SUMMARY OF THE REMEDIATION TECHNOLOGIES DEVELOPMENT FORUM
PHYTOREMEDIATION OF ORGANICS ACTION TEAM
TOTAL PETROLEUM HYDROCARBON (TPH) IN SOIL SUBGROUP
CONFERENCE CALL

October 19, 1998
12:00 p.m.-1:30 p.m.

On October 19, 1998, the following members of the Phytoremediation of Organics Action Team, Total Petroleum Hydrocarbon (TPH) in Soil Subgroup, met in a conference call:

Lucinda Jackson, Chevron Corporation (RTDF Action Team Co-Chair and Subgroup Co-Chair)
Phil Sayre, U.S. Environmental Protection Agency (EPA) (Subgroup Co-Chair)
Evelyn Drake, Exxon Research and Engineering
Peter Kulakow, Kansas State University (KSU)
David McMillan, ARM Group
David Tsao, Amoco Research Center

Also present was Christine Hartnett of Eastern Research Group, Inc. (ERG).

UPDATE ON CONTRACTUAL AGREEMENTS AND POTENTIAL SITES

Petroleum Environmental Research Forum (PERF)

Evelyn Drake noted that four or five companies in PERF plan to participate in the TPH Subgroup's field study program. The companies that have expressed interest include: Exxon, Chevron, Amoco, ELF Aquitane, and Phillips Petroleum Company. In previous discussion, Drake noted, the TPH Subgroup agreed that PERF participants would be required to contribute $20,000 each and would be collectively responsible for field studies at two sites. She said that Chevron has already submitted their $20,000.

Although it has been agreed that a Chevron site in California will serve as one of the PERF test sites, the location of the other is still in question. David Tsao said he is hoping that one of Amoco's New Mexico sites will serve as the other PERF site, but noted that political conflicts prevent him from committing at this time. Drake expressed strong interest in having Tsao lead the remediation efforts for the second PERF site. If that is not possible, Drake said, Phillips Petroleum Company has a potential site in Lubbock, Texas.

Drake asked whether PERF participants could sign a single Cooperative Research and Development Agreement (CRADA) with EPA rather than negotiating individual CRADAs for each company. Phil Sayre said he spoke to Larry Fradkin about this topic and learned that either approach would likely be acceptable. He did note, however, that some problems were encountered in the past when single contracts were used.

Drake said it would be easier if a single PERF-EPA contract was negotiated. She said Exxon's lawyers have drafted a PERF contract that has a CRADA attached. Under this arrangement, Drake explained, PERF participants would sign the PERF contract and one contract coordinator would sign the CRADA with EPA. Drake said the contract coordinator would be a PERF representative and would negotiate agreements with EPA on behalf of all the PERF team members. Drake said a contract coordinator has not officially been assigned, although she has been taking the initiative to date. She noted that Lucinda Jackson and Tsao would also make suitable contract coordinators. Drake said Exxon's lawyers have noted a few changes that will need to be made to the CRADA before it is acceptable to PERF companies. For example, the CRADA's language will need to be changed to reflect the fact that Exxon is self-insured. She noted that the participating PERF companies will need to review the CRADA carefully to make sure each company's needs are met under one CRADA. Sayre said he would contact Fradkin and let him know Drake's preference for signing a single contract. Sayre said he did not think this would prove to be a problem.

Amoco

Tsao noted that Amoco may have as many as four sites participating in the Subgroup's field testing program. As noted above, one of the sites is located in New Mexico and site activities would be conducted under the PERF contract. The other three sites, he reported, are located in Rhode Island, Texas, and Illinois. Tsao stressed that participation of the latter site was not completely certain. Field work for these three sites, he explained, would be conducted through a CRADA negotiated directly between EPA and Amoco rather than through the PERF contract. He said that EPA and Amoco are close to finalizing their CRADA.

Chevron

Like Amoco, Chevron will be participating in the RTDF program under two different contractual agreements: (1) the PERF contract and (2) a CRADA negotiated directly between Chevron and EPA. Jackson said Chevron plans to conduct field studies at sites located in California, Texas, and Ohio. She said activities at the California site will be conducted under the PERF contract and activities at the other sites will be conducted under the EPA-Chevron CRADA.

Site in Upstate New York

David McMillan said he hopes to convince the owners of an upstate New York site to participate in the Subgroup's field testing program. He described the site as a highly contaminated area with free product and polycyclic aromatic hydrocarbon (PAH) concentrations ranging from 50 to 1,000 parts per million (ppm). He said two parties are involved: (1) the company that owns the mess, and (2) the organization that owns the land. He said both parties are interested in using phytoremediation, but that the land owners cannot commit to the project until they resolve issues with New York state regulators. McMillan said land owners are meeting with the state in October 1998 and that it should soon be evident whether the site will be included in the Subgroup's field testing program. McMillan noted that he and Steve Geiger, a representative from RETEC, are working from "opposite ends of the same stick" to promote participation. Assuming they are successful, McMillan agreed to contact Fradkin to discuss CRADA issues.

In the summer of 1998, McMillan reported, investigators performed a small-scale suitability study at two areas within the site to test the viability of grass and willows. Since that time, McMillan continued, the viability experiment has been replicated in four other areas and plants have been shown to grow at PAH concentrations as high as 1,000 ppm. Interestingly, McMillan noted, native plants do not grow as heartily as the grass and willows.

KSU

In previous conference calls, KSU had indicated that they might have sites to include in the Subgroup program. During this conference call, however, Peter Kulakow said that it appears that activities at these sites are not progressing fast enough to meet the Subgroup's timeline.

