SUMMARY OF THE REMEDIATION TECHNOLOGIES DEVELOPMENT FORUM
NON-AQUEOUS PHASE LIQUID CLEANUP ALLIANCE MEETING

Hilton Crystal City
Arlington, Virginia
February 3-4, 2004

WELCOME AND OPENING REMARKS
Mark Lyverse, ChevronTexaco Energy Research and Technology Company
Bob Maxey, U.S. Environmental Protection Agency (EPA), Office of Solid Waste (OSW)

Mark Lyverse and Bob Maxey, co-chairs of the Non-Aqueous Phase Liquid (NAPL) Cleanup Alliance, welcomed attendees (See Attachment A) to the meeting. Lyverse provided background information on the three major projects that Alliance members are working on: (1) developing a NAPL Management Decision Framework (NMDF); (2) creating a light non-aqueous phase liquid (LNAPL) training program; and (3) investigating and remediating a ChevronTexaco site in Casper, Wyoming. Maxey informed the group that the meeting's priority would be preparing Module 1 of the LNAPL training program for external review. Lyverse thanked Alliance members for the work they performed over the last 3 months to move Module 1 toward completion.

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. These modules will include: Module 1 (The Basics), Module 2 (NAPL Management), and Module 3 (Advanced Topics). Module 1 and 2 have already been started, with Module 1 nearing completion. During this meeting, Alliance members focused their attention on Module 1 and talked about changes that need to be made in order for Module 1 to receive the RTDF's stamp of approval. Carolyn Perroni of Environmental Management Support, Inc. (EMS) led the discussion.

Module 1

Vic Kremesec, BP America, Inc., informed the group that he had presented the current Module 1 training program to both regulators and consultants four times over the past two months. Each presentation lasted approximately 3.0 to 3.5 hours, depending on the number of questions that audience members asked. Kremesec noted that reaction to the training has been positive. Lyverse questioned whether the length of the presentation (approximately 100 slides) is appropriate for a Module entitled "The Basics." Kremesec said that he believes the presentation is an appropriate length, noting that you cannot have a good scientific discussion about NAPL without the basic concepts strongly in hand. Maxey agreed, stating that for proper training, a lengthy presentation is necessary.

Module 1 - Changes
A facilitated discussion was held to review the changes that should be made to Module 1 before it is released for external review. Changes were suggested over the previous 3 months and those where consensus had not been reached were discussed. Alliance members presented these changes to the group and explained why each change will improve the training module.

Dawn Kaback, Concurrent Technologies Corporation (CTC)
During Kaback's presentation, consensus was reached over the following changes:

• Slide 1 - The first and second slides will be combined into one introductory slide that will include information on the history and purpose of the Alliance, as well as the purpose of the training.



• The use of the term "soil" is technically inappropriate for LNAPL training and will be replaced by "subsurface" or "aquifer" where appropriate. However, a note will be added indicating that it is acceptable to use the word "soil" to avoid a language barrier during training sessions.

Brian Smith and Jeff Hostetler, Trihydro Corporation
Smith and Hostetler were concerned that some of the slides could shed questionable light on specific analytical procedures. They added that there are many ways to look at technical issues and that Module 1 should be less prescriptive in nature. During the presentation, the group reached consensus on the following changes.

• Slide 8 - A new image (from Wilson, 1990) needs to be incorporated.



• Slide 15 - The x-axis scale and background color need to be adjusted. The axis scale should read 0 to 1, not 0 to 1.2, and the background color should be adjusted so that the image is clearly visible.



• Slide 39 - The group debated whether to include the sentence "The use of a model or laboratory data is debated by experts." The wording gives the reader the impression that the authors are not supportive of using laboratory data. Rather than remove the sentence, the group decided that the phrase "it is up to the project team to make a decision on which one to use," should be added after "experts."



• Slide 68 - The sentence "and in some circumstances a correlation has been obtained between LIF response and LNAPL saturation," is not supportive of the work done at the case study sites in Casper, Wyoming. The wording gives the impression that the authors may not be supportive of LIF to LNAPL saturation correlation evaluation techniques. Perroni suggested that the word "circumstances" be replaced with "sites." Maxey will work with Smith and Hostetler on the exact wording.



