U.S. Environmental Protection Agency—Region 6 Offices
Dallas, Texas
May 21–22, 2003

WELCOME AND OPENING REMARKS
Mark Lyverse, ChevronTexaco Energy Research and Technology Company

Mark Lyverse, co-chair of the Non-Aqueous Phase Liquid (NAPL) Cleanup Alliance, welcomed meeting participants and asked them to introduce themselves. (Attendees included representatives from petroleum companies, consulting firms, and federal and state regulatory agencies; see Attachment A (PDF, 39KB).) Lyverse noted that Randy Breeden, who has served as the Alliance’s other co-chair for several years, has temporarily stepped away from his position to accept a new assignment. Christine Lehnertz, representing Region 8 of the U.S. Environmental Protection Agency (EPA), will serve as a co-chair in Breeden’s absence. Unfortunately, Lyverse said, Lehnertz was unable to attend this meeting.

Lyverse provided background information on the NAPL Cleanup Alliance. The group is one of six active teams participating in the Remediation Technologies Development Forum (RTDF). This forum, which is supported by EPA’s Technology Innovation Office (TIO), fosters collaboration between the public and private sectors in developing innovative solutions to hazardous waste problems. The Alliance’s roots stretch back to 1998, when a meeting was held in Region 8 to discuss challenges associated with sites contaminated with light non-aqueous phase liquid (LNAPL). During the meeting, much interest was expressed in identifying better ways to manage and remediate LNAPL sites. This interest gave birth to the NAPL Cleanup Alliance, a partnership that has been formalized with a memorandum of understanding. The Alliance has worked on several projects since its inception, Lyverse said, noting that the status of each would be discussed during the meeting.

THE ALLIANCE’S DECISION-MAKING FRAMEWORK

Background Information

The NAPL Cleanup Alliance is developing a NAPL Management Decision Framework (NMDF) document in an effort to help people identify practicable and reasonable approaches for cleanup and long-term management of LNAPL sites. One of the document’s major themes is the importance of fostering collaboration and consensus-building approaches among diverse stakeholders.

Dawn Kaback, of Concurrent Technologies Corporation (CTC), is preparing the document with support from Sage Risk Solutions, Inc., and Paulson & Cooper, Inc. Over the last year, Alliance members have reviewed several versions of the document’s outline. The review process sparked debate and prompted several members to submit comments about the document’s scope, flow, and content. These comments were carefully considered, and in late March 2003, the Alliance leadership finalized the outline and asked Kaback to develop the first full draft of the NMDF document. The draft was distributed to Alliance members on May 13, 2003.

Overview of the NMDF Draft Document
Dawn Kaback, CTC

Kaback provided a brief overview of the draft NMDF document’s content and organization. In summary, she said, the document includes the following major sections:

• Introduction and Objectives
  
  
• Organize Resources, Develop the End-State Vision, and Establish LNAPL Management Goals
  
  
• Collect and Analyze Supplemental Data
  
  
• LNAPL Management Strategy
  
  
• Establish Endpoints To Measure Progress
  
  
• Implement and Monitor
  
  
• Revisit the LNAPL Management Plan
  
  
• Appendix A: Current Conditions Checklist
  
  
• Appendix B: Selection of LNAPL Management Options
  
  
• Appendix C: Selected LNAPL Characterization and Remediation Technology References
  
  
• Appendix D: References

See Kaback’s presentation (included as Attachment B (PDF, 54KB)) for additional information about the subtopics in each major section.

Group Discussion on the Draft NMDF Document
Facilitated by Dawn Kaback (CTC) and David Zabcik (Shell Oil Products US Company & Motiva Enterprises)

Kaback and David Zabcik, co-chairs of the Alliance’s NMDF Subgroup, asked attendees to comment on the NMDF document. The attendees obliged, recommending the following:

• Make it clear that the NMDF document is designed to address sites where imminent hazards are already under control and site managers already know that an LNAPL problem exists. The Alliance leadership agreed that the NMDF document should address sites where imminent hazards are already under control (e.g., sites where environmental indicators [EIs] have already been met) and said that this point should be emphasized in the Executive Summary, the “Introduction and Objectives” section, and the document’s flowchart. Focusing on the latter, attendees questioned whether the text in the first box of the flowchart (i.e., “Immediate hazards under control?”) should be modified to read “Have you completed your EIs?” Leslie Hay Wilson advised against this proposed modification, saying that the term “EI,” which is a RCRA term, is too prescriptive and would lead people to believe that the flowchart can only be applied to RCRA sites. Another attendee advised changing the box to read “Has all of your risk been assessed?” Terry Vandell-Bell said this proposed modification is also problematic: risk is constantly reassessed throughout all stages of the LNAPL management process. It is erroneous to imply, she said, that risk is evaluated just once during the initial stage of a project. Moving on to another topic relating to imminent hazards, some attendees advised including citations in the NMDF document that readers can use to determine whether imminent risks have already been adequately addressed at their sites. Other attendees, however, did not think it was necessary to provide such citations. Sue Westbrook suggested including information on the steps that need to be taken to determine whether a site even has an LNAPL problem in the first place. John Meyers said that this type of information would not be necessary. He said that it is fair to assume that those who will be using the NMDF document have already performed enough research to determine whether an LNAPL problem exists. Other attendees agreed with Meyers.
  