Other Potential Sites

During previous conference calls, Sayre and Jackson noted, interest in participating in the Subgroup's program was expressed by:

• Mike Reynolds. Sayre said that Reynolds has sites in Alaska and possibly Korea that could be included in the Subgroup's program. Assuming Reynolds does participate, Sayre said, he would do so under an interagency agreement rather than a CRADA. Kulakow agreed to contact Reynolds for an update. Sayre asked Kulakow to let him know what Reynolds says.
• Duane Wolf. McMillan said that Wolf was still considering participating in the Subgroup's program. He said he would ask Wolf to contact Sayre. Kulakow agreed to contact Wolf as well and to report his findings to Sayre.

CHOOSING ANALYTICAL LABORATORIES

In previous conference calls, the Subgroup discussed which analytical laboratories to use for sample analysis. Drake said the topic was discussed at great length because Subgroup participants expressed concern that (1) only a small number of laboratories have the ability to analyze PAHs at the required accuracy level, and (2) data might not be comparable across different laboratories. Drake said the Subgroup contacted Arthur D. Little (ADL) and Battelle and that both agreed to analyze the Subgroup's samples for an exceptionally discounted rate. Drake said the Subgroup decided using either laboratory would be acceptable.

McMillan noted that his clients prefer to use a university laboratory and asked whether this would be allowed. Drake said it would be, provided that the university laboratory proves it is capable of equaling ADL and Battelle's precision. Drake said Exxon is preparing a spiked sample that will be sent to all participating laboratories. The sample, she said, will be run with every sample batch to ensure that analytical testing provides the appropriate level of sensitivity. McMillan said his clients would be willing to send samples to ADL if the university laboratory does not prove to be sufficiently sensitive.

CONTRACTS WITH ANALYTICAL LABORATORIES

Jackson asked how the TPH Subgroup wants to handle contractual agreements between itself and analytical laboratories. Two options were suggested:

• Establishing one contract between the laboratory and the entire TPH Subgroup.
• Establishing multiple contracts between the laboratory and individual participating team members.

Sayre noted that ADL and Battelle offered discounted rates under the assumption that they would receive a large number of samples from the Subgroup. He asked whether signing individual projects would jeopardize the discounted rate. Conference call participants concluded that this would probably not be the case. McMillan thought samples processed under individual contracts could probably be applied to the overall Subgroup total. McMillan said his clients prefer to sign individual contracts rather than being included in one blanket contract. After much discussion, the participants agreed that individual contracts should be established between the analytical laboratories and each organization or company. Using this approach, Drake noted, the laboratory will bill each company directly. For samples collected at the two PERF sites, she explained, the laboratory will bill the PERF contract coordinator directly.

Jackson asked how quickly the contract could be established between ADL and PERF. She stressed that urgency is needed because Chevron is ready to collect samples from their California site. Drake recommended establishing a temporary letter contract rather than waiting for formal contracts to be finalized. She said she would look into forwarding Chevron's $20,000 to ADL.

Conference call participants asked for information on ADL's discount offer as well as the standard language that should be included in each contract. Drake said she would send ERG a letter detailing ADL's rates and turn-around times. ERG agreed to distribute the information to other conference call participants.

UPDATE ON SITE INFORMATION DATABASE

Sayre noted that the Subgroup generated a table summarizing site information several months ago. He agreed to send the table to Drake and Kulakow. Kulakow agreed to update the information in the database by contacting listed site owners. Jackson and Drake recommended collecting information on site locations, soil contaminant levels, and the type (e.g., aged or diesel) of hydrocarbon contamination. It was agreed that Kulakow should start collecting data rather than waiting for CRADAs to be signed. Once updated, Sayre noted, the database will be distributed to other Subgroup members via fax or mail.

MISCELLANEOUS

Tsao asked if BP has been informed of the phytoremediation project. Drake said Terry Walden was involved with the laboratory phase before moving to Europe. She said she knows of a contact who is following up on Walden's interests. She agreed to call the contact and to let that person know about the Subgroup's activities. She also agreed to send the contact's name and telephone number to Tsao.

McMillan said he was interested in learning more about ADL's analytical protocols. Drake agreed to send McMillan, Sayre, and Kulakow a packet of information about different protocols.

NEXT CONFERENCE CALL

The next conference call is scheduled for Monday, November 9, 1998, from 12:00 to 1:30 EST.

ACTION ITEMS

• Sayre said he would contact Fradkin and let him know Drake's preference for signing a single PERF contract.
• McMillan agreed to contact Fradkin to discuss how to establish a CRADA between EPA and a site in upstate New York.
• Kulakow agreed to contact Reynolds and Wolf to ask them about the status of their sites. Sayre asked Kulakow to let him know what they said.
• McMillan said he would ask Wolf to contact Sayre.
• Sayre agreed to contact Steve Rock to inquire about additional potential sites.
• Drake recommended establishing a temporary letter contract between PERF and ADL rather than waiting for formal contracts to be finalized. She said she would look into forwarding Chevron's $20,000 to ADL.
• Drake said she would send ERG a letter detailing ADL's rates and turn-around times. ERG agreed to distribute the information to other conference call participants.
• Sayre noted that the Subgroup generated a table summarizing site information several months ago. He agreed to send the table to Drake and Kulakow. Kulakow agreed to update the information in the database by contacting listed site owners. Once updated, Sayre noted, the database will be distributed to other Subgroup members via fax or mail.
• Drake agreed to call Terry Walden's contact person. She also agreed to send the contact's name and telephone number to Tsao.
• Drake agreed to send McMillan, Sayre, and Kulakow a packet of information about different analytical protocols.