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 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”
Written by Steve Henshaw, President & CEO, EnviroForensics
As seen in the December 2013 issue of Cleaner & Launderer
On November 6, 2013 ASTM E1527-13 became official as the guidance standard used by environmental consultants for conducting Phase 1 Environmental Site Assessments. Environmental Site Assessments are required by banks and lenders before those entities loan money on real estate holdings and they are designed to identify potential or existing environmental liabilities associated with the subject properties. The reason that this is important to dry cleaners is that the new guidance puts greater emphasis on assessing the potential impacts from vapor intrusion and vapor migration on the property. In fact, the definition of a “release” within the guidance has been changed to include contamination in the subsurface vapor phase, in addition to the soil and groundwater.
Continue reading “Increased Attention To Dry Cleaners Likely Under New Property Due Diligence Requirements”
Written by Stephen Henshaw, P.G., President & CEO, EnviroForensics
As seen in the October 2013 issue of Cleaner and Launderer
Over the years, environmental regulations have gotten more and more restrictive. The permissible levels of chlorinated solvents in groundwater, soil and indoor air continue to be pushed lower. While the acceptable level of PCE in indoor air was actually increased by the federal government, the acceptable level of TCE (a breakdown product of PCE) was drastically lowered, which has resulted in an increase of Sites posing a public health risk. It is the vapors, which contain volatile organic compounds from releases of cleaning solvents or gasoline, which is posing the greatest risk to people living or working near the Sites where the contaminants were released. The regulatory requirement to evaluate the fate and distribution of these contaminated vapors into homes, apartments, schools, and businesses is raising the publics concern and could create the perception of risk and with those perceptions associated concerns and fears of health effects.
Continue reading “DEALING WITH THE PERCEPTION OF RISK; THE VALUE OF HAVING AN EFFECTIVE COMMUNICATIONS PLAN”
Written by Stephen Henshaw, P.G., President and CEO, EnviroForensics
As seen in the September 2010 issue of Cleaner & Launderer
You’ve found solvent contamination at your facility and its impacted groundwater or an adjacent property. You are probably thinking, not only is it costly to address the contamination, but it could also ruin my good business reputation. Have you ever thought that cleaning up environmental contamination could be good public relations? It can, it’s a matter of selling the right message to your audience.
Clearly, one has to be careful in how you are addressing your contamination issue. Most people’s biggest concern is that their neighbor’s property will have contamination on it or that vapor intrusion is going into their neighbor’s home or business and that the neighbors will sue them. While that may be a possibility, I’ve been conducting environmental investigations for a long time (ok almost 30 years, I’m old) and I rarely ever see that as an issue. When it is an issue it’s almost always happens in reverse. A lawsuit is filed by a party or group of people against all of the parties that owned the property or business where contamination is allegedly emanating from. It is rarely that a drycleaner conducts a cleanup and they are now being sued. While PERC dry cleaning solvent is considered a known carcinogen, it is generally very difficult to attribute a person’s adverse health condition to PERC exposure. That is to say that if someone that has cancer was exposed to PERC, they have likely been exposed to other chemicals that are also carcinogenic, making the direct link between the alleged PERC exposure and the health effect more difficult to legally prove. Continue reading “Environmental Cleanup Can Be Good Public Relations”