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

Holiday Inn-Capital Plaza
Sacramento, California
April 16-17, 2002

OPENING REMARKS
Randy Breeden, U.S. Environmental Protection Agency (EPA)
Mark Lyverse, Chevron Texaco-Energy Research Technology Company

Randy Breeden and Mark Lyverse, co-chairs of the Remediation Technologies Development Forum's (RTDF's) Non-Aqueous Phase Liquid (NAPL) Cleanup Alliance, welcomed meeting participants. Attendees included representatives from petroleum companies, consulting firms, and federal and state regulatory agencies (see Attachment A).

Breeden provided a summary of the Alliance's purpose, history, and activities. He noted that light non-aqueous phase liquid (LNAPL) contamination is present at petroleum refinery sites across the United States, but that the approach used to address these sites differs markedly from state to state and site to site. For example, at some sites, if LNAPL is not directly affecting receptors, little is done to remove it. At other sites, owners are expected to clean up ground water to drinking water standards even if no receptors are being impacted and the technology is not available to achieve this goal. EPA's Region 8 hosted a meeting to discuss this disparity in 1998. The meeting, which was designed to exchange information between the regulatory community and industry, raised several questions. EPA's Technology Innovation Office (TIO) advised forming an RTDF team to address these questions. This suggestion was embraced, and in 2001 the RTDF NAPL Cleanup Alliance was formed.

A memorandum of understanding (MOU), signed by federal and state regulatory agencies and several petroleum companies, outlines the Alliance's goals. These are: (1) evaluate the cost and performance of different NAPL removal techniques, and (2) develop a decision-making framework that can be used to determine the practicability and reasonableness of removing NAPL at different sites. The Alliance is trying to meet the latter objective by developing a NAPL Management Decision Framework (NMDF). This document is designed to help regulators and industry members think through the steps that should be taken (and the data that should be collected) to develop meaningful NAPL management plans. To date, a draft annotated outline has been created. The co-chairs said that many of the state regulators in attendance were new to the group, noting that they had been invited to provide (1) information on NAPL management approaches used in their states and (2) comments on the Alliance's draft annotated NMDF outline. The Alliance wants to ensure, the co-chairs noted, that this document is useful to state regulators.

OVERVIEW OF THE INTERSTATE TECHNOLOGY REGULATORY COUNCIL (ITRC)
Paul Hadley, California Environmental Protection Agency
Rick Tomlinson, ITRC Program Director

Paul Hadley provided an overview of the ITRC, a state-led organization that promotes the use of innovative remediation technologies. He said that 40 states currently participate in the ITRC, and that each state has one point of contact. (Hadley is the point of contact for California.) The ITRC forms teams to evaluate different technologies; these teams prepare guidance documents and undertake efforts to build confidence in new innovative technologies. Hadley described the ITRC's goals and explained what benefits this organization offers to states and industry. His presentation is included as Attachment B (PDF, 230k). Additional information can be obtained by visiting http://www.itrcweb.org .

Rick Tomlinson said that the ITRC identified state regulators who might be interested in the NAPL Cleanup Alliance's activities and paid to have them attend this meeting. Such support will not be available in the future, Tomlinson said, unless the NAPL Cleanup Alliance and the ITRC form a formal partnership. Breeden said that this possibility would be discussed the next day, during the Alliance's business meeting.

PRESENTATIONS BY STATE REGULATORS

California
Frank Dellechaie, California Environmental Protection Agency

Frank Dellechaie said that California is second only to Texas in terms of the number of refineries located within the state. He described the approach California uses to address RCRA refinery facilities. He said that the Department of Toxic Substances Control (DTSC) has regulatory authority over RCRA facilities, but that this agency only directly oversees about one-third of the state's RCRA sites. The remainder are addressed either by state water boards or the state Superfund program.

Dellechaie described the short-term goals (or Environmental Indicators [EIs]) and the long-term goals that RCRA facilities are expected to meet. Two short-term goals must be met:

• Protection of human health. This is a risk-based EI. To meet it, facilities must prove that they have taken measures to protect humans from harmful contaminant exposures. DTSC hopes that 95% of RCRA facilities will offer such assurances by 2003. Dellechaie said that threats to human health via inhalation are of particular concern, noting that NAPL can vaporize from soil and ground-water sources and infiltrate indoor air spaces. He said that these vapors can harm refinery workers, construction workers, and other people who conduct activities in the vicinity of a NAPL plume. DTSC is encouraging RCRA sites to address this danger in their health and safety plans. If they did so, several RCRA facilities would be compliant with human health EIs.