  
• Make it clear that a written “LNAPL Management Plan” is not always needed. The NMDF document, Lyverse said, should not imply that management decisions must be recorded in a formal LNAPL Management Plan. While documenting decisions in a written plan might be useful, he said, it is also acceptable for people to solidify their decisions over a handshake. Lyverse’s comments spurred other attendees to comment on some of the prescriptive language that is currently included in the document. Attendees advised the authors to steer away from words like “should” and “must,” noting that the document’s purpose is to provide suggestions and recommendations on addressing LNAPL sites rather than serving as an authoritative regulatory guidance document.
  
  
• Soften the superlatives. Greg Fletcher advised against using statements like “this activity is best conducted by . . .”
  
  
• Replace the term “end-state vision” with “long-term vision.” Attendees decided to use the term “long-term vision” in place of “end-state vision.” Kaback provided some clarification on the term, noting that “long-term vision” refers to the qualitative big picture that is envisioned for a site. Ali Tavelli said that it might be unrealistic to expect stakeholders to achieve consensus on one long-term vision at the start of the LNAPL management decision-making process. In light of Tavelli’s point, Zabcik advised making it clear that failure to achieve consensus up front on a single long-term vision should not prevent people from moving forth with the LNAPL management decision-making process.
  
  
• Define and describe key terms more clearly. Greg Fletcher advised underlining the terms that are formally defined in the NMDF document. Attendees also recommended defining terms in the Executive Summary as well as the “Introduction and Objectives” section of the document. When defining terms, Mark Adamski and Vic Kremesec said, the document should include examples to help readers fully understand the meaning of each term. For example, when defining the phrase “long-term vision,” Kremesec said, the authors could state that the vision will differ from site to site: while achieving pristine conditions might be the long-term vision at one site, continuous operation as an active refinery might be the long-term vision at another site. Hay Wilson asked NAPL Cleanup Alliance members to submit suggestions on real-world examples that could be used to further define the NMDF document’s key terms.
  
  
• Tell readers where to find key information within the document. Adamski noted that there are a series of text boxes peppered throughout the document that highlight key points. He said that a reader who is already savvy about LNAPL issues might be able to absorb the gist of the entire document just by reading the Executive Summary and the text boxes. Thus, he said, it might be useful to let readers know that they can obtain the key messages just by reading these sections. This will allow readers who already know a lot about LNAPL management issues—and therefore do not require as much detailed background information—to read through the document in a streamlined fashion.
  
  
• Add information about the RTDF NAPL Cleanup Alliance’s history and qualifications. Jeff Hostetler advised including additional historical and background information about the Alliance, either in the Executive Summary or in a preface. This will prevent readers from asking, “Who is writing this document, what qualifications do they have, and why is the document being written?” Attendees thought Hostetler’s suggestion was a good one.
  
  
• Provide information about how the NMDF document advocates a better approach to LNAPL management decision-making processes. Hostetler recommended providing background information in the Executive Summary about the pitfalls one commonly encounters when trying to manage large LNAPL sites. After doing so, he said, it is important to explain how the NMDF document will help avoid these pitfalls. The idea, he said, is to stress the fact that the NMDF document represents a forward-thinking and progressive philosophy that bypasses existing stumbling blocks. It would be useful to explain, he said, how this document differs from other documents.
  
  
• Be wary of using the phrase “maximum extent practicable.” The term “maximum extent practicable” is used in the second paragraph of the Executive Summary. Zabcik advised against using this phrase, noting that it is used for the Underground Storage Tank (UST) program. Hay Wilson said that the paragraph will be restructured to hit the following ideas: the default point, from a regulatory perspective, is to remove NAPL to the extent practicable, but this stance is not necessarily always the best one to take. Lyverse noted that “maximum extent practicable” is also used in the “Introduction and Objectives” section of the document, where it is accompanied by a reference to federal regulations. Attendees agreed that this reference should be removed.
  
  
• Clarify that short-, intermediate-, and long-term goals do not have to be set all at once. As written, Meyers said, the NMDF document implies that all of these goals must be established simultaneously. While such an approach is acceptable, he continued, the document should make it clear that it is also acceptable to set the goals individually as long as care is taken to ensure that short-term goals do not conflict with long-term goals.
  
  
• Modify the last sentence under the “Collect and Analyze Supplemental Data” heading in the Executive Summary. Kremesec advised making it clear that evaluating risk and regulatory compliance considerations is a key part of the LNAPL management process.
  
