SUMMARY OF THE REMEDIATION TECHNOLOGIES DEVELOPMENT FORUM
NON-AQUEOUS PHASE LIQUID CLEANUP ALLIANCE MEETING
U.S. Environmental Protection Agency—Region 6
May 21–22, 2003
WELCOME AND OPENING REMARKS
Mark Lyverse, ChevronTexaco Energy Research and Technology Company
Mark Lyverse, co-chair of the Non-Aqueous Phase Liquid (NAPL) Cleanup Alliance,
welcomed meeting participants and asked them to introduce themselves. (Attendees
included representatives from petroleum companies, consulting firms, and federal
and state regulatory agencies; see Attachment A (PDF,
39KB).) Lyverse noted that Randy Breeden, who has served as the Alliance’s other
co-chair for several years, has temporarily stepped away from his position
to accept a new assignment.
Christine Lehnertz, representing Region 8 of the U.S. Environmental Protection
Agency (EPA), will serve as a co-chair in Breeden’s absence. Unfortunately,
Lyverse said, Lehnertz was unable to attend this meeting.
Lyverse provided background information on the NAPL Cleanup Alliance. The
group is one of six active teams participating in the Remediation Technologies
Development Forum (RTDF). This forum, which is supported by EPA’s Technology
Innovation Office (TIO), fosters collaboration between the public and private
sectors in developing innovative solutions to hazardous waste problems. The
Alliance’s roots stretch back to 1998, when a meeting was held in Region
8 to discuss challenges associated with sites contaminated with light non-aqueous
phase liquid (LNAPL). During the meeting, much interest was expressed in identifying
better ways to manage and remediate LNAPL sites. This interest gave birth to
the NAPL Cleanup Alliance, a partnership that has been formalized with a memorandum
of understanding. The Alliance has worked on several projects since its inception,
Lyverse said, noting that the status of each would be discussed during the
THE ALLIANCE’S DECISION-MAKING FRAMEWORK
The NAPL Cleanup Alliance is developing a NAPL Management Decision Framework
(NMDF) document in an effort to help people identify practicable and reasonable
approaches for cleanup and long-term management of LNAPL sites. One of the
document’s major themes is the importance of fostering collaboration
and consensus-building approaches among diverse stakeholders.
Dawn Kaback, of Concurrent Technologies Corporation (CTC), is preparing the
document with support from Sage Risk Solutions, Inc., and Paulson & Cooper,
Inc. Over the last year, Alliance members have reviewed several versions of
the document’s outline. The review process sparked debate and prompted
several members to submit comments about the document’s scope, flow,
and content. These comments were carefully considered, and in late March 2003,
the Alliance leadership finalized the outline and asked Kaback to develop the
first full draft of the NMDF document. The draft was distributed to Alliance
members on May 13, 2003.
Overview of the NMDF Draft Document
Dawn Kaback, CTC
Kaback provided a brief overview of the draft NMDF document’s content
and organization. In summary, she said, the document includes the following
- Introduction and Objectives
- Organize Resources, Develop the End-State
Vision, and Establish LNAPL Management Goals
- Collect and Analyze Supplemental
- LNAPL Management Strategy
- Establish Endpoints To Measure Progress
- Implement and Monitor
- Revisit the LNAPL Management Plan
- Appendix A: Current Conditions Checklist
- Appendix B: Selection of LNAPL
- Appendix C: Selected LNAPL Characterization and Remediation
- Appendix D: References
See Kaback’s presentation (included as Attachment
B (PDF, 54KB)) for additional
information about the subtopics in each major section.
Group Discussion on the Draft NMDF Document
Facilitated by Dawn Kaback (CTC) and David Zabcik (Shell Oil Products US
Company & Motiva
Kaback and David Zabcik, co-chairs of the Alliance’s NMDF Subgroup,
asked attendees to comment on the NMDF document. The attendees obliged, recommending
- Make it clear that the NMDF document is designed to address sites
where imminent hazards are already under control and site managers already
know that an LNAPL problem exists. The Alliance leadership agreed that the
NMDF document should address sites where imminent hazards are already under
control (e.g., sites where environmental indicators [EIs] have already been
met) and said that this point should be emphasized in the Executive Summary,
the “Introduction and Objectives” section, and the document’s
flowchart. Focusing on the latter, attendees questioned whether the text in
the first box of the flowchart (i.e., “Immediate hazards under control?”)
should be modified to read “Have you completed your EIs?” Leslie
Hay Wilson advised against this proposed modification, saying that the term “EI,” which
is a RCRA term, is too prescriptive and would lead people to believe that the
flowchart can only be applied to RCRA sites. Another attendee advised changing
the box to read “Has all of your risk been assessed?” Terry Vandell-Bell
said this proposed modification is also problematic: risk is constantly reassessed
throughout all stages of the LNAPL management process. It is erroneous to
imply, she said, that risk is evaluated just once during the initial stage
of a project.