• Protection of ground water. This is a resource-based EI; it has nothing to do with risk. DTSC considers stability to be the short-term goal for ground-water protection. Thus, if a plume is under control and not migrating, it is compliant with California's ground-water EIs. DTSC hopes all RCRA sites will achieve control by 2005. Dellechaie said that slow NAPL removal rates pose an obstacle to compliance. In addition, some sites have trouble achieving goals because underground pipes and tanks are still leaking petroleum into the subsurface. (Dellechaiesaid that it would behoove operators at refinery sitesto undertake aggressive leak prevention programs. In fact, he recommended abandoning all underground pipes and tanks and replacing them with aboveground structures if possible.)

Dellechaie provided some examples to describe California's short-term goals. Any site that is located near receptors, emits dangerous volatile organic compounds (VOCs), and has a migratory plume is not compliant with EIs. In contrast, if contaminant exposure is unlikely at a site and plume migration has been controlled, the site is compliant with EIs.

After EIs are met, Dellechaie said, long-term goals are set for RCRA sites. The goal-setting process has not been formalized; instead, goals are set on a case-by-case basis according to each site's porosity, proximity to drinking water sources, and receptor profile. California sets reasonable and finite site-specific time periods for final corrective NAPL actions. If VOCs are not mixed in with the NAPL, he said, the NAPL is regulated under RCRA as a solid waste. Most NAPL, however, does contain some VOCs and is regulated as a hazardous waste. Dellechaie said that sites are prioritized based on the amount of risk they pose over the long term.

Georgia
Ron Wallace, Georgia Department of Natural Resources

Ron Wallace said that he is with Georgia's Underground Storage Tank (UST) program; he is not directly involved with large complex refinery sites. Wallace described the approach that Georgia, Tennessee, Mississippi, and South Carolina use to address free product under their UST programs. His presentation is included as Attachment C (PDF, 2073k). Different states set different remedial goals. For example, in Georgia and Mississippi, free product must be cleaned to of an inch thickness, but Georgia allows more exceptions to this rule. In Tennessee, the law says that free product must be removed to the "maximum extent possible." In South Carolina, free product may not exceed 0.01 feet in thickness.

Wallace focused most of his talk on Georgia's UST program. The program uses risk-based guidance to evaluate the severity of UST releases; receptor surveys play an important role in determining the level of risk associated with spills. The program sometimes uses fate and transport ground-water models, he said, to determine whether contaminants are likely to migrate to areas where people could be exposed (e.g., wells, surface water bodies, and basements). In Georgia, air sparge plus vacuum extraction, pump and treat, and mobile vacuum units are the most commonly used free-product-removal technologies. Wallace presented information about two specific sites that were cleaned up under the UST program: (1) Jackson Fina and (2) Jekyll Island Patrol and Welcome Center.

Wallace recognized that the Alliance is interested in learning about the approaches different states use to address major releases that occur outside UST programs. Nevertheless, he noted, it is important to understand a state's UST regulations because many states use these regulations as default guidance and apply them to large spills. The Georgia Geological Survey addresses large releases that occur within Georgia's state boundaries; in many other states, such spills are addressed by hazardous waste divisions.

New York
Christopher Magee, New York State Department of Environmental Conservation (DEC)

Christopher Magee said that there are several major oil storage facilities in New York. The same decision-making process is used for large and small spills. First, a regional spill engineer is informed of the spill. (Note: there are nine DEC offices located throughout the state; regional offices decide when a spill is closed.) Then, a spill response team is activated and cleanup/stabilization activities are initiated. After these activities are completed, the regional spill engineer may close out the site if he/she believes the spill has been adequately contained. If not, additional investigations are conducted, interim remedial measures are implemented, and a final remedy is ultimately selected and implemented. If the site meets Applicable or Relevant and Appropriate Requirements (ARARs), the regional spill engineer closes out the site. If ARARs are not met but the site has been remediated to a point that is "practical," the site may receive an "inactivation" designation. Magee presented two case studies:

• The Cibro site. Magee said that this site was formerly used as a refinery. A spill occurred, and the responsible party (RP) installed a multiphase vacuum extraction system to remediate the spill. After operating this system for 18 months and extracting 7,000 gallons of free product, the RP asked for permission to shut down the system, arguing that a point of diminishing returns had been reached. Upon closer analysis, it became apparent that this argument was flawed. Thus, regulators instructed the RP to optimize the recovery system and operate it for another 6 months. The RP did so, and was able to extract another 8,000 gallons of free product from the subsurface and reduce the thickness of free product from 4.5 feet to 0.5 feet.



