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    Mike Tartanella
    Life expectancy of dry cleaner chemicals (and...
    Topic posted January 31, 2012 by Mike TartanellaMember, last edited February 9, 2012
    907 Views, 13 Comments
    Title:
    Life expectancy of dry cleaner chemicals (and specifically tetrachloroethylene)
    Content:

    Does anyone know of any studies regarding the ultimate life expectancy of dry cleaning chemicals and of course  tetrachloroethylene?  It has always been my policy that all on-site dry cleaning operations are a REC except for a very few select physical scenarios.  We come across many historical dry cleaners that stopped operations in the late 60s-early 1970s and are now entering the 40+ year gap since the source was active and the question is:  will there ever be a time frame when a historic dry cleaner is no longer an issue or has there not been evidence yet that provides that answer.

    Comment

     

    • PWoloszyn
      posted February 1, 2012 by PWoloszynContributor

      Hello Mr. Tartanella,

      I know of many studies that aim to address the life expectancy (fate and transport) of dry cleaning chemicals as a contaminant in the environment including subsurface soil and groundwater.

      I do not know of any research project that concludes with results specific to: "will there ever be a time frame when a historic dry cleaner is no longer an issue ...." I believe that there is no evidence yet that can provide that answer with confidence.

      I am aware of scientific and ancedotal evidence that strongly indicates each unique dry cleaner must be investigated on its own merits, back to the general beginning time period that tetrachloroethylene (PCE) was introduced in the USA as a dry cleaning chemical (circa 1930's).

      I strongly suggest that your steadfast policy "... that all on-site dry cleaning operations are a REC except for a very few select physical scenarios" remain in place.

      Additional details available upon request.

       

      Pawel Woloszyn, President

      Pacific Environmental Management, Inc.

      415-710-5708

      Real Estate Environmental Risk Management

      There is No Substitute for Experience

       

       

       

       

    • ZekeF
      posted February 1, 2012 by ZekeFContributor

      To build on the previous post:  The half-life of any released hazardous substance is based on many variables.  Is it in the soil or the groundwater, what type of soil, is it oxygen rich or not, etc.   Not to mention you wouldn't know the contaminant mass that was released.  It makes a big difference if it was a small release or if they were releasing large amounts of PCE continuously for 40 years.  

      Also, PCE is fairly resistent to degradation/biodegradation and thus has a relatively long half-life in groundwater.  Especially compared to substances like gasoline.  I've found gasoline related contaminants above cleanup criteria 30 to 40 years after last use.  I'm sure others have found it after even longer in the right conditions.

      To answer the original question, I don't think it will happen any time soon.  Even if you get to the point where PCE was last used 100 yers ago, there are to many variables (such as contaminant mass) to be able to say it wouldn't be a problem.  I don't think I would conclude that a gas station wouldn't be a problem either after 100 years.  To many variables.   

      Does anyone out there feel comfortable making a decision regarding ANY historical use of the property based on age?  I've seen in done in a report for a gas station before.  But that report also said that they didn't know exactly where the gas station would have been (address change, but highly likely it was on site), so it wasn't a problem.  

    • mkulka
      posted February 1, 2012 by mkulkaElite Contributor

      I investigated an adjoinng offsite plant that had ceased operations in the 60s and was greated with a foot of DNAPL.  I agree we will not see this happen in our lifetime.

    • Richard Dagnall
      posted February 1, 2012 by Richard DagnallMember

       Mike,

      If I remember my chemistry correctly, another problem with tetracholoroethylene is that the degradation products are also carcinogens, trichloroethylene, dichloroethene and vinyl chloride. 

    • Show/Hide Replies
      Mike Tartanella
      posted February 1, 2012 by Mike TartanellaMember

      Thanks everyone who has responded to my query.  I hadn't heard of an end life to dry cleaning chemicals but I wanted to reach out via this forum to make sure.  From the responses here, it appears that it will be quite a few decades before we can even think about answering such a question.  I have to battle borrowers (and our account officers) all the time with this specific issue, so in a sense it is comforting that it is very definitive in terms of current theory and practice.  Thanks again.

      • Tom Speight
        posted February 1, 2012 by Tom SpeightElite Contributor
         You, me, and probably everyone else on this forum.... A lot of our clients have got their heads pretty well around the idea that petroleum breaks down, so it's another challenge to educate them that some things DON'T go away like that. We cleaned up an old gas station once, and did a dry cleaner for the same guy's brother. The brother was a little perturbed that the tiny dry cleaner on his property was a more costly cleanup than the other guy's whole gas station.
      • PWoloszyn
        posted February 1, 2012 by PWoloszynContributor

        Oh yes, the persistent battle with your borrowers and account officers. One tool that can be powerful to support your position is to find real world examples of dry cleaner sites within your geographic areas of lending that meet your criteria (stopped operations in the late 60’s – early 70’s) and have a significant investigation and cleanup liability. There should be plenty of state and local databases available.

