1. ITRC Overview: Decision-making Tools and Resources for the Environmental Community Copyright 2006 Interstate Technology and Regulatory Council Regulatory Acceptance for New Solutions Frank Camera, New Jersey DEP September 2006

2. 2 Consensus-based Tools and Resources  Technology overviews  Case studies  Regulatory and technical guidance  Peer exchange / network  Technology advocates  Classroom training courses  Internet-based training courses Innovative technologies and approaches for site characterization, monitoring, and remediation

3. 3 Interstate Technology & Regulatory Council  State government-led initiative that brings the environmental community together Fostering collaboration Focusing on mutual priorities Leading to partnered solutions Creating consensus-based tools  Advances innovative environmental decision-making Achieving better environmental protection Reducing the technical/regulatory barriers Expanding the regulatory acceptance of new technologies and approaches

4. 4 ITRC (www.itrcweb.org) – Shaping the Future of Regulatory Acceptance  Network State regulators Federal government Industry Consultants Academia Community stakeholders  Documents Technical and regulatory guidance documents Technology overviews Case studies  Training Internet-based Classroom ITRC State Members Federal Partners Host Organization DOEDODEPA ITRC Member State

5. 5 2006 ITRC Technical Teams  Alternative Landfill Technologies  Brownfields  Diffusion Samplers  MTBE and Other Fuel Oxygenates  Radionuclides  Remediation Process Optimization (RPO)  Risk Assessment Resources  Sampling, Monitoring, Characterization  Unexploded Ordnance (UXO)  Bioremediation of DNAPLs  Ecological Land Re-Use  Enhanced Attenuation: Chlorinated Organics  Perchlorate  Vapor Intrusion Pending teams  Arsenic in Groundwater  Mining Waste  Concentrated Animal Feeding Operations Proposal process for new topic areas

6. 6 ITRC Technical Team Process  State-led teams  Target audience is state regulators  Tools and resources for decision making  Work toward consensus-based solutions  Diversity of membership Regulators Federal agencies Industry Consultants Academia Community stakeholders More…

7. 7 ITRC Course Topics Scheduled for 2006  Alternative Landfill Covers  Constructed Treatment Wetlands  Environmental Management at Operational Outdoor Small Arms Ranges  DNAPL Performance Assessment  Mitigation Wetlands  Perchlorate Overview  Permeable Reactive Barriers: Lessons Learn and New Direction  Radiation Risk Assessment  Radiation Site Cleanup  Remediation Process Optimization  Site Investigation and Remediation for Munitions Response Projects  What’s New With In Situ Chemical Oxidation  Triad Approach  Characterization, Design, Construction and Monitoring of Bioreactor Landfills  Direct-Push Wells for Long-term Monitoring  Ending Post Closure Care at Landfills  Planning and Promoting of Ecological Re-use of Remediated Sites  Rads Real-time Data Collection  Remediation Process Optimization Advanced Training  More in development… New in 2006Popular courses from 2005 Training dates/details at: www.itrcweb.org Training Archives

8. 8 Internet-based Training How It Works…  Free!!! On-line registration – www.itrcweb.org  Based on ITRC consensus-based documents  Technical experts from ITRC Teams  From comfort of your own office or conference room  Audio and on-line presentation materials (call or simulcast)  Interaction with instructors during question and answer periods  National and international audience

9. 9 ITRC Internet-based Training Classes: Sept. – Oct. Site Investigation and Remediation for Munitions Response Projects Oct. 12 Guidance for Characterization, Design Construction and Monitoring of Mitigation Wetlands Oct. 19 Environmental Management at Operating Outdoor Small Arms Firing Ranges Oct. 31 What's New With In Situ Chemical OxidationOct. 5 Planning and Promoting Ecological Reuse of Remediated Sites Sept. 28 Register via www.itrcweb.org click on “Internet-Based Training”