  
• Clearly define what is meant by the phrase “iterative nature” and do not lead readers to believe that the LNAPL Management Plan requires constant updating. Kaback said that the sections that discuss the iterative nature of the LNAPL management decision-making process will be reworked.
  
  
• Clarify what is meant by the term “source zone.” Dick Woodward said that the NMDF document implies that source zones should already be addressed. Woodward said that this assumption could be false, especially if the NMDF document is being used to guide management systems at an operating facility where existing structures preclude access to contaminated soils. Zabcik said that there are two types of sources: (1) leaking facilities—which really should be fixed up front before one gets too involved with the long-term NAPL management process, and (2) contaminated soil. The NMDF document should make this clear.
  
  
• Incorporate the concept of contingency plans. Lyverse suggested incorporating the concept of contingency planning into the NMDF document. Meyers agreed, and advised modifying the document’s flowchart to incorporate this concept. He advised adding another box to the flow diagram that reads “Contingency Plan.” Users would be directed to this box, he said, if they answered “no” to the questions that ask about whether endpoints have been met. Dashed lines leading back to earlier parts of the decision-making flowchart would emanate from the “Contingency Plan” box. Meyers said that the potential reasons for not achieving endpoints can be numerous. For example, they can range from something relatively simple like needing to make remediation system modifications to more serious problems, like trying to meet an impracticable goal. The Contingency Plan, which should be established prior to system implementation, Meyers said, should discuss all the potential causes and the appropriate response actions.
  
  
• Make minor changes to the flowchart. Vandell-Bell advised adding “and data” to the box that reads “Organize Resources.” In addition, Meyers stated that the box that asks whether acceptable options are available should be modified to remind users that they need to ask themselves whether the initial site goals are still practicable. If the answer to either question is “no,” Meyers said, dashed arrows should be added to direct the reader to either the goal-setting step or the “more data needed?” decision box. Before the end of the year, Jim Higinbotham said, the American Petroleum Institute (API) plans to release a browser-based training program, called eManual, that consists of a set of tools that can be used to develop an overall approach for evaluating and managing LNAPL. One of the tools included in the eManual package is a flowchart that outlines an LNAPL management strategy. Higinbotham said that the first draft of the flowchart has been created and presented to API representatives. The flowchart is similar to the one the Alliance has created for the NMDF document. Higinbotham and Harley Hopkins said that it would be useful to harmonize the two flowcharts to ensure that they do not conflict. Since the RTDF flowchart has progressed further, Kremesec said, it makes sense for the API flowchart to be modified to mirror the RTDF’s flowchart. Higinbotham and Hopkins agreed to work on this. In fact, before the meeting ended, they had already begun.
  
  
• Include additional EPA references. Kaback said that the document does not currently provide all the references that it should. She agreed to send Alliance members a list of the references that are currently cited. She encouraged them to review the list and to let her know whether additions should be made.
  
  
• Modify the text box that addresses the Guadalupe Oil Field. Kaback said that this text box has been created to give an example of successful stakeholder collaboration. Adamski expressed surprise: he had heard that relations at the Guadalupe Oil Field site were adversarial and that the cleanup project had been a failure. Kaback and Tavelli acknowledged that this was true of the project’s initial phases. The project was salvaged, however, when the stakeholders decided to embrace a collaborative, consensus-building approach. Zabcik advised adding information to the text box about the problems that existed before the collaborative process was initiated. Kaback agreed to do so, saying that she would ask Eva Davis for additional information about the public involvement component of the Guadalupe Oil Field project if necessary.
  
  
• Modify Table 2 and the text box entitled “Contaminated Site Cleanup Example.” Some attendees thought that the information provided in these two sections was misleading. They said that these sections imply that all of the stakeholders who represent a certain group automatically feel a certain way about site cleanup goals. Attendees advised changing the tone in the table and the text box. Kaback agreed to do so. In addition, attendees advised changing the title of Table 2 to “Common Stakeholder Starting Positions” and modifying the statement that says that regulatory agencies will be interested in “continu[ing] compliance with LNAPL regulations.” As an alternative, Tavelli recommended saying that regulators will want to “eliminate releases and control sources as best as possible.” Attendees also advised changing the language in the text box to say that health risks should be reduced to acceptable values rather than zero or near zero.
  
  
• Consider using the word “impacted” rather than “contaminated.” Kaback also asked attendees to think of other alternatives for the word and to submit suggestions directly to her.
  
  
• Provide a better definition for the term “mobility.” Adamski said that the definition currently provided for the term “mobility” is circular in nature. Tavelli advised revising the definition to say something like “If you have to change the chemical or physical properties of a NAPL to move it, then it is considered immobile.” Other attendees liked this definition and recommended highlighting it in a text box, along with information to distinguish the difference between “mobility” and “mobile plumes.”
  
  
• Modify the first sentence in paragraph two of Section 3.4. Kremesec advised making it clear that geological site conditions affect the extent and success of LNAPL recovery.
  
