Radisson City Center Hotel
St. Paul, Minnesota
May 12–13, 2004
WELCOME AND INTRODUCTIONS
William Linn, the chair of the State Coalition for Remediation of Drycleaners (SCRD), welcomed attendees to the meeting. He opened the session by asking the attendees (see Attachment A, PDF, 3 pp., 193 KB) to introduce themselves and provide information on their backgrounds.
Rich Steimle, a representative from the U.S. Environmental Protection Agency (EPA), praised the SCRD for its work to date. He reminded the group that SCRD meetings and contractor support is provided through the Superfund program. Although Superfund monies are decreasing, he said, interest in supporting the SCRD group appears to be steady. This is due, at least in part, to the fact that SCRD is a state-led group and that the states are going to be asked to absorb more responsibility for Superfund sites in the future. Pointing out that the Interstate Technology Regulatory Council (ITRC) is another well-respected state-led organization, Steimle advised strengthening communications between SCRD and ITRC. For starters, he suggested having an SCRD representative deliver a presentation at the next ITRC meeting. Craig Dukes agreed to contact ITRC to request a spot on the agenda of their fall 2004 meeting.
STATE PROGRAM UPDATES
Linn asked state representatives to report on the status of their drycleaner cleanup fund programs and to present information about noteworthy drycleaner-related developments.
Pam Wilson, Alabama Department of Environmental Management (ADEM)
Pam Wilson provided information (see Attachment B, PDF, 2 pp., 39 KB) on recent developments associated with Alabama’s Drycleaner Trust Fund, a reimbursement program that has been operational for less than a year. Wilson said that the fund balance is about $2.3 million but will increase once those drycleaners who are delinquent in paying their 2001 and 2002 fees settle up with the state. Wilson said that ADEM is reviewing claims that have been submitted for three drycleaning sites. (All three sites are in the assessment phase; no remediation work has been performed yet.) She also noted that Alabama’s Drycleaner Trust Fund Board recently hired an Administrative Services Group and an environmental consultant to support the Fund program. The consultant—a former ADEM employee—is developing a fair rate schedule, an application form for contractors, and an application for reimbursement. The consultant is also certifying remediation companies and making sure that reimbursements are only paid to companies with proven experience remediating halogenated solvents.
Wendy Cohen, Central Valley Regional Water Quality Control Board (CVRWQCB)
California does not have a drycleaner cleanup fund program established at this point in time. Although a bill was drafted to create such a fund, the bill died when it became known that the Governor was opposed to it. Nevertheless, Wendy Cohen provided information about several drycleaner-related events that have taken place in California over the last few months:
William Linn, Florida Department of Environmental Protection (FDEP)
The Florida Drycleaning Solvent Cleanup Program recently celebrated its 10th birthday. Linn presented detailed information about the status of the Fund program, including information on the budget, site status, and the types of technologies deployed (see Attachment D (PDF, 1 pp., 16 KB) for details). In Florida, Linn said, the state hires contractors to assess and remediate drycleaning sites. To ensure that the work goes smoothly, FDEP meets with its contractors each year. During this year’s FDEP-contractor conference, Linn said, bioaugmentation and biostimulation were highlighted on the agenda.
Trey Cantrell, Georgia Environmental Protection Division, Hazardous Sites Response Program
Trey Cantrell thanked the SCRD members for inviting Georgia to participate in its first SCRD meeting and he provided information on the scope of the drycleaner problem in Georgia (see Attachment E, PDF, 1 pp., 16 KB). Although the state does not currently have a drycleaner cleanup fund program, much interest has been expressed in developing one. About 6 months ago, Cantrell said, the Georgia Board of Natural Resources drafted a legislative proposal that called for the creation of a Joint Dry Cleaners Solvent Usage Study Committee, the goals of which would be to (1) perform research on the incidence of tetrachloroethylene (PCE) contamination and (2) develop legislation for a drycleaner cleanup fund program. Due to budgetary constraints, however, the committee has not been formed yet.
Even though Georgia does not have a formal drycleaner remediation fund program, Cantrell said, the state has gained experience addressing contaminated drycleaning sites. He said that drycleaners are required to notify his department if solvents enter the ground water or if contaminants are released at levels exceeding the Soil Notification Level. Sites that fall into this category are scored using the state’s Guidance Manual for the Reportable Quantities Screening Method. Sites that score high are listed on the Agency’s inventory list and dealt with at a more aggressive pace than those that score low. (Scores are assigned based on the risk that site soils and ground water pose to the public and to the environment.)
Pat Eriksen, Drycleaner Environmental Response Trust Fund of Illinois
Pat Eriksen provided a status report (see Attachment F, PDF, 1 pp., 44 KB)) on Illinois’ Drycleaner Environmental Response Trust Fund program. He noted that Illinois recently raised its solvent and drycleaning licensing fees but that the revenue generated from the latter has been lower than anticipated. Eriksen said that there are about 1,400 licensed drycleaners in Illinois and that there may be as many as 100 additional active drycleaners who are out of compliance with their licensing requirements. There is currently abut $6.6 million in the fund. Eriksen said that there are 266 open claims, that nearly $5 million has already been spent on these sites, and that an additional $15 million will be required. He also noted a new trend that is emerging: many drycleaners are starting to move away from using chlorine-based cleaners and are starting to use agents that have been billed as being more environmentally friendly, such as GreenEarth.
Leo Henning, Kansas Department of Health and Environment (KDHE)
Henning distributed a handout (see Attachment G, PDF, 1 pp., 35 KB) summarizing the status of the Kansas Drycleaner Facility Release Trust Fund. He said that KDHE is not seeking any major legislative changes to the program’s statute at this time because the 8-year-old program is running smoothly. Henning noted that the revenue coming in to the program is consistent with expectations and that project expenditures have been low this year because KDHE postponed some large projects. These projects will get underway, however, in summer or fall 2004. About 10 small drycleaning businesses exit the program each year.
Dale Trippler, Minnesota Pollution Control Agency (MPCA)
Trippler provided detailed information about Minnesota’s drycleaner cleanup fund program in a handout (see Attachment H, PDF, 1 pp., 30 KB). He noted that the fund’s revenue stream took a dramatic drop (going from about $650,000 a year to $200,000 a year) when an interim fee clause expired, reverting the revenue stream back to 1995 levels. Revenue is also decreasing because the number of drycleaners paying into the fund program is going down. It is unclear, Trippler said, whether this departure from the fund program is a reflection of drycleaners going out of business, or an indication that there are drycleaners out there that choose to be noncompliant and refuse to pay into the fund program. In an effort to increase revenues, the state’s drycleaner association has drafted a legislative proposal asking for the interim fee clause to be reinstated. It is unclear whether this proposal will be passed. Trippler also noted that the fund program has paid some major drycleaner site–related expenses recently. For example, within a 2-week period, the fund was used to pay cleanup costs incurred at three Superfund sites. Payment of these bills caused the fund balance to go from $1.5 million to $850,000.
