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Knowledge through Education How ITRC Reduces Regulatory Barriers to the Use of Innovative Environmental Approaches

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Title: Knowledge through Education How ITRC Reduces Regulatory Barriers to the Use of Innovative Environmental Approaches


1
Knowledge through Education How ITRC Reduces
Regulatory Barriers to the Use of Innovative
Environmental Approaches
Sriram Madabhushi ITRC Program Advisor Remediatio
n Risk Management and Green and Sustainable
Remediation Teams
2
Our Mission and Role
3
Purpose of ITRC
ITRC is a state-led, national coalition of
regulators and others working to
  • Improve state permitting processes and
  • Speed implementation of new environmental
    technologies

4
(No Transcript)
5
Who We Are
  • Members
  • State government
  • Federal government
  • Industry
  • Consultants
  • Academia
  • Community stakeholders
  • Tribal representatives

6
ITRC Membership Distribution
7
Distribution of State Members
70 of states have 2 or more members
8
Geographic Distribution of State Membership
9
How we do it
  • We use a proven, cost-effective approach to
    advanceenvironmental solutions.

100 Documents 60 Training courses 40 Technical
Teams
10
2009 Project Portfolio
Ongoing Implementation New
Integrated DNAPL LNAPL Metals Rads Mining Waste Phytotechnologies Sediments Remediation Risk Management UXO Wide Area Assessment Bio DNAPL EACO Perchlorate Rads DD RPO - PBM UXO Quality Considerations Green Sustainable Remediation Multi-Incremental Sampling Biowall Technology Environmental Impacts of Ethanol and Bio-Based Fuels In Situ Stabilization and Solidification
11
Internet Based Training
  • 48,000 people trained thru Q3 2008

60 courses over 10 years
12
2009 Members from Texas
  • 33 members from Texas one of the largest
  • A state point of contact
  • Six TCEQ members on seven technical teams
  • Other members from consultants, vendors, site
    owners, AFCEE and EPA
  • Participation on all active teams

13
Products Services
  • Regulatory and Technical Guidelines
  • Technology Overviews
  • Case Studies
  • Peer Exchange
  • Technology Advocates
  • Classroom Training Courses
  • Internet-Based Training Sessions

14
Documents
15
Document Contents
  • Site Characterization
  • Pretreatment Sampling
  • Site Modeling
  • Exposure Analysis
  • Historical Data about Site Use
  • Data Requirements
  • Analytical Methods
  • QA/QC
  • Performance Data
  • Treatability Studies
  • Test and Demonstration
  • Monitoring for Treatment Goal and Fugitive
    Emissions
  • System Operating Requirements
  • Health and Safety Requirements
  • Feed Limitations
  • Cleanup Levels
  • Closure Criteria
  • Intended Use
  • Receptors
  • Surrounding Community

16
State Engagement Program
  • Ensures ITRC documents are available, understood,
    and used
  • Promotes multistate concurrence of technical and
    regulatory guidelines
  • Coordinates Internet-based training
  • Documents ITRCs successes
  • Promotes regulatory innovation
  • Promotes peer exchange

17
Tackling Regulatory Barriers
  • ITRC catalyzed USEPA to clarify RCRA 3020(b)
  • Furthering deployments of in situ technologies
  • New Jersey modifying permit process
  • Effort to increase use of enhanced in situ
    bioremediation
  • States integrating ITRC documents into processes
  • Guiding proposal and approval process for
    innovative environmental technologies
  • Kansas estimates saving 50 time in approving
    natural attenuation

18
Benefits to States
  • Access to peers and experts in other regulatory
    agencies
  • Shortened learning curve by obtaining advance
    knowledge of new and used technologies
  • Cost-effective involvement in demonstrations
    conducted in other jurisdictions
  • Sounding board for problem solving
  • Information and technology transfer
  • Maximize limited resources
  • Personal and professional development

19
Benefits to Industry
  • Forum conducive to advancing technology and
    solutions
  • Insight into the regulatory world
  • Access to multiple state entities
  • Opportunity for broader review of technology
  • Unique and cost-effective approach to
    demonstration and deployment of new technology
  • Mechanism to identify and integrate regulatory
    performance expectations among states

