Holiday Inn Denver Downtown
Denver, Colorado
September 10-11, 2003

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.


Background Information

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 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:

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:


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:

Module 1 (The Basics)

Adamski provided an update on Module 1's status. He opened by saying that Vic Kremesec and Barbara Padlo—two BP America representatives who have played a major role in developing the training—distributed 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 1—one 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:

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 community—herself included—objected 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:

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:


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.


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.


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 Implementation—to structure its update reports. Therefore, he used the GITEI paradigm to structure his update during this meeting as well.

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.


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:


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:

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:

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:

Future Meetings

Miscellaneous Topics


RTDF Non-Aqueous Phase Liquid (NAPL)
Cleanup Alliance
Action Team Meeting

Holiday Inn Denver Downtown
Denver, Colorado
September 10-11, 2003

Attendees *Speaker  
Tom Aalto
Environmental Scientist
U.S. Environmental Protection (8P-HW)
999 18th Street - Suite 300
Denver, CO 80202
Fax: 303-312-6064
*Mark Adamski
BP America, Inc.
501 Westlake Park
Boulevard (1571)
Houston, TX 77079-2696
Fax: 281-366-7094
Ed Barth
1650 38th Street - Suite 201E
Boulder, CO
Jerry Breed
Environmental Program Principal
Solid & Hazardous Waste Division
Wyoming Department of Environmental Quality
122 West 25th Street
Herschler Building 4-W
Cheyenne, WY 82002
Fax: 307-777-5973
Don Cunningham
Environmental Engineer
Management Branch
Environmental Restoration Division
Naval Facilities
Engineering Service Center
1100 23rd Avenue (ESC 413)
Port Hueneme, CA 93043-4370
Fax: 805-982-4304
Leslie Hay Wilson
Sage Risk Solutions, LLC
3267 Bee Caves Road (PMB 96)
Suite 107
Austin, TX 78746
Fax: 512-327-0915
*Harley Hopkins
Senior Environmental Scientist
Regulatory Analysis & Scientific Affairs
American Petroleum Institute
1220 L Street, NW
Washington, DC 20005-4018
Fax: 202-682-8031
*Jeff Hostetler
TriHydro Corporation
920 Sheridan Street
Laramie, WY 82070
Fax: 307-745-7729
*Dawn Kaback
Concurrent Technologies Corporation
999 18th Street - Suite 1615
Denver, CO 80202-
Fax: 303-297-0188
*Mark Lyverse
Groundwater Technology Team
Chevron Texaco - Energy Research Technology Company
Building 10 - Room 1604
100 Chevron Way
Richmond, CA 94802
Fax: 510-242-5577
Robert Maxey
Environmental Engineer
Office of Solid Waste
U.S. Environmental Protection Agency
1200 Pennsylvania Avenue (5303-W)
Washington, DC 20460
Fax: 703-308-8638

*John Meyers
Senior Technical Consultant
The Retec Group, Inc.
Building 22 - Suite 150
1726 Cole Boulevard
Golden, CO 80401
Fax: 303-277-0110

Brian Smith
TriHydro Corporation
920 Sheridan Street
Laramie, WY 82070
*Ali Tavelli
Program Principal
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-
Fax: 307-777-5973
*J. David Zabcik
Environmental Advisor
Shell Oil Products & Motiva Enterprises
12700 Northborough Drive
Houston, TX 77067
Fax: 281-874-7925
RTDF Technical and Logistical Support Provided by:
Christine Hartnett
Environmental Scientist
ERG, Inc.
5608 Parkcrest Drive - Suite 100
Austin, TX 78731-4947
Fax: 512-419-0089
Carolyn Perroni
Senior Project Manager
Environmental Management
Support, Inc.
8601 Georgia Avenue - Suite 500
Silver Spring, MD 20910
Fax: 301-589-8487
Laurie Stamatatos
Conference Assistant
ERG, Inc.
110 Hartwell Avenue
Lexington, MA 02421
Fax: 781-674-2906

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.