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

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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
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Our Mission and Role
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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

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Who We Are

• Members
• State government
• Federal government
• Industry
• Consultants
• Academia
• Community stakeholders
• Tribal representatives

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ITRC Membership Distribution
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Distribution of State Members
70 of states have 2 or more members
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Geographic Distribution of State Membership
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How we do it

• We use a proven, cost-effective approach to
  advanceenvironmental solutions.

100 Documents 60 Training courses 40 Technical
Teams
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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
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Internet Based Training

• 48,000 people trained thru Q3 2008

60 courses over 10 years
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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

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Products Services

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

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Documents
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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

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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

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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

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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

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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

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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

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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)

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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

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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

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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

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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

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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.

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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?

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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
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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

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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)

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Team Composition
Total Members 77 as of 3/2/09
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Schedule
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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?

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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?

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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?

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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?

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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

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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)

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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?

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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)

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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.

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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.

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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

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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

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Risk as we use in Remediation
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Remediation Risk Management
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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.

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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

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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.
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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.
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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.
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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

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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

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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