Ken Koon, Missouri Department of Natural Resources (MDNR)
Ken Koon provided information (see Attachment I, PDF, 1 pp., 33 KB) about Missouri’s Drycleaning Environmental Response Trust (DERT) program. He opened by noting that the balance in Missouri’s drycleaner cleanup fund program is about $2 million. He said that annual revenue is about $700,000, but that this amount could increase if the state succeeds in forcing noncompliant drycleaners (there are about 80 of them) to pay fees into the fund program. By the end of the year, Koon hopes to have a list of the drycleaners who have not submitted fees. In addition, MDNR is compiling a list of solvent suppliers who have failed to submit surcharges to the state. Once completed, this list will be posted on MDNR’s Web site. Rules for the DERT program will be published on May 17, 2004, and should become effective by the end of the calendar year.
Koon said that there are 419 active drycleaners in the state and that MDNR has already been notified of the existence of 150 abandoned sites. No applications have been processed for these sites yet. Industry representatives realize that it will be impossible to address all of these sites with just $700,000 coming into the program each year. Therefore, some consideration is being given to proposing a gross receipt sales tax during the next legislative session. Also during that session, a proposal will be presented to change the program’s sunset date from August 2007 to August 2012. Koon closed by noting that MDNR is eager to hire two environmental specialists to administer the program, and that he hopes this will be accomplished before the end of the year.
Jim Harrington, New York State Department of Environmental Conservation
Jim Harrington said that New York does not have a formal drycleaner cleanup fund program established. In this state, many contaminated drycleaners are being addressed under the Brownfields program, a voluntary program that the state adopted in October 2003. Harrington said that the state’s Brownfields program has some interesting components. (For example, sites participating in the program must address source areas.) Harrington said that the State is required to develop soil cleanup standards and a ground-water cleanup strategy for the Brownfields program over the next few years. The public will be given ample opportunity to comment before the standards and strategies are finalized, however.
John Powers, North Carolina Department of Environmental and Natural Resources (NCDENR)
In fiscal year 2004, money from a gross receipts tax started being directed into North Carolina’s Dry-Cleaning Solvent Cleanup Act (DSCA) program. As a result, John Powers said, there has been a dramatic increase in the amount of revenue coming into the fund this year. (As shown in Attachment J, PDF, 1 pp., 16 KB, the fund balance has jumped by more than $8 million, bringing the total up to about $9.6 million.) While this increase is obviously welcomed, Powers said, there is concern that the fund’s growth will attract attention and make the fund susceptible to “raiding” by state representatives who are searching for money to cover other state expenses.
Powers said that NCDENR is still setting up the groundwork for the drycleaner fund program. Toward that end, the following is being done:
Dick DeZeeuw, Oregon Department of Environmental Quality (DEQ)
Dick DeZeeuw provided an overview (see Attachment K, PDF, 1 pp., 25 KB) of Oregon’s drycleaner cleanup fund program. In summary, he said that DEQ will have about $500,000 available to spend on the program this year, about half of which will be used to address one site. DeZeeuw said that the program has undergone some recent statutory changes, including the following:
Craig Dukes, South Carolina Department of Health and Environmental Control (DHEC)
Craig Dukes provided information (see Attachment L, PDF, 2 pp., 79 KB) about South Carolina’s drycleaner cleanup fund program. He opened by noting that the revenue generated for the program has decreased over the years. In an effort to fix this problem, the state’s drycleaners association pushed a bill through the legislature that directs a 1 percent sales tax on drycleaning services into the fund program. Although the bill has not been signed by the Governor yet, the drycleaners association is optimistic that it will be signed and that the sales tax will go into effect in July 2004. In another effort to raise revenue, Dukes said, South Carolina is beginning to crack down on the 150 drycleaners who are delinquent in paying their fees. Toward this end, DHEC has scheduled a meeting with DOR to talk about asking delinquent drycleaners to pay back taxes through 1995. Until additional revenue becomes available, Dukes said, the state will have to hold off on any new remediation efforts. At this point, there is only enough money to cover the fund’s administrative costs, as well as activities that have already been initiated and assigned as obligated costs.
Dukes said that the following statutory changes were made during the last legislative session:
Steve Goins, Tennessee Department of Environment and Conservation (TDEC)
Goins opened with information (see Attachment M, PDF, 2 pp., 124 KB) on the budgetary status of Tennessee’s drycleaner cleanup fund program. There is currently $4.8 million in the fund and $1.8 million of that has already been obligated. The remaining $3 million will disappear quickly, Goins said, once TDEC starts taking on projects that have been temporarily on hold. TDEC collects the fees for the program—a task it is happy to perform. On a regular basis, TDEC reviews the solvent usage reports submitted by drycleaners and solvent suppliers and bills the drycleaners based on the information in these reports. Drycleaners have the right to dispute the bills if they desire to do so.
Goins said TDEC is doing the following to improve the state’s drycleaner cleanup fund program:
Goins noted that TDEC has the authority to revoke a drycleaner’s operating licence if the drycleaner fails to comply with best management practices. At an upcoming Board Meeting, two drycleaners will contest TDEC’s authority and seek permission to continue operating even though TDEC has revoked their licenses.
Dan Switek, Texas Commission on Environmental Quality (TCEQ)
Dan Switek provided information (see Attachment N, PDF, 2 pp., 23 KB) on Texas’ drycleaner cleanup fund, a program that came into existence nearly a year ago. Switek said that approximately $2.7 million has been collected in registration and license fees, but that this number is expected to grow to $5 or $6 million by the end of the year. About $135,000 has been spent to support the program so far. This money, which has primarily been used to pay salaries, has allowed TCEQ to start registering facilities, developing a Web site, creating a listserv, developing rules, and generating a ranking system.
Robin Schmidt, Wisconsin Department of Natural Resources (WDNR)
Robin Schmidt provided information (see Attachment O1, PDF, 1 pp., 35 KB and O2, PDF, 1 pp., 34 KB) on Wisconsin’s Dry Cleaner Environmental Response Fund (DERF). She said that some statutory changes have recently been made to the program. Major changes include (1) extending the deadline for the date by which drycleaners must submit reimbursement forms, (2) making clarifications about who is eligible to participate in the fund program, and (3) streamlining licensing procedures.
Schmidt said that 114 drycleaners have confirmed that their sites are contaminated and have contacted WDNR to request admittance into the fund program. Of these, 34 drycleaners have already submitted applications for reimbursement and six drycleaning facilities have been closed out. Schmidt reminded attendees that the state’s program operates on a reimbursement paradigm: drycleaners hire their own contractors to perform work, pay for the work up front, and are later reimbursed. To ensure that contractors offer competitive rates, WDNR requires drycleaners to obtain multiple bids and to obtain WDNR’s approval on the contractor’s work plan before proceedings with assessment and remediation activities. Contractors who are submitting bids must fill out the DERF Site Investigation Bid Summary Consultant Selection Cover Sheet (see Attachment O3, PDF, 1 pp., 23 KB for details.) Schmidt said that some contractors have provided positive feedback on the form: they feel that it will help standardize the bidding process and make it more difficult for companies to submit misleadingly low bids.
