State Coalition for Remediation of Drycleaners Meeting
Madison Concourse Hotel
Madison, Wisconsin
October 8-11, 2002

WELCOME AND INTRODUCTIONS
Dick DeZeeuw, the chair of the State Coalition for Remediation of Drycleaners (SCRD), opened the meeting by welcoming attendees (see Attachment A) and pointing out that a representative from California was in attendance. California is not currently part of SCRD, DeZeeuw said, and it does not have a drycleaner cleanup fund program established. Nevertheless, California does have experience addressing drycleaning sites, and SCRD is eager to form relationships with representatives from that state. DeZeeuw said that he has contacted representatives from Georgia and Connecticut to determine if they are interested in participating in SCRD activities; no formal relationships have been forged with these states, however.

Richard Steimle, from the U.S. Environmental Protection Agency's (EPA's) Technology Innovation Office (TIO), provided an update on SCRD's Site Profile Project. (The profiles provide information about contaminated drycleaning sites, including information on hydrogeology, contaminants, assessment and remediation strategies, and lessons learned.) EPA recently hired an intern, Steimle said, to create profiles for drycleaning sites participating in Michigan's Voluntary Cleanup Program. As a result of this effort, about 10 new profiles have been posted to SCRD's online database. Steimle said that additional interns could be hired to generate site profiles. Some meeting attendees recommended hiring one intern to create site profiles for drycleaning sites in Minnesota, Nebraska, and Iowa. Steimle's discussion about site profiles prompted one attendee to ask whether project managers, rather than interns, should be creating site profiles. Bob Jurgens indicated that he prefers project managers, noting that they are better suited to interpret site data and to provide information on lessons learned. In some states, however, project managers indicate that they are unable to create site profiles due to time constraints. In such instances, interns are invaluable, DeZeeuw said. Doug Fitton said that Florida has started using interns in a different capacity. Rather than using them to generate site profiles, he said, the interns help Florida's project managers compile information for research studies and papers. (For example, an intern might be hired to assist with a paper on Florida's experience using chemical oxidation strategies at contaminated drycleaning sites.)

Steimle also discussed funding issues, noting that SCRD is supported by the Superfund program. As Congress cuts back on Superfund funding, he said, the programs that rely on these funds will be expected to reduce expenses. Steimle asked SCRD members to send him ideas on how SCRD could reduce its support costs. One option, he said, is to reduce the frequency of SCRD meetings, holding them every 8 to 9 months rather than every 6 months. Some attendees disliked this idea, noting that SCRD's work products would suffer as a result.

STATE PROGRAMS UPDATE
DeZeeuw asked state representatives to report on the status of their drycleaner cleanup fund programs and to present information about noteworthy drycleaner-related developments.

Alabama
George (Dave) Davis, Alabama Department of Environmental Management
Alabama established a drycleaner cleanup fund program several years ago, Dave Davis said, and revenue is currently being collected for the fund. Assessment and cleanup activities have not been initiated yet, however. Davis said that draft regulations have been created for the program and that a stakeholder meeting has been scheduled to discuss them. If all goes well, he said, the regulations will go into effect before the end of the calender year. Developing the regulations has been a challenge, Davis said, because the fund program's enabling legislation is not entirely consistent with other state and federal laws. As a result, the state's Drycleaner Association, which spearheaded the fund program's creation, will be expected to work with state legislatures to redo and fix portions of the enabling legislation.

California
Leslie Laudon, Central Valley Regional Water Quality Control Board (CVRWQCB)
Leslie Laudon said that she is with CVRWQCB, one of nine regional boards in California that exist to protect water quality. She provided an historical overview of California's experience with drycleaning sites. Under the state's Well Investigation Program, she said, investigators sampled numerous municipal wells for volatile organic compounds in the 1980s and early 1990s. The results indicated that tetrachloroethylene (PCE) was present in about 260 of the 750+ municipal wells that were sampled in the Central Valley region. Using soil gas analyses and other investigative techniques, Laudon said, investigators found that drycleaning sites were responsible for most of the PCE contamination. In one case, CVRWQCB also listed a city (Turlock) as a responsible party using the logic that the city—as the owner of leaking sewer pipes—had allowed PCE to escape from the municipal sewer system. Assigning responsibility for PCE contamination proved to be a challenging and controversial endeavor, Laudon said, noting that municipalities and representatives from the drycleaning industry rallied to oppose many of the "responsible party" designations that CVRWQCB issued. In 1992, in response to the outcry, California's state legislature created a task force to address drycleaner contamination issues. The task force—composed of environmental groups, industry members, state representatives, and municipalities—did write a report but disbanded without publishing concrete recommendations on pollution prevention requirements, remediation strategies, or whether a cleanup fund program should be developed. The latter, Laudon said, was proposed by the drycleaning industry in 1994. But the proposed legislation, which would have absolved drycleaners of much responsibility, never passed. Thus there is no dedicated program to address contaminated drycleaning sites in California. Instead, many of the sites are addressed through California's Voluntary Cleanup Program. One drycleaning site in Modesto is being addressed through Superfund.

After providing this historical overview, Laudon provided information on the following policies and ongoing projects that relate to drycleaning sites in California:

Florida
Doug Fitton, Florida Department of Environmental Protection (FDEP)
There are 1,422 sites eligible to participate in Florida's drycleaner cleanup fund program, Fitton said. Assessments are underway at 20 of the sites, remedial design is ongoing at 22 sites, construction is underway at 8 sites, active cleanup efforts have been initiated at 37 sites, natural attenuation has been selected as a remedial option at 64 sites, and work has been completed at 52 sites. Fitton discussed a change in funding policy that has impacted the fund program. Last year, he said, the program shifted to a fixed capital outlay system. Fitton and his colleagues hoped that this system would provide smoother funding streams by preventing end-of-fiscal-year work slowdowns. Funding complications still persist, however. This year, in fact, FDEP received 20 percent of its budget on July 1, 2002, with no indication of when the remaining 80 percent would become available. The 20 percent was allocated quickly, Fitton said, and funding stream problems prevented FDEP from initiating the full range of assessment and cleanup activities it had planned. FDEP had to submit several justifications to obtain the remaining 80 percent of the budget, which was finally released at the end of September 2002. Fitton said that concern is mounting about potential revenue shortfalls.

