Phase 1 Environmental Site Assessments, A Checked Box for Lenders or a Valuable Tool for Buyers?

PHASE 1 ENVIRONMENTAL SITE ASSESSMENTS (PHASE I ESAS) ARE MORE THAN A COMMODITY. LEARN THE TRUE VALUE OF A PHASE I.

BY: STEVE HENSHAW, PG, & CASEY MCFALL, CHMM  

Buyers and sellers of property are familiar with the need to have Phase I Environmental Site Assessments (Phase I ESAs) prepared when there is a transaction or a refinancing of a property.  To most stakeholders, including the buyer, seller, and lender, the Phase I ESA is part of the due diligence checklist, simply a report like a home inspection report, to identify potential environmental concerns with a property.

In the environmental consulting industry, Phase Is are considered “loss leaders,” meaning there is little to no profit to be made conducting the Phase I.  Either the consulting company believes they must offer the service because their competitors offer it, or they believe that a certain percentage of Phase Is will require follow up environmental work because of the likelihood of contamination turned up during the investigation. Because the profit margin on a Phase I is at best slim, it is not uncommon for consultants to use lower paid and generally less experienced staff to conduct much of the Phase I. One side note, there is no project that carries with it more risk for the consulting firm than a Phase I, because if contamination is not identified during the Phase I, but is found later in time, the consultant and its liability provider could be on the hook for damages.

For the lending officer, their goal is to get the loan approved by the internal lending committee so they can get the sales commission. There is stiff competition between banks, and the cost of a Phase I can make a difference in a sale or not.

These dynamics set the stage for the Phase I becoming a commodity in the marketplace, and little thought is given to the value of the Phase I and, conversely, to the risk of having a Phase I completed that does not adhere to ASTM Standard E1527.

So, what is the true value of a Phase I ESA? What is often misunderstood or unknown to Buyers and Lenders is the actual liability protection afforded to potential purchasers by correctly completing a Phase I ESA. This liability protection is known as achieving bona fide prospective purchaser (BFPP) status through the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA). People acquiring property, even with known contamination, can obtain BFPP protection if “all-appropriate inquiry” (i.e., completing a Phase I ESA) is completed prior to purchasing the property. The purchaser also must meet continuing obligations regarding any known or suspected contamination, including taking reasonable steps to stop any continuing release, preventing a future release of hazardous substances, ensuring property occupants are not being exposed to contamination, and there is not a threat of exposure to off-property persons. Obtaining BFPP protection can prove financially invaluable to the property owner or tenant, potentially saving hundreds of thousands or even millions in cleanup cost responsibility. Property owners without BFPP protection that did not contribute to or cause contamination at a property can still be held liable for cleanup costs by state and/or federal environmental regulators.

The Phase I ESA is a complex document that must be completed in its entirety to afford the prospective purchaser BFPP. Minor details that are often missed in Phase Is can result in a court rejecting a BFPP claim for a property owner. These minor details include but are not limited to not listing the exact purchasing entity as having reliance on the report, the prospective purchaser not completing the required questionnaire, and having an expired Phase I at the time of closing. This last point is especially important as we hear many parties state that they don’t need a Phase I ESA, as there was one previously completed for the property. The truth is that environmental standards change, and what may have been acceptable several years ago may constitute an environmental concern under today’s environmental regulations. Unless the exact prospective purchasing entity is listed as having reliance in the Phase I ESA and the report is under 180 days old, the Phase I is likely not valid for BFPP purposes. Additionally, it should be noted that the 180-day window for Phase I ESAs is from the date the first record is reviewed by the report preparer, not the date the report was issued. 

Baseball great Leo Durocher once said that baseball is a game that many attend, but few understand. This can absolutely be applied to the world of environmental due diligence and Phase I ESAs. There are many environmental companies who claim to complete Phase I ESAs, but their product often will not afford the purchaser BFPP, even if it was completed prior to the property purchase. It’s the nuances that make the difference in the world of environmental due diligence. If you have questions or a need for environmental due diligence of Phase I ESA services, EnviroForensics would be happy to discuss your situation and, if appropriate, prepare a complete Phase I ESA that will provide liability protection and peace of mind for you and your business. 

