SUMMARY OF THE REMEDIATION TECHNOLOGIES DEVELOPMENT FORUM
NON-AQUEOUS PHASE LIQUID CLEANUP ALLIANCE MEETING
The Westin City Center Dallas
June 17-18, 2004
WELCOME AND OPENING REMARKS
Mark Lyverse, ChevronTexaco Energy Research and Technology Company
Bob Maxey, U.S. Environmental Protection Agency (EPA)
Mark Lyverse and Bob Maxey, co-chairs of the Non-Aqueous Phase Liquid (NAPL) Cleanup Alliance, welcomed attendees (see Attachment A) to the meeting. Lyverse noted that the Alliance is working on three major products: (1) developing a decision-making framework, (2) creating a light non-aqueous phase liquid (LNAPL) training program, and (3) investigating and remediating a ChevronTexaco site in Casper, Wyoming. He and Maxey commended the Alliance members for the progress that has been made on all three fronts over the last 4 or 5 months. Lyverse provided a quick overview of the agenda. He said that some time would be spent discussing the Alliance's decision-making framework and training program, but that the primary purpose of the meeting was to give vendors a chance to deliver presentations on potential remedial strategies for the Casper site.
Lyverse noted that the NAPL Alliance meeting was being held in conjunction with an EPA conference titled Accelerating Site Closeout, Improving Performance, and Reducing Costs Through Optimization (referred to as the Optimization conference). He thanked Dawn Kaback for providing information about the NAPL Cleanup Alliance during one of the Optimization conference sessions.
THE ALLIANCE'S DECISION-MAKING FRAMEWORK
Kaback said that the Alliance's NAPL Management Decision Framework (NMDF) has been completed and sent to EPA Headquarters for final approval. The Agency's Office of Public Affairs has provided comments and the document is now awaiting legal review. Maxey agreed to check on the status of the document and to find out whether anything can be done to expedite the review process. Once EPA completes its review, Kaback will finalize the document so that it can be posted on the RTDF Web site.
Kaback noted that she recently presented information about the NMDF at a couple of different meetings and that attendees appeared interested in the document and eager for its release. She said that the document's release will be timely, noting that the topics it covers (e.g., focusing on process, developing conceptual models, developing end-state visions, and reevaluating goals) are increasingly gaining attention as important factors to consider. (For example, these topics were discussed in detail at the Optimization conference.)
NAPL CASE STUDIES
EPA is spearheading an effort to develop case studies of large NAPL-contaminated sites. The first case study, which was released in draft form to Alliance members in early June 2004, addresses a ChevronTexaco site located in Cincinnati, Ohio. The case study (1) describes the investigation technologies (i.e., PITT and CPT/ROST) that were used to delineate the site and (2) provides detailed information about the evaluation that was performed to determine whether Surfactant Enhanced Aquifer Remediation (SEAR) is a viable technology for the site. Ellen Rubin said that the Agency is eager to receive feedback on the case study; she asked whether anyone had reviewed it yet. John Meyers indicated that he had and offered the following feedback:
EPA is now working on its second case study, which describes the strategy being used to address a large active NAPL-contaminated industrial site in Sugarcreek, Missouri. At the moment, Rubin said, no other sites are in the queue for case study development. The Agency is eager, however, to take on more sites.
THE CASPER REFINERY SUBGROUP
Brian Smith provided a brief status report on behalf of the Casper Refinery Subgroup, a group that is using the process advocated in the NMDF to develop a long-term NAPL management strategy at a former refinery site owned by ChevronTexaco. He said that the group is currently focusing on finalizing the site's NAPL Investigation Report, initiating a NAPL partitioning study, developing an attenuation work plan, and selecting a remediation technology. Expanding on the latter, Smith noted that the Subgroup is searching for a technology that is already commercially available and can perform effectively under the geological and hydrological conditions present at the Casper site. He said that the Subgroup originally identified a broad set of technologies to consider but has narrowed the list down to five: chemical oxidation, surfactant/co-solvent flooding, phased soil resistive heating, hot water flooding, and steam flooding. In an effort to learn more about the capabilities of each, Smith said, the Subgroup is soliciting information from a variety of vendors and listening to what each has to say. He said that three vendors (Surbec Environmental, LLC, Thermal Remediation Services, Inc., and MECX, LLC) would present information about their products during this Alliance meeting and that two more (INTERA and ISOTECH) would travel to Laramie, Wyoming, within the month to deliver additional presentations to the Casper Refinery Subgroup. Smith said that the vendors have been asked to present cost and performance data, discuss technological challenges, and provide specific information about how their products are likely to perform at a site like the Casper Refinery.
