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On behalf of the interstate Technology and Regulatory Council Welcome to today's training remediation management, of complex sites.

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My name is Devin, Setcar. I'm your moderator today from Arlington, Virginia.

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So this zoom webinar it or excuse me, zoom training is recorded. Just so.

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Everybody knows, and we do have live transcripts enabled.

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So if you need that, you can see that at the bottom of your screen, and remember, at any time you can submit questions or any technical difficulties into the Q and A.

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Pod, and I will answer any technical difficulties in point.

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Those questions toward our trainers for our 2. During our 2 Q. A.

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Breaks. This training is an introduction to the Associated Online guidance document noted on this slide.

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Remediation management, a complex sites. This guidance document was produced by Itrc in 2,017.

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We hope it will serve as a resource for you, as you are working on your environmental sites.

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Today's training is sponsored by the interstate technology and Regulatory Council or the Itrc.

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And is hosted by the Us. Epa Cleanup Information network.

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Also known as Clewen. Today's training is scheduled for 2 h and 15 min, and like I said, is being recorded while we're in the Zoom webinar.

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You're not able to access any of the live links and excuse me.

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The live web links in our slide deck. You can access those links through the downloaded Pdf Format of the P.

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Of the Powerpoint on the clue, and training page that brought you to the course today in Zoom you have access to the Q.

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A. Window where you can put any questions or technical difficulty at any time, and we will address those throughout the training.

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There's online feedback form for you to complete at the end of the training today by completing the feedback form, you're will be eligible to receive your certificate a completion to support your continuation excuse me your documentation of continuing education, at the end of the

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feedback form. You will check a box to certify that you participated, and in a certificate will be emailed to you.

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The interstate technology and Regulatory Council is a program of the Environmental Council of States.

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We are a state-led organization, composed of over 1,000 members from State agencies, Federal government, The private sector, academia and community stakeholders.

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Our members participate in technical teams which produce tools, resources and training courses, such as the one you're participating on today If you'd like to be a part of Itrc please, visit our website or feel free to contact Us.

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Directly on our website. You can register for teams and learn more about how you can become an active member.

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The full Itrc disclaimer is available on our website.

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If you do plan to use Itrc materials, we ask that you review that policy in detail, and be sure to credit Itrc.

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Accordingly. Irc. Is partially funded by the Us.

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Government, Itrc. Nor the Us. Government warranty the materials, or endorse any specific products.

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Okay, on slide Number 5. I appreciate the opportunity to introduce our expert trainers today.

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All of them have been active members of Itrcs.

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Remediation management, a complex sites team over the years.

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Not only do they service volunteer trainers for Itrc.

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They have also dedicated many hours to develop the guidance document that is used in this training today.

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A special thank you to all of them for participating today.

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So for today our trainers are John Price, from the Washington Department of Ecology.

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Thank you, Devin. So what is the challenge at complex sites?

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Why was this guidance written as profession? We have about 40 years of experience with environmental remediation, but at many sites complete remediation is still a significant.

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Challenge? We may have taken care of the immediate risk to human healthy environment, but it may be decades, or even longer, to reach regulatory standards at other sites.

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Remediation progress may be uncertain, although each site is unique, We wonder if anyone has solved the problem like ours as an Itrc team We came up with the following description of a complex site a site where remediation progress is uncertain and remediation is not expected to achieve closure or even

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long-term management within a reasonable timeframe.

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Would you bring up the poll? Devin: Okay, thank you. As an itrc team.

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We came up with following description of complex site, a site where remediation progress is uncertain, and remediation is not expected to achieve closure or even long-term management.

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Within a reasonable timeframe. The poll question that was presented when people were signing in highlights some examples of challenges that we all face at complex sites We'll talk more about those site challenges in today.

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Today's training

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Okay, Thank you. Yeah, Actually, Devin: I wanted this. Did we have a poll when we were signing in? That was a poll.

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I wanted to pull up. Okay, Yeah, that was the one

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Looks like you're a little trouble with poll results. No worries.

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Sorry Sorry about that, John. Okay, alright, there we go

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Okay. Well, we'll pull that

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you're doing that. Okay? So there's our results here.

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We got a pretty wide spread there as far as what people think makes a complex sites.

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Okay, So I'm gonna go ahead and go to a case study.

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These are 2 examples of complex sites. We have 16 case studies presented in the guidance document.

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The first photo on the upper left hand corner is the an aerial view of the rocky, flat site in Colorado.

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This former department of energy facility is 10 square miles, and was used for manufacturing parts for nuclear weapons.

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The 7 billion dollar cleanup was completed in October.

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2,005, and at the time was the largest environmental cleanup of a circular site.

