State Coalition for Remediation of Drycleaners Meeting

State Coalition for Remediation of Drycleaners Meeting

Doubletree Hotel
Nashville, Tennessee
May 7-10, 2002

WELCOME AND INTRODUCTIONS
Dale Trippler said that Dick DeZeeuw, the chair of the State Coalition for Remediation of Drycleaners (SCRD), sent his regrets for being unable to attend the meeting. Trippler welcomed participants on DeZeeuw's behalf, noting that he was hopeful that the next 3 days would prove to be a productive and beneficial learning experience.

At the request of the meeting participants, Richard Steimle addressed the issue of SCRD's funding. He said that SCRD is supported by Superfund; while funding tends to be declining, the U.S. Environmental Protection Agency (EPA) plans to continue supporting SCRD. Steimle said that EPA is interested in the characterization and remediation of drycleaning sites because the knowledge gained at these small sites can be applied to large Superfund sites. Steimle asked members to think about long-term strategic goals for SCRD and how those goals would apply to the program's sunset.

STATE PROGRAMS UPDATE
A representative from each member state, except Oregon, provided a program update and responded to questions. (Representatives from Oregon were unable to attend the conference.) A list of the participants and observers attending the meeting is provided in Attachment A.

Alabama
George (Dave) Davis, Alabama Department of Environmental Management
Dave Davis said that Alabama passed legislation to establish a drycleaner program a few years ago. He expects that the cleanup fund, which is a dedicated fund held by the Alabama Department of Revenue, will reach the 1 million dollar goal. (Steve Goins remarked that even though the funds have been dedicated to the drycleaner program, the state legislature may still be able to access the funds.) Davis said that the Alabama Department of Environmental Management has promulgated and is in the process of finalizing risk-based cleanup regulations for the program. Nevertheless, it may still be 2 years before remediation activities are initiated at an actual contaminated drycleaner site. Davis also mentioned that a seven-member board appointed by the governor will ultimately decide which sites will be investigated and what remediation options will be implemented.

Florida
Doug Fitton, Florida Department of Environmental Protection (FDEP)
Doug Fitton said that no new sites have entered into Florida's program since eligibility closed in 1998. A total of 1,422 sites are eligible. Two hundred fifty sites have been assigned. Assessments are complete at 216 of these and are underway at 24 more; the remaining 10 sites still require assessments. Design is underway at 23 sites, construction is underway at 15 sites, active cleanup is underway at 43 sites, natural attenuation is being monitored at 46 sites, and work is complete at 47 sites. Of the latter 47 sites, 33 required no further action, 10 received natural attenuation monitoring, and 4 required active remediation. Fitton provided average costs associated with different phases of site remediation (site assessment: $105,000; design cost including a pilot: $46,000; remedial actions: $184,000; and interim source removal: $55,000). Almost all the funding was spent this fiscal year (which ends in June), and the standard budget of $10 million to $12 million is expected to be allotted for next year.

Fitton described activities that might impact Florida's drycleaning cleanup program. For example, he said, efforts are underway to make the petroleum, brownfield, and drycleaning rules consistent. In addition, a bill has been introduced to increase liability protection. The impetus for the bill stems from the Courtney vs. Publix case. This case was brought forth by a third party (an adjacent property owner) whose property value diminished because of its proximity to a contaminated drycleaning facility. The case went to the appellate court and the judge concluded that the state legislature must resolve the liability protection issue.

Illinois
Pat Eriksen, Drycleaner Environmental Response Trust Fund of Illinois
Pat Eriksen mentioned that both the Fund Council and four drycleaner trade groups have tried to increase solvent taxes and license fees in Illinois. The Council proposed increasing the solvent tax from $3.50 to $9.00 per gallon for tetrachloroethene (PCE) and from 35 cents to 90 cents per gallon for petroleum, and to restructure the license fee system so that most license fees will double. Unfortunately, the Council has not been able to meet since December 2001 and the legislation proposed by the drycleaner trade groups was unsuccessful.

Currently there is $6.5 million in the fund, and about $2 million a year is generated in revenue. The drycleaner program has historically spent about $1 million a year, but Eriksen estimated that spending could increase to $3.0-$3.5 million this year. The Drycleaner Environmental Response Trust Fund of Illinois is working with the Illinois Department of Revenue to collect fees from drycleaners that failed to register for licenses.

Eriksen distributed a March 2002 activity report for the Drycleaner Environmental Response Trust Fund of Illinois. He explained that there are two types of claims: remedial claims and insurance claims. Remedial claims cover contamination that occurred at facilities before owners purchased insurance coverage. (To be eligible for the remediation claim program, a site must have been filed in the state's fund program by July 1, 2000.) The Drycleaner Environmental Response Trust Fund has paid about $1 million and expects to pay an additional $4.7 million for the 76 eligible remedial claims. In addition, Illinois has approved $875,000 for 104 potential remedial claims in which sites have requested budget approval for site assessment work. Site assessment costs average $25,000 to $30,000 for about 70% of sites; a few sites with ground-water contamination have estimated costs up to $80,000. Eriksen also noted that based on the semi-annual projections, the fund will have a $35 million shortfall by the program's sunset date of January 1, 2010.

Eriksen said that the maximum allowed for a remedial claim is $160,000. Robin Schmidt wondered who paid the difference if remediation efforts cost more than this amount. Eriksen explained that site remediation is voluntary and the drycleaner owners are responsible for paying the difference. If there is a threat to human health and safety, EPA can mandate cleanup under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA).

Kansas
Bob Jurgens, Kansas Department of Health and Environment (KDHE)
Bob Jurgens distributed a handout that summarized the financial status of Kansas's drycleaner cleanup program. As of December 31, 2001, the program had generated $1.4 million. The budget for fiscal year 2002 is $2.6 million, and $1.7 million has been spent as of April 2002. There are 65 facilities in the Kansas Drycleaner Facility Release Trust Fund--4 sites are closed, 19 are undergoing remediation, 7 are being monitored, 12 have completed site assessments, and 23 are awaiting funding. Remedial activities currently in use include packed tower air stripper, aquifer air sparging, KVA C-Sparger, dual-phase extraction with a shallow tray air stripper system, soil vapor extraction (SVE), and excavation. Jurgens commented that SVE is working well. He also noted that work at a large scale site in Hutchinson, Kansas has been postponed since 2001, but that is it scheduled to begin again soon.

Minnesota
Dale Trippler, Minnesota Pollution Control Agency (MPCA)
Since 1995, Trippler said, Minnesota's fund program has generated $4.2 million in revenue from annual fees ($2.1 million), interest earned on unspent fund balance ($400,000), and solvent fees ($1.7 million). As of May 1, 2002, the Fund had an outstanding balance of $1.9 million.

Trippler said that Minnesota has a reimbursement program (called the Voluntary Investigation and Cleanup Program, or VIC), to which about 40 drycleaners have applied. Sites must have approval for reimbursement or they lose eligibility. Of the 13 sites where a response action has been taken, 9 have work completed and are no longer involved in the program. A total of $2.2 million has been paid to owners and operators of drycleaning facilities or to the State to cover administrative costs (about $170,000 total for 7 years).

Trippler said that there have been some changes that will impact the state's drycleaner fund program. First, he said, the definition of a drycleaning solvent has been changed to include "any non-aqueous solvent for use in the cleaning of garments or other fabrics at a dry-cleaning facility, including, but not limited to . . ." In addition, a fee of 35 cents per gallon has been assessed for all non-aqueous solvents. Trippler explained that Minnesota now has a 3-tiered fee system: $7.00/gallon for chlorinated solvents (e.g., PCE), $1.40/gallon for a hydrocarbon-based solvent (e.g., stoddard), and 35 cents per gallon for all other non-aqueous solvents (e.g., CO2 and Green Earth).

Missouri
Tim Eiken, Missouri Department of Natural Resources
Although Missouri's drycleaner program was started in August 2000, Tim Eiken said, there has never been enough money in the budget to hire full-time staff. Eiken hopes that next year's budget will allow for 4.5 full-time employees. The current staff is working to establish a program to register drycleaners in the state. There are two sources of revenue for the program: annual registration fees ($500, $1,000, or $1,500, depending on solvent usage) and a solvent surcharge. There are currently 319 drycleaners (226 small, 75 medium, and 18 large, in terms of solvent usage) registered with the state. The solvent surcharge is paid by the solvent suppliers on a quarterly basis. Collection began on April 1, 2001; $700,000 has accumulated in the fund since that time.

North Carolina
Lisa Taber, North Carolina Division of Waste Management (DWM)
Lisa Taber reported a balance of $3.7 million in the drycleaner fund program. She thinks that the state legislature will try to take some of the money from the fund to pay for a state deficit. Beginning in 2003, though, 2% of the state's sales tax will be appropriated for the fund. Starting at that point, the drycleaner fund expects to receive $8 million to $9 million a year.

