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

EPA Conference Facility
Denver, Colorado
November 7-8, 2001

INTRODUCTION

Randy Breeden and Mark Lyverse, co-chairs of the Remediation Technologies Development Forum's Nonaqueous-Phase Liquid (NAPL) Cleanup Alliance, welcomed the meeting attendees (see Attachment A) and thanked them for their participation. Breeden asked for updates on activities that have occurred since the Alliance's June 2001 meeting. The following information was provided:

• EPA's Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action has been finalized and is now publicly available.



• Carolyn Perroni has contacted Concur to ask for copies of their report, entitled Finding Solutions for the Cleanup of the Largest Land-based Oil Spill in the United States: Utilizing a Neutral, Expert, Fact-Finding Panel in the Guadalupe Oil Field Mediation. Concur has agreed to distribute complimentary copies to Alliance members. Copies for other interested parties are available for a fee.



• EPA recently sponsored a source removal workshop. Kathleen Yager will distribute copies of the workshop summary to Alliance members once the summary has been finalized.



• There is still some interest in including a BP America site in the NAPL Cleanup Alliance. (Victor Kremesec should be contacted for additional details.)

TEXACO (CASPER REFINERY) TECHNICAL SUBGROUP
Jeff Hostetler, TriHydro Corporation

Jeff Hostetler provided a progress report on the Texaco Subgroup's activities. He noted that Subgroup members plan to conduct 160 to 180 laser-induced fluorescence (LIF) pushes and 20 Soil Video Imaging System (GeoVis) pushes at the Casper Refinery site. To date, about 50% of the LIF data (i.e., 80 pushes) have been collected. The site team anticipates that they will need four more days to reach their data-collection goals. John Meyers outlined the Subgroup's upcoming objectives:

• Identify product types. The LIF data will be used to generate maps of product intensity (amount of energy being returned). These intensity patterns will correspond to soil hydrocarbon composition.



• Determine saturation within each product type. Representative core samples will be collected to quantify soil saturation by each hydrocarbon product type. The site team anticipates collecting core samples in the month of December, hoping for a minimum of eight plugs per product type. Kremesec and Dawn Kaback suggested alternative core collection methodologies, noting that they increase the accuracy of saturation measurements.



• Correlate measured saturation with LIF intensity for each product type. Ali Tavelli said that the site team will compare core sampling results collected with the Site Characterization and Analysis Penetrometer System (SCAPS) and GeoVis. Once saturation is determined, the team will correlate saturation ranges with intensity and type of hydrocarbon found.

Hostetler noted that the field team is also trying to identify groundwater table depths via piezocone and SCAPS. He said that the SCAPS method yields a more refined picture of NAPL distribution than typical "lake" maps do. The latter assume relatively equal distribution of contaminants over less precisely sampled areas. Hostetler concluded by outlining some of the questions that remain to be answered for the site: (1) Will the SCAPS and core sampling provide adequate information on mobility? (2) Will the site team be able to use conventional techniques for the NAPL cleanup? (3) Where will innovative technology be needed? (4) Are there portions of the site's NAPL that are nonmobile and do not require cleanup?

TECHNICAL INFORMATION SUBGROUP
Dawn Kaback, Concurrent Technologies Corporation

Dawn Kaback said that progress is being made on the Groundwater Central Web portal. It is not publicly available at this time, but the design has been finished and the Web site is currently being populated with links. (There are currently about 300 links in the database, 85 of them specific to LNAPL.) Kaback said that the database will be searchable, giving examples of how many "hits" show up for different search terms. For example, she said, the term "NAPL Removal" elicits more than 100 responses, "LNAPL Remediation" yields 268 results, and "Soil Vapor Extraction" yields 63 results.