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Our case study features, remediation efforts At just one of the 4 groundwater plumes which was sourced from 5, solar evaporation ponds that were used to store low-level radioactive waste and other waste the commingled uranium and nitrate

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plumes covered 50 acres; The second photo in the lower right hand shows investigation work in a residential area affected by vapor intrusion and groundwater contamination down gradient of the Moffatt field Middle field Ellis Wishman which is a mouthful so we'll just call

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that the mew site throughout the rest of this training this side is complex because of multiple source areas, multiple responsible parties, addressing commingled plumes, multiple aquifers that were actually 8 zones, geologic heterogeneities, multiple exposure pathways, and residential land use

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Nationwide. There's been a lot of interest in complex sites, but there has been little guidance for tackling the challenges of these sites.

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A National Research Council or Nrc. Report in 2,013 sparked our interest in forming an Itrc team on this topic.

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That report estimated that a approximately 10% of sites nationwide are complex with a total cost to complete estimate.

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At that time of 127 billion dollars that cost a complete continues to grow by 2017.

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The government, Accountability Office reported the Federal Government's estimated environmental liability was 400, and 65 to 1 billion dollars.

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That was the third largest non-discretionary liability for the Federal Government.

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The Nrc. Committee rather the issue of complex sites, but noted that we, reaching agreement on which site should be included in this category.

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And what should be done with such sites as proved to be difficult, and that made a clear need for additional guidance.

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This itrc guidance is for State regulators, site owners and their representatives and other stakeholders working at complex sites.

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Our Itrc team was large into verse. We had almost 200 team members, which at the time was the largest team that Itrc had ever had.

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We had representatives from different groups. This guidance represents a recommended process for mediation, management.

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Complex sites. We call that process adaptive site management.

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This guidance incorporates a refers to best management.

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Practices brought together existing tools and technologies described in previous publications by the Us.

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Environmental Protection Agency, Itrc itself. The Department of Defense and others.

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We've included sixteenth case studies where regulatory decisions have been made, But for many of these case studies it will take decades to establish whether site objectives have been met, stakeholder perspectives at these complex sites are also summarized one thing you can do at your own complex

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Site is ask different parties, what is their definition of success for the site?

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If you'll likely hear different answers from the site owner and their consultants, regulators, and community interest groups

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This slide presents a roadmap to today's training which follows the organization of the guidance.

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It's a little small here, but there is a full-page version of the flow chart under additional resources.

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And this figure was also provided along with your registration information.

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Following my introduction, we will talk about site challenges, which is the content.

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From chapter 2 of the guidance will present a remediation potential assessment which is covered in Chapter 3 adaptive remedy, selection, and long-term management We'll also highlight case studies throughout and talk about stakeholder engagement throughout the training stakeholder engagement

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is summarized in Chapter 6 and 7, of the guidance This flow chart shows the adaptive site management process.

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The color coding corresponds with each chapter, where the steps are discussed in detail.

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Adaptive site Management is a comprehensive, flexible, and iterative process.

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That as well suited for complex sites, where there are significant uncertainty and remedy, performance, prediction, adaptive site management involves periodically evaluating and adjusting the remedial approach.

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Against interim objectives. It may involve multiple technologies at any one time, and may involve changes in those technologies over time.

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Since we're advocating adaptive site management, Let's talk about what we can accomplish using it at complex sites.

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For first of all, it does not offer shortcuts or the means to avoid site.

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Remediation. We need to continue to maintain protection of human, healthy environment, to fulfill regulatory environment requirements, Adaptive site, management can improve site decisions, a streamlined, decision, making decreasing remediation costs in the long term and potentially reducing your mediation

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timeframes. It can help establish milestones to demonstrate air in progress that eventually leads to the long-term goal. It can reduce potential technical, regulatory, and procedural barriers to using various remediation management approaches by that exist but are infrequently

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practices, practice and it encourages returning all or part of the site to beneficial reuse.

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Earlier in the remediation life cycle remediation.

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Milestones are reached, While recognizing that additional time is needed to achieve overall site objectives.

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Okay, let's go to another case. Study. This is one of my favorites.

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as practitioners at complex sites. We all get to the point where we learn from our prior actions.

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I like this case, study for the Naval air Station, Jacksonville, Florida, because it specifically calls out adaptive site management.

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Many of our case studies used adaptive site management, even if they don't call it out as such at the Naval Air Station.

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The conceptual site model was refined, which we emphasize throughout this guidance that refinement facilitated, discontinuing, interim remedial actions, and conducting additional site characterization to reduce remaining site risk the site moved to risk-based remediation approach

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supported by technology demonstrations.

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I've mentioned stakeholders a couple times already.

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Adaptive site. Management includes stakeholder involvement throughout the process.

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Stakeholders include all groups and individuals potentially impacted by the project. Complex sites.

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There may be multiple stakeholder groups, and they, like have a long site history to take into account.

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As I mentioned previously. Chapter 7 provide stakeholder perspectives and concerns at complex sites, and as well as best practices, to help stakeholders engage with owners and regulators.

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We recommend, involving stakeholders early to build Trust with them, foster respect and improve the quality of decisions.

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The experience at complex sites indicates that effective stakeholder engagement reduces the cost of remediation and long term management.

