Jeff Carnahan talks environmental remediation in American Drycleaner

Jeff Carnahan shares his experience on environmental remediation for dry cleaning industry with American Drycleaners editor Tim Burke. In the interview, Jeff discusses

  • Environmental remediation for perchloroethylene, also known as Perc (a common drycleaning solvent)
  • Three different types of subsurface contamination at dry cleaning sites
  • Reasons to start an environmental investigation
  • Five common dry cleaning environmental scenarios
  • Insurance archaeology as an alternative funding source
  • And Jeff’s biggest tip for dry cleaners

To read the Q&A article, download it here.

EnviroForensics Joins IDEM’s Pollution Prevention Program

EnviroForensics’ Senior Project Manager, R. Scott Powell, PE (second from left) accepts a framed copy of the Indiana Partners for Pollution Prevention pledge, following the company’s induction. Also pictured (from left): IDEM Assistant Commissioner Julia Wickard, Indiana Partners for Pollution Prevention Executive Director, Ben McKnight, and IDEM Deputy Assistant Commissioner, Robert Lugar.

Cleaning up contamination and protecting the environment is one of EnviroForensics’ missions, and for our employees, that mission goes beyond the job description. Protecting the environment drives how we conduct ourselves in our lives and habits. On June 12, EnviroForensics pledged to implement voluntary environmental initiatives at all our offices, share information and expertise with other businesses, foster environmental stewardship among our employees, and help raise public awareness. EnviroForensics is proud to join the Indiana Department of Environmental Management’s (IDEM) Indiana Partners for Pollution Prevention program. The members are comprised of Indiana industries, businesses, and nonprofit organizations that volunteer for a public-private partnership with the IDEM. Each member takes the Partners Pledge to affirm their commitment to promote pollution prevention and environmental stewardship. The partner members engage in environmental stewardship within their business by promoting practices, procedures, and plans that aim to achieve measurable reductions of pollution.

As an environmental engineering firm, EnviroForensics creates healthier community through remediating and removing environmental contaminants. And by taking the Partners Pledge, we are committed to implementing practices and procedures that can lead to even better outcomes for the environment. 

As part of our pledge to raise awareness, we are sharing our internal procedures and best practices for reducing waste and our carbon footprint. 

6 Ways to Be an Environmental Steward

1. Recycling

We have clearly marked recycling bins in every common space in our office. Next to each recycling bin is a list of items that can be recycled for the purpose of continuing education. We also collaborate with the Indiana Recycling Coalition for recycling training seminars.

2. Paperless document prep and delivery

We are consistently refining our own approaches and encouraging regulatory agencies in using digital preparation and submittal methods to reduce the amount of paper used during project report submittals, which also reduces fuel consumption that would have otherwise been used to deliver the documents. Additionally, we recycle and shred our used paper, and have saved roughly 39 trees so far this year.

3. Reducing the generation of investigatory waste

We manage project implementation with an emphasis on reducing the generation of investigatory waste while maintaining remedial objectives. This is implemented through the refined boring selection to reduce the number of borings required at a site, and the implementation of the most appropriate drilling methods that will reduce waste generation.

4. Implementing appropriate site controls to prevent the release of contaminants during remediation

Environmental remediation can be the destruction and/or removal of contaminants from impacted media. We pride ourselves on designing and implementing efficient remedial systems that remediate the target media with minimal generation of waste. This is implemented through reuse of system components and includes research and identification of expendable components that are environmentally friendly upon expiration.

5. Partnering with a local high school

EnviroForensics has an outreach program with Herron High School that includes regular educational workshops at our office. Pollution prevention and remediation issues are discussed, and best practices are identified to educate the students.

6. Neighborhood Cleanup Days

EnviroForensics organizes neighborhood cleanup days to pick up discarded waste in the streets, parking lots, and blocks around each office. It shows that we take pride in keeping our corner of the neighborhood clean, and we hope it inspires others to do the same.

At EnviroForensics, we deeply understand the importance of sustainable business practices and encourage everyone to implement these practices in your own businesses and homes.  

For tips on reducing waste, check out our 10 Things You Can Do to Reduce Plastic Pollution blog post. 

