SUMMARY OF THE REMEDIATION TECHNOLOGIES DEVELOPMENT FORUM
NON-AQUEOUS PHASE LIQUID CLEANUP ALLIANCE MEETING
Holiday Inn Denver Downtown
September 10-11, 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 attendees (see
Attachment A) to the meeting and introduced Bob Maxey to the group. Maxey, who works for the U.S.
Environmental Protection Agency's (EPA's) Office of Solid Waste, has been chosen to serve as the Alliance's
new EPA co-chair. Maxey said that he looks forward to working with Alliance members, supporting their work
products, and encouraging more EPA and state regulators to participate in the Alliance's activities. Tom Aalto,
from EPA Region 8, also received a formal introduction. Kathy Yager welcomed Aalto to the Alliance, and
thanked him for agreeing to facilitate communication between the Alliance and EPA's regional offices.
Lyverse provided background information on the three major projects that Alliance members are currently
working on: (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.
Lyverse said that updates would be provided during the meeting for these three projects. As the discussions
would show, he predicted, much momentum has gathered on all three fronts. He encouraged Alliance members
to maintain this momentum and push forth rapidly to complete the projects.
THE ALLIANCE'S DECISION-MAKING FRAMEWORK
In an effort to help people identify practicable and reasonable approaches for cleanup and long-term
management of LNAPL sites, the NAPL Cleanup Alliance is developing a NAPL Management Decision
Framework (NMDF) document. Dawn Kaback, of Concurrent Technologies Corporation, is preparing the
NMDF document with support from Sage Risk Solutions, Inc., and Paulson & Cooper, Inc.
In May 2003, Kaback distributed the first draft (referred to as Revision 0) of the NMDF document. Alliance
members reviewed and commented on the draft. Some of the comments were submitted via e-mail; others were
delivered over the phone; and some were delivered in person at the Alliance's May 2003 meeting. (See
http://www.rtdf.org/public/napl/minutes/052203/index.htm for a summary of the proceedings.) Kaback and
Lesley Hay Wilson incorporated the comments and released a revised NMDF document (referred to as Revision
1) in July 2003. This version was distributed to Alliance members and to a long list of EPA and state regulatory
reviewers.(1) Comments were due on August 22, 2003.
Reviewing and Resolving the Comments
Discussion led by Dawn Kaback, Concurrent Technologies Corporation; David Zabcik, Shell Oil Products U.S. Company and Motiva Enterprises; and Lesley Hay Wilson, Sage Risk Solutions, Inc.
On September 5, 2003, Hay Wilson distributed an 11-page memorandum listing comments on Revision 1 of the
NMDF document. The memorandum lists comments that Kaback and Hay Wilson thought the Alliance should
be aware of and/or comments that raised controversial issues that should be resolved in front of the full
Alliance membership. Positive comments and accolades were not included in the memorandum; neither were
comments that addressed simple editorial issues. With that introduction completed, Kaback and Hay Wilson
asked attendees to turn their attention to the first 31 comments listed in the memorandum. Attendees did so, and agreed that the following should be done to address the comments:
- Make it clear that the principles advocated in the NMDF document must be implemented within a
regulatory framework. Kaback and Hay Wilson will add text to the Executive Summary section and the
Introduction and Objectives section to make it clear that the NMDF document does not supplant existing
regulatory frameworks. (These modifications will help address the concerns listed in Comments 1, 2, and
11 of the September 5 memorandum.)
- Indicate how a variety of states, rather than just Texas, address NAPL management issues. Page 1 of the
NMDF document highlights the approach Texas uses to set goals and endpoints. One reviewer (see
Comment 3 in the September 5 memorandum) said that Texas' approach is not relevant for states with laws
that prevent the type of flexibility Texas is allowed. Thus, in an effort to balance the document, Ali Tavelli
will send Kaback information about approaches used in one or two other states. (California, New Jersey,
and Wyoming were identified as possibilities.) David Zabcik advised simply describing the approaches, not commenting on which approach is better. Several attendees agreed that it would be counterproductive to criticize NAPL management approaches employed by specific states.
- Clarify the section that discusses stakeholder involvement. While active involvement of a broad group of stakeholders is desirable, it is not required as a prerequisite for initiating the NAPL management decision process. Kaback said that the NMDF document will be revised to make this point clear. With this clarification, she said, readers will not get the impression that the decision-making process has to be halted if a stakeholder fails to show interest in participating. (This will address the concerns listed in Comment 4 of the September 5 memorandum.) Tavelli advised emphasizing, however, that stakeholders should be actively encouraged to participate early in decision-making.
- Provide examples of educational and support resources that would be of use to stakeholders. Attendees
agreed that the NMDF document should mention that a wide variety of resources are available to support
and educate stakeholders. Attendees said that it would be unwise, however, to include a list of the
companies that provide such services. Instead, they agreed, a sentence should simply be added saying that resources can be obtained through EPA, the states, consultants, academic institutions, and lawyers. (This will help address the concerns listed in Comments 7 and 8 of the September 5 memorandum.) Kaback noted that one reviewer asked the authors to provide information on who pays for educational and support services. Attendees agreed that this question could not be answered since payment mechanisms differ from site to site.
