Category: Blog

Indiana Finds Elevated Levels of PFAS in Drinking Water at Nine Small Utilities

Posted on by Elizabeth Hemingway

BY: NICK HILL, LPG

The State of Indiana recently reported finding per- and polyfluoroalkyl substances (PFAS) or “forever chemicals” above the 2022 federal advisory levels at nine community public water systems (CWSs) in Indiana. The sampling was performed by the Indiana Department of Environmental Management (IDEM) to comply with the United States Environmental Protection Agency (USEPA) proposal in 2022 for monitoring PFAS in drinking water nationwide.  

A CWS regularly provides drinking water to at least 25 residents on a year-round basis or has at least 15 service connections to residents.  These new results from the IDEM are from the second round (Phase 2) of testing at 59 smaller CWSs (serving less than 10,000 residents) across the state from November 2021 to December 2022.  The nine facilities with elevated PFAS include: Delphi Water Works, Crescent Hills Mobile Home Park, Leavenworth Water Company, Westport Water Company, Haubstadt Water Department, And-Tro Water Authority – District 1, Troy Township Water Association, Indiana American Water – Farmersburg, and Sullivan-Vigo Rural Water Corp. 

The IDEM is planning to complete additional testing at larger CWSs (facilities that service more than 10,000 residents) before the end of May 2023. The results from both rounds of IDEM testing and the IDEM’s PFAS sampling schedule are available on the IDEM PFAS website.

As more testing is completed and publicly available data is released in Indiana, and across the nation, we will continue to assess the findings and provide additional interpretations and guidance to our clients on the potential risks associated with PFAS contamination.  

If you have PFAS questions, please contact us.

‘Air’ial Assault: How Contaminated Air From Past or Current Operations Can Impact Your Property & Surrounding Community

Posted on by Elizabeth Hemingway

EnviroForensics’  Vapor Intrusion and Mitigation lead shares his expertise on how contamination in the air from current and/or past operations may be impacting your property and community health. 

BY: JORDAN GOFF, LPG

Access to fresh air and water are required to sustain a healthy life and should not be taken for granted. Do you know if current and/or historical operations at your property are adversely impacting the breathing air within your building or nearby structures? If you have read EnviroForensics’ past articles, we have explained the basics of environmental contamination, how it impacts properties, and the process by which an environmental consultant like us can assist with investigating, mitigating, or remediating a contaminated property. In this article, I am focusing on explaining how contamination in the air from current and/or past operations may be impacting your property and nearby properties.

HOW ENVIRONMENTAL CONTAMINATION OCCURS

Let’s briefly review how environmental contamination can occur. Environmental contamination begins with a sudden and/or incidental release(s) of hazardous materials into the environment. These are referred to as “spills” and can occur in areas where hazardous materials are used. Perhaps it was a leaky connection to a drycleaning machine that dripped solvent for years, or a sudden accident where a container of solvent (virgin or waste) tipped over and released out the back door soaking into the asphalt parking lot or ground surface. These areas where contaminants are released are termed “source areas”. The contaminants in source areas can migrate downward in the subsurface due to gravity. Because the contaminant molecules from a spill can bind to soil particles, a source area can continue to release contaminants into the subsurface over time. Contaminants that migrate vertically can reach the groundwater and spread as they dissolve into the groundwater and migrate in the direction of groundwater flow. This is a common way for contamination to travel away from a source area and impact adjacent properties. So now that you know how a contaminant can be released and enter the subsurface environment; how exactly can this impact air quality?

HOW VAPOR INTRUSION OCCURS  

Drycleaning solvents like tetrachloroethene (PCE), also known as perchloroethylene or commonly referred to in the industry as PERC, are volatile organic compounds (VOCs). As these chemical compounds are volatile, they readily evaporate from liquid to vapor phase. Let’s take nail polish remover for example: as soon as you open the container you will smell the acetate in the air immediately. This is because acetate is volatile and readily evaporates from its liquid form to its vapor form when exposed to ambient air. The potent odor from the nail polish container, or PERC container within your building, is an indicator of the vapor phase quickly filling a room when a container is opened. Now if we consider a contaminant source area where PCE was spilled into the subsurface, we can understand that the material will readily evaporate, or ‘off-gas’, and the vapor phase will contaminate the surrounding subsurface air residing within spaces between soil particles. Given the characteristics of vapors, the contaminated air will migrate laterally and upward towards the ground surface. Contaminant vapors in the subsurface air will continue to spread outward as contaminants move from areas of high concentration to areas of low concentration.

As contaminants off-gas from impacted soil and groundwater, they can potentially produce a soil gas contaminant plume (or vapor plume) which is basically a subsurface ‘cloud’ of contaminated air. These soil gas plumes can accumulate beneath structures and enter the structure’s breathing air, this is commonly referred to as “vapor intrusion”. This can occur in a variety of structural settings, whether a structure is constructed over a crawlspace with a gap between the soil and floor of the building or if it is a concrete slab placed directly on the soil. Contaminated air from the subsurface can seep into the structure from the exposed soil of a crawl space or through cracks, floor drains, sumps, or other penetrations in a concrete slab. Depending on the contaminant concentrations of the vapor plume, breathing the indoor air impacted with contaminant vapors could adversely affect the health of occupants within the structure. Vapor plumes can exist in the subsurface and impact structures long after the spill and spread of contamination initially occurs. As contamination released to groundwater can allow contaminant to travel away from the source area, vapor intrusion can occur at structures well away from the initial source area of contamination as well. 

TESTING AIR QUALITY FOR VAPOR INTRUSION

These air impacts can go unnoticed as they are not typically concentrated enough to be observed by your sense of smell and require specialized sampling and analytical testing to evaluate the concentrations in indoor air. To ensure that property owners and residents near known source areas and vapor plumes are not being exposed to potential health risks from these vapors, it may be necessary to test the air quality.  Soil gas monitoring wells can be installed nearby known environmental contamination to evaluate the subsurface conditions in the area. If samples collected from soil gas monitoring wells indicate the presence of contamination at certain levels, then nearby structures may be further evaluated. Indoor air samples can be collected from within the occupied living spaces of structures to evaluate indoor air quality while samples can also be collected outdoor to evaluate the air conditions outside for comparison. In addition, small sampling points can be installed through the concrete slab of a structure, known as sub-slab vapor sampling points, and used to collect samples from beneath a structure. Evaluating the air conditions beneath the concrete slab aid in determining what can potentially enter the structure through the concrete slab or other penetrations. 

In addition to environmental contamination in the subsurface leading to vapor intrusion and contaminated breathing air withing structures, business operations can impact indoor air. We occasionally have our clients ask us if subsurface impacts can affect breathing air of structures, how are drycleaners able to use these solvents within their own facilities? And can actively using them present the same health issues to occupants in adjacent or nearby properties? 

Many industrial facilities like drycleaners legally use known hazardous substances to carry-out their manufacturing or other business operations. As hazardous substances can provide risk(s) to workers using certain products, the Occupational Safety and Health Administration (OSHA) requires proper communication of the substances used by the employer. This communication includes acceptable indoor air exposure levels of the chemical used in a business environment. 