Moving on to another topic relating to imminent hazards, some attendees advised
including citations in the NMDF document that readers can use to determine
whether imminent risks have already been adequately addressed at their sites.
Other attendees, however, did not think it was necessary to provide such
citations. Sue Westbrook suggested including information on the steps that
need to be
taken to determine whether a site even has an LNAPL problem in the first
place. John Meyers said that this type of information would not be necessary.
that it is fair to assume that those who will be using the NMDF document
have already performed enough research to determine whether an LNAPL problem
Other attendees agreed with Meyers.
- Make it clear that a written “LNAPL Management Plan” is
not always needed. The NMDF document, Lyverse said, should not imply that management
decisions must be recorded in a formal LNAPL Management Plan. While documenting
decisions in a written plan might be useful, he said, it is also acceptable
for people to solidify their decisions over a handshake. Lyverse’s comments
spurred other attendees to comment on some of the prescriptive language that
is currently included in the document. Attendees advised the authors to steer
away from words like “should” and “must,” noting that
the document’s purpose is to provide suggestions and recommendations
on addressing LNAPL sites rather than serving as an authoritative regulatory
- Soften the superlatives. Greg Fletcher advised against using
statements like “this activity is best conducted by . . .”
the term “end-state vision” with “long-term
vision.” Attendees decided to use the term “long-term vision” in
place of “end-state vision.” Kaback provided some clarification
on the term, noting that “long-term vision” refers to the qualitative
big picture that is envisioned for a site. Ali Tavelli said that it might be
unrealistic to expect stakeholders to achieve consensus on one long-term vision
at the start of the LNAPL management decision-making process. In light of Tavelli’s
point, Zabcik advised making it clear that failure to achieve consensus up
front on a single long-term vision should not prevent people from moving forth
with the LNAPL management decision-making process.
- Define and describe key
terms more clearly. Greg Fletcher advised underlining the terms that are
formally defined in the NMDF document. Attendees
also recommended defining terms in the Executive Summary as well as the “Introduction
and Objectives” section of the document. When defining terms, Mark Adamski
and Vic Kremesec said, the document should include examples to help readers
fully understand the meaning of each term. For example, when defining the phrase “long-term
vision,” Kremesec said, the authors could state that the vision will
differ from site to site: while achieving pristine conditions might be the
long-term vision at one site, continuous operation as an active refinery might
be the long-term vision at another site. Hay Wilson asked NAPL Cleanup Alliance
members to submit suggestions on real-world examples that could be used to
further define the NMDF document’s key terms.
- Tell readers where to
find key information within the document. Adamski noted that there are a
series of text boxes peppered throughout the document
that highlight key points. He said that a reader who is already savvy about
LNAPL issues might be able to absorb the gist of the entire document just by
reading the Executive Summary and the text boxes. Thus, he said, it might be
useful to let readers know that they can obtain the key messages just by reading
these sections. This will allow readers who already know a lot about LNAPL
management issues—and therefore do not require as much detailed background
information—to read through the document in a streamlined fashion.
information about the RTDF NAPL Cleanup Alliance’s history
and qualifications. Jeff Hostetler advised including additional historical
and background information about the Alliance, either in the Executive Summary
or in a preface. This will prevent readers from asking, “Who is writing
this document, what qualifications do they have, and why is the document being
written?” Attendees thought Hostetler’s suggestion was a good
- Provide information about how the NMDF document advocates a better
approach to LNAPL
management decision-making processes. Hostetler recommended
providing background information in the Executive Summary about the pitfalls
one commonly encounters when trying to manage large LNAPL sites. After doing
so, he said, it is important to explain how the NMDF document will help avoid
these pitfalls. The idea, he said, is to stress the fact that the NMDF document
represents a forward-thinking and progressive philosophy that bypasses existing
stumbling blocks. It would be useful to explain, he said, how this document
differs from other documents.
- Be wary of using the phrase “maximum extent practicable.” The
term “maximum extent practicable” is used in the second paragraph
of the Executive Summary. Zabcik advised against using this phrase, noting
that it is used for the Underground Storage Tank (UST) program. Hay Wilson
said that the paragraph will be restructured to hit the following ideas:
the default point, from a regulatory perspective, is to remove NAPL to the
practicable, but this stance is not necessarily always the best one to take.
Lyverse noted that “maximum extent practicable” is also used
in the “Introduction and Objectives” section of the document,
where it is accompanied by a reference to federal regulations. Attendees
that this reference should be removed.
- Clarify that short-, intermediate-,
and long-term goals do not have to be set all at once. As written,
Meyers said, the NMDF document implies that
all of these goals must be established simultaneously. While such an approach
is acceptable, he continued, the document should make it clear that it is
also acceptable to set the goals individually as long as care is taken to
that short-term goals do not conflict with long-term goals.
- Modify the last
sentence under the “Collect and Analyze Supplemental
Data” heading in the Executive Summary. Kremesec advised making
it clear that evaluating risk and regulatory compliance considerations is a
of the LNAPL management process.
