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
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.
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.
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:
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.
The Kentucky Chamber of Commerce's upcoming
Conference on Feb. 20-21 in Lexington, KY will
include two presentations by Linebach Funkhouser, Inc. (LFI)
personnel. On February
Johnston, Principal Geologist, will speak on
Soil and Groundwater Remediation
Issues and Case Studies. Also on
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
By Mary Jo Harrod
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
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
"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
Mary Jo Harrod is Public
Information Officer, Energy and Environment Cabinet, Division of
Compliance Assistance, Frankfort, KY.
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
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
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
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
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
By: Russell H. Brooks, P.G.
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.
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
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.
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
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
Site utilities will be marked with
paint and flags. The following universal color system
indicates what is buried below the surface:
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
For more information about the
national 811 system, visit http://www.call811.com
Linebach Funkhouser, Inc. has been awarded two contracts with
the Kentucky Transportation Cabinet-Division of Environmental
Analysis. One is a two year contract for Statewide
Underground Storage Tank/Hazardous Materials Services
(UST/HazMat). This is a work order-based contract with a
value of $2,000,000. Services for this contract include
investigating and remediating UST/HazMat sites on highway
right-of-ways prior to highway construction. Linebach
Funkhouser has been providing these services as a pre-qualified
consultant since 2003.
The second is a two year contract for Statewide Environmental
Investigations and Remediation Services for Kentucky Transportation
Cabinet-owned facilities. This is also a work order-based
contract with a value of $2,000,000. Services for this
contract include Comprehensive Environmental Response,
Compensation, and Liability Act (CECRLA) and Resource
Conservation and Recovery Act (RCRA) based site assessments,
evaluations, remedial plans and compliance reviews in accordance
with RCRA, CERCLA, the Clean Water Act and related US EPA
regulations, and Kentucky UST regulations. This contract
covers facilities located in Highway Districts 1-6. Linebach
Funkhouser has been providing these services as a pre-qualified
consultant since 2006.
Linebach Funkhouser is a pre-qualified consultant with the
Kentucky Transportation Cabinet in the following areas:
Mr. Russell Brooks, manager of these contracts, has worked with
Linebach Funkhouser, Inc. for nearly 10 years. In his current
role, Mr. Brooks leads the government services group assisting
various local, state and federal clients with soil, water, and
waste issues. Mr. Brooks can be reached by calling
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