JAIR Environmental:

Jones, Adams, Isom, Ryan

A South Jersey Based Company Servicing All of NJ

Proposal 2018
 Executive Summary

The mission of JAIR Environmental is to offer innovative remediation clean up technologies. We

specialize in soil vapor extraction enhanced pump and treat systems. Our core objectives include:

● VOC & SVOC removal, especially those produced as dry-cleaning wastes

● LNAPL removal
● Unique multiple contaminant cleanup plans
● Contracting with outside organizations to perform site assessments
● Environmental law and litigation advice
● Affordable clean-up payment plans for our clients

Given the limited capabilities of conventional pump and treat systems and the large number of
contaminated sites, a substantial market exists for innovative groundwater cleanup technologies.
The large size of the market has left other firms unmotivated to develop innovative, more
efficient technologies. JAIR Environmental believes innovation drives success and, as such,
offers a combined remediation technique that incorporates SVE and P&T; two current popular
technologies. With SVE enhanced pump and treat we are able to cover a large range of pollutants
including organics, inorganics, metals and vapors. This makes us a perfect solution for those
experiencing a multitude of contaminants while remaining a viable option for those seeking
removal of a select group VOC/SVOCs or inorganic metals.

Traditional pump and treat systems are limited by the lengthy duration required to successfully
remove the full extent of a contaminant. When combined with the vacuum pressure associated
with SVE, however, the pump and treat process becomes expedited, allowing a larger mass of
contaminant to be remediated in a significantly shorter period of time. The increased oxygen
content resulting from the SVE process also increases aerobic biological breakdown of surface
contaminants through a process known as natural attenuation.

Our company’s methods and competitive pricing allow us to cater to both small scale and large
scale remediation projects. While other chemical remediation techniques (i.e. oxidation) may
have the capability to clean up large quantities of contaminants in shorter periods of time, the
technology proves uneconomical for small and mid-sized sites. SVE enhanced P&T can offer the
best of both worlds by providing an affordable cost and an effective clean-up within a reasonable
amount of time. Our potential clientele ranges from former and current dry cleaning facilities,
gas stations, industrial sites, and the federal government via superfund sites.

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 Table of Contents

Executive Summary……………………………………………………………….....1-1

I. Industry Overview………………………………………………………………....4-7
Common Dry Cleaning Contaminants…………………………………….…4-5
i. Dry Cleaning Solvents…………………………………………..…4-5
Entry into the Environment……………………………………………….….5-5
Relevant Case Studies…………………………………………………….….5-7
i. White Swan and Sun Cleaners………………………………….….5-6
ii. Garden State Co. Cleaners….………………………………...…...7-7

II. Survey of Polluted Sites, New Jersey……………………………..………..….….7-9

III. Executive’s Qualifications…………………………………………………….......9-9

IV. Scope of Work…………………………………………………………….….…10-18

Physical……………………………………………………………….….…10-12
i. Soil Excavation……………………………………………….…..10-10
ii. Soil Capping………………………………………………….......10-11
iii. Soil Washing…………………………………………………..…11-11
iv. Soil Flushing………………………………………………..…....11-12
Chemical…………………………………………………………..………...12-18
i. Soil Vapor Extraction……………………………...……………....12-14
ii. Permeable Reactive Barriers………………...…………………....14-15
iii. Oxidation…………………………………………………………15-17
iv. Pump and Treat…………………………………………………...17-18
Our Scope………………………………………………………………..….18-19

V. Our Specialization…………………………………………………………….…..19-21
SVE Enhanced Pump and Treat Technology………………………………...19-19
i. Pump and Treat Techniques………….…………………………….20-20
ii. SVE Enhancement…………………………....…………….……..21-21

VI. Management Strategy….……………………………………………………..….22-22

VII. Operating and Equipment Costs……………………………………….…..…....22-24

In-House Staffing……………………………………………………..….…..23-23
Out of House Operating Costs……………………………………..…..….....23-24

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VIII. References……………………………………………………………..…..25-27

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I. ​Industry Overview

New Jersey has several contaminated sites as a result of the mismanagement of dry cleaning
wastes at former dry cleaning/laundering facilities. Such wastes have contaminated soils on the
abandoned properties and/or leached into the groundwater, potentially affecting thousands of
local residents. This activity has spurred the need for remediation companies such as JAIR
Environmental to clean-up these sites to reduce liability for prospective companies and, more
importantly, limit the risk involved for the community.

Common Dry Cleaning Contaminants

Dry Cleaning Solvents

These refer to the liquid chemicals that do not contain any water (hence “dry”) that are
used to clean clothing (Flanery, n.d.). They are typically volatile organic chemicals
(VOCs) that easily become airborne. Historically, dry cleaners used petroleum solvents
such as kerosene to do the task before the dangers associated with high-flammability
caused petroleum based solvents to be phased-out. Dry cleaning solvents are topically
applied to garments and upholstery that have been soiled by substances that are difficult
to remove or for delicate fabrics that would be otherwise damaged by a washer. These
solvents easily dissolve most forms of organic staining. (see Table 1) (“How do Stain
Removers Work?”, 2009).

Contaminant Industrial Uses Environmental Fate/Health Impacts

Trichloroethylene (PCE)
·​ ​Dry cleaning solvent that
causes bleeding of certain
acetate dyes
·​ ​Used in water repellent
and spotting agents as well
·​ ​Can quickly volatize into the air,
posing the biggest threat to factory
workers and those who live near
hazardous waste sites
·​ ​While in soil, it can leach into
groundwater or volatilize, potentially
causing vapor intrusion

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 Perchloroethylene (perc) ·​ ​Popular choice after the
phasing-out of petroleum dry
cleaning solvents.
·​ ​90% of perc use in the
united states was for dry
cleaning.
·​ ​Chronic exposure via ingestion can
result in headaches, neurological
maladies, and liver damage.
·​ ​Dry cleaning workers have a high
incidence of bladder cancer &
non-Hodgkin lymphoma.