Lyverse suggested that summary reports, along with specifically-designed Internet searches, be written to address questions regarding:

• Regulatory agreements for LNAPL cleanup and technical impracticability (TI) waiver summaries



• NAPL mobility



• Treatment technologies for LNAPL

Meeting attendees agreed that information on these topics was not easily accessible. They decided to begin a search for related information by asking Department of Defense representatives about their decision-making procedures for NAPL/source removal subsequent to land partitioning and redevelopment. Perroni, Kaback, Breeden, David Zabcik, and Don Cunningham agreed to get in touch with their contacts. Breeden said that any information gathered about the presence (or absence) of unified NAPL management approaches (in the form of records of decisions, TI waivers, etc.) will be useful to the Alliance's Decision Framework Subgroup.

DECISION FRAMEWORK SUBGROUP
Mark Lyverse, Chevron Research and Technology Company

Lyverse said that the Decision Framework Subgroup plans to write a NAPL management plan; he distributed the most recent version of the document's preamble and outline. Meeting attendees offered the following suggestions for the document's format:

• Possibly break document into two parts: an outline and an appendix.



• Include a flow diagram that outlines the decision-making process. (For example, a diagram could be added to lead readers through the goal-setting procedures that are outlined in the first few sections of the document.)

Meeting attendees then reviewed the document's draft preamble. They recommended adding some additional information:

Meeting attendees then proceeded to review the document's outline, and solicited comments from the meeting attendees. The most up-to-date version is included as Attachment B.

OPEN DISCUSSION

Breeden mediated an open discussion session and asked participants to comment on the following:

Inviting State Regulators To Review the NAPL Management Plan

Meeting attendees agreed that the first draft of the NAPL management plan should be reviewed internally, but that subsequent versions should be reviewed by external entities as well. They expressed interest in inviting regional and state regulators to review the early drafts. (Names of potential reviewers were provided.) Yager suggested having the next Alliance meeting take place in conjunction with a corrective action meeting, noting that the latter attracts many regulators. She cautioned that regulators would need at least 2 months' advance notice of the Alliance's meeting. Attendees agreed that the next Alliance meeting should be held in spring 2002.

Alliance Resource Needs

Yager noted that EPA's Technology Innovation Office has been providing funds for the NAPL Cleanup Alliance's logistical support. She stressed that there are not enough funds available to cover the writing of the entire NAPL management plan. Alliance members will need to contribute money. Kaback agreed to draft a scope of work and budget proposal for the writing and editing of the document. Industry representatives agreed to use the proposal to ask their companies for contributions toward the document writing.

New Projects

Meeting attendees agreed not to undertake any new projects until the framework document is complete.

ACTION ITEMS

• Core team members will send Breeden the names of state regulators and EPA Regional contacts who should be invited to the spring 2002 meeting.



• Core team members will send Kaback (kabackd@ctc.com) information about Web sites that contain NAPL-related information that would be useful to link to the Groundwater Central Web portal.



• Yager will distribute the summary of EPA's recent source removal workshop once the summary has been finalized.



• Kremesec will follow up to determine whether a BP America site can be incorporated into a new NAPL Cleanup Alliance project.



• Carolyn Perroni, Kaback, Breeden, Zabcik, and Cunningham will speak with Department of Defense representatives to find out about their decision-making procedures for NAPL/source removal subsequent to land partitioning and redevelopment.



• All core team members will send comments on the revised NAPL management plan outline to Kaback no later than December 1, 2001.



• John Meyers will send Kaback his report, "Free Product Recovery Investigation Report May 2000," which might help the Alliance write the NAPL management plan.



• Kaback will send a proposed scope of work and a budget estimate for completing the NAPL management plan document, then send these to core team members (excluding EPA, Wyoming, TriHydro, and ThermoRetec).

