Written by Stephen R. Henshaw, President & CEO, EnviroForensics
As seen in the December 2014 issue of Cleaner & Launderer
The latest wrinkle in the cleanup process of sites contaminated with chlorinated solvents (PCE and TCE) is in understanding how long the site, and those sites downgradient, will need to be monitored when complete contaminant removal is not possible and potential human exposure remains. Generally speaking, the more contamination left in place, the longer the site will need to be monitored. I want to tell you this because the cleanup costs that will be generated for your site, will be greatly affected by two things; 1) the removal of contaminated soil and groundwater in the source area and 2) the long-term monitoring requirements (how many locations need to be monitored and for how long). If you are not aware of these two big issues, you are not looking at the full picture and you could be unwittingly reviewing cleanup cost estimates that may have been prepared using the old “bait and switch”.
Let me make no bones about it, the environmental consulting industry is highly competitive and like many purchases consumers make, price is a large factor when you select a consultant to clean up environmental contamination. Nowhere is this price more susceptible to variation than in asking for the consultant to give a true site closure cost estimate. The most important thing to understand about what I am telling you is that you know to ask the hard questions about the provided cost to closure and don’t get caught up in hearing what you want to hear. Consultants don’t enjoy being the bearer of bad news and they realize that they might be competitively shopped, especially if the provided costs are higher than the party paying for the contamination expects. Consequently, the consultant may try to soft pedal the remediation costs. I refer to this as, “telling people what they want to hear”. I see this all the time, particularly when insurance companies are responsible for paying for the cleanup. Continue reading “Long-term Stewardship of Contaminated Sites, Vapor Intrusion Mitigation and Monitoring Fit the Requirements”
Written by Stephen R. Henshaw, President & CEO, EnviroForensics
As seen in the November 2014 issue of Cleaner & Launderer
“How clean is clean”, has been a phrase that has been debated for decades. It is used in reference to determining the degree to which a site that is contaminated by chlorinated solvents such as PCE (Perc) and TCE, needs to be cleaned up and remediated before the site is deemed to be free of environmental encumbrances. Commonly this clean up level is based on concurrence from the regulatory agency overseeing the site. When the regulatory agency determines that cleanup levels have been satisfactorily demonstrated, they will issue a No-Further-Action (or equivalent) letter. But not all site closures are equal, nor in the best interest of the property owner.
I want to tell you this because obtaining site closure may not avail a property owner with property that can be marketed and utilized to its fullest value, even constricting future land uses. I want to tell you this because most people are so afraid of the environmental contamination that their focus is on getting the site closed. By putting the site closure focus ahead of the future value may leave a property owner with a long-term management problem and an under preforming asset. If property owners do not think about the future land use and long-term monitoring requirements of a property, they could be restricted to use the property for a specific land use (e.g. industrial or commercial) by way of a deed restriction that is placed on the property for generations to come. The property owner could be required to manage contamination left in place by having to ensure that the deed restriction is enforced. They could be required to maintain the operation and maintenance of a vapor mitigation system for as long as twenty to thirty years after site closure. They might even find that a bank is not willing to lend on the property, restricting the use of the property as collateral for fear of future changes in the law or potential future third party personal injury or property value claims.
Continue reading “HOW CLEAN IS CLEAN MAY DEPEND ON HOW CLEAN YOU NEED IT TO BE”
Written by Stephen R. Henshaw, President and CEO of EnviroForensics
As Seen in the May 2014 issue of the Cleaner & Launderer
Cleaning up soil and groundwater contamination from a release of chlorinated solvents, such as tetrachloroethylene (PCE) and trichloroethylene (TCE) can be a time consuming and complicated process. That’s why it is so important for you to build the right team to represent you during this process. That team should understand what your business plans are and your schedule for implementing those plans. Dealing with environmental contamination is a crossroads of where you have been and where you are going with your business and your future. It can be an opportunity that forces you to make decisions that you may not have considered, like, “What do I want to do with the business? What about the property?” If you don’t develop the right team, you could spend a great deal of money addressing the cleanup without having a road map as to what to expect. If you do not have the right team you could have business interruptions from drilling activities, and face a parade of activities that seem never ending. With the right team, you don’t need to become an expert on environmental matters – that’s what you have them for. They’re the experts and they communicate with you so you know what’s going on without needing to take chemistry classes. You should be able to focus on your business, while your team focuses on how to move your project through the site closure process.
