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Regulatory Acceptance for New Solutions. Presented by Brian Sogorka, NJDEP Remedial Technology Manager 609-633-1344, brian.sogorka@dep.state.nj.us. Purpose of ITRC. ITRC is a state-led, national coalition of regulators and others working to. improve state permitting processes and

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regulatory acceptance for new solutions

Regulatory Acceptance for New Solutions

Presented byBrian Sogorka, NJDEPRemedial Technology Manager

609-633-1344, brian.sogorka@dep.state.nj.us

purpose of itrc
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.
goals
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
tackling regulatory barriers
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
other participants
Other Participants
  • Industry representatives
  • Host organization
  • Academia

Environmental Council of the States

  • Public stakeholders
  • Federal agencies
  • State organizations

U.S. Department of Energy

Western Governors’ Association

U.S. Environmental Protection Agency

Southern States Energy Board

U.S. Department of Defense

organizational structure

ECOS/ERIS

State institutional support

Enable state staff participation

Funding support

Fiscal agent

Board of Directors

Two PublicStakeholders (Industry,Env)

Federal Partners

EPA DOE DOD

Ex Officio

Co-Chairs

State

State EngagementState Point of Contact Network (41 POCs)

State

Engagement

Coordinator

Association Affiliates

WGA and SSEB

Ex Officio

Team Leader

Liaison - State

  • Ensure state awareness/use of ITRC products
  • Coordinate training on ITRC products
  • Coordinate concurrence on ITRC products
  • Coordinate concurrence on ITRC products
Organizational Structure

Program Director

Technical Teams

  • Alternative Landfill Technologies
  • Brownfields
  • Constructed Wetlands
  • Contaminated Sediments
  • Dense Nonaqueous Phase Liquids
  • Diffusion Samplers
  • DOE Gate 6 Technologies
  • In Situ Bioremediation
  • MTBE-Contaminated Groundwater
  • Permeable Reactive Barriers
  • Radionuclides
  • Remedial Process Optimization
  • Sampling, Characterization, and Monitoring
  • Small Arms Firing Range
  • Unexploded Ordnance
products services
Products & Services
  • Regulatory and Technical Guidelines
  • Technology Overviews
  • Case Studies
  • Peer Exchange
  • Technology Advocates
  • Classroom Training Courses
  • Internet-Based Training Sessions
document contents
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
benefits to states
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
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
benefits to dod
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)
itrc dod partnering
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
itrc dod partnering13
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
benefits to doe
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
benefits to usepa
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
state engagement program
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
active technical teams
Active Technical Teams
  • MTBE-Contaminated Groundwater
  • Permeable Reactive Barriers
  • Radionuclides
  • Remedial Process Optimization
  • Sampling, Characterization, and Monitoring
  • Small Arms Firing Range
  • Unexploded Ordnance
  • Alternative Landfill Technologies
  • Brownfields
  • Constructed Wetlands
  • Contaminated Sediments
  • Dense Nonaqueous Phase Liquids
  • Diffusion Samplers
  • DOE Gate 6 Technologies
  • In Situ Bioremediation
completed teams
Completed Teams
  • Accelerated Site Characterization
  • Environmental Technology Acceptance and Reciprocity Partnership (e.TARP)
  • In Situ Bioremediation (1995-2000)
  • In Situ Chemical Oxidation
  • Low-Temperature Thermal Desorption
  • Metals in Soils
  • Phytotechnologies
  • Plasma Technologies
  • Policy
accelerated site characterization
Accelerated Site Characterization

Value: Offers the potential to reduce the 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

alternative landfill technologies
Alternative Landfill Technologies

Value: Offer reductions in construction, operation,

and maintenance costs of landfill covers

Status: Newly formed team pursuing some interests of closed-out Phytotechnologies Team