Carbon Tetrachloride ·​ ​first chlorinated solvent ·​ ​The liver is sensitive because the
used in dry cleaning chemical can attack liver cell proteins.
operations. ·​ ​Nervous system detriment in those
·​ ​Phased out due to its with chronic exposure.
ability to corrode the
machinery and its high
toxicity.
Table 1:​ Common VOCs at dry cleaning sites, their uses, and potential environmental/health impacts.

Entry into the Environment

It is important to mention that most organic chemicals have various stages of degradation (e.g.
TCE is a degradation product of PCE). The aforementioned chemicals can enter the environment
when operators dump cleaning solvent waste directly into the soil on-site or via storm drains.
Legally, operators may discharge wastes into sanitary sewer lines, which lead to wastewater
treatment plants (Keyes, n.d.). Unfortunately sanitary sewer lines often leak, causing
contamination of the soil and groundwater.

Relevant Case Studies

White Swan Laundry and Sun Cleaners Inc.​ (Wall Township, NJ)

These two separate dry cleaners which operated from 1960-1991 in Wall Township,
Monmouth County, are the sources of area-wide VOC contamination (“White Swan
Laundry and Cleaner Inc. Wall TWP, NJ”, n.d.). The contaminants released over that
time span include typical dry cleaning solvents such as: TCE, PCE,
cis-1,2-dichloroethene (n.d.). Due to their activities, a contaminant solvent plume
emanates from their facilities on Sea Girt Ave, which contaminated the Kirkwood aquifer
and, thus, the Sea Girt Municipal Well Field that served 1,170 residents (Fig. 1). The
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shallow, sandy composition of Kirkwood aquifer hastened the spread of contamination
(Brown., 2013). Since the contaminants are volatiles, the local air quality became
compromised necessitating the installation of specialized ventilation systems in 27 area
buildings (residential and commercial) (Brown).

Remedial activities overseen by the EPA at the site included excavation of contaminated
soils at the White Swan property and off-site landfill disposal (“White Swan Laundry and
Cleaner Inc. Wall TWP, NJ”, n.d.). Remedial action at Sun Cleaners property entailed the
installation of a soil vapor extraction/air sparging system in the vadose zone of the area in
2016. In time, a pump and treat system will be installed to treat the most concentrated
VOC plumes in the groundwater. Clean water will be discharged back into aquifer, which
will be continuously monitored for the degradation of remaining organics via the natural
attenuation process and to ensure water quality standards are met (n.d.). For a complete
breakdown of each remedial action taken, please see section IV.

Figure 1:​ Aerial View of Solvent Plume Contamination Relative to White Swan Laundry & Sun Cleaners
Inc.

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 Garden State Cleaners Co.​ (Minotola, NJ)

This Superfund site was a dry cleaning facility that operated from 1969 to 2011 despite
VOC (primarily TCE & PCE) detection in the soils by the NJDEP as early as 1984
(“Garden State Cleaners Co. Minotola, NJ”, n.d.). The site neighbors South Jersey
Clothing Co., another superfund site. As such, all remedial activity became joint effort to
clean the two similarly contaminated sites (n.d.). The local aquifer, from which
approximately 9,000 residents retrieve their drinking water, had to be closed resulting in
the construction of a new municipal water supply system.

The site’s 1991 record of decision (ROD) selected for SVE for contaminated soils.
Remediators met this cleanup objective in 1995. A pump & treat system installed in 1999
continues to address groundwater contaminated with VOCs. The treatment portion in this
situation involves on-site carbon adsorption and air striping units (“Garden State Cleaners
Co. Minotola, NJ”, n.d.). The site was demolished in 2011, allowing for the excavation of
all contaminated underlying soil. Please see section IV for a breakdown of each remedial
method.

II. ​Survey of Polluted Sites, New Jersey

New Jersey has more designated superfund sites under than any other state despite its status as
the fifth smallest and most densely populated state in the nation. 115 superfund sites have been
identified throughout New Jerseys 21 counties (see figure 2 below), and NJDEP has confirmed
contamination at over 10,000 sites in the state. Nearly all New Jerseyans live close to at least one
contaminated site. The pollutants found in NJ soils and groundwater range from VOCs and
SVOCs such as: BTEXs, PAHs, TCE, PCE, PCBs as well as a solid presence heavy metal
contamination in areas of the state. TCE, PCE, DCE and vinyl chloride are contaminants
common in th​e dry cleaning industry. Carbon tetrachloride, Freon 113, Stoddard solvent,
Kerosene and Mineral spirits were associated with dry cleaning activities when petroleum based
products were permitted in the industry (​Dry Cleaners Pollution, n.d.).

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 Figure 2:​ Federally designated superfund sites in NJ

Perchlorethylene (PCE) has been a common cleaning solvent for dry cleaning since 1934 and
rose to the solvent of choice by 1962. Today, 90% of dry cleaners across the U.S use PCE
despite its status as a potential carcinogen. The USEPA has set a groundwater standard of 5 parts
per billion (ppb) for PCE. A state law in New Jersey, however, sets a stricter standard; 3 ppb.
PCE’s presence in aquifers across the state has impacted drinking water and created vapor
intrusion problems in facilities near plumes. The State Coalition for the Remediation of Dry
Cleaners (SCRD) estimates that 75% of dry cleaning facilities have leaked contaminants at some
point or another. However, this issue stems predominately from past industry operations and
standards. Significant improvements have been made in the last 10-20 years (​State Funded Dry
Cleaner Remediation Program, n.d.).

