Siegrist wrote for EPA recently, two EPA technology reports, and a report by a ground-water remediation technology analysis center. In addition, Siegrist is almost finished with a book on in situ chemical oxidation, published by Battelle Press, that covers principles, practices, and field results, and provides a special focus on permanganate.

Siegrist has conducted research on this technology for the last 10 years. Research and development have covered reaction chemistry, transport processes, and delivery methods. Early research on in situ chemical oxidation during the early 1990s focused on hydrogen peroxide and Fenton's reagent, which is hydrogen peroxide mixed with a transition metal such as ferrous iron, also known as iron(II). Over time, researchers began to investigate the permanganate ion (MnO4-), delivered as either potassium permanganate or sodium permanganate (other forms exist as well). Ozone has received attention recently. In general, these oxidants have been studied to determine their effectiveness in treating chlorinated solvents and petrochemicals.

After investigating the reaction chemistry in the laboratory, Siegrist said, field research was initiated to focus on effective methods for delivering chemical oxidants to constituents of concern in subsurface soil or ground water. Currently there are more than 200 field applications for in situ chemical oxidation, including the use of vertical probe injection of potassium permanganate to treat high levels of trichloroethylene (TCE) in subsurface soil and ground water; combining fracturing techniques with oxidant delivery; recirculation techniques for extracting, chemically amending (with sodium permanganate), and redelivering ground water; and using a five-spot pattern approach or horizontal wells for delivering oxidants into thin interbedded aquifer zones. Of the 200 full-scale applications of in situ chemical oxidation that have been deployed, about 40 involved permanganate. Performance has varied; however, in many cases constituents of concern have decreased between 70% and almost 100% in a short period of time (a few weeks to a few months). Costs have also been variable but can be competitive with other remediation techniques applied to source zones or plumes. Cost generally will not be an overriding factor in deciding whether to use in situ chemical oxidation. The cost of the oxidant itself equals 10% to 20% of the total remediation cost, while the major costs involve implementation and monitoring.

Siegrist said that field experiences with this technology have varied from good to bad, but some of the bad results are due to a lack of knowledge on how to effectively use this technology. Siegrist recommended keeping an open mind regarding in situ chemical oxidation and trying to understand the fundamentals of the technology before judging it.

In situ chemical oxidation provides many benefits as a remediation technology. First, there are a number of oxidants and delivery techniques available from many companies and, as a result, the technology is readily available and can be varied to address many different situations. In addition, the oxidants produce rapid reactions with a wide variety of common organic contaminants of concern including BTEX compounds, polyaromatic hydrocarbons (PAHs) of various types, chlorinated solvents, MTBE, and some of the energetics such as TNT and HMX. The speed of the reaction also allows in situ chemical oxidation to be used to facilitate or enhance other remediation techniques such as bioremediation or surfactant flushing. Lastly, in situ chemical oxidation can be used for rapid cleanup in property sales.

Although there are many benefits, Siegrist admitted that in situ chemical oxidation also has limitations. The technology is not easy to implement, requires training to use effectively, and cannot address constituents of concern that are resistant to oxidative degradation, such as saturated aliphatic compounds like trichloroethane. In addition, high treatment efficiency is not always possible. Delivering the oxidant and distributing it into the subsurface soil or ground water to reach the target compounds can be very difficult. There are also other chemical scavengers in the subsurface that are not the target of in situ chemical oxidation that nevertheless create a high oxidant demand for delivered chemical oxidants. These subsurface substances, including natural organic material and some minerals, can use up delivered chemical oxidants before the oxidants have a chance to effectively treat constituents of concern. Scavengers also can include some of the breakdown products of constituents of concern. Lastly, there are some process-induced detrimental effects that need to be considered.

Characteristics of Different Oxidants

Siegrist noted that the most common chemical oxidants—Fenton's reagent, ozone, and permanganate—each have different characteristics and are therefore useful in different situations. The characteristics of the various oxidants should be considered early in the process when considering in situ chemical oxidation as a remediation option. Oxidants exhibit variation in:

The Impact That Oxidants Have on Subsurface Conditions

Additional factors to investigate when considering in situ chemical oxidation, Siegrist said, are the oxidants' effects on subsurface pH, temperature, microbial ecology, and toxicity. In situ chemical oxidation can sometimes affect the characteristics of the subsurface. Subsurface pH is not usually changed dramatically by oxidants except in regions with free DNAPL (pH is lowered in those regions). Soil materials and subsurface deposits have a natural buffering capacity that limit changes to pH. Temperature might increase locally at the point of introduction for strong oxidants but there is usually little change in temperature overall. The chance for metals to mobilize in the subsurface soil or ground-water sediment material due to in situ chemical oxidation appears to be very site- and oxidant-specific. In some cases, chromium(III) is transformed to chromium(VI); however, depending on the site or oxidant, this might transform back to chromium(III) or be adsorbed onto mineral surfaces and not become an issue. The permeability of the subsurface can be affected because oxidants generate gas. Fenton's reagent and ozone release oxygen and water vapor, while permanganate generates carbon dioxide.

Microbes in the subsurface can be affected by oxidants, but are unlikely to be sterilized by them. Thus, bioremediation processes may persist following chemical oxidation. Oxygen gas generated by Fenton's reagent and ozone can actually stimulate aerobic biological activity in the subsurface. Permanganate does not release oxygen and is unlikely to stimulate microbial activity.

Implementation Considerations

Matching the oxidant and delivery system to the constituents of concern, site conditions, and performance goals is key to effective application of in situ chemical oxidation. After tentatively selecting an oxidant, lab testing and a pilot test are recommended, possibly at the field-scale. Tests should be evaluated to determine the capability of the oxidant to degrade constituents of concern at the site, the rate and extent of any natural oxidant demand, and the permeability of the subsurface and its effect on oxidant delivery. Information about permeability, for example, can help determine the feasibility and cost of applying chemical oxidants in situ. If the permeability of the subsurface is very low, then the oxidants cannot move very far from the point of introduction. As a result, another method such as lancing, mixing, or fracturing must be used to ensure delivery of the oxidant.

Before moving forth with a field application, investigators must make sure that materials used in equipment and construction are compatible with the oxidant used. For example, at high concentrations, permanganate can corrode certain types of steel. Also, most oxidants react fiercely with neoprene and petroleum-based materials. Health and safety issues must also be addressed before going to the field. Oxidants are hazardous materials. Thus, oxidant handlers should be well trained, follow established procedures, and wear appropriate protective clothing. (There have been accidents in the field when oxidant handlers did not follow established procedures.) In addition, before a project moves forth, investigators must determine whether permitting is required for subsurface chemical injection or ground-water re-injection, and what waste management and chemical disposal practices are required for the spent oxidant.

Another implementation issue to consider is the possibility of process-induced adverse effects. When permanganate is delivered to the subsurface via injection well, carbon dioxide or manganese oxide particles can form. These byproducts can have an adverse effect on permeability at the well-screen, the well filter pack, or in the subsurface formation surrounding the injection point. If a site has underground utilities, preferential pathways into a building, or residents nearby, in situ chemical oxidation might not be appropriate if there is concern that oxidants could generate gas, heat, or fugitive emissions.

