Employee Spotlight: Samantha Henderson


Headshot of Samantha Henderson in front of sunlit cornfield


ANSWER: I have a B.S. in Geology from IUPUI. At this point in my career, I am focused on learning and developing the basic skills to become a well-rounded environmental professional and manager. I am not sure where this path will take me yet, but I look forward to each step. I have a very analytical and technical brain, so I wouldn’t be surprised if I gravitate toward a specialty in remediation in the future.

A: I was genuinely surprised to be recognized. At EnviroForensics, we are fortunate to work with so many talented and personable people. Everyone does the best job they can do – they go above and beyond every day. When you work with the “A” team every day, it feels incredibly validating and fulfilling to be seen and appreciated for your unique skills and how you contribute to the team.

A: At EnviroForensics, I feel that each person is valued for who they are and not just what strength they can bring to the team. It may sound a bit corny, but I feel like I matter, and I feel valued and respected. Our job is to do whatever needs to be done when it needs to be done. No one is above any job or task, and everyone is treated as equal. Perhaps more importantly, this company truly cares about the science and not just the revenue generated from projects. We don’t take shortcuts and the science is paramount to success.

A: The project team just finished an exceedingly complex and dynamic excavation that I had been directing since November 2019. The planning for the job took well over a year, so it was very gratifying and humbling to be chosen and trusted to manage the daily work and ensure its successful implementation. I have learned and grown so much by doing this work! There were constant surprises from unplanned pipelines, colorful and unprecedented soils, to regulatory and landfill delays, but through it all we all pushed forward and tackled all of the challenges as a team to get the job done correctly and efficiently. I am so proud of what we have accomplished! In the end, we removed over 4,000 tons of material at the Site, which is a huge step forward to drive the client’s needs.

A: My husband and I share a home in Brownsburg with our senior pug/french bulldog. In my free time, I am usually doing some form of house or yard maintenance, socializing with friends, rockhounding, trying new recipes, or just relaxing and spoiling the dog. I love to travel and look forward to being able to do that safely again. I think the best way to get to know someone is to get those little details that make us unique. We all go to work and we all have families, but I think what you do and feel when you are by yourself is very telling. Some quirky facts about me:

  • I have a tall torso, so I usually hunch over pretty far when I eat and I end up looking like a straight-up goblin.
  • My favorite color is orange. I gush when I see Autumn Blaze maple trees.
  • My favorite food is popcorn; Honorable mention to well-seasoned, medium-rare steak.
  • Autumn is the absolute best season. I’m always ready to feel that spooky Halloween vibe!
  • I weirdly like hosting and planning parties. I often host fancy tea parties and I put a lot of work into making the perfect tiny sandwiches.

The Value of an Environmental Cleanup


Picture of person's hand holding pen over a calculator, notepad assessing their property value

The decision to undergo an environmental investigation and cleanup is an understandably tough one for drycleaners. It requires an outsized investment of time, money, and other resources that can put a small business under significant stress. But, in the long-term, deciding to address one’s environmental issues proactively can prove to be an incredibly business-savvy decision. An environmental cleanup not only removes contamination, but it also alleviates business stress, such as regulatory and legal liabilities while increasing the monetary value of your business investment.


The short answer to this question, if you’re a dry cleaner, is you. By law, the parties responsible for potential environmental issues are liable for costs to clean up the problem. An environmental cleanup project may be the most expensive thing you ever buy. Our firm has been cleaning up properties contaminated with Perc for nearly 25 years, and we have seen that the average price ranges from $1 to $1.25 million dollars. That’s a pretty big lift for anyone, especially a small to medium-sized dry cleaner. Even if you can afford it, that doesn’t mean you want to afford it.

This is where I will stop and pose a question for you to ponder throughout this article, where is the value for a business to clean up contamination?


Value can be a subjective concept and it means different things to different people. Even by definition, it has multiple meanings. Maybe value isn’t the first thing considered when evaluating environmental problems, but it fits into the conversation in a few important ways.

  1. The word value can be used as a noun as in “This customer’s dress has great value”, or as a verb like “I value my customers very much”.
  2. Value can also be used as a meaning for one’s moral or ethical beliefs, such as “I respect this employee’s values”.
  3. Value can also be used when talking about monetary exchanges such as paying for an environmental cleanup. We typically would think of value as meaning that we have received an ample amount of goods or services in exchange for the money we’ve spent. In environmental cleanups, maximizing this type of value is mostly managed by choosing an experienced consultant to lead the project with competitive pricing for completion of the work.

Now that we’ve covered the different ways value can be used, I’ll apply them to environmental issues with a few examples. Then you’ll have to decide which ones mean the most to you, based on your individual needs and…values.


The most common driver for initiating an environmental cleanup is the fact that a federal or state regulatory agency is requiring that it be done. There may be other factors that arise during the process that are also motivating, such as an identified human exposure, but the number one value that the cleanup satisfies is getting the regulator off your back. This can be huge for some businesses, but what else do you get out of it? Very simply stated, you also get a cleaner piece of property. A clean and unencumbered plot of commercial property is an investment. We all know that. There are real estate investment companies out there whose sole business model is to buy and sell commercial properties based on its predicted future price or value. As such, even if the primary objective of performing an environmental cleanup has absolutely nothing to do with the potential sales price of your property, the reality is that the commercial viability of a property will increase as a result of the cleanup. As a matter of fact, if a property owner could shift their mindset to fully understand and quantify the potential gains associated with an environmentally clean property, it may be a good enough reason alone for initiating such a project. The average cost of a dry cleaner environmental cleanup is pretty hefty, as mentioned above, but there are plenty of smaller examples where the cost of cleanup could be paid for by the resulting increase in property value. In such a case, the regulatory closure would be just a bonus.

Thinking about selling your dry cleaning business? Read our blog How to Sell Your Dry Cleaning Business in 3 Steps


Value can also be added to cleanup projects by the elimination of long-term liability associated with environmental contamination. Whether or not it is on your radar, any time there is contamination, there is risk and liability, which can take many forms. Just think of the many ways that you may become aware of contamination; there are unique forms of liability in each.