New Jersey is currently home to 2,000 dry cleaning operations and an unknown number of
closed facilities. Extrapolation from SCRD’s statistics estimates more than 1,500 dry cleaners
have discharged waste into the environment. Despite this, the NJDEP’s Site Remediation
Program only lists about 300 dry cleaners as known sites of contamination. This means that the
majority of currently operating and former dry cleaner facilities have been left unaddressed. This
creates a substantial market for JAIR Environmental’s services. Most of these operations have
used the chemical tetrachloroethylene which is also referred to as perchlorethylene, perc, or PCE.
PCE breaks down into other harmful contaminants including trichloroethylene,
di-chloroethylene, and vinyl chloride. Neither PCE or its by-products readily degrade in the
environment, and both are carcinogens known to increase incidence of kidney and liver

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problems. These chemicals can be found in soil, groundwater, and even reach the air via
migration through subsurface soils and preferential pathways. Additionally, many dry cleaners
are located in areas near residential settings which increases the potential of vapor intrusion
exposure (​State Funded Dry Cleaner Remediation Program, n.d.).

III. ​Our Qualifications

Utah Adams

Offering experience in soil quality analysis techniques, including moisture content, carbon
content, pH, and cation exchange capacity. Will complete B.S. in Environmental Science with a
concentration in Environmental Quality in 2018 with OSHA certification complete by the time
of company start-up.

DeAnno Isom

Working towards OSHA HAZWOPER certification, LSRP certification, and LEED certification.
Will complete a B.A. in Environmental Science in 2018.

Megan M. Jones

Providing experience in soil and water analysis techniques, as well as XRD sampling.
Anticipated B.S. in Environmental Science with a minor Geology in 2018, and pursuing a
J.D./M.P.H. OSHA certification to be completed prior to company start-up.

Raina Ryan

Offering experience in water sampling and soil analysis. Will complete a B.S. in Environmental
Science with a concentration in Environmental Quality in 2018. Pursuing a J.D. in
Environmental Law and M.P.P in Environmental Policy. 40 OSHA HAZWOPER to be
completed prior to company start-up.

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IV. ​Scope of Work

Physical Remediation Methods

Soil Excavation

Since soil excavation is intrinsic to almost all other remediation methods, especially those
employed by this company, this method will be discussed first. Excavation is done
on-site for relatively shallow and contained soil contamination. One must consider the
significant costs of contracting companies to dredge/dig the soil and transfer
contaminated soil to off-site or on-site treatment facilities. Since this is a relatively
intrusive method, backfilling of clean soil will be necessary to ensure that original
topography is restored.

Pros:
● Effective for reducing exposure of soils contaminated with radionuclides,
organics, and heavy metals that pose an immediate threat to the community
● Potential future liability is limited since contamination is being removed from the
site
● Inexpensive when dealing with small amounts of contaminated soil (“A Citizen’s
Guide to Excavation of Contaminated Soil”, 2012)
Cons:
● Air monitoring must be used since dust and contaminant vapors might be released
● Not fully addressing the issue, just moving it elsewhere
● Limited in extent; not effective for situations below the water table or sites with
deep contaminant plumes.

Soil Capping

Barrier wall and capping technologies are used to break the 'source-pathway-receptor’
chain at a site. The method is most often employed when pollution of groundwater must
be mitigated, but no economical solution for the target contaminant exists. Capping can
be done for most soils and sediments, and involves physically separating the pollutants
from areas where they could cause issues for humans and the environment. Not all caps
are physical, but the most common ones are and can include: sediment, clay
(montmorillonite, bentonite), rubber, or plastic caps.

Pros:
● Economical/Affordable

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 ● Easy to implement
● Immediate (yet temporary) solution to source plume
Cons:
● Does not actually remediate contaminants
● Temporary/Short term solution
● Rebound can occur if contaminant migrates

Soil Washing

Soil washing is a physical remediation technique that also employs the application of
chemicals to extract metal contaminants from the soil. The process may be employed
on-site or ex-situ and is most commonly used to treat metals such as arsenic (metalloid),
cadmium, chromium, mercury, and lead. Soil is generally excavated, washed with
chemical agents, and back-filled to its original area. There are three general options for
the soil washing process: physical separation, chemical extraction, or physical separation
and chemical extraction combined.

During physical separation, soil particles are separated by grain size from coarse to fine.
Chemical extraction typically binds heavy metals in soil to a chelator, causing separation
from the soil solution. Acids and bases may be added to improve the extraction of organic
solvents, or surfactants to improve the extraction of low-solubility organics (Dermont et
al., 2008).

Pros:
● Applicable to soils contaminated with SVOCs, fuels, heavy metals (including
radionuclides), select VOCs, and pesticides.
● Performed in a closed system under controlled conditions
● Lower cost than removing contaminated soil
Cons:
● Process does not destroy or immobilize the contaminants
● Shifts disposal responsibility to another party
● Soil contaminated with VOCs may require emissions control
● Effectiveness limited by complex waste mixtures, high humic content in soil, and
high fine-grained clay content

Soil Flushing

Soil flushing is an in-situ remediation technology in which contaminants (metals, VOCs,

SVOCs, etc.) are extracted from soil or groundwater via the injection/infiltration of

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 flushing fluids in an aqueous solution. Flushing solutions are comprised of regular water
that may be enhanced by the addition of surfactants, cosolvents, and other solubility
agents. Injection wells for flushing solutions are placed upgradient of the contaminated
area. Once the fluid is injected into the contaminated zone of either soil or groundwater,
the fluid and contaminants are leached into the groundwater. They are then removed via
extraction wells placed downgradient of the contaminated area and sent for treatment
(Roote, 1997).

