Ranking and Choosing Remedial Technologies

We are always looking for ways to better serve our clients when it comes to remediation design. After all, they rely on our expertise and command of chlorinated solvents to guide them through what could potentially be a very challenging chapter in their lives. Continually developing our abilities to think critically and make sound, confident decisions can go a long way towards choosing the best course of action.  Enter the EnviroForensics Colloquium series; a series of bi-weekly discussions held among our staff to facilitate discussion and learning regarding the topic for that session.

The most recent discussion focused on remediation design, and more specifically, how our teams go about choosing one remedial technology over the other. It’s a significant subject, since the client’s wishes are heavily considered during this process.

Ranking Remediation Design Approaches

Our technical staff utilize screening matrices that help the tech team rank the remedial approaches to a given project Site. Geological conditions are typically the first elements to be taken into account. Understanding the nature of the soil and how layers of rock or sediment stack up provides the starting point in determining the technology needed to reduce contaminant concentrations. There are some remedial applications that don’t have the effectiveness in certain types of soil or geological conditions.

Contaminant Conditions

Contaminant Conditions (the nature and extent of impact) are also an important consideration during remediation design. How much is in the soil and groundwater? And where is it traveling? How fast?  These answers can narrow down the options based on what technologies will be effective in treating the impact.

Land Usage

Land usage must also be assessed. What is the property’s use right now? How will it be used in the future? If it’s a business and it’s going to continue to be one, the cleanup strategy will be considerably less invasive and more labor intensive.  Cleanup standards are different for residential vs commercial land use.

Cost-Effective Approaches

We prioritize cost-effectiveness. Our aim as a company is to utilize a technology that will require the fewest resources while maintaining a high level of effectiveness.  Not hitting on either of these targets causes costs to rise.  We focus on our client’s needs and receive a fair amount of business through word of mouth.  We take great pride in that.


Which brings us to another important client –driven factor; timing. How quickly does the client need this project to be finished? And what kind of technologies can deliver the desired effects in that period of time? We want to be able to close out the project as quickly as we can: effectively remediating the contamination while keeping with the client’s needs.

Safety Concerns

Safety concerns can loom large for some technologies. A miscalculation on a subsurface injection or a slip of the wrist on the operating lever of a backhoe can pose serious threats to health and safety at the project Site. One of our core values here at EnviroForensics involves “contributing to a healthy community.” We like to practice what we preach, so if there’s a different, more safe method of remediation, we will always go in that direction.

Continual Learning

EnviroForensics provides this and many other training and learning opportunities for our staff at all levels.  Chlorinated Solvents are our specialty, and activities like these allow us to retain a high level of excellence in this niche. It should be noted we operate with a “we over me” mentality often collaborating in teams to ensure the client get the best service possible, and education is key for this to happen.  The colloquium series is a led discussion by our Chief Geologist or a different expert on a topic.  Attendees are provided materials to read or consider prior to the meeting.  We keep our eyes forward to stay on the cutting edge of technology and the most effective application of our skills.

Helping you with property redevelopment after remediation

Often times our clients are concerned about our work impeding their business, or worse yet, standing in the way of reaching the goal of property redevelopment.  To the contrary – our work from the big picture, helps them gain back their property as an asset.  A case in point is when clients of ours in southern Indiana were going out of business due to less demand for services, they were trying to sell their property.  After having several interested buyers walk away because of rumors that the EPA forced them to close due to the environmental problems, we offered additional service.  Our marketing team created a flyer which contained vital information regarding notifying prospective buyers of the ongoing and “all expenses paid” environmental clean-up at the property and enrollment of the site in the Voluntary Remediation Program (VRP). This information will educate prospective buyers, and should put them at ease with regard to the environmental status of the property. The clients were very happy and thankful we are looking out to help them with property redevelopment.

Helping Clients with Property Redevelopment - Commercial Real Estate Poster


Poster text: “The property has been enrolled in the Voluntary Remediation Program (VRP) with the Indiana Department of Environmental Management (IDEM). We have cleaned clothes for decades and prior to selling, have engaged with the IDEM voluntarily to clean up the environment beneath and around our facility. The process is common among dry cleaners and other industrial facilities. In this case, it is being fully funded to comply with the IDEM and perform the reasonable and necessary work to obtain the clean bill of health for the property. This is good news for any prospective purchaser! There is currently a Remediation Work Plan (RWP) submitted to the IDEM that is moving the Site property toward regulatory closure. The facility is in the heart of the commercial district in a great location. Please feel free to address an inquiries too: John & Jane Doe at 555-555-5555.”

