SUMMARY OF THE REMEDIATION TECHNOLOGIES DEVELOPMENT FORUM
NON-AQUEOUS PHASE LIQUID CLEANUP ALLIANCE MEETING
San Luis Obispo, California
February 28, 2001
Randall Breeden and Mark Lyverse, the two co-chairs of the Remediation Technologies Development Forum (RTDF) Non-Aqueous Phase Liquid (NAPL) Cleanup Alliance, opened the meeting by welcoming participants and thanking them for attending. (See Attachment A for a list of attendees.) The co-chairs said that they hoped the meeting would serve to solidify the Alliance’s goals, define its future direction, and propel activities forward. Before launching into the agenda items, the co-chairs agreed that it would be valuable for attendees to summarize what they hoped to gain from the meeting. Attendees expressed the following expectations:
MEMORANDUM OF UNDERSTANDING
Kaback said that an MOU has been prepared for the NAPL Cleanup Alliance. It is intended to serve as an umbrella document, providing a broad overview of the Alliance's goals and the relationships that will exist between Alliance members. Draft versions of the MOU were circulated, Kaback said, and comments have been incorporated. A final version was distributed to potential alliance members on February 22, 2001. Kaback asked meeting attendees whether the entities they represented planned to sign the MOU. Their responses revealed that:
Kaback thanked the group for working diligently to get the MOU signed. She agreed to collect and collate original copies of the signatory pages, distribute copies of the signed MOU to participating entities, and forward the originals to the U.S. EPA Technology Innovation Office (TIO).
Before this discussion was closed, Yager highlighted a couple of the points that the MOU makes. First, she said, MOU signatories needed to understand that the Alliance is subject to the Freedom of Information Act (FOIA). Thus, some of the documents shared between group members could be made available to the public under FOIA. Also, Alliance meetings are open to the public. (Meetings do not have to be advertised, but any member of the public who wants to observe an Alliance meeting must be allowed to do so.) Yager's second point addressed the role of the Alliance's co-chairs. She said that the two co-chairs (Breeden and Lyverse) are ultimately responsible for steering the Alliance's activities. For example, if the group fragments and camps with opposing ideas about a situation develop, the co-chairs will be responsible for resolving the conflict.
DISCUSSION ABOUT THE ALLIANCE'S ORGANIZATIONAL STRUCTURE AND OPERATIONAL PRACTICES
Sharing Information Through the RTDF Web Site
Carolyn Perroni said that information about the NAPL Cleanup Alliance’s mission, goals, and objectives will be posted on a Web page at www.rtdf.org. This Web page will also feature summaries of all Alliance meetings and conference calls. Useful links will also be made available; for example, a link will be established to direct users to the Guadalupe Oil Fields Web site. Perroni asked attendees to send her information on other useful links. The Alliance’s Web page will also contain a password-protected area where Alliance members can share preliminary reports and sensitive information. User identifications and passwords will be distributed to Alliance members soon, Perroni said, along with instructions on how to post files to the protected area.
Perroni said that there is much that the Alliance can do with their Web page. For example, other RTDF Action Teams have posted bibliographies, created site profiles, and established photo libraries. Some of the meeting attendees suggested posting the MOU on the Web page, but others did not think this was necessary. If it is posted, one attendee noted, Alliance members would need to decide whether it should be posted to the password-protected or the public portion of the Web site. If the latter is chosen, the signatory page should be omitted.
Tiers of Involvement
Attendees said that there are many ways in which people can interact with the Alliance. They defined three tiers of involvement:
Perroni agreed to distribute an e-mail listing people who fall under these three tiers. Alliance members will be asked to review the list and offer feedback.
Attendees agreed that meeting invitations should be distributed to all core members and associate members, but they did not reach consensus on what kinds of information to distribute to those in the “other interested parties” category. While Breeden suggested simply directing these people to the Alliance’s Web page, Yager suggested sending them yearly progress reports.
Yager asked whether a steering committee should be formed. Attendees decided against it. Instead, they agreed, it would be more useful if the Alliance co-chairs formed temporary steering committees whenever they need help developing meeting agendas or performing other tasks.
Perroni, observing that the Alliance is a new organization, advised establishing some rules. For example, she said, the group may want to define a process for making decisions about Alliance activities. If the Alliance does decide to outline a framework, Perroni said, the following questions will need to be addressed: (1) What constitutes a quorum? (2) Does each entity get just one vote? and (3) Does the majority rule or is consensus necessary? Attendees agreed to defer this discussion to a later date.
