State Coalition for Remediation of Drycleaners Meeting

Stardust Resort and Casino
Las Vegas, Nevada
April 25-26, 2000

WELCOME
Dale Trippler (the group leader) and Carolyn Perroni (the meeting facilitator) welcomed attendees to the third official meeting of the State Coalition for Remediation of Drycleaners (SCRD). Upon Trippler's request, attendees introduced themselves (see Attachment A). The attendees included representatives from 12 states: 9 that have programs established to fund cleanups at drycleaning sites, 2 that have started drafting legislation for such programs, and 1 that is trying to determine whether a program is feasible. In addition, one drycleaner attended, along with representatives from The Dow Chemical Company, the Wisconsin Fabricare Institute, and the International Fabricare Institute (IFI). Trippler said that the meeting would span four days.¹ On the first two days, he said, SCRD would meet to discuss assessment and remediation issues, waste management practices, and a variety of other topics. On the last two days, the National Ground Water Association (NGWA) would offer training on dense nonaqueous phase liquids (DNAPLs).

UPDATES ON ACTIVITIES IN THE DIFFERENT STATES²
Trippler asked attendees to provide updates on the status of their state Fund programs. State representatives reported on a variety of topics, including legislation and rule development, fee structures, Fund revenues, field visits, hazardous waste management practices, site assessments, and cleanup activities.

Florida
William Linn and Brent Hartsfield, representatives from the Florida Department of Environmental Protection (DEP), said that Florida's Fund program has been operating for several years. During their presentation, they focused on what they know about drycleaning operations, what they have discovered during site assessment investigations, and the approach that Florida is using to remediate sites.

Operational History and Assessment of Drycleaners in Florida
To be eligible to participate in Florida's Fund program, Linn said, drycleaner owners/operators had to submit applications by December 31, 1998. About 1,563 applications were submitted, and about 1,400 sites have been deemed eligible. All of these sites have soil and/or ground-water contamination. Linn said that assessment activities, which cost about $90,000 per site, have been completed at 154 sites, are ongoing at 26, and will soon be initiated at another 12. These activities have revealed the following about drycleaning operations and the extent of contamination that is associated with them:

• A significant portion of drycleaning sites are inactive. Based on available data, Linn said, about 68.7% of the facilities assessed are active, and the other 29.3% are inactive.

• Many drycleaners do not own the property they operate on. Linn said that only 18.4% of drycleaners actually own the property they operate on.

• Many drycleaning facilities began operating before the Resource Conservation and Recovery Act (RCRA) was passed and before the advent of hazardous waste haulers. Linn said that about 45.3% of drycleaning facilities were operational before November 21, 1980, the date when RCRA passed. Establishment of these waste management rules did not put an immediate end to irresponsible disposal practices, he said; hazardous waste haulers were not even available until 1985. (About 64% of the sites began operating before 1985.)

• The vast majority of sites are conventional drycleaning facilities. Linn said that 98% of the facilities that have been visited are conventional drycleaners. Only 1% are wholesale distributors, and another 1% are categorized as coin-operated facilities. Linn said that the coin-operated facilities had dry-to-dry machines, no distillation equipment, and no reclamation systems. Most did have two filters, though. Contaminants at these sites are most likely to be found near dumpsters (where filters are dumped) and near drycleaning machines.

• Most facilities are located in shopping areas or strip malls. Linn said that 77% of the sites that have been assessed are in shopping areas or strip malls. About 20% are in free-standing buildings.

• Most drycleaning facilities have been operating between 5 and 20 years. Linn said that most of the sites assessed have been operating between 5 and 20 years, but that many have been operating longer. For example, two drycleaning facilities started operating in 1926. It appears that the original equipment is still being used at one of these sites.

• Investigators can use a facility's operation dates to make predictions about what could be found at a site. Linn noted that almost no tetrachloroethylene (PCE) was used in Florida before 1942, and that drycleaning facilities did not really start using it much until the 1960s. Before that time, petroleum solvents dominated the drycleaning market. Today, he said, PCE is the most commonly used drycleaning solvent; but some facilities continue to use petroleum products, others use both, and a couple use Freon 113 or valclene. The latter is no longer made, so the owners must have stockpiled the product.

• The vast majority of drycleaning sites have contaminated ground water. Linn said that ground-water contamination was found at all but 3% of the sites that Florida has assessed. He described the contaminants that have been detected at the contaminated sites:
  
  

  —	Chlorinated compounds. Linn said that chlorinated compounds have been found in the ground water at many drycleaning sites. For example, the following have been detected: PCE (at 136 sites), trichloroethylene (at 118 sites), cis-1,2-dichloroethene (at 110 sites), trans-1,2-dichloroethene (at 70 sites) 1,1-dichloroethene (at 30 sites), and vinyl chloride (at 58 sites). Linn said that it is clear that microbial activity is degrading PCE at several sites, but that concentrations remain very high at others. (Degradation activities are more pronounced in the southern parts of Florida.)
  —	Non-chlorinated compounds. Linn said that non-chlorinated compounds have also been found at many sites. Those identified include BTEX (benzene, toluene, ethylbenzene, and xylene), methyl tertiary butyl ether, 1,2,4-trimethylbenzene, naphthalene, 1,2-dichloroethane, and chloromethane. Many of these compounds, Linn said, are probably not associated with drycleaning activities. Sites are typically located in commercial areas. Thus, they are often impacted by multiple sources.
  —	DNAPL. According to a rule of thumb put forth by the University of Waterloo's John Cherry, if a DNAPL constituent (e.g., PCE) is present at concentrations that exceed 1% of its aqueous solubility in water, DNAPL may be present. About one-third of Florida's drycleaning facilities have reported that this is the case at their sites. Linn said that the "1% rule" is simply a conservative indicator; it does not confirm DNAPL's presence. In fact, DNAPL presence has only been confirmed at three of the sites that have been assessed so far.

• There are certain places where investigators should look for source zones. Linn said that source zones are often located near drycleaning machines and distillation units. Thus, it is important to sample underneath building slabs in these areas. Source zones are also frequently located near back doors, storm sewers, rain collection pits, septic tanks, and sewer lines. In fact, Linn said, a paper published by a group from California identifies sanitary sewer lines as the number one culprit for drycleaner-related ground-water contamination. In addition, Linn said, sites that use petroleum solvents may have source zones emanating from aboveground storage tanks and underground storage tanks (USTs).
  
  
• Ground-water plumes typically extend over less than an acre, do not exceed 300 feet, and have a length-to-width ratio of 2:1. While most of the drycleaner-related plumes in Florida are small to moderate in size, some do stretch over long distances. For example, Linn said, one plume, located over an unconfined aquifer was over 42 acres in size.
  
  
• Ground-water contaminants have migrated offsite in many cases, and are often present at levels that exceed regulatory standards. Linn said that contaminated ground water has migrated offsite at about 57% of the sites that have been assessed in Florida. In about 77% of these cases, offsite concentrations exceed Florida's regulatory standards.

During the assessment process, Linn said, risk-based corrective action (RBCA) worksheets are used to help score sites based on their potential to adversely impact human health or the environment. A plume's distance to drinking water wells is critical in determining site ranking, Linn said, noting that Florida's aquifers are generally unconfined and shallow (average depth of 7.2 feet), and that 92% of the state's drinking water is collected from ground-water sources. Linn said that information about drinking water wells is gathered using money from the Fund program. (A department within DEP is hired to identify and sample all the wells within a quarter mile of each site.) Elaine Glendening asked whether exposure to indoor air contaminants (generated via off-gassing processes) is considered when sites are scored. Linn said it is not, primarily because people do not live above drycleaning facilities in Florida. (He said that this issue is of greater concern in states like New York, where apartments are frequently located over drycleaning facilities.)

Selecting a Remedial Strategy for Drycleaning Facilities
Of the sites that have been assessed, Linn said, decision memorandums—documents that list a chosen remedial approach—have been completed for 92. To date, 17% of the sites have been listed as requiring no further action (NFA), either because: (1) soil and ground-water contaminant concentrations did not exceed regulatory levels, or (2) soil concentrations did exceed leaching standards, but laboratory tests indicated that leaching will not occur. At 45% of the sites, Linn said, monitored natural attenuation has been chosen as a remedial approach. The remaining 38% of the sites will have active remedial systems; in fact, 30 systems have already been installed.

Linn and Hartsfield described the process that Florida uses to choose remedial approaches. For many sites, an official remedy selection evaluation is initiated, but this is not always required. For example, remedial managers can forego this process if natural attenuation is chosen as the preferred approach. There are natural attenuation default values for chemicals; natural attenuation is considered appropriate for sites where contaminants do not exceed these values. Linn said that natural attenuation default values for carcinogenic compounds are 100 times greater than regulatory MCLs. For noncarcinogenic compounds, the default values are only 10 times greater than the MCLs. In Florida, investigators are told to identify a contaminant source zone and determine two boundaries for the dissolved portion of a plume: (1) an outer boundary that indicates where contaminants equal the regulatory MCL and (2) an inner boundary that indicates where contaminants equal natural attenuation default concentrations. If contaminants do not exceed the natural attenuation default values, Linn said, active remediation is usually deemed unnecessary and project managers must simply monitor the site and notify appropriate parties if contaminants migrate offsite. There are exceptions to this rule. For example, Linn said, if a plume were located near wells or moving vertically, active remediation would be initiated, even if concentrations were below natural attenuation default values.

If natural attenuation is not automatically chosen as a remedial option, Hartsfield said, a site-specific remedy selection process is initiated, and a remedy that meets a variety of criteria (e.g., feasibility, reliability, efficacy in reducing risk) is identified. Florida's statute, said Hartsfield, specifies that innovative technologies must be considered during this process. Forty-four sites have gone through Florida's remedial alternative evaluation process; for each, cleanup criteria were identified, key site conditions were assessed, various technologies were screened, detailed evaluations were conducted on the technologies that passed the screen, and a preferred remedy was selected. Hartsfield described the screening process, noting that a spreadsheet has been created to assist with this step. It lists technologies that should be considered, Hartsfield said, and asks investigators to evaluate their appropriateness based on several criteria (i.e., feasibility, implementability, reliability, adverse impacts, O&M requirements, cleanup time, and cost). The technologies listed are divided into three categories, based on which situations they can be used to address:

• Soil contamination. Hartsfield said that removal and vacuum extraction are listed as options. If contaminants are under a slab, removal may not be a viable option. If a site has a high ground-water table as well, vacuum extraction may also be inappropriate. In such cases, Hartsfield said, multiphase extraction or dewatering might be used, or a technical impracticability waiver might be sought.
  
  
• Dissolved ground-water plumes. Hartsfield said that the following are listed as options: natural attenuation, permeable treatment walls, pump-and-treat, multi-phase extraction, air sparging, recirculating wells, in situ bioremediation, and in situ chemical oxidation.

• DNAPL. Hartsfield said that the following are listed: multiphase extraction, air sparging, recirculating wells, in situ bioremediation, in situ chemical oxidation, in situ flushing, and in situ thermal processes.

Hartsfield distributed a table listing the technologies that have been chosen to remediate soil, dissolved plumes, and DNAPL at Florida's drycleaning sites. He noted that some of the selected remedies are considered conventional, but that others are innovative. He asked attendees to review the list on their own, but did provide a few details about some of the remedial projects. He said that recirculating wells were used in one pilot study; after the wells operated for 2 to 3 months, PCE concentrations decreased from about 1,600 parts per billion (ppb) to about 300 or 400 ppb. Also, Hartsfield said, studies have been performed using in situ flushing and in situ bioremediation (using hydrogen release compound [HRC™] injections). Both pilots were successful: in situ flushing recovered 40 liters of PCE within 3 weeks, and HRC™ removed 96% of PCE mass within 150 days at another site. (Papers have been completed on both of these pilots.³) In addition, in situ chemical oxidation (using potassium permanganate and hydrogen peroxide) is being piloted at drycleaning sites in Florida.

Lessons Learned/Recommendations
Linn and Hartsfield summarized the lessons that Florida's DEP has learned working at drycleaning sites:

• Learn as much as possible about historical waste management practices at drycleaning facilities. Linn noted that contractors often have better luck collecting this information than state representatives do.
  
  
• Remember that the highest contaminant concentrations are often under or close to building footprints.
  
  
• Make sure to obtain good vertical and lateral characterization data in source areas, and make sure to install an adequate number of monitoring wells. Linn said that this information becomes critically important when choosing remedial approaches. He advised using push probes to characterize sources.
  
  
• Make sure that those who conduct site assessments have been educated about drycleaning sites, and that they know where to look for contamination.
  
  
• Ask those who conduct site assessments to establish communication with remedial designers.
  
  
• Develop hydrogeological models to predict contamination occurrences and transport for different aquifers.
  
