Regulatory Acceptance for New Solutions. December 2002 Copyright 2003 Interstate Technology and Regulatory Council

Transcription

1 Regulatory Acceptance for New Solutions December 2002 Copyright 2003 Interstate Technology and Regulatory Council 1

2 Purpose of ITRC ITRC is a state-led, national coalition of regulators and others working to improve state permitting processes and speed implementation of new environmental technologies December

3 Goals Achieve better environmental protection through innovative technologies Reduce the technical/regulatory barriers to the use of new environmental technologies Build confidence about using new technologies December

4 Other Participants Industry representatives Academia Public stakeholders Federal agencies U.S. Department of Energy U.S. Environmental Protection Agency U.S. Department of Defense Host organization Environmental Council of the States State organizations Western Governors Association Southern States Energy Board December

5 Organizational Structure ECOS/ERIS State institutional support Enable state staff participation Funding support Fiscal agent State Engagement State Point of Contact Network (41 POCs) Ensure state awareness/use of ITRC products Coordinate training on ITRC products Coordinate concurrence on ITRC products Two Public Stakeholders (Industry,Env) State Engagement Coordinator Accelerated In Situ Bioremediation Training Alternative Landfill Technologies Brownfields Contaminated Sediments Dense Nonaqueous Phase Liquids Diffusion Sampler Technology In Situ Bioremediation Mitigation Wetlands MTBE-Contaminated Groundwater Board of Directors Co-Chairs State Team Leader Liaison - State Program Director Technical Teams Federal Partners EPA DOE DOD Ex Officio Association Affiliates WGA and SSEB Permeable Reactive Barriers Phytotechnologies Classroom Training Radionuclides Remediation Process Optimization Risk Assessment Resources Sampling, Characterization, and Monitoring Small Arms Firing Range Unexploded Ordnance December

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

7 Document Contents Site Characterization Pretreatment Sampling Site Modeling Exposure Analysis Historical Data about Site Use Data Requirements Analytical Methods QA/QC Cleanup Levels Closure Criteria Intended Use Receptors Surrounding Community Performance Data Treatability Studies Test and Demonstration Monitoring for Treatment Goal and Fugitive Emissions System Operating Requirements Health and Safety Requirements Feed Limitations December

8 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 December

9 Nationwide Success December

10 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 December

11 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 December

12 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 December

13 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 December

14 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) December

15 ITRC/DOD Partnering ITRC-sponsored training classes and Internet seminars have been well attended by DOD and service branch environmental managers as well as EPA, state regulators, and stakeholders ITRC documents on soil washing and phytoremediation were instrumental in the deployment of these technologies at a firing range on Ft. Dix in New Jersey Massachusetts DEP has used ITRC guidance documents to support review of technologies and processes at the Massachusetts Military Reservation December

16 ITRC/DOD Partnering (continued) The Seneca (N.Y.) Army Depot site manager and contractors used ITRC guidance to place monitoring wells and establish an acceptable work plan for a reactive barrier ITRC provided third-party information at public information sessions to promote acceptance of new technologies at Kelly Air Force Base in Texas ITRC has worked with AFCEE and AFRPA to implement cost-saving groundwater diffusion sampling at DOD facilities December

17 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 Get the information out! December

18 Active Projects Accelerated In Situ Bioremediation Training Alternative Landfill Technologies Brownfields Contaminated Sediments Dense Nonaqueous Phase Liquids Diffusion Sampler Technology In Situ Bioremediation Mitigation Wetlands MTBE-Contaminated Groundwater Permeable Reactive Barriers Phytotechnologies Classroom Training Radionuclides Remediation Process Optimization Risk Assessment Resources Sampling, Characterization, and Monitoring Small Arms Firing Ranges Unexploded Ordnance December

19 Completed Projects Accelerated Site Characterization Environmental Technology Acceptance and Reciprocity Partnership (e.tarp) DOE Gate 6 Technologies In Situ Bioremediation ( ) In Situ Chemical Oxidation Low-Temperature Thermal Desorption Metals in Soils Plasma Technologies Policy December

