STATE COALITION FOR REMEDIATION OF DRYCLEANERS MEETING
The Quarterage Hotel
Kansas City, Missouri
September 2930, 2004
INTRODUCTORY REMARKS AND A DISCUSSION ABOUT THE SITE PROFILE DATABASE
William Linn, Florida Department of Environmental Protection (FDEP)
Richard Steimle, U.S. Environmental Protection Agency (EPA)
William Linn, the chair of the State Coalition for Remediation of Drycleaners (SCRD), welcomed attendees to the meeting. (A list of attendees is included as Attachment A.) Noting that there were some new people in the audience, he thanked them for their interest in SCRD and described some of the resources that can be accessed through the SCRD Web site (http://www.drycleancoalition.org). For example, he said, those who visit the Web site can subscribe to an SCRD newsletter, access a variety of drycleaner-related publications, obtain lists of drycleaner-related chemicals, learn about drycleaner cleanup fund programs that have been established across the country, view relevant government and technology Web links, and access a long list of drycleaner-related references. Most importantly, Linn said, the SCRD Web site hosts a site profile database, which provides information about remediation activities that have been (or are being) implemented at contaminated drycleaning sites across the nation. (About 95 site profiles are currently posted, but 5 might be removed because they lack remediation data. Before any of those are removed, though, the original authors will be contacted and given a chance to add remediation data.)
Linn encouraged attendees to do the following to improve the site profile database:
Address the backlog. Although 30 site profiles have been initiated for sites in Illinois, Tennessee, and Texas, these profiles need to be reviewed and/or updated before they can be posted to the Web site. Linn asked representatives from these three states to speed up the review process.
Remain on the lookout for new sites to add to the database. Linn reminded SCRD members that it is acceptable to include sites that are being addressed outside of their states' formal drycleaner cleanup fund programs. For example, he said, contaminated drycleaning facilities that are being remediated through the Brownfields program, voluntary cleanup programs, or Superfund would all be good candidates for inclusion. If attendees learn of new sites, Linn said, they should tag them for potential profiles and try to identify people who will submit information about them.
Update existing site profiles on a regular basis. Linn noted that several SCRD members are listed as contacts for the sites that appear in the database. He encouraged them to provide updates and to submit new data regularly.
Follow the guidelines for writing site profiles. Linn passed out a handout, entitled "Preparing and Submitting Drycleaning Site ProfilesSCRD Web site," which lists recommendations on how to improve the quality of the site profiles. (The handout is available as Attachment B (PDF, 3 pp., 43 KB.)) Linn encouraged attendees to keep these recommendations in mind when developing new profiles. In particular, he said, attendees should strive to include information on costs and lessons learned.
Linn spoke briefly about the SCRD newsletter, a publication that Carolyn Perroni puts together twice a year. The newsletter is distributed to about 150 people and is also posted on the SCRD Web site. It has a broad readership and is tracked closely by organizations like the National Clothesline. The newsletter presents cumulative data on the number of sites being addressed under state drycleaner cleanup fund programs and provides a breakdown on how many sites are in the assessment, remediation, and close-out phase. Linn encouraged attendees to continue supplying such data to Perroni so that she can provide the most up-to-date information in the newsletter.
Linn turned the podium over to Rich Steimle, who also thanked the attendees for their interest in SCRD. EPA supports SCRD, Steimle said, because the Agency believes that the lessons learned at small drycleaning sites can be applied to larger Superfund sites. Drycleaning sites can be assessed and remediated more quickly than larger sites; as a result, conclusions about the efficiency of different remedial technologies can be made relatively quickly. Steimle said that EPA is eager to hear about what lessons have been learned using different technologies at drycleaning sites. For this reason, it is important for SCRD to continue to maintain and improve the site profile database. In fact, Steimle said, the database helps him justify SCRD's existence. Steimle reiterated the point that Linn made about the importance of updating existing profiles and adding new ones to the database. To assist with the latter, Steimle said, EPA is willing to hire summer interns to assist with site profile development. He noted that Ray Frigon (representing Connecticut) and Dave Anderson (representing Oregon) have expressed interested in this idea. If other states are interested, they should let Steimle know as soon as possible, but no later than December 31, 2004. Anyone who requests an intern should be prepared to set aside sufficient time to ensure that the intern has access to pertinent information and data.
STATE PROGRAM UPDATES
Perroni 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 an update (see Attachment C (PDF, 1 p., 32 KB)) on Alabama's Drycleaner Trust Fund, a reimbursement program that has been operational since 2001. The fund balance is about $2.6 million, but this amount is expected to drop in October when administrative allowances are issued. There are 99 sites participating in the fund program, 5 of which have initiated the assessment process and are being reviewed by ADEM. None of these sites have received reimbursement for their assessment costs yet. Wilson said that one of the five sites might be able to use institutional controls (rather than performing remedial work) to address environmental concerns. Touching on program administration issues, Wilson noted that ADEM has hired three new people to implement the fund program and that the Board (a seven-member entity that helps ADEM administer the fund program) is reviewing applications in an effort to line up contractors who perform assessment and remediation work. Wilson concluded by saying that several drycleaners have asked her for more information on the fund program's status and activities. She plans to make the Board aware of these requests.
Ray Frigon, Connecticut Department of Environmental Protection (CDEP)
Ray Frigon thanked SCRD members for the opportunity to speak, noting that this marked the first time Connecticut has been represented at an SCRD meeting. Connecticut does have a formal drycleaner cleanup fund program, but it is administered through the state's Department of Economic Community Development rather than CDEP. The latter does, however, provide oversight on assessment and remedial activities that are conducted at contaminated drycleaners. Frigon said that he did not have up-to-date information on the fund program's financial status because the state's accounting systemrecently transferred to a private consulting firmis not fully operational at the moment.
Jennifer Farrell, FDEP
Jennifer Farrell presented information about the status of Florida's drycleaner cleanup fund program. Attachment D (PDF, 1 p., 26 KB) provides detailed information on the fund's financial standing and the types of technologies that have been deployed and proposed to address contaminated drycleaners. Farrell said that 1,422 facilities are eligible to participate in the fund program. Assessment activities have been completed at 243 of these sites. Remedial activities (excluding excavation) have been initiated at 133 of them and completed at 35. FDEP has closed out 85 sites, none of which required active ground-water remediation. Soil remediation activities have been required at most (if not all) of the contaminated facilities.
Farrell said that several innovative technologies have already been implemented and that more will be tested in the near future. She expressed particular interest in Newman Zone, a bioremedial approach that involves injecting an emulsified vegetable oil that is fortified with lactate. Upon request, Farrell provided an update on a bioremediation project (involving potassium lactate injections) that is being conducted at a contaminated drycleaning facility in Florida. She noted that low pH values (ranging from 4.7 to 5.2) have inhibited reductive dechlorination activities at this site. To address this problem, potassium hydroxide was introduced into the aquifer to buffer the low pH ground water. This action succeeded in raising pH levels to the 6.3 to 6.8 range.
Jacki Scarbary, Georgia Environmental Protection Division, Hazardous Sites Response Program
Georgia has not established a formal drycleaner cleanup fund program, but some interest has been expressed in developing such a program. Jacki Scarbary provided information (see Attachment E (PDF, 1 p., 17 KB)) about the scope of the drycleaner problem in Georgia. Tetrachloroethylene (PCE) releases have been reported at about 407 current or former drycleaners. At one point, 51 of these sites were on the Hazardous Site Inventory. About 18 sites were removed from the list, however, when site investigation and remediation activities were completed. Scarbary said that 338 property owners have contacted Georgia claiming that their properties have been (or are suspected of being) negatively impacted by PCE releases from drycleaners.
Juho So, Drycleaner Environmental Response Trust Fund of Illinois
Juho So provided an update on Illinois' Drycleaner Environmental Response Trust Fund program. (See Attachment F (PDF, 1 p., 43 KB) for details.) He opened by stating that the fund's revenue stream has increased; he believes this is because license fees have doubled and insurance premiums have increased. He also provided information about the number of sites that are being addressed under the fund program, noting that claims are still open for 307 sites, "No Further Remediation" letters have been issued for 34 sites, closure is pending for 16 sites, remedial activities are ongoing at 5 sites, and remedial activities are scheduled to start at 10 additional sites in the near future.
In the past, So said, many drycleaners resented the fact that they were expected to pay into the fund. Some of this resentment has started to dissipate, however, as the drycleaners have gained a better understanding of why the fund was created and how it can benefit them. This shift in attitude can be credited, at least in part, to the fact that contamination has been detected at 90 percent of the drycleaners that have been investigated so far. Statistics of this nature help drycleaners understand the magnitude of the contamination problem. So said that Illinois is interested in determining whether there is a correlation between the age of a drycleaning facility and the degree of contamination found. (So far, the state has found no such correlation.)
Bob Jurgens, Kansas Department of Health and Environment (KDHE)
Jurgens distributed a handout (see Attachment G (PDF, 1 p., 71 KB)) that summarized the financial status of the Kansas Drycleaner Facility Release Trust Fund. In addition, the handout provided information on the number of sites participating in the program and the types of remedial technologies that are being used to address these sites. Jurgens mentioned that KDHE has done the following over the last year:
Restructured contracting mechanisms. Jurgens said that contracting services have been split into three categories: assessment, remediation, and operation and maintenance (O&M) activities. KDHE has hired four contractors, three of which can provide all three of these services.
