Knowledge through Education How ITRC Reduces Regulatory Barriers to the Use of Innovative Environmental Approaches Sriram Madabhushi ITRC Program Advisor Remediation Risk Management and Green and Sustainable Remediation Teams

Our Mission and Role Reduce barriers to the use of innovative environmental technologies Improve the clean up process by educating on environmental technologies and processes Provide a national consensus on approaches to implementing innovative environmental technologies

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 CollaborationInnovation ConsensusPartnership Network

Who We Are Members State government Federal government Industry Consultants Academia Community stakeholders Tribal representatives Federal Partners DOEDODEPA Industry Partners 56 Total

ITRC Membership Distribution

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 advance environmental solutions. Conduct Training Implement Solutions Develop Products Select Projects Form Teams 100 Documents 60 Training courses 40 Technical Teams

2009 Project Portfolio OngoingImplementationNew 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 Training 48,000 people trained thru Q 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 training  Documents ITRC’s successes  Promotes regulatory innovation  Promotes 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 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

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

 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. ITRC Web Page: Training Web Page:

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 GroupRank Out Of 9 Combined EPA ranking5 Combined DOD ranking3 Combined DOE ranking3 Combined State ranking2 ASTSWMO ranking2 Citizen stakeholders1 Combined industry ranking4

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)

Team Composition Total Members : 77 as of 3/2/09

Schedule State Survey Overview Document Technical Regulatory Guidance Training Modules Year 1Year 2Year 3

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

 5.CASE STUDY APPLICATIONS AND LESSONS LEARNED 5.CASE STUDY APPLICATIONS AND LESSONS LEARNED  5.1HANFORD 300 AREA URANIUM 5.1HANFORD 300 AREA URANIUM  5.2LAWRENCE LIVERMORE SITE LAWRENCE LIVERMORE SITE 300  5.3LESSONS LEARNED 5.3LESSONS LEARNED  6.DECISION FRAMEWORK 6.DECISION FRAMEWORK  6.1INTRODUCTION TO THE FRAMEWORK 6.1INTRODUCTION TO THE FRAMEWORK  6.2KEY FEATURE/FACTORS WHEN USING THE FRAMEWORK 6.2KEY FEATURE/FACTORS WHEN USING THE FRAMEWORK  6.3SOURCE AND/OR PRIMARY PLUME TREATMENT (DEFINE SOURCE AND PRIMARY PLUME TREATMENTS) 6.3SOURCE AND/OR PRIMARY PLUME TREATMENT (DEFINE SOURCE AND PRIMARY PLUME TREATMENTS)  6.4EVALUATE TREATMENT EFFECT ON SYSTEM 6.4EVALUATE TREATMENT EFFECT ON SYSTEM  6.5ASSESS SYSTEM HYDROLOGY, GROUNDWATER CHEMISTRY, AND CONTAMINANT DISTRIBUTION (EPA - TIER I) 6.5ASSESS 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? 6.6 IS THE PLUME STABLE OR SHRINKING?  6.7EVALUATE MECHANISM(S) AND RATE(S) OF ATTENUATION (EPA – TIER II) 6.7EVALUATE MECHANISM(S) AND RATE(S) OF ATTENUATION (EPA – TIER II)  6.8DO ATTENUATION RATES SUPPORT A REASONABLE TIMEFRAME? 6.8DO ATTENUATION RATES SUPPORT A REASONABLE TIMEFRAME?  6.9MECHANISM STABILITY AND CAPACITY (EPA- TIER III) 6.9MECHANISM STABILITY AND CAPACITY (EPA- TIER III)  6.10IS THE SYSTEM CAPACITY SUFFICIENT? AND IS THE CONTAMINANT STABILITY SUFFICIENT? 6.10IS THE SYSTEM CAPACITY SUFFICIENT? AND IS THE CONTAMINANT STABILITY SUFFICIENT?  6.11CAN REGULATORY CRITERIA BE MET? 6.11CAN REGULATORY CRITERIA BE MET?  6.12DESIGN PERFORMANCE MONITORING PROGRAM AND CONTINGENCY PLAN(S) (EPA – TIER IV) 6.12DESIGN PERFORMANCE MONITORING PROGRAM AND CONTINGENCY PLAN(S) (EPA – TIER IV)  6.13APPROVE AND IMPLEMENT MNA 6.13APPROVE AND IMPLEMENT MNA  6.14EVALUATE PERFORMANCE 6.14EVALUATE PERFORMANCE  6.15IS PERFORMANCE ACCEPTABLE? 6.15IS PERFORMANCE ACCEPTABLE? Attenuation Processes for Metals and Radionuclides (contd.)

 6.16IMPLEMENT CONTINGENCIES, IF NEEDED 6.16IMPLEMENT CONTINGENCIES, IF NEEDED  6.17EVALUATE ENHANCEMENT OPTIONS 6.17EVALUATE ENHANCEMENT OPTIONS  6.18 ARE SUSTAINABLE ENHANCEMENTS VIABLE? 6.18 ARE SUSTAINABLE ENHANCEMENTS VIABLE?  6.19IMPLEMENT AND MONITOR THE ENHANCEMENT(S) 6.19IMPLEMENT 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 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

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 process 1. 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. Uncertainties Risk TypeDescription 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.

Risks vs. Uncertainties Risk TypeDescription 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 TypeDescription 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 Overview Companies 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 Questions?