Let’s say that an adjacent property owner has decided to sell their property and has undergone the due diligence process and that they have identified environmental impacts emanating from your dry cleaning operations. You may now be exposed to several types of liability from this single situation.

  1. First, you have a liability to investigate and clean up the contamination on their property. That’s to be expected. What may not be anticipated is the risk of additional liability that could be associated with trespass. In many states, the law says that if contamination from one property “trespasses” upon a second property owned by a different party, there can be a lawsuit. This is important because in a trespass suit the judge may award punitive damages in excess of the cost of performing the cleanup itself. I’m not an attorney and I can’t give legal advice as to the interpretation of trespass laws, but I’ve seen my clients forced to deal with this situation.
  2. Another type of liability that happens at times as related to environmental contamination is the threat of bodily injury or even wrongful death lawsuits. It’s no secret that Perc has been identified by the EPA as a likely carcinogen. Even though many dry cleaners have worked around this solvent for many years, or even their whole lives, people who aren’t as familiar with Perc as dry cleaners can be substantially more skittish about having been exposed to it. This risk of liability is most realized when contamination has entered drinking water supplies or indoor air at offsite buildings through vapor intrusion.
  3. Liability could even potentially come from your own employees. Studies have even shown that people exposed to Perc in the workplace are subject to increased risk of several types of cancer, including non-Hodgkin lymphoma. Typically, your successful OSHA monitoring practices should protect you from having this problem.

The intended purpose of mentioning all these potential liabilities is to highlight the fact that when an environmental cleanup is performed, these issues get brought to light, and then put to bed. The value that brings can be immeasurable.


An obvious, but perhaps often overlooked value to performing an environmental cleanup is that by improving the environmental conditions of your little corner of the world, you are on the positive side of the environmental history. Our planet has seen its fair share of degradation through the last several centuries brought on by advancements in the industry. There was a time when the progress of civilization almost always meant the degradation of environmental quality. The industrial revolution in the US and Europe was a time of great strides in technological innovations that created a huge boost for humans and a huge hit to the environment.

Dry cleaning as we know it came around toward the end of the industrial revolution. For decades now, the trend has been toward reversing those negative effects and focus has been more on improving environmental conditions. There has been a shift in our values on that matter. There is good news because this shift in values toward more environmentally friendly industrial technologies doesn’t need to interfere with continued technological advancement. So, while “greener” industrial development marches on, the process of restoring those environmental damages that occurred in the past is in full swing. When you take care of your regulatory obligation to clean up a property, not only do you increase the value of your property and relieve those liabilities as discussed above, you also get to be a part of cleaning up of the planet. Even if that doesn’t resonate strongly with you personally, I’d hazard a guess that it does with a good portion of your customers.

Learn more about how an environmental cleanup can be good public relations for your dry cleaning business

That brings me to the last point of added value from an environmental cleanup – peace of mind. There can’t be a dollar amount assigned to the value of putting all of this behind you. I’m sure that everyone can relate to how issues perceived to be negative can linger and tap your energy day after day. Once the issue has been tackled and resolved, we always say to ourselves, “I wish I had taken care of that years ago”. The common wisdom that has been passed from generation to generation in almost every major philosophical discipline is, “Thinking is harder than doing”. When it is time for you to tackle your environmental issues and conduct a cleanup, please be sure to recognize that there are many ways for it to be valued for your business, your community, and last but not least your peace of mind.

Contact us to learn more about how you can get maximum value out of your environmental cleanup.

As seen in Cleaner & Launderer

Going into science: Women scientists at EnviroForensics offer 5 pieces of career advice


As an environmental engineering firm, we are proud to be part of the science, technology, engineering, and mathematics (STEM) community. As a workplace, we know that our most innovative work happens when we utilize the perspective and opinions of all our team members.

For future female leaders interested in starting or advancing your career in STEM fields, we asked some of our teammates to share their best advice for unlocking career opportunities. Here are 5 pieces of advice from some of our team members.


Jennifer Hallgarth, LPG, Regional Director
Jennifer Hallgarth is one of our highest level directors and administratively oversees the majority of our technical staff, which is the heart of our business. She is also a champion for the environment and an entrepreneur as a beekeeper in her spare time.

“Your worth is defined by your integrity. Surround yourself with those who know your value. Positivity is everything.”


Grace Randall, Vapor Intrusion Specialist
Grace Randall is our Vapor Intrusion Specialist and a key member of our industry-leading VI team. She is an animal lover and once rescued a kitten from a car engine who is now her beloved pet Luna.

“Aim high and surround yourself with excellence. Don’t ever underestimate yourself.”


Brianne Inman, Senior Project Manager
Bri Inman is one of our Senior Project Managers. She manages environmental projects ranging from chlorinated solvent, petroleum, and hexavalent chromium site impacts. She is a great agriculture resource, lives on a farm and has expertise in raising farm animals.

“Women are having a moment. We’re everywhere right now and it’s being celebrated across many fields and industries. The scientific field is no different, my advice to anyone wanting a career in environmental science is to work hard and go for it.”


Morgan Saltsgiver, LPG, Director of Brownfields and AgriBusiness
Morgan Saltsgiver is our Director of Brownfields and AgriBusiness and represents us as the AgrIInstitute’s first environmental consultant. In her free time, she’s also the Treasurer for the Indy National Association of Women in Construction (NAWIC) and the President of the Midwestern States Environmental Consultants Association.

“Be bold, persistent, and push yourself out of your comfort zone. Volunteer for the difficult projects, stay late working on that complicated calculation, make that difficult call first thing on your to-do list for the day. Finally, never apologize for being awesome at what you do!”


Michele Murday, Northwest Indiana Regional Manager
Michele Murday is Regional Manager of our Northwest Indiana office and leads community relations with movers and shakers in the region. She is also the Event Chair for Water For Empowerment, a water charity that works to bring clean water access to women in the developing world and is the Environmental Committee Chair for the Northwest Indiana Forum.

“Treat every day like a learning day. There is no such thing as a stupid question, it’s a “learning question” and without asking questions, you will not advance your knowledge base. Also, there will be days (or weeks.. or more) when you want to give up. Try your best to push through those days and ask as many questions as you can because those are the days that will make you build character and grow the most.”