Illinois
Pat Eriksen, Drycleaner Environmental Response Trust Fund of Illinois
Earlier in the year, Pat Eriksen said, the seven-member Council that administers the Illinois' Drycleaner Environmental Response Trust Fund had been inactive. Over the past few months, however, the Governor appointed six new members to the Council and regular meetings have resumed. During the next Council meeting, Eriksen said, prioritization issues will be discussed as part of a strategic planning session. Prioritization is necessary, he said, because the costs associated with drycleaner assessment and remediation is expected to be greater than that which can be met using fund program monies. As in other states, contamination appears to be widespread among drycleaners: of the 145 sites evaluated to date, only 8 have been clean. Eriksen said that he does not know which approach will be used to generate additional revenue for the fund program, noting that the sales tax is considered unconstitutional in Illinois and proposals for a gross receipt tax have already been shot down. Licence fees and solvent taxes are currently the fund program's main source of revenue. Proposals to increase these fees, Eriksen said, have been met with resistance from drycleaners in the past. Eriksen provided a brief overview of two policy issues that are receiving attention:

In closing, Eriksen mentioned the following: (1) remedial action plans are moving forward at 12 drycleaning sites in Illinois, (2) a heated soil vapor extraction (SVE) system has been installed at one site, and (3) a vendor conference will soon be held in Chicago. At the conference, vendors, drycleaners, and regulators will be invited to discuss remediation strategies.

Kansas
Bob Jurgens, Kansas Department of Health and Environment (KDHE)
Jurgens distributed a handout summarizing the financial status of the Kansas Drycleaner Facility Release Trust Fund. Fund income for fiscal year (FY) 2002 was $1.42 million, expenditures were $1.49 million, and the FY 2003 budget will be about $2.01 million. Jurgens said that 69 facilities are participating in Kansas' drycleaner fund program—4 sites are pending closure, 21 are undergoing remediation, 14 are being monitored, 7 are in the assessment phase, and 27 are awaiting funding. Remediation technologies currently in use at drycleaning facilities include packed tower air stripper, KVA C-Sparger, dual-phase extraction with shallow tray air stripper, and SVE. Jurgens commented briefly on Kansas' experience with these technologies. He said that the KVA C-Sparger system has been problematic, but that the SVE system has been very effective. Jurgens also provided updates on activities in Hays, Salina, and McPherson—three areas where regional ground-water systems have been installed to address impacted public water systems. In each of these three areas, Jurgens said, KDHE has turned the ground-water systems over to the city; thus, fund program monies are not being used to pay for the continued maintenance of the systems. Jurgens also discussed the following sites:

Jurgens indicated that KDHE hopes to obtain assistance from Kansas State University's Hazardous Substances Research Center in performing research on an organism that appears to possess strong bioremediation capabilities. When the organism is present at PCE-contaminated sites, Jurgens said, complete degradation occurs. (That is, PCE degrades to ethene.) At contaminated sites where the organism is absent, reductive dechlorination halts before PCE reaches ethene.

Minnesota
Dale Trippler, Minnesota Pollution Control Agency (MPCA)
Dale Trippler distributed a report that summarizes the status of Minnesota's drycleaner fund program. In summary, he said, the program has generated about $4.4 million in revenue since its inception in 1995. More than half of this amount has been expended; as a result, the fund's outstanding balance is about $1.99 million. Fund monies have been used to perform work at 13 drycleaning sites, Trippler said, noting that activities have been completed at nine of them. Two to three new sites are expected to enter the program soon. In Minnesota, he reminded attendees, there is no deadline for entering the fund program. As a result, site owners typically wait to enter the program until they want to sell their property. Trippler described one unusual site that has recently captured the state's attention and may require assistance through the fund program. The site, a residential property, has a stash of contaminated barrels. These barrels were discovered, Trippler said, by a new homeowner. After performing an investigation, MPCA learned that the property was previously owned by a drycleaner who brought barrels home and dumped them in his backyard rather than hiring a waste management company to dispose of the barrels properly.

Missouri
Ken Koon, Missouri Department of Natural Resources
Although Missouri has established a drycleaner cleanup fund program, Ken Koon said, it will probably take 1 to 2 more years to make the program operational. In the mean time, contaminated drycleaning sites will continue to be addressed through the state's Voluntary Cleanup Program. Koon said that revenue is being collected for the fund; the current balance is about $1 million. Two full-time staff members will be hired soon to write rules for the program.

North Carolina
Lisa Taber, North Carolina Division of Waste Management (DWM)
Lisa Taber provided an update on North Carolina's effort to implement its drycleaner cleanup fund program, which Taber described as a state-led/state-contractor program. Over the past few months, she said, two sets of rules were finalized, DWM received permission to hire project manager and hydrogeologists, and efforts were initiated to hire contractors for the program. (Four contractors will be hired. Each will be awarded a $600,000 contract; DWM will reserve the option to add $400,000 if it is pleased with a contractor's performance. Candidate contractors will be interviewed in November 2002.) In addition, Taber said, DWM is preparing guidance materials for the fund program.

About 65 drycleaning sites have already been certified under the fund program, and DWM knows of at least 140 more sites that will enroll. There could be hundreds more, Taber said, noting that some people suspect that there are as many as 800 to 900 drycleaning sites in North Carolina. Because the fund program is not fully operational yet, many contaminated drycleaning sites are currently enrolled in the state's understaffed and underfunded Voluntary Cleanup Program. Efforts are underway, however, to start moving sites through the fund program even though this program is still under development. In effect, Taber said, DWM is moving forth with site-related activities before all of the fund program's components have fallen into place. DWM is involved with the following site-related activities:

Taber mentioned one other issue that DWM staff are tackling: developing risk-based cleanup rules. This effort is controversial—the Underground Storage Tank program is the only other program in North Carolina that makes use of such standards.

Oregon
Dick DeZeeuw, Oregon Department of Environmental Quality (DEQ)
DeZeeuw said that Oregon's drycleaner cleanup fund program balance is about $302,000. Of that, $241,000 is encumbered to pay for future assessment and remediation work at drycleaning sites. DeZeeuw reported on the 34 drycleaning sites that are currently participating in the fund program:

The drycleaner fund program's fee structure has recently undergone significant changes. Reform was needed, DeZeeuw said, because the old fee structure: (1) failed to collect sufficient revenue, and (2) elicited solvent surcharges that were high enough to give drycleaners an incentive to purchase PCE out of state. The new fee structure, which is considered more equitable, has the following components:

Despite efforts to revamp the fee structure, DeZeeuw said, the fund is still falling short of its annual $1 million revenue target. As a result, some of the abovementioned fees will be raised. DeZeeuw described one other fee-related change that could impact fund revenue. Owners/operators must now register inactive sites and pay $250 per year (per site) in order for such sites to be eligible for inclusion under the state's fund program. This new registration requirement allows DEQ to gain an understanding of how many inactive sites exist, an estimate that, up to this point, had been a guess.