Developed a drycleaner database. Jurgens invited attendees to visit http://www.kdhe.state.ks.us/dryclean, a Web site developed to help KDHE track the different elements of the state's drycleaner cleanup fund program. This site provides information on fund revenue and expenditures, fund application procedures, drycleaner registration procedures, and compliance findings.
Generated a list of contaminated sites. Jurgens said that Kansas has generated (and posted to the Internet) a list of contaminated sites that are located in the state. In the future, more detailed information (including geospatial information) will be added about each site on the list. Funding for this activity is being provided through an EPA grant.
Created a tool that helps people determine which regulations apply to specific industries.
Inspected drycleaning facilities. Jurgens said that KDHE usually inspects about 20 to 25 drycleaning facilities each year to determine whether drycleaners are meeting best management practices and complying with applicable environmental regulations. About half of the 2004 inspections have been completed, Jurgens said, and infractions have been recorded at 60 percent of the facilities. KDHE is disheartened by these results. In response, the Agency will ramp up inspection activities and visit every drycleaner in the state over the next couple of years. So asked whether drycleaners are punished for noncompliance. Jurgens said that KDHE is more interested in fixing problems than administering punishment. Thus, as a first step, KDHE simply sets a deadline for fixing the infraction rather than automatically administering a fine. If a drycleaner fails to meet the deadlines, KDHE can charge a fine up to $500. Jurgens said that the state's Small Business Environmental Assistance Program has served as a useful resource and has helped some facilities determine what they need to do to comply with regulations. In Illinois, So said, noncompliant drycleaners face a harsher punishment: the state refuses to pay for their cleanup costs if contamination is found at their sites.
Dale Trippler, Minnesota Pollution Control Agency (MPCA)
Trippler distributed a handout (see Attachment H (PDF, 1 p., 65 KB)) that provided detailed information about Minnesota's drycleaner cleanup fund program. His discussion focused on changes that have impacted the fund's revenue stream. He opened by noting that the fund's annual revenue decreased from $650,000 to $240,000 when an interim fee clause expired and reverted the revenue stream back to 1995 levels. Some drycleaners were not aware of this change and they continued to pay into the fund at a higher rate than required throughout 2004. These drycleaners will have to be compensated next year for the overpayments they submitted this year. As a result, the revenue for 2005 could be as low as $80,000. Trippler said that the reduction in annual revenue has definitely impacted the fund balancethe balance has gone from about $2 million to $300,000 over a short period, and he expects the balance to reach $0 by the end of the fiscal year. Once that happens, MPCA will have to tell drycleaners that they must wait a year or two to obtain money for environmental cleanup activities. Trippler said that the state's drycleaner association is lobbying to pass legislation that would raise the fund program's revenue stream back up to the $650,000 level. It is unclear whether their efforts will be successful, however.
Ken Koon, Missouri Department of Natural Resources (MDNR)
Ken Koon provided detailed information (see Attachment I (PDF, 2 pp., 42 KB)) about the status of Missouri's Drycleaning Environmental Response Trust (DERT) program. He said that there are about 531 active drycleaning facilities and about 250 abandoned sites in Missouri. Three sites are currently being investigated under the DERT program. While $750,000 was collected for the fund this year, Koon thinks $1 million could have been gathered if everyone who was supposed to pay into the fund had actually done so. Those who fail to pay only suffer minor penalties, so MDNR has little recourse to enforce payment obligations.
Koon said that he had hoped that rules for the fund program would be in place by the end of the fiscal year. In fact, he said, MDNR was prepared to file the rules with the Secretary of State on September 24, 2004. At the last minute, however, the Joint Committee of Administrative Rules challenged the rules, claiming that MDNR does not have the authority to issue them. The proposed rules are currently being held in abeyance; a decision will be made about how to move forth in January 2005, when the state legislature is back in session. Before finishing his update, Koon mentioned that MDNR has received approval to hire two new employees under the DERT program and is setting up databases for the DERT fund, establishing enforcement protocols, and developing reimbursement review protocols.
Jim Harrington, New York State Department of Environmental Conservation
Jim Harrington provided information (see Attachment J (PDF, 1 p., 30 KB)) about the way in which New York addresses contaminated drycleaning sites. The state does not have a formal drycleaner cleanup fund program, but about 75 contaminated drycleaners are currently being investigated or remediated. About 50 are on the state's hazardous waste site registry and are being addressed through the state's Superfund program; the remainder are being addressed under the Brownfields program, a voluntary program that the state adopted in October 2003. Harrington said that the Brownfields program is gaining in popularity for two reasons: it offers better liability protection than the Superfund program, and it offers advantageous tax credits. (The latter was not the intention of the original legislation. The state plans to evaluate the tax credit structure in the near future.) Harrington said that the state was supposed to develop soil cleanup standards for the Brownfields program by October 7, 2004. Although this deadline will not be met, efforts are underway to complete and issue the standards as soon as possible. Harrington brought up the issue of environmental easements, which are required at any Brownfields site that has institutional controls. He also noted that vapor intrusion issues continue to be a source of concern in New York. In addition, he provided a list of the technologies that have been used at drycleaning facilities and said that he planned to submit a site profile for a drycleaning facility that was treated with an iron wall.
John Powers, North Carolina Department of Environmental and Natural Resources (NCDENR)
In fiscal year (FY) 2004, money from a gross receipts tax started being directed into North Carolina's Dry-Cleaning Solvent Cleanup Act (DSCA) program. As a result, there has been a dramatic increase in the amount of revenue coming into the fund this year. (As shown in Attachment K (PDF, 2 pp., 76 KB), about $9.5 million was collected during FY 2004 and the fund balance had reached about $13 million by June 30, 2004.) While this increase is obviously welcomed, John Powers said, there is concern that the fund's growth will attract the attention of state representatives who are searching for money to cover other state expenses. For this reason, those administering the DSCA program are eager to move forth rapidly with site investigation and remedial activities to ensure that fund monies are indeed used to address drycleaning sites. Before the program can move ahead at full speed, however, NCDENR must finalize its risk-based rules. To assist with that effort, Powers said, a risk contractor will be hired to develop rules and write guidance material, tasks that will probably take about 12 to 18 months to complete.
Powers summarized activities that have been initiated (or in some cases completed) over the last several months to support the DSCA program. NCDENR has (1) executed contracts with four state-lead contractors, (2) developed a new prioritization system and prioritized 30 of the 95 drycleaning facilities participating in the DSCA program, (3) initiated efforts to hire an additional project manager, and (4) developed an assessment-remediation agreement for site work. Powers said that NCDENR has also paid past-cost claims (to the tune of $1.1 million) in accordance with the portion of the DSCA statute that allows reimbursement from the DSCA fund under certain conditions to drycleaners who incurred eligible cleanup costs between 1997 and 2001. In addition, Powers said, NCDENR has started examining the compliance component of the DSCA program and is preparing to hire someone who will oversee active drycleaners to ensure that they are following minimum management practices (MMPs). Efforts will also be made to coordinate with the state's Division of Air Quality (DAQ) inspection program to ensure that DAQ's inspectors are equipped to inspect active facilities to determine if they are in compliance with the DSCA program's MMP regulations. Powers ended by saying that he is concerned that tension could easily arise at sites that are slated for redevelopment. In some cases, he said, redevelopers might want to pursue more aggressive remedial timeframes than NCDENR believes to be justified based on the priority ranking of the site.
Bruce Gilles, Oregon Department of Environmental Quality (DEQ)
Bruce Gilles provided information about Oregon's drycleaner cleanup fund program. The Oregon DEQ, he said, will have about $905,000 available to spend on the program in FY 2005. Gilles said that 40 sites are participating in the program and that 13 (soon to be 14) sites have been closed out. Remediation activities have been initiated at 19 sites and completed at 9 of them. About 15 sites are sitting in the queue awaiting funding before any work can be performed at them. Gilles listed the remedial technologies (see Attachment L (PDF, 2 pp., 70 KB) for details) that have been used to address Oregon's drycleaning sites. In addition, he presented some anecdotal information about some of the sites that have been addressed. For example, sodium lactate performed well at one site, which DEQ is now closing out. At another site, Regenesis' HRC product achieved some success in addressing a source zone area. Indoor air concerns arose at a daycare center near another drycleaner site; to address the problem, DEQ retrofitted the daycare's HVAC system. Shifting to administrative issues, Gilles made the following points: (1) Oregon (like North Carolina) is concerned that redevelopment projects could place a strain on the program, and (2) Oregon recently recovered money for cleanup costs that had been spent on a drycleaning facility that was not complying with applicable environmental regulations.
Craig Dukes, South Carolina Department of Health and Environmental Control (DHEC)
Craig Dukes provided information (see Attachment M (PDF, 2 pp., 126 KB) about South Carolina's drycleaner cleanup fund program. About 303 facilities are participating in the program. Of those, 29 have entered the assessment phase, 3 are in the remediation phase, 1 is in the monitoring phase, and 1 is pending closure. Of the three sites in the remedial phase, ozone sparging has been used at two of them and potassium permanganate has been used at the third. Dukes said that the fund balance was about $823,000 as of June 30, 2004, but that $387,000 of this total has already been obligated to pay for outstanding site commitments. DHEC must wait to receive more revenue before initiating additional remedial projects at drycleaning sites. Starting in July 2004, a 1 percent tax started being diverted toward the fund. DHEC will find out how much money has been generated through that revenue source on October 20, 2004. Dukes said that he is optimistic that the tax will contribute an additional $1 to $1.5 million to the fund's annual revenue stream.