• Slide 69 - The language discussing sample depths, numbers, locations, and costs is not supportive of the work done at the Casper site. Smith advised the group not to be overly prescriptive in the description of these figures. The group decided that the wording should be more general, and figures such as depths, locations, and number of samples should be left up to the project team's discretion.



• Slide 70 - Leave as is.



• Slide 71 - The second bullet should not specify "every 4 to 6 inches" because the exact depth frequency is site-specific. Similarly, the third bullet should not specify an exact number of samples upon which grain size analysis should be performed (currently "2 to 5"). Finally, the bullet that states "a final optional task is to obtain imbibition curve data" should indicate that due to significant costs, this choice should be "based upon professional judgement."



• Slide 73 -The statement "it is very difficult to develop a correlation between the intensity of fluorescence and the LNAPL saturation in the soil," should not be eliminated. While this correlation may be rare, a correlation coefficient between 0.4 and 0.5 was developed at the Casper site, and the value of laser-induced fluorescence should not be discounted. Instead of eliminating this statement, the slide should note that "at many sites it can be difficult to develop a correlation, but the Casper site has proven that it can be accomplished."

Vic Kremesec, BP America, Inc.
Kremesec presented the comments of Don Lundy and Mary Ann Parcher of ES&T. While Lundy and Parcher referenced a significant number of slides, Kremesec focused only on the most pertinent. During his presentation, the Alliance reached consensus on the following changes:

• Slide 18 - The capillary numbers on the right of the slide should be removed.



• Slide 19 - The explanation below the slide should include Greek symbols matching the equations in the slide.



• Slide 20 - The arrow indicating "residual non-wetting phase saturation" should point to an endpoint, not the x-axis. For this to happen, the endpoint needs to be enhanced.



• Slide 30 - Neither Kremesec nor the Casper team have found that "the inverse relationship between oil thickness and water table elevation change is most common with homogeneous sediments/soils." This should be noted on the slide.



• Slides 33 and 34 - It should be noted that there are two different methods for doing baildown tests. Kremesec indicated that either method is fine since there is usually reasonable agreement between the two.



• Slide 38 - A different graph has been sent to EMS for insertion into the slide.



• Slides 42 and 43 - Kremesec indicated that he will analyze these slides using a new software (BaildownSolver) that helps obtain the best-fit van Genuchten parameters.



• Slide 44 - The Rē value of 0.48 is believable and should be kept.



• Slide 49 - The simulated images move too quickly from the NAPL release date to one year after the release. This is a significant gap during which critical NAPL movement occurs. The Alliance will contact Parcher to see if data between the release period and one year post-release are available so that a more comprehensive simulation can be created.



• Slide 50 - A new slide needs to be sent to EMS by ES&T. The new slide will include conductivity values and a caption that reads "LNAPL Conductivity."



• Slide 51 - The first bullet needs to be edited to read "is partially recoverable" or "most recoverable."



• Slides 69 to 73 - The wording on these slides needs to be reduced. The audience will not have time to read the slides and listen to the speakers.



• Slide 88 - Maxey indicated that the reference to van Genuchten parameters is confusing since it is not referenced at any other point in the presentation. The van Genuchten parameters were previously referred to in Slide 16, but are now excluded. He suggested that the group reinsert the information on fitting curves based on van Genuchten parameters as part of Slide 16 or Slide 20.



• Slide 93 - This slide may have to be edited based upon the insight of regulators in Missouri. Kremesec asked that the group send him a note about revisiting this slide.

The Alliance also discussed comments provided by John Wilson, who was absent from the meeting:

• Slide 4 - In his notes, Wilson states that as NAPL moves toward the water table, the smaller soil pores are filled with water and NAPL can only occupy the larger pores. The group argued that the smaller pores can be occupied if the soil is extremely dry, or if NAPL has been in the ground long enough to undergo chemical change. If this is the situation, then site investigators should run a relative permeability test or LNAPL saturation curve. The group agreed that they would like to limit the discussion to more general situations and avoid this comment. Kathleen Yager (of EPA Region 1) will pass these comments on to Wilson.

Before sending Module 1 out for external review, Yager asked for a list of people who have reviewed the training. Kremesec asked if he could look at Jim Weaver's comments.

