Conference Call Minutes from July 8, 1998

CLU-IN: State Dry Cleaners Remediation Project Conference Call: July 8, 1998

State Dry Cleaners Remediation Project
Conference Call

July 8, 1998

State Representatives

John Kelley; Illinois
Leo Henning, Bob Jurgens; Kansas
Dale Trippler; Minnesota
Jack Butler; North Carolina
Dick Dezeeuw; Oregon
Steve Goins; Tennessee
Tim Steele; Arizona
Robin Schmidt; Wisconsin
Bill Burns; Florida
Craig Dukes; South Carolina

Introduction

Rich Steimle (U.S. EPA, Technology Innovation Office) began the call by introducing both himself and Kathy Yager (TIO) to the participants. He acknowledged that many of the participants already met at a previous Association of State and Territorial Solid Waste Management Officials (ASTSWMO) meeting and had taken the initiative to begin informal discussions. Walter Kovalick, Jr. (TIO) presented the main goal of these more structured discussions as the creation of a formal relationship to discover, promulgate, and document cost and performance data on innovative technologies for the remediation of contaminated dry cleaning facilities. Kovalick noted that Regional EPA staff have been notified of this conference call, and had expressed interest is being informed of any undertaken activities.

Yager further elaborated on the possibility of creating a more formal relationship between TIO and the state representatives. She emphasized that any developing relationship should be based on the needs and interests of the states. Yager outlined suggestions for future directions given to her by state representatives during previous discussions. These included: regular e-mail correspondence, monthly conference calls, the election of a chair or co-chairs and establishment of a formal group and creating a web site. Ideas which state representatives were interested is discussing included: natural attenuation, presumptive remedies, risk-based cleanups, brownfields, and the involvement of trade associations. A researcher from the University of Florida also offered to establish an advisory panel on the remediation of dry cleaning facilities.

John Kelley (Illinois) suggested that a web site could be created within TIO’s Hazardous Waste Clean- Up Information (CLU-IN) web site. This site would not necessarily need to create additional content, but might consolidate other resources available online. Kelley offered his four-page list of dry cleaning web sites as a starting point for such an effort. Kovalick replied that if a web site is constructed, it could consist of both public and private areas protected by passwords.

Dale Trippler (Minnesota) questioned other participants on the status of any national efforts to create a comprehensive dry cleaning bill. Kovalick responded that he was unaware of any efforts underway in Congress. Dick Dezeeuw (Oregon) added that the initial efforts to remediate dry cleaning facilities were at the national level, and that state efforts became significant only when national efforts failed.

Florida’s Experience

Bill Burns, Florida Department of Environmental Protection

Burns began by noting that Florida has one of the larger state programs to remediate contaminated dry cleaning sites. Florida has completed evaluation of 1,300 facilities known to be contaminated. Assessments have been conducted at 82 of these sites, and an additional 21 assessments are expected to enter the program this week. Of the initial 82 sites, remedies have been selected for 78 sites.

Florida is using several innovative technologies to remediate dry cleaning sites. Bioaugmentation is being used at a site with initial contaminant levels of 300 ppb PCE. Permanganate flushing and zero- valent iron (Fe0) are being used at other sites. One innovative remedy that is currently drawing considerable attention within the state is an ethanol flooding project that is being conducted with the EPA at a site in Jacksonville. When the project begins, 9,000 gallons of ethanol will be cycled through contaminated ground water to flush out a DNAPL plume. During the extraction phase of this cycle, PCE will be separated from the ethanol. A test period of 1.5 - two weeks is currently being planned, followed by three to four weeks of monitoring. The primary goal of the project is source control. The total cost of the project, $360,000, will be split evenly between Florida’s Department of Environmental Protection and EPA.

Burns told the participants that statutory authority allows the Department of Environmental Protection to incur the risks involved in implementing innovative remedies. Legislative emphasis is on rapid, inexpensive remediation of these sites. One example of this emphasis is the goal of beginning site construction within one year after the beginning of assessment.

The State of Florida estimates that it will cost $1.8B (1990 dollars) to remediate all contaminated facilities in the state. However, the State is currently receiving only $8M per year from the dry cleaning industry through two taxes. The first is a 2% tax on gross receipts for all dry cleaners. The second is a $5 per gallon tax on PCE. This tax has not only generated revenue for the state (an estimated $2M for 1998), but has led to a 50% decrease in PCE usage over the last few years, with almost all dry cleaning equipment expected to be fourth or fifth generation by 1999. Finally, Burns estimated that Florida would have 2,000 known contaminated facilities by the end of 1998.

Florida has partnered with two universities in the development and use of innovative remediation technologies. However, they often fail to provide the rapid turnaround that the state requires. One area of emphasis for the state right now, is achieving uniformity in remedy selection. Presumptive remedies will not function adequately in Florida because of the varying geology (predominantly limestone with solution cavities, and thick surficial deposits of gravel and sand in northern areas) and depth to ground water (ranges from zero to 200 ft below ground surface). Burns concluded by offering presumptive remedies as a potential topic for discussion by the group.

Burns was asked how much an average site investigation cost and whether most of the investigated sites had ground water contamination. Burns replied that approximately 90% of Florida’s sites have both contaminated soil (in excess of leachability) and ground water, and that the average cost of a site investigation is $90,000 (range from $40,000 to $240,000).

Burns was questioned on the role of site owners in remedy selection. Burns replied that up to this point, the state has been making remedy selections without owner input. However, some owners are beginning to argue for a greater role in remedy selection because they are effected by that remedy. One area of possible future contention originates in the requirement that if natural attenuation is selected as a remedy, PCE concentrations must be below MCL’s for off-site contamination within five years. This projection can be challenged by affected parties. Burns was further asked if off-site property owners can apply for cleanup. Burns answered that only source owners can apply, but as these applications are accepted, associated off-site contamination will also be remediated.

