Month: February 2019

PERC IS ONE OF THE MORE EXPENSIVE CONTAMINANTS TO CLEAN UP. HERE’S WHY IT’S SO EXPENSIVE TO CLEAN UP AND WHAT YOU CAN DO ABOUT IT.

Dry cleaners are keenly aware that the use of tetrachloroethene (PCE, known as Perc) in the textiles industry has become as heavily regulated as nearly any other industrial chemical to date. In fact, environmental concerns resulting from the current or past use of Perc are practically as common as those arising from old gasoline stations. Everyone has seen the vacant, seemingly valuable, corner lot that used to house a bustling gas station yet is now sitting in ruin. These old gas stations are known to have been the cause of environmental problems, and the high cost of the cleanup is often the reason why they go dormant for so long. Unfortunately, the amount of time and money that is required to investigate and ultimately clean up dry cleaner sites that have been impacted with Perc can be several times higher than at typical gas station sites. A common gas station site falls into the $350,000 range, and we have seen average closure costs for dry cleaner sites more in the $1 million to $1.25 million range. What makes Perc so much harder and more expensive to clean up than petroleum?

This article discusses a few of the complicating factors about Perc releases that make them so unique and so darn expensive.

1. PERC IS HEAVIER THAN WATER

Part of the reason that Perc releases are so challenging to investigate and cleanup is because of its chemical properties. PCE is over 60% heavier than water under normal conditions and sinks to the bottom while the groundwater floats on top. Likewise, when a release of Perc to the ground occurs and it reaches down to the groundwater table, it will continue to sink until it hits a layer of dense material, like clay.

It will sit there and continue to dissolve for a long time, which can cause a long groundwater contamination plume. The groundwater plume may also be very deep, depending on the geological conditions in your neighborhood. Big and deep means that more off-site properties are likely to be impacted as the plume grows. If multiple clay layers exist, there may be continuing sources of groundwater impacts.

FACT: PERC IS HEAVY AND CAN TRAVEL FAST AND FAR, WHICH CREATES LARGE PLUMES IN GROUNDWATER.

Petroleum products, including gasoline, diesel fuel, Stoddard solvent, and the like, are less dense than water. In contrast to Perc releases, once a petroleum spill reaches the groundwater table it floats on top of the groundwater and migrates horizontally. As a result, most petroleum releases are fairly shallow and comparatively simple to investigate and cleanup.

2. PCE IS RESISTANT TO NATURAL BREAKDOWN

There are naturally occurring microbes, bugs, in the subsurface that breakdown many organic compounds and materials. In the shallow zones, there is usually plenty of oxygen in the soils and groundwater, and oxygen-loving bugs thrive here. Some varieties of these bugs readily use petroleum contamination as a food source, which has the result of slowly reducing the amount of petroleum contamination over time. So, recall that most gas station and petroleum pollution is present in the shallower zones of the subsurface where there are plenty of these helpful, oxygen-loving bugs that eat petroleum, and voila; you have a cheap cleanup method. In fact, a common and cost-effective remediation strategy in these situations involves simply monitoring the effects until cleanup objectives are reached, which is called Monitored Natural Attenuation (MNA).

Conversely to petroleum releases, the type of bugs responsible for the biodegradation of Perc and other chlorinated solvents thrive in an environment without the presence of much oxygen (anaerobic conditions). The most common biological process that naturally occurring bugs use for breaking down Perc is called reductive dechlorination. In this process, the bugs cause hydrogen atoms present in the groundwater (H₂O) to be substituted for chlorine (Cl) atoms in the Perc molecule.

That’s why it’s called dechlorination. Each time a chlorine atom is plucked off the parent Perc molecule; Perc, which has four chlorine atoms, is transformed to trichloroethene (TCE), which has three chlorine atoms, to dichloroethene (DCE), which has two, to vinyl chloride, which has one, and ultimately to ethene, which is basically a Perc compound with no chlorines at all. While Perc and all its other daughter products are considered toxic, ethene is non-toxic.

