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

November 9, 1998
12:00 p.m.-1:30 p.m.

On November 9, 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)
Jim Brown, Roy F. Weston
Evelyn Drake, Exxon Research and Engineering
Steve Geiger, RETEC, Inc.
Peter Kulakow, Kansas State University (KSU)
David McMillan, ARM Group
C.M. (Mike) Reynolds, U.S. Army Cold Regions
Steve Rock, EPA
David Tsao, Amoco Research Center
Duane Wolf, University of Arkansas

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

UPDATE ON CONTRACTUAL AGREEMENTS AND POTENTIAL SITES

Chevron

Steve Rock said he hopes to have the Cooperative Research and Development Agreement (CRADA) between Chevron and EPA finalized by mid-November. He said the CRADA was reviewed by several EPA representatives, one of whom told Rock that he needed to reword the language regarding work performed by the Hazardous Substances Research Center (HSRC). Rock said that he has altered the CRADA so that the language is now within the boundaries of EPA's contractual laws. Lucinda Jackson asked whether Chevron's lawyers will need to review the changes. Rock said he did not think this would be necessary.

Peter Kulakow, who is currently updating the TPH Subgroup site database, said he has received site descriptions for Chevron's Ohio and California sites. Jackson said activities are underway at the California site and that baseline samples will be collected in mid-November. She said planting is scheduled for the first week of December and noted that Kulakow will be onsite to assist.

Amoco

Rock said EPA is close to finalizing a CRADA with Amoco. Kulakow noted that seven Amoco sites are currently listed in the TPH Subgroup site database and asked whether all are still being considered for field testing. David Tsao said some of the sites should be removed from the database. Currently, Amoco only has three sites, located in Texas, Rhode Island, and New Mexico, that are being considered for field demonstration projects. In the future, Tsao noted, one or two additional sites might be added to the list.

Tsao said he plans to conduct activities at the Texas and Rhode island sites under the Amoco-EPA CRADA. He said he would like to initiate field work in spring 1999, but is waiting for the Rhode Island and Texas regulatory commissions to grant approval for the demonstrations.. (Rock recommended sending a letter explaining that EPA is supporting phytoremedial technologies. He noted that this approach helped California regulators feel comfortable about granting approval for Chevron's California field study.) As for the New Mexico site, which is a gas pit sludge site, Tsao said he hopes to conduct this field study under the Petroleum Environmental Research Forum (PERF)-EPA CRADA. He said he is still unsure, however, whether this site can be used because site owners have not yet granted approval.

PERF

Evelyn Drake said Exxon's lawyers are drafting a PERF contract that has a CRADA attached. Under this arrangement, Drake explained, PERF participants (i.e., Exxon, Chevron, Amoco, ELF Aquitane, and Phillips Petroleum Company) will sign the PERF contract and one contract coordinator (i.e., Drake) will sign the CRADA with EPA. Although the CRADA will only be signed by one person, Drake stressed that the language in the CRADA must be agreeable to all PERF participants.. Drake said Exxon's lawyers have generated some comments on a draft CRADA (dated August 1998). Rock said a more up-to-date version is available; he and Drake agreed to talk off line about the CRADA.

Drake noted that two sites will be evaluated under the PERF-EPA CRADA. Although it has been agreed that Chevron's California site will serve as one of the PERF test sites, the location of the other is still in question. As noted above, Tsao said he is hoping that one of Amoco's New Mexico sites will serve as the other PERF site. Drake asked whether Tsao has a backup if the New Mexico site cannot be used. Tsao said he was under the impression that the second PERF site must be a gas pit sludge site and noted that he has few potential sites that fall into that category. Drake said it would be preferable to use a gas pit sludge site, but that it is not an absolute requirement. In that case, Tsao said, the Rhode Island and Texas sites (see above) can be considered as backups. Drake said the PERF contract will simply state that two sites, one provided by Chevron and the other by Amoco, will be studied under the PERF-EPA CRADA.

