SUMMARY OF THE REMEDIATION TECHNOLOGIES DEVELOPMENT
NAPL CLEANUP ALLIANCE
January 30, 2003
11:00 a.m.-1:00 p.m.
On January 30, 2003, the following members of the Training Workgroup of the Remediation Technologies Development Forum's (RTDF's) Non-Aqueous Phase Liquid (NAPL) Cleanup Alliance met in a conference call:
Mark Adamski, BP America, Inc. (Workgroup co-chair)
David Ariail, U.S. Environmental Protection Agency (EPA), Region 4
Jerry Breed, Wyoming Department of Environmental Quality
Brian Espy, Alabama Department of Environmental Management
Harley Hopkins, American Petroleum Institute (API)
Jeff Hostetler, TriHydro Corporation
Dawn Kaback, Concurrent Technologies Corporation (CTC)
Mark Lyverse, ChevronTexaco Energy Research and Technology Company
Quenton MacDonald, Environmental Management and Engineering, Inc. (EME)
John Meyers, The Retec Group, Inc.
Barbara Padlo, BP America, Inc.
Brian Smith, TriHydro Corporation
Bruce Stuart, Missouri Department of Natural Resources
David Taggard, BP America, Inc.
Ali Tavelli, Wyoming Department of Environmental Quality
Also present were Carolyn Perroni of Environmental Management Support, Inc., and Christine Hartnett of Eastern Research Group, Inc.
The Training Workgroup is developing a training program that (1) describes the technical aspects of NAPL distribution and mobility, (2) corrects common misconceptions about NAPL, (3) outlines recent thinking on NAPL conceptual models, and (4) explores NAPL management issues. In 2002, a team of industry and regulatory representatives started meeting regularly (via conference call) to develop a NAPL training program. The group decided to include four modules in the training program. They discussed the existing outlines and overall thrust for Module 1 (The Basics) and Module 2 (NAPL Management), seeking to determine how those modules might form the basis for a training package that merits the RTDF's stamp of approval and is acceptable to all of the NAPL Cleanup Alliance's Core Team members.
MODULE 1--THE BASICS
Barbara Padlo (of BP America, Inc.) has completed a draft set of presentation slides for Module 1. Padlo agreed to send Workgroup members an e-mail to let them know how to access an electronic copy of the slides. She asked call participants to review the slides, suggest changes, and add scripting by February 20, 2003. Padlo will revise the slide set based on the Workgroup's recommendations. On March 1, 2003, the revised slide set and script will be delivered to Region 4 in the form of an online training program. People who participate in the online training will not have to complete the program within a specified amount of time. This means, Mark Adamski said, that Workgroup members do not need to worry about time constraints when they review the slide set and script.
In the future, call participants noted, Module 1 will be presented to a much broader audience, delivered in person, and endorsed (hopefully) by the RTDF team. Adamski said that the RTDF-endorsed version of Module 1 might differ from the version that is sent to Region 4. For example, it might be shortened so that it can be delivered in a 2-hour timeframe.
MODULE 2--NAPL MANAGEMENT
The goal of Module 2, Adamski said, is to help trainees understand how the emergence of new NAPL conceptual models (a topic explored in Module 1) will impact NAPL management approaches. For example, he said, once trainees gain a better understanding of the technical limitations that hamper NAPL recovery, he said, they might decide that new management approaches are needed to identify realistic and obtainable NAPL management goals and endpoints.
Adamski said that a draft strawman for Module 2 was reviewed and discussed on January 7, 2003. During the review, regulators said that the strawman was slanted toward industry's perspective. Thus, during this conference call, Adamski recommended reworking the Module 2 outline and identifying the points that Workgroup members can agree upon. With that, Adamski solicited comments from the call participants. They made the following suggestions:
Tavelli's recommendation to incorporate the GITEI structure into Module 2 stimulated much discussion. In particular, call participants spent a significant amount of time discussing the "G" part of the GITEI acronym. At many NAPL-contaminated sites, call participants said, the goal is to "recover NAPL to the extent practicable." Experience has shown that technical limitations make it very difficult to remove all of the NAPL, however. For example, Adamski said, existing technologies have often only been able to remove about 60 percent of NAPL from the subsurface. Research also indicates, continued Adamski, that little progress is made toward achieving cleanup standards (e.g., Maximum Contaminant Levels [MCLs]) if a significant amount (e.g., 40 percent) of NAPL is left behind in the subsurface. This forces one to ask, he said, whether it is advisable to establish goals like "recover NAPL to the extent practicable" or "clean the site to MCLs" if technical limitations make it impossible to meet these goals in a timely fashion. He advised making the following point in the training: one should consider technical limitations when setting goals and establishing endpoints. He also said that the training should recommend subjecting goals to the SMART test to ensure that the goals are Specific, Measurable, Attainable, Recordable, and Time-predictable.
Bruce Stuart and Tavelli reminded call participants that goals like "recover NAPL to the extent practicable" or "clean the site to MCLs" are often established in statutes. In some states, for example, the law demands that regulators embrace such goals as a general guide for establishing long-term objectives. Tavelli said that the training program should advocate a generic decision-making process that can be applied in any state, at any site, and any under regulatory framework. Thus, it should not try to force a specific goal upon the regulatory community. Instead, Module 2 should simply state that it is important to establish a goal up front and should advocate for an effective goal-negotiation process that is based on science. Under the GITEI rubric, Tavelli said, stakeholders sit down together and establish an initial goal. Sometimes the goal chosen is prescribed by statute. After the goal is set, a detailed site investigation is performed and data are evaluated to determine whether the initial goal is still considered realistic. If it is not, the site's stakeholders work together to establish a new goal that is acceptable to all concerned. The GITEI process is being tested (and is working), Tavelli said, at the Casper Refinery Site. (See the RTDF's January 2003 meeting summary report at http://www.rtdf.org/public/napl/minutes for details on how this site's goal will change based on site investigation findings.)
Brian Espy expressed concern over the ordering of the GITEI process, saying that it makes little sense to establish a goal before performing an investigation. John Meyers defended the GITEI concept: establishing goals up front helps to get all of the stakeholders involved early in the management process. Also, Meyers said, more tailored investigations can be performed if a goal has been established up front. For example, he said, if mobility reduction is identified as a site goal, then site investigations can be tailored to obtain information that provides specific insight on NAPL mobility issues. Meyers also said that the GITEI process assumes that site managers will have at least a cursory understanding of a site's characteristics before they launch into the NAPL management process and set a goal. Espy said that this last point might not be true at small sites. Quentin MacDonald joined the debate as well. Once a NAPL problem is discovered, he said, the first goal should be to perform a full characterization of the problem and identify potential receptors. If no receptors are present or the receptors have already been protected, he said, it is reasonable to develop long-term NAPL management goals. Full characterization, however, should be performed before regulators establish goals.
Lyverse recommended providing a list of the technical, social, and political drivers that influence NAPL management goals. He also recommended making it clear that future land use should be considered when establishing intermediate NAPL management goals. Meyers agreed that land use is an important consideration but advised against delving into this topic in great detail in Module 2. Tavelli said that land use is an acceptable factor to consider when setting goals, but the training program should refrain from dictating a prescribed set of factors that must be considered when setting a goal.
Tavelli also encouraged Workgroup members to contact her offline if they have additional comments on the Module 2 outline. Call participants agreed to contact her by phone (307-777-5447) or e-mail (Atavel@state.wy.us).