North Carolina's drycleaner fund program currently employees two dedicated project managers and is in the process of hiring an additional person. Thirty-seven drycleaner sites have petitioned for cleanup under the program. Once a site enters into an agreement with the state, a standard site assessment will be conducted. (Assessments will cost $5,000 to $25,000.) Once the assessment is completed, the drycleaner program's project managers will decide what actions are necessary and initiate remediation activities. Taber expects that site assessments will begin soon. The drycleaner fund will help reimburse past reasonable, necessary, and documented remediation costs (up to $50,000) if the principal responsible party (PRP) applies for reimbursement by June 30, 2002. To help ensure that the fund persists, there is a limit on the amount of money that may be reimbursed from the fund in any given year (i.e., the program may only spend 10% of the money collected in the preceding year). Representatives from Minnesota and Wisconsin noted that they also have similar program caps established.

Taber reported that the North Carolina fund program team is working on establishing risk-based cleanup rules and encouraging additional participation in the program. In addition, the team is working on creating an interactive Web site with a database and maps of the sites.

South Carolina
Craig Dukes, South Carolina Department of Health and Environmental Control (DHEC)
Craig Dukes noted that the South Carolina legislature attempted to remove money from the state's drycleaner fund, but that the attempt was unsuccessful. In South Carolina, he said, the state government has the lead on contaminated drycleaning facilities. Before a facility is accepted into the fund program, the drycleaner owner must submit one soil sample to the state. The state uses the results from the sample to prioritize the site, and to determine an assessment and remediation schedule. There are currently 21 drycleaner sites in some phase of assessment. A partial soil removal has occurred at one site; in June, a remedy will be initiated at a second site. The state will propose remedies for 8 additional sites by the end of summer and will hold public meetings in the fall. Dukes anticipates that remediation will begin at these sites in spring 2003. Dukes reported that the drycleaner program has a budget of $4 million--$3.4 million is obligated, leaving about $300,000 in uncommitted funds.

Tennessee
Steve Goins, Tennessee Department of Environment and Conservation (TDEC)
In Tennessee, Steve Goins said, there does not have to be evidence that a site is contaminated in order for it to enter the state's drycleaner fund program. If a site is shown to be impacted, it is ranked for further investigation and remediation. Goins reported that 50 drycleaner sites have applied for acceptance into the program. Another five sites have been closed. The fund balance is around $6 million. Since the program's inception, the fund has paid out $2.5 million for site assessments and remediation. Another $2.5 million has been committed for 35 sites that were determined to need further assessment and remediation. The program operates on a reimbursement basis. There are no established caps for a maximum payment at a site, but there are deductibles. However, many sites have required remediation above the deductibles, resulting in an increase in spending.

After 3 to 4 years of lobbying, the Tennessee legislature recently changed the definition of drycleaning solvents to include alternative solvents, such as CO2 and Green Earth. In addition, the annual fee was changed to be based on solvent usage rather than full time employee equivalents and a loophole in the statute was closed so that drycleaners cannot operate if they have not paid all their fees. The program's sunset date is in 2007, at which point the Tennessee legislature will re-evaluate the program.

Wisconsin
Robin Schmidt, Wisconsin Department of Natural Resources (WDNR)
Robin Schmidt said that about 54 sites have notified the state that they will be seeking reimbursement from the drycleaner program. She explained that because Wisconsin has a reimbursement policy, drycleaners must seek external funding. For drycleaners to receive reimbursement, they must notify WDNR that there has been an environmental release and that they plan to submit a claim. According to the current law, site owners do not have to receive pre-approval for reimbursement if they choose to remediate using the lowest bid.

One recent revision to Wisconsin's rule is that every site in the program has to have a project manager approve the investigation work plan, so that the state will know the schedule and estimated costs and will be able to determine how work at the site will affect the fund. The drycleaner program is also concentrating more on educating consultants and drycleaners to address more than just petroleum compounds at drycleaning sites (i.e., they need to focus on assessing and remediating chlorinated compounds, too).

Schmidt estimates that the program will run out of money after July 2003, when the spending authority will be decreased to $1 million. A shortfall is anticipated even though there is a limit to the amount of money that may be spent on a site ($500,000). Therefore, WDNR is trying to develop a prioritization system for the drycleaner program that will "piggyback" onto the state cleanup program's prioritization system. In addition, Schmidt mentioned, attempts are being made to change the mandated deadline for reimbursement (September 2005 for closed facilities and September 2008 for new facilities). In addition, Wisconsin has a solvent fee system in place and would like to change the statute to make it illegal for solvent suppliers to sell solvents to an unlicenced facility.

Taber asked how small drycleaners can afford to remediate their sites up front and then wait for reimbursement. In Minnesota, Tennessee, and Illinois, some meeting participants responded, joint checks (e.g., to the drycleaner, property owner, and contractor) can be issued. Also, a drycleaner may submit for reimbursement more than once a year in Wisconsin (twice a year) and Tennessee (every 60 days). In a few rare cases, Schmidt said, drycleaners received funding from a separate state environmental fund, which was then reimbursed by the drycleaning program.

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

Outreach Subgroup
Chair: Robin Schmidt, WDNR
In the past, Schmidt said, the Outreach Subgroup has created brochures, poster boards, and presentation materials. The Subgroup is not currently working actively on outreach activities. She suggested performing outreach for the other two SCRD Subgroups. Trippler suggested developing a more aggressive SCRD outreach program and Scott Stupak suggested that SCRD pursue a higher level of exposure. The following suggestions for additional outreach were discussed at different times throughout the meeting:

Program Development/Administration Subgroup
Chair: Doug Fitton, FDEP
Fitton said that the Program Development/Administration Subgroup received flow charts and cleanup criteria summaries from some SCRD members. Member states that have not submitted these materials should send them to Taber as soon as possible. Fitton also said that the Subgroup plans to create an "options" product that provides information about components of different state drycleaning programs (e.g., registration/license, funding, tracking, cleanup criteria). This product will not endorse one program over another, but will serve as an information source for states that are in the initial stages of developing a drycleaning program. Fitton said that the product will be in "endtable" format, with some words of explanation at the beginning. It will be available on the SCRD Web site with links provided to the referenced state programs. The goal is to create a table that lists information that is desired for the "options" product and to have this filled out for each state before the fall 2002 meeting. Ideally, the product will be finalized within four meetings. However, Fitton clarified, it will be a "living" product that is continually updated with new information.

Technical Issues Subgroup
Chair: Bill Linn, FDEP
Stupak mentioned that a useful database, Chemicals Used in Drycleaning Operations, is now publicly available through the SCRD Web site under the "Publications" subheading. He demonstrated how to search for chemical information by product name, chemical name, or CAS number and noted that a January 2002 report accompanies the database.

Linn said that 45 site profiles from seven different states are now posted on the SCRD Web site. He encouraged members to send him additional site profiles and suggested collecting information and creating site profiles for drycleaning sites that are handled outside of state drycleaning fund programs. Linn reminded members that cost information and lessons learned are useful components to include in the site profiles. The information from these site profiles will be used to create a decision tree that provides hands-on experience with various remedial and assessment technologies at drycleaner sites.

The Subgroup is also planning to generate a draft report Conducting Contaminant Assessment of Dry Cleaning Sites by the fall 2002 SCRD meeting. Linn promised to circulate an outline and encouraged SCRD members to assist with any of the sections.

Linn reminded SCRD members that the WebBoard is a useful tool that provides an opportunity to expand on questions and ideas. Anyone who is interested in it should contact Perroni for a password. Henning, Jurgens, and Taber remarked that they do not always receive e-mails notifying them of new postings; Perroni agreed to make sure that the e-mail response feature is working properly.

COALITION BUSINESS

Next Meeting
SCRD members discussed several locations for the next SCRD meeting, which is to take place in October 2002. Madison, Wisconsin, and Kansas City, Kansas, were the two top choices. Other suggestions included Minneapolis or St. Paul, Minnesota; Syracuse, New York; and Raleigh, North Carolina. Joseph agreed to investigate the top two locations. Schmidt offered to assist in this effort by looking into hotel, meeting room, and field trip options for Madison, Wisconsin. In addition, meeting participants discussed the possibility of having the fall 2002 meeting in a state that is interested in developing a drycleaning program, but cannot participate in SCRD meetings because of travel restrictions. Joseph mentioned that there is money in the budget to allow for visiting states to attend a meeting on a one-time basis.

Training Sessions
SCRD members noted that training will be incorporated into the fall 2002 meeting. They discussed potential training topics. The favored suggestions were Stoddard solvents, fractured bedrock, indoor air, and assessment techniques. Other suggestions included thermal treatment, nanoinjection, permeable reactive barriers, hydrofracing, and how to deal with different types of contaminated environments (e.g., clays). SCRD members discussed spending a couple of hours on each topic and allotting additional time for case studies. They agreed to determine the training topic(s) for the fall meeting during the next conference call. They will also need to make decisions about how long the training sessions should be and who should coordinate them.