WDNR is only allowed to spend $1 million on the DERF program each year. During the next fiscal year, Schmidt said, the $1 million mark will be reached after a month has passed. Thus, WDNR will ask the legislature to release additional money from the fund so that WDNR can continue releasing reimbursements. (WDNR does not want to maintain a high fund balance for fear that this would attract raids.)
COMMITTEE MEETING REPORTS
SCRD has three operating committees. On May 11, 2004, they met in breakout sessions to discuss the status of existing projects and to identify future initiatives. Committee leaders were asked to summarize the breakout discussions. Their summaries are presented below.
Program Development/Administration Committee
Steve Goins, the chair of the Program Development/Administration Committee, said that three projects were discussed during the Committee’s breakout session:
Schmidt noted that she has been the sole member of the Outreach Committee for quite some time. Hearing this, Mary Siedlecki agreed to join the Committee and assist Schmidt in identifying outreach opportunities. Schmidt said that there have been some developments on the outreach front over the last several months. For example, Perroni has developed a listserv that provides updates on SCRD’s activities. To date, this listserv has attracted 25 to 30 subscribers representing a range of affiliations, including consulting companies, law firms, state governments, drycleaner organizations, and international groups. Schmidt said that she recently contacted the president-elect of the International Fabricare Institute to ask him to join the listserv. Schmidt said that some SCRD group members have expressed interest in posting additional links on the SCRD Web site. She encouraged attendees to send their recommendations for additional Web links directly to Perroni.
Each time the SCRD meets, Schmidt said, each member state presents a formal update of its program’s budgetary and site status. Schmidt advised compiling the information that each state provides and posting it on the Web site. At this point, it would be difficult to do this since the update reports do not all follow the same format. In an effort to streamline and standardize the reporting process, Schmidt said, she and Perroni will create a new State Update Report template and distribute it to SCRD members before the next meeting.
Schmidt said that she had hoped to raise awareness about SCRD by establishing a connection with the International Association of Shopping Centers (IASC). Toward this end, Schmidt drafted an article and submitted it to IASC for publication. She is still waiting to find out whether it will be published. In addition, Schmidt contacted IASC to ask whether SCRD could have a spot on the agenda of the next IASC conference. Although IASC did express interest, it could not grant Schmidt’s request.
Before closing the discussion on outreach initiatives, attendees noted that SCRD members have made an effort to raise awareness about SCRD activities by delivering presentations and setting up informational booths at a variety of conferences. For example, in March 2004, SCRD representatives delivered a paper at the Association for Environmental Health and Sciences (AEHS) conference. One attendee asked whether it would be useful to pursue additional speaking and booth-display opportunities. While many SCRD members responded by saying that it would be useful to deliver additional presentations, skepticism was expressed about the utility of presenting informational booths or poster sessions. Some attendees questioned whether the exposure obtained by manning an informational booth warrants the cost of securing the booth and suggested that the group’s money would be better spent producing handouts and brochures. Picking up on the suggestion to deliver presentations at future meetings, Perroni advised the group to start identifying speaking opportunities now. She said that plans need to be made early: abstracts for conferences are often due far in advance. For example, she noted, abstracts for the 2005 AEHS conference are due in July 2004. Schmidt and Goins expressed interest in sending an SCRD representative to the next Clean Show. Schmidt agreed to research this possibility and determine whether there would be an opportunity for SCRD to do something other than just setting up an informational booth at this show. (Perroni said that the booths for the Clean Show typically cost about $2,300.)
Project Management/Technical Issues Committee
Craig Dukes said that the Project Management/Technical Issues Committee discussed the following Committee-related activities during its breakout session:
SCRD BUSINESS SESSION
Perroni passed out a list of the people who are identified as contacts on the SCRD Web site. She asked attendees to review the contact information to ensure its accuracy. If there are errors, she said, SCRD representatives should report them to her so that she can modify the information as soon as possible. (Some SCRD member states have five or six contacts listed; Perroni advised against including additional contact names for these states.)
Linn noted that Louisiana is currently listed as an Associate Member1 of the SCRD even though it has not participated in an SCRD meeting or conference call for a long time. Henning said that he thinks Louisiana is seriously interested in initiating a drycleaner cleanup fund program, and therefore, should be retained as an Associate Member. Linn agreed to contact a representative from Louisiana for an update.
1 Associate member states are those that are still developing formal drycleaner cleanup fund programs.
SCRD has developed a database (available through the SCRD Web site) that presents case studies (also referred to as Site Profiles) of contaminated drycleaning sites. Linn passed out a handout, entitled “Preparing and Submitting Drycleaning Site Profiles—SCRD Web site,” which lists recommendations on how to improve the quality of the site profiles. (The handout is available as Attachment P, PDF, 3 pp., 37 KB.) Linn encouraged attendees to keep these recommendations in mind when developing new site profiles. Rich Steimle emphasized the importance of the Site Profile database, noting that it is one of the best databases that EPA maintains. He encouraged SCRD members to update their Site Profiles regularly. Linn said that 44 site profiles have been initiated for sites in Illinois, Tennessee, and Texas, but that they still need to be reviewed and/or updated before they are posted to the Web site. He asked Juho So, Nancy Frazier, and Mike Leckie to follow up with the profiles that have been initiated for their states. (Linn said that profiles that only have assessment data available should not be posted on the SCRD Web site at this point; these profiles should be held back until remediation data are also available.) Dukes said that he would like to obtain site profiles for sites in Georgia and California. Cohen agreed to ask her colleagues in California to start preparing site profiles. When she makes her pitch, Perroni advised, it would be useful to hand out the Site Profile Submission Form available at http://www.drycleancoalition.org/profiles/form.cfm.
Linn asked attendees to let him know if they are interested in writing and presenting papers on behalf of SCRD. Several attendees (e.g., Trippler, Dukes, and Schmidt) said that they were interested but were unsure if their management would allow them to make these trips.
Future SCRD Meetings
The Fall 2004 SCRD Meeting
Attendees agreed that the fall 2004 meeting should be held in Kansas City. Koon suggested holding the meeting on the Missouri side of the city, noting that state representatives from Missouri might have trouble obtaining permission to attend the meeting if it is held in Kansas. Linn asked attendees to start thinking of topics and identifying speakers for this meeting. From past discussions, he said, it is apparent that the group is interested in holding a session on direct-push technologies. He recommended contacting Geoprobe® Systems (which is based in Kansas) to perform a demonstration. Linn also recommended asking a representative from the U.S. Navy to attend and speak about microwell technology.
The Spring 2005 SCRD Meeting
Linn said that some SCRD members have expressed interest in holding the spring 2005 meeting in Chapel Hill, North Carolina.
The Fall 2005 SCRD Meeting
Linn asked the attendees for recommendations on the location for the fall 2005 SCRD meeting. Several locations were suggested, including Texas (Austin or San Antonio), somewhere in the Northeast (perhaps Albany), and somewhere in the Northwest (perhaps Seattle). Linn agreed to contact representatives from Connecticut, as well as other Northeastern states, to ask whether they would be willing to attend an SCRD meeting if it was located in the Northeast. DeZeeuw said that he would research the possibility of having the meeting in the Northwest. Linn and DeZeeuw will report their findings during the next SCRD conference call.