Planned• Case studies document

Products: • Technical and regulatory

guidance document

•Internet-based training

• Consideration of classroom training

• Documentation of deployment successes in ITRC states

brownfields
Brownfields

Value: Environmental contamination

complicates redevelopment of

abandoned, idled, or underused

industrial and commercial facilities

Status: Newly formed in 2001

Activities: • Interface with U.S./German Bilateral Working Group in developing and implementing the 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 and implement training

constructed wetlands
Constructed Wetlands

Status: New team in 2002

Activities: • Developing a Technical and Regulatory

Guidance Document

• Developing an Internet-based training

course and a classroom training module

Value: Self-sustaining

manmade wetlands

built specifically to

treat contaminants

contaminated sediments
Contaminated Sediments

Value: ~10% of sediment under our

surface waters is contaminated

with toxic pollutants

Status: New team in 2002

Activities: • Interface with others, such as

U.S. Army Corps of Engineers, USEPA, port

authorities, USEPA’s Remediation Technology

Development Forum, and USEPA’s Sediment

Management Work Group

•Collaborate in site demonstrations, including

demonstrations of technologies to handle large

volumes of dredged materials from harbor areas

•Review related work by other groups, including

white papers, technical papers, decision trees, and

draft guidance

dense nonaqueous phase liquids
Dense Nonaqueous Phase Liquids

Value: Unremoved DNAPLs sources could continue to contaminate groundwater for centuries

Products:•Technology Overview—Dense

Non-Aqueous Phase Liquids: Review of Emerging

Characterization and Remediation Technologies

•Regulatory Overview—DNAPL Source Reduction:

Facing the Challenge

Activities: • Developing Internet-based training modules and three

technical/regulatory guidance documents:

characterization, surfactant, and thermal

• Working with federal partners (EPA, DOE, DOD) on

deployment and documentation of DNAPL

characterization and treatment technologies

diffusion samplers
Diffusion Samplers

Value: A relatively 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

Activities: • Participating with DOD, DOE, and private industry to

demonstrate this technology and identify potential sites

for deployment

•Compiling and evaluating data to facilitate deployment

of this technology

• Developing guidance for implementing diffusion bag

samplers for long-term monitoring

doe gate 6 technologies
DOE Gate 6 Technologies

Value: Engages ITRC technical teams

with DOE technical efforts

Activities: •DNAPLs and RADs teams participate in

DOE conferences and review work plans

for new demonstrations or deployments

•Characterization, Sampling, and

Monitoring;DNAPLs; PRB; and RADs

teams pursue opportunities for partnership

between ITRC and DOE

environmental technology acceptance and reciprocity partnership
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, 2nd Edition);

Strategy for Reciprocal State Acceptance of

Environmental Technologies (MOU-1); Tier 1

Guidance

Status: Continuing its work as a separate entity

in situ bioremediation closed
In Situ Bioremediation (closed)

Value: A cost-effective solution in many cases of chlorinated solvent contamination in soil and groundwater

Products: Two classroom training courses and seven documents, including case studies and a technical and regulatory overview

Status: Closed out in 2000

in situ bioremediation current
In Situ Bioremediation (current)

Value: Streamlining preparation, review, and approval of in situ bioremediation applications for a variety of contaminants in groundwater

Planned A Systematic Approach to In Situ Bioremediation:

Products: Nitrate, Carbon Tetrachloride, Perchlorate, a

Technical and Regulatory Guidance Document

evaluating the applicability of ISB to any

contaminant of concern and illustrating this

systematic approach by providing examples for

these three contaminants

Activities: Developing an Internet-based training course

in situ chemical oxidation
In Situ Chemical Oxidation

Value: Shows promise in quickly destroying or degrading an extensive variety of hazardous wastes in groundwater, sediment, and soil

Products: •Technical and Regulatory Guidance for

Using In Situ Chemical Oxidation to

Remediate Contaminated

Soil and Groundwater

• Internet-based training

course

Status: Closed out in 2001, but

Internet training continues

low temperature thermal desorption
Low-Temperature Thermal Desorption

Value: Removes hazardous solvents and other contaminants from mixed waste, reducing waste volume and lowering disposal costs

Products: Guidelines on technical requirements for

•petroleum/coal tar/gas plant wastes

•chlorinated organics

•mixed waste and/or mercury

Status: Closed out in 1998

Success: Contributed to $100/ton savings for treatment in New York

metals in soils
Metals in Soils

Value: Treatment could help avoid costly excavation, transportation, disposal at waste facility, capping, and monitoring