Next Conference Call
Meeting attendees agreed that the next SCRD conference call should be held in late June or early July.

Elections
SCRD members noted that new Subgroup chairs will be elected at the fall 2002 meeting. They agreed to start thinking about nominees.

Strategic Planning
Steimle's initial inquiry about SCRD's long-term goals and sunset prompted the group to begin discussing SCRD's future direction.

Fitton said that the purpose of the group is to be an information source for states considering developing drycleaner programs. The options product that the Program Development/Administration Subgroup is developing will help other states structure new programs and determine technical solutions at contaminated drycleaner sites. Dukes remarked that even though the product is expected to be finalized in 2 years, it will continually be updated with new information and technology. Therefore, he does not foresee a specific end for SCRD. Steimle remarked that typically there is a great deal of activity when a coalition forms, but that activity starts to decline at some point. However, he agreed with Dukes that it does not seem possible to estimate a time at which SCRD activity will decline, because activity will increase as more information is generated.

Steimle commented that contamination at drycleaner sites is a national problem (over 25,000 sites in the United States are contaminated). Jurgens noted that SCRD continually demonstrates its usefulness by reviewing and demonstrating how innovative technologies are progressing. This exchange of lessons learned is improving the overall effectiveness of cost management at drycleaner sites by allowing states to assess and remediate contaminated sites more efficiently.

Meeting participants agreed to set aside 2 to 3 hours at their fall 2002 meeting to continue these discussions and develop a strategic plan for SCRD.

Membership Issues
Pointing out that 20% of the nation's states are currently participating in SCRD, Steimle asked whether greater participation should be sought. SCRD members discussed ways to encourage additional state participation (e.g., locating meetings in states that show interest but do not have travel funds), but noted that states should only be encouraged to join SCRD if they are committed to participating actively in SCRD activities. Meeting attendees also discussed ways to justify participation. Several SCRD members mentioned that outside recognition (e.g., from the SCRD chair or EPA) helps convince upper management that participation in SCRD is beneficial.

Linn said that being involved with SCRD is a great opportunity. He suggested making sure that at least one of the attendees from each member state has a technical background and that all attendees are willing to participate actively. Fitton suggested rotating state representatives to allow more people to benefit from the program. Jurgens noted that states are currently allowed to send two representatives to SCRD meetings. He asked whether a third person from a state could be invited if another state can only send one attendee. Joseph replied that this might be possible, noting that flexibility is built into the SCRD budget.

TRAINING SESSIONS

Prioritization/Eligibility Determination/Process Flow

Illegal Activities of Drycleaners
Dale Trippler, MPCA
Trippler distributed a flowchart describing Minnesota's drycleaner remediation fund program and briefly explained that MPCA administers the program and oversees remediation at sites that have extensive contamination. Reimbursement is only applicable for sites where remediation was or is necessary to protect public health and/or the environment. A drycleaner site may be addressed through the drycleaner fund program or through Superfund. Reimbursement is ultimately made by the drycleaner fund program. In response to questions, Trippler noted that (1) the drycleaner fund only pays for reasonable remediation; (2) sites are cleaned to risk-based standards; and (3) MPCA encourages innovative technologies--if a pre-approved innovative remedy fails, the state will pay for another remedy.

Trippler distributed a memo concerning MPCA's policy on illegal actions. Minnesota's drycleaner law indicates that sites will be disqualified from receiving reimbursement if the actions that caused the release violated federal, state, or county hazardous waste management laws in effect at the time. This provision has only been used once. In that instance, water contaminated with PCE was being released to the ground via a pipe that exited the facility's back wall. The facility's operator did not heed the warning to fix the problem and was thereby deemed ineligible for reimbursement by the drycleaner fund program. Trippler mentioned that MPCA would like to see the law changed so that reimbursement is only denied if there are repeated violations. Fitton noted that Florida also has an illegal action clause that excludes sites that create contamination "willfully, knowledgeably, and with the intent to harm the environment or public health." Proving such a motive, is quite difficult, Fitton said.

Illinois Third Party Insurance Experiences
Patrick Eriksen, Drycleaner Environmental Response Trust Fund of Illinois
Eriksen discussed Illinois' drycleaner pollution liability insurance program. His presentation is included as Attachment B (PDF, 403k). Insurance was included in the drycleaner program to promote compliance with environmental regulations, enhance marketability of drycleaning facilities, provide landlords with "peace of mind," and prepare for a transition into the private insurance market in the future. Eriksen commented that sites must meet certain requirements to be eligible for coverage. This keeps drycleaners focused on compliance, thereby minimizing future releases and cleanup cost. The state can issue a warning that the insurance will be canceled if the site does not correct a noted violation within 60 days.

Eriksen briefly explained that Illinois has a mandatory licensing and registration process, but that participation in the state's remedial and insurance program is voluntary. State insurance policies have been issued for 922 drycleaner sites in Illinois. State insurance is less expensive than private insurance, but many drycleaners are under the impression that private insurance and general liability insurance will provide coverage for contamination cleanup. For this reason, 500 drycleaner sites did not purchase the state insurance by the June 30, 2000, deadline; these sites are not eligible for cleanup benefits through the state fund program.

In response to Barbara Pyles and Schmidt's questions, Eriksen clarified that the insurance program provides coverage for contamination released after the date of the policy. If site investigations reveal pre-existing contamination, the site is handled through the state's remedial program rather than the insurance program.

State-Led Prioritization Schemes
Panel: Jennifer Farrell, FDEP; Lisa Taber, North Carolina DWM; and Craig Dukes, South Carolina DHEC
Farrell distributed a handout that summarizes Florida's site scoring and prioritization system. She explained that the system is driven by receptor information and that its primary concern is to protect uncontaminated drinking water wells. Florida is no longer accepting applications to the drycleaner program: with a few exceptions, all sites have been scored and prioritized.

Farrell noted three problems with the scoring and prioritization system:

  1. It places priority on remediating drycleaner sites near uncontaminated drinking water wells rather than sites near contaminated wells, even though sites in the latter category may be the worst offenders.
  2. Scores are based on information provided by private consulting companies and are verified later in the field. Experience has shown that the initial information is not always accurate. As a result, some sites require re-scoring.
  3. DRASTIC was not weighted heavily enough in the scoring system. (Farrell explained that DRASTIC is a standardized system for evaluating ground-water pollution potential using hydrogeologic settings. DRASTIC is an acronym for the following seven geologic factors: depth to water, net recharge, aquifer media, soil media, topography, impact of vadose zone media, and hydraulic conductivity of the aquifer.)

Taber distributed North Carolina's Prioritization Ranking Form. She explained that it was developed by stakeholders rather than legislators. Because North Carolina DWM is just now beginning to accept sites into the drycleaner program, Taber expects the prioritization and ranking system to evolve as sites are processed through the state's fund program. Taber said that sites are scored based on their risk to receptors. Using such a system allows the state to place priority on the sites that pose the most harm. Sites are considered high priority if supply wells are contaminated, if solvent vapor concentrations exceed standards, or if surface water or soil contaminants exceed standards. The comprehensive site priority evaluation focuses on potential releases to shallow ground water, potential releases to deeper ground water, potential presence of nonaqueous-phase liquid (NAPL), and threats to potential receptors. Taber noted one problem with the system: the site priority score is fixed. It does not change even if site conditions change. In response to Linn's question, Taber said that prioritizing a site costs about $10,000 to $15,000. (This price includes a receptor survey and limited testing.)

Dukes discussed South Carolina's prioritization system, noting that a detailed 250-page document helps guide the process. This document was developed for uncontrolled hazardous waste sites, and pre-dates the state's drycleaner fund program. Dukes said that sites are scored based on receptor impact via three pathways--ground water, surface water, and direct contact. Scores are assigned based on factors such as human exposure, length of operation, age of facility, well size, and well proximity. It typically costs $560 to score and prioritize a site. Dukes noted that applications were submitted for 300 drycleaning facilities within the first month of the fund program's inception. Each applicant had to collect one soil sample from their site and submit it with the application: this sample's characteristics determined whether the site was eligible for inclusion. Soil sample results and other information provided in the application were used to rank sites. Once sites are prioritized, Dukes said, their ranking cannot be changed. This is problematic. The state now realizes that some sites have been ranked too high and some too low. Part of the problem lies with the fact that the contractors who collected and submitted soil samples did not always collect them from the most representative parts of the site.

In Illinois, Juho So remarked, sites that contain free product must be addressed first, regardless of whether or not those sites are impacting receptor populations.