Take the pledge to reduce pollution

Help protect the environment in Indiana. The Indiana Partners for Pollution Prevention program provides its members with a forum to network with other businesses, share their pollution prevention experiences and ideas, and discuss member integration into IDEM’s environmental policies and programs. 

Learn more about how your company or organization can join the Indiana Partners for Pollution Prevention Program.

5 Considerations When Selecting an Environmental Consultant for Dry Cleaners


Property owner taking notes during interview with environmental consultant


Environmental contamination from past dry cleaning operations negatively affects many businesses, properties, communities and individuals across America. Dealing with environmental contamination has become a routine part of running a dry cleaning business–it’s even changed the standards for conducting environmental due diligence when buying or selling commercial property. I’ve compiled a list of five things dry cleaners need to consider when choosing an environmental consultant.


You are certainly not the first dry cleaner in your area to deal with an environmental release. There are many excellent national and regional dry cleaner associations, and some of their members have been through this before. Sometimes, just a conversation about someone else’s experience with the unknown can be enough to set one’s mind at ease, or at least give some level of comfort. One of the first things that anyone who has dealt with environmental contamination issues will tell you is that you need to hire a good consultant and a good attorney.

If you get a referral, evaluate the business situation of the person who gave you that referral. Be sure to ask:

  1. What was their business situation?
  2. What was the extent of their contamination?
  3. What was their end goal?
  4. How much did they spend out-of-pocket on costs?
  5. Did they achieve their goal?
  6. Was their property value restored to fair market price?

Remember each situation is unique. Be careful that you don’t fall into selecting an environmental consultant based upon close proximity or perceived to be the cheapest.

Selecting the right environmental consultant is one of the most important business decisions you’ll face and there are important differences between environmental consultants. If a business owner doesn’t know that there are differences between environmental consultants, countless hours and dollars may be wasted, projects could drag on for years and site closure or settlement may not be achieved.


An environmental consultant is typically a scientist or an engineer who has received specialized training about the way contamination behaves in the soil, groundwater, and air and possesses an understanding of the regulatory climate under which contamination issues are governed. Given the wide variety of geological conditions across the planet, the vast numbers of different types of contaminants in the world today, and the complex network of local, state, regional and national regulatory agencies; it’s a pretty tall order for one person to be an expert at them all. That’s why most businesses facing environmental issues hire an environmental consulting firm, which includes a number of individual professionals with expertise across many scientific and regulatory disciplines. This way you get the benefit of all this expertise for one price.

Your consulting firm must have demonstrated experience with successful investigations and cleanups of subsurface chlorinated solvents releases, like PCE and TCE

From an investigation perspective, it can be challenging to identify the true source areas of a Perc release, to determine the timing of when the release occurred, know where to look for downgradient portions of migrating groundwater plumes, and anticipate what caused the release.

From the cleanup perspective, chlorinated solvents, like perc, have chemical and physical properties that make it much more complicated to clean-up and achieve regulatory closure. It doesn’t breakdown in most natural subsurface environments and pockets of pure Perc product that hasn’t yet dissolved can be mobilized if appropriate care and skill aren’t exercised, which can create a bigger problem than already exists. I’d say a consultant who hasn’t yet managed over a hundred Perc dry cleaner sites probably doesn’t yet have a good feel for the unique complexities these sites hold.


Download our Environmental Consultant Interview Questionnaire to help you during the interview process.


For many dry cleaner sites, vapor intrusion issues are typically at the forefront of concerns. Perc, a common dry cleaning chemical, has a high degree which means the volatility of the chemical almost always results in subsurface vapor or vapor intrusion. Since vapor intrusion is common at dry cleaner sites, you’ll want to find a vapor intrusion experts who also understand Perc sites.

Not all environmental consulting firms have vapor intrusion experts. Some firms shy away from the vapor intrusion work even though they do soil and groundwater sampling work on Perc or TCE sites. Firms without their own vapor intrusion experts often subcontract those services, which can dilute the internal communications with the client. A firm with demonstrated expertise in all forms of Perc contamination ensures that the vapor intrusion investigation, mitigation, and risk management can remain a strategic component of the entire site closure approach.


