Historical Dry Cleaners: How Can These Things Even Be An Issue?

It hadn't been a dry cleaners for over 40 years. The research was clear though - City Directory records from as early as 1930 through 1971 indicated that it had been there - and it was enough information to call it a 'recognized environmental condition'. That is, the presence of a dry cleaners was enough to represent the likely presence of hazardous substances in, at, or on this property. This raised questions. How could we be sure that it was a dry cleaners? How could something that old still be considered an issue?


These are fair questions. But a dry cleaners is not likely to be misidentified in 40 years of historical records, and it's certainly possible that contamination could be a concern. One recent blog called dry cleaners an "environmental scourge" - one that is often overlooked during property transactions.


Had this been a gas station I'd have been less concerned. Petroleum in the ground would have likely degraded after that amount of time. In fact, dry cleaning operations in the 1930s and 1940s probably used Stoddard Solvent, a petroleum-based chemical that would tend to naturally degrade over time.


By the late 1950s, however, most dry cleaning operations had made the switch to tetrachloroethylene, also known as perchloroethylene, or PCE. Originally developed in the 1930s, this chemical became the preeminent solvent in the dry cleaning industry, its use peaking in the 1980s. Naturally more resistant to degradation, this chemical was routinely treated with stabilizers and surfactants, creating a chemical that could travel quickly in the subsurface and remain there for a very long time.


Previous studies have noted that older operations used 5 to 10 times more solvent than modern operations, and were much more likely to release PCE. The State Coalition for Remediation of Drycleaners has estimated that about 75% of dry cleaners in the US caused environmental contamination. Today PCE is considered a carcinogen, and modern dry cleaning operations are subject air, hazardous waste, and wastewater regulations.


In short, historical dry cleaners can represent a significant risk for a property transaction. In my research I found insurance agencies and environmental lawyers alike that consider such properties to represent a real concern. At the end of the day, it's worth knowing what you're purchasing. The same questions are likely to come up again when the property is sold again down the road.

December 2014. Funkhouser interview comments included in local television report.


KDEP's Hazardous Waste Management Fund is the only funding mechanism available to clean up contaminated sites that have no viable responsible party. Several of these sites include former dry cleaning operations and abandoned industrial properties whose former owners may have died or gone bankrupt. Funding for the HWMF, which was created in 1980, is no longer keeping pace with the number of sites that have been identified. LFI's expertise has been tapped by the KDEP to assist in the assessment and cleanup of some of the HWMF sites over the years. A story on the HWMF by Marcus Green of Louisville television station WDRB included comments by LFI's Roy Funkhouser and makes mention of assessment sites where work has been performed by LFI.

2014 OSHA Training

Linebach Funkhouser, Inc. (LFI) completed its annual 8-hour refresher course of OSHA Standard 1910.120 on November 7, 2014. In addition to current and previous LFI staff, attendees included professionals from industry, government, and contractors. A total of 34 persons attended the day long training session, which LFI has offered annually since 2002.

The purpose of the training was to provide the required continuing education for health and safety protocols for persons who may have to perform work with hazardous materials. In addition to standard topics such as site characterization, chemical hazards, physical hazards, and personal protective equipment, two guest speakers provided additional insight and information:

  • Mr. Keith McBride of Louisville Gas and Electric discussed health and safety issues when dealing with natural gas and electric utilities. Mr. McBride stressed the importance of reporting possible natural gas leaks and safety when working within electric substations.
  • Sargent Robert Kaelin of the Louisville Bomb Squad provided information regarding explosives and emergency response actions. The presentation included a hands-on demonstration of the robot their team uses during emergency events.


Doug Linebach of LFI thanked Sargent Robert Kaelin of the Louisville Bomb Squad for their presentation and demonstration.


For additional information regarding health and safety training services please contact Doug Linebach at (502) 895-5009.

Linebach Funkhouser, Inc. Awarded On-Call Environmental Services Contract for Louisville International Airport & Bowman Field Airport

By Bill Johnston, PG

LRAA - blog

Linebach Funkhouser, Inc. (LFI) was awarded the On-Call Environmental Services Contract by the Louisville Regional Airport Authority (LRAA) on October 16, 2014. LFI will provide various specialized environmental services related to construction projects and regulatory compliance issues associated with the operation of Louisville's International Airport and Bowman Field Airport.