Concentrations of the volatilized chemicals produced during business operations can permeate the indoor air and other materials/contents within the structure. The contaminated air within a building (generated from operations or vapor intrusion) will spread outward exhausting to the outdoors through doors, windows, exhaust fans, etc. at which point they migrate along with the general wind direction. Depending on the property layout and surrounding properties, this contaminated air could potentially infiltrate nearby structures’ breathing air, introduced through open doors and/or windows, or can even be entrained into ventilation systems of a nearby structure. In some scenarios where a facility may share a common interior wall with an adjacent business (like in a strip-mall for example), the air concentrations from materials being used in one business can permeate through the walls and/or above the shared ceiling or attic space into the adjacent business. Although adjacent spaces may have their own separate ventilation system and not have direct access to the area where the contaminated air is generated, air mixing can still occur and impact adjacent spaces.

As we previously discussed, OSHA permits a facility using hazardous materials to have certain concentrations of contaminants in the workers breathable air, but what about the breathing air of the adjacent business unit or the potential residential structure across the alley? The permissible levels allowed by OSHA are prescribed for workers, not for the occupants of nearby structures. When environmental investigations are performed, indoor air concentrations are compared to levels prescribed by the local and/or state government, or in some cases the Environmental Protection Agency (EPA). These levels are much lower, or more stringent, than OSHA levels as the occupants of these structures are not electing to work at a business or live in a residence that knowingly stores or uses hazardous chemicals. As one might imagine, this can be problematic for operators of facilities that use hazardous materials. Although they can maintain compliance within the work environment, the same air concentrations may not be in compliance if determined to be present in adjacent or nearby properties.

MITIGATING VAPOR INTRUSION

Now that I’ve explained scenarios by which past and/or current hazardous material storage, use, and releases can impact indoor air, you’ll be relieved to know that appropriate measures can be taken to mitigate the impacted air and ensure a healthy breathing environment. EnviroForensics has installed numerous systems, designed to mitigate the potential for unwanted contaminated air from entering the breathing air of a structure. For vapor intrusion scenarios, where unwanted vapors are entering the structure from the subsurface beneath a structure’s foundation, a vapor mitigation system can be installed. A vapor mitigation system is designed to interrupt the pathway by which vapors enter the breathing air. As structural foundations can vary, vapor mitigation systems can be comprised of multiple components, for example: active venting, passive venting, sub-slab depressurization extraction points, vapor barrier in crawlspaces, pre- and post-construction installations, vapor matting, etc. For scenarios where unwanted air generated from active operations is the issue, ventilation systems can be rerouted and/or modified to mitigate the issue. Once a system is in place, long-term operations, maintenance, and monitoring is often completed to continue to confirm the system(s) are operating as designed.  

Rest assured, EnviroForensics is here to assist you for if you have concerns that one of these scenarios may exist at your property. Our team of scientists have a wealth of experience at tackling complex environmental issues to aid in managing liability for clients and minimizing any potential threat or undue harm from air contamination in their communities. Contact us to learn more on how we can help you address your environmental risks in a business-friendly approach.  

As seen in Cleaner & Launderer

Federal Government takes further steps toward regulating PFAS, Forever Chemicals

Posted on by Elizabeth Hemingway

IF FINALIZED, IT WILL SET LEGALLY ENFORCEABLE COMPLIANCE STANDARDS FOR DRINKING WATER 

BY: NICK HILL, LPG

On March 14, 2023, it was announced that the Biden-Harris Administration will be proposing the first-ever national standards for six (6) per- and polyfluoroalkyl substances (PFAS) or “forever chemicals”. In addition, the U.S. Environmental Protection Agency (EPA) Office of Enforcement and Compliance (OECA) held its first of two public listening sessions to obtain general comments about their proposed plans for enforcement of PFAS under the Comprehensive Environmental Response Compensation and Liability Act (CERCLA) and the financial obligations for responsible parties of PFAS contamination to further their development of a CERCLA PFAS enforcement discretion policy. Both actions build on President Biden’s PFAS pollution action plan and the EPA’s PFAS Strategic Roadmap, which were started over two years ago with the objectives of controlling and addressing PFAS pollution and holding PFAS polluters accountable to safeguarding public health, and advancing environmental justice.  

If finalized, the Biden-Harris Administration proposal would regulate two (2) compounds, PFOA and PFOS, as individual contaminants with an enforceable level, or maximum contaminant level (MCL), of 4 part per trillion (ppt). Additionally, four (4) other PFAS (PFNA, PFHxS, PFBS, and GenX Chemicals) would be regulated as a mixture. Their combined levels in water systems would be evaluated via a hazard index calculation to determine the potential risk. Furthermore, if this new drinking water regulation is finalized, public water systems would be required to monitor these chemicals, inform the public if PFAS levels in the drinking water exceed the new standard, and take action to reduce the PFAS levels. The EPA is now seeking input on this proposal by holding a public listening session on May 4, 2023, and accepting written comments before making a final ruling. The pre-publication version of this proposal is linked here.  

In another step, the EPA OECA held a public listening session that centered on the financial obligations of responsible parties as part of developing a CERCLA PFAS enforcement discretion policy. During this session, the EPA stated its intent to focus enforcement actions toward the PFAS manufacturing/discharging entities and suggested that it is considering allowing for exemptions to specific entities that “passively” receive or secondarily use materials that may potentially contain PFAS contamination. The list of potentially exempted entities currently consists of solid waste landfills, public water sources and public owned treatment works (POTW), farmers who apply biosolids, and fire departments and airports of municipal, state, and tribal sectors. While many commenters expressed appreciation of the EPA’s progress and consideration of exemptions, others found the EPAs plans to be unclear, specifically regarding the potential effects on stormwater permits, how municipal water suppliers will manage and fund PFAS treatment, and the potential for third party liability against the exempted services. The topic’s next EPA listening session will be held virtually on March 23, 2023.  Recordings for both listening sessions will be available via the EPA website here after the March 23, 2023 session.  

While these two proposals present progress, additional questions arise on the future of PFAS regulation implementation and the potential financial obligations and risks to municipalities and other sectors. For instance, we do not have a clear understanding of who will be held responsible for funding the cleanup of PFAS contamination via the aqueous film forming foam (AFFF), a.k.a. firefighting foam, releases at many airports and fire departments, since the EPA is proposing to exempt these entities. Based on the U.S. EPA’s prior comments, it is possible they would hold the manufacturer responsible for some costs, but the lines of evidence to demonstrate responsibility have yet to be defined, and there is a risk that municipalities and airports have not retained appropriate purchase records if needed. Additional potential risks include the responsibility of known exposures. Though the U.S. EPA is proposing some exclusion to responsibility for the cleanup of PFAS releases, the management of known and continued releases, such as POTW discharges, will likely require long-term mitigation and management.  