THE CASPER REFINERY WORKING GROUP
As noted above, one workgroup has already formed under the Alliance’s umbrella. This workgroup, which consists of Tavelli, Hostetler, Jewett, Kent Udell, and John Meyers, will address contamination at a refinery site in Casper, Wyoming. This site is owned by Texaco Group, Inc.
An Overview of Texaco’s Philosophy and Stance
Randy Jewett, Texaco Group, Inc.
Jewett said that Texaco owns several refinery sites that are no longer operational. These sites, which are large, complex, and contaminated, pose a managerial and financial challenge to the company. Texaco’s way of handling such sites, Jewett said, has changed over the years. In the past, the company had no hopes of selling the properties. As a result, they made efforts to prevent contaminant migration, but did not undertake aggressive onsite cleanup. Texaco adopted this approach, Jewett explained, because the company believed it would be more expensive to clean up and sell a site than it would be to simply continue to own the non-remediated site indefinitely. By 1995, however, it had become clear that this strategy had drawbacks. Over time, site managers realized that closed refineries tend to “take on lives of their own.” Jewett explained that more and more staff members were being hired to manage the closed sites and the operating budgets for the sites kept growing. The company decided to embrace a different approach toward closed refineries: dismantle abandoned sites, remove facilities, clean up portions of the site, and sell the property. The company’s new goal, Jewett said, is to remove the closed refineries from the company’s asset base.
Jewett provided information about the Texaco site that the Casper Refinery Working Group will be working on. At one point, he said, ground-water contaminants from the site were discharging to the North Platte River. Not surprisingly, this caused great concern among the public and the regulatory community, the latter of which issued cleanup orders. Thus, Texaco’s first goal was to stop facility-related contaminants from migrating beyond the site’s boundaries. Jewett said that a variety of remedial measures were used to stabilize the site, including ground-water interceptor trenches, pump-and-treat systems, soil vapor extraction, total fluid vacuum extraction, and hydrocarbon recovery wells. In addition, a sealed-joint barrier wall was installed between the site and the North Platte River in December 1999. These measures allowed Texaco to achieve its short-term objective—stabilizing the site.
Jewett said that Texaco will continue to operate the remedial systems it has deployed. Now that the site has been stabilized, the company is ready to pursue the loftier goal of addressing onsite contamination. Over the long term, Jewett said, Texaco hopes to tackle the following question: Is it possible to identify and implement a series of remedies that would work fast enough, effectively enough, and economically enough to reduce contaminant concentrations below risk-based standards so that the site would be considered acceptable for future re-use? Jewett said that Texaco plans to test innovative technologies to determine whether they will compress remediation timeframes. He said that the site is an ideal place to conduct a demonstration because the barrier wall provides a protective cushion. Thus, even if contaminants were mobilized in unanticipated ways, no harm would be done because the sealed-joint barrier wall would prevent contaminants from migrating into the North Platte River.
Reversing the gradient and extracting large quantities of water has caused the water table to drop. Therefore, in a way, installing the remedial systems has created a scenario that mimics a severe drought. As the ground-water table has dropped, Hostetler said, researchers have observed an interesting phenomenon: LNAPL is starting to accumulate and thicken in wells where it has not appeared in years. Hostetler, with help from Meyers, explained why this might be happening. As the water table drops, they said, gravity overcomes capillary pressure and releases NAPL from soil pore spaces. Victor Kremesec said that he has also seen NAPL quantities increase as ground-water levels decrease at other sites. This occurs, he said, even if only a small portion of the pore space is filled with NAPL—for example, at one site, 14 feet of NAPL accumulated even though soil saturation was only about 5%. Kremesec asked whether soil saturation had been measured at the Casper site. Hostetler said that it had not. Both Kremesec and Fletcher agreed that such measurements can be very informative. This sparked a discussion on the best way to measure soil saturation. Kremesec advised collecting capillary pressure measurements from soil cores. He said that saturation predictions obtained with this method correlate well to actual saturation measurements from soil cores. Eva Davis cautioned that error is embedded in methodologies that involve coring: some NAPL drains out as cores are pulled to the surface. Kremesec did not think that this drainage is overly significant. Not all of the attendees agreed with him, however. Meyers did say that oil companies have long recognized that measurements generated in the laboratory differ from those collected in situ. He said that it would be useful if cores could be frozen before being extracted from the ground, and that some groups are trying to develop such technologies.