Site in Kansas

Kulakow said KSU would like to initiate a field demonstration project at a military site in Kansas in spring 1999. Kulakow said some of the analyses (e.g., TPH analysis) would be conducted in-house, but said he knows the Subgroup would prefer to use outside laboratories (e.g., Battelle and ADL) for certain analyses. Kulakow said he is trying to secure funds to have at least the initial and final sampling batches analyzed at outside laboratories. He asked whether Subgroup participants felt this was sufficient. Conference call participants did not provide an answer. Rock asked whether Kulakow knew of any funding sources that might be willing to contribute to KSU's project. Kulakow said the Army has been generous. Phil Sayre asked Kulakow whether he thought additional funds could be raised if the Subgroup distributed a letter that explained how important it is to adhere to the protocol. Kulakow said he would talk to a site representative about the best approach to take in the effort to raise additional funds. Rock said that he would talk to Kulakow about the topic in more detail offline..

Site in Arkansas

Duane Wolf said the University of Arkansas would like to conduct a field demonstration project under the TPH Subgroup program. He said sufficient funds are available and that he did not foresee any problems with establishing a CRADA between the University and EPA. Wolf said he would like to conduct a greenhouse feasibility study in the winter and initiate field activities in the spring. Before doing so, Wolf said, he needs input from the Subgroup on whether the proposed Arkansas test site should be included in the field program. Wolf said the site consists of several small pockets of contaminated soils that surround numerous wellheads. He said the contaminated areas are much too small for a 20-foot by 20-foot plot to be established. He said a block of three treatments could be established at each wellhead, but that four wellheads would need to be included in the study to generate four replicates. Wolf said he is concerned that using this approach will generate a fair amount of variability. (Wolf noted that the amount of weathering that has occurred varies dramatically [e.g., 3 to 10 years] across different parts of the site.) Wolf said the University's statistician told him that his proposed approach was acceptable. Nevertheless, Wolf said he wants the Subgroup's opinion before proceeding with his plan. Wolf agreed to summarize his concerns in an E-mail and to distribute it to conference call participants.

Jim Brown said that he has experience working at a site that is similar to the one Wolf described. The site, Brown reported, was located in western Kentucky and contained several wellheads that were surrounded by small areas of surface contamination. At this site, Brown continued, TPH concentrations and weathering indices ranged dramatically across the site because different wellheads had different leaking histories. Like Wolf's site, contaminated areas at the western Kentucky site were too small to establish large treatment plot sizes. To solve the problem, Brown said, soil was excavated from each wellhead and consolidated into one larger area. Kulakow asked whether saline conditions were present around the wellheads. Brown said he did not think saline conditions were detected at the western Kentucky site.

Sites in the Northeast

The following conference call participants indicated that they know of potential field study sites in the northeastern United States:

• David McMillan. McMillan said he is working with a client who plans to initiate field demonstration projects at two sites in central New York. McMillan said the client would like to initiate these projects under the TPH Subgroup. He said the client reviewed a draft CRADA and did not have substantial objections to the agreement proposed. McMillan said that internal funding issues must be resolved before his client will be ready to sign a CRADA.
• Steve Geiger. Geiger said that he is also working with a client who plans to initiate a field demonstration project in the Northeast. Geiger said the client has several sites that could be used for the project and is in the process of choosing one. Geiger said the characteristics at the site will likely be similar to those at the central New York sites that McMillan mentioned.

Sites in Alaska

Mike Reynolds said his group will conduct field studies at three Alaskan sites, located in Barrow, Galena, and Ketchikan. Kulakow said the TPH Subgroup site database currently has information on the Barrow and Galena sites. Reynolds agreed to send him information on the Ketchikan site. Reynolds said field characterization samples have been collected from all three sites and are currently being analyzed by Battelle. He noted that the Subgroup's protocol recommends collecting T_-1 and T₀ samples, but said his team combined these efforts in one sampling trip because of the high expense associated with traveling to Alaska. Reynolds said the Galena and Ketchikan sites have been fertilized and planted. At the Barrow site, these activities have been postponed until June 1999.

Site in Indiana

Kulakow asked for an update on activities at a potential site in Bedford, Indiana. Rock said he thinks a phytoremediation demonstration project will be initiated at this site but was unsure of the starting date. He said site representatives have agreed to change their plot size to 20 feet by 20 feet.