DeZeeuw summarized some of the policy issues that are likely to be addressed during the next legislative session. One topic that will demand attention, he said, is identifying ways to generate more revenue. Other topics warranting attention include:

South Carolina
Richard Haynes and Craig Dukes, South Carolina Department of Health and Environmental Control
South Carolina's drycleaner fund program has a balance of about $3 million, Richard Haynes said, but noted that much of that money is already obligated. During last year's state budget crunch, proposals were put forth to divert fund program monies to other state programs. The proposals were abandoned, however, after the drycleaner industry voiced strong opposition. The fund's revenue is declining: according to recent projections, $650,000 is expected in revenue this year. Haynes fears that this projection could be $50,000 too high. The drycleaner industry is concerned about the decline and is examining the viability of alternative funding mechanisms. According to some reports, Haynes said, the industry might propose diverting 2% of the state's existing 5% sales tax toward the fund program. (Doing so would generate an additional $1.5 million each year.) If the drycleaners do propose such a plan, Haynes said, they must drop the lawsuit they have filed claiming that the sales tax is unconstitutional. Haynes said that new revenue might also be generated by pulling Stoddard users into the fund program. (Under the existing statute, drycleaners who use Stoddard can opt out of the program.) The state has already instituted one change to help offset revenue declines—the program's deductible has been raised. Letters were distributed to drycleaners alerting them of this change in policy.

Haynes said that the fund program is currently addressing 29 drycleaning sites. Costs incurred range from $40,000 to $400,000+ per site, with an average of about $120,000 per site. The site that has generated the highest costs, Haynes said, has a 30-acre contaminant plume that extends to multiple depths, the deepest of which is 160 feet. Two drycleaning sites are in the remedial design/remedial action phase, and six to eight more sites will enter this phase before summer 2003. In June 2002, Haynes said, the KVA C-Sparger system was installed at one site. Operational difficulties were encountered, resulting in a situation where remedial systems were only operating properly about 50% of the time. Many of the problems have been fixed since that time, however, and the KVA C-Sparger is now operating more smoothly. ground-water samples will be collected soon to determine how effectively the technology is actually working.

Craig Dukes said that South Carolina has been evaluating the indoor air intrusion pathway. At one drycleaning site, he said, GORE-SORBER® modules were used to identify areas where vapor is rising from a subsurface PCE ground-water plume. The GORE-SORBER® modules recorded hot spots in some areas; lower detections were recorded near buildings downgradient of the hotspots. Before the end of the month, Dukes said, soil gas samples will be collected in areas where detections were recorded and an effort will be made to calibrate the GORE-SORBER® data to the soil gas data. (Taber expressed interest in being kept up to date on the calibration effort.) Dukes said that the indoor air vapor intrusion pathway will also be addressed at another site, where a drycleaner's PCE plume flows under residential houses and commercial buildings. In parting, Dukes said that South Carolina's Superfund team is also addressing air pathways: the team recently spent $50,000 to collect indoor air samples from 10 houses located near a manufacturing site. (Taber expressed interest in obtaining these data; Dukes said that the data are not available yet.)

Tennessee
Steve Goins, Tennessee Department of Environment and Conservation (TDEC)
Tennessee's state drycleaner fund program has a balance of $5.25 million, Steve Goins said; of this, $2 million has already been obligated for activities at the 56 sites participating in the program. Goins summarized the status of the sites: about 7 of them have been closed, about 40 have been ranked for further investigation, and 10 are in the remedial phase. More sites are expected to enter the program in the near future. Goins said that the following statutory changes emerged out of the last legislative session:

Goins said that Tennessee's program rules will be amended soon. Several changes will be recommended, including: (1) establishing a minimum revenue threshold (i.e., $1.25 million per year), (2) giving the Board permission to raise fees (without having to initiate statutory changes) if the revenue threshold is not met, (3) changing some of the rules that relate to contractors, and (4) requiring all drycleaners to comply with the state's best management practices (BMPs) by October 15, 2007. Expanding on the latter, Goins noted that the program's existing rules offers leniency to drycleaners that were operating prior to the fund program's inception; such facilities do not currently have to meet BMPs before they officially enroll in the fund program.

Before finishing his update, Goins mentioned that the state is using a new approach, informally coined "The Time Versus Certainty" approach, to address a contaminated site in Chattanooga. (This site is described in more detail under Barbara Pyles' case study—see below.) The City of Chattanooga, Goins said, plans to construct a multi-million-dollar office building on the site in the near future. As a result, the City is eager to remediate the site as quickly as possible. TDEC is doing its best to respect the City's timeline, Goins said, and is moving forth aggressively with assessment and remediation activities. TDEC is not willing, however, to be rushed into making decisions about the property. In an effort to meet the needs of the City without compromising the fund program's monies, TDEC is considering the following agreement: using fund program money to implement the assessment and remediation strategy proposed by Chattanooga's contractor, but specifying that Chattanooga will be expected to purchase insurance to cover any costs that exceed $1.2 million. If this approach is used, Goins said, the fund program will not be penalized if the city's contractor proves to be wrong about cost estimates. With this type of insurance in place, he said, TDEC would be more comfortable moving forth with remediation activities at the pace that Chattanooga desires.

Wisconsin
Robin Schmidt, Wisconsin Department of Natural Resources (WDNR)
Robin Schmidt said that Wisconsin's drycleaner fund program rules were amended as follows in order to ensure consistency with recent statutory changes:

Schmidt said that 65 to 75 eligible drycleaning sites are currently enrolled in Wisconsin's fund program. About five of the sites are either closed or in the process of active remediation. Schmidt said that the fund can be used to pay for the lowest-cost remediation strategy. If a site owner/operator wants to use a more expensive, faster-acting technology, he/she must pay the extra costs. Schmidt also noted that site investigation is underway at 24 sites and is scheduled to start at another 5 to 8 sites in the near future. To date, Schmidt said, site investigation costs have averaged about $40,000 per site. These costs are lower than originally anticipated. Some WDNR employees are concerned that the costs are low because site investigators are not searching for contamination as aggressively as they should. Site investigation costs could go up significantly, though, once a new guidance document is released. This guidance, which will be released for comment in about 3 weeks, describes steps that should be taken to assess natural attenuation processes at chlorinated solvent sites. Schmidt said that Wisconsin is also working on a guidance manual that addresses the Resource Conservation and Recovery Act's (RCRA's) "Contained-In-Contained-Out" policy. This guidance is scheduled for release before the end of the calender year.

In closing, Schmidt noted that Wisconsin's drycleaning industry has received some positive press over the last few months. For example, the Wisconsin Fabric Care Institute received the state's Business Friend of the Environment Award, and Hangers Cleaner received a National Pollution Prevention Award.