It is crucial to understand the soil and contaminant parameters at a site before performing
soil flushing as they determine the type of extraction fluids to be utilized. Important soil
parameters to understand include: pH, buffering capacity, structure, texture, and
permeability. Important contaminant characteristics include: concentration, solubility,
products, and Kd (Chirenje, 2018).

Pros:
● Applicable to metals (except lead), VOCs, SVOCs, PCBs, fuels and pesticides
● No expense for excavation and treatment for excavated soil as contaminant
removal occurs in-situ
Cons:
● Slow rate of diffusion process in the liquid phase causes long remediation period
● Potential of spreading of contaminants beyond capture zone
● Certain geologic limitations, such as low permeability, high clay or organic
content, and close proximity to potable aquifers (Roote, 1997)

Chemical Remediation Methods

Soil Vapor Extraction (SVE)

While this method involves both physical and chemical methods, SVE is largely
considered chemical since the procedure involves the chemical alteration of captured
vapors to reduce toxicity or destroy contaminants. SVE requires in-situ installation of
extraction wells that apply a negative pressure (vacuum) to soils in the vadose zone,
which induces the controlled flow of air. SVE is typically effective at a depth of 3-5 ft,
though the process has successfully been applied to depths of 300 ft (“4.8 Soil Vapor
Extraction”, N.d.). In most cases, vertical extraction wells are installed but horizontal
wells may be considered depending on site characteristics.

This method can only be used with volatiles (i.e. VOCs and SVOCs) that have a vapor
pressure greater than 0.02 inHg (“4.8 Soil Vapor Extraction”, N.d.). SVE requires a

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constant flow of air which precludes the method from employment in non-permeable or
clayey soils with a high moisture content (n.d.). Often times, groundwater pumps are
co-installed to reduce the upward movement of groundwater into the vadose zone that
can occur as a result of the vacuums.

SVE can be enhanced with air sparging (See Figure 3). Air sparging equipment is
installed underneath the water table in the area of the plume. Sparging increases SVE
efficiency since the sparged air increases evaporation rates of VOCs, allowing organics to
easily travel up through groundwater into the extraction wells.

If not accounted for, the extracted VOCs will rise and compromise air quality in the area.
The VOC containment process first introduces the vapors to a water filtration system to
decrease vapor interference with the containment process (“A Citizen's Guide to Soil
Vapor Extraction and Air Sparging”, 2012). The air is then pumped into an activated
carbon adsorption unit, which may either be filled with Powder Activated Carbon or
Granular Activated Carbon, that filters the air (2012). Gas molecules physically attach,
adsorb, to the active carbon. The activated carbon reaction efficacy depends on the
temperature, concentration, and polarity of the substance (“Adsorption/Active Carbon”,
n.d.). At this point, the air has been cleansed and can be discharged into the atmosphere.
Note, active carbon is not the only suitable treatment method. Microbes can be utilized to
metabolize vapors into harmless gases in a process coined “biofiltration” (“A Citizen's
Guide to Soil Vapor Extraction and Air Sparging”, 2012).

Pros:
● When used in conjunction with sparging, bio-activity may increase and enhance
the remediation process
● Treatment involves no harmful chemicals
● Effective for remediation of dry cleaning solvents, many of which are VOCs
(TCE, PCE, etc.)
● Granulated Active Carbon Removes 90% of TCE from gas
Cons:
● A higher vacuum (thus, more energy and costs) must be applied in the following
scenarios: high percentage of fines, high degree of saturation
● Not effective for metals, PCBs, or heavy oils (“4.8 Soil Vapor Extraction”, N.d.)
● Soils with a high organic content will reduce efficiency due to high sorption
capacity for VOCs
● One must consider the dangers of in-situ exhaust air from treatment systems

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 Figure 3:​ SVE System with Air Sparging of Saturated Zone

Permeable Reactive Barriers (PRBs)

A permeable reactive barrier (PRB) can be described as a subsurface emplacement of

reactive materials through which a dissolved contaminant plume flows, typically due to
natural gradients. Treated water exits the other side of the PRB. PRBs are an in-situ
method which combine the use of either a chemical or biological treatment zone with the
management of subsurface fluid flow. Reactive barriers designs consider the level and
mix of contaminants meant to pass through the reactive media. Residence time must be
accounted for to ensure no further groundwater contamination. Different PRB media can
be selected and combined to effectively treat multiple contaminant types.

PRBs can be installed as either permanent or semi-permanent structures and come in

several different configurations. Two of the most popular configurations include
continuous trench style PRBs and funnel and gate PRBs. The continuous trench style
configuration involves treatment material as it is backfilled into a trench that is
perpendicular to and intersects the groundwater plume. The funnel and gate configuration
includes low-permeability walls (the funnel) which direct the groundwater plume toward
a permeable treatment zone (the gate). These PRBs use collection trenches, funnels, or

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containment to capture the plume either by gravity or hydraulic head​ in order to pass it
through a treatment medium.
A common PRB medium used is zero valent iron (ZRI) which can be used to treat both
metal oxyanions and divalent metals. The benefits of ZVI include its mildly reductant
nature, ability to reduce and de-halogenate most halogenated hydrocarbons, and its ability
to remove hexavalent chromium, arsenic, and uranium from a contaminated medium.
ZVI’s key mechanisms is the formation of an inner space complex. The complex yields
corrosion products including ferrous hydroxide, mixed valence iron, oxides, hydroxides,
and ferric oxyhydroxides. The removal of divalent metallic cation occurs through
reductive precipitation, surface adsorption or complexation, and coprecipitation with iron
oxyhydroxides. PRBs can also be employed using biological media, such mulch and
vegetation.