Despite these unknowns, some relief can be felt as funding addresses emerging contaminants like PFAS through the recent passing of President Biden’s Bipartisan Infrastructure Law. This law allows the distribution of $10 billion over the next five years to help make drinking water safe in affected communities.

Those who used or interacted with PFAS during their business operations can face a variety of environmental exposures due to PFAS. Those insured should look into their historical commercial general liability (CGL) policies that may aid them in paying for the investigation, remediation, and legal defense of PFAS claims.

As the regulations for these emerging contaminants develop, we will continue to keep our eye on the factors that may affect our clients.  

*In Indiana and New Mexico, policies issued after this time period can also respond to environmental claims. Contact us to learn more.

No Need to Close Your Doors to Cleanup Contamination

Posted on by Elizabeth Hemingway


LEARN HOW ENVIRONMENTAL CLEANUP DOES NOT HAVE TO BE A BUSINESS DISRUPTION 

Is your consultant listening? As consultants, we evaluate cleanup strategies based on the contaminant, site conditions, and their cost effectiveness. But what about what works for you? Has your consultant asked about your business operations and what cleanup approach works for you? Your interests need to be part of the cleanup plan. For example, many of you have heard the distressing stories of a dry-cleaner taking heavy financial losses because the environmental cleanup required the business to shut down. It’s bad enough to shut a business down at all, but I’ve stories where businesses were shut down for several weeks or more. As you know, once a customer finds another cleaner, getting them back typically doesn’t happen. However, this does not have to be the case. Businesses can maintain operations while having their environmental remediation needs addressed. 

INVASIVE REMEDIAL TECHNOLOGIES

Many invasive remedial technologies proposed to cleanup a source area or contaminant plume concentrate heavily on the most efficient approach to remove the contaminants. Often, they do not incorporate business needs of the building occupant into the remedial implementation plan, which leads to a financial hardship for the business owner. Invasive remedial technologies such as excavation, thermal extraction, soil vapor extraction (SVE), air-sparging, ozone-sparging, multi-phase extraction, and other remedial systems with above grade components can be very effective in meeting remedial objectives but may not be appropriate to meet your business needs. A good environmental consultant will incorporate your businesses operational needs into the remedial plan and work with you to identify an approach that is non-invasive, or at least minimally invasive so business operations can continue with minimal disruption.  

In a typical invasive event to install SVE and sparge wells, a drilling rig needs to access your interior space. These drilling rigs take up a lot of your business operational surface area and typically requires the equipment pertinent to your business to be moved or removed from the building entirely. This approach can require numerous well points to be installed since the effective radius of influence is centered on each point. Each of those points must be piped to the system trailer. These above ground pipes can take up more surface space and interferes with your business operations after the installation is done.  

NON-INVASIVE AND MINIMALLY INVASIVE REMEDIAL TECHNOLOGIES

Business friendly, non-invasive remedial technologies can alleviate the stress to your business, your staff, and yourself. These approaches can include some of the same technologies identified above, implemented in a way that does not interfere with your operations. A common and effective non-invasive approach is to use horizontal drilling techniques to install the SVE and air-sparge system components. The horizontal drill rig sets up access points outside the building, and space permitting, at a distance from the building to not interfere with your customer traffic. A horizontal drill rig can bore multiple lines from the same access point. These lines can be horizontally and vertically distributed to optimize well placement. Additionally, horizontal wells can have a greater area of influence from just one well screen installed along the target zone than the traditional vertical well method. Standard vertical well installation requires multiple well locations in a line to influence the same area as one horizontal well. The use of horizontal drilling methods can allow the business to stay in operation throughout the remedial system installation event. Additionally, there will be no encumbering piping components inside the building during remedial system operation.  

There are also minimally invasive remedial techniques that can be implemented to reduce the impact to business operations. Conducting remedial action through chemical and/or microbial injections can limit the time needed to access your business operational space. In comparison to an excavation event that can take a week to months and required significant if not complete access to your business space, an injection event can be completed in a couple days. It is possible to use small hand-cart size rigs that can maneuver around your business equipment limiting the need to stop business operation. The injection approach uses specifically designed mixtures to treat the impacts below your business operations. To reduce the chance of subsequent injections events, your environmental consultant can work with suppliers to careful design and tailor these chemical and microbial mixtures to meet site-specific conditions, which can increase the remedial rate and success of remedial actions at your property, reducing the chance for follow up events.  

Limited trenching is also a minimally invasive approach in comparison to others. Instead of trying to remove the contaminants via excavation or injections with a high density of locations, the installation of perforated pipes in the subsurface for an SVE or vapor mitigation system along accessible paths within your building could be sufficient to remediate the contaminant mass. An appropriate design could be installed in a short timeframe and allow for continued business operations during installation. Simple actions such as placing plywood over open trenches until the piping and backfill can be placed and the floor resealed will allow your business to continue operations through the installation.  

As with everything, cost is king. That is no different with environmental remediation and alternative remedial approaches. Therefore, a cost benefit analysis is a critical part of the assessment process. For example, horizontal drilling is much more costly per foot than conventional drilling. However, the cheaper cost of a conventional drilling approach compounded by the loss of revenue may be significantly more than selecting the expensive horizontal drilling operation that allows you to keep your business doors open during installation.  

Learn how to be a good neighbor during an environmental cleanup on a drycleaning property.

There are many different approaches to implement a business-friendly remedial action, those reviewed above are just a few. Your consultant should bend over backwards to minimize business interruption. Whether that requires working at night or over the weekends when your operations are closed or using hand equipment instead of mechanical drills and machinery, there is almost always a workaround. Your environmental consultant should listen to you and be able to provide you a comparison summary of different remedial approaches, the rough costs for each approach, anticipated timelines, and potential business interruptions for each approach, if any. In the end, there is no one answer that solves the “best approach” concern, but with the right environmental consultant by your side, you should be able to find the least restrictive approach that allows the remedial objectives to be met and keeps you financially stable with minimal business disruptions.  

Every project is different, every property owner has unique concerns and needs, and these environmental demands that interfere with your business are not fun or what you want. We are here to help make your environmental cleanup event as easy as possible.  Contact us to learn more on how we can help you address your environmental risks in a business-friendly approach.  

As seen in Cleaner & Launderer

Author: R. Scott Powell, PE, LPG, Regional Director 

R. Scott Powell has 20+ years of environmental consulting experience. Powell’s expertise covers a wide variety of projects ranging from due diligence, site investigations, assessment of appropriate remedial technologies, to remedial system installation, operations, and maintenance. Powell’s experience includes sites with co-mingled contaminant plumes, chlorinated solvents, polychlorinated biphenyls (PCBs), perfluoroalkyl and polyfluoroalkyl substances (PFAS), petroleum, metals, asbestos, lead based paint, and various other hazardous materials. He manages complex relationships and fosters cohesive involvement of responsible parties and regulatory agencies. Powell manages negotiations with state and federal regulatory agencies and provides litigation support in matters concerning environmental issues.