Disclaimer: Some states do not accept BFPP status as absolute liability protection.  We are not lawyers and cannot give legal advice; as such, all Buyers should consult with qualified legal counsel when buying property.    

Contact us with your questions about real estate due diligence.

As seen in Cleaner & Launderer


Steve Henshaw, PG, CEO

With 30+ years of experience, Stephen Henshaw holds professional registrations in numerous states. As Officer of EnviroForensics, Henshaw serves as a client manager and technical manager on complex projects involving contaminated and derelict properties, creative litigation, deceased land owners, tax liens, non-performing bank notes, resurrecting defunct companies, and cost recovery. Henshaw’s expertise includes a comprehensive understanding of past and current industry and waste handling practices and the fate and transport of chlorinated solvents in soil and groundwater. He has served as a testifying expert for plaintiffs and defendants on high-profile cases involving causation and timing of releases, contaminant dispersion, allocation, damages, past costs, and closure estimates. He has a strong knowledge of state and federal regulations, insurance law, RCRA, and CERCLA. He has managed several hundred projects, including landfills, solvent and petroleum refineries, foundries, metal plating shops, food processors, dry cleaners, wood treating facilities, chemical distribution facilities, aerospace manufacturing facilities, and transporters and provides strategy instrumental in funding projects and moving them to closure.

Casey McFall, CHMM, Director of Real Estate Due Diligence

Casey McFall is the Director of Commercial Real Estate Services and a Certified Hazardous Materials Manager with 15+ years of experience as an environmental consultant. He has managed numerous petroleum and chlorinated solvent projects throughout various stages of investigation, remediation, and closure. His professional experience includes all areas of project management, due diligence, reporting, and regulatory negotiation. He has experience managing projects in Alaska, California, Georgia, Indiana, Kentucky, Ohio, South Carolina, Wisconsin, and Washington. Casey also has experience acting as an environmental liaison for municipalities, offering expert advice regarding environmental issues and providing risk communication to stakeholders and the community by explaining complex environmental issues in a concise, understandable way.

EnviroForensics to Present Research Findings at Battelle Chlorinated Conference 2022

THREE ENVIROFORENSICS SCIENTISTS PRESENTING AT INTERNATIONAL CONFERENCE ON CHLORINATED SOLVENTS AND RECALCITRANT COMPOUNDS

Three EnviroForensics scientists will present the results of their current research projects at this year’s Battelle International Conference on Remediation of Chlorinated and Recalcitrant Compounds. The conference is considered the signature forum for the environmental remediation industry and will feature the largest technical program to date with over 1,300 platform and poster presentations on the schedule.

“Scientific innovation and excellence form the foundation of our environmental remediation service lines. A mainstay of scientific work is peer review, and Battelle’s 2022 Chlorinated Conference gives us the opportunity to share what we have learned and receive valuable feedback from the remediation community,” said EnviroForensics President, Jeff Carnahan. “We believe that our application of cutting-edge environmental investigation and remediation approaches keeps our clients at the top of the list of regulated closures each year, particularly at chlorinated solvent sites. We are excited to collaborate and learn at the Chlorinated Conference this year.”

This year’s presentations by R. Scott Powell (PE, LPG), Brian Kappen (LPG), and Michele Murday Pariso (Project Geologist), cover current remediation topics like the study of dilution to improve injection-based remedial treatment, targeted soil excavation with a passively dispersed reductive amendment in a source area over fractured bedrock, and the use of horizontal colloidal activated carbon permeable reactive barriers to control vertical mass loading into a sandstone aquifer. Read our summaries below.

WHEN DILUTION IS THE SOLUTION TO POLLUTION: HOW MOBILIZING DNAPL RESULTED IN A MORE SUCCESSFUL INJECTION-BASED REMEDIAL TREATMENT APPROACH
BY: MICHELE MURDAY PARISO AND COLLIN MARTIN (ASH UNION)
EnviroForensics designed and directed implementation of in-situ treatment of solvent contamination at a former drycleaning facility in Northwest Indiana. The remedial approach consisted of source area reagent injections and installation of a permeable reactive barrier (PRB). The Site logistics played an important role in this plan, as a down-gradient right-of-way provided a buffer zone between the site and off-site properties that allowed for the limited migration of the diluted source area DNAPL after the first injection event. Following a second injection event in 2021, groundwater monitoring data indicate a substantial reduction of the remaining source area mass, and no breakthrough of contamination has been detected beyond the down-gradient PRB. 

