WEBVTT 00:00:01.000 --> 00:00:21.000 With that very quick visual tour, looking at my clock, I think we are about ready to begin. So I'm going to call our presenter up to the screen. So, Tom, I will encourage you to come on camera, and as we are getting ready for that, I'll also ask you, once you get your camera on and I've situated your video, I will go ahead and ask you to start sharing your screen. 00:00:21.000 --> 00:00:33.000 So, Tom, I'm going to put your spotlight up as you begin sharing the screen with our live audience, and I wanted to introduce everyone to our speaker. Amish Rubin, who is a scientist here in EPA's Office of Underground Storage Tanks. 00:00:33.000 --> 00:00:53.000 He has been here in Aus where he's concentrating on insurance and cleanup issues, and he started his career as an environmental engineer in 1981. Back in 1986, he joined EPA oust to help write federal OST regulations and to assist in state regulatory programs and state funds with the release prevention and corrective action issues. 00:00:53.000 --> 00:01:08.000 Since his first time with House, he developed and managed several environmental insurance programs, redeveloped numerous contaminated properties, and helped tank owners and state underground storage tank cleanup funds recover costs from insurers, responsible parties, equipment manufacturers, and installation contractors. 00:01:08.000 --> 00:01:18.000 He is also participated in the development of numerous ASTM and UL standards, and is currently chairing ASDM's Moving Sites to Closure Task Group. 00:01:18.000 --> 00:01:27.000 So with that introduction, Tom, I want to thank you for being here. I can confirm we can see your slides. Just one last request, if you can click that hide button at the bottom middle. 00:01:27.000 --> 00:01:36.000 on the little floater. Perfect. Your slides look great. I encourage you to unmute your mic and take it away from here, Tom. 00:01:36.000 --> 00:01:51.000 and let me see, Tom, if you need any assistance, I'm going to push a button. And let's see if you get that pop up. 00:01:51.000 --> 00:01:52.000 I'm unmuting. Thank you. Now I'm going to share again. 00:01:52.000 --> 00:02:10.000 There we go. Excellent. 00:02:10.000 --> 00:02:11.000 You're doing great. 00:02:11.000 --> 00:02:27.000 Okay, really, I'm going to get there. Alright, thank you. Thank you, everyone, for, uh, for joining today. I really appreciate you taking the time to listen to this presentation. I'm a long-time listener to Clue In, and I've really appreciated the clue in throughout my career. 00:02:27.000 --> 00:02:34.000 And this is my first time presenting on Kluen, so I'm really honored to be here today as a presenter. 00:02:34.000 --> 00:03:04.000 Um… The things I want to cover today, several topics. I'm going to give a little bit of technical background to how we got to the Moving Sites to closure standard, and then… talk about two EPA, I guess, position papers. The first one is a clarification on free product removal, which is in our reg, the federal reg. And then talk about our exposure threat assessment policy statement. 00:03:06.000 --> 00:03:10.000 Then we'll talk about the… ASTM standard. 00:03:10.000 --> 00:03:15.000 And finally, I want to talk a little bit at the end about implementation. 00:03:15.000 --> 00:03:22.000 Um, and how we see that potentially going forward. 00:03:22.000 --> 00:03:31.000 This is our problem statement that we started with in the ASTM task group, and this is why I came back to EPA back in 2001. 00:03:31.000 --> 00:03:38.000 Uh, we have… this is, what, 50,000 open underground storage tank release cases looks like. 00:03:38.000 --> 00:03:56.000 And every state's got some, and some have more than others, but we're we've had this persistent sort of very difficult to close storage tank releases. We've closed 500,000 releases in this program, which is. 00:03:56.000 --> 00:04:03.000 truly astounding when you think about it. I mean, we started… when I started in this program back in the late 80s. 00:04:03.000 --> 00:04:16.000 And, uh, we knew the mountain was very high, and we had no idea if we'd ever reached the top. We did reach that top. We've been working away at this. We've closed 500,000 sites so far. 00:04:16.000 --> 00:04:25.000 Um, but we just have this $50,000 to go, which are… which are a little bit… have been proving a little difficult. 00:04:25.000 --> 00:04:34.000 So, just before we get started, I wanted to see if we could do a poll question and sort of get a feel for where people are. 00:04:34.000 --> 00:04:50.000 All right, so I'm going to pop back here on the screen and launch the poll. So everyone, you should see a pop-up window that is now appearing on the screen asking, in your experience, what is the most frequent reason that a petroleum UST releases cases essentially do not reach closure? 00:04:50.000 --> 00:05:09.000 And you'll be presented with options such as lack of funding, a non-responsive owner, no access to properties to perform site assessment, LNAP will in the monitoring well is above state standards, or groundwater contamination above state standards. So you're going to pick what you think is the most frequent reason and then click the circle to the left, and then hit submit. 00:05:09.000 --> 00:05:25.000 I'm looking at it, and of the 450 or so of you here, almost 300 of you have voted. If you're participating as a team in a conference room, sharing one entry, you'll have to fight it out amongst yourselves and come to consensus, and just pick an answer. We quickly want to get a. 00:05:25.000 --> 00:05:39.000 A quick set of input from everyone. I'm going to go ahead and close this poll out here. So if you haven't voted, now is your time. If you haven't and can't see it, you can always just send a message in through the Q&A if you'd like to respond in writing that way. Let me close the poll here out. 00:05:39.000 --> 00:05:48.000 In three, two, one, and share those results. So Tom, while there is a distribution. 00:05:48.000 --> 00:06:05.000 It does look like they, uh, about 40% of the audience, that was the most popular response, felt that groundwater contamination above state standards was the most frequent reason why petroleum us release case would not reach closure. 00:06:05.000 --> 00:06:11.000 That's awesome. Should we go on? 00:06:11.000 --> 00:06:22.000 Okay. So let's just go back a little bit in time to back when I got into the business of underground storage tanks back in the '80s. 00:06:22.000 --> 00:06:36.000 Back at that time. we were dealing with very conservative, sort of worst-case cleanup standards, um, and it was… and they were sort of universally applied, and it wasn't very site-specific. 00:06:36.000 --> 00:06:51.000 And if you couldn't dig it up, or pump it out, it was gonna stay in the ground. Very limited remedies, and we knew that biodegradation was taking place, but we really didn't know much about it. 00:06:51.000 --> 00:07:07.000 Through the 90s, we developed this source pathway receptor concept that you all are probably very familiar with. We developed methods for determining site-specific target cleanup levels. There was a blossoming of. 00:07:07.000 --> 00:07:22.000 cleanup methods, lots of in situ methods, um, just a ton. We have an amazing array of cleanup technologies available to us now. And we developed, through the 90s, we developed tests for biodegradation. 