NEXT SCRD CONFERENCE CALL
Attendees identified June 23, 2004, as a potential date for their next conference call. If this date is a problem, Perroni said, SCRD members should let her know before the end of May. If no complaints are voiced, the call will be set up for that date.
The Groundwater Resources Association of California’s Tenth Symposium
in the Series on Groundwater Contamination
Wendy Cohen, CVRWQCB; Dick DeZeeuw, Oregon DEQ; and William Linn, FDEP
On April 7, 2004, Cohen, DeZeeuw, and Linn attended a 1-day symposium in Sacramento, California, that focused on the investigation and remediation of drycleaning sites. (Detailed information on some of the meeting sessions is included as Attachments Q1, PDF, 2 pp., 19 KB and Q2, PDF, 2 pp., 25 KB.) This symposium, which was sponsored by the Groundwater Resources Association of California, was the tenth in a series of symposia that address topics related to ground-water contamination. Some consideration is being given to repeating the series in southern California in the near future.
Cohen, DeZeeuw, and Linn said that the symposium had been well attended: there were about 250 people in the audience, among them mayors, attorneys, consultants, regulators, engineers, industry representatives, and academics. The vast majority of the attendees were regulators, DeZeeuw said; only a few drycleaners were in attendance. (Cohen estimated that regulators from 12 to 18 states were in the audience.) Topics addressed during the symposium included (1) confronting the challenges associated with drycleaning sites, (2) screening for contaminants, (3) characterizing the subsurface, (4) using innovative remediation technologies, and (5) implementing institutional controls. Cohen, who moderated a session on remediation strategies, said that the following people delivered presentations during her session:
Cohen said that an interesting panel discussion was held to discuss issues facing the City of Lodi, a municipality that is being held responsible for PCE that leaked from its sewers. In addition, Cohen said that interesting information was also presented about obstacles and policy issues that are associated with contaminated drycleaning facilities. These included (1) identifying a fair way to name responsible parties, (2) determining whether old insurance policies can be used to offset cleanup costs, (3) cleaning up at the source rather than just at the well head, and (4) identifying sufficient funds. (See Attachment Q2, PDF, 2 pp., 25 KB for more details.)
Susan Johnson, MPCA; Barb Gnabasik, MPCA; and Dave Wolfgram, Terracon
Susan Johnson, Barb Gnabasik, and Dave Wolfgram provided information about cleanup activities that are being considered to address a contaminated drycleaner in Littlefork, Minnesota. (Their presentation is included as Attachment R (PDF, 58 pp., 2,800 KB.) This site, which operated as a drycleaning facility in the 1940s, is near seven gas stations. Johnson said that PCE contamination was discovered in the early 1990s when workers noticed an odor while excavating a leaking gas tank. The discovery of PCE contamination prompted residential well sampling events, the results of which showed that there was extensive PCE and petroleum contamination across the city. As a result, an emergency was declared in 1993, bottled water was provided to several residences as an interim measure, the site was listed as a Superfund site in 1994, and MPCA connected affected residences to the municipal water supply in 1996. Once the immediate exposure hazards were addressed, Johnson said, the site dropped in priority and was not investigated aggressively again until 2001. Now that MPCA has redirected attention to the site, several site characterization studies have been performed and efforts are underway to identify potential remedial solutions.
Gnabasik provided a summary of the findings from the site characterization studies. The results indicate that site soils have a low permeability, the water table is encountered at about 10 to 18 feet below ground surface (bgs), and a deeper aquifer is encountered at about 85 feet bgs. Investigations also reveal that PCE concentrations in the ground water range from 500 to 700 parts per billion (ppb), that a plume extends under residential houses, and that the ground water is moving at a slow rate toward a river. (The river has not yet been impacted by PCE, however.) Johnson said that investigation is still ongoing—she hopes that the Remedial Investigation will be completed by this summer.
Dan Wolfgram noted that a remedial study was recently performed at the site to determine whether natural attenuation is a viable strategy for this site. After collecting data on a variety of parameters (e.g., oxygen, nitrate, manganese, sulfate, methane, chloride, ethane/ethene concentrations) and performing a screening analysis, researchers concluded that natural attenuation only has limited potential at this site. Therefore, MPCA has launched an effort to evaluate other soil and ground-water remedial alternatives. Those being considered are listed in Attachment R (PDF, 58 pp., 2,800 KB). So far, Johnson said, soil excavation appears to hold the most promise for soils, and air sparging (in combination with soil vapor extraction, or SVE) appears to be the most promising approach for addressing the site’s ground water. Johnson concluded by saying that MPCA plans to produce a Feasibility Study in winter 2004/2005.
Alabama Drycleaning Environmental Response Trust Fund
Pam Wilson, ADEM
Wilson provided an overview of Alabama’s Drycleaning Environmental Response Trust Fund (DERTF), a program that passed into law on May 24, 2000. Her presentation, which is included as Attachment S (PDF, 43 pp., 2,336 KB), provides detailed information about DERTF and the process used to administer the program. In summary, she made the following points:
Before concluding her presentation, Wilson did note that the DERTF program has encountered some challenges. Payments are often late; there was concern about contractors and consultants overcharging, necessitating a Fair Rate Schedule; the Act attempts to circumvent RCRA; the Act states that ADEM may not seek out contamination; contractors have voiced concern about payment of their services; and some drycleaners have used non-Board-approved contractors.
Wilson opened the floor for questions and comments. Steimle said that the DERTF program appears to provide little incentive for non-polluting drycleaners to join. In some ways, he said, it serves to reward the “bad apples” of the industry. Larry Norris said that ADEM is aware of this, but was unable to change the program’s legislation to address this problem. (He noted that the program’s legislation was drafted by Alabama’s Drycleaner Association and that ADEM was not given an opportunity to modify the legislation.)
Vapor Migration Issues and Indoor Air Case Study at a Chlorinated Site
Jim Harrington, New York State Department of Environmental Conservation
Jim Harrington (whose presentation is included as Attachment T, PDF, 30 pp., 672 KB) said that vapor intrusion concerns have become a major issue in New York. The state considers vapor to be a potential exposure pathway and requires environmental agencies to evaluate whether vapors emanating from a site have the potential to intrude into indoor air spaces and cause adverse health effects. Such evaluations are required for newly contaminated sites as well as legacy sites. To date, the state has whittled the number of sites that require vapor intrusion evaluations down to 300. Harrington said that he believes the state will be able to address 30 to 40 of these sites this year. He also noted that New York’s Department of Health has started working on a vapor intrusion guidance document that will address the following topics: sampling, evaluation, mitigation, and monitoring.