In addition, other questions that investigators should address include:

Research Efforts

Siegrist discussed his research on in situ chemical oxidation, noting that his students and staff have often looked at DNAPL-related problems that are relevant to drycleaning sites. They also have worked on transport processes, delivery methods, the chemistry and stoichiometry of oxidation reactions, and treatment efficiency. In addition, Siegrist's team has investigated how the oxidation reaction affects the degradation of various constituents of concern, how biochemistry is affected in the subsurface, and which process variables affect the rate and extent of the reaction. They have also researched biotoxicity, metal behavior, and the byproducts formed from oxidation of more complicated materials. Most of this research has been conducted in the laboratory either in aqueous phase systems such as a syringe reactor, slurry reactor, or zero-head space reaction vessels, or at the column and tank scale. Some field studies have been performed as well.

Siegrist mentioned some of his research findings on permanganate that could have a significant impact upon the effective use of in situ chemical oxidation. First, Siegrist noted that oxidant demand increases with increasing amounts of less chlorinated byproducts from the reaction between PCE and permanganate (e.g., TCE, DCE, and vinyl chloride). Vinyl chloride produces a higher oxidant demand than DCE, and DCE a higher oxidant demand than TCE. However, when vinyl chloride is oxidized to an ethane, the ethane becomes resistant to oxidation by permanganate.

Siegrist noted the importance of understanding the stoichiometry of the oxidation reaction. In order to completely oxidize the entire amount of contaminant present, a proportional amount of oxidant is needed, which can be determined from a balanced chemical equation of the reactants.

Siegrist provided details on his research that showed the significant ability of oxidant scavengers in the subsurface to interfere with the oxidation of constituents of concern and he presented his measurements of oxidant demand for various scavengers.

Another very important research finding, Siegrist said, is that increased concentrations of oxidant can result in undesired reactions and ultimately reduce treatment efficiency and increase costs. As the concentration of permanganate is increased, for example, permanganate decomposition speeds up, which reduces the availability of permanganate for oxidizing constituents of concern. In this case, manganese oxide, which forms when permanganate is reduced, acts as a catalyst to decompose permanganate (0.7 to 4.5 mass units of manganese oxide are formed per mass unit of target chemical oxidized). Siegrist believed that some of the problems in the use of in situ chemical oxidation are due to a lack of understanding of this chemistry.

Siegrist has used X-ray and gamma ray attenuation to investigate DNAPL issues in tank systems and has looked to see how entrapment morphology affects in situ chemical oxidation. According to laboratory studies, DNAPL appears to be reduced due to the addition of oxidants. When DNAPL is oxidized, there is mass transfer that results in the dissolution of the DNAPL from the organic liquid phase into the aqueous phase (e.g., ground water). In the interface between the aqueous phase and DNAPL, a stagnant film is assumed to be formed, with characteristics dependent on reaction rates, advection, and other factors. Siegrist developed mathematical equations to describe the effects that chemical oxidants have on DNAPL. He emphasized that there should be enough oxidant in the system to compress the stagnant film or increase the rate of reaction between the oxidant and the DNAPL.

Although DNAPL can be reduced by oxidants, there appear to be some limits to this reaction. Siegrist studied the entrapment morphology of manganese oxide deposits that form at the interface between the aqueous and DNAPL phase as DNAPL is oxidized by permanganate. These manganese oxide deposits, which form more quickly depending on how fast DNAPL is degraded, can entrap the DNAPL and reduce the rate of its dissolution. In addition, the formation of manganese oxide particles, which are generally 0.5 to 1 micron in size, can plug up pores in the oxidant delivery system such as well-screen openings. This can be especially problematic for treatment systems that involve ground-water extraction, oxidant amendment, and re-injection—manganese oxide particles are hard to remove before re-injecting and can cause well-screen and well filter pack fouling without having a very sophisticated particle removal system.

Siegrist noted, however, that the formation of manganese oxide particles might have a positive effect by limiting metal mobility in the subsurface. Although there might be an initial increase in metal mobility due to the addition of permanganate, the manganese oxide particles produced act as strong sorbents for many metals, and may eventually reduce the metal concentration in and around the treated region.

Siegrist distributed a recent research article published in the April 2001 Journal of Environmental Engineering, "Comparison of potassium permanganate and hydrogen peroxide as chemical oxidants for organically contaminated soils." He encouraged attendees to contact him if they wanted this publication or had any additional questions for him.

Delivery Techniques for In Situ Chemical Oxidation

Dan Oberle, SECOR

Dan Oberle is a chemical engineer who has applied chemical oxidation cleanup techniques for 13 years. (See Attachment B for Oberle's presentation materials.) Injecting chemicals into the ground carried a stigma in the early 1990s, but regulators have become more accepting of the process as they have come to realize that the technology can be used to quickly destroy compounds in situ. The process can accomplish cleanup in days or weeks, which is much more attractive than the months or years associated with conventional technologies. Nevertheless, many barriers and a slight stigma remain. The application of in situ chemical oxidation is difficult for several reasons. First, it is difficult to actually get the oxidants to all of the contaminant. In addition, there are interferences that minerals and organics have with the reaction; there are regulatory restrictions in the field; and patent infringement may be a problem. Although the technology has been successful at many sites, a number of failures have occurred as well. At some sites where the technology has been used, controversy has arisen regarding whether the technology is really effective or whether it can be used safely.

The Pros and Cons of Different Oxidants

Oberle noted that there are four primary oxidants: ozone, hydrogen peroxide, Fenton's reagent, and permanganate. He cited some pros and cons associated with each of them.

Oberle said that ozone is a good oxidant and very powerful. It is so strong, however, that it also interacts with water. This reaction creates secondary radicals, which can create Fenton-like reactions in the aqueous phase. However, gaseous ozone will also react with PCE by the same mechanisms as permanganate, as described by Criegee in 1949. It is important to realize, Oberle noted, that ozone has a low solubility and the Occupational Safety and Health Administration (OSHA) has developed some restrictions regarding its use. These restrictions require that injection concentrations be fairly low; this, in turn, limits how fast the oxidant can be introduced into the subsurface.

Oberle said that hydrogen peroxide is a weak oxidant and does not work well for a number of compounds, including PCE. Despite its limitations, in the 1980s and early 1990s, it was used in very high concentrations in the subsurface. The oxidant has been shown to have some useful applications, such as thermally stripping VOCs. When utilized as high-strength hydrogen peroxide, self-degradation of the peroxide occurs rapidly and much heat and oxygen gas is generated in the subsurface. A hydrogen peroxide concentration of 11% can cause ground water to boil. In fact, hydrogen peroxide can release 1,200 BTUs of energy per pound of peroxide and generate 6 cubic feet of oxygen gas, which makes it a great in situ air stripping system. As a result, hydrogen peroxide works well with MBTE (boils at 130 F) but should not be used with hydrocarbons that can cause flammability problems. With hydrogen peroxide, the remediation mechanism is largely volatilization, although some Fenton-like reactions can occur as well.

Fenton's reagent produces free radicals and is very powerful, Oberle said, but requires a low pH to be effective. In the Fenton's reaction, the ferrous ion reacts with hydrogen peroxide to produce a hydroxyl radical.

