Recap of the 2019 NELA Annual Meeting

EnviroForensics’ Account Executive, Joe Miller, shares some insights from the 2019 NorthEast Laundry Association’s Annual Meeting and Fall Conference.

We were pleased to attend the 107th NorthEast Laundry Association (NELA) Annual Meeting and Fall Conference in Newport, Rhode Island. Established in 1911, NELA is one of the longest operating associations for textile supply and service companies in the country. NELA member companies clean and maintain reusable textile products like uniforms, sheets, table linen, shop and print towels, floor mats, mops and other items to businesses in all industries. 

This year’s Annual Meeting and Conference was packed with opportunities for laundry operators to network, share ideas, and learn new ways to maintain and promote their businesses, and cultivate relationships.    

Annual Meeting Overview

Breakfast and “Cracker Barrel” Session

Saturday started bright and early with the breakfast and “Cracker Barrel” session. All conference attendees gathered in the Newport Marriott’s Grand Ballroom to partake in the most important meal of the day and hear each vendor give a 30-second overview speech about their company and how they work hand-in-hand with the laundry operators. This was a useful session to get to know the players in the industry and break the ice in the process. 

The Cracker Barrel Session during breakfast gave vendors an opportunity to give a quick, 30-second speech about their companies to the group.

Educational Sessions

After everyone had a chance to reacquaint themselves, it was time for the education sessions. EnviroForensics had the honor of presenting on environmental investigations and insurance recovery. Our presentation, Environmental Investigation and Cleanup: Getting Into the Driver’s Seat, talked about the complex environmental investigation and cleanup process and how to minimize out-of-pocket costs and add value to your business.

EnviroForensics’ Joe Miller presenting “Environmental Investigation and Cleanup: Getting into the Driver’s Seat.”

After the presentation, we had the opportunity to learn more about individual NELA members concerns regarding environmental issues.

Learn how insurance archeology can find historical insurance policies that help protect businesses from environmental liability claims.

Capping off the educational sessions was the President of Fortune Web Marketing, Jennifer Rae Stine, who talked about digital marketing and how it can be applied to the textile industry. Her presentation focused on leveraging social media and search engine optimization (SEO) to “win the web,” and create new business in this mobile-driven, user-centric landscape in which we live.

Networking and Forging New Relationships

The conference ended with a formal dinner and reception where laundry owners and operators had another opportunity to mingle with vendors and sponsors in attendance and create new business connections. We talked with some laundry business owners about their own concerns with potential environmental liability, and answered questions about the process. As usual, it was rewarding to see small business owners come together around a common cause and talk about how they can continue to support one another.

If you want to become a member of the NorthEast Laundry Association, visit

Joe Miller, Account Executive
Joe Miller brings 15+ years of account management and environmental due diligence experience. He is a licensed mitigator and understands the technical aspects of contaminated sites as well as the associated business liabilities. As an Account Executive, Miller conducts preliminary assessments to help determine if historical coverage can be a funding option and provides proven solutions to private business owners including dry cleaners, small-large manufacturing facilities, municipalities, and redevelopment coalitions.

Q&A: EnviroForensics Answers Questions From Members of the Pennsylvania Delaware Cleaners Association

An environmental investigation and cleanup at a dry cleaner presents a series of complex and unique challenges. With the help of an insurance archeologist, a trusted environmental attorney, and an experienced team of environmental consultants, it doesn’t have to be so difficult.

EnviroForensics’ President, Jeff Carnahan, LPG, Director of Accounts, Dru Shields, and Account Executive, Joe Miller discussed this in a recent webinar co-sponsored by the Pennsylvania Delaware Cleaners Association (PDCA). At the end, attendees submitted questions about their own environmental situations for the panel to answer.

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

Dru Shields: When a cleanup has already been completed, it is possible to recover some of the costs that have been spent already. You may not recover all costs. Depending on case law in your state, there may be some hurdles. But, seeking out an insurance archeologist can help you go through your information, and locate historical insurance policies by:

  • recovering old business records and old historical insurance policies,
  • walking through the process of pulling together the corporate history,
  • pulling together any information on stakeholders that were involved in the business, and
  • pulling together any business records that you do have will be helpful when you initially reach out to an insurance archeologist.