Pros (ZVI):
● Mild reductant
● Able to reduce and de-halogenate and many halogenated hydrocarbons
● Ability to remove hexavalent chromium, arsenic, and uranium.
Pros(Biological):
● Treatment process extend downgradient
● Treats multiple contaminants
Cons (ZVI):
● Only effective for certain inorganic metals and hydrocarbons
● Produces iron which can causes issues at high concentrations
Cons (Biological):
● Shorter lifespan than ZVI
● Many require replenishment of organic substrate

Oxidation

Chemical oxidation occurs when one or more electrons are lost within a substance
through contact with an oxidant. The compounds are reduced by the oxidizing agent to
allow their release from the contaminated medium. Chemical oxidants (e.g. Fenton’s
Reagent) are often injected via vertical or horizontal wells hastily to counteract the rapid
rates of reaction (“4.4 Chemical Oxidation”, n.d.). The efficacy of an oxidant is primarily
determined by site conditions and the contaminant characteristics.

Some oxidants are only effective in a certain pH range and others require a specific
temperature range to work. Soil characteristics such as fulvic acid fraction content,
organic matter, and minerals (chiefly carbonate), may also thwart operations depending

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on the oxidant (“4.4 Chemical Oxidation”, n.d.). Site conditions must be monitored at all
times to prevent any explosion hazard that may arise from the rapid reaction rates.

Pros:
● Typically meet high treatment efficiencies of above 90% (“4.4 Chemical
Oxidation”, n.d.)
● Excellent choice for eliminating and/or stabilizing a range of organics (i.e. TCE,
TCA, PCE, etc.)
● Oxidants can be tailored to many different sites
● Future research is being done to modify reagents for higher pH conditions
● Can be used in conjunction with bioremediation since reaction by products may
serve as electron donors or acceptors
Cons:
● Should be used in conjunction with SVE to extract the by-products of oxidation
● A buffer will be needed since oxidation reactions can decrease the pH
● Mobilization of redox-sensitive metals that are adsorbed to the exchangeable
fraction (“4.4 Chemical Oxidation”, n.d.) may occur
● Genesis of new compounds undesirable in soils and groundwater

Peroxide with Fenton’s Reagent

Hydrogen peroxide is an extremely strong oxidant that is particularly effective

against petroleum distillates. The weakly bonded oxygen atoms in the compound
easily create free radicals, which drives the hydrogen peroxide oxidative
properties. The high reactivity of hydrogen peroxide is also its downfall. When
injected into groundwater, hydrogen peroxide will quickly react with organic
material and degrade to oxygen and water within a few hours. Ferrous iron is
injected with the peroxide as a catalyst to create Fenton’s Reagent. This reaction
creates highly reactive hydroxyl radicals, which quickly react with organic
contaminants. The hydroxyl radicals make the solution extremely effective at
breaking hydrocarbon bonds such as those in BTEX, PAHs, and MTBE. While
highly effective, this reaction is limited by both pH and organic content. Fenton’s
Reagent requires a pH between 2-4 to react and yield the hydroxyl radicals.
Hydroxyl radicals are limited by the clay and organic matter in soil as well. The
high reactivity of the radical causes reactions to occur with the organic matter or
bind with clay particles preferentially over the target organic contaminants.
Long-term monitoring of sites remediated with Fenton’s Reagent is recommended
due to the possibility of rebound in heavier soil types. The Fenton’s Reagent
reaction is exothermic and causes the extraction of a variety of vapors. Safety

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 precautions to mitigate explosion possibilities and the implementation of SVE
procedures to prevent spread of vapors are necessary for this oxidant.

Ozone

The reaction of molecular oxygen with an oxygen free radical forms ozone. This
compound is highly reactive, which both creates issues in the stratosphere and
allows ozone to be an extremely effective oxidant. The gas is difficult to obtain
due to permitting issues, so will need to be generated on-site. This process can be
costly. Once generated ozone is bubbled through water via a process called
sparging (Chirenje, 2018). The strong oxidative potential of ozone allows the gas
to remediate organics (e.g. BTEX and PAHs). Use of ozone, a potent disinfectant,
runs a high risk of decimating the microbial population in groundwater and,
therefore, must be added to water before injecting and supersaturating the
groundwater. This procedure supports the biological community in groundwater
and allows ozone driven chemical oxidation to be used in conjunction with
bioremediation methods.

Potassium Permanganate

Potassium permanganate oxidizes over a much wider pH range than Fenton’s

Reagent. The reaction with organic contaminants produces little heat and reacts
slowly allowing for remediation of a further extent than faster acting oxidants.
While this oxidant is the most cost efficient of the oxidants, potassium
permanganate cannot break the bonds in aromatics (i.e. benzene). The oxidant
should, however, be used with great caution as permanganate is itself a
contaminant.

