WELCOME AND INTRODUCTIONS
Dick DeZeeuw, the chair of the State Coalition for Remediation of Drycleaners (SCRD), welcomed attendees (see Attachment A) to the meeting and provided background information on SCRD’s activities. He said that the group’s main goal is to share information about how contaminated drycleaner sites are being addressed across the country. Most of the people who participate in SCRD, he said, represent states that have already established formal drycleaner cleanup fund programs.
DeZeeuw thanked the California representatives for hosting the meeting and Cheryl Joseph, of the National Ground Water Association (NGWA), for making the logistical arrangements. DeZeeuw provided an overview of the agenda, noting that multiple topics would be covered during the course of the meeting. This “multi-topic” approach, he said, differs from the “theme-oriented” agendas SCRD used in its early days. At the end of the meeting, DeZeeuw said, he wanted attendees to indicate which style they prefer.
Richard Steimle, from the U.S. Environmental Protection Agency, also welcomed attendees and said that two new interns—Tina Petersen and Gabrielle Coovrey—have been hired to assist SCRD members with their projects. Petersen will write case studies on contaminated drycleaning sites that are located in Illinois, Minnesota, Tennessee, and Texas, Steimle said, and Coovrey will work with Bill Linn to collect information on bioremediation projects that have been conducted at contaminated drycleaning sites in Florida.
STATE PROGRAM 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.
Larry Norris, Alabama Department of Environmental Management (ADEM)
Alabama established a drycleaner cleanup fund program in 2001. Revenue has been building in the fund since the program’s inception, Larry Norris said: the balance has reached about $2 million. (See Attachment B for more details.) Drycleaners are not required to participate in the program, he said, but about one-third of them have decided to do so. Program regulations, which have been written and posted for public notice, are due to go into effect in August 2003, at which time ADEM will become more active in enforcing and implementing the drycleaner cleanup fund program. Although ADEM will be heavily involved with assessment and cleanup activities, Norris said, all funds will be controlled by a drycleaner board.
Leslie Laudon, Central Valley Regional Water Quality Control Board (CVRWQCB)
California does not have a drycleaner cleanup fund program established, Leslie Laudon said, but efforts to create such a program are underway. (Details about these efforts are presented later in this report, under Tom Mohr’s presentation.) At one point, Laudon said, she had hoped that the state’s cleanup and abatement account could be used as an informal state drycleaner cleanup fund program. This thought is now moot, she said, because the account has been depleted to address the state’s $35 billion deficit.
Beth Walker and Doug Fitton, Florida Department of Environmental Protection (FDEP)
Beth Walker and Doug Fitton provided a status report on Florida’s drycleaner cleanup fund program. Attachment C provides detailed information about the program’s budget and staffing requirements and the technologies that are being used to remediate drycleaning sites. Walker and Fitton made the following points:
Pat Eriksen, Drycleaner Environmental Response Trust Fund of Illinois
Illinois is also facing budgetary challenges, Pat Eriksen said, but it is not yet clear whether the state’s fiscal problem will impact Illinois’ Drycleaner Environmental Response Trust Fund program. According to some rumors, Eriksen said, some special-use funds could be targeted to alleviate the state deficit. At this point, however, no official notification has been issued to suggest that this will be the case. About 6 weeks ago, he said, a directive was issued indicating that appropriations must be reduced by 8 percent. On April 9, 2003, the Governor will announce how he plans to balance the state’s budget.
Eriksen provided an overview of the drycleaner fund program’s income, expenditures, and site status. (See Attachment D for details.) As of March 28, 2003, the fund balance was about $1.5 million; $1.3 million of this total will be expended during fiscal year 2003. There are currently 162 open claims. Some of these have progressed to the remediation stage, and several others will enter that stage over the next few months. About 189 facilities have received budget approval to conduct intrusive testing. (This testing must be performed by June 30, 2004, in order to receive benefits under the state’s drycleaner cleanup fund program.)
A bill has been presented to the state legislature asking for a the drycleaner cleanup fund program to be extended for 10 years. The bill recently passed the House, but only by the slimmest of margins. When drafting the legislative package, Eriksen said, the Council—the seven-member group that administers the drycleaner fund program—worked closely with the Korean-American Drycleaners of Chicagoland (KADA) and the Illinois State Fabricare Association. In fact, in late February 2003, the Council met with both groups and modified the bill’s language to reflect the changes KADA requested. Despite this fact, KADA has withdrawn its support for the bill.
Bob Jurgens, Kansas Department of Health and Environment (KDHE)
Bob Jurgens distributed a handout (see Attachment E) summarizing the status of the Kansas Drycleaner Facility Release Trust Fund. He made the following major points:
Dale Trippler, Minnesota Pollution Control Agency (MPCA)
Dale Trippler distributed a handout (see Attachment F) summarizing the status of the Minnesota drycleaner cleanup fund program. He made three points about the program’s fiscal status: (1) the program’s income has leveled out, (2) revenue collected from solvent fees has decreased, and (3) revenue from annual registration fees is holding steady. These observations could be interpreted positively, he said, because they suggest that drycleaners have reduced their solvent usage and are not being driven out of business. Trippler said that Minnesota’s Department of Revenue, which collects the solvent and annual registration fees, has negotiated quarterly payment plans with some drycleaners to help the cleaners comply with payment requirements. In Minnesota, Trippler said, drycleaning sites are addressed through either of the following approaches:
Only 16 drycleaners are participating in Minnesota’s drycleaner fund program. MPCA suspects that additional contaminated drycleaners exist, Trippler said, but the agency does not have the authority to go out and search for the sites. In Hennepin County, however, officials plan to start inspecting drycleaning facilities in an effort to identify potential polluters. The drycleaning industry is opposed to this plan.
The state legislature has expressed interest in using the drycleaner fund program, which currently has a balance of about $2 million, to help pay for the state’s $4.2 billion deficit. After hearing of this plan, Trippler drafted a letter to justify the program’s existence. In this letter, he indicated that the fund’s balance will be close to zero by the end of 2003 because payments must be made to reimburse the Superfund program for expenses incurred on drycleaning sites.
Ken Koon, Missouri Department of Natural Resources
Missouri’s drycleaner cleanup fund program, which was established about 2 years ago, is not fully operational yet. Ken Koon said that the following is being done in an effort to get the program up and running:
Since the program’s inception, Koon said, annual registration fees and solvent surcharges have been collected and deposited into the fund. (Annual registration fees, which generate about $300,000 per year, are based on the size of the drycleaner and range from $500 to $1,500. Solvent surcharges, which generate about $600,000 to $650,000 per year, are $8 per gallon for chlorinated solvents and $0.40 per gallon for nonchlorinated solvents.) The fund currently has a balance of $1.3 million. Although some groups have expressed interest in folding this money into the state’s general revenue fund, Koon said, such proposals are not likely to be accepted.
Lisa Taber, North Carolina Department of Environmental and Natural Resources (NCDENR)
Lisa Taber provided an update on North Carolina’s effort to implement its Drycleaning Solvent Cleanup Act (DSCA) program, which Taber described as a state-led/state-contractor program. Detailed information about the program’s fund balance and site status is included in Attachment G. The fund currently has a balance of about $3.3 million, Taber said, but this amount is expected to increase dramatically after April 2003, when a 4 percent sales tax on drycleaning services will be diverted to the DSCA program. This change is expected to raise the fund’s annual revenue by $8 million to $10 million. In an effort to thwart “raids,” Taber said, a large portion of the program’s funds will be encumbered. (The drycleaner cleanup fund program has not been raided before, but similar programs have experienced this fate. For example, in 2002, about $2 million was taken from the state’s underground storage tank, or UST, program to pay for non-UST state expenditures.)