2. 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?

Shields: That is a really good question. We’ve actually had a few of these situations come through recently. Even if you don’t have an action against you that’s going to trigger your insurance, locating those policies and making sure you have a safety net in place for when that situation arises, is always going to put you in a much better position than if you were to be in a reactive position, when it comes to actually getting the claim needed, whether that’s the lawsuit or a letter from your state regulatory agency. As I mentioned before, with the lawsuits it doesn’t necessarily have to be a contentious lawsuit. It could be an agreement you have in place with someone—whether it’s a neighbor or a landlord—someone who understands that to get the situation cleaned up and addressed, you’re going to need a lawsuit. So, that is something that we can assist with as well.

3. What is the average cost of a Phase I and a Phase II investigation?

Joe Miller: The average cost of a Phase I and a Phase II can vary all over the map. A Phase I is mostly a desktop investigation to see what the history of the property usage was, so not only was there just a dry cleaner, but what was there in the past? What could have potentially impacted that property beforehand? And also, what, in the surrounding area, could be impacting that property, too? What is the risk? So, the cost of a Phase I can range anywhere from $1,800 to upwards of $2,500-$3,000.

A Phase II are a little more difficult to name a price on because that’s really tough to determine how many holes to poke in the ground. That’s an actual investigation where you’re sampling; you’re taking samples of the soil beneath your site, you’re taking samples of groundwater beneath the site, sending those for analysis, and then generating a robust report of those findings. So, in any case a Phase I or a Phase II, we still suggest that you do your insurance due diligence first; Make sure we have a safety net of payment in place, in case something does pop out of those, especially a Phase II. And, be ready to go in case an environmental issue is found in those investigations.

Jeff Carnahan: I think the cost of a Phase II—if you’ve done what you’re talking about and actually have done the homework and find out that you’ve got coverage in place—the cost of your Phase II investigation can be mitigated, it can be kept minimal. In that situation what you’re concerned about is: Do I have a problem or don’t I have a problem? And, since we’ve worked with a lot of dry cleaners across the country, we know of three or four locations at a site where a problem is likely to be found. If that Phase II is to satisfy a lender, they might need more data confirming a property’s compliance. So, on the short-end, you’re looking at $10,000 – $12,000 for a minimal Phase II. If you need to satisfy your lending institution for a transaction, it might be closer to $25,000.

4. Can you use insurance archeology in addition to state-funded environmental cleanup programs?

Shields: The short answer here is yes. We have worked with a few different state funds to keep dry cleaners eligible for the fund. The goal is to use the historical insurance policies to pay for the cleanup. We have also worked with funds to implement language where a dry cleaner is required to look into locating historical insurance policies before they’re eligible for the fund. So, those funds want members to make sure there isn’t another source of funding before they’re able to dip into the funds provided by the states. And, that’s not to say though that there aren’t some funds that may have rules in place that would maybe not allow for insurance where they would prefer people who are using insurance to use only insurance, but if you have insurance and it’s going to cover it, and you have a state fund, and we’re able to keep you eligible, then yes, you can use both.

Learn more about how insurance archeology can help dry cleaners in states where the dedicated cleanup funds are drying up.

5. Will PERC naturally degrade over time if nothing is done?

Carnahan: I’ll try not to geek out too much on the science, guys. A lot of times we’ll go investigate gasoline sites and we’ll find evidence of impacts, but gasoline contamination will naturally degrade over time. If it’s a really old spill, sometimes you don’t have to do much. On the other hand, chlorinated solvents are considered recalcitrant compounds. That means that they don’t go anywhere, and they are very stubborn. Under natural conditions, there can be some breakdown, but not substantial over time. With Perchlorethylene, the degradation process that microbes will assist with; it goes from perchlorethylene down to trichlorethylene, so these chlorine atoms will cleave off of the molecule over time. We have investigated 50, 60, 70 year old dry cleaners or chlorinated solvent sites where we only see perchlorethylene; There’s been zero degradation over time. So, if your plan is, “Gee, my grandpa never did anything because he was hoping it would go away over time. My dad did the same thing. My mom did the same thing. And, now I’m doing the same thing,” it may not work out for you very well.