00:07:22.000 --> 00:07:37.000 Now, coming to today. Uh, current best practices, we're using a lot of screening distances, there's a lot of focus on stability, which we're going to talk about more in the presentation, and alternative endpoints. Again, the subject of Mystic. 00:07:37.000 --> 00:07:51.000 Um, in the remedial methods, a lot of the recent work has focused on recoverability and natural source zone depletion and ways to enhance natural biodegradation. 00:07:51.000 --> 00:07:59.000 Um, and for natural degradation, we now know that you can rely on biodegradation at every single site. 00:07:59.000 --> 00:08:10.000 We don't… the rate may differ from site to site and situation to situation, but we know that every single petroleum must release site has biodegradation occurring at it. 00:08:10.000 --> 00:08:17.000 And we've gotten really good at calculating the rate of biodegradation at those sites. 00:08:17.000 --> 00:08:28.000 And I want to go now to the to our conceptual model. This is out of the standard, and I've kind of got a little cartoon to go with it. 00:08:28.000 --> 00:08:33.000 So, if you have a UST release, um, it's going to make, uh. 00:08:33.000 --> 00:08:40.000 It's gonna have liquid petroleum go in the ground, and that NAPL will. 00:08:40.000 --> 00:08:55.000 Some will dissolve into the groundwater, some will evaporate into the soil vapor, and that soil vapor, it's coming off of both the NAPL and off of the dissolved phase of the, you know, the groundwater. 00:08:55.000 --> 00:09:12.000 And what we worry about is, are those fumes coming up into homes. We worry about people drinking that water through drinking water wells that contaminated water. And we're worried about, you know, the idea is that eventually it's going to reach a. 00:09:12.000 --> 00:09:20.000 a daylight point, it's gonna hit a river, a stream, a lake, and then it could affect the ecology in the. 00:09:20.000 --> 00:09:24.000 Uh, in the… where it comes out in daylights. 00:09:24.000 --> 00:09:40.000 Um, so this is… when I got into this business back in the 80s, this was kind of the conceptual model in our, in our heads. And, you know, is that really true? We've done a lot of… there's been a lot of good science done, there's been a lot of experience gained. 00:09:40.000 --> 00:09:54.000 through all the cleanups that we've conducted, and we now know that that's kind of, like, an overly conservative view of what happens underground with the petroleum release. 00:09:54.000 --> 00:10:02.000 realistically, and what we see site after site, is that the plume reaches a maximum length. 00:10:02.000 --> 00:10:18.000 And then it kind of stalls out for the dissolve phase, what happens is the biodegradation that's happening at the leading edge of the plume is keeping up with the movement of groundwater and the dissolving of new contaminants into that groundwater. 00:10:18.000 --> 00:10:31.000 So it reaches a maximum length and stops there. And what happens in the Vegos zone is the vapors come up and they degrade in the ground. 00:10:31.000 --> 00:10:49.000 some… if it's in an anaerobic condition, they're degrading to methane, and if it's aerobic, they're degrading to CO2. And if you've got enough distance still, your methane will further degrade once it gets aerobic into carbon dioxide. 00:10:49.000 --> 00:10:59.000 So, if you're monitoring… if you're drinking water well is inside that zone, it's going to stay contaminated for a long time. If it's outside that zone. 00:10:59.000 --> 00:11:07.000 It's not gonna get contaminated, because it's past the maximum length of the… of the plume. 00:11:07.000 --> 00:11:15.000 And over time, the degradation is going to make the plume shrink, and also it's going to make the. 00:11:15.000 --> 00:11:19.000 Uh, it's going to reduce the contaminants in the. 00:11:19.000 --> 00:11:34.000 Uh, in the Elmapple as well. So it's… it's degrading from within, and it's degrading from the edges, uh, and making it smaller. Eventually, it's going to get small enough that we don't have to worry about it anymore. 00:11:34.000 --> 00:11:49.000 So, just a few science-y slides here. There's been a ton of work done, we call them plumathon studies, has been done examining these large databases that we have of sites and all the site monitoring results. 00:11:49.000 --> 00:11:57.000 And we have learned that there's a statistical distribution of length of plume. 00:11:57.000 --> 00:12:16.000 And every site reaches a maximum distance. We haven't been able to predict how far that maximum distance will be, but we know that every site does reach a maximum distance for each contaminant. Mtbe goes further typically than benzene. 00:12:16.000 --> 00:12:28.000 And the 50th percentile is a lot shorter than the 90th percentile, but we've proved this in numerous studies that there is a maximum. 00:12:28.000 --> 00:12:38.000 that these sites reach. So, knowing that, you know, that really kind of changes our conceptual model. 00:12:38.000 --> 00:12:50.000 Also, I wanted to show this slide again based on thousands of sites. This is sort of average. This is the average or the median, I'm sorry, it's the median. 00:12:50.000 --> 00:13:06.000 concentration in the source area of releases, and you can see that over time, the concentrations are going down of the, um, of the constituents in that. 00:13:06.000 --> 00:13:14.000 of that petroleum. And this kind of looks like a first order decay curve, but it's not totally smooth. 00:13:14.000 --> 00:13:31.000 It's got bumps, it's got ups and downs, not every, um… the different components of the gasoline or the diesel will degrade at different speeds, but eventually, it's pretty clear that the plume will eventually. 00:13:31.000 --> 00:13:37.000 reach a very low level. 00:13:37.000 --> 00:13:53.000 And then one more slide. This is kind of our new version of a conceptual model, and we're it's got the… it's got the area of NAPL sort of at the center, and it's above and below the water table, and we've got groundwater moving. 00:13:53.000 --> 00:14:10.000 and dissolving out some of the constituents, and we've got vapors coming off, and now we know, like, 70% of the losses from this plume, or from this LNAPL area, go to go through the vapor phase. 00:14:10.000 --> 00:14:21.000 the dissolve phase is a very small part of the… of the total concentration, or the total mass in underground. 00:14:21.000 --> 00:14:37.000 Um, and we've done throughout history, we've looked at the dissolve phase with monitoring wells, and we're really only… we now understand, we're really only looking at sort of a shadow of the actual contamination that's underground. Most of it's in the NAPL. 00:14:37.000 --> 00:14:57.000 or volatilizing out into the atmosphere. The rate of degradation, there's a lot of… there's ASTM has a whole standard on how to measure the rate of natural source zone depletion, and there are… there's a lot of debate about it, and it varies from site to site, varies. 00:14:57.000 --> 00:15:08.000 by an analytic method that you use, but there's a lot of good work being done in that area now. 00:15:08.000 --> 00:15:23.000 So that's our… that's kind of what we know now as our sort of new generic conceptual model. Knowing that EPA a couple of years ago, we decided to clarify. 