Module 1- Packaging and Delivery
With Module 1 nearing completion, it is important to determine how best to package and present the training program so that it reaches the appropriate personnel. For this to happen, Alliance members agreed to develop (1) a delivery format, (2) a testing strategy, and (3) a roll-out strategy. During this meeting, Alliance members focused on the delivery format and offered the following ideas:

• In-person training - The Alliance agreed that a live speaker brings his or her own knowledge and experiences to the table and therefore enhances the training experience. Also, live speakers can read body language, analyze reactions, and suggest changes to the presentation based on those reactions. In addition, live speakers can facilitate interactive question and answer sessions. To rollout this training, Walter Huff (of Mississippi Department of Environmental Quality) suggested that the Alliance plan a road show to deliver the training four or five times throughout the course of the year. Huff noted that the drawback to a road show is the infrequency of training. Government jobs have a high rate of turnover, requiring more than one training per region per year. David Ariail (of EPA Region 4) agreed, adding that the cost barrier associated with such face-to-face training will be prohibitive, especially if payment is left up to state regulators. Kremesec stated that he will ask BP if it can help fund the training, on the condition that Module 1 be approved by RTDF. Yager countered that if this training is an Alliance product, then it should be delivered by a cross section of Alliance members, not just those in industry. Kaback summarized the group's intentions, indicating that the Alliance plans to sponsor four face-to-face training sessions, each involving two Alliance members, during the first year.



• Internet seminar - In response to the concerns raised by Ariail and Huff, Alliance members suggested delivering Module 1 as an Internet seminar, noting that a seminar allows the training to be conducted during any 3 hour time period, without associated travel costs. This would be a real-time event, with PowerPoint slides and background information available via the Web, and possibly a question and answer session using teleconferencing. However, the group agreed that due to complications that inevitably arise using Web media it would be best to first test Module 1 using the face-to-face method.



• Internet self-training - Members noted that many people either prefer being self-taught, or simply do not have time to sit through 3.5 hours of training. However, until the script and delivery of Module 1 are finalized, the Alliance agreed that this concept should be tabled.



• Web-based materials/CD - Once RTDF has approved Module 1, the presentation and materials can be posted to the Web and/or compiled onto a CD. In doing so, it should be noted that these materials are merely reference materials and do not supplement the actual training. Alliance members noted that a web-based version is preferable to software as it can be updated and replaced easily and more frequently.

After debating which delivery format to pursue, the Alliance agreed that an Internet seminar would be the most cost effective and beneficial test strategy. Yager informed the group that before any of the delivery formats can be implemented, Module 1 first must be approved by RTDF. For initial review, she stated that the EPA will schedule a seminar, send out slides and background materials 2 weeks prior to the seminar, and facilitate the training session via the Web. Feedback and comments from this session will be taken over the phone and reviewed by the Alliance.

Module 1 - External Review
Thus far, Alliance members have had a chance to review the training program, but there has been little response from outside parties. Kaback said that this is to be expected, noting that typical response rates hover around 20 percent. With this in mind, Huff suggested that it would be best to conduct a formal review using face-to-face training and ask for both verbal and written reviews upon completion. Others asserted that an Internet seminar would be more accessible and therefore beneficial in terms of obtaining comments. With this in mind, Kremesec proposed the following schedule:

• End of February - Finalize internal changes as discussed at this meeting.



• End of March - EMS will incorporate these changes and create an interim final version. This interim final version can then be sent out to EPA staff for review, possibly using an Internet seminar. The date for this seminar needs to be finalized before Module 1 is released, perhaps sometime in April. The current Module 1 Development Team of Kremesec, Lyverse, Maxey, and Jerry Breed need to decide who will present each part of the training via the Internet seminar. Maxey noted that if review and comment are expected throughout the training, the seminar will most likely exceed the 3-hour threshold.



• End of April - After the initial Internet seminar and corresponding review, a third draft of Module 1 should be prepared for presentation to RTDF.

Kaback proposed that after this initial review takes place (sometime in April) a broad Internet seminar should be scheduled for May.

Module 2

Module 2 is being developed to help people understand how the emergence of NAPL conceptual models (as discussed in Module 1) impacts NAPL management approaches. The training is intended for management involved in the NAPL decision-making process and should be 30 to 60 minutes long. Breed (of Wyoming Department of Environmental Quality [WDEQ]) led a discussion reviewing the purpose of Module 2 and presented a content outline as drafted by Ali Tavelli. Kaback stated that the current outline has solid content and a good progression, but that the draft slides are missing some of the key points that are presented in the NMDF. For instance, references need to be made to long-term vision, contingency plans, supplemental investigations, and evaluating management options. Kaback said she will develop some slides and send them to Tavelli with an explanation.