20 New Projects 2004 Indoor Air Mercury Ecological Enhancements December

21 Accelerated Site Characterization Value: Offers potential to reduce time and costs of characterizing a site before a cleanup plan is chosen Products: Two Technology Overviews Guidelines on technical requirements for SCAPS LIF SCAPS VOCs Status: Closed out in 1998 Success: Document helped Texas use SCAPS LIF at an EPA Superfund creosote site December

22 Alternative Landfill Technologies Value: Reductions in construction, operation, and maintenance costs of landfill covers Activities: Compiling case studies Identifying barriers to the deployment and beneficial use of evapotranspiration covers Planned Technology overview document Products: Technical/regulatory guidance on methods to design, construct, and monitor landfills using alternative landfill covers, including post-closure care Guidance documents on design, construction, and operation of bioreactors December

23 Brownfields Value: Developing a coordinated approach for addressing the issues surrounding the cleanup and reuse of contaminated sites Activities: Subteams researching three issues: indoor air impacts, dynamic work plans, and long-term monitoring and engineering controls Interface with U.S./German Bilateral Working Group in developing/implementing Site-Specific Management Approach and Redevelopment Tools (SMART) Plan Gather information regarding field demonstrations of site characterization, remedial, and field screening technologies applicable to brownfields Develop guidance and workshops December

24 Dense Nonaqueous Phase Liquids Value: Products: Activities: Unremoved DNAPLs sources could continue to contaminate groundwater for centuries Technology Overview Dense Non-Aqueous Phase Liquids: Review of Emerging Characterization and Remediation Technologies Regulatory Overview DNAPL Source Reduction: Facing the Challenge Developing technical/regulatory guidance documents and Internet-based training on characterization and surfactant/cosolvent flushing Producing case study/overview document on thermal treatment technologies; collaborating with Army Corps of Engineers and USEPA Technology Innovative Office on an engineering manual for in situ thermal remediation December

25 Diffusion Sampler Technology Value: Inexpensive and simple way to sample groundwater and groundwater discharges to surface water Products: Collaborated with Navy, Air Force, and Army to develop User s Guide for Polyethylene-Based Passive Diffusion Bag Samplers to Obtain Volatile Organic Compound Concentrations in Wells Developed Internet-based training Created Diffusion Sampler Information Center on Internet Produced position paper on the use of PDBs for long-term monitoring and CD of relevant articles and presentations Activities: Focusing on passive samplers for inorganics (metals, minerals) and combination (inorganics/organics) samplers Evaluating state and federal guidance on use of PDBs Developing guidance for interpreting data generated by PDBs December

26 Environmental Technology Acceptance and Reciprocity Partnership Value: Changing how states review, accept, and make permit decisions on new technologies Products: Multi-State Evaluation of Elements Important to the Verification of Remediation Technologies (VT-1, 2 nd Edition); Strategy for Reciprocal State Acceptance of Environmental Technologies (MOU-1); Tier 1 Guidance Status: Continuing its work as a separate entity December

27 In Situ Bioremediation (current) Value: Streamlining preparation, review, and approval of in situ bioremediation applications for a variety of contaminants in groundwater Products: A Systematic Approach to In Situ Bioremediation, technical/regulatory guidance evaluating applicability of ISB to any contaminant, illustrated by examples for nitrates, carbon tetrachloride, and perchlorate Internet-based training course Activities: Presenting document to state environmental agencies Tracking success of document/training in leading to more ISB deployments December

28 Metals in Soils Value: Products: Status: Success: Treatment could help avoid costly excavation, transportation, disposal at waste facility, capping, and monitoring Overviews of three emerging technologies:! phytoremediation! electrokinetics! in situ stabilization Issued guideline in 1997; updated in 1999 Evolved into Phytotechnologies Team Facilitated community acceptance of soil washing and phytoremediation at Ft. Dix, New Jersey December

29 Value: Small Arms Firing Range Assist decision makers in understanding issues in characterizing and cleaning lead from soil at small arms firing ranges Activities: Completing first product Technical and Regulatory Guide for Characterization and Remediation of Closed Small Arms Firing Ranges Embarking on maintenance and management guide to assist small arms firing range operators to properly design, manage, maintain, and oversee firing ranges with focus on pollution prevention Developing Internet-based and classroom courses December