Oberle said that permanganate has received much attention because it does not have the pH limitations that are associated with Fenton's reagent. In addition, it works well, exhibiting fast oxidation reactions, with PCE, TCE, DCE, and vinyl chloride. The time frame for destroying constituents of concern with permanganate is similar to Fenton's, at least with some of the alkenes. Permanganate can be used for aldehydes, methyl ketones, and primary alcohols, although it is a poor oxidant for alkanes (e.g., 1,1,1-trichloroethane, or 1,1,1-TCA) and most petroleum compounds. For this reason, it is not good for drycleaning sites that have a problem with Stoddard solvents because significant degradation of some petroleum compounds will not occur. One concern with using permanganate is whether, when using it with a contaminant of concern such as PCE, a harmful byproduct will be produced. According to Oberle, the reaction pathway creates unstable compounds, which are quickly converted into carbon dioxide. Oberle said that these intermediate reactions are so short-lived that they are not of significant concern.

Steps Involved With Successful In Situ Chemical Oxidation Applications

Oberle discussed the steps that are needed to make the application of in situ chemical oxidation successful. In summary, the following is important:

Determine whether the technology is appropriate at the site.
Oberle said that it is important to realize that in situ chemical oxidation will not be useful at every site and is more often found to be unsuitable than suitable. For example, when contamination is shallow, an excavator can be used to add permanganate and mix it with the soil to quickly achieve remediation. If the contamination is 60 feet below grade with a high oxidant demand in the soil, then the use of in situ chemical oxidation will be too costly.

Conduct a bench-scale test and calculate mass balance to determine oxidant demand.
Oxidant demand must be estimated, Oberle said, to determine the amount of oxidant mass required for a specific treatment. He said that enough oxidant must be added for complete oxidation of contaminants and to account for scavengers such as soil organics and minerals. Oberle believed a major reason for in situ chemical oxidation not working is that vendors and consultants applying the technology do not realize the importance of calculating oxidant demand. Oberle suggested doing bench-scale testing to determine oxidant demand. Bench-scale tests should be run over an extended period of time to examine fast reactions as well as slower, diffusive-type reactions.

Steimle asked whether bench-scale tests can be skipped now that there have been more than 200 applications of the technology. Oberle replied that a bench-scale test is almost always necessary because every site has different characteristics and different oxidant demands. Evaluating analytical site data, such as total organic content and iron concentrations, is simply not sufficient. He noted that disastrous pitfalls can be avoided if bench-scale tests are performed. For example, it is only through a bench-scale test that investigators would know whether a site had an organic peat layer with the potential to use up 99% of the oxidant. Siegrist agreed that bench-scale testing is very important, noting that it must be done properly and carefully. He said that bench-scale testing should be performed using the same oxidant concentrations that are proposed for a site's field application. Siegrist also said that the decision to conduct a bench-scale test should be weighed against the risk of making an incorrect decision without one.

Determine what concentration of oxidant should be delivered to the subsurface.
Oberle said that identifying the appropriate oxidant concentration is an important part of the planning process. Applying the oxidant in low concentrations creates logistical problems such as needing greater injection volumes of solution and more time to get it in. Overall, this approach is more expensive than alternatives. Higher concentrations, though, can cause self-degradation issues, be dangerous to work with, or create other inefficiencies. For example, volatilization can become an issue when Fenton's reagent is used at high concentrations. Oberle stressed the importance of being fully informed of the health and safety issues that are encountered when oxidants are used in high concentrations.

Identify the most efficient application method for delivering the oxidants to the ground.
Oberle noted that application techniques are vitally important to the success of in situ chemical oxidation projects. One very important factor in achieving success in the application of in situ chemical oxidation, Oberle said, is to ensure adequate contact of the oxidant with the contaminant. Contact limitations, caused by such things as channeling, will occur in an in situ application regardless of the application technique. Use of a mixing technique can increases the likelihood of making contact, but it is more expensive. The depth of contamination and the type of soils that are present at a site will play a large role in determining whether mixing is necessary. For example, if a site has clay-type materials and the contaminants are restricted to the upper 12 feet of soil, mixing techniques should probably be considered.

Oberle described the techniques that his research team used at four different sites. At one site, which was characterized by a shallow water table and saturated and porous sands, mixing was not required and permanganate was simply added around the interface of the site's capillary fringe. At a different site, which was characterized by a high oxidant demand (i.e., 15,000 mg/kg to 20,000 mg/kg), mixing was required to ensure that there was adequate contact between permanganate salts and contaminants. Oberle described a third site that required a bit more complicated application technique. This site, contaminated with TCE and TCA, utilized Fenton's reagent. Prior to injecting the oxidant, hydrogen peroxide and a sulfuric acid solution were added to lower the soil's pH. Then, all of the top soil was removed to prevent the reagent from interacting with the high organic content that was present in the sandy top soil layer. Finally, the oxidant was delivered through liquid injection. At the fourth site that Oberle discussed, a technique called Fenton's "slurry oxidation" was used to treat 1,1,1-TCA present at concentrations of 500 to 1,000 parts per million (ppm) in weathered bedrock as well as in upper soil layers. To treat this site, an excavator was used to break the material apart and Fenton's reagent was injected in slurry form.

Work closely with regulatory agencies to ensure application techniques are acceptable.
Oberle said that in situ chemical oxidation technologies face regulatory barriers. The regulations that come into play with in situ chemical oxidation include the following:

Avoid patent infringement.
Oberle said that patent issues have started becoming a concern for consultants, vendors, and regulators who are interested in applying in situ chemical oxidation. In recent years, vendors have encountered some infringement liability. Regulators paying for the work can become involved in indirect infringement issues as well. Beginning in the 1990s, when chemical oxidation technologies first started being applied at sites, a flurry of patent applications were submitted. Although the chemistry cannot be patented, the apparatus, method of application, reagent mixture, and order for adding the reagents can be. Oberle recommended visiting the U.S. Patent Office at

Questions and Answers

At the end of Oberle's presentation, attendees asked questions about the following topics:

Fenton Reaction (and Use of Permanganate)

Matt Dingens, Geo-Cleanse International, Inc.

Matt Dingens is a remediation subcontractor working for Geo-Cleanse International (GCI), a business that has applied in situ chemical oxidation at 80 sites worldwide, in many cases for the U.S. military. Fenton's reagent was used at about 75% of these sites, Dingens said, and permanganate was used at the remainder. For larger plumes, GCI has used Fenton's reagent in conjunction with natural attenuation. The company has also treated drycleaning sites. Dingens provided information about the characteristics of Fenton's reagent and permanganate, and discussed implementation considerations that must be addressed with each of these oxidants. In addition, he presented information about a hypothetical drycleaning facility and discussed how he would approach remediation at that site. (See Attachment C for Dingens' presentation materials.)

Fenton's Reagent

Dingens said that GCI uses Fenton's reagent frequently because they believe it is the most powerful and versatile oxidant available. Fenton's reagent can treat many compounds, including ethenes, ethanes, petroleum products, explosives, pesticides, and coal tars. However, it cannot be used to treat ethanes that are sorbed to soil in an unsaturated environment. Fenton's reagent can be used in all types of geological formations—sands, silts, clays, tills, and bedrock. One advantage of using Fenton's chemistry on drycleaning contaminants, Dingens said, is that PCE and TCE are not degrading into DCE or vinyl chloride during the treatment process. Instead, the compounds immediately break down to a fatty acid that eventually becomes carbon dioxide, oxygen, water, or chloride ions. Dingens summarized the strengths of Fenton's reagent, highlighting the following favorable attributes:

Dingens said that GCI conducts bench-scale testing for Fenton's reagent application in a sealed autoclave environment. During the test, an offgas is generated that runs through a silica gel and produces leachate. Since GCI has control over all of the byproducts and reactants, researchers are able to use mass balance analyses to obtain a true estimate of oxidant demand.