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one of the practitioners involved with developing this guidance, said frequently, stakeholders enter the remediation process with different goals or priorities than responsible parties, or regulators, so stakeholder groups may have competing interests or perspectives among themselves our experience across

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The Us. Has shown, however, that robust stakeholder involvement can enhance community acceptance by modifying our plans and activities, and by informing stakeholders about the existing program when all parties are informed remediation often progresses faster and more efficiently okay, back, to the

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mew case. Study again one of the remote, unique aspects of Itrc is that we include community stakeholders on the teams that develop guidance.

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Our team had multiple stakeholder representatives because of their H degree of interest in complex sites, Stakeholders contributed to several of our case, studies which is reflected in those case studies descriptions of community involvement this case study was actually nominated by the stakeholders the stakeholders

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the Mew site influenced changes to characterization and selected remedy essentially became part of the remedy, because they recommended local zoning and permitting requirements that Address vapor intrusion problems at this site this case study is an example of how remediation process and outcomes can

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improve because of stakeholder involvement. Yeah, okay, let's talk about what you'll be able to do after this training. But into this training you should be able to identify and integrate technical and non-technical site, challenges into a holistic approach or remediation you'll

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use the remediation potential assessment tool that we're going to talk about in a little bit to identify whether adaptive site management is warranted due to site complexity.

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You should be able to understand and apply adaptive site management principles, you should be able to develop a long-term performance-based action plan.

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You should be able to apply well demonstrated techniques for effective stakeholder engagement, and will allow you to access additional resources, tools and case studies that are most relevant for complex sites.

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We hope that you'll communicate the value of this guidance to regulators.

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Practitioners, community members, and others.

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Okay, that concludes the introduction. The training, And there are many of the sections of the training We will be discussing again.

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Site Challenges remediation, potential assessment. A tool will have a question and answer period.

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Then we'll talk about adaptive remedy, selection, and long term management We'll prepare you to take action, and then we'll have a final question, and answer.

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Thanks, John. Can you hear me

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Oh, fantastic! Alright! Well, hi everyone and and thanks for the introduction.

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Okay, what I'm going to do is summarize chapter 2 of the guidance document, and the chapter is to, as you can see here, identify and integrate technical and non-technical site challenges into a holistic approach to remediation and just a quick note the guidance

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is somewhat limited to aquifer remediation, and I think this chapter is important, because if you see at the little tiny remediation process decision diagram on the right which starts with a an orange rectangle on top it's it's instructing you to develop the

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conceptual site model as a first step, but it wants you to take into account challenges.

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You might run into during remediation. So site challenges have been narrowed down to about 11 categories, which were shown on your poll, earlier, and they either fits into technical or non-technical challenges.

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So I've got about 20 min to go over these 11 types of challenges, and then I'll hand it over to Chuck.

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And now I need to advance the slide. There we go.

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Okay, great. So, of of course, would most people want to answer is, what is a complex site? And you also had a poll on this.

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It sounds like almost everyone on this presentation today has participated in the complex site, and of course, we are a whole industry.

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if you were easy we wouldn't have work, and anyways an important part of this guidance is really to look at example case studies.

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And so I I suggest going through those summaries to to see what others have done.

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so one example of of of a site is mine waste remediation.

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And this is definitely complicated, to say the least. In fact, there's an entire sector of our industry dedicated to these type of projects.

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Itrc, for example, has mining waste guidance with 22 remediation techniques to address mining influence, water and solid waste and our guidance.

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That I'm scheming about today has examples from the Tri-state mining district, which is what you can see on the on this, on this cartoon here and the sites here Impacted multiple watersheds, multiple communities 3 states and 2 different epa

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regions, and you know the the masses, the massive source of lead and zinc.

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That was mine in this area played a nice role in in winning World War.

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2 and positioning the Us. As a world power. But the downside, of course, is the devastating effect of these developments on various ecosystems.

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Human health, and and land itself. The mind tailings from the case.

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Study on this slide. They're locally called chat piles, and they're so big you can practically see them some space.

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So, exposing these subsurface materials to atmospheric conditions created pathways for toxic contaminants to reach humans.

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And just just as an example, there was a study in the 1994 measuring lead levels and in the blood of children.

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So this this in turn, required, providing the whole community with bottle, water, and and relocating the entire towns.

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So adding to these complicities is the fact that stakeholders here include a number of local native American tribes with unique yet legally complex leasing requirements which add expensive components to to the cleanup.

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Process so it wasn't difficult to agree amongst the group that this is a complex site, and and in a way, size does matter and And you know, that's why we when we operate.

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Do we? We tend to tackle the problem site, narrow it down to operable units, and and clean up small portions at a time.

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But what does a team understand as complex sites and whoops?

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Is there a poll up? Okay, I think there's a pull up asking you guys which roommation timeframe usually makes for a complex site.

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so go ahead and and tagging your answers, which range from 10 to a 100 years, or or alternately, that timeframe does not determine the site complexity and we can talk about your room results in just a minute but if we look at the slide which I can there's a pull

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here, there, we go, sorry at compass sites. Rumination progress is uncertain and remediation is not anticipated.