The subject of modeling in Florida was raised. Burns explained that past experience with modeling in Florida has not yielded accurate results. Due to this inaccuracy, the state has largely abandoned modeling in predicting whether off-site contamination will fall below MCL’s in five years (and therefore selecting natural attenuation as a remedy). To construct this projection, the state performs a simple extrapolation with available data reinforced with the presence of actual degradation products to determine if a site qualifies for natural attenuation.

Burns was asked how PCE was tracked in larger cavities within the karst geography that characterizes much of the state. Burns admitted that dilution can be a large factor, and that once it reaches larger cavities, it sometimes cannot always be traced.

Kansas’ Experience

Bob Jurgens, Leo Henning, Kansas Department of Health and Environment

Jurgens described a multi-site pilot program in Hutchinson, Kansas. Three different dry cleaning sites were treated using three different methods. Subsurface deposits for the sites are uniform, consisting of clay and silty clay to a depth of approximately seven ft. This clay and silty clay grades to very fine- grained to coarse-grained sand with gravel at the base of the unconfined aquifer. Ground water is fourteen to sixteen ft below ground surface.

Factors used to evaluate the three technologies were: overall cost, effectiveness in contaminant removal, ease of use and applicability to a wide range of locations. The first technology used was a combination of air sparging and soil vapor extraction. For the 90-day test period, 66% removal was realized. The second technology used was a combination of ozone and air injection (C-SpargeTM). This test was conducted both with and without the use of ozone. Without ozone, the C-SpargeTM system achieved 71% removal. With ozone, 91% removal was realized. In-well stripping was used at the third site (NoVOCsTM), and achieved 87% removal.

Overall, the C-SpargeTM system provided the highest performance. The No-VOCsTM also was judged to have performed well, but at a significantly higher cost than the other two systems. Presently, the state is planning to install the C-SpargeTM system at two sites in Hutchinson, KS.

Jurgens was asked if an increase in degradation products was seen at any of the three pilot sites. Jurgens responded that the in-well stripping process removed contaminants for treatment, and the ozone mixture used with C-SpargeTM system turned PCE into harmless products.

One participant was concerned that the performance of the NoVOCsTM system may not have performed as well because of its requirement that the treated matrix material by very homogeneous. Jurgens replied that extensive sampling was performed at the NoVOCsTM site to ensure the presence of a homogeneous substrate. However, this testing is part of the additional cost involved in using the NoVOCsTM system.

Jurgens was questioned on the use of bioremediation at any sites in Kansas. He replied that the state does have a developing joint pilot project with EPA using hydrogen injection that will hopefully begin this summer.

Group Discussion

Both Florida and Kansas were asked if any program information or reports are posted on their respective web sites. Florida replied that they are developing an integrated GIS web site that will eventually provide information on particular sites. This effort is far from complete, and Burns said he is willing to supply electronic or hard copies of information to anybody who desires it in the interim. Kansas stated that there isn’t any information up on their web site currently, but they are also happy to provide information to anybody who would like it.

The interaction between the states and contractors was discussed by both Florida and Kansas. Kansas stated that there is a genuine interaction between state officials and contractors, as opposed to one side solely educating the other. Florida added that a similar situation exists in that state. Kovalick added that when liability is an issue in cleanup decisions (ex. Superfund), contractors may be leery of using methods that are not completely proven to be as effective as more conventional methods. Burns noted that because the law in Florida places an emphasis on completing remediation faster and cheaper while allowing for mistakes, contractors have the ability to take risks in attempting to use innovative technologies. Kansas added that state employees create the basic design for site remediation, then elaborated upon by the contractor. In addition, state officials are ultimately responsible for the success or failure of the cleanup, not the contractors. Florida’s Project Managers have the same responsibility. Kansas has found that Project Managers are motivated to participate in dry cleaning site cleanups because of their lack of administrative requirements.

Florida was asked how it identified contaminated dry cleaning sites. Burns replied that the state questioned dry cleaning solvent suppliers to obtain lists of customers. From these lists, the state was able to determine the set of all solvent-on-premises dry cleaners. After this list was created, the legislature required that all dry cleaners register with the state. This provided information on dry-drop dry cleaners, facilities where no actual cleaning is performed on-site. Information on site contamination is contained in the applications the State receives from facilities that want to join the remediation program. As part of the application, an initial site screening that provides data on the type and level of contamination present at a site must be performed.

Next Steps

Group membership was discussed. Kelley stated that the State of Illinois is planning to create a governing council for the dry cleaner cleanup program, and that he would like somebody from that board to be able to participate in the group. Kovalick agreed that such participation would be valuable. Robin Schmidt (Wisconsin) added that a similar situation exists in Wisconsin, but that a group representing responsible parties will run the program through existing cleanup programs. One participant argued that some of the trade associations have consultants that lobby for certain technologies, and therefore the group should limit itself to state officials and academics in order to remain unbiased. There was agreement by another participant agreed on this issue.

Yager revisited the possibility of a web site for the group. Kelly reiterated that he had a four-page list of sites related to dry cleaning, and that maybe all the group needed was a site composed of relevant links. Dick Dezeeuw (Oregon) agreed that a web site serving as a document clearinghouse would be a good place to start. Dezeeuw stated that they are receiving a lot of pressure from cleaners to research the issues related to remediation but do not have a lot of resources to do so. Kovalick stated that TIO will write one-paragraph summaries on each of Kelly’s web sites for everyone to review during the next conference call.

Kovalick asked participants if they felt another conference call before Labor Day would be valuable. The participants agreed. Schmidt suggested additional state presentations as a possible agenda item. Both Wisconsin and Oregon volunteered to give presentations during the next call.