Re: Definition, VCPs, and Brownfields -Reply

[CHARLES PATRIZIA <CAPATRIZIA@phjw.com>]

It's absolutely correct that former dry cleaning "plant on premises" sites
that have perchlorethylene contamination have been treated as
hazardous waste sites, regardless of whether the contamination was
intentional or not.  I have been involved in characterization and
remediation programs for several such sites.  Moreover, intention simply
isn't the issue.  Indeed, there are some who argue that it every older dry
cleaning plan released perc, because the chemical suffuses through
concrete, and all facilities had some releases associated with operations
inside the store, not just still bottoms and residues being pitched out the
back door.

Intention to spill unlawfully is not really the governing issue.  For example,
the Fabric Care Institute, the trade association for cleaning industry,
operated a facility in an office building in suburban Maryland outside of
Washington, D.C., where they tested the effect of cleaning chemicals on
various fabrics.  Small amounts of Perc went down the sanitary drain. 
The sanitary sewer system, like most such systems, leaked, and created
Perc contamination on the adjoining parcel.  The owner of the adjoining
parcel recovered from both the Institute and the local sewer authority.

Chuck Patrizia