EPA Conference Facility
Denver, Colorado
November 7-8, 2001


Randy Breeden and Mark Lyverse, co-chairs of the Remediation Technologies Development Forum's Nonaqueous-Phase Liquid (NAPL) Cleanup Alliance, welcomed the meeting attendees (see Attachment A) and thanked them for their participation. Breeden asked for updates on activities that have occurred since the Alliance's June 2001 meeting. The following information was provided:

Jeff Hostetler, TriHydro Corporation

Jeff Hostetler provided a progress report on the Texaco Subgroup's activities. He noted that Subgroup members plan to conduct 160 to 180 laser-induced fluorescence (LIF) pushes and 20 Soil Video Imaging System (GeoVis) pushes at the Casper Refinery site. To date, about 50% of the LIF data (i.e., 80 pushes) have been collected. The site team anticipates that they will need four more days to reach their data-collection goals. John Meyers outlined the Subgroup's upcoming objectives:

Hostetler noted that the field team is also trying to identify groundwater table depths via piezocone and SCAPS. He said that the SCAPS method yields a more refined picture of NAPL distribution than typical "lake" maps do. The latter assume relatively equal distribution of contaminants over less precisely sampled areas. Hostetler concluded by outlining some of the questions that remain to be answered for the site: (1) Will the SCAPS and core sampling provide adequate information on mobility? (2) Will the site team be able to use conventional techniques for the NAPL cleanup? (3) Where will innovative technology be needed? (4) Are there portions of the site's NAPL that are nonmobile and do not require cleanup?

Dawn Kaback, Concurrent Technologies Corporation

Dawn Kaback said that progress is being made on the Groundwater Central Web portal. It is not publicly available at this time, but the design has been finished and the Web site is currently being populated with links. (There are currently about 300 links in the database, 85 of them specific to LNAPL.) Kaback said that the database will be searchable, giving examples of how many "hits" show up for different search terms. For example, she said, the term "NAPL Removal" elicits more than 100 responses, "LNAPL Remediation" yields 268 results, and "Soil Vapor Extraction" yields 63 results.

Lyverse suggested that summary reports, along with specifically-designed Internet searches, be written to address questions regarding:

Meeting attendees agreed that information on these topics was not easily accessible. They decided to begin a search for related information by asking Department of Defense representatives about their decision-making procedures for NAPL/source removal subsequent to land partitioning and redevelopment. Perroni, Kaback, Breeden, David Zabcik, and Don Cunningham agreed to get in touch with their contacts. Breeden said that any information gathered about the presence (or absence) of unified NAPL management approaches (in the form of records of decisions, TI waivers, etc.) will be useful to the Alliance's Decision Framework Subgroup.

Mark Lyverse, Chevron Research and Technology Company

Lyverse said that the Decision Framework Subgroup plans to write a NAPL management plan; he distributed the most recent version of the document's preamble and outline. Meeting attendees offered the following suggestions for the document's format:

Meeting attendees then reviewed the document's draft preamble. They recommended adding some additional information:

Existing Version of the Preamble Additions Recommended by Meeting Attendees
The objective of this outline is to describe a NAPL management plan for a site that generally has complex large-scale groundwater/NAPL issues, has a significant financial liability, and is expected to require long term remedial measures to get to some negotiated endpoints. This Plan describes the elements that may be needed (i.e. each site will be different in some respects) for developing a specific process or road map that addresses the higher level concept of NAPL management.
  • Clarify that this is a guidance document. It is not to be used to explicitly generate another report, but to provide justification and a thought process for decision-making.

  • After the document is finished, one could use it to provide information to the community or to form the basis for negotiations between regulators and those being regulated.
Use of the document could be either internal or external depending on the drivers of the project, but in the end, lead to a comprehensive documentation that is understood by all significant project stakeholders as to what the goals and endpoints for NAPL management are. Elements of the Plan may also show up in documentation required for RCRA-type projects. However, these types of documents are usually not specific with respect to how NAPL is managed or how recovery endpoints are determined. It is the intent of this Plan to focus on these specific issues.
  • Clarify that owner/operator goals need to be established in the beginning. If the owner/operator cannot reach consensus as to the goals for the site, successful progress will not be made.