With these introductory comments completed, Smith turned the meeting over to the vendors, who delivered the following presentations:
Cartwright and Aboulafia focused the remainder of their presentation on the chemical oxidation (or ChemOx) portion of the remedial process. They noted that MECX has performed more than 250 ChemOx projects across 26 different states. Hydrogen peroxide has been used as the reactive species at the vast majority of these sites, but persulfate has been used on occasion as well. Unlike some of its competitors, Cartwright said, MECX places great emphasis on health and safety issues and reduces risks by doing the following (1) ensuring that its personnel are well trained, (2) introducing the reagent in a sequential fashion, (3) using a low-pressure (siphoning) process, (4) using low peroxide concentrations, (5) instituting proactive field data monitoring, and (6) using in situ thermocouples. Through these measures, Cartwright said, MECX has succeeded in implementing ChemOx at more than 250 sites without incurring any OSHA-reportable incidents. The speakers presented case studies and described the process that MECX uses to implement projects. (See Attachment D for details). At the end of the presentation, Cartwright presented a cost estimate for the Casper site. He estimated that it would cost about $160,000 to $190,000 to implement ChemOx across a ¾-acre test site at Casper. If the project were to be implemented full scale, the cost might be about $14 million, he saida 33 percent economy of scale.
THE ALLIANCE'S TRAINING PROGRAM
The RTDF NAPL Cleanup Alliance is developing a series of training modules that describe the technical aspects of NAPL distribution and mobility, correct common misconceptions about NAPL, and explore NAPL management issues. To date, Alliance members have started developing the first two modules of the training program. An update on their status was presented during the meeting.
Module 1 (The Basics)
In early April 2004, a draft version of Module 1 was completed and distributed for review to Alliance members and about 50 EPA representatives and state regulators. Some of those who received the module did indeed review it and submit comments. On the whole, Kathy Yager said, it appears that the training was well received, as is evidenced by the fact that none of the commenters expressed any major problems with the concepts presented in Module 1. Carolyn Perroni, who was called upon to incorporate the comments, asked John Meyers and Vic Kremesec to assist her in the effort. In most cases, Perroni said, the information that Kremesec and Meyers provided gave her what she needed to address the comments. She still needs guidance, however, on how to address the following issues:
Perroni thanked the group for their input and said that she will make the necessary changes to Module 1. The module will also be expanded to include a case study that Lyverse is providing. Once these modifications are made, Module 1 will be a 2.5-hour-long training session. Perroni said that she hopes to have Module 1 revised and redistributed by the end of July 2004. Yager asked Perroni to make sure that a disclaimer is included in the revised version. Once the revised version of Module 1 is available, Yager said, she will ask EPA's Office of General Counsel to look at it.
Attendees agreed that Module 1 should be posted on the Internet so that people can access the training materials remotely. At a minimum, attendees said, it should be posted on the RTDF Web site. David Zabcik recommended posting it on EPA's RCRA Corrective Action Web site as well. Maxey said that he was willing to ask whether this was possible, but warned that the request might not be granted since the training was not widely reviewed by RCRA staff. Ali Tavelli recommended asking EPA's Web master to list Module 1 under the "What's New?" section of EPA's main Web site. Yager and Maxey said that obtaining a prominent position on the EPA Web site might be difficult since Module 1 is not being released as a formal EPA document.
In addition to posting the training on the Internet, Alliance members agreed, it is important to schedule live deliveries. Two live deliveries have already been scheduled:
In addition, the following were identified as possible venues for live deliveries of the Module 1 training: Corrective Action meetings, Forums meetings, Petroleum meetings, and Interstate Technology Regulatory Council (ITRC) meetings. Details about the steps that Alliance members will take to secure spots on the agendas of these meetings are included under the "Action Items" section of the document.
Attendees also agreed that it would be useful to hold an Internet seminar. Perroni said that she would try to reserve a spot for Module 1 on the fall 2004 agenda of the Clu-in Live Training program. If Module 1 is to be presented in that forum, Yager said, the training materials must be shortened.
Module 2 (NAPL Management)
Hopkins said that a work group has formed to develop Module 2 of the Alliance's training program, the goal of which is to help people understand how the emergence of new technical information regarding NAPL behavior and characteristics could impact NAPL management approaches. Tavelli said that the module will be written so that it is broad enough to apply to any site, no matter what regulatory structure the site is operating under. She also noted that Module 2 will reflect the ideas that are presented in the NMDF. Hopkins said that Module 2, which will target managers and other high-level decision-makers, will be shorter than Module 1 and will have a less technical tone. It will not advocate any particular technology.