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To achieve, closure, or even long term management within the reasonable timeframe.

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So that's where the time component comes In The next bullet says that you'll have technical and non-technical challenges.

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Great results are in. So I see that about 5% can say that if it's even over 10 years, it can be considered complex or over 30 years, 35%.

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But more than half of you agree that timeframe doesn't necessary.

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Determine if site is complex or not, I think it'll be interesting to compare the results of today's attendees with the results of the group.

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When we were developing this guidance, the last bullet on the slide is an important reminder that when you end up identified challenges early on you can improve your conceptual site model and and and maximize remedial effectiveness so a successful conceptual site, model on a complex

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site. We'll have input from many experts, not just remediation experts, but toxicologist, regulator urban developers and the stakeholders that John spoke about alright.

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So, going to the next slide, let's compare our results today with a similar poll.

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Send to every state point of contact. When preparing this guidance.

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And it's it's somewhat similar. The pie chart shows that that to a degree, a lot of people don't think that remediation time is is a factor is a factor when when classifying a site as complex or not and then a majority, I guess assume that if you can't clean it

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up within your your lifetime like 30 years or so.

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Then then it's probably complex. In any case, the concept of complex site includes the term reasonable timeframe, and although time is a concept difficult to agree, on complex sites do take longer and that's a fact so Anyway, let's let's go to to the challenges

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Here is the list that you spoke to, and we are dividing them by technical.

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On the left and non-technical on the right.

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And look how of the 5 technical terms 3 have the Geo in them.

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So I guess that's important. Let's go to the first one.

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geologic, related site challenges. We'll start with heterogeneity if conditions can vary by the foot.

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Honey. These huge projects You can imagine that trying to model or predict how to do things is is is complicated.

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Nature, a fracture bedrock for us in history we we we know this is complex.

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yeah, in 2 weeks. You think that a non permeable rock is is protected from contamination.

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But yes, the little tiny cracks and cleavages, and soak up toxic chemicals, and and ultimately rock is is kind of difficult to clean.

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Up. This also goes for Karst bedrock.

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These are difficult to think about. Sync wholes and hard water, or these preferential flow.

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Pass where a small spill here could appeal my miles away, and and and last on list is low probability media.

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So, think about clays, or or the sticky material and aquifers.

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These are very good at trapping contaminants, and unfortunately they do release them at the diffusion rate that is just high enough to become a problem, and not let us close the site or clean it up.

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so what I think that has some animations. Yeah, something about geology.

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This is a pretty cool example We can use high resolution probing where you punch holes in the ground, and you find out that you might have a well, that's little dirty and then, another one that's also kind of dirty at some death.

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And then you punch another. Hold down here, which is clean.

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So just to make a cartoon of as engineers, we'd say Well, there's probably a layer that's 30, and this let's let's go ahead and install a barrier here to protect the ingredients but that's when you need the input from

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a trained geologist who would quickly recognized by the boring lines in the and the setting.

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That this is but the positional setting with that would strategy graphic heterogeneity from from the environment of, say, like a river channel that shifted lottery over time.

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So you can learn that there's very little hydraulic conductivity between these hypothetical wells, even though their screen across apparently similar units.

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So there we go. Yeah, which is so important. The next type of challenge is hydrogelogic conditions.

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So this is technical. Challenge 3 or 5, and then aquifer is composed of, you know geologic material and groundwork. So of course, the hydraulics are important.

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fast ground water, for example, in the in the narrow canyon, with Charlotte bedrock can wash away treatment so that could be an example.

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Why the speed is is complicated, excessive pumping.

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let's say in thirsty Los Angeles, where the refinery old and apple, spills, they can smear through great variations in water tables and create submerged elm apple ganglia, over tens of feet which which is a very challenging situation to get these

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blobs of contamination out of the ground, or treating one, for dioxin in in the desert, like Tucson Tucson, which has very deep aquifer.

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That's the highly necessary or ready nuclei 250 feet below ground surface at Hanford.

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So contaminant depth is is definitely a challenge The little cartoon on the picture on the right is conceptualizes that when you have, you're trying to clean up an area that has surface water groundwater interactions And this is supposed to be the F area And the savannah

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river in South Carolina shows that there's a lot of at stake in these types of situations.

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We're at that particular side. There's radioactive material.

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There's wet lens. Yeah, and it's in the sensitive ecology sediments, which is an industry on its own surface.

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Water groundwater, and and of course, this ads several dimensions of of complications

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Geochemistry is also the last of the Geo words, and there are certain geochemical conditions that complicate things.

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for example, if the groundwater is becoming very acid, and inhibits the natural attenuation, or or or if there's changes in the redox conditions that can release toxic metals to drink and water sources and then if you look at that picture on the right you know there are

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certain, very difficult to access sites where you might need to wait for a child to free.

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So you can drive your truck to a spill in Alaska and and try to get a sample.