Miller: One other piece to mention is the differences of geology in different areas. One of these degradation materials that Perc turns into is vinyl chloride, which likes to hit sand and travel even faster through sand than actual Perc does. So, sometimes a problem that could have been a big problem to begin with, can be a miles-long problem after years and years of motion in groundwater.

See why Perc contamination expensive to clean up, and why an experienced consultant is required to manage the issue in a cost-effective way.

6. 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: Not really. But you can be essentially hounded by the regulatory agency, and they’ll be on your back for a long time. Regulatory agencies are able to enforce stipulated penalties and/or fines if work does not move forward, but realistically if the money is just not there, there’s not a whole lot they can do about it other than to continue to be on your case about it. Now, ultimately if there’s actually a human exposure because of the contamination at your site, but you literally do not have the money to clean it up, the EPA or the state agency can actually come in and take control of your site and spend money to take care of that ongoing exposure. However, just because the state comes in it doesn’t mean that they’re going to shoulder that cost. You’re going to get hit with a bill for money that somebody else spent. So, again, if you’re having trouble like that, we really recommend looking for your old policies. Let us look for those historical insurance assets so you can take control of the environmental issue yourself, because only then will be able to really take care of the situation.

7. On average, how long does it take to look for old insurance policies?

Shields: We typically give our insurance archeologists about 90 days to complete a project. If it needs to be expedited, we can take that into consideration as well, but the average time is 90 days.

8. How do I select a good environmental consultant?

Carnahan: Dry cleaner sites can be very specific. The contamination that occurs at a dry cleaner site is most likely operations-oriented. Whether it’s been a series of boil-overs in your still, whether or not there’s been a release to the sewer from the separator water, whether or not it’s been from a muck pile or from a drum of spent cartridges out back, you really need to find a consultant who has specific dry cleaner experience because they’re the ones who are going to know where to look. They’re the ones who will be able to more efficiently define the nature and extent of contamination in a reasonable manner. Also, chlorinated solvents are really tricky. They don’t break down over time. The pure product is heavier than water, which means that whenever it migrates down to the water table and continues down beneath the water table, it’s really hard to find, and if you don’t have a consultant that’s experienced with that specifically, it can be difficult to get your site cleaned up. So, how do you go about doing that? We can help you with that and can work with you. If you’re located where we can’t specifically get out there and start doing the investigation ourselves, which is of course one of our specialities, we’ll work with you. We’ll stand beside you during the claims process. We’ll stand beside you during the investigation process, and make sure that everything is on the up and up and looking good.

See our list of 5 considerations for when a dry cleaner is selecting an environmental consultant

9. We’ve found our insurance policies, but what happens when the insurance company no longer exists?

Shields: We’ve seen cases where insurance companies have been acquired by other insurance companies, and in that case you can find the chain of ownership and figure out who the main carrier is and whether or not you can still tender claims on those policies. We have also seen cases where the insurance carrier has been completely liquidated, and in some instances, there have been time stamps on how long you can tender claims. If that timeframe is up, you won’t be able to tender on those policies. In many cases we’ve found that dry cleaners switch insurance carriers over time. The likelihood of a dry cleaner having one insurance carrier for the entire extent of their ownership is low. It’s more likely that they would have changed to get better premiums, so the goal there would be to find policies that would have been held by insurance carriers that are still solvent.

Do you have a question that hasn’t been answered here? Contact us for a confidential consultation.


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.

Dru 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 Midwest Drycleaning and Laundry Institute (MWDLI) Advisory Council. 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.