CAN LESS REMEDIATION BE MORE EFFECTIVE? COMBINING TARGETED SOIL EXCAVATION WITH PASSIVELY DISPERSED REDUCTIVE AMENDMENT IN A SOURCE AREA OVER FRACTURED BEDROCK
BY: R. SCOTT POWELL
Extensive remediation was needed at a site in Northeast Indiana with high concentrations of tetrachloroethene (PCE) source material located directly over fractured bedrock. This contaminant mass was leaching directly into unconsolidated and bedrock groundwater, resulting in an elevated dissolved phase plume that migrated offsite. A multi-faceted (and costly) remedial approach would be needed to reduce both the vadose zone source area contaminant mass and the dissolved phase contaminant mass within the bedrock fractures.  

Soil excavation was selected as a cost-effective remedial option to remove the source area vadose soils overlying the fractured bedrock, but excavation of deeper saturated soils and fractured bedrock was not a feasible or cost-effective option. Therefore, a soil reagent was applied to the bottom of the excavation by specialized methods prior to backfilling to promote 1) abiotic degradation within residual saturated soils and bedrock interface impacts, and 2) enhanced reductive dechlorination (ERD) in the natural groundwater environment for prolonged dissolved phase contaminant mass reduction. The effectiveness the remedial approach has been demonstrated through enhanced reducing conditions, PCE breakdown products, and abiotic markers in groundwater samples collected to date, with additional groundwater monitoring to continue during 2022.

USE OF A HORIZONTAL COLLOIDAL ACTIVATED CARBON PERMEABLE REACTIVE BARRIER TO CONTROL VERTICAL MASS LOADING INTO A SANDSTONE AQUIFER
BY: BRIAN KAPPEN AND KEITH GASKILL (REGENESIS)
A novel approach for reducing mass loading of chlorinated volatile organic compounds (CVOCs) to a sandstone aquifer was implemented at a site in Southern Wisconsin. Glacially-deposited material and a fractured dolomite unit overly a sandstone unit, creating a complex hydrogeological system. The CVOCs moved vertically through the unsaturated overburden into the dolomite, spreading through it and migrating into the sandstone. These conditions formed a 30,000 square feet area of contaminant mass loading, resulting in a mile-long CVOC plume in groundwater.

Direct treatment of contamination in the dolomite would not be effective due to the clay-filled fracture network. Rather, a horizontally-oriented colloidal activated carbon (CAC) permeable reactive barrier (PRB) was applied to remove contaminants from the dissolved phase and reduce the vertical migration of CVOCs into the sandstone. Nearly 100,000 gallons of CAC mixture were injected via a network of 21 specially designed and positioned injections points to form the horizontal PRB. Post-application monitoring has demonstrated reduced CVOC mass loading to the aquifer, and compound-specific isotope analysis (CSIA) of groundwater samples indicates that CVOC biodegradation will continue to occur in the absence of any further remedy. Based on these results, the overseeing agency has agreed that the site is ready for regulatory closure.

CHLORINATED 2022 CONFERENCE INFORMATION
These and over 1,000 other posters and presentations will be on display at the Twelfth International Conference on Remediation of Chlorinated and Recalcitrant Compounds in Palm Springs, California, which runs from May 22-26.

Learn more about our innovative environmental investigation and remediation capabilities.

___________________________________________________________________________

Michele Murday Pariso, Northwest Indiana Branch Manager
Michele Murday has more than nine years of experience in environmental consulting with a focus in investigation and remediation projects involving dry cleaners, lead, and petroleum impacts. Michele has been responsible for the management of numerous projects throughout various stages of investigation, remediation, and closure ranging from $1,000 to $5,000,000. Michele has directed numerous subsurface investigations of varying size and employed a variety of remedial technologies, including soil excavation, multi-phase extraction systems, vapor mitigation, soil mixing, and chemical injections. Michele’s experience includes data analysis and interpretation, reporting on all phases of projects from investigations through closure, preparing 3D site visualizations, proposal scoping, project management, due diligence research, and risk communication. She has also worked closely with clients, subcontractors, and municipalities, as well as state and federal regulators.