- Clearly define what is meant by the phrase “iterative nature” and
do not lead readers to believe that the LNAPL Management Plan requires constant
updating. Kaback said that the sections that discuss the iterative nature
of the LNAPL management decision-making process will be reworked.
what is meant by the term “source zone.” Dick
Woodward said that the NMDF document implies that source zones should already
be addressed. Woodward said that this assumption could be false, especially
if the NMDF document is being used to guide management systems at an operating
facility where existing structures preclude access to contaminated soils. Zabcik
said that there are two types of sources: (1) leaking facilities—which
really should be fixed up front before one gets too involved with the long-term
NAPL management process, and (2) contaminated soil. The NMDF document should
make this clear.
- Incorporate the concept of contingency plans. Lyverse suggested
incorporating the concept of contingency planning into the NMDF document.
and advised modifying the document’s flowchart to incorporate this concept.
He advised adding another box to the flow diagram that reads “Contingency
Plan.” Users would be directed to this box, he said, if they answered “no” to
the questions that ask about whether endpoints have been met. Dashed lines
leading back to earlier parts of the decision-making flowchart would emanate
from the “Contingency Plan” box. Meyers said that the potential
reasons for not achieving endpoints can be numerous. For example, they can
range from something relatively simple like needing to make remediation system
modifications to more serious problems, like trying to meet an impracticable
goal. The Contingency Plan, which should be established prior to system implementation,
Meyers said, should discuss all the potential causes and the appropriate
- Make minor changes to the flowchart. Vandell-Bell advised
data” to the box that reads “Organize Resources.” In addition,
Meyers stated that the box that asks whether acceptable options are available
should be modified to remind users that they need to ask themselves whether
the initial site goals are still practicable. If the answer to either question
is “no,” Meyers said, dashed arrows should be added to direct the
reader to either the goal-setting step or the “more data needed?” decision
box. Before the end of the year, Jim Higinbotham said, the American Petroleum
Institute (API) plans to release a browser-based training program, called eManual,
that consists of a set of tools that can be used to develop an overall approach
for evaluating and managing LNAPL. One of the tools included in the eManual
package is a flowchart that outlines an LNAPL management strategy. Higinbotham
said that the first draft of the flowchart has been created and presented to
API representatives. The flowchart is similar to the one the Alliance has created
for the NMDF document. Higinbotham and Harley Hopkins said that it would be
useful to harmonize the two flowcharts to ensure that they do not conflict.
Since the RTDF flowchart has progressed further, Kremesec said, it makes sense
for the API flowchart to be modified to mirror the RTDF’s flowchart.
Higinbotham and Hopkins agreed to work on this. In fact, before the meeting
ended, they had already begun.
- Include additional EPA references. Kaback said
that the document does not currently provide all the references that it should.
She agreed to
send Alliance members a list of the references that are currently cited.
She encouraged them to review the list and to let her know whether additions
- Modify the text box that addresses the Guadalupe Oil Field. Kaback
said that this text box has been created to give an example of successful
stakeholder collaboration. Adamski expressed surprise: he had heard that
relations at the
Guadalupe Oil Field site were adversarial and that the cleanup project had
been a failure. Kaback and Tavelli acknowledged that this was true of the
initial phases. The project was salvaged, however, when the stakeholders
decided to embrace a collaborative, consensus-building approach. Zabcik advised
information to the text box about the problems that existed before the collaborative
process was initiated. Kaback agreed to do so, saying that she would ask
Eva Davis for additional information about the public involvement component
the Guadalupe Oil Field project if necessary.
- Modify Table 2 and the text
box entitled “Contaminated Site
Cleanup Example.” Some attendees thought that the information provided
in these two sections was misleading. They said that these sections imply that
all of the stakeholders who represent a certain group automatically feel a
certain way about site cleanup goals. Attendees advised changing the tone in
the table and the text box. Kaback agreed to do so. In addition, attendees
advised changing the title of Table 2 to “Common Stakeholder Starting
Positions” and modifying the statement that says that regulatory agencies
will be interested in “continu[ing] compliance with LNAPL regulations.” As
an alternative, Tavelli recommended saying that regulators will want to “eliminate
releases and control sources as best as possible.” Attendees also advised
changing the language in the text box to say that health risks should be reduced
to acceptable values rather than zero or near zero.
- Consider using the word “impacted” rather than “contaminated.” Kaback
also asked attendees to think of other alternatives for the word and to submit
suggestions directly to her.
- Provide a better definition for the term “mobility.” Adamski
said that the definition currently provided for the term “mobility” is
circular in nature. Tavelli advised revising the definition to say something
like “If you have to change the chemical or physical properties of a
NAPL to move it, then it is considered immobile.” Other attendees liked
this definition and recommended highlighting it in a text box, along with information
to distinguish the difference between “mobility” and “mobile
- Modify the first sentence in paragraph two of Section
3.4. Kremesec advised making it clear that geological site conditions
affect the extent and
success of LNAPL recovery.