Reimbursement Programs Prioritization
Panel: Barbara Pyles, TDEC; Robin Schmidt, WDNR; and Dale Trippler, MPCA
Pyles distributed Tennessee's Drycleaner Environmental Response Program (DCERP) Prioritization Ranking form. The form's scoring is based on available data concerning facility operations, potential receptors, subsurface setting, and contaminant presence. Although the form is available, it has not been used to rank drycleaning sites. This is because sites came into the state's fund program so slowly that it was not deemed necessary to prioritize them. At this point in the program, Pyles said, she does not recommend using the prioritization ranking because it does not fully characterize sites (e.g., it does not ask for information concerning the extent of a site's plume). Pyles did say, however, that it would not cost much to fill out the prioritization form.

Schmidt said that Wisconsin has a different philosophy: all contaminated sites in Wisconsin must be scored in order to justify using state money on them. WDNR is in the process of testing a new stream-lined scoring system (which only takes about 15 minutes to use) based on factors such as environmental characteristics, potential receptors, and waste characteristics. The prioritization system does not affect how or when cleanup is completed at a site, Schmidt said, but it does influence when a site will receive reimbursement for assessment and cleanup activities. Schmidt reminded participants that drycleaners in Wisconsin are legally obligated to inform WDNR of releases and are required to remediate these releases regardless of funding availability. Drycleaner sites follow the same state cleanup rules and guidance as any other contaminated site in Wisconsin; the difference is that there is the potential for reimbursement. Drycleaners are reimbursed on a "first in" basis. Using such an approach encourages drycleaners to clean up their sites quickly. Because both high- and low-priority sites require remediation, Wisconsin has developed a plan to invest 60% of the funds at high-priority sites, 25% at medium-priority sites, and 15% at low-priority sites. High-priority sites are categorized as posing an imminent risk to human health and/or having contamination above health-based standards.

In order to receive reimbursement for drycleaner remediation costs in Minnesota, Trippler said, a site must meet three criteria: (1) it must be eligible, (2) MPCA must approve its response action plan, and (3) its owner must complete a reimbursement application. Trippler does not anticipate having to prioritize sites because money is currently available and no future sites are expected to drain the fund. However, the fund will not pay interest rates or legal fees. Trippler noted that if a drycleaner site enters the Superfund program, the site has to be scored on the HRS2 scoring system to get onto the potential list of priorities (PLP).

Jurgens and Henning explained that Kansas' prioritization system is based on ground water, surface water, and soil information; distance to drinking water wells and surface water; and type of soil cover. A drycleaner site will score high if it has contaminated wells or is located near municipal wells (i.e., wells that service many people). In Kansas, some problems were encountered when KDHE first started ranking sites. Preliminary and final ranking systems have been established to address these problems. This system provides a means for changing a site's ranking after initial assessment. In addition, KDHE always asks for a ground-water sample to assist in prioritization efforts.

Fitton noted that Florida's prioritization seems to be unique in that uncontaminated wells rank as a higher priority than wells that have already been contaminated.

Site Characterization/Rapid Screening and Investigation

Ground Water Investigations in Karst Topography
Bill Wolfe, United States Geological Survey (USGS); John Hoffelt, TDEC; Shannon Williams, USGS; Tom Byl, USGS
Bill Wolfe's presentation was called Chlorinated Solvents Accumulation in Karst Aquifers. It is included in this document as Attachment C (PDF, 805k). Wolfe's presentation described karst environments as those that contain many large openings and few absolute barriers. He said that chlorinated solvents are highly mobile and persistent in karst environments. He also described the various ways chlorinated solvents move through the different geologic regions in Tennessee. He emphasized the importance of removing chlorinated solvents while in the regolith--before they enter the karst system--because the odds of remediating decrease with depth in karst environments.

John Hoffelt presented Dye Tracing in Karst Terrains. His presentation is included as Attachment D (PDF, 7716k). He said that karst is a landform characterized by subsurface drainage. Therefore, ground-water monitoring of karst systems requires identifying the subsurface drainage network. One way to do this is to use tracer tests with fluorescent dyes (other options include inorganic salts and biologic agents). After establishing background conditions, dyes can be injected into the system and measured (using a spectrofluorophotometer) in areas that are hydrogeologically connected (e.g., at wells and springs). This technique helps determine ground-water flow and contaminant flow. In some states, Hoffelt said, dyes may not be injected into the environment without a permit.

Shannon Williams presented Monitoring Volatile Organic Compounds (VOCs) in Karst Springs. His presentation is included in this document as Attachment E (PDF, 2680k). He described a study that was performed at three sites: Wilson Spring (primary contaminant: chloroform), Rutledge Falls (primary contaminant: trichloroethene), and Cascade Springs (primary contaminant: cis-dichloroethene). The primary objectives of the study were to develop sampling strategies for karst springs, document VOC trends in karst springs, evaluate sample collections and analytical techniques, and examine the use of passive adsorption samplers to estimate average concentrations in karst springs. Williams described the field and laboratory techniques that were used during the study and presented the results. The following conclusions were made: (1) storm sampling is needed at many sites, (2) collecting continuous monitoring data is useful, (3) using automatic samplers and portable gas chromatographs is effective, and (4) passive adsorption samplers have the potential to be a useful screening technique.

Tom Byl presented Karst Microbiology, Geochemistry, and Biodegradation Research. His presentation is included as Attachment F (PDF, 4871k). (He also noted that USGS publications are available at the following Web site: http://tn.water.usgs.gov/pubs/index.html .) Byl described research that has been performed to determine the number and diversity of bacteria in conduits, the adaptation and transport mechanisms employed, and the geochemical conditions and rate of biodegradation. He said that karst water contains more bacteria than unconsolidated aquifers and that there are many different types of bacteria present in the conduits. In addition, bacteria adapt different transport mechanisms for aerobic versus anaerobic wells (flagellated bacteria are found in aerobic wells and floating, density-changing bacteria are found in anaerobic wells). He also said that conditions in karst formations are optimal for reductive dechlorination and that bacteria will biodegrade PCE as long as a food supply (i.e., an electron donor) is available. In response to questions, Byl noted that the number of bacteria appears to be high in "all" karst systems, geochemical diversity is to be expected, algae are also found in karst systems, and the cost to determine bacterial counts is minimal.

Gore Sorbers
Bob Jurgens, KDHE
Jurgens provided information about GORE-SORBER® modules, a passive soil gas sampling technology. These devices, made by W.L. Gore & Associates, are being used in Kansas to assist in site characterization efforts. Jurgens said that KDHE likes the GORE-SORBER® module technology because it works well with PCE, offers more reliable results than active soil gas sampling techniques, and effectively identifies hot spots. Once hot spots are identified, Jurgens said, more comprehensive soil sampling efforts should be initiated to determine the full extent of subsurface contamination. Jurgens discussed Kansas' experience using GORE-SORBER® modules. His presentation, which is included as Attachment G (PDF, 2345k), summarizes the technology's pros and cons, describes lessons learned about installation techniques, lists the type of data collected by these devices, and provides information about cost.

In response to questions, Jurgens clarified that at some sites, the GORE-SORBER® modules are deployed during the first stage of analysis; at other sites, these sampling devices are used later in the assessment process or in conjunction with plume delineation efforts. Jurgens also said that the devices are typically spaced at about 25 to 50 feet, but that they can be spaced more densely if investigators want to hone in on a small hot spot. Jim Gilbert remarked that some contractors space GORE-SORBER® modules closer together than necessary. Dukes noted that EPA evaluated GORE-SORBER® modules and active soil gas sampling devices, and concluded that the former are more sensitive.

Soil Gas Survey Technique
Juho So, Drycleaner Environmental Response Trust Fund of Illinois
So said that soil gas survey techniques are useful at drycleaning facilities because the technology: (1) can be deployed in areas with limited space, (2) can be used to locate hot spots and determine if intrusive site investigation is needed, and (3) is cost effective at sites where organic compound mixtures are present.

So said that EMFLUX® is a quick and easy soil gas sampling method that can be used to analyze volatile organics. He provided a brief description of how the technology works. Devices are typically installed 0 to 4 inches deep, but So recommended installing the collectors much deeper (3 to 4 feet). While in place, soil gas emanates into the collection chamber through passive adsorption. The collectors are removed after 3 days and sent to the laboratory for analysis. So also mentioned that EMFLUX® surface-placed collectors are available for sampling soil gas at the surface (e.g., at landfills). He recommended contacting Beacon Environmental Services at 1-800-878-5510 for additional details.

So said that he has used the EMFLUX® technique at three different drycleaner facilities. Soil gas results obtained using EMFLUX® do not necessarily correlate well with results obtained through other soil sampling techniques. For example, if a high soil gas concentration is detected with EMFLUX®, it does not automatically follow that soil contaminants will be detected at high concentrations in samples collected from the same location but with another method. Regardless, So believes that the EMFLUX® technique is a useful tool. He said that EMFLUX® tends to be conservative (e.g., it never reports a false negative), and that results are provided at a lower cost and a faster turnaround than with more traditional sampling techniques. (EMFLUX® costs $4,600 to $5,600, and more traditional methods range from $8,900 to $16,400). So said that Illinois likes using the EMFLUX® soil gas survey technique. It is an effective tool for determining the presence of contamination during preliminary site investigations because it can obtain results quickly for a relatively low cost. He noted, however, that confirmatory intrusive investigation is usually necessary to close a site because of regulatory requirements. He also noted that EMFLUX® cannot pinpoint contaminated spots.