As we celebrate the progress made, we look forward to supporting the up-and-coming women in STEM. EnviroForensics is a gender-balanced company that promotes women in all areas of our business. Interested in joining us? Check out EnviroForensics careers.

Rolling the Dice for Regulatory Closure—3 Rules on How to Hedge Your Bets and Come Out a Winner

Environmental cleanups involve a great deal of creativity to make sure that the goals are met within acceptable timeframes, regulatory requirements, and of course, budget. The whole game plan is to reduce the amounts of contamination in the ground to levels that are deemed safe for human health and the environment should an exposure occur at some time in the future.

While a good environmental consulting firm will be able to tell you what kind of cleanup approach is most likely to be successful, they will base that opinion on their own past experience in similar situations and the published past experiences of their professional peers in the industry. Unfortunately, there is not an “off-the-shelf” approach that is guaranteed to work, so in many ways, a cleanup effort is a proverbial roll of the dice.

However, there are some consulting firms like ours who will stand behind their designs and guarantee results. Our ability to do this is due to several factors that help us hedge our bets when performing an environmental cleanup. If you follow these three rules of creating a successful cleanup plan, you can come out on top as well.

1. Experience Counts!

During my college pursuits, I had a professor who always used to say, “The best geologist is the one who has seen the most rocks”. I always took that to heart and mention it often to my peers. I’m sure it’s also true that the best cleaner is the one who has processed the most articles of clothing or textiles. Why? Because they are the ones who have experienced the most situations where challenges have come up that needed to be solved. They’re the ones who learned from each of those situations and tweaked their process to make sure that the occurrence of the same problem was minimized in the future. Each challenge is a learning opportunity, and those who have learned the most, are frequently the best.

I’ve said it before, and I’ll say it a thousand more times that when you are choosing your environmental consultant to design and implement your environmental cleanup strategy, you need to find one who has a great depth of experience with dry cleaner sites. They are the ones who will understand the nuances of Perc contamination. They are the ones who have had to decipher the subtle differences between releases from dry cleaner operations and other kinds of processes. They’re the professionals who have seen the most cleanup challenges and solved them to get the job done and achieve regulatory closure.

Get a step-by-step process in “5 considerations when selecting an environmental consultant for dry cleaners”

2. Strategically Plan Investigation to Save Money During Remediation

Let’s face it; the subsurface environment is a bit of a black box. Geologists and environmental professionals are educated and trained to interpret a wide view of conditions beneath the ground from only a handful of data collection points and samples. The more data collected during investigation phases, the better conditions are understood and the greater the odds of a successful remediation later. Remember that the process is:

  1. Investigate the nature and extent of contamination; and
  2. Perform the cleanup.

If the full nature and extent of contamination is not really understood, the cleanup plan has almost no chance of success. Way too often, consultants with less experience think that just because they have the contaminant plume defined in all directions, they are finished with the investigation. There are a lot more data points that need to be explored to really understand the nature of the impacts, which will also allow for a good predictive cleanup approach to be prepared. These include, in part, the naturally occurring geochemistry of the soil and groundwater, actual measurements of porosity and permeability, the calculated rate of groundwater migration across the site, the organic content of soils, the infiltration rate of rainwater down through the soils and into the groundwater, etc. These data points are where the surprises usually come during cleanup if they haven’t yet been considered.

The trick to making sure that an environmental investigation is performed correctly is to collect information needed to design the cleanup approach and retrieve that data at the same time. If the focus of the investigation is to simply determine the extent of the contamination plume, then only part of the picture is being captured. Given that situation, a separate remedial planning phase of the investigation will then have to be undertaken to get this vital information, which will likely involve going back to areas where the previous sampling has already occurred. This adds cost to the project. Because of this point, there may be hesitation to approve the remedial planning investigation, leaving the consultant to design a cleanup approach without all the necessary information.

If performed appropriately, remedial planning investigation efforts can be added for as little as a 10% increase in costs. However, if something is overlooked during an investigation and a cleanup plan is inappropriately designed because of it, the extra effort could easily double the price of the cleanup itself. If you ask a remedial contractor what causes cleanup plans to fail, they will almost always say a lack of adequate investigation data. I always ask them that, and that’s what they always say. Spend the extra 10% on an investigation, it will save you money during remediation. Period.

Read more about remediation strategy best practices

3. Combine Remedial Technologies

Ideally, once a cleanup begins, it ends when the remedial objectives have been met and enough contamination has been removed. Sounds simple enough. Many times, cleanup projects start very well and appear to be heading toward closure (even under budget), but the cleanup appears to stop working. This is among the challenges requiring creativity to get the last bit of contamination out of the ground. Oh sure, the first 90 to 95 percent of the contamination is removed very quickly and effectively and this makes everyone happy. But as time passes, the effectiveness of the cleanup can dwindle making everyone unhappy. The levels of contamination may continue to slowly decrease, but never quite get to closure levels under a single approach. It’s not so much that it stopped working, as it is that it reached a point where it is no longer cost-effective to continue. This happens with a lot of good cleanup technologies. So, with the clock still ticking, the money still flowing into the project, and contamination removal rates slowing, there needs to be a shift in strategy to get the job completed.

With a multitude of remediation technologies available for use, it’s important to follow a logical, yet creative path to select the right combination from the very beginning. For example, let’s say technology A is used because the level of contamination is high, and it is expected to effectively reduce the level of impact to low, but not low enough. When the removal rate of technology A slows down to a crawl, we change to technology B to treat the remaining concentrations to a lower level and achieve closure. Usually, technology B can be performed at a lower unit rate cost than technology A and therefore, project costs can also be constrained. Clearly, cost considerations are very important, but for the purpose of this discussion, the point is that it should not be assumed that using one contaminant removal technology alone is the right approach.

Dealing with the stress and cost of environmental contamination issues is bad enough on its own. Paying attention to these three rules of cleanup planning will help you avoid a bad roll of the dice and let you double down on your bet for a successful project.