Scott Powell, PE, LPG, Senior Project Manager
R. Scott Powell has 20+ years of environmental consulting experience. Powell’s expertise covers a wide variety of projects ranging from due diligence, petroleum, hazardous material remediation, asbestos, lead-based paint, to remedial systems. He manages complex relationships and fosters cohesive involvement of PRPs on multiple sites with co-mingled contaminant plumes requiring the implementation of remedial solutions for chlorinated solvents, hazardous materials, and petroleum hydrocarbon impacts. Powell manages negotiations with state and federal regulatory agencies and provides litigation support in matters concerning environmental issues. Powell has been responsible for the overall management and administration of environmental projects ranging from $1,000 to $3,300,000.

Brian Kappen, PG, Senior Geologist, Project Manager
Brian Kappen has 15+ years of experience in environmental consulting with a focus on contaminated site management. His diversified professional experience includes research, proposal scoping and budgeting, preparation of work plans and reports, project management, geologic and hydrogeologic data collection, vapor intrusion assessments, data analysis and interpretation, remedial action evaluation, and implementation of remedial actions. Kappen has served in supporting and management roles on numerous investigation and remediation projects regulated by state, RCRA and CERCLA programs, primarily involving chlorinated solvent impacts. Kappen has also been involved with several Phase I and Phase II environmental site assessments and served as a field team leader for a comprehensive two-year environmental baseline study at a remote mine prospect in Michigan.

Are PFAS a Drycleaning Problem?

THERE IS AN EVOLVING QUESTION AS TO WHETHER PFAS IS A DRY CLEANING PROBLEM. A RECENT FLORIDA STUDY STARTED TO ANSWER THIS QUESTION. THIS ARTICLE WILL FOCUS ON WHAT PFAS ARE AND SUMMARIZE SOME OF THE FLORIDA STUDY RESULTS AND WHAT IT MIGHT SAY ABOUT DRY CLEANERS AS A SOURCE OF PFAS.   

BY: BRAD LEWIS & ROB HOVERMAN 

If you have not heard of Perfluorooctanoic Acid (PFOA), Perfluorooctyl Sulfonate (PFOS) and other perfluoroalkyl substances (PFAS) yet, you will soon. For brevity, we will refer to these groups generically as PFAS plural. PFAS are a broad group of chemicals widely used in manufacturing and found widespread in the environment. The 2019 movie Dark Waters starring Mark Ruffalo and Anne Hathaway featured one of the first and highest-profile lawsuits regarding PFAS. PFAS are emerging contaminants that the United States Environmental Protection Agency (USEPA) is attempting to regulate. Some states like Michigan, Wisconsin, Florida, and New Jersey have gotten out in front of the USEPA and have established state regulatory limits for a small number of the more commonly used compounds.  

WHAT ARE PFAS?
First, the “what”: PFAS are part of a broad chemical group first developed in the 1940s. Since then, manufacturers have introduced over 4,000 PFAS compounds into the production of consumer goods both as primary and secondary components. Some of these compounds are being phased out due to toxicity concerns; however, manufacturers are developing new fluorinated compounds like Gen X and ADONA to replace them. Many PFAS are banned from use and import in manufactured goods in the United States. 

Well known for their unique chemical properties, PFAS repel oil and water and resist temperature, chemicals, and fire. These are the attributes that make PFAS attractive and are why so many durable industrial and everyday products like non-stick surfaces, firefighting foam as a flame retardant, stain resistant fabrics, water repellent coatings, and plating demisters contain PFAS. 

The chemistry is complex because PFAS are not one chemical compound; they are a class of chemical compounds that share the common carbon-fluorine bond. The carbon to fluorine bond is one of the strongest bonds in organic chemistry, making PFAS compounds particularly resistant to degradation and therefore cleanup. Since they do not break down and they have widespread use, they are being found everywhere in the environment.   