Services will include regulatory permitting, preparation of contract documents for SPCC related projects, removal of USTs, installation and inspection of ASTs, site delineation, characterization/disposal of hazardous/special wastes, Phase I/II studies, soil remediation studies, surface/subsurface water quality studies, de-icing studies, air quality studies, and conducting workshops for Louisville Regional Airport Authority staff and tenants. LFI will also provide consulting services concerning 24-hour environmental emergency response actions as part of the annual contract.

The Kentucky Chamber of Commerce’s upcoming 12th Annual Kentucky Environmental Conference on Feb. 20-21 in Lexington, KY

The Kentucky Chamber of Commerce's upcoming 12th Annual Kentucky Environmental Conference on Feb. 20-21 in Lexington, KY will include two presentations by Linebach Funkhouser, Inc. (LFI) personnel.  On February 21st, Bill Johnston, Principal Geologist, will speak on Soil and Groundwater Remediation Issues and Case Studies. Also on the 21st, Roy Funkhouser, Principal, is teamed with Shawn Cecil of the Kentucky Department for Environmental Protection and Kelly Bartley of Bingham Greenebaum Doll to give a Keynote Presentation on Liability Protection Under Kentucky's Brownfield Redevelopment Program.

A Happy Ending at KY Landfill

By Mary Jo Harrod

Happy Hollow

In 1962, the city of Middlesboro granted a household garbage franchise to Roy Shoffner and Sam Mars to operate a landfill in Happy Hollow, a narrow valley of 14 acres. Though the city made garbage pickup mandatory, illegal burning and dumping were constant problems at Happy Hollow.

Bulldozers covered garbage and burned materials, but vegetation grew until trees were 20 feet tall. By 1974, the two business partners decided to sell the franchise and garbage trucks back to the city and close the landfill.


Though it was closed and posed no immediate threat to human health and the environment, Happy Hollow was still on the state's list of uncontrolled landfills and considered to be a brownfield. In 2007, Shoffner & Mars, LLC voluntarily began the appropriate regulatory landfill closure process.


"There was never a threat to the water supply and no methane was ever detected," says Sammy Mars, son of one of the original owners of Happy Hollow. "We contacted Linebach Funkhouser Inc. for assistance in proceeding with the remediation of the landfill and bringing the site into compliance for closing. We wanted to protect the environment and later chose to develop the site."


Phase I consisted of adding 20 more feet of soil cap, implementing a passive vapor barrier and constructing a landfill cap. A monitoring well extends to the bedrock in the hollow and is checked every six months, though it has been problem-free. Phase II entailed removing 150,000 yards of dirt from a hillside to raise the property level and create flat areas for business. A communal asphalt parking lot for the hotels sits on a portion of the site.


Being a privately held company, Shoffner and Mars, LLC is ineligible for U.S. Environmental Protection Agency brownfield cleanup grants. However, the company recognized the potential and spent its own money for the project. The earth-moving cost alone for Phases I and II was $1.2 million.


The property had a 60-room Holiday Inn-Express that stayed at capacity and could not be expanded. But at the project's end in 2010, a second hotel, a 50-room Sleep Inn, opened on the site. The property is located on the border of Middlesboro's central business district at the town's main stoplight. Between the two hotels, they now generate 60 percent of tourist tax revenue for the area.


Middlesboro is in a flood-prone area. Before the project, the hilly land was valued at $10,000 per acre. After moving dirt to create level areas higher than the flood zone, the land's value is $200,000 per acre.


"There were project challenges, such as with the leachate collection system, which had to be re-engineered," says Charles Leachman, senior geologist from Linebach Funkhouser. "The state wanted us to use a specific type of stone, which was difficult to find, to set around lines to improve drainage. Also, we encountered waste further down the hill than we anticipated and had to be careful to keep it from rolling down the hill."


In redevelopment cases such as this, Leachman recommends bringing a good conceptual project plan to the regulatory agency and asking for advice in case something has been overlooked. Working proactively in this manner makes a project go more smoothly and often prevents delays in the redevelopment process.


Middlesboro is an economic hub for the Tri-State region of northeast Tennessee, southwestern Virginia and eastern Kentucky. The new hotel and parking lot fill a need for the area, which is near the Cumberland Gap Tunnel. With a shortage of hotel rooms before the Sleep Inn was built, the community's response has been positive.


"For Middlesboro, this project has the Wow! Factor," says Mars. "The landfill is gone, and a new hotel is on-site. The community has pride in the results of the project, which is a prime example of the state working with private industry."


Though no chemicals or hazardous wastes were ever known to have been accepted at the property, Shoffner & Mars went beyond what was required by law to protect the environment. The community has benefited from the revitalization of the area and creation of jobs.