As seen in Cleaner & Launderer

Jeff Carnahan, President at EnviroForensics
Jeff Carnahan, LPG, has 20+ years of environmental consulting and remediation experience. His technical expertise focuses on the investigation and interpretation of subsurface releases of hazardous substances for the purpose of evaluating and controlling the risk and cost implications. He has focused on being a partner with the 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.

7 Drycleaning Industry Predictions for the Next 10 Years

 Disclaimer: These responses were written in January 2020 prior to COVID-19 in the United States

Drycleaning business owners are accustomed to the ever-evolving industry standards and practices – making change a way of life for drycleaners of all sizes. They are constantly applying new ways to run their businesses more efficiently and keep their loyal customers coming back. Drycleaners are learning new ways to clean stains and new fabrics, grow their business, manage marketing programs, train their staff and explore new technologies such as point-of-sale systems.

While it’s impossible to see the future, we can make educated guesses about it. In this article, we asked seven industry leaders from across the country to share where they see the drycleaning industry going in the next 10 years. Here are their predictions.

Mary Scalco – CEO, Drycleaning & Laundry Institute
“In 2030, I believe we’ll be seeing fewer drycleaning facilities. I think we will go ‘back to the future’ with larger central facilities being fed by more and more drop-off retail locations, pick-up and delivery routes, lockers, and other convenient ways to transfer the items back and forth.

I think drycleaners will continue to offer a wider variety of services in addition to drycleaning such as wash-dry-fold, commercial linen cleaning, and other diverse services. As cleaners increase the percentage of customers wardrobes that they receive for cleaning they will also see an increase of household textiles as drycleaners care for more linens, draperies, carpets, and other household items.

They will offer their services in ever more convenient ways with longer business hours, routes, drop-off facilities, and on-demand pick-up.

Point of sale systems and apps will track when garments are cleaned and send reminders to consumers much like the oil change sticker on your car. Robotics will be introduced in some capacity. Consumers, who will be more and more environmentally conscience, will continue to drive how cleaners process and package their items.”

Mark Pollock, C.P.D. – Director of Operations, Signature Cleaners and Member, Drycleaning & Laundry Institute Board
“Going forward I see significant changes to the Fabricare industry. More central plants servicing more satellite locations. Automation continuing to lessen the reliance on a shrinking labor pool. The need to provide added related services giving customers more reasons to patronize your company.”

Chuck Hempstead – Executive Director, Southwest Drycleaners Association
“It looks to me that by the end of this new decade the growing drycleaning operations will be the ones that diversify their operations – be that routes, cleaning non-traditional items like footwear, wash and fold, and simplifying the customer experience. Differentiating from one’s competitors will include emphasizing quality and mastering marketing. Also, we’ll continue to see consolidation as economy of scale is applicable to all industries.

Association membership will grow in importance to the successful companies in order for them to remain competitive. Change and opportunity occur too fast for any of us to go it alone.”

Wisconsin Fabricare Institute
“The Drycleaning Industry has seen its ups and downs over the last 40 years. I feel in the next 10 years, the Drycleaning Industry will be thriving. There will always be a need to have your fine garments dry cleaned. With all the help from outside sources, dry cleaners are doing their best in being more environmentally friendly in their cleaning process and in their packaging process. We have continuing education at our hands-on how to succeed and to keep our industry from failing.”

Tim Burke – Editor, American Drycleaner
“Many garment care owners tell me they are adding services to their operations to offer more to their clients. The most progressive minded say they will continue to keep up with their clients’ need for convenience, such as with technology. And they tell me they strive to make their operations look modern, and to always help their clients look their best. That won’t change. It’s what they do.”

Darcy Moen – Drycleaning Industry Consultant and Columnist for Cleaner & Launderer magazine
“As the baby boom demographic bulge moves through the owners of drycleaning businesses we will see a decline in the number of dry cleaners as owners retire. Many of the children of owners have moved into other careers and won’t be following in the footsteps of their parents. But as one generation moves on, I see newcomers with fresh eyes stepping in creating new ways of doing business. As the gig economy influences drycleaning and laundry services I expect to see a dramatic surge of new ‘on demand’ types of drycleaning and laundry growing.

Mass supply of lower cost of clothing has led to closets stuffed with more and more designer goods. Despite advances in laundry detergents and appliances, nobody has any more free time for cleaning and pressing clothes than they did ten years ago. In fact, with most people experiencing increased demands on their time from careers, family, and social commitments, there are fewer hours for personal fashion care than ever before. I can see huge pent up demand for cleaning services from masses of people with masses of clothes wanting affordable, quick and reliable fashion care maintenance for those mountains of clothes. The question is, who is going to do all that work? Most likely it will be done by a cleaner/launderer who can deliver a low cost and profitable service through a plant designed with efficient capacity to deliver cleaning. And by cleaning, I don’t mean a conventional drycleaning service but a hybrid of drycleaning and laundry services. I can foresee a new type of cleaner, one that focuses on delivering a crisp, clean, like new appearance but at a cost that is relative to the cost of quick fashion of today. Customers don’t care how we as an industry deliver service, just as long as their clothes are clean, pressed, looking like new and ready to wear at an affordable price with quick turn-around. The challenge of the next decade will lie in transforming plants of today into a new type of cleaning facility that can service a broader range of clothing at a price that is as affordable as doing your laundry at home while generating a profit. It’s up to us to rise to the challenge and find the solution of the magic bullet plant for the new markets that are emerging.”

Jeff Carnahan – President, EnviroForensics & PolicyFind
“In the twenty-plus years that we have been serving the drycleaning community, we have certainly seen changes in the market. Less small players, more consolidation, franchises, etc. What hasn’t changed is their hard work ethic, commitment to customer service, or comradery among peers. Regardless of how the drycleaning industry morphs in the coming years, I can’t see any of these going away. EnviroForensics and PolicyFind are proud of our association with dry cleaners and we’re honored to continue our commitment to them into the future.”

This decade will be trying for some and filled with opportunities for others. As with trends of any nature, some come and go, whereas others stay the course and become fundamentals. No matter a dry cleaner’s unique situation, they can rest assured that the entire drycleaning community is behind them and wants to see the best outcome for them.

For more drycleaner articles, visit our blog.