SOURCES OF PFAS 
The USEPA advisories in the May 25, The USEPA first announced PFAS health advisories in the May 25, 2016 Federal Register. Since then, numerous updates and significant research has been published by USEPA, State Agencies, and private researchers. After which, State regulatory agencies began pushing primary and secondary industries into investigate for PFAS. To date, most of the investigations and cleanups have centered on both the manufacturers of PFAS compounds and military airports. The three general sources of PFAS impact on the environment include:    

  • Primary: Manufactures of PFAS Compounds  
  • Secondary: Manufactures of Items with PFAS or direct use of PFAS compounds  
  • Tertiary: Use/Disposal of PFAS containing products  

The manufacturers of the PFAS compounds generally include the large chemical manufacturers that have been the subject of much regulatory scrutiny and private litigation. The secondary group includes all the industrial and commercial processes that directly applied these chemicals to products or processed materials previously coated. Dry cleaners that offered the application of stain-resistant coatings containing PFAS fall within this second group but also fall within the third group.    

The third group is comprised of all consumer and commercial use and disposal of PFAS treated products. The potential for PFAS impacts to the environment from this third group is probably least understood. This third group is where dry cleaning may have its most significant exposure for PFAS impacts since dry cleaning byproducts (spent solvent, lint, still bottoms, etc.) have had contact with PFAS containing textiles.  

We know historically dry cleaners accidentally released solvents to the environment, but how much PFAS were in these spent solvents? Studies from Toronto University have shown fast fashion items contain high levels of PFAS and other contaminants at levels that cannot be coincidental. When these PFAS laden clothes are washed, PFAS can accumulate in the various waste streams and mechanical vents at dry cleaners. Additional studies show that cosmetics also contain high levels of PFAS. Clothing with cosmetics stains may also contribute to low level accumulation of PFAS in facilities that would concentrate wastes. That is to say, dry cleaners, through filtration processes, concentrate PFAS, which may then enter the environment incidentally near waste storage and vent discharge points at dry cleaning and laundry facilities.   

Learn more about testing for PFAS and the available remediation methods  

TESTING OF DRYCLEANING SAMPLES
The Florida PFAS study evaluated both virgin and spent dry cleaning products from seven (7) Florida dry cleaning facilities. Virgin cleaning products at two of the seven facilities contained detectable concentrations of PFAS. One facility had a small detection of PFAS in a dry-cleaning machine cleaner and the other facility had a more substantial detection in a virgin petroleum-based solvent mixed with soap. Some virgin dry cleaning products do contain PFAS. The take-away message for you is to ask your chemical supplier for details on what is in your incoming products.   

PFAS were detected in dry cleaning wastes (spent solvents, solids, filters) in six out of seven of the facilities tested. PFAS compounds on treated fabrics clearly come off the fabrics during the cleaning process and are concentrated in the resultant waste products. Although use of some of these compounds have been phased out years ago, you can probably expect to see this continue for a while.   

The Florida study went even further and evaluated PFAS in virgin and spent products from seven wet laundry facilities. One out of four laundry detergents contained PFAS at relatively low levels. However, PFAS were detected in every wastewater discharge sample analyzed.   PFAS clearly come from treated clothing even during a wet laundry process, although to a lesser extent than from dry cleaning. One interesting finding of the study that speaks to the ubiquitous nature of PFAS is that they were detected at low concentrations in the incoming potable water at most of these facilities.   

TESTING OF SOIL AND GROUNDWATER
In the Florida study, ten sites with known dry cleaning solvent contamination (chlorinated and petroleum based) were evaluated. Eight of these sites had undergone some level of remediation. Samples of soil and groundwater were collected and submitted for analytical testing for 28 PFAS and GenX compounds. PFAS compounds were detected in groundwater at all ten sites. While the presence of PFAS seemed to correlate to the presence of PCE there was little correlation between concentrations of PFAS and PCE. This is likely due to how these compounds behave in the environment.  

The study did identify four sites where it appears there was PFAS entering the site from an off-site source. Again, given PFAS widespread use and their propensity to not degrade, this is not entirely unexpected. However, even at these four sites, there was evidence of PFAS contribution due to the releases of dry cleaning products.   