TPH SUBGROUP SITE DATABASE

As noted previously, Kulakow is updating the TPH Subgroup site database. He said he would like to collect detailed information about initial site conditions from each of the sites. To do this, he plans to:

• Establish a working relationship with site managers. Kulakow said he already has a strong working relationship with the site managers at the Chevron sites. He said it is important to establish relationships early in the demonstration process. By doing so, he explained, the Subgroup can encourage managers to generate a clear picture of initial site conditions. Kulakow stressed the importance of conducting agronomic soil testing before field activities are initiated. He said KSU can perform agronomic analyses, but stressed that a number of other laboratories are also qualified in this area. Geiger asked whether KSU uses different procedures to analyze soil from different regions. For example, Geiger noted, measuring available phosphorus in Western soils requires a different procedure than that used for Northeastern soils. Kulakow said KSU would make sure that the appropriate procedures were used for each region. He said KSU would recommend taking the samples to another laboratory if it did not have the capabilities to perform a certain procedure.
• Generate a form for site managers to fill out. Kulakow said he started developing a list of the type of information that should be included in the TPH Subgroup site database. If this form is distributed to site managers, he explained, similar information can be collected for each site. Kulakow said he will develop the form and distribute it to conference call participants before the next conference call.

Kulakow agreed to distribute the TPH Subgroup site database after it has been updated. He agreed to distribute the database to Drake, Geiger, and conference call participants who have potential sites listed in the database.

RTDF WEB SITE

Sayre said Union Carbide asked for a copy of the Subgroup's protocol. Sayre said several versions of the protocol are available on the Web site but none are easy to locate. Rock said he would talk to ERG and EMS about having the protocol presented more prominently on the Web site. Sayre also said he would like to have a map, depicting potential field study sites, posted on the Web site. Reynolds said that he drafted a map several months ago. Kulakow and Reynolds agreed to work together to update the map so that it depicts those sites that are currently being considered for field demonstrations. Once the map is updated, Reynolds said, he will forward the map to Sayre and Rock. (Sayre noted that some sensitivity had been expressed about listing potential sites on the public Web site. Conference call participants agreed, however, that the locations on the map would be general enough to protect site confidentiality.)

ANALYTICAL LABORATORIES

As noted in previous conference calls, the Subgroup identified Arthur D. Little (ADL) and Battelle as two analytical laboratories that the Subgroup can use. Conference call participants talked briefly about topics related to the laboratories, including:

• Using a standard sample. During previous conference calls, the Subgroup agreed that a standard crude oil sample should be sent to ADL and Battelle. The standard sample, the Subgroup had decided, should be analyzed with every sample batch to ensure that each laboratory is providing accurate results. Kulakow asked whether the standard has been prepared. Drake said it has not. She said the Subgroup could either (1) create a spiked sample, or (2) use a well-homogenized sample collected from an actual site. Jackson said a sample from Chevron's California site could serve as a potential stock for the standard. She said Chevron is planning to collect soil from this site in mid-November and agreed to have extra soil sample sent to ADL. Assuming the polycyclic aromatic hydrocarbon (PAH) levels in Chevron's sample are low, Drake said, the Subgroup should strongly consider using this as a standard. (Drake noted that PAH concentrations should be low to ensure that the laboratories' methodologies are adequately sensitive.)
• Consistency between protocols. Kulakow asked whether the Subgroup has confirmed that ADL and Battelle will be using the same analytical procedures to analyze the Subgroup's soil samples. Reynolds said he is fairly confident that the two laboratories are operating under the same protocols. He said the laboratories are located near each other and many of their personnel have migrated between the laboratories.
• Archiving. Kulakow asked whether soil samples will be archived at the laboratories. Rock, Reynolds, and Jackson said they will.

MICROBIAL ANALYSIS

Rock recently reviewed Attachment 5 of the Subgroup's protocol. He said this section describes four different microbial analysis techniques. As it is currently written, Rock noted, it is unclear whether (1) the microbial analysis is optional and (2) any of the recommended methods are preferred over one another. He asked conference call participants for input on these topics. Geiger said he does not think his client will perform microbial analysis. Reynolds said he thought the Subgroup had decided to make microbial analysis optional. His team, Reynolds noted, has opted to perform fairly extensive microbial analysis and has developed its own protocol. He agreed to distribute the protocol to conference call participants. Tsao said the decision to use microbial analysis will be made on a site-by-site basis at the Amoco sites. In cases where state regulators want the analysis performed, Amoco plans to use Kathy Banks' microbial analysis methodology.