Emerging Contaminant Alert for Dry Cleaners: PFAS is the New Bad Guy in Town!


beads of water on PFAS treated glass in front of blue background


I believe that most dry cleaners were just beginning to feel like they were well-informed of the risks environmental liability contributes to their businesses, then all of a sudden came the onset of vapor intrusion (VI) issues a little over 10 years ago. It was gradual in the beginning, but at one point it seemed like dry cleaners were utterly swamped with new regulatory demands to immediately assess whether there could be VI problems emanating from their sites. Now, although still a part of environmental investigations, the VI panic has mostly subsided. As the VI exposure pathway was further studied and understood, the ultra-conservative approach initially unleashed by the regulators began to soften to a more reasonable level.

Well, there is a new bad guy in town, and its name is PFAS or perflouoroalkyl substances. It’s a big deal, and although the dry cleaning industry is in no way at the epicenter of the developing PFAS issue, dry cleaners will get involved before this is all over with. Similar to what we saw with VI, I certainly anticipate that the regulatory community will initially react with an abundance of caution as the toxicological and political process settle into a plan. There have already been incidences of dry cleaners being forced to include PFAS in their sampling plans when a solvent release is known to exist. In this article, I want to explain what PFAS really are, wherein the dry cleaning industry they may have been used historically, and how the regulatory process development has been progressing. You will need to stay aware as the toxicological study and regulatory reaction develops related to this emerging contaminant.

Fluorosurfactants, otherwise known as perflouoroalkyl substances, or PFAS, are a wide group of engineered chemicals created to lower the surface tension of water. The various individual chemicals are created by replacing the Carbon atom on normal petroleum hydrocarbons with a Flourine atom. Essentially, anything that has been developed industrially or commercially to be non-stick, or waterproof owes its success to PFAS. Although initially created in the 1930s, the first widely used PFAS material was polytetrafluoroethylene (PTFE), which was a non-stick coating developed by DuPont that became known by its trade name, Teflon. Given the wide success of Teflon, further research and development led the way to a total of nearly 5,000 different PFAS chemicals in subsequent years. Some of the other products that were created using this group of chemicals focused on water repellency and stain resistance, such as 3Ms Scotchgard. One of the most prevalent uses of PFAS chemicals has been in the production of fire-fighting foams, especially in the air transportation industry and especially at the United States Department of Defense facilities. There have been, and still are, a very wide range of products that contain PFAS chemicals, including:

Firefighting Foam

Fire crews battling fire with flame retardant foam which commonly contain PFAS

Some grease-resistant paper, fast food containers/wrappers, microwave popcorn bags, pizza boxes, and candy wrappers

Grease resistant cardboard that potentially contains PFAS

Nonstick cookware

Non-stick pan that is potentially treated with PFAS

Stain-resistant coatings used on carpets, upholstery, and other fabrics

Dog sitting on stain-resistant carpeting potentially containing PFAS

Water-resistant clothing

person wearing water-resistant coat potentially treated with PFAS

Cleaning products

Cleaning products that contain PFAS in front of yellow background

Personal care products (shampoo, dental floss) and cosmetics (nail polish, eye makeup)

Makeup container that potentially contains PFAS

Paints, varnishes, and sealants

Open paint cans that potentially contain PFAS

PFAS compounds are one of several groups of chemicals referred to as “Forever Chemicals”. This means that they are so well-built, so to speak, that they are extremely durable and don’t break down easily. It was great for the products they are used to make, but that also makes their presence in the subsurface very troublesome now that they have been determined to be hazardous to human health and the environment. Of course, when I say “now” they are known as hazardous, I really mean that it has been known by researchers for over 20 years that exposure to PFAS chemicals is harmful to humans, but it has taken this long to get the giant commercial and regulatory ship to turn. In fact, there are estimates that PFAS compounds can be found in the bloodstream of 98% of the United States population.

I’m sure that you all know better than I do, the whole host of products that have been available through the years to make textiles, rugs, and leathers waterproof and stain-resistant. Clearly, these are the primary connection between the dry cleaning industry and PFAS, although there has been some discussion regarding detergents and other additives during the cleaning process. The theory is that during the cleaning process, some of the PFAS enter the waste solvent solution. As such, anywhere there has been an environmental release of dry cleaning solvent to the subsurface, the presence of PFAS is also possible because materials treated with related products may have been cleaned at the facility. The dry cleaning operations that actually performed waterproofing would be the most at risk.

Once released into the subsurface, PFAS chemicals are highly resistant to breakdown and are very soluble, and as such, they can migrate quite far in the groundwater. Drinking water supplies are of primary concern to the Federal and State environmental regulators. The U.S. Environmental Protection Agency (US EPA) has established health advisories for two of the most prevalent PFAS chemical contaminants, called PFOA and PFOS, based on the agency’s assessment of the latest peer-reviewed science. These advisories will provide the most up-to-date information on the health risks of these chemicals and aid drinking water system operators and state, tribal and local officials in making determinations as to the appropriate steps needed to address PFOA and PFOS in their communities.

Infographic explaining what the EPA is doing to regulate PFAS
The EPA has established PFAS measurement methods, issuing drink water health advisories, supporting site-specific challenges and providing tools and information so communities can better understand processes and procedures. Courtesy: epa.gov/pfas

The EPA’s assessment indicates that drinking water with individual or combined concentrations of PFOA and PFOS below 70 parts per trillion (0.07 micrograms per liter ug/L) is not expected to result in adverse health effects over a lifetime of exposure. Current studies indicate that exposure above these levels in drinking water could increase a person’s lifetime risk of several types of cancer, immune system dysfunctions, or developmental disorders.

One of the primary concerns about PFAS, given its widespread use and known releases to the environment, is its impact on the country’s drinking water supply. Although the US EPA issued its PFAS Action Plan on February 14, 2019, many states have expressed frustration with the EPA’s proposed plan and have started the process of regulating PFAS in drinking water themselves. As we saw the vapor intrusion regulation process evolve, some states have moved forward with their own versions of regulations and standards that present significant challenges to impacted industries.