  • Explain where this document fits in and clarify how to use it.

  • Note that a high-risk site would not be appropriate for use with this document.

Meeting attendees then proceeded to review the document's outline, and solicited comments from the meeting attendees. The most up-to-date version is included as Attachment B.


Breeden mediated an open discussion session and asked participants to comment on the following:

Inviting State Regulators To Review the NAPL Management Plan

Meeting attendees agreed that the first draft of the NAPL management plan should be reviewed internally, but that subsequent versions should be reviewed by external entities as well. They expressed interest in inviting regional and state regulators to review the early drafts. (Names of potential reviewers were provided.) Yager suggested having the next Alliance meeting take place in conjunction with a corrective action meeting, noting that the latter attracts many regulators. She cautioned that regulators would need at least 2 months' advance notice of the Alliance's meeting. Attendees agreed that the next Alliance meeting should be held in spring 2002.

Alliance Resource Needs

Yager noted that EPA's Technology Innovation Office has been providing funds for the NAPL Cleanup Alliance's logistical support. She stressed that there are not enough funds available to cover the writing of the entire NAPL management plan. Alliance members will need to contribute money. Kaback agreed to draft a scope of work and budget proposal for the writing and editing of the document. Industry representatives agreed to use the proposal to ask their companies for contributions toward the document writing.

New Projects

Meeting attendees agreed not to undertake any new projects until the framework document is complete.




EPA Conference Facility
Denver, Colorado
November 7-8, 2001

Tom Alto
U.S. Environmental Protection Agency
999 18th Street - Suite 500 (8P-HW)
Denver CO 80202
Fax: 303-312-6064

Randall Breeden
U.S. Environmental Protection Agency
999 18th Street - Suite 500 (8P-HW)
Denver CO 80202
Fax: 303-312-6064

Don Cunningham
Environmental Engineer
Navel Facilities Engineering Service Center
1100 23rd Avenue (ESC413DC)
Port Hueneme CA 93043-4370
Fax: 805-982-4304

Jeff Hostetler
TriHydro Corporation
920 Sheridan Street
Laramie WY 82070
Fax: 307-745-7729

Dan Irvin
Program Manager - Technology
Conoco, Inc.
600 North Dairy Ashford
Ponca Building - Room 3034
Houston TX 77079
Fax: 520-447-5077

Randy Jewett
Project Manager
Texaco Group, Inc.
P.O. Box 7756
Burbank CA 91510-7756
Fax: 818-736-5559

Dawn Kaback
Concurrent Technologies Corporation
999 18th Street - Suite 1615
Denver CO 80202
Fax: 303-297-0188

Victor Kremesec
BP America, Inc.
150 West Warrenville Road (MS H-7)
Naperville IL 60563
Fax: 630-420-5016

Mark Lyverse
Senior Hydrogeologist
Groundwater Technology Team
Chevron Research & Technology Company
P.O. Box 1627
Richmond, CA 94802-0627
Fax: 510-242-1380

John Meyers
Senior Technical Consultant
The Retec Group, Inc.
Building 22 - Suite 150
1726 Cole Boulevard
Golden CO 80401
Fax: 303-277-0110
Carolyn Perroni
Senior Project Manager
Environmental Management Support, Inc.
8601 Georgia Avenue - Suite 500
Silver Spring MD 20910
Fax: 301-589-8487

Ali Tavelli
Program Principal
Solid and Hazardous Waste Division
Wyoming Department of Environmental Quality
122 West 25th Street
Herschler Building, 4th Floor West Wing
Cheyenne, WY 82002
Fax: 307-777-7953

Dick Woodward
Sierra Environmental Services, Inc.
9431 West Sam Houston Parkway, S
Houston TX 77099
Fax: 713-774-1602

Kathleen Yager
Environmental Engineer
U.S. Environmental Protection Agency
11 Technology Drive
2890 Woodbridge Avenue
N. Chelmsford MA 01863
Fax: 617-918-8417

David Zabcik
Environmental Coordinator
Equiva Services, LLC - SH&E Environmental Affairs
12700 Northborough Drive
Houston TX 77067
Fax: 281-874-7925