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That's when it's 40 degrees minus 0 to determine If B text, the K Rates are acceptable for attenuation or not just just to name an example of of weather.

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Conditions and and I guess one of the most important challenges is what you're trying to get rid of.

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And contaminate related conditions in our industry, we can be remimidating pesticides, fertilizers, explosives, and and all sorts of impacts from human activity or or naturally occurring industrial discharges, accidental spills etc and within our group

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we tend to regroup these contaminants, due to their difficulty, looking up, as, as, for example, they can be an apple or or dissolved in water, we can call them or call so trends and this implicitly is complex, or or they can enter the emerging

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contaminant groups, and And Itrc has guidance on for all these concepts

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Okay, So let's close where we started. Large scale sites as as we.

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As I spoke about before the context of the location can can make a site more or less challenging, whether it's a busy port, and in Boston more Rotterdam or Annull spilling in Alaska you know hundreds of acres of chat pals.

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close to communities that made this Tri-state mining area a difficult just for its sheer size.

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and and the fact is that these tough projects, bringing, of course, technical, political, and economical issues, You may have multiple sources and and broadly disperse container, etc.

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And with this we wrap up the technical considerations, and so I'm going to show you a case study, And this is a case study where a solution called a technical impractability wave was used I'm speaking about the manufactured gas plant sites

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that started in the thousands of gallons of out of spec Coltar We're we're dumped in the in the pits that eventually licked into very difficult to characterize.

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Like a fractured bedrock, and much of this dean apple that tends to Sync has oozed into the Susquehanna River and and by the until the mid nineties the site entered the superfund program and since then You can imagine Sheet piles have you Driven

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between the plant and the river Sediments have been dredged out, but at the end of the day a technical practicability waiver was was was chosen as an option.

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Which what happened here? Is There's a compromise solution where the the Dean apple was considered not very soluble.

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and the river concentrations met the standards so trying to recover this residual Dean apple on this very that that's very weathered and sick and and difficult to locate with with existing technologies was not only very expensive and difficult but in fact, it has the potential

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to create new routes, or or liberty. A suite of toxic constituents that are otherwise semi-controlled.

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So with this example, I'll go to the non technical challenges that you saw on your pull.

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I wonder if you guys can remember any of them

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And here they are. Notice that these complexities make more sense, or or become more relevant when when you're expecting very long timeframe as As a factor so we have these challenges, grouped in in 3 categories.

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those related to the purpose, or or perceived purses of of the of the cleanup intervention?

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Did our goals move from risk-based to maximum contaminant levels, or vice versa.

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our our homeowners or pressure groups, afraid that these these clean up efforts can can lower their property value if it's gonna take forever other additional expenses that weren't previously expended on the premises green and sustainability process then there are other types of

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challenges associated, with which authority and accountability, and and of course, the legal framework, which is an important factory that drives our industry, and and here, at least in the Us It's, not uncommon to have overlapping regulatory.

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Responsibilities This, in turn will offer. For example, Federal and State cooperation, or Epa State and Department of the fence, and and and cooperation with the potentially responsible parties, etc. or there are cases when we just don't have an actual responsible party and

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lastly, is, is these challenges associated to to change management?

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think about long time frames. We're staffed one over.

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We'll lose institutional knowledge. So you you have to think of ways where you can hand off the challenges you had to to the next generations, and there are more challenges.

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I wonder if you remember? Here are the rest. Institutional controls These types of methods are useless.

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If they're not properly managed or or respected land use, which changes conceptual site, model and and exposure pass, and and the last one who's gonna pay for for all, this, how much is it gonna cost and and how what is priority of of this expense compared to

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other important expenses. There's a little picture there on the right, and it belongs to the Rocky Mountains Arsenal case, study which is one of the examples that you can go through in the in the and the Guidance and Yeah, at the side a lot, of very toxic chemicals would

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produce, like Sarin, or Ddt. All sorts of venom and Agent X.

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And they were starting window less concrete mono list.

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Then hopefully, we're resistant to You know. We're talking about the Cold war here, and one of the solutions to to to for this was turning part of the site into a Nash.

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A huge national wildlife refuge which helped the bald Eagle recover from from being endangered

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Here is an example where we're highlighting a non-technical challenge.

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This is the vesicle site in Michigan. A quick review.

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This is what very toxic pesticides were manufactured.

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There's Dean Apple, or or Dvd.

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In pure phase that leads into this this pine river, and this site is Sms, because the little red robins didn't have the luck of the all legal, and in the previous case study but as as in many sites how are the size there were a lot of complications finding responsible

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parties. And then all these legal things, So there was a confidential side.

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Bio out, follow by some bankruptcy, and and and then the call of a custodial trust to finally move this clean up to the super fun.

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Let site, and then clean ups Efforts at the site include a lot of excavation dewatering, residential cleanup, and and, in fact, some thermal remediation So with this.