  
• Make it clear that LNAPL saturation values cited in the literature can be erroneous. Section 3.7 indicates that LNAPL saturation for a site “can be compared to a residual saturation value, either from the literature . . . or from laboratory measurements.” Adamski said that he is uncomfortable with this statement—he has little faith in values cited in the literature. Attendees advised adding a statement that cautions readers against believing everything they read in the literature.
  
  
• Modify the discussion of natural attenuation rates. Hay Wilson said that the NMDF document will be modified to say that it is useful to collect information about a site’s natural attenuation rate.
  
  
• Consider changing the title for Section 4.0—LNAPL Management Strategy. Meyers recommended making it clear that technology selection is the key activity covered by Section 4.0. Hay Wilson said that the authors decided against including the term “technology” in the title for Section 4.0 since institutional controls are also a viable management strategy.
  
  
• Add information to Appendix A. Tavelli agreed to send information to Kaback about what Wyoming does to ensure that stakeholder input is obtained. This information, Kaback said, could be included in the NMDF document’s Current Conditions Checklist.
  
  
• Add more references to Appendix C. This appendix provides references on characterization and remediation technologies that can be used to address LNAPL sites. Meyers suggested expanding the list. Kaback said that the authors recognize that the list is not comprehensive. The intent is to provide a few key references that direct readers to other sources of information. Attendees advised adding some statements to the appendix (and/or to the text in the main part of the document) stating that Appendix C is not meant to be comprehensive, that the list highlights some key references and Web sites that provide additional information on technologies, and that the NMDF document is not endorsing one technology over another. Kathy Yager recommended saying that the Alliance has determined that there is a need to compile references on different technologies and that such a list will be posted in the future on the RTDF Web site. This spurred discussion about the goals that the Alliance has for the NMDF document. In the group’s early days, Adamski noted, the EPA co-chair—Randy Breeden—said that the Alliance should offer input on which technologies worked the best at LNAPL sites. Zabcik verified Adamski’s comments, but said that the Alliance’s focus has changed since Breeden’s original statements were made. In later years, Zabcik said, the Alliance agreed to focus on establishing a decision-making framework first and to use case studies to provide commentary on the efficacy of specific technologies. While the Alliance had hoped to include such case studies as a separate appendix to the NMDF document, Kaback said, it has become clear that case studies will not be ready any time soon. Zabcik recommended adding a statement in the NMDF document indicating that case studies will be available through the RTDF Web site in the future. Meyers reminded the Alliance members that the original intent of the case studies was to provide examples of sites which have successfully implemented the NMDF strategy and not to focus on which technology was used.

Path Forward

Attendees decided that the following steps should be taken to move forward with the development of the NMDF document:

• Complete the internal Alliance review and revise the NMDF document. Kaback asked Alliance members to submit their written comments on the draft by May 30, 2003. Based on the comments she receives, Kaback said, she will revise the NMDF document and distribute the revised draft by July 1, 2003.
  
  
• Send the revised NMDF document to a broad set of regulatory reviewers. Alliance members agreed to seek the RTDF’s stamp of approval on the NMDF document. To obtain this approval, Yager said, EPA representatives must be comfortable with the NMDF document’s content and be allowed to participate in a formal review process. Toward this end, the following must be done:
  
  
• Generate a list of potential reviewers. Yager said that she has created a list of EPA representatives who might be interested in reviewing the NMDF document. Some of the people on the list work at EPA Headquarters, others work at the EPA laboratories, and some work within the regions (e.g., Regions 2, 4, 5, 6, 8, and 9). In addition, some EPA-sponsored groups, like the Groundwater Forum, are also included on Yager’s list of potential reviewers. Several attendees advised including state regulators on the review list. Gaining endorsement from at least some state representatives, Tavelli said, could help other state representatives appreciate the value of the NMDF document more fully. Carolyn Perroni advised including all of the state regulators who have participated on the Alliance’s Training Workgroup on the list of potential reviewers. Attendees thought this was a good idea.
  
  
• Establish contact with the reviewers. Yager said that she has contacted about half of the people who are listed as potential reviewers. She said that efforts should be made soon to contact the remainder and tell them about the deliverables that will be sent to them for review.
  
  
• Prepare a cover letter for the NMDF. Perroni will prepare a letter that describes the Alliance’s mission and the products that are in development. The letter will explain why EPA review is being sought for the NMDF document and why the RTDF stamp of approval is considered important. The letter will also mention that the Alliance is preparing a training program, which will be sent to reviewers in the near future. Perroni will send the letter to EPA’s Jeff Heimerman, who will work with the Alliance while Yager is away over the summer.
  