EnviroForensics to Present Research Findings at Battelle Chlorinated Conference 2022

Posted on by Alex Miller

THREE ENVIROFORENSICS SCIENTISTS PRESENTING AT INTERNATIONAL CONFERENCE ON CHLORINATED SOLVENTS AND RECALCITRANT COMPOUNDS

Three EnviroForensics scientists will present the results of their current research projects at this year’s Battelle International Conference on Remediation of Chlorinated and Recalcitrant Compounds. The conference is considered the signature forum for the environmental remediation industry and will feature the largest technical program to date with over 1,300 platform and poster presentations on the schedule.

“Scientific innovation and excellence form the foundation of our environmental remediation service lines. A mainstay of scientific work is peer review, and Battelle’s 2022 Chlorinated Conference gives us the opportunity to share what we have learned and receive valuable feedback from the remediation community,” said EnviroForensics President, Jeff Carnahan. “We believe that our application of cutting-edge environmental investigation and remediation approaches keeps our clients at the top of the list of regulated closures each year, particularly at chlorinated solvent sites. We are excited to collaborate and learn at the Chlorinated Conference this year.”

This year’s presentations by R. Scott Powell (PE, LPG), Brian Kappen (LPG), and Michele Murday Pariso (Project Geologist), cover current remediation topics like the study of dilution to improve injection-based remedial treatment, targeted soil excavation with a passively dispersed reductive amendment in a source area over fractured bedrock, and the use of horizontal colloidal activated carbon permeable reactive barriers to control vertical mass loading into a sandstone aquifer. Read our summaries below.

WHEN DILUTION IS THE SOLUTION TO POLLUTION: HOW MOBILIZING DNAPL RESULTED IN A MORE SUCCESSFUL INJECTION-BASED REMEDIAL TREATMENT APPROACH
BY: MICHELE MURDAY PARISO AND COLLIN MARTIN (ASH UNION)
EnviroForensics designed and directed implementation of in-situ treatment of solvent contamination at a former drycleaning facility in Northwest Indiana. The remedial approach consisted of source area reagent injections and installation of a permeable reactive barrier (PRB). The Site logistics played an important role in this plan, as a down-gradient right-of-way provided a buffer zone between the site and off-site properties that allowed for the limited migration of the diluted source area DNAPL after the first injection event. Following a second injection event in 2021, groundwater monitoring data indicate a substantial reduction of the remaining source area mass, and no breakthrough of contamination has been detected beyond the down-gradient PRB.

CAN LESS REMEDIATION BE MORE EFFECTIVE? COMBINING TARGETED SOIL EXCAVATION WITH PASSIVELY DISPERSED REDUCTIVE AMENDMENT IN A SOURCE AREA OVER FRACTURED BEDROCK
BY: R. SCOTT POWELL
Extensive remediation was needed at a site in Northeast Indiana with high concentrations of tetrachloroethene (PCE) source material located directly over fractured bedrock. This contaminant mass was leaching directly into unconsolidated and bedrock groundwater, resulting in an elevated dissolved phase plume that migrated offsite. A multi-faceted (and costly) remedial approach would be needed to reduce both the vadose zone source area contaminant mass and the dissolved phase contaminant mass within the bedrock fractures.

Soil excavation was selected as a cost-effective remedial option to remove the source area vadose soils overlying the fractured bedrock, but excavation of deeper saturated soils and fractured bedrock was not a feasible or cost-effective option. Therefore, a soil reagent was applied to the bottom of the excavation by specialized methods prior to backfilling to promote 1) abiotic degradation within residual saturated soils and bedrock interface impacts, and 2) enhanced reductive dechlorination (ERD) in the natural groundwater environment for prolonged dissolved phase contaminant mass reduction. The effectiveness the remedial approach has been demonstrated through enhanced reducing conditions, PCE breakdown products, and abiotic markers in groundwater samples collected to date, with additional groundwater monitoring to continue during 2022.

USE OF A HORIZONTAL COLLOIDAL ACTIVATED CARBON PERMEABLE REACTIVE BARRIER TO CONTROL VERTICAL MASS LOADING INTO A SANDSTONE AQUIFER
BY: BRIAN KAPPEN AND KEITH GASKILL (REGENESIS)
A novel approach for reducing mass loading of chlorinated volatile organic compounds (CVOCs) to a sandstone aquifer was implemented at a site in Southern Wisconsin. Glacially-deposited material and a fractured dolomite unit overly a sandstone unit, creating a complex hydrogeological system. The CVOCs moved vertically through the unsaturated overburden into the dolomite, spreading through it and migrating into the sandstone. These conditions formed a 30,000 square feet area of contaminant mass loading, resulting in a mile-long CVOC plume in groundwater.

Direct treatment of contamination in the dolomite would not be effective due to the clay-filled fracture network. Rather, a horizontally-oriented colloidal activated carbon (CAC) permeable reactive barrier (PRB) was applied to remove contaminants from the dissolved phase and reduce the vertical migration of CVOCs into the sandstone. Nearly 100,000 gallons of CAC mixture were injected via a network of 21 specially designed and positioned injections points to form the horizontal PRB. Post-application monitoring has demonstrated reduced CVOC mass loading to the aquifer, and compound-specific isotope analysis (CSIA) of groundwater samples indicates that CVOC biodegradation will continue to occur in the absence of any further remedy. Based on these results, the overseeing agency has agreed that the site is ready for regulatory closure.

CHLORINATED 2022 CONFERENCE INFORMATION
These and over 1,000 other posters and presentations will be on display at the Twelfth International Conference on Remediation of Chlorinated and Recalcitrant Compounds in Palm Springs, California, which runs from May 22-26.

Learn more about our innovative environmental investigation and remediation capabilities.

___________________________________________________________________________

Michele Murday Pariso, Northwest Indiana Branch Manager
Michele Murday has more than nine years of experience in environmental consulting with a focus in investigation and remediation projects involving dry cleaners, lead, and petroleum impacts. Michele has been responsible for the management of numerous projects throughout various stages of investigation, remediation, and closure ranging from $1,000 to $5,000,000. Michele has directed numerous subsurface investigations of varying size and employed a variety of remedial technologies, including soil excavation, multi-phase extraction systems, vapor mitigation, soil mixing, and chemical injections. Michele’s experience includes data analysis and interpretation, reporting on all phases of projects from investigations through closure, preparing 3D site visualizations, proposal scoping, project management, due diligence research, and risk communication. She has also worked closely with clients, subcontractors, and municipalities, as well as state and federal regulators.

Scott Powell, PE, LPG, Senior Project Manager
R. Scott Powell has 20+ years of environmental consulting experience. Powell’s expertise covers a wide variety of projects ranging from due diligence, petroleum, hazardous material remediation, asbestos, lead-based paint, to remedial systems. He manages complex relationships and fosters cohesive involvement of PRPs on multiple sites with co-mingled contaminant plumes requiring the implementation of remedial solutions for chlorinated solvents, hazardous materials, and petroleum hydrocarbon impacts. Powell manages negotiations with state and federal regulatory agencies and provides litigation support in matters concerning environmental issues. Powell has been responsible for the overall management and administration of environmental projects ranging from $1,000 to $3,300,000.