Having All of Your Bases Covered During a Phase I Assessment

When conducting a Phase I Environmental Site Assessment for a property transaction, it’s important to understand what your client wants to do with the property. A solid grasp on their project and objectives can go a long way in identifying all environmental due diligence topics that may apply. Many people don’t realize there are Out-of-Scope topics not covered by the Phase I Assessment reporting standard, and if overlooked, they could present environmental liability issues to a prospective purchaser.  These include:


•      Wetlands – For properties undergoing development, assessment is ESSENTIAL.  Regulated federally by the Army Corp of Engineers and by IDEM in Indiana.

•      Mold – Can pose health concerns.  No state or federal regulations on mold assessment in Indiana but guidelines are in place by several trade associations.

•      Asbestos – Can pose health concerns and can be costly to abate.  Regulated by EPA federally and IDEM in Indiana.

•      Lead Paint – Can pose health concerns and might apply to any project involving painted surfaces: multi-family residential, child care, bridge repairs, and commercial structures.  Regulations vary by project.

•      Environmental Compliance – Is the business following all federal, state, and local environmental laws and regulations?  Could be relating to permitting, reporting, waste disposal, etc.

•      Air Quality – Can pose health concerns.  In addition to vapor intrusion (covered by the Phase I standard) indoor air quality from an indoor source may be a concern.  Regulations may include OSHA, but vary by source.


If you are hiring an environmental consultant to conduct due diligence investigations at a commercial or industrial property, be sure to discuss your specific needs and not assume that all topics will be covered in a Phase I Assessment report.  Communication is the key to success!


New Hazardous Waste Management Rules Are Coming Soon – Are You Ready?

Some of our drycleaning clients are in the process of, or already have transitioned away from perc solvent, but there are still plenty of functioning perc drycleaning machines currently in operation across the country.  Parts degreasers utilizing chlorinated solvents are also commonplace.  All spent chlorinated solvents have to be properly managed and disposed of in order to avoid unintentional releases to the environment.

Spent solvents are considered hazardous waste under the Resource Conservation and Recovery Act (“RCRA”). Depending on the amount of solvents used and disposed of, the user is either classified as a Very Small Quantity Generator (“VSQG,” formerly CESQG), a Small Quantity Generator (“SQG,”) or a Large Quantity Generator (“LQG”). Most, but not all of our clients are either VSQGs or SQGs, the difference being that SQGs are required by law to report their activities and acquire a RCRA waste disposal number from their state regulatory agency.

Since its passage into law in 1980, RCRA has seen some changes; the U.S. Environmental Protection Agency (“EPA”) and industry are constantly looking to fine-tune the process of safe disposal of hazardous waste while not overly burdening the industries that generate it as a by-product of their operations. EPA’s last rulemaking affecting the hazardous waste generator regulatory program was in 2004 and addressed many of the remaining rough edges.The most recent rulemaking, which goes into effect this fall (2016), further improves the process by building in flexibility for generators who properly dispose of their waste.

How do these new rules regarding Perc this affect our clients?

  1. The new rules allow a generator, who normally falls under VSQG/CESQG or SQG status, avoid categorization as a higher status generator during a month in which they generated episodic waste, so long as they properly dispose of said waste.
  2.  They allow VSQGs to send hazardous waste to an LQG that is under the control of the same person, allowing for satellite locations of larger facilities to consolidate and dispose of waste in a more efficient manner; and
  3.  They make it easier for generators located in urban environments who find it difficult to meet the requirement that containers holding ignitable or reactive waste be placed 15 meters (50 feet) from the site’s property line by allowing generators to apply for a waiver from this requirement from their local fire department or emergency response organization.