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I think I've quickly gone over 11 types of site challenges you will definitely encounter in in all sites, and you should somehow consider them when preparing your conceptual site model and before handing finishing my part, I'd like to go over how a conceptual site model is expected to change with time

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of course, as you gain more information, and and and and try different things, and this is generic cleanup steps, and their relation to the conceptual site model maturity.

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So, even before adding the cyclical nature of the adaptive Site Management strategy that we are promoting.

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With this guidance our concept site models are constantly evolving

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Okay, So you you you likely recognize the list of technical challenges.

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We went through complex sites will be disproportionately more expensive and always longer. Time.

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Friends are expected. So like, I said before, it is important to learn to work with multidisciplinary teams, to help recognize different types of challenges that will eventually emerge.

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When designing your conceptual site model and then go through your queue.

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Your clean up program great. So with that, I think I'm ready to hand it over to check.

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Well, thanks. David. Well, to start out, John told us why we're here basically.

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And then David came in and told us, This is a really difficult world that we live in this roomediation world.

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Now what I'm gonna do is try to describe this process.

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A process of 8 questions that informs you about a remediation assessment.

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Potential Really, this question is, Can you get there from here? Can you achieve your mediation objectives?

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And so with this process, you have the option to to, you know, work qualitatively or semi quantitatively and it's very adaptive and very flexible.

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First, let's go in and talk a little bit about the the learning objectives, and and what this thing's all about.

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So we got on this slide here, our learning objectives. We can see the the different information about the We have a flow chart.

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What would it be You know, an itc document without some learning objectives.

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But under a this chapter 3. This remediation potential assessment, we have going to use this approach to identify whether adaptive site management's warranted due to the site challenges.

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So the real, end goal here is you're gonna go through this process.

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Answer these 8 questions, and then at some point, you're gonna get some answers and say, no, maybe adaptive site management is not necessarily needed, or more likely for dealing with a complex site.

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Yeah, this is exactly the process that we need So let's go to the next slide.

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And we're gonna talk about different processes and outcomes, and in terms of of this particular process, And we've got this setup on the process side, What is this thing?

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It's a process. That's a screening tool that uses this weight of evidence approach to assess a site is likely to achieve remediation objectives and a reasonable time frame and that's it's also a basis for aligning everybody's expectations, about what you can do And

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can't can't do at a particular site, and you know they're really 2 extremes here.

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And then let's say if you've got a group of stuffholders, they're very diverse We've got a lot of different opinions on one side.

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There's there's one person who says we've got to do this remediation to every last molecule of contaminants been removed.

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It can be pretty difficult, based on what we know about mediation and fate and transport of our contaminants.

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The other hand, somebody else might say, on the other, extreme, Hey, we can't clean this side up.

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Let's just walk away from this. There's no need to do anything, so this will be 2 extremes, But the going through this process it helps people align and understand different perspectives, and get that group to work, together.

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And to to understand, or to try to determine how we're gonna manage this complex sites.

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The number 3. It's this process that promotes effective and transparent interaction between people.

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and the stakeholders, And so that's on the process side and on the outcome side.

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This is this sort of the this the end goal, I guess, is that you're going to determine if your site clean up objectives, they are attainable or that this remediation potential is low, and you should consider this adaptive site management dive into the it or so quote itrc flow

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chart and get the things to to work out in here.

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Now one quick note is it's not really this this yes, no thing that you're gonna go through here and just say, Hey, I'm gonna I'm gonna yeah, they're either attainable, or not there's a there's adapt to.

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Site. Management. It's also useful for sites where you actually say no.

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We think we can get there. So it's is this adaptive site management concepts, this key thing and this remediation potential assessment to way to assess you know, when you're when you're really gonna need it but it also has other benefits in cases where it might not necessarily

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be be sort of the key thing to do. Okay, to explain this thing.

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I thought it would go into this. The simple example. And this is actually something that happened to me where my brother in law came in and was talking about a property that he inherited from from his dad and this is this idea that if you're an expert in something and you get asked a question by a lay

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person, you Quickly come into your mind about a series of questions that you can.

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You can sort of the try to get the information for options, and it quickly comes to a conclusion solution.

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This is echoes of my actual PHD program.

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Many years ago, where I wasn't working with rule based systems and artificial intelligence.

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An expert Ts had these series of key rules. And so let's just say, at this site that somebody came to you and said I've inherited this property and then it's a gas station.

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I'm worried about this groundwater contamination, So you say.

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Well, how big's the site? And they say, Well, I got this map here.

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It's actually pretty small, and how how how deeps the groundwater! It's pretty close to the water table.

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Hey, What does that transmissive unit look like this geology?

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Oh, okay, here's these boring laws, hey? It's mostly Sam.

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And you might say, Well, how big are the concentrations, How high are they?

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Pretty low at this side. Here's this map, and you showed that your friend of the maps of this stuff, hey?

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It's Benzene. It's pretty fast in a subsurface.

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Hey, Do we see any of that Eln apple stuff?

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Nothing showing up here. So then you would say, just based on those questions about a couple of key facts of these things, these essential nature of the site, You could tell your your friend I don't think this is going to be a big problem.