        The most useful databases will give you brief site histories in a project summary plus access to reports and correspondence for the listed projects via the internet. Within these documents, you can find further descriptions of operating histories, site conditions, investigation and cleanup requirements, vapor intrusion considerations, etc.

        Other databases may give you brief descriptions of operating histories but not provide access to related project documents. Those would require more work = in person review of the selected project files.

        The most basic databases will just give you a listing of investigation and cleanup sites. Here again, in person review of selected project files would be required.

        In addition to state and local databases, US EPA Envirostor could be a useful resource.

        In California, we have some v.good state databases available via the internet: the State Water Resources Control Board (SWRCB) GeoTracker and the Department of Toxic Substances Control (DTSC) EnviroStor.

        It could take some work but your efforts should provide rewards far into the future.

    • mkulka
      posted February 1, 2012 by mkulkaElite Contributor

      It is unfortunate that we have to defend our professional and technical results/opinions so often.  That is the nature of the beast in the environmental due diligence world sometimes.  It is funny how some of these same types relish the slightes concern if there are brownfield incentives to be gained if it is contaminated.

    • Show/Hide Replies
      Trey Hess
      posted February 2, 2012 by Trey HessMember

      About as long as a Muncipal Landfill.... Therefore, based on Subtitle D Financial Assurance Requirements, that should make it a fixed 30 years regardless of size, geology, etc.

      • RobE
        posted February 2, 2012 by RobESuper Contributor
         I would refrain from linking the 30 year Financial Assurance Requirements found in RCRA Subparts C or D to fate and transport of drycleaning solvents in the environment. That is a slippery slope. I know there are some pre 1982 PCE/TCE/DCE/VC plumes out there!
    • Tom Speight
      posted February 3, 2012 by Tom SpeightElite Contributor

      Actually, I'm aware of one plume in my area that probably dates to the 1950s and still has concentrations > MCLs in four towns, including the opposite end of the plume.  The stuff had migrated at least three miles from the apparent source zones by the time municipal well testing begain in 1980, and they found TCE left and right.  The main source areas are some old burn-and-bury sites  GE had used back in the 50s, and which then had residences built on them.  Fortunately we don't have many big sandy unconfined aquifers around here....

       

      I may be mistaken, but I thought the rationale for the 30-year period for financial assurance was that by the time 30 years went by they'd be certain whether a problem existed or not, not whether the problem would have gone away by then.

    • PWoloszyn
      posted February 8, 2012 by PWoloszynContributor

      The classic story of Peter Pan … Cleaners. The attached 11 page pdf includes the original regulatory agency documents.

       In 2008, the CA Regional Water Board sends a letter request for information:

      “… currently working on two cases … where PCE discharges to groundwater have occurred. The sites are both identified as Peter Pan Cleaners … currently in the process of identifying all legally responsible parties for the necessary investigation and cleanup of contaminated soil and groundwater….

      With regards to Peter Pan #1, we know that a dry cleaning facility operated from 1949 to 1966 … It operated until approximately 1966 when the plant was moved to Peter Pan #2. We are interested in knowing …

      The PCE discharge at Peter Pan #1 was discovered during preparation of a City utility project. The extent of contamination has not been investigated. The PCE discharge at Peter Pan #2 was discovered when a private water supply well was tested and confirmed to be impacted…. the PCE plume extends beneath the Steele Lane Elementary School.”

      In 2008 and 2009 the Regional Water Board sends additional letters requesting information.

      In 2011, the Regional Water Board sends a next letter:

      “The purpose of this letter is to inform you as the current land owner … and request a work plan to investigate the extent of groundwater impacts …”

      Of course, these projects are just beginning. Check back in … 10 – 15 years for further update.

      Peter Pan Cleaners.pdf (891KB)
    • R Scott Powell
      posted February 9, 2012 by R Scott PowellElite Contributor

      Everyone has already covered the basics of chlorinated VOCs above.  In my mind, a dry cleaner is always a REC.  Even the new ones that have epoxy floors and secondary containment, potentially have irresponsible people working for them.  The natural attenuation parameters of Cl-VOCs changes from parent to daughter products, and PCE & TCE degrade better in anoxic conditions, which your less likely to encounter in the vadose zone and surficial aquifer.  Therefore, these DNAPLs sink, even through clays, before degrading … if they degrade (got to have the right bugs).  As outlined in the examples above, Cl-VOCs hang around for a long time.