00:15:23.000 --> 00:15:29.000 Uh, the… what is in our standard for free product removal. 00:15:29.000 --> 00:15:45.000 Under the federal standard, we have a sort of two stages of cleanup, and the first stage is automatic, everyone has to do it. If you've got free product that's migrating into clean areas, you've got to mitigate that, remove it. 00:15:45.000 --> 00:15:53.000 to the maximum extent practicable. And that's sort of the automatic… you don't need a regulator to tell you to do it, you just gotta do it. 00:15:53.000 --> 00:16:07.000 And then the second stage of cleanup is you develop a corrective action plan, you assess the site fully, develop your corrective action plan, and figure out how you're going to protect human health and the environment. 00:16:07.000 --> 00:16:24.000 So for that first stage, the sort of the immediate response stage, that's when, uh, that's where we get this free product removal requirement, and we issued a clarification as a response to a questions that we received. 00:16:24.000 --> 00:16:38.000 that says… You need to address product or NAPL that's in the ground that's migrating. In other words, that's spreading laterally to clean areas. 00:16:38.000 --> 00:16:46.000 Since we wrote the standards back in the 80s, when we wrote the standards back in the 80s, the term was free product. 00:16:46.000 --> 00:17:01.000 And that was all we used. Now, in sort of more recent times, we've developed this LNAPL divided into three different categories, residual, mobile, and migrating. 00:17:01.000 --> 00:17:07.000 Migrating, meaning it's spreading laterally because there's head pressure on that napple, and it's… and it's moving. 00:17:07.000 --> 00:17:24.000 It's making the plume bigger and a bigger footprint. Mobile meaning that it's going up and down with the water table, it could accumulate into monitoring wells. And that's mobile, but you really can't recover it very easily. 00:17:24.000 --> 00:17:38.000 And then residual is it's bound up with the soil particles, and no matter what you do, it's going to kind of stay there, uh, and it's just going to degrade in place, or you could maybe… it'll evaporate, some will evaporate off. 00:17:38.000 --> 00:17:58.000 So, what we said in this… in this clarification was you the first part of it, the automatic part of it, is really only focused on NAPL that's spreading laterally, that's migrating, and that you should address the residual and the mobile NAPL as part of your overall corrective action plan. 00:17:58.000 --> 00:18:06.000 And if it's… if it… if you can protect human health and the environment without removing that El Napol. 00:18:06.000 --> 00:18:14.000 that's mobile or residual, then, then it can stay in place. 00:18:14.000 --> 00:18:34.000 And that's a big change. Epa never really said anything about it before. It's a big change for some of the states. They looked at that and said, well, that isn't how we address it. But this is what we, this is our interpretation of our rules, and this is what applies to our sites in Indian country. 00:18:34.000 --> 00:18:47.000 The other thing we've done recently is, since the ASTM standard came out, since the Mystic standard came out, EPA issued a policy statement or a that. 00:18:47.000 --> 00:19:03.000 that encourages… our state programs to end… and our regional offices to look at their inventory of open releases. So, some states have hundreds, some states have a couple thousand. 00:19:03.000 --> 00:19:18.000 take a look at your open releases and assess them again on, like, a desktop review using modern science, using our latest techniques, and look at it knowing now what we know. Many of our sites have been in. 00:19:18.000 --> 00:19:30.000 been monitored for 20 years now, and so you've got all that additional knowledge that you had… didn't have when you first set the cleanup goals at the very beginning of the corrective action. 00:19:30.000 --> 00:19:38.000 So we're asking our programs to re-examine their open sites and take a look at them again. 00:19:38.000 --> 00:19:56.000 And then, you know, when you re-examining them, focus on the… focus your resources on the high-threat sites and close the low-threat sites. As we've been doing this in Indian country, we have found that, you know what, 15 years ago, when this site first started. 00:19:56.000 --> 00:20:11.000 We didn't address the vapor intrusion issue or nobody's actually sampled the drinking water well that's next door to the release site. Maybe we should go sample that well. So we've been finding exposure potential. 00:20:11.000 --> 00:20:20.000 Um, as we go back and review these sites and treat those as a higher threat and schedule them for additional investigation. 00:20:20.000 --> 00:20:37.000 We've also found a lot of sites that are low threat and are just open because there's maybe… maybe they haven't met their initial cleanup goal, or, you know, for various reasons. Maybe they still have measurable NAPL in the monitoring well. 00:20:37.000 --> 00:20:46.000 And if it's a low threat site, we're encouraging our programs to close those sites and focus their resources on the higher threat sites. 00:20:46.000 --> 00:21:01.000 We also, in this paper, uh, suggest, because 50,000 is a lot of sites to review, we're suggesting make that review process open and transparent so that the owners and their consultants can participate in this, and they can. 00:21:01.000 --> 00:21:13.000 They can also make these, you know, these reviews and make a proposal to the… to the regulator, and that's a lot simpler than the regulator doing the review themselves. 00:21:13.000 --> 00:21:31.000 And then also, you said in this policy paper that you should consider looking at the ASTM moving sites to closure standard for a framework for how to do these assessments. There are other ways to do it. We're not saying that the ASTM method is the only way to do it. 00:21:31.000 --> 00:21:41.000 Um, but we're saying it's a good and it's a sound standard. Uh, it's based on a lot of good science and a lot of good thought went into it. 00:21:41.000 --> 00:21:57.000 So what is a threat assessment? A lot of people use threat assessment and risk assessment interchangeably. We've tried to draw a distinction between them as we worked on the MISTIC standard and as we worked on the policy statement. 00:21:57.000 --> 00:22:03.000 The way… the way we've been looking at it, threat assessment is the first step to a risk assessment. 00:22:03.000 --> 00:22:10.000 And threat assessment is, do I have contaminants reaching or potentially reaching a receptor? 00:22:10.000 --> 00:22:17.000 And then risk assessment takes that information, goes one step further, and says if it's going to reach the receptor. 00:22:17.000 --> 00:22:28.000 Is the concentration of it, or the amount of it, is that going to be a… is that going to cause sickness, disease, injury, destruction of ecosystem? 00:22:28.000 --> 00:22:36.000 So, with threat assessment, there's really only three answers to are my receptors threatened? 