- Make it clear that LNAPL saturation values cited
in the literature can be erroneous. Section 3.7 indicates that LNAPL saturation
for a site “can
be compared to a residual saturation value, either from the literature . .
. or from laboratory measurements.” Adamski said that he is uncomfortable
with this statement—he has little faith in values cited in the literature.
Attendees advised adding a statement that cautions readers against believing
everything they read in the literature.
- Modify the discussion of natural attenuation rates. Hay
Wilson said that the NMDF document will be modified to say that it is useful
information about a site’s natural attenuation rate.
- Consider changing
the title for Section 4.0—LNAPL Management
Strategy. Meyers recommended making it clear that technology selection is the
key activity covered by Section 4.0. Hay Wilson said that the authors decided
against including the term “technology” in the title for Section
4.0 since institutional controls are also a viable management strategy.
information to Appendix A. Tavelli agreed to send information to Kaback about
what Wyoming does to ensure that stakeholder input is obtained.
This information, Kaback said, could be included in the NMDF document’s
Current Conditions Checklist.
- Add more references to Appendix C. This appendix
provides references on characterization and remediation technologies that
can be used to address
LNAPL sites. Meyers suggested expanding the list. Kaback said that the authors
recognize that the list is not comprehensive. The intent is to provide a few
key references that direct readers to other sources of information. Attendees
advised adding some statements to the appendix (and/or to the text in the main
part of the document) stating that Appendix C is not meant to be comprehensive,
that the list highlights some key references and Web sites that provide additional
information on technologies, and that the NMDF document is not endorsing one
technology over another. Kathy Yager recommended saying that the Alliance has
determined that there is a need to compile references on different technologies
and that such a list will be posted in the future on the RTDF Web site. This
spurred discussion about the goals that the Alliance has for the NMDF document.
In the group’s early days, Adamski noted, the EPA co-chair—Randy
Breeden—said that the Alliance should offer input on which technologies
worked the best at LNAPL sites. Zabcik verified Adamski’s comments, but
said that the Alliance’s focus has changed since Breeden’s original
statements were made. In later years, Zabcik said, the Alliance agreed to focus
on establishing a decision-making framework first and to use case studies to
provide commentary on the efficacy of specific technologies. While the Alliance
had hoped to include such case studies as a separate appendix to the NMDF document,
Kaback said, it has become clear that case studies will not be ready any time
soon. Zabcik recommended adding a statement in the NMDF document indicating
that case studies will be available through the RTDF Web site in the future.
Meyers reminded the Alliance members that the original intent of the case studies
was to provide examples of sites which have successfully implemented the NMDF
strategy and not to focus on which technology was used.
Attendees decided that the following steps should be taken to move forward
with the development of the NMDF document:
- Complete the internal Alliance review and revise the NMDF document. Kaback
asked Alliance members to submit their written comments on the draft by May
30, 2003. Based on the comments she receives, Kaback said, she will
revise the NMDF document and distribute the revised draft by July 1, 2003.
the revised NMDF document to a broad set of regulatory reviewers. Alliance
members agreed to seek the RTDF’s stamp of approval on the NMDF
document. To obtain this approval, Yager said, EPA representatives must be
comfortable with the NMDF document’s content and be allowed to participate
in a formal review process. Toward this end, the following must be done:
- Generate a list of potential reviewers. Yager said that she has created
a list of EPA representatives who might be interested in reviewing the NMDF
document. Some of the people on the list work at EPA Headquarters, others
work at the EPA laboratories, and some work within the regions (e.g., Regions
4, 5, 6, 8, and 9). In addition, some EPA-sponsored groups, like the Groundwater
Forum, are also included on Yager’s list of potential reviewers. Several
attendees advised including state regulators on the review list. Gaining endorsement
from at least some state representatives, Tavelli said, could help other state
representatives appreciate the value of the NMDF document more fully. Carolyn
Perroni advised including all of the state regulators who have participated
on the Alliance’s Training Workgroup on the list of potential reviewers.
Attendees thought this was a good idea.
- Establish contact with the
reviewers. Yager said that she has contacted about half of the people who
are listed as potential reviewers. She said that
efforts should be made soon to contact the remainder and tell them about the
deliverables that will be sent to them for review.
- Prepare a cover letter for the NMDF. Perroni will prepare a letter
that describes the Alliance’s mission and the products that are in development.
The letter will explain why EPA review is being sought for the NMDF document
and why the RTDF stamp of approval is considered important. The letter will
also mention that the Alliance is preparing a training program, which will
be sent to reviewers in the near future. Perroni will send the letter to EPA’s
Jeff Heimerman, who will work with the Alliance while Yager is away over the
- Send the NMDF document out for review and schedule a conference call
to introduce the document. Yager said that Heimerman will attach the cover
letter that Perroni creates to the NMDF document and send it out to the list
of EPA reviewers. Tavelli said that she would be willing to distribute the
document to the state regulators who have been selected to participate in the
review process. Soon after the NMDF document is sent to reviewers, attendees
agreed, a conference call should be held between the reviewers and the Alliance.