In response to questions, So said that EMFLUX® is very sensitive (to the nanogram level) and will most likely detect organics even after a site has been remediated. For this reason, if EMFLUX® sampling shows negative results, investigators can be confident that the area is not contaminated.

Streamlined Assessment Protocol
Craig Dukes, South Carolina DHEC
Dukes opened his presentation by describing the approach that is traditionally used to delineate plumes at drycleaning sites. The process typically takes 2 years, he said; it involves installing a few monitoring wells, collecting samples, sending the samples away for analysis, waiting for results, and then using these results to identify targeted locations for additional monitoring well installation and sample analysis. In the interest of streamlining activities, Dukes said, South Carolina DHEC has started delineating plumes using Direct Push and Color-Tec Screening techniques, an approach that allows investigators to delineate plumes in less than 2 weeks. Information on how the technology works can be found on the SCRD Web site (see http://www.drycleancoalition.org/reference.cfm#innovative ) and in Dukes's presentation, which is included as Attachment H (PDF, 1255k). The latter also provides information on the types of site where the technology is most successful. For example, Dukes said that the streamlined assessment approach has proven to be quite useful for testing sewer access points, and performs well in soils characterized by coastal deposits, sands, and clays. In contrast, direct push technologies are not sufficient as a standalone assessment screening technique at sites where contamination has penetrated bedrock. In response to questions, Dukes clarified that the Color-Tec Screening technique alerts investigators that contaminants are present, but does not provide detailed information about the type of contaminant that is present. Dukes also noted that Color-Tec Screening can be used to evaluate soils as well as ground water.

Stoddard Solvent Chemical Fingerprinting
James Bruya, Friedman and Bruya, Inc.
James Bruya presented Chemistry and Chemical Testing. His presentation is included in this document as Attachment I (PDF, 77k). Bruya began by emphasizing the benefit of talking to chemists when trying to understand the intricacies of a site's contaminant profile. He listed a variety of "fingerprinting" techniques that chemists use to identify specific products. He said that chromatographs for gasoline, diesel fuel, mineral spirits, and evaporated gasoline are all very different from one another. Chemists look at these chromatographs to identify individual chemical constituents and to determine which types of product are present in environmental samples. Bruya noted that chlorinated solvents are often attributed to drycleaners, but said that some petroleum products also contain chlorinated solvent additives. (These solvents are added to petroleum either to help refine catalysts or to serve as product markers.) Bruya concluded his presentation with the following advice: (1) be cautious of numerical results because the process generates numbers, not information about how the numbers were obtained; and (2) if results do not make sense, call your friendly chemist for help with interpretation.

In response to questions, Bruya explained that diluting a sample is often necessary to eliminate high "carryover" from one sample to the next. Specifically, for PCE, anything over 500 parts per billion (ppb) should be diluted before analysis. This is consistent with EPA methods. Stupak and Gilbert inquired about varsol fingerprinting. Bruya responded that solubility should be investigated--varsol does not dissolve in water, while benzene, toluene, ethylbenzene, and xylene (collectively called BTEX) do. He also suggested analyzing for hexane or heptane if trying to determine if dissolved varsol exists at a site. Dukes asked what kind of sample would be needed to determine whether non-chlorinated solvent contamination (e.g., stoddard) originated from a drycleaner. Bruya suggested collecting a sample with pure product, such as a soil sample.

Indoor Air Intrusion From Subsurface Plumes

Kansas Air Monitoring Policy
Leo Henning, KDHE
Henning provided information on indoor air issues and challenges posed by this exposure pathway. His presentation is included as Attachment J (PDF, 2227k). For quite some time, Henning said, health officials have known that contaminant exposure via inhalation causes health risks. Nevertheless, no federal standards have been established to provide guidance as to what level of indoor air exposure is unacceptable. Henning provided information about air monitoring sampling devices, the costs associated with these devices, and the questions that one should address when designing air monitoring programs. He also listed the questions that must be addressed if sampling results reveal high indoor air contaminant concentrations. He concluded his presentation by making three recommendations: (1) only analyze for known chemicals of concern, (2) contact local radon experts for estimates of remediation costs and establish a contract with these experts, and (3) initiate discussions about indoor air exposure within each state now. This will help states adopt a proactive rather than a reactive approach to this exposure pathway.

In response to questions about indoor air monitoring techniques, Henning recommended placing air monitoring canisters wherever contamination is expected to be found. He also noted that KDHE uses three different sampling methods to collect data and compares the results obtained from each method. Gilbert remarked that New York has generated a significant amount of information about indoor air issues and would be a good resource.

Evaluation and Use of Computer Models To Predict Interior Air Intrusion
Craig Dukes, South Carolina DHEC
Dukes said that the vapor intrusion pathway has received significant attention in New York and Washington, and that interest is mounting in other parts of the country as well. He described the processes that lead to vapor intrusion, such as negative pressure and cracks in foundation slabs. Dukes said that air monitoring can be used to determine whether vapor intrusion has introduced indoor air contaminants at elevated concentrations. Sampling does have its drawbacks, however: for example, it is expensive, prone to false positive results, and is problematic from a public perception standpoint. (He described an indoor air monitoring study that took place in Washington to demonstrate his points.)

Given these drawbacks, Dukes suggested using computer modeling programs prior to air monitoring efforts. He said that models are cheap to use and help investigators target areas that require more intensive investigation. Dukes acknowledged that some people place little trust in computer models, and that models have received negative press. For example, the models used at the Redfield Scope Manufacturing site to predict indoor air concentrations grossly underestimated actual indoor air concentrations. But upon closer analysis, it became apparent that the inaccurate results were a product of erroneous data inputs. Once the problem was identified and corrected, the model did indeed perform well.

Dukes focused the remainder of his presentation on the Johnson and Ettinger (J&E) model, which can be accessed at the following Web site: http://www.epa.gov/superfund/programs/risk/airmodel/johnson_ettinger.htm. He summarized the key parameters that influence indoor air concentrations (e.g., building air exchange rate, soil types, depth of contamination), described validation studies that have been performed on the J&E model, and acknowledged some of the model's limitations (e.g., it does not currently handle crawl spaces). Dukes also debunked some of the myths that shroud the discussion about indoor air intrusion. For example, he indicated that changes in ground-water temperature have an insignificant impact on vapor volatilization. Dukes's presentation is included as Attachment K (PDF, 2139k).

PRESENTATIONS

Reported Leaks, Spills, and Discharges and Florida Drycleaning Sites
Bill Linn, FDEP
Linn summarized and presented the results from a new publication, which is available at http://www.drycleancoalition.org/download/leaks/ . The paper presents data collected by the Florida Drycleaning Solvent Cleanup Program on reported spills, leaks, and discharges of drycleaning solvent and solvent-contaminated wastes. The paper presents data for 530 reported incidents; these occurred across 334 drycleaning facilities and 14 drycleaning wholesale supply facilities in Florida.

The largest number of reported spills/discharges (39.2%) were associated with drycleaning equipment failure; Linn summarized the types of equipment failures mentioned, noting that leaking door gaskets were the most commonly reported source of solvent leakage. Discharges of solvents and solvent-contaminated wastes during drycleaning machinery operation accounted for 20.9% of reported discharges, and many of these discharges were the result of operator error. Solvent transfer and storage accounted for 15.3% of reported discharges, and most of these spills were related to transferring solvents (e.g., from tanker trucks to storage tanks) or filling a drycleaning machine. Discharged solvent and solvent wastes during drycleaning machine/equipment maintenance, particularly during filter changes, accounted for 13.8% of all reported spills/releases. Waste discharges and other spills accounted for about 10% of reported releases.

Linn also discussed estimated spill volumes, which were reported in 96 of the 530 reported incidents. Spills during solvent storage and transfer, while only accounting for 15.3% of reported incidents, accounted for the largest amount of solvent spilled/discharged. Spills associated with equipment failures accounted for the second largest volume of solvent spilled.

Based on the information from this study, Linn recommended sampling around the front and back of current and former locations of drycleaning machines and distillation units, current and former solvent storage and transfer areas, facility service doors, sanitary sewer lateral lines, septic tanks/drainfield systems, floor drains, and waste storage and disposal areas.