ATTACHMENT A: ATTENDEE LIST

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

EPA Conference Facility
Denver, Colorado
November 7-8, 2001

ATTACHMENT B: OUTLINE FOR THE NAPL MANAGEMENT PLAN

1. Goals
   
   
1. Owner/operator (owner's expectations for the site)
1. Going to keep facility active or redevelop?
2. Managing for level of perceived risk?
3. Future land use--industrial, commercial, recreational, other?
4. Minimize costs while achieving regulatory goals
   
   
2. Regulator
1. Goals for the property
1. Time frame
2. Future land use (potential exposure routes)
3. Risk-based vs. non-risk-based
4. Cost
   
   
3. Stakeholders
1. Community, local governments, receptors, special interest groups, etc.
   
   
4. Regulatory structure/statutory requirements
1. Minimum regulatory requirements--Applicable and Appropriate Requirements that have to be addressed at the site
2. Regulatory program being applied
   
   
5. Mechanism to accomplish goals
1. Existing policies that allow flexibility to reach mutually acceptable goals
   
   
6. NAPL management goals
1. Established by considering:
1. Regulatory requirements
2. Current and future land use
3. Existing and/or potential receptors
4. Technology options
5. Interaction with other remediation measures (e.g., boundary control systems)
6. Stakeholder issues
7. NAPL distribution and characterization
8. Cost
9. Post-remedy risks/uncertainty analysis
10. Points-of-compliance
1. Where is the POC?
2. Is one needed? Why/why not?
2. What are the goals for NAPL recovery?
1. EI
2. Intermediate goals
3. Final remedy
4. Mobility reduction? mass removal?
   
   
2. Current conditions
   
   
1. Land use/ownership
1. Short term (e.g., present to 10 years)
1. Who owns the property and adjacent properties?
2. Who owns the liability of the property?
3. Is there an expected ownership change in the near future?
4. Is the facility active? closed? Or is this the site of a former facility?
1. How is the property/adjacent property being used?
2. How is the property/adjacent property zoned?
3. Are there institutional controls in place?
5. What adjacent/regional property development plans are underway or expected?
1. Do they fit with the community master plan?
6. Is it expected that adjacent property use will change?
2. Intermediate (e.g., 10 to 30 years)
1. Are any of the above conditions expected to change for this time frame?
3. Long term (e.g., more than 30 years)
1. Are any of the above conditions expected to change for this time frame?
   
   
3. Site conditions and characterization
   
   
1. Hydrogeological setting
1. Fluctuating water table?
2. Distance to water/NAPL?
3. Groundwater classification system?
4. Geological setting?
   
   
2. Soil properties
1. Soil lithologic and hydrogeologic properties in the interval that contains NAPL
1. Grain size distribution, porosity, effective porosity, hydraulic conductivity, etc.
   
   
3. Subsurface NAPL distribution
1. Major NAPL sources?
2. Release areas?
3. Estimated volumes?
4. Type(s) of NAPL?
5. Smear zone?
6. Potential for releases that would significantly impact the NAPL management strategy?
7. Other data
1. ROST, CPT, LIF, GeoVis, MIPS, etc.
   
   
4. Known fluid properties--ground water and NAPL
1. Current NAPL characteristics
1. E.g., vapor pressure, boiling point, distillation curve
2. Fluid properties that influence mobility
1. E.g., viscosity, density, interfacial tension, relative permeability
   
   
5. History of plume extent (liquid and dissolved phases)
1. What are plume dimensions over time? (maps)
1. How has the sampling program impacted the plume definition?
2. How has groundwater elevation impacted the plume definition?
2. Does modeling exist?
   
   
6. Recovery history
1. NAPL recovery history and significant aspects of the program (graphs)
1. Methods for recovery, time line, number of wells
2. Operational history
   
   
7. Current NAPL management program
1. What is the management philosophy for the NAPL?
1. Pumping, barriers, other means of stabilization? (How was the EI met?)
2. Perimeter control, aggressive recovery where warranted, memorandums of understanding?
3. Plume on-site/off-site?
   