- Avoid specifying a timeframe for establishing a long-term vision. One reviewer (see Comment 9 in the
September 5 memorandum) requested information on the length of time it takes to establish a long-term
vision for a site. Some attendees responded by saying that a 1- to 3-year time period was reasonable. Other
attendees thought it was more useful to estimate how many stakeholder meetings (perhaps three) are
required to establish a long-term vision. After much discussion, attendees agreed that it was unproductive to
specify a timeframe since timeframes could vary significantly from site to site. They did agree, however, that it would be useful to say that the timeframe for establishing a long-term vision will be reduced if one uses the consensus-building processes outlined in the NMDF document.
- Refrain from changing the document's title. Kaback noted that some reviewers (see Comments 10 and 18 in
the September 5 memorandum) advised changing the title of the NMDF document. One reviewer thought
the title was too broad, and another recommended changing the word cleanup to management. After much
debate, attendees agreed to leave the title as is. (They agreed that the footnote on page 1 of the NMDF
document reduces the scope, and that it is acceptable to use the word cleanup in the title since the document clearly states that active cleanup technologies are encompassed in LNAPL management options.)
- Modify the list of references. The NMDF document's reference section includes many publications listed
under the American Petroleum Institute (API). Attendees agreed that these references should be listed under
individual author names rather than the API organizational heading. Kaback asked Yager to identify
additional EPA references for the document. Hay Wilson said that she would send Yager the most updated
version of the reference list. In turn, Yager will send this list out to EPA representatives and ask them to let her know whether important EPA references are missing. (Yager's efforts will help address the concerns listed in Comment 12 of the September 5 memorandum.)
- Expand the discussion on LNAPL mobility to make it clear that poor design and/or substandard operation
and maintenance (O&M) activities can result in poor NAPL recovery rates. Kaback and Hay Wilson will
revise the NMDF document to make it clear that the decision-making process advocated in the document is
designed to ensure that the remedial systems that are chosen are robust enough to prevent design problems
and O&M pitfalls. Nevertheless, Kaback said, it is important to acknowledge the problems that can result from poor design, since substandard systems could be inherited at a site. (This will help address the concerns listed in Comment 14 of the September 5 memorandum.)
- Indicate that some aggressive technologies have the potential to reduce LNAPL management timeframes.
The NMDF document identifies nine principles for LNAPL management. Kaback and Hay Wilson agreed
to change the wording in item #5 to make it clear that LNAPL may (rather than will) need to be managed for an extended period of time. They will also add a tenth principle that says: In some instances, management timeframes can be reduced through the use of aggressive technologies. (These modifications will help address the concerns listed in Comment 15 of the September 5 memorandum.)
- State that changes to the hydrologic system can cause changes to subsurface LNAPL conditions. One
reviewer (see Comment 16 in the September 5 memorandum) noted that small changes in the hydrologic
system can cause changes in the ground-water table. John Meyers objected to this statement, saying that it
would take major (not minor) forces to induce changes. Moving past the controversy of the major versus
minor issue, Lyverse said that it is important to address the reviewer's concern and acknowledge that
hydrologic changes can alter subsurface conditions. He said that it would be unwise, however, to use
extreme eventssuch as a 100-year floodas a driver for choosing a remediation strategy. Kaback said
that she and Hay Wilson would summarize the points that attendees brought up in relation to the reviewer's points. Once they develop some new text, they will distribute it to Meyers, Lyverse, and Mark Adamski for review, and then add it to the NMDF document.
- Make it clear that the contingency plan is the safety net for remediation and/or containment effort failures. Hay Wilson said that the NMDF document will note that any type of system can fail and that contingency plans exist to address this reality. (This will address Comment 17 of the September 5 memorandum.)
- Modify Table 3. Kaback said that she and Hay Wilson will develop
better examples for "Table 3Examples of Typical Goals." (This will address
Comments 19, 20, and 21.)
- Make it clear that the document does not lock agencies into a final objective. One reviewer (see Comment
22 of the September 5 memorandum) said that agencies might not want to lock into a long-term vision
immediately, especially in cases where a refinery is still operational. Attendees agreed that the document does not, and should not, lock agencies into such an arrangement.
- Make it clear that NAPL management issues are not the only concern that must be addressed at sites.
Kaback said that one reviewer (see Comment 23 of the September 5 memorandum) noted that non-NAPL
contaminants such as lead are often present at refinery sites. Kaback said that the document will
acknowledge the importance of addressing such contaminants, but will make it clear that consideration of them lies outside the scope of the NMDF document.
- Indicate that the innovative approach advocated in the NMDF document establishes visions that can be
attained within a realistic timeframe and a reasonable budget, while protecting the environment and
meeting regulatory requirements. Hay Wilson advised adding information about environmental protection
and regulatory requirements in an effort to balance the statements that are made about realistic timeframes and reasonable budgets. She thought this would help address the concerns listed in Comment 24 of the September 5 memorandum.
- No additional discussion is needed about the role statistical evaluations play in establishing endpoints.
Kaback noted that one reviewer (see Comment 25 of the September 5 memorandum) advised including
more information about the benefits of performing statistical analysis to establish endpoints. Attendees agreed that such an addition was not necessary.
