Sriram Madabhushi ITRC Program Advisor Remediation Risk Management and

1. 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

2. Our Mission and Role

3. 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

5. Federal Partners DOE EPA DOD Who We Are Members • State government • Federal government • Industry • Consultants • Academia • Community stakeholders • Tribal representatives Industry Partners 56 Total

6. ITRC Membership Distribution

7. Distribution of State Members 70% of states have 2 or more members

8. Geographic Distribution of State Membership

9. Conduct Training Implement Solutions Develop Products Select Projects FormTeams How we do it We use a proven, cost-effective approach to advanceenvironmental solutions. 100 Documents 60 Training courses 40 Technical Teams

10. 2009 Project Portfolio

11. Internet Based Training 48,000 people trained thru Q3 2008 60 courses over 10 years

12. 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

13. Products & Services • Regulatory and Technical Guidelines • Technology Overviews • Case Studies • Peer Exchange • Technology Advocates • Classroom Training Courses • Internet-Based Training Sessions

14. Documents

15. 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

16. 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

17. 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

18. 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

19. 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

20. 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 DOE’s remediation needs (metals, organics, asbestos, mixed waste) • Several technical teams are dedicated to problems of particular concern to DOE

21. 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)

22. 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

23. WWW.ITRCWEB.ORG Since 1995, we’ve 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

24. 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

25. 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

26. 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.

27. 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?

28. 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)

29. 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

30. 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)

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

32. Schedule

33. 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?

34. 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?

35. 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?

36. 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?

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

38. 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.)

39. 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.)

40. 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.)

41. 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.

42. 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.

43. 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

44. 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

45. Risk as we use in Remediation

46. Remediation Risk Management

47. 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.

48. 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 O&M costs • Public perception/public relations Identifying where Murphy’s Law might strike

49. Risks vs. Uncertainties

50. Risks vs. Uncertainties