Read more about PFAS and learn about currently available state resources

From the environmental consultant’s perspective, I see this playing out very much as VI did in the 2000s, as I mentioned. As new toxicological studies are completed by those agencies to whom the US EPA relies upon to make their policy and regulations, there will be an ongoing debate in Washington D.C. This is certainly to be expected since PFAS chemicals have become such a large industry, the regulators will want to make sure they respond appropriately. There is a very large amount of money at stake, and a misstep that leads to over-regulation could create a huge financial crater in the US manufacturing, commercial and retail, and insurance sectors. As a business owner, I’m sure you can understand that perspective.

We have already seen some of our dry cleaner clients with known subsurface releases of Perc being asked by the state regulatory agency to start looking for PFAS as well. We’ll just have to keep an eye on regulatory developments across the states this coming year. In the meantime, it would definitely be worth the time to consider how PFAS could be associated with your past operations.

The good news is that subject to the same limitations I have written about many times, your business’ old commercial general liability (CGL) insurance policies could be used to pay for the investigation and cleanup of PFAS, if they are identified, just like Perc. Most of the time, however, if you are going to find PFAS, you will already have a solvent release problem.

The main impacts of this PFAS issue will be to draw even more dry cleaners into the regulatory process and to increase the cost of environmental investigation and cleanup. Instead of seeing it as another blow to the dry cleaning industry, you could see it as another reason to sit up and take notice of your potential environmental problems.

Have you been asked to include PFAS in your environmental sampling? Share your thoughts.

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

As seen in Cleaner & Launderer

Jeff Carnahan, President at EnviroForensics
Jeff Carnahan, LPG, has 20+ years of environmental consulting and remediation experience. His technical expertise focuses on the investigation and interpretation of subsurface releases of hazardous substances for the purpose of evaluating and controlling the risk and cost implications. He has focused on being a partner with the 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.

Understanding remediation strategy: Environmental contaminant removal vs environmental risk management

A shortsighted view during environmental remedial planning can make it tempting to favor short-term over long-term savings for dry cleaner cleanups. However, when looking at the entire cleanup process and all associated costs, the need to balance present-day cleanup efforts with anticipated future costs becomes far more important.

With perchloroethylene (Perc; PCE) and other chlorinated solvents, the threat of future exposure does not readily go away. These lingering contaminants may present serious problems for future environmental cleanup costs and long-term environmental liability.

In this article, I’ll share why it’s important to work with an environmental consultant who understands the value and significant cost savings that can be realized by choosing a more active remedy instead of long-term stewardship.

The strategic options for eliminating contamination exposure pathways and attaining regulatory closure can have vastly different costs when it comes to future liabilities and long-term stewardship that will be required following regulatory closure. For example, source removal can be a relatively large short-term expense compared to a vapor mitigation system. In fact, that same vapor mitigation system might end up costing far more over time than source removal if the system is not properly maintained or the building on which it has been installed remains in use for a long time without any meaningful remedy to the contaminant source.

Look at the total lifecycle cost when planning your remedial strategy

Post-closure monitoring, legal risk, and administrative costs really add up over time. When dealing with environmental issues, regulatory closure is often seen as the end goal. While regulatory closure can be attained through various strategies, most revolve around the elimination of exposure pathways, at least in part. Regulatory agencies typically prefer a remediation strategy where a large amount of contamination is removed, but when push comes to shove, they usually will approve remedies with little or no contaminant reduction if the risk of exposure to people is controlled. Because of this, it has become increasingly clear that regulatory closure should be viewed as only an interim milestone when dealing with contaminated properties.

Proper cost-analysis that takes all these factors into account can help you find a balance between short-term and long-term costs and make decisions that are right for you. There is a reverse relationship between money spent on immediate cleanup versus the costs of stewardship and the often-overlooked component of potential legal damages resulting from dry cleaning contaminants left behind. The demand of cash-flow considerations in most businesses, especially small businesses like dry cleaners, can really drive decisions regarding remedial planning. By looking at the total lifecycle cost during the decision-making process and attempting to keep your sights on the longer game, it could save hundreds of thousands of dollars over time.

Whether we’re treating the contaminants in soil, groundwater, or vapor directly or implementing a mitigation system to cut off the pathway, the goal of any environmental remedial strategy is to eliminate exposure.

Understanding the decisions in selecting an environmental remediation strategy

The following case studies provide a helpful guide for property owners, developers, and environmental professionals to consider when evaluating remedial efforts vs. long-term stewardship. The cases outlined are actual sites where EnviroForensics was involved in recommending and then implementing an effective remedial plan and ultimately saving both time and money in addressing the environmental contaminants of concern.

The costs of future legal liability included in our case studies below were estimated by experienced attorneys who performed an analysis taking court cases nationwide and assigning a higher cost component for prevalent claims in similar cases. Alternatively, in a situation where claims were not made, they assigned estimated damages to parcels that may be potentially affected. The cost examples presented are case-specific and subject to margins of variability.

Case Study 1: A Dry Cleaning Site Uses Enhanced Reductive Dechlorination (ERD) Approach to Achieve Site Goals and Lower Lifecycle Costs and saves $420,000

This dry cleaning site had PCE contamination that extended beneath several buildings, including residential property impacts that were present in the soil, and exceeded direct contact thresholds and the migration groundwater standards. The groundwater plume was also expanding and contributed directly to vapor intrusion (VI) exposure issues. VI mitigation was necessary for both the source area and at downgradient residential structures.

These were the two remedial strategies considered.

Remedial Strategy A:

  1. Impacted soil would be excavated to promote future contaminant plume stability
  2. Institutional controls would be implemented to cut off exposure pathways from the groundwater. Institutional controls typically consist of groundwater usage restriction (i.e. no drinking water wells allowed) but requirements vary from state to state
  3. VI mitigation would be installed and maintained

Remedial Strategy B:

  1. Impacted soil would be removed
  2. Groundwater plume would be treated in situ via amendment injections

Comparing the two strategies, the upfront cost of Strategy A is lower as there is no cost associated with groundwater treatment. However, as can be seen in the cost analysis of Strategy B, by removing the groundwater contaminant reservoir, the cost of groundwater monitoring and VI mitigation are eliminated. Future liability is also significantly reduced because exposure pathways to outlying properties would be cut off.