Brian Kappen, PG, Senior Geologist, Project Manager
Brian Kappen has 15+ years of experience in environmental consulting with a focus on contaminated site management. His diversified professional experience includes research, proposal scoping and budgeting, preparation of work plans and reports, project management, geologic and hydrogeologic data collection, vapor intrusion assessments, data analysis and interpretation, remedial action evaluation, and implementation of remedial actions. Kappen has served in supporting and management roles on numerous investigation and remediation projects regulated by state, RCRA and CERCLA programs, primarily involving chlorinated solvent impacts. Kappen has also been involved with several Phase I and Phase II environmental site assessments and served as a field team leader for a comprehensive two-year environmental baseline study at a remote mine prospect in Michigan.

Are PFAS a Drycleaning Problem?

Posted on by Alex Miller

THERE IS AN EVOLVING QUESTION AS TO WHETHER PFAS IS A DRY CLEANING PROBLEM. A RECENT FLORIDA STUDY STARTED TO ANSWER THIS QUESTION. THIS ARTICLE WILL FOCUS ON WHAT PFAS ARE AND SUMMARIZE SOME OF THE FLORIDA STUDY RESULTS AND WHAT IT MIGHT SAY ABOUT DRY CLEANERS AS A SOURCE OF PFAS.   

BY: BRAD LEWIS & ROB HOVERMAN 

If you have not heard of Perfluorooctanoic Acid (PFOA), Perfluorooctyl Sulfonate (PFOS) and other perfluoroalkyl substances (PFAS) yet, you will soon. For brevity, we will refer to these groups generically as PFAS plural. PFAS are a broad group of chemicals widely used in manufacturing and found widespread in the environment. The 2019 movie Dark Waters starring Mark Ruffalo and Anne Hathaway featured one of the first and highest-profile lawsuits regarding PFAS. PFAS are emerging contaminants that the United States Environmental Protection Agency (USEPA) is attempting to regulate. Some states like Michigan, Wisconsin, Florida, and New Jersey have gotten out in front of the USEPA and have established state regulatory limits for a small number of the more commonly used compounds.  

WHAT ARE PFAS?
First, the “what”: PFAS are part of a broad chemical group first developed in the 1940s. Since then, manufacturers have introduced over 4,000 PFAS compounds into the production of consumer goods both as primary and secondary components. Some of these compounds are being phased out due to toxicity concerns; however, manufacturers are developing new fluorinated compounds like Gen X and ADONA to replace them. Many PFAS are banned from use and import in manufactured goods in the United States. 

Well known for their unique chemical properties, PFAS repel oil and water and resist temperature, chemicals, and fire. These are the attributes that make PFAS attractive and are why so many durable industrial and everyday products like non-stick surfaces, firefighting foam as a flame retardant, stain resistant fabrics, water repellent coatings, and plating demisters contain PFAS. 

The chemistry is complex because PFAS are not one chemical compound; they are a class of chemical compounds that share the common carbon-fluorine bond. The carbon to fluorine bond is one of the strongest bonds in organic chemistry, making PFAS compounds particularly resistant to degradation and therefore cleanup. Since they do not break down and they have widespread use, they are being found everywhere in the environment.   

SOURCES OF PFAS
The USEPA advisories in the May 25, The USEPA first announced PFAS health advisories in the May 25, 2016 Federal Register. Since then, numerous updates and significant research has been published by USEPA, State Agencies, and private researchers. After which, State regulatory agencies began pushing primary and secondary industries into investigate for PFAS. To date, most of the investigations and cleanups have centered on both the manufacturers of PFAS compounds and military airports. The three general sources of PFAS impact on the environment include:    

  • Primary: Manufactures of PFAS Compounds  
  • Secondary: Manufactures of Items with PFAS or direct use of PFAS compounds  
  • Tertiary: Use/Disposal of PFAS containing products  

The manufacturers of the PFAS compounds generally include the large chemical manufacturers that have been the subject of much regulatory scrutiny and private litigation. The secondary group includes all the industrial and commercial processes that directly applied these chemicals to products or processed materials previously coated. Dry cleaners that offered the application of stain-resistant coatings containing PFAS fall within this second group but also fall within the third group.    

The third group is comprised of all consumer and commercial use and disposal of PFAS treated products. The potential for PFAS impacts to the environment from this third group is probably least understood. This third group is where dry cleaning may have its most significant exposure for PFAS impacts since dry cleaning byproducts (spent solvent, lint, still bottoms, etc.) have had contact with PFAS containing textiles.  

We know historically dry cleaners accidentally released solvents to the environment, but how much PFAS were in these spent solvents? Studies from Toronto University have shown fast fashion items contain high levels of PFAS and other contaminants at levels that cannot be coincidental. When these PFAS laden clothes are washed, PFAS can accumulate in the various waste streams and mechanical vents at dry cleaners. Additional studies show that cosmetics also contain high levels of PFAS. Clothing with cosmetics stains may also contribute to low level accumulation of PFAS in facilities that would concentrate wastes. That is to say, dry cleaners, through filtration processes, concentrate PFAS, which may then enter the environment incidentally near waste storage and vent discharge points at dry cleaning and laundry facilities.   

Learn more about testing for PFAS and the available remediation methods  

TESTING OF DRYCLEANING SAMPLES
The Florida PFAS study evaluated both virgin and spent dry cleaning products from seven (7) Florida dry cleaning facilities. Virgin cleaning products at two of the seven facilities contained detectable concentrations of PFAS. One facility had a small detection of PFAS in a dry-cleaning machine cleaner and the other facility had a more substantial detection in a virgin petroleum-based solvent mixed with soap. Some virgin dry cleaning products do contain PFAS. The take-away message for you is to ask your chemical supplier for details on what is in your incoming products.   

PFAS were detected in dry cleaning wastes (spent solvents, solids, filters) in six out of seven of the facilities tested. PFAS compounds on treated fabrics clearly come off the fabrics during the cleaning process and are concentrated in the resultant waste products. Although use of some of these compounds have been phased out years ago, you can probably expect to see this continue for a while.   

The Florida study went even further and evaluated PFAS in virgin and spent products from seven wet laundry facilities. One out of four laundry detergents contained PFAS at relatively low levels. However, PFAS were detected in every wastewater discharge sample analyzed.   PFAS clearly come from treated clothing even during a wet laundry process, although to a lesser extent than from dry cleaning. One interesting finding of the study that speaks to the ubiquitous nature of PFAS is that they were detected at low concentrations in the incoming potable water at most of these facilities.   

TESTING OF SOIL AND GROUNDWATER
In the Florida study, ten sites with known dry cleaning solvent contamination (chlorinated and petroleum based) were evaluated. Eight of these sites had undergone some level of remediation. Samples of soil and groundwater were collected and submitted for analytical testing for 28 PFAS and GenX compounds. PFAS compounds were detected in groundwater at all ten sites. While the presence of PFAS seemed to correlate to the presence of PCE there was little correlation between concentrations of PFAS and PCE. This is likely due to how these compounds behave in the environment.  