Joe Miller brings 15+ years of account management and environmental due diligence experience. He has a background in geology, is a licensed mitigator, and understands the technical aspects of contaminated sites as well as the associated business liabilities. As an Account Executive, Miller conducts preliminary assessments and provides proven solutions to private business owners, small-large manufacturing facilities, municipalities, and redevelopment coalitions.

The Environmental Consultant’s Remediation Tool Belt for Dry Cleaners



Some questions you may consider when faced with environmental cleanup include “What does the cleanup process look like?”, “How long does it take?”, “How much does it cost?”, “What kind of inconvenience will you or your tenant have to endure during the process?”. There are many options available for use during site remediation at dry cleaning sites, but several factors need to be considered to determine which of them is best, including:

  1. Types of contaminants, like perc, that need to be addressed
  2. Extent of the contamination like soil impacts and/or soil, groundwater and vapor
  3. Property-specific geologic conditions like clay or sand
  4. Naturally occurring geochemical conditions
  5. Timing limitations
  6. Cost limitations
  7. Property usage limitations like building occupancy

Once a clear picture has been developed regarding your specific needs, then your environmental consultant can put together a remediation plan with the various tools from their tool belt to get the job done. Each technical component of the cleanup approach will have limitations, based upon your site needs, so putting together the right tools requires some creativity and a substantial amount of attention to your business needs. If this all goes smoothly, you can get your regulatory closure and peace of mind knowing that this challenge is now in the past.


For environmental consultants to understand the right way to get contaminants out of the subsurface, they first need to learn how they got into the ground in the first place. Most of the time, one can consider a conceptual model consisting of a soil source area created by a spill. This can include leached contaminants to the groundwater, and then the impacts in groundwater have migrated to an extent and created a groundwater plume. Vapors can emanate from any portion of the impacted areas too.

Once the contaminants have moved through the subsurface to create these distinct reservoirs of impacts, environmental consultants can’t exactly reverse the process. Rather, they must address each reservoir independently, and a different cleanup technology might be necessary for each. It’s not uncommon for the soil source area and the groundwater source area to be actively remediated, while the downgradient plume is left to reduce naturally over time. Sometimes, all groundwater levels will reduce to acceptable levels just by removing a large percentage of the contaminants in the soil source area.


The best way to decide which remedial technology is best used to address some or all the contaminants at your property is to look at their characteristics, capabilities, and limitations. Let’s look at some of those together, in order of the subsurface location of the contaminants.

Infographic showing how drycleaning solvent can flow into soil and groundwater and all of the environmental issues that will need to be remediated
This graphic outlines a sample dry cleaning property with soil source area, groundwater source area and groundwater plume area impacts, including its resulting vapors.


Excavation and Disposal is a common approach to remove contamination from soils above the water table in areas that have access to the ground surface. This doesn’t mean that excavation is only good for areas beneath the parking lot, or out back. Quite often, EnviroForensicsperforms surgical source area excavation activities inside buildings with active dry cleaning operations. It can be tricky, and planning is needed, both for the environmental work and to make sure that your operations aren’t interrupted, but it can be done. That being said, it is certainly easier to perform a significant excavation outside of buildings, and if the extent of impacts is limited and well-defined, it is often the fastest and easiest way to definitively remove a large amount of impacted materials from your property. Even for a sizeable excavation, we are talking about days or weeks, rather than months or years to achieve the objectives of the soil source area cleanup objectives.

Aerial view of the remedial method of soil excavation outside of an industrial warehouse
Excavation removes contaminated soil above the water table, and replaces it with clean soil.


Another soil source area cleanup technology that is popular at dry cleaning properties is Soil Vapor Extraction (SVE). This technology takes advantage of the volatile properties of dry cleaning solvents and, as the name suggests. A SVE system includes a series of screened pipes that are installed in the soil, which are all piped together and connected to a high-volume, specially designed and manufactured industrial fan, or blower. When activated, air is drawn through the treatment area and extracted through the screened pipes.