In 2002, NCDENR started accepting applications to the DSCA program. Of the 145 drycleaning facilities that the agency knows about, 74 have voluntarily petitioned to participate in the DSCA program. NCDENR has certified nearly all of them, Taber said, and has approved work plans for eight facilities. After applying to the program, Taber said, facility owner/operators must perform a prioritization assessment and submit the results to NCDENR. The agency uses these data to determine which drycleaning facilities should be addressed first. Money is allocated to the high-priority sites first. No mechanism has been established to encourage low-priority sites to move forth with remedial activities quickly. Taber identified five challenging issues that have emerged in North Carolina:
Dick DeZeeuw, Oregon Department of Environmental Quality (DEQ)
DeZeeuw distributed information (see Attachment H) on the status of Oregon’s drycleaner cleanup fund program. The program is operated almost entirely on a cash flow basis, he said: the fund balance is nearly zero and funds are spent or encumbered almost as soon as they become available. This approach has its pros and cons. While it does make the fund an unlikely target for raiding, it leaves almost no room to address contingencies. Compared to drycleaners in other states, drycleaners in Oregon pay low annual fees (about $2,000) and receive very comprehensive benefits (e.g., unlimited cleanup funds and third party liability protection).
DeZeeuw said that there are 40 drycleaning sites in the program: 10 have been cleaned up and designated “no further action” sites, 7 are in the assessment phase, 7 are being actively cleaned up, and 16 are waiting in the queue until additional resources become available. DeZeeuw provided information (see Attachment H) on the average costs incurred per site, but emphasized that the costs cited might be on the low end. This is because low-priority sites, which were addressed during the program’s early years, are included in the cost averages. As the program starts to focus on higher-priority sites, he said, the averages will likely increase.
DeZeeuw said that Oregon uses a prioritization system to determine which sites should be addressed first under the program’s state-led model. Oregon DEQ does have the latitude, however, to elevate a site’s ranking under certain circumstances. For example, if a site is scheduled for reconstruction, DeZeeuw said, cleanup activities may be pushed forward to coincide with the time when contaminated areas are most accessible (i.e., after demolition is completed but before rebuilding starts). To prevent low-priority drycleaners from sitting idly waiting for their sites to come up in the queue, Oregon has indicated that low-priority drycleaners may begin cleanup on their own and request reimbursement later.
DeZeeuw said that the following legislative changes have been recommended for the program:
DeZeeuw said that there has also been some discussion about privatizing Oregon’s drycleaner cleanup fund program. Audience members said that such proposals have been put forth for other state programs as well. For example, in North Carolina, Taber said, the idea of privatizing the UST program is debated every couple years.
Richard Haynes, South Carolina Department of Health and Environmental Control (DHEC)
Richard Haynes distributed a handout (see Attachment I) summarizing information about South Carolina’s drycleaner cleanup fund program. The fund balance forwarded to fiscal year 2003 was about $3.4 million, he said, but noted that much of this has already been obligated. During last year’s state budget crunch, Haynes said, some people proposed using the fund’s money to pay for other state programs. These proposals were abandoned, however, when the drycleaning industry voiced strong opposition. The fund’s revenue has declined over time, Haynes said, noting that $620,000 in revenue is expected this year. The following ideas have been proposed to fix this problem:
Haynes said that 303 facilities are included in the program. Of these, 1 is pending closure, 3 are in the remediation phase, 1 is being monitored, and 29 are being assessed. Haynes also provided information (see Attachment I) about technologies that are being used to address drycleaning sites in South Carolina.
Steve Goins, Tennessee Department of Environment and Conservation (TDEC)
Steve Goins distributed a handout (see Attachment J) summarizing the status of the Tennessee drycleaner cleanup fund program. As of February 28, 2003, the program had a balance of $5.5 million, Goins said, noting that $2.8 million of this total has been obligated. In 2003, Goins said, the funds expended by the program will exceed those collected and the fund balance will decrease. Goins expressed concern about the fund’s safety, noting that a bill has been drafted to give the state the authority to use money from reserve accounts and dedicated funds to balance the state’s budget. Goins said that the drycleaner fund program’s Board members will oppose this bill. In fact, he said, the Commissioner plans to meet with representatives from the Governor’s office to explain why the fund’s money should be allocated specifically to drycleaners.
Goins said that Tennessee’s drycleaner fund program is based on a reimbursement model and that there is no deadline for entering the program. Goins said that 8 sites have received “no further action” letters and 54 sites are actively involved in the program. Of these, nine sites are in the prioritization investigation stage and are being investigated to determine whether they are contaminated. Even if these sites prove to be clean, Goins said, the state will pay the investigation costs incurred.
During the last legislative session, Goins said, the drycleaner cleanup fund program’s statute was amended to base annual registration fees on solvent usage rather than full-time equivalents and to give the Board the authority to set the fee categories. The Board has followed through on its assignment and has written a set of rules (see Attachment J), posted them for public comment, and submitted them to the Attorney General’s office for approval. Goins said that TDEC is pleased with the revised statutory language and the Board’s rules, noting that it took years of hard work to get the legislative amendment passed. Despite this effort, the amendment is now under threat. In fact, a bill has been proposed to undo the amendment. If it passes, the Board will no longer have the authority to establish a schedule of annual registration fees based on solvent usage.
Robin Schmidt and Jeff Soellner, Wisconsin Department of Natural Resources (WDNR)
Robin Schmidt distributed a handout (see Attachment K) summarizing the status of the Wisconsin drycleaner fund program. She said that the program is structured as a reimbursement program. Drycleaner owner/operators are expected to initiate investigation and cleanup as soon as possible, regardless of whether there is money immediately available in the drycleaner fund to reimburse them for their expenditures. While all eligible drycleaners will eventually be reimbursed, Schmidt said, they may have to wait in the queue for reimbursement if there is not enough money in the fund to cover their expenses. In Wisconsin, 25 percent of the program’s yearly funds are used to reimburse high-priority drycleaners, and 60 percent and 15 percent of the program’s funds are used to pay for medium- and low-priority drycleaners, respectively.
In July 2003, Schmidt said, WDNR’s annual spending authority for the program will be reduced from $3 million to $1 million. The fund program’s balance currently exceeds $1 million, however, and WDNR would like to use the excess to pay for backlogged reimbursement claims. Thus, WDNR will ask state legislators to raise the agency’s spending authority to the level of the fund balance. Jeff Soellner provided information on the fund’s spending projections. Starting in 2006, he said, WDNR will probably start spending more than it takes into the fund.
Schmidt said that statutory changes have been recommended practically every year since the drycleaner cleanup fund program was established. This is because the statute, which was written by the drycleaning industry, contains prescriptive language and advocates some programmatic elements that have proven to be ineffective. In past years, Schmidt said, WDNR introduced proposals for the statutory amendments in the state’s budget bill. This practice will no longer be allowed, however, since Wisconsin’s new Governor has indicated that all non–fiscal-related items must be removed from the budget bill. Thus, WDNR is looking for a new vehicle for its proposed statutory amendments. One statutory change that WDNR will propose, Schmidt said, involves extending the deadline for reimbursement claim submittals. The existing statute states that reimbursement claims will not be accepted after August 30, 2005, for any facility closed before September 1998, or after August 20, 2008, for all other facilities. As a result, in order for drycleaners to obtain full reimbursement for cleanup costs, Schmidt said, they must complete cleanups before these dates. These approaching deadlines are of concern to the drycleaning community. Thus, WDNR proposes amending the statute to say that all potential claim forms must be submitted before August 30, 2008, in order for a facility to be considered for reimbursement. If this modification is accepted, drycleaners will simply need to let WDNR know if contamination is present and whether a cleanup is planned by the August 2008 deadline. Such a modification would extend the life of the drycleaner cleanup fund program. Schmidt said that the drycleaning industry is split in its opinion about how long the program should operate. New drycleaners, many of whom are using green cleaning agents, do not want to pay into the fund in perpetuity, arguing that they are not the culprits responsible for environmental contamination. Drycleaners who have been in business for years, however, want to ensure that the program has a long life.
Schmidt also noted that Wisconsin recently completed the following two documents: (1) Guidance for Hazardous Waste Remediation and (2) Understanding Chlorinated Hydrocarbons Behavior in Groundwater: Investigation, Assessment, and Limitations of Monitored Natural Attenuation. The latter, Schmidt said, describes how to assess natural attenuation processes at chlorinated solvent sites.