Dingens spoke about three design goals that are involved in applying Fenton's reagent:

In most cases, Dingens said, Fenton's reagent is injected into formations using a low pressure gradient between 15 and 30 psi. GCI installs specially constructed injection wells into the subsurface and seals them to create pressure. Thus, injected fluids go into the formation instead of back up the borehole. Each well has a small screened interval between 2 and 8 feet, through which reagents injected into the well can exit into the formation. GCI simultaneously delivers the reagents, which include hydrogen peroxide, acidic water carrying iron, air, and catalysts. The pressure gradient causes the reagent to expand out from a small screened interval, creating a zone of remediation.

Dingens noted that researchers can determine whether Fenton's reagent is working at a site by analyzing off-gas. If carbon dioxide appears in the off-gas, this indicates that the oxidation reaction is taking place. (GCI has found that carbon dioxide in the off-gas disappears as the oxidant is used up.) Heat signatures, such as areas of melted snow, serve as another indication that the oxidation reaction is taking place.

Dingens said that the geology determines the volume of the remediation zone. For example, in a saturated environment, the zone of remediation can have a 20- to 40-foot radius of influence and a 10- to 15-foot vertical component. (In a sandy environment, the radius of influence might be as large as 60 feet.) In an unsaturated environment, however, the vertical component of the zone is usually only as high as the screened interval itself. Reagents that are injected into bedrock formations typically follow the same pathways as contaminants. Thus, chemical oxidation can be used to treat contaminants located in fissures and cracks in weathered bedrock. However, in situ chemical oxidation cannot be used on contaminants bound up in shale: the permeability of the rock is too low. Dingens said that GCI plans to release a paper on the field application of Fenton's reagent in weathered bedrock fairly soon.

Dingens said that Fenton's reagent has limited effectiveness in areas with the following characteristics:


Dingens said that GCI uses permanganate when it cannot use Fenton's reagent—that is, in 25% of its cases. Permanganate is a more stable oxidant than Fenton's reagent, and it works especially well with ethenes such as PCE, TCE, and vinyl chloride. GCI uses permanganate in sands, silts, tills, and bedrock, but not clays. Dingens said that the following strengths are associated with permanganate: (1) it provides time and cost savings even in areas of high alkalinity or bicarbonate, (2) the oxidant is safe to use in areas with utilities because heat is not produced, and (3) permanganate remains in contact with the contaminant for a long time.

Dingens said that GCI applies permanganate using direct-push technologies to create small radii of influence (smaller than with Fenton's reagent) in the subsurface. Ground-water movement and advection, rather than a pressure gradient, move the oxidants into contact with contaminants. Permanganate is a long-lived oxidant; it is not spent by the time ground water moves it. In the field, if water in the wells begin to turn purple, this is a sign that the oxidation reaction with permanganate is occurring. Jurgens asked whether an air sparging system could be used in conjunction with permanganate injection in order to stimulate ground-water movement and achieve better contact between the oxidant and contaminants. Some attendees said that this was a good idea.

Dingens said that permanganate is not useful for sites that have the following characteristics:

Hypothetical Drycleaning Site

Dingens provided information on how GCI approaches drycleaner sites. He started by outlining a hypothetical site: a drycleaner in a strip mall, characterized by sandy soil, acidic pH, a 10-foot depth to ground water, an average PCE concentration of 1,000 parts per billion (ppb), and a drain underneath a drycleaning unit that serves as the source of contamination.

Dingens said that GCI would not work at this site if the contaminant plume stretched underneath the strip mall or another business property. In fact, GCI turns down work at 60% of the drycleaning sites offered to them because of accessibility issues or health and safety issues. Before Fenton's reagent could be applied at this hypothetical site, it would be necessary to obtain access agreements from all businesses located above the plume and have them close during remediation. This would not be feasible. If the plume were located behind the strip mall, however, GCI could use Fenton's reagent or permanganate, because business owners would not be affected and site conditions would be amenable to the oxidants. If the site had clay soil and, again, if the plume were in the back, GCI would use Fenton's reagent instead of permanganate—Fenton's reagent does not rely on ground-water advection and would achieve better contact with the contaminant more quickly. If the same site had sandy soils, shallower ground-water contamination, and a utility trench, GCI would choose permanganate over Fenton's reagent to avoid generating heat. However, in certain situations, Fenton's reagent could be used even in the presence of utilities if a soil vapor extraction (SVE) system were used to draw gas and heat away from the utilities. If the site were located in soil with shell-rich sands, the alkalinity would be higher, which would make permanganate a better choice.

Dingens noted that the remedial approach chosen would be much different if contaminant concentrations were significantly higher than those cited for the hypothetical site. For example, if the contaminant was present at a very high concentration (6,000 ppb), this would mean the contaminant was present as free product. In that case GCI might not use chemical oxidation at the site after all. With free product, permanganate could not be used, because manganese dioxide would become more of a factor in clogging the system and reducing its effectiveness. On the other hand, if the soil at the site were silty sands, even if the concentrations were very high (40,000 ppb), GCI would be able to address the site with Fenton's reagent: there would not be any pH or bicarbonate issues and Fenton's reagent can address DNAPL.

Cost Issues

The most important parameters that affect the costs of in situ chemical oxidation are contaminant mass, the size of the plume (which determines the number of injectors required, drilling costs, or geoprobe time), and geology or soil structure. It is important to understand how much contaminant mass is at a site. The mass can be estimated, given an idea of the volume and contaminant concentration. One can use stoichiometry to determine the amount of oxidant needed based on the contaminant mass. As for plume size: the more spread-out a plume is, the harder it is to treat and the more oxidant is needed. The geology at the site has the biggest impact, because the oxidant is delivered as a fluid. Sandy soils require more fluid than clay.

Potassium Permanganate Pilot Test

Kevin Warner, Levine-Fricke

Kevin Warner, of Levine-Fricke, discussed a potassium permanganate pilot test conducted at a drycleaning site in Jacksonville, Florida. (Before it was a drycleaning site, it was a service station that dispensed gasoline.) Warner noted that Levine-Fricke's pilot test carried four goals: (1) inject potassium permanganate directly into the source area, (2) evaluate the effectiveness of this approach in affecting the source area, (3) develop conclusions, and (4) determine full-scale design parameters.

Warner provided a brief description of the site's conditions and contaminants. From the surface to 20 feet below ground surface, he said, the soil is characterized by silty fine sands, with some clay lenses at about 13 to 14 feet. From 20 to 30 feet down, the soil is fine sand. Below 30 feet, clay is present. Ground-water depth is about 5 feet, hydraulic conductivity is about 5 to 10 feet per day, and flow velocity is about 40 feet per year. The site is contaminated by PCE. The source area is about 5 to 10 feet in diameter. The PCE concentrations in the ground water suggest the presence of DNAPL. PCE's breakdown products (e.g., TCE, DCE, and vinyl chloride) are present as far as 450 feet downgradient of the source area.

