SUMMARY OF THE REMEDIATION TECHNOLOGIES DEVELOPMENT FORUM
NAPL CLEANUP ALLIANCE
CONFERENCE CALL

11:00 a.m.-12:30 p.m.
September 29, 2004

On Wednesday, September 29, 2004, the following members of the NAPL Cleanup Alliance met in a conference call:

Bob Maxey, U.S. Environmental Protection Agency (EPA) (Alliance Co-chair)
Harley Hopkins, American Petroleum Institute
Jeff Hostetler, TriHydro Corporation
Sanjay Garg, Shell Global Solutions, Inc.
Nigel Goulding, Ashland/URS Diamond Alliance
Rick Greiner, ConocoPhillips
Dawn Kaback, Concurrent Technologies Corporation
Martin Johnson, BP/Atlantic Richfield Company
John Meyers, The Retec Group, Inc.
Ellen Rubin, EPA
Brian Smith, TriHydro Corporation
Kathy Yager, EPA

Also participating in the call was Christine Hartnett from ERG.

WELCOMING NEW MEMBERS

Bob Maxey indicated that two new people have joined the NAPL Cleanup Alliance: Nigel Goulding and Rick Greiner. Maxey extended a welcome to them and thanked them for their interest in becoming involved with the Alliance's activities.

THE ALLIANCE'S NAPL MANAGEMENT DECISION FRAMEWORK

EPA is reviewing the Alliance's NAPL Management Decision Framework (NMDF); comments are expected by September 30, 2004. Kathy Yager acknowledged that the review process has been slow, noting that it took several months to determine exactly which office within EPA would perform the final review. This roadblock has been passed, however, and a specific contact has been assigned to review the document. Once comments are provided, the document will be sent to Dawn Kaback for modification. Yager said that she hopes that the document will be finalized by the end of the calendar year. She reminded call participants that the NMDF cannot be advertised as an RTDF-endorsed product until EPA completes its review.

THE ALLIANCE'S TRAINING PROGRAM

The NAPL Cleanup Alliance is developing a series of training modules that describe the technical aspects of NAPL distribution and mobility, correct common misperceptions about NAPL, and explore NAPL management issues. Module 1 (The Basics) and Module 2 (NAPL Management) of the training program were discussed during this conference call.

Status of Module 1's Development

A draft version of Module 1 has been completed and Alliance members have started presenting it to live audiences. The training package, which takes about 3 hours to deliver, consists of about 110 slides. Yager indicated that she plans to submit Module 1 to EPA for review as soon as the Agency completes its review of the NMDF. Maxey said that he believes the review process will go smoothly, noting that he plans to meet with his boss in October to explain why the training has been developed, what it entails, and why the RTDF is seeking EPA's review, and also to establish a plan and a schedule for the review process. In the meantime, Yager said, if Module 1 is delivered again before EPA completes its review, presenters should make it clear that the training package is still in draft form and that EPA has not endorsed it yet.

Status of Module 2's Development

Harley Hopkins said that a workgroup met (via conference call) on July 16, 2004, to discuss the latest draft of the Module 2 training package--a product that consists of about 30 slides. Hopkins said that Ali Tavelli plans to submit written comments on the product soon. When he receives her comments, Hopkins said, he will modify the slide presentation and send a revised version to Carolyn Perroni so that it can be distributed to the NAPL Cleanup Alliance Core Team. Responding to a question posed by Maxey, Hopkins indicated that the working title for Module 2 is currently "New Strategy for NAPL Management," but that he thinks "Rethinking Our Strategy for NAPL Management" might serve as a better title.

Delivering the Training Materials

As noted above, Module 1 has already been delivered to some audiences. For example, over the last few months, the training (or in some cases, an abbreviated version of the training) has been delivered to:

• Consultants and engineers attending an American Petroleum Institute (API)/National Ground Water Association (NGWA) meeting. This presentation was delivered in Baltimore, Maryland, on August 16, 2004. Vic Kremesec was the principal presenter; Maxey delivered about 10 slides.



• Regulators from Maryland. This presentation was delivered on August 19, 2004. Kremesec was the principal presenter, but Maxey and Mark Lyverse delivered some of the slides. Maxey said that the training was well received and that the audience asked good questions.



• Region 3 representatives. Maxey recently delivered an abbreviated version (45 minutes) of Module 1 at the annual EPA Region 3 meeting.



• Additional audiences. Maxey indicated that he thinks Kremesec has delivered Module 1 to three or four other audiences as well. For example, in recent months, the presentation has been delivered in Pennsylvania and Nebraska.

Call participants brainstormed about additional venues for the Module 1 workshop. They identified the following possibilities:

• EPA's UST/LUST National Conference. This meeting will be held in Seattle, Washington, in March 2005. Hopkins said that a solicitation for session topics was recently issued; he advised contacting the meeting organizers to obtain a slot on the agenda for the Module 1 workshop. Maxey thought this was an excellent idea and he agreed to follow up on it. Maxey asked whether the meeting organizers were interested in the abbreviated or the full-length version of Module 1. Hopkins said that he was not aware of any time restrictions.