  
• Collect natural attenuation data during the assessment phase. Hartsfield said that Florida has released an advisement document; this provides guidance on what parameters (e.g., dissolved oxygen, nitrates, sulfates, and hydrogen sulfide) to measure and how to evaluate transport. In addition, he said, it also provides instructions on how to set up a monitored natural attenuation system.

• When selecting a remedy, it is important to: (1) be receptive to innovative technologies, (2) have a thorough understanding of the selection process, and (3) screen a comprehensive list of technologies.

Illinois
Pat Eriksen, a representative from the Drycleaner Environmental Response Trust Fund of Illinois, focused his discussion on administrative issues, such as licensing, outreach activities, insurance policies, and compliance programs. He said that all drycleaners in Illinois must be licensed. So far, more than 1,450 facilities have obtained licenses, but estimates indicate that there could be as many as 1,800 active facilities in the state. Eriksen said that there is great incentive for drycleaners to become licensed: if they fail to, they will be charged a fee of $5 per day and they will have to pay back fees for 1998, 1999, and 2000. In addition, most solvent suppliers will not sell products to unlicensed cleaners, because they could be fined $5,000 for doing so.

Eriksen said that the Fund program will pay for cleanups that address historical contamination. (The Fund will pay up to $50,000 and $160,000 for inactive and active facilities, respectively.) To be eligible for this benefit, however, drycleaners must:

• Submit an application by July 1, 2000. Eriksen said that an extensive outreach effort has been initiated to make sure that drycleaner owner/operators know about the application deadline. So far, only 71 applications have been submitted, and regional trade associations do not think that more than 400 applications will be submitted before the deadline. Eriksen said that these low estimates concern him. A significant language and cultural barrier exists in Illinois, he explained, and this confounds outreach efforts. (He said that about 70% of Illinois' drycleaners are Korean.)
  
  
• Purchase an insurance policy. Eriksen said that drycleaners must purchase an insurance policy through the Fund program; this provides $500,000 in pollution liability coverage, and can be used only to address releases that occur in the future. Eriksen said that the premiums for the insurance policies are very low. It currently costs $250 per year, and will be increased by $125 per year for the next four years. After this period, the premiums will be reassessed and an actuarial study will be performed to evaluate risk factors at different facilities. Eriksen said that drycleaner owner/operators have not been purchasing insurance policies in a timely manner. In fact, only 26 policies have been issued by the Fund program. He said that the Korean Drycleaners Association of Chicago recently placed an advertisement in the newspaper, claiming that they will offer private insurance. The seven-member council that administers Illinois' Fund program will review this private policy in the near future.
  
  
• Adhere to pollution prevention requirements. To be eligible for insurance, Eriksen said, drycleaners must comply with certain pollution prevention requirements. Three compliance programs have been established, and a fourth one will be established very soon. Eriksen said that outside firms and organizations are used to ensure that facilities are in compliance. (For a fee of $35 to $300, these groups visit facilities to make sure there is proper containment and hazardous waste management.)

Eriksen said that revenue for the Fund is generated through the collection of insurance premiums, licensing fees, and solvent taxes. Currently, actual revenues are about one-third lower than projected. The Council may choose to adjust the solvent and license fees in the near future. (Eriksen said that solvent fees could double over the next fiscal year.)

Kansas
Bob Jurgens, a representative from the Kansas Department of Health and Environment (KDHE), provided an overview of recent field experiences and findings. Assessment has either been completed or is ongoing at 16 sites, he said, and costs have averaged about $30,000 per site. (Jurgens said that it is difficult to predict whether future assessments will cost more or less.) As for remedial activities, he said, soil remediation has been completed, has been initiated, or is pending at 10 sites. (Remedial activities include two soil removals and nine soil vapor extraction [SVE] systems.) In addition, ground-water remediation has been deemed necessary at 10 sites. Three of the remedial systems have been installed at municipal sites—located in McPherson, Salina, and Hays—and the costs of these systems are being divided between KDHE and other entities (e.g., municipalities and the UST program). Jurgens provided details about some of the remedial systems that have been installed at drycleaning sites in Kansas:

• KVA C-sparger. Jurgens said that it cost about $60,000 to $70,000 to install equipment and wells for the KVA C-sparger system. Initially, he said, problems were encountered with this technology, but the technology's vendor addressed them. Since early 2000, the equipment has been operating properly. Jurgens said that results will be available soon to determine whether the system has reduced contaminant concentrations at the site. (Initial PCE concentrations were measured at 15 to 20 ppb.)
  
  
• In situ chemical oxidation. Jurgens said that sodium permanganate injections are being used at one site. One injection has already been completed, but it was not overly successful, probably because too little sodium permanganate was used. (When the injection quantities were calculated, KDHE was under the impression that contaminant concentrations were much lower than they actually are.) Jurgens remains hopeful that this technology will prove effective; it will be tested again soon, and this time much higher quantities of sodium permanganate will be injected.
  
  
• In situ bioremediation. Jurgens said that HRC™ was tested as a remedial option at one site, but with limited success. The technology did not fail; rather, it was used in an inappropriate application. (Ground-water flows about 1 to 2 feet per day at the site—too fast to allow complete reaction between HRC™ and contaminants.)
  
  
• Air sparging. Jurgens said that an air sparger (costing about $30,000 to $35,000) has been installed at one site. Monitoring results at this site offer conflicting information. While samples collected from monitoring wells indicate that the water is clean, those collected with geoprobes suggest that contaminants are in the 30 ppb range.
  
  
• Dual phase extraction. Jurgens said that an SVE system and a shallow tray stripper are being used to treat a source area in Hays. The system, which has been operating for about 4 months, appears to be effective. About 1,200 pounds of PCE were removed from the vadose zone in about 4 or 5 months. After that, removal activities leveled off. After the ground-water table was lowered by about 9 feet, however, removal rates rose dramatically for some time before leveling off again.

Louisiana
Harold Ethridge, a representative from the Louisiana Department of Environmental Quality, said that his state does not have a Fund program established, but that it may in the future. There are at least 650 active drycleaners in the state, Ethridge said, but he is not sure if this represents 10% or 90% of the actual total.

In many states, Ethridge said, Fund program statutes are drafted and driven by fabricare associations and members of the drycleaning industry. Once the laws are in place, he continued, state agencies are left to determine how to make them operate on a practical level. Often, the way a statute is written makes this a difficult task. Ethridge said that he does not want Louisiana to follow the same path. Instead, the state should take the initiative in drafting potential legislation, rather than leaving it to industry representatives. Working toward that end, Ethridge has created a guidance document that recommends how to structure a Fund program if Louisiana chooses to adopt one. The document is still in generic form, but Ethridge hopes to have it reviewed by his agency's executive staff in the near future. He said that the document does not currently describe how to raise revenues for the Fund program; he is working on that section now. He gave audience members an idea of what he plans to propose, however: creating a system that relies heavily on gross receipts and registration fees rather than solvent fees. The registration fees, he said, will be used to pay the Fund program's administrative costs. Before closing, Ethridge noted that he has learned much by communicating with SCRD members. He thanked them for sharing what they have learned with him.

Minnesota
Dale Trippler, a representative from the Minnesota Pollution Control Agency (MPCA), discussed two changes that were recently made to Minnesota's Fund program. First, he noted, the due date for fee collection has been changed from July 1 to October 1. Second, annual revenue projections for the Fund have been lowered from $800,000 to $650,000. The latter change was made, Trippler said, because revenues were not meeting projections even though fee rates had been raised to maximum allowable amounts. Trippler said that he believes that this failure resulted because solvent usage has decreased dramatically in recent years. He cited three reasons why less solvent is being purchased in Minnesota: (1) drycleaning machines are more efficient, (2) owners/operators may be drawing from solvent stockpiles that they accumulated before the fees were established, and (3) drycleaners may be losing business to cleaners in North and South Dakota. Expanding on the latter, Trippler noted that some of the Dakota cleaners drive about 100 miles into Minnesota, pick up clothes, drive back to their shops, and then return cleaned clothes to Minnesota. He said that the Dakota cleaners, which do not pay fees into a Fund program, can offer lower prices than their Minnesota counterparts. Robin Schmidt asked whether mechanisms are in place to prevent cleaners in Minnesota from purchasing solvents in Wisconsin. Trippler said that there are not.

Trippler commented on the technologies that are being used to remediate drycleaning sites in Minnesota. For the most part, he said, conventional technologies (e.g., pump-and-treat and SVE) are being used. In the future, however, HRC™ and oxygen release compounds (ORC^®) might be used at a site in Minnesota.

New Mexico
Nancy Gillard, a graduate student interning at the New Mexico's Ground Water Quality Bureau, said that there is significant interest in establishing a Fund program in her state. About 200 drycleaning facilities in New Mexico use PCE, she said, and contamination has already been identified at some of them. Gillard said that she is writing a paper that will propose draft legislation for a Fund program. This must be completed and ready for presentation to the state legislature by September or October 2000. Over the last two months, Gillard said, she has been profiling the drycleaning industry and making contacts with various organizations and agencies (e.g., the Southwest Drycleaners Association, air quality organizations, and RCRA). In addition, she has already compiled a great deal of information about PCE usage and has information on usage rates at most drycleaning sites. As a next step, she plans to look at each site's potential for impacting nearby wellheads. Gillard provided a brief overview of some of the elements that she plans to incorporate into her report and draft legislation: (1) full liability protection, (2) application deadlines, and (3) incentives for switching to cleaner machines that use "greener" products. She said that she has not decided on a strategy for raising revenue, but some organizations have expressed interest in using gross receipt and solvent surcharges.

North Carolina
Lisa Taber, a representative from the North Carolina Superfund Section, focused her discussion on amendments that are being proposed for her state's Fund program and rules that are being developed. The program, which was created by industry representatives, is still in its developmental stage and must be amended to become viable. Recently, Taber said, the state informed the North Carolina Association for Cleaners and Launderers that it will move to repeal the entire Fund program unless: (1) a pollution liability insurance requirement is repealed, and (2) a mechanism is established to generate additional revenue. Thus, the Association is lobbying for an amendment and is currently evaluating alternative funding resources. Taber said that the Association is currently investigating whether revenues could be raised through a gross receipts surcharge or by diverting a portion of sales tax to the Fund program. If the amendments go through, Taber said, annual revenues could increase from $800,000 to $8 to $10 million.

Taber said that the state has been identifying drycleaning sites and collecting files. Also, she said, it has been working closely with stakeholders, interested parties, environmentalists, drycleaner associations, and lawyers to develop rules for minimum management practices. These rules will go into effect this legislative session, Taber said, as long as no bill is raised to block them. These rules state that facilities (abandoned and active) must not use USTs to store solvents or waste. In addition, active facilities must meet the following requirements to be considered eligible for the Fund program's benefits:

• Make sure that no solvent or wastewater is discharged to land, waterbodies, sanitary sewers, storm drains, floor drains, septic systems, boilers, or cooling towers. Taber noted that some drycleaners will probably choose to have their waste hauled offsite; these facilities must keep records and invoices of these transactions. Other cleaners will choose to treat their wastewater onsite using atomizers, evaporators, carbon filters, or other equipment. These facilities will be required to document the purchase of the equipment, keep records of all service and maintenance activities, and provide their records to the state when they apply to the Fund program. Taber said that the state had to fight for the recordkeeping requirements. In general, industry members were defensive about having requirements placed on wastewater treatment practices. Taber said that the state insisted upon this, arguing that it was needed so that it could determine whether equipment is being operated according to manufacturer specifications. Taber said that the state will work with drycleaner associations to develop outreach programs. About eight workshops will probably be held, and a manual may be developed to explain how to keep records.
  
  
• Install spill containment by January 1, 2002. Taber said that containment structures must be made of impervious material, be specifically designed to contain drycleaning products, and be large enough to hold 110% of the volume of the largest vessel, tank, or container within the spill area.
  
  
• Make sure that any new PCE machines that are purchased meet air emissions standards that equal or exceed the standards for comparable dry-to-dry machines with refrigerator condensers.
  
  
• Install a closed-container solvent transfer system by January 1, 2002. Taber said that this applies to cleaners that use PCE.

Taber stressed that the rules described above outline the minimum management practices that North Carolina's drycleaners must meet; the state is currently working on defining rules for best management practices. Also, the state plans to draft risk-based rules that explain how to prioritize sites.

Scott Stupak, another representative from the North Carolina Superfund Section, listed technologies that are being used to remediate PCE at sites in North Carolina. (These sites are not being remediated through the Fund program; they are being addressed by other programs.) He said that in situ surfactant flushing, air sparging, UVB, and KGB are being used at the Camp Lejeune site; a molasses injection is being used at the JFD/Channel Master site; Fenton's reagent is being used at Hamilton Beach/Proctor-Silex; and iron walls have been installed at DuPont and the Elizabeth City site. (Information about the latter is available at http://www.rtdf.org.) In addition, Stupak said, guar gum injections and sodium permanganate injections are proposed for Hamilton Beach/Proctor-Silex and the W.P. Ballard property, respectively.