  
• Send the NMDF document out for review and schedule a conference call to introduce the document. Yager said that Heimerman will attach the cover letter that Perroni creates to the NMDF document and send it out to the list of EPA reviewers. Tavelli said that she would be willing to distribute the document to the state regulators who have been selected to participate in the review process. Soon after the NMDF document is sent to reviewers, attendees agreed, a conference call should be held between the reviewers and the Alliance. The intent of this call will not be to collect comments, but to let the Alliance explain why the document has been written and describe the history of the Alliance’s effort. Call participants agreed that it would be useful for the Alliance’s EPA co-chair (Christine Lehnertz) to lead the call. Kaback said that she is also willing to help lead the call and to describe the NMDF document’s content. (Kremesec and Tavelli said that they could also participate.) Some attendees discussed conducting an Internet seminar, using EPA’s CLU-IN site, to present the NMDF document to EPA and state reviewers. These seminars are formal slide presentations, presented over the Internet, coupled with conference calls that allow participants to ask questions and get answers as the presentation proceeds. Since EPA/TIO hosts these seminars on the CLU-IN site, Yager said it would not be a problem to use the system.
  
  
• Consolidate the comments in preparation for the Alliance’s next meeting. Yager said that the reviewers should be given 4 weeks to submit their comments, and that all comments should be directed to Kaback. Kaback agreed to consolidate the comments.
  
  
• Present information about the NMDF document at an upcoming conference. The 2003 RCRA National meeting is scheduled to take place in Washington, D.C., on August 12–15, 2003. David Zabcik recommended presenting information about the NMDF document at this meeting. Since many Alliance members are planning to attend this conference, he said, it might be beneficial to hold a full Alliance meeting in conjunction with the RCRA National conference. Tavelli expressed enthusiasm for this idea—many state regulators will attend the RCRA conference, and some of them might be interested in reviewing and commenting on the NMDF document. The Alliance members decided that it would be useful to coordinate the next Alliance meeting with the RCRA conference. Yager said that several concurrent sessions will take place during the conference, and that Alliance members could probably reserve a slot for a half-day session if they so desired. She said that she would ask Karen Tomimatsu whether this is possible and report her findings to Lyverse, Kremesec, Tavelli, and Zabcik, all of whom offered to help plan the next NAPL Cleanup Alliance meeting.

THE ALLIANCE’S TRAINING PROGRAM

Background Information

The RTDF NAPL Cleanup Alliance plans to release a series of training modules to (1) describe the technical aspects of NAPL distribution and mobility, (2) correct common misconceptions about NAPL, (3) present a NAPL conceptual model, and (4) explore NAPL management issues. An Alliance Training Workgroup has been created to help guide the development of the training program, which will consist of four modules: Module 1 (The Basics), Module 2 (NAPL Management), Module 3 (Advanced Topics), and Module 4 (Modeling). For now, the Alliance is only focusing on Modules 1 and 2.

The Alliance hopes to obtain the RTDF stamp of approval on the training modules. In order to obtain this stamp, the modules must be subjected to a broad EPA review. The review process will mirror the process described above for the NMDF document.

Module 1 (The Basics)
Vic Kremesec, BP America, Inc.
David Ariail, EPA, Region 4

EPA Region 4 provided the impetus for Module 1’s development, Kremesec said, when it asked BP America to develop online training programs on several topics, including LNAPL behavior. Before moving forth with a full report on Module 1’s status, Kremesec asked David Ariail to provide a more thorough description of the training initiatives that Region 4 is undertaking. In response to this request, Ariail presented an overview of the training programs that are being developed to support the region’s UST program.

Ariail said that employees who work under the UST program have extensive training needs. Providing training to all of them is a costly endeavor, especially if they are expected to travel to training events. To alleviate this problem, he said, Region 4 is committed to developing a series of online trainings. Toward this end, the region has pooled resources, hired contractors, and is working with BP America and university personnel to develop training programs. In addition, Ariail said, the Region 4 states have created a Region 4 Innovative Training Workgroup and are working with the Office of Underground Storage Tanks (OUST) to obtain funding to develop additional training modules. Spurred on by the Region 4 efforts, he said, OUST has created a UST/LUST National Training Workgroup and is now evaluating what must be done to implement a national program to address the training needs of UST/LUST professionals.

Kremesec thanked Ariail for the overview, then resumed his status report on Module 1’s development. He said that this module has almost been completed: 66 slides have been created, a script has been created, and audio has been generated for each of the slides. Additional site characterization information will be incorporated into the training program over the next couple of weeks. Once completed, the module will be sent to Region 4 and the NAPL Cleanup Alliance membership. Kremesec said that NAPL Cleanup Alliance members will be asked to review the module and submit written comments. BP America will revise the module based on the comments and rerelease the training package. This revised version will be sent to the broad list of EPA reviewers that Yager has identified (see the discussion above on the NMDF document).

Module 2 (NAPL Management)
Mark Adamski, BP America, Inc.