   
8. Groundwater EI status
1. Approved, submitted, planned? (NAPL migration/groundwater under control?)
   
   
4. Existing and/or potential receptors (qualitative)
   
   
1. NAPL plume
1. Human/ecological
1. Water supply wells
2. Water bodies (lakes, streams, etc.)
3. Utility trenches
4. Buildings
   
   
2. Dissolved-phase plume
1. Human/ecological
1. Water supply wells
2. Water bodies (lakes, streams, etc.)
3. Utility trenches
4. Buildings
   
   
5. Remedial technologies considered and proposed--screening of technologies and identification of data gaps

(Similar to that used for general RCRA evaluations and ranking, but limited to technologies focused on NAPL remediation)

1. Types
1. Passive
1. Bioremediation
2. Phytoremediation
3. Containment
4. Monitored natural attenuation
2. Innovative/aggressive
1. SVE
2. TFE
3. Thermal
4. Surfactant
   
   
2. Ranking or metrics used to evaluate technologies?
   
   
3. Short list of technologies that may be used, given the stated cleanup goal(s) and existing site knowledge
   
   
4. Should a phased or combination technology remediation approach be used? (e.g., active followed by passive remediation)
   
   
5. What data gaps must be filled in order to complete the technology selection?
   
   
6. Practical removal
1. What is practical removal? (considering cost, risk, technical capabilities)
2. In what time frame? (considering cost, risk, technical capabilities)
3. Will lab, bench-scale, or field tests be required?
   
   
7. NAPL Mobility
1. How mobile is the NAPL?
2. What field evidence exists that supports plume stability or potential for migration?
   
   
8. Is it helpful to understand the process of benzene dissolution from the NAPL if meeting MCLs is an issue or goal?
   
   
9. Are vapors an issue (with respect to NAPL present or remaining) once removal goals are achieved?
   
   
10. Risks
    
    
11. Time
    
    
12. Surface disturbance
    
    
13. Other impediments that might influence technology selection
    
    
6. Supplemental NAPL investigation (if data gaps are present)--what decision/goal is your investigation intended to support?
   
   
1. What field engineering data must be obtained to quantify the NAPL distribution, volume, and mobility? (e.g., LIF borings, soil borings and cores, monitoring wells, hydrocarbon bail down tests)
   
   
2. What laboratory data must be obtained to quantify the NAPL distribution, volume and mobility? (e.g., fluid properties, soil properties, soil-fluid interaction properties)
   
   
3. What models and calculation methods will be used?
   
   
4. What field engineering and test data must be obtained to fill the technology selection data gaps (e.g., pilot tests, treatability tests, geotechnical tests)
   
   
7. Determining NAPL endpoints
   
   
1. Given all of the above conditions, formulate a preliminary comprehensive closure plan that includes:
1. The cleanup goal(s)
2. Measurable endpoint criteria (used to determine when the active remediation system(s) can be suspended)
3. The performance monitoring plan
4. The closure criteria
5. The compliance monitoring plan
   
   
2. What endpoint criteria must be met to be able to suspend active remediation?
1. E.g., mobility, ACL, soil concentration standard
   
   
3. How will the endpoint criteria be measured?
1. E.g., hydrocarbon bail down tests, groundwater concentration at the point of compliance, statistical confirmation soil sampling
   
   
4. What measurements, models, and calculation methods will be used?
   
   
5. What criteria must be met to demonstrate compliance with the goals?
1. E.g., mobility, MCL, ACL, soil concentration standard
   
   
8. Long-term site NAPL management plan
   
   
1. Use of institutional controls/deed restrictions
   
   
2. Financial assurance
   
   
3. Short term and intermediate goals
1. What performance monitoring will be undertaken during remediation to track system progress toward achieving the endpoint criteria?
1. Will the chemical footprint of the NAPL change over time?
1. How?
2. From upgradient to downgradient? vertically?
2. Is the plume degrading as one would conceptually think it might?
1. How will this be supported?
3. Mass removal tracking
4. Diminishing returns
2. What post-remediation compliance monitoring will be done to verify that the remediation system has achieved and maintained the goals?
3. Schedule/time line