Schmidt made two additional comments before ending her presentation: (1) Wisconsin has modified its database to make it easier to collect information on the types of remediation technologies that are being used in the state, and (2) WDNR is wrestling with indoor air vapor intrusion concerns. Expanding on the latter, Schmidt asked a series of questions. If a drycleaner-related plume travels under residences, she asked, should the drycleaner fund program be used to pay for indoor air sampling at each and every home that overlies the plume? Or should a subset of homes be sampled instead? If the latter, what process should be used to select the homes? What methods should be used to communicate risk to the community?
Jurgens introduced the three speakers who had been selected to present information on bioremediation. He said that a number of strategies fall under the bioremediation umbrella, and that each speaker would discuss a different approach for remediating tetrachloroethylene (PCE) contamination via biological pathways.
Bioaugmentation With KB-1™ for In Situ Treatment of
Phil Dennis, SiREM
Phil Dennis, whose presentation is included as Attachment L, discussed bioaugmentation, a process that involves adding microorganisms to contaminated sites. Dennis focused on Dehalococcoides, a family of reductive dechlorinators that foster the following chain of conversions: PCE --> trichloroethylene (TCE) --> 1,2-dichloroethylene (1,2-DCE) --> vinyl chloride --> ethene. Many microorganisms are capable of causing at least some of these conversions, Dennis said, but those in the Dehalococcoides family are the only ones known to mediate complete dechlorination of chloroethenes to ethene. At sites where indigenous Dehalococcoides is not present, he said, reductive dechlorination often stalls out at the cis-1,2-DCE stage. Dennis said that Dehalococcoides are not ubiquitous throughout the environment; in fact, research reveals that they are absent at 20 to 30 percent of contaminated sites. SiREM has developed molecular techniques that can be used to determine whether indigenous Dehalococcoides are present at chloroethene-contaminated sites. (The analytical costs are $500 per sample, Dennis said, noting that three samples are typically needed to characterize a site.) If members of the Dehalococcoides family are absent, Dennis said, site owners should consider augmenting bioremedial processes by injecting KB-1™ into the subsurface. He said that KB-1™ is a mixed anaerobic culture that contains about 30 organisms, some of which are in the Dehalococcoides family. The product is free of known pathogens and does not contain genetically modified organisms.
Dennis said that KB-1™ is being used at sites across the nation. He listed eight sites (see Attachment L) where KB-1™ field demonstrations have been performed and provided detailed information about a project completed at Kelly Air Force Base (AFB), a site characterized by aerobic ground-water conditions and chlorinated volatile organic compound (CVOC) contaminants in the 2 parts per million (ppm) range. When characterizing the site, Dennis said, researchers found that (1) PCE was the predominant contaminant, (2) some TCE and cis-1,2-DCE were present, (3) vinyl chloride and ethene were absent, and (4) Dehalococcoides organisms were absent. A control plot was established at the site, Dennis said, to determine how adding an electron donor (i.e., an acetate/methanol mixture) would impact the ground water. At the KB-1™ test plot, an electron donor was added to the subsurface during a pre-bioaugmentation phase and KB-1™ was injected to the subsurface soon after. Samples were collected throughout the entire process. The results showed that adding an electron donor stimulated PCE and TCE degradation, but failed to stimulate reductive dechlorination past the cis-1,2-DCE stage. In the plot where KB-1™ was injected, however, cis-1,2-DCE degraded rapidly and vinyl chloride and ethene appeared. In fact, about 115 days after the KB-1™ injection, Dennis said, PCE, TCE, and cis-1,2-DCE had all fallen below Maximum Contaminant Levels (MCLs); vinyl chloride was detected at 25 parts per billion (ppb); and ethene was detected. In summary, Dennis made the following conclusions about the Kelly AFB case study: (1) bioaugmentation with KB-1™ stimulated complete dechlorination; (2) the electron donor, when used in isolation, could not stimulate complete dechlorination; (3) dechlorination rates were faster in the field than in microcosms; (4) KB-1™ was well distributed in the subsurface; and (5) the KB-1™ did not travel outside of the test plot.
Substrate-Release Composition™ (SRC™)
Eric Hince, Geovation Consultants
Eric Hince, whose presentation is included as Attachment M, opened his presentation by providing background information on the challenges encountered cleaning up dense non-aqueous phase liquid (DNAPL) sites. He described the fate and migration characteristics of DNAPL, difficulties associated with DNAPL characterization, and issues that one should address when developing a remediation plan. He warned attendees that there is no cheap and easy solution for DNAPL sites. Given this reality, he said, at any given DNAPL site, it is important to make sure that the nature of the problem is well understood, the objectives are clear, and expectations are properly managed. Bioremediation is one approach that can be used to address contaminated DNAPL sites, Hince said, and Geovation’s SRC™ can be used to enhance bioremedial processes.
In contrast to the product described by the previous speaker, Hince said, SRC™ does not contain microorganisms. Instead, SRC™ consists of a complex blend of substrates and nutrients that help enhance anaerobic bioremediation processes and support microbial populations that are already present in the subsurface. Hince said that SRC™ can be applied directly into wells and/or with filter socks. The product, which is in briquette form, is designed to simplify or improve substrate-treatment logistics, substrate transport/dispersion, and anaerobic biodegradation/mineralization processes. Expanding on these points, Hince noted that SRC™ is easy to apply; does not require injection or mixing; minimizes treatment labor; can be applied in a fashion that targets the water table, vapor halo, or smear zones; and exhibits enhanced diffusion-driven lateral substrate dispersion as well as enhanced density-driven vertical substrate transport. In addition, Hince said, the SRC™ product’s complex substrate chemistry fosters stable, low-Eh, less acidic conditions, and promotes the growth of a robust consortium of anaerobic bacteria, archaea, and fungi. Microbial diversity, Hince said, enhances anaerobic catabolism and promotes mineralization of recalcitrant compounds. Hince said that stalling (i.e., buildup of cis-1,2-DCE and vinyl chloride) is not observed when SRC™ is used.
Hince provided information about the approach Geovation uses to design treatment plans. In addition, he presented case studies (see Attachment M) to provide evidence of the positive results that have been achieved using SRC™ in the field. He also summarized the advantages SRC™ offers over other remedial alternatives. For example, he said, SRC™ is easy to implement; is a feasible approach for enhancing anaerobic degradation; is relatively low cost; and requires no major construction, facilities, utilities, or power. In addition, Hince said, the diffusion- and density-driven dispersion patterns exhibited by SRC™ make the product well suited to address DNAPL sites.
Biological Reductive Dechlorination of Chlorinated Compounds
Barry Molnaa, ARCADIS
Barry Molnaa, whose presentation is included as Attachment N, discussed the goals that underlie bioremediation, the processes involved, the benefits offered, and the challenging questions that have been posed about bioremediation technologies. Bioremediation technologies are designed to enhance ongoing biological degradation of CVOCs, the goal being to convert PCE to nontoxic ethene. Molnaa said that two schools of thought exist in the bioremediation world. While some advocate bioaugmentation, others opt for approaches that enhance the degradative activities of indigenous microorganisms. (Enhancement can be accomplished by injecting materials that foster anaerobic conditions, contribute a carbon source, and/or foster low redox potentials.) It is not clear whether one approach is better than the other, Molnaa said.
Molnaa presented a conceptual model explaining how bioremedial processes promote CVOC degradation. When a degradable carbon source is injected into the subsurface, he said, this helps establish a variety of reactive zones, each of which supports a different set of microorganisms and degradation processes. Molnaa said that three basic reductive dechlorination pathways operate in the subsurface: hydrogenolysis, cometabolic degradation, and dehalorespiration.