Steve Goins, Tennessee Department of Environment and Conservation (TDEC)
Goins opened with information (see Attachment N (PDF, 1 p., 66 KB)) on the budgetary status of Tennessee's drycleaner cleanup fund program. Fund revenue just cleared the $1.25 million threshold this year, he said, noting that TDEC would have had the authority to raise registration fees by 10 percent if the revenue had slipped below this mark. About $4 million has been spent addressing the 46 sites currently in the program; much still remains to be done at the majority of these sites. Goins said that 15 drycleaning facilities have been closed out in Tennessee, but he emphasized that these sites represent the "easy ones" and did not have any ground-water contamination issues associated with them. Goins noted that TDEC has established a new ranking system and is currently trying to generate a generic risk assessment template that can be used to evaluate drycleaning facilities.
Mike Leckie, Texas Commission on Environmental Quality (TCEQ)
Mike Leckie provided information (see Attachment O (PDF, 1 p., 613 KB)) on Texas' drycleaner cleanup fund, a program that came into existence in 2003. Leckie said that 1,937 drycleaners (66 percent of which use PCE) and 1,462 drop stations have registered. Approximately $4.4 million has been collected for the fund so far and about $167,000 has been expended. Solvent distributors are expected to collect solvent fees from drycleaners and to send the fees to the state. Recently, however, TCEQ learned that one distributor has been keeping the money rather than turning it over to the state. Disciplinary action is being considered.
TCEQ recently released an application form; those who wish to obtain money
from the fund program will be expected to fill it out. TCEQ will use the information
provided on the application forms to rank sites. After TCEQ issues a ranking,
Leckie said, site owners will be given 45 days to determine whether they want
to address their sites under the fund program or the state's voluntary cleanup
program. (They will not be allowed to enter their sites into both programs.)
Leckie concluded by noting that seven new people have been hired to administer
the fund program and that draft rules will be proposed on October 27, 2004.
Meade Anderson, Virginia DEQ
Meade Anderson said that Virginia explored the idea of establishing a drycleaner cleanup fund program in 1994, but the initiative did not pass. Interest in such an program is mounting again, however. In the meantime, contaminated drycleaning facilities will continue to be addressed under the State's Voluntary Remediation Program (VRP). About 60 drycleaning facilities are currently participating in VRP, Anderson said. Assessment activities have been completed at 40 of them, remedial activities have been completed at 31 of them and initiated at an additional 7, post-monitoring activities are ongoing at 15 sites, and closure has been achieved at 22 sites.
Anderson noted that vapor intrusion issues have attracted a significant amount of attention. There is also concern about the potential for construction workers to be exposed to contaminated subsurface soils at some contaminated drycleaning facilities. Responding to a question posed by Steimle, Anderson said that there is no central database that stores information about Virginia's contaminated drycleaning facilities. Kevin Greene (one of Anderson's colleagues) said that it might be possible to pull this information together and develop some site profiles, however.
Jeff Soellner, Wisconsin Department of Natural Resources (WDNR)
Jeff Soellner provided information (see Attachment P (PDF, 2 pp., 71 KB)) on Wisconsin's Dry Cleaner Environmental Response Fund. He said that the program has 124 participating facilities, about 40 of which have already received at least some reimbursement for assessment and/or remediation activities. Some legislative changes were introduced in spring 2004 and the program's codes were revised in summer 2004. (Additional information about these changes is presented in the "Case Studies" section of the report.)
COMMITTEE MEETING REPORTS
SCRD has three committees. On Monday, September 27, 2004, these committees met in breakout sessions to discuss the status of existing projects and 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:
The state program tables. The Committee has posted three tables that summarize the elements of each SCRD member state's drycleaner cleanup fund program. (The tables can be found at www.drycleancoalition.org/survey.pdf (PDF, 15 pp., 188 KB).) Goins said that these tables needed to be updated, and he asked attendees to review them and let him know if any changes are needed
The components paper. The Committee recently completed a paper entitled "State Approaches for Drycleaner Programs." The paper is available at http://www.drycleancoalition.org/docs/components. Goins asked attendees to review the paper and let him know if modifications are necessary.
The resource allocation project. Goins said that Committee members spent the majority of the breakout session talking about funding and staffing shortages that are likely to arise given the magnitude of the drycleaner problem that persists across the county. Prior to the meeting, Pat Eriksen distributed a list of 14 resource-allocation-related topics to discuss. Goins said that Committee members only had enough time to address seven of the topics, but that they plan to address the remaining seven when they meet again in spring 2005. Topics discussed during this meeting included: What are the greatest resource demands on your program? What internal policies/practices inhibit your ability to complete your mission? Does your program have definitive goals and establish timelines for meeting those goals? How do administrative and technical components of your program work together, and can anything be done to improve upon (and track) the coordination of these two elements? If you could change anything about your program, what would you change? Does your state establish financial projections? How do you balance income with potential liability? Goins said that Committee members will consider summarizing the content of their discussions and posting a summary on the non-public portion of the SCRD Web site.
Goins concluded by noting that Pat Eriksen will be taking over as the Committee's chairperson.
Robin Schmidt, who chaired the Outreach Committee for several years, has taken another position and is no longer participating in SCRD. Perroni said that she worked closely with Schmidt and was tasked with implementing many of the Outreach Committee's initiatives, such as developing news releases, newsletters, and maintaining an outreach list. Perroni expressed willingness to continue implementing these tasks, encouraging attendees to contact her if they have additional outreach ideas. Nancy Frazier said that she thinks Mary Siedlecki would be interested in assisting Perroni with outreach efforts. Perroni thanked Frazier for this suggestion and agreed to contact Siedlecki.
Project Management/Technical Issues Committee
Bob Jurgens said that the Project Management/Technical Issues Committee spent its breakout session working on a paper that discusses remediation technologies that are being used to address chlorinated solvents at drycleaning sites. Jurgens said that the session was productive: the group succeeded in ironing out some difficult issues. Jurgens said that he plans to consolidate all of the text that has been written so far and to send it to Committee members for review. The paper must be completed in time for the Association for Environmental Health and Sciences conference that is scheduled for March 2005 in San Diego, California.
Jurgens said that Dukes will be taking over as the Committee's cochair and he turned the floor over to him. Dukes said that he hopes SCRD members will start using the non-public portion of the SCRD Web site to engage in more online dialogue about the merits and drawbacks of innovative technologies. In addition, he asked attendees to let him know if they hear of new technologies that might be applicable to drycleaning sites. When he becomes aware of new technologies, he said, he invites vendors to deliver a presentation to a group of DHEC representatives. If any technologies show promise, he said, he will present information about them at future SCRD meetings.
SCRD BUSINESS SESSION
SCRD members discussed several topics during the business portion of their meeting, including future SCRD meetings, training opportunities, the non-public portion of the SCRD Web site, and a variety of miscellaneous topics. Their discussions are summarized below.
Future SCRD Meetings
The Spring 2005 SCRD Meeting
Attendees agreed that the spring 2005 meeting should be held in North Carolina. Cheryl Joseph agreed to start making arrangements and identify a suitable meeting facility. She said that the meeting will probably be held in Raleigh, Chapel Hill, or Wilmington. Lisa Appel recommended inviting state representatives from South Carolina and Virginia.
Attendees spoke briefly about the meeting agenda. They suggested including 2 days of training (see the section below entitled "Training Opportunities" for additional details), a half day of SCRD business (including state updates, Committee reports, and a business meeting), a half day of case studies, and a half day of panel discussions. The latter was proposed by Dukes and Linn. The goal of the panel discussions, Dukes said, would be to capture the expertise that SCRD members have gained using different remedial technologies. He recommended forming multiple panels and focusing each one on a specific technology (e.g., permanganate injections, ozone injections, bioremediation, or soil vapor extraction [SVE]). He also advised preparing a list of questions for the panelists in advance. Dukes said that the main points expressed during the panel discussions could serve as the basis for a future SCRD paper. Several attendees expressed interest in Duke's idea. One attendee suggested dedicating one or two of the panels to administrative issues (e.g., risk-based numbers, land use restrictions, or redevelopment issues) rather than focusing solely on technologies. Dukes also thought it would be a good idea to set aside 30 minutes at each SCRD meeting to discuss emerging technologies.
The Fall 2005 SCRD Meeting
Attendees agreed that it would be beneficial to hold a meeting in Texas. Dan Switek recommended holding the meeting in Austin, since TCEQ's offices are located in that city.
The Spring 2006 SCRD Meeting
Attendees talked about holding a meeting in New England in spring 2006. Providence, Rhode Island, and Hartford, Connecticut, were identified as possible meeting locations. Frigon agreed to talk to his managers about hosting a meeting in Hartford.