• The Oil City Redevelopment Project. Magee said that this site, used for petroleum storage, is contaminated with petroleum products and was being cleaned up with horizontal extraction wells. In recent years, the property changed hands. The new owners decided to redevelop the site, erecting a mall on top of it. Thus, it is now imperative that the site be cleaned up quickly; the area will be excavated and contaminated soil will be hauled to a hazardous waste landfill. The property's new owners will be expected to pay for the excavation, but they are receiving significant tax breaks as a reward for their development efforts.

UPDATE ON THE CASPER REFINERY SITE

The NAPL Cleanup Alliance hopes to test its decision-making framework at real sites and to identify innovative NAPL remediation and management approaches. Toward this end, the Alliance hopes to form several Subgroups, each of which will perform a case study on a particular site. One Subgroup already exists: The Casper Refinery Subgroup. The team consists of Ali Tavelli, Randy Jewett, Jeff Hostetler, Brian Smith, and John Meyers.

The Regulatory Perspective
Ali Tavelli, Wyoming Department of Environmental Quality

Tavelli said that the Casper Refinery site falls under the regulatory authority of the Wyoming Department of Environmental Quality. She is the regulator assigned to the site. Tavelli said that Wyoming has issued an order for the Casper Refinery site; it states that the RP must recover NAPL "to the extent practicable." When regulators and the RP met to discuss the site, it became apparent that the two groups had different ideas about what was "practicable."

Tavelli described Wyoming's approach toward NAPL remediation. The state's statute, she says, expresses a non-degradation policy for ground water. Risk-based methods may be used to identify cleanup levels for soil, but ground water must be cleaned to maximum contaminant levels (MCLs) or background levels. Tavelli said that the state's statute is unique in the following respects:

• RCRA sites can be cleaned up through the state's voluntary remediation program.



• Local communities have the right to comment on the timeframe for remediation and the technology that is chosen.



• Information about the cost of different remedial options is presented to the public.

The Casper Refinery site, originally operated by Texaco, is one of eight RCRA refinery sites located in Wyoming. Six of the sites are still operational, but the Casper site and one other site are no longer operational. Tavelli said that the refinery sites have met the state's short-term goals, or EIs. The state is now starting to address the long-term issues associated with these sites. NAPL recovery activities have been ongoing at Wyoming's RCRA refinery sites for years, and millions of gallons of NAPL have been recovered using traditional remedial techniques. Unfortunately, these technologies have reached their limits: the NAPL that was easy to extract has been removed, but more recalcitrant product still remains in the subsurface. Thus, Tavelli said, Wyoming is interested in identifying new technologies and innovative approaches that can be used to extract additional NAPL from the subsurface. For this reason, she is excited to be working on the Casper Refinery site--as one of the NAPL Cleanup Alliance's case study sites, it will be targeted for innovative demonstrations. Tavelli said that she realizes that it would be cost prohibitive to implement an innovative technology across the entire 200-acre site. Therefore, the goal is to identify the areas that are most important to clean up. A treatment train approach might prove useful. Tavelli said that the Casper Refinery Subgroup is trying to address the following question: what type of aggressive innovative technology is needed to reduce NAPL quantities to a point where a more passive technology (e.g., natural attenuation) can be used to achieve MCLs within 50 years?

Update on Site Characterization Activities
Jeff Hostetler, TriHydro Corporation
Brian Smith, TriHydro Corporation

Hostetler and Smith serve as technical consultants on the Casper Refinery siteproject, and are working closely with Meyers on site characterization efforts. Hostetler provided a brief summary of the site's history and characteristics. In summary, he said that the site has been closed for 20 years, and has been subjected to a significant amount of site characterization studies (e.g., monitoring well and soil boring collection efforts) and short-term remediation initiatives (e.g., pump-and-treat technology and sheet-piling installations). These efforts helped investigators develop a rough conceptual picture of the site's subsurface and provided the information that was needed to design site stabilization approaches. To meet Wyoming's long-term goals, Hostetler said, more sophisticated assessment and remediation efforts will be required. Toward this end, the Casper Refinery Subgroup is using Site Characterization and Analysis Penetrometer System (SCAPS) tools to develop a more sophisticated understanding of NAPL mobility and distribution. Developing more accurate conceptual models will help regulators and RPs design more targeted cleanup approaches.