Harrington identified the following as issues that are difficult to address:
Harrington presented information about an IBM site in Endicott, New York, that is currently struggling with vapor intrusion issues. Endicott has one of the highest concentrations of drycleaning facilities in the world, Harrington said, noting that a drycleaning facility was located on IBM’s property at one time. In 1979, ground-water contamination was detected in Endicott and IBM accepted responsibility for part of the problem and agreed to pay for remediation. In more recent years, concern has grown about PCE plumes migrating under residential structures and impacting indoor air quality. In an effort to address this concern, samples have been collected and IBM has installed mitigation systems in structures where a discernable difference in PCE concentrations has been detected between the subslab and ambient air. To date, IBM has installed 450 mitigation systems, the cost of which has been significant. (Harrington said that a typical mitigation system costs between $1,500 and $2,000 but that some systems—e.g., those installed in commercial structures—are significantly more expensive.) Given the high concentration of industry in the area, Harrington said, IBM does not think it is responsible for all of the contamination in the area. Therefore, the company does not want to pay to install mitigation systems in houses that are located above the part of the plume for which IBM claims no responsibility. Residents are not happy with this approach, and the issue of who receives mitigation systems has become quite contentious. About 5 miles from Endicott, Harrington said, the Hill Crest community has also expressed concern about vapor intrusion, claiming that industrial practices have led to the formation of a cancer cluster. The Department of Health performed a study, but was unable to confirm the existence of a cancer cluster in that community. Nevertheless, the state is considering installing mitigation systems in the Hill Crest community.
Linn asked Harrington to describe the mitigation systems that have been installed in Endicott. Harrington said that the system consists of a pipe and a booster fan. Schmidt asked for information about who owns the mitigation systems and who takes responsibility for their operation and maintenance (O&M). Harrington said that he was not sure who owned the systems, but he was fairly certain that IBM takes responsibility for the O&M activities. Schmidt also asked Harrington how the vapor intrusion issue was brought to the public’s attention. Harrington said that he was not sure, but that two public action groups had become involved with the issue. Once IBM was aware of the public’s concerns, he said, the company established a center to field the public’s questions and listen to their concerns. This center recently closed, however, due to lack of public participation.
Nancy Frazier, TDEC
Nancy Frazier provided information (see Attachment U, PDF, 29 pp., 667 KB) about remedial options being considered to address PCE contamination at Crown Cleaners, an active drycleaning facility located in Knoxville, Tennessee. This site, which has been active since 1964, used an aboveground storage tank between 1964 and 1991. PCE leaked from the tank and created a PCE plume under the facility. Frazier said that ground water at this site is found in a weathered shale layer and that it has a very slow horizontal flow (19 centimeters per year). Sampling reveals that PCE concentrations in the soil are low and that PCE concentrations are decreasing in all but one of the site’s monitoring wells. (The well that is experiencing the increase has gone from 1.3 ppm to 2.4 ppm.) Frazier said that the following two technologies are being considered as remedial options for this site:
Frazier said that TDEC is at a crossroads for this site. The agency must decide whether to pursue the chemical oxidation or the bioremediation option further. If TDEC chooses the latter, the agency will use electron donors to promote anaerobic conditions and then inject additional microbes into the subsurface. Before choosing this option, however, TDEC might further assess bioremediation’s potential using the BIOCHLOR model. Before concluding her presentation, Frazier wanted to make attendees aware of a new tool—Bio-SEP® beads—that can be used to analyze the efficacy of different bioremedial amendments.
Report on the AEHS Vapor Intrusion Conference
Craig Dukes, DHEC
Dukes provided a summary of the topics discussed at an AEHS conference that was held in Mission Valley, California, on March 15 and 16, 2004. He said that this conference was held to discuss the vapor intrusion pathway and to determine whether the attenuation factors included in EPA’s December 2002 guidance document are appropriate. In his presentation (which is included as Attachment V, PDF, 33 pp., 3682 KB), Dukes also presented his own opinions about the ideas expressed at the conference.
Dukes opened by noting that attenuation factors are screening values that can be used to determine whether vapor intrusion can be eliminated as a pathway of concern at a given site. EPA’s December 2002 guidance document proposes some generic attenuation factors, but several groups have been collecting data and releasing information about measured attenuation factors. This conference was held to see how the measured values compare with EPA’s proposed generic values. Dukes said that making such a comparison is problematic: the generic values, which predict the amount of contaminant entering a building, do not account for the impact that building characteristics (e.g., ventilation, free air exchange, depressurization) can have on vapor concentrations once the vapor has already entered a building. In contrast, measured attenuation factors do incorporate the effect that building characteristics have on vapor concentrations. Dukes said that the measured attenuation factors presented at the meeting for chlorinated hydrocarbons and petroleum were all over the board. (Attachment V (PDF, 33 pp., 3682 KB) has more detailed information about the data presented and the conclusions that EPA’s Dr. Dawson drew from these data.) In his opinion, Dukes said, the following can be said about the attenuation factors listed in EPA’s December 2002 guidance document:
Dukes said that some of the papers delivered at the AEHS conference offered some intriguing ideas. For example:
Dukes said that other speakers at the conference talked about how difficult it is to predict and measure the impacts of vapor intrusion. This point was driven home in papers that discussed (1) the impact of seasonal variations on observed indoor air concentrations, (2) the difficulty of collecting accurate background samples, and (3) the impact that subsurface geology has on vapor intrusion. Expanding on the latter two points, Dukes described a site where background samples were skewed because investigators placed sampling devices in a poplar tree that was pulling trichloroethene (TCE) out of the ground water and emitting it into the air. At another site—characterized by tight clay soils—preferential pathways formed, making it virtually impossible to predict how vapors would migrate in the subsurface. Dukes did note that some of the speakers suggested ways to eliminate concerns about background contaminant sources. For example, one speaker advised using a Trace Atmospheric Gas Analyzer Mobile Laboratory and another discussed the merits of using subslab sampling probes. Dukes said that he doubted that either of these suggestions would be feasible in the field: the former would probably be too expensive and the latter too intrusive.
Ken Koon, MDNR
Koon provided information about the Springfield Laundry, the first site to be addressed under Missouri’s DERT program. (His presentation is included as Attachment W, PDF, 18 pp., 51 KB.) The site, which opened as a laundry in the 1920s and closed in 1997, used Stoddard solvent between 1926 and 1983, PCE between 1983 and 1995, and a petroleum cleaning agent between 1995 and 1997. While it was operational. Koon said, the facility used several underground and aboveground storage tanks. The latter, which were used to store water, were supplied by an onsite deep well and municipal wells. When water from the aboveground storage tanks was sampled in 1995, PCE was detected at 26 ppb. This finding led the site owners to conclude that back flow from their drycleaning machines had gone down the well and contaminated it with PCE. (This well has since been plugged up to 230 feet and is currently only used as an extraction well.)
Koon said that representatives from EPA Region 7 were the ones to first detect PCE contamination at the site. (EPA Region 7 chose to sample the Springfield Laundry during an area-wide survey to examine the potential impacts local businesses were having on the area’s aquifer.) At that time, although the site owner was not enrolled in any environmental cleanup program, efforts were made to perform an initial site investigation. The investigation’s results revealed that PCE was present in the aboveground storage tanks (at concentrations of 37 ppb), in the well head (at concentrations of 82 ppb), and in soils and shallow wells (at concentrations below cleanup standards).