When subsurface contaminants that have originated at your dry cleaner site migrate to off-site properties in the soil, groundwater or vapors, there are difficult yet necessary conversations ahead. Sometimes there are even conversations that need to be had with your own on-site employees, on-site tenants, or neighbors. Each of these communications regarding how contamination, that you are responsible for, has impacted their property, or potentially even exposed site occupants above health-based screening levels, is a high-risk of liability for you. Your environmental attorney is going to be intimately involved in these conversations, but a good environmental consultant is going to employ professionals who are highly skilled in explaining these situations to affected persons or communities.

In my experience of representing dry cleaners for over 20 years, I routinely need to convince next door neighbors to allow access for sampling on their properties and even explain how there may need to be restrictive covenants outlining a contract or agreement for their properties following regulatory closure.

Your environmental consultant should engage their professionals who have specific training and experience in risk communication and public relations to hold public meetings or interface with the occupants of buildings where vapor intrusion exposure issues are known to exist. Trust me, when you have a consultant walking into an elementary school gymnasium full of anxious parents to discuss a vapor intrusion concern on your behalf, you want them to have expertise in more than just the science of the matter.


The financial liability can be huge for a release of perc, and your ability to manage it is directly related to your ability to find the money to pay for it. Therefore, you need to find an environmental consulting firm with expertise in funding resources. A consultant who is truly looking out for your best interest is going to put your financial concerns near the top of the list of importance.

At my environmental consulting firm, we use your historical commercial general liability (CGL) insurance policies to help pay for the cost of environmental investigations and cleanup, among other sources.  

Infographic illustrating the what commercial general liability policies can be used to pay for, such as environmental and defense costs.
Once triggered historical commercial general liability (CGL) policies may be used to for legal fees, defense against claims, site investigation, remediation/cleanup, interim remedial measures, building legal case, potentially responsible parties (PRP) search, interfacing with agencies and prior costs be may be retroactively recovered.


To learn more about historical CGL insurance policies and how to find, read How Does It Work? Insurance Archeology and CGL Policies

There are also other funding strategies that may be of assistance, such as state trust funds or cost recovery through litigation if there are other responsible parties. It’s important to be careful about relying too heavily on state trust funds. There are reports of state dry cleaning environmental programs having a lack of sustainability and delays in reimbursement, adding even more emphasis to the need for strategic financial planning. There may be municipal or state incentives available, should you find yourself in a position to partner with redevelopers. Financial planning, just like clean-up strategies, should be custom-tailored to your specific situation and needs.



Selecting an environmental consultant may be the biggest decision for your business, so treat it very seriously. Select your consultant the same way you’d select your doctor. You wouldn’t want a foot doctor working on your heart and you shouldn’t have a tank removal contractor working on a solvent spill.


  • Evaluate the consultant’s experience
  • Download our Environmental Consultant Interview Questionnaire to help you evaluate your potential environmental consultant during your interview process
  • Find out how many sites they have worked on
  • Find out how many they have closed
  • Find out if there are alternative sources of funding other than just your business. If the consultant doesn’t have a clue as to what you are asking, run the other direction.  
  • Ask tough questions about the investigation and remediation process.
  • Understand why you are doing the work and whether you need the site closed to sell the property or the business.
  • Ask for a roadmap and plan of action.


  • Select an environmental consultant based on a referral alone.
  • Choose a consultant on price alone.
  • Choose a consultant because they tell you what you want to hear.

Take all of these considerations and use them as evaluation criteria during your search for the environmental consultant. I always tell dry cleaners that your environmental consultant works for you and you need someone in their corner looking out for their well-being. If the environmental consultant you’re considering doesn’t feel right, it’s probably not right.

Have questions? Contact EnviroForensics today. As seen in Cleaner & Launderer

Jeff CarnahanPhoto of Jeff Carnahan, President at EnviroForensics, 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 Do You Remediate Hexavalent Chromium Cr(VI)?

Hexavalent chromium is a highly mobile and toxic contaminant often found at manufacturing sites. Here we dive into the details and look at how to remediate this contaminant.

While a lot of environmental investigation and remediation work involves chlorinated hydrocarbon impacts, it is important to remember that this class of chemicals is just one of the hundreds that can impact sites. The contaminant that environmental consultants seem to be encountering more often at manufacturing sites is hexavalent chromium or Cr(VI).