While RCRA is not the model of legislative clarity, these most recent proposed rules from EPA look to further simplify the requirements on industries that produce hazardous waste while maintaining protection of human health and the environment. If you have questions about compliance with these new rules, EnviroForensics has professionals trained in managing hazardous materials who are on hand to assist you.

Minimizing The Impact of a Cleanup

It can feel like their whole world has been turned upside down when our clients receive the news that they have an environmental contamination issue on their property that could take hundreds of thousands, or millions, of dollars to clean up. Adding to this sense of panic is the knowledge that active remediation activities can be intrusive, time-consuming, and potentially disrupt business operations.  The risk of losing loyal customers during forced down-time can keep anyone up at night. That’s why EnviroForensics goes to great lengths to work with drycleaner owners to make sure we’re doing our job while also allowing them to do theirs.

Recently, we began the process of remediating a Site in Indiana where the best remedial technology necessitated work inside the drycleaner building.  The owners needed to keep the business running uninterrupted, and we needed to work with them to make that happen. We put our heads together and came up with a schedule and approach to install our remedial components while minimizing the impact on the drycleaner’s ability to conduct normal business.

We moved most of the drilling outside to minimize impact to the business.
We moved most of the drilling for our ozone sparge points outside to minimize impact to the business.

The first task was the installation process involved installing ozone sparge points into the groundwater beneath the Site building. Ozone sparge technology is able to oxidize contaminants in groundwater through the injection of ozone through subsurface injection points. For this phase, we devised a way to stay out of our clients way altogether by drilling angled sparge points from outside of the building to reach the contaminants beneath the building.  This innovative approach allowed for normal cleaning operations to continue inside the building during the drilling activities.

The second step of the installation process was a little bit trickier since it necessitated the installation of soil vapor extraction (SVE) wells and above ground piping inside the building.  We were able to schedule this portion of the work during February, which has historically been one of the slower times of year for our clients. For two weeks, dry cleaning and laundry operations were conducted as normal from 8am to 2pm before the building shifted into remediation mode.  The front desk and pick-up/drop-off operations continued as usual while our experienced install team went to work installing the SVE system from 2pm until 10pm each night.  Pulling those second shift hours paid dividends for our dry cleaning partner by allowing them to keep the doors open and meet the cleaning needs of their customers.  Now, while the public gets their dry cleaning finished on time, our remediation system is keeping a low profile, cleaning up soil and groundwater impacts.

Staying open is a big deal. For some business owners, it’s absolutely necessary to keep their heads above water. For others, it’s just a powerful statement to their loyal customers that they can continue to serve them in spite of their commitment to improving environmental conditions at their site. Keeping our client’s best interests in mind is a vital part of our job, and we demonstrate this on each and every project through team work and innovation to develop new solutions to old problems.  We work hard behind closed doors so yours can stay open.

This poster is prominently displayed outside the actual drycleaner. It was put up to help maintain transparency between the business and its loyal customers as well as establish the drycleaner owners as stewards for the environment.

A Vapor Intrusion Success Story

Sometimes detecting and addressing a vapor intrusion pathway is like a giant game of whack-a-mole. As soon you knock one down, another one pops up, and so on and so forth. One of our teams recently encountered this issue, having discovered that their initial mitigation efforts had not decreased the concentration of tetrachlorethene (PCE) inside an apartment located above a dry cleaner.  Despite this setback, our team dusted themselves off, and went back to work, going by the old addage; if at first you don’t succeed, you try again.

To give you an idea of what we were working with, our site building is a 2-story structure with a dry cleaner on the first floor, and an apartment on the second. The dry cleaner is now a drop-off only location, but had conducted on-site cleaning in the past. We discovered PCE in the sub-slab vapor underneath the structure, which helped us determine there were vapor intrusion risks to both the dry cleaner building and, perhaps more importantly, the apartment above it. We installed a sub-slab depressurization system (SSDS) to address this issue.

Unfortunately, that did not solve the problem. Indoor air PCE concentrations in both the first floor dry cleaner and second floor apartment remained above the residential vapor action level despite the operation of the SSDS. The concentrations were similar on both floors, which suggested direct physical pathways for indoor air movement. The HVAC systems that services these spaces were the most likely culprit.