Adamski said that Module 2 is being developed to help people understand how the emergence of new NAPL conceptual models (a topic explored in Module 1) impacts NAPL management approaches. Module 2 is still in the initial stages of development. Adamski said that some of the Alliance Training Workgroup’s industry members prepared a strawman for the module in late 2002. That version, he said, was viewed as having too strong of an industry bias. In late January 2003, Tavelli agreed to alleviate this problem by revising the strawman to make it more acceptable from a regulator’s perspective and reorganizing the training topics to follow the organizational structure presented in the Alliance’s NMDF document. Tavelli placed her efforts on hold, however, when she heard that the NMDF document’s outline was still undergoing revision. Now that a draft of the NMDF document has been completed, Adamski said, Tavelli should feel free to resume her effort to revise the strawman. Tavelli agreed to do so; she will come to the next Alliance meeting prepared to present and discuss the revised version of the Module 2 strawman. Once the Alliance Training Workgroup agrees on the strawman, Hopkins said, API can ask one of its consultants to start developing slides for the Module 2 training program.

Attendees discussed the scope of the Module 2 training package. Adamski and Hopkins said that they think the training program should provide more detailed information than the NMDF document does. For example, Hopkins recommended including detailed information about what people need to do “to get real about endpoints.” Lyverse asked whether the Module 2 program will include information about how to address and manage imminent risk at sites. As acknowledged earlier in the meeting, he said, the NMDF document does not cover this topic. Lyverse said that the training package’s title—NAPL Management—implies that the package covers all phases of the NAPL management problem, including imminent risk management. His statement prompted some attendees to ask whether the training module should be renamed. Zabcik recommended Implications for LNAPL Management as one possibility. No decision was made about whether the title should be changed.

INTRODUCTION TO GROUNDWATER CENTRAL^©
Dawn Kaback, CTC

Kaback provided information about Groundwater Central^©, a multi-component portal that links people to information on ground-water science and technology. (The portal can be accessed by visiting http://www.groundwatercentral.info .) Kaback’s PowerPoint presentation, which is included as Attachment C (PDF, 1.6MB), provides detailed information about Groundwater Central^©. The highlights of her presentation are presented here. Kaback said that Groundwater Central^©has two components:

• A resource database. Groundwater Central^©uses a “smart” search engine to link to records on LNAPL, NAPL, dissolved or vadose zone hydrocarbons, petroleum oil lubricants (POLs), or oxygenate contaminants or technologies. At this time, she said, the link database is populated by more than 3,000 records. Records will continue to be added as time progresses. The “smart” search engine can search through multiple layers of Web sites to provide direct links to appropriate information. It is also equipped to perform advanced searches and to provide detailed reports of search results.
  
  
• A communications center. The Groundwater Central^©Communications Center currently has four features:
  
  
• An events calendar. Information about conferences, field trips, and request-for-proposal deadlines is posted on the calendar. Although all who register with Groundwater Central^©are allowed to post events on the calendar, postings have been sparse.
  
  
• Discussion forums. Bulletin boards have been created for seven topics: access, characterization and monitoring, contaminants, NAPL cleanup, physical setting, policy, and remediation technologies. All visitors can view information that has been posted to the bulletin boards, but only registered users can post new materials.
  
  
• The “Ask an Expert” service. Registered users can send experts anonymous questions on bioremediation, permeable reactive barriers, and thermal-enhanced remediation. Experts are expected to respond to questions within 2 weeks.
  
  
• Chat room. This feature allows users to chat directly with other users who are logged on to Groundwater Central^©at the same time.

Kaback said that Groundwater Central^© was officially launched on January 31, 2003. She and Yager asked Alliance members to visit the site and explore its features. After doing so, Alliance members should submit comments about the utility of Groundwater Central^©and offer recommendations on how to improve it. Kaback agreed to serve as the repository for the comments and to forward them to Yager.

Ariail asked whether the ground-water sites to which Groundwater Central^©provides links also link back to Groundwater Central^©. Kaback was not sure, but agreed to find out. Perroni advised sending an email to the webmasters who manage the sites to which Groundwater Central^©links, and asking them to establish a link to Groundwater Central^©. Lyverse asked whether Module 1 of the Alliance training could be made available through the Groundwater Central^©portal. Kaback said that this was possible.

UPDATE FROM THE CASPER REFINERY SUBGROUP
Jeff Hostetler, TriHydro Corporation

Hostetler provided information on behalf of the Casper Refinery Subgroup, a group that is using the decision-making process advocated in the NMDF document to develop a long-term NAPL management strategy at a former refinery site that is owned by ChevronTexaco. Hostetler said that the Subgroup recently completed a mobility study. The results indicate that 8 million gallons of NAPL are in the subsurface, and less than 2 percent of that NAPL is mobile and readily recoverable. Given this finding, Hostetler said, the Subgroup is now reexamining the goal that it originally set for the site to evaluate whether the goal is still practical. Now that he has a better understanding of the nature of the NAPL problem, Hostetler said, he doubts that the goal—to remove enough NAPL to enable natural processes to return ground-water quality to background levels or maximum contaminant levels (MCLs) within about 50 years after remedial engineering processes have been discontinued—is practical. As a result, the goal may require reformulation. Hostetler said that the Subgroup is currently working on the following:

• Performing more studies. Additional site investigation activities will be initiated in the near future. For example, a natural attenuation study will be performed and NAPL–ground-water partitioning/dissolution, volatilization, and biodegradation data will be collected. Among other things, Hostetler said, the investigations will be used to evaluate whether certain portions of the subsurface NAPL pose less risk than others.
  