Smith provided an update on the Casper Refinery site's mobility study. He opened his presentation by showing the rough conceptual model that had been developed in the past, noting that much of the information that was used to construct the model was derived from monitoring well data. Data of this type cannot be relied upon to provide an accurate picture, because NAPL quantities fluctuate dramatically when there is a change in water table depth. Smith said that SCAPS is being used to derive a more accurate conceptual site model. SCAPS sampling locations were established across the entire Casper Refinery site. Laser-induced fluorescence (LIF) pushes were performed in about 160 locations. (LIF emits light and provides information on subsurface lithography. LIF provides information about the presence or absence of hydrocarbon, but does not reveal exactly how much is present. Meyers and Smith are hopeful, however, that a correlation can be found between LIF light intensity and NAPL saturation.) At some of the LIF locations, soil cores were also collected and GeoVIS video was employed. Smith said that analyzing soil cores is expensive and using the GeoVIS technology is time intensive. In comparison, the LIF technology is easy to use and inexpensive. Thus, the goal is to establish correlations between the LIF data and information that is collected using other techniques. Smith said that the mobility study is a work in progress, and that he, Hostetler, and Meyers are still analyzing the data provided with the SCAPS tools. More information about the work already completed, the techniques employed, and the studies planned for the future are included in Smith's presentation (see Attachment D (PDF, 1966k)).

Question and Answer

One meeting attendee asked about the cost associated with SCAPS. Tavelli said that the project has cost more than $300,000 so far. Hostetler said that SCAPS may be cost prohibitive for small sites. At a big site, however, it is imperative to obtain a thorough understanding of the subsurface before implementing a remediation system. At such a site, remediation designers have to get the design right on the first try. RPs cannot afford to install three or four remediation systems and learn by trial and error.

Another meeting attendee asked why SCAPS was chosen as an assessment technique. Hostetler said that LIF is one of the least disruptive in situ assessment techniques available, and that it is less expensive than other options.

ANNOTATED OUTLINE OF THE NMDF

Introduction

As noted above, the NAPL Cleanup Alliance plans to release a decision-making framework that describes what steps to take when preparing cleanup and/or long-term management plans for large, complex LNAPL sites. Dawn Kaback has taken the lead in developing the framework, and hired Leslie Hay Wilson and Glenn Paulson to assist in the effort. On April 1, 2002, a draft annotated outline of the NMDF was distributed for comment. Kaback provided a brief overview of the annotated outline's layout and content. As it is currently structured, the document has six major sections:

• Preamble



• Current Conditions



• Determining NAPL Management Goals and Endpoints



• Technical and Regulatory Approaches to Long-Term NAPL Management



• Techniques for Reaching Consensus



• Long-Term NAPL Management Plan

See Attachment E (PDF, 655k) for additional information about the subtopics included under each major section.

Discussion

Kaback asked meeting attendees to provide comments on the annotated outline. Comments fell under the following categories:

The Utility of the NMDF

Prior to the meeting, Kaback and Lyverse heard some state regulators express doubts about the NMDF's utility, suggesting that guidance documents were already available to help regulators navigate the complexity of LNAPL sites. Kaback asked meeting attendees to comment on these remarks.

Christine Jump asked Alliance members to provide more information about how the NMDF differs from other LNAPL guidance documents. Tavelli said that the NMDF describes "where the rubber meets the road" in terms of NAPL. The NMDF is not an EPA guidance document, Tavelli said, noting that its development will not impose any additional requirements on state regulators. Instead, it will make a state regulator's job easier by providing a tool that can be used when writing up a site's Corrective Measures Study (CMS). Meeting attendees asked Jump for information on Kansas' approach toward NAPL sites. Jump said that NAPL must be removed, but that Kansas' guidelines are vague about how much must be removed and how quickly it must be removed. Meyers said that the NMDF will help Kansas make decisions about the amount of NAPL that should be removed and how much time should be allowed to meet goals and endpoints.

Magee did not think the document would be particularly useful in New York, a state that offers little flexibility in setting goals and endpoints. In New York, Magee said, all NAPL must be removed and all ground water must be returned to drinking water standards. Any efforts to relax the state's goals might be regarded as "selling out" to meet industry's interests.

Representatives from California, a state that does have some flexibility, thought the NMDF would be useful. Bruce La Belle noted that it will provide guidance on the type of information that must be gathered to make sound decisions about LNAPL sites. Dellechaie said that the document would help get regulators, non-governmental organizations, and industry members on the "same page" when it comes to making risk-based cleanup decisions at a site. Its utility will increase, he said, if it is widely endorsed across the country, and by EPA and a number of different states. It should be made clear, he said, that the document is not being written in an attempt to countermand or supersede state regulatory authority.

The Scope of the NMDF

At what point in the remediation/management process, one participant asked, should the NMDF be used? Should managers apply it before addressing immediate hazards and setting EIs, or is it supposed to be used post-EI? These questions stimulated debate. In the end, it was decided that the document would be most applicable to--and therefore should be written to target--sites that have already moved through the EI process. The discussion prompted another question: should the NMDF be written strictly to address RCRA sites, or should it be broadened so that it can be used at sites being addressed under non-RCRA programs? Meeting attendees chose the latter approach. Thus, RCRA program-specific jargon (e.g., "EI") should be eliminated from the main body of the text and replaced with more generic language. Breeden did not want RCRA-specific information to disappear entirely; he recommended providing information about RCRA-specific requirements in side bars and text boxes.