In subsequent years, Greene County expressed interest in purchasing the Springfield Laundry site and redeveloping it as a parking lot. At the time, the County believed that the following would be required to address the site: (1) perform some ground-water extraction, (2) lower PCE concentrations to 5 ppb, and (3) use the deep well to control ground-water flow and prevent contaminant migration. To expedite the redevelopment process, Greene County entered the site into the Brownfields/Voluntary Cleanup Program and expressed interest in closing the site out quickly. Before this could be done, however, MDNR indicated that additional investigation was required to determine whether an ongoing source existed at the site. Toward that end, a geologist went to the site and performed a downhole camera survey of the deep well. Cracks were detected and seepage was observed. Additional samples were collected and investigators detected PCE concentrations of 332 ppb at 220 feet bgs, 170 ppb at 450 feet bgs, and 64 ppb at 1,170 feet bgs. These results led investigators to believe that there was an additional shallow source of PCE at this site. To determine if this was the case, in November 2001, additional soil and ground-water samples were collected. The results indicated that contamination was present in locations outside of the deep well area. Thus, investigators concluded that the PCE contamination at this site was not solely attributable (as the original site owner had suggested) to back flows that entered the deep well. Rather, it is more likely that the PCE entered the environment via several routes, such as machine leaks and spills, the concrete wastewater collection sump, and the sanitary sewer lines.
On March 10, 2004, the site entered the DERT program. Before developing a remedial strategy, Koon said, DERT Project Managers believe it is necessary to further delineate the extent of contamination. As part of this effort, they will recommend installing bedrock wells to ensure that contaminants have not infiltrated the deep aquifer that underlies the site. Koon said that it is unclear which remedial option(s) will be chosen, but he suspects that it might involve a combination of excavation and in situ remediation. Site closure goals and procedures will be clarified when Missouri’s risk-based remediation guidance is released. (This document is scheduled for release in late 2004 or 2005.)
BioRem H-10 Pilot Study Results: Carousel Cleaners
Bruce Gilles, Oregon DEQ
Bruce Gilles presented information about a bioremediation pilot study performed at Carousel Cleaners. The PowerPoint presentation that he delivered (included as Attachment X, PDF, 22 pp., 159 KB) was created by BioRem Technologies, Inc. In addition to delivering BioRem’s presentation, Gilles offered his own opinions about the level of success that the pilot project achieved.
Gilles said that Carousel Cleaners, a drycleaning facility that has been operating since 1989, has released PCE to the environment. PCE has been detected at concentrations ranging from 2.2 ppm to 7,130 ppm in soils and at concentrations of 14,800 ppb to 27,600 ppb in ground water. In an effort to identify remedial options for the site, DEQ agreed to let BioRem perform a bioremediation demonstration project on a 15-foot by 15-foot test plot. Prior to the pilot study, conditions at the site were not conducive to biodegradation. BioRem claimed, however, that one could enhance biodegradation processes by injecting BioRem H-10 (a consortium of bacteria) into the subsurface. Following BioRem’s advice, DEQ agreed to inject three rounds of BioRem H-10 over the span of about 1 year. To track the impact of this remedial agent, data were collected on VOC concentrations (i.e., PCE, TCE, dichloroethene [DCE], vinyl chloride, and methane), natural parameters (i.e., pH, dissolved oxygen, chlorides, iron, and manganese), and heterotrophic bacterial growth. Investigators found that PCE concentrations dropped sharply after the first BioRem H-10 application but rebounded after the second one. As for TCE and DCE—the breakdown products of PCE—these contaminants started appearing after the second application. Gilles said that he is unsure whether BioRem H-10 was responsible for the sharp decline in PCE concentration that was observed after the first injection. He noted that the decline coincided with heavy rainfall events and that the rebound occurred during the driest part of the year, leading him to believe that the decline might have been a reflection of contaminant dilution rather than actual remediation. Despite Gilles concerns, BioRem has concluded that its product successfully reduced PCE levels. The company does acknowledge, however, that complete biodegradation was hindered by recontamination from source areas. Gilles said that he agrees that the source area is a problem, noting that some of the data collected on the site suggest that a large vapor cloud emanates from the source zone.
Gilles said that the BioRem H-10 pilot study has been terminated. Although the technology may have worked to some degree, he said, it probably did not achieve the level of success that BioRem would suggest. If he could start over at this site, Gilles said, he would have evaluated bioremediation as a polishing technology rather than a main technology. In the near future, researchers will return to the site to collect additional samples and develop a detailed soil profile. In addition, a focused Feasibility Study will be performed to identify a more appropriate technology to address the site’s source zone. SVE and chemical oxidation are two options being considered.
Heated Soil Vapor Extraction Pilot Project at United Cleaners, Lemont,
Juho So, Drycleaner Environmental Response Trust Fund
Juho So provided information (see Attachment Y, PDF, 18 pp., 988 KB) about a pilot project performed at the United Cleaners facility in Lemont, Illinois. He opened with background information about the site. The subsurface is characterized by tight clays and is contaminated with PCE. An initial site investigation (which involved the installation of 21 soil borings) was conducted soon after the site owners submitted a claim to Illinois’ drycleaner cleanup fund program. This investigation, which was completed in January 2002, indicated that PCE concentrations in the soils ranged from 48 ppm to 4,700 ppm, the latter of which was significantly higher than the remedial objectives established for this site. (So said that the remedial objective was originally 110 ppm but is now 408 ppm.) In February of 2002, the state received a proposal to pilot a heated soil vapor extraction (HSVE) system at this site. The proposal was accepted and the pilot project was performed at a cost of about $65,000.
So described HSVE systems: they are basically SVE systems that have an extra heat source. At the United Cleaners site, heat was applied by installing a pipe into the ground and running hot water through the pipe. The hope was that the heat from the pipe would radiate into the surrounding subsurface and volatilize contaminants. Compared to conventional SVE systems, So said, HSVE systems are touted as being able to enhance VOC volatilization and working better in a broad range of soils, including tight clays. They do, however, occupy a larger space, cost more, and require more maintenance.
The HSVE system was installed at United Cleaners in September 2002. At that time, the vendor claimed that the system would remove 80 to 90 percent of the site’s subsurface VOCs within a 2-month timeframe. So said that the vendor was unable to deliver on his claims. Sampling events performed in December 2002, January 2003, and March 2003 all showed the same thing: although a large amount of VOCs were removed from the subsurface, PCE concentrations remained above remedial objectives. Samples collected in July 2003 yielded even worse news and suggested that more PCE was present than originally anticipated. Given these results, So said, the state decided to terminate the pilot study, perform additional site investigation, and start investigating the potential of other remedial technologies, such as chemical oxidation, excavation, and electrical heating. Each of these technologies has some complicated issues associated with it, however. (See Attachment Y, PDF, 18 pp., 988 KB for more details.)
Before closing, So listed some lessons that have been learned working at this site. These include: (1) it is useful to have as many soil borings installed as feasible, (2) it is important to be realistic rather than overly optimistic when making predictions about how fast cleanup will occur, and (3) it is difficult to remediate sites that are characterized by tight clays.