Before closing North Carolina's presentation, Stupak described a drycleaning site that is being assessed by one of North Carolina's programs. This site has a chlorinated solvent plume that is migrating toward a nearby stream. (Concentrations of PCE have been detected as high as 118,000 ppb, but are 75,000 ppb in areas closer to the stream. Trichloroethylene has been detected at concentrations as high as 14,400 ppb.) According to Stupak, investigators thought it would take five years for the plume to meet the stream. However, some evidence suggests that impacts have already occurred. Stupak presented a schematic drawing of the site; this prompted Glendening to point out that a food store was located nearby. She asked whether indoor air had been assessed to determine whether gases from the plume were being deposited in fatty foods. Stupak did not know.

Oregon
Dick DeZeeuw and Elaine Glendening, representatives from the Oregon Department of Environmental Quality (DEQ), focused their discussions on the status of Oregon's Fund program, changes that should be made to it, efforts being made to streamline its efficiency, and what was learned during field visits. DeZeeuw said that about seven drycleaning facilities apply for inclusion to the program each year. (No mechanisms are in place to force owners/operators to apply by a certain time. They are often motivated to do so when a lease expires or property is transferred.) Of the sites that have been assessed so far, DeZeeuw reported, four have already been designated as NFA sites, and eight more will probably receive this status by the end of the year.

DeZeeuw said that there is currently about $1 million in the Fund. Beginning this year, more sites will enter the assessment and remedial phases, he said; this will cause annual Fund expenditures to exceed annual revenues by about $300,000. DEQ will address this problem by prioritizing sites and making sure that money is available for sites that pose the greatest potential risk. DeZeeuw said that amendments are being suggested for the next legislative session. Most notably, efforts are underway to change the program's fee structure so that: (1) actual revenues start meeting projected revenues, (2) PCE surcharges stop climbing, and (3) petroleum fees are not so exorbitant. Under the current statute, DeZeeuw explained, PCE solvent surcharges are raised by $4.00 each year for which the Fund fails to meet projected revenues. As a result, there is currently a $21.50 fee charged for every gallon of PCE sold. In addition, petroleum users are currently charged $10.5 for every gallon of stoddard that they purchase; some are paying as much as $30,000 annually in solvent surcharges.

In an effort to increase efficiency and reduce costs, DeZeeuw said, DEQ is trying to streamline activities and standardize procedures. Several tools are now in place to help them do so. For example, RBCAs have been established for PCE and all of its breakdown products. Also, DeZeeuw said, costs spent on assessment and remediation will be streamlined.

Glendening said that drycleaners are supposed to meet a variety of waste management requirements. During the summer of 1999, she said, members from DEQ's Hazardous Waste Division, Waste Management and Cleanup Division, and Air Quality Division joined efforts to determine whether drycleaners in Oregon are complying with the requirements. More than 470 facilities were visited, she said, and drycleaners were told that (1) the visits would be educational, (2) technical assistance and guidance would be offered, and (3) no punishment would be administered for noncompliance as long as problems were fixed by November 1999. During the field visits, drycleaner owners/operators received checklists, reminder calenders, and sample logsheets. (Materials were provided in English and Korean; about half of the drycleaning owners/operators in Oregon are Korean.) Glendening said that the following was assessed during the field visits:

• Profile information. Of the 472 facilities visited, Glendening said, 331 were actual drycleaners. (PCE was used as a drycleaning solvent at 313 of them; the remainder either used petroleum products or something else, such as one of the newer "green" products.) Of the facilities, 33 were closed businesses and 108 were considered drystores.
  
  
• Are drycleaners complying with equipment requirements? Glendening said that all 313 of the PCE-based drycleaners had ceased operating transfer-type machines. About 94% of them were delivering solvent using a closed direct-coupled delivery system. All drycleaners that bought new machines after June 1995, Glendening said, purchased dry-to-dry machines that were equipped with refrigeration condensers. (Some drycleaners used available tax credit programs to purchase this equipment.) Of those that were still using older machines, 99% had installed refrigerated condensers on them.
  
  
• Are drycleaners complying with containment requirements? Glendening said that 97% of the facilities had containment pans under their drycleaning machines, but that only 36% had pans under all items (e.g., buckets and wastewater treatment units) that contained solvent. She said that PCE was visible in some of the containment pans. Many of the pans that are being used, Glendening continued, were inadequate in design. To help ameliorate this problem, DEQ representatives advised owners/operators to make sure their pans are impervious, labeled with hazardous waste stickers, covered, and capable of holding 110% of the equipment's volume.
  
  
• Are cleaners complying with hazardous waste management requirements? Glendening said that most (99%) drycleaners have stopped discharging wastewater to sanitary sewers and septic systems. In addition, 98% understood that their solvent-laden wastes are considered hazardous. This does not mean, however, that wastes are being handled and treated appropriately in all cases. For example, at 11 facilities, solvent-contaminated wastewater is evaporated directly to the environment without being treated first. At 26 other sites, Glendening continued, crockpots are being used to address wastewater. Many drycleaners do have more state-of-the-art treatment equipment, but fewer than 50% had shut off valves or alarms incorporated into their wastewater treatment units. Thus, they have no way of knowing if their systems are working, when filters should be changed, or when PCE is breaking through.
  
  
• Are cleaners complying with annual drycleaning reporting requirements? About 10% of drycleaners failed to report on hazardous waste management and air quality compliance.
  
  
• Are drycleaners keeping good records? At one point, Glendening said, the Air Quality Division had talked about making PCE-based drycleaning facilities monitor ambient air. This was deemed an unrealistic goal, however, so the Division compromised, deciding that a facility's compliance with air quality requirements could be assessed through a review of its records. Thus, drycleaners in Oregon are supposed to keep logs of (1) the amount of PCE they use, (2) the temperature of their refrigerator condensers, and (3) the occurrence of equipment leaks. Glendening said that very few drycleaners (only 19%) are keeping these logs. In fact, she said, about 39% of facilities do not even have temperature gauges that could be checked. DEQ representatives told drycleaners that these thermometers must be installed; without them, there is no way to know whether solvents are being adequately recovered from clothes. Glendening also said that machines at several facilities appeared to be leaking PCE into the air. (Glendening said that she used a "sniffer" to identify leaks. Stupak asked if she had backed up the device's results with a soap test. She had not.) Glendening said that field investigators advised owners/operators to tighten their gaskets, or identify alternative solutions if tightening did not eliminate the leaks. Glendening said that she is distressed by the poor compliance with recordkeeping requirements: drycleaners are failing to meet the Air Quality Division's recordkeeping requirements, and many are also lax in recording solvent purchases. Information on the latter, Glendening said, is needed so that cleaners can prove they are up to date on surcharge fees and eligible for the Fund program's benefits.
  
  
• Do drycleaners have a thorough understanding of the equipment that they operate? Glendening said that some drycleaner owner/operators did not know much about the mechanics of their equipment or how to determine whether it is operating properly. Given this finding, she said, it might be useful to consider making Oregon's drycleaners take an industrial certification exam.

South Carolina
Craig Dukes, a representative from the South Carolina Department of Health and Environmental Control (DHEC), focused his presentation on administrative issues and site assessment activities. He said that South Carolina's Fund program might receive an influx of revenue in the near future: the Department of Revenue (DOR) has agreed to pursue unregistered drycleaners and collect back fees from them. In addition, the program may receive revenue from other sources. (There is currently a 5% sales tax on drycleaning services. In an effort to remove the tax, the drycleaning community has filed suit against the state. The cleaners asked DHEC to support them, offering to give the Fund program 2% of their gross receipt surcharges in return. DHEC is not, however, in a position to take sides. If the drycleaners win their lawsuit, $18 million in back sales tax will need to be returned. It will be logistically impossible to return this money to consumers; thus, some drycleaners propose rolling it into the Fund program.)

Dukes also discussed some proposed changes to the Fund program's legislation. For example, he said, DHEC successfully proposed making containment requirements more stringent. (A stopgap measure has been placed on the Fund program legislation; this will allow DHEC to spell out what containment requirements drycleaners must meet.) Dukes said that DHEC also plans to ask legislators to change the law so that petroleum users are no longer allowed to opt out of the Fund program. (Dukes said that many petroleum users have opted out of the Fund program. As a result, only 10% of the drycleaners that are covered by the Fund program use petroleum. However, these cleaners represent about 50% of the Fund program's highest-priority sites. Some of the petroleum sites are about 55 years old, Dukes said, and are located near public supply wells in small towns.)

Dukes said that DHEC has prioritized their drycleaning sites and that assessment activities have been initiated at some of the highest-ranking ones. He described what has been done at three of them. At one site, a drycleaning facility used to be present, but it has been completely leveled. Although ground-water contamination was detected in the 1970s, Dukes said, monitoring well data later indicated that it had disappeared. A public food market was built upon the site and DHEC received a NFA request. DHEC decided that the site needed to be investigated more thoroughly, since it is only located a couple hundred feet from a public well. Therefore, DHEC and a contractor went to the site and collected samples using a direct-push probe and a mobile laboratory. Their analytical results told a different story than the monitoring well data had: contaminants were found at 80,000 ppb in the ground water. At another site, Dukes said, assessment activities were initiated at an active facility. Within a two-week period, DHEC's contractor found ground-water contamination and characterized a plume. The effort, which cost about $127,000, revealed that the plume is 900 feet long, 300 feet wide, 25 to 125 feet below ground surface, and about 700 feet away from a public well. At a third site, Dukes said, very high PCE concentrations (82,000 parts per million [ppm]) have been detected in the soil. This contamination must be addressed very soon, because the contamination is at the edge of a low-income residential area. Dukes said that ground water at this site is also contaminated, but that the contamination does not pose an imminent public health threat. No immediate action to remediate ground water is necessary; the site will be reprioritized after the soil is remediated.

Tennessee
Steve Goins, a representative from the Tennessee Department of Environment and Conservation (DEC), opened his presentation by saying that Tennessee's Fund program is voluntary and has no application deadline established. Only about 40 facilities are currently included in the program, he said, even though there are more than 500 active sites and several abandoned ones located across Tennessee. About two or three sites are added each month, Goins said; this number is expected to increase as more owner/operators learn about the benefits that the Fund program offers. (Significant outreach efforts have been initiated. For example, the Division of Communication Assistance has agreed to help conduct workshops.) Goins said that solvent suppliers are also allowed to participate in the Fund program, and that one just recently applied.

Goins said that revenue for Tennessee's Fund program is generated, in part, through solvent surcharges and annual registration fees. Enforcement mechanisms are in place, he said, to make sure that the solvent surcharges are paid, collected, and forwarded to the state. For example, unregistered drycleaners must pay $50 per day. In addition, solvent suppliers are penalized $50 per day if they fail to collect fees from drycleaners or fail to forward the money to the state. They may be penalized by as much as $10,000 if they sell product to an unregistered drycleaner. Goins commented briefly on registration fees: they are currently calculated based on the number of full-time employees (FTEs) who work at a facility, but he hopes that a different standard (such as solvent usage rate) will be used in the future.

To be eligible for the Fund program, Goins said, a drycleaner must pass an exam (administered by IFI) to become a Certified Environmental Drycleaner (CED). To pass the test, Goins said, drycleaners must be knowledgeable about environmental regulations, hazardous waste management requirements, and Occupational Health and Safety Administration standards. The test is offered in both English and Korean, he said, noting that 10% to 15% of the facilities in Tennessee are owned or operated by Koreans.

Before closing his presentation, Goins described two sites that will be addressed through the Fund program:

• An abandoned facility in Memphis. Goins said that an elementary school is being built on an abandoned drycleaning site. Contaminated soils have been excavated and ground water will be treated. The treatment system will be installed in the school's boiler room.
  
  
• A large facility (100 to 110 employees) under which a 48-inch water main broke. Goins said that this site has not been assessed yet.

Vermont
Michael Smith, a representative from the Vermont Department of Environmental Conservation, said that Vermont does not have a Fund program, but that he is trying to determine whether such a program is feasible. The state has only about 40 active drycleaning facilities, 32 of which use PCE. With such small numbers, Smith said, he is not sure whether adequate revenue could be generated for a Fund program.