- Acknowledge that there are uncertainties associated with predicting how long it will take to reach cleanup endpoints. Hay Wilson said that she will see what page 7.2 of EPA's Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action says about uncertainties. If the information fits well with the NMDF document, she will reference the EPA document in the NMDF document. (This will help address the concerns listed in Comment 26 of the September 5 memorandum.)
- Address the importance of financial insurance. Long-term financial obligations are discussed in the Introduction and Objectives section of the NMDF document. Hay Wilson said that a statement will be added to emphasize the importance of establishing mechanisms to ensure that financial commitments will be met far into the future. (This will help address the concerns listed in Comment 27 of the September 5 memorandum.)
- Make changes to the flowchart. Figure 1 of the NMDF document is a flowchart that depicts the major steps
of the NAPL management decision-making process. Many comments (see Comments 28 and 29 under the
"Comments to Discuss" section of the September 5 memorandum and Comments 1 through 5 under the
"Comments on the Flowchart" section) were submitted on the flowchart. Attendees discussed the comments
and decided to include two, rather than one, flowcharts in the document. They agreed that a simple high-level flowchart should be included in the Executive Summary of the NMDF document to meet the needs of
managers. In addition, a more detailed version of the flowchart should be included in the Introduction and
Objectives section of the NMDF document to meet the needs of engineers. The latter flowchart, which was
referred to as the Engineering Flowchart for the rest of the discussion, should be a modified version of the
flowchart that currently appears as Figure 1 in the NMDF document. Even though the Engineering
Flowchart will be very detailed, Maxey said, it will not capture all of the pathways discussed in the NMDF
document. Thus, the text introducing the Engineering Flowchart should clearly state that the figure captures
the most common decision-making pathways, but that there are site-specific nuances that cannot be
captured. Attendees agreed that the following changes should be made to the Engineering Flowchart: (1)
add more lines coming out of the "Implement Contingency Plan" box; (2) add a "Confirmation Monitoring"
box after the "Have endpoints been achieved?" diamond; (3) change the diamond that reads "Has the long-term vision been achieved?" to "Has the goal been achieved?"; (4) add another diamond before the "End Process" box that asks "Was this a final goal?"; and (5) send the reader back to the "Develop Long-Term Vision and Goals" box if the answer to the last diamond is "no."
- Make it clear that a written "LNAPL management plan" is not always needed. Section 3.6 of the NMDF
document, said Meyers, leads readers to believe that they must record management decisions in a formal
LNAPL management plan. Attendees agreed that a written plan is not always necessary. Kaback said that
the text will be modified to make this point clear. Zabcik advised eliminating the heading for Section 3.6 and simply incorporating the important points addressed in Section 3.6 under Section 3.5. (These
modifications will help address the concerns listed in Comment 30 of the September 5 memorandum.)
- Indicate that it would be ideal to pursue just one goal at a time at a site. In Section 3.4 of the NMDF
document, Meyers said, the authors should make it clear that only one goal should be pursued at a time.
Some attendees thought Meyer's proposed change was too prescriptive. Tavelli advised saying that the
ideal is to pursue one goal at a time, but acknowledging that some people might choose to pursue multiple goals per site simultaneously. Kaback and Hay Wilson agreed to modify the language. (This will help address the concerns listed in Comment 31 of the September 5 memorandum.)
- Obtain clarification on some of the comments. Some of the comments (see Comments 5 and 13) included in
the September 5 memorandum were a bit ambiguous. In an effort to address Comment 5, Tavelli agreed to
ask Carl Anderson (from Wyoming Department of Environmental Quality) for clarification about his
concern that the NMDF document marginalizes certain stakeholder groups. (Tavelli will ask Anderson to
recommend some text to correct the problem.) In addition, in an effort to address Comment 13, Yager and
Maxey will contact Hal White (from EPA's Office of Underground Storage Tanks) to discuss his concerns
about industry's role in establishing cleanup goals.
Path Forward for the NMDF Document
Attendees agreed that it is critical to release the NMDF document to the public as soon as possible. They agreed that the following steps should be taken toward this goal:
- Give key reviewers one last chance to submit comments on the Revision
1 version of the NMDF document. Comments on Revision 1 were due on August
22, 2003. Although the deadline has passed, Yager said that she would like
to give the Groundwater Forum a final chance to submit comments. She agreed
to inform Forum representatives that they must submit comments within a couple
of weeks if they want to offer input on the document. She will also talk to
her bossWalter Kovalickto find out if anyone else from EPA should
be encouraged to provide comments.
- Create the next version of the NMDF document and prepare and distribute a formal "Response to
Comments." Alliance members asked Kaback and Hay Wilson to prepare the next version of the NMDF
document. As part of this effort, Yager said, a formal "Response to Comments" needs to be prepared to
explain how and why the Alliance incorporated (or chose not to incorporate) each comment. No deadline
was set for these tasks because Kaback and Hay Wilson are not yet funded to perform these activities.
Yager agreed to talk to Kaback and Harley Hopkins offline about funding issues.