Hexavalent chromium is used in chrome plating operations because it increases hardenability and corrosion resistance and has desirable finishing characteristics for industrial manufacturers. Chromite is used as a raw material for the production of chromium chemicals. Chromium alloys are used to make products such as oil tubing, automobile trim, and cutlery.

What is hexavalent chromium?

Like a lot of metals, chromium can occur in various valence or charge states. The two most common states are the trivalent (Cr+3) and hexavalent (Cr+6). While both are chromium, they behave differently. Trivalent chromium has relatively low toxicity, low solubility, and low mobility in the environment. By contrast, hexavalent chromium is toxic, has a higher solubility and greater mobility in the environment. Hexavalent chromium has historically been used in chrome plating operations because it is less costly than plating with trivalent chromium.

Chromium in the periodic table.
Chromium in the periodic table.

What are the exposure concerns for hexavalent chromium?

In addition to chromium plating operations, hexavalent chromium is used in a number of industrial processes such as leather tanning, colored glass making and in paint pigments and inks that color plastics and fabrics. Widespread industrial use can result in worker exposure to toxic hexavalent chromium. It’s estimated that over 500,000 workers are potentially exposed to Cr(VI) in the USA. Typically, people who are exposed to Cr(VI) work in welding and other types of “hot work” involving stainless steel and other materials containing chromium, use pigments or operate chrome plating baths. The public’s use of groundwater resources impacted by hexavalent chrome is another source of exposure.

Hexavalent chromium is known to cause cancer and targets the respiratory system, kidneys, liver, skin, and eyes. It is hazardous when breathed in, ingested, or touched. You might remember this contaminant from the movie “Erin Brockovich” with Julia Roberts, in which it was the subject of a massive lawsuit.

What is the regulatory enforcement for hexavalent chromium?

Regulatory agencies typically have screening levels for total chromium and then even lower screening levels for hexavalent chromium. Hexavalent chromium is heavily regulated to minimize human exposure. According to the EPA, they are continually re-evaluating drinking water standards to ensure that they are incorporating the latest research on the chemical.

How do you remediate hexavalent chromium?

Since hexavalent chromium is an element that cannot be destroyed, it has to either be physically removed by excavating soil or pumping and treating groundwater or transformed to the less toxic trivalent form and stabilized within the subsurface environment by forming insoluble and immobile trivalent hydroxide precipitates and iron and sulfide complex co-precipitates. Luckily, this transformation can be performed using many of the same injectable chemicals that are used at chlorinated sites for in-situ chemical reduction (ISCR) and enhanced reductive dechlorination (ERD).

The chemical reaction between hexavalent chromium and ZVI reduces the concentration levels of hexavalent chromium and creates a less toxic daughter product, or transformed version of the contaminant, called trivalent chromium. Trivalent chromium further reacts with other minerals in the subsurface to create less water-soluble compounds. The result is that the remaining chromium is less toxic, less soluble and less mobile in the environment. The resulting trivalent chromium impacted soil can remain in place without removal and with less concern of further migration of any remaining contamination. 

EnviroForensics recently pilot tested some of these injectable compounds with zero-valent iron (ZVI) at a hexavalent chromium contaminated site in the Midwest. A full implementation design plan was prepared for the reduction of hexavalent chromium and stabilization in both soil and groundwater.

Case Study: Remediating Cr(VI) at a Former Wire Plating Site

At a wire manufacturing company, hexavalent chromium plating operations were performed from 1963 to 1981. The operation was discontinued in 1981 and the chrome plating equipment was dismantled and sold in 1982 as part of the decommissioning process. In 1985, the site was sold to new owners that do not perform chrome plating operations. Prior to the sale, the inside of the plating facility was cleaned of all chrome plating residue; however, releases to the subsurface environment had occurred during past plating operations.

In 1985, a sump pump in the former plating facility failed and the water that began seeping into the basement was stained yellow. The water was tested and was found to contain high concentrations of hexavalent chromium.