Permanganate Oxidation of Chlorinated Ethenes
Brenda Veronda, Carus Chemical Co.
Brenda Veronda briefly discussed the benefits of using permanganate to oxidize chlorinated solvents at contaminated sites. She cited the following benefits: (1) the reaction occurs efficiently and rapidly (within minutes or hours), (2) the end result is complete mineralization, (3) permanganate is stable and will continue to oxidize for a wide range of pH levels, (4) there are no heat complications, (5) permanganate is non-corrosive, and (6) there is no decomposition. She indicated that permanganate works well on chlorinated solvents, but is not recommended for gasoline range organics (GRO) and BTEX. She said that Carus Chemical Co. is the only permanganate manufacturer in the United States. In response to questions, Veronda explained that spent or excess permanganate can be taken to a water treatment plant and that dilution is the key to safety when one deals with permanganate.

CASE STUDIES

Wisconsin

Washington Square Mall, Germantown, Wisconsin
Gregory Page, ARCADIS
Gregory Page provided information about Washington Square Mall, which he described as a successful remediation and redevelopment project. A site profile is available on SCRD's Web site. Page's presentation, which is included as Attachment L (PDF, 1874k), focused on the site's remediation program. The program consisted of two main efforts. First, in August 1998, more than 3,000 tons of PCE-affected soils were excavated and disposed of off site. Second, between August 1998 and September 1999, enhanced reductive dechlorination (ERD) was used to remediate PCE-contaminated ground water. The remediators accomplished this by injecting a dilute molasses solution into the subsurface. The molasses served as a carbon source for subsurface microorganisms and enhanced biodegradation activities. According to Page, the ERD remediation effort was a success. PCE concentrations fell below detection limits within 16 months, and more than 90% of the PCE degraded to ethene/ethane within 20 months. In addition, dichloroethylene (DCE) and vinyl chloride (VC) concentrations are decreasing. These encouraging results prompted WDNR to close the site in January 2001. After Page completed his presentation, meeting attendees asked questions about the following:

Kansas

Former Four Seasons Drycleaner, Wichita, Kansas
Bob Jurgens, KDHE
Jurgens described the approach that KDHE is using to address the Former Four Seasons Drycleaner site. His presentation, which is included as Attachment M (PDF, 1869k), provided information about the site's history, the contaminants present, and the efforts being taken to protect human health and clean up the environment. Jurgens said that the site first entered Kansas's drycleaning trust fund in 1999, but was considered a mid-risk site and therefore, did not receive aggressive attention in 2000 or 2001. This changed in November 2001, when it became clear (through investigations performed at another site) that PCE had migrated from the Former Four Seasons Drycleaner site and was impacting domestic wells. Jurgens said that KDHE responded quickly and provided bottled water to residences identified as having impacted wells. Agency representatives suspected that there were other impacted wells still in use; an effort was launched to identify these additional contaminated wells and to hook up impacted residences to city water supplies. Toward this end, historical records research was performed, a town meeting was held, water account data tracking systems were analyzed, and street-by-street reconnaissance was performed to obtain complete neighborhood address lists. Jurgens said that site assessment and remediation efforts are progressing at the site, noting that the site owner has agreed to pay for remediation up front and will be reimbursed by Kansas' drycleaning trust fund later. The owner has agreed to have all remediation work approved by KDHE and to use KDHE's contractors. The field work and the Corrective Action Report will be completed by June 2002.

In response to questions, Jurgens said that a construction company (subcontractor) will be land farming the soil, which will cost about $10 to $15 per yard. Taber noted that land farming is not allowed in North Carolina if the concentration is above 6 ppb.

Kam Kar Wash, Goodland, Kansas
Bob Jurgens, KDHE
Jurgens presented information about a passive diffusion bag (PDB) sampler study performed at the Kam Kar Wash. This site, formerly used as a drycleaning facility, is contaminated with PCE and associated breakdown daughter products. The water level is 185 feet below ground surface (bgs), and the aquifer depth extends beyond 300 feet. Well screens are present between 180 and 210 feet bgs. Jurgens said that KDHE performed a PDB pilot study at the Kam Kar Wash in an effort to: (1) determine the reliability and cost-efficacy of PDB techniques as compared to conventional ground-water sampling activities, (2) identify the vertical stratification of contaminant across the screened interval, and (3) determine labor requirements for implementing PDB samplers. Toward this end, Jurgens said, PDB samplers were deployed in seven wells. Jurgens presentation, which is included as Attachment N (PDF, 11919k), focused on best practices for PDB deployment and retrieval. He also provided a summary of the data collected with the PDB samplers and compared those data to data collected via more conventional sampling methods (i.e., aggressively purging three well volumes in the middle of the well screen). Some data discrepancies were observed across the different sampling techniques. Jurgens offered three possible explanations for this reality: (1) PDB samplers act as a filter and keep out colloidal soil particles, (2) preferential ground-water flow is around the well bore hole, or (3) conventional well purging may mix water from different vertical horizons. Jurgens also provided information about the costs associated with PDB samplers: while this technique may be more expensive than conventional methods in the short term, he said, it does have cost advantages over the long term. KDHE plans to continue using this technology. Representatives from Florida and Tennessee noted that they are also using this technology and have observed similar correlations.

In response to a question, Jurgens explained that the deployment tube is filled with distilled water to maintain the shape and diffusion of gases, resulting in "clean" ground-water samples. Answering another question, he said that the diffusion bags are available in a variety of sizes.

Florida

Swift Cleaners, Jacksonville, Florida
Jennifer Farrell, FDEP
Farrell said that remediation efforts are underway at Swift Cleaners, an active drycleaning facility that has been in business since 1971. A site profile is available on SCRD's Web site. PCE is present in the site's ground water and soil at concentrations as high as 10,000 ppb and 40 ppm, respectively. The plume size is 300 feet by 1,000 feet, and the depth to ground water is 3 to 14 feet. SVE is being used to clean the site's soil, and in situ chemical oxidation is being used to address ground water. Farrell's presentation, which is included as Attachment O (PDF, 1608k), focused on the ground-water remediation effort.

Farrell said that Oxy-Cat™, a Fenton's-based in situ oxidation process, is being used; it consists of a mixture of 12% to 14% hydrogen peroxide (H2O2) and ferrous iron. The remediators tested Oxy-Cat™ in a pilot project (in 1999) before moving to full-scale implementation. Farrell described how Oxy-Cat™ works. A ferrous sulfate catalyst solution is injected into a well and H2O2 follows closely behind. Once in the subsurface, the ferrous iron converts the H2O2 to hydroxyl radicals, which in turn oxidize chlorinated hydrocarbons to carbon dioxide, water, and chloride ions. Farrell said that results regarding the efficacy of Oxy-Cat™ have been mixed. During the pilot test, contaminant concentrations decreased in some areas but increased significantly in others. Results appeared to be more promising once full-scale implementation was underway. In fact, first quarter monitoring results indicated that PCE concentrations were decreasing. A subsequent monitoring event, however, indicated that PCE contaminant levels within the source area have increased significantly. Farrell presented information on the costs associated with the Oxy-Cat™ technology: $100,000 for the pilot test and $200,000 for full-scale implementation.

Steimle commented that this is probably the first well-documented study of a site containing DNAPL. In response to a question from Dukes, Fitton replied that one reason that PCE concentrations may have increased is that the DNAPL was probably sorbed onto the organics and once the organics were destroyed, the DNAPL was freed.

Dixie Cleaners, Jacksonville, Florida
Jennifer Farrell, FDEP
Farrell said that Hydrogen Release Compound® (HRC®) injections are being used to remediate contamination at the Dixie Cleaners site. A site profile is available on SCRD's Web site. HRC® is used to enhance in situ biodegradation through its ability to support anaerobic reductive dechlorination processes. When injected into the subsurface, Farrell explained, HRC® releases lactate, which is metabolized in situ to produce hydrogen. The hydrogen prompts reductive-dechlorinating microorganisms to progressively remove chlorine atoms from chlorinated hydrocarbon contaminants. As a result, the following reactions occur:

PCE arrow Trichloroethene (TCE) arrow DCE arrow VC arrow Ethene

Farrell's presentation is included in this document as Attachment P (PDF, 876k). She provided information about site characteristics, described the phases of the HRC® remediation effort, summarized available results, and offered information about costs and lessons learned. In summary, she noted that HRC® was chosen as a remediation option at Dixie Cleaners because this site already exhibited reductive dechlorination processes. Investigators hoped that enhancing these processes would reduce PCE, TCE, DCE, and VC concentrations at the site. Toward this end, two HRC® injections have been performed. The first one took place in June 2000, took 25 days to complete, involved 175 points, and cost $290,000. The second injection took place in April 2002, took 5 days to complete, involved 52 points, and cost $53,000. The results collected to date are encouraging: reductive dechlorination processes have accelerated and PCE has nearly been degraded at the site. The reaction has not yet reached completion, however, as is evidenced by the fact that DCE and VC concentrations are still accumulating. Additional sampling activities are planned for May 2002. In response to a question from Pyles, Farrell said that FDEP paid about $6 per pound and So remarked that Illinois pays $5 per pound.