- Send the next version of the NMDF document to Alliance Core Team members for a quick review, address
any last-minute comments, and post the document on the RTDF Web site. Once the next version of the
NMDF document is completed, Kaback and Hay Wilson will distribute it to the Alliance Core Team
members, who will be given two working days to indicate whether the document is ready for final EPA
approval. If no objections or concerns are voiced, the document will be ushered into the final EPA approval
process. If any issues are flagged, Kaback and Hay Wilson will set up a conference call to resolve them and make the necessary revisions before submitting the document for final EPA approval. When the document reaches this stage, attendees agreed, it should be formatted and posted on the RTDF Web site as a draft document.
- Find out what steps are involved with EPA's final approval process. The NMDF document will be published through the Office of Superfund Remediation and Technology Innovation (OSRTI). Yager agreed to find out exactly what steps need to be taken to finalize and publish the document. For example, she will contact the Office of General Counsel to inquire about its procedures for signing off on documents.
- Issue the final document. Once the NMDF document goes through EPA's final approval process, it will be formally released to the public as a document that has the RTDF stamp of approval.
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. There will be four of these modules: Module 1 (The Basics), Module 2 (NAPL
Management), Module 3 (Advanced Topics), and Module 4 (Modeling). Modules 1 and 2 have already been
started. Alliance members provided an update on those modules, discussed their end vision for them, and
identified the steps that need to be taken to reach this vision. They agreed on the following:
- Modules 1 and 2 should have the RTDF stamp of approval. In order to obtain this stamp, the modules must be reviewed and accepted by Alliance members and then subjected to a broad EPA review.
- A variety of forums should be used to present the modules. Yager advised formulating a training delivery
plan, noting that it would be useful to start thinking about how and where the training will be delivered
before sending the modules to a broad list of EPA reviewers. Attendees agreed that efforts should be made
to reach a wide audience and that it would be a good idea to make the training accessible through a variety
of forums. If possible, the modules should be delivered face-to-face in a meeting setting with a live
audience and live speakers. (To avoid bias, speaking responsibilities should be shared between
representatives from EPA and industry.) In addition, the training should be made available as a self-paced
narrated PowerPoint presentation that trainees can walk through from the comfort of their own desks. Also,
attendees agreed, effort should be made to hold special Internet training seminars (in which an expert
delivers the presentation over the phone while trainees view PowerPoint slides on their computers) and to advertize these sessions through TechDirect. Once the modules are further along in development, Maxey said, he would be willing to work with EPA representatives to identify appropriate forums for the training.
Module 1 (The Basics)
Adamski provided an update on Module 1's status. He opened by saying that Vic Kremesec and Barbara
Padlotwo BP America representatives who have played a major role in developing the trainingdistributed a
draft of Module 1 to Alliance members and state regulators early this summer. Adamski provided an overview
of the comments received. Some reviewers recommended providing more discussion about who the training is
intended for, what it is supposed to accomplish, and how it should be applied. Other reviewers advised
removing prescriptive language, eliminating the "BP America" tone, modifying the technical content, and
injecting more flexibility into the training module. Meyers gave an example of what was meant by the latter:
rather than endorsing one type of investigation methodology, the training should list a variety of options and
leave it to individual analysts to determine which is most appropriate for a given site.
Adamski said that Padlo and Kremesec are committed to furthering the development of Module 1 and are
willing to revise Module 1 and release the new draft to a broad list of EPA reviewers. Tavelli expressed concern
about proceeding so rapidly, indicating that she did not think that Module 1 had obtained the Alliance's
endorsement yet. Without buy-in from the Alliance, she said, the draft is not ready to go out for broad EPA
review. She said that Alliance members need to be given another chance to review the Module 1 draft. Adamski
responded by saying that Alliance members have already had several chances to review the draft document, but
few have embraced the opportunity. For example, he said, of the long list of people who received the draft this
summer, only five people submitted comments. Carolyn Perroni and Tavelli said that the lack of response could
reflect miscommunication. Tavelli had thought that Kremesec and Padlo were developing two versions of
Module 1one version as an EPA Region 4 product (which is due soon) and one version as an RTDF product.
She thought that the draft that had been distributed earlier this summer was the Region 4 product. If others were
under the same impression, she said, they may not have bothered to review the training module with an eye
toward its acceptability as an RTDF product. Adamski said that BP America is just working on one version of
the training. Thus, the version that was distributed this summer should have been reviewed as a potential RTDF
product. With this confusion put to rest, attendees identified a path forward for Module 1's development and
agreed that the following steps should be taken:
- Distribute the draft of Module 1 and the comments received thus far to the Alliance Core Team. Perroni
agreed to load the draft version of Module 1, which consists of more than 80 slides, onto an FTP site and to
send an e-mail to Alliance Core Team members with directions on how to access the file. Padlo will e-mail
Perroni all the comments that BP America has received thus far. Perroni will consolidate the comments into one file and e-mail them to Alliance Core Team members.
- Ask the Alliance Core Team to review the document. Tavelli stressed how important it is for the Alliance's
Core Team to give Module 1 a proper airing. She advised people to go through the training in its entirety and to comment on its organization, tone, usability, content, and acceptability as an RTDF product.