Audience members talked about training opportunities that might be available to SCRD members. First, Linn asked audience members to look at a 2-page handout describing a course called "Estimating Times of Remediation Associated with Monitored Natural Attenuation and Contaminant Source Removal." Linn said that this 1½-day course could be delivered to SCRD members as part of the spring 2005 SCRD meeting. So was not enthusiastic, saying that SCRD has already heard several speakers discuss natural attenuation. Several other audience members, however, expressed strong interest in the course. One attendee also suggested contacting Blayne Hartman to find out whether he is available to deliver a half day of training at the spring 2005 SCRD meeting.
Steimle brought up another training-related idea: sending trainers to individual states. He noted that Patrick Haas did an excellent job delivering training on accelerated bioremediation at SCRD's spring 2004 meeting. In fact, the training was so well received that Schmidt (a former SCRD member) asked EPA to arrange to send Haas to Wisconsin to deliver training to regulators in that state. Schmidt's request will be granted, Steimle said, and EPA might also be able to send Haas (or other trainers) to other states as well. If any states are interested in this type of opportunity, they should contact Steimle as soon as possible. Frazier advised Steimle to alert neighboring states whenever a training session is going to be delivered in a particular place. That way, she said, representatives from nearby states might be able to attend as well if space allows.
Accessing the Non-Public Portion of the SCRD Web site
Perroni noted that some SCRD members have expressed interest in using the non-public portion of the SCRD Web site to post sensitive information and to spur dialogue among SCRD members. She reminded audience members that they can access the non-public portion of the Web site by clicking on the "Admin" button that appears on the SCRD Web site and typing in a username and password. Linn encouraged SCRD members to use this section of the Web site to access the Web board. This tool, which was used a bit in the past, provides an excellent forum for dialogue and for sharing knowledge. Dukes noted that several categories of discussion are listed on the Web board; he recommended having the Program Development/Administration Committee review these categories to make sure the topics are still relevant.
Many attendees indicated that they had forgotten their usernames and passwords. Perroni agreed to resend these items. She will also distribute information on how to use the Web board and how to set up a notification feature so that users are alerted when new information is posted to the board.
SCRD members discussed the following:
Identifying emerging technologies. Dukes said that the Department of Energy posts profiles of emerging technologies and he agreed to send the Web link to SCRD's email distribution list. Dukes said that he periodically searches through the Web site in an effort to identify technologies that might have some potential at drycleaning sites.
Using iron walls to remediate contaminated drycleaning sites. Dukes said that he recently heard an interesting presentation from a company (GeoSierra) that claims to be able to install a zero-valent iron wall into the subsurface without having to use trenching equipment. (The iron is injected into wells and spreads in the subsurface.) Dukes said that he thinks this technology could prove to be useful (and perhaps cost-effective) at some drycleaning sites. He agreed to email additional information about the technology to SCRD members.
Providing ideas about future directions for SCRD. Linn said that he would like some input from SCRD members regarding what they hope to see SCRD accomplish in the coming years. He will send out a questionnaire in an effort to collect this information. He asked for responses as soon as possible.
Performing active soil gas screening. One of Florida's contractors has performed active soil gas screening at a drycleaning site and written up a paper describing the screening process in detail. Linn said that he thought the screening exercise provided very useful information.
Bentley's Garment Care Ground-Water Remediation System
Jim Schneider, KDHE
Jim Schneider described a project to address PCE contamination at Bentley's Garment Care, a drycleaning facility in Neodesha, Kansas. This facility is located near a public park, a public pool, and a high school. It began operating in 1981; though it was mainly used as a coin-operated laundry, some drycleaning services have also been performed on site. In 1996, BP/Amoco detected PCE in a monitoring well about a half-mile west of the facility. Bentley's Garment Care was identified as the source of the contamination. Upon making this discovery, the drycleaner applied to the Kansas Drycleaner Facility Release Trust Fund. The drycleaner was accepted into the program in 2001 and funds were provided for an Environmental Site Assessment (ESA). Attachment Q (PDF, 46 pp., 2.5 MB) presents detailed information about the ESA's results. In summary, it showed that the area is characterized by tight clays, that the contaminant source lies under a building, and that the dissolved phase of the plume is smaller than anticipated because the city pool's sump pump is acting as a minor capture device. These findingscoupled with the fact that the drycleaner is in a high-visibility area, that a BP plume is located nearby, and that remediation funds are limitedwere taken into account when identifying a corrective action for the site. After weighing these factors, Schneider said, KDHE decided to focus on the plume (rather than the source) and to do the following: build a 180-foot-long interceptor trench to capture ground water, pump ground water through a remediation system, and discharge treated water into the sanitary sewer.
Detailed information about the installation process is included in Attachment Q (PDF, 46 pp., 2.5 MB). In summary, Schneider highlighted the following points: (2) digging a test pit before introducing the trencher was important because it allowed contractors to identify old (and unmapped) pipes, (2) keying into bedrock helped ensure good ground-water recovery, and (3) establishing a good relationship with the City's public works staff helped make the project run smoothly. Elaborating on the latter point, Schneider noted that the City agreed to use the excess soils that were removed from the trench for other public works projects. (Before taking the soil away, however, the remedial contractors were required to dump it onto a plastic liner and test it to ensure that contaminants were not present at unacceptable levels.)
The remediation systemwhich was housed in a small buildingconsisted of a holding tank, a transfer pump, a stripper (which created bubbles and stripped out PCE), and a granulated active carbon (GAC) drum (which captured volatiles that had escaped to the air). Telemetry enabled KDHE representatives to monitor the system and to access real-time data remotely. Although the remediation system started operating in March 2004, KDHE's engineers had to make some modifications on July 19, 2004, to get it operating more efficiently. These modifications (performed at no cost) included installing a new joint to the effluent side of the stripper, installing additional baffles, placing a stand under the GAC drum, and addressing calcium carbonate buildup issues. PCE concentrations have been decreasing since the modifications were completed.
Schneider said that the trench cost $55,000 and the remediation system was $64,000. KDHE expected these costs to be higher, but was able to save money by using existing equipment and capitalizing on some contractor scheduling issues. Responding to questions from the audience, Schneider said that O&M costs are about $12,000 per year and KDHE plans to address the source at this site when funding becomes available and a promising technology is identified.
Ex Situ Treatment and CAMU Implications at the Springvilla Site
David Anderson, Oregon DEQ
Dave Anderson talked about the impact that RCRA-related issues can have on drycleaner remediation projects. In 2002, he said, the Oregon Department of Justice (DOJ) made it clear that materials generated in the process of remediating a contaminated drycleaner are F-listed wastes. (For example, PCE-contaminated soils that are displaced or excavated during remedial activities are F-listed wastes.) DOJ's ruling could have been very costly for the state's drycleaner cleanup fund program, Anderson said: RCRA regulations require F-listed soils to be disposed of in Subtitle C landfills, at about $300 per ton. To avoid incurring these costs, Anderson said, drycleaners in Oregon can pursue one of the two following options:
Treat contaminated soils on site so that they can be sent to Subtitle D (rather than Subtitle C) landfills. Contaminated soils can be treated on site in Corrective Action Management Units (CAMU). If concentrations decrease to an acceptable level, the soils may then be disposed of off site at Subtitle D facilities at a cost of about $50 per ton of soil.
Send wastes to"CAMU-eligible" Subtitle C landfills. Anderson noted that the RCRA rules were amended in January 2002 to allow for offsite disposal of certain remediation wastes known as "CAMU-eligible wastes." With these modifications in place, listed wastes may be downgraded to "CAMU-eligible" status if site managers can reduce their toxicity or mobility to certain standards. (See Attachment R (PDF, 22 pp., 482 KB) for additional details.) "CAMU-eligible" wastes may be shipped off sitefor a price of about $70 per tonto Subtitle C landfills that are permitted to accept them.
Anderson focused the remainder of his talk on a remediation project that is being performed at Springvilla Cleaners, a site with PCE in its soil (at concentrations ranging from 130 ppm to 640 ppm) and ground water (at concentrations of about 79 ppm). Several municipal, residential, and industrial wells are located nearby. Springvilla Cleaners is no longer operational; in fact the building that once housed the cleaner has been partially demolished. Strong interest has been expressed in redeveloping the site as soon as possible. Anderson noted that 200 cubic yards of soil have been excavated and treated on sitewrapped in plastic, allowed to heat up, and exposed to a blower that stripped out VOCs. Offgassing was addressed using a vapor-phase carbon system. By treating the soils on site, Anderson said, the site team succeeded in reducing contaminant concentrations enough to allow for offsite disposal in a Subtitle D landfill. This strategy resulted in huge cost savings. (Soil disposal costs were $12,000 rather than the $84,000 that would likely have been spent if the soils had been disposed of as F-listed wastes in a Subtitle C landfill.) Anderson said that a chemical oxidation technology will soon be deployed to address the source area. Sub-slab venting of the vadose zone and bioremediation activities will also be considered for this site. Expanding on the latter, Anderson said that site managers propose injecting about 6,000 pounds of emulsified oil into the subsurface to promote biodegradation processes. In addition, samples will be collected to determine whether contaminant-degrading microbes occur naturally at the site. If necessary, site managers will augment the microbial population by introducing Dehalococcoides ethanogenes to the environment.