Mary Jo Harrod is Public Information Officer, Energy and Environment Cabinet, Division of Compliance Assistance, Frankfort, KY.

In-Situ Remediation

By Bill Johnston, PG


Linebach Funkhouser, Inc. (LFI) personnel performed permanent closure, assessment and corrective action activities on (UST) systems at a former retail petroleum facility located in Louisville, KY. Three gasoline/diesel USTs were removed from the subject site in 1997.  During the removal of the USTs, a large amount separate phase product was observed leaching into the common tank pit area.  Product recovery procedures were immediately initiated to mitigate the contamination concurrent with notifying the appropriate agencies including the Kentucky Department for Environmental Protection (KDEP), Division of Waste Management, Emergency Response Section and the State Fire Marshal's Office.  Following the completion of the removal and initial abatement procedures, several documents including Initial Abatement, Product Recovery and UST Permanent Closure reports were filed with the KDEP, DWM, and Underground Storage Tank Branch (USTB) on our client's behalf. Several assessments were completed to define the horizontal and vertical extent of the separate phase and dissolved petroleum contaminant plumes identified in the shallow groundwater.  LFI personnel enrolled our client in the USTB Petroleum Storage Tank Environmental Assurance Fund (PSTEAF) in an effort to recover eligible costs for assessment and remediation.


A corrective action plan (CAP) was written for the site with the assistance of AST Environmental (AST) of Midway, Kentucky that proposed utilizing a "cutting edge" in-situ remediation technology. The technology developed by Remediation Products, Inc. (RPI) of Golden, Colorado known as BOS 200® is a Trap & Treat® Bacteria Concentrate applied with a high velocity/high pressure delivery system designed and implemented by AST. This combined product-delivery remediation technology was outlined in the CAP that was submitted and approved by the USTB.


Prior to implementation of the CAP, subsurface impacts consisted of petroleum hydrocarbons in soils, accumulation of light non-aqueous phase liquids (LNAPL) in three monitoring wells and aqueous phase (dissolved) benzene in groundwater as high as 11 milligrams per liter (mg/L). The impacted area immediately surrounding the former tank pit, occupied approximately 7,000 square feet of the approximately 3-acre site.


LFI and AST teamed to develop a remedial approach to address the LNAPL and dissolved phase petroleum hydrocarbon impacts at the site.  Specifically, an injection design was prepared and implemented to address LNAPL and dissolved phase petroleum hydrocarbons. The goal was to inject BOS 200® to remediate the site for removal all the LNAPL and reduce benzene concentration to below 0.005 mg/L in the on-site monitoring wells.


On Friday, August 19, 2011, 20,400 lbs of BOS 200® was delivered to the subject site.   On the morning of August 22, 2011, AST mobilized personnel and equipment to the site and setup for the injection effort to begin that day.  The injections were completed in 8 workdays with AST injecting the 20,400 pounds (lbs) in 150 injection points to approximately 14' below grade surface. AST prepared BOS 200® slurries and injected it into the subsurface through probe rods. The slurry is pumped through the probe rods using a positive displacement diaphragm pump capable of delivering 1,200 pounds per square inch (psi) at 35 gallon per minute (gpm).  The injection pressure varied from 200 to 600 psi.  The pressure injection scheme created extensive "fracturing or soil lifting" of the soil to create preferential pathways within the fine grain clay which are filled with BOS 200®. The injection effort was completed on 8/31/2011.


The post injection monitoring reports from July and October 2012 reveal that the full list of analytes and all constituents of concern (COCs) were well below the CAP and EPA defined clean-up goals. Based on these results KY-USTB issued a No Further Action for the site on December 20, 2012

The Flow Below

By Brendan Merk, Senior Hydrogeologist

In February of 2013, as part of LFI's ongoing professional training and development program, the LFI staff was provided a technical presentation by Mr. Joseph Ray, a certified Professional Geologist and published author of many papers dealing with dye tracing and subsurface flow. A renowned karst specialist, Mr. Ray provided information on the flow of groundwater below actively running rivers - water features typically considered natural barriers to subsurface flow.


Kentucky features one of the most famous karst areas in the world, and much of the State's manufacturing base overlies it. Karst environments are well known for topographic features such as sinking streams, caves, and springs. In areas of well-developed karst, such as the Mammoth Cave area, subsurface flow is considered the norm and surface water streams and rivers are rare.