- Give the Alliance Core Team until October 7, 2003, to submit comments, and then discuss and resolve the
comments during a conference call. ERG will schedule a conference call for 11:00 Eastern Time on
October 7, 2003. (The lines will be open until 4:00 Eastern Time.) Padlo and the Alliance Core Team will
participate in the call. Alliance Core Team members will submit their comments on Module 1 during that
call. As an alternative, they will e-mail their comments to Chris Hartnett (firstname.lastname@example.org) before October 7, 2003. Hartnett will distribute the comments that she receives to the Alliance Core Team.
- Prepare a revised version of Module 1, send it to the Alliance Core Team for a quick-review, and address
any last-minute comments. Padlo and Kremesec will incorporate comments and release a revised version of
the Module 1 training program by October 31, 2003. This will be sent to the Alliance Core Team members,
who will be given 2 working days to indicate whether any additional modifications are required. If no
objections are voiced, the module will be sent out to a broad list of EPA reviewers.
- Give EPA reviewers 3 or 4 weeks to submit comments, and offer to provide additional background
information to the reviewers via conference call.
- Compile the reviewers' comments, distribute them to Alliance Core Team members, and schedule a
conference call (or a meeting) to resolve the comments.
- Finalize Module 1. As part of this step, Yager said, sophisticated graphics and animation should be added to the training program. EMS might be called upon to assist with this effort.
Module 2 (NAPL Management)
Tavelli provided background information on Module 2's evolution. She said that the intent of Module 2 is to
help people understand how the emergence of new technical information about NAPL behavior and
characteristics might impact NAPL management approaches. Late in 2003, industry members drafted an outline
for Module 2 and presented it to state regulators. Although the outline contained useful information, Tavelli
said, some people in the regulatory communityherself includedobjected to its tone and some of its
statements. Thus, it was agreed that Tavelli should revise the outline based on the state regulators' comments.
Tavelli completed this task in early August 2003 and distributed the revised outline to the Alliance Core Team.
Tavelli said that some topics have been reordered and that she has revised the text to make it clear that all
involved parties, not just the regulatory community, need to expand the way they think about NAPL
management issues. Tavelli asked attendees for feedback on the revised outline.
Attendees complemented Tavelli on a job well done, and advised her to highlight the following in the Module 2 training program:
- Case studies. Several attendees recommended including real-world examples in the training manual. Four
NAPL-contaminated sites were identified as potential candidates for case study: Sugarcreek, the
ConocoPhillips site, BP Casper, and ChevronTexaco Casper. Attendees agreed that it would be useful to
describe the decision-making processes that were used, highlight the site characterization studies that were
performed, discuss the negotiation processes that occurred, and highlight any creative solutions (e.g., tradeoffs) that emerged from these discussions.
- Discussions about goals and reasonable endpoints.
- The NMDF document. Kaback advised weaving in the main points that appear in the NMDF document.
- Information about when it is appropriate to use aggressive technologies. In some instances, Adamski said,
it may be better to address a site using an economical conventional technology rather than an expensive
aggressive technology. He said that Chet Clark has created a table that might help regulators balance risks
and resources. The table helps answer the following questions: In a world of finite resources, where should you concentrate your efforts? Is it possible to prioritize sites and the rigor that is needed to address them?
Attendees agreed that Tavelli's outline is a good launching pad for Module 2, and they encouraged her to move
forward with the training program's development. Tavelli agreed to take the lead on this effort and identified the following as steps that need to be taken:
- Form a workgroup. Tavelli agreed to convene a workgroup consisting of herself, Maxey, Zabcik, Adamski,
Lyverse, and Hopkins. She also hopes to recruit two state regulators to the group. She said that Chet Clark
(of the Texas Commission on Environmental Quality) would be an excellent choice. Bruce Stuart (of the
Missouri Department of Natural Resources) and Frank Dellechaie (of the California Environmental
Protection Agency) were also recommended as possible workgroup members. Tavelli asked whether OSRTI
could provide funding for the state regulators to travel to future NAPL Cleanup Alliance meetings. Yager agreed to look into this possibility.
- Develop a complete draft of the Module 2 training program and distribute it to the Alliance's Core Team
for review. Once she convenes the workgroup, Tavelli will ask its members to establish a schedule for
Module 2's development. Ideally, she said, the group will strive to complete and distribute a set of slides and speaker notes in January 2004. Hopkins said that he has already converted Tavelli's outline into some rough slides; he offered this as a starting point for the training program's development.
REPORT ON THE RCRA NATIONAL MEETING PRESENTATION
Harley Hopkins, API
In August 2003, Hopkins delivered a presentation on the Alliance's behalf at a RCRA National meeting that took place in Washington, D.C. Lyverse thanked Hopkins for doing this and asked him for information on how the audience received the presentation.
First, Hopkins thanked Kaback, Lyverse, Jeff Hostetler, and Brian Smith for the roles they played in putting
together the PowerPoint presentation. The presentation, he said, was designed to inform people about the
Alliance and to generate interest in the Alliance's projects. Although the talk was not well attended, Hopkins
said, those who did attend appeared to be interested in what he had to say, as was evidenced by the fact that all
10 of the audience members returned to hear the end of his talk after a fire drill interrupted the presentation.