Kaback and Lyverse asked meeting attendees to comment on the document's level of specificity. For example, Lyverse said, should the document simply say "endpoints should be established," or should it include a detailed discussion of the process that should be used to establish endpoints? Meeting attendees agreed that the document should be as short as possible. Jump and Wilson warned against providing too much detail, noting that the NMDF could be mistaken for a cookbook if too many details are provided. The decision was made not to include a step-by-step methodology for accomplishing tasks.

General Organization

The "Current Conditions" section in the NMDF currently precedes the "Determining NAPL Management Goals and Endpoints" section. Hostetler suggested switching the sections. If there is a lack of consensus on goals and endpoints, he noted, developing an agreeable cleanup or management plan will be quite difficult. Several other meeting attendees agreed that the order of the two sections should be reversed.

Lyverse and David Zabcik suggested placing the bulk of the material that currently appears under "Current Conditions" in an appendix. La Belle made a more specific recommendation: place information about current regulatory requirements in the "Determining NAPL Management Goals and Endpoints" section and move the remainder of the "Current Conditions" section to an appendix. Kaback said that it might be best to place a checklist that lists the topics covered in the "Current Conditions" section in the main body of the text, and to provide more detail about these topics in an appendix.

Format (Length, Checklists, Decision Trees, Flowcharts, and Case Studies)

Kaback said the document will be user friendly. Toward this end, efforts will be made to keep the document short; to include checklists, decision trees, and flowcharts; and to shift non-critical information to appendices. As noted by one meeting attendee, it would be ideal if a reader could get through the main body of the text in half an hour. Then, if the reader wanted additional information about specific elements of the NMDF, he or she could consult the document's appendices, side bars, and figures.

Several meeting attendees said they liked the idea of incorporating checklists and flowcharts into the document. Breeden suggested providing a flowchart at the beginning so that readers have a road map explaining what will be covered.

Meeting attendees also suggested including case studies in the document's appendices. Paulson, Wilson, and Kaback asked meeting attendees to send them information about sites that would lend themselves to case studies. A few possibilities were identified during the meeting:

• Conoco's site. Meyers described the decision-making process that was used to identify goals and endpoints at one of Conoco's large, complex NAPL-contaminated refinery sites. Alliance members will ask Conoco to develop a 2- to 4-page case study that summarizes the experience.



• Sites in California. Dellechaie said that two sites in the Bay Area are strong candidates for case studies. Information about both of them is available through the public record.

Preamble

Wallace recommended adding language to the preamble to make it clear that the NMDF describes an active process and that it is designed to identify goals and endpoints. If not, he said, some state regulators may dismiss the document, regarding it as an industry-led attempt to circumvent responsibility.Jump recommended making it clear up front that this document addresses only NAPL--not dissolved-phase contaminants and metals.

Determining NAPL Management Goals and Endpoints

Meeting attendees recommended starting the "Determining NAPL Management Goals and Endpoints" section with a discussion about the drivers (e.g., change in land use, regulatory criteria, risk management) that make site cleanup and long-term management necessary. The drivers, one participant noted, have a direct impact on the goals that are chosen for a site.

Meyers said that the difference between goals and endpoints should be clearly stated. He defined goals as broad objectives (e.g., reduce NAPL mobility) and endpoints as specific results that must be achieved in order to prove that broad goals have been achieved. If no specific endpoints are set, Meyers noted, site remediation managers will not know when to stop cleanup activities. He said that an endpoint should be something objective and measurable, such as achieving a specified MCL or performing cleanup until the system goes asymptotic. Meeting attendees recommended providing concrete examples of goals and endpoints that have been established at different sites. (These examples will be short; the authors will not include a methodical, step-by-step description of the process used to set endpoints. Detail about the process used at specific sites, however, might be included in the appendices as case studies.)

Meyers suggested introducing the acronym "GITEI," which defines the steps for addressing cleanup as Goals, Investigation, Technology, Endpoints, and Implementation. Meyers said that goals should be established up front, and that investigations should be tailored to provide information that is pertinent to the goals. After a targeted investigation is finished, Meyers continued, technologies that are designed specifically to meet the goals should be deployed. Endpoints must be clearly established so that site managers know when, or if, they reach their goal. Breeden suggested presenting Meyer's GITEI approach in a decision tree.

