Cleaning up Contaminated Soil and Groundwater at Dry Cleaning Facilities

A dry cleaning facility can contaminate soil or groundwater with hazardous chemicals used in dry cleaning. Such a situation can create a danger to the environment or public health. Additional reasons to clean up these hazardous chemicals in a timely manner are:

• Property Transactions: The dry cleaner may be faced with difficulty in borrowing money or selling dry cleaning property if it is contaminated.
• Potential Liability: The dry cleaner may be faced with the filing of private party lawsuits seeking compensation or cleanup if the property is contaminated.
• Potential Enforcement Action: Illinois EPA is authorized to respond to and clean up or control releases of hazardous substances and petroleum. Costs and damages incurred by the Illinois EPA as a result of such releases are recoverable from responsible parties (e.g., dry cleaners).

The Site Remediation Program (SRP) is an Illinois EPA program where participants may address hazardous chemicals with Illinois EPA oversight. Claimants of the Drycleaner Environmental Response Trust Fund must enroll in the Site Remediation Program and conduct remedial action (35 Ill. Adm. Code 1501.300(b) and 1501.400(c)). 

Under the SRP, the Illinois EPA provides technical assistance and issues a No Further Remediation (NFR) Letter after the cleanup is performed satisfactorily. The SRP also assists in financial reviews of budget plans and reimbursement requests for sites eligible in the Drycleaner Environmental Response Trust Fund. 

Steps required to clean up a site under the SRP are:

• Conduct a Site Investigation and submit a Site Investigation Report
• Develop Risk Based Objectives and submit a Remediation Objectives Report
• Identify appropriate controls and activities and submit a Remedial Action Plan
• Perform and document the cleanup and submit a Remedial Action Completion Report

Solvents used in drycleaning machines can contaminate soil, groundwater, and air. Typical areas where hazardous chemicals may be present at a dry cleaning facility include:

• Process areas and storage areas (e.g., areas where perchlororethylene, used filters, cartridges, and wastes are stored)
• Dumpsters, utility lines
• Cracks in the floor, entryways
• Piping, floor drains, sump areas
• Sewage line to the main storm or sewer lines
• Known or suspected spill areas

Hazardous chemicals are also found in these wastes generated by the dry cleaning facility:

• Used filters and filter media
• Spent carbon and cartridges from carbon absorbers
• Still residues (evaporator or cooker sludge)

Typical constitutents of concern found at dry cleaning facilities are:

• Perchloroethylene (Tetrachloroethylene, PCE, or perc)
• Trichloroethylene (TCE)
• Volatile Organic Compounds (VOCs) and Semi-Volatile Organic Compounds (SVOCs)

These chemicals can breakdown further into other hazardous chemicals that also have special handling requirements.

Ultimately, the site investigation should characterize the extent and concentration of hazardous chemicals in the dry cleaning property's soil and groundwater.

The Tiered Approach to Corrective Action Objectives (TACO) is the methodology that the SRP uses for developing site-specific, risk-based remediation objectives (i.e., cleanup levels). TACO takes into account the extent and concentration of hazardous chemicals, the possibility of people inhaling or ingesting the hazardous chemicals, and current and future use of the property.

TACO uses a three-tiered approach for establishing remediation objectives. Each successive tier allows more information to be used to develop remediation objectives (along with a more comprehensive site investigation and analysis).

After remediation objectives are established using the TACO procedures, a dry cleaner may:

• Reduce chemical concentrations to meet established objectives through active remediation (e.g., removal of contaminated soil, soil-vapor extraction system);
• Restrict exposure to contaminated soil or groundwater or both by using engineered barriers or institutional controls;
• Take no action, if chemical concentrations are not above the remediation objectives; or
• Use a combination of the options above.

If a cleanup is conducted where contaminated soil or groundwater is generated as a waste, RCRA regulations may apply. Generators must classify the waste generated. If the waste is determined to be hazardous, it must be managed in accordance with RCRA requirements.

Upon approval of a report that documents how the contaminants of concern have been addressed to meet the approved remediation objectives (Remedial Action Completion Report), the Illinois EPA will issue a NFR Letter to the dry cleaner. To be effective, the NFR Letter must be recorded with the Office of the Recorder in the county in which the site is located.

Yes. All SRP site activities and report preparation must be conducted by, or under the general supervision of a person licensed in Illinois to practice as a professional engineer. As an exception, the Site Investigation Report may be prepared by a Licensed Professional Geologist (LPG). 

Some things to consider in selecting a consultant:

• Professional reputation
• References
• Licenses, registration, certification
• Experience in dealing with your particular problem and successful completion of similar projects in Illinois

Yes, if you are eligible! The Illinois General Assembly created the Drycleaner Environmental Response Trust Fund to establish:

• A remedial action account to help pay for the clean up of dry cleaning solvent releases (e.g., solvent leaks, spills) from dry cleaning facilities discovered on or after July 1, 1999 and before July 1, 2004.
• An insurance account for insuring environmental risks from releases from dry cleaning facilities within Illinois

The Fund is financed by the following sources:

• Dry-cleaning facility license fees
• Dry-cleaning solvent tax
• Insurance premiums
• Administrative assessment fees

SRP and TACO:

Voluntary Site Remediation Unit

Remediation Project Management Section

217-524-3300

Selecting an environmental consultant:

Illinois Environmental Services Directory

DCEO Environmental Assistance Program

https://dceo.illinois.gov/smallbizassistance/environmentalassistanceprogram/environmentalconsultants.html