10. 10 How can you get involved?  Join ITRC as a State Member  Appoint a State POC (Point of Contact)  Approximately 10% time commitment  Encourage staff to use ITRC tools and resources  Guidance documents, technology overviews, etc.  Internet-based Training from your office  Classroom Training Courses  Support staff to join ITRC technical teams  Approximately 10% time commitment  Monthly conference calls; 3-4 meetings/year  Develop content of products / training

11. 11 How You Can Gain Value From ITRC  Participate in a FREE on-line training event  Download FREE documents from www.itrcweb.org www.itrcweb.org  Join ITRC as a technical team member  Join the Industry Affiliates Program (IAP) For non-governmental members (i.e., industry, consultants)  Speak to your ITRC State Point of Contact

12. 12 Chemical Oxidation Overview and Overcoming Regulatory Barriers  Defining in situ chemical oxidation  General applicability  Regulatory review

13. 13 What is In Situ Chemical Oxidation?  Definition: A technique whereby an oxidant is introduced into the subsurface to chemically oxidize organic contaminants changing them to harmless substances Rapidly emerging technology Still subject of academic research as well as applied routinely as a commercialized process Several options for selection of oxidant chemicals Requires good understanding of contaminant and site characteristics to ensure effective treatment

14. 14 Advantages and Disadvantages of ISCO  Advantages Fast treatment (weeks to months) Temporary facilities Treatment to low levels Effective on some hard-to- treat compounds  Disadvantages Requires earlier spending commitment Involves handling powerful oxidants, and carries special safety requirements

15. 15 General Applicability of ISCO  ISCO has been successfully used in every state  Addresses organic contaminants Including hydrocarbons, pesticides, and PCBs  Addresses contaminant phases High soil/groundwater concentration Standard application Low soil/groundwater concentration Possible, but may not be cost-effective Mobile NAPL (free product) Applicable, but requires more knowledge/control Residual NAPL (sorbed) Applicable, but requires a high oxidant dose

16. 16 Regulatory Approval  How it used to be Inconsistent, bureaucratic permitting Resource Conservation and Recovery Act (RCRA) often caused delays Fear of liability on the part of contractors, stakeholders, etc.  Today Underground Injection Control (UIC) program To protect drinking water Resource Conservation and Recovery Act (RCRA) Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) Emergency Planning and Community Right to Know Act (EPCRA)

17. 17 State Regulatory Requirements  States that require an Underground Injection Control (UIC) permit/registration include AL, CT, DE, FL, GA, KS, LA, MD, MO, NE, NV, NH, NJ, NM, NC, OK, OR, RI, SC, WV, WY  All other states require other approvals See Table 4-1: Regulatory permitting requirements for oxidant injection by state ITRC's In Situ Chemical Oxidation of Contaminated Soil and Groundwater Second Edition (ISCO-2, 2005) available at www.itrcweb.org

18. 18 Regulatory Review of ISCO Proposals  Remediated to applicable groundwater remediation standard  Ensure that the injection Will not cause the plume to migrate Will not create adverse vapor impacts Is of sufficient volume to get the job done, and if not, that additional round(s) of injection will be necessary  Additional injectant-specific requirements would apply, depending on contaminant and injectant

19. 19 Regulatory Review of ISCO Proposals: Effectiveness of Remedial Actions  Groundwater elevation contour maps  Graphs of contaminant concentrations over time  Summary of the volume of soil/groundwater treated  Summary of contaminant concentrations above/below applicable remediation standards Generic evaluation criteria regarding the effectiveness of active soil and groundwater remedial actions

20. 20 Regulatory Review of ISCO Proposals: Performance-based Evaluation  If contamination continuously decreases, even after the injectant is used up Natural attenuation mode Post-treatment monitoring for at least 8 quarters  If concentrations rebound soon after the injectant is used up, it does not necessarily mean the technology has failed – need to continue monitoring to determine if: Concentrations continue to rebound Concentrations stabilize Concentrations decrease