ARCADIS has used bioremedial technologies at about 150 sites, some of which have reached closure. Compared to other technologies, Molnaa said, bioremediation offers several benefits. For example, bioremedial technologies take advantage of existing site conditions, use readily available reagents (e.g., food-grade products), foster full contaminant degradation, inflict minimal physical impacts, are easy to install and manage, can be scaled up easily with minimal effort, and are less costly and more reliable that pump-and-treat systems. Moreover, Molnaa said, over the years, bioremediation has come to be accepted as a well-proven, proactive, and aggressive in situ treatment strategy. Despite these glowing accolades, the following questions persist about bioremediation technologies:
Attendees asked questions about the following topics:
INDOOR AIR VAPOR INTRUSION
Joye Cleaners—A Case Study in Indoor Air Sampling
Lisa Appel, South Carolina DHEC
Lisa Appel, whose presentation is included as Attachment O, provided information about Joye Cleaners, a site that was evaluated for its potential to pose indoor air vapor intrusion problems. Appel said that shallow PCE and TCE ground-water plumes have formed under the drycleaner and have spread under nearby businesses and residential areas. To determine whether contaminants could be vaporizing off the plumes and entering buildings, DHEC performed the following activities:
Panel Discussion on the Indoor Air Vapor Intrusion Pathway
Leo Henning, KDHE; Lisa Taber, NCDENR; Doug Fitton, FDEP; and Roger Brewer, San Francisco Bay Regional Water Quality Control Board
Overview of EPA’s New Guidance Document
Henning said that EPA has created a guidance document to help people address concerns about the indoor air vapor intrusion pathway. The document, which is in draft form, helps people (1) identify sites that might pose an unacceptable health risk via the vapor intrusion pathway, (2) screen out sites that do not pose such a threat, and (3) determine whether additional information must be collected to properly assess the issue. Henning said that the document, which can be found at http://www.epa.gov/correctiveaction/eis/vapor.htm, addresses residential settings rather than commercial or industrial settings. He also noted that the document presents indoor air target levels, all of which are based on a 10-4 risk level. One strong message that comes through, he said, is that indoor air sampling does not need to be performed at each and every residence that is located near a contaminated site. As an alternative, he said, the EPA document advises using soil gas data and subslab sampling data to determine where indoor air problems are most likely before choosing a subset of houses to target for indoor air sampling. Henning said that the document has received criticism from industry representatives as well as some regulators. For example, while some people believe the 10-4 risk level is too conservative, others do not think it is conservative enough.
Henning asked panel members to provide information on the approach states plan to use to address the indoor air vapor intrusion pathway. Commentary was offered by representatives from the following states:
Henning encouraged audience members to ask questions. The following topics were discussed:
PRESENTATIONS RELATING TO ACTIVITIES IN CALIFORNIA
Assessing Potential Impacts to Drinking Water Quality
Tom Mohr, Santa Clara Valley Water District (SCVWD)
Tom Mohr, whose presentation is included as Attachment P, provided historical information about ground-water use in the Santa Clara Valley. At one point, he said, the valley’s residents relied solely upon surface water for their water needs. As time progressed, wells (many of which are now abandoned) were dug throughout the valley to supply water to the growing fruit orchard industry. By the early 1900s, the aquifer was in overdraft, extensive subsidence resulted, and water had to be brought in from other sources to address the problem. In response to the discovery of solvent contamination from the high-tech industry in the early 1980s, monitoring wells have been established throughout the basin and sampled regularly. (In fact, Mohr said that there are currently about 27,000 monitoring wells in the area.) During sampling events, low concentrations of chlorinated solvents have been detected in monitoring wells and water supply wells. In many instances, the contaminated wells were not within the paths of plumes that originate from large industrial polluters. As a result, it was concluded that small businesses are responsible for much of the contamination.
Mohr said that a study is underway to examine the impact drycleaning operations have had on water supply wells in the Santa Clara County. The study aims to prioritize site investigation activities by determining which drycleaners are the most likely polluters and juxtaposing this information with ground-water sensitivity data. The study, which will cost about $70,000, will be completed in September 2003 and will be posted on the SCVWD Web site. Mohr provided detailed information about the methodology that is being used to perform the study and listed factors that are being used to generate a drycleaner threat index. These factors include the time period in which the drycleaner operated, the number of years the facility operated, the type and amount of solvent used, the type of cleaning equipment and waste management practices used, proximity to drinking water wells, the type of soil that surrounds the facility, depth to ground water, proximity to abandoned wells and other vertical conduits, and the proximity of sewer lines to the water table. Mohr said that the study also has an additional objective: assess ongoing drycleaner remediation projects, determine how they are performing, and evaluate the relationship between successful remediation and site investigation budgets.
Before concluding his presentation, Mohr talked briefly about SCVWD’s effort to establish a drycleaner cleanup fund program for the state of California. He said that legislation has been drafted and introduced as Assembly Bill 698—The California PCE Environmental Cost Recover Act. The bill’s progress can be tracked on the Internet by visiting http://www.leginfo.ca.gov. As currently written, Mohr said, the bill proposes raising revenue through solvent fees (e.g., $10 per gallon of PCE) and annual registration fees (e.g., $1,500 for drycleaners and $5,000 for PCE wholesalers).
Rule 1421—Control of PCE Emissions From Drycleaning Systems
Jill Whynot, South Coast Air Quality Management District (SCAQMD)
Jill Whynot, whose presentation is included as Attachment Q, provided information on efforts SCAQMD has made to curtail PCE usage at drycleaning facilities. SCAQMD, one of about 35 regional air quality agencies in California, has a comprehensive air toxics program and adopts about three or four rules each year in an effort to reduce toxics emitted by specific industries. In 2002, the drycleaning industry was the subject for rulemaking because drycleaners emit PCE, a chemical that has been categorized as a probable/possible human carcinogen and has been linked to a variety of non-cancer health effects. Given these health concerns, Whynot said, SCAQMD drafted a rule that phases out PCE-using drycleaning machines and encourages the use of alternative cleaning approaches, such as wet cleaning, carbon dioxide (CO2) machines, and/or machines that use non-PCE solvents. Even before the rule was issued, Whynot said, about 100 of the 2,100 drycleaners under SCAQMD’s jurisdiction had already switched to alternative cleaning methods.
SCAQMD considered many issues when drafting the text for the rule, Whynot said. For example, the agency obtained PCE emission estimates, considered economic impacts, weighed the tradeoff between reducing PCE emissions and increasing smog-inducing DF2000 emissions, and listened to drycleaners’ concerns regarding the uncertainty of future regulatory requirements. Using this information, SCAQMD proposed text for a rule and submitted it to the Governing Board. The text was amended significantly.
The final rule offers a good compromise, Whynot said: while it does contain the end goal proposed by environmental groups, it also includes ideas recommended by industry members. The rule stipulates that all PCE drycleaning machines must be phased out by 2020. In addition, the rule sets nearer-term deadlines for the phaseout of converted machines and stipulates that any PCE machines still in use as of November 2007 must have both primary and secondary controls. A strict posture was taken with brand new facilities, she said. Any facility that opens after January 1, 2003, will be unable to obtain a permit for a PCE machine. A $2 million grant program has been established to assist drycleaners with equipment conversion.
Attendees asked Whynot questions about the following topics:
RECOVERING INSURANCE ASSETS
Finding Funds To Address Environmental Liability
Steve Henshaw and Paul Wildrick, Environmental Forensics Investigations, Inc.
Steve Henshaw, whose presentation is included as Attachment R, said that Environmental Forensics Investigations, Inc., is a full-service environmental engineering and legal support firm that helps companies and individuals use historical insurance policies to pay legal, site investigation, and cleanup fees. The company is currently helping about 35 drycleaners with such activities. He said that states benefit when drycleaners obtain money from insurers because this money can be used to pay for expenses that would otherwise fall upon the state. In Oregon, he said, the state hopes to use insurance money to pay for expenses that are currently being charged to the drycleaner cleanup fund program. Some states are more amenable to the idea of using historical insurance claims than others, Henshaw said.