The work group has developed a draft version of Module 2 and is now reviewing it. (The draft incorporates concepts from an outline that Tavelli developed, a PowerPoint presentation on the Texas Risk Reduction Program that Chet Clarke developed, and materials created by Tom Sale.) Hopkins said that the group plans to hold a conference call within the next couple of weeks to determine whether Module 2 has the right tone.
ATTRACTING ADDITIONAL REGULATORS
Yager said that it is important to encourage more federal and state regulators to participate in the NAPL Cleanup Alliance. In fact, she said, her management is puzzled by the fact that there are not more participating already. Citing limited travel funds as a possible explanation, Yager asked whether API would be willing to pick up travel expenses for state regulators if this would help diversify the attendee list at NAPL Cleanup Alliance meetings. Hopkins said that he would look into this possibility. Maxey noted that the regulators from Wyoming (Jerry Breed and Ali Tavelli) participate in the Alliance because the Casper Refinery site is located in their state. Perhaps regulators from other states would become involved, Maxey posited, if they too had sites that were being addressed under the Alliance's umbrella.
FUTURE NAPL ALLIANCE PROJECTS
Attendees agreed that the Alliance's three main projects (i.e., the NMDF, the LNAPL training program, and the Casper site project) are well underway. Therefore, in order to justify the Alliance's continued existence, Yager said, it is time to start thinking about initiating some new projects. Toward this end, the attendees partook in a brainstorming session and identified several potential projects:
Address Additional NAPL-Contaminated Sites Under the Alliance's Umbrella
The Casper Refinery is using the concepts outlined in the NMDF to develop a long-term NAPL management strategy. Several attendees expressed interest in pulling more sites into the Alliance and forming new subgroups to address each of the new sites. Involving multiple sites, they agreed, would help the Alliance test the utility of the NMDF in the field. Tavelli, Breed, Smith, and Meyersall of whom are members of the Casper Refinery Subgroupsaid that they have benefitted from participating in the Alliance and they encouraged other site managers to follow the same path. By addressing the Casper Refinery site under the Alliance's umbrella, Breed and Tavelli said, they have been able to access a broad array of expertise, tap into a consensus-building decision-making paradigm, and push activities forward at a quicker pace.
Although the Alliance would be willing to work on any applicable NAPL-contaminated site, Maxey said, it would be particularly beneficial to work on a site that differs from the Casper site either in geology, NAPL characteristics, regional location, or receptors. Martin Johnson asked Alliance members to create a list of the characteristics they are looking for in a test site. Doing so, he said, will allow companies that own a number of NAPL-contaminated sites to determine which are the most appropriate to offer up as test sites. For starters, Tavelli said, when choosing a test site, a company should hone in on those that have been stabilized, have no imminent threat, and have already met their Environmental Indicators. Lyverse said that the size of the site should also be a screening factor: the Alliance is primarily interested in large-scale sites. In response to his statement, however, some attendees questioned whether it would be wise to expand the net and include smaller sites, such as underground storage tank sites and terminal sites. No final decision was made on how far to expand the scope.
One meeting attendee said that BP and Suncor (formerly ConocoPhillips) might own some sites that would be good candidates for inclusion in the Alliance. In fact, representatives from both companies once initiated efforts to identify potential test sites. These efforts were put on hold, however, because there were so many other Alliance-related activities that required attention. Now that the Alliance's projects are well underway, the attendee suggested, perhaps it is time for these companies (as well as others) to reevaluate their repositories of potential test sites. Yager said that it would also be a good idea to research the possibility of using a federal site. She recommended searching through the Navy's site repository and Tavelli advised searching through EPA's Superfund Innovative Technology Evaluation program for candidates. Zabcik said that the site managers who will be the most interested in participating in the Alliance are those whose sites are changing from one usage category to another, or those who are confronted with regulatory drivers that necessitate the development of a long-term NAPL management strategy. Picking up on this point, Hopkins advised looking at brownfields programs to identify sites that are slated for redevelopment and are under pressure to move forth quickly with a NAPL management strategy. Zabcik noted that some states (e.g., California, Florida, and New York) have been told that they must assume responsibility for NAPL-contaminated sites. He advised contacting these states and asking them to volunteer a site to be addressed by the Alliance.
Promote Efforts to Modify Existing State Regulations
Meyers said that he supports the idea of bringing more test sites into the Alliancebut that doing so would keep only the Alliance's site-specific subgroups busy, not the entire RTDF membership. Therefore, Meyers advised taking on a larger group project as well, such as working with states to amend state regulations that are founded upon non-technical premises (e.g., the minimum thickness measurable with an oil/water interface probe) and are not consistent with the current understanding of LNAPL behavior. Three states (Texas, New Jersey, and Pennsylvania) are considering amending, or are in the process of amending, their NAPL cleanup regulations for this reason.