Since 1985, several rounds of subsurface investigations have been performed by multiple environmental consultants to better determine the extent of chromium impacts in soil and groundwater. A groundwater recovery and treatment system was initially installed in 1988 to collect and treat groundwater. The treatment system removed some chromium over time, however, it had been inefficient at addressing the source of groundwater impacts. This means there’s still chromium in the soil and groundwater.

In 2013, EnviroForensics was contacted to work on this site. After evaluating all likely remedial options, a ZVI option was chosen as the most practical and effective for reducing source area impacts within a reasonable time.

A ZVI pilot test was performed at the site and has already shown large decreases in groundwater hexavalent chromium concentrations. A plan for full-scale in-situ mixing has been presented and approved by the environmental regulatory agency. The result of choosing ZVI as the remedial action will likely lead to site closure within the next two years.

Staying ahead of environmental contaminants

There is a lot to know about the sampling, chemistry, and remediation of hexavalent chromium to stay at the forefront of monitoring this environmental contaminant.

We’re proud to have some of the smartest minds working hard to find remediation solutions for these sites.

Contact us to learn more about environmental contaminants like hexavalent chromium.


Brad Lewis, CHMM, Principal Scientist at EnviroForensics

Brad Lewis is a detailed-oriented and collaborative leader with 30+ years of environmental consulting experience that covers a variety of projects ranging from due diligence, environmental compliance, landfill, Brownfields, underground storage tank, and chlorinated hydrocarbon investigations and cleanups. As Principal Scientist, he oversees investigations and cleanups. He helps project teams set the technical and regulatory strategies that will meet their client’s goals. Lewis has implemented many innovative site investigation strategies including the use of down-hole sensing equipment, mobile laboratory, and an immunoassay to characterize sites.

He has consulted on many high-profile projects dealing with petroleum hydrocarbons, polychlorinated biphenyls, hexavalent chromium, chlorinated solvents, bedrock impacts, vapor intrusion investigations, and vapor mitigation. 

Q&A: EnviroForensics Answers Questions from Dry Cleaners

The process of finding a client’s old insurance policies, tendering claims, and utilizing those available funds to clean up environmental contamination is a complex one. EnviroForensics’ President, Jeff Carnahan, LPG, and Director of Accounts, Dru Shields have extensive experience successfully guiding dry cleaners through the process. At the end of a recent webinar, we had a Q&A session full of interesting and frequently asked questions. Here are the responses.

Watch the webinar “How to use old insurance to pay for environmental cleanup,” to see the recorded presentation and Q&A session, and download the slideshow

This Q&A session has been lightly edited for clarity.

1: What if the insurance company is no longer in business?

Jeff Carnahan: We do actually see that periodically. We hope that that’s not your only insurer historically, but if it is, we have seen situations where now a defunct insurance carrier sets up some roll-off funds in order to provide certain amounts of dollars on the coverage. It’s not a great situation, to be honest, but in that type of a scenario, we would want to look at some other potential funding options. You might be in a state where there’s a dry cleaner trust fund, but there are also some other potential funds available. Maybe by working with your local municipality, there can be some low-interest loans available, and some other financial resources that might be able to help out.  

2: What could I do if a delivery company that spilled the PERC was part of the contamination and that company is no longer in business?

Carnahan: So, there are a few different parts to this answer. First of all, let’s just say that there was another party responsible for part of the contamination. Let’s start there. So, one of the things we do during the investigation phase — or typically during the defense stage — is we try to evaluate all the potential sources of contamination. And, if we identify, or if there’s actual proof or anecdotal evidence of another source, we typically will start to use the science and use the analytical data to allocate responsibility for the contamination in the ground. If, let’s say, the trucking company was not defunct, you would file a claim. We would work with your carrier and they would likely file a claim directly against that transportation company’s, or they would put a claim in on their own insurance company. Whenever that company is out of business, I like to say that there’s a difference between “dead” and “dead and buried.” So, if a company is out of business, there are still avenues of access to their old policies, and we can work with counsel to actually file a claim against that company who is now no longer viable against their insurance companies, presuming that they’re viable.

3: How do you make claims when the insured has no records of coverage but recalls the specific insurance companies he bought policies from?