So, cleanup of Perc spills can be performed taking advantage of these naturally occurring bugs, but they aren’t really found in very common places. The conditions present in the subsurface need to be studied carefully and a remediation plan needs to be devised that takes advantage of this complicated, naturally occurring process to help achieve cleanup objectives where spills of Perc have occurred. Many times, naturally occurring conditions in the groundwater must be enhanced to take away the oxygen and we may even need to inject more of the right kind of bugs to speed up the reductive dechlorination process.

FACT: THE PERC DECHLORINATION PROCESSES ADDS SIGNIFICANT COST AND TIME TO REMEDIATION PROJECTS, AS COMPARED TO THE SIMPLE MONITORED NATURAL ATTENUATION OF A PETROLEUM PLUME.

3. PCE VAPORS ARE PERSISTENT AND MOBILE

Not only is Perc resistant to natural degradation, it also can remain in the soil as a vapor for a long period of time without breaking down. As all dry cleaners know, the volatile nature of Perc means that it will evaporate from a liquid to a vapor easily, which is one of the characteristics that make it such a good cleaning solvent. However, once PCE is released to the subsurface it also volatilizes as it disperses through the soil. If the vapors reached an occupied structure, like a house, and migrate into the indoor living space, vapor intrusion (VI) has occurred.

VI concerns are at the top of most regulator’s list of concerns since Perc is considered a probable carcinogen. Just like we discussed above, the special kind of bugs needed to break down Perc don’t like oxygen, and the soil where the Perc vapors are is full of oxygen. Perc vapors don’t breakdown, and they can cause VI concerns for a long time. Since PCE vapors do not readily breakdown, they have been known to travel great distances  even from minor solvent spills. Many dry cleaners are located close to their customers in highly populated areas, and as a result the risk of VI occurring from a subsurface release is compounded.

FACT: THE VI EXPOSURE PATHWAY IS AN EXTREMELY COMPLICATED PROCESS, WHICH REQUIRES A SOPHISTICATED AND KNOWLEDGEABLE ENVIRONMENTAL PROFESSIONAL TO ADEQUATELY INVESTIGATE AND ADDRESS THE PATHWAY. BECAUSE OF THIS, COSTLY VI INVESTIGATIONS AND MITIGATION SYSTEMS COME WITH NEARLY EVERY DRY CLEANER SITE WHERE A RELEASE OF PERC HAS OCCURRED.

On the flip-side, VI issues occasionally happen with gas station sites, but it’s not all that common. The petroleum hydrocarbon compound Benzene is a major component of gasoline spills. It is also very volatile and is a known carcinogen, like Perc. The difference is that benzene vapors have been shown to naturally degrade in soils. As a result, the occurrence of VI concerns resulting from releases of petroleum products is limited, and the associated costs are not necessary at gas station sites as often as at dry cleaner sites.

These are only a few of the reasons that releases of PCE from neighborhood dry cleaners are commonly so much more expensive to address than those from the typical corner gas station.

WHAT YOU NEED TO KNOW

It’s crucial that owners and operators of dry cleaning operations that have historically used or presently use Perc be aware of all potential funding sources available to them, such as:

• Historical insurance policies
• Redevelopment cleanup grants
• State Trust Funds

In those states that have dry cleaner remediation trust funds available for cleaning up dry cleaner sites, they are commonly stretched thin due to lack of funding, if eligibility is still available.

Historical insurance policies have proven to be the most powerful funding sources for dry cleaners across the country. Dry cleaner sites contaminated with Perc are complicated, expensive, and risky. Your best plan of action is to actually have a plan of action.

Contact us to get your action plan started.

As seen as Cleaner & Launderer

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Jeff Carnahan, LPG, has 20+ 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 focused on being a partner with the dry cleaning industry for the past decade, and he’s a frequent contributor to the national dry cleaning publication Cleaner & Launderer. He is an industry leader in understanding that environmental risk includes not only cleanup costs, but also known and unknown third-party liability.