Develop Additional Training Modules
As noted above, the Alliance is working on Modules 1 and 2 of an LNAPL training program. Hopkins reminded attendees that there are two more modules that need to be developed: Module 3 (Advanced Topics) and Module 4 (Modeling). Tavelli said that she thinks it would be useful to start developing these modules. Meyers said that some work has already been performed in this area, noting that information on API tools (e.g., spreadsheets and databases) has been presented in some states. (Meyers said that this training does not lend itself well to a PowerPoint presentation.) In addition, Yager recommended developing a training module that describes the lessons the Alliance has learned about water flooding technologies and the lessons that are being learned at the Casper Refinery site.
Develop a Paper That Discusses Treatment Train Approaches
Tavelli noted that the Casper Refinery group is considering using an aggressive technology to obtain significant mass reduction and then following up with bioremediation. She thought it might be useful to gather and release information about the efficacy of a treatment train approach. Yager said that the Alliance's industry members have experience in this area and that it might be worthwhile to summarize what they have learned.
Explore Resource Optimization
Yager said that several topics were discussed during EPA's Optimization conference. Of particular interest, she said, were presentations that discussed the steps that ChevronTexaco and BP are taking to reduce long-term monitoring costs at their sites. For example, in an effort to reduce costs associated with long-term ground-water monitoring, BP is trying to determine whether there is spatial or temporal redundancy built into its ground-water monitoring plans: Could it take fewer samples without sacrificing the quality of the information collected? Yager said that new statistical tools are available to help answer questions of this nature. She suggested exploring topics related to resource optimization during future Alliance meetings. While this would not serve as a main Alliance project, she said, it might serve as useful filler material. Attendees responded to Yager's suggestion with only lukewarm interest, however.
NEXT ALLIANCE MEETING
Lyverse noted that EPA provides funds to support the RTDF Action Team meetings and that the RTDF leaders have asked all of the Action Teams co-chairs to identify ways to reduce the costs associated with these meetings. One way to accomplish this, Lyverse said, is to hold Alliance meetings in conjunction with conferences that have already been set up. Perroni asked whether the next Alliance meeting should be held in conjunction with the API/NGWA conference that is scheduled to take place in Baltimore in August 2004. Attendees said that they did not think it was necessary to meet again so soon; they preferred to meet in the fall of 2004 instead. Perroni agreed to compile a list of conferences that have already been scheduled for the fall and distribute the list to the Alliance members. If any of the meetings are of interest to the group, she said, arrangements can be made to piggyback an Alliance meeting onto the end or the beginning of the existing meeting.
Attendees identified the following as topics to cover during the next meeting:
Baltimore meeting (August 19, 2004). Lyverse said that he plans to present Module 1 to a group of regulators in Maryland on August 19, 2004. Maxey will check his schedule to determine whether he is available to help Lyverse deliver the presentation.
Internet training. Yager and Perroni agreed to find out whether Module 1 can be presented as an Internet seminar. Perroni will try to reserve a spot for the course on the fall 2004 agenda of the Clu-in Live Training program.
Corrective Action meetings. A Corrective Action meeting is scheduled to take place in the fall of 2004 in Region 3. Yager agreed to find out whether the meeting organizers would be willing to allot time on the agenda for Module 1. Maxey agreed to find out whether other Corrective Action meetings are scheduled to take place in other regions in the near future.
ITRC meetings. Yager agreed to contact ITRC to find out whether Module 1 can be presented at the next ITRC meeting.
Forums meeting. Perroni will find out when the Groundwater, Engineering, and Federal Facilities Forums plan to hold their next meeting and will request to have Module 1 presented at that time.
Petroleum meeting. Breed will contact Tom Aalto (of Region 8) to find out whether another petroleum meeting is scheduled to take place in the future. If so, Breed will try to reserve a slot for Module 1 on the meeting agenda.
Attachments A through D
Attachments A through D are available on the Internet. To view these attachments, visit the RTDF home page at http://www.rtdf.org, click on the "NAPL Cleanup Alliance" button, then click on the "Alliance Meetings" button. The attachments will be available as part of the June 2004 meeting summary.
Attachment A: Final Attendee List (PDF, 43KB)
Attachment B: Surfactant Enhanced Subsurface Remediation for Source Zone Removal (PDF, 2.3MB)
Delivered by Jeffrey Harwell and Benjamin Shiau of Surbec Environmental, LLC
Attachment C: Thermal Technology (PDF, 5.5MB)
Delivered by Greg Beyke of Thermal Remediation Services, Inc.
Attachment D: Bio-Chemical Oxidation Technology (PDF, 3.4MB)
Delivered by Richard Cartwright and Isaac Aboulafia