The Texas Drycleaning Program’s Site Scoring System
Dan Switek, TCEQ
Switek said that Texas is developing an application form for its drycleaner cleanup fund program. The form has been drafted but is awaiting approval. Once approval is granted, Switek will send the form to Perroni so that it can be distributed to the entire SCRD team for review. Switek said that he would appreciate any feedback the group has to offer.
The application only has to be completed by those drycleaners who suspect that their sites are contaminated. The information provided will help TCEQ determine how to rank the state’s drycleaning sites. Switek said that the form asks for information on the types of machines used, solvent usage and delivery practices, waste management practices, site maps, receptor surveys, geological information, and ground-water and soil sampling results. Switek said that he realizes this is a lot of information to request and that most drycleaners will have to hire consultants to help fill out the form. Nevertheless, TCEQ believes it is acceptable to put part of the onus of data collection on the drycleaners since there are too many drycleaners in Texas for TCEQ to take over the data gathering process.
Remedy Selection at a Wisconsin Drycleaning Site
Robin Schmidt, WDNR
Schmidt provided information (see Attachment Z, PDF, 25 pp., 367 KB) on remedial options that are being considered to address a PCE-contaminated drycleaning facility in West Bend, Wisconsin. The facility, which first started operating in 1965, is located next to a residential area. Soils in the area consist of fine-grained sand, a little silt, and gravel. Ground water is encountered at 6 to 10 feet bgs. Contamination was first detected in 1997 during a Phase I/II site assessment that was being performed on the property. Initial investigations revealed that there were low levels of PCE in onsite ground water, but that none of the samples (except for two pulled from a temporary well point) had detections exceeding ground-water standards. The results also showed that PCE had impacted about 1,300 cubic yards of soil, but that exposure was not occurring because the contaminated materials were located under an asphalt parking lot. Based on these results, the responsible party asked whether WDNR would consider closing out the site if a deed restriction was placed on the property to ensure that the soils remained capped. WDNR denied the request, stating that more investigatory work was needed. Schmidt said that this investigatory work has been completed and that the results show that the contamination is more extensive than previously thought. In fact, PCE was detected at concentrations of 1,000 ppb in one well. Schmidt said that the plume at this site passes under residential properties, and that this made the Project Manager express concern about the potential for vapor intrusion. Although the responsible party was reluctant to evaluate the vapor intrusion pathway for fear that doing so would alarm the public, soil gas samples were eventually collected and the results suggested that vapor intrusion is not a concern.
Schmidt said that the drycleaner’s consultant prepared a Remedial Action Options Report for the site and concluded that natural attenuation is the most cost-effective remedy. With that conclusion in hand, the drycleaner was asked to obtain three bids for the remedial work and submit them to WDNR for approval. Four consultants submitted bids. Three of them indicated that bioremedial processes would be sufficient to address the site and claimed that they could build a case for site closure within 2 years. They quoted prices ranging from $71,000 to $93,000, although one of the consultants admitted that it might be necessary to add HRC® to the subsurface and that doing so would raise the cost of remediation substantially. The fourth consultant advised the drycleaner to abandon hope of obtaining site closure through natural attenuation processes alone, arguing that there was not adequate evidence to support the idea of using this approach as a sole remedial strategy. As an alternative, this consultant advised installing an SVE system and following up with a permanganate injection. Upon analyzing the site more thoroughly, Schmidt said, WDNR concluded that the fourth consultant’s assessment made sense and that the consultant who had advised the drycleaner to rely on natural attenuation had not thoroughly analyzed the situation.
Before closing, Schmidt asked audience members to provide input on the following questions:
Nu-Look One Hour Cleaners, Coral Springs, Florida
Jo Johnson, FDEP
Jo Johnson provided information about remediation activities performed at the Nu-Look One Hour Cleaners, a drycleaning facility that operated between 1991 and 1998 but is now only used as a dry drop location. Her presentation is included as Attachment AA (PDF, 59 pp., 305 KB). Johnson said that the facility operated for several years without a secondary containment system and that PCE was the primary cleaning agent used. A site assessment was performed in 1997 to determine whether the facility’s operations had impacted the environment. The results showed that contaminants had indeed entered the environment, with concentrations in soil reaching 130 ppb for PCE and 325 for TCE, and concentrations in the ground water reaching 1,990 ppb for PCE, 11,700 ppb for TCE, 10,200 ppb for cis-1,2-DCE, and 1,000 ppb for vinyl chloride. The results also indicated that ground-water contamination reaches to depths of 54 feet bgs and that a dissolved plume extends over an area of 1.25 acres. Johnson said that a municipal wellfield is located about 0.3 miles from the site and that the wells are screened to a depth of 60 to 120 feet bgs.
Johnson described the remedial approach used to address the site. She said that an SVE system was used to address the soils. This system, which operated from April 2001 until November 2002 (but not continuously), extracted 9 pounds of contaminated gas and succeeded in decreasing contaminant concentrations in the soil below Synthetic Precipitation Leaching Procedure (SPLP) levels. As for ground water, Johnson said, this is being addressed using a three-pronged strategy consisting of the following elements:
Johnson said that $511,000 has been spent on the site to date. (A more detailed breakdown of the costs is included in Attachment AA, PDF, 59 pp., 305 KB.) For this price tag, site managers were able to reach a state of No Further Action for the soils and to reduce VOCs in the ground water by about 98 percent. Investigators will continue to sample the ground water on a regular basis to monitor its status.
Abiotic Natural Attenuation of Dichloroethylene Isomers
Mark Ferrey, MPCA
Mark Ferrey presented information (see Attachment BB, PDF, 25 pp., 909 KB) about abiotic processes that appear to play a role in contaminant degradation. Although his presentation did not speak directly about drycleaning facilities, Ferrey said that he thought his presentation would be of interest to SCRD members because it speaks about degradation processes that break down DCE—one of PCE’s daughter products.
When people speak of natural attenuation mechanisms, Ferrey said, they typically focus on biological reductive dehalogenation, sorption, and dilution. For the most part, abiotic mechanisms are ignored and considered inconsequential. New data suggest, however, that abiotic processes can play a major role in DCE degradation. To support his statement, Ferrey described experiments performed at the Twin Cities Army Ammunition Plant (TCAAP), a site that is primarily contaminated with TCE.