Products:•Overviews of three emerging technologies:

phytoremediation

electrokinetics

in situ stabilization

•Issued guideline in 1997; updated in 1999

Status: Evolved into Phytotechnologies Team

Success: Facilitated community acceptance of soil washing and phytoremediation at Ft. Dix, New Jersey

mtbe contaminated groundwater
MTBE-Contaminated Groundwater

Value: Leaking underground fuel tanks

contaminate groundwater with

MTBE and other oxygenates

Status: New team in 2002

Activities: • Develop an overview of treatment technologies for

MTBE-contaminated groundwater

• Develop a technical and regulatory guidance

document and Internet training

• Interface with other active groups such as RTDF,

ASTSWMO, USEPA, and the American Petroleum

Institute

permeable reactive barriers
Permeable Reactive Barriers

Value: Offers potential to restore many types of sites to the standards that can’t be met by conventional groundwater treatments

Products: Regulatory guidance for (1) chlorinated solvents and (2) inorganics and radionuclides and (3) design guidance for groundwater remediation

Activities: •Offers Internet-based training

•Involved in a DOD long-term performance

monitoring project

Success: Process—from design through installation—took less than four months in New Jersey

phytotechnologies
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

plasma technologies
Plasma Technologies

Value: Thermal treatments that have potential to treat hazardous, radioactive, military, and medical wastes

Product: A Regulatory Overview of Plasma Technologies

Status: Closed out in 1998

policy
Policy

Value: Investigated state use of performance-based systems and voluntary cleanups

Products: Two case studies:

•An Analysis of Performance-Based Systems for Encouraging Innovative

Environmental Technologies (POL-1)

•Case Studies of Selected States’ Voluntary

Cleanup/Brownfields Programs (POL-2)

Status: Closed out in 1998

radionuclides
Radionuclides

Value: Facilitate the cleanup of radioactively contaminated

federal facilities by encouraging regulatory cooperation and sharing technological successes

and approaches

Product: Radiation Reference Guide: Relevant Organizations and Regulatory Terms (RAD-1)

Activities: Producing two case studies:

•Developing Cleanup Levels at

Radioactively Contaminated Sites: Case Studies

•Stewardship and Technology: Challenges for

Future Management of Radiologically

Contaminated Sites and Associated Case Studies

remedial process optimization
Remedial Process Optimization

Value: Regulatory issues and emerging technology can affect optimization of operating remedial systems; faster approval times will result from state and local environmental officials understanding RPO goals

Status: Newly formed in 2001

Activities: Forming a multidisciplinary team

with DOD (all branches), DOE, EPA,

state, and stakeholder participation

to evaluate the effectiveness of

existing RPO programs

Planned Guidance document summarizing

Products: available approaches to RPO and

identifying key regulatory issues and technology acceptance processes that affect implementation

slide41
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: Newly formed team

Activities: •Preparing inventory of field analytical

technologies

•Developing guidance document

•Educating regulators, vendors, and site

managers

Sampling, Characterization, & Monitoring

small arms firing range
Small Arms Firing Range

Value: Assisting DOD and states with identifying appropriate technologies for cleanup and maintenance of lead-contaminated firing ranges

Planned •Technical/regulatory

Products: •Maintenance/management document

•Internet-based training

•Classroom training

unexploded ordnance
Unexploded Ordnance

Value: Examining the problem of

military munitions

contaminating Defense

Department and private sites

Products: •Case Study: Breaking Barriers to the Use of

Innovative Technologies: State Regulatory Role in

Unexploded Ordnance Detection and

Characterization Technology Selection

• Classroom training

Status: Developing Internet-based training and multiple Technical and Regulatory Guidance Documents

contacts
Contacts

Web Site: http://www.itrcweb.org

Cochairs, ITRC Board of Directors:

Brian C. Griffin Oklahoma Secretary of Environment

(405) 530-8995 bcgriffin@owrb.state.ok.us

Ken Taylor SC Department of Health and

(803) 896-4011 Environmental Control

taylorgk@dhec.state.sc.us

Program Director:

Rick Tomlinson rickt@sso.org

(202) 624-3669