Zabcik said that Section 2B ("Example Owner Goals") and Section 2C ("Example State and Federal Regulatory Agency Goals") are repetitious. He recommended consolidating the redundant information in one table.

Long-Term NAPL Management Plan

Kaback noted that the "Long-Term NAPL Management Plan" section is brief and asked for suggestions on how to make it more useful. At one point, she said, there was talk of including an actual LNAPL management plan as an appendix. If this route is chosen, Tavelli said, the plan written for the Casper Refinery site might serve as a good example.

Dellechaie said that he disagrees with point A4 in this section. (It reads "All parties agree that management of NAPLs should be dealt with separately from remediation efforts, such as surface cleanup.")

Other Comments

• Harley Hopkins suggested including a table that lists LNAPL remediation technologies. If the technology is already well established, references should simply be listed to direct readers to places where they can learn about the technology.



• Dellechaie suggested adding text that describes the importance of checking for leaks at operational facilities. Failure to do so, he said, can make remediation a moot point. Zabcik agreed that "Overall NAPL Management" would be a useful section to include in the NMDF. Wilson said that this discussion would probably be most appropriate under the "Current Conditions" section; she said that American Petroleum Institute (API) documents would be consulted for input on this topic.



• Lyverse questioned whether the "Techniques for Reaching Consensus" section should be included in the NMDF. Breeden recommended describing the points in this section in sidebars.

Path Forward

The Alliance's core members thanked the state regulators for reviewing the NMDF. Breeden asked if they wanted to review future draft revisions. All of the state regulators expressed interest in doing so. Breeden said that he was not sure whether funds were available to pay for travel expenses in the future. Thus, state regulators would most likely be asked to participate as Associate Members, review documents from their desks, and forward comments to Alliance members. (Breeden agreed to forward an excerpt from the Alliance's MOU that describes the role of Associate Members.) Representatives from California (Dellechaie and Suzanne Davis) and Missouri (Jennifer Surber) said that they knew of additional state regulators who would be interested in reviewing the NMDF. They agreed to forward contact names to Breeden (breeden.randy@epa.gov).

Meeting attendees agreed that the next version of the NMDF should be released prior to July 30, 2002. Kaback said that it might not be possible to complete all of the document's checklists, case studies, and decision trees in time for the meeting. This was not viewed as a problem; place holders will be inserted to let people know what is missing.

ALLIANCE BUSINESS MEETING

On the morning of April 17, 2002, core Alliance members met to discuss upcoming activities and explore new partnerships.

Partnership Opportunities With the National Petroleum Technology Office (NPTO)
David Alleman, National Petroleum Technology Office

David Alleman presented information about NPTO, which is part of the National Energy Technology Laboratory (NETL). His presentation is included as Attachment F (PDF, 1149k). Alleman said that NETL's main goal is to ensure that U.S. fuel resources meet the demands of the American public. Thus, NETL is interested in the NAPL Cleanup Alliance's efforts because it will help refinery operators identify more cost-effective approaches to cleanup, which in turn will help operators stay in business. Alleman said that NETL (and NPTO) get involved with the following types of projects:

• Technology development. NETL helps new technologies reach commercial markets by funding technology demonstration projects.



• Streamlining of state regulatory requirements. NPTO identifies ways to streamline state regulatory requirements so that refinery operators can meet requirements in a smoother, more cost-effective fashion. Care is taken to ensure that standards are not relaxed in the process.



• Broker agreements. NPTO is regarded as an honest broker that helps create study designs that are used to answer contentious questions.

Meeting participants asked whether NETL is willing to partner with the NAPL Cleanup Alliance. Alleman said that this might be possible, but that NETL would require additional information about the RTDF team's goals and activities before making a commitment. For the most part, he said, NETL's 2003 budget has already been allocated. If NETL and the RTDF form a partnership, however, it might be possible to contribute funds to the Alliance in 2004.

Meeting attendees discussed different funding mechanisms that could be used to fund RTDF projects if NETL did decide to partner with the Alliance. Alleman said that NETL puts out calls for proposals twice a year; RTDF could submit proposals and participate in a competitive proposal review process. As an alternative, NETL might be able to form an Interagency Agreement with EPA and transfer funds to TIO. If this approach were taken, TIO would be expected to direct the money to the Alliance. Yager said it might be easier if NETL transferred money to the U.S. Navy through an Interagency Agreement: the Navy has more discretion than EPA does in the way it spends funds.

Alleman and Jim Marsh said they would distribute information about NETL to Alliance members. Yager said that she would send NETL the Alliance's MOU. Breeden said that Alliance members will compile a wish list that describes projects they hope to fund. The Alliance and NETL will meet (via conference call) to discuss potential partnership opportunities in about a month.