Use of ArcGIS Software to Depict Site and Regional Contamination
Joseph Dom, KDHE
Joseph Dom presented information (see Attachment S (PDF, 32 pp., 2.79 MB)) about the merits of ArcGIS software as a management, analysis, and communication tool. He opened by defining the geographic information system (or GIS) as a tool for managing, analyzing, and graphically displaying geospatially referenced data. Although many people think of GIS simply as a map-making software package, Dom said, it really has much wider applications and can be a great planning tool for project managers.
Dom walked attendees through the different types of GIS software packages that are available and he summarized the types of tools that come with the software. In addition, he presented some examples of the way that data sets can be overlaid on top of each other to show the way in which different features in the environment relate to each other. For example, he showed how KDHE used GIS to determine which of the wells in Colby, Kansas, were most likely to be impacted by contaminant plumes.
Dom did note, however, that some pitfalls can be encountered when using GIS. For example, it is important to check the metadata when developing GIS maps. Users should also keep in mind that there can be some difficulties with obtaining accurate geospatial representations. For example, roads and rivers might only appear as thin lines, but it is important to remember that these features do have widths associated with them.
Dom said that GIS-generated maps can be a very effective communication tool to use at public meetings. This is because maps convey an enormous amount of information in an easy-to-understand format. People from a broad range of backgrounds, with widely differing experience and education, seem to respond well to maps and understand them.
Dom asked audience members if they had any questions or comments. Perroni said that GIS maps can be useful aids at public meetings if they are presented in a manner that is legible to attendees. All to often, Perroni said, she has attended meetings where maps were projected on screens that were too small for adequate viewing. She encouraged SCRD members to keep this in mind if they plan to present maps at their meetings.
In Situ Bioremediation at the Ridgeway Logging Site and the Blacks
Cleaners Site Using Emulsified Oil Injection
Bruce Gilles, Oregon DEQ
Bruce Gilles provided information (see Attachment T (PDF, 27 pp., 1.73 MB)) about two contaminated sites in Oregon that are being treated with emulsified vegetable oil injections. He opened by explaining the theory behind this emerging bioremedial approach: emulsified oil acts as a slow-release electron donor and promotes reductive dechlorination activities. In a nutshell, injecting emulsified oil fosters reductive dechlorination activities by increasing the amount of organic material available in the subsurface and reducing oxygen content. Gilles said that Oregon DEQ is hoping that emulsified oil might have some advantages over competing biostimulants. For example, given the slow degradation rate associated with emulsified oil, the Agency is hoping that effective results can be obtained with one injection rather than repeated injections. If this bears out, it could have significant cost saving implications. In addition, DEQ suspects that emulsified oil might be easier to distribute in the subsurface than its competitors. Gilles also mentioned that emulsified oil is significantly cheaper (about $1.6 to $1.8 per pound) than some other commercially available bioremedial agents. Gilles spent the remainder of the presentation talking about two sites:
Blacks Cleaners. This sitean active drycleaning facilityhas soil contamination, ground-water contamination, and vapor intrusion issues. An underground storage tank was removed in 1995, and PCE-contaminated soils were excavated and shipped off site in 2000. Unfortunately, space constraints made it impossible to remove all of the impacted soil; residual concentrations as high as 7,000 ppm have been detected in the sidewalls of the excavation. Multiple bioremediation studies have been performed at this site in an effort to address the source area. For example, a side-by-side field demonstration project was initiated in October 2002 to compare the efficacy of sodium lactate (a biostimulant) with that of CL-OUT (a bioaugmenter). With sodium lactate, the site team found that they had to reinject every 3 to 6 months to maintain high total organic carbon concentrations and a strongly reducing environment. For this reason, the team decided to switch to a slow-release electron donor. Toward this end, in April 2004, emulsified oil (2,500 gallons at 10 percent dilution) was injected into the subsurface and chased with 170 gallons of water. Also in 2004, site managers decided to install a biobarrier (consisting of 500 gallons of BIOREM H-10 solution) downgradient of the source area to deal with the dissolved phase of the contaminant plume. Results collected to date suggest that the emulsified oil has succeeded in supporting a strong reducing environment and degrading PCE to cis-dichloroethene (cis-DCE). The jury is still out, however, on whether the cis-DCE "bottleneck" in the source area can be overcome. As for the downgradient biobarrier, Gilles said, although the BIOREM amendments do improve treatment performance, the effects are not sustained. Gilles did note that Dehalococcoides will be injected to further stimulate bioremedial activities in October 2004.
Ridgeway Logging. This facility, which operated as a scissors manufacturing facility, is being addressed under the state's orphan program. The site has been identified as a source of widespread PCE ground-water contamination, Gilles said, noting that 40 residences have been hooked up to municipal water supplies as a result. Vapor intrusion issues have also arisen as a source of concern. Soil was removed from the site in 1997, and a site investigation was performed in 1998. Efforts to address ground-water contamination were initiated in April 2004, at which time a biobarrier of emulsified oil was installed at the site. Gilles said that the barrier extends across a distance of about 500 feet and a depth of 15 feet below ground surface (bgs) to 40 feet bgs. About 8,400 pounds of the emulsified oil (diluted to about 38,400 gallons) were injected to create the wall. Although a reducing environment has been established, PCE concentrations have not dropped significantly at the site yet. Some studies indicate that Dehalococcoides is absent. To address this problem, site managers plan to inject these microbes into the subsurface in the near future.
Gilles concluded by listing some of the design and installation issues that one should take into account when using emulsified oil. (See Attachment T (PDF, 27 pp., 1.73 MB) for details.) He also noted that (1) some responsible parties in Oregon are thinking of experimenting with emulsified oil, (2) there has been some discussion of using emulsified oil as a presumptive interim remedial action for drycleaner sites, and (3) it might be wise to consider using emulsified oil in combination with bacteria inoculations.
Cinderella Cleaners: Bench-Scale Microcosm Studies and In Situ Tracer Testing
Dan Nicoski, KDHE
Larry Davis, Kansas State University (KSU)
Dan Nicoski and Larry Davis teamed up to present information about efforts that are underway to identify a remedial strategy for Cinderella Cleaners. Nicoski opened the presentation by noting that intermittent hits of chlorinated solvents had been showing up in public supply wells in Manhattan, Kansas. Investigations identified Cinderella Cleaners, a drycleaning facility located 6,000 feet upgradient, as the source of the contamination. Nicoski said that a large GAC unit was installed to remediate contaminants at the wellhead and that this has resolved any concerns that existed about impacted drinking water. Emphasis is now being placed on identifying a remedial strategy to address the 6,000-foot-long chlorinated-solvent plume that emanates from the Cinderella Cleaners site.
Nicoski said that Cinderella Cleaners was in operation between 1967 and 1997 and that PCE machines were used at the site. The soils underlying the site are characterized by clays interbedded with silty clays (from ground surface to 35 feet bgs), silty clay interbedded with silty sand (from 35 feet bgs to 45 bgs), and fine to medium sand (from 45 feet bgs to 55 feet bgs). Ground water is encountered about 15 feet bgs. Describing the source area, Nicoski noted that concentrations of PCE have been detected at concentrations of 820 ppm in the soils and that PCE (50,000 ppb), TCE (6,500 ppb), DCE (2,100 ppb) and vinyl chloride (values less than 10 ppb) have all been detected in ground water. In the downgradient portion of the plume, almost no PCE is found, some TCE is detected, and a fair amount of DCE is present. Such findings suggest that natural attenuation processes are occurring.
Nicoski turned the presentation over to Larry Davis, who said that KSU is performing a series of tracer tests and microcosm studies to answer some of the following questions about Cinderella Cleaners: Where are the contaminants going? What kind of natural attenuation processes are already occurring? How will biostimulation and/or bioaugmentation effect degradation processes? What contaminant concentrations are actually present? What volume of soil and water actually need to be cleaned up? What needs to be done to prevent natural attenuation processes from stalling out at DCE? How much nutrient, hydrogen donor, or microbial mass is needed to adequately address the area? A description of the study design and a detailed summary of the results collected to date can be found in Attachment U (PDF, 25 pp., 1.22 MB). In summary, Davis made the following main points:
Tracer studies are being performed to track ground-water flow through deep and shallow areas. The deep tracer test was conducted first; results suggest that ground water is flowing about 0.7 to 1 feet per day and that the plume might be about 20 years old. The shallow tracer test was initiated on September 16, 2004. Preliminary results suggest that the ground-water flow direction might be variable. Additional analyses are required before more conclusive statements can be made, however.
Based on the results collected from microcosm studies, it appears that site soils and ground water are naturally endowed with microbes that promote natural attenuation. The magnitude of natural degradation processes differs depending on whether supplements and nutrients are added to the system. In addition, degradation rates vary across location. For example, samples collected from certain parts of the site exhibit faster contaminant degradation rates than samples collected from other locations. The microcosm studies also revealed that degradation is enhanced by adding SiRem's KB-1 microbial consortium to the system.
Davis said that KSU plans to perform additional studies. For example, efforts will be made to estimate natural attenuation rates, calculate diffusion and dispersion rates, and estimate the cost of implementing an in situ biostimulation or bioaugmentation pilot study at the site. Several students are assisting with the research: the site has been chosen as a case study for one of KSU's environmental engineering classes.
What About the Other Drycleaning Solvent?