00:22:36.000 --> 00:22:52.000 The first one is no, and if it's not threatened, then can I demonstrate that? Can I prove it to the public and to, you know, skeptics? Do I have the data to show that it's actually low threat? And if it is low threat, can I close the corrective action? 00:22:52.000 --> 00:23:02.000 And if it is a threat, do I have a remedy in place? Does the remedy need more work? Is it making adequate progress? 00:23:02.000 --> 00:23:18.000 And then all too often, what we're finding is we're doing these file reviews is we don't know if the receptors are threatened. And so the outcome of the threat assessment is, what data do I need to understand the current threat? So it'll identify those data gaps. 00:23:18.000 --> 00:23:25.000 that we need to close so that we can complete that threat assessment. 00:23:25.000 --> 00:23:33.000 Benefits of threat assessment. I think this is probably well know in the industry to you all on this call. 00:23:33.000 --> 00:23:44.000 But recognizing, you know, finding threats you didn't really recognize before vapor intrusion, drinking water wells that could be contaminated, that's really important. 00:23:44.000 --> 00:24:01.000 We're finding that these threat assessments that we're doing, we're doing them on sort of a checklist format. They turn out to be really good ways to communicate to the public and to communicate to the owners and officials. 00:24:01.000 --> 00:24:19.000 tribal officials when we're doing our tribal sites. It's easier to understand sort of a narrative of what's getting impacted or not impacted than to hand them a table of numbers and to say, oh, these concentrations are good or these concentrations are bad. 00:24:19.000 --> 00:24:26.000 That tends to cause, you know, a lot of members of the public's eyes to glaze over. 00:24:26.000 --> 00:24:52.000 And knowing what's residual, what's at the sites, what threats are out there, that's really good for people planning, for people trying to redevelop properties, understanding those threats and how… severe they are, how threatening they are, is really key to getting some of these abandoned properties redeveloped and put back into good use. 00:24:52.000 --> 00:25:06.000 And then also, concentrating on your high-threat sites and closing out your low-threat sites, that's a much more efficient use of cleanup funds and for staff. 00:25:06.000 --> 00:25:11.000 So, just wanted to talk a little bit about this… about the Mystic standard. 00:25:11.000 --> 00:25:19.000 Um, it took a long time to develop. It is definitely the biggest standard I've ever worked on, the longest standard I've ever worked on. 00:25:19.000 --> 00:25:34.000 Uh, we had a 90-person task group. It was the biggest task group I've ever chaired. It was a little bit of a wild group. We met monthly and had a lot of really good arguments and discussions. We had about, I think, almost 20 people. 00:25:34.000 --> 00:25:50.000 were writers of the standard, which is a really good contribution level. But everybody on the task group was really great about reviewing drafts and getting in comments and participating in the discussions. 00:25:50.000 --> 00:25:57.000 So we had… we… it was a really successful group. We published in May of 2025. 00:25:57.000 --> 00:26:13.000 Um, after two rounds of balloting, and ASTM is a really good consensus process. And throughout that process, we did talk to our states and had a lot of comments and input from, uh, from our state programs as well. 00:26:13.000 --> 00:26:28.000 during that process. Um, now I wanted to show you sort of the process, and I apologize for this chart being so busy, but this is kind of right out of the standard, so I'm just going to talk about the bigger blocks here. 00:26:28.000 --> 00:26:38.000 Um, the standard starts out with the conceptual site model. You've got to have a conceptual site model that can help you make these decisions. 00:26:38.000 --> 00:26:49.000 And so we have a whole chapter on how to review the model, the conceptual site model, do you have enough information? Is it sound? Or, um, you know, do you have data gaps in it? 00:26:49.000 --> 00:27:06.000 So that's where you begin. Then we have a chapter on non-technical issues, things like access, getting access, a lot of our sites, the owners have disappeared, and so you've got a non-responsive owner. You run out of funding, you run out of staff. 00:27:06.000 --> 00:27:18.000 So, we have we encourage people to classify their sites as to what non-technical issues are keeping them from making progress. 00:27:18.000 --> 00:27:33.000 Um, because it's a lot easier to solve a problem when you know how big that problem is, so if you've got 100 sites that have access problems, that's a lot easier to figure out than you can get everyone motivated to solve that problem. 00:27:33.000 --> 00:27:50.000 Rather than, uh, dealing with them one at a time, and having one… each project manager struggle through that on their own. And then also we have in that chapter, some of the solutions that states have come up with sort of best practices. 00:27:50.000 --> 00:27:55.000 from our states. Uh, for overcoming those barriers. 00:27:55.000 --> 00:28:09.000 Then the… then the… we have the sort of the… more technical chapters of this are related to the alternative cleanup standards. 00:28:09.000 --> 00:28:27.000 So… You may have started out with a cleanup goal that was based on groundwater as measured in this one well or these several wells. There may be other ways to look at that site to determine if it's a low threat. 00:28:27.000 --> 00:28:40.000 And we broke it into NAPL, groundwater, soil, and vapor intrusion, and then for each of those, we talk about different ways to that the user can look at. 00:28:40.000 --> 00:28:51.000 the threat posed by the site. In this… in these chapters, we also have some really good information on how to evaluate uncertainty. 00:28:51.000 --> 00:29:03.000 And also, how do you do the interplay with institutional controls and engineering controls in terms of controlling pathways and receptors? 00:29:03.000 --> 00:29:14.000 So, if you get to the point, when you get through that, you've come up with some alternatives, closure standards you want to try and meet, you have to decide, do I want to propose closure or not? 00:29:14.000 --> 00:29:25.000 If you don't want to propose closure, maybe you don't meet the standard, or maybe you don't want to live with the maintenance that goes along with the engineering control. 00:29:25.000 --> 00:29:38.000 Then… then we have a chapter on how to evaluate the remedy, is it making adequate progress, is it effective? And if it's not making adequate progress, how do you select the next remedy? 00:29:38.000 --> 00:29:55.000 So I have a chapter on that. And then we just have two very short sections at the end on what we think should be in a closure proposal, and then what should be in the implementation plan and the implementation of the closure. 00:29:55.000 --> 00:30:07.000 And those are really just sort of outlines, because that's going to depend very much on state by state, the regulatory process in that state. 00:30:07.000 --> 00:30:19.000 So that's the process. Does Mystic apply to all the sites? No. Mystic applies… When you're sure the release is stopped. 