Wisconsin
Robin Schmidt, a representative from the Wisconsin Department of Natural Resources (DNR), said that the rules for Wisconsin's Fund program became effective on February 1, 2000. For those facilities that are eligible, she said, the program reimburses cleanup costs. To obtain reimbursement for past costs (i.e., those incurred between 1991 and 1997) drycleaners had to apply to the program by March 31, 2000. A large outreach effort was conducted during early 2000, Schmidt said, to make sure that drycleaners knew about the deadline. (DNR distributed a folder, which contained fact sheets, background information, and applications, to all licensed drycleaners. In addition, the deadline was advertised through newsletters, fabricare institutes, and radio broadcasts.) About 14 sites applied for reimbursement before the deadline. In total, Schmidt said, applicants asked for about $653,000. About $250,000 of the costs will be denied, because they were submitted by drycleaners who are not eligible for the Fund program's benefits. Schmidt said that there are several issues that DNR hopes to address and resolve in the near future:

• The fairness of deductibles. Before obtaining reimbursements from the Fund, Schmidt said, drycleaners must pay deductibles; these can range depending on the cost of the cleanup or the status (inactive or active) of the facility. As the law is currently written, Schmidt said, active facilities must pay at least $10,000, but the minimum for closed facilities is $130,000. Thus, there is a big incentive for companies to stay in business.
  
  
• Ability to pay. Schmidt said that many drycleaners claim to be unable to pay the Fund program's deductibles. She said that a final decision has not been made on how to deal with this, but that she may propose waiving the deductible in such cases, proceeding with cleanup, and imposing liens on the property. (Dukes said that ability to pay has also emerged as an issue in South Carolina; the state has dealt with it by establishing low-interest loans for those who cannot pay their deductibles within a one-year period. He suggested that Schmidt consider this approach as an alternative.)

• Enforcing hazardous waste management practices. Schmidt said that there is currently no way to ensure that drycleaners comply with hazardous waste management requirements.
  
  
• Standardizing agreement processes. Schmidt said that drycleaners cannot obtain reimbursement until they have signed an agreement with the state. It currently takes about three months to review an agreement, she said, but the time could probably be reduced if agreement formats and review processes are standardized. DNR will work with its legal department on this.

• Other issues. Schmidt said that DNR is trying to determine the best ways to address petroleum sites and commingled plumes.

INTERSTATE TECHNOLOGY AND REGULATORY COOPERATION (ITRC) WORK GROUP
Brent Hartsfield said that ITRC, a state-led organization formed in 1995, promotes innovative technologies by reducing regulatory and technological barriers. ITRC is currently composed of representatives from about 31 states, as well as members from industry, the Western Governors Association, the Southern States Energy Board, the U.S. Department of Energy, the U.S. Department of Defense, the U.S. Environmental Protection Agency (EPA), and other stakeholders.

ITRC's main goals are to (1) reduce regulatory barriers that prohibit the use of innovative technologies, (2) track remedial and cost efficacy of new technologies, and (3) gather information about lessons that have been learned. Hartsfield provided an example of one regulatory barrier that ITRC has addressed: injecting substances into the subsurface. Many innovative in situ technologies remediate subsurface contaminants by injecting substances (e.g., surfactants, co-solvents, hydrogen peroxide, or permanganate) into the ground. In many cases, regulatory agencies have not allowed these technologies to be used, because they violate some of the rules that have been established by underground injection control (UIC) programs. These programs were developed, in part, to prevent additional releases to subsurface environments. ITRC is trying to convince UIC managers that using innovative technologies will improve subsurface conditions over the long term. Significant headway is being made, but there is still much variation, across the states, in how UIC managers view this issue. In Florida, Hartsfield said, injections have been allowed for several years. At first, UIC managers did not allow injected streams to contain constituents that exceeded primary drinking water standards. This made it difficult to use a product like potassium permanganate, which is often associated with significant quantities of cadmium. Recently, however, EPA's Region 4 stated that substances may be injected even if they exceed standards. After an injection is performed, however, the subsurface must be monitored to prove that excessive residuals are not present.

Hartsfield said that there are several work groups within ITRC. Each of these groups focuses on a particular technology or technical issue, releases products, and offers services. For example, he said, some work groups have released case studies, technical/regulatory guidelines, and technology overviews. Some have delivered training courses, established information sharing avenues, and served as technology advocates. Hartsfield, who is a member of ITRC's DNAPL Work Group, said that his group is currently:

• Writing a technology overview document. In April 2000, Hartsfield said, the group produced a draft document, entitled Technology Overview: Dense Non-Aqueous Phase Liquids: Review of Emerging Characterization and Remediation Technologies. The document provides information on three innovative characterization techniques (geophysical technologies, direct-push, and in situ large-volume-tracer-type techniques) and three innovative remedial systems (in situ flushing, thermal technologies, and in situ chemical oxidation). The document will be finalized soon, Hartsfield said, and SCRD members will be notified when it is available.
  
  
• Coordinating with the Interagency DNAPL Consortium. Hartsfield said that the Consortium is performing pilot studies at the Cape Canaveral Air Station. In situ oxidation and two variations of steam flushing (six-phase and steam injection) are being tested to evaluate their ability to remediate DNAPL.

Within the next year, Hartsfield said, the DNAPL Work Group also plans to: (1) create a document that focuses on thermal remediation technologies, and (2) start collaborating with SCRD.

Hartsfield said that some of the work being performed by other ITRC work groups might also interest SCRD members. For example, he said, several documents have already been written by the In Situ Bioremediation Work Group, and documents will be released by the In Situ Chemical Oxidation Work Group and the Permeable Reactive Barriers (PRB) Work Group in the future. Also, Hartsfield said, SCRD members might benefit from attending the following ITRC courses: (1) Natural Attenuation of Chlorinated Solvents in Ground Water: Principles and Practices, and (2) In Situ Permeable Reactive Barriers: Application and Deployment. (Additional information about ITRC can be found at http://www.sso.org/ecos/itrc.)

PROPOSED MODEL LEGISLATION
Janet Hickman, a representative from The Dow Chemical Company, said that the Halogenated Solvents Industry Alliance (HSIA) has created a model legislation package. This is intended to serve as a template for states that want to set up Fund programs. Hickman, who is a member of HSIA, provided background information on HSIA, explained why it undertook this effort, outlined the model's key elements, and gathered comments from the audience.

Background Information
Hickman said that HSIA, advocates for safe and responsible solvent usage. Its members include chlorinated solvent users, manufacturers, and distributors. Hickman said that HSIA funds scientific research (e.g., toxicological studies) and serves as an information resource. It releases bimonthly newsletters, publishes white papers, and generates a variety of other materials (e.g., a drycleaning safe handling book). HSIA also would like to serve as a resource to regulators and to provide comments on proposed legislative packages. (Additional information about HSIA can be found at http://HSIA.org.)

Hickman said that drycleaners do not typically have the financial capacity, the technical expertise, or the legal expertise to address site assessment and remediation. HSIA has summarized these issues into a problem statement: How do you devise a strategy to meet society's desire for a cleaner environment and safe drinking water that fits within today's legal framework and is both technically and economically feasible? In an effort to address the problem statement, HSIA developed a model Fund program legislative package. During the effort, HSIA gathered ideas from other relevant models (e.g., state drycleaning Fund programs, gas station UST cleanup programs, IFI's proposed national model legislation, and the Barton Bill), and gathered information about the lessons that have been learned about existing Fund programs.

A Summary of the Model Legislation Package
Hickman distributed the draft model legislation package to meeting attendees and summarized some of its key elements. The first three sections, she said, contain boilerplate legal language. The fourth one describes what states must do to implement a Fund program. This includes establishing (1) performance standards for new drycleaning facilities and distribution facilities, (2) a schedule for "retrofitting" existing facilities, (3) criteria for reporting contamination or releases, (4) procedures for initial investigations, (5) criteria for prioritizing sites, (6) procedures for investigating, assessing, and remediating sites in a prioritized order, and (7) criteria for determining completed actions and NFA sites. Hickman said that Section 4 also lists a number of pollution prevention activities that should be implemented at all sites. For example, it states that all solvent-contaminated wastes must go to authorized hazardous waste facilities. It also states that no wastewater can be discharged to land, water, sanitary sewers, or septic tanks. It also specifies that (1) solvents and wastes must be stored in closed containers, (2) new or replacement equipment must be at least third generation,⁴ (3) dikes or containment structures must be installed for drycleaning machines and solvent storage and waste areas, (4) all diked surfaces must be coated, (5) solvent must be transferred through a direct-coupled solvent delivery system, and (6) facility owners/operators must obtain industry certification.

Section 5 of the model legislation, Hickman said, discusses what the Fund can be used for and provides a general overview of how its monies are to be managed. For example, it states that:

• The Fund will only cover contamination from drycleaning activities.
  
  
• Assessment and remediation costs will be paid upfront by the state rather than through a reimbursement system.
  
  
• Fund monies may not be used by or loaned to any other agency, and the Fund's interest/earnings may only be credited to the Fund itself.
  
  
• Fee collection should stop if "unobligated" principal is $5 million or greater, but that collection should start again if the Fund drops to $3 million.
  
  
• States should be protected from incurring costs that exceed the Fund's balance.

Section 5 also provides for annual drycleaning audits and notes that these activities should be documented in the public record.

Section 6 describes how revenues are to be raised. Like many of the existing state Fund programs, Hickman said, the model imposes a solvent surcharge fee. (HSIA is proposing a $5-10 per gallon fee on chlorinated solvents and a $1-2 per gallon fee on non-chlorinated solvents.) Basing a large percentage of the Fund's revenue on solvent surcharges can be risky, Hickman said, noting that PCE usage has decreased by 70% over the last 10 years. Thus, the model package also recommends using other avenues to collect revenue, such as a 1% environmental surcharge on gross receipts and an annual registration fee. (Hickman said that annual registration fees will be $100 for drycleaning facilities. For distributors, the fee will be $5,000 for the first year and $2,500 thereafter.) Hickman said that Section 6 recommends establishing an enforcement system, in which penalties would be issued if a distributor sold solvent to an unregistered facility or if a cleaner purchased products from an unregistered distributor. She said that the model legislation incorporates suggestions aimed to help state representatives determine whether cleaners and distributors are paying into the Fund. That is, it states that DOR must (1) provide certificates to registered facilities and (2) compile a list of registered facilities, which can be released for public inspection.

Section 7 places restrictions on the expenditure of funds, Hickman said, and explicitly states that (1) no more than $250,000 can be spent on any site during a given year, (2) the Fund must always maintain a minimum balance of $100,000, and (3) monies can not be used for federal Superfund sites or sites that are permitted as hazardous waste management facilities under RCRA. Section 8 states that a Drycleaning Environmental Response Board must be established to provide oversight, and says that its members should consist of small drycleaners (up to 10 FTEs), medium-sized cleaners (11 to 24 FTEs), large cleaners (more than 25 FTEs), wholesale distributors that sell drycleaning solvents, state environmental departments, the engineering/scientific community, and lessors of real property. Section 9 addresses liability issues, Hickman explained, noting that the model legislation recognizes that retroactive liability under Superfund is unlikely to be repealed or revised any time soon. Eligible sites—once contamination is reported—are protected from administrative and judicial actions. Also, Hickman said, eligible sites are not liable to third parties or to any other person unless (1) there is proof that the drycleaner has failed to exercise due care, or (2) the drycleaner is being sued based solely on personal injury claims. Hickman said that Sections 10, 11, and 12 outline provisions for administrative costs, provisions to allocate funds to state academic institutes, and notification requirements.

Hickman said that she hopes that this model legislative package will serve as a useful springboard for states that are considering developing Fund programs. Although it is still considered a working draft, it is being presented to organizations that have expressed interest. These include the North Carolina Association of Cleaners and Launderers, the Alabama Drycleaners Association, the Missouri Drycleaners Coalition, the Louisiana/Mississippi Drycleaners and Launderers Association, and the Northeast Fabricare Association.

Comments on the Model Legislation Package
Hickman asked attendees to provide comments on the model legislation. Attendees offered the following:

• Industrial certification. Dukes noted that HSIA's proposed model legislation requires drycleaners to obtain industrial certification. The same requirement exists in South Carolina, he said, where it has caused several problems. For example, he said, the exam that IFI administers in South Carolina is slanted to PCE-based users. Thus, petroleum-based users have had trouble passing it, and this has kept several of them from obtaining eligibility under the Fund program. Dukes also questioned the efficacy of the certification process, saying that (1) the exam contains several questions that do not even pertain to environmental issues, and (2) he has met some certified drycleaners who barely know how to run their machines. Because the certification program has been such a failure in South Carolina, Dukes said, his department is hoping to eliminate it as a requirement. Goins said that Tennessee also requires drycleaners to be certified; unlike Dukes, however, Goins thinks the certification process is valuable. He said that petroleum users in Tennessee have had little problem passing IFI's exam. In fact, they have higher passing rates than PCE users do. Eriksen said that Illinois also has a certification program. He does not think that it will eradicate all bad management practices, but said that it is probably a good first step toward this goal. Hickman agreed with Eriksen. She asked SCRD members to send her suggestions on how to optimize the efficacy of certification programs. Juho So offered one suggestion: make sure that facility operators (not just owners) are certified.