Craig Dukes, South Carolina DHEC
Dukes provided information about Stoddard, a petroleum-based solvent (PBS) that is commonly used at drycleaning facilities. He opened by saying that some forms of PBS were being used as cleaning agents in the late 1800s, but that Stoddard was developed in the 1920s as a response to pleas for a less flammable solvent. Dukes said that "Stoddard" is a generic term for petroleum distillates that meet specifications for a variety of criteria, including flash point, distillation temperature range, boiling point, corrosivity, and pH. Several different brand names fall under the Stoddard umbrella. Attachment V (PDF, 68 pp., 4.27 MB) provides detailed information about the chemical composition of Stoddard.
Although only about 15 percent of drycleaning facilities across the United States use Stoddard, the product accounts for about 40 percent of the drycleaning solvent that is sold across the country. Dukes said that Stoddard is used most heavily in the Southern states. In his own state, Stoddard is used at about one-third of the drycleaning facilities. These facilities, even though they do represent a significant proportion of South Carolina's drycleaners, are not required to participate in the drycleaner cleanup fund program if they started operating before 1995. (This holds true even for PBS-using facilities that also use some PCE.) Nevertheless, about 61 PBS-using facilities have opted to join the fund program. Of these, 29 define themselves as PBS-only facilities and the remaining 32 have indicated that they use PBS and PCE. Dukes said that soil samples have been collected from the PBS-using facilities and that petroleum-based contaminants have been detected at many of the sites. In addition, PCE was detected at 38 percent of the sites that were classified as "PBS-only." The latter result came as a surprise, Dukes said; DHEC is formulating theories as to why PCE might be present at these sites. One possibility, is that PCE is present because it is a component of spotting agents and petroleum-based soaps. Another possibility is that PCE was used in waterproofing dip tanks. Alternatively, PCE might have been introduced at some of these sites as an antibacterial agent: according to one former drycleaner, some drycleaners used to add PCE to Stoddard to keep it from turning rancid.
Dukes said that DHEC has prioritized the 302 drycleaners that are participating in the state's drycleaner fund program and that six PBS-only sites are listed in the top 25 list. Dukes described all six of these sites (see Attachment V (PDF, 68 pp., 4.27 MB) for details). In summary, he noted that DHEC has learned that even though some of the sites were registered as PBS-only sites, some of them did use PCE machines in the past. For such facilities, PCE contamination proved to be a problem even if the PCE machine had been removed from service long ago. At sites where PBS really was the only solvent used, however, PBS releases did not appear to pose imminent public health concerns because the PBS-related contaminants appeared to be locked up in the soil.
Dukes said that it is still unclear whether there are negative environmental consequences associated with PBS releases. One thing to consider when trying to put releases into perspective, he said, is that Stoddard is a registered herbicide in many states and that farmers are allowed to apply about 180 gallons per acre to the ground each year. Also, Stoddard is introduced to the environment in large quantities as a byproduct of paving activities. (Stoddard is a component of some formulations of "cutback asphalt,"a material that is sprayed on bare earth or roadbeds before asphalt is laid.) Dukes said that the jury is still out regarding the toxicity of Stoddard. Although the National Toxicology Program recently concluded a 2-year animal study to test the effects of inhaling Stoddard, no definitive results were obtained from the study. (There was some evidence of carcinogenic activity in male rats, no observable effect with female rats and male mice, and inconclusive evidence with female mice.) The State of California, however, recently listed naphthalene (one of the chemicals found in Stoddard) as a carcinogen.
Connecticut's Property Transfer Act and Drycleaning Remediation Fund
Ray Frigon, CDEP
Frigon provided information (see Attachment W (PDF, 71 pp., 1.66 MB)) about how contaminated drycleaners are addressed in Connecticut. He opened by noting that the state does have a drycleaner cleanup fund and that revenue for the fund is generated through a 1 percent surcharge on gross sales. Drycleaners who use PCE or Stoddard are eligible to participate, but participation is not mandatory and drycleaners are not forced to pay into the fund. Those who choose not to pay, however, are not allowed to tap into the fund's financial benefits if contamination is found at their sites. Eligible participants can obtain up to $50,000 per year to help pay for site assessment and remediation activities. No more than $150,000 may be used at any given site, however. Frigon said that he thinks that the $150,000 spending cap is low, and that he would like to see the surcharge on gross sales double to generate more revenue for the fund. Frigon said that drycleaners are invited to apply for fund benefits two times a year, noting that three or four applications are typically submitted during each open application period. The fund program is administered through the state's Department of Economic Community Development rather than CDEP. Once a drycleaner submits an application, however, CDEP is called upon to provide review and oversight. Frigon said that CDEP also gets involved with drycleaning facilities through two other programs:
The Property Transfer Program. In the past, Frigon said, properties were often sold without the benefit of an ESA performed before the sale. As a result, many innocent buyers were unwittingly saddled with contamination they did not create. To combat this problem, Connecticut passed the Property Transfer Act in 1985. The Act stipulates three major points: (1) sellers must disclose the environmental condition of their property or business to potential buyers, (2) responsible parties must be identified to address contamination, and (3) CDEP must be informed of property transfers. Anyone who owns a drycleaning business that was operating on or after May 1, 1967 (or anyone who owns the property that the drycleaner is located upon) must adhere to the Property Transfer Act. Frigon described the forms (see Attachment W (PDF, 71 pp., 1.66 MB)) that must be filled out. One of the formsthe Environmental Condition Assessment Formis designed to give CDEP a snapshot of a site's environmental conditions and setting. CDEP uses this form to determine whether to provide direct oversight over the site or turn the site over to a Licensed Environmental Professional (LEP). (LEPs are not state employees, but they do have to pass a test to prove their prowess in managing contaminated sites. Connecticut calls upon LEPs in an effort to alleviate some of the burden that would otherwise fall upon CDEP staff members. Sites deferred to LEPs are those that have low contaminant levels and do not pose imminent health threats.) Frigon said that CDEP is given 45 days to review the forms submitted by an owner and to make a determination of how the site will be handled. After CDEP makes its determination, the responsible party has 30 days to send CDEP a plan of action explaining how they will address the site and when they plan to complete specific objectives.
The Voluntary Remediation Program. Drycleaners do not have to wait for a property transfer situation to address contamination at their sites. In fact, some people choose to initiate the process a few years before they retire or sell their businesses. That way, when it comes time to sell, an owner is in a position to confidently say one of the following: (1) my site is not contaminated, (2) my site was contaminated but it has been addressed to CDEP's satisfaction, or (3) my site is contaminated but steps are already underway to address the problem.
Kansas Drycleaner ProgramOnline Drycleaning Registration Web Site
Bob Jurgens, KDHE
Kansas has developed a Web site (https://www.accesskansas.org/dryclean/registration.html) that allows drycleaners to register and pay their registration fees online. Jurgens said that there are several benefits to placing the registration process online. First, it reduces paper processing. Second, it allows drycleaners to obtain registration certificates instantaneously and allows solvent distributors to gain access to information24 hours a day and 7 days a weekabout which drycleaners are up to date with their registration requirements and therefore eligible for a solvent delivery.
Jurgens presented a detailed overview (see Attachment X (PDF, 35 pp., 3.97 MB) for details) of the online registration process. In summary, he said that the registration form asks drycleaners to provide contact information for facility owners and real property owners, fill in retailer sales tax numbers and federal employer identification numbers, submit information on the type and age of drycleaning machines present, indicate how much solvent is used and who it is purchased from, specify how separator water is disposed of, indicate whether best management practices are being met, and pay a $100 registration fee. Jurgens also noted that the online registration form includes a "Helpful Hints" section, a verification page, and a search function. The latter feature can be used to search for drycleaners by name, city, or registration number. (Lists that are generated via the search function, however, may not be used for commercial purposes. Those who access lists must sign a statement indicated that they understand that this restriction is in place.)
Jurgens said that the online registration form has been operational since December 2003. Although a couple of glitches were encountered when the system first came online, much progress has been made in addressing these problems. The drycleaners have not taken full advantage of the site yet. In fact, only 12 of them have chosen to register online so far. Jurgens indicated that KDHE plans to promote the Web site more aggressively in 2005.
Changes to Wisconsin's Drycleaning Environmental Response Fund
Jeff Soellner, WDNR
Jeff Soellner opened with a brief description of Wisconsin's Dry Cleaner Environmental Remediation Fund (DERF), explaining that it is a reimbursement program established to help drycleaner owners/operators (as well as property owners with licensed drycleaners on site) pay site investigation and cleanup costs. Drycleaners/property owners are expected to hire their own environmental consultants, take the lead in investigation and remediation activities, and pay for the associated costs up front. They can recover their expenditures, however, by submitting reimbursement claims to WDNR.
Soellner said that many programmatic changes were approved for DERF this year (see Attachment Y (PDF, 12 pp., 135 KB) for details). While some of these changes have been written into the program's statute, others involve rule revisions. Soellner provided an overview of the changes, which fall into the following topical areas:
Deadlines for reimbursement forms. Drycleaners/property owners will now be given until August 30, 2008, to submit claim forms. Contamination must be discovered on the property before a form is submitted, and applicants must provide information explaining why they are eligible to participate in DERF.