Overview of the Regulatory Perspective and Outline of the Workgroup’s Goals
Ali Tavelli, Wyoming DEQ
Tavelli said that Wyoming DEQ is the main regulatory agency involved at the Casper site. She described the relationship between DEQ and Texaco as cooperative and productive. In order to successfully address the site, Tavelli said, Texaco will be required to work within the regulatory framework of Wyoming’s statues. Portions of the statute are rigid, she said; for example, the law indicates that ground water must be cleaned up to meet maximum contaminant limit (MCL) standards. It also clearly states that chosen remedies must protect human health and the environment, reduce or eliminate sources, and comply with waste management standards. Although these requirements are rigid, Tavelli said, the statute does offer flexibility in timeframes. For example, the state indicates that goals must be achieved in a “reasonable” timeframe, and that remedial measures must be undertaken to the point “practicable.” The law does not define the terms “reasonable” or “practicable.”
Tavelli said that the Casper Refinery Working Group will work toward defining what is reasonable and practicable for the Casper site. The group will strive to develop a scientific approach that can be used to put shape to these words and substance behind them. She said that the workgroup will focus on portions of the site where surface soil contamination is not a driver of risk. She acknowledged that surface soil will need to be addressed before the property can be reused for other purposes, but said that focusing on the subsurface is also essential if Texaco wants to transfer the property. Even if surface conditions were considered perfectly safe for reuse, she explained, Texaco would continue to be liable for the site as long as subsurface contaminants persisted at levels above MCLs. Tavelli said that she and Hostetler have started drafting a list of factors that must be addressed to define “reasonable” and “practicable.” These are:
|Timeframe and Influence on the Word "Reasonable"||F||Technology and Influences on the Word "Practicable" (Note: dig and haul is not an option)|
|Public tolerance||U||Ambient air conditions|
|Regulatory tolerance||N||Contaminant characteristics and distribution|
|Site owner tolerance||D||Technology availability|
|Endpoints of remedial stages||I||Stage of development|
|G||Endpoints of remedial stages|
Future Activities for the Casper Refinery Working Group
Tavelli said that the workgroup would meet immediately after the Alliance meeting to discuss their goals and scope of work in more detail. Once the scope is more refined, she said, it will be distributed to the Alliance’s core members for comment and review. Hostetler said that the workgroup also plans to establish a Cooperative Research and Development Agreement (CRADA) between Texaco Group, Inc., Trihydro Corporation, Wyoming DEQ, EPA, ThermoRetec Consulting Company, and the University of California. The CRADA, among other things, will specify that Texaco, as the site owner, has the final say in all decisions that impact the site. (Hostetler said that CRADAs were discussed during a conference call; the summary is available at www.rtdf.org/public/napl/minutes/020101.htm.)
Tavelli said that the workgroup hopes to draw upon the expertise and in-kind services of Alliance members and to solicit input and comments from core members. She said that the core team must decide what it expects back from the Casper Refinery Working Group. Does the Alliance want quarterly reports from the workgroup, she asked, or would brief updates posted on the RTDF Web page be more useful?
THE GUADALUPE OIL FIELD
On the day before their meeting, Alliance members went on a field trip to the Guadalupe Oil Field. Breeden asked participants to direct any questions that they had about the site to Udell. Attendees embraced the opportunity and asked:
THE ALLIANCE’S FUTURE ACTIVITIES AND NEXT STEPS
Identifying Other Sites To Investigate
Hostetler, Tavelli, Kaback, and Jewett said that they envisioned a network of workgroups forming under the Alliance to address contamination at different refinery sites. Kaback said that she hoped that the lessons learned at different sites would be used to address some of the larger issues that the Alliance is tackling. Jewett reminded attendees that the Alliance is supposed to address nationwide issues; therefore, efforts should be initiated to solicit sites from different parts of the country. Other attendees also thought it would be interesting to address multiple sites, noting that cleanup at each site might be motivated by a different set of drivers.
Kremesec asked whether a process had been defined for forming new workgroups. Breeden and Kaback said that the process is informal: once a potential site has been identified, the person proposing the site should solicit volunteers to work on the project, identify the site’s main issues and goals, and propose a new workgroup. Yager said that workgroups should have two co-chairs, one representing industry and the other representing a regulatory agency.