As it stands, the outline is too focused on goals and endpoints and needs to focus on the entire process. While there was little disagreement with the content of the outline, the Alliance agreed that it should incorporate more concepts from the NMDF. Perroni asked that the group assemble a team that will focus on pulling together these concepts over the coming months, and to schedule a conference call to discuss these concepts. Lyverse, Breed, Tavelli, and Harley Hopkins (of American Petroleum Institute) agreed to participate in this effort.

CASE STUDIES

ChevronTexaco, Texas Site
Mark Lyverse, ChevronTexaco

The Alliance has agreed that for Module 1 to be most effective, it must include actual examples of NAPL cleanup. In addition to the ChevronTexaco site in Casper, Wyoming, other sites have been proposed for inclusion. Lyverse suggested using a ChevronTexaco site in Texas as an example. He presented information about a number of assumptions that are commonly made at NAPL-contaminated sites.

• Most old NAPL release sites are stable.
• Cleanup of NAPL rarely reduces observation of NAPL to zero.
• If you get to the release soon after it happens, you have the best chance of a reduced environmental footprint.
• The success of the cleanup depends on the source distribution and properties of the soil.

Lyverse focused on a site in Texas where 100,000 gallons of light Texas crude oil (similar to diesel) were released in late 1999. The exposure was at the surface with source removal occurring soon after the release was discovered. The key variables of the release were recorded (time, duration, volume, and point sources), making it a good case study for evaluating NAPL plume development, genesis, and mobility. Both Cone Penetrometer Technology (CPT) and Rapid Optical Screening Technology (ROST) were used for evaluation, with the ROST investigation giving a better understanding of in situ conditions.

Both the CPT and ROST technologies helped build a strong conceptual model of the smear zone. The model indicates that approximately 4 feet of NAPL lies 10 feet below the water table and follows the path of least resistance. Due to subsurface pressure and the nature of the soil, the NAPL initially moved upgradient due to subsurface pressure. This counterintuitive movement proves that NAPL plumes may not behave as expected, and this should be noted in the Alliance's training program. After 18 months, the mobility of the NAPL has apparently decreased and has fallen below rates that are observable in the field. Although theoretical calculations suggest that there could be movement of 1 to 10 feet per year, this potential is expected to decrease over time as NAPL concentrations decrease. There is currently no risk to neighboring properties and the potential for future migration is being closely monitored.

The case study has been used by ChevronTexaco during internal workshops, as well as by the Texas Commission on Environmental Quality (TCEQ). Key lessons learned from this case study include:

• NAPL plumes may not behave as expected. In this case, the plume actually moved upgradient due to subsurface pressure.
• Evaluation of plume mobility is a key parameter in the decision-making process.
• LNAPL finds the path of least resistance.
• It is important to gather the data necessary to build a solid conceptual model.
• The best chance for a reduced environmental footprint is for source removal shortly after release.
• NAPL recovery is most effective in the core of the plume.

Smith asked if it would be possible to get a 3-dimensional representation of the plume. This would give a better sense of how NAPL follows the most conductive sediments and can actually move upgradient. Kremesec noted that this example includes many variables that the BP Casper site lacks and would be a good addition to the training program. He will work with Lyverse to see where this study best fits in Module 1.

ChevronTexaco Casper, Wyoming Site
Jeff Hostetler, Trihydro Corp.

Hostetler presented an update on the progress of ChevronTexaco's Casper, Wyoming remediation project. He informed the group that there has been a major administrative change since the September 2003 meeting as Jerry Breed has taken over the duties of Ali Tavelli. In addition, Randy Jewett was given a leadership role at ChevronTexaco's Cincinnati site, so Ed Wilson has stepped in to fill his place for the Casper site. Hostetler emphasized that a change in leadership roles is typically challenging for a site like the former refinery, and he commended the site team on a smooth transition. Hostetler's summary included the following notes:

• The team is working to finish building the site conceptual model, which will be renamed the NAPL transitivity model.
• During their study, the team has learned a lot about the distribution characteristics and physical parameters of NAPL, yet questions remain over the chemistry, solubility, and toxicity of NAPL, and how these parameters vary throughout the smear zone.
• The Casper team believes that the project needs to be retooled to better reflect the NMDF. Suggested changes include revisiting the project goals, reevaluating decision-making now that NAPL distribution and transmissivity are better understood, and reevaluating what commercially available technologies might be recommended for consideration.