20
Benefits to DOE
  • Facilitates interactions between DOE managers and
    state regulators
  • Increases consistency of regulatory requirements
    for similar cleanup problems in different states
  • Can help reduce uncertainties when preparing
    cleanup plans
  • Addresses DOEs remediation needs (metals,
    organics, asbestos, mixed waste)
  • Several technical teams are dedicated to problems
    of particular concern to DOE

21
Benefits to DOD
  • Facilitates interactions between DOD managers and
    state regulators
  • Increases consistency of regulatory requirements
    for similar sites in different states
  • Helps reduce uncertainties when preparing cleanup
    plans
  • Addresses contaminants of concern to DOD (heavy
    metals, VOCs, PAHs, organic pesticides, solvents,
    etc.)
  • Technical teams dedicated to problems unique to
    DOD (UXO, Small Arms Firing Range)

22
Benefits to USEPA
  • Forum to facilitate idea sharing between
    regulators at the federal and state levels
  • Unique and cost-effective approach for
    demonstrating and deploying new technology
  • Mechanism for identifying and integrating
    regulatory performance expectations among states

23
WWW.ITRCWEB.ORG
Since 1995, weve been helping expedite quality
regulatory decision-making, while protecting
human health and the environmental.
ITRC Web Page http//www.itrcweb.org/ Training
Web Page http//www.clu-in.org/training/upcoming

24
Example Teams
  • Green Sustainable Remediation
  • Incremental Sampling Methodology
  • PRB Technology Update
  • Environmental Impacts of Ethanol and Bio-Based
    Fuels
  • In Situ Stabilization and Solidification
  • Remediation Risk Management
  • UXO Wide Area Assessment

25
Why Green and Sustainable Remediation?
  • No nation-wide guidance on how to best
    incorporate green and sustainable remediation
    into a regulated cleanup process.
  • No consistency on how to use and interpret
    sustainability metrics and/or life cycle
    analysis.
  • Need a way to communicate best practices to state
    regulators and environmental consultants

26
ITRCs Green and Sustainable Remediation (GSR)
Team
  • Goal
  • Provide documents and training that educate state
    regulators and other environmental professionals
    on how to appropriately incorporate
    sustainability and green technologies into the
    cleanup process.

27
ITRCs Green and Sustainable Remediation (GSR)
Team
  • What metrics are most useful and have the
    greatest impact?
  • What is a consistent and appropriate way of
    interpreting the metrics?
  • How can we minimize the overall risk to human
    health and the environment by applying sound GSR
    practices?
  • How can we reduce energy consumption or use
    alternative sources of energy that will be less
    harmful to overall environment?
  • How do we promote the use and development of GSR
    technologies?

28
GSR Team Selection
  • GSR Team proposal was ranked 1 of 9 team
    proposals by the ITRC Board of Advisors and
    liaisons (weighted average with state input
    weighted higher)

Membership Group Rank Out Of 9
Combined EPA ranking 5
Combined DOD ranking 3
Combined DOE ranking 3
Combined State ranking 2
ASTSWMO ranking 2
Citizen stakeholders 1
Combined industry ranking 4
29
GSR Team Leadership and Composition
  • Tom ONeill NJ Department of Environmental
    Protection
  • 26 states have committed a team member (as of Aug
    2008) or resources for product review and
    implementation
  • Team membership commitments from major industry
    organizations, DOD, DOE, EPA, and citizen
    stakeholders

30
State Participation
  • Committed a team member (as of Feb 2009) AL, CA,
    FL, GA, KY, MA, NJ, OR, PA, SD, TX, VA (12)
  • Committed resources for product review and
    implementation CT, FL, HI, IL, IN, IA, KY, MI,
    MN, MT, NE, NY, OH, PA, RI, SC, UT, VT, WY (19)

31
Team Composition
Total Members 77 as of 3/2/09
32
Schedule
33
Incremental Sampling Methodology
  • ISM Team is developing a Technical and Regulatory
    Review document
  • At what types of sites can IS be used?
  • When should IS not be employed?
  • What contaminants are most suitable for IS?
  • What soil sampling depth should be used with IS?
  • Does IS mask areas of high concentration (hot
    spots) due to compositing and homogenization?