Warner said that the pilot test was designed to target permanganate to a very small area of DNAPL and maximize the residence time of the oxidant in the formation. The DNAPL was located in an alleyway behind the drycleaning facility. (There was very limited space available at the site—the alleyway was only 5 feet wide. In addition, a residence abutted the alleyway.) To determine the exact location of the DNAPL, Warner said, Levine-Fricke installed a monitoring well cluster in the alleyway; wells were installed in 5-foot screened intervals down to 30 feet below to provide good spatial resolution. In addition, an injection well cluster was installed in the alleyway. These wells, each of which was about 1-inch in diameter, had manifold flow meters with control valves to regulate how much permanganate would enter the cluster. The wells were "jetted in" because there was no room for a drill rig or direct push rig. In addition to the alleyway well cluster, Levine-Fricke installed a well cluster inside the garage facility and an SVE system to treat vadose zone soils. Installation was completed in October 1999.

In late 1999, Levine Fricke injected 2,500 pounds of permanganate into the aquifer. (In October 1999, 10,000 gallons were injected. Another 10,000 gallons were introduced to the system in December 1999.) The injection concentration was 7.7 grams per liter, which was the maximum concentration that the Florida DEP allowed in the variance provided to Levine-Fricke. The fluids were injected into all of the zones at first, but Levine-Fricke stopped injecting fluid into the lower zone when they started observing a lower oxidant demand in those zones. From that point forward, the team focused more on the 10- to 15-foot zone where most of the DNAPL was located. During implementation, Levine-Fricke had to reinstall a couple of the injection wells because of blow-out and permanganate welling up around the wells.

In the zones with low oxidant demand, Warner said, oxidant is still present. In the upper zones that had higher oxidant demand, the permanganate disappeared after 4 or 5 weeks. Levine-Fricke's sampling suggested that the DNAPL source area persisted—one monitoring well indicated that PCE concentrations were rebounding after each injection event within a 5- to 10-foot diameter around the well. PCE concentrations were initially at 10,000 g/L. After the first two injections and an initial decline, the PCE concentration jumped to 22,000 g/L PCE. After Levine-Fricke injected permanganate again and waited a few months, the concentrations rebounded again. Declines and rebounds continued as they added more oxidant. To address the DNAPL PCE source, Levine-Fricke believes that several more permanganate injections will be needed. In a monitoring well downgradient of the source area, more degradation and less rebound was observed. Levine-Fricke believes that this well is outside the source area, and that oxidation is effective in the dissolved-phase plume.

Warner noted that Levine-Fricke learned some lessons at this site. In light of this experience, Warner recommends shortening injection and sampling episodes so that there is a 2- to 3-month interval between injection and sampling. He also suggested using a newer process called co-oxidation, which Levine-Fricke eventually plans to implement at the site to address the DNAPL source. The process involves injecting a co-solvent to dissolve contaminants into an aqueous phase so they can be readily attacked by potassium permanganate. Warner believes that slow PCE mass transfer rates at the site are a major obstacle to successful cleanup; the co-solvent should speed up the rate at which mass transfer occurs, allowing potassium permanganate to address the contaminant rather than be lost to constituents in the soil that are not the target of remediation. Warner hopes that co-oxidation will make in situ chemical oxidation plausible at sites that were once considered borderline candidates for oxidation technologies. Warner said that Levine-Fricke will use tert-butyl alcohol as a co-solvent with a mole fraction of 55%. Siegrist asked if Warner had looked for any mass transfer limitations on the residual leftover, such as film formation in the source area. If there are such limitations, Siegrist said, tert-butyl alcohol would not be effective. Warner said that Levine-Fricke had not determined if there is film formation in the source area, adding that it would be extremely difficult to collect source samples from the aquifer.

Ozone Injection

Bill Kerfoot, KV Associates, Inc. (KVA)

Kerfoot spoke about ozone applications and discussed KVA's C-Sparger® (Criegee Oxidation) system. (His presentation materials are included as Attachment D.) He said that ozone has been used to treat contaminants for a long time—in fact, most of the principles for waste water treatment evolved out of investigations of ozone and the hydroxyl radical. Kerfoot said that ozone is a very powerful oxidant and is made even more powerful with the addition of a catalyst. Ozone can destroy PCBs and other compounds that other oxidants are unable to address. In addition, with the invention of C-Sparger®, KVA was able to develop a system that uses ozone to degrade PCE.

C-Sparger® technology is a complete remediation process. It incorporates technology and equipment. The technology works by introducing microbubbles of encapsulated ozone directly into the ground water using the KVA C-Sparger® system. The microbubbles are randomly dispersed through the formation. A gaseous film of hydroxyl radicals and hydrogen peroxide form around the ozone microbubbles. Then, Fenton's reaction occurs in the film if iron silicates are added to it. The oxidative capacity of the microbubbles can be substantially increased by making the film thicker, adding precursors to peroxides, or injecting catalysts such as microscopic palladium powder into the bubbles. The central bond of the ethene molecule is broken down, resulting in harmless byproducts.

Kerfoot said that a basic system for delivering ozone uses a double-screened well and a recirculating well system. A recirculating well system can treat a broad area effectively by moving the microbubbles through the subsurface and into the smallest of pores, readily removing contaminants such as DNAPL or other heavily adsorbed material. More advanced delivery systems involve liquid and gas injectors that make it possible to coat microbubbles with liquid catalysts.

Kerfoot said that the C-Sparger® has the following benefits:

Kerfoot said that KVA has patents on their processes for applying C-Sparger® technologies, but that licensing programs have been developed to make patent infringement unlikely. KVA offers site licenses and licenses on a per-well basis. They also can supply equipment or make creative arrangements so that remediators can use the process without using the equipment.

Kerfoot also said that KVA has completed 300 installations of ozone in Europe and the United States over the past 6 years; 78% of these achieved closure in less than 2 years. (He noted that sites that have not gone quickly to closure very often have multiple source problems.) C-Sparger® technologies are being used in more than 25 states, either in pilot tests or for approved remediation projects. State drycleaning programs are using the technology, and many federal organizations are as well. A Science Applications International Corporation (SAIC) study demonstrated that the U.S. Army could save about $500,000 by substituting C-Sparger® technology for stripping and carbon for the rapid removal of a host of chlorinated organics. EPA's Superfund Technical Assessment and Response Team (START) program is conducting a pilot test with C-Sparger® technology, and the Kansas drycleaning program is comparing the technology to air sparging with SVE and with NOVACS recirculating wells.

Kerfoot said that 60% of sites addressed by KVA have been drycleaners. With drycleaners, PCE and its breakdown products (TCE, 1,2-DCE, 1,2 cis-DCE, 1,2 trans-DCE, 1,1-DCE, vinyl chloride, 1,1,1-TCA, and 1,1-dichloroethane) are the primary compounds that require remediation. Ozone treats all of them effectively. Kerfoot said that common sources of release at drycleaner sites include sewer lines, catch basins, distilling tank bottom disposal, tank leaks and pumpage, and distiller steam systems. Many of the sites contaminated by sewer lines, he said, can be cleaned up readily because contaminants leaking from the lines are mostly aqueous in form when released to the environment. In some cases, however, DNAPL product has stuck to pipe hinges and created a continuous source of contamination. Catch basins are a big problem at drycleaners, Kerfoot said, mainly because of tank bottoms. Catch basin sources usually require multiple treatments and, in worst-case situations, must be dug up and removed. Still tank bottoms protect themselves very well since they are coated by heavy body oils (like grease)—it is difficult to get oxidant inside them. They pose a major difficulty at many drycleaning sites. Tank bottoms can have very high contaminant concentrations (1,000,000 ppb of DNAPL) and if they need to be removed, they are expensive to incinerate ($20,000+).

