There’s Been a PCE Release at My Dry Cleaner: How Long Will Cleanup Take and How Much Will It Cost?

The Cost and Timeframe of Cleaning Up a PCE Release at a Former or Existing Dry Cleaning Business

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Dry cleaners are the leading source of environmental liability at commercial retail properties. That’s because the use and handling of tetrachloroethylene (PCE) is, or was, inherent in their business. If you are a real estate professional, property owner, developer, or operator involved with a former or existing dry cleaning business, there’s a good chance you could face liability stemming from a PCE release.

If a release is identified and you’re involved, your first thoughts might turn to questions like, “How long is cleanup going to take?” and “What’s it going to cost?” Unfortunately, answers to those questions are hard to get.

Too often, I’ve sat in meetings where the RP (responsible party) asks “How long will it take to clean up my site?” or “How much is this going to cost?”, and never heard a straight answer. We will try to answer those questions here.

Understanding the Challenges of Dry Cleaner Contamination: Funding, Cleanup, and More

You may have received a letter from a regulatory agency that reads something like this:

“Upload a work plan detailing and justifying a scope of work to assess the extent and magnitude of chlorinated solvents in groundwater and subsurface vapor…You have been identified as a potential responsible party for the contamination because you operated the dry cleaners or own the property.”

You are not alone. In 2019, California reported there were 12,947 inactive (unfunded) dry cleaner cases and 1,791 active cases in the state. In 2018, the Department of Toxic Substances Control (DTSC) had 120 tetrachloroethylene (PCE) cases open and only 15 sites categorized as “no further action.”

Consider:

  • There are a large number of undiscovered sites in urban areas, many of which are or were, family-owned businesses with no resources for cleanup. There are an estimated 17,000 sites throughout California with unknown or suspected releases of chemicals.
  • Funding is extremely limited. Of the 120 active DTSC sites, clean-up was federally funded at 14 sites, state-funded at 14 sites, and privately funded by the responsible party at 92 sites. The California Site Cleanup Program (SCP) reported there are approximately 3,932 open SCP sites; approximately 1,280 are inactive and in need of funding.
  • The primary funding mechanisms currently in place for the cleanup of SCP sites include the Underground Storage Tank (UST) Cleanup Fund, Cost Recovery, and Site Cleanup Subaccount Program (SCAP). SCAP is the only funding mechanism for property owners and operators of dry cleaners. Of the known SCP sites in California, only a small fraction are receiving SCAP funding assistance.
  • PCE and trichloroethylene (TCE), chemicals associated with dry cleaning, are notoriously difficult to remove from soil and groundwater. Unlike policy for gas stations (petroleum hydrocarbon fuels), for dry cleaners, there is no standard policy or recipe available in California for obtaining case closure with no further action. This is important, so let me emphasize - There is no standard policy or recipe available in California for obtaining case closure with no further action.

The problem facing a property owner or operator of a dry cleaner or former dry cleaner is there is a significant chance PCE was released during the operation of the dry cleaner. The identification of a release can happen under several different scenarios, some of which the property owner or operator has no control over.

For example, some counties require that before changing the use of a building that housed a dry cleaner, the soil, soil gas, and/or groundwater beneath the building must be investigated for release. The same holds for your neighbors who are looking to develop, sell or refinance their property - they might identify your release as part of their work next door.

Once a release is identified, the local regulatory agency usually gets involved and issues a letter requesting an investigation. At this point, the property owner and/or the operator of the dry cleaner are faced with the investigation and cleanup of a PCE release.

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How Long Does It Take to Clean Up a Dry Cleaner Site in California?

Unfortunately, there is little information regarding how long it takes to clean up dry cleaner sites in California. However, there is plenty of information on the cleanup of Underground Storage Tank (UST) sites. So, we will apply UST cleanup information to answer how long it takes to clean up dry cleaner sites. 