The intent of this call will not be to collect comments, but to let the Alliance
explain why the document has been written and describe the history of the Alliance’s
effort. Call participants agreed that it would be useful for the Alliance’s
EPA co-chair (Christine Lehnertz) to lead the call. Kaback said that she is
also willing to help lead the call and to describe the NMDF document’s
content. (Kremesec and Tavelli said that they could also participate.) Some
attendees discussed conducting an Internet seminar, using EPA’s CLU-IN
site, to present the NMDF document to EPA and state reviewers. These seminars
are formal slide presentations, presented over the Internet, coupled with
conference calls that allow participants to ask questions and get answers
as the presentation
proceeds. Since EPA/TIO hosts these seminars on the CLU-IN site, Yager said
it would not be a problem to use the system.
- Consolidate the comments in preparation
for the Alliance’s
next meeting. Yager said that the reviewers should be given 4 weeks to
submit their comments, and that all comments should be directed to Kaback.
agreed to consolidate the comments.
- Present information about the NMDF document
at an upcoming conference. The 2003 RCRA National meeting is scheduled
to take place in Washington, D.C.,
on August 12–15, 2003. David Zabcik recommended presenting information
about the NMDF document at this meeting. Since many Alliance members are planning
to attend this conference, he said, it might be beneficial to hold a full Alliance
meeting in conjunction with the RCRA National conference. Tavelli expressed
enthusiasm for this idea—many state regulators will attend the RCRA conference,
and some of them might be interested in reviewing and commenting on the NMDF
document. The Alliance members decided that it would be useful to coordinate
the next Alliance meeting with the RCRA conference. Yager said that several
concurrent sessions will take place during the conference, and that Alliance
members could probably reserve a slot for a half-day session if they so desired.
She said that she would ask Karen Tomimatsu whether this is possible and report
her findings to Lyverse, Kremesec, Tavelli, and Zabcik, all of whom offered
to help plan the next NAPL Cleanup Alliance meeting.
THE ALLIANCE’S TRAINING PROGRAM
The RTDF NAPL Cleanup Alliance plans to release a series of training modules
to (1) describe the technical aspects of NAPL distribution and mobility, (2)
correct common misconceptions about NAPL, (3) present a NAPL conceptual model,
and (4) explore NAPL management issues. An Alliance Training Workgroup has
been created to help guide the development of the training program, which will
consist of four modules: Module 1 (The Basics), Module 2 (NAPL Management),
Module 3 (Advanced Topics), and Module 4 (Modeling). For now, the Alliance
is only focusing on Modules 1 and 2.
The Alliance hopes to obtain the RTDF stamp of approval on the training modules.
In order to obtain this stamp, the modules must be subjected to a broad EPA
review. The review process will mirror the process described above for the
Module 1 (The Basics)
Vic Kremesec, BP America, Inc.
David Ariail, EPA, Region 4
EPA Region 4 provided the impetus for Module 1’s development, Kremesec
said, when it asked BP America to develop online training programs on several
topics, including LNAPL behavior. Before moving forth with a full report on
Module 1’s status, Kremesec asked David Ariail to provide a more thorough
description of the training initiatives that Region 4 is undertaking. In response
to this request, Ariail presented an overview of the training programs that
are being developed to support the region’s UST program.
Ariail said that employees who work under the UST program have extensive training
needs. Providing training to all of them is a costly endeavor, especially if
they are expected to travel to training events. To alleviate this problem,
he said, Region 4 is committed to developing a series of online trainings.
Toward this end, the region has pooled resources, hired contractors, and is
working with BP America and university personnel to develop training programs.
In addition, Ariail said, the Region 4 states have created a Region 4 Innovative
Training Workgroup and are working with the Office of Underground Storage Tanks
(OUST) to obtain funding to develop additional training modules. Spurred on
by the Region 4 efforts, he said, OUST has created a UST/LUST National Training
Workgroup and is now evaluating what must be done to implement a national program
to address the training needs of UST/LUST professionals.
Kremesec thanked Ariail for the overview, then resumed his status report on
Module 1’s development. He said that this module has almost been completed:
66 slides have been created, a script has been created, and audio has been
generated for each of the slides. Additional site characterization information
will be incorporated into the training program over the next couple of weeks.
Once completed, the module will be sent to Region 4 and the NAPL Cleanup Alliance
membership. Kremesec said that NAPL Cleanup Alliance members will be asked
to review the module and submit written comments. BP America will revise the
module based on the comments and rerelease the training package. This revised
version will be sent to the broad list of EPA reviewers that Yager has identified
(see the discussion above on the NMDF document).
Module 2 (NAPL Management)
Mark Adamski, BP America, Inc.