At some drycleaning sites, ozone is not as good a choice as permanganate or other oxidants. Injecting microbubbles of ozone requires suitable soil permeability ranging from 100 to 10-6 cm/sec, which includes clay sands and silty sands in the 10-5 range, but not straight clay or silts. C-Sparger® technology can use 5% void space occupancy by DNAPL. DNAPL can be recovered if present in 20-30% void space, but DNAPL is not always present as a recoverable fraction. Ozone is limited by depth (because of pressure associated with compressors in subsurface materials), so it usually cannot be used if the principal volume of contaminants is in the vadose zone.

Before closing his presentation, Kerfoot summarized work that KVA has performed at three drycleaning sites. All three of these projects, he said, have been reviewed by third parties. At a site in Nevada, Kerfoot said, PCE leaking from a vadose-zone sewer line created an aqueous plume. KVA conducted an assessment at the site, installed equipment, and cleaned up the site at a cost of $180,000. Before KVA's intervention, concentrations had been recorded at 1,000 ppb; within 1 month of treatment, PCE concentrations met drinking water standards. At a different site, where a PCE plume had migrated beneath residential buildings, Kerfoot said, KVA lowered PCE concentrations to meet drinking water standards within one month and provided vapor control using horizontal drilling. At a third drycleaning site, Kerfoot said, KVA detected and addressed three contaminant sources. (The last source was discovered when contaminants continued to rebound after treatment. This source was associated with a catch basin and included 12 cubic yards of contaminated soils with still tank bottoms, which were eventually removed.)

Chemical Oxidation via the Fenton Reaction: Theoretical and Practical Considerations

Scott Huling, EPA Robert S. Kerr Environmental Research Laboratory

Scott Huling conducts research and provides technical support to EPA regional and headquarters staff. Huling said that he considers in situ chemical oxidation an emerging technology—it has advanced beyond the stage of experimental technology, but it is not yet a proven, off-the-shelf, cost-effective technology such as pump and treat, SVE, carbon absorption, or air stripping. Because of this, one must monitor in situ oxidation rigorously; doing so provides a "safety net" and lets one adequately evaluate treatment performance. Huling focused his presentation on the Fenton reaction, noting that if the potential limitations of the Fenton reaction were understood, in situ chemical oxidation systems could be made more effective and the monitoring systems that evaluate their performance could be improved. (His presentation materials are included as Attachment E.)

The Mechanics of the Fenton Reaction and A Description of Its Limitations

The Fenton reaction involves hydrogen peroxide and iron(II), which creates iron(III) and the free hydroxyl radical and generates acid and heat. Iron(III) can be reduced back to iron(II) if it reacts with peroxide or the supraoxide radical, after which the iron(II) can be used in the Fenton reaction again. As iron is cycled between oxidation states, the hydroxyl radicals are produced until the peroxide is fully consumed. The hydroxyl radical is highly reactive because it has an unpaired electron. It reacts with most compounds that need to be cleaned up, including those found at drycleaner sites (such as PCE); however, not all chlorinated solvents react as well with the hydroxyl radical. These less-reactive compounds include carbon tetrachloride, chloroform, 1,1,2-TCA, 1,1,1-TCA, and methylene chloride.

The downside of the hydroxyl radical's high reactivity, Huling said, is that the radical reacts with many compounds that are not the target of remediation, including carbonates, bicarbonates, chlorides, and the peroxide itself. Non-productive reactions involve the consumption of hydrogen peroxide without the production of ·OH. Classic examples of these include the enzyme catalase, and manganese. Manganese cycles between oxidation states similar to iron but radicals are not produced. These non-productive reactions (and probably others) reduce the amount of hydrogen peroxide available for the Fenton reaction. Some of the non-productive reactions also produce oxygen gas. Oxygen gas in saturated porous media may result in gas flow blockage of ground water. In a Darcian flow hydraulic configuration, this could prevent the delivery of the oxidant to the targeted contaminant zones. These limitations may constitute a major source of process inefficiency. Additional potential limitations of the Fenton reaction include:

Bench-Scale Studies and Performance Evaluations

Huling stressed the importance of performing bench-scale studies to determine the oxidant's chance of success under site-specific conditions. Fenton chemistry is moderately complex and since so many reactions are possible—both desired and undesired depending on site conditions—it is sometimes unclear whether desired reactions will be significant at the site.

Huling provided his opinion regarding the most important objectives of bench-scale treatability studies.

Huling described the components to be included in the bench-scale reactor. Representative solid phase material will provide the main source of contamination, scavengers, and pH- and redox-sensitive metals. Contaminated ground water is not critical but preferred since it may also contain large quantities of contaminants, scavengers, and metals. Oxidation reagents including hydrogen peroxide and possibly iron(II) and acid.

Huling said that performance evaluations should compare contaminant concentrations before and after chemical oxidation treatment. He recommended incorporating the following components and/or strategies into bench-scale studies/performance evaluations:

When conducting performance monitoring in the field, one should establish a baseline and compare post-oxidation values to it. Monitoring the target compound in groundwater is the most desirable approach. Monitoring contaminants in soil or soil gas may also provide useful information. Solid-phase analysis at drycleaner sites may require many samples, because DNAPL distribution is usually very complex at these sites. One needs many samples to make a valid comparison between pre- and post-oxidation, which can be very expensive. While monitoring the target compound, one should give the subsurface system enough time for rebound to occur. So long-term monitoring is required. It also is important to monitor metals if metal mobilization is an issue.

Implementation Issues—Using Fenton Reactions in The Field

Huling discussed several important design and implementation issues that investigators should be aware of before initiating Fenton reaction oxidation technologies in the field. These include:

Questions and Answers

At the end of Huling's presentation, attendees asked questions about the following topics:


Attendees decided to hold the next SCRD meeting in October 2001. Agenda items will include: (1) presentations offered by Florida and South Carolina, (2) technical presentations on HRC™ and ORC®, and (3) election of a new SCRD chairperson. Henning said that Dow Chemical is interested in giving a presentation on remedies they have carried out at PCE-contaminated chemical-plant sites. Fitton believed the presentation would be more useful if SCRD could choose which case studies Dow presents.

Attendees agreed that they would like NGWA to offer a training session either immediately before or after the October 2001 SCRD meeting. Given the responses of a questionnaire that was sent to SCRD members, NGWA decided that SCRD needs a geochemistry class, including fundamentals and practical applications. Henning said he did not believe such a class would provide enough practical information. He asked if any state knew of a trainer who could look at state presentations and case studies and then create more-relevant geochemistry training. Juho So said he will provide the name of a trainer who could do this.