To account for the differences between UST and dry cleaner sites, we will identify the differences between UST contaminants (benzene, methyl tertiary butyl ether [MtBE]) and dry cleaner contaminants (PCE, trichloroethylene [TCE]), and how those differences might factor into differences in site cleanup time. We know that recognized cleanup methods (such as groundwater or soil vapor extraction, air sparging, and high vacuum dual phase extraction) work in both cases, and we have data from 2011 that show for 3,654 clean-up stage UST sites with groundwater impact, 75 percent of the cases were 10 years old or older and half of those were 15 years or older.

ComplexSystemOne difference between the two contaminant groups we can explore is the difference in environmental screening levels (ESLs), which are sometimes used as cleanup goals. For petroleum hydrocarbons released from a UST, the ESLs are published in California's Low Threat UST Case Closure Policy. The cleanup goals for benzene and MtBE in groundwater under moderate conditions are 3,000 micrograms/liter (ug/l) and 1,000 ug/l, respectively. The most stringent Low Threat UST criteria for benzene in soil gas 5 feet beneath a residential building is 85 microgram/cubic meter (ug/m3).

There are no Low Threat UST policy criteria for the dry cleaner contamination, but Tier 1 ESLs published by the San Francisco Bay Regional Water Quality Control Board can serve for comparison and are sometimes used as cleanup goals. Tier 1 cleanup goals for tetrachloroethylene in groundwater and soil gas are 0.64 ug/l and 15 ug/m3, respectively. For trichloroethylene in groundwater and soil gas, the ESLs are 1.2 ug/l and 16 ug/m3, respectively.

A comparison shows that cleanup goals for dry cleaner sites are significantly stricter than those for UST sites, suggesting the possibility that cleanup for dry cleaner sites may extend to 15 years or more since that is the case for UST sites. This is especially true when considering PCE remains unchanged in the natural environment significantly longer than gasoline compounds, which are subject to much greater rates of natural decay. Technology and regulation have changed over the last 10 years since the UST data were published; however, cleanup goals for PCE have become more strict due to a greater understanding of inhalation health risks, while technological advances have only marginally improved cleanup time frames.

The answer: it will likely take at least 10 years, and possibly 15 years or more, to clean up a dry cleaner site. Funding could impact these numbers, as has been shown for UST cleanup; however, there is currently no funding policy for dry cleaners that functions like the UST Cleanup Fund.

Estimating the Average Cost of a PCE Release Cleaning Up a Dry Cleaner Site

groundwater sampling 2General information on how much it costs to clean up a dry cleaner site is slim, but as we did for the first question, we can turn to the UST Cleanup Fund information for costs and use those to estimate the cleanup costs for a dry cleaner. 

According to a performance audit of the UST Cleanup Fund, over the five fiscal years ending in the fiscal year 2018-2019, the average cost of a closed UST Fund claim was $600,772. We can start here with an answer to how much it will cost to clean up a dry cleaner site - at least $600,000. Now let’s consider factors that account for the differences between UST site contaminants and dry cleaner contaminants.

In a 2007 report, the Santa Clara Valley Water District (SCVWD) compares PCE, MtBE, and benzene plume lengths - the distance contamination moves with groundwater from the source. They reported median plume lengths of 300 feet for PCE, 174 feet for MtBE, and 144 feet for benzene. Their report suggests that the bigger the plume length, the higher the cleanup cost. It's plain to see that PCE plume lengths are considerably longer than those for MtBE and benzene, so it is likely the average cost to clean up a dry cleaner release is greater than $600,000.

The answer: the average cost for cleanup of a PCE release from a dry cleaner is about $600,000+.

We answered important questions for anyone faced with a PCE release from a dry cleaner site

We answered two important questions for anyone faced with a PCE release from a dry cleaner.

  1. We found that it will take at least 10 years, and possibly 15 years or more, to clean up a dry cleaner site and
  2. That the average clean-up cost could exceed $600,000.

You may have other important questions not answered here. If so, we can help. Call us at (831) 475-8141 or click the button below to schedule a free consultation.

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