Dru Shields: That is the whole purpose of hiring an insurance archeologist. It’s very difficult to go to the insurance carrier and say, “I know that you covered me. Will you please provide a defense?” That’s why you need to be able to show proof that a policy existed for the insured. Even if you don’t have old business records, there are efforts that insurance archeologists can implement as far as locating proof of policies, but you will need to be able to have that proof; some sort of evidence to show that you were insured by a specific insurance carrier to require them to defend.

4: I completed a cleanup and it was at great expense. Who can I talk to look into historic insurance?

Shields: You would need to be able to locate and prove that there were policies in place that would defend. Again, it kind of also depends on state case law as far as how those insurance policies would apply. You may not be able to recoup all costs of what you’ve spent on a cleanup, but you’d be able to recover some of those costs.

Carnahan: I think that falls into the category of a “cost recovery claim”, and we’ve certainly helped clients do that as Dru mentioned. There’s no guarantee that we will recover 100% of what they spent but a good chunk can be available.

5: On average, how long does it take to look for old insurance policies?

Shields: We typically allow 90 business days for our insurance archeologists to complete a search for insurance policies. There are rush options available, too.

To learn more about insurance archeology and CGL policies, read How Does It Work? Insurance Archeology and CGL Policies


6: Is there any liability on behalf of sewer districts? A lot of contamination comes from the fact that sewers were designed to leak.

Carnahan: I just saw a couple of days ago that, in California, there was a suit decided saying that the municipality did have some responsibility. It’s going to have to be proven up pretty significantly, but it can certainly be done. From the dry cleaner’s perspective, sewer releases are very common. I’ve seen situations where there’s been no release on the property itself. The cleaner had no idea there was a problem until sewer work was done about a quarter of a mile downstream, and they found a release and actually went back and pointed the finger at the dry cleaner. Those are the types of situations where we recommend partnering with a good defense attorney; that’s where that strategy is going to come from. We work very closely with defense counsel to help devise litigation and a scientific strategy that’s going to help prove your case. And then, we’ll just go after other potentially responsible parties.

7: Do you work on an hourly or contingency fee basis?

Carnahan: It’s more common for us to work on an hourly basis. We do time and materials invoices, and we provide our invoices directly to the carriers. And, our invoices are extremely detailed. They look like a law firm’s invoices if you’ve seen those before, which I’m sure most of you have as business owners. So, it’s time and materials. We provide that to the insurance carriers, and then we take the initiative on making sure that it gets paid, and we do the arguments. Now there are some situations like the cost recovery case that was brought up a little earlier, that we could potentially do on a contingency basis. Also, I’ve had dry cleaner clients who had multiple sites (multiple stores) and after having a problem, they want to cash in their old CGL policies. That’s also a possibility. We have done that for dry cleaner clients and we can also do that on a contingency.

Shields: We also do insurance archeology on a time and materials basis. That one, we don’t typically do on contingency, but it would be something we could talk about on a one-on-one basis.

8: What is the average cost of a Phase I and a Phase II?

Carnahan: Phase I Environmental Site Assessment are required by lenders before they will loan on property sale or use the property as collateral when lending. Phase 1’s are also required in order to obtain Bone Fide Prospective Purchaser (BFPP) status when purchasing a contaminated property. The requirements for conducting a Phase 1 has increased over the years, however, the cost has remained relatively constant. The true price of a Phase 1 is about $4,500, but because they are considered a commodity by banks and small consulting firms and one-person shops compete for this work, the prices can be as low as $2,500. There is a lot of liability in the Phase 1 ESA investigation and reporting, so going cheap may not be the best decision in the long run.

Phase II’s, on the other hand, are designed to give an understanding as to whether or not soil and groundwater have been impacted at the subject property. A Phase II may give the consultant an understanding as to the magnitude of an environmental problem, but it will not necessarily be the final investigative work required to determine the extent of a problem. A Phase II can be in the range of, say $15,000 to $30,000. It could be even less if everything looks clean on the Phase I –except for the fact that there is, in fact, a dry cleaner involved. As many of you may know, the current standard established for conducting Phase I’s says that if it is a dry cleaner site or it is adjacent to a dry cleaner, there must be Phase II sampling.

9: How does a dry cleaning business owner start the insurance archeology and environmental cleanup process if there hasn’t been a lawsuit or a sale to trigger a defense?