Similar results were seen in soil samples collected and submitted for laboratory analysis.  Although all the soil sample detections were below levels deemed safe by Florida for direct exposure, they were above levels that have the potential to impact groundwater above safe levels.   

Dry cleaners inadvertently introduce PFAS compounds through the chemicals they use. Going forward it’s important that dry cleaners document the PFAS content of incoming chemicals from your suppliers and if possible avoid PFAS containing products. What is clear is that the dry cleaning process itself introduces PFAS into your waste streams by extracting them off of the stain-resistant garments. How big of a problem this will be for the dry cleaning industry is unknown as the science and regulatory framework surrounding PFAS is evolving.   

RESPONDING TO REGULATORY REQUESTS
Should someone ask you to sample for PFAS compounds at your site, what should your response be? First and foremost, your response should be a cautious one made with input from a qualified consultant and potentially legal counsel. It should be clear under what authority the demand is being made and what some of the ramifications might be should PFAS be found on your property. If the decision is made to proceed, you will want to consider:  

  1. What PFAS compounds am I being asked to sample for? 
  2. What analytical methods will be acceptable to the entity asking for these results? 
  3. To what criteria will the results be compared to? 
  4. Are there other sources of PFAS surrounding my property? 
  5. Will my consultant control the accidental introduction of PFAS into environmental samples?   
  6. What are the consequences of not responding?  
  7. Is any of this data confidential?   

THE CONSEQUENCES OF A RELEASE
Currently, it is difficult to say what will be required should you discover a release. One thing that is certain is that the cleanup of a PFAS release, to likely very low cleanup standards, will not be easy. The amount of research into PFAS cleanup being conducted at this time by commercial and private companies is staggering. Promising interim technologies are being developed by the not-for-profit Batelle research organization and others. It is likely that the best solution will present itself in a technology yet unknown to us at this time.  

Because of PFAS chemical structure, they are recalcitrant and do not lend themselves to many of the chemical and biological processes traditionally employed to remediate dry cleaning solvent plumes. Research is being conducted but as of now, there are few in place options for soil and groundwater remediation. The physical removal of the compounds from soil and groundwater is, for now, likely the best remediation option. Excavation of soil and the pumping and treating of groundwater are two ways of physically removing PFAS from the environment. Physical removal of these compounds creates waste products that need ultimate disposal. Heat destruction of these waste products offers promising results; however, the temperatures required are difficult to achieve and economically unsustainable. 

Find out why PFAS are so difficult to remediate, and why they’re known as “forever chemicals” 

CONCLUSIONS
The Florida study indicates that PFAS may well be an issue at drycleaner cleanup sites. Prior to implementing any sampling efforts that may put you in the liability hot seat, make sure you are thoroughly engaged with a consultant and legal counsel that can outline your options.   

The USEPA will within the next two years establish certain PFAS as a hazardous substance, which will make it easier for them to regulate. Without the hazardous substance designation from the EPA, investigations and remediation vary by State. PFAS sampling is more expensive than traditional environmental sampling and because the remedial options are limited and the regulatory framework is still up in the air, your long-term costs and liabilities are difficult to predict.  

Contact us with your questions about PFAS 


As seen in Cleaner & Launderer

Brad Lewis, CHMM, Principal Scientist
Brad Lewis is a detailed-oriented and collaborative environmental professional with over 24 years of environmental consulting experience. Brad has a Master’s Degree in Environmental Science and is a Certified Hazardous Material Manager (CHMM) with expertise that covers a variety of projects ranging from due diligence, environmental compliance, Brownfields, underground storage tank, and chlorinated hydrocarbon investigations and cleanups.  Because of his strong analytical chemistry background, Brad has implemented many innovative site investigation strategies including the use of mobile laboratory, and immuno-assay to characterize sites. Brad is a member of the Midwestern States Environmental Consultants (MSECA) organization and took part in MSECA’s work group advising the Indiana Department of Environmental Management (IDEM) on revisions to the Remediation Program Guide. 

