December 22

EnviroForensics Obtains Three No Further Action Letters for Chlorinated Solvent Sites in 2015

2015 was a year of growth and success for EnviroForensics. We began construction on our new downtown Indianapolis headquarters, added 23 employees to our team, and made progress on numerous sites for our clients. We are particularly proud to announce that we obtained three No Further Action (NFA) letters for clients in the past year. Three may not seem like a very large number of closures, but keep in mind that releases of chlorinated solvents like PCE can be very complicated to assess.  Additionally, regulators scrutinize work on chlorinated solvent sites, as there are multiple exposure concerns to address on even fairly straightforward sites.

Client in San Diego, California

The first no further action determination we received was for a former dry cleaner operating as a drop-off shop in San Diego, California. The former dry cleaner was located in a tenant space in a strip mall. Corrective actions were required for the site by the San Diego County Department of Environmental Health (SDCDEH) due to the potential for vapor intrusion (VI) to occur at the dry cleaner. Because of this location, multiple parties were involved during the site investigation and remediation process. In addition, the strip mall became part of a real estate transaction during the remedial phase, which created additional objectives and time frames.

EnviroForensics was hired in 2005 by the responsible party after a Corrective Action Plan (CAP) submitted by a former consultant was approved by SDCDEH. Past operational activities had caused volatile organic compound (VOC) contamination beneath the building. The approved CAP recommended soil excavation combined with soil vapor extraction (SVE) throughout the remaining contaminated soils. Since active dry cleaning operations were occurring at the site at the time of the CAP approval, the CAP was implemented in stages to avoid disrupting business activities. An SVE system was installed in December 2007, expanded in October 2010, and retired in 2013 to prepare for the completion of the soil excavation activities.

The soil excavation activities included the removal of dry cleaning and steam pressing equipment, clothing racks, and piping to facilitate the indoor soil excavation. Geotechnical and structural engineers were brought in to assess the soil excavation plan. After remedial activities were finished, several rounds of indoor air samples were completed to mitigate any vapor intrusion pathways.

In February 2015, the SDSCEH issued a Case Closure Summary Letter to the site, allowing for the pending real estate transaction to be completed.

Client in Elkhart, Indiana

Another NFA determination was achieved for a client of ours in Elkhart County, Indiana. TCE was detected during a commercial property transaction in the groundwater on our client’s property. Never having used TCE in any of their operations, our client was perplexed.

Subsurface investigations begin in 2014, consisting of widespread soil and groundwater testing. Although TCE was found in the groundwater, no traceable sources were discovered on the site. We were able to provide several lines of evidence that showed the contamination was from an unknown up gradient source. In response, the Indiana Department of Environmental Management (IDEM) issued an NFA letter to the site in July, 2015.

Client in Jasper, Indiana

The third NFA letter we obtained was for a dry cleaner client in Jasper, Indiana. Our client began their operation in 1997 after converting the property from an ice cream parlor. Although there had been no evidence from historical records that dry cleaning operations had been conducted at the site prior to our client purchasing it, PERC contamination was found in soil and groundwater samples beneath the building in late 2012. Investigation and site characterization was performed, and in January 2014, we concluded that minimal chlorinated concentrations in soil and in the initial water-bearing zone were only located on a small area beneath the site.

We were able to prove that the contaminants were not migrating through groundwater or preferential pathways to offsite receptors or the river by using several lines of evidence. We requested that IDEM approve Site Characterization and recommended the site seek an Environmental Restrictive Covenant. In May 2015, IDEM issued a NFA letter to the site. Our client was looking to sell the business, and with this NFA status will be able to move forward and finalize the sale.