Pump and Treat Systems (P&T)

Similarly to SVE, P&T systems require two parts: extraction wells to transfer subsurface
contamination upward and a treatment apparatus. Groundwater monitoring wells may
also be considered an essential component since it checks the efficacy of the system. In
many cases, groundwater monitoring wells reveal that current remedial actions on a site
are not working, and need to be edited. Multiple groundwater extraction wells situated at
different depths are constructed since plumes may be vast and complex (Fig. 4). Pump
and treat is commonly used to remediate groundwater and contain contaminate plumes
before they reach potable sources. . The treatment step typically involves some form of
activated carbon (see “Soil Vapor Extraction”), but the process is usually divided

17
 amongst several steps depending on the contaminants and their respective concentrations.
Water that is processed through the treatment facility is tested to ensure that it meets
regulatory standards and is safe for stream discharge or reentry underground (“Citizens
Guide to Pump & Treat”, 2012). Pump and treat systems are found at over 800 superfund
sites, proving its reliability for a number of contaminants.

Pros:
● Treat an array of contaminants such as VOCs, SVOCs, fuels, and metals so long
as they are all dissolved.
Cons:
● May take years to meet cleanup goals (50-100 years) unless enhanced
● Not completely effective on its own for non-aqueous phase liquids (NAPLs) and
any compound insoluble in groundwater
● Depresses groundwater and exposes soil to residuals; recharge of groundwater
may cause these residuals to dissolve (“rebound”)

Figure 4:​ Schematic of a Pump and Treat System

Our Scope

As previously mentioned, there are currently 2,000 dry cleaning operations in the state of New
Jersey, and the NJDEP Site Remediation Program lists 300 of these sites. With an estimated 75%
of dry cleaners that have discharged contaminants (PCE, TCE) in the environment, the SCRD
projects the 300 sites to increase to 1,200. The aforementioned Superfund sites represent a
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snapshot of the current dry cleaning pollution situation, this further facilitates the future need for
our company’s services.

Pump-and-treat technology is the most common form of groundwater remediation; it was

employed at 73% of cleanup agreements at superfund sites with groundwater contamination from
1982 to 1992. According to the EPA’s Summary of Previous Effectiveness Evaluations of
pump-and-treat systems, “according to the Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA) and the National Contingency Plan (NCP), a 5-year
review must be conducted for all remedial actions that do not allow unlimited use and
unrestricted exposure”(2000). Results from a 5-year region-wide survey showed that 36 out of
the 45 operational and evaluated pump-and-treat systems reported to have had performance and
effectiveness evaluated and found to be sufficient. Of all 26 states evaluated in the survey, New
Jersey employed the largest number of systems in this survey, with 12 systems and an estimated
over $150 million in operational and maintenance cost (without discount) (US EPA, 2000).

Although pump and treat systems are already widely employed throughout the state, its
limitations (e.g. rebound and clean-up time) necessitates employment of innovative groundwater
cleanup technologies. JAIR Environmental addresses these limitations by enhancing our pump
and treat technology with SVE. Increasing demand for treatment of contaminated dry cleaner
sites and the need for innovative groundwater cleanup technologies gives our company an edge
over competitors. We will service contaminated dry cleaning sites, gas stations, and other sites
that require treatment of LNAPLs and VOC or SVOC contaminated soil and groundwater
throughout the state. Our qualified team will employ a combination of physical and chemical
remediation technologies to address both soil and groundwater contamination.

V. ​Our Specialization

SVE Enhanced Pump and Treat Technologies

JAIR Environmental will specialize in SVE enhanced pump and treat technologies to remediate
dry cleaner sites with VOC and SVOC soil and groundwater contamination. Other sites with
VOC or SVOC contamination will be considered as we build our client base. Additionally, we
can perform certain inorganic metal and LNAPL removal through our combined pump and treat
systems. Phase I ESAs, Phase II ESAs, and treatment of contaminants ex-situ will not be
performed by JAIR Environmental; we will contract outside parties. The following sections will
focus on the specific remediation techniques to be performed by the company, to ensure the most
effective results.

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Pump-and-Treat Techniques

I. Site Investigation and Characterization

Once the results of Phase I and Phase II confirm that a dry cleaner site contains
contaminants within the company’s scope (VOCs and SVOCs), the treatment
process can proceed. Site characteristics are just as crucial as contaminant
characteristics for proper design of pump and treat systems. We will accurately
assess the types, extent and forms of contamination both in the groundwater as
well as the subsurface area. Team members will have a strong understanding of
the physical phases in which the contaminants exist, and possible byproducts and
constituents. In the case of dry cleaner site remediation, all team members will
have a strong background and understanding of the breakdown and volatilization
of PCE. For example, the breakdown of PCE to its daughter products TCE,
cis-DCE, trans-DCE, and VC (Gaskill, 2011).

All JAIR remediation team members have a strong background in soil and water
quality analysis, and will apply their skills to the evaluation of important soil and
groundwater parameters, including but not limited to: particle size, sorption
characteristics, porosity and hydraulic conductivity. Determining these parameters
will be prioritized, as to reduce the likelihood of rebound effects. Geophysical
contractors will also be contracted to produce three-dimensional characterizations
and figures of subsurface soils and hydrogeologic conditions to ensure the proper
placement and location of wells.

II. Technological Management

One of the major concerns of pump and treat systems are the massive amounts of
groundwater removed in exchange for low levels of contaminant removal.
Contaminant removal will be maximized via efficient pumping techniques, such
as pulse pumping. This method of pumping will increase the ratio of contaminant
mass removed to groundwater volume by increasing the diffusion, desorption, and
dissolution rates in slower moving groundwater (U.S. EPA, 1996). To ensure
proper functioning and effectiveness, frequent analysis of groundwater will be
performed during the early phases of pumping.