The Results

Based on projected cost savings, the client chose to implement Strategy B and long-term VI issues were eliminated by virtue of removing the groundwater impacts, and short-term VI mitigation implementation where there were known exposure pathways. Shortly after the remedial injections, PCE concentrations across the site sharply decreased while, as expected. While remediation is ongoing, post-injection PCE concentrations have remained at non-detect.

The total cleanup costs, including investigation and remediation efforts, was $1,450,000. By spending $200,000 upfront to remediate the groundwater, the client avoided long-term expenditures and achieved a lifecycle cost savings of $420,000.

Case Study 2: A Multi-Residence Site’s Remedial Approach Mitigates Vapor Intrusion and Saves $250,000

This multi-residence site had a large soil gas plume located deep in the soil. The contaminant plume was under a seven-story multi-family residential unit onsite and several residential buildings offsite. There was significant contamination onsite and the soils held very high vapor concentrations. There were complete VI exposure pathways at numerous offsite properties with basements, so interim measures were installed to mitigate risk during the investigation process.

Read more about vapor intrusion exposure pathways in “5 Things to Know about Vapor Intrusion, Your Home and Your Health”

These were the two remedial strategies considered:

Remedial Strategy A:

  1. The onsite building would be demolished
  2. Shallow soils would be excavated
  3. Institutional controls would be implemented to restrict groundwater usage
  4. VI mitigation would remain in place

Remedial Strategy B:

  1. The onsite building would be demolished
  2. Shallow soils would be excavated and stabilized with a chemical oxidant
  3. A soil vapor extraction (SVE) system would be installed

Neither remedial strategy included groundwater treatment since the primary concern was the vapor intrusion. With Strategy A, the costs are deferred, leaning towards keeping present-day dollars and instead opting to gamble on the costs of long-term liabilities and stewardship costs. With Strategy B, the upfront costs are significant, due primarily to the capital expenditure required for the installation and operation of the SVE system. The payoff is that the cost of long-term stewardship, VI mitigation, and potential future liabilities would be greatly reduced or eliminated altogether because the contaminant mass, and therefore the risk, would be removed.

The Results

Favoring a more aggressive remedial approach, the remediation plan that was implemented was Strategy B. The costs of the anticipated long-term stewardship program were significantly reduced from an estimated $195,000 to $15,000, requiring only occasional institutional control monitoring for groundwater usage. While the initial costs of the SVE were high, the system was well-engineered and achieved a remarkable radius of influence, successfully eliminating the liability posed by the vapor in the deep soil reservoir. Because the treatment removed the vapor, any VI concerns were alleviated.

The total cost of cleanup including investigation and remedial efforts came to $1,650,000. The major difference between the two strategies was the implementation of the SVE system which cost $450,000 in the short-term but garnered $250,000 in lifecycle cost savings by reducing the cost of long-term stewardship, VI mitigation, and potential legal damages.

Note that although strategy B is much cheaper, almost all of the money gets spent in the first two years, whereas in strategy A half the costs get deferred.

In these two case studies, you can see that there are situations when dry cleaners and real estate developers should take the full picture of risk management and future liability into consideration when planning for cleanup. It’s not always the wisest decision financially to do as little active cleanup as possible. Your environmental consultant and attorney should be showing you the whole picture and looking out for your best interests. Make sure they have the vision to do it for the long haul.

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

As seen in Cleaner & Launderer

Jeff Carnahan, President at EnviroForensics
Jeff Carnahan, LPG, has 20+ years of environmental consulting and remediation experience. His technical expertise focuses on the investigation and interpretation of subsurface releases of hazardous substances for the purpose of evaluating and controlling the risk and cost implications. He has focused on being a partner with the 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 are Polychlorinated Biphenyls (PCBs)?

In this article, EnviroForensics’ Senior Project Manager R. Scott Powell shares his expertise on PCB contamination, remediation, and mitigation, and provides a 101 introduction to this man-made organic chemical. Scott has worked on a variety of projects with PCB contamination across the Midwest.

Do you have a PCB issue?

Polychlorinated biphenyls (PCBs) are man-made organic chemicals that were manufactured from approximately 1929 through 1979 when they were banned. PCBs were included in the manufacturing process of many materials and incorporated into products during this timeframe. At that time, the health risks of PCBs were not well understood or commonly known. PCBs were desired for their non-flammable, chemically stable, high boiling point, and insulating properties. PCB containing equipment, materials, and oils were regularly managed without sufficient care causing personnel and environmental exposures.

12 chemical structures for dioxin-like PCBs. Source

In 1976, the United States (U.S.) Congress passed the Toxic Substance Control Act (TSCA), which included regulations on PCBs and included the ban on the manufacturing or use of PCBs and other chemicals after December 1979. Because of PCB’s extensive use in the electrical utility sector, Congress did leave a caveat in the TSCA rules that allowed for PCBs to be used in equipment in a “totally enclosed manner” such as a transformer.

After the 1979 ban on the manufacturing of PCBs and PCB containing equipment, the most common source of PCB contamination on properties was from spills and releases from old leaking transformers, capacitors, and other electrical equipment that were left in service after the ban. These were generally addressed in the 1980s through the 2000s. However, unreported historical spills are still encountered to this day due to the chemical stability of PCBs.

Other potential sources of PCBs on your property can be from old equipment or other legacy materials such as: building caulking, window glazing, waste oil tanks, hydraulic equipment, oil-based paints, fluorescent light ballasts, thermal insulation, adhesives, large compressors, asphalt roofing materials, floor finishing, pesticides, printing inks, and wood treatment chemicals.

What are the health risks of PCBs?

The most common exposure routes of PCBs are direct contact and ingestion. Direct contact is likely from areas of PCB spills or leaking PCB containing equipment. Ingestion can be from improper hand washing after touching PCB contaminated areas or the consumption of fish or game in PCB contaminated areas. PCBs are a bioaccumulating molecule that collects in organisms and biomagnifies, which means that concentrations become more concentrated as they travel up the food chain.