• California. Martin Johnson said that BP would like to present the training to regulators in California, and he agreed to keep Maxey abreast of BP's efforts to set up a workshop. Maxey said that he or Ellen Rubin could help deliver the training if BP succeeds in setting something up.



• Kentucky. Nigel Goulding said that Ashland is interested in presenting the training to regulators in Kentucky. Maxey indicated that he could probably assist in delivering a presentation if a workshop is set up in this state.



• EPA's RCRA National Meeting. See the discussion under "Future NAPL Cleanup Alliance Meetings" for more information.

Alliance members also discussed the importance of thinking about how the training is packaged and marketed. At this point, John Meyers said, Alliance members are flying around the country and delivering the training at no charge to anyone who requests it. While such an approach does have several benefits, Meyers and Jeff Hostetler said that using such a haphazard approach could put the Alliance at risk of being perceived as something akin to a traveling salesman that is peddling products. Meyers noted that some groups, such as the Interstate Technology Regulatory Council (ITRC), charge a fee for training courses and issue formal brochures to advertise them. (An example of ITRC's brochure was distributed prior to this call.) Maxey said that he likes ITRC's brochure and that he would like something similar produced for the Alliance's training program. He was not as enthusiastic, however, about the idea of charging a fee. Some call participants agreed that it would not be beneficial to charge a fee at this time, but suggested considering charging consultants and other non-governmental trainees at some future date. If such a tack is taken, Yager and Rubin said, it would be best to have an organization like API or NGWA collect the fee.

Call participants agreed that it would be beneficial to develop a formal "Training Delivery Plan" to ensure that the training meets its initial goal: providing unbiased technical training to regional and state representatives. Hopkins offered to help develop the delivery plan, but he did not think it would be appropriate for him to take the lead on this effort.

FUTURE NAPL CLEANUP ALLIANCE MEETINGS

EPA plans to hold a RCRA national meeting in Denver, Colorado, on May 3 and 4, 2005. Call participants agreed that they should piggyback onto this meeting and hold a formal NAPL Cleanup Alliance meeting at the same location on May 5 and 6. Call participants also agreed that it would be beneficial for the Alliance to get onto the agenda for the RCRA meeting. Rubin said that she has already initiated this effort and that the meeting organizers are holding a 1-hour time slot on the agenda for the Alliance. Maxey advised focusing the 1-hour presentation on how the Alliance's products can be used to help the RCRA Corrective Action program meet its goal of achieving cleanups at all RCRA sites by 2020. He asked Hopkins to help put together the 1-hour presentation. Hopkins indicated that he was willing to do so. In addition to the 1-hour presentation, Rubin suggested presenting the 3-hour Module 1 workshop during one of the evenings or immediately before or after the RCRA National Meeting. While some call participants thought this was a good idea, Hopkins said that he was not sure that the meeting was the right venue for the workshop since the audience would largely consist of managers and nontechnical individuals.

Call participants also talked about meeting once (perhaps in January 2005) before the May 2005 RCRA national meeting. Yager noted that the Navy has expressed interest in presenting information about some of its LNAPL remediation work and in hosting the next Alliance meeting at one of its California sites (perhaps Port Hueneme or San Diego). Call participants expressed interest in this proposal and asked Yager to obtain more details on where the meeting would be held, what an agenda might look like, and whether a field trip would be included. Yager agreed to obtain this information from her Navy contact and to pass it on to Maxey and Lyverse for consideration.

RECRUITMENT EFFORTS—ENCOURAGING STATE REGULATORS TO PARTICIPATE IN THE NAPL CLEANUP ALLIANCE

Maxey said that interest has been expressed in encouraging more state regulators to participate in the NAPL Cleanup Alliance. Kaback said that past recruitment attempts have not been overly fruitful. Two issues have hampered the effort: (1) restrictions placed on state regulators prevent them from traveling to Alliance meetings, and (2) it has been difficult to identify the state-level people who deal directly with NAPL issues on a day-to-day basis. Despite these difficulties, call participants agreed to revitalize the recruitment effort and to do the following:

• Follow up with state representatives from the Region 3 area. As noted above, Maxey recently delivered an abbreviated version of Module 1 at the annual EPA Region 3 meeting. Maxey said that he used this opportunity to make a pitch for additional state regulatory participation. He agreed to follow up with some of the contacts that he established during the meeting to push the recruitment effort.



• Contact Chet Clarke from the Texas Commission on Environmental Quality (TCEQ). Hopkins said that TCEQ is starting to allow its employees to become more involved with national initiatives. This means that Clarke might be able to become involved with the NAPL Cleanup Alliance. Maxey agreed to contact Clarke and formally invite him to participate.



• Advertize at the ITRC meeting. Hopkins and Rubin plan to attend the ITRC meeting that is scheduled to take place in Albuquerque, New Mexico, during the week of October 25, 2004. They will talk to attendees about joining the Alliance.



• Ask EPA regional representatives to recommend state contacts. Hopkins recommended identifying the "NAPL gurus" in each EPA region and asking them to provide a list of the state-level people who deal with NAPL-related issues. Hopkins said that he is interested in identifying these contacts because they might be interested in (1) participating in the Alliance and (2) obtaining API's tools and products. Maxey agreed to send Hopkins a list of the EPA regional contacts.