CASE STUDIES

Cedarburg Drycleaners
Mark Drews, WDNR
Mark Drews presented information about Cedarburg Drycleaner, a site where PCE has been detected in ground-water at concentrations as high as 18,000 ppb. Chlorinated solvents were detected in 1991 during an investigation performed by a neighboring gas station. The drycleaner's status as a responsible party was confirmed when long-time employees reported that past waste management practices involved dumping wastes directly on property grounds. The site's geology is characterized by a thick layer of tight clay, Drews said. And fill material and a sandy permeable layer lie over and under the clay layer, respectively. (PCE has not migrated past the clay layer.) Between 1991 and 1998, several piezometers and monitoring wells were installed and samples were collected and analyzed. In 1995, Cedarburg Drycleaner's consultant proposed a remediation strategy involving ground-water extraction coupled with vapor extraction. The site owners rejected the plan due to concern that this strategy would not perform well in the site's tight clay environment. In 1998, a different consultant convinced the site owners to perform a Hydrogen Release Compound® (HRC®) pilot test on a 10-foot by 6-foot area. Despite promising results, the site owners rejected the consultant's recommendation to move forth with full-scale HRC® implementation. (Drews was unable to provide an estimate of the costs quoted for the full-scale implementation. He did note, however, that it probably would have been very expensive to use HRC® over the site's entire treatment area [200 feet by 70 feet].) In June 1999, the site owners proposed excavating the site's contaminated soils and disposing of them in a landfill. This plan was rejected, however, after the owners learned that landfills in Wisconsin do not accept soils that are characterized as hazardous waste.

In August 1999, the site owners solicited additional remediation strategy proposals. ARCADIS, the consultant whose plan was chosen, recommended using an Immobile Injection Treatment Unit to dig up and churn soils (down to 15 feet below ground surface) and a vent to suck up released vapors. Molasses injections were also included as part of the remedial strategy. (Before the injections could be performed, injection permits had to be obtained from WDNR.) The Immobile Injection Treatment Unit operated between October 1999 and March 2000. Molasses injections were conducted during and after this 1999-2000 time frame. Drews described some of the obstacles encountered with the remediation effort. First, he said, the trenching machine had difficulty digging up and churning the site's tight clay. In addition, the presence of preexisting sumps necessitated the unanticipated removal and treatment of 46,000 gallons of water. These obstacles caused some cost overruns. As a result, even though the cost originally proposed for the remedial strategy was in the range of $350,000, about $400,000 has already been spent. Drews said that ARCADIS has not submitted substantial post-remediation ground-water data yet, so he could not comment on the treatment strategy's efficacy. He does expect to receive data soon, though. ARCADIS is preparing a site closure request for WDNR.

Drews fielded questions from the audience. Jurgens asked whether there has been any settling or recompaction problem. Drews was not aware of any. Another attendee asked whether rebound has been an issue. Drews said that he was unable to answer the question because he has not seen much post-remediation ground-water data. He did indicate that WDNR understands that a decision about site closure would have to be postponed if molasses were injected into the site in 2002. More time would need to pass to determine whether ground-water concentrations would rebound following the injection.

Garden City Laundry
Bob Jurgens, KDHE
Jurgens provided information about Garden City Laundry, a former drycleaning site located about 1,500 feet cross- and upgradient from a public water supply well that has low-level PCE detections. (His presentation is included as Attachment B.) Jurgens said that KDHE identified Garden City Laundry as a potential PCE source in 1995. The following year, KDHE received an application requesting inclusion in the state's drycleaner fund program. The site received a high priority ranking due to its proximity to a public water supply well. Assessment activities, which totaled about $45,000, were completed in September 1997. Following assessment, Jurgens said, KDHE focused its efforts on protecting the public water supply well. Toward this end, in 1998, a KVA C-Sparger system was installed downgradient of the source area. The system, which operated between 1998 and 2002, experienced several cumbersome equipment failures. These problems resulted in unplanned system shutdowns and delays. Despite these problems, influent concentrations in the treated area fell from 18.5 ppb to 1.5 ppb. Although the end results were satisfactory, Jurgens said, he was not sure he would choose the KVA C-Sparger as a plume containment strategy again. Although the technology's vendor touts the KVA C-Sparger as a low-cost option, KDHE did not find this to be the case. Costs incurred totaled about $116,000, with design, installation, and startup costs amounting about $29,000; equipment reaching about $31,000, and operational and monitoring costs reaching an unexpectedly high $56,000. In addition to containing the plume, Jurgens said, KDHE addressed the site's source, an area with maximum PCE concentrations in the 35 ppb to 48 ppb range. SVE combined with air sparging was chosen as a remedial strategy and pilot-tested. After producing favorable results, the SVE/air sparging system was implemented full scale. Costs incurred totaled about $152,000. Over about 4 months, Jurgens said, the SVE/air sparging system succeeded in cleaning up the source area. At least 250 pounds of volatile organic compounds were removed from each of three SVE wells that were installed, and PCE concentrations in ground water dropped from 48 ppb to non-detect levels. Rebound has not been observed, Jurgens said, but KDHE will continue to monitor the site for a couple more years. The site is moving toward closure.

In his presentation, Jurgens included slides depicting the SVE/air sparging system. He noted that the entire system was housed in a non-conspicuous mobile trailer that did not attract complaints or attention from neighboring property owners. Using a trailer to house equipment, Jurgens said, carries several benefits. Most importantly, it helps KDHE save money because the trailer can be easily moved to other contaminated sites and reused.

Remediation Activities at Three Sites
Barbara Pyles, TDEC
Mark Harrison and Stanford Lummus, S&ME, Inc.
Barbara Pyles, Mark Harrison, and Stanford Lummus teamed up for a presentation on three chlorinated solvent sites. They focused on the Butcher Block site, but also discussed two other sites, seeking to provide information on successes achieved using permanganate injections and SVE/air sparging technologies. Detailed information about the sites is included as Attachment C.

The South Carolina Site and the Georgia Site
Lummus provided information about:

The Butcher Block Site
Pyles and Harrison provided an overview of the Butcher Block site, a 200-foot by 250-foot block located in downtown Chattanooga, Tennessee. Pyles said that a drycleaner operated at the site for more than 20 years, but that the facility was removed in the early 1980s. The drycleaning site is now considered an abandoned facility. On February, 28, 2002, she said, the City of Chattanooga, applied to have the site enrolled in Tennessee's state drycleaner cleanup fund program. (The City paid all the necessary back fees.) At the same time, the City indicated that it hoped to have an eight-story office building and parking garage constructed at the Butcher Block site. Because the site has been targeted for redevelopment, Pyles said, the City is eager to assess and remediate it as possible. The following activities have already been performed:

Pyles said that the Butcher Block site is unique in many respects. It is the first of the fund program's drycleaning sites that is also designated as a Brownfield site. Unique approaches are being used to pay for the site's assessment and remediation activities. (For example,"The Time Versus Certainty" approach has been developed to address this site. See Steve Goins' presentation for more details.) Also, efforts are currently underway to determine whether there are any old insurance claims that could be used to cover cleanup activities at this abandoned drycleaning site.