Miller Machinery and Supply, Jacksonville, Florida
Doug Fitton, FDEP
Fitton presented If I Had a Million Dollars . . . Miller Machinery & Supply--a Retrospective of Miller Time! When Alcohol Isn't the Answer. The Miller Machinery & Supply site, a former wholesale supplier, housed an aboveground storage tank that accepted and distributed PCE, resulting in two hot source areas. Fitton mentioned that the site is adjacent to a swamp and bayou area with an aboveground surface water table. The soils are a layer of peat, followed by sand, clay, and limestone about 30 to 55 feet deep. The original plan, Fitton said, was to excavate the source area and treat the contaminated soil aboveground. This plan involved the following steps: perform a co-solvent leach heap pilot test (with ex situ soil flushing), conduct a large diameter auger excavation, stockpile the soils for treatment, backfill the area with a concrete mixture to minimize flow through the source area, amend the backfill with zero-valent iron (but this was omitted), perform full-scale on-site treatment with co-solvent leach heap, dispose of treated soils off site, and establish a ground-water extraction treatment system to dewater the stockpiled soils.

Fitton explained the soil extraction process. Several large pieces of equipment were used to remove soil to a depth of 15 to 55 feet. The excavated soil was placed in a 100- by 40- by 10-foot treatment box that had a geosynthetic liner and a sandy bottom. The hole was backfilled with a concrete mixture. Because of the type of media present, as soil was being extracted, the boreholes continually refilled; this resulted in more soil being excavated than intended. As a result, the treatment box filled up sooner than anticipated and excavation was terminated before it was completed. In addition, there were significant delays because big equipment kept getting stuck in the mud.

Fitton described the first pilot test--a co-solvent leach heap. The intent was to achieve a 6 ppm level and to send soil off site as nonhazardous waste. Twelve tons of the most contaminated soils were placed in a lined bin with a gravel bed and gravel top. About 400 gallons of the co-solvent (isopropyl alcohol) were percolated through the system for several days. Unfortunately, the test failed to achieve the goal of 6 ppm, and significant amounts of free-phase DNAPL still existed. In addition, investigators discovered that the liner had leaked and the isopropyl alcohol/PCE-laden mixture had seeped into the ground. Therefore, the remediation team opted for Plan B--a second pilot test using indirect heat volatilization. The contaminated dirt was placed in a self-contained steam stripping box for 5 days. Unfortunately, this treatment also failed to achieve the goal of 6 ppm.

In the end, 1,000 cubic yards of excavated soil were trucked off site. Fitton explained that depending on the results of composite samples, the soil could be shipped to a landfill as nonhazardous waste (about 336 tons) or processed with a ChemOx treatment before disposal (about 724 tons). The materials used in the first pilot test (about 16 tons) were incinerated. In addition, about 30,000 gallons of water treated with a trailer-mounted air stripper system and 4,000 gallons of a water/sediment mixture required appropriate disposal.

Fitton remarked that the total cost of the project was $1,015,174 and only half its scope was achieved (i.e., only part of the source material was removed). The lessons learned are: (1) remediators should perform pilot tests before excavating, (2) data should be collected quickly, and (3) alcohol may be a promising technique, but it will not work everywhere.

In response to questions, Fitton made the following points: (1) air sparging would not work at the site because of the DNAPL and peat, (2) slow natural biodegradation is occurring in the peat, and (3) the owner has been very cooperative.

Illinois

Family Pride Cleaners, Dundee, Illinois
Juho So, Illinois Drycleaner Environmental Response Trust Fund
So provided information about Family Pride Cleaners, a drycleaning facility that has been active for about 38 years. He said that PCE is used at the facility and that a gas station is located nearby. The site is insured through Illinois' drycleaner cleanup fund program. Contamination that occurred prior to the policy's issuance is eligible for cleanup under the fund's remedial claims program. (The site owner filed a remedial claim in July 2000.) So said that site investigation was initiated in April 2000. As of January 2002, 11 soil borings had been drilled and 7 monitoring wells had been installed. No contaminated soil hotspots have been identified, but diffuse ground-water contamination has been detected over a large area. The boundaries of the contaminated plume have not been delineated yet. So said that ground-water flow direction has been analyzed with computer models, but that flow patterns are complex. For example, the direction of ground-water flow changes during the rainy season. Additional site investigation is planned for June and July 2002. In sum, So said, site assessment costs for the site are likely to fall between $60,000 to $70,000.

So said that remediation activities could be initiated as soon as August 2002. Chemical oxidation--particularly with permanganate--is being considered as an option. Permanganate is attractive, he said, because it is easy to deliver, is chemically stable, and is a slow-releasing compound. It will be difficult, however, to determine the optimal amount that should be injected into the subsurface. Pyles asked what Illinois does when site owners have indicated that they cannot afford remediation costs. In such cases, Eriksen responded, the state works with the community to establish a ground-water ordnance; if the site poses harm to human health or the environment, Illinois EPA may step in and require cleanup.

Tennessee

Tiger Cleaners, Memphis, Tennessee
Jim Gilbert, TDEC
Gilbert presented information about a HRC® pilot study that was performed at Tiger Cleaners. (His presentation is included as Attachment Q (PDF, 1497k).) He said that TDEC is hopeful that this remediation technology will remediate the site's ground water and vadose zone. Gilbert distributed a copy of the site profile, which is also available on SCRD's Web site. He said that the site's main source of contamination originates under the facility's drycleaning machine. The site's secondary contaminant source is located at the facility's back door, where filters drained. Gilbert said that remediators introduced HRC® to the subsurface using both horizontal and vertical injections. An AMS PowerProbe DPT and Drilling Rig were used to create borings for vertical injections, and a DitchWitch JT 1720 Horizontal Drilling Rig was used to drill four borings underneath the building. A sensor in the head of the probe allowed the operator to maneuver into ideal locations. In an effort to avoid saturating the area, HRC® was injected into the borings using a minimal amount of water. Nevertheless, the area did become saturated. In response to questions, Gilbert offered the following information: (1) it took an entire day to drill the horizontal borings and the effort cost $8 per foot, and (2) the total cost for the injection was about $71,000.

Former Loeb's Laundry and Cleaners/City of Memphis Downtown Elementary School, Memphis, Tennessee
Barbara Pyles, TDEC-DCERP
Pyles distributed a handout that describes the issues associated with the Former Loeb's Laundry and Cleaners site. This site was used as a drycleaning facility between the 1930s and the 1970s. By the 1990s, all of the structures associated with the facility had been removed and discussions about redevelopment were initiated. A decision has been made to build an elementary school on top of the property. The school will be built directly on top of the most contaminated portions of the site. In an effort to mitigate potential health risks, soil removal operations were conducted and completed in 1999 and 2001. In addition, a horizontal collection system was installed in 2001. Ground water is contaminated with high levels of PCE and VC; to remediate this situation, over 60,000 gallons of ground water were removed during a 4-day pump test in February 2002. A pump-and-treat system will be installed at the site in the future. Pyles said that some consideration is being given to sampling indoor air quality once the school is built. Dukes suggested running indoor air models to estimate whether there will be an indoor air problem.

Pyles asked meeting participants whether they thought the amount of money given to property owners for environmental cleanup should differ depending on how they plan to use a site. For example, should property owners who plan to keep former drycleaner sites commercial be given the same amount of money as re-developers who plan to make sites accessible to children? (In Illinois, Eriksen replied, property owners are required to clean up sites according to the current use, not the potential future use.) Before closing her presentation, Pyles cited one important lesson that has been learned: make sure to hold a consultation with site owners before accepting their application for participation in state fund programs. Doing so, she said, will help avoid misconceptions about the time and money involved with completing environmental work.

North Carolina

Southern Cleaners & Laundry (Southern Uniform), Jacksonville, North Carolina
Scott Stupak, North Carolina DWM
Stupak presented information about the Southern Cleaners & Laundry site, which is an enhanced natural attenuation site that was recently accepted into the state's drycleaner cleanup fund program. The ground water under this site is contaminated with PCE; the highest concentrations have been detected in an area that formerly contained three underground storage tanks. (All the tanks have been removed.) Stupak said that the area surrounding the site is mostly residential and commercial, and that a city and county government complex is being proposed for the property. In 1997, after a baseline was acquired, air sparging and SVE were initiated. In 1998, remediators attempted to enhance natural attenuation by adding a 1% sucrose solution into the ground-water wells (25 gallons were injected twice a week for 8 months). In 1999, there was a request for no further action due to financial hardships (the owner spent $200,000 trying to remediate the site). In response, the ground water was only sampled semi-annually and the air sparging was discontinued. From 1997 to 1999, a decrease in PCE, TCE, and cis-DCE was observed, though BTEX was still present.