Attendees decided that the October 2001 meeting should be held either in Portland, Nashville, or Washington D.C. Future meetings, they agreed, must be located in places at which there is a compelling reason to meet. The group discussed a number of criteria for choosing a meeting location. Steimle believed that cost should not be the first consideration. The group decided that it would be good to have meetings in states that work with drycleaner sites, and are willing to offer presentations on what their state has accomplished. Cheryl Joseph noted that if this new policy makes travel expenses rise, NGWA might have to reduce the number of people who can attend training. Also, scheduling meetings in locations where other conferences or training sessions are taking place is problematic: it would be more expensive for NGWA and would be difficult for attendees to be away from their jobs for so long. A meeting in California might make sense because California staff have difficulty traveling out of state. Trippler suggested spending more time in the Southeast, where more member states are located. DeZeeuw mentioned that, depending on the timing, Regenesis might be able to conduct a demonstration of HRC™ at an Oregon site if SCRD meets in Portland in the fall.


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. The leaders discussed projects that are currently being worked on and identified new ones that will be initiated soon.

Program Development/Administration Subgroup

Fitton, the Program Development/Administration Subgroup's leader, said that the Subgroup has been updating a table that summarizes program information for each of the different state's drycleaner cleanup fund programs. He plans to finalize the table soon, and to send the completed version to Carolyn Perroni. The table will be posted on the SCRD Web site and will also be used at the upcoming International Containment and Remediation Technology Conference and Exhibition that will be held in Florida.

Fitton said that the Subgroup is also compiling information on cleanup standards that are used by the different states. Although this is coming together, Fitton asked whether the interns to be hired by Steimle could help with this task. Steimle believed this would be possible.

Fitton also said that the Subgroup is exploring indoor air quality issues. Discussion has focused on what air contaminants to look for, how to sample the air pathway to account for temporal issues, and what to do if compounds that are not drycleaner constituents are detected in indoor air above action levels. Fitton thought these topics might be of interest to the Project Management/Technical Issues Subgroup as well.

The Subgroup is also discussing program issues regarding property owners, specifically how involved they are with applications to the programs and responsibilities with regard to site access. Some states deal with this issue using joint applications, Fitton said, while other states have owner/operators direct activities (giving the state less leverage in gaining access to a site). Fitton recommended that states communicate with each other on this issue.

The Subgroup also discussed how the definition of drycleaning solvents can affect funding issues, given the new solvents that are beginning to be used. Henning agreed to send Kansas' definition to Minnesota.

Fitton also noted that Nicholson is looking at types of insurance requirements and liability coverages in the different states. Because there appears to be limited interest in that, the Subgroup has decided to leave it up to the individual states to follow up with each other for more detail. Davis is looking into de minimus loss issues and RCRA disposal issues that states might have to deal with.

Project Management/Technical Issues Subgroup

Jurgens, the Project Management/Technical Issues Subgroup's leader, said that the Technical Issues Subgroup is developing many projects. For example, the Subgroup is compiling site profiles and working with Perroni to get these posted to the SCRD Web site. Jurgens said that a list is being compiled of the sites that will be profiled. He hoped to finalize the list by June 1.

Jurgens said that he was recently asked how remediation approaches towards drycleaners have changed over the last several years. The Subgroup will start formulating an answer to this question during the October 2001 SCRD meeting: information from the site profiles will be used to answer the question.

Jurgens said that the Subgroup is also examining historical drycleaning processes to identify solvents and spotting agents that were used in the past. With this information in hand, a timeline will be developed to show what agents were used between the 1920s and now. This information will help investigators determine which contaminants to look for when conducting site assessments. Jurgens said that Florida has already collected information on this, but the Subgroup would like to expand upon the effort. Toward this end, the Subgroup will contact chemical and fabric-cleaning industries to gather information.

Jurgens said that the Subgroup also plans to develop a list of drycleaning products, and provide information on what is in the products and whether impurities are found in them.

Project Management/Technical Issues Subgroup members agreed that the indoor air issues that the Program Development/Administration Subgroup mentioned were of interest to them. It was agreed that Fitton and others would determine what sampling techniques and equipment have been used in different states. (A survey will be distributed to different states. The survey will ask for information on what sampling techniques have been used, what state requirements exist, and what air contaminants are being evaluated.)

Outreach Subgroup

Schmidt said that the SCRD Web site has solicited many visitors. She expressed interest in working with the Project Management/Technical Issues Subgroup to develop a search engine for the site profiles, noting that it would be useful to sort site profiles by technology, hydrogeology, soil, or climate.

Schmidt said that the Subgroup has also been talking about the different audiences that are interested in SCRD's activities, and ways to deliver information to the following groups:


Bob Jurgens, KDHE

Jurgens presented information on the Gilbert-Mosley site, a 3,580 acre area located in Wichita, Kansas. (Jurgen's presentation materials are included as Attachment F.) In 1990, he said, VOCs, particularly TCE and PCE, were detected in the central and south-central areas of Wichita. More detailed evaluations indicated that contaminants were present above maximum contaminant levels (MCLs) on 2,115 acres, and above action levels on 1,221 acres. (Action levels are slightly higher than MCLs; action levels for PCE and TCE are 14 g/L and 21 g/L, respectively.) Six plumes were identified with contamination above action levels. Jurgens said that 20 sources were identified as being responsible for the contamination. Of these, five were drycleaning facilities, all of which were eligible for funding through Kansas' drycleaning fund program. Jurgens said KDHE was thankful that the state's trust fund does not cover chemical distributors; otherwise, the agency would have been responsible for addressing even more than the five source facilities.

Jurgens presented site maps that depicted the plumes that were associated with the five drycleaning sites, and the chemicals that were associated with different parts of the site. Jurgens said KDHE was concerned about controlling TCE sources, noting that source control had to be established upstream of the drycleaning facilities to prevent further contamination of the drycleaner areas. Accordingly, KDHE pushed for rapid cleanup of source areas.

Jurgens said that the City of Wichita did not want the area to become a Superfund site. Thus, the city decided to work with the state cooperative program to address the contamination. Between 1991 and 1999, the city conducted four remedial investigations. Because the city worked through and received approval from the state cooperative program (which is part of the bureau that the drycleaning program is in), the drycleaning program became responsible for many of the city's costs. The program's regulations indicate that when the bureau approves costs, the drycleaning program becomes responsible for them. This became a very serious financial concern.

The City of Wichita asked the drycleaning program to pay for a significant amount of the costs, for example, $3.9 million for just one of the plumes. Since these costs would have overwhelmed the drycleaning program, KDHE tried to determine what their costs would have been had they been the ones making the choices for investigation and design. Their projected cost for two sites was $2.6 million plus $250,000 to $500,000 for source control. The drycleaning program repeated this for each plume caused in part by drycleaners at the site. The resulting estimates were much lower than the amounts the City of Wichita wished to recoup. Because of this, the drycleaning program was able to negotiate a final cost that was more reasonable for them (one-third of initial request).

The City of Wichita is implementing tax increment financing; under this approach, everyone in the district will have to pay a tax for cleanup and redevelopment. (The tax will be used for orphan portions of the site, that is, portions that a business refuses or is unable to clean up.) In addition, the city is trying to recoup as much money from responsible parties as possible.

The drycleaning program learned a number of lessons from this experience:


Henning thanked everyone for attending the meeting, and said that he looks forward to the next one. He thanked all who participated for their input and informative presentations.