Identifying a Mechanism To Interact With State Regulators

Breeden said that the NMDF's utility will be maximized if state regulators acknowledge it as a useful resource. Thus, it was agreed that it is important to encourage state regulatory participation and to keep the states involved in the NMDF's development. Without such participation, Breeden noted, the NMDF might be regarded as a document that federal regulators and industry are forcing upon the states. In addition, meeting participants noted, it would be ideal to start new pilot studies, similar to the project being performed at the Casper Refinery site. This will require participation from state regulators who have regulatory authority over the sites.

Meeting attendees discussed mechanisms that could be used to ensure state regulatory participation. For this meeting, Yager said, state regulators were able to attend and participate because ITRC paid for their travel expenses. In order for ITRC to do this in the future, she noted, ITRC would require the Alliance to formalize a partnership and create an official ITRC working group. If this route is chosen, Yager said, $110,000 would be required up front to establish the working group and ITRC would identify states that are willing to contribute full-time equivalent (FTE) for the development of technical guidance documents. Meeting attendees discussed the pros and cons of forming a partnership with ITRC, and decided not to pursue a partnership at this point.

Instead, the Alliance members will take on the responsibility of inviting state regulators to participate in Alliance meetings. Several strategies will be employed to identify the most appropriate people. (These strategies are summarized below under "Action Items.") State regulators will be invited to participate as peer reviewers. Those who are interested in performing work similar to the Casper Refinery project will be asked to participate as core Alliance members, and will participate in much the same way that Tavelli (of Wyoming) does.

Training Opportunities
Victor Kremesec, BP America, Inc.

Vic Kremesec said that BP America and API are collaborating on LNAPL training programs. These programs provide information on the hydrogeology, regulatory issues, and technological obstacles associated with LNAPL cleanup. Kremesec described three different training sessions; his slides, which are included as Attachment G (PDF, 96k), provide information on the topics addressed under each session. For the most part, Kremesec said, the sessions have been successful. Some state regulators, however, express skepticism about having industry members present information on risk-based cleanup levels. For this reason, Kremesec said, it would be useful to form a partnership with non-industry members and have them review, modify, and endorse the materials. Hopkins said that additional training sessions are currently under development. For example, a 1-hour session is being developed to explain API's NAPL recovery spreadsheets. This training, tailored to meet the needs of policy-makers, should be ready in summer 2002.

Breeden expressed interest in having API/BP present LNAPL training at several conferences. Hopkins said that API would be willing to do so. Meeting attendees brainstormed to identify other mechanisms for training delivery. Yager said that EPA hosts Internet training seminars, and that an LNAPL training session could be offered via this forum. (About 350 people can participate in the training at one time; the session is advertised through TechDirect, which reaches about 15,000 people.) Meeting attendees expressed enthusiasm for Yager's suggestion and asked her to contact EPA's Jeff Heimerman (the person in charge of EPA's Internet training program) to reserve a spot for an LNAPL session. Kremesec and Hopkins will create materials for the training session and distribute them to Alliance members for approval. The presentation should be no longer than 70 slides.

NEXT ALLIANCE MEETING

Alliance members agreed they should meet in fall 2002, but they did not decide upon a location. A number of suggestions were offered, including Pinedale, Wyoming, and Jackson Hole, Wyoming. Some attendees suggested holding their meeting in conjunction with a larger conference, such as: (1) the API/National Ground Water Association meeting that is scheduled to take place on November 6-8, 2002, in Atlanta, Georgia; (2) the 18th Annual International Conference on Contaminated Soil, Sediments, and Water, which is scheduled to take place on October 21-24, 2002, in Amherst, Massachusetts; (3) the International Petroleum Environmental Conference that is scheduled to take place on October 22-25, 2002, in Albuquerque, New Mexico; or (4) a Ground Water Forum or Engineering Forum meeting.

Alliance members talked briefly about what they hope to accomplish during the next face-to-face meeting. They will discuss the most up-to-date version of the NMDF, the Casper Refinery site's progress, and training initiatives. In addition, vendors will be invited to discuss remediation technologies. Meeting attendees expressed interest in learning more about several technologies, such as steam floods and pressure pulse techniques.

MISCELLANEOUS INFORMATION

Hopkins said that API produces spreadsheets, models, and other tools that can be used to address LNAPL characterization and cleanup. (For example, API has created models that allow site remediation managers to play "what if" games and analyze the impact specific NAPL removal efforts have on plume longevity.) New tools will be released this summer. Their availability will be announced via TechDirect. The tools can be accessed by visiting http://api-ep.api.org/index.cfm.