For a technology to be used at the Casper site, it should be capable of altering the physical/chemical properties of NAPL in the subsurface. Of the mass of NAPL that remains at the Casper site, it is estimated that less than 2 percent can be mobilized by simple hydraulic stimulus. Therefore, the team is making a paper evaluation of several commercially available thermal and non-thermal technologies, including:

• Chemical oxidation
• Electrical resistive heating
• Hot water flood
• Steam flood/injection
• Surfactant/Co-solvent floods

Each of these technologies has advantages and disadvantages. Vendors give varying information on the amount of NAPL they can remediate as well as the cost of that remediation. For instance, Casper has received estimates from $30 to $150 per cubic yard. Hostetler said that $30 may be economically feasible, but that $150 is much too expensive. The Casper team must now decide what criteria upon which to base future recommendations to ChevronTexaco.

Kremesec noted that thermal technologies create vapor problems that can present significant risk management challenges during application. In addition, very few studies exist about the nature of the reaction in the subsurface. Hostetler agreed, noting that chemical oxidation can cause the subsurface to behave as a large reaction chamber, noting that the reactions must be controlled. In the absence of such control, chemical oxidation can pose a threat, especially if there are other land uses in the surrounding area. Casper is a closed refinery on vacant land, which may enable the team to use secluded pieces of the smear zone, minimizing exterior risk. Nevertheless, Hostetler acknowledged, such issues need to be carefully considered.

Hostetler closed by stating that any technology that is applied at the Casper site must be capable of achieving one or more of the following goals in order for it to be considered a viable option:

• Significant reduction in the site risk profile.
• Substantial reduction in site care requirements, and/or
• Significant progress toward full restoration of the effected ground-water resource to an ünaltered" condition.

EPA's Release of NAPL Case Studies
Kathleen Yager, U.S. EPA, Region 1

One of the Alliance's main goals is to exchange information and lessons learned about NAPL case studies with the public. With this in mind, Yager asked the group whether EPA can make information on various case studies available on the Internet. While the information contained in these studies may need to be simplified for the general public, it is important that documentation be made available. Perroni stated that EMS can create a Web page with links to background information for each study. In addition, EMS can draft a Web site devoted to excerpts from Alliance meetings.

Yager informed the group that her office has started gathering information on LNAPL removal projects. Three or four volunteers came forward with NAPL cleanup data, of which two retracted stating they were uncomfortable releasing such information. This leaves two sites: (1) a ChevronTexaco site in Cincinnati, Ohio, and (2) a BP site in Sugar Creek, Missouri. These sites focus on multi-phase extraction involving two different types of soil conditions. Yager suggested that draft reports be sent to both BP and ChevronTexaco for internal review. Once all comments have been addressed, and the Alliance conducts its own review, each study can be posted to EPA's Web site.

Hostetler informed the group that there are a number of projects that might be useful to post (17 total in the United States and Canada). Unfortunately, the availability of detailed information for these sites is limited, possibly as a result of site owner policy and/or because it was never collected or documented. Kaback said that while corporations may be willing to share background information such as the geology and hydrology of the site, companies are highly unlikely to share important information such as cost data and technology use. Hostetler stated that unless the Alliance is able to contact the key decision-makers in the cleanup project, it is unlikely that the Alliance will obtain the detailed information that it seeks.

Yager also shared information on EPA's upcoming Remediation Optimization Conference, to be held June 15-17 in Dallas, Texas. This conference will focus on accelerating site closings, improving remediation performance, and reducing costs through optimization. EPA will be releasing four or five new guidance documents at the conference including fact sheets, guides, and optimal contracting techniques.

NAPL MANAGEMENT DECISION FRAMEWORK
Dawn Kaback, Concurrent Technologies Corporation (CTC)

The Alliance has nearly completed development of its NMDF. This document will help people identify practicable and reasonable approaches for cleanup and long-term management of LNAPL sites. The framework focuses on the importance of collaboration and consensus-building among diverse stakeholders in the NAPL cleanup process.