Attachment A: Final Attendee List

State Coalition for Remediation of Drycleaners (SCRD) Meeting

Holiday Inn Hotel & Conference Center
Old Town Scottsdale
Scottsdale, Arizona
April 17-20, 2001

Lisa Appel
South Carolina Department of Health and Environmental Control
2600 Bull Street
Columbia, SC 29201
Fax: 803-896-4001

Kenyon C Carlson
Arizona Department of Environmental Quality
3033 North Central Avenue (S1603C)
Phoenix, AZ 85012-2809

Mubeen Darji
Florida Department of Environmental Protection
2600 Blair Stone Road
Tallahassee, FL 32399-2400
Fax: 850-922-4368

George (Dave) Davis
Chief, Environmental Assessment Section
Alabama Department of Environmental Management
1400 Coliseum Boulevard
Montgomery, AL 36130-1463
Fax: 334-270-5631

Dick Dezeeuw
Oregon Department of Environmental Quality
811 Southwest 6th Avenue
Portland, OR 97204
Fax: 503-229-6954

Matt Dingens
Geo-Cleanse International, Inc.
4 Mark Road - Suite C
Kenilworth, NJ 07033
Fax: 908-206-1251

Craig Dukes
South Carolina Department of
Health and Environmental Control
2600 Bull Street
Columbia, SC 29201
Fax: 803-896-4001

Tim Eiken
Superfund Section
Hazardous Waste Program
Missouri Department of Natural Resources
1739 East Elm - P.O. Box 176
Jefferson City, MO 65102-0176
Fax: 573-751-7869

Pat Eriksen
Drycleaner Environmental Response Trust Fund of Illinois
814 Pierce Street
P.O. Box 9400
Sioux City, IA 51102
Fax: 712-252-5974

Harold Ethridge
Louisiana Department of Environmental Quality
P.O. Box 82263
Baton Rouge, LA 70884-2263

Doug Fitton
Bureau of Waste Cleanup
Florida Department of Environmental Protection
2600 Blair Stone Road
Tallahassee, FL 32399-2400
Fax: 850-922-4368

James Gilbert
Environmental Specialist
Superfund Division
Dry Cleaner Environmental Response Program
Tennessee Department of
Environment & Conservation
401 Church Street
L&C Annex - 4th Floor
Nashville, TN
Fax: 615-741-1115

Keith Gilliland
Alabama Department of Environmental Management
P.O. Box 301463
Montgomery, AL 36130-1463
Fax: 334-271-5631

Steve Goins
Program Manager
Dry Cleaner Environmental Response Program
Superfund Division
Tennessee Department of Environment and Conservation
401 Church Street
L&C Annex - 4th Floor
Nashville, TN 37243-1538
Fax: 615-741-1115

James Harrington
Division of Environmental Remediation
New York State Department of Environmental Conservation
50 Wolf Road - Room 268
Albany, NY 12233-7010
Fax: 518-457-9639

Leo Henning
SCRD Chair
Section Chief
Assessment and Restoration Section
Bureau of Environmental Remediation
Kansas Department of Health and Environment
Forbes Field - Building 740
Topeka, KS 66620
Fax: 785-296-4823

Janet Hickman
Chlorinated Organics TS & D
The Dow Chemical Company
2020 Dow Center
Midland, MI 48674
Fax: 517-638-9615

Scott Huling
Office of Research & Development
Subsurface Protection & Remediation Division
U.S. Environmental Protection Agency
Robert S. Kerr Environmental Research Center
P.O. Box 1198
Ada, OK 74821-1198

Tom Hvizdak
Wisconsin Department of Natural Resources
473 Griffith Avenue
Wisconsin Rapids, WI 54494

Bob Jurgens
Kansas Department of
Health and Environment
Forbes Field - Building 740
Topeka, KS 66620
Fax: 785-296-4823

Bill Kerfoot
KV Associates, Inc.
Madaket Place - Unit B
766 Falmouth Road
Mashpee, MA 02649
Fax: 508-539-3566

Bruce Nicholson
Special Remediation Branch
North Carolina Superfund Section
401 Oberlin Road - Suite 150
Raleigh, NC 27605
919-733-2801, Ext.: 353
Fax: 919-733-4811

Dan Oberle
2321 Club Meridian Drive - Suite E
Okemos, MI 48864

Kevin Parrett
Environmental Cleanup Division
Oregon Department of Environmental Quality
811 Southwest 6th
Portland, OR 97204
Fax: 503-229-6954

Larry Quandt
Minnesota Pollution Control Agency
Metro District
520 Lafayette Road
St. Paul, MN 55155
Fax: 651-296-9707

Robin Schmidt
Remediation and Redevelopment
Wisconsin Department of Natural Resources
101 South Webster Street
P.O. Box 7921
Madison, WI 53707
Fax: 608-267-7646

Bob Siegrist
Associate Professor
Environmental Science & Engineering Division
Colorado School of Mines
112 Coolbaugh Hall
Golden, CO 80401-1887
Fax: 303-273-3413

Juho So
Drycleaner Environmental
Response Trust Fund of Illinois
1000 Tower Lane - Suite 140
P.O. Box 7380
Bensenville, IL 60106-7380
Fax: 630-741-0026

Lisa Taber
North Carolina Superfund Section
401 Oberlin Road - Suite 150
Raleigh, NC 27605
919-733-2801, Ext.: 244
Fax: 919-733-4811

Dale Trippler
Policy and Planning Division
Minnesota Pollution Control Agency
520 Lafayette Road, N
St. Paul, MN 55155-4194
Fax: 651-297-8676

Kevin Warner
Principal Engineer
LFR Levine-Fricke
3382 Capital Circle, NE
Tallahassee, FL 32308

Jason Dubow
Eastern Research Group, Inc.
110 Hartwell Avenue
Lexington, MA 02421-3136
Fax: 781-674-2851

Christine Hartnett
Eastern Research Group, Inc.
5608 Parkcrest Drive - Suite 100
Austin, TX 78731-4947
Fax: 512-419-0089

Cheryl Joseph
National Ground Water Association
601 Dempsey Road
Westerville, OH 43081
Fax: 614-898-7786

Carolyn Perroni
Environmental Management Support, Inc.
8601 Georgia Avenue - Suite 500
Silver Spring, MD 20910
Fax: 301-589-8487

Kate Schalk
Eastern Research Group, Inc.
110 Hartwell Avenue
Lexington, MA 02421
Fax: 781-674-2906

Richard Steimle
Technology Innovation Office
U.S. Environmental Protection Agency
401 M Street, SW (5102G)
Washington, DC 20460
Fax: 703-603-9135

Laurie Stamatatos
Eastern Research Group, Inc.
110 Hartwell Avenue
Lexington, MA 02421-3136
Fax: 781-674-2906

Duane Winegardner
Cardinal Environmental
326 Sequoyah Trail
Norman, OK 73071-7245
Fax: 405-843-4687

Attachments B through F

Attachments B through F are available on the Internet. To view these attachments, click on the documents listed below.

Attachment B: Delivery Techniques for In Situ Chemical Oxidation (Dan Oberle)

Attachment C: Fenton Reaction and Use of Permanganate (Matt Dingens)

Attachment D: Ozone Injection (Bill Kerfoot)

Attachment E: Chemical Oxidation via the Fenton Reaction: Theoretical and Practical Considerations (Scott Huling)

Attachment F: Kansas: Lessons Learned at the Gilbert-Mosley Site in Wichita, Kansas (Bob Jurgens)