  
• Applying to Wyoming’s voluntary remediation program (VRP). Once the Casper Refinery site enters the VRP, Hostetler said, public involvement will increase and ChevronTexaco will be expected to identify stakeholders who are deeply interested in the site. While the public has been involved to some extent already, Hostetler said, the collaborative stakeholder decision-making process is just now about to go into full swing at the Casper Refinery site.
  
  
• Finalizing a Current Conditions report. Hostetler said that ChevronTexaco has consolidated detailed information about human resources, material resources, and data into one report. The report is under review and will be finalized in the near future.
  
  
• Developing a remediation agreement. ChevronTexaco is in the process of developing a draft preliminary remediation agreement. The Wyoming Department of Environmental Quality and ChevronTexaco hope to sign a final remediation agreement by the end of 2005.
  
  
• Identifying innovative remediation technologies to use at the site. Hostetler said that the Subgroup is trying to generate case studies about the way innovative technologies have performed at LNAPL sites. To date, he said, the Subgroup has experienced much difficulty collecting case study information. Although the Subgroup knows this information exists, it is difficult to extract technical and cost performance data from the site managers and consultants who have those data. For this reason, Hostetler said, the Subgroup needs help from Alliance members in identifying contacts who are willing to provide such information. Hostetler said that he has generated a 1-page data profile sheet that lists the information the Subgroup is trying to collect. He will e-mail it to the Alliance members. He strongly encouraged Alliance members to submit completed data profile sheets or to submit the names of contacts who could provide such information. Hostetler said that the case studies might eventually be posted on an EPA Web site. If people are not comfortable having the information go public, he said, they do not have to include site names in their data profile sheets. Hostetler’s request for information spurred discussion about projects that might make good case studies. The following projects and potential contacts or resources were identified:
  
  
• ConocoPhillips’ water-flooding project. Greg Fletcher agreed to check with ConocoPhillips’ management to find out whether cost and performance data from a recent remediation effort could be released to the Subgroup. He said that he did not think ConocoPhillips would object to releasing performance data to the Alliance, noting that these data will be reported to the state in July 2003.
  
  
• An expert on bioremediation technologies. Tavelli recommended contacting an EPA representative who is an expert on bioremediation technologies for input on potential case studies.
  
  
• A trenching project. Westbrook said that trenching was successfully performed at an active refinery site, and that the experience obtained at this site might make an interesting case study.
  
  
• The CLU-IN Web site. Kaback said that CTC has been examining site profile information that has been posted on EPA’s CLU-IN site. Kaback said that she would let Hostetler know whether this information is relevant to the Subgroup’s data collection effort.
  
  
• BP America projects. Kremesec said that he could provide completed profiles and/or contact names for a biowall project, a bioventing project, a steam flood project, and a microwave project.

Lyverse asked Hostetler to discuss the long-term vision for the Casper Refinery site. Hostetler said that this vision can be separated into two components:

• Future land use. The goal is to use the site for light industrial use and some recreational purposes.
  
  
• Groundwater restoration. Wyoming’s nondegradation policy dictates that remedies focus on eventual reduction of ground-water contaminants to background concentrations or MCLs.

UPDATE ON THE EMANUAL PROJECT
Jim Higinbotham, ExxonMobil

Higinbotham provided information about API’s LNAPL eManual, a diverse set of tools that presents information on a variety of LNAPL topics. He said that the product, which will be available at no cost to the public, will be distributed as a CD-ROM. It will include educational information, checklists, an LNAPL management flowchart, calculation tools, remedial selection tools, assessment tools, and a broad range of other useful tools, including the most recent generation of LNAST.

Higinbotham said that the first draft of the eManual product was completed and presented to API on May 20, 2003. API members have been asked to review the eManual tool and submit comments by July 18, 2003. The final version of the product is scheduled for release on January 4, 2004. Once it is released, training forums will be held to provide additional information on how to use the eManual product.

NEXT MEETING

As noted above, the Alliance plans to hold its next meeting in conjunction with the 2003 RCRA National meeting that is scheduled to take place in Washington, D.C., on August 12–15, 2003. (The NGWA conference that is scheduled to take place in Costa Mesa, California, on August 20–22, 2003, was chosen as a potential backup meeting location.) Attendees agreed that the Alliance’s meeting agenda should include the following topics: (1) EPA’s comments on the NMDF document, (2) the revised Module 2 strawman, and (3) an update on the Casper Refinery site.

WRAP UP

Lyverse thanked everyone for their participation and said that he thought the meeting had been productive. He thanked Westbrook, of EPA Region 6, for hosting the meeting.