TPH WORKING GROUP METHODOLOGY--DERIVING RISK-BASED TPH CLEANUP LEVELS

Geiger said the TPH Working Group has developed a methodology to calculate risk-based TPH cleanup levels. He said the methodology involves a direct analysis technique, where TPH is extracted with pentane and then fractionated, via various treatments, into aliphatic and aromatic compounds. Using this methodology, Geiger explained, TPH is divided into 13 fractions based on equivalent carbon numbers. Each fraction is then evaluated for its toxicity and a risk-based cleanup level is calculated using the risk-based corrective action (RBCA) program. (Geiger said eight different toxicity values are used for the 13 fractions.) Geiger stressed that the methodology calculates a risk-based cleanup level based on noncarcinogenic risks. Carcinogens (e.g., benzene and PAHs) are screened out. As such, Geiger continued, the methodology is most applicable at sites with weathered materials.

Geiger said that some states (e.g., Massachusetts and Michigan) have started using the TPH Working Group methodology. He noted that valuable data could be generated if the Subgroup opted to follow this methodology. He said using this risk-based tool could help convince regulators of the merits of using phytoremedial technologies as a polishing technology. If the Subgroup can show that phytoremediation reduces TPH levels below risk-based cleanup levels, regulators would likely be impressed by the technology.

Drake, Jackson, and Reynolds expressed interest in using the TPH Working Group methodology. Geiger thought it would be sufficient to use the fractionating methodology on just initial and final soil samples and said that additional soil quantities would not need to be collected. Geiger and Drake thought ADL and Battelle would be capable of performing the analysis. Drake warned, however, that this analysis was not included in the laboratories' initial cost estimates. Geiger agreed to make some phone calls to determine how much it costs to fractionate TPHs.

Geiger noted that the risk-based analysis must be performed by a risk assessor who is familiar with the TPH Working Group methodology. Reynolds asked whether one person could calculate the values for all of the individual Subgroup teams. Geiger thought this was feasible and noted that the analysis is not overly time-consuming because it simply entails a Tier I analysis and plugging several default values into the RBCA program.

Geiger agreed to distribute a writeup to conference call participants that would provide: (1) an overview of the TPH Working Group methodology, (2) an explanation of what can be gained by using the methodology, and (3) costs associated with fractionation.

MISCELLANEOUS

Kulakow asked whether the proposed TPH Subgroup test sites offer a wide range of petroleum hydrocarbon contamination situations. Specifically, he asked whether the range will be broad enough so that the Subgroup's work can be generalized. Rock said the Subgroup will focus primarily on weathered materials.

NEXT CONFERENCE CALL

The next conference call is tentatively scheduled for Monday, December 7, 1998. Rock agreed to have the call set up.

ACTION ITEMS

• Drake and Rock agreed to talk offline about the PERF-EPA CRADA.
• Kulakow said he would talk to a site representative about how to generate additional funds for a demonstration project at a military base in Kansas. Rock said that he would talk to Kulakow about the topic in more detail offline.
• Wolf noted that he was concerned about using small plot sizes at his proposed field demonstration site. He agreed to summarize his concerns in an E-mail and to distribute it to conference call participants.
• Reynolds agreed to send Kulakow information on the Ketchikan, Alaska site.
• Kulakow said he started developing a list of the type of information that should be included in the TPH Subgroup site database. Kulakow said he would distribute the list to conference call participants before the next conference call.
• Kulakow agreed to distribute the TPH Subgroup site database after it has been updated. He agreed to distribute the database to Drake, Geiger, and conference call participants who have potential sites listed in the database.
• Rock said he would talk to ERG and EMS about having the Subgroup's protocol presented more prominently on the RTDF Web site.
• Kulakow and Reynolds agreed to work together to create a map that depicts potential TPH Subgroup field demonstration sites. Once updated, Reynolds said he would forward the map to Sayre and Rock.
• The Subgroup agreed that a standard crude oil sample should be sent to ADL and Battelle. Jackson said a sample from Chevron's California site could serve as a potential stock for the standard. She said Chevron is planning to collect soil from this site in mid-November and agreed to have extra soil sample sent to ADL.
• Reynolds agreed to distribute a microbial analysis protocol to conference call participants.
• Geiger agreed to distribute a writeup to conference call participants that would provide: (1) an overview of the TPH Working Group methodology, (2) an explanation of what can be gained by using the methodology, and (3) costs associated with TPH fractionation.
• The next conference call is tentatively scheduled for Monday, December 7, 1998. Rock agreed to have the call set up.