General bidding requirements. To determine whether reimbursement claims are legitimate, WDNR insists on being involved in the bidding review and the work plan approval process. In the past, the Agency has been inundated with bids. To address this problem, the new rules state that drycleaners/property owners must obtain at least three bids but may not submit more than six. The rules clearly state that all bids are to be submitted directly to WDNR and the responsible party.
Third party issues. Third parties will now be able to obtain up to $15,000 reimbursement for site investigation costs. Reimbursement will only be warranted if contamination is actually discovered.
Interim site investigation reimbursements. In the past, responsible parties were required to complete site investigation activities before submitting a reimbursement claim for these costs. Under the new rules, a responsible party will be allowed to ask for one interim reimbursement if the cost of site investigation is expected to exceed $45,000.
Streamlining the site investigation report. WDNR used to require a Remedial Action Options Report (RAOR) as part of the site investigation report. It has become clear, however, that consultants who bid on remedial activities do not consider RAORs that are written by other site investigation consultants. Therefore, WDNR has decided to eliminate this requirement, a change that will reduce the costs associated with site investigation activities by about $5,000.
The remedial action bidding process. Any consultant bidding on remedial activities will be required to provide an evaluation of remedial alternatives. The consultant will also be expected to include technical and economic feasibility assessments, cost estimates for pilot testing if they are proposing an active remediation system, cost estimates for site-closure-related activities, and cost estimates for at least four ground-water sampling events. The company that wins the bid will be reimbursed for the cost of preparing the bid.
Identifying additional ineligible costs. The new rules make it clear that reimbursement will not be offered for the cost of obtaining site access permits or for costs associated with document delivery.
Membrane Interface Probe at A Site in Florida
Jennifer Farrell, FDEP
Jennifer Farrell focused her discussion on membrane interface probes (MIPs) and talked about assessment and remedial activities that have been performed at one drycleaning facility in Florida. She opened by saying that a MIPwhich consists of a thin polymer membrane (heated to 100 to 120 degrees Celsius) that is mounted to a stainless steel probeis an effective site characterization tool. As a MIP is advanced into the subsurface, vapor-phase contaminants diffuse across the membrane and are carried to a series of three detectors, including a flame ionization detector, a photoionization detector, and a dry electron capture detector. MIPs used in the field generate continuous logs of chemical profiles, conductivity measurements, temperature readings, and the speed of its own advancement. These data are used to construct a vertical profiling map; they provide information on contaminant location, approximate contaminant concentrations, and general site lithology.
Farrell spent the remainder of her presentation talking about a drycleaning facility that operated between 1950 and 1990. PCE and petroleum-based machines were both used at the facility. She said that ground water is shallow at this siteencountered within 5 feet bgs. In 1997, a site assessment was performed and PCE was detected at concentrations of 33 ppb in the soil and 67,000 ppb in the ground water. Investigators were puzzled by the low soil concentrations, so they decided to take some additional soil samples in 2001. These revealed PCE at concentrations of about 250 ppm in the soil. More recently, Farrell said, investigators returned with MIPs to further delineate the site and to determine whether DNAPL is present. She noted that KB Labs was called upon to perform the MIP analysis and that they completed their onsite activities over the course of two 10-hour days. Although the effort cost about $11,000, Farrell said, it yielded valuable information. For example, investigators learned that DNAPL concentrations persist at shallower and deeper depths than originally predicted.
Farrell also provided some information about remedial activities that have been deployed at the drycleaning facility. In April 2004, about 250 cubic yards of contaminated soil were removed from underneath the building, an effort that cost about $280,000. During the removal process, horizontal and vertical vapor extraction wells were installed inside the building. Samples collected from the base of the excavation indicate that PCE is still present at concentrations ranging from 64 to 75 ppm. According to some monitoring well data, PCE in ground water is present at 2,050 ppm. Although Farrell is not sure what remedial approach will be chosen to address the site's ground water, she suspects that it will center around a containment strategy.
Farrell concluded by providing the following advice to anyone considering using MIPs: (1) ask to get copies of the electronic data on CD, (2) be on site or at least maintain close contact with the contractors who are performing the MIP assessment, (3) make sure that you have hired a contractor who has experience using this equipment, (4) know what a "DNAPL" log looks like in advance, and (5) stay on the lookout for problematic logs and make the necessary adjustments to fix them.
TennesseeA Different Approach to Oversight
Steve Goins, TDEC
Goins opened by providing background information about Tennessee's Drycleaner Environmental Response Program (DCERP), a program that was established in 1995 to help drycleaners deal with environmental contamination. Goins provided detailed information (see Attachment Z (PDF, 15 pp., 265 KB)) about who is eligible to participate in the program and what fees and deductibles they must pay in order to receive the fund's benefits. In summary, a contaminated drycleaner who wants to tap into the fund must apply for entry into DCERP, perform a facility inspection, undergo a prioritization investigation, perform a solvent impact assessment, perform a remedial alternatives study and rank remediation priorities, implement a remedial strategy, and obtain a completion letter from TDEC. Goins described this series of steps as Track 1 of the DCERP program. Those who pass through it receive funds for investigation and remediation activities, liability protection, state oversight, and a completion letter. To give audience members an idea of the financial benefits that a Track 1 drycleaner could receive, Goins said that the drycleaner would probably only be expected to pay about $5,000 if the total bill for site investigation/cleanup came to $250,000. DCERP would pick up the remaining $245,000.
Tennessee's drycleaner cleanup program is facing some financial constraints. To put the problem in perspective, Goins explained that 50 drycleaning facilities are currently participating in the program and that 5 to 10 new sites enter the program each year. To date, TDEC has spent an average of $79,000 to close out what Goins called the "easy sites": drycleaning facilities with low levels of contamination and no complicated ground-water contamination issues. TDEC suspects, however, that the costs incurred per site could climb up to $400,000 to address more complicated sites. With costs so high and fund revenue hovering around $1.25 million, Goins said, TDEC's ability to address the backlog of drycleaning facilities in a timely fashion will be greatly hampered. In an effort to address this problem, TDEC is exploring the possibility of creating a separate trackone that does not drain resources from the fundthat drycleaners can pass through to address their sites. This track, which Goins called Track 2, could be used by drycleaners who are not concerned about receiving reimbursement for assessment and remediation activities. Individuals who might be interested in this track would include those who wish to speed up assessment and cleanup activities so that time-critical property transactions can proceed. Because the Track 2 projects would receive TDEC oversight, drycleaners participating in them could rest assured that the assessment and cleanup activities being performed at their sites were up to DCERP standards. Liability protection, however, would not be provided to Track 2 drycleaners. Goins said that TDEC is still defining the criteria for the Track 2 pathway and making decisions about how different types of applicants would move through the program. For example, as noted in detail in Attachment Z (PDF, 15 pp., 265 KB), different requirements would have to be followed depending on whether the facility is active or inactive or whether it is up to date or behind with applicable program-related fees. If the Track 2 proposal is turned down by the DCERP Board, Goins said, some consideration might be given to modifying the Brownfields program so that it will embrace drycleaning facilities.
Goins listed some other projects DCERP is pursuing: (1) developing a plan for matching program costs with program revenue, (2) developing a risk assessment model that is specific to drycleaning solvents, (3) obtaining a better understanding of the universe of eligible sites, (4) updating TDEC's Web site to provide answers to frequently asked questions, (5) streamlining the drycleaner certification program, and (6) continuing efforts to publish the Drycleaner Compliance Calendar.
Goins concluded by noting that TDEC recently had to issue a waiver to its own rules. TDEC encourages any drycleaner that is relocating across town to ask its solvent supplier to drain PCE from its old machines and deliver it to the new location. Some solvent suppliers alerted TDEC that there is a problem with this plan: suppliers have no way to get the PCE removed from old machines into closed-loop containers. As a result, they cannot deliver the PCE to new machines in closed-loop containers, as the state requires. A waiver has been issued to address this problem.
The Kings Highway Retail Center
Ken Koon, MDNR
Koon provided information (see Attachment AA (PDF, 16 pp., 468 KB)) about efforts to address a drycleaning facility at the Kings Highway Retail Center. The facility, which was used for laundering purposes between 1920 and 1972, used some PCE and petroleum solvents to assist with cleaning operations. Assessment activities have been initiated at the site. The results indicate that naphtha is present in the soils at depths between 3 and 10 feet bgs and that PCE is present in the soil and ground water at concentrations of about 7 ppm and 27 ppb, respectively. In addition, residual TCE concentrations have been detected in soil and ground water. It is unclear where the source area is, but the back door, storage area, and sewer lines have all been identified as possible culprits. Ground water is encountered at about 30 feet bgs and some public water supply wells are located near the site. Other drycleaning facilities are also located nearby.
The Bank of America owns the facility and is eager to sell it. At one point, the Bank enrolled the site in the state's Brownfields/Voluntary Cleanup Program and started developing remedial plans. The proposed remedial plan included soil removal activities to address the naphtha contamination, HRC injections to promote bioremedial activities, and institutional controls and long-term monitoring to address residual ground-water contamination. Activities stalled under the Brownfields program, however, in part because Bank of America did not want to open up a legal battle over who was responsible for ground-water contamination in the area. The site entered Missouri's DERT program in August 2004, a shift that Bank of America is pleased about.