Geologists and engineers are routinely taught that water will flow downhill to join a river or stream at the surface, even when that water flows underground. Conventional wisdom is that the river will act as a natural barrier - the stopping point where groundwater flow becomes surface water flow. The only rule with karst though, is that normal rules just don't apply. Failure to understand and property interpret subsurface flow can lead to significant errors in determining where contamination may be going, and how much it's going to cost to clean it up.


Mr. Ray presented compelling evidence that the flow of groundwater through fractured rock beneath overlying rivers and streams is more commonplace than has been historically believed. Pathways of preferential flow make it possible for water to disappear underground for a distance, only to appear again later as a spring. These subsurface pathways are not connected to flow at the surface however, making it possible for the water sink and the spring to be on opposite sides of the river.


Karst environments with fractured rock flow occur in varying degress in all the states surrounding Kentucky. Mr. Ray emphasized that geologic knowledge of such features is important, as is the ability to apply that information to a given situation. He provided an example of a city in Kentucky where a municipal water supply at a spring turned out to be originating from a water sink just downhill from the city's sewage treatment plant.


Following his presentation, Mr. Ray entertained several questions from LFI staff. Mr. Ray's presentation is one of several technical lectures and training sessions in which LFI staff will participate in 2013. Training and continuing education are a part of life at LFI, and a cornerstone in producing exceptional work for our clients.

Linebach Funkhouser Receives Subcontracts for Ohio River Bridges Project

Linebach Funkhouser, Inc. (LFI) was recently awarded two subcontract agreements with Walsh Construction Co. and Jacobs Engineering Group, Inc. to manage environmentally affected materials that may be encountered during upgrades to Spaghetti Junction and the new Downtown Crossing over the Ohio River in Louisville, Kentucky. LFI will serve as the Contaminated Materials Manager under the subcontracts. Affected soils and other materials resulting from historical operations of various industrial and commercial properties within the footprint of the construction must be properly characterized and managed in accordance with regulatory requirements.

LFI will provide project-wide management of affected materials including development of Site Management Plans, Materials Management Plans, Corrective Action Plans, Construction Monitoring Plans, and Environmental Health and Safety Training, as needed, for site workers.


Call Before You Dig

By: Russell H. Brooks, P.G.

Senior Engineer

The federally-mandated, national "Call Before You Dig" number, 811, was created to help prevent unintentionally hitting underground utility lines while working on excavation, drilling, or similar subsurface projects. People often make risky assumptions regarding marking utility lines due to concerns about project delays, costs, and experience (or luck) with other projects in which utilities were not marked. These assumptions can be life-threatening.

Every excavation/drilling job requires a call - even small projects like planting trees or shrubs. Hitting an underground utility line while digging can seriously harm you or those around you, disrupt service to an entire neighborhood or industrial park, and potentially result in significant fines and repair costs.

Waterline on top of USTs

The 811 system will notify member utilities; however, in many cases small local municipalities are not members of the 811 system.  Therefore, it is your responsibility to identify and contact non-member utility providers.

Typical environmental jobs often include subsurface activities, such as drilling soil boring and groundwater monitoring wells, and excavating to remove impacted soils, waste materials and underground storage tanks (USTs).  The 811 call should be made 48 to 72 hours prior to commencing work on all subsurface operations.  Depending on individual state laws, you must account for holidays and weekends, so do not call on Friday and expect the utilities to be located on Monday.

Soil boring 4 inches from gas line marking

An 811 utility locate request will only mark utilities up to the service meter for the property. It is the responsibility of the contractor to ensure that all utilities beyond the meter are properly located and marked prior to the start of work.

In cases of large coverage areas, the utility clearance company has the right to request work area demarcation prior to marking the utilities.  Identifying work areas on large sites helps to minimize the locator's time on-site, and also confirms that utilities in work areas have been marked.

Site utilities will be marked with paint and flags.  The following universal color system indicates what is buried below the surface:

  • Red - ElectricMultiple lines
  • Orange - Communications, Telephone/CATV
  • Blue - Potable Water
  • Green - Sewer/Drainage
  • Yellow - Gas/Petroleum Pipe Line
  • Purple - Reclaimed Water
  • White - Area of Intended Excavation/Subsurface work (marked by contractor)

Once the utilities are marked it is the excavator's/driller's responsibility to avoid damaging the utilities.  Although no specific "hand-dig" zone is outlined in the Call Before You Dig law; the American Public Workers Association and several industry-accepted Best Practices recommend hand-digging 18″ on either side of the utility markings to a depth of 24". It is recommended that shovel excavation or a similarly gentle method of excavation take place in the hand-digging zone to uncover utilities prior to proceeding with more powerful equipment.

For more information about the national 811 system, visit