• Revenue caps. Several attendees commented on the model legislation's revenue cap, noting that they did not think it is advisable to stop collecting fees when $5 million of unobligated funds have accumulated and begin again when the Fund drops to $3 million. Eriksen stressed the importance of defining what HSIA means by the terms "obligated" and "unobligated." (Some groups may think funds become obligated once claims are submitted, but others may define them that way only after budgets have been approved.) Eriksen said that the gap between HSIA's maximum and minimum cap values may be too narrow. Some states are not able to switch off fees immediately. In Illinois, Eriksen said, it takes 90 days to do so; thus, by the time fee collection would actually stop, the Fund might be near the point of needing to have collection initiated again. Goins questioned whether a $5 million cap is too low. It may be wise to generate as much money as possible initially, he said; even if funds get large during the first few years, they will dwindle rapidly once assessment and remediation activities are initiated at several sites. Ethridge did not like the idea of imposing a revenue cap, but Leo Henning said that he did, because the drycleaning community might become upset if they thought the state had the power to amass excessively inflated funds. Ethridge said that the drycleaners' concerns could probably be addressed without using a revenue cap; as an alternative, he suggested having the Fund evaluated and fee rates adjusted by a review board every 5 to 10 years. Following up on Ethridge's comment, Hickman asked whether other states had established review panels. DeZeeuw said that a committee has been formed in Oregon. Eriksen said that a seven-member council exists in Illinois. Schmidt said that a governor-appointed council is established in Wisconsin.
  
  
• Composition of the Drycleaning Environmental Response Board. Schmidt noted that the model legislation proposes establishing a Drycleaning Environmental Response Board. She recommended including environmentalists on the Board.

• Non-chlorinated solvent surcharge fees. Dukes commented on the model legislation's proposed solvent surcharges, noting that it recommends charging $5-10 for every gallon of PCE and $1-2 per gallon for petroleum products. This 5:1 ratio is also used in South Carolina, Dukes said; it was chosen because legislators recognized that petroleum users purchase more solvent. Thus, they thought using this ratio would make it so PCE users and petroleum users payed equivalent amounts into the Fund. After evaluating revenues for a few years, however, it appears that petroleum users in South Carolina pay more than their PCE-based counterparts. Many petroleum users feel this is unfair, especially because cleanups at PCE-based sites are expected to be more common and more expensive than at petroleum-based sites. Goins said that equity was voiced as a concern in Tennessee as well; the issue has been resolved by tracking where revenue comes from and making sure that fees collected from petroleum users are only used to address petroleum-contaminated sites. Likewise, fees collected from PCE users are only used at PCE-contaminated sites. (If both types of contaminants are present, DEC determines which poses the most risk and uses the revenue associated with that contaminant to pay for assessment and cleanup.)
  
  
• Clarification on which solvent distributors will be covered under the Fund program. Trippler asked whether distributors are covered under the proposed model legislation. Hickman said that those that sell only to drycleaning facilities will be covered. Trippler said that Hickman's answer contradicts what appears on page 14 of the draft model legislation. Hickman agreed to fix this.
  
  
• Covering solvent distributors under the Fund program. Henning said that he does not think Fund programs should cover solvent distributors. If HSIA insists upon including them, he said, he would recommend charging higher registration fees than the model legislation currently proposes. Hickman thanked Henning for his comments, but said that there are some compelling reasons why distributors should be eligible for benefits. For example, she said, distributors help Fund programs by (1) collecting surcharge fees and forwarding these to the state, (2) carrying the tax that drycleaners pay on their books, and (3) helping to advocate the Fund program. Henning questioned the validity of the last two claims. Eriksen said that he tends to agree with Henning's stance—that distributors should not be covered—but that he might reconsider his position if distributors agreed to spearhead active outreach and educational efforts. Eriksen said that distributors are in an ideal position to impact operational practices and promote compliance with environmental regulations, because they communicate with drycleaners face to face.
  
  
• Storing drycleaning solvents. DeZeeuw noted that the model legislation indicates that (1) solvent may be stored onsite, and (2) solvent must be delivered using a direct-coupled delivery system. He felt that these two statements contradict each other, because stored solvent cannot be transferred via a direct-coupled solvent delivery system. In addition, DeZeeuw said, he thinks that facilities that store solvent might be buying it illegally to avoid surcharges. Thus, he does not think drycleaners should be allowed to store solvents onsite. Hickman said that she will clarify the model legislation's language to indicate that it refers to detergents and pre-spotting agents, not materials for use in drycleaning machines.
  
  
• Provisions for administrative costs. Trippler noted that the model legislation states that administrative costs should not be charged to the Fund. He wondered whether some states will disagree with this.
  
  
• Enforcement. Henning recommended adding enforcement provisions to the model legislation so that state representatives can penalize those who fail to meet environmental regulations.
  
  
• Liability coverage. Henning said that he thinks the model legislation provides too much liability coverage. He said states generally do not want to be involved with third-party claims. Goins also commented on this issue: he advised against providing retroactive coverage.
  
  
• Specifying who wrote the model legislation and making sure no one is led to believe that SCRD has endorsed it. After looking through Hickman's handouts, Schmidt said that the package does not clearly indicate who the authors are. This is a problem, she said, and recommended adding HSIA's logo and name to the cover page. Schmidt and Henning stressed that no one should be led to believe that SCRD endorses the model legislation just because it was discussed during one of SCRD's meetings.
  
  
• Is it appropriate for HSIA to create a model legislation package? Steve Mitchell, a drycleaner from Oregon, said that he thinks it is inappropriate for chemical manufacturers (one of HSIA's member groups) to instruct states on how to address drycleaning sites. Hickman said that HSIA undertook this effort after several organizations asked for help developing Fund programs. She believes that HSIA's effort will prevent states from repeating old mistakes in new legislation. Also, it will make it so that states do not have to start from scratch when writing legislation.
  
  
• Given the differences between states, is it really possible to create a meaningful template? Schmidt noted that there are many variations within existing state Fund programs. For example, some offer reimbursement, while others perform state-led cleanups. At this point, she said, it is not clear which will work better. She questioned whether it might be more useful to create a document that lists a menu of options rather than just one approach.

Trippler suggested establishing a page on SCRD's Web board for additional comments. Bruce Nicholson suggested formalizing SCRD's comments and sending them to Association of State and Territorial Solid Waste Management Officials (ASTSWMO). That way, any concerns that SCRD has about the model legislation could be more readily available to states. SCRD members agreed that Nicholson's recommendation should be considered.

COST ISSUES

How Do States Control Costs?
Trippler asked attendees to describe how their states control assessment and remediation costs. Attendees obliged; the following table summarizes their responses.

Approach Used to Control Assessment and Remediation Costs

Kansas: Site assessment and cleanup is usually performed by state-hired consultants. Drycleaners who initiate activities voluntarily will be reimbursed for their efforts, but only if their sites rank high enough on the priority list. Money from the Fund program will not be used to pay for sites that have very low risk. If a cleanup is necessary, but it is conducted before it comes up on the state's priority list, reimbursement will not be issued until KDHE reaches it on the priority list.

Illinois: Drycleaners hire consultants to perform assessments and cleanups. The costs incurred are reimbursed by the Fund program. The Department of Community, Commerce, and Environmental Affairs has created a list of consultants and contractors that are willing to address drycleaning sites. Drycleaners can use this list as a reference. They must obtain three bids. (There are two drycleaner associations in the state that guide drycleaners through the bidding process.) The three bids are then submitted to the state, which works with the drycleaner to select an appropriate consultant/contractor. The state must preapprove costs. If a contractor proceeds with work before approval is granted, the contractor will be held liable for the costs, not the drycleaner. If necessary, the state can take a more direct lead rather than relying on a reimbursement system. (A provision in the Fund program's statue allows the state to contract with consultants directly.)

Minnesota: Drycleaners hire consultants to perform assessments and cleanups. The costs incurred are reimbursed by the Fund program. The program, however, only pays costs that MPCA deems necessary. For example, if 20 wells are installed, but only 3 were needed, MPCA will only pay for 3 wells. It benefits the drycleaners and consultants to have their costs preapproved before initiating assessment and cleanup.

Oregon: For some sites, DEQ hires consultants and pays them directly for their field work. At other sites, drycleaners hire their own consultants, get their costs preapproved by DEQ, proceed with the assessment or cleanup, and then ask for reimbursement.

Tennessee: Drycleaners hire consultants to perform assessments and cleanups. The costs incurred are reimbursed by the Fund program. To be eligible for reimbursement, a drycleaner must submit a work plan and cost estimate to DEC and obtain preapproval for each phase of work. (Tennessee divides the work into five or six phases.)

Wisconsin: Drycleaners hire consultants to perform assessments and cleanups. The costs incurred are reimbursed by the Fund program. To be eligible for reimbursement, drycleaners must use consultants and remedial approaches that have been approved by DNR. Drycleaners are expected to obtain three bids. They do not have to use the contractor that submits the lowest bid, but they must justify their choice of contractor. Before receiving reimbursement benefits, site owners will have to pay a deductible, the amount of which will vary depending on the cost of the cleanup and the type of facility that is being cleaned.

Fee Structures: A Discussion on Gross Receipt Surcharges
Trippler reiterated a point that had been brought up several times during the meeting: over the last several years, PCE usage has decreased markedly. As a result, less solvent surcharges are collected; this has caused annual revenues for the Fund to decrease. Trippler said that this trend is likely to continue as additional cleaners switch to more efficient PCE-based drycleaning machines or start using "greener" agents. A reduction in PCE usage, he said, could have significant impacts on Fund revenues in several states. He asked attendees to discuss how they plan to keep their revenues stable.

Attendees said that annual revenues will be less influenced by market shifts if a state's fee structure relies more heavily on annual registration/license fees, sales tax, or gross receipt surcharges. Nearly all of the meeting attendees agreed that it is beneficial to collect gross receipt surcharges. In fact, many states are already doing so, and others are moving towards this approach. They did recognize, however, that some states might have trouble implementing this surcharge, because:

• There are political and administrative obstacles. DeZeeuw said that Oregon does not have a sales tax; in fact, it has been voted down on several occasions. A gross receipt surcharge might be very unpopular, he said, because it might be perceived as a sales tax. Also, he said, collecting a surcharge would be difficult from an administrative standpoint, since there is no collection system.
  
  
• Many large drycleaners do not support such an approach. If a gross receipt surcharge is adopted, DeZeeuw said, large cleaners will pay more money into the Fund than smaller ones. Some large cleaners argue that this is unfair, and that a facility should pay based on its likelihood to require Fund benefits rather than simply on its ability to pay.

• Some drycleaners claim that adding another surcharge will put them out of business. Some drycleaners claim that they will be unable to remain competitive if they are forced to add another surcharge to their customers' bills. In Minnesota, Trippler said, drycleaners located near the Dakota borders are particularly concerned about this. As it is, he noted, these cleaners are already losing business to their Dakota counterparts. Schmidt asked whether the environmental surcharge could be marketed in a positive way. Many consumers are environmentally conscious, she said, and would not begrudge a surcharge if they knew it was being used to protect the environment. Schmidt proposed asking fabricare associations to work on marketing strategies with drycleaners.

Making Sure That Fees Are Being Paid
Most states require cleaners to be up to date on their payments in order to be eligible for Fund benefits. Thus, it is essential for those who administer the program to have access to payment information. In many states, however, obtaining this information from DOR can be very difficult. Some states have developed or proposed approaches to circumvent this obstacle. These are summarized in the following table.

Approaches Used (or Proposed) to Ensure That Fees Are Paid and Ways to Obtain Information on Payment Status

Illinois: DOR has agreed to release information to the Drycleaner Environmental Response Trust Fund on the condition that the latter will keep all of the information confidential. Even though this agreement has been established, it is still difficult to determine whether facilities are up to date with solvent surcharge fees. This is because solvent suppliers (who collect the surcharges and send them to DOR) report total gallons sold without breaking this number down by facility. Distributors will be asked to change their reporting formats.

Oregon: DOR is required to (1) issue certificates to drycleaners that pay their annual registration fees, and (2) send a list of certified facilities to DEQ on an annual basis. This allows DEQ to determine which cleaners have paid their registration fees, but it still does not provide information on whether they are up to date on solvent fees.

South Carolina: When drycleaners submit applications, they must certify that they are up to date on their payments, then have their applications notarized. Drycleaners that falsify applications are subject to prosecution. Thus, there is a strong incentive to be honest.

Tennessee: For the most part, DOR is bypassed, because drycleaners send their money directly to DEC. When DEC has asked DOR for information, it has had no problem obtaining it, because there is a statute that orders DOR to share information. To make sure that solvent fees are being paid, DEC requires (1) distributors to report the amount of solvent they sell, and (2) drycleaners to report the amount of solvent they purchase. The numbers are then compared.