Ferrey said that some cis-1,2-DCE has been detected at the site, but vinyl chloride and ethene are virtually absent. The site’s geochemistry is not conducive to biological reductive dehalogenation. Knowing this, EPA chose to use this site to beta-test its natural attenuation remedy protocol, guidance that is designed to predict the impact that natural attenuation will have at a given site. EPA expected that the study would predict that (1) the aquifer at TCAAP is not favorable to biological degradation of chlorinated solvents and (2) natural attenuation processes will have little impact on the site’s chlorinated solvent plume. While EPA did confirm the former, Ferrey said, researchers were surprised to see that the latter did not hold true. Even in the absence of significant biological reductive dehalogenation, researchers found that the plume attenuated to a significant degree. To determine which mechanisms were responsible, microcosm studies were performed using sediment and ground water from the site. Each microcosm had 45 grams of sediment slurry and was spiked with either cis-DCE or 1,1-DCE. Half of the microcosms were autoclaved to kill the microbes present in the sample. The microcosms were stored for 830 days and then sampled on a quarterly basis. The data suggested that the rate of contaminant decay in the live microcosms and the autoclaved microcosms was the same, a finding that came as a surprise to researchers because it suggested that abiotic processes were responsible for DCE degradation at the TCAAP site. At the same time that these results were being generated, scientists from the University of Michigan (i.e., Lee and Batchelor) released a paper suggesting that (1) magnetite and pyrite can dechlorinate chlorinated ethenes through abiotic processes and (2) vinyl chloride is not generated when DCE is dechlorinated through these abiotic processes. These findings led the authors to conclude that “[iron-containing minerals] could be more important than microorganisms under some conditions in affecting the fate of chlorinated ethenes.” Ferrey said that the abiotic processes mentioned in the University of Michigan paper could be operating at TCAAP: the sediments at this site have a significant amount of iron-containing minerals. Ferrey said that the Strategic Environmental Research and Development Program is funding additional research on the mechanisms of action that underlie the abiotic processes reported in the University of Michigan paper.
Before concluding, Ferrey said that it was important for attendees to take home the following messages:
Mary Siedlecki, NCDENR
Mary Siedlecki presented information about a problem confronting North Carolina’s DSCA program. When the program was being formulated, she said, NCDENR was enthusiastic about the idea of working with parties who wanted to redevelop drycleaning facilities. In fact, the Agency informally welcomed the idea of working on sites slated for redevelopment, expecting that redevelopers would likely raze building structures and make it easier (and more cost-effective) to excavate contaminated soils. Now that the DSCA program has become operational, however, NCDENR is becoming overwhelmed by developers who want to use the DSCA program to serve their own interests. Siedlecki supported her point by presenting case studies. Although her PowerPoint presentation (included as Attachment CC, PDF, 30 pp., 598 KB) included three case studies, Siedlecki could only provide information about the following two sites due to time constraints:
Siedlecki said that NCDENR is trying to identify solutions to the problems encountered with developers. Toward this end, three ideas have been proposed:
The Rummel Fibre Company Site
Trey Cantrell, Georgia Environmental Protection Division, Hazardous Sites Response Program
Cantrell presented information on remediation efforts that have been performed at The Rummel Fibre Company, a facility that produced television antennas and electronics between 1968 and 1990. Although the facility is not a drycleaner, Cantrell said, lessons learned there are applicable to SCRD members since the site is contaminated with the same types of chlorinated solvents that are typically found at drycleaning sites. (TCE is present. Concentrations have been detected at 45,000 ppb and 8,000 ppb in the soil and ground water, respectively.)
A standard pump-and-treat system operated between 1995 and 2002. Although this system achieved 75 percent mass removal, it did not succeed in lowering contaminant concentrations below maximum contaminant levels. In 2003, site managers decided to adopt a more aggressive remedial approach. They chose an electrochemical geo-oxidation system in conjunction with a carbon dioxide vacuum stripping well. Sampling results suggest that this technology has lowered soil contaminants to acceptable levels. TCE concentrations in the ground water, however, still remain higher than is acceptable. Site managers hope to see these numbers come down after the remediation system has been operational for a longer time period.
Old National Shopping Center Site—Enhanced Fluid Recovery and
in situ Chemical Oxidation with Fenton’s Reagent
Elizabeth Penny, Georgia Environmental Protection Division, Hazardous Sites Response Program
Elizabeth Penny discussed remediation efforts performed at the Old National Shopping Center, a property with a drycleaning facility onsite. This drycleaner has released contaminants to the environment, Penny said. Two source areas have been identified, and PCE (along with all of its daughter products, i.e., TCE, DCE, and vinyl chloride) has been detected in soil and ground water. (Maximum PCE concentrations detected in soil and ground water are 210 ppm and 20 ppm, respectively. Concentrations of other contaminants are listed in Attachment DD, PDF, 26 pp., 1883 KB.) Penny said that the site consists of a sandy soil and that ground water is first encountered 5 to 10 feet bgs. She also noted that a contaminant plume extends across a 500-foot by 200-foot area and that contaminants extend to a depth of 85 feet bgs.
Penny said that a three-pronged remedial strategy has been adopted at this site:
To date, Penny said, the remedial activities performed at the site have removed
approximately 190 gallons of solvents from the site’s subsurface, decreased
VOC concentrations in ground water by 83 percent, and decreased VOCs in soil
by 84 percent.
Attachments A Through DD
Attachments A through DD 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 May 2004 meeting summary.
|Final attendee list (PDF, 3 pp., 193 KB)|
|State update handouts|
|Preparing and Submitting Drycleaning Site Profiles—SCRD Web site (Created by Bill Linn) (PDF, 3 pp., 37 KB)|
|Summary materials related to The Groundwater Resources Association
of California’s 10th Symposium in the Series on Groundwater Contamination
(prepared by Wendy Cohen) Q1 (PDF,
2 pp., 19 KB)
Q2 (PDF, 2 pp., 25 KB)
|Littlefork Site (Susan Johnson, Barb Gnabasik, and Dave Wolfgram) (PDF, 26 pp., 2468 KB)|
|Attachment S:||Alabama Drycleaning Environmental Response Trust Fund (Pam Wilson) (PDF, 22 pp., 57 KB)|
|Vapor Migration Issues and Indoor Air Case Study at a Chlorinated Site (Jim Harrington) (PDF, 24 pp., 576 KB)|
|Crown Cleaners (Nancy Frazier) (PDF, 15 pp., 890 KB)|
|Attachment V:||Report on the AEHS Vapor Intrusion Conference (Craig Dukes) (PDF, 33 pp., 3682 KB)|
|Attachment W:||Springfield Laundry (Ken Koon) (PDF, 18 pp., 51 KB)|
|BioRem H-10 Pilot Study Results: Carousel Cleaners (PDF, 22 pp., 159 KB)|
|Attachment Y:||Heated Soil Vapor Extraction Pilot Project at United Cleaners, Lemont, Illinois (Juho So) (PDF, 18 pp., 988 KB)|
|Attachment Z:||Remedy Selection at a Wisconsin Drycleaning Site (Robin Schmidt) (PDF, 25 pp., 367 KB)|
|Attachment AA:||Nu-Look One Hour Cleaners, Coral Springs, Florida (Jo Johnson) (PDF, 59 pp., 305 KB)|
|Attachment BB:||Abiotic Natural Attenuation of Dichloroethylene Isomers (Mark Ferrey) (PDF, 25 pp., 909 KB)|
|Attachment CC:||Developing Dilemma (Mary Siedlecki) (PDF, 30 pp., 598 KB)|
|Attachment DD:||Old National Shopping Center Site—Enhanced Fluid Recovery and in situ Chemical Oxidation with Fenton’s Reagent (Elizabeth Penny) (PDF, 26 pp., 1883 KB)|