Knowledge through Education
How ITRC Reduces Regulatory Barriers to the Use of Innovative Environmental
Approaches
Sriram MadabhushiITRC Program Advisor
Remediation Risk Management
and
Green and Sustainable Remediation Teams
Our Mission and Role
Purpose of ITRC
Improve state permitting processes and
Speed implementation of new environmental technologies
ITRC is a state-led, national coalition of regulators and others working to
ITRC Values
State Leadership Integrity
Technical Excellence Change
Collaboration Innovation
Consensus Partnership
Network
Who We Are
Members• State government• Federal government• Industry • Consultants• Academia• Community
stakeholders• Tribal
representatives
Federal Partners
DOE DODEPA
Industry Partners
56 Total
ITRC Membership Distribution
Local and State Gov
36%
Consultant25%
Stakeholder3%
Academic3%
Vendor3% Site Owner
3%
DoD14%
DOE3%
EPA9%
Other Fed1%
Federal Gov26%
Q1 2009 Membership: 551
Distribution of State Members
70% of states have 2 or more members
Geographic Distribution of State Membership
How we do it
We use a proven, cost-effective approach to advanceenvironmental solutions.
Conduct Training
Implement Solutions
Develop Products
Select Projects
FormTeams
100 Documents60 Training courses40 Technical Teams
2009 Project PortfolioOngoing Implementation New
• Integrated DNAPL•LNAPL•Metals & Rads•Mining Waste•Phytotechnologies•Sediments•Remediation Risk Management
•UXO Wide Area Assessment
•Bio DNAPL•EACO•Perchlorate•Rads D&D•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
Internet Based Training48,000 people trained thru Q3 2008
620
3,265 4,161 3,494 3,3795,010
6,460 7,332 7,735
0
4000
8000
1999 2000 2001 2002 2003 2004 2005 2006 2007
60 courses over 10 years
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
Products & Services
Regulatory and Technical Guidelines
Technology Overviews
Case Studies
Peer Exchange
Technology Advocates
Classroom Training Courses
Internet-Based Training Sessions
Documents
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
State Engagement Program
Ensures ITRC documents are available, understood, and used
Promotes multistate concurrence of technical and regulatory guidelines
Coordinates Internet-based trainingDocuments ITRC’s successes Promotes regulatory innovationPromotes peer exchange
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
Benefits to States
Access to peers and experts in other regulatory agenciesShortened learning curve by obtaining advance
knowledge of new and used technologiesCost-effective involvement in demonstrations conducted
in other jurisdictionsSounding board for problem solving Information and technology transferMaximize limited resourcesPersonal and professional development
Benefits to Industry
Forum conducive to advancing technology and solutions
Insight into the regulatory worldAccess to multiple state entitiesOpportunity for broader review of technologyUnique and cost-effective approach to
demonstration and deployment of new technology
Mechanism to identify and integrate regulatory performance expectations among states
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 DOE’s remediation needs (metals, organics, asbestos, mixed waste)
Several technical teams are dedicated to problems of particular concern to DOE
Benefits to DOE
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)
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
Since 1995, we’ve been helping expedite quality regulatory decision-making, while protecting
human health and the environmental.
WWW.ITRCWEB.ORG
ITRC Web Page:
http://www.itrcweb.org/
Training Web Page:
http://www.clu-in.org/training/#upcoming
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
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
ITRC’s 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.
ITRC’s 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?
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
GSR Team Leadership and Composition
Tom O’Neill – 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
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)
Army, 4
Navy, 5
Air Force, 5
Stakeholder, 1
Academicians, 2
Site Owners, 3
Consultant, 23
State, 15 SERDP/ESTCP, 3
EPA, 14
DOE, 1
NASA, 1
Team Composition
Total Members : 77 as of 3/2/09
Schedule
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?
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?
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?
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?
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
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)
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?
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)
Attenuation Processes for Metals and Radionuclides (contd.)
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.
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.
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
Identify Hazards
Identify HazardsRemedy 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
Risk as we use in Remediation
Remediation Risk Management
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.
RRM Overview
Part of a two-step Risk Evaluation process1. Identify the project performance risks
2. Analyze the probability and consequences
Risk Affected Program Areas• Remedy quality and performance• Implementations schedule• Installation and O&M costs• Public perception/public relations
Identifying where Murphy’s Law might strike
Risks vs. UncertaintiesRisk Type Description
Contaminant Risks:On-Site Human HealthOn-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.
Risks vs. UncertaintiesRisk 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.
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.
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
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
Sriram Madabhushi
Program Advisor
Booz Allen Hamilton
700 N St Mary’s Street
San Antonio, TX 78205
210-487-2611
Questions?