ACTION ITEMS

• API is interested in partnering with the NAPL Cleanup Alliance and plans to sign the Alliance's MOU. Hopkins agreed to check on the MOU's status.



• Alleman and Marsh agreed to distribute brochures and fact sheets about NETL. These will provide information about the projects NETL funds and the capabilities of the U.S. national laboratories.



• Alliance members will put together a "wish list" that describes projects they would like funded (e.g., laboratory research, field pilot tests, technology demonstrations, state regulatory participation). Suggestions for the list should be sent to Breeden by May 3, 2002. Members who propose projects should submit a brief paragraph, which should include information about project costs and how the project could benefit NETL. Breeden will compile a draft "wish list," distribute it to core members for comment, and set up a conference call with NETL representatives to discuss the list. (The call will be scheduled for mid-May.)



• Kathy Yager will send Alleman a copy of the Alliance's MOU and the URL for the RTDF Web site.



• Meeting attendees decided not to pursue a partnership with ITRC at this time. Yager will inform ITRC of the Alliance's decision.



• Meeting attendees agreed to find additional state regulators who are interested in peer-reviewing the Alliance's documents. States from Region 6 (Arkansas, Louisiana, New Mexico, Oklahoma, and Texas) and Region 8 (Colorado, Montana, North Dakota, South Dakota, Utah, and Wyoming) were identified as important states to target. California, Delaware, Illinois, Indiana, Kansas, New Jersey, and Washington were also identified as important states. Yager agreed to compile a list of contact names for these states, and to set up a conference call so that core Alliance members can discuss the list. The following efforts will be made to identify state regulators:

—	Contact the Environmental Council of the States (ECOS). Yager will contact ECOS to ask for recommendations.
—	Contact the Association of State and Territorial Solid Waste Management Officials (ASTSWMO). Tavelli agreed to contact ASTSWMO to find out whether they know of state regulators who would be interested in participating in the NAPL Cleanup Alliance.
—	Perform outreach at the Refinery RCRA Corrective Action Stakeholder meeting that is scheduled to take place in Denver, Colorado, July 30-August 1, 2002. Breeden said that many regulators from Regions 6 and 8 will attend this meeting. Breeden will contact the meeting planners to reserve a time slot for the Alliance to make an appeal for state regulator participation. Tavelli agreed to help Breeden prepare his presentation. In addition, prior to the meeting, Tavelli will provide information about the Alliance's activities to state regulators who are pre-registered for the meeting.
—	Collect suggestions from California and Missouri representatives. Representatives from California (Dellechaie and Davis) and Missouri (Surber) said that they knew of state regulators who would be interested in participating with the Alliance. They agreed to forward contact names to Breeden (breeden.randy@epa.gov).

• Meeting attendees should review the April 1, 2002, version of the NMDF annotated outline and forward comments to Kaback (kabackd@ctc.com) as soon as possible.



• Another version of the NMDF will be released before the Refinery RCRA Corrective Action Stakeholder meeting.



• The Alliance will ask Conoco to develop a 2- to 4-page case study for the NMDF document. The case study will describe the process Conoco used to identify goals and endpoints at a large, complex NAPL-contaminated refinery site.



• Breeden expressed interest in having API present LNAPL training at several conferences. Hopkins said that API is willing to do so. Breeden will send Hopkins a schedule of upcoming meetings and conferences.



• Meeting attendees agreed to prepare an LNAPL training session for EPA's Internet training seminar program. Yager will talk to those in charge of the training program to reserve a spot. Kremesec and Hopkins will work together to create the training, and will distribute it to the Alliance members for their approval.



• Alliance members agreed to invite vendors to their next meeting. They expressed interest in learning about several technologies, including pressure pulse techniques. Tavelli and Breeden will ask a vendor who uses this technology to give a talk in Laramie, Wyoming. After hearing the talk, they will decide whether to invite this vendor to the next Alliance meeting.



• Breeden said that he would send the state regulator participants an excerpt from the Alliance's MOU that describes the role of Associate Members.

ATTACHMENT A: ATTENDEE LIST
REMEDIATION TECHNOLOGIES DEVELOPMENT FORUM
NAPL CLEANUP ALLIANCE

HOLIDAY INN-CAPITAL PLAZA
SACRAMENTO, CALIFORNIA
APRIL 16-17, 2002

RTDF/Technical and Logistical Support Provided by:

Attachments B through G

Attachments B through G are available on the Internet. To view these attachments, visit the RTDF home page at http://www.rtdf.org, click on the "Non-Aqueous Phase Liquid (NAPL) Cleanup Alliance" button, then click on the "Alliance Meetings" button. The attachments will be available as part of the April 2002 meeting summary