Wisconsin: In general, DOR does not share information with DNR. In Wisconsin, the drycleaners police each other. That is, they call DNR if they know that a competitor is not licensed. DNR advises them to call DOR and to follow up with a call to the Governor if DOR fails to pursue the noncompliant competitor.

Liability Coverage and Its Potential Impact on Fund Money
Henning said that he fears that Fund monies could be depleted rapidly if programs offer full liability coverage. Some sites may have commingled plumes and be impacted by numerous source areas. If a lawsuit is brought forth, and a drycleaner is listed as a responsible party, Henning said, the state's Fund program could be overwhelmed with costs if it does not have a liability cap.

WASTEWATER: DISPOSAL, STATE REQUIREMENTS, AND UNRESOLVED ISSUES

An Overview of Issues Pertaining to Wastewater Disposal and Treatment
Linn listed the types of contact water (i.e., water that contacts solvent or solvent vapors) that are generated during the drycleaning process: separator water, vacuum water, precleaning and spotting wastes, mop water, conventional laundry water, and boiler blow-down water. Sampling results indicate that these waters often have high solvent concentrations associated with them. (Linn distributed an April 2000 document entitled Wastewater Streams Generated in Drycleaning Operations; he said that it contains additional information about the different wastewater streams.)

Linn focused the remainder of his discussion on separator water, which is generated when solvent-laden water enters a separator. Within a separator, solvents and water physically separate; the former are reused for cleaning purposes and the latter is handled in a variety of ways. The fate of separator water is of concern to many regulators, Linn noted, because separator water can contain high solvent concentrations, particularly if a drycleaner fails to maintain the separator properly. During some field visits, Linn said, Florida representatives have actually seen slugs of PCE sitting in recovery buckets. Linn listed some of the methods that are used to handle separator water:

• Discharging to sanitary sewers. Many states still allow drycleaners to discharge separator water to the sewer. In fact, Linn said, IFI polled more than 1,000 drycleaners in 1989; the results indicated that 70% of them discharge to sewers and septic systems. Linn said that discharges from drycleaners have caused problems for several publicly owned treatment works (POTWs). For example, at one, microbial populations were killed off after a drycleaner discharged high concentrations of PCE into the sanitary sewer. In some cases, Linn said, POTWs have been held liable for the contamination that leaks from sewer lines.⁵ Contaminants that travel through the sewers can also cause problems upstream of the POTWs. One EPA study, Linn said, predicted that 5% of the stream that passes through sanitary sewers leaks out. Dukes said that he was not surprised by this estimate; he once read that sewer designs allow up to 10,000 gallons of leakage per mile per day. (Dukes will distribute this reference if he can find it.)
  
  
• Using evaporators or atomizers. Linn and Stupak noted that several evaporation systems (e.g., Zero Waste) and atomizers (e.g., Safety Kleen, Dynaclean, Hydromist, and Galaxy) are available on the market. These systems are supposed to reduce PCE concentrations, Stupak said, before evaporating or misting separator water into the air. There is much variation between the treatment systems, Linn said; some have carbon-absorption filters, some have polymer filters, and some have alarm systems that go off when the treatment unit malfunctions.
  
  
• More primitive evaporation systems. Linn said that some drycleaners are still evaporating their separator water using crockpots and muck cookers.
  
  
• Illegal dumping. In some cases, Linn said, state representatives may find flagrant disregard for rules. Some drycleaners may still be dumping recovery water out their back doors or down the sewer.

How Do the Different States Address Separator Water?
Linn said that the requirements that drycleaners must meet when handling separator water vary significantly between the states. He described what is required in Florida and asked other attendees for information on their states. Responses are summarized in the following table.

Addressing Separator Water

Florida: In 1996, representatives from DEP, RCRA, and Air Quality worked together to address separator water. This effort produced a memorandum, which: Encourages drycleaners to have separator water hauled off by an authorized hazardous waste management company. Tells drycleaners that they must reduce PCE concentrations to 700 ppb before misting or evaporating it. Puts responsibility on the owners/operators by telling them that they must: -Keep records. - Send their filters to hazardous waste management facilities. - Make sure that, if an equivalent treatment technology is used, the unit meets the same treatment concentration standards prior to discharge. -Make sure that treated separator wastestreams are evaporated using a heat source or vaporized using a functionally equivalent system.

Illinois: Facilities must demonstrate that PCE concentrations are below a certain value before releasing separator water through an evaporator or mister. A compliance program will be initiated soon to determine whether discharges are acceptable and to make sure that filters are changed often enough.

Kansas: Drycleaners may have wastes hauled to a hazardous waste facility, or they may use heated evaporation units or misters.

Louisiana: Drycleaners must treat all of their wastes as solid or hazardous wastes. Some wastes are allowed down the sewer, but some POTWs have disallowed this, since they can be held liable for contamination.

Minnesota: Drycleaners must be in compliance with state and federal rules.

North Carolina: The Fund program's rules for minimum management practices state that: There may be no discharge to sewers. Drycleaners must retain records (including receipts for separator water treatment systems) and save all service- and maintenance-related invoices.

Oregon: According to the Fund program's statute, nothing can be discharged to the sewer. A guidance document has been created that advises cleaners to (1) make sure PCE levels are reduced to less than 1 ppm, (2) use a two-carbon-filter treatment system, (3) add an alarm to the treatment system, and (4) make sure all discharges occur outside work areas.

South Carolina: For the most part, no water may be discharged to the sanitary sewer. Dukes said that he does know of one facility, however, that is allowed to discharge separator water with 25 ppm PCE.

Tennessee: No discharges to the sanitary sewers are allowed.

Vermont: Evaporator pans are used.

Linn acknowledged that the requirements listed above do not necessarily reflect a state's ideal set of rules. For example, Linn said, he wishes separator water discharges to sewers were illegal in Florida, but this is not currently possible given how statutes and laws are set up. (In Florida, the memorandum had to be put together using existing regulations; nothing had been written in previous statutes about banning disposal to sewers.) Taber said that North Carolina's rules also reflect a compromise rather than an ideal. In the future, she hopes, her state will establish performance standards that must be met before evaporating or misting separator water into the environment. Dukes questioned whether it is realistic to identify meaningful performance standards.

Linn said that he thought it was great that attendees are so interested in exploring the potential hazards that are associated with separator water. He encouraged them, however, to avoid getting bogged down in this issue since it falls under the domain of hazardous waste management. It is more appropriate, he said, for RCRA's staff to determine how this wastestream should be handled.

Attendees were asked to indicate which requirements they think are the most important. Various suggestions were offered, including (1) disallowing discharge to the sanitary sewer, (2) requiring drycleaners to change their filters regularly, (3) requiring a two-filter treatment unit, and (4) requiring drycleaners to install an alarm system so that they will know when their treatment units are not working properly.

Unresolved Issues

Are Treatment Units Efficient Enough, and Which Are the Best to Use?
Several attendees expressed concern about handling separator water with evaporators and misters. They questioned whether treatment units reduce PCE concentrations to low enough levels before evaporating or misting the separator water and releasing it to the outdoor environment. Stupak distributed a handout that summarized the PCE levels that treatment-unit manufacturers claim their products can meet. For one system, he said, the manufacturer claims that its product can reduce PCE to less than 100 ppb; the other five systems are touted as being able to achieve concentrations of less than 10 ppb. Juho So expressed some skepticism about these claims. Linn said that a group in California tested some treatment units to determine which are most effective, but did not publish their results because they probably feared vendor lawsuits. SCRD members agreed that it would be helpful if IFI would perform a comparison study on the different systems and release information from the study to drycleaners. If IFI were to take on such a project, Mary Scalco said, it would not advocate one product over the other. Rather, IFI would simply release a guidance document that outlines what drycleaners should look for when purchasing a treatment unit.

Are Treatment Units Being Operated Properly?
Attendees brought up an important point about treatment systems: they will definitely fail to meet their potential if they are not operated properly. For example, significant quantities of PCE will remain in separator water if a treatment unit's filters are not changed regularly. Some attendees suggested setting up outreach programs to educate drycleaners about how to operate machinery and equipment. Hickman said that forcing drycleaners to obtain industrial certification will also help to initiate the educational effort.

Could Contaminants Redeposit on the Ground?
Some attendees wondered if contaminants could be redeposited after being vented out of drycleaning facilities. They recognized that this would probably not be a problem in dry environments, but wondered if it would be in rainy or humid areas. Some attendees did not think that the amounts released to the air would be high enough to contaminate soil and ground water through deposition. They noted that some air quality divisions allow PCE air emissions of up to 36 or 100 pounds per year. Thus, they did not think that the amounts coming out of the misters or evaporators would concern air quality experts. Taber and Nicholson said that they are still concerned. Taber said that she knows of a drycleaner that, although it has been operating for less than two years, has found soil and ground-water contamination near its mister. DeZeeuw asked whether SCRD should identify a group that could fund research on this issue. Taber thought this was a good idea, noting that she actually proposed asking EPA to perform such a study during a previous conference call. She asked if there was enough interest to pursue this idea. The consensus was that there is not, at least at this point. Scalco said that IFI performed some preliminary laboratory tests on evaporators and misters and that she would be happy to share this with SCRD.

Could Other Methods Be Used to Treat Separator Water?
Stupak asked if anyone has considered dropping potassium permanganate into recovery buckets to treat separator water. Henning said that this would probably mineralize PCE, but that he did not know what quantities would need to be added. Hickman said that EPA's Office of Solid Waste might regard this approach as a hazardous waste treatment activity that requires a permit.

SUBGROUP REPORTS: DISCUSSIONS ON CURRENT AND FUTURE SCRD ACTIVITIES
Three Subgroups have been formed within SCRD. During the meeting, each Subgroup met in a breakout session to discuss the status of projects and future goals. Subgroup leaders were then asked to summarize what was discussed during the breakout sessions. The leaders discussed projects that are currently being worked on and identified new ones that will be initiated soon. These are discussed below and summarized in tabular form in Attachment B.

Outreach Subgroup
Robin Schmidt, the Outreach Subgroup's leader, said that the Subgroup plans to:

• Put together a list of conferences. Schmidt said that the Outreach Subgroup will identify upcoming conferences and meetings that may be of interest to SCRD. It is important to identify these events, Schmidt said, because SCRD members may want to (1) present papers or posters at them or (2) plan a SCRD meeting in conjunction with one of them.
  
  
• Distribute additional outreach letters. Schmidt noted that the Outreach Subgroup sent an introductory letter—listing SCRD Web site address, goals, activities, and key players—to numerous trade and state associations. Unfortunately, she said, the Subgroup has not received many responses to their letter. Additional letters will be sent out after Hickman provides a list of national organizations that might be interested in SCRD's activities.
  
  
• Create an Outreach Toolbox. Schmidt said that the Outreach Subgroup wants to create an online toolbox that contains a library of photos and presentations. She asked attendees to send digital photos that they are willing to share to Carolyn Perroni.
  
  
• Create a brochure. Schmidt noted that Perroni created a one-page document about SCRD. The Outreach Subgroup plans to modify this and to make it available as a brochure.
  
  
• Update SCRD products regularly. Schmidt said that SCRD's other two Subgroups plan to post their findings on SCRD's Web site. This information will need to be updated regularly. The Outreach Subgroup will communicate with the other two Subgroups to determine the best way to make sure these updates occur.
  
  
• Compile a site profile database. Schmidt said that the Outreach Subgroup would like to create an online site profile database, which could be a useful tool for consultants, drycleaners, and state project managers. Schmidt said that the database could be set up so that users could search by contaminant or by geological conditions. Contact names would be provided, she said, along with general information about the technologies that have been used. Basic information for the profiles could be gathered by distributing a one-page questionnaire. (Perroni said that the Remediation Technologies Development Forum's PRB Action Team has created an online database, whose Web address she will forward.)

Program Development/Administration Subgroup
DeZeeuw, the Program Development/Administration Subgroup's leader, said that Subgroup members are currently working on:

• Comparing and contrasting each state's Fund program through a series of tables. The tables were drafted over the summer of 1999, DeZeeuw said, and have been revised on several occasions. During the Subgroup's breakout session, the tables were reviewed again; members decided that changes should be made to Table 1. (The column entitled "Requirements of Facility Owners/Operators" should be split into two columns to separate eligibility requirements from waste minimization requirements. Also, a column that references state statutes should be added.)
  
  
• Finalizing a presentation. DeZeeuw said that the Subgroup has written a paper that Schmidt will present at Battelle's Remediation of Chlorinated and Recalcitrant Compounds conference, which will take place in Monterey, California, in May 2000. (Schmidt brought a draft version of her presentation to the meeting and presented it. Participants expressed praise for the paper, but provided some comments as well. These comments are summarized in Appendix C. The presentation will be posted on SCRD's Web site in the future.)