34
Incremental Sampling Methodology (continued)
  • How does IS differ from composite sampling?
  • What effect does sample processing have on
    contaminant concentration?
  • How many replicate samples should be collected?
  • How are DQOs addressed?
  • What is a decision unit and how is it
    established?
  • How do IS results relate to action levels?

35
Incremental Sampling Methodology (continued)
  • ISM Team is developing a Technical and Regulatory
    Review document
  • At what types of sites can IS be used?
  • When should IS not be employed?
  • What contaminants are most suitable for IS?
  • What soil sampling depth should be used with IS?
  • Does IS mask areas of high concentration (hot
    spots) due to compositing and homogenization?

36
Incremental Sampling Methodology (continued)
  • How does IS differ from composite sampling?
  • What effect does sample processing have on
    contaminant concentration?
  • How many replicate samples should be collected?
  • How are DQOs addressed?
  • What is a decision unit and how is it
    established?
  • How do IS results relate to action levels?

37
Attenuation Processes for Metals and Radionuclides
  • 1. Introduction
  • 1.1 Defining the Problem
  • 1. 2 Document Organization
  • 2. MONITORED NATURAL ATTENUATION PROCESSES FOR
    METALS RADIONUCLIDES
  • 2.1 Technical Advantages and Limitations
  • 3. REGULATIONS AND REQUIREMENTS
  • 3.1 Federal Policy and Guidance
  • 3.2 State Policies and Guidance
  • 4. TRIBAL AND STAKEHOLDER ISSUES
  • 4.1 Community Participation
  • 4.2 Attenuation Pathway
  • 4.3 Future Use
  • 4.4 Health and Safety

38
Attenuation Processes for Metals and
Radionuclides (contd.)
  • 5. Case Study Applications and Lessons Learned
  • 5.1 Hanford 300 Area Uranium
  • 5.2 Lawrence Livermore Site 300
  • 5.3 Lessons Learned
  • 6. Decision Framework
  • 6.1 Introduction to the Framework
  • 6.2 Key Feature/Factors When Using the Framework
  • 6.3 Source and/or Primary Plume Treatment (define
    source and primary plume treatments)
  • 6.4 Evaluate Treatment Effect on System
  • 6.5 Assess System Hydrology, Groundwater
    Chemistry, and Contaminant Distribution (EPA -
    Tier I)

39
Attenuation Processes for Metals and
Radionuclides (contd.)
  • 6.6 Is the Plume Stable or Shrinking?
  • 6.7 Evaluate Mechanism(s) and rate(s) of
    attenuation (EPA Tier II)
  • 6.8 Do Attenuation Rates Support a Reasonable
    Timeframe?
  • 6.9 Mechanism Stability and Capacity (EPA- Tier
    III)
  • 6.10 Is the System Capacity Sufficient? and Is
    the Contaminant Stability Sufficient?
  • 6.11 Can Regulatory Criteria be Met?
  • 6.12 Design Performance Monitoring Program and
    Contingency Plan(s) (EPA Tier IV)
  • 6.13 Approve and Implement MNA
  • 6.14 Evaluate Performance
  • 6.15 Is Performance Acceptable?

40
Attenuation Processes for Metals and
Radionuclides (contd.)
  • 6.16 Implement Contingencies, If Needed
  • 6.17 Evaluate Enhancement Options
  • 6.18 Are Sustainable Enhancements Viable?
  • 6.19 Implement and Monitor the Enhancement(s)

41
Permeable Reactive Barriers Technology Update
  • In 2005, ITRC published Permeable Reactive
    Barriers Lessons Learned/New Directions (PRB-4)
  • Technical and regulatory guidance document as it
    relates to recent advances in PRBs, including the
    increased use of non-iron reactive materials.
  • To help become more familiar with the treatment
    applicability, installation, performance, and
    mechanisms of reactive materials PRBs.