HOW TO MAKE FINANCIALLY SOUND ENVIRONMENTAL CLEANUP DECISIONS

BY: JEFF CARNAHAN

Many years ago, when I was a younger man just waiting for life to teach me the lessons I’d need, I had a brown, four-door 1976 Ford Maverick. This thing wasn’t pretty, and it certainly wasn’t cool, but it got me to school and to work, and occasionally it would deliver a brave girl and I to the movies on a Saturday night. I spent the time needed to change the oil and replace the filters, but for the most part I took for granted how important it was to me. One day on my way to somewhere, I heard an awful clunk and it just died. The first thought through my head was, “Oh no! How much is this going to cost me?” After a $50 tow to the shop and following several hours of waiting, the mechanic asked me this question, “Well son, do you want it to run, or do you want it fixed?”

I’m sure you can figure out the rest of the story. Since I was counting pennies at the time, I chose to have the minimum amount of work done to get my car running and back on the road immediately for the cheapest amount possible, rather than investing the time and money into getting it fixed correctly. I won’t bore you with the details but be assured that when that old Maverick died for good soon after, I was left high and dry with no transportation and wishing I’d have made a different decision a few months prior. That was an important lesson for me, and one that I keep with me.

TIP: FIX THINGS RIGHT, AND THE INVESTMENT WILL MORE THAN PAY FOR ITSELF.

I’d love to say that it only took that one incident for me to learn this lesson. It’s funny how life keeps giving you opportunities to learn.

Most of us have an example of how we’ve experienced this situation in the past, but when these types of decisions must be made in business it’s even trickier. In your experience, was it during a dry cleaning machine repair job or when fixing a leaky roof, or even as you tried to put yet another quick fix on that temperamental boiler? Environmental cleanups probably don’t come to mind for most folks, but the exact same thing applies for them. There are three components to dealing with an environmental contamination problem:

1. Immediately halting any human exposure to chemicals that may be occurring;
2. Cleaning up the contamination on-site and off-site; and
3. Getting a Closure, or No Further Action, Letter from the state regulatory agency.

Once the necessary work has been conducted to stop human exposure, the question then becomes, “Now, do you want it clean, or do you just want a regulatory closure?” This may be putting the cart before the horse a little bit, but let’s leave the discussion about why immediately halting human exposure is top priority and non-negotiable for a later edition, and let’s focus on the interplay between cleaning up and getting regulatory closure.

WHAT DOES “CLEAN” MEAN IN AN ENVIRONMENTAL CLEANUP?

When performing an environmental cleanup, there is very little basis to involve the word “clean”. True clean never really occurs. There are only various levels of not quite, and at some point, it’s “clean enough”. In the world of environmental contamination there are numerous people setting the standard for when a property can be called “clean enough”. Most regulators worry mainly about two things beyond the current human exposure component:

1. Ensuring that the contamination problem is getting better rather than worse
2. Ensuring that there is no threat of future human or ecological exposure

Believe it or not, your property doesn’t have to be very clean at all for these boxes to be checked. Other parties who will be deciding if your property is clean enough are future purchasers and their financial lenders. They will not only be looking at whether you have a regulatory closure, but they will also be using the general environmental health of the property to help determine its practical value. This is a component that often gets overlooked when deciding how clean is “clean enough”. If the money isn’t spent during the first crack at environmental remedy, it could cost a significant amount of money later in the form of a lower property value when it’s time to sell, or a requirement for additional environmental work to be performed to even attract qualified purchasers.

TIP: THE TRICK IS TO STRIKE JUST THE RIGHT BALANCE BETWEEN SPENDING MONEY ON ACTIVE ENVIRONMENTAL CLEANUP, AND THE FUTURE COSTS THAT COULD ARISE. THIS WILL BE A LITTLE DIFFERENT FOR MOST EVERYONE FACING THESE DECISIONS, BUT THE FUNDAMENTAL THOUGHT PROCESS REMAINS THE SAME.

