March 3, 2003
12:00 p.m.–1:00 p.m.
On March 3, 2003, the following members of the Remediation Technologies Development Forum’s (RTDF’s) Non-Aqueous Phase Liquid (NAPL) Cleanup Alliance’s NAPL Management Decision Framework (NMDF) Subgroup met in a conference call:
Dawn Kaback, Concurrent Technologies Corporation (Subgroup leader)
Leslie Hay Wilson, Sage Rick Solutions, LLC
Jeff Hostetler, TriHydro Corporation
Vic Kremesec, Group Environmental Management Company (A BP Affiliated Company)
John Meyers, The Retec Group, Inc.
Sue Westbrook, U.S. Environmental Protection Agency (EPA), Region 6
Kathy Yager, EPA
Also present was Christine Hartnett of Eastern Research Group, Inc.
The Subgroup is developing an NMDF, a document that is designed to help regulators and industry representatives think through the steps they should take in reaching meaningful decisions about NAPL management issues. Dawn Kaback, who has taken the lead in developing the document, has released several versions of the NMDF’s outline for comment and review. The most recent of these, she said, was distributed in late February 2003. Vic Kremesec, Jeff Hostetler, and John Meyers submitted comments on it. Kaback said that she has modified the outline to reflect their comments. None of the content has been deleted, she said, but the sections have been rearranged to better mirror the Goals, Investigation, Technology, Endpoints, and Implementation (GITEI) process. For example, she said, the LNAPL Management Plan discussion will now be incorporated into the introduction rather than appearing as a standalone chapter. Kaback said that the outline will be used to formulate the NMDF text. She opened the call up for discussion and asked people to comment on the revised outline.
FEEDBACK ON THE NMDF OUTLINE
Call participants debated the following topics:
¦ Terminology. Call participants said that there is still confusion about the terms concerns, interests, goals, objectives, and endpoint, and they recommended adding end-state vision to the terms that are being used in the NMDF document.
¦ Scope. The revised NMDF outline suggests, Leslie Hay Wilson said, that there should only be one goal established per project. She said that such a stance might be too rigid, noting that there is often more than one goal established per site. Meyers and Hostetler—the main advocates of the one-goal approach—said that only one goal should be established for each phase in the NAPL management process. Their comments spurred a discussion about the NMDF’s scope. Should it be designed to lead people through the decision-making process for a single phase of investigation, call participants asked, or should it be designed to help people develop end-state visions for sites and develop long-term management plans? This topic was debated at length. Advocates of the “single phase” approach said that NAPL management can become an unsolvable problem if site managers try to achieve too many goals simultaneously. The beauty of the GITEI process, they said, is that it fosters intelligent thinking on how to address problems in a phased and step-wise approach, allowing people to focus on one goal at a time rather than becoming overwhelmed with too many problems all at once. When one uses the GITEI process, Meyers said, one ends up with concrete marching orders for designing, operating, maintaining, and monitoring remedial solutions. Kremesec said that focusing on just one phase of investigation is a mistake, pointing out that other documents have already been created for this purpose. He advocated focusing the NMDF document on long-term planning processes and stakeholder-consensus-building activities. Hostetler said that he agrees that long-term planning and stakeholder-consensus building should be addressed in the document. The question, he said, is how much focus to place on these topics.
RESOLUTION AND PATH FORWARD
Kaback thanked the call participants for expressing their concerns. She said that she plans to create a draft of the NMDF by May 2003, and that she will do her best to incorporate the points of view that she heard on the call. She and Hay Wilson advised doing the following to address the call participants’ concerns:
¦ Include a glossary. Kaback said that controversial terms (identified above) will be defined in a glossary at the front of the document. In addition, the NMDF document’s authors will make an effort to identify areas where EPA and industry terminology differ. The authors will also differentiate between goals and end-state visions.
¦ Achieve a balance. Kaback said that the NMDF document will focus on technology selection and the GITEI process, but will also emphasize the importance of establishing end-state visions, performing long-term planning, and engaging in consensus-building activities.
¦ Make it clear that the GITEI process is something that site managers go through several times at a given site. For example, the GITEI process can be used once to meet environmental indicators, once to identify interim corrective measures, and once to identify final corrective measures.
¦ Clarify what is meant by “LNAPL Management Plan.” Hay Wilson said that the NMDF’s authors will make the point that the LNAPL Management Plan does not necessarily have to be a written document. Rather, the plan reflects the decisions that are made throughout the entire GITEI process.
¦ Maintain flexibility. Hay Wilson said that the document must be flexible enough to accommodate a wide variety of sites and scenarios.
¦ Add another chapter to the end of the document. Kaback said that she and Hay Wilson will consider adding another chapter to the document so that it does not end with a discussion on monitoring.
Kaback said that she would be in touch with individual Subgroup members if she required additional input. In addition, she agreed to contact David Zabcik to let him know what was decided during this call.