Brad manages large chlorinated hydrocarbon sites with large, deep, groundwater plumes that impact overburden, bedrock, and surface water resources.  To these projects he brings a keen understanding of contaminant fate and transport and an ability to develop a thorough conceptual site model.  This includes development of 2-dimensional and 3-dimensional visualizations of site lithology, hydrogeology and plume characteristics. 

He provides strategic planning of the technical and regulatory approach on most EnviroForensic projects.  This includes evaluation of new and innovative remedial technologies and changing regulatory and business climates. Brad facilitates communications between the responsible party, project managers, counsel, regulators, and the affected residences.    

Rob Hoverman, LPG, Northern Midwest Regional Director 
Rob Hoverman is the Northern Midwest Regional Director and a registered professional geologist with more than 19 years of professional environmental services with a focus on contaminated site management. Rob currently serves as senior project manager for several projects in Indiana and Wisconsin.  His diversified professional experience includes research, scoping and budgeting, project management, data analysis and interpretation for both hazardous and non-hazardous substances, including compounds such as chlorinated solvents, petroleum-related constituents, as well as metals. Rob has managed numerous investigation and remediation projects regulated by state programs, and his responsibilities involved every aspect of projects from proposal preparation through project closure, regulatory negotiations and stakeholder communications.  Beyond technical evaluation and interpretation duties include obtaining contract approval, job initiation, budgetary analysis, budget tracking, and subcontractor contracting and management. Rob has also served as technical support for numerous vapor intrusion including soil gas, sub-slab, indoor air sampling and mitigation.  As the Regional Director for EnviroForensics, Rob maintains momentum and resources for Wisconsin projects. 

Everything a drycleaner needs to know about environmental contamination

A COMPREHENSIVE GUIDE TO OUR ENVIRONMENTAL RESOURCES FOR DRYCLEANERS AND PROFESSIONAL LAUNDERERS

BY: JEFF CARNAHAN

We’ve discussed a lot of topics pertaining to drycleaners over the years, and I hope that the information has been helpful. There has been the full gamut of information regarding the process of dealing with contamination related to drycleaning operations. The primary focus, of course, has been on how to manage liabilities and costs associated with a subsurface release of Perc. The focus has been here, largely due to the fact that Perc releases are the most complicated, the most expensive to remedy, and present the greatest amount of risk to owners and operators of drycleaning facilities and associated properties.

At the beginning, we talked about 5 Considerations when selecting an environmental consultant for dry cleaners. It is so important to find a scientifically and strategically sound technical representative to guide you through the process of evaluating the extent of your contamination problem, and to help you choose the right remediation approach. If you’re just getting started in the environmental closure process, or you want to revisit my advice on making sure you have the right help, you’ll find some ideas in this article.

I wrote about the subsurface investigation process in these articles:

Sometimes it can be confusing or frustrating that it takes a long time to get your arms around a sizeable soil or groundwater plume. The above articles should give you a better understanding as to why it’s so complicated.

We also discussed remediation technologies and regulatory closure strategies in these articles:

There is a lot of information in these articles related to risk-based closures and more active closures. You may recall that a risk-based closure is one where a primary mechanism for regulatory closure is a demonstration to the agency that there is no direct human exposure or harm being done as a result of the contamination’s existence. These approaches are fine to get closure, but they don’t actually cleanup your property to a significant degree. EnviroForensics has also done a substantial amount of data research and analysis that show once you factor in the cost of long-term monitoring to ensure that exposure control methods remain viable, active cleanup approaches that remove contamination from the property are actually cheaper than risk-based approaches.

We explored the wide range of legal risk that the owner and/or operator of a former Perc shop may have to contend with as a result of an environmental release from your plant or someone else’s in these articles:

When the stigma of environmental contamination at a drycleaner site gets out in front of actual investigation and cleanup, operators and owners are subject to a whole host of different types of legal liability from multiple sources.

The high cost of cleaning up and dealing with a Perc contamination problem has been covered in many of the articles I’ve written for The Cleaner & Launderer, but expense was the focus in these articles:

You know as well as I do that those decisions based on impact to the profit and loss statements are a huge part of any business. The fact remains that the investigation and cleanup of environmental contamination caused by a release of Perc is extremely costly. Look through these articles again and ask yourself what your plan is going to be if you discover a Perc problem.