Hanners Drycleaner
Jennifer Farrell, FDEP
Farrell provided information about Hanners Drycleaner, a former drycleaning site where PCE contamination was recorded at concentrations reaching 37 ppm in the soil and 42,000 ppb in the ground water. TCE, cis-dichloroethylene, and vinyl chloride were also present in the soil and ground water at concentrations exceeding target cleanup levels. Assessment activities, which were completed in 1998, showed that a 25-acre contaminant plume was emanating from the site. Fortunately, Farrell said, the plume did not impact a nearby Well Protection Area. Farrell provided information about the site's geology: the depth to ground water is 7 feet and the subsurface is characterized by a medium-grade coarse sand with silt and limestone fragments. Farrell spent the remainder of her presentation discussing the remedial strategies that have been used to clean up the site. First, in May 2000, excavation was performed to remove contaminated soil from an area surrounding a former underground storage tank. Next, two more remedial technologies were deployed at the site:

Farrell's presentation, which is included as Attachment D, provides additional detail on the remedial strategy's technical aspects and design, performance results, costs, benefits, and drawbacks. Her presentation also provides a summary of the lessons learned at the site.

Donaldson's One-Hour Cleaners
Jennifer Tobias, WDNR
Jennifer Tobias, whose presentation is included as Attachment E, provided information about remedial activities performed at Donaldson's One-Hour Cleaners. This site's subsurface is characterized by a 9-foot clay layer that is underlain by 1 to 2 feet of rubble, which in turn sits on top of fractured bedrock. Tobias said that Lake Winnebago, a drinking water source, is located about 1 mile from the drycleaner. Prior to initiating remedial activities, Tobias said, contaminant concentrations in soils were detected at concentrations reaching 660,000 ppb for PCE, 3,000 ppb for TCE, 3,100 ppb for cis-dichloroethylene, and 500 ppb for vinyl chloride. Contaminants were also present in the ground-water—maximum concentrations detected in one source area monitoring well reached 55,000 ppb for PCE, 6,400 ppb for TCE, 19,000 ppb for cis-dichloroethylene, and 1,600 ppb for vinyl chloride. When it came to choosing a remedial strategy for the site, Tobias said, space limitations became an important factor to consider. The source area, she said, is near the drycleaner's back door and is hemmed in by several other commercial buildings. As a result, remediation had to be performed in a very small area. The remedial technologies chosen, Tobias said, included excavation, ground-water extraction, and an SVE/air sparging system. In October 2000, about 59.62 tons of contaminated soil materials were excavated and disposed of off site. (The soils failed the Toxic Characteristic Leachate Procedure [TCLP] and were therefore considered hazardous waste. As a result, the soils were shipped to a landfill in Michigan since no landfills in Wisconsin accept hazardous waste.) In July 2001, Tobias said, a ground-water extraction/SVE well (screened at 6 to 16 feet) was installed at the site, along with an air stripper and blower. The system has been operational ever since. Tobias provided information on the treatment system's accomplishment. Between July 2001 and June 2002, she said, 982,095 gallons of ground water were extracted, 51.62 pounds of solvent were removed from the ground water, and 297.6 pounds of solvent were removed from the rubble. Tobias said that about $231,616 was spent on the site between 1999 and March 2002. (About $92,439 has been spent on site investigation, $60,648 on soil remedial action activities, $66,667 on ground-water remediation, and $11,862 on laboratory expenses.)

INDOOR AIR INTRUSION
Helen Dawson, EPA Region 8
Helen Dawson delivered a 4-hour training session called Evaluating the Vapor Intrusion to Indoor Air Pathway. She opened by asking: why has so much concern been generated about subsurface contaminants vaporizing and intruding indoor air spaces? The reason is two-fold, she said. First, the sheer complexity of the vapor intrusion pathway warrants concern and attention. Also, there is concern that the inhalation exposure pathway might pose greater health risks than other pathways (i.e., ingestion and dermal contact). Dawson said that the vapor intrusion pathway started receiving attention as early as 1987, when articles in Groundwater Monitoring and Review broached the topic. In 1989 and 1990, Massachusetts emerged as a pioneer in addressing the pathway, creating guidance criteria for it. In 1991, Dawson said, the Johnson and Ettinger (J&E) model was published in an effort to predict how volatilization from the subsurface would impact indoor air in overlying buildings. Several variations of that model were developed in the following years. Dawson said that the vapor intrusion pathway has attracted the interest of EPA officials for several years. Recognizing this, Henry Schuver, of EPA's Office of Solid Waste, started developing a guidance document in the late 1990s to address the pathway. The effort has since been taken over by the Office of Solid Waste and Emergency Response (OSWER), which has agreed to ensure that the guidance can be used to address sites in the Superfund, RCRA, and Brownfield programs.

After providing this introduction, Dawson launched into her training materials. The highlights, summarized here, fall under the following topics: lessons learned in Colorado, conceptual models, assessment, the OSWER guidance document, and empirical attenuation factors and reliability assessments.

Colorado Case Studies
Dawson said that the vapor intrusion pathway has been studied extensively at two sites in Colorado: the Colorado Department of Transportation and Redfields Rifle Scope Company. These studies were important, she said, because the findings shattered conventional beliefs about vapor intrusion. For example, according to conventional thinking, indoor air exposure from vapor intrusion is only a problem at sites where ground water is very shallow, contaminant concentrations are very high, and buildings have basements or crawl spaces. At the Colorado sites, however, investigators found that the vapor intrusion pathway was impacting indoor space even though ground water was shallow to moderately deep and the plume concentrations were low to moderate. In addition, problems were identified in buildings of all construction types, including apartment buildings built slab on grade.

The two Colorado sites have the same geology, Dawson said: ground water is located about 20 to 30 feet below ground surface and the subsurface, which is fractured and parted, is characterized by 10 to 30 feet of wind and stream deposits over blocky mudstone and siltstone. Both sites were contaminated with 1-1-dichloroethylene (1,1-DCE), which is a useful vapor intrusion tracer. This is because 1,1-DCE, unlike other solvents (such as PCE and TCE) is rarely found in household products. Therefore, if 1,1-DCE is detected in an indoor air sample, this provides strong evidence that volatile compounds are entering a building via vapor intrusion rather than some other pathway. Dawson said that 1,1-DCE was indeed detected in homes near both sites. To remediate the problem, she said, mitigation systems were installed in the buildings. Follow up monitoring showed that the mitigation systems consistently reduced 1,1-DCE to concentrations that were too low to warrant concern. (Dawson said that a paper has been released documenting the efficacy of mitigation systems; SCRD members expressed interest in obtaining a reference for this paper.)