Henshaw provided information about which insurance policies are most likely to cover environmental pollution damages. Most policies written after 1985, he said, have pollution exclusion clauses and are therefore unlikely to provide coverage for site investigation and cleanup costs. Policies written before the mid-1980s, however, typically lack such exclusions and can be called upon to pay for expenses that result from unintended environmental pollution. Most drycleaners do not realize this, Henshaw said, and many of them do not even keep track of their policies. Environmental Forensics Investigations, Inc., helps drycleaners find their old policies, tender insurance claims, defend against third-party liability suits, negotiate insurance settlements, resolve liabilities, and identify other responsible parties. Insurance coverage falls under two categories: indemnity and defense. While cleanup and settlements fall under the former category, Henshaw said, the following activities are addressed under the latter: building a case against the insurance carrier, performing site investigation, searching for other responsible parties, conducting interim remedial measures, interfacing with agencies, paying legal fees, and recovering costs.
Paying for Environmental Liabilities Using Historical Insurance Policies
Matthew Cockrell, Matthew W. Cockrell and Associates
Jay Goldstein, Envirensics, Inc.
Matthew Cockrell opened by saying that a strong set of environmental case law supports the idea that insurance companies, at least in part, are responsible for the environmental liability of their policy holders. Thus, he said, state representatives should encourage drycleaners to use their Comprehensive General Liability (CGL) insurance policies to obtain funds for site investigation and cleanup. Money obtained from private insurance companies, Cockrell said, can be used to relieve the burden on existing cleanup programs that are supported by public tax dollars.
Cockrell said that CGL insurance policies purchased before 1985 can be used to cover environmental liability costs. He presented a hypothetical scenario to explain how the coverage works. If a drycleaner opened in 1950 and purchased $1 million worth of CGL coverage each year for 10 years, the insurer could be held responsible for up to $10 million in damages. (The $1 million of coverage would kick in for each year that pollution, even one drop, occurred at the site.) There is no statute of limitations, Cockrell said. Even if contamination is not detected until 2003, the drycleaner could make claims on its historic policies as long as at least some of the contamination could be attributed to activities that occurred when the coverage was in place. If a drycleaner has insurance policies from multiple carriers, Cockrell said, claims may be submitted to more than one carrier. Cockrell strongly encouraged attendees to advise drycleaners in their states to collect all their historical insurance policies and store them in a safe place. If drycleaners want to submit claims, he said, they should hire lawyers with experience recovering insurance assets.
Jay Goldstein provided detailed information about the process that is used to recover historical insurance assets. The steps include the following: using insurance archeologists to find historical policies, evaluating the policies’ language to determine whether restrictions apply, determining whether the timing of polluting activities coincides with the policy period, determining whether environmental releases were accidental, proving that property damage (actual or threatened) has occurred, and calculating a price tag for the damages. Goldstein provided detailed information about each step in the process. He also made the following points: (1) the goal is to settle with insurance companies instead of entering into lengthy litigation battles, (2) states have the right to make claims on natural resource damages, and (3) policy holders do not have to adhere to risk-based standards when calculating cleanup costs. Expanding on the latter, Goldstein said that policy holders can sue insurance companies for the amount that would be needed to remediate a site to natural background levels.
Attendees asked the following questions:
Successful Approaches to PCE Remediation
Bill Fisher, International Fabricare Institute (IFI)
Bill Fisher, whose presentation is included as Attachment S, provided information about an IFI site in Maryland that is contaminated with PCE. This site, which operated as a drycleaning facility between 1969 and 1974, served as IFI’s headquarters and research center between 1974 and 1991. In 1992, Fisher said, an adjacent property owner discovered PCE contamination. Subsequent investigations revealed that the contamination came from IFI’s sanitary sewer lines and the Washington Suburban Sanitary Commission sewer trunk line. Both entities were sued for negligence and a jury ruled against them. Fisher said that these events made IFI realize that there was a need to develop programs that assist drycleaners and property owners who have inadvertently contaminated their properties. Thus, efforts to develop state drycleaner cleanup fund programs were initiated.
Fisher said that IFI does not believe that traditional separator water discharge to the sewer lines was the primary pathway responsible for PCE contamination at the IFI site or for contamination at most drycleaner sites. He presented information about the IFI site’s operational practices and investigations that ARCADIS performed. These findings suggest, Fisher said, that most, if not all, of the contamination probably resulted from undocumented spills that date back to 1969, and that mass quantities recovered at most sites are far too large to have come from the ~ 150 ppm saturation level of PCE in water discharges from water separators.
Fisher provided information about the efforts IFI has made to remediate and control the site. In 1996, he said, IFI entered into an Administrative Consent Order with the Maryland Department of Environment (MDE). This order required IFI to achieve MCLs for PCE, perform additional ground-water investigations, address leaking sewer lines, and perform vacuum-enhanced ground-water recovery and treatment. In response, Fisher said, IFI has installed a pump-and-treat system, performed SVE, and collected extensive ground-water monitoring data. (These data can be made available to SCRD members upon request.) As a result of these efforts, he said, ground-water contaminant concentrations have decreased significantly. This has been achieved at a high cost, however: about $7,600 is spent for every pound of PCE removed from the subsurface. Although the plume’s size has shrunk, Fisher said, it has become apparent that pump-and-treat technology will not be able to achieve MCLs at this site. Thus, in recent years, MDE has indicated that alternative cleanup goals can be established if the goals are calculated using site-specific human and ecological risk analysis techniques. In addition, MDE has approved the following plan: IFI will be allowed to shut down the pump-and-treat system for 2 years and evaluate alternate remedial technologies, such as monitored natural attenuation.
In response to questions that he received from the audience, Fisher made the following points:
Ineeda Cleaners—That Plume Is Moving Where?
Bob Jurgens, KDHE
Jurgens provided information about Ineeda Cleaners, an operating drycleaning facility in Hutchinson, Kansas. His presentation is included as Attachment T. An expanded site assessment was completed for this site in 1997. Its results indicated that a 2.5-mile-long PCE plume was present and that maximum concentrations in the plume were about 100 ppb. Results also showed that the plume’s migration pathway was greatly influenced by the IMC Salt Company, a facility that pumped about 1,800 gallons per minute from the aquifer until it closed in 1999. The surrounding area, Jurgens said, has also been impacted by a PCE plume that originated from the Lowen Company.
Jurgens discussed remedial activities that have been performed at Ineeda Cleaners. Work has been performed in the source area, he said, noting that an SVE and KVA C-Sparger system had been installed but that the latter was shutdown in 2003 due to chronic maintenance problems. Some excavation work will be performed soon, Jurgens said, but this remedial technique will not be able to address the entire source area. In the future, KDHE will evaluate additional source zone remediation approaches. For now, Jurgens said, efforts will focus on plume containment and making sure contaminated ground water does not threaten community wells or businesses.
In the late 1990s, Jurgens said, KDHE generated a plume containment plan that included the following elements: (1) entering into a joint venture with the Lowen Company to establish a packed tower air stripper system, (2) installing three remediation wells, and (3) discharging the well water to a ditch. These plans were put on hold, however, when natural gas explosions started occurring in Hutchinson. All remedial activities came to a halt until the townspeople were able to address this problem. This resulted in a 2-year delay. In fall 2002, KDHE refocused attention on the site. Rather than implementing the containment plan immediately, the agency performed additional investigations. This decision proved to be wise. When investigators reexamined the area, they found that (1) PCE concentrations had fallen below MCLs in the locations proposed for the three remediation wells, (2) the plume had shifted to the south and was impacting or threatening five domestic wells, and (3) the highest PCE concentrations in the plume were only 31 ppb. Expanding on the latter point, Jurgens said that an injection well located one block downgradient of Ineeda Cleaners may have played a role in reducing PCE concentrations. (Clean warm water, which was pumped into the aquifer through this well, might have diluted contaminants or stimulated biological activity.) After obtaining the new site investigation information, Jurgens said, KDHE revised its ground-water containment plan. The revised plan does not involve a joint venture with the Lowen Company. Under the new plan, KDHE will install two remediation wells to cut off and contain ground-water flow and the water will be treated with granular activated carbon (GAC) rather than an air stripper. Cargill Salt Company has expressed interest in using the treated water as noncontact cooling water.