An example of biomagnification of PCBs in the food chain. Source

PCBs are metabolized by the monooxygenase system (human metabolism of drugs) causing toxicity and can bond to proteins, RNA, and DNA causing DNA breakdown. Known human effects include dermal lesions, respiratory problems, reproductive and developmental problems, endocrine effects (thyroid problems), liver damage, liver cancer, stomach cancer, intestinal cancer, thyroid cancer, cardiovascular problems, musculoskeletal problems, and neurological problems, to name a few.

What is the current state of PCB use and what are my exposures?

PCBs have not been included in the manufacturing of materials in the U.S. since the 1979 ban. However, legacy issues remain at many properties.

PCB containing equipment that was manufactured before 1979 was allowed to remain in operation as long as the equipment maintained the PCBs in a “totally enclosed manner”. Some of these pieces of equipment can still be found in operation today such as fluorescent light ballasts and electrical transformers.

This is a photo of a former oil-filled transformer that had leaked from an elevated pedestal in an industrial building.
This is a photo of concrete stained with PCB containing transformer dielectric oil.

Though some of the initial PCB cleanup actions concentrated on the most prominent and visible PCB oil spills, other materials have been found to be PCB sources at facilities. Building caulking that was manufactured in the 1950s through the 1970s readily contained varying concentrations of PCBs. Even after the 1979 ban, these materials were stored and sold years after the ban since they met the exceptions of being manufactured before the ban was in place. Therefore, some structures built in the 1980s were subsequently contaminated during construction with PCB caulk. The PCB in caulk has been shown to migrate into the adjacent building materials, and as the caulk weathers that can migrate down to the soil.

Until recently, a prominent practice with a lasting effect can still be found at some sites today, which consisted of spraying down gravel parking lots and drives with waste oil to keep the dust down. Many times these waste oils contained PCBs.

One of the most extensive PCB impacted media is sediments along waterways and coastal areas. PCBs applied and used on land for agricultural, commerce, or industry follow the surface drainage, sewer drain lines, and other sedimentation paths flowing along drainage pathways to water bodies. Waterways receive sediment from multiple sources and subsequently distribute contaminants along their flow paths. PCBs are hydrophobic, which means that they are heavier than water and do not degrade readily, so they tend to settle into the sediments and get picked up by bottom-feeding organisms, which allows them to follow the food chain up to the top predators.

The examples above outline some of the more common legacy issues that can be found on properties; however, there are many other potential pathways and sources for PCB exposure. Knowing the historical operations and maintenance practices on your property will provide some guidance on exposure risks.

Do I need to mitigate or remediate PCBs at my property?

Though PCB toxicity varies between the different PCB species (carbon, hydrogen, and chlorine combinations), the U.S. Environmental Protection Agency (U.S. EPA) looks at the total PCB concentration for regulatory risk assessment and material management. Under the self-implementing cleanup rules [40 CFR 761.61(a)], response actions for PCB impacts and wastes are based on the class of the material (such as bulk PCB remediation waste, porous surfaces, non-porous surfaces, and liquids) and the area occupancy time (such as low-occupancy or high-occupancy). Material class and occupancy should be determined by your environmental consultant following 40 CFR 761.61(a). As a rule of thumb, materials below the threshold limits can generally remain in place while materials that exceed their appropriate threshold limits may need to be mitigated or removed.

Below are some of the most common PCB impact conditions and risk mitigation approaches found today. If you have any of these situations present on your property, you should contact an appropriately trained environmental professional to address your specific site needs.

  • PCB impacts on non-porous materials like metal, glass, epoxy coatings, etc. may be able to be washed off and demonstrated through sampling to be “clean” requiring no further remedial action.
  • Porous surfaces like concrete, porcelain, brick, etc. may be able to be cleaned, but more likely than not, they will need to be sealed with a solvent resistant coating applied in two layers. When the PCB impacts of porous materials exceed 10 milligrams per kilogram (mg/kg), the material may have to be removed and disposed of appropriately.
  • PCBs in the soil can remain in place with no action required when concentrations in the soil are less than 1 mg/kg, but when the concentration reaches or exceeds 1 mg/kg the soil will have to be removed or covered with an engineered control such as “clean” soil or pavement. If the PCB concentration in the soil exceeds 10 mg/kg, then it may have to be removed and appropriately disposed of.
  • PCB containing equipment can remain in service as long as it is in good condition. PCB equipment noted to be leaking will have to be replaced. Property owners disposing of PCB equipment will need to do so at an appropriately licensed landfill.

In addition, property owners need to be cautious of PCBs in sewers since the TSCA regulations have a PCB discharge limit of 3 micrograms per liter (µg/L) for liquids and 3 micrograms per kilogram (µg/kg) for solids. Though you may have a gravel parking lot with total PCB concentrations less than 1 mg/kg, requiring no additional action, the surface sediment can be transported to the storm or sanitary sewers during rain events. If this is a potential condition at your property, the sewer sediment and water will need to be sampled. If the materials within the sewer exceed the discharge limit of 3 µg/L for water or 3 µg/kg for sediment, then mitigation and/or remediation actions would be warranted to cease offsite exposure.

Site conditions, property use, and negotiations with U.S. EPA through your trusted environmental consultant will dictate mitigation and/or remedial actions appropriate for your property through a self-implemented approach, a performance-based approach, or a risk-based approach.

R. Scott Powell, PE, Senior Project Manager

Mr. R. Scott Powell is a Senior Project Manager with over 20 years of environmental consulting experience. Mr. Powell’s expertise covers a wide variety of projects ranging from due diligence, LUST/petroleum, hazardous material remediation, asbestos, lead-based paint, remedial actions, to remedial systems. He manages complex relationships fostering the cohesive involvement of several parties on multiple sites with co-mingled contaminant plumes requiring the implementation of remedial solutions for chlorinated solvents, hazardous materials, and petroleum hydrocarbon impacts. He has extensive experience with environmental regulatory compliance, including Clean Water Act (CWA), Comprehensive Environmental Response Compensation Liability Act (CERCLA), Resource Conservation Recovery Act (RCRA), Superfund Amendments and Reauthorization Act (SARA), and Toxic Substance Control Act (TSCA). Mr. Powell manages negotiations with state and federal regulatory agencies, provides litigation support in matters concerning environmental issues, and acts as a third-party reviewer of work performed by others.

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.