ACTION ITEMS

Several action items were identified during the meeting:

• In an effort to move forth with the development of the NMDF document:
  
  
  • Alliance members will send Kaback comments on the NMDF document by May 30, 2003.
    
    
  • Tavelli will send Kaback information that can be included in the NMDF document’s Appendix A: Current Conditions Checklist.
    
    
  • Kaback will distribute a list of EPA references that will be included in the NMDF document. Alliance members will review the list and let Kaback know of any citations that should be added to it.
    
    
  • Higinbotham and Hopkins will compare the NMDF flowchart with the one created for API’s E-manual toolkit. They will look for ways to harmonize the API flowchart with the NMDF toolkit. If they have any changes to recommend for the NMDF flowchart, they will submit their suggestions by May 30, 2003.
    
    
  • Kaback will revise the NMDF document based on the comments she receives from Alliance members and redistribute the document by July 1, 2003.
    
    
  • Yager will e-mail a list of potential reviewers to Alliance members. Perroni will make sure that the state regulators who participate in the Alliance Training Workgroup are added to Yager’s list.
    
    
  • Perroni will prepare a letter that describes the Alliance’s mission, projects, and products. She will send the letter to Heimerman.
    
    
  • Heimerman will send the NMDF document out to EPA reviewers with Perroni’s cover letter attached. (Yager will contact Heimerman to let him know that someone from the Alliance might be contacting him in July about distributing the NMDF document.) Tavelli is willing to distribute the NMDF document to state regulators.
    
    
  • Soon after the NMDF is sent to reviewers, the Alliance will hold a conference call to explain why the document has been written and describe the history of the Alliance’s effort. Call participants agreed that it would be useful for Lehnertz to lead the call. Kaback is also willing to help lead the call and to describe the NMDF document’s content. (Kremesec and Tavelli are also willing to participate.) Some attendees discussed conducting an Internet seminar, using EPA’s CLU-IN site, to present the NMDF to EPA and state reviewers. Since EPA/TIO hosts these seminars on the CLU-IN site, Yager said, it would not be a problem to use the system.
    
    
  • The EPA/state regulator reviewers will be given 4 weeks to submit their comments. Kaback agreed to serve as the repository for all of the comments and to consolidate them.
    
    
  • Attendees expressed interest in presenting information about the NMDF document at the 2003 RCRA National meeting that is scheduled to take place in Washington, D.C., on August 12–15, 2003. Yager said that several concurrent sessions will take place during the meeting, and that Alliance members could probably reserve a slot for a half-day session if they so desired. Yager will ask Karen Tomimatsu whether this is possible and report her findings to Lyverse, Kremesec, Tavelli, and Zabcik, all of whom offered to help plan the next NAPL Cleanup Alliance meeting.
    
    
• Kremesec agreed to send the most recent version of the Module 1 training package to Kaback as soon as he returned to the office. In a few weeks, Kremesec will send the module out to the entire Alliance for review. Alliance members will be given about 2 weeks to comment on the module. Once the Alliance is comfortable with the training program, it will be sent to a broader list of reviewers.
  
  
• Tavelli will prepare and distribute a revised version of the Module 2 outline before the next Alliance meeting. The revisions will be based, at least in part, on comments received from the Alliance’s Training Workgroup members. Hay Wilson asked Tavelli to let her and Kaback know whether any of the Workgroup members’ comments are relevant to the NMDF document. Tavelli agreed to look through the comments as soon as possible.
  
  
• Alliance members will visit Groundwater Central^©(http://www.groundwatercentral.info ), explore its features, and provide feedback on its utility. Kaback will collect the comments and send them to Yager.
  
  
• Kaback will find out whether the sites that Groundwater Central^©links to are linking back to the Groundwater Central^©page.
  
  
• Hostetler will send out blank data profile sheets to Alliance members. (The forms ask for information on LNAPL cleanup projects.) Alliance members agreed to help fill out the forms and/or name a contact who might be able to provide relevant information. In response to Hostetler’s request, Greg Fletcher agreed to check with ConocoPhillips’ management to find out whether information about a recently completed waterflood project can be released to the Alliance and developed into a case study. (He will ask whether cost data, as well as performance data, may be released.) Also, Kremesec and Westbrook offered to send Hostetler information and/or contact names.
  
  
• Perroni will send Alliance members an updated list of the Alliance’s e-mail notification list.
  
  
• Yager and Kaback will call Lehnertz and Breeden to let them know about the major decisions that were made during the Alliance meeting.

ATTACHMENTS A through C

Attachments A through C 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 May 2003 meeting summary.

Attachment A: Final Attendee List (PDF, 39KB)

Attachment B: Dawn Kaback’s presentation entitled Decision-Making Framework for Cleanup of Sites Contaminated With LNAPLs (PDF, 54KB)

Attachment C: Dawn Kaback’s presentation entitled GWRTAC’s Groundwater Central^© (PDF, 1.6MB)