00:30:19.000 --> 00:30:29.000 When there are no current impact to receptors, you're not closing a site if you've got, uh, if people are drinking contaminated water, you're going to be still working that cleanup. 00:30:29.000 --> 00:30:47.000 You've got to have no migrating Elnaple. The LNAPL can be mobile, can be… can be residual, but it can't be migrating. And then you've got to have a basic CSM. Those are sort of the table stakes to get into the mystic standard. 00:30:47.000 --> 00:30:53.000 And then for every… just talking about what… what do you have to have in the CSM? 00:30:53.000 --> 00:31:08.000 The CSM is where we exercise as professionals the most judgment. But there are free questions that every CSM should answer in in the way we put it in this standard anyway. 00:31:08.000 --> 00:31:22.000 Are there any receptors that are currently exposed? Uh, what's the potential for exposure to receptors, including, sort of, reasonably anticipated future receptors? And is there a potential for NAPL migration? 00:31:22.000 --> 00:31:38.000 Every CSM should address that. If the answers to any of the first three questions are yes, then the CSM should also address is groundwater… are groundwater contaminants likely to migrate? 00:31:38.000 --> 00:31:42.000 And, um, if you're going to do a remedy. 00:31:42.000 --> 00:31:59.000 What do you need to know about… you need to know about the soil, the characteristics, depending on the remedy that you're choosing for the removal of NAPL, for the treatment of groundwater, you know, all those things. There's a lot of subsurface information you need to design that. 00:31:59.000 --> 00:32:16.000 or select the proper remedy. And then there's always the question of, you know, how much information is enough? When is enough enough kind of question. And this comes up a lot, because it's it's really easy to say, you know what? If I had. 00:32:16.000 --> 00:32:25.000 I could probably be confident in my decision if I had 3 more monitoring wells, or if I had 5 more monitoring wells. It's always easy to collect more information. 00:32:25.000 --> 00:32:39.000 Um, but you really need to tie that additional information to is it… is it going to really alter my exposure assessment? Is it going to alter my corrective action decision? 00:32:39.000 --> 00:32:47.000 And we, you know, so there's a balancing act, and this is where judgment comes in. 00:32:47.000 --> 00:33:03.000 So, just for an example of alternative… alternative cleanup or closure standards, we in this, we listed five different ways that are supported by literature and scientific study. 00:33:03.000 --> 00:33:13.000 of showing that Elnaple is not migrating. So we have these 5 different methods, um, and we've listed them in the standard. 00:33:13.000 --> 00:33:31.000 We think they're all sound. But you and your state, you may think that only 3 of them are sound, or 2 of them are sound. That's up to the state to decide, but we think there are five different methods out there today that give reliable indications of stability. 00:33:31.000 --> 00:33:38.000 And then for groundwater soil and vapor intrusion, we broke the alternatives into. 00:33:38.000 --> 00:33:46.000 distance screening methods, contaminant concentration methods, and mass flux discharge sort of modeling methods. 00:33:46.000 --> 00:33:59.000 And the distance screening methods you're probably familiar with that in the last 10, 15 years we've done a lot with vapor intrusion screening distances. We think you can apply screen distances also. 00:33:59.000 --> 00:34:14.000 to the… the distance from the leading edge of the plume to a groundwater receptor, say, a drinking water well, if it's more than 300 feet, or 500 feet from the leading edge of the dissolved face plume. 00:34:14.000 --> 00:34:22.000 that that drinking water well will not be expected to be exposed to those contaminants. 00:34:22.000 --> 00:34:41.000 The contaminant concentrations is is somewhat like is references back to the Rebecca standard, and you can use a variety of methods that are like Rebecca and looking at those. And then the mass flux and discharge. There's been a lot of really great developments in. 00:34:41.000 --> 00:34:56.000 using modeling to gain insight into, sort of, worst-case scenarios or conservative looks at what's going on in the ground. But the mass… but the modeling scenarios typically require a lot more data about the site. 00:34:56.000 --> 00:35:13.000 And generally get used on bigger, more complex sites, and our typical UST sites, it's usually the… one of the first two methods to determine low threat. 00:35:13.000 --> 00:35:27.000 So you know, what are the what can state programs expect as major changes based on Mystic? If you adopt and embrace mystic, how that is likely to change your program? 00:35:27.000 --> 00:35:42.000 Um, the biggest thing is is is this idea of going back and assessing the current threats of your open releases. A lot of sites, we establish a cleanup goal 20 years ago. 00:35:42.000 --> 00:35:57.000 And we are still chasing that same cleanup goal, trying to get there. And what we're asking is to go back, take a step back, and say, so what do we know now today about the actual threat from that site? 00:35:57.000 --> 00:36:08.000 We think that Mystic is consistent with non-degradation goals. A lot of states… well, several states have non-degradation goals in statute or in regulation. 00:36:08.000 --> 00:36:26.000 And Mystic gets you there with this low threat idea because what it says is the… You're eventually, the groundwater and the contaminants are going to degrade naturally over time, and eventually that site will reach. 00:36:26.000 --> 00:36:32.000 The non-detect level, or the MCL level, whatever level is your goal. 00:36:32.000 --> 00:36:47.000 Uh, it's just in the meantime, we want to make sure that no receptors are exposed, and if there are no receptors exposed, we can go ahead and close the cleanup and let the natural degradation take care of the rest of it. 00:36:47.000 --> 00:36:57.000 On its own. Um, in under the mystic framework, it's a lot more about stability and less emphasis on concentrations. 00:36:57.000 --> 00:37:09.000 If the plume is not moving, it doesn't matter how much what the concentrations are within the plume. If as long as the receptors are far enough away from it that they're not going to be impacted. 00:37:09.000 --> 00:37:19.000 So you can get these sort of more descriptive closure proposals than a numeric closure proposal. 00:37:19.000 --> 00:37:35.000 And we have two methods of showing groundwater stability under Mystic. The first one, which is kind of been what everyone's used for many, many years, is to sort of do trending analysis of concentrations in monitoring wells. 00:37:35.000 --> 00:37:47.000 or thicknesses of the NAPL, and, uh, you know, GWS data is a great tool for doing that, and we recommend that as a really good way to look at and demonstrate stability. 00:37:47.000 --> 00:38:05.000 Um, but you can… we also offer the option of using groundwater plume retraction as a method, and the idea with plume retraction is you look past the leading edge of the contaminant plume, and if you're seeing degradation byproducts. 00:38:05.000 --> 00:38:20.000 it passed the leading edge, that means that the plume has been there and is now retracting to its current state. So, you can say, well, that plume is stable, and in fact, it's retracting. 