• Solicit participation from those involved with the RCRA Corrective Action program. Rubin said that she plans to participate in a RCRA Corrective Action conference call that is scheduled to take place in October. During the call, she will encourage EPA regional representatives and state regulators to become more involved with the NAPL Cleanup Alliance.



• Put together a list of state regulators who are addressing refinery sites. Hopkins noted that refinery sites (as well as other NAPL-contaminated sites) are already being addressed across the country. For each site being addressed, a regulator has been assigned to ensure that the cleanup is performed properly. Hopkins advised generating a list of the specific regulators who have been assigned to these sites and inviting them to participate in the Alliance. Hostetler agreed to jumpstart the effort to put together the list, noting that he will ask his TriHydro colleagues to send him the names of state regulators who have worked on NAPL-contaminated sites. Maxey and Rubin said they are willing to call the people who appear on the list to personally invite them to participate in the Alliance.

IDENTIFYING ADDITIONAL NAPL-CONTAMINATED SITES TO ADDRESS UNDER THE ALLIANCE'S UMBRELLA

One site—the Casper Refinery site—is currently being addressed under the Alliance's umbrella. Maxey asked whether any progress has been made in identifying additional sites. Martin Johnson (representing BP), Nigel Goulding (representing Ashland), and Sanjay Garg (representing Shell) said that they would talk to their respective managers about identifying additional sites to address under the Alliance's umbrella. In addition, upon Maxey's request, Meyers agreed to ask Greg Fletcher (of Suncor) whether a NAPL-contaminated site located in Denver would be a viable candidate for inclusion. Maxey agreed to work with Lyverse to generate a more formal request for site participation. The request, which will be distributed as an email or a letter, will describe why the Alliance is seeking additional sites, discuss the benefits that site managers can expect from participating in the Alliance, and provide a list of the characteristics the Alliance is looking for in a test site.

ACTION ITEMS

In summary, the following action items were identified during the conference call.

• Yager will submit the Module 1 training package to EPA for review and approval. In an effort to help the review process proceed smoothly, Maxey will meet with his boss in October to explain why the training has been developed, what it entails, and why the RTDF is seeking EPA's review, and also to establish a plan and a schedule for the review process.



• Call participants will continue to brainstorm about venues for delivering the Module 1 workshop and the following activities will be performed:




—Maxey will contact the meeting organizers for EPA's UST/LUST National conference to obtain a slot on the agenda for the Module 1 workshop.

—Johnson will pursue the idea of delivering the training to audiences in California.

—Goulding will pursue the idea of delivering the training to audiences in Kentucky.

—Alliance members will develop a formal "Training Delivery Plan." (Hopkins offered to help with the plan's development, but he did not think it would be appropriate for him to take the lead on this effort.)

—Rubin will ask whether training opportunities exist when she participates in the RCRA Corrective Action conference call that is scheduled to take place in October.

• Hopkins will revise the Module 2 training package as soon as he receives comments from Tavelli. Once it has been revised, Hopkins will send the package to Perroni for distribution to the NAPL Cleanup Alliance Core Team.



• Hopkins will help Maxey put together a 1-hour presentation for the RCRA National meeting that is scheduled to take place on May 3 and 4, 2005. Rubin will make sure that a paragraph describing the Alliance's presentation is submitted to the meeting organizers. ERG will start making arrangements to hold an Alliance meeting at the same location on May 5 and 6.



• Yager will follow up on the idea of holding an Alliance meeting in January 2005. Toward this end, she will contact Navy representatives to determine whether they are still interested in hosting the meeting, where they would like to host it, and what presentations they would like to deliver. Yager will communicate her findings to Maxey and Lyverse. If necessary, a conference call will be set up to make a final decision about whether to hold an Alliance meeting in January 2005.



• Call participants will continue to recruit additional state regulators. Toward this end, the following will be done:




—Maxey will follow up with representatives from the Region 3 area. He will also contact Chet Clarke to formally invite him to participate in the Alliance. In addition, Maxey will send Hopkins a list of the "NAPL gurus" that exist in each EPA region.

—Hopkins and Rubin will solicit new recruits at the ITRC meeting, which is scheduled to take place during the week of October 25, 2004.

—Rubin will solicit participation from those involved with the RCRA Corrective Action program when she speaks to these representatives during an October 2004 conference call.

—Hostetler will start developing a list of state regulators who have worked on NAPL-contaminated sites. Other Alliance members will be encouraged to add names to the list. Once a list has been compiled, Maxey and Rubin will call all of the people on it to personally invite them to participate in the Alliance.

• Call participants agreed to do the following to promote the effort to identify additional sites to address under the Alliance's umbrella:




—Maxey will work with Lyverse to generate a formal request for site participation.

—Johnson, Goulding, and Garg will talk to their respective managers about identifying sites.

—Meyers will ask Greg Fletcher (of Suncor) whether a NAPL-contaminated site located in Denver would be a viable candidate for inclusion.