42
Remediation Risk Management
  • In 2005, ITRC published Permeable Reactive
    Barriers Lessons Learned/New Directions (PRB-4)
  • Technical and regulatory guidance document as it
    relates to recent advances in PRBs, including the
    increased use of non-iron reactive materials.
  • To help become more familiar with the treatment
    applicability, installation, performance, and
    mechanisms of reactive materials PRBs.

43
What Are Remediation Project Risks?
  • Risk The potential inability to achieve
    objectives within cost, schedule, or technical
    performance objectives
  • The components of risk are
  • Probability or likelihood
  • Consequences or impacts
  • Risk Event Things that could go wrong
  • Typically measured as Likelihood x
    Consequences

44
Identify Hazards
  • Identify Hazards
  • Remedy Selection Risks
  • Risks Associated with Site Investigation
  • Types of required criteria/drivers
  • Risks Associated with Technology
  • Implementation Performance Risks
  • Design, construction, operation
  • New Sources are discovered

45
Risk as we use in Remediation
46
Remediation Risk Management
47
Risks Versus Uncertainties
  • Consensus by the RRM Team members has resulted in
    identification of the following
  • Site remediation should result in an overall
    benefit to human health and the environment.
  • Risks should be avoided or reduced, and not
    ignored or transferred to other receptors.

48
RRM Overview
  • Part of a two-step Risk Evaluation process
  • Identify the project performance risks
  • Analyze the probability and consequences
  • Risk Affected Program Areas
  • Remedy quality and performance
  • Implementations schedule
  • Installation and OM costs
  • Public perception/public relations
  • Identifying where Murphys Law might strike

49
Risks vs. Uncertainties
Risk Type Description
Contaminant Risks On-Site Human Health On-Site Ecological Human health risks are traditional solitary decision driver for performing remediation, and is a conservative estimate of risks presented by site conditions to likely human receptors through likely complete exposure pathways. Ecological risk assessments estimate the potential hazard to likely ecological receptors and may be used to augment a remediation decision.
Travel, Transportation, and Disposal Risks incurred as a result of the movement of people and materials needed to install, construct, operate, maintain, monitor, and abandon (demolish) an active remediation system.
50
Risks vs. Uncertainties
Risk Type Description
Climate Change Risk presented by the incremental additional greenhouse gas emissions caused by an active remedial approach, especially energy-intensive methods.
Unintended Consequence of Remediation Risks presented to workers from the activities directly and indirectly performed in support of active remediation and monitoring at a site. These risks to remediation workers are in effect transferred from likely receptors of on-site contamination to other human receptors. Risks or damage caused to the environment resulting from performance of an active remedy. For sites with ecological risk drivers that demand remediation, this may constitute a transfer of risk from one ecological receptor to another.
51
Risks vs. Uncertainties
Risk Type Description
Financial Risks to project teams, regulatory case workers, insurance companies, banks, local and regional economies that are caused by the diversion of resources based on a decision to, or not to perform active remediation at a site.
Political Risk of damage to the effectiveness of governance over environmental issues.
Failure Risk of ineffective action that does not reduce net cumulative risk to human health and the environment
Professional Risk to professional reputation or livelihood of an agency, company, or individual.
52
RRM Highlights
  • RRM will reduce risk in remediation
  • RRM will reduce uncertainties in remediation
    decision making
  • RRM will help to minimize remediation derived
    wastes
  • Waste destruction not transfer is achieved
    through RRM
  • RRM will achieve protection of human health and
    the environment by considering alternative
    approaches to reduce risk of active remediation
    while meeting the cleanup goals
  • RRM will benefit the environment through
    successful remediation of contaminated sites

53
Industrial Affiliate Program
  • IAP OverviewCompanies and Trade Associations can
    join the IAP
  • site owner, consultant, technology developer, or
    trade association
  • Benefits
  • Information exchange
  • Access to a large audience
  • Participation on ITRC technical teams

54
Questions?
Sriram Madabhushi Program Advisor Booz Allen
Hamilton 700 N St Marys Street San Antonio, TX
78205 210-487-2611 Madabhushi_sriram_at_bah.com
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