Jurgens said that the following lessons were learned during this project: (1) do not rely on historical information, (2) avoid delays if possible, (3) keep abreast of changes in ground-water usage patterns, and (4) perform extensive pre-remedial investigations. Jurgens then opened up the floor to questions. One attendee asked how long KDHE plans to operate its remediation wells. Jurgens said that these wells might operate for 30 to 40 years. Another attendee asked why KDHE decided to use GAC instead of an air stripper. Jurgens said that the former is easier to maintain.
Ozone Remediation of PCE at the Former Market Place Shopping Center
Walter Gerald and Grant Olson, EarthTech, Inc.
Walter Gerald and Grant Olson, whose presentation is included as Attachment U, provided information about a remediation project that is being performed at a site in Hilton Head, South Carolina. A drycleaning facility operated on the site between 1974 and 1992, Gerald said, but the facility has been torn down and replaced by a supermarket.
Chlorinated solvents have been detected in the ground water, with maximum concentrations recorded as follows: PCE (15,300 ppb), TCE (7,170 ppb), cis-1,2-DCE (13,100 ppb), and vinyl chloride (319 ppb). DHEC has signed a Record of Decision (ROD) for the site. Among other things, Gerald said, the ROD specifies that (1) source areas will be addressed using air sparging with ozone chemical oxidation and (2) plume edges will be addressed via monitored natural attenuation. The remainder of the presentation focused on the ozone sparging remediation effort.
Grant Olson provided information about the process that was used to design and implement the ozone sparging system. First, he said, the remediation team had to obtain underground injection control (UIC) permits for the sparge wells and obtain approval from the Hilton Head Island Design Review Board on the placement and appearance of the remediation system. (Hilton Head is a popular vacation spot, Olson said, noting that the community takes great pride in maintaining a high aesthetic standard. For example, for this project, the Board indicated that the equipment storage shed had to be outfitted with professional landscaping and painted with textured paint that matched the color of the adjacent stucco supermarket.) As part of the design process, Olson said, EarthTech Inc., calculated the total ozone demand and the amount of time that would be required to remediate the site. Analysis suggested that 168 kilograms of ozone would be required and that the site could be cleaned up to MCLs in 3 years. Olson presented information (see Attachment U) on the assumptions that were used to calculate these values. He also presented information on the design layout, the individual components of the design, the approach used to install the system, and the cost-saving measures that were used during the installation process. Expanding on the latter point, Olson said that EarthTech, Inc., was able to save $10,000 in installation costs by using alternative tubing for sparge points, using a sonic drilling technique (rather than conventional auger drilling), and using off-the-shelf vaults from home-supply stores for landscaped non-traffic areas. Installation was completed in 2002, and the system started operating on May 31, 2002. About 44.5 kilograms of ozone were delivered to the subsurface between that time and January 2003. Throughout the process, ORP, alkalinity, and chemical oxygen demand (COD) have been monitored. In addition, EarthTech, Inc., has made system modifications as necessary, Olson said, noting that these changes have improved the system’s design and reliability. Results collected to date are encouraging, he said, noting that CVOC concentrations have decreased rapidly. He concluded by saying that ozone sparging appears to be an effective approach for remediating contaminated areas that are located beneath active properties.
Several attendees asked about costs. Olson responded that design and installation
costs for the ozone sparging system were about $317,000, and an additional $110,000
will be required to achieve MCLs at the site. (This estimate assumes that MCLs
can be achieved within the 3-year time period EarthTech, Inc., predicted.) Utility
costs for the system run about $150 to $200 per month.
Black’s Cleaners Update: Bioremediation
Dick DeZeeuw, Oregon DEQ
DeZeeuw, whose presentation is included as Attachment V, provided information about Black’s Cleaners, a drycleaning facility in Portland, Oregon. This facility, which has been operational since the 1950s, used Stoddard as a cleaning solvent until 1959 and then switched to PCE. Soil and ground-water contamination has been detected at the site, and a chlorinated solvent plume extends beyond the site’s footprint and passes under an apartment building. Indoor air vapor intrusion is the main pathway of concern at this site, DeZeeuw said, noting that PCE has been detected in nearby basements at concentrations exceeding risk-based concentrations. Community members know about the contamination and were initially quite angry about it. Sales of two houses fell through once news about the contamination went public. DeZeeuw said that home owners thought it was unfair that their property values had gone down, but that no one could be sued for this. (In Oregon, drycleaners who participate in the drycleaner cleanup fund program are protected from third-party liability suits.) Anger and concern has decreased somewhat, however. This may be due, DeZeeuw said, at least in part to a compelling presentation that a toxicologist delivered to the community.
Between October 2001 and April 2002, DeZeeuw said, pilot studies were performed to determine whether naturally occurring bioremedial processes could be enhanced at this site. Toward this end, two products were evaluated in side-by-side test plots:
The test plots were located downgradient of the source zone, DeZeeuw said, and each plot was equipped with one injection well and two observation wells. Monitoring was performed biweekly during the first 2 months of the study, and once per month for the remainder of the study. According to the results, both products were able to degrade PCE to cis-1,2-DCE, but only the Cl-OUT™ product was able to drive the reductive dechlorination pathway to completion and stimulate cis-1,2-DCE degradation and ethene generation. Because WILCLEAR™ “stalled out,” DeZeeuw said, it has not been selected as a full-scale remedial option for the site. Instead Cl-OUT™ has been selected as a viable approach for remediating the source zone. Although consultants recommend injecting Cl-OUT™ on a monthly basis, Oregon DEQ has opted for bi-annual injections because the more aggressive treatment schedule, which would cost $110,000, is too expensive. DeZeeuw said that two additional activities have been initiated to address the source zone:
DeZeeuw thanked attendees for their attention and suggested contacting Bruce Gilles, the site’s project manager, for additional information about the site.
Butler Cleaners Update: Co-oxidation
Doug Fitton, FDEP
Fitton, whose presentation is included as Attachment W, discussed remedial activities performed at Butler Cleaners. This site, he said, was used as a gas station and automotive repair shop before being converted to a drycleaning facility in the 1960s. A drum of solvent was discharged behind the facility in 1972 and backdoor dumping has also occurred. Contaminants have migrated to ground water, and presumptive evidence suggests that DNAPL is present 10 to 15 feet below ground surface. Most of the assessment activities at this site were performed between 1996 and 1998, but some supplemental investigation activities occurred in March 2001.
In an effort to identify a treatment technology for the source area, Fitton said, FDEP and its consultants have piloted a variety of innovative approaches. For example, between October 1999 and August 2000, a potassium permanganate [KMnO4] ISCO demonstration study was performed; the results indicated, however, that the technology was unable to meet FDEP’s remedial objectives. While KMnO4 injections did cause PCE concentrations to decrease, Fitton said, the effect was only transitory.
In an effort to bolster the remedial capacity of the ISCO technology, FDEP and its consultants decided to combine the KMnO4 ISCO technology with a co-solvent injection. In theory, Fitton said, the cosolvent should eliminate mass flux limitations, solubilize contaminants, and increase the efficacy of KMnO4. Tertiary butyl alcohol (TBA) was chosen as the co-solvent because it is a strong co-solvent and it does not react with KMnO4. The co-oxidation demonstration project, which was initiated in May 2001, used a push-pull technique to distribute materials through the source area. (Injections served as the push and extractions served as the pull.) To initiate the project, 1,000 gallons of 130-degree water were injected into the subsurface to preheat the formation. Next, 1,000 gallons of a hot water/KMnO4 solution were injected into the subsurface. This was followed by another 1,000 gallons of a water/KMnO4/TBA solution. About 8,000 gallons were extracted during the pilot study. According to monitoring results, Fitton said, while PCE concentrations did initially decrease, concentrations started rebounding in May 2002, leaving FDEP to conclude that co-oxidation failed to achieve remedial objectives. Nonetheless, the agency remained optimistic and redeployed the co-oxidation technique in May 2002 using a slightly modified approach. Changes included the following: a five-spot injection/extraction design was used, injections fluids were not heated, and KMnO4 solutions of 30 grams per liter were used rather than 54 grams per liter. Unfortunately, Fitton said, the May 2002 co-oxidation redeployment has not succeeded in lowering PCE concentrations to acceptable levels. He said that this makes him skeptical about using co-oxidation technologies to address DNAPL source zones. If the technology is going to work, he said, it should have worked here, because the site has a small source area and is characterized by fine sands. Thus, he did not recommend performing additional ISCO or co-oxidation projects at this time. Fitton said that remediation efforts at Butler Cleaners have now shifted to ground-water extraction. For example, in February and March 2003, about 26,550 gallons were extracted, treated on site, and disposed of off site.