Carnahan: If you don’t have a lawsuit or a sale to worry about, it’s the perfect time to start pulling things together. Have a quick look at your business records and see what you can pull together. Give Dru a call at 866-888-7911 to start talking about some insurance archeology services. And, if you are planning on selling off the property, but keeping the stock of the company, that means you’ll retain the insurance policies, and that’s a good thing.

For insight on how to handle environmental contamination situations, read Fear, Hope and Determination: A Tale of Two Dry Cleaners


10: Who makes the final determination that a site has been sufficiently cleaned up?

Carnahan: At first blush, the regulatory agency makes that decision. Again, the cleanup standards are typically based on human health exposure criteria, and that’s what they use to establish the cleanup objectives. So, once the state regulatory agency is comfortable that you’ve reduced contamination at the site to concentrations that are deemed to be safe to human health and the environment, they can provide you a closure.

The second part of the answer is that the property owner has the right to determine what that land use is going to be. There are different sets of cleanup standards for commercial land use or industrial land use, residential land use, and even recreational land use. Typically, if the owner of the property has plans of future residential usage, there will be stricter cleanup objectives that need to be met. The standards are a little less strict if the property is going to be used for commercial purposes. So, it’s sort of a hybrid answer in that the regulatory agencies will have final say based on the land use that’s established by the property owner.

For tips on making financially sound environmental remediation decisions, read How Clean is Clean Enough? Regulatory Closure vs. Environmental Cleanup


11: If I purchase my dry cleaning shop after 1986, and an environmental issue pops up, is there still a way to utilize the policies of past owners of the same business/properties?

Shields: Yes, you can, and as I mentioned before when I was discussing insurance and through the process of insurance archeology, we are looking for policy information for any potentially responsible party. So, any of that past ownership we would be looking to find policies for those entities. In that instance, typically what you will need to do is hire legal counsel to help pursue responsible parties for those insurance policies to kick in and pay for any investigation and remediation.

Carnahan: Most of the time those can be very friendly arrangements. Those don’t have to be litigious situations. They can be, but they don’t have to be.

Shields: And even if those entities are deceased or bankrupt, they are still usable at that point, too.  

12: Will PERC naturally degrade over time if nothing is done?

Carnahan: No. Perc is actually considered a recalcitrant compound, and what that means is that under normal conditions, perc will not break down naturally. The twist is that “normal conditions” assumes that the aquifer and/or the subsurface has oxygen available, and in an oxygen rich environment, perc does not break down. One of the things we do whenever we inject chemicals is to try to create an oxygen-depleted environment, so certain types of microbes can flourish, which will then break down the PERC. If it’s a mere surface release in the absence of anything creating an oxygen-depleted environment, the stuff just hangs around. We deal with a lot of dry cleaner sites where releases occurred fifty or sixty years ago, and other than being bigger and more spread out, the perc just hasn’t broken down at all.

To learn more about PERC contamination, read What Makes Cleaning Up PERC Spills So Expensive?


13: What if contamination is found on my property, but money is not available for me to clean it up? Can I be shut down?

Carnahan: The regulatory agency can demand a cleanup, but the first thing they’re going to do is determine if there are any potentially exposed parties. In other words, if someone next door has a vapor intrusion problem caused by the contamination at your site. You might not necessarily – right out of the gate – be looking at millions of dollars here, but you could easily be looking at tens of thousands of dollars to make sure that no one is being exposed as time goes on. It’s not a perfect situation, but like I said before, we should at least look into other potential funding sources available that could help out.

Do you have questions? Contact us


Photo of Jeff Carnahan, President at EnviroForensicsJeff 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.


Photo of Dru Shields, Director of Accounts at EnviroForensicsDru Shields has over 10 years of account management experience in the environmental consulting and engineering industry. She manages a team of account executives who work across the country. Shields is a member of numerous regional dry cleaning associations in addition to serving on the board of the Midwest Drycleaning and Laundry Institute (MWDLI). Shields has extensive experience in assisting clients in securing funding for their projects through historical insurance policies. As Director of Accounts, Shields helps business and property owners facing regulatory action to navigate and manage their liability.