The contamination in the soil transfers from within the soil itself to the circulating subsurface air, which then travels through the system to a discharge stack. Once passed into the air and exposed to sunlight, the volatile compounds are destroyed. The result is clean soil. SVE systems can be installed both inside and outside of existing buildings, and new buildings can even be constructed over the top of these systems, so access is not usually that big of a problem.

The potential usefulness of SVE depends mostly on the characteristics of the soil. Tighter materials like clay are not as conducive to SVE as sandier soils. Even in nice, sandy soils, the process can take a year or two following the installation and startup of the system. The blowers can be a little noisy, but in most situations, that can be taken care of pretty easily. SVE is a nice option because it also takes care of vapor intrusion problems at the same time it is cleaning up due to the negative pressure created in the subsurface during its operation.

Series of pipes and gauges that make up extraction wells for the remedial technology of a soil vapor extraction system
Extraction wells inside a Soil Vapor Extraction (SVE) system. This is where the vapors from the ground are pulled into the system, before being discharged into the atmosphere where the volatile compounds are destroyed.


Another option for addressing contamination in the soil source area is the use of a Thermal Treatment technology. There are several alternatives available, but they all include the primary approach of heating up the subsurface to a temperature high enough to increase the volatility of the contaminant, and then capture the resulting vapors using an SVE system as described above. Thermal treatment has several advantages, such as being relatively quick and very reliable. It makes even more sense when used to treat the groundwater beneath the soil source area at the same time. The main drawback is the price because it’s usually a more costly options since so much electricity is used to create the high subsurface temperatures. Thermal is a great option if you absolutely must have a very clean site, have less than a year to do it, and you can avoid active usage of the area during the duration of the treatment. It’s possible to conduct thermal beneath buildings, but it is not usually feasible. EnviroForensics has used thermal at a dry cleaner site and the cleanup results were awesome. I wish we could use it more often.

Aerial view of fenced in thermal remediation system behind an old drycleaning building
A Thermal system heats up the subsurface to a temperature high enough to increase the volatility of the contaminant, and then capture the resulting vapors using an SVE system.


Directly beneath the soil source area, the area of highest groundwater impacts is usually found, which is referred to as the groundwater source area. When the remediation strategy involves the removal or destruction of contamination from the groundwater source area, there are many options to choose from.

In fact, the treatment of groundwater contamination is one of the most active areas of research and development in the environmental industry. Twenty years ago, it was common to install systems to pump out the contaminated groundwater, treat it at the surface, and then discharge it to a sewer. That practice didn’t really work very well, however nowadays most groundwater treatment actually takes place in the ground. When a treatment is applied in place, it is called an in-situ treatment.

In-situ Chemical Oxidation (ISCO) and In-situ Chemical Reduction (ISCR) are processes wherein chemicals are injected directly into the groundwater treatment area through drill-rods or temporary wells, where the chemical reacts with, and destroys the contaminant. It is a fairly quick process, which is good, but that also means that the effective life of the chemical injected is short.

One of the main limitations of any in-situ injection approach is that the desired chemical reaction is only able to happen precisely in the area where it is injected. You must have enough injection points to actually disperse the chemical where it needs to be. Subsurface intricacies in the geologic conditions tend to hijack your injection strategy, thereby leaving areas inadvertently untreated. This can result in disappointing initial results that lead to additional injection events, which is why second and even third injection events are often planned for the cleanup strategy. There are great products available for in-situ application in groundwater, and we have had a great deal of success using them, but you just have to manage expectations and hedge your bets.

Environmental consultant in full protective gear overseeing an in-situ remediation application using a drill
In-situ remediation uses drills or temporary wells to inject chemicals that react with and destroy contaminants.


The area of contamination downgradient of the source areas typically carry the lowest relative concentrations, but they may still be quite high. The Downgradient Groundwater Plume is the most likely to cross property boundaries into locations that aren’t under your control, leading to the need for an active clean up even though the contaminant levels may be low. Also, it may be necessary to lessen the risk that an impacted adjacent property owner decides to sue you. The in-situ injections I mentioned previously are a great way to treat this section of impacts since the extent of the plume may be quite large and the volume of chemicals necessary to destroy the lower levels of contaminants may not be large.