Hopkins talked to some state regulators after the presentation and collected their business cards. One gentleman approached him to ask whether the Alliance has tried partnering with the Interstate Technology and Regulatory Council (ITRC). Hopkins informed the gentleman that the Alliance had communicated with the ITRC in the past.
STATUS OF API'S LNAPL EMANUAL PROJECT
Harley Hopkins, API
API is in the process of developing an eMANUAL, a product that contains information on a variety of LNAPL
topics. The eMANUAL will include educational information, checklists, an LNAPL management flowchart,
calculation tools, remedial selection tools, and assessment tools. Hopkins said that he was not sure when the
product would be released. He originally hoped to release a beta version in January 2004, but it is unclear
whether this deadline will be met. Hopkins said that a schedule for the product's development will be
established during an upcoming Task Force meeting.
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 owned by ChevronTexaco. Hostetler presented the NMDF's flowchart to the group,
pointing to the two boxes where the Casper Refinery Subgroup is currently focusing its efforts: (1) Are the
goals still practicable? and (2) Identify, evaluate, and select management options. During past meetings,
Hostetler said, the Casper Refinery Subgroup has used GITEI an approach that identifies the steps for NAPL
management as Goals, Investigation, Technology, Endpoints, and Implementationto structure its update
reports. Therefore, he used the GITEI paradigm to structure his update during this meeting as well.
- Goals. Hostetler said that the Subgroup originally set the following as a goal for the site: remove enough
NAPL to enable natural processes to return ground-water quality to background levels or maximum
contaminant levels (MCLs) within about 50 years of discontinuing active remedial engineering processes.
After setting this goal, the Subgroup performed additional investigations and found that there are 8 million
gallons of NAPL in the subsurface, and less than 2 percent of that NAPL is mobile and readily recoverable.
Given this finding, the Subgroup is now reexamining the original goal. Hostetler said that the goal should
be SMART (Specific, Measurable, Achievable, Results-oriented, and Time-bound) and that, in
reformulating the goal, the Subgroup should identify a technology that will significantly reduce risk and site-care requirements and achieve significant progress toward resource restoration.
- Investigation. Within the year, Hostetler said, the Subgroup plans to perform additional investigations (e.g.,
biodegradation studies, partitioning studies, and NAPL chemistry studies) at the ChevronTexaco site. The
purpose behind these investigations is twofold: provide information about subsurface NAPL and provide
information that the Wyoming Department of Environmental Quality needs for the site's Risk Assessment
and Corrective Measures Study. Efforts are being made to streamline the data collection process to meet
these two informational needs.
- Technology. Hostetler said that the Subgroup is currently focusing much of its effort on selecting a remediation technology for the ChevronTexaco site. A five-step process is being used to accomplish this task:
- Step #1: Identify a long list of aggressive/innovative NAPL remediation technologies for consideration.
Hostetler said that the Subgroup split technologies into two categories: thermal technologies (e.g., six-phase electrical heating, steam injection/flooding, hot water flooding, radio-frequency heating, and
microwave-frequency heating) and non-thermal technologies (e.g., cold water flooding, in situ flushing, chemical oxidation, electrokinetics, and ultrasound enhancement).
- Step #2: Screen the long list of aggressive/innovative technologies, eliminate some, and develop a short
list of technologies to consider. Hostetler said that the Subgroup is currently engaged in Step #2 of the
technology-selection process. He discussed the resources that the Subgroup is using to collect
information on the technologies. First, he said, the Subgroup is reviewing information that is available
through EPA's Groundwater Remediation Technologies Analysis Center Database, RTDF NAPL
Cleanup Alliance members, the literature, and the Internet. In addition, the Subgroup has distributed a
technology profile questionnaire, interviewed people, and started compiling case study documentation.
Hostetler said that it has been surprisingly difficult to obtain information. For example, although the
technology profile questionnaire was sent to about 40 people, very few people have filled out and
returned the questionnaire. The distribution of the technology profile questionnaire did, however,
generate some discussion on thermal technologies. For example, Jim Cummings and Eva Davis (both
from EPA) contacted Hostetler to promote thermal technologies. Hostetler said that Cummings knew
that thermal technologies are often ruled out because of their cost. According to Cummings, however,
efforts are underway to make thermal technologies more cost-competitive with other technologies. In an
effort to screen technologies for their utility at the ChevronTexaco site, Hostetler said, the Subgroup is
asking the following questions: Is the technology well-suited to mass removal and/or mass
transformation? Is the technology commercially available? Hostetler said that the Subgroup defines
commercially available as meaning that the design and deployment requirements for the technolog(ies)
are well understood from a scientific and engineering perspective and are readily available through
- Step #3 (Conceptual Design and Cost Estimates/Pilot List), Step #4 (Pilot Design, Deployment, and Evaluation), and Step #5 (Final Selection or Reevaluate). The Subgroup has not reached these steps yet.
- Endpoints. The Subgroup is not currently focusing its efforts on this step in the GITEI process.
- Implementation. The Subgroup is not currently focusing its efforts on this step in the GITEI process.
