SUMMARY OF THE REMEDIATION TECHNOLOGIES DEVELOPMENT FORUM
NAPL CLEANUP ALLIANCE
August 6, 2003
2:00 p.m.-3:00 p.m.
On August 6, 2003, representatives from the Remediation Technologies Development Forum's (RTDF's) Non-Aqueous Phase Liquid (NAPL) Cleanup Alliance held a conference call. The call was held to discuss the status of the Alliance's NAPL Management Decision Framework (NMDF). Over the last week, a draft version of this document was sent out to a wide range of reviewers, including state regulators and personnel from EPA. The NAPL Cleanup Alliance held this conference call to introduce the document to the reviewers and to address preliminary questions. The following people participated in the call:
Mark Lyverse, ChevronTexaco Energy Research and Technology Company (Alliance
Tom Aalto, U.S. Environmental Protection Agency (EPA), Region 8
David Ariail, EPA, Region 4
Leslie Hay Wilson, Sage Risk Solutions, LLC
Jeff Heimerman, EPA
Dawn Kaback, Concurrent Technologies Corporation
Bob Maxey, EPA, Office of Solid Waste
Ali Tavelli, Wyoming Department of Environmental Quality
Guy Tomassoni, EPA
Ron Wallace, Georgia Department of Natural Resources
Kathy Yager, EPA
David Zabcik, Shell Oil Products US Company and Motiva Enterprises
Also present was Christine Hartnett of ERG.
BACKGROUNDOVERVIEW OF THE RTDF AND THE NAPL CLEANUP ALLIANCE
Kathy Yager said that the RTDF, which was established more than a decade ago, brings representatives from industry, government, and academia together to work on hazardous waste problems. There are currently six active RTDF teams, one of which is the NAPL Cleanup Alliance. Yager said that EPA pushed for the formation of the Alliance after realizing that it would be beneficial to bring together people who were committed to looking at innovative solutions and improved strategies for the characterization, remediation, and long-term management of large petroleum sites (e.g., shipping terminals, tank farms, and refineries). In 2001, representatives from industry, consulting/engineering firms, state governments, and the federal government (e.g., EPA, the Department of Energy, the Navy, and the Air Force) rallied to the cause and created the NAPL Cleanup Alliance with the signing of a memorandum of understanding. To date, the Alliance has invested its energy in four projects:
THE ALLIANCE'S NMDF DOCUMENT
Yager, Mark Lyverse, David Zabcik, and Dawn Kaback joined forces to provide information about the NMDF document. Yager and Lyverse initiated the discussion by noting the following: (1) the document is not intended to serve as EPA guidance or a policy document, and (2) the Alliance leadership assumes that the document will be used to address sites where imminent hazards are already under control.
Lyverse said that the NMDF document is designed to help those who are working on large-scale LNAPL-contaminated sites develop reasonable and practicable approaches for addressing these sites. The document presents a framework that promotes consensus-building among diverse stakeholders, and it describes a process that can be used to develop long-term visions, goals, and realistic endpoints. The framework also promotes an iterative process and encourages stakeholders to revisit goals and objectives on a frequent basis. Yager said that the framework can be applied under a variety of regulatory scenarios, such as RCRA, CERCLA, or state programs. Lyverse and Yager said that the NMDF document helps readers think through the following issues: What stakeholders need to be at the table? What information needs to be collected? What needs to be done to characterize the site? How should the data be evaluated? What needs to be done to determine how much NAPL must be removed in order to make a site acceptable for its designated land reuse? Will using an aggressive remediation technology help reach the goals that have been established for the site?
Expanding on the points that Lyverse and Yager made, Zabcik said that the NMDF document will help stakeholders arrive at a collective decision that is best for a site. By working through the decision framework, Zabcik said, a site's stakeholders will formulate a common long-term vision, identify remedial technologies and endpoints that fit with the long-term vision, and arrive at a defensible decision on how to manage the site. Building on Zabcik's comments, Jeff Heimerman said that the document presents a conceptual model for LNAPL management strategy development.
Kaback emphasized the fact that the NMDF document is a process document--not a technical document. In an effort to make technical information available, however, the text does include links and references. Kaback asked the reviewers to let her know if additional technical resources should be added to the document.
Yager said that the Alliance hopes to publish the document with the RTDF's stamp of approval. Before this can happen, the document must receive wide review and input from the regulatory community. For this reason, it has been forwarded to state regulators and EPA personnel (e.g., representatives from Headquarters, the regions, the laboratories, and the Ground Water Forum).
Call participants asked the following questions:
Reviewers have been asked to submit comments on the NMDF document by August 22, 2003. Kaback will compile the comments, and the comments will be discussed at the Alliance's next meeting, which is scheduled to take place in Denver, Colorado, on September 10-11, 2003.
Yager said that she would like to have more state and EPA representatives participating in Alliance activities. She encouraged anyone interested in becoming more involved to contact her, Heimerman, or Ali Tavelli.