Updates on developments in the environmental world that are impacting drycleaners were provided in these articles:

Time marches on, folks, and I know it may not always seem like it, but the science related to the toxicological effects of chemicals we are exposed to gets better all the time. New contaminants of concern and revised health-based cleanup levels will be a constant moving forward.

As industry trends and reader input turned an interested eye toward business succession plan topics, we also spent some time talking about the environmental aspects of this process in these articles:

When you stop and think about it, nearly every old environmental problem is related to buying, selling, or owning a piece of property. Maybe not yours; but someone’s. The intentional or accidental transference of environmental liability along with commercial real estate is one of the driving forces behind the entire environmental industry. It was designed that way as a method of ultimately evaluating all old industrial properties. Please get help during a property transaction. You may think you understand the game, but the playbook is complicated, and you can only score big if you stay on offense.

Finally, I’ve tried to sprinkle in some of my own commentary related to drycleaners and how our clients have worked through the gut-wrenching decisions that they must make when they decide to take-on a contamination issue headfirst in these articles:

Listen, I get it. Nobody wants to poke the bear. Ya’know….my mother was an amazingly pragmatic woman. What she told me often was, “It is what it is,” and “You gotta do what you gotta do.” When it’s time to do what you gotta do, give me a call. We’ll help you through.

Contact us with your question about the environmental cleanup process.

As seen in Cleaner & Launderer


Photo of Jeff Carnahan, President at EnviroForensicsJeff Carnahan, President  
Jeff Carnahan, LPG, has 24+ years of environmental consulting and remediation experience. His technical expertise focuses on the investigation and interpretation of subsurface releases of hazardous substances for the purpose of evaluating and controlling the risk and cost implications. He has been a partner of the drycleaning industry for the past decade and is a frequent contributor to the national drycleaning publication Cleaner & Launderer. He is an industry leader in understanding that environmental risk

EnviroForensics Director of Brownfields and AgriBusiness becomes first environmental consultant to graduate from AgrIInstitute’s Agricultural Leadership Program

MORGAN SALTSGIVER LOOKS FORWARD TO SERVING ENVIROFORENSICS’ AGRIBUSINESS AND MUNICIPAL CLIENTS WITH A CLEAR UNDERSTANDING OF THE CONNECTION BETWEEN AGRICULTURE AND COMMUNITY

EnviroForensics’ Director of Brownfields and Agribusiness, Morgan Saltsgiver, LPG, has graduated from the AgrIInstitutes highly acclaimed Agricultural Leadership Program and has become the first environmental consultant to do so. Morgan was specifically selected to the program for her perspective on environmental issues that the agricultural community faces.

Morgan looks forward to leveraging her experiences to better meet the needs of EnviroForensics’ clients in rural communities across the Midwest. “My main takeaway from the program is that I was constantly reminded how closely agriculture and community are connected. We learned so much about the role of local government, the importance of rural broadband, divisive topics in the agricultural industry, and how the health of Indiana’s farmers has much broader implications than just on the farm,” Morgan says.

The cornerstone of the AgrIInstitute’s programming is the Indiana Agricultural Leadership Program (ALP), which is the only class of its kind in the state. As a part of the ALP’s curriculum, Morgan, and her colleagues—who represent a wide variety of viewpoints and perspectives—met with lawmakers in Indianapolis and Washington D.C. to discuss big issues impacting agricultural communities and hash out solutions for the future. “Getting these opportunities to develop agricultural and governmental partnership connections, while gaining a true understanding of the connections between agriculture and the community have been invaluable,” she said, “I look forward to applying this expertise through continued Brownfields redevelopment support for our communities.”

Morgan has worked in the environmental industry for over 18 years specializing in providing Brownfields redevelopment, agribusiness, and traditional environmental consulting services. She also serves as the current president of the Indianapolis Chapter of the National Association of Women in Construction (NAWIC) and immediate past president of Midwestern States Environmental Consultants Association (MSECA).

Learn more about how our expertise at EnviroForensics can help your community meet its environmental needs.