00:38:20.000 --> 00:38:37.000 Um, as I mentioned before, NAPL that's not migrating might be acceptable if… but you have to determine if it's causing a contribution to making the groundwater plume grow. 00:38:37.000 --> 00:38:50.000 Or, um… So, that's a big change for many states that have they can't close sites because there's measurable Elnaple or in the in a monitoring well. 00:38:50.000 --> 00:39:00.000 And then also, another big change is Mystic would say, you know, it's useful to monitor the natural attenuation process till you've got a trend. 00:39:00.000 --> 00:39:07.000 Uh, but after… once you've established that trend, you don't need to monitor anymore to make sure it's successful. 00:39:07.000 --> 00:39:16.000 You may need to monitor land use, you may need to monitor to make sure that no one's putting in a drinking water well in the contaminant zone. 00:39:16.000 --> 00:39:27.000 But monitor natural attenuation sites can end the monitoring part of the natural attenuation after you've shown the stability. 00:39:27.000 --> 00:39:37.000 And then this idea of reviewing the effectiveness of remediation, many of our programs, once an owner has a corrective action plan. 00:39:37.000 --> 00:40:07.000 uh, they're… they are gonna run that plan till… till the end of time, or till they're out of money. And whether or not it's effective and the regulator has sort of… have limited ability to go back in and say, hey, wait a minute, you're… you've run the course with that remedy, let's switch to another remedy going forward. 00:40:09.000 --> 00:40:25.000 So that's… that's kind of the summary of Mystic, and it's very… that's very brief and and uh… I'd be happy to go into it more if you have specific questions, but I just want to spend a couple minutes to talk about implementation. 00:40:25.000 --> 00:40:37.000 We know that at EPA, we rarely, if ever, tell our states this is how you got to do it. 00:40:37.000 --> 00:40:47.000 We are offering training and assistance. We think Mystic is cool. We think the, um, reassessing your open sites is a great idea, but it's up to the. 00:40:47.000 --> 00:40:55.000 It's up to the individual state to decide if they want to do it and how they want to do it. So we're focusing on training and assistance. 00:40:55.000 --> 00:40:58.000 And if states want to pick it up, that's great. 00:40:58.000 --> 00:41:04.000 Um, we partnered with ASTM to develop the training, and I'll talk about that in a little bit. 00:41:04.000 --> 00:41:21.000 And, um, and like I said, we're doing training and assistance, and also we're doing a lot of workshops, we're doing presentations like this. We're at conferences, uh, you know, raising awareness and talking to people about this process. 00:41:21.000 --> 00:41:29.000 So this is how we see potentially individual programs adopting Mystic. 00:41:29.000 --> 00:41:38.000 Um, and this is just… this is just as we're getting started. If you talk to me next year, I'll have probably a more detailed idea about how this works. 00:41:38.000 --> 00:41:51.000 Um, but we've been beginning with, like, an awareness webinar or a workshop to sort of get staff, get management aware of what Mystic could do for their program. 00:41:51.000 --> 00:42:02.000 Then the program needs to decide what they want to change. Mystic is written in an a la carte menu. You can use some of this and some of that and ignore this other part. 00:42:02.000 --> 00:42:09.000 So you have to decide the scope of your change and how much you want to revise your guidelines. 00:42:09.000 --> 00:42:15.000 And meanwhile, we've been creating a generic two-day training with ASTM. 00:42:15.000 --> 00:42:30.000 should be ready in March. It's our hope anyway. And then once the state knows what they want to do with their… how they want to… what parts they want to adopt, we'll customize that training to fit the state program. 00:42:30.000 --> 00:42:41.000 The state can publish and ASCM will invite in the consultants, the staff, and all the stakeholders in for a two-day training, hold that training. 00:42:41.000 --> 00:42:49.000 And then everyone's off on the same page, you know, going… starting with the revisions in the program, everyone on the same page. 00:42:49.000 --> 00:42:54.000 And then we'll help… EPA will help with measuring effectiveness. 00:42:54.000 --> 00:43:12.000 And revising the process in the state, helping the state see what maybe needs to change in their state, but also we want to go back and revise the ASTM standard when we… find things that are wrong in it, or could be improved. 00:43:12.000 --> 00:43:28.000 Now, this… I put in this timeline for, like, as fast as we could go with a state that doesn't need to make hardly any changes to their guidance. We could go as fast as, you know, getting to 90 days, 120 days, getting out there to getting the. 00:43:28.000 --> 00:43:34.000 Training done. And like I said, we've got this two-day training almost ready to go. 00:43:34.000 --> 00:43:47.000 If… if the state has a lot of changes, uh, like I'm working with Montana, they have to change their law, they've applied to the legislature, the legislature will meet next year, you know, it's going to be a long time. 00:43:47.000 --> 00:44:00.000 In Montana, they're going to make some of the changes that they can make within their current authorities. And then once or if they get additional authority from their state legislature, they'll make some more changes. 00:44:00.000 --> 00:44:21.000 This could drag out for a couple years, uh, easily, uh, to… it's not a… it's not a simple process, but we think the flow of it is pretty similar in that… in that it has followed the same path, it just takes longer, and there's more work making the… for the state to make their changes. 00:44:21.000 --> 00:44:38.000 So that's what I had for my presentation. If you will have a little bit of time, I think, to have questions. And if you have any further questions, if we don't answer them today, you can always reach out to me. 00:44:38.000 --> 00:44:54.000 Uh, we… and I have… we have a… we have, like, this sort of one-hour sort of webinar that we can do. We can do it in person. We have a four-hour workshop that we've been doing, and I'm… we're doing that with a number of states in the… in the next month or two. 00:44:54.000 --> 00:44:59.000 And, um, like I said, we'll have this two-day training available. 00:44:59.000 --> 00:45:00.000 So with that, I will turn it back over to Gene, and we can answer questions. 00:45:00.000 --> 00:45:15.000 Oh. 00:45:15.000 --> 00:45:16.000 Oh. Okay. 00:45:16.000 --> 00:45:28.000 Alright, thank you so much, Tom. So just a gentle reminder to the live audience. You can continue to submit your questions on in using the Q&A window. And Tom, I'll have you pull the slides back up because some of the questions relate back to them. Full disclosure, we've got about 10 minutes left and we may not be able to get through all of the questions, but I'm going to try to get through as much as I can and sort of group them together. 00:45:28.000 --> 00:45:41.000 A number of individuals have asked about a specific point, and I think there was a statement that you were making earlier, and I want to give you the opportunity to sort of clarify or repeat it regarding LNAPL. 