DeZeeuw said that the Subgroup has also identified several additional projects to work on:

• Compiling lessons learned. DeZeeuw said that the Subgroup will provide information on what has worked and failed in different states. (The focus will be on administrative issues, such as fee structures and cost control approaches.) Schmidt suggested taking this project further by creating a menu-driven online document that summarizes SCRD's lessons learned. She said that this would be a useful tool for states that are developing programs; it could serve as an alternative to HSIA's model legislation.
  
  
• Evaluating tax credits. Some states offer tax credits; the Subgroup will evaluate the incentives that they provide and the impact they could have on state Fund programs.
  
  
• Exploring insurance issues. The Subgroup will evaluate whether existing insurance policies can bring in revenue. Also, the Subgroup will research whether drycleaners can obtain premium reductions.

Project Management/Technical Issues Subgroup
Linn, the Project Management/Technical Issues Subgroup's leader, described the projects that the Project Management/Technical Issues Subgroup is working on:

• Gathering information on technologies and creating technology profiles. Linn said that Subgroup members are gathering information on technologies that are being used to assess and remediate drycleaning sites. This information is being collected through surveys and phone interviews. Once the information is compiled, the Subgroup will hold a conference call to discuss posting technology profiles on SCRD's Web site. (The Subgroup will communicate with Perroni and the Outreach Subgroup to determine how best to do this, and whether it should be addressed as part of the Outreach Subgroup's site profiling effort.) Linn said that the technical profiles should hone in on practical matters, such as lessons that have been learned, problems that have been encountered, and solutions that have been employed. He said that the technologies profiled will include HRC™, co-solvent flushing, chemical oxidation, PRBs, anaerobic bioventing, and recirculating wells. The profiles will be working documents, and more will be added to them as more information comes forth about the technologies' efficacy at drycleaning sites.
  
  
• Finalizing a poster. Linn said that the Subgroup plans to present a poster at Battelle's May 2000 meeting (described above). Perroni brought a draft version of the poster to the meeting, and Subgroup members reviewed it. Linn said that David Anderson will present the Subgroup's poster, but asked if others could assist him. Schmidt and Smith said that they will be at the conference.

Linn said that Dukes—a Subgroup member—recommended an additional activity for the Subgroup: developing recommendations on acceptable levels of exposure to drycleaning solvents. Dukes said that several standards are currently in place, but that some people question the relevance of them. He recommended exploring this issue to make sure that standards are not just being set based on precedence. Having reasonable standards is important, Dukes said, because some cost-effective technologies may not be able to reach the strict standards that are currently established in some states. Meeting participants said that they do not want to establish a standard; Taber said that she does not think SCRD has the expertise to do so. Attendees did express interest, however, in gathering information about each state's soil and ground-water cleanup standards and basic information on how the values were derived. (They agreed that it will be important to have this information when performing cost comparisons. If one technology costs significantly more than another, but is capable of achieving a more stringent cleanup standard, it might be preferred over one that is cheaper but less effective.) SCRD members discussed ways to compile the information. Nicholson and DeZeeuw offered to initiate the effort. They will summarize and distribute information on how North Carolina and Oregon derive their standards.

DISCUSSION ON SCRD'S ORGANIZATIONAL STRUCTURE AND FUTURE MEETINGS

Group Organization and Structure
During SCRD's October 1999 meeting, several decisions were made about how to structure and organize SCRD. Perroni said that she has been asked to reopen communication on these topics so that decisions can be reassessed and modified.

Criteria for Members and Associate Members
Currently, Perroni said, SCRD member states are simply defined as those that have Fund programs established. There is no participation requirement, so states can be labeled as members and given voting rights without ever participating in SCRD's activities. Perroni asked whether a participation requirement should be added. Trippler said that he was in favor of this, and he recommended setting the following criteria: member states must (1) have a Fund program established and (2) participate in one SCRD meeting each year unless they have a reasonable excuse for not attending. Perroni polled the current SCRD members to determine whether they approved of this suggestion. They did; as a result, Connecticut is no longer considered a member, since it has never attended a SCRD meeting. (Trippler said that Connecticut will be notified of the next SCRD meeting. If the state does want to participate, it will be reinstated as a member.)

Perroni asked attendees to also discuss SCRD's second tier of participation—associate membership. States that are designated as associate members do not have voting power, she said, but they do receive funding to attend SCRD meetings. Currently, Perroni said, associate member states are defined as those that might have a Fund program established in the future. (In some cases, associate member states may be taking the lead on developing legislation. In other cases, industry associations are driving the effort.) Perroni asked if a time limit should be placed on associate membership. Attendees were against this, but said that associate members must understand that they may not always receive travel funds. If travel budgets are significantly reduced, SCRD members will have to decide how to allot travel funds among associate member states.

Trippler and Henning noted that some states do not want to be associated with SCRD because they fear that becoming involved will imply that they support industry-led Fund program initiatives. Thus, Trippler said, it is presumptuous to assume that states will want to participate. Attendees agreed, and decided that all members and associate members must express interest in joining SCRD before being listed as members and associate members. During the meeting, the following states expressed their desire to participate as members: Florida, Kansas, Illinois, Minnesota, North Carolina, Oregon, South Carolina, Tennessee, and Wisconsin. In addition, Louisiana and New Mexico expressed interest in participating as associate members. Although these requests were made informally, members agreed that, in the future, states will have to be more formal and submit requests from the agencies that they work for. Trippler noted that Missouri was voted in as an associate member during the last SCRD meeting. He agreed to contact that state's representatives to let them know that they must formally express interest in participating to maintain their associate member status. Trippler said that he will also contact representatives from New York and Alabama, since these states are also considering implementing Fund programs. He will let them know what they must do if they want to become SCRD associate members. If attendees learn of additional states that are working on legislation, Trippler said, they should send contact names to him. Nicholson suggested contacting ASTSWMO and letting it know of SCRD's existence. ASTSWMO could then direct states that are considering legislation to SCRD.

Invited Guests
Two SCRD meetings are held each year and NGWA pays travel expenses for about 20 state-government representatives to attend each. During SCRD's October 1999 meeting, Perroni said, the group decided that official invitations should only be extended to those who could be funded by NGWA. She asked if attendees wanted to adhere to this decision. SCRD members decided not to; they said that SCRD is ready to reach out to more states and to a more diverse audience. Thus, invitations will be extended to more people, and not all invited guests will be offered travel funds. DeZeeuw recommended inviting more representatives from the drycleaner associations to attend the next SCRD meeting. Once a date has been chosen, he said, IFI could be notified so that they could let other drycleaner associations know about the meeting.

Leadership
During SCRD's October 1999 meeting, Trippler was voted in as SCRD's leader. He agreed to fill this role for one year. Thus, a new leader may need to be identified at SCRD's next meeting. In addition, those who are currently leading SCRD's Subgroups may want to step down from their positions soon. Attendees agreed to discuss these issues in greater detail during one of SCRD's conference calls.

Next SCRD Meeting

Location and Date
Meeting participants agreed that the next SCRD meeting should be held in fall 2000. Trippler asked for suggested meeting locations. Schmidt recommended the Northeast, but attendees agreed that hotel rates there would be too high. Trippler recommended holding the meeting in the Southeast, since so many SCRD participants are located in that area. He said that NGWA has already done some preliminary research on this region and has identified four cities that are relatively cheap to fly into: Nashville, Raleigh/Durham, Orlando, and Tampa. SCRD members said that Orlando and Tampa are their top choices, and that NGWA should focus on these cities. If Orlando is chosen, some participants recommended (1) having the meeting at Cocoa Beach, an area with a ground-water plume, and (2) taking a field trip to the Cape Canaveral Air Station to learn about pilot studies that are being performed. Some participants questioned whether a field trip would be productive, however. The exact dates for the meeting were not chosen; attendees will determine whether any conferences are taking place in Orlando or Tampa in fall 2000. If so, SCRD may hold their meeting in conjunction with a conference.

Agenda Items and Training Component
SCRD participants debated whether to include a training component during their next meeting. After much debate, a vote was taken: the majority decided to have a four-day meeting, with one day allotted to formal training and the other three dedicated to issues that are relevant to SCRD.

Cheryl Joseph, a representative from NGWA, asked participants to let her know what kind of training they want. She said that she knew of three NGWA courses that SCRD members had expressed interest in previously: (1) Fundamentals of Ground Water Geochemistry, (2) Screening Modeling for Natural Attenuation with Bioscreen, Biochlor, and NA Tool Kit, and (3) Low-Cost Remediation Strategies for Contaminated Soil and Ground Water. She asked participants if they had other topics to recommend. Taber said that she would like to learn about computer models that EPA uses to evaluate a small business owner's ability to pay. Gillard recommended providing training on RBCA. Schmidt asked whether one of ITRC's training programs could be offered. After discussing all of the proposed options, SCRD members made NGWA's Low-Cost Remediation Strategies for Contaminated Soil and Ground Water their first choice. Joseph gave attendees a handout describing the course; she asked them to review it and let her know which agenda items could be eliminated. In the meantime, Joseph said, she will determine if this course can be condensed to one day and whether an instructor is available to teach it. If so, she said, a revised course agenda will be distributed to SCRD so that members can comment on the course's level of detail.

Jurgens recommended holding the training on the first day of the meeting and holding the SCRD conference on the following three days. The following were identified as potential agenda items:

• Case studies. Attendees enthusiastically agreed that a full day should be allotted to discussing case studies. They expressed much interest in learning more about the technical issues that arise during site assessment and remediation activities. Attendees decided that representatives from all of the SCRD states should be allowed to present a case study if they have information that would benefit the group. Those who are interested in making a presentation should contact Trippler or Perroni and provide estimates on the amount of time they will need. Nicholson also suggested letting outside speakers present cases studies as well. For example, he said, if the meeting is held in Orlando, a Cape Canaveral Air Station representative could be invited to speak about that site's pilot projects.
  
  
• The nuts and bolts of Fund program management. Schmidt said that she would like to learn the approaches that different states use to process applications and determine eligibility criteria.
  
  
• Subgroup breakout sessions. Trippler said that he thinks a whole day will be needed for Subgroup breakout sessions.

MISCELLANEOUS TOPICS

Barton Bill
Scalco provided an update on HR 2726, the Barton Bill. (She said that this bill recommends adopting EPA's Soil Screening Guidance number for PCE inhalation as the environmental standard to use for drycleaning sites that are not associated with drinking water sources. The bill does, however, allow states to set stricter standards on a site-by-site basis.) Scalco said that the bill currently has about 56 sponsors. Much of the bill's content has also been incorporated into a Superfund amendment (HR 2528), which has not reached the House yet.

Alternatives to PCE-Based Machines
Gillard said that the University of California Los Angeles and Occidental College have been investigating "greener" cleaning processes, primarily those that involve wet cleaning. Another attendee said that North Carolina State University's environmental engineering department is performing life cycle analyses and comparing different cleaning processes. Gillard said that she is very interested in research that is being performed to develop processes that do not use PCE. Nicholson said that MiCELL Technologies has developed a drycleaning machine that uses carbon dioxide as a cleaning agent. To promote its use, Nicholson said, tax credits are being proposed on the state and federal level. He said that it would be useful for SCRD participants to talk about this new technology during their next conference call. Jim Gilbert concurred, noting that he would like to talk about how the introduction of these machines could impact Fund revenue.

Outreach Versus Enforcement
Henning said that he noticed a common theme that ran through the SCRD meeting: attendees think that communication efforts are needed to teach drycleaners about environmental requirements, recordkeeping, waste minimization practices, machine operations, and how to maintain treatment units. In Kansas, he said, outreach efforts have been ongoing for years. For example, KDHE has held public meetings, distributed information about rules and laws, provided self-inspection forms, and provided information on where drycleaners can go for technical guidance. Henning said that he believes that these efforts have been fairly unsuccessful. He described what was found during a recent inspection effort to demonstrate his point. Fourteen drycleaners were chosen at random and informed that they would be inspected. When inspectors audited the facilities, only two passed. The other 12 all failed to meet secondary containment and recordkeeping requirements, at least 4 did not have closed-loop transfer systems in place, and some were discharging to the sewer. The cleaners who were out of compliance have been given 90 days to fix their problems. If they fail to do so, they will be fined under an Administrative Order. For more than four years, Henning said, KDHE has been trying to use education to promote compliance. Unfortunately, he said, it appears that enforcement activities, in the form of a monetary penalty, are required to motivate cleaners to follow waste minimization requirements.