The study did identify four sites where it appears there was PFAS entering the site from an off-site source. Again, given PFAS widespread use and their propensity to not degrade, this is not entirely unexpected. However, even at these four sites, there was evidence of PFAS contribution due to the releases of dry cleaning products.   

Similar results were seen in soil samples collected and submitted for laboratory analysis.  Although all the soil sample detections were below levels deemed safe by Florida for direct exposure, they were above levels that have the potential to impact groundwater above safe levels.   

Dry cleaners inadvertently introduce PFAS compounds through the chemicals they use. Going forward it’s important that dry cleaners document the PFAS content of incoming chemicals from your suppliers and if possible avoid PFAS containing products. What is clear is that the dry cleaning process itself introduces PFAS into your waste streams by extracting them off of the stain-resistant garments. How big of a problem this will be for the dry cleaning industry is unknown as the science and regulatory framework surrounding PFAS is evolving.   

RESPONDING TO REGULATORY REQUESTS
Should someone ask you to sample for PFAS compounds at your site, what should your response be? First and foremost, your response should be a cautious one made with input from a qualified consultant and potentially legal counsel. It should be clear under what authority the demand is being made and what some of the ramifications might be should PFAS be found on your property. If the decision is made to proceed, you will want to consider:  

  1. What PFAS compounds am I being asked to sample for? 
  2. What analytical methods will be acceptable to the entity asking for these results? 
  3. To what criteria will the results be compared to? 
  4. Are there other sources of PFAS surrounding my property? 
  5. Will my consultant control the accidental introduction of PFAS into environmental samples?   
  6. What are the consequences of not responding?  
  7. Is any of this data confidential? 

THE CONSEQUENCES OF A RELEASE
Currently, it is difficult to say what will be required should you discover a release. One thing that is certain is that the cleanup of a PFAS release, to likely very low cleanup standards, will not be easy. The amount of research into PFAS cleanup being conducted at this time by commercial and private companies is staggering. Promising interim technologies are being developed by the not-for-profit Batelle research organization and others. It is likely that the best solution will present itself in a technology yet unknown to us at this time.  

Because of PFAS chemical structure, they are recalcitrant and do not lend themselves to many of the chemical and biological processes traditionally employed to remediate dry cleaning solvent plumes. Research is being conducted but as of now, there are few in place options for soil and groundwater remediation. The physical removal of the compounds from soil and groundwater is, for now, likely the best remediation option. Excavation of soil and the pumping and treating of groundwater are two ways of physically removing PFAS from the environment. Physical removal of these compounds creates waste products that need ultimate disposal. Heat destruction of these waste products offers promising results; however, the temperatures required are difficult to achieve and economically unsustainable. 

Find out why PFAS are so difficult to remediate, and why they’re known as “forever chemicals” 

CONCLUSIONS
The Florida study indicates that PFAS may well be an issue at drycleaner cleanup sites. Prior to implementing any sampling efforts that may put you in the liability hot seat, make sure you are thoroughly engaged with a consultant and legal counsel that can outline your options.   

The USEPA will within the next two years establish certain PFAS as a hazardous substance, which will make it easier for them to regulate. Without the hazardous substance designation from the EPA, investigations and remediation vary by State. PFAS sampling is more expensive than traditional environmental sampling and because the remedial options are limited and the regulatory framework is still up in the air, your long-term costs and liabilities are difficult to predict.  

Contact us with your questions about PFAS 

As seen in Cleaner & Launderer

Brad Lewis, CHMM, Principal Scientist
Brad Lewis is a detailed-oriented and collaborative environmental professional with over 24 years of environmental consulting experience. Brad has a Master’s Degree in Environmental Science and is a Certified Hazardous Material Manager (CHMM) with expertise that covers a variety of projects ranging from due diligence, environmental compliance, Brownfields, underground storage tank, and chlorinated hydrocarbon investigations and cleanups.  Because of his strong analytical chemistry background, Brad has implemented many innovative site investigation strategies including the use of mobile laboratory, and immuno-assay to characterize sites. Brad is a member of the Midwestern States Environmental Consultants (MSECA) organization and took part in MSECA’s work group advising the Indiana Department of Environmental Management (IDEM) on revisions to the Remediation Program Guide. 

Brad manages large chlorinated hydrocarbon sites with large, deep, groundwater plumes that impact overburden, bedrock, and surface water resources.  To these projects he brings a keen understanding of contaminant fate and transport and an ability to develop a thorough conceptual site model.  This includes development of 2-dimensional and 3-dimensional visualizations of site lithology, hydrogeology and plume characteristics. 

He provides strategic planning of the technical and regulatory approach on most EnviroForensic projects.  This includes evaluation of new and innovative remedial technologies and changing regulatory and business climates. Brad facilitates communications between the responsible party, project managers, counsel, regulators, and the affected residences.    

Rob Hoverman, LPG, Northern Midwest Regional Director
Rob Hoverman is the Northern Midwest Regional Director and a registered professional geologist with more than 19 years of professional environmental services with a focus on contaminated site management. Rob currently serves as senior project manager for several projects in Indiana and Wisconsin.  His diversified professional experience includes research, scoping and budgeting, project management, data analysis and interpretation for both hazardous and non-hazardous substances, including compounds such as chlorinated solvents, petroleum-related constituents, as well as metals. Rob has managed numerous investigation and remediation projects regulated by state programs, and his responsibilities involved every aspect of projects from proposal preparation through project closure, regulatory negotiations and stakeholder communications.  Beyond technical evaluation and interpretation duties include obtaining contract approval, job initiation, budgetary analysis, budget tracking, and subcontractor contracting and management. Rob has also served as technical support for numerous vapor intrusion including soil gas, sub-slab, indoor air sampling and mitigation.  As the Regional Director for EnviroForensics, Rob maintains momentum and resources for Wisconsin projects.   

Everything a drycleaner needs to know about environmental contamination

Posted on by Alex Miller

A COMPREHENSIVE GUIDE TO OUR ENVIRONMENTAL RESOURCES FOR DRYCLEANERS AND PROFESSIONAL LAUNDERERS

We’ve discussed a lot of topics pertaining to drycleaners over the years, and I hope that the information has been helpful. There has been the full gamut of information regarding the process of dealing with contamination related to drycleaning operations. The primary focus, of course, has been on how to manage liabilities and costs associated with a subsurface release of Perc. The focus has been here, largely due to the fact that Perc releases are the most complicated, the most expensive to remedy, and present the greatest amount of risk to owners and operators of drycleaning facilities and associated properties.

It is so important to find a scientifically and strategically sound technical representative to guide you through the process of evaluating the extent of your contamination problem, and to help you choose the right remediation approach. If you’re just getting started in the environmental closure process, or you want to revisit my advice on making sure you have the right help, you’ll find some ideas in this article.