Sometimes, the contaminant concentrations in the downgradient plume are low enough that the plume starts to shrink once active remediation is conducted in the source areas. This is actually what we hope for most of the time. In this scenario, the concentrations in the downgradient plume just needs to be monitored on a periodic basis to ensure that they continue to decline. When this strategy is undertaken, it is called Monitored Attenuation. Obviously, this is a pretty cost effective and non-invasive approach, but the timeframe can get pretty long. If monitored attenuation is attempted without aggressive cleanup in the source areas, it can go on for decades and end up costing more than active remediation.


Contact EnviroForensics, the dry cleaning industry’s most trusted environmental consultant.

As seen in Cleaner & Launderer

Headshot of Jeff CarnahanJeff 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 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.

What Triggers an Environmental Investigation? Take a look into Pandora’s Box.


Picture of hand holding a magnifying glass in front of obscure environment

For years dry cleaners have suspected that they might have an environmental problem, but have been afraid to find out whether they do or not. It’s completely understandable why dry cleaners would be afraid of collecting soil and groundwater samples at their site. Of course, the biggest reason for not looking into the environmental conditions at your site or sites is opening Pandora’s Box. Simply stated, the cost of an environmental cleanup could cause financial hardships and sleepless nights.


Sometimes you can control the situation, but most of the time you can’t. Below are five events that can trigger an environmental investigation at a dry cleaning site.

  1. YOU’RE SELLING YOUR BUSINESS OR PROPERTYIf you want to sell your business or property, due diligence is required during business and property transactions to determine if the operating business and/or property carries any potential environmental liability including hazardous waste contamination, lack of permits, permit violations, and compliance deficiencies. Understanding these conditions allows the buyer to evaluate potential limitations, liabilities, and risks associated with the property. Often times, due diligence at a dry cleaner is going to uncover environmental problems. Due Diligence will start with a Phase I Environmental Site Assessment (ESA) to identify if there’s any likelihood of contamination. For most dry cleaners, a Phase II ESA will be required, which includes collecting samples of soil, groundwater or building materials to analyze for various contaminants
  2. YOU’RE REFINANCING YOUR PROPERTYIf you’re refinancing your property, your bank is going to require a Phase I ESA, which is the formal process that assesses the real estate for potential risk of environmental contamination. Again, for most dry cleaners, a Phase II ESA will be required.
  3. YOU’RE RETIRING WITH PLANS TO HAND OFF YOUR BUSINESS TO YOUR CHILDREN OR GRANDCHILDRENIf you want to retire and hand off your business to your children or grandchildren, there’s a high probability that contamination may be lurking beneath your building due to decades of dry cleaning operations. Since you’re passing the business onto family, you’ll want to conduct environmental due diligence to make sure they are protected from liability.
  4. YOUR NEIGHBOR IS SELLING OR REFINANCING THEIR PROPERTY, WHICH REQUIRES AN ENVIRONMENTAL INVESTIGATIONIf your neighbor is selling or refinancing their property, they’ll conduct real estate due diligence. Their environmental investigation may uncover a commingled plume that may lead to you. This will lead to conducting your own environmental due diligence process.
  5. YOU PURCHASED A PROPERTY AT TAX SALEIf you want to buy a property, which used to house a dry cleaner or any other commercial operation, you’re going to have to conduct real estate due diligence if you want to avoid taking on the environmental liability yourself.


The first step in the due diligence process is performing a Phase I Environmental Site Assessment (ESA), which is an evaluation of recent and historical activities at and near the property to identify potential or existing environmental contamination liabilities. A Phase I ESA may be required by a bank or other lending institution during financing processes, or it could be recommended by your attorney or other business advisors.