WHAT DOES REGULATORY CLOSURE MEANS FOR DRY CLEANERS?

Some state environmental regulators have very prescribed cleanup standards that have been put in place for regulated chemicals and are based upon certain human exposure scenarios given various land uses. For example, the cleanup standard for tetrachloroethene (PCE, or Perc) is much less stringent for properties which are and will remain commercial or industrial in nature, as opposed to used for residential purposes. This is because commercial property users spend much less time at the property than a residential user would and are engaging in activities that are much less likely to put them in contact with subsurface contamination than the residential user. So even when regulators strictly apply cleanup standards, their definition of clean is different for commercial and residential properties.

Other states allow for the person or business entity responsible for the contamination (Responsible Party, or RP) to decide how clean is clean enough by giving them the option to determine ongoing land usage more specifically with deed restrictions that limit the type of activities property owners and users can perform. A classic example is turning a contaminated property into a parking lot, and then putting in place a deed restriction or covenant that states that the property must always remain a parking lot, and it must be maintained that way, so no one can come into contact with the contamination. In this scenario, there is no need to perform much contaminant removal beyond what is necessary to keep it from spreading to other properties beyond the owner’s control. The presence of the well-maintained parking lot surface and the accompanying deed restrictions essentially remove the “risk” of human exposure. This type of regulatory closure is called a “Risk-Based Closure”. Many RPs initially love to employ such Risk-Based Closures because they are much cheaper initially than those remedies where a substantial amount of cleanup occurs. But keep in mind the little story about my old Ford Maverick. “Do you want it fixed, or do you just want it to run?” Well, do you want it clean, which restores your property to fair market value and provides you with a more robust set of reuse options, or do you just want a regulatory closure, which doesn’t restore your property to fair market value and limits future reuse options?

Settling for a pure Risk-Based Closure in lieu of a significant active cleanup can negatively impact the value of your property. I’m not saying complete elimination of environmental impacts is wise, or even possible. In fact, most of the time, it’s not even realistic to assume that every molecule of contamination can be removed from the soil, groundwater and soil gas after an environmental release. As such, nearly every remedy contains some component of a Risk-Based Cleanup. As I mentioned a bit earlier, the trick is finding the right balance that incorporates not only your wants and needs regarding post-closure usage of your property, but also takes into consideration your ability to shoulder the significant cost of active remedy.

BUSINESS AND PROPERTY OWNERS SHOULD WANT BOTH THE REGULATORY CLOSURE AND ENVIRONMENTAL CLEANUP

Environmental cleanup is a very costly endeavor, and it can heavily burden a business. Depending on how your business is set up, the liability for contamination could actually lie with you personally. Before you make that decision about how clean is clean enough, carefully consider all that you can afford. If you can swing it, the investment in a cleaner site will pay off in the future. Be sure to consider all your financial assets that can be used to pay for environmental cleanup.

TIP: REMEMBER THAT PAST COMMERCIAL GENERAL LIABILITY INSURANCE POLICIES CAN BE TRIGGERED TO PAY FOR ENVIRONMENTAL CLEANUP. ESPECIALLY SINCE MOST ENVIRONMENTAL RELEASES ALSO OCCURRED IN THE PAST.

By levering as much cleanup power and by choosing the best cleanup option, you can add value back to your contaminated property for future reimbursement. I wish the decision I made back with my Ford Maverick had been, “I want it to run, and I want it fixed.” As is the case for many dry cleaners, you’ll be better off if you get a regulatory closure and a cleanup.

Contact us to discuss leveraging environmental cleanup to restore property value.

As seen in Cleaner & Launderer

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Jeff Carnahan, President at EnviroForensics
Jeff Carnahan, LPG, has 20+ 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 focused on being a partner with the drycleaning industry for the past decade, and he’s a frequent contributor to the national drycleaning publication Cleaner & Launderer. He is an industry leader in understanding that environmental risk includes not only cleanup costs, but also known and unknown third-party liability.