Adamski said that Module 2 is being developed to help people understand how
the emergence of new NAPL conceptual models (a topic explored in Module 1)
impacts NAPL management approaches. Module 2 is still in the initial stages
of development. Adamski said that some of the Alliance Training Workgroup’s
industry members prepared a strawman for the module in late 2002. That version,
he said, was viewed as having too strong of an industry bias. In late January
2003, Tavelli agreed to alleviate this problem by revising the strawman to
make it more acceptable from a regulator’s perspective and reorganizing
the training topics to follow the organizational structure presented in the
Alliance’s NMDF document. Tavelli placed her efforts on hold, however,
when she heard that the NMDF document’s outline was still undergoing
revision. Now that a draft of the NMDF document has been completed, Adamski
said, Tavelli should feel free to resume her effort to revise the strawman.
Tavelli agreed to do so; she will come to the next Alliance meeting prepared
to present and discuss the revised version of the Module 2 strawman. Once the
Alliance Training Workgroup agrees on the strawman, Hopkins said, API can ask
one of its consultants to start developing slides for the Module 2 training
Attendees discussed the scope of the Module 2 training package. Adamski and
Hopkins said that they think the training program should provide more detailed
information than the NMDF document does. For example, Hopkins recommended including
detailed information about what people need to do “to get real about
endpoints.” Lyverse asked whether the Module 2 program will include information
about how to address and manage imminent risk at sites. As acknowledged earlier
in the meeting, he said, the NMDF document does not cover this topic. Lyverse
said that the training package’s title—NAPL Management—implies
that the package covers all phases of the NAPL management problem, including
imminent risk management. His statement prompted some attendees to ask whether
the training module should be renamed. Zabcik recommended Implications for
LNAPL Management as one possibility. No decision was made about whether the
title should be changed.
INTRODUCTION TO GROUNDWATER CENTRAL©
Dawn Kaback, CTC
Kaback provided information about Groundwater Central©,
a multi-component portal that links people to information on ground-water science
(The portal can be accessed by visiting http://www.groundwatercentral.info .)
Kaback’s PowerPoint presentation, which is included as Attachment
C (PDF, 1.6MB),
provides detailed information about Groundwater Central©. The
highlights of her presentation are presented here. Kaback said that Groundwater
- A resource database. Groundwater Central©uses a “smart” search
engine to link to records on LNAPL, NAPL, dissolved or vadose zone hydrocarbons,
petroleum oil lubricants (POLs), or oxygenate contaminants or technologies.
At this time, she said, the link database is populated by more than 3,000 records.
Records will continue to be added as time progresses. The “smart” search
engine can search through multiple layers of Web sites to provide direct
links to appropriate information. It is also equipped to perform advanced
and to provide detailed reports of search results.
- A communications center.
The Groundwater Central©Communications
Center currently has four features:
- An events calendar. Information about conferences, field trips, and
request-for-proposal deadlines is posted on the calendar. Although all who
register with Groundwater Central©are allowed to post events on the calendar,
postings have been sparse.
- Discussion forums. Bulletin boards have
been created for seven topics: access, characterization and monitoring, contaminants,
NAPL cleanup, physical
setting, policy, and remediation technologies. All visitors can view information
that has been posted to the bulletin boards, but only registered users can
post new materials.
- The “Ask an Expert” service. Registered
users can send experts anonymous questions on bioremediation, permeable reactive
and thermal-enhanced remediation. Experts are expected to respond to questions
within 2 weeks.
- Chat room. This feature allows users to chat directly with other
users who are logged on to Groundwater Central©at the same time.
Kaback said that Groundwater Central© was officially launched on January
31, 2003. She and Yager asked Alliance members to visit the site and explore
its features. After doing so, Alliance members should submit comments about
the utility of Groundwater Central©and offer recommendations on how to
improve it. Kaback agreed to serve as the repository for the comments and to
forward them to Yager.
Ariail asked whether the ground-water sites to which Groundwater Central©provides
links also link back to Groundwater Central©. Kaback was not sure, but
agreed to find out. Perroni advised sending an email to the webmasters who
manage the sites to which Groundwater Central©links, and asking them
to establish a link to Groundwater Central©. Lyverse asked whether Module
1 of the Alliance training could be made available through the Groundwater
Central©portal. Kaback said that this was possible.
UPDATE FROM THE CASPER REFINERY SUBGROUP
Jeff Hostetler, TriHydro Corporation
Hostetler provided information on behalf of the Casper Refinery Subgroup,
a group that is using the decision-making process advocated in the NMDF document
to develop a long-term NAPL management strategy at a former refinery site that
is owned by ChevronTexaco. Hostetler said that the Subgroup recently completed
a mobility study. The results indicate that 8 million gallons of NAPL are in
the subsurface, and less than 2 percent of that NAPL is mobile and readily
recoverable. Given this finding, Hostetler said, the Subgroup is now reexamining
the goal that it originally set for the site to evaluate whether the goal is
still practical. Now that he has a better understanding of the nature of the
NAPL problem, Hostetler said, he doubts that the goal—to remove enough
NAPL to enable natural processes to return ground-water quality to background
levels or maximum contaminant levels (MCLs) within about 50 years after remedial
engineering processes have been discontinued—is practical. As a result,
the goal may require reformulation. Hostetler said that the Subgroup is currently
working on the following:
- Performing more studies. Additional site investigation activities
will be initiated in the near future. For example, a natural attenuation
study will be performed and NAPL–ground-water partitioning/dissolution,
volatilization, and biodegradation data will be collected. Among other things,
the investigations will be used to evaluate whether certain portions of
the subsurface NAPL pose less risk than others.