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This is one of these things that's that is definitely going to be manageable.

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And the your friends very appreciative, and he's very happy and then you get a nice Christmas present from them, you know.

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Maybe a ham, or some you know, like, with nice bottle of wine.

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Everything works well So that's on one side of how an expert might quickly process with a series of questions.

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Can you get there now. The other hand Yeah, another friend comes and they're talking about this site, and they're looking at this, and they've beenherited this, property?

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And you know it's a large site, and it's oh, the contamination is really deep Lot of the sources under a big building.

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It's gonna be hard to get get to it, you know.

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It's a the hydrogeology is more pernicious. It's sand.

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So fractured, plays, you know there's not that much 5 degradation going on with these compounds, you know, So that's that's a negative, and you gotta go a long way you need more than a 99.9% reduction, in concentrations.

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So you're gonna be honest with your friend and say, this is this is a big issue for you.

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If you that liability that site, and then internally, you're gonna say something like, don't loan this person any money So But this was our just a simple example about how the the the Itrc group got together, the complex site groups and start saying if you're going to go to a site.

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Where are the key questions you would ask? Okay, So a little bit more background before we go into the real money part of this part of the talk which is these 8 magic questions: right?

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So first the their mediation potential assessment, the purpose.

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It's intended to inform this remedial process.

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just you know the overall, determinant, adaptive management process is beneficial.

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It it allows for greater transparency, and also take future reviews to the process.

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It can be modified, It's in some ways it's it's the answer is not the key thing in the end, although it's certainly important.

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But there was this autobiography. I read about Steve Jobs, called the journey as the reward and if you're in a group of stakeholders, you're going down this path in this complex?

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Site, So how this going through this remediation potential assessment can be very beneficial.

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Okay, just one more slide and background about what this remediation potential assessment does and does not do. So.

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One thing is that allows it's very flexible.

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Allows the site specific input to an iterative process. It requires detailed supporting data, You know, you you're gonna base these answers to these questions on what you know about that site.

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So it has to be some of that characterization that has to be processed, and people have to know their site have a good conceptual model, then finally considers her mediation potential of individual factors and context of other pertinent factors so they're all together so that's what this thing does

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what what are some of the things it doesn't do?

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Well, it doesn't. It's not intended to be a means to avoid requirements to manage that site and protect human health.

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The environment I mean, that's Job, one for us in our field right next it.

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It doesn't really evaluate whether sites complex or not. It's not part of the definition, You know what this is doing?

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Is this roadmap? It says. Oh, I need to use this adaptive site management.

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next. It does not directly consider cost, so cost is not in here explicitly, but in some of the questions it is in there sort, of indirectly or implicitly.

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Finally, it doesn't produce a default decision. Different sites are gonna have different end results.

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And we're gonna see how this thing works. Okay? Well, now, let's go to the the 8 questions.

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And just just as a metaphor for this I was at a wedding reception, and that was sitting next to of a recruiter from shell who hired like 10 or 15 people a week and talking about how does he determine if somebody's going to be a good employee or

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not. He sort of jokingly said he had these 2 questions that he could ask.

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Every of these candidates, and sort of look into their soul, and really understand, if they would be sort of these, these these people who would would work well in in working at a job, and so in some ways, this is, what we're trying to do here, is the group, set down and what are these ap questions that if you know the answer

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to about your site, you can look into the soul of your site and really understand how all this stuff works.

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Okay, So let's go to the the first one or the 8 questions.

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And the first one something like this: It's just how difficult is it to work at the surface of the site And where are these different ranges we have in here?

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Basically, you're gonna talk about for this question. What's the likelihood of of achieving your remediation objectives?

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And you're gonna say it's high medium or low, so let's say you've got a picture like this, and you know you're at your your queue, but your task, And the person the out in the field they say hey?

338
00:49:42.000 --> 00:49:47.000
Listen. It's literally a cow pasture. We can drive our direct pushing Regis out here.

339
00:49:47.000 --> 00:49:50.000
We can inject our amendments really easily. Just, you know.

340
00:49:50.000 --> 00:49:59.000
Scatter those cows. And so you'd say, Well, this this is gonna be higher likelihood that we can or meet, achieve or mediation objectives.

341
00:49:59.000 --> 00:50:02.000
Because this site right here, like, I say, it's a cow pastor.

342
00:50:02.000 --> 00:50:15.000
You can get out there. It's really easy to do the other hand, it was something like this, and you're drilling in the middle of a neighborhood, and then all of a sudden, you're starting to think Oh, the utility clearances they are gonna be they're gonna be a bear they're gonna be

343
00:50:15.000 --> 00:50:18.000
bad And then there's people out here. You've got to be very careful.

344
00:50:18.000 --> 00:50:23.000
There's traffic. You can't put one of your holes wherever you want.

345
00:50:23.000 --> 00:50:26.000
Maybe maybe there's some location that's under somebody's living room.

346
00:50:26.000 --> 00:50:29.000
Can't go into there. So this one might be on the low end.