Conceptual Model
During this part of the training, Dawson challenged SCRD members to reach beyond the generic conceptual model for the vapor intrusion pathway. She described the generic model as one that envisions vapors migrating, via vertical diffusion, through relatively homogeneous and isotropic soils into homes. The model also assumes that contaminant concentrations attenuate steadily as vapors migrate to the surface. In the real world, Dawson said, predicting vapor migration routes and attenuation factors is far more complex. For example, preferential pathways may develop, allowing for lateral movement and providing routes for vapor to migrate directly to buildings. Also, fresh-water lenses can develop seasonally and block vapor migration during part of the year, and fluctuating water tables can affect vapor transmission rates.

Issues Associated with the Vapor Intrusion Pathway
When investigating the vapor intrusion pathway, Dawson said, one seeks to determine whether subsurface contaminants are volatilizing and entering nearby buildings. This can be determined by analyzing samples or using models. Dawson discussed the challenges associated with each of these methods.

Sampling Issues
Ground-water, soil gas, and indoor air samples are used to identify areas that could be impacted by vapor intrusion. Dawson discussed the merits and drawbacks of each type of sampling.

For example, while ground-water data are typically reliable, wells are often far away from receptors of concern. Well screening intervals, water table fluctuations, and recharge can complicate efforts to use ground-water data as a predictor of intrusion. Furthermore, ground-water data must be converted to vapor concentrations using Henry's Law, an exercise that can result in overpredictions.

Soil gas samples, meanwhile, can yield useful predictions, especially if they are collected directly under a building's subslab. But soil gas data are not reliable. No specific soil gas sampling protocol has been endorsed; as a result, there is a lack of consistency in the way samples are collected and analyzed. Furthermore, soil gas results exhibit high temporal and spatial variability.

Common sense would argue, Dawson said, that the most accurate way of determining where vapor intrusion will be a problem is to collect indoor air samples directly from individual buildings. This technique does have some drawbacks:

Information about indoor air background concentrations, Dawson said, has been compiled; SCRD members expressed interest in obtaining this information.

Modeling
Models can be used as screening or predictive tools, Dawson said, but the former application is easier to justify than the latter. Although several types of model are available, EPA chose to post the J&E model on its Web site. Dawson said that this model has been harshly criticized as an underpredictive tool. While it is true that the model often underpredicts problems, Dawson said, this is largely due to the fact that the people using the models are entering inaccurate inputs. All too often, she said, users resort to EPA's default input values without even trying to obtain more site-specific data. In order to cut down on underpredictions, EPA is revising the J&E default parameters to make them more conservative.

OSWER's Vapor Intrusion Pathway Guidance Document
Dawson provided a sneak preview of EPA's guidance document, a draft of which will be released and published in the Federal Register soon. The guidance is being developed, Dawson said, to help people identify sites that might pose an unacceptable health risk via the vapor intrusion pathway and to screen out sites that do not pose such a threat. It does not aim to instruct people on how to delineate the extent and magnitude of risks. Dawson said that the guidance document is structured using a yes/no, flow diagram format. It employs a tiered approach, starting with simple and reasonably conservative screening and gradually progressing toward a more complex assessment involving an increasingly greater input of site-specific data. Dawson walked meeting attendees through the guidance document's structure. She made the following points: (1) several checkpoints are included to ensure that users are really thinking carefully about the issues, (2) the guidance is designed to fast-track activities at problem sites, and (3) a 26-page table listing screening values will be included in the guidance document. Dawson said that EPA plans to offer a 2-day training session on the guidance manual. Sessions will be held in San Francisco, Dallas, and Atlanta between December 2002 and February 2003. (See http://www.epa.gov/ttbnrmrl/indoorair.htm for exact locations and dates.)

Empirical Attenuation Factors and Reliability Assessments
Dawson said that an effort is underway to compile data from sites that have assessed the vapor intrusion pathway. EPA is using the data to evaluate how well different investigative techniques correlate with one another (e.g., estimating soil vapor concentration from ground-water samples) and to perform reliability assessments and determine the validity of the attenuation factors listed in EPA's guidance document. Conclusions made thus far include:

SUBGROUP MEETING REPORTS
SCRD has three operating Subgroups. During the meeting, the Subgroups met in breakout sessions to discuss the status of existing projects and to identify future initiatives. Subgroup leaders were asked to summarize the breakout discussions. Their summaries are presented below.

Program Development/Administration Subgroup
Doug Fitton, the chair of the Program Development/Administration Subgroup, said that Subgroup members are working on two projects:

Technical Issues Subgroup
Jurgens opened his summary presentation by noting that the Technical Issues Subgroup strove to answer the following question when they met: What is the Subgroup's purpose? The answer, Jurgens said, is to provide information to SCRD member states, associate members, represented states, and the general public. Jurgens then proceeded to provide information about the Subgroup's activities.

Assessment Paper
The Subgroup is writing a paper called "Conducting Contamination Assessments at Drycleaner Sites." Several states (Florida, Oregon, South Carolina, Tennessee, and Wisconsin) have already contributed text for the paper. Jurgens encouraged the remaining SCRD member states to submit text as well. (Text should be sent to Bill Linn by November 12, 2002.)

Data Collection Effort—Using Questionnaires To Track Technology Usage
In 1999, Jurgens said, the Technical Issues Subgroup created and distributed a questionnaire to obtain information on assessment and remediation technologies that are used at drycleaning sites across the nation. The Subgroup plans to revise and redistribute the Technology Questionnaire. The goal is to determine whether technology usage patterns are changing over time and to gain information on the successes achieved and obstacles encountered with different technologies. Implementing the data collection effort will involve the following steps:

Site Profiles
Jurgens said that the Subgroup wants to continue moving forward with the Site Profile Project. This will involve adding more profiles to the database and updating existing ones as new information becomes available about technologies' performance and costs (including operational and maintenance costs) and lessons that have been learned. Jurgens' discussion about site profiles prompted dialogue on the following topics:

Other Subgroup Activities/Goals
Jurgens said that the Subgroup is also committed to promoting the expansion of case study presentations at SCRD meetings, as well as encouraging all SCRD members to share information about training opportunities. In the future, he said, the Subgroup hopes to develop a paper about remediation strategies being used at drycleaning sites across the country. Such a paper would be a companion to the abovementioned "Conducting Contamination Assessments at Drycleaner Sites."

Outreach Subgroup
Schmidt said that the Outreach Subgroup has temporarily disbanded. Nevertheless, she is willing to continue providing outreach services to SCRD's other two Subgroups as needed. At this point, the following outreach activities are in the pipeline:

SCRD BUSINESS SESSION

Mission Statement
Perroni asked attendees to review the SCRD mission statement. Attendees did so. They agreed that the mission statement is still relevant. Therefore, it remains:

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

Election of New Subgroup Chairs
DeZeeuw said that it was time to elect new Subgroup co-chairs. Schmidt agreed to stay on as the Outreach Subgroup chair. Goins and Jurgens were elected as the new chairs for the Program Development/Administration Subgroup and the Technical Issues Subgroup, respectively.

