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

Madabhushi_sriram@bah.com

Questions?