Armed with this new knowledge, we focused our efforts on the first floor room that houses both of the HVAC systems. We first sealed up the mechanical room, using an air-tight door gasket and sweep. Duct work and piping penetrations in and out of the mechanical room were also sealed and a furnace filter cover was added to prevent the apartment furnace system from potentially capturing vapors from the first floor. We then installed door gaskets between the first floor store and the second floor apartment stairway. The final touch was an energy recovery ventilator (ERV) installed on the apartment’s furnace to increase fresh air exchange.

Early returns suggest this latest attempt to address the problem was successful. The first post-mitigation indoor air sample collected from the apartment did not contain PCE above laboratory detection limits. Our team will conduct a confirmation air sampling event during the upcoming winter months, when conditions will be ideal for a “worst case” air assessment.

In the Environmental Cleanup business, there really isn’t any room for failure. The preceding is a good example of the trial and error we go through when looking for all potential vapor intrusion pathways. Using the experience and ingenuity we have managing contaminations like this, we were able to come up with another solution. And, at least in the short run, it appears the residents of that 2nd floor apartment can breathe easy without having to worry about the potential health risks of exposure to PCE.

image was a courtesy of Washington State, Department of Ecology
image was a courtesy of Washington State, Department of Ecology

Putting the Forensics in EnviroForensics

When you hear the word “Forensics”, often times it conjures up images of television detectives. You imagine a hard-boiled cop working on his second cup of coffee, lifting up the caution tape on the police perimeter, so he can walk onto the crime scene and begin to reconstruct what happened. He collects clues like patches of fabric, hair and blood samples. Talks with witnesses and potential suspects; interrogating the shifty ex-con whose fingerprints are all over the crime and whose past won’t afford him the benefit of the doubt. It all invariably leads to the climactic finish with the unlikely perpetrator being caught in the final ten minutes of a neatly wrapped 60-minute serial. Environmental Forensics is kind of like Hollywood forensics – we reconstruct the past to answer questions like “who done it?”, and its application can assist in a multitude of ways when dealing with an environmental liability.

Environmental forensic investigations differ from traditional environmental investigations in that the objective is not to identify human health exposure pathways or answer remedial feasibility and design questions, but rather to answer specific questions about historical contaminant release scenarios.  The leading question is typically, “who is responsible?”  To answer this question, it is often instructive to determine where and/or when the release occurred.  Other potentially useful information may include contaminant type and indicator parameters detected with the contamination.  The need for a forensic investigation often comes about through environmental litigation proceedings, but forensic evidence can also be used to support insurance claims, out-of-court settlement proceedings, or other questions that may be aided by understanding the contaminant release and migration history at a site.  We have many tools to use for this purpose, including Fate and Transport Modeling (most common), Compound Specific Isotope Analysis, Principal Components Analysis, and Chemical Ratio Analysis, to name a few.

Just like our Hollywood example, forensic evidence in an environmental case also plays a huge role in the legal side of things.  We deal with the question of “who-done-it” a lot.  After all, figuring out who’s responsible/liable is what sets this whole thing into motion in the first place.  Often times, there are multiple, overlapping plumes with more than one potentially responsible party.  Forensic evidence can help us determine who is at fault, if there are any other responsible parties, and if a suit or claim is defensible.

It may not be as dramatic or as glamorous as the criminal forensics you see on TV, but environmental forensics is still a very important and useful practice.  The tools involved allow us to determine the nature of a release of a chemical contaminant, the timing of release, and perhaps most importantly, the source of release.  These facts not only help us better understand the site and recommended courses of action, but also aid in cost allocation, identify responsible parties, and support litigation proceedings.



EnviroForensics Uncovers Liability in Site Cleanups



As Seen in the July 14-20, 2003, Vol. 24, No. 18,  issue of the Indianapolis Business Journal.

PDF Version

Dry cleaner Denver Cain provided a blunt assessment about the pickle he’d be in if he were left to finance a half-million-dollar cleanup at one of his properties.

“I’d be in deep doo-doo,” he said.

Fortunately for Cain, he found the consulting firm Environmental Forensic Investigations Inc. The locally based company, known as EnviroForensics, specializes in locating sources to pay for site investigations and cleanups. Continue reading “EnviroForensics Uncovers Liability in Site Cleanups”