Graphic showing the Phase I ESA process, which starts with step one: conduct a user questionnaire. Step two: review historical documents to determine past use. Step three: conduct site walk and reconnaissance. Step four: interview site contacts and local agencies. Step five: review regulatory records for the site and surrounding properties

The consultant conducting the Phase I ESA will inspect the site for signs of staining, evidence of spills, stressed vegetation, determination of underground and above ground tanks, secondary containment, violations, and operating practices. They will evaluate records at the fire department, local health department, state environmental agencies, and federal EPA, to determine whether fires or chemical spills were reported on the property or on neighboring properties.

This review would also evaluate what businesses are operating in the near vicinity that could cause environmental impacts and could impact the subject site. A Phase I doesn’t include actual subsurface samples such as soil, soil gas, or groundwater. However, there is a standard that must be followed under the American Standard for Testing and Materials or ASTM, which now includes determining whether indoor vapor intrusion is likely.


If the Phase I ESA identifies a reasonable potential that soil and groundwater may be impacted, the consultant will suggest that a Phase II ESA be conducted.

The thing about conducting a Phase I ESA on real estate that has a dry cleaner is that, because of the history of dry cleaning operations, a Phase II investigation is nearly always required. In other words, one can be certain that if the real estate has an active or historical dry cleaner on the site and it is being considered for refinancing or purchasing, follow-up soil, soil gas or groundwater samples will be required.

A Phase II is a step further in the process of determining whether a dry cleaner has affected a piece of property. The Phase II is also referred to as a “subsurface investigation” and includes the actual collection of a series of subsurface (soil, groundwater) samples to determine whether the property has been impacted by chemicals that pose a risk to human health or the environment. This is where the costs start to add up when chemicals are identified.

Other items out of your control that can trigger environmental investigations include:

  • Contamination showing up in municipal or private drinking water wells;
  • Contamination showing up beneath neighboring or downgradient properties; and
  • Regional investigations conducted under the direction of state or federal regulatory agencies.

These triggers can mean perchloroethylene (PERC) has been identified in the groundwater and because PERC is a common dry cleaning solvent focus is put on dry cleaners both past and present. We have seen situations where the perc levels in municipal drinking water wells and immediately set out to identify all dry cleaners that operated within a mile radius of the well over the past 50 years. With a little digging, it is fairly easy to identify the address, name and period of time that a dry cleaner has operated at a location. We have seen the states pursue a retired couple that operated a dry cleaner for just two years from 1958 through 1959.


While no one wants to be the bearer of bad news, it’s important that all dry cleaners understand how investigations are triggered and what to expect once they are triggered. For this reason, we always talk about finding the businesses or property owner’s old comprehensive general liability (CGL) insurance policies first before the environmental investigation begins.

Graphic showing EnviroForensics' proven process for addressing environmental liability. Step one: insurance archeology. Step two: environmental investigation. Step three: environmental remediation.
EnviroForensics’ process to protect our clients from financial and legal challenges through insurance archeology before the environmental investigation and environmental remediation steps begin.

Old CGL policies may be the most valuable piece of paper you could ever have. Historical CGL policies written before 1985 or 1986 do not have absolute pollution exclusion language in them and therefore may be used to defend the insured against claims. A claim is what an “injured” party can bring against a business or individual that owned or operated a business that is found to have any amount of responsibility for the contamination found in the subsurface, typically the groundwater.

When confronting issues like this it’s important to have knowledge of the situation, process, and your options.


Our goal is to educate you about the environmental arena. Here are seven things you should know and do to be proactive and avoid surprises:

  1. Understand how investigations are triggered.
  2. Understand that your old insurance policies or those that you bought your businesses from may be worth millions of dollars.
  3. Be aware of your surroundings and what drilling activities are happening in your neighborhoods.
  4. Know your rights by reviewing your lease agreements.
  5. Find your old insurance policies and store them securely.
  6. Store information regarding the individuals that operated at your location before you did.
  7. Seek a qualified environmental consultant for assistance.
  8. Talk to an insurance archeologist.

And to remember the story of Pandora’s Box… Zeus had given Pandora a box and told her not to open it, but she did anyway. And even though all evils subsequently unknown to man escaped from the jar, at the very bottom of the jar there lay hope.