Kremesec asked whether people should get regulatory approval before proposing new sites to the Alliance. Kaback thought this would be useful, pointing out that activities that progress without the blessing of regulators are not likely to succeed.
Fletcher asked whether a workgroup could be formed for a site for which a remedial technology was already chosen. Attendees said that sites fitting this profile are too far along to be considered. Breeden said that an ideal site would be one that: (1) has some site characterization data, (2) is regulated by agencies open to innovative technologies, and (3) has some preliminary environmental indicator goals defined.
Kremesec said he knew of a site that might be a strong candidate. Fletcher said that he knew of another, this one in Billings, Montana. He asked Breeden to contact a Conoco representative to inquire about the latter site. Breeden agreed to do so.
Developing a Decision-Making Framework
Attendees agreed that it would be useful to create a decision-making framework that describes how to address contaminated refinery sites. They agreed that a workgroup should be formed to start developing the framework. Liguori, Kremesec, Woodward, and Lyverse volunteered to spearhead the effort. Lyverse will identify other industry representatives who might be interested in participating. At the same time, Tavelli and Breeden will query the National Refinery Work Group to identify state regulators who are willing to become workgroup members.
While the workgroup will take the lead on developing the framework, attendees agreed, the work produced by other Alliance workgroups will feed into the final product. For example, the Casper Refinery Working Group’s conclusions about how to define “reasonable” and “practicable” will have tremendous relevance.
Attendees cited the following concepts or sources that might serve as useful starting points for developing a decision-making framework:
The Technical Information Workgroup
Breeden said that a workgroup has formed to review information on cleanup projects that have already been completed in the United States and Europe. This group will perform a literature review, identify useful text, and make it available to other Alliance members. Breeden said that he, Yager, Woodward, and Kaback have volunteered to participate in the effort. He agreed to search for other state regulators who might be interested in participating as well.
While perusing existing documents, Kaback said, the workgroup members will look for information that might help other Alliance workgroups establish decision-making frameworks and define “practicable” and “reasonable.”
Attendees cited some completed projects that might be interesting to evaluate. These included the steam-enhanced extraction project at Alameda Naval Air Station and projects at DOD base realignment and closure sites.
Lyverse asked whether Alliance members would be asked to contribute funds to facilitate workgroup activities. At this point, attendees noted, they hope that Alliance members would offer in-kind services. No mechanism currently exists to collect revenue from team members. Some attendees said that this might change as the Alliance and associated workgroups develop more concrete goals. These particular attendees said that they envisioned the Alliance acting much like the Petroleum Environmental Research Forum, a forum created to allow petroleum companies to pool resources in an effort to answer research questions. If a similar model is adopted for the Alliance, industry members might be asked to make cash contributions and regulatory agencies would be expected to offer in-kind services.
Breeden said that some Alliance members have already expressed interest in creating a small pool of funds to support Alliance activities. He agreed to research mechanisms for establishing such a fund. At this point, he said, it might be useful to use the funds to pay travel expenses for state regulators who are needed at Alliance meetings.
A Summary of the Alliance’s Goals
Breeden said that he thought the Alliance’s overarching goals had been clarified during the meeting. He and Lyverse agreed to create a strawman that summarizes the group’s goals and gives some overarching “marching orders” to the Alliance’s workgroups. Once the strawman is completed, it will be e-mailed to Alliance members for comment.
The Next Alliance Meeting
Alliance members decided that their next meeting should be held during the third week of June. They suggested having a 2-day meeting and holding it either in Chicago, Illinois, or in Oakland, California. ERG will start researching the possibility of holding a meeting in one of these cities.
Breeden and Lyverse thanked the attendees for their participation. They agreed that the meeting had been productive and that progress had been made in refining the Alliance’s goals. Before departing, the attendees revisited the expectations they had listed for the meeting. For the most part, attendees said, the meeting was a success and expectations had been met. They did note, however, that more discussion is still needed on: (1) efforts to leverage funds and technology, (2) how the Alliance’s work will benefit industry, and (3) schedules and deadlines for deliverables.
The following action items were identified during the meeting:
San Luis Obispo, California
February 28, 2001
Alexandra (Ali) Tavelli
RTDF technical and logistical support provided by: