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 December 2014 issue of Cleaner & Launderer

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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”

Vapor Intrusion or Process Emissions – Help Me, Help You

Written by Stephen R. Henshaw, President & CEO, EnviroForensics

As seen in the August 2014 issue of Cleaner & Launderer

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I’ve talked a lot about vapor intrusion over the past few years. Vapor intrusion occurs when volatile organic compounds (VOCs) in soil and groundwater off-gas and migrate into occupied buildings and store fronts. The need to conduct vapor intrusion sampling is often times the result of VOCs in the soil and groundwater. Typically a vapor intrusion assessment will include collecting sub-slab soil gas samples along with the collection of indoor air samples. This paired sampling, as it is often times referred to, is designed to show two things: 1) whether or not there is contamination in the subsurface soil gas sample that could create a vapor intrusion issue; and 2) whether or not there are concentrations of VOCs in the breathing air that could be attributable to the subsurface contamination.

I want to tell you this because if it is determined that vapor intrusion exists and VOCs are migrating from the subsurface into occupied building structures, you as the responsible party for the subsurface impacts, would also be responsible for mitigating those vapors. Additionally, the identification of a vapor intrusion issue in buildings not owned by you could lead to the potential for third party litigation should it be determined that people have been breathing contaminated air. Continue reading “Vapor Intrusion or Process Emissions – Help Me, Help You”

RISK BASED SITE CLOSURES SHOULD INCLUDE REMEDIATING THE SOURCE AREA

Written by Stephen R. Henshaw, President and CEO of EnviroForensics & PolicyFind
As Seen in the March 2014 issue of the Cleaner & Launderer

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The environmental remediation industry has been in full swing for the last 35 years, but it has only been in the past few years that the regulatory agencies have come to accept risk-based closures as a practical cleanup strategy. In the recent past, cleanup criteria was established for hundreds of individual chemical constituents for soil, surface water and groundwater. The cleanup criteria was based on the toxicological risks assigned to each of the chemical constituents and then further divided into different land-use scenarios (e.g. residential, commercial, wetlands, etc.)

This process made it easy for people to know what the target cleanup objective would be. That is not to say that there was not frustration over the toxicological science that was used to establish the cleanup criteria, but, because the closure numbers were laid out on a table, it made the discussion with the regulatory agencies black and white.

Continue reading “RISK BASED SITE CLOSURES SHOULD INCLUDE REMEDIATING THE SOURCE AREA”

Vapor Intrusion – A Concern, but an Easy Fix

Written by Stephen R. Henshaw, President and CEO of EnviroForensics & PolicyFind

As Seen in the January 2014 issue of the Cleaner & Launderer

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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”

Increased Attention To Dry Cleaners Likely Under New Property Due Diligence Requirements

Written by Steve Henshaw, President & CEO, EnviroForensics

As seen in the December 2013 issue of Cleaner & Launderer

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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”