WATCH OUT FOR THOSE DRY CLEANER FACILITIES WHEN REVIEWING A PHASE I ESA. The biggest red flag at a shopping center would be the presence or former presence of a dry cleaning operation. Many releases that occur as a result of a dry cleaning business were not necessarily the result of negligence and could even have resulted through an inadvertent discharge of small quantities of dry cleaning solvents through piping. Soil and groundwater cleanup target levels (CTLs) for dry cleaning compounds in the State of Florida are very low, i.e., you don’t need very much to cause a problem. In addition, these compounds are heavier than water and tend to “sink” in the aquifer, making a release more costly to assess and many times more costly to remediate.

A state funded program was in place to address releases from dry cleaning facilities. The State of Florida Dry Cleaning Solvent Cleanup Program (DCSCUP) provides State funded assessment and remediation of soil and/or groundwater that has been contaminated as a result of dry cleaning solvents from dry cleaning facilities. An eligibility requirement of the program did require that dry cleaning solvent compounds be detected in the soil and/or groundwater; however, it was not required that the detected concentrations meet or exceed regulatory limits in order to make an application to the program. Site remediation under the program did not include third party liability. Applications to the program were not accepted after December 31, 1998.

According to a representative of the Florida Department of Environmental Protection (FDEP), 1,563 dry cleaning facilities (current and former) that were contaminated as a result of a release of dry cleaning solvents, made an application to the DCSCUP. A total of 1,400 sites were deemed eligible for the program. FDEP however, believes that at least 2,800 facilities could have applied, indicating that only about one-half of these types of sites would have been eligible for the program.

It is also interesting to note that facilities deemed ineligible for the DCSCUP cannot be compelled to assess and remediate their sites if knowledge of the release was the result of having made an application to the program. Therefore, do not assume that a dry cleaning facility has not impacted the subsurface if they were deemed program ineligible. Contact MADELINE FELL at for additional information regarding environmental concerns associated with dry cleaner facilities or questions regarding phase I environmental site assessments.

As of April 22, 2010, federal law requires that:  (a) renovation firms must be certified under EPA's Renovation, Repair and Painting (RRP) Rule; (b) individuals must be trained in lead-safe work practices; and (c) training providers must be accredited b EPA.  The RRP Rule requires that firms performing renovation, repair, and painting projects that disturb lead-based paint in pre-1978 homes, child care facilities and schools be certified by EPA and that they use certified renovators who are trained by EPA-approved training providers to follow lead-safe work practices.

Asbestos is a mineral fiber.  There are several types of asbestos fibers.  In the past, asbestos was added to a variety of products to strengthen them and to provide heat insulation and fire resistance.  The following information is taken largely from a document developed in 1990.  The US EPA is current revising the original document. read more...

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