Fitton concluded by saying that small source areas can cause very large problems. Even though more than $1 million has been spent on remedial activities at this site, PCE concentration in the source zone remains above acceptable levels. Wendy Cohen said that California considers TBA to be a contaminant. She asked whether FDEP had to obtain a UIC permit before it could inject TBA into the subsurface. Fitton said that a permit was indeed required.
Electrical Resistive Heating
Dwight Hoenig, Clayton Group Services
Dwight Hoenig, whose presentation is included as Attachment X, presented information about electrical resistive heating (ERH). He opened by saying that ERH, an in situ remediation technology, works as follows: electrodes are placed in the subsurface, electrical energy is pumped into the system, soil and ground water are heated in the process, contaminants are removed by direct volatilization and in situ steam stripping, and VOCs are collected and treated in an SVE system. Compared to other in situ treatment technologies, Hoenig said, ERH produces rapid results and is one of few technologies that have been shown to reduce ground-water contaminants to MCLs. In addition, he said, ERH effectively removes DNAPL from low-permeability soil and works well in heterogeneous environments. Furthermore, unlike many other technologies, ERH works well at sites that have buildings and utilities. Remedial costs vary from site to site, Hoenig said, but typically range between $57 to $130 per cubic yard. The following factors play a role in determining how costly ERH technology will be at a particular site: (1) amount of surface area to address, (2) thickness and depth of the treatment interval, (3) depth to ground water, (4) total organic carbon content, (5) electrode spacing, (6) the boiling points of the contaminants, (7) average power input required, (8) power costs and seasonal fluctuations in power costs, (9) remedial goals, (10) metrics for success, and (11) whether regulators will require SVE emissions to be treated.
Hoenig presented results from a soil remediation project that was performed at a drycleaning site in suburban Chicago. This site was contaminated with about 3,150 pounds of VOCs. Before remediation, Hoenig said, PCE soil concentrations exceeded the remedial objective of 529 ppm that had been established for the site. In fact, average and maximum PCE soil concentrations were recorded as 1,400 ppm and 13,000 ppm, respectively. Three different remedial alternatives were identified as options: SVE, excavation, and ERH. The latter was chosen as the preferred alternative based on cost, timeliness, and ease of implementation. ERH technology proved to be effective at this site: after applying heat for 120 days, 2,392 pounds of PCE were removed and average PCE concentrations fell to 50 ppm. These results were obtained at a cost of $695,000.
Hoenig also presented information about projects that have been performed to address contaminated ground water, noting that ERH technology has been used as a ground-water treatment technology at 13 sites. In all 13 cases, he said, ERH technology was able to drive contaminant concentrations below site-specific ground-water cleanup goals. For example, PCE concentrations fell from 3,600 ppb to 5 ppb at a drycleaning site in Washington, and the concentration of several CVOCs decreased by more than 98 percent at a large warehouse facility in Skokie, Illinois. At the latter site, Hoenig said, rebound has been observed in two wells but concentrations continue to drop in seven others.
One attendee asked Hoenig whether stray voltage is a problem. If ERH systems are well grounded and designed appropriately, Hoenig said, stray voltage is not a problem. Another attendee asked whether ERH damages utilities or fiberoptics. Hoenig said that problems of this nature have not been observed. Another attendee asked whether ERH exacerbates indoor air vapor intrusion problems. Hoenig said that this has not been a problem at the sites he has investigated.
Former 7 to 7 Cleaners: Dual-Phase Extraction
John Jang, San Francisco Bay Regional Water Quality Control Board
Warren Chamberlain, Clayton Group Services
John Jang and Warren Chamberlain, whose presentations are included as Attachments Y1 and Y2, provided information about the 7 to 7 Cleaners site. This drycleaner operated between 1977 and 1995, was demolished in 2001, and has been replaced by a commercial nursery. Sampling was first performed at the site in 1991, Jang said, after an environmental consultant noticed discharge coming out of a hole in the building. The results confirmed that PCE—along with its breakdown products—had been released to the soil, ground water, and a nearby creek. According to some estimates, Chamberlain said, approximately 1,200 pounds of PCE (representing an estimated 2.5 percent of the PCE used on site) made its way into the subsurface soil and ground water. To address this problem, the following remedial actions have been taken:
Between these two remedial strategies, Chamberlain said, 1,190 pounds of VOCs have been removed from the source area. He provided the following breakdown: 39 pounds of total VOCs were removed from the ground water that was extracted from the formation, 719 pounds of total VOCs were removed from the soil vapor that was extracted from the formation, and 432 pounds of VOCs were removed during excavation activities.
Jang and Chamberlain said that efforts are now underway to enhance naturally occurring bioremedial processes. As microbial analyses revealed, Chamberlain said, several reductive dechlorinators are already present at the 7 to 7 Cleaners site. Starting in 2003, nutrients and food have been added to support these microbes.
Jang spoke briefly about risk management efforts. First, he said, before the DPE system was installed, environmental risk assessments were performed on the soil and ground water. In addition, in 2002, a human health risk assessment (HHRA) was performed to determine whether it was safe to redevelop the site as a commercial nursery. As part of this effort, soil gas samples were collected to determine whether vapors might impact future workers and customers. The HHRA results indicated that it was safe to construct a nursery on the site because the location chosen for redevelopment was outside of the contaminated area.
Tiger Cleaners: Using HRC® as a Remedial Technology
Jim Gilbert, TDEC
Jim Gilbert, whose presentation is included as Attachment Z, provided information about a bioremediation project that is being performed at the Tiger Cleaners site in Memphis, Tennessee. This site, which is contaminated with PCE, TCE, DCE, and vinyl chloride, has a contaminated ground-water plume that extends across a 20,000-square-foot area. Gilbert said that the maximum contaminant concentrations detected at the site are as follows: 20,000 ppb for PCE, 16,000 ppb for TCE, 26,000 ppb for trans-1,2-DCE, and 8,000 ppb for cis-1,2-DCE. HRC® is being piloted as a potential remedial solution for the site.
Tiger Cleaners has two main sources of contamination: outside the back door and under the former drycleaning machine. In April 2002, Gilbert said, about 100 pounds of HRC® were injected into the first of those locations and 270 pounds were injected into the second. (Materials were delivered under the building via 40-foot horizontal borings.) In addition, about 21 pounds of HRC® were injected downgradient of the source areas to address the ground-water plume. The site has been monitored frequently since the injections were performed. The HRC® injections had little impact on contaminant concentrations during the first few months, Gilbert said, but degradative activity has been observed since that time. In fact, he said, as of January 2003, the PCE source area under the building had practically disappeared and PCE levels in downgradient wells were below 5 ppb. Similar success stories have been observed with the other constituents that contaminate the site. Monitoring will continue for another year. If the results show that vinyl chloride concentrations are high, Gilbert said, TDEC will consider injecting additional HRC® or using another bioremediation technology to drive the reductive dehalogenation process to completion.
One attendee asked how TDEC decided on the amount of HRC® to inject into the subsurface. Gilbert said that TDEC used the amounts recommended by Regenesis, the company that sells HRC®. In Florida, Fitton said, some remediation teams believe that HRC® may work better when it is injected in small doses over multiple occasions rather than in one large dose. This may reduce the chance of system shock, he said. Gilbert said that a phased injection approach was not possible at Tiger Cleaners because TDEC had only been granted a one-time injection permit for the pilot study.
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.