Reducing SCRD Meeting Expenses
Attendees revisited the proposal that Steimle had made at the start of the meeting: reduce SCRD support costs by reducing the frequency of SCRD meetings. Attendees indicated that they prefer maintaining the biannual meeting schedule and finding other ways to reduce SCRD-related costs. They proposed the following cost-cutting strategies:

Next SCRD Meeting
Attendees agreed that the next SCRD meeting should only be 3 days long and that no formal technical training component should be included. Instead, case studies will stand as the technical component of the meeting. Attendees agreed that the meeting's agenda will be influenced by the meeting location. For example, the state that is hosting might be asked to present a number of case studies, or a local vendor might be invited to give a presentation. Attendees recommended setting a new stipulation for the next meeting: requiring at least one representative from each state to stay through the SCRD Business Session.

California was recommended as the location for the next meeting. DeZeeuw noted that SCRD has been pursuing participation from this state for a long time. If the meeting is held in California, that state's program managers will be able to attend and present several case studies. Laudon will determine which location in California would be best for a meeting. (Santa Rosa, San Diego, and Sacramento are probably the best candidates.) Attendees agreed that the meeting should be held in April or May 2003, preferably during the first 2 weeks of April. Perroni will send an e-mail to SCRD members polling them on their availability during this time frame.

Attendees expressed interest in improving the quality and uniformity of presentations at their future SCRD meetings. Toward this end, they recommended creating the following:

Next Conference Call
The next SCRD conference call will be held on December 4, 2002, between 11:00 a.m. and 12:30 p.m. Eastern Standard Time.

WRAP-UP AND ADJOURNMENT
DeZeeuw thanked attendees for their participation and expressed appreciation to those who played a role in planning and implementing the meeting.

 

Attachment A: Final Attendee List

State Coalition for Remediation of Drycleaners Meeting
Madison Concourse Hotel
Madison, Wisconsin
October 8–11, 2002


Delonda Alexander
North Carolina Div. of Waste Management, Superfund Section, Drycleaning
Solvent Cleanup Act Program
Environmental Engineer/Project Manager
401 Oberlin Rd., Suite 150
Raleigh, NC 27699-1646
919-733-2801 ext. 317
Fax: 919-733-4811
E-mail: delonda.alexander@ncmail.net

Lisa Appel
Project Manager
Federal and Drycleaning Remediation Section
Bureau of Land and Waste Management
South Carolina Dept. of
Health & Environmental Control
2600 Bull St.
Columbia, SC 29201
803-896-4024
Fax: 803-896-4002
E-mail: appellr@dhec.state.sc.us

William E. Burns, Jr.
Environmental Manager
Florida Dept. of Environmental Protection
Drycleaning Solvent Cleanup Program
MS 4520
2600 Blairstone Rd.
Tallahassee, FL 32399-2400
850-245-8927
E-mail: Bill.Burns@dep.state.fl.us

Eric Cathcart
Hydrogeologist
Federal and Drycleaning Remediation Section
Bureau of Land and Waste Management
South Carolina Dept. of
Health & Environmental Control
2600 Bull St.
Columbia, SC 29201
803-896-4045
Fax: 803-896-4292
E-mail: cathcaef@dhec.state.sc.us

George (Dave) Davis
Chief, Environmental Assessment Section
Alabama Dept. of Environmental Management
1400 Coliseum Blvd.
Montgomery, AL 36130-1463
334-271-7968
Fax: 334-279-3050
E-mail: GDD@adem.state.al.us

Richard (Dick) Dezeeuw
Oregon Dept. of Environmental Quality
Dry Cleaner Program Coordinator
811 SW 6th Ave.
Portland, OR 97204
503-229-6240
Fax: 502-229-6954
E-mail: dezeeuw.dick@deq.state.or.us

Craig Dukes
Environmental Health Manager
Federal and Drycleaning Remediation Section
Bureau of Land and Waste Management
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

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
850-245-8927
Fax: 850-245-8976
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
850-245-8931
Fax: 850-245-8976
E-mail: Douglas.Fitton@dep.state.fl.us

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

Richard Haynes
Section Manager
Federal and Drycleaning Remediation Section
Bureau of Land and Waste Management
South Carolina Dept. of
Health & Environmental Control
2600 Bull St.
Columbia, SC 29201
803-896-4070
Fax: 803-896-4292
E-mail: haynesra@dhec.state.sc.us

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

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

Ken Koon
Environmental Specialist
Missouri Dept. of Natural Resources
ALPD/Hazardous Waste Program
P.O. Box 176
Jefferson City, MO 65102-0176
573-526-3748
Fax: 573-526-8922
Email: nrkoonk@mail.dnr.state.mo.us

Leslie S. Laudon
Sr. Engineering Geologist
Central Valley Reg. Water Quality Control Board
3443 Routier Rd., Suite A
Sacramento, CA 95827
916-255-3422
Fax: 916-255-3052
E-mail: LaudonL@rb5s.swrcb.ca.gov

Rob Murphy
Environmental Engineer
Missouri Dept. of Natural Resources
Hazardous Waste Program
P.O. Box 176
Jefferson City, MO 65102
573-522-9080
E-mail: nrmurpr@mail.dnr.state.mo.us

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

Robin Schmidt
Remediation and 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: Robin.Schmidt@dnr.state.wi.us

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

Jeff Soellner, CF/8
Dry Cleaning Grant Coordinator
Wisconsin Dept. 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: Jeffrey.Soellner@dnr.state.wi.us

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

Dale Trippler
Minnesota Pollution Control Agency
Majors and Remediation Division
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
334-271-7987
Fax: 334-279-3050
E-mail: PWilson@adem.state.al.us

Technical and logistical support provided by:

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

Christine Hartnett
Eastern Research Group, Inc.
5608 Parkcrest Dr. B Suite 100
Austin, TX 78731-4947
512-407-1829
Fax: 512-419-0089
E-mail: chris.hartnett@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. Suite 500
Silver Spring, MD 20910
301-589-5318
Fax: 301-589-8487
E-mail: carolyn.perroni@emsus.com

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

INSTRUCTORS

Kenneth Bradbury
Wisconsin Geological & Natural History Survey
3817 Mineral Point Rd.
Madison, WI 53705-5121
608-263-7921
Fax: 608-262-8086
E-mail: krbradbu@facstaff.wisc.edu

Helen E. Dawson, Ph.D.
Regional Superfund Hydrogeologist
US EPA Region 8
999 18th St., Suite 300
Denver, CO 80202
(303) 312-7841
Fax: (303) 312-6065
E-mail: Dawson.Helen@epamail.epa.gov

OBSERVERS

Mark Harrison, P.G., E.I.
Project Manager
S&ME, Inc.
1413 Topside Rd.
Louisville, TN 37777
865-970-0003
Fax 865-970-2312
E-mail: mharrison@smeinc.com

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

Stanford Lummus, P.E.
Senior Environmental Engineer
S&ME, Inc.
155 Tradd St.
Spartanburg, SC 29301
(864) 574-2360
Fax 864-576-8730
E-mail: slummus@smeinc.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
E-mail: Brenda.Veronda@caruschem.com

Attachments B through E

Attachments B through E are available on the Internet. To view these attachments, visit the SCRD home page at www.drycleancoalition.org, click on the "Members” button, then click on the "Meetings" button. The attachments will be available as part of the October 2002 meeting summary.