30 Mitigation Wetlands Value: Status: Replace wetland habitats lost to development or degradation Evolved from Constructed Wetlands Team Activities: Finishing technical/regulatory guidance for constructed treatment wetlands Developing Internet-based training on constructed wetlands Conducting overview to assess authorities that oversee no-net-loss policies affecting restored wetlands Developing technical/regulatory guidance to standardize criteria for evaluating and documenting the performance of mitigation/restoration wetlands December

31 MTBE-Contaminated Groundwater Value: Leaking underground fuel tanks contaminate groundwater with MTBE and other oxygenates Activities: Readying first product for publication Overview of MTBE/TBA Groundwater Treatment Technologies Working to become a forum for regulators and other members of the environmental community seeking to collaborate with groups such as RTDF, ASTSWMO, USEPA, and the American Petroleum Institute Planned Case study database, technical/regulatory guidance Products: document, and classroom and Internet-based training December

32 Permeable Reactive Barriers Value: Products: Activities: Offers potential to restore many types of sites to the standards that can t be met by conventional groundwater treatments Design guidance for groundwater remediation Regulatory guidance for (a) chlorinated solvents and (b) inorganics and radionuclides Basic and advanced Internet-based training Participating in joint projects with other groups interested in furthering the deployments of PRBs Using data from monitoring at tri-services sites to update advanced Internet course December

33 Phytotechnologies Value: Contribute to the understanding of phytoremediation applications, processes, and reliability Products: Phytoremediation Decision Tree document and online tool Phytotechnology Technical and Regulatory Guidance Document Status: Closed out in 2001, but classroom and Internet-based training courses continue December

34 Radionuclides Value: Facilitate cleanup of radioactively contaminated federal facilities by encouraging regulatory cooperation and sharing technological successes and approaches Products: Radiation Reference Guide: Relevant Organizations and Regulatory Terms Developing Cleanup Levels at Radioactively Contaminated Sites: Case Studies Activities: Working with DOE and EPA to update radiation risk assessment training to for classroom and Internet Evaluating characterization technologies to inform technical/regulatory guidance and future training Investigating long-term stewardship issues and needs December

35 Remediation Process Optimization Value: Activities: Planned Products: Focuses on designing and optimizing remedial systems to ensure remedial protectiveness while maximizing risk protection and cost-efficiency and assists states prepare for management of fund-lead NPL sites that will soon be 100% state funded Formed a multidisciplinary team of states, DOD, DOE, EPA, and industry representatives to evaluate options for implementing state optimization programs Participating in RPO visits at federal and state sites, identifying key issues, recurring themes, and lessons learned Guidance document for implementing RPO programs Internet training focused on needs of state regulators Fact sheet providing an overview of optimization programs December

36 Risk Assessment Resources Value: Invalid determinations of risk can lead to remedial responses that are either overly conservative or underprotective of human health and the environment Status: Newly formed in 2003 Planned Activities: Expanding understanding of methods, assumptions, and issues surrounding risk assessment and management in corrective actions Creating a resource to identify and help alleviate unnecessary variability among states and federal agencies using risk determinations to manage cleanups Working with EPA in pilot project to implement a Corrective Action Strategy to streamlining cleanups Surveying ITRC member states regarding various risk assessment approaches and issues Reviewing risk documents and programs December

37 Sampling, Characterization, & Monitoring Value: Addresses innovations and paradigm shifts in sampling and monitoring related to real-time information, continuous monitoring, and long-term monitoring for site closure and stewardship Status: New in 2002 Activities: Working to promote broader application of Triad approach, an innovative approach to characterization that incorporates systematic planning, dynamic work plans, and on-site analytical tools Planning technical/regulatory documents and training on the Triad approach and the use of directpush wells for environmental monitoring December

38 Unexploded Ordnance Value: Innovative site investigation and cleanup technologies to facilitate the safe transfer of former Defense Department training ranges Products: Case Study: Breaking Barriers to the Use of Innovative Technologies: State Regulatory Role in Unexploded Ordnance Detection and Characterization Technology Selection Classroom training Activities: Publishing document on how to research ordnance and explosives historical records Finishing document dealing with site-specific geophysical proveouts December

39 Contacts Web Site: Cochairs, ITRC Board of Directors: Ken Taylor SC Department of Health and (803) Environmental Control Acting Program Director: Tim Titus (202) December