Kaback informed the group that she has incorporated the Alliance member's comments into the latest NMDF document, and that a formal comment resolution may have to be drafted. She noted that the Alliance reviewed comments on the NMDF at the September 2003 Alliance meeting (see http://www.rtdf.org/public/napl/minutes/091103.htm). As a followup to that meeting the following comments have been addressed.¹

• Comment 3 - Since Tavelli did not create a balancing example to counter the Texas approach in Section 1, the Texas example was deleted for the sake of moving forward.



• Comment 4 - Section 2.3 was changed to say that "the responsible party and the regulatory agencies are a minimum for participation."



• Comment 10 - it was suggested that the title of the document be changed so that gas station owners and operators are aware that it does not apply to their industry. However, the group decided that the title should remain as is.



• Comment 13 - Kaback asserted that the document does not go outside of regulatory requirements.



• Comment 18 - The group decided that the title should not be changed.



• Comment 28 - The difference between long-term vision, goals, and endpoints was discussed and clarified.

Kaback also led a discussion over the revision of the flowchart entitled "NAPL Management Decision Framework Process." Kaback suggested that the bottom half of the chart is confusing and needs to be streamlined. In response, the box entitled Section 9.0 LNAPL Management Plan was changed to Section 9.0 Evaluate Progress. The group decided to leave the flowchart as is, adding a Section 9.0 box and shading that box to resemble the middle section of the chart. Hopkins asked when the changes will be finalized, to which Kaback requested that the Alliance give her until the end of the first week in March. She will send the current NMDF out for a final review and report back to the group by March 5, 2004. Yager asked how best to promote the NMDF document once all comments have been incorporated. Maxey stated that discussion sessions during conferences would work best. EPA's Remediation Optimization Conference was suggested, to which Kaback said she would submit an abstract on behalf of the NAPL Alliance.

NEXT MEETING

Alliance members agreed to hold their next meeting in May 2004. A conference call will be held on February 27, 2004 at 12 p.m. EST to identify possible agenda items. Some Alliance members suggested focusing the May 2004 meeting on a review of NAPL cleanup technologies. For example, the Alliance could invite three or four vendors representing different technologies to present their products to the group and limit the discussion to a set list of questions.

ACTION ITEMS

Several action items were identified during the meeting:

Module 1 - Changes

• Perroni will incorporate all changes that were finalized during this meeting.



• Maxey will work with Smith and Hostetler to develop exact wording for Slide 68.



• The Alliance needs to contact Mary Ann Parcher regarding the images on Slide 49, and to ask her whether data between the release period and one year post-release are available.



• Kremesec will revisit Slide 93 based on new information from Missouri regulators.



• Yager will pass along the group's reaction to John Wilson's comments.



• The group will provide Yager with a list of people who have reviewed Module 1.



• Kremesec asked for a member of the group to pass along Jim Weaver's comments.

Module 1 - Packaging and Delivery

• Kremesec will ask BP about the possibility of funding face-to-face presentations of Module 1.



• Yager will schedule an Internet seminar for the purpose of reviewing Module 1. This includes distribution of slides and background materials. The goal is to complete this review by April 2004.



• Kremesec, Lyverse, Maxey, and Breed will decide who should present during this seminar and what section each member will be responsible for.

Module 2

• Kaback will develop slides that reference long-term vision, contingency plans, supplemental investigations, and evaluating management options and send them to Tavelli. These slides will then be incorporated into Module 2 so that it better reflects the NMDF.



• Breed, Lyverse, and Hopkins will coordinate and schedule a conference call to discuss how best to proceed with the development of Module 2.

Case Studies

• Lyverse will investigate whether a 3-dimensional representation of the NAPL plume at ChevronTexaco's Texas site is available. If it is, he will forward it to Smith.



• Kremesec and Lyverse will work to see where the Texas case study best fits in Module 1 and how it can be incorporated.

NMDF

• A shaded box for Section 9.0 (Evaluate Progress) needs to be added to the flowchart entitled "NAPL Management Decision-Making Framework Process."



• Kaback will send an email requesting a final review of the current NMDF document. She will gather comments and finalize the NMDF by March 5, 2004.



• Kaback will submit an abstract promoting the NMDF for EPA's Remediation Optimization Conference in Dallas, Texas, June 15-17, 2004.

Next Meeting

• Perroni will schedule a conference call for February 27, 2004, at 12 p.m. EST.

ATTACHMENT A: ATTENDEES