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SVE Enhancement

Pump and treat systems benefit greatly from being enhance with SVE, which in and of itself is a
form of pump and treat. Conventional pump and treat systems have to extract large quantities of
water while extracting relatively low contaminant concentrations. Geological complexities and
the slow rate at which desorption and dissolution of contaminantes occurs cause these systems to
displace much of the aquifer to fully flush out contaminants. As such, conventional pump and
treat systems are inherently inefficient at subsurface contaminant removal. Emerging
technological advancements, including those that can remove soil contaminants (typically
LNAPLs) that would otherwise migrate to the ground and the removal of volatile contaminants
(VOC/SVOC) allows ambitious firms such as JAIR Environmental to invest in techniques that
will most efficiently serve our clientele. This brings us to soil vapor extraction (SVE); one of the
innovative technologies that has gained wide use. SVE extracts organic contaminants, usually
from unsaturated zone, by flushing with air. When the air comes into contact with pollutants
dissolved in the water inside of soil pores a mass transfer of pollutants to the air occurs. The
contaminated air is then transported to the surface, which it can be cleaned. The increased
oxygen supply that occurs at the subsurface during SVE enhances biodegradation of
contaminants via natural attenuation by aerobic microbes.

An SVE system usually has one or more extraction wells, vacuum pumps/air blowers, and a
treatment system for the extracted vapors (Figure 5). The ground is sometimes covered with an
impermeable cap to control the direction of air flow and ensure the capture of all the extracted
vapors (​NAP.edu, n.d.​).

Figure 5: ​A general setup of a typical SVE system

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VI. ​Management Strategy

While designing a company division plan, it is important to resemble the management operation
styles of other successful remediation companies. This includes an executive management team
consisting of: a president or CEO, vice president, project managers, operation and safety
managers, client services managers, and technical service managers. Additionally, those staffed
on this team should include at least some expert scientists and engineers, experienced
businessmen, and certified LSRPs.

As the company grows the executive team has the potential to develop into a board of directors.
The board of directors serve primarily to offer advice on technical and operational matters,
including new services and business solutions. The board will also make recommendations to the
CEO about specific projects as well as current and previous operations to keep JAIR
Environmental on the forefront of new remedial technology.

Additionally, we may want to consider a legal support service, a commodity rarely available at
other remediation companies. Keeping legal services on retainer both protects our company and
provides our clientele with a sense of safety in the unlikely event of litigation. Legal
consultations also serves to educate unsure clientele on common business and environmental
practices and regulations in this industry.

PCE remediation can cost between $100,000-$5,000,000. Dry cleaners are mostly small business
owners unable to bare the burden of such costs. While New Jersey does not currently have a state
funded dry cleaner remediation program, the idea has been discussed in the State Congress.
Implementation in 6 other states may spur New Jersey legislators to develop a state specific
program in the future. If implemented, dry cleaners will be able to apply for assistance in the
form of government funding.

Part VII: Operating and Equipment Costs

Operating, equipment, staffing, and associated start-up costs are an essential component of a
business plan in any industry. JAIR Environmental will employee an in-house staff as well as
contract out to minimize operating cost expenditures. Below, costs are estimated for in and out of
house staffing, equipment costs, and technology costs related to our specialization.

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In-house Staffing

CEO:​ As the company head, this position come with a base salary of $75,000 with pay per
performance bonuses in the form of stock options as the business grows and the profit margin
widens

LSRP:​ Filling this position is essential for a remediation company as the LSRP must approve and
sign-off on any proposed remediation project before remediation must begin as per the Site
Remediation Reform Act (SRRA) of 2009. This position will start at $65,000 and has the
potential to increase with experience.

Project Managers:​ As JAIR Environmental is a small company, we will employee two project
managers at a salary of $50,000 per year.

Client Services Liaison:​ Proper communication is necessary to ensure our clients’ needs are met
in a timely manner with costs and complications clearly communicated. While many remediation
firms do not maintain a business and marketing department, JAIR Environmental believes
dedicated client services personnel will give our company an advantage that will allow us to
grow more quickly. Our current size requires only one employee for this position at a starting
salary of $45,000, but company growth may require the expansion of this position into its own
department.

All of our employees at JAIR Environmental receive full medical, dental, and vision insurance
with the option to opt into an FSA to cover health costs. Starting employees are eligible for one
week paid vacation and two PTO days. These benefits will grow per year of service at JAIR
Environmental and increase employee retention rates.

Out of House Operating Costs

Environmental Consulting Firm:​ Conducting Phase I and Phase II assessments in-house is too
costly and not the most efficient use of our time. ESA’s are, of course, a necessary component in
the remediation process. Since dry cleaning facilities tend to be rather limited in size, we
estimate a cost of $3000 per ESA (How Much, n.d.). This figure rises substantially with the
implementation of a Phase II assessment. An exclusivity deal with a reliable firm in exchange for
discounted costs will be thoroughly explored.

Insurance:​ JAIR Environmental believes the litigious nature of the business realm requires us to
carry insurance to protect the firm as a whole and our LSRP who, in the event of a less than
desired judicial outcome, shoulders the financial burden. PCE remediation, without consideration

23
of associated labor and equipment, costs runs between $100,000 - $500,000. As such, we
recommend an insurance policy of no less than $5,000,000 (State Funded Dry Cleaner
Remediation Program, n.d.).

Subcontractors:​ JAIR Environmental may consult a geophysical expert if mapping must be done
to determine the extent of contamination. we will also contract out for heavy machinery we do
not feel is advantageous to purchase. As is frequently done in the contracting process, we will
allow potential subcontractors to bid and vet the most favorable bidder to ensure reliability.