Stupak said that this site poses some challenging questions: Were remediation efforts "reasonable" and "necessary"? Should operation of remedial systems continue? He said that these questions pose a challenge to North Carolina's regulators, and that they are coming up at several sites where remedial systems have been operating for some time. Stupak said that it is difficult to say whether remediation at the Southern Cleaners & Laundry site has been reasonable and necessary because the site has not been thoroughly studied. Some results suggest that there is significant contamination in deeper ground water. Also, there has been no attempt to remediate the source area or to locate a preferential pathway.


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

Doubletree Hotel
Nashville, Tennessee
May 7-10, 2002

George (Dave) Davis
Chief, Environmental Assessment Section
Alabama Dept. of Environmental Management
1400 Coliseum Blvd.
Montgomery, AL 36130-1463
334-271-7755
Fax: 334-279-3050
E-mail: GDD@adem.state.al.us


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


Tim Eiken
Superfund Section
Hazardous Waste Program
Missouri Dept. of Natural Resources
1739 E. Elm
P.O. Box 176
Jefferson City, MO 65102-0176
573-526-2737
Fax: (573) 751-7869
E-mail: nreiket@mail.dnr.state.mo.us


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


Jennifer Farrell
Florida Dept. of Environmental Protection
Bureau of Waste Cleanup
Drycleaning Solvent Cleanup Program
2600 Blair Stone Rd. (MS 4500)
Tallahassee, FL 32399-2400
850-488-0190
Fax: 850-922-4368
E-mail:
Jennifer.A.Farrell@dep.state.fl.us


Douglas M. Fitton
Project Manager
Florida Dept. of Environmental Protection
Drycleaning Solvent Cleanup Program
2600 Blair Stone Rd. (MS 4520)
Tallahassee, Florida 32399
850-413-0065
Fax: 850-922-4368
E-mail:
Douglas.Fitton@dep.state.fl.us


James D. Gilbert
Environmental Specialist
Tennessee Dept. of Environment & Conservation
Division of Superfund
Drycleaner Environmental Response Program
401 Church St.
L & C Annex, 4th Floor
Nashville, TN 37243-1537
615-741-4998
Fax: 615-741-1115
E-mail: Jim.Gilbert@state.tn.us

Steve Goins
Environmental Program Manager
Drycleaner Environmental Response Program
Tennessee Division of Superfund
401 Church St., 4th Floor L&C Annex
Nashville, TN 37243-1538
615-532-8599
Fax: 615-741-1115
E-mail: steve.goins@state.tn.us


Leo Henning
Section Chief
Assessment & Restoration Section
Bureau of Environmental Remediation
Kansas Dept. of Health & Environment
1000 SW Jackson, Ste. 410
Topeka, KS 66612-1367
785-296-1914
Fax: 785-296-4823
E-mail:
lhenning@kdhe.state.ks.us


Robert Jurgens
Unit Chief
Assessment & Restoration Section
Kansas Dept. of Health & Environment
1000 SW Jackson, Ste. 410
Topeka, KS 66612-1367
785-291-3250
Fax: 785-296-4823
E-mail: bjurgens@kdhe.state.ks.us


Bill Linn
Environmental Engineer
Florida Dept. of Environmental Protection
Bureau of Waste Cleanup
Drycleaning Solvent Cleanup Program
2600 Blair Stone Rd. (MS 4500)
Tallahassee, FL 32399-2400
850-488-0190
Fax: 850-922-4368
E-mail: william.linn@dep.state.fl.us


Hugh Murrell
Environmental Specialist
Missouri Dept. of Natural Resources
Hazardous Waste Program
P.O. Box 176
Jefferson City, MO 65102
573-526-8915
Fax: 573-526-8922
E-mail:
nrmurrh@mail.dnr.state.mo.us


Gregory B. Page. P.E.
ARCADIS
97 Midway Lane
Oak Ridge, Tennessee 37830
Office (865) 481-3000 X3130
Cell (865) 806-0410
Email: gpage@arcadis-us.com

Barbara Pyles
TN PG1810
Environmental Specialist
TDEC-DCERP
401 Church St., 4th Floor L&C Annex
Nashville, TN 37243-1538
615-253-3876
Fax: 615-741-1115
E-mail: Barbara.Pyles@state.tn.us


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

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


Jeff Soellner
CF/8
Dry Cleaning Grant Coordinator
Wisconsin Department of Natural Resources
Bureau of Community Financial Assistance
101 S. Webster St.
Madison, WI 53707-7921
608-266-1967
Fax: 608-267-0496
E-mail: soellj@dnr.state.wi.us


Scott Stupak
Environmental Scientist
North Carolina Division of Waste Management, Superfund Section, Drycleaning
Solvent Cleanup Act Program
401 Oberlin Rd., Ste. 150
Raleigh, NC 27605
919-733-2801 (Ext. 241)
Fax: 919-733-4811
E-mail: scott.stupak@ncmail.net


Lisa Taber
Program Manager
North Carolina Division of Waste Management, Superfund Section, Drycleaning
Solvent Cleanup Act Program
401 Oberlin Rd., Ste. 150
Raleigh, NC 27605
919-733-2801 (Ext. 244)
Fax: 919-733-4811
E-mail: lisa.taber@ncmail.net


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


Pam Wilson
Alabama Dept. of Environmental Management
1400 Coliseum Blvd.
Montgomery, AL 36130-1463
334-271-7756
Fax: 334-279-3050
E-mail: Pwilson@adem.state.al.us


Technical and logistical support provided by:

Michelle L. Arbogast
Eastern Research Group, Inc.
110 Hartwell Ave.
Lexington, MA 02421-3136
781-674-7246
Fax: 781-674-2851
E-mail: michelle.arbogast@erg.com

Cheryl Joseph
National Ground Water Association
601 Dempsey Rd.
Westerville, OH 43081
614-899-2479
Fax: 614-898-7786
E-mail: cjoseph@ngwa.org

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

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


Also attending from Tennessee:

John Hoffelt (TDEC)
Shannon Williams (USGS)
Alex Harper (TDEC)
Tom Byl (USGS)
Brenda Apple (TDEC)
Barry Brawley (TDEC)
Pamela Franklin (TDEC)
Brad Parman (TDEC)
Obi NKPA (TDEC)
Jack Arvin (TDEC)
Bill Wolfe (USGS)


Other Participants:

Dr. James E Bruya
President
Friedman & Bruya, Inc.
3012 16th Ave. W.
Seattle, WA 98119-2029
206-285-8282
Fax: 206-283-5044
E-mail: fbi@isomedia.com

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

Brenda Veronda
Hazardous Remediation Program Manager
Carus Chemical Co.
315 5th St.
Peru, IL 61354
800-435-6856 (Ext. 6557)
Fax: 815-224-6663
brenda.veronda@caruschem.com


Attachments B through Q

Attachment B: Illinois Third Party Insurance Experiences (Patrick Eriksen) (PDF, 403k)

Attachment C: Chlorinated Solvents Accumulation in Karst Aquifers (Bill Wolfe) (PDF, 805k)

Attachment D: Dye Tracing in Karst Terrains (John Hoffelt) (PDF, 7716k)

Attachment E: Monitoring Volatile Organic Compounds (VOCs) in Karst Springs (Shannon Williams) (PDF, 2680k)

Attachment F: Karst Microbiology, Geochemistry, and Biodegradation Research (Tom Byl) (PDF, 4871k)

Attachment G: Passive Soil Gas Surveys Using GORE-SORBER® Modules (Bob Jurgens) (PDF, 2345k)

Attachment H: Streamlined Assessment Protocol (Craig Dukes) (PDF, 1255k)

Attachment I: Chemistry and Chemical Testing (James Bruya) (PDF, 77k)

Attachment J: Indoor Air Issues at Contaminated Sites in Kansas (Leo Henning) (PDF, 2227k)

Attachment K: Vapor Intrusion Pathway (Craig Dukes) (PDF, 2139k)

Attachment L: Complete PCE Degradation and Site Closure Using Enhanced Reductive Dechlorination--Washington Square Mall, Germantown, Wisconsin (Gregory B. Page) (PDF, 1874k)

Attachment M: Rapid Response to Groundwater Impacts of Domestic Water Wells--Former Four Seasons Drycleaner, West & Central, Wichita, Kansas (Bob Jurgens) (PDF, 1869k)

Attachment N: Passive Diffusion Samplers Monitoring Pilot Study--Kam Kar Wash, Goodland, Kansas (Bob Jurgens) (PDF, 11919k)

Attachment O: Hydrogen Peroxide Injection for PCE Remediation at Swift Cleaners, Jacksonville, Florida (Jen Farrell) (PDF, 1608k)

Attachment P: Results of HRC® Injection at Dixie Cleaners, Jacksonville, Florida (Jen Farrell) (PDF, 876k)

Attachment Q: Tiger Cleaners, Memphis, Tennessee--HRC® Pilot Study Horizontal and Vertical Injections (Jim Gilbert) (PDF, 1497k)