00:45:41.000 --> 00:45:51.000 So, there were a number of individuals who asked about leaving El MAPL in groundwater if there's a federal drinking water standard for it. 00:45:51.000 --> 00:45:58.000 Uh, so specifically, we have an individual who put in a really great statement. 00:45:58.000 --> 00:46:01.000 Boy, there's a bunch of them that just came in on this one. 00:46:01.000 --> 00:46:08.000 But essentially, they're asking, there's a federal drinking water standard. How can we leave Elnaple in the groundwater? 00:46:08.000 --> 00:46:16.000 Yeah, the Federal Drinking Water Standards are measured at the at the tap or at the wellhead. 00:46:16.000 --> 00:46:33.000 There's a lot of sites. In fact, the vast majority of our sites have some residual at them, so there is some groundwater under that site that is contaminated and does not meet the federal drinking water standards. Where you, where the Federal drinking water standards apply is at. 00:46:33.000 --> 00:46:46.000 the wellhead, or at the user interface, and so what we want to do is make sure that that… that those petroleum contaminants do not get into those. 00:46:46.000 --> 00:46:47.000 All right. 00:46:47.000 --> 00:47:00.000 into that water supply. And if… and if for some reason there's an impact to a individual private well that you've got to put carbon on that well if you can't get an alternative water supply in and protect that, uh, protect that water supply. 00:47:00.000 --> 00:47:01.000 Okay. 00:47:01.000 --> 00:47:08.000 But those are both acceptable resolutions, and the contaminants end up staying in the ground in those situations. 00:47:08.000 --> 00:47:23.000 Okay, and then we have some questions about degradation. So, one of the participants wanted to know, does the standard include parameters for other compounds to confirm natural attenuation, like increasing daughter products or biological organisms? 00:47:23.000 --> 00:47:42.000 They'd like you to, and another question, discuss the role of microbial testing in moving to site closure. They're just trying to… they've been thinking specifically about this idea that they can rely on biodegradation at us sites. So they're wondering about the role of microbial testing into CSM development, corrective action evaluation. 00:47:42.000 --> 00:47:49.000 Yeah, so microbial testing used to be we used it a lot to confirm that degradation was occurring. 00:47:49.000 --> 00:47:50.000 Mm-hmm. 00:47:50.000 --> 00:48:06.000 We now know that degradation occurs at every site and microbial testing has now shifted for petroleum. I'm talking about petroleum products only here, has now shifted more into is my remedy being effective? Is it stimulating enough microorganisms? 00:48:06.000 --> 00:48:26.000 So, microbial testing is now used more in a… is a remedial effectiveness measure than a, um, than is degradation occurring or not. We've tested so many sites and not found a single site where degradation isn't occurring, at least at some level. 00:48:26.000 --> 00:48:29.000 That we now know you can rely on at every site. 00:48:29.000 --> 00:48:48.000 Okay. One of the big questions that a number of people are asking for is about states, and you mentioned some states might be willing to adopt, some states might not, so I have got questions. For example, has New Jersey shown any interest in this? I've got questions asking about Michigan. 00:48:48.000 --> 00:48:58.000 Someone else is asking, is there a public list of the states who are interested in or have adopted this? So can you talk a little bit about implementation from a state perspective? 00:48:58.000 --> 00:49:09.000 Um, yeah, we're just getting started, and a lot of states have expressed interest. New Jersey is one that has expressed interest. They're going to learn more about it. We're going to do some training and have some discussions. 00:49:09.000 --> 00:49:16.000 Uh, I know that there's a lot of interest in the public and amongst the owner community in New Jersey. 00:49:16.000 --> 00:49:46.000 Um, Michigan is a state that is also expressed interest, but right now they're implementing one massive change that they developed have been developing over the last 3 years, and they're going to they'll probably be more interested in looking at Mystic next year. 00:49:49.000 --> 00:49:50.000 Mm-hmm. 00:49:50.000 --> 00:49:59.000 Um, we've got, so far, I think I… the last count I've got of people that have called and talked, and I'm kind of keeping a, uh… tabs on them. We've got, uh, six states so far that have committed to adopting Mystic and you know a lot more that have committed to I want to learn more about it, and we're going to train them up over the next few years. 00:49:59.000 --> 00:50:07.000 Uh, next two years to, you know, get them up to where they can decide what they want to adopt, how they want to adopt it. 00:50:07.000 --> 00:50:26.000 Okay. I'm trying to group some of the questions here so we can get the most bang for our buck here in terms of time remaining. So, another large chunk of questions are focusing on accessing the standard. So, I'm seeing questions from EPA staff. If we help develop it, can EPA staff get to it for free? 00:50:26.000 --> 00:50:48.000 Um, then there's others asking, uh, do you have to buy it, or if… is there a free version that they could get to? And then, sort of, are there templates and boilerplates and tools included in the standard, if they do pay for it? What do they get with it? 00:50:48.000 --> 00:50:49.000 Okay. 00:50:49.000 --> 00:51:15.000 Yeah, I'll answer the… I'll answer the last one first. Yeah, there's a whole… there's several appendices of checklists that we developed for the standard that make it easy, at least as a starting point for states to develop their own checklists. So there's lots of tools in the… within the standard that are worth the price of admission alone. As far as for state regulators, ASTM has a free read-only version. You can contact Molly Linek at ASTM. 00:51:15.000 --> 00:51:16.000 Okay. 00:51:16.000 --> 00:51:30.000 or contact me, and I'll put you in touch with her, and she can get you a free read-only access. Many states and EPA already have free access to standards. Epa pays for it, but any EPA employee can access the standard for free, download it. 00:51:30.000 --> 00:51:43.000 and use it with their… in their work. If you have trouble learning how to do that, I'll… I can show you how to do it. 00:51:43.000 --> 00:51:52.000 So just contact me. But yeah, at EPA, all of the employees have unlimited access to all the ASTM standards. 00:51:52.000 --> 00:52:02.000 Okay, and then several people have asked about the two-day trainings or the workshops. How do they find them? How do they access them? And is there a cost? 00:52:02.000 --> 00:52:17.000 Uh, the… the way we're hoping to do the two-day trainings is that the state will sponsor it once the state knows how they want to change their system, and ASCM will work with that state to develop the. 00:52:17.000 --> 00:52:32.000 The cost for them, and the… our deal with ASCM is that the owners and the consultants will pay, and the state regulators will join for free in those, uh, in that two-day training. 