Lab and Disposal Fees:​ Contaminants removed from sites will be disposed of at an off-site
facility with the specified ability to treat and store volatiles. Funding for this process and the
remediation itself may be available through the national superfund program if the client’s site has
been declared a superfund site.

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VIII. ​References

4.4 Chemical Oxidation. (n.d.). ​FRTR. ​Retrieved from: https://frtr.gov/matrix2/section4/4_4.html

4.8 Soil Vapor Extraction. (n.d.).​ FRTR.​ Retrieved from:

https://frtr.gov/matrix2/section4/4-7.html

A Citizen’s Guide to Excavation of Contaminated Soil. (2012, September). ​USEPA​. Retrieved

April 6, 2018 from:
https://www.epa.gov/sites/production/files/2015-04/documents/a_citizens_guide_to_exca
vation_of_contaminated_soil.pdf

A Citizen’s Guide to Pump and Treat. (2012, September). ​USEPA​. Retrieved April 6, 2018 from:
https://clu-in.org/download/Citizens/a_citizens_guide_to_pump_and_treat.pdf

A Citizen’s Guide to Soil Vapor Extraction and Air Sparging. (2012, September). ​USEPA​.
Retrieved April 6, 2018 from:
https://clu-in.org/download/Citizens/a_citizens_guide_to_soil_vapor_extraction_and_air_
sparging.pdf

Adsorption/Active Carbon. (n.d.). ​Lenntech​. Retrieved from:

https://www.lenntech.com/library/adsorption/adsorption.htm

Alternatives for Groundwater Cleanup. (n.d.). Retrieved April 07, 2018

from https://www.nap.edu/read/2311/chapter/6#128

Brown, K. (2013, August). ​EPA: ‘Astonishing Toxic Legacy’ At Former Wall Dry Cleaners Site​.
Retrieved from:
https://patch.com/new-jersey/wall/epa-astonishing-toxic-legacy-at-former-wall-dry-clean
ers-site_103e7198

Chemicals Used In Dry Cleaning Operations. (2002, January). Retrieved April 6, 2018 from:
https://drycleancoalition.org/chemicals/chemicalsusedindrycleaningoperations.pdf

Chirenje, T. (2018). Chemical Remediation-Chemical Oxidation. Retrieved April 07, 2018 from
https://envl4446.weebly.com/chemical-oxidation.html

Chirenje, T. (2018). Physical Remediation-Soil Flushing. Retrieved April 06, 2018 from
https://envl4446.weebly.com/physical.html

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Dry Cleaners Pollution. (n.d.). Retrieved April 05, 2018, from
https://www.environmentalpollutioncenters.org/dry-cleaners/

Dermont, G., et al. (2008). Soil washing for metal removal: A review of physical/chemical
technologies and eld applications. ​Journal of Hazardous Material​, ​152, pp. 1-31​.

Flanery, T. (n.d.). ​Ultimate Guide to Using Dry Cleaning Solvent Uses For Stain Removal.
Retrieved April 6, 2018 from:
https://www.stain-removal-101.com/dry-cleaning-solvent.html

Garden State Cleaners Co. Minotola, NJ. (n.d.).​ USEPA​. Retrieved April 6, 2018 from:
https://cumulis.epa.gov/supercpad/cursites/csitinfo.cfm?id=0200362

Gaskill, M.K., (July 2011). Fate of Spilled Perc in the Subsurface. Retrieved April 06, 2018 from
https://www.enviroforensics.com/fate-of-spilled-perc-in-the-subsurface-understanding-th
e-basics-when-it-gets-in-the-ground/

How Do Stain Removers Work?. (2009, November). ​UCSB ScienceLine​. Retrieved April 6, 2018
from: http://scienceline.ucsb.edu/getkey.php?key=2173

How Much Does a Phase I Environmental Assessment Cost? (n.d). Retrieved April 7, 2018
from:
https://www.rmagreen.com/rma-blog/bid/89507/how-much-does-a-phase-i-environmenta
l-site-assessment-cost

Keyes, G. (n.d.). ​Cleaning Up After Dry Cleaners​. Retrieved April 6, 2018 from:
https://www.ccim.com/cire-magazine/articles/cleaning-after-dry-cleaners/?gmSsoPc=1

Roote, D. (1997) Groundwater Remediation Analysis Technology Center: In-Situ Flushing.

Retrieved April 06, 2018 from https://clu-in.org/download/remed/flush_o.pdf

Soil Washing. (n.d.) Retrieved April 06, 2018, from

ceeserver.cee.cornell.edu/mw24/Archive/01/cee453/Lectures/soil_washing.ppt

Soil Washing. (n.d.) Retrieved April 06, 2018, from:

www.cpeo.org/techtree/ttdescript/soilwash.htm

State Funded Dry Cleaner Remediation Program. (n.d.). Retrieved April 5, 2018, from
http://www.nj.gov/dep/srp/stakeholders/whitepapers/dry_cleaner_rem.pdf

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Sullivan, S. (2017, April 06). The most toxic sites in New Jersey., from:
http://www.nj.com/news/index.ssf/2017/04/the_most_toxic_sites_in_each_new_jersey_c
ounty.html

United States EPA (2000). Groundwater Pump and Treat Systems: Summary of Selected Cost
and Performance Information at Superfund-financed Sites. Retrieved April 06, 2018 from
https://clu-in.org/download/remed/542r01021b.pdf

White Swan Laundry and Cleaner Inc. Wall TWP, NJ. (n.d.). ​USEPA​. Retrieved April 6, 2018
from:
https://cumulis.epa.gov/supercpad/SiteProfiles/index.cfm?fuseaction=second.cleanup&id
=0204241

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