No matter your situation, we’re ready to find the best solution for you. Contact us today.

As seen in Cleaner and Launderer

Stephen Henshaw, CEO at EnviroForensics & PolicyFind has over 30+ years of experience and holds professional registrations in numerous states. Henshaw serves as a client manager and technical manager on complex projects involving contaminated and derelict properties, creative litigation, deceased landowners, tax liens, non-performing banknotes, 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.

Insights from the 2019 Lakeshore Chamber Business Expo

EnviroForensics’ Northwest Indiana Branch Manager, Michele Murday, and Account Executive, Joe Miller, share insights from the 2019 Lakeshore Chamber Business Expo. 

We were pleased to attend the 15th annual Lakeshore Chamber Business Expo put on by the Lakeshore Chamber of Commerce. The Chamber’s mission is to be the voice for business and a forum for the exchange of ideas to promote and strengthen economic vitality throughout East Chicago, Hammond, and Northwest Indiana.

The Lakeshore Business Expo was packed with insights about workforce development, retention and helpful tidbits for local businesses. It started with a luncheon featuring keynote speaker, Blair Milo who is the Indiana Secretary for Career Connections and Talent. There was also an exhibition and networking section for attendees to share ideas and establish new connections.  

Business Expo Overview

Luncheon with Keynote Speaker, Blair Milo

In her presentation, Building a 21st Century Workforce, Blair Milo talked about her role as Indiana’s “Chief Talent Officer.” In 2017, she was appointed by Governor Eric Holcomb to the office of Secretary for Career Connections and Talent where her main responsibility is to help facilitate the governor’s promise to fill one million job openings over the next decade. The former La Porte, Indiana Mayor, and Navy veteran talked about her work with the Governor’s Workforce Cabinet, and the efforts they’re making to ensure the Hoosier State has the highly skilled workforce required to meet the demands of an ever-changing economy. She expressed enthusiasm for the job creation efforts in the Northwest Indiana region. 

Indiana Secretary for Career Connections and Talent, Blair Milo presents at the 15th Annual Lakeshore Business Expo. Courtesy:

Exhibition and Networking

The main part of the Lakeshore Chamber Business Expo was the three-hour networking session. We had the opportunity to meet with dozens of businesses in attendance. There were representatives from local banks, human resource companies, healthcare providers, insurance companies, and engineering firms to name a few.  

Account Executive, Joe Miller and Northwest Indiana Regional Manager, Michele Murday at the Lakeshore Chamber Business Expo.

As usual, it was great to see how the business community in Northwest Indiana continues to grow and what our colleagues are doing to meet the increasing demands of the area. It was also nice to meet new potential partners, catch up with old acquaintances, and learn more about how we can all support each other.

If you want to become a member of the Lakeshore Chamber, visit

Michele Murday, Northwest Indiana Branch Manager

Michele Murday has 5+ years of experience in environmental consulting with a focus on investigation and remediation projects involving dry cleaners and petroleum impacts. Her experience includes preparing 3D site visualizations, environmental remediation, geologic and hydrogeologic data collection, data analysis and interpretation, reporting on all phases of projects from investigations through closure, proposal scoping and budgeting, project management, due diligence research, vapor intrusion assessments, and risk communication with property owners. Her previous field experience includes plume investigation, delineation, and remediation at dry cleaner/chlorinated solvent and petroleum impacted facilities. Murday has employed remediation techniques including soil excavation, chemical injections, soil mixing, multi-phase extraction systems, and sub-slab depressurization systems. She has also worked closely with clients and subcontractors, as well as state and federal regulators.

Joe Miller, Account Executive

Joe Miller brings 15+ years of account management and environmental due diligence experience. He is a licensed mitigator and understands the technical aspects of contaminated sites as well as the associated business liabilities. As an Account Executive, Miller conducts preliminary assessments to help determine if historical coverage can be a funding option and provides proven solutions to private business owners including dry cleaners, small-large manufacturing facilities, municipalities, and redevelopment coalitions.