We’re Stronger Together

This June marks the 50th anniversary of the Pride movement, which began with the pivotal riot at New York’s Stonewall Inn. EnviroForensics’ team reflects on this historic event, as well as, LGBTQ+ scientists who made major contributions to their scientific fields as, we look ahead to Indianapolis’ own Pride festival.

We’re Better Together

LGBTQ+ individuals are positive and creative leads of all subgroups in our society. They are members of all races and professional disciplines, all religions, and every branch of government and military service. They are doctors, lawyers, engineers, scientists, marketers, bankers, accountants, athletes, artists, mechanics, laborers, and every other profession under the sun. They are friends and strangers, family members, work colleagues, and civic leaders. Today, more than ever, we must celebrate our diversity and embrace our commonality. Today more than ever, we must speak of the love for our brothers and our sisters and defy hate, discrimination and bigotry.

We’re stronger together and we are a stronger society when we stand up for the rights of others and cast aside hate and fear. Our best decisions and our best work happen when we are driven by all the identities and perspectives of our team members and clients.

We’re Smarter Together

As scientists, we strive for objective answers to questions. Today, LGBTQ+ scientists are making contributions in every branch of physical, social, natural, engineering, and computer sciences. Here’s a look back at just a few noted LGBTQ+ scientists who have made huge impacts in the scientific community.

Sally Ride, First Woman in Space

Sally Ride was an American astronaut, physicist, and engineer. At 32 years old, she became the first American woman in space in 1983. She left NASA in 1987, after flying twice on the Orbiter Challenger. For two years, she worked at Stanford University’s Center for International Security and Arms Control, and then at the University of California, San Diego as a professor of physics, primarily researching nonlinear optics and Thomson scattering.

Alan Turing, Biologist

Alan Turing was an English mathematician, computer scientist, logician, cryptanalyst, philosopher and theoretical biologist. He was highly influential in the development of theoretical computer science, providing a formalization of the concepts of algorithm and computation. He’s widely considered to be the father of theoretical computer science and artificial intelligence. During WWII, Turing played a pivotal role in cracking intercepted coded messages that enabled the Allies to defeat the Nazis in many crucial engagements. His work gave the Allies the edge they needed to win the war in Europe and led to the creation of the computer. He worked for the National Physical Laboratory, where he designed the Automatic Compute Engine, which was one of the first designs for a stored-program computer. He joined Max Newman’s Computer Machine Laboratory, where he helped develop the Manchester computers and became interested in mathematical biology. He wrote a paper on the chemical basis of morphogenesis, which was a mathematical explanation of how things grow. It became a completely new field of mathematical biology.

Julia Serano, Biologist

Julia Serano is an American writer, spoken-word performer trans-bi activist, and biologist. She earned her Ph.D. in biochemistry and molecular biophysics from Columbia University. She researched genetics and development and evolutionary biology at the University of California, Berkeley for seventeen years. Serano has written three books, “Whipping Girl: A Transsexual Woman on Sexism and the Scapegoating of Femininity”, “Excluded: Making Feminist and Queer Movements More Inclusive”, and “Outspoken: A Decade of Transgender Activism and Trans Feminism”. She is a national speaker on transgender and trans women’s issues and her writings have been used as teaching materials in gender studies courses across the United States.

These are only a few examples of LGBTQ+ contributions to only one of many aspects of our culture and society. Not only are we smarter together, but we celebrate diversity because we all have something to learn from one another. At EnviroForensics, we don’t just accept difference – we celebrate it, we support it and we thrive on it for the benefit of our employees, our services and our community. So, celebrate with us, the contributions given to all of us from all walks of life. We need them all!  

We’re More Valuable Together

Established in 1987, Indiana Youth Group (IYG) is a drop-in center for youth ages 12-20 who identify as lesbian, gay, bisexual, transgender, queer, questioning, and more. Youth who are allies to the LGBTQ+ community are also welcome. IYG’s mission of creating safe spaces, providing wellness programming, and educating LGBTQ+ youth and the community is accomplished through services, activities, affinity programs, referrals, and providing gather space. IYG is a 501 (c)(3) not-for-profit corporation.


Help support Indiana’s youth by donating to Indiana Youth Group.