Dry Cleaners Due Diligence & Municipal Settings Designation

Services Performed

ESE was retained by a national retail developer and property manager to conduct a Phase II Environmental Site Assessment (ESA) on a property located along Westheimer Road in West Houston.  The Phase II ESA was requested by the client in response to an on-site dry cleaner that was identified as a Recognized Environmental Condition in a previous Phase I ESA.  ESE Partners’ Phase II ESA confirmed the presence chlorinated volatile organic compounds (VOCs) in shallow soils and groundwater at concentrations greater than Texas Commission on Environmental Quality (TCEQ) Protective Concentration Levels (PCLs). As a result of the Phase II ESA findings, ESE on behalf of the client enrolled the site into the TCEQ’s Voluntary Cleanup Program (VCP) and proceeded with site characterization activities in accordance with 30 Texas Administrative Code (TAC) §350 Texas Risk Reduction Program (TRRP).  Upon completion of soil and groundwater plume delineation and characterization, ESE completed a Municipal Setting Designation (MSD) application that was accepted by the City of Houston.  The MSD effectively eliminated the groundwater ingestion pathway by means of institutional control, allowing the site to receive Certificate of Completion from the TCEQ’s VCP, upon approval of the Affected Property Assessment and Response Action Plan.


ESE’s objective was to obtain a Certificate of Completion from the TCEQ’s VCP for the release of chlorinated solvents to shallow soil and groundwater, as a result of historical dry cleaning activities.

Scope of Work

  • ESE conducted a Phase II ESA, which confirmed the presence of chlorinated VOCs in shallow soil and groundwater.
  • Delineation of the chlorinated VOC plumes in shallow soil and groundwater.
  • Demonstrated plume stability in groundwater through quarterly groundwater monitoring and Mann-Kendall modeling.
  • Completion and acceptance of a MSD application by the City of Houston.
  • Provided client representation at public hearings and City Council meetings.
  • Made required notices to applicable Retail Public Utilities and private well owners of the proposed MSD application.
  • Prepared an Affected Property Assessment Report and Response Action plan in accordance with 30 TAC §350 TTRRP.
  • Received a Certificate of Completion from the TCEQ’s VCP.

Key Benefits to Client

  • Environmental impacts at the site were addressed through risk based corrective action strategies, significantly reducing the cost of remediation.
  • The risk based closure strategy allowed for continual use of the Site without business interruption. The implementation of a MSD significantly reduced the schedule required to obtain regulatory closure.
  • All exposure pathways including those associated with vapor were fully evaluated and demonstrated not to be a threat to the future inhabitance of the Site, regardless of future Site use.
  • A Certificate of Completion was obtained from the TCEQ’s VCP, indemnifying future protective purchasers from the environmental liability identified at the Site.  This indemnification significantly increased the marketability and fair market value of the property.

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