The most important thing to understand about this concept of building the right team, is that the team must represent the outcome that you desire, within your expectations, and the team that you rely on needs to be strong enough to give you the truth and their best professional opinions, even when the news is bad. The second most important point is that your team needs to have a good working relationship with one another. Your consultant and your attorney need to be on the same page as to the Site Closure strategy. Depending on the business owner’s future plans, site closure strategies might vary significantly. Your strategy might be to sell your business, but while the property is being remediated, you can’t. You may own the property and want to refinance it, but most banks are reluctant to loan on the property as long as it is impaired. You may have no immediate plans to change your business at all and you just want to control the outflow of cash while you focus on growing your business. These are all different business scenarios that I’ve seen and they all directly affect the site closure strategy. Continue reading “Remediation of PCE and TCE in Impacted Soil and Groundwater Requires Teamwork and Coordination”
Written By: Steve Henshaw, President and CEO of EnviroForensics in collaboration with Keith Gaskill, Senior Geochemist, EnviroForensics
As seen in the February 2014 issue of Cleaner & Launderer
When scientists evaluate how to best cleanup groundwater that has been contaminated with chlorinated solvents, such as perchloroethylene (perc) from a drycleaner or trichloroethene from a manufacturing facility, the option of in-situ treatment is considered. If the subsurface conditions are favorable, in-situ (or in-place) remediation can have a lot of advantages to other remedial alternatives.
One of the most common in-situ approaches is the use of bioremediation and reductive dechlorination. The advantages to using in situ bio-remediation or reductive dechlorination technology are that a liquid can be injected into the subsurface using a small drilling rig while there is minimal business interruption. There is no need for an active treatment system involving a trailer or stationary shed with electrical pumps, compressors and treatment tanks. There is no trenching for conveyance lines and electrical wires. There are no costs for routine operation and maintenance, electrical power, or monitoring telemetry. Other advantages to using in situ bio-remediation are that the product is relatively inexpensive, readily available and it is safe and easy to handle. In-situ treatment is particularly favorable when remediating a contaminated groundwater plume that has migrated away from the Site where the release occurred.
Continue reading “Enhanced Reductive Dechlorination It’s A Matter of Give and Take”
Written by Stephen R. Henshaw, President and CEO of EnviroForensics & PolicyFind
As Seen in the January 2014 issue of the Cleaner & Launderer
Those of you who have read my past articles, have heard me speak, or have ever looked at EnviroForensics’ website, know that we specialize in helping dry cleaners work through the regulatory and insurance maze of investigating and remediating soil and groundwater impacts caused by the release of percholoroethene (PCE). The EnviroForensics team takes pride in helping to solve environmental problems for the dry cleaning industry; and over the past 18 years, we have helped more than 400 dry cleaners.
So much has changed since I started working with dry cleaners. The laws and regulations enforced by the regulatory agencies, the cleanup technology, and the perceived human health exposure of vapors, known as vapor intrusion, are continually changing and evolving. It seems that the only constants are that dry cleaners are targets and continue to be blamed when PCE is found in soil and groundwater. PCE is considered a risk to public health, contaminated soil and groundwater makes property transactions difficult to complete, and cleaning up PCE in soil and groundwater is expensive. Oh, and old CGL insurance policies continue to be one of the saving graces for dry cleaners when faced with the daunting reality that they have been named as a party responsible for PCE contamination. Continue reading “Vapor Intrusion – A Concern, but an Easy Fix”