RTDF Logistical and Technical Support by:

Christine Hartnett
Conference Manager
Eastern Research Group, 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

Danielle Sass
Technical Writer
Eastern Research Group, Inc.
110 Hartwell Avenue
Lexington, MA 02421
Fax: 781-674-2851

Laurie Stamatatos
Conference Coordinator
Eastern Research Group, Inc.
110 Hartwell Avenue
Lexington, MA 02421
Fax: 781-674-2906


  1. Goals

    1. Owner/operator (owner's expectations for the site)
      1. Going to keep facility active or redevelop?
      2. Managing for level of perceived risk?
      3. Future land use--industrial, commercial, recreational, other?
      4. Minimize costs while achieving regulatory goals

    2. Regulator
      1. Goals for the property
        1. Time frame
        2. Future land use (potential exposure routes)
        3. Risk-based vs. non-risk-based
        4. Cost

    3. Stakeholders
      1. Community, local governments, receptors, special interest groups, etc.

    4. Regulatory structure/statutory requirements
      1. Minimum regulatory requirements--Applicable and Appropriate Requirements that have to be addressed at the site
      2. Regulatory program being applied

    5. Mechanism to accomplish goals
      1. Existing policies that allow flexibility to reach mutually acceptable goals

    6. NAPL management goals
      1. Established by considering:
        1. Regulatory requirements
        2. Current and future land use
        3. Existing and/or potential receptors
        4. Technology options
        5. Interaction with other remediation measures (e.g., boundary control systems)
        6. Stakeholder issues
        7. NAPL distribution and characterization
        8. Cost
        9. Post-remedy risks/uncertainty analysis
        10. Points-of-compliance
          1. Where is the POC?
          2. Is one needed? Why/why not?
      2. What are the goals for NAPL recovery?
        1. EI
        2. Intermediate goals
        3. Final remedy
        4. Mobility reduction? mass removal?

  2. Current conditions

    1. Land use/ownership
      1. Short term (e.g., present to 10 years)
        1. Who owns the property and adjacent properties?
        2. Who owns the liability of the property?
        3. Is there an expected ownership change in the near future?
        4. Is the facility active? closed? Or is this the site of a former facility?
          1. How is the property/adjacent property being used?
          2. How is the property/adjacent property zoned?
          3. Are there institutional controls in place?
        5. What adjacent/regional property development plans are underway or expected?
          1. Do they fit with the community master plan?
        6. Is it expected that adjacent property use will change?
      2. Intermediate (e.g., 10 to 30 years)
        1. Are any of the above conditions expected to change for this time frame?
      3. Long term (e.g., more than 30 years)
        1. Are any of the above conditions expected to change for this time frame?

  3. Site conditions and characterization

    1. Hydrogeological setting
      1. Fluctuating water table?
      2. Distance to water/NAPL?
      3. Groundwater classification system?
      4. Geological setting?

    2. Soil properties
      1. Soil lithologic and hydrogeologic properties in the interval that contains NAPL
        1. Grain size distribution, porosity, effective porosity, hydraulic conductivity, etc.

    3. Subsurface NAPL distribution
      1. Major NAPL sources?
      2. Release areas?
      3. Estimated volumes?
      4. Type(s) of NAPL?
      5. Smear zone?
      6. Potential for releases that would significantly impact the NAPL management strategy?
      7. Other data
        1. ROST, CPT, LIF, GeoVis, MIPS, etc.

    4. Known fluid properties--ground water and NAPL
      1. Current NAPL characteristics
        1. E.g., vapor pressure, boiling point, distillation curve
      2. Fluid properties that influence mobility
        1. E.g., viscosity, density, interfacial tension, relative permeability

    5. History of plume extent (liquid and dissolved phases)
      1. What are plume dimensions over time? (maps)
        1. How has the sampling program impacted the plume definition?
        2. How has groundwater elevation impacted the plume definition?
      2. Does modeling exist?

    6. Recovery history
      1. NAPL recovery history and significant aspects of the program (graphs)
        1. Methods for recovery, time line, number of wells
        2. Operational history

    7. Current NAPL management program
      1. What is the management philosophy for the NAPL?
        1. Pumping, barriers, other means of stabilization? (How was the EI met?)
        2. Perimeter control, aggressive recovery where warranted, memorandums of understanding?
        3. Plume on-site/off-site?