Schmidt, the only active member of the Outreach Subgroup, said that she plans to reach out to property owners to let them know that they are eligible to participate in state drycleaner cleanup fund programs. In Wisconsin, she said, many property owners who have drycleaners on their premises do not even know that such programs exist. To address this problem, Schmidt hopes to publish an informational article in the International Shopping Center Association’s publication. (She asked attendees to let her know of other applicable publications.) Schmidt said that she has already drafted the article. The text says that drycleaners offer an important community service but also acknowledges that drycleaning operations can pollute the environment. Because this problem is pervasive, the article explains, some states have developed drycleaner cleanup fund programs to help drycleaners and property owners address contamination. Schmidt asked whether anyone objected to printing the article. No one did, but Trippler and Fitton recommended modifying the language to make it clear that (1) Minnesota’s drycleaner fund program does not accept applications from property owners and (2) Florida’s program is no longer accepting applications. Schmidt agreed to email the article to SCRD members. She asked them to submit their comments to her directly via email.
Schmidt’s discussion on property owners sparked discussion about the difficulties some states have encountered identifying property owners. This has not been a problem in Florida, Fitton said, because the state required all program applicants to include the property owner in the application process. He advised other states to consider using this approach as well.
Audience members discussed two other outreach-related topics:
— The 19th Annual International Conference on Contaminated Soils, Sediments, and Water, scheduled for October 2003, in Amherst, Massachusetts. Trippler and DeZeeuw have submitted an abstract to speak at this conference. They will find out whether it has been accepted in May 2003.
— The Clean Show, scheduled to take place in Las Vegas in August 2003. Taber, who plans to attend this conference, said that she is willing to set up a booth for SCRD. Perroni said that she has contacted the conference coordinator and IFI representatives in an effort to reserve a booth, but has received no response. Taber agreed to call IFI’s Bill Fisher to request a spot.
Technical Issues Subgroup
Jurgens said that the Technical Issues Subgroup discussed the following topics during its breakout meeting:
Program Development/Administration Subgroup
Goins, the chair of the Program Development/Administration Subgroup, said that the Subgroup discussed two topics during their breakout session:
SCRD BUSINESS SESSION
Next SCRD Meeting and Identification of Future Training Topics
Attendees started talking about locations for the SCRD fall 2003 meeting. Two potential options were identified:
— Remediation characterization. Jurgens said that the Technical Issues Subgroup would like to learn more about assessment activities that are used to support remedial designs.
— Thermal technologies. Jurgens said that the Technical Issues Subgroup is also interested in thermal technologies and would like to know more about the stray voltage issue. Schmidt said that people in Wisconsin are interested in this topic as well. Thus, if the meeting is held in Minneapolis, she said, several people from WDNR would probably attend this training session.
— Value engineering. Fitton said that it would be useful to discuss “value engineering” and to identify tools for determining when it is cost-effective to switch technologies.
— Communicating risk to the public. Schmidt expressed interest in learning about techniques that are used to communicate risk to the public. She suggested dedicating a couple of hours to this topic. Schmidt’s request prompted Jurgens and Laudon to provide information on existing resources. Jurgens said that EPA offers a 2-day course on managing difficult situations and public meetings. Laudon advised contacting a group called Technical Outreach Services for Communities for advice on risk communications. (Additional information about this group can be found at http://tosc.orst.edu.)
— Low-cost remediation technologies. Some attendees expressed interest when Joseph mentioned that Todd Wiedemeier delivers a 2-day course on low-cost remediation technologies. Joseph agreed to distribute additional information about the course content.
Attendees will make a decision about the meeting location during their next conference call. The call’s date will be set after Joseph distributes the agenda for NGWA’s New Orleans meeting.
Carolyn Perroni noted that a new SCRD chair will be elected during the fall 2003 SCRD meeting. She asked SCRD to come to the meeting prepared to nominate someone for the position or to volunteer their own services.
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.
Attachments A Through Z1
Attachments A through Z1 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 April 2003 meeting summary.
Note: Some documents are divided into more than one downloadable
section due to the file size of the document.
Portable Document Format (PDF) file information appears next to documents that must be downloaded and viewed with the Adobe Acrobat Reader. For more information about the Acrobat Reader, click here.
Attachment A: Final attendee list
Attachments B–K: State update handouts
Attachment B: Alabama
(134 Kb PDF)
Attachment G: North
Carolina (42 Kb PDF)
Florida (22 Kb PDF)
Attachment H: Oregon
(18 Kb PDF)
Attachment D: Illinois
(29 Kb PDF)
Attachment I: South
Carolina (73 Kb PDF)
Attachment E: Kansas
(34 Kb PDF)
Attachment J: Tennessee
(144 Kb PDF)
Attachment F: Minnesota
(16 Kb PDF)
Attachment K: Wisconsin
(37 Kb PDF)
Attachment L: Bioaugmentation With KB-1™ for In Situ Treatment of Chlorinated Ethenes (Phil Dennis) (2.0 Mb PDF)
Attachment M (Section 1): Substrate-Release Composition™ (SRC™) (Eric Hince) (1.9 Mb PDF)
Attachment M (Section 2): Substrate-Release Composition™ (SRC™) (Eric Hince) (1.7 Mb PDF)
Attachment N: Biological Reductive Dechlorination of Chlorinated Compounds (Barry Molnaa) (1.9 Mb PDF)
Attachment O (Section 1): Joye Cleaners—A Case Study in Indoor Air Sampling (Lisa Appel) (1.5 Mb PDF)
Attachment O (Section 2): Joye Cleaners—A Case Study in Indoor Air Sampling (Lisa Appel) (900 Kb PDF)
Attachment P (Section 1): Assessing Potential Impacts to Drinking Water Quality (Tom Mohr) (2.2 Mb PDF)
Attachment P (Section 2): Assessing Potential Impacts to Drinking Water Quality (Tom Mohr) (2.0 Mb PDF)
Attachment P (Section 3): Assessing Potential Impacts to Drinking Water Quality (Tom Mohr) (1.9 Mb PDF)
Attachment P (Section 4): Assessing Potential Impacts to Drinking Water Quality (Tom Mohr) (1.6 Mb PDF)
Attachment Q: Rule 1421—Control of PCE Emissions From Drycleaning Systems (Jill Whynot) (449 Kb PDF)
Attachment R: Finding Funds To Address Environmental Liability (Steve Henshaw and Paul Wildrick) (318 Kb PDF)
Attachment S: Successful Approach to PCE Remediation (Bill Fisher) (1.0 Mb PDF)
Attachment T: Ineeda Cleaners—That Plume Is Moving Where? (Bob Jurgens) (1.9 Mb PDF)
Attachment U (Section 1): Ozone Remediation of PCE at the Former Market Place Shopping Center (Walter Gerald and Grant Olson) (1.3 Mb PDF)
Attachment U (Section 2): Ozone Remediation of PCE at the Former Market Place Shopping Center (Walter Gerald and Grant Olson) (1.9 Mb PDF)
Attachment V: Black’s Cleaners Update: Bioremediation (Dick DeZeeuw) (769 Kb PDF)
Attachment W: Butler Cleaners Update: Co-oxidation (Doug Fitton) (1.0 Mb PDF)
Attachment X (Section 1): Electrical Resistive Heating (Dwight Hoenig) (1.4 Mb PDF)
Attachment X (Section 2): Electrical Resistive Heating (Dwight Hoenig) (1.1 Mb PDF)
Attachment Y1: Former 7 to 7 Cleaners (John Jang) (1.2 Mb PDF)
Attachment Y2: Dual-Phase Extraction for Source Removal of PCE Impacted Soil (Warren Chamberlain) (757 Kb PDF)
Attachment Z (Section 1): Tiger Cleaners: Using HRC® as a Remedial Technology (Jim Gilbert) (2.0 Mb PDF)
Attachment Z (Section 2): Tiger Cleaners: Using HRC® as a Remedial Technology (Jim Gilbert) (1.9 Mb PDF)
Attachment Z (Section 3): Tiger Cleaners: Using HRC® as a Remedial Technology (Jim Gilbert) (1.9 Mb PDF)
Attachment Z1: Outline
for the Eligibility and Prioritization Components (30 Kb PDF)