00:52:32.000 --> 00:52:48.000 That's… that's how we, so far, have… have set them up. I imagine, over time, we're going to end up with two-day trainings that are not tied to any particular state program, but at least the way we're starting out is the two-day trainings will be tied to individual states. 00:52:48.000 --> 00:53:08.000 Okay. Okay. There are a number of what I would describe as more situation or site-specific application style questions, like in this case, at this type, do I need the following? And unfortunately, we simply don't have time to get into that, but we'll remind everyone on how they can follow up with Tom on more specific applications style questions. 00:53:08.000 --> 00:53:09.000 No. 00:53:09.000 --> 00:53:19.000 But I do have a few people that have commented on trends or impacts that they're noticing, and there are some statements in here. 00:53:19.000 --> 00:53:28.000 Regarding, perhaps, the need for more environmental covenants. Specifically, it sounds like to some of the participants, a site that's closed with Mystic. 00:53:28.000 --> 00:53:35.000 means, or to them, sounds like they're going to see an increase or need more institutional controls and environmental covenants. 00:53:35.000 --> 00:53:36.000 So contamination is left, but it's stable. Would you say that that's a fair characterization? 00:53:36.000 --> 00:53:59.000 Yeah. Yeah, that's a fair characterization. Not every site where contaminants are left behind needs environmental covenants or land use covenants, but that is definitely one way to do it. There's a ASGM has several standards on that ITRC has a great guide on it as well. 00:53:59.000 --> 00:54:07.000 EPA has a couple manuals on using engineering and institutional controls that are also quite good. So there's a lot of information out there. 00:54:07.000 --> 00:54:21.000 Anytime you leave contaminants behind, you need to consider them. They not always needed, and if you're going to use them, you need to use them properly. There's nothing worse than an institutional control that isn't enforced. 00:54:21.000 --> 00:54:22.000 and tracked. And so, yes, definitely that is that is. 00:54:22.000 --> 00:54:28.000 Mm-hmm. 00:54:28.000 --> 00:54:40.000 And we have a whole chapter on that, on that interplay. It's a very important consideration if you're going to leave a significant contaminants behind, you need to certainly consider. 00:54:40.000 --> 00:54:44.000 the need for institutional or engineering controls. 00:54:44.000 --> 00:55:14.000 Okay. All right, um, I do see, uh, we've got probably a two dozen or so more questions and simply not enough time, but I do want to remind the audience, right, that this is one of their very first possible touchpoints with you, Tom, and that there are other ways to follow up for more training, to ask more questions, to get access to information. 00:55:20.000 --> 00:55:33.000 Oh, just thanks for listening, and um… and if you… if you have questions, contact me. I'd be happy to engage and figure out what's best for your situation. 00:55:33.000 --> 00:55:50.000 Alright, so with that, I'm going to thank Tom so much for his time and willingness to share his expertise today. I'm going to take back control of the screen and walk the audience through just a few quick final reminders before we go ahead and close out today's live broadcast. 00:55:50.000 --> 00:56:07.000 So, uh, as Tom noted, we… push back here, gonna pass this one. I will encourage everybody to visit us at the Cleanup Information Network, as well as sign up for our free monthly newsletter Tech Direct, which is how we advertise sessions, and as more resources and opportunities become available. 00:56:07.000 --> 00:56:18.000 For Mystic, we will be happy to include those in future editions of TechDirect, so if you're not a subscriber, I encourage you to visit us there and sign up. Our next edition will go out on the 1st of March. 00:56:18.000 --> 00:56:36.000 Remember, when we started today's session, we did develop a unique seminar homepage. The URL is shown in red on the slide. You can also access it with the QR code here on that seminar homepage. We have already posted copies of the presentation materials, links to the standard, as well as links to a variety of other resources and websites on the topic. 00:56:36.000 --> 00:57:00.000 Some of you have asked if this session qualifies for CEUs or PDHs, and while I don't offer those types of credit hours, you may be able to earn them from your own accrediting institution. Oftentimes, the items that are required to give you credit, such as information about the speaker, the speaker bios, the session descriptions, copies of the slides, all of that we have posted here on the seminar home page. 00:57:00.000 --> 00:57:21.000 And if you fill out the online feedback form, we have a button to that right there on the seminar homepage. Once you fill out that online feedback form, at the bottom, there will be a button to certify you are here for the entire delivery. As soon as you click that box and submit your feedback, you'll then have immediate access to download or print out a certificate of participation, which has all the details on the session. 00:57:21.000 --> 00:57:38.000 If you happen to be sharing the room with a group of other individuals, and they didn't register on their own, if you point them or send them to this seminar homepage, each person in that room can fill out the feedback form on their own and get their own certificate of participation for their own records, even though they didn't register individually. 00:57:38.000 --> 00:57:53.000 So for those of you looking for credit hours while I cannot issue the hours myself, you might have luck earning them with this type of documentation. And if you happen to be one of the lucky ones watching the recorded version of today's webinar, yes indeed, we did record today's session. In about one week, there'll be an automatic email to all registrants. 00:57:53.000 --> 00:58:11.000 With the link to access and replay today's session. You're welcome to forward it on to other professionals that you think will find this a valuable expenditure of their time. And if you've made it to this point in the recording, you can still follow the link to the seminar homepage or scan the QR code shown on the slide, and fill out the online feedback form, checking the box at the bottom. 00:58:11.000 --> 00:58:27.000 Indicating you replayed the entire archive and get a certificate for your records based on watching the archive session. If you, again, have made it at this point in the archive, right about now in the upper right corner in the recorded version above my head, there will be a link to that seminar homepage, so you can head on over and give us feedback. 00:58:27.000 --> 00:58:57.000 and get your own certificate of participation. So with that, I want to thank the nearly 500 individuals who joined us for today's live broadcast, as well as the support team who helped me run today's session, and our wonderful speaker, Tom Schrubin. I hope that you enjoyed yourself today, and we will see you on a future ClueN Seminar. With that, it is my pleasure to formally conclude today's live broadcast. 00:59:14.000 --> 00:59:25.000 Thank you.