- Applying to Wyoming’s
voluntary remediation program (VRP). Once the Casper Refinery site enters
the VRP, Hostetler said, public involvement
will increase and ChevronTexaco will be expected to identify stakeholders who
are deeply interested in the site. While the public has been involved to some
extent already, Hostetler said, the collaborative stakeholder decision-making
process is just now about to go into full swing at the Casper Refinery site.
a Current Conditions report. Hostetler said that ChevronTexaco has
consolidated detailed information about human resources, material resources,
and data into one report. The report is under review and will be finalized
in the near future.
- Developing a remediation agreement. ChevronTexaco is
in the process
of developing a draft preliminary remediation agreement. The Wyoming Department
of Environmental Quality and ChevronTexaco hope to sign a final remediation
agreement by the end of 2005.
- Identifying innovative remediation technologies
to use at the site. Hostetler said that the Subgroup is trying to generate
case studies about the
way innovative technologies have performed at LNAPL sites. To date, he said,
the Subgroup has experienced much difficulty collecting case study information.
Although the Subgroup knows this information exists, it is difficult to extract
technical and cost performance data from the site managers and consultants
who have those data. For this reason, Hostetler said, the Subgroup needs help
from Alliance members in identifying contacts who are willing to provide such
information. Hostetler said that he has generated a 1-page data profile sheet
that lists the information the Subgroup is trying to collect. He will e-mail
it to the Alliance members. He strongly encouraged Alliance members to submit
completed data profile sheets or to submit the names of contacts who could
provide such information. Hostetler said that the case studies might eventually
be posted on an EPA Web site. If people are not comfortable having the information
go public, he said, they do not have to include site names in their data profile
sheets. Hostetler’s request for information spurred discussion about
projects that might make good case studies. The following projects and potential
contacts or resources were identified:
- ConocoPhillips’ water-flooding project. Greg Fletcher agreed
to check with ConocoPhillips’ management to find out whether cost and
performance data from a recent remediation effort could be released to the
Subgroup. He said that he did not think ConocoPhillips would object to releasing
performance data to the Alliance, noting that these data will be reported to
the state in July 2003.
- An expert on bioremediation technologies. Tavelli recommended contacting
an EPA representative who is an expert on bioremediation technologies for input
on potential case studies.
- A trenching project. Westbrook said that trenching was successfully
performed at an active refinery site, and that the experience obtained at this
site might make an interesting case study.
- The CLU-IN Web site. Kaback said that CTC has been examining site
profile information that has been posted on EPA’s CLU-IN site. Kaback
said that she would let Hostetler know whether this information is relevant
to the Subgroup’s data collection effort.
- BP America projects. Kremesec said that he could provide completed
profiles and/or contact names for a biowall project, a bioventing project,
a steam flood project, and a microwave project.
Lyverse asked Hostetler to discuss the long-term vision for the Casper Refinery
site. Hostetler said that this vision can be separated into two components:
- Future land use. The goal is to use the site for light industrial
use and some recreational purposes.
- Groundwater restoration. Wyoming’s
nondegradation policy dictates that remedies focus on eventual reduction
of ground-water contaminants to background
concentrations or MCLs.
UPDATE ON THE EMANUAL PROJECT
Jim Higinbotham, ExxonMobil
Higinbotham provided information about API’s LNAPL eManual, a diverse
set of tools that presents information on a variety of LNAPL topics. He said
that the product, which will be available at no cost to the public, will be
distributed as a CD-ROM. It will include educational information, checklists,
an LNAPL management flowchart, calculation tools, remedial selection tools,
assessment tools, and a broad range of other useful tools, including the most
recent generation of LNAST.
Higinbotham said that the first draft of the eManual product was completed
and presented to API on May 20, 2003. API members have been asked to review
the eManual tool and submit comments by July 18, 2003. The final version of
the product is scheduled for release on January 4, 2004. Once it is released,
training forums will be held to provide additional information on how to use
the eManual product.
As noted above, the Alliance plans to hold its next meeting in conjunction
with the 2003 RCRA National meeting that is scheduled to take place in Washington,
D.C., on August 12–15, 2003. (The NGWA conference that is scheduled to
take place in Costa Mesa, California, on August 20–22, 2003, was chosen
as a potential backup meeting location.) Attendees agreed that the Alliance’s
meeting agenda should include the following topics: (1) EPA’s comments
on the NMDF document, (2) the revised Module 2 strawman, and (3) an update
on the Casper Refinery site.
Lyverse thanked everyone for their participation and said that he thought
the meeting had been productive. He thanked Westbrook, of EPA Region 6, for
hosting the meeting.