I wrote about the subsurface investigation process in these articles:

Sometimes it can be confusing or frustrating that it takes a long time to get your arms around a sizeable soil or groundwater plume. The above articles should give you a better understanding as to why it’s so complicated.

We also discussed remediation technologies and regulatory closure strategies in these articles:

There is a lot of information in these articles related to risk-based closures and more active closures. You may recall that a risk-based closure is one where a primary mechanism for regulatory closure is a demonstration to the agency that there is no direct human exposure or harm being done as a result of the contamination’s existence. These approaches are fine to get closure, but they don’t actually cleanup your property to a significant degree. EnviroForensics has also done a substantial amount of data research and analysis that show once you factor in the cost of long-term monitoring to ensure that exposure control methods remain viable, active cleanup approaches that remove contamination from the property are actually cheaper than risk-based approaches.

We explored the wide range of legal risk that the owner and/or operator of a former Perc shop may have to contend with as a result of an environmental release from your plant or someone else’s in these articles:

When the stigma of environmental contamination at a drycleaner site gets out in front of actual investigation and cleanup, operators and owners are subject to a whole host of different types of legal liability from multiple sources.

The high cost of cleaning up and dealing with a Perc contamination problem has been covered in many of the articles I’ve written for The Cleaner & Launderer, but expense was the focus in these articles:

You know as well as I do that those decisions based on impact to the profit and loss statements are a huge part of any business. The fact remains that the investigation and cleanup of environmental contamination caused by a release of Perc is extremely costly. Look through these articles again and ask yourself what your plan is going to be if you discover a Perc problem.

Updates on developments in the environmental world that are impacting drycleaners were provided in these articles:

Time marches on, folks, and I know it may not always seem like it, but the science related to the toxicological effects of chemicals we are exposed to gets better all the time. New contaminants of concern and revised health-based cleanup levels will be a constant moving forward.

As industry trends and reader input turned an interested eye toward business succession plan topics, we also spent some time talking about the environmental aspects of this process in these articles:

When you stop and think about it, nearly every old environmental problem is related to buying, selling, or owning a piece of property. Maybe not yours; but someone’s. The intentional or accidental transference of environmental liability along with commercial real estate is one of the driving forces behind the entire environmental industry. It was designed that way as a method of ultimately evaluating all old industrial properties. Please get help during a property transaction. You may think you understand the game, but the playbook is complicated, and you can only score big if you stay on offense.

Finally, I’ve tried to sprinkle in some of my own commentary related to drycleaners and how our clients have worked through the gut-wrenching decisions that they must make when they decide to take-on a contamination issue headfirst in these articles:

Listen, I get it. Nobody wants to poke the bear. Ya’know….my mother was an amazingly pragmatic woman. What she told me often was, “It is what it is,” and “You gotta do what you gotta do.” When it’s time to do what you gotta do, give me a call. We’ll help you through.

Contact us with your question about the environmental cleanup process.

As seen in Cleaner & Launderer

EnviroForensics Director of Brownfields and AgriBusiness becomes first environmental consultant to graduate from AgrIInstitute’s Agricultural Leadership Program

Posted on by Alex Miller

MORGAN SALTSGIVER LOOKS FORWARD TO SERVING ENVIROFORENSICS’ AGRIBUSINESS AND MUNICIPAL CLIENTS WITH A CLEAR UNDERSTANDING OF THE CONNECTION BETWEEN AGRICULTURE AND COMMUNITY

EnviroForensics’ Director of Brownfields and Agribusiness, Morgan Saltsgiver, LPG, has graduated from the AgrIInstitute’s highly acclaimed Agricultural Leadership Program and has become the first environmental consultant to do so. Morgan was specifically selected to the program for her perspective on environmental issues that the agricultural community faces.

Morgan looks forward to leveraging her experiences to better meet the needs of EnviroForensics’ clients in rural communities across the Midwest. “My main takeaway from the program is that I was constantly reminded how closely agriculture and community are connected. We learned so much about the role of local government, the importance of rural broadband, divisive topics in the agricultural industry, and how the health of Indiana’s farmers has much broader implications than just on the farm,” Morgan says.

The cornerstone of the AgrIInstitute’s programming is the Indiana Agricultural Leadership Program (ALP), which is the only class of its kind in the state. As a part of the ALP’s curriculum, Morgan, and her colleagues—who represent a wide variety of viewpoints and perspectives—met with lawmakers in Indianapolis and Washington D.C. to discuss big issues impacting agricultural communities and hash out solutions for the future. “Getting these opportunities to develop agricultural and governmental partnership connections, while gaining a true understanding of the connections between agriculture and the community have been invaluable,” she said, “I look forward to applying this expertise through continued Brownfields redevelopment support for our communities.”

Morgan has worked in the environmental industry for over 18 years specializing in providing Brownfields redevelopment, agribusiness, and traditional environmental consulting services. She also serves as the current president of the Indianapolis Chapter of the National Association of Women in Construction (NAWIC) and immediate past president of Midwestern States Environmental Consultants Association (MSECA).

Learn more about how our expertise at EnviroForensics can help your community meet its environmental needs.

How to manage environmental risk through historical and modern insurance agreements

Posted on by Alex Miller

LEARN WHICH TYPES OF INSURANCE POLICIES ARE MORE FAVORABLE FOR BUSINESS OWNERS WITH DIFFERENT ENVIRONMENTAL CIRCUMSTANCES

BY: JEFF CARNAHAN

The strategic avoidance of risk through insurance agreements was contemplated as early as the Babylonian Empire over 6,000 years ago. The history of applying insurance products directly to environmental contamination risks isn’t quite as ancient; but the sequence of identifying environmental risks and developing insurance products to offset those risks has been ongoing since environmental contamination was first perceived and understood several decades ago. Insurance products from the 20th Century are still being used today to pay for environmental cleanup of old releases, and modern insurance policies are being created to address the threat of a new environmental release, the threat of legal action being taken against a policyholder due to environmental issues, or the threat of encountering unknowns during remediation projects that can threaten your cleanup.

INSURANCE PRODUCT OFFERINGS AND ENVIRONMENTAL COVERAGE
The development of new insurance products by the carrier market is an iterative process. As new risks are identified, the insurance market develops new products, or policies to sell to their policyholders to help manage those risks. The insurance products that commonly apply to old environmental releases are commercial general liability (CGL) policies. Commercial General Liability Policies are those that nearly every business purchases to help them in the case of a lawsuit or damage that could be related to just about anything, so long as it’s not excluded by the policy. Those CGL policies were typically written such that only the occurrence needed to exist within the policy term. The claim could come later. So, let’s put that in the perspective of an environmental incident. If somebody at a company with a CGL policy accidentally knocked over a drum of solvent out back in 1960, there was an occurrence, but there was no regulatory agency in existence that would make a demand for anything to be done about it. There was no liability associated with that spilled solvent, but the occurrence happened, and it happened during the term of a CGL policy. It was only later after environmental agencies began enforcing their new regulations and laws that a liability to do anything about environmental releases was created. So, you can see how a spill in 1960 didn’t really turn into a liability until, perhaps, 1970 with the formation of the Environmental Protection Agency (EPA), or 1980 with their creation of a significant Act that defined environmental responsibility. By the early 80’s there were environmental liabilities for sure. Since the CGL policies written in 1960 to a premium-paying policyholder was occurrence based, a liability that was applied in 1982 could constitute a claim that could be tendered against that old occurrence-based policy. Depending on the language written into the policy, historical CGL policies may be used for legal fees, defense against lawsuits, site investigation, remediation/cleanup, interim remedial measures, building a legal case, potentially responsible parties (PRP) search, and interfacing with regulatory agencies in response to an old environmental release.