347
00:50:29.000 --> 00:50:44.000
Okay, So for all these questions, you're gonna, say, hi medium or low, and then, if it's high, that means oh, it's your w We're more likely to achieve these objectives and if it's low, then the complications, are coming up, you're saying hey?

348
00:50:44.000 --> 00:50:48.000
It's gonna be much more difficult for potentially to to achieve this.

349
00:50:48.000 --> 00:50:52.000
But we're gonna do the 8 times 8 different calls questions.

350
00:50:52.000 --> 00:50:56.000
Let's go to question 2. How difficult it to drill up the site.

351
00:50:56.000 --> 00:51:02.000
So you're putting on your hard hat, You're thinking about your drilling, you know you're going out there, and let's just give another example.

352
00:51:02.000 --> 00:51:06.000
Here! Hey! It's it's really shallow to get down to groundwater.

353
00:51:06.000 --> 00:51:11.000
You Actually, you can. You could soil, You can actually use hand augers to get the this.

354
00:51:11.000 --> 00:51:14.000
A lot of samples down in there so you'd say this one is a high like.

355
00:51:14.000 --> 00:51:21.000
this is really nice. On the other hand, if you're on the top of this thing, and they call back, you know it's a basalt.

356
00:51:21.000 --> 00:51:28.000
I get to use this air rotary drilling, it's going to be really nasty It's a it's real expensive to get down that It's really deep.

357
00:51:28.000 --> 00:51:32.000
You're gonna call that one a low. So now you see this, we have these 8 questions.

358
00:51:32.000 --> 00:51:37.000
Here's the first 2. And these questions came from the group.

359
00:51:37.000 --> 00:51:43.000
It just, you know, to be honest at the very beginning, everybody knew exactly 8 key questions.

360
00:51:43.000 --> 00:51:46.000
That would let you peer into the soul of your site.

361
00:51:46.000 --> 00:51:58.000
It turned out that all everybody in the in the group that was working on this had a different 8 questions, And we've spent about a year work in the problem, and and then and combining things splitting things up into the end.

362
00:51:58.000 --> 00:52:02.000
We got to these 8 Let's go to number 3, and this is about size.

363
00:52:02.000 --> 00:52:07.000
What is the scale of the source zone, or that plume that you got to manage?

364
00:52:07.000 --> 00:52:11.000
And it was something like here. It's just, you know, 10 meters by 10 meters.

365
00:52:11.000 --> 00:52:15.000
Hey? That's the size of our comp, you know, in our in our office.

366
00:52:15.000 --> 00:52:23.000
We can do this? Nothing else. You could just do this excavation if it's shallow, then if it's bigger 100 meters by 100 meters, hey?

367
00:52:23.000 --> 00:52:30.000
That's getting getting a little bit new, more challenging something that we can still do, And of all of these sites you have something bigger?

368
00:52:30.000 --> 00:52:46.000
David talked about. You know, this big site? Yeah, the that Arkansas region mining region Then all of a sudden, they just becomes much more difficult, so that the very green green one would be high likelihood of achieving these objectives.

369
00:52:46.000 --> 00:52:51.000
Hey, blob on a map, you know. That's acres and acres hundreds of acres, you know.

370
00:52:51.000 --> 00:53:01.000
That definitely would be this low In the document we give some quantitative guidelines of what typical sizes are a typical size of a intent to remediation projects.

371
00:53:01.000 --> 00:53:08.000
About 10,000 cubic yards, so we try to get people, some him on what that looks like So let's go to the next one.

372
00:53:08.000 --> 00:53:13.000
What contamination and concentration reductions needed.

373
00:53:13.000 --> 00:53:15.000
And for this I I talk about. We're in this remediation universe, you know.

374
00:53:15.000 --> 00:53:21.000
This is I go into this office, or you know. Just think about remediation.

375
00:53:21.000 --> 00:53:26.000
You know, 40 or 50 h a week and I've been doing it, as you can tell a long, long time.

376
00:53:26.000 --> 00:53:34.000
But one thing I've come to appreciate in this business is that we live in this order of magnitude, world, and I call these orders of magnitude.

377
00:53:34.000 --> 00:53:39.000
Oh, okay. And it you can tell, because we talk about hydraulic connectivity. Right?

378
00:53:39.000 --> 00:53:46.000
We talk about. Oh, this is a 10 to the minus one sand, 10 to minus one centimeters per second.

379
00:53:46.000 --> 00:53:53.000
That's a 10 to the minus 7 cm per second clay That's a lot of orders of magnitude between those and we draw plume maps.

380
00:53:53.000 --> 00:53:58.000
What do we put on there? Here's one p one Ppb: Here's 10 Pbb.

381
00:53:58.000 --> 00:54:03.000
Here's a 100. Here's a 1,000. Those are in terms of orders of magnitude.

382
00:54:03.000 --> 00:54:08.000
So if you have a, you have to decide how far do you have to go?

383
00:54:08.000 --> 00:54:12.000
What concentration