Several action items were identified during the meeting:
- In an effort to move forth with the development of the NMDF document:
members will send Kaback comments on the NMDF document by May 30, 2003.
- Tavelli will send Kaback information that can be included in the
NMDF document’s Appendix A: Current Conditions Checklist.
will distribute a list of EPA references that will be included in the NMDF
document. Alliance members will review the list and let Kaback
know of any citations that should be added to it.
- Higinbotham and Hopkins will compare the NMDF flowchart with the
one created for API’s E-manual toolkit. They will look for ways to harmonize
the API flowchart with the NMDF toolkit. If they have any changes to recommend
for the NMDF flowchart, they will submit their suggestions by May 30, 2003.
will revise the NMDF document based on the comments she receives from Alliance
members and redistribute the document by July 1, 2003.
- Yager will e-mail a list of potential reviewers to Alliance members.
Perroni will make sure that the state regulators who participate in the Alliance
Training Workgroup are added to Yager’s list.
- Perroni will prepare a letter that describes the Alliance’s
mission, projects, and products. She will send the letter to Heimerman.
- Heimerman will send the NMDF document out to EPA reviewers with Perroni’s
cover letter attached. (Yager will contact Heimerman to let him know that someone
from the Alliance might be contacting him in July about distributing the NMDF
document.) Tavelli is willing to distribute the NMDF document to state regulators.
- Soon after the NMDF is sent to reviewers, the Alliance will hold
a conference call to explain why the document has been written and describe
the history of the Alliance’s effort. Call participants agreed that it
would be useful for Lehnertz to lead the call. Kaback is also willing to help
lead the call and to describe the NMDF document’s content. (Kremesec
and Tavelli are also willing to participate.) Some attendees discussed conducting
an Internet seminar, using EPA’s CLU-IN site, to present the NMDF to
EPA and state reviewers. Since EPA/TIO hosts these seminars on the CLU-IN site,
Yager said, it would not be a problem to use the system.
- The EPA/state
regulator reviewers will be given 4 weeks to submit their comments. Kaback
agreed to serve as the repository for all of the comments
and to consolidate them.
- Attendees expressed interest in presenting information about the
NMDF document at the 2003 RCRA National meeting that is scheduled to take place
in Washington, D.C., on August 12–15, 2003. Yager said that several
concurrent sessions will take place during the meeting, and that Alliance
probably reserve a slot for a half-day session if they so desired. Yager
will ask Karen Tomimatsu whether this is possible and report her findings
Kremesec, Tavelli, and Zabcik, all of whom offered to help plan the next
NAPL Cleanup Alliance meeting.
- Kremesec agreed to send the most recent version
of the Module 1 training
package to Kaback as soon as he returned to the office. In a few weeks, Kremesec
will send the module out to the entire Alliance for review. Alliance members
will be given about 2 weeks to comment on the module. Once the Alliance is
comfortable with the training program, it will be sent to a broader list
- Tavelli will prepare and distribute a revised version of the
Module 2 outline before the next Alliance meeting. The revisions will be
least in part, on comments received from the Alliance’s Training Workgroup
members. Hay Wilson asked Tavelli to let her and Kaback know whether any of
the Workgroup members’ comments are relevant to the NMDF document. Tavelli
agreed to look through the comments as soon as possible.
- Alliance members will
visit Groundwater Central©(http://www.groundwatercentral.info ),
explore its features, and provide feedback on its utility. Kaback will collect
the comments and send them to Yager.
- Kaback will find out whether the sites
that Groundwater Central©links
to are linking back to the Groundwater Central©page.
will send out blank data profile sheets to Alliance members. (The forms ask
for information on LNAPL cleanup projects.) Alliance members
agreed to help fill out the forms and/or name a contact who might be able to
provide relevant information. In response to Hostetler’s request, Greg
Fletcher agreed to check with ConocoPhillips’ management to find out
whether information about a recently completed waterflood project can be released
to the Alliance and developed into a case study. (He will ask whether cost
data, as well as performance data, may be released.) Also, Kremesec and Westbrook
offered to send Hostetler information and/or contact names.
- Perroni will send
Alliance members an updated list of the Alliance’s
e-mail notification list.
- Yager and Kaback will call Lehnertz and Breeden
to let them know about the major decisions that were made during the Alliance
ATTACHMENTS A through C
Attachments A through C are available on the Internet. To view
these attachments, visit the RTDF home page at http://www.rtdf.org, click
on the “Non-Aqueous
Phase Liquid (NAPL) Cleanup Alliance” button, then click on the “Alliance
Meetings” button. The attachments will be available as part of the May
2003 meeting summary.
Attachment A: Final Attendee List (PDF, 39KB)
Attachment B: Dawn Kaback’s presentation entitled
Decision-Making Framework for Cleanup of Sites Contaminated With LNAPLs (PDF,
Attachment C: Dawn Kaback’s presentation entitled GWRTAC’s
Groundwater Central© (PDF, 1.6MB)