Innovative Sampling Devices
Dukes wanted to let attendees know of two new assessment tools that have become available. One, called a ribbon sampler, consists of a tube that is impregnated with a dye; the dye changes color when it contacts DNAPL. The tube can be inserted into the subsurface, retrieved, and inverted to give investigators a picture of subsurface DNAPL layers. The other device, Dukes said, has been developed by DHEC's contractor. It can detect PCE, and provides a good qualitative analysis over a short period of time.

CLOSING REMARKS
Trippler thanked everyone for attending the meeting, and for their energy, input, and commitment. He said that the group accomplished a lot, and that he looked forward to the next SCRD meeting.

Attachment A: Final Attendee List
State Coalition for Remediation of Drycleaners Meeting

Stardust Resort and Casino
Las Vegas, Nevada
April 25-26, 2000

Lisa Appel South Carolina Department of Health & Environmental Control 2600 Bull Street Columbia, SC 29201-1708 803-896-4060 Fax: 803-896-4001 E-mail: appelr@columb34.dhec.state.sc.us Charles Cass Wisconsin Fabric Care Institute N42 W27251 Highway JJ Pewaukee, WI 53072 Dick Dezeeuw Oregon Department of Environmental Quality 811 Southwest 6th Avenue Portland, OR 97204 503-229-6240 Fax: 503-229-6954 E-mail: dezeeuw.dick@deq.state.or.us Craig Dukes Dry Cleaning Restoration Trust Fund South Carolina Department of Health & Environmental Control 2600 Bull Street Columbia, SC 29201 803-896-4057 Fax: 803-896-4001 E-mail: dukescv@columb34.dhec.state.sc.us Pat Eriksen Administrator Drycleaner Environmental Response Trust Fund of Ilinois 814 Pierce Street P.O. Box 9400 Sioux City, IA 51102 Phone: 712-252-4041 Fax: 712-252-5974 E-mail: hpe@willconsult.com Harold Ethridge Louisiana Department of Environmental Quality P.O. Box 82263 Baton Rouge, LA 70884-2263 225-763-5407 E-mail: harolde@deq.state.la.us James Gilbert Environmental Specialist Dry Cleaner Environmental Response Program Superfund Division Tennessee Department of Environment & Conservation 401 Church Street L&C Annex - 4th Floor Nashville, TN 37243-1538 615-741-4998 Fax: 615-741-1115 E-mail: jgilbert@mail.state.tn.us Nancy Gillard Ground Water Quality Bureau Assessment and Abatement Section State of New Mexico Environment Department 4131 Montgomery, NE Albuquerque, NM 87109 505-841-9413 Fax: 505-884-9254 E-mail: gillardn@unm.edu Elaine Glendening Oregon Department of Environmental Quality 811 Southwest 6th Avenue Portland, OR 97204 503-229-6015 Fax: 503-229-6954 E-mail: glendening.elaine.a@deq.state.or.us Steve Goins Program Manager Dry Cleaner Environmental Response Program Superfund Division Tennessee Department of Environment & Conservation 401 Church Street L&C Annex - 4th Floor Nashville, TN 37243-1538 615-532-8599 Fax: 615-741-1115 E-mail: sgoins@mail.state.tn.us Brent Hartsfield Bureau of Waste Cleanup Florida Department of Environmental Protection 2600 Blair Stone Road Tallahassee, FL 32399-2400 850-488-0190 Fax: 850-922-4368 Leo Henning Chief, Assessment & Restoration Section Kansas Department of Health & Environment Forbes Field - Building 740 Topeka, KS 66620-0001 785-296-1914 Fax: 785-296-4823 E-mail: lhenning@kdhe.state.ks.us Janet Hickman Industry Development Manager Chemicals and Metals The Dow Chemical Company 2020 Dow Center Midland, MI 48674 517-636-0465 Fax: 517-638-9615 E-mail: jch@dow.com Bob Jurgens Kansas Department of Health & Environment Forbes Field - Building 740 Topeka, KS 66620-0001 785-291-3250 Fax: 785-296-4823 E-mail: bjurgens@kdhe.state.ks.us Bill Linn Environmental Engineer Bureau of Waste Cleanup Florida Department of Environmental Protection 2600 Blair Stone Road Tallahassee, FL 32399-2400 850-488-0190 Fax: 850-922-4368 E-mail: linn_w@dep.state.fl.us

Steve Mitchell Nu-Way Cleaners 601 East Main Street Medford, OR 97501 541-776-5254 Bruce Nicholson Head, Special Remediation Branch North Carolina Superfund Section 401 Oberlin Road - Suite 150 Raleigh, NC 27605 919-733-2801, Ext. 353 Fax: 919-733-4811 E-mail: bruce.nicholson@ncmail.net Mary Scalco Vice President of Education & Research International Fabricare Institute 12251 Tech Road Silver Spring, MD 20904 301-622-1900, Ext. 131 Fax: 301-622-1568 E-mail: education@ifi.org Robin Schmidt Remediation and Redevelopment Wisconsin Department of Natural Resources P.O. Box 7921 101 South Webster Street Madison, WI 53707 608-267-7569 Fax: 608-267-7646 E-mail: schmirr@dnr.state.wi.us Michael Smith Waste Management Division Vermont Department of Environmental Conservation 103 South Main Street/West Building Waterbury, VT 05671-0404 802-241-3879 Fax: 802-241-3296 E-mail: miles@dec.anr.state.vt.us Juho So Drycleaner Environmental Response Trust Fund of Illinois 1000 Tower Lane - Suite 140 P.O. Box 7380 Bensenville, IL 60106-7380 Phone: 800-266-0663 Fax: 630-741-0026 E-mail: jso@willconsult.com Scott Stupak North Carolina Superfund Section 401 Oberlin Road - Suite 150 Raleigh, NC 27605 919-733-280, Ext. 241 Fax: 919-733-4811 E-mail: scott.stupak@ncmail.net Lisa Taber North Carolina Superfund Section 401 Oberlin Road - Suite 150 Raleigh, NC 27605 919-733-280, Ext. 244 Fax: 919-733-4811 E-mail: lisa.taber@ncmail.net Dale Trippler Principal Planner Minnesota Pollution Control Agency Policy and Planning Division 520 Lafayette Road, N St. Paul, MN 55155-4194 651-297-8483 Fax: 651-297-8676 E-mail: dale.trippler@pca.state.mn.us Technical and logistical support provided by: Dennis Goldman Director of Science & Technology National Ground Water Association 601 Dempsey Road Westerville, OH 43081 800-551-7379, Ext. 557 Fax: 614-898-7786 E-mail: dgoldman@ngwa.org Christine Hartnett Eastern Research Group, Inc. 5608 Parkcrest Drive - Suite 100 Austin, TX 78731-4947 512-407-1829 Fax: 512-419-0089 E-mail: chartnet@erg.com Cheryl Joseph National Ground Water Association 601 Dempsey Road Westerville, OH 43081 800-551-7379 Fax: 614-898-7786 E-mail: cjoseph@ngwa.org Carolyn Perroni Environmental Management Support, Inc. 8601 Georgia Avenue - Suite 500 Silver Spring, MD 20910 301-589-5318 Fax: 301-589-8487 E-mail: cperroni@emsus.com Kate Schalk Eastern Research Group, Inc. 110 Hartwell Avenue Lexington, MA 02421-3136 781-674-7324 Fax: 781-674-2906 E-mail: kschalk@erg.com Richard Steimle Technology Innovation Office U.S. Environmental Protection Agency 401 M Street, SW (5102G) Washington, DC 20460 703-603-7195 Fax: 703-603-9135 E-mail: steimle.richard@epamail.epa.gov Meg Vrablik Eastern Research Group, Inc. 110 Hartwell Avenue Lexington, MA 02421-3136 781-674-7396 Fax: 781-674-2906 E-mail: mvrablik@erg.com

Attachment B: Summary of Ongoing and Planned SCRD Activities

Project	Strategy and Time Table
Create technology profiles	The Project Management/Technical Issues Subgroup will take the lead on gathering information on technologies. In late May or early June, the Subgroup will meet via conference call to discuss how to present the information as a set of online technical profiles. Also the Subgroup will communicate with Perroni and the Outreach Subgroup to determine the best way to execute this effort, and whether it should be addressed as part of the Outreach Subgroup's site profiling effort.
Create site profiles	The Outreach Subgroup will take the lead on developing site profiles. Perroni will send information on how to access the PRB Action Team's online profiles; these may serve as a useful model. The Subgroup will generate a one-page questionnaire to gather information for the profiles.
Compile information on cleanup standards	Nicholson and DeZeeuw offered to summarize and distribute information on standards used in North Carolina and Oregon, along with information on the methodologies that are used to derive them.
Finalize and deliver presentations for the Battelle May 2000 meeting	Schmidt and Perroni will finalize the Program Development/Administrative Subgroup's presentation. Perroni will complete the poster for the Project Management/Technical Issues Subgroup and forward it to the meeting location. Anderson will present the poster; Smith and Schmidt might help with this effort. (Linn will talk to them about this possibility.)
Modify tables that compare Fund program elements	The Program Development/Administrative Subgroup will do this in the near future.
Compile information on lessons learned	The Program Development/Administrative Subgroup will take the lead on this effort.
Evaluate tax credits	The Program Development/Administrative Subgroup will initiate this effort before the next SCRD meeting.
Explore insurance issues	The Program Development/Administrative Subgroup will initiate this effort before the next SCRD meeting.
Compile a list of conferences	The Outreach Subgroup will do this.
Distribute additional outreach letter	The Outreach Subgroup will do this. Hickman will provide a list of national organizations that might be interested in SCRD's activities.
Create toolbox	The Outreach Subgroup will do this. SCRD team members are asked to send digital photos to Perroni.
Create brochure	The Outreach Subgroup will do this. The Subgroup will use the text from Perroni's one-page summary as a springboard.
Update SCRD products regularly	The Outreach Subgroup will talk with the other two Subgroups about the best way to do this.

Attachment C: Comments Provided on Schmidt's PowerPoint Presentation

Robin Schmidt is scheduled to present a paper at Battelle's Remediation of Chlorinated and Recalcitrant Compounds conference, which will be held in Monterey, California, in May 2000. Schmidt brought a draft version to the SCRD meeting and presented it. Participants provided the following comments:

• Dukes noted that Schmidt mentioned a value of $14 million. He stressed that it should be made clear that this value is an annual one.
  
  
• Trippler noted that the presentation did not mention Vermont; he asked Wisconsin to fix this omission.
  
  
• Taber commented on the values that were provided for administrative costs. The values cited for North Carolina, she said, reflect what the state is allowed to spend, not what they have actually spent. She asked whether the presentation could be changed and the lower value inserted. Schmidt said that it could, but that she needs to receive all adjustments in early May. Schmidt also advised participants to let DeZeeuw know if adjustments are required so that he can revise the Program Development/Administration tables.
  
  
• Goins recommended adding a slide that lists SCRD's three Subgroups. Nicholson advised streamlining the Subgroup names.
  
  
• Goins commented on the series of slides that provide state-specific information. He recommended presenting topics in the same order on each slide.
  
  
• Henning asked Schmidt to change how she defined associate members. He noted that the presentation stated that associate members "are likely to have programs in the near future." This, he said, implies that the associate states are pushing the legislation through. This is not typically the case, he said, noting that many of the Fund programs have been initiated by industry.
  
  
• Dukes asked Schmidt to explain why actual revenue have fallen short of projected funds. He said it should be made clear that industry members set the projections, not state representatives.

1. This summary only covers the first two days of the meeting.

2. Some of the information provided during other portions of the meeting has been pulled into this section to streamline the summary report. For example, William Linn's presentation on assessment activities has been incorporated into the Florida update. Likewise, Lisa Taber's presentation on minimum management practices is presented under the North Carolina update.

3. These papers, which were distributed to participants, are entitled:

• "Enhanced Biological Reductive Dechlorination at a Drycleaning Facility"
• "Evaluation of In-Situ DNAPL Remediation and Innovative Site Characterization Techniques"

4. Hickman classified equipment as follows:

• First generation: Washers and dryers separated.
• Second generation: Dry-to-dry machine with a water condenser; carbon absorbers added to treat air streams during venting processes.
• Third generation: Dry-to-dry machine with a direct-coupled solvent delivery system, no vent, and a refrigerator condenser.
• Fourth generation and above: Third generation machines that have carbon absorbers.

Hickman presented a slide showing how the amount of PCE that is needed to clean 1,000 pounds of clothes has decreased as drycleaning equipment has become more efficient.

5. Linn suggested reading:

• Izzo, Victor. Dry Cleaners—A Major Source of PCE in Ground Water. Approved by the California Regional Water Quality Control Board, Central Valley Region, on March 27, 1992.
• Siler, D.A., Romita, M.N. Out of Sight, Out of Mind? Emerging Liabilities under CERCLA for Releases from Sanitary Sewers. Copyrighted in 1994 by the Bureau of National Affairs, Inc., Washington, D.C.