Attachment B: Garden City Laundry (Bob Jurgens)

Attachment C: Remediation Activities at Three Sites (Barbara Pyles, Stanford Lummus, and Mark Harrison)

Attachment D: Hanners Drycleaner (Jennifer Farrell)

Attachment E: Donaldson’s One Hour Cleaner (Jennifer Tobias)

Attachment F:
The Program Development/Administration Subgroup’s
Drycleaning Solvent Cleanup Program Components
(Information Submitted by Doug Fitton)

OUTLINE:

Funding Mechanisms

 

Fees/Taxes

 

 

Annual Fees

 

 

 

Full-time Employees (FTE) (MN)
Annual Operating Drycleaning/Wholesale Supply Facility Registration (FL)
License
Sliding Scale
Annual Supplier Registration (AL, TN)
Cleanup Contractor Registration/License (TN)
Considerations:

 

 

 

 

Identifies universe of facilities of concern
Limited fee income may not balance cost for tracking registration
Compliance requires FTE reporting for determination of fee (TN)
Late Fees/Penalties may not encourage compliance
Solvent use tracking from suppliers to ensure compliance (IL)
Compliance tracking difficult if non-program agency collecting fees/taxes

 

 

Gross Receipt Taxes

 

 

 

Flat rate (AL, FL, WI)
Scaled
Percentage of Sales Tax (NC)
Considerations:

 

 

 

 

Compliance tracking
Non-payment of taxes
Partial payment/Under-reporting of applicable gross receipts
Service application of taxes- all services v. drycleaning only
Accountability for interagency reporting
Timely reporting/disbursement of fund balances

 

 

Solvent Fees

 

 

 

Per Gallon rates
Incremental fee increases based on fund balance (OR-former fee structure)
Based on type of Solvent- PCE, Petroleum, other
Fee structure related to compliance controls- License requirement for distribution of solvents (TN, IL, KS), non-compliance penalties
May be paid by Supplier or Drycleaning Facility

(Include range of fees)

 

 

 

Considerations:
Decreases in use leads to decrease revenue
Fee increases may lead to decrease in use, conversion to alternate technologies, use of alternate suppliers
Per gallon fee structure may not include alternate solvents, i.e. CO2, distributed by pound unit in pressurized cylinders

 

 

Risk-based Fees (OR)

 

 

 

Solvent usage (PCE v. petroleum) / Period of operation (OR)
Reflects potential for discharge and likelihood of utilizing program/fund

 

 

Insurance Premiums

 

 

 

Future Liability Coverage (IL)

 

Deductibles

 

 

Sliding Scale (WI)

 

 

 

FTE Sliding scale (OR)

 

 

Phased (IL)

 

 

Fixed

 

 

 

(FL- based upon date of application)

 

Penalties

 

 

Compliance Enforcement Penalties (OR, et al)
Late Fees (FL, MN, OR, WI, TN)
Interest on assessed fees (OR- 9%, et al)

 

Co-payments

 

Interest

 

 

Fund Balance interest

 

Collection Agency

 

 

DOR
Program Agency
Combination (FL: DOR-taxes;DEP-fees)

 

Fund Tracking

 

Annual Revenue/Fund Balance Fee Adjustments

 

 

Fee increase mechanisms

 

Expenditure Limits

 

 

Site Spending Caps

 

 

 

(IL- $160K, FL- none, KS- $250K/yr)

 

Eligibility

 

 

Application

 

 

Fee Payment

 

 

Compliance Enforcement

 

Prioritization

 

Implementation

 

 

Reimbursement / Pre-approval

 

 

Direct Contract (State-lead)

 

Benefits

 

 

Beneficiaries

 

 

 

Active Drycleaning Owner/operators
Inactive Drycleaning Facility Owner/operators
Real Property Owners
Nearby Real Property Owners
Public
Environment

 

 

Liability Protection

 

 

 

Limited
Complete
Exception

FL- cleanup only, conditionally extended to “nearby properties”
OR, TN
no liability protection from federal programs, e.g. RCRA
FL- explicit language regarding limit of federal liability protection

 

 

Funding for Cleanup Programs

 

 

Limits State Costs for Cleanup / CERCLA Cost Share

 

 

Funded Cleanup/Assistance

 

 

Provides Economic Viability for Drycleaning Facility Owner/Operators

 

 

Property Value Revitalization

 

 

Facilitate Property Transfers

 

 

 

Cleanup
Liability Protection

 

 

Wellhead/Water Supply Protection

 

 

Environmental Protection

 

 

 

Site Remediation
Pollution Protection

 

 

 

 

Site Remediation
Pollution Protection
Secondary Containment
Sewer Discharge Protection
Closed-loop Delivery Systems
Hazardous Waste Management

 

 

Risk Management

 

 

 

Site Prioritization
Identification of Potential Sources
Identification of Potential Exposures

 

 

Voluntary Cleanup Programs

 

 

 

Incentives

For Further Discussion:

 

Authority

 

 

Statute

 

 

 

FL- Chapter 376.3078, Florida Statutes

 

 

Rule

 

 

 

FL- Chapter 62-782, Florida Administrative Code

 

 

Guidance

 

 

Program Sunsets

 

 

Application period

 

 

 

FL- December 31, 1998

 

 

 

Program Operation

 

 

 

FL- no sunset

 

 

Long-term Liability Concerns

 

 

Cleanup Criteria

 

 

Soil / Groundwater / Surface Water
(Cleanup Criteria Table ?)
Risk-based

 

 

Site Closure

 

 

NFA Conditions

 

 

 

RBCA
Institutional/Engineering Controls

 

 

Pollution Prevention Requirements

 

 

Secondary Containment
Continual Compliance

 

 

Program Administration

 

 

State Agencies

 

 

 

Environmental/Revenue

 

 

Boards/Council

 

 

Program Structure

 

 

Administrative fees

 

 

 

Review / NFA

 

 

Voluntary Cleanup

 

 

Contract Mechanisms

 

 

Direct Long-term Contracts
Competitive Bid
Approved Contractors / Pre-approved rates

 

 

Cost Controls

 

 

Direct Oversight
Pre-approved Rates

 

 

Web Site Links