Missouri is now moving from its current cleanup guidance document to a risk-based corrective action approach, Koon said, and this change will impact the way that the Kings Highway Retail Center is addressed. For example, under the existing system, the site would only be considered acceptable for commercial use. Under the risk-based approach, however, commercial and industrial uses will be considered. Also, once the new system is in place, Missouri will be in a better position to address ground-water contamination issues that involve multiple parties.
Koon said that MDNR plans to perform additional assessment activities at the site to ensure that all of the contamination has been identified. The main goals of the assessment will be to analyze the impact PCE has had on the ground water and to resample soils in the source area using analytical methods specified under the state's new approach. In addition, efforts will be made to learn more about site lithology and to determine whether there is a confining layer in shallow areas. (To date, the only known confining layer is located 200 feet bgs.) Once the site is better characterized, Koon said, MDNR will be in a better position to identify a remedial action plan that will drive the site toward closure.
Two Sites, Two Weeks, Too GoodAssessment Made Quick and Easy!
Lisa Appel, South Carolina DHEC
Lisa Appel provided information (see Attachment BB (PDF, 17 pp., 1.74 MB)) about assessment activities performed at two drycleaning facilities in South Carolina. In both cases, she said, Color-Tec was used to quickly delineate the extent of contaminated ground water. The two sites that Appel discussed were:
Joye One Hour Cleaners. This site has been active since the 1970s, and its operators use PCE as a drycleaning solvent. The site, which has contaminated ground water, ranked 12th in priority out of the 303 drycleaning facilities that are being addressed through South Carolina's drycleaner cleanup fund program. This site received such a high rank because it is located near four public water supply wells. Assessment activities were initiated at Joye One Hour Cleaners in June 2001. Using the Color-Tec screening methodology, DHEC and its contractor delineated a 17.9-acre contaminated ground-water plume in 8 days. Appel reminded attendees that Color-Tec provides information about the extent of contamination, but does not indicate exactly which chemicals are present. To obtain that level of detail, the site team installed a monitoring well network and collected ground-water samples. The results indicated that PCE is present at concentrations as high as 31,600 ppb. In addition, PCE was detected in ground-water samples collected from a nearby Texaco station at concentrations of 62,900 ppb. Appel said that the Texaco detection surprised DHEC, because the gas station is not downgradient of Joye One Hour Cleaners. Upon further investigation, DHEC determined that the PCE was probably carried to the Texaco location via sewer lines.
The DCUSAHighway 17 Bypass Site. This facility, which used PCE as a drycleaning solvent, began operating in 1986. Four public drinking water wells are located within 1 mile of the site and 43 private irrigation wells (7 of which are contaminated with PCE) are also located nearby. Assessment activities were initiated in 2002; the Color-Tec method delineated a 79.7-acre ground-water plume in 10 days. Followup monitoring activities showed that the ground water is contaminated with PCE (12,000 ppb), TCE (6,900 ppb), and cis-DCE (3,100 ppb).
Appel fielded questions and comments from the audience members. Trippler said that he was not surprised to hear that PCE had been detected at the Texaco station located near Joye One Hour Cleaners. In the past, he said, some gas stations used tank bottoms from drycleaning machines to clean automobile engine parts. Another attendee asked whether alternate water supplies had been provided to the people who owned the private wells near the DCUSAHighway 17 Bypass site. Appel turned the question over to Dukes, who reminded attendees that the wells in question were used for irrigation rather than drinking water. Dukes went on to say that DHEC asked the state's Risk Advisement Group whether it is necessary to shut down the irrigation wells and provide an alternate water source. The Risk Advisement Group concluded that it was not: the wells are not being used for long-term consumption, and the PCE in the ground water is likely to volatilize as soon as the water reaches daylight.
Biostimulation Using Ethyl Lactate at the Former 60 Minutes Cleaners
William Linn, FDEP
Linn provided information (see Attachment CC (PDF, 29 pp., 2.68 MB) for details) about a contaminated drycleaning facility in Fort Myers, Florida. He said that PCE was used at this facility between 1968 and 1999, at which time the drycleaner shut down and moved to a new location. The owner was cited for noncompliance on more than one occasion. One such event, in the early 1990s, resulted in some assessment activities. Subsequent site investigations indicate that PCE and its daughter products are present in soil and ground water, a finding that has raised concern since several public water supply wells are located nearby. The results also indicated that the contaminant source area is near the back door and in the vicinity of the former PCE machine location.
Linn discussed the site's lithology and the data collected on a variety of ground-water field and natural attenuation parameters. (Attachment CC (PDF, 29 pp., 2.68 MB) provides details on this as well.) In summary, there is a shallow and a deep surficial aquifer, ground water is first encountered at depths less than 5 feet bgs, anaerobic conditions are present, and evidence suggests that natural attenuation processes are active.
Linn said that several remedial technologies have been deployed at the site, including:
SVE and air sparging. Three 20-foot horizontal recovery wells and two 170-pound GAC units were installed at the site. They recovered about 20 pounds of VOCs. Air sparging has been performed in an effort to drive down vinyl chloride concentrations.
Ethyl lactate injections. Ethyl lactate, a material that hydrolizes to lactic acid and ethanol, has been injected into shallow and deep zones to promote bioremediation. (Detailed information about the circulation system that was used is included in Attachment CC (PDF, 29 pp., 2.68 MB).) A total of 6,517,000 gallons of 1% to 2% solution of ethyl lactate were injected into the subsurface between March 2003 and June 2004. Linn provided data (again, see Attachment CC (PDF, 29 pp., 2.68 MB) for details) showing the injections' impact on contaminant concentrations. The remedial strategy appears to be working.
Linn said that $618,000 has been spent to address the site thus far. This reflects the amount spent to support site assessment ($209,000), design ($32,000), construction and startup costs ($234,000), and operation and maintenance ($142,000).
Linn thanked the attendees and the speakers for participating in the meeting. He also thanked those who had helped plan the meeting.
Attachments A Through CC
Attachments A through CC 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 September 2004 meeting summary.
|Attachment A:||Final attendee list|
|Attachment B:||Preparing and Submitting Drycleaning Site Profiles (PDF, 3 pp., 43 KB)|
|Attachments CP:||State Update Handouts|
Attachment C: Alabama (PDF, 1 p., 32 KB)
Attachment D: Florida (PDF, 1 p., 26 KB)
Attachment E: Georgia (PDF, 1 p., 17 KB)
Attachment F: Illinois (PDF, 1 p., 43 KB)
Attachment G: Kansas (PDF, 1 p., 71 KB)
Attachment H: Minnesota (PDF, 1 p., 65 KB)
Attachment I: Missouri (PDF, 2 pp., 42 KB)
Attachment J: New York (PDF, 1 p., 30 KB)
Attachment K: North Carolina (PDF, 2 pp., 76 KB)
Attachment L: Oregon (PDF, 2 pp., 70 KB)
Attachment M: South Carolina (PDF, 2 pp., 126 KB)
Attachment N: Tennessee (PDF, 1 pp., 66 KB)
Attachment O: Texas (PDF, 1 pp., 613 KB)
Attachment P: Wisconsin (PDF, 2 pp., 71 KB)
|Attachment Q:||Bentley's Garment Care Ground-Water Remediation System (PDF, 46 pp., 2.5 MB) (Jim Schneider)|
|Attachment R:||Ex Situ Treatment and CAMU Implications at the Springvilla Site (PDF, 22 pp., 482 KB) (David Anderson)|
|Attachment S:||Use of ArcGIS Software to Depict Site and Regional Contamination (PDF, 32 pp., 2.79 MB) (Joseph Dom)|
|Attachment T:||In Situ Bioremediation at the Ridgeway Logging Site and the Blacks Cleaners Site Using Emulsified Oil Injection (PDF, 27 pp., 1.73 MB) (Bruce Gilles)|
|Attachment U:||Cinderella Cleaners: Bench-Scale Microcosm Studies and In Situ Tracer Testing (PDF, 25 pp., 1.22 MB) (Dan Nicoski and Larry Davis)|
|Attachment V:||What About the Other Drycleaning Solvent? (PDF, 68 pp., 4.27 MB) (Craig Dukes)|
|Attachment W:||Connecticut's Property Transfer Act and Drycleaning Remediation Fund (PDF, 71 pp., 1.66 MB) (Ray Frigon)|
|Attachment X:||Kansas Drycleaner ProgramOnline Drycleaning Registration Web Site (PDF, 35 pp., 3.97 MB) (Bob Jurgens)|
|Attachment Y:||Changes to Wisconsin's Drycleaning Environmental Response Fund (PDF, 12 pp., 135 KB) (Jeff Soellner)|
|Attachment Z:||TennesseeA Different Approach to Oversight (PDF, 16 pp., 265 KB) (Steve Goins)|
|Attachment AA:||The Kings Highway Retail Center (PDF, 16 pp., 468 KB) (Ken Koon)|
|Attachment BB:||Two Sites, Two Weeks, Too GoodAssessment Made Quick and Easy! (PDF, 17 pp., 1.74 MB) (Lisa Appel)|
|Attachment CC:||Biostimulation Using Ethyl Lactate at the Former 60 Minutes Cleaners (PDF, 29 pp., 2.68 MB) (William Linn)|