Learn more about the different environmental services old CGL policies can pay for.

As insurance companies started getting a bunch of environmental claims tendered against their old CGL policies, they started putting exclusions in their new CGL policies around 1985 or 1986. That means that releases that occurred after 1985 or 1986 were most likely excluded from coverage under those policies. The insurance industry then developed contemporary insurance products that were and are intended specifically to manage risks in the environmental arena.

CONTEMPORARY ENVIRONMENTAL RISK MANAGEMENT PRODUCTS
As pollution issues were being excluded from CGL policies, new types of policies were being created by insurers to specifically cover pollution related problems. For those industries, like drycleaning, where the risk of an environmental release is real for some operators, the insurance industry now offers specific pollution coverage that can be triggered to respond to accidents, or even cover currently unknown pre-existing conditions. Site Pollution Policies or Pollution Legal Liability are for cleanup of pollution that has occurred on the insured’s own site, or if it runs off into a neighbor site. The next most important coverage is for third-party bodily injury and property damage and associated defense costs. They won’t cover first-party damages, like your own employees or first party property, but just third party. Included in that is diminished value of potentially diminished value of neighbors, neighboring properties, matched coverage for natural resource damages, and coverage for things like civil fines and penalties.

If you send your wastes to non-owned disposal sites, like when a waste vendor comes and collects your spent filters and waste barrel, and if one of their disposal facilities becomes a Superfund site you can be protected by pollution insurance. If your waste or product is being transported by your own employees, which shouldn’t happen, or by third party and there’s a pollution release, then the same coverage is applied.

A significant difference about pollution legal liability policies is that their coverages are claims-made based, not occurrence-based coverage. This means that the claim must be made during the policy term or during the extended reporting period. Coverage can be provided for both sudden and accidental and gradual pollution conditions. Coverage can also be provided in certain circumstances for known pollution conditions. Interestingly, these policies can cover both preexisting and new pollution conditions, so a pre-existing condition, like we discussed earlier, is easiest to cover it if it’s unknown and happened in the past and you purchase insurance covered for pre-existing conditions for a site. Pre-existing conditions are where the spill or release occurred prior to policy inception, so these can be very helpful and flexible policies that can be tailored to the insureds specific needs. Usually, they are purchased for one to three years, three years being the sweet spot, but these types of policies can be purchased for terms as long as 10 years.

Other coverages that are provided are coverage for natural disasters, so if there is a windstorm or a flood and it causes a pollution release, that resulting pollution would be covered. Coverage is included for mold Legionella and in some circumstances can be included for asbestos, lead-based paint, PFAS, disinfection of mold and Legionella and things like virus and bacteria can also be covered. Nearly anything you can think of can really be covered by these policies as far as contamination goes. You just have to work with your insurance representative, who will help you put together one or more policies that include the specific coverages you need to protect your business.

Watch the webinar: “Insurance to help manage remediation costs and risks”

Our company works with policyholders who have purchased either non-specific environmental protections from old CGL policies, or specific environmental liability related protections from contemporary policies. As a result, we have a good working knowledge of how these policies work, but please consider the information presented here as a very broad overview of the types of coverages that may be available to you to help manage your environmental liability. I strongly suggest that you reach out to a specialty insurance product agent or broker and start a discussion about how they may help. You will get the precise information that you need. There are several reputable insurance professionals who work closely with the drycleaning industry, so ask a friend or post a question on the  .

Start a conversation with us today about how to manage your liabilities using insurance.

As seen in Cleaner & Launderer

Headshot of Jeff CarnahanJeff Carnahan, President
Jeff Carnahan, LPG, has 24+ 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 been a partner of the drycleaning industry for the past decade and is a frequent contributor to the national drycleaning publication Cleaner & Launderer. He is an industry leader in understanding that environmental risk

Morgan Saltsgiver starts second term as Indy NAWIC President

Posted on by Alex Miller

ENVIROFORENSICS DIRECTOR OF BROWNFIELDS AND AGRIBUSINESS EXCITED TO LEAD INDIANAPOLIS CHAPTER OF NATIONAL ASSOCIATION OF WOMEN IN CONSTRUCTION FOR A SECOND YEAR

Morgan Saltsgiver, Director of Brownfields and AgriBusiness has officially started her second term as President of the National Association of Women in Construction’s (NAWIC) Indianapolis Chapter. NAWIC is an organization that has supported women in construction with professional development, education, networking, leadership training, and public services for more than 55 years. 

Morgan says she’s excited to continue her leadership position and feels very strongly about NAWIC’s role in welcoming more women into the construction industry and providing them with a support system for them to succeed. “NAWIC is a place where we provide our members with opportunities to collaborate, connect, and construct together. For me, being a member and serving on the Board of NAWIC has been an uplifting experience – our chapter gives us the opportunity to build each other up and challenge each other to be the best leaders we can be in the construction industry,” says Morgan. 

The 2021-2022 Indy NAWIC Board, From Left: Jennifer Arvin, Parliamentarian, Jamisyn Rodimel, Immediate Past President, Caitlin Poe, Corresponding Secretary, Emily Byl, Recording Secretary, Megan Gumbel, Treasurer, Tierra Maesch, Vice President, Morgan Saltsgiver, Chapter President, April Brown, Director, Emily Lucas, Director, Jordyn Nelson, Director, Baylee Nowicki, Director, Michelle Roberts, Director, Tereissa Sauer, Director, Julie Van Horn, Director, Faith Walters, Director. 

Morgan says she’s looking forward to continuing to work with the 2021-2022 Indy NAWIC Board. “It’s going to be a busy year of serving our membership and their needs alongside this great group of women leaders,” Morgan said.

Morgan was previously named Foremost Leader by NAWIC’s North Central Region, which includes 15 chapters throughout Pennsylvania, Ohio, West Virginia, Kentucky, Indiana, and Michigan. Morgan says, “I have learned so much through my six years of membership and am looking forward to being a career-long member of NAWIC!”

Morgan has worked in the environmental industry for over 16 years specializing in providing Brownfields redevelopment, agribusiness, and traditional environmental consulting services. She has also served as the President of the Midwestern States Environmental Consultants Association (MSECA), and recently finished up her leadership certification with the AgrInstitute Agricultural Leadership Program.

To learn more about Morgan, visit her company profile.