Attendees expressed support for the five-step methodology that the Casper Refinery Subgroup is using to select
remedial technologies. Some attendees recommended releasing information about the five-step methodology to
the public now and releasing information about the Subgroup's findings in real time. For example, Hay Wilson
advised posting a diary on the RTDF Web site that tracks the Subgroup's progress and activities. Members of
the Casper Refinery Subgroup were not enthused by this idea; Hostetler and Meyers advised simply letting
people know that information about the technology-selection process will be released as a case study in the
future. When the results from the Subgroup's site investigation study are released, Meyers said, the Subgroup should advise the public to stay tuned for the results of the technology-selection effort.
Before closing on the topic of technology selection, Maxey commented on the Subgroup's decision to rule out
technologies that are not commercially available. If the Subgroup is unwilling to test research-and-development-phase technologies, Maxey asked, who will? Hostetler said that the Subgroup has indicated that it
is willing to make the ChevronTexaco site available to vendors who are interested in piloting cutting-edge
technologies, as long as the vendor is willing to pay for a significant amount of the pilot study. No one has embraced the Subgroup's offer. Don Cunningham said that other programs exist to support small companies that have innovative technologies to pilot. For example, he said, the Navy facilitates this type of research.
FUTURE ALLIANCE MEETINGS
Attendees started making plans for their next two meetings. They agreed to hold an Alliance meeting in late
January 2004, possibly in Baltimore, Maryland, or Washington D.C. They also agreed that it would be
beneficial to reserve a half-day time slot for the Alliance on the agenda of an upcoming RCRA Corrective
Action conference. This conference, which will be held in spring or summer 2004, might take place in Miami,
Florida, or Atlanta, Georgia. It would be the perfect forum, attendees agreed, to roll out the Alliance's NMDF
document, the Module 1 training program, and the draft version of the Module 2 program. Aalto said that he has
been asked to help plan the RCRA Corrective Action meeting. Thus, he will keep Alliance members informed
about the status of that meeting, and will let them know what they need to do to reserve a slot on the agenda.
Before ending the meeting, attendees discussed the following topics:
- Lyverse asked Yager for an update on OSRTI's effort to examine aggressive technologies. Yager said that two reports have been written on the topic and they are awaiting review. Once the reports are finalized, Yager will distribute them to Alliance members.
- Cunningham said that the Navy has compiled information on dense non-aqueous phase liquid (DNAPL)
source removal projects. He agreed to make this information available to the Alliance members.
Detailed action items are embedded throughout this summary report. For the sake of simplicity, the action items are consolidated and repeated here in a streamlined form.
The NMDF Document
Attendees agreed that it is critical to release the NMDF document to the public as soon as possible. They said
that the following steps should be taken to move toward this goal: (1) give key reviewers one last chance to
submit comments on the "Revision 1" version of the NMDF document; (2) create the next version of the
NMDF document and prepare and distribute a formal "Response to Comments"; (3) send the next version of the
NMDF document to Alliance Core Team members for a quick review, address any last-minute comments, and
post the document on the RTDF Web site; (4) find out exactly what steps are involved with EPA's final
approval process; and (5) issue the final document. For all of these steps to occur, specific actions must be taken by the following people:
- Yager will tell representatives from the Groundwater Forum that they must submit comments within a
couple of weeks if they want to offer input on the document. She will also ask her boss if anyone else in
EPA should be encouraged to provide comments. In addition, Yager will call Kaback and Hopkins about
obtaining funds to support the next iteration of the NMDF document. She will also find out exactly what
steps need to be taken to publish a document through OSRTI. In addition, Yager will help Kaback and Hay
Wilson address some of the comments that were submitted on the NMDF document by (1) sending out the
NMDF document's reference list to EPA representatives and asking them to let her know whether any
important EPA references are missing, and (2) contacting Hal White (from EPA's Office of Underground
Storage Tanks) to discuss his concerns about industry's role in establishing cleanup goals. Maxey will also assist with this last action item.
- Kaback and Hay Wilson will revise the NMDF document and prepare a "Response to Comments" once
funding becomes available. When the next version of the NMDF document is completed, Kaback and Hay
Wilson will distribute it to the Alliance Core Team members, who will be given 2 working days to indicate
whether the document is ready for final EPA approval. If any issues are flagged, Kaback and Hay Wilson
will set up a conference call to resolve them and make the necessary revisions before submitting the
document for final EPA approval.
- Tavelli will help Kaback address some of the comments that were submitted on the NMDF document.
Toward this end, Tavelli will provide information about goal-setting and endpoint-setting approaches that are used in one or two states other than Texas. She will also contact Carl Anderson for clarification about his concern that the NMDF document marginalizes certain stakeholder groups.
Module 1 of the Training Program
Attendees agreed that the following steps should be taken to develop Module 1 of the training program: (1)
distribute the draft version of Module 1 and the comments received thus far to the Alliance Core Team; (2) ask
the Alliance Core Team to review the document; (3) give the Alliance Core Team until October 7, 2003, to
submit comments, and then discuss and resolve the comments during a conference call; (4) prepare a revised
version of Module 1, send it to the Alliance Core Team for a quick review, and address any last-minute
comments; (5) give EPA reviewers 3 or 4 weeks to submit comments, offering to provide additional background
information to the reviewers via conference call; (6) compile the reviewers' comments, distribute them to
Alliance Core Team members, and schedule a conference call (or a meeting) to resolve the comments; and (7) finalize Module 1. For all of these steps to occur, specific actions must be taken by the following people:
- Perroni will load the draft version of Module 1, which consists of more than 80 slides, onto an FTP site
and send an e-mail to the Alliance Core Team members with directions on how to access the file. Perroni
will also consolidate the comments that have been submitted thus far into one file and e-mail them to the Alliance Core Team members.
- Maxey will start working with EPA representatives to identify forums for the training.
- The Alliance Core Team members will review the draft version of Module 1 and provide comments on the document's tone, content, and acceptability as an RTDF product.
- Hartnett will schedule a conference call for 11:00 Eastern Time on October 7, 2003, for the Core
Team to discuss and resolve the Module 1 comments. In addition, Hartnett will serve as the repository
for written comments that are submitted prior to the conference call. She will distribute the comments
she receives to the Alliance Core Team.
- Padlo and Kremesec will incorporate the comments they receive and release a revised version of the
Module 1 training program by October 31, 2003. They will send this to Alliance Core Team members,
who will be given 2 working days to indicate whether any additional changes are needed.
Module 2 of the Training Program
Attendees agreed that the following steps should be taken to develop Module 2 of the training program: (1) form a Workgroup and (2) and develop a draft of the Module 2 training program. To make this happen, the following people must take specific actions:
- Tavelli will convene a workgroup, establish a schedule, and take the lead in developing a full draft of Module 2. (Ideally, she will strive to distribute a set of slides and speaker notes in January 2004.)
- Yager willfind out whether OSRTI is willing to provide travel funds for the state regulators who join the Module 2 Workgroup.
- Attendees agreed that it would be useful to hold an Alliance meeting in late January 2004, possibly in Baltimore, Maryland, or Washington D.C. Hartnett will talk to Yager offline about scheduling a date and deciding on a location.
- Attendees agreed that it would be beneficial to reserve a half-day time slot on the agenda of an upcoming RCRA Corrective Action conference. Aalto will keep Alliance members informed about the status of the meeting, and will let them know what they need to do to reserve a slot on the agenda.
- OSRTI has written two reports on aggressive technologies. These reports are awaiting review. Once they are finalized, Yager will distribute them to Alliance members.
- The Navy has compiled information on DNAPL source removal projects. Cunningham will make this information available to the Alliance members.
A: ATTENDEES LIST
RTDF Non-Aqueous Phase Liquid
Action Team Meeting
Holiday Inn Denver Downtown
September 10-11, 2003
U.S. Environmental Protection (8P-HW)
999 18th Street - Suite 300
Denver, CO 80202
BP America, Inc.
501 Westlake Park
Houston, TX 77079-2696
1650 38th Street - Suite 201E
Environmental Program Principal
Solid & Hazardous Waste Division
Wyoming Department of Environmental Quality
122 West 25th Street
Herschler Building 4-W
Cheyenne, WY 82002
Environmental Restoration Division
Engineering Service Center
1100 23rd Avenue (ESC 413)
Port Hueneme, CA 93043-4370
|Leslie Hay Wilson
Sage Risk Solutions, LLC
3267 Bee Caves Road (PMB 96)
Austin, TX 78746
Senior Environmental Scientist
Regulatory Analysis & Scientific Affairs
American Petroleum Institute
1220 L Street, NW
Washington, DC 20005-4018
920 Sheridan Street
Laramie, WY 82070
Concurrent Technologies Corporation
999 18th Street - Suite 1615
Denver, CO 80202-
Groundwater Technology Team
Chevron Texaco - Energy Research Technology Company
Building 10 - Room 1604
100 Chevron Way
Richmond, CA 94802
Office of Solid Waste
U.S. Environmental Protection Agency
1200 Pennsylvania Avenue (5303-W)
Washington, DC 20460
Senior Technical Consultant
The Retec Group, Inc.
Building 22 - Suite 150
1726 Cole Boulevard
Golden, CO 80401
920 Sheridan Street
Laramie, WY 82070
Voluntary Remediation Program
Solid & Hazardous Waste Division
Wyoming Department of Environmental Quality
Herschler Building - 4th Floor West (Building A-W)
122 West 25th Street
Cheyenne, WY 82002-
|*J. David Zabcik
Shell Oil Products & Motiva Enterprises
12700 Northborough Drive
Houston, TX 77067
|RTDF Technical and Logistical Support Provided
5608 Parkcrest Drive - Suite 100
Austin, TX 78731-4947
Senior Project Manager
8601 Georgia Avenue - Suite 500
Silver Spring, MD 20910
110 Hartwell Avenue
Lexington, MA 02421
1 Alliance members sought input from the regulatory community because the Alliance wants to release the final version of the NMDF document with the RTDF's stamp of approval. If this stamp is to be obtained, regulators must be comfortable with the NMDF document's content and be allowed to participate in a formal review process.