    8. Groundwater EI status
      1. Approved, submitted, planned? (NAPL migration/groundwater under control?)

  4. Existing and/or potential receptors (qualitative)

    1. NAPL plume
      1. Human/ecological
        1. Water supply wells
        2. Water bodies (lakes, streams, etc.)
        3. Utility trenches
        4. Buildings

    2. Dissolved-phase plume
      1. Human/ecological
        1. Water supply wells
        2. Water bodies (lakes, streams, etc.)
        3. Utility trenches
        4. Buildings

  5. Remedial technologies considered and proposed--screening of technologies and identification of data gaps
  6. (Similar to that used for general RCRA evaluations and ranking, but limited to technologies focused on NAPL remediation)

    1. Types
      1. Passive
        1. Bioremediation
        2. Phytoremediation
        3. Containment
        4. Monitored natural attenuation
      2. Innovative/aggressive
        1. SVE
        2. TFE
        3. Thermal
        4. Surfactant

    2. Ranking or metrics used to evaluate technologies?

    3. Short list of technologies that may be used, given the stated cleanup goal(s) and existing site knowledge

    4. Should a phased or combination technology remediation approach be used? (e.g., active followed by passive remediation)

    5. What data gaps must be filled in order to complete the technology selection?

    6. Practical removal
      1. What is practical removal? (considering cost, risk, technical capabilities)
      2. In what time frame? (considering cost, risk, technical capabilities)
      3. Will lab, bench-scale, or field tests be required?

    7. NAPL Mobility
      1. How mobile is the NAPL?
      2. What field evidence exists that supports plume stability or potential for migration?

    8. Is it helpful to understand the process of benzene dissolution from the NAPL if meeting MCLs is an issue or goal?

    9. Are vapors an issue (with respect to NAPL present or remaining) once removal goals are achieved?

    10. Risks

    11. Time

    12. Surface disturbance

    13. Other impediments that might influence technology selection

  7. Supplemental NAPL investigation (if data gaps are present)--what decision/goal is your investigation intended to support?

    1. What field engineering data must be obtained to quantify the NAPL distribution, volume, and mobility? (e.g., LIF borings, soil borings and cores, monitoring wells, hydrocarbon bail down tests)

    2. What laboratory data must be obtained to quantify the NAPL distribution, volume and mobility? (e.g., fluid properties, soil properties, soil-fluid interaction properties)

    3. What models and calculation methods will be used?

    4. What field engineering and test data must be obtained to fill the technology selection data gaps (e.g., pilot tests, treatability tests, geotechnical tests)

  8. Determining NAPL endpoints

    1. Given all of the above conditions, formulate a preliminary comprehensive closure plan that includes:
      1. The cleanup goal(s)
      2. Measurable endpoint criteria (used to determine when the active remediation system(s) can be suspended)
      3. The performance monitoring plan
      4. The closure criteria
      5. The compliance monitoring plan

    2. What endpoint criteria must be met to be able to suspend active remediation?
      1. E.g., mobility, ACL, soil concentration standard

    3. How will the endpoint criteria be measured?
      1. E.g., hydrocarbon bail down tests, groundwater concentration at the point of compliance, statistical confirmation soil sampling

    4. What measurements, models, and calculation methods will be used?

    5. What criteria must be met to demonstrate compliance with the goals?
      1. E.g., mobility, MCL, ACL, soil concentration standard

  9. Long-term site NAPL management plan

    1. Use of institutional controls/deed restrictions

    2. Financial assurance

    3. Short term and intermediate goals
      1. What performance monitoring will be undertaken during remediation to track system progress toward achieving the endpoint criteria?
        1. Will the chemical footprint of the NAPL change over time?
          1. How?
          2. From upgradient to downgradient? vertically?
        2. Is the plume degrading as one would conceptually think it might?
          1. How will this be supported?
        3. Mass removal tracking
        4. Diminishing returns
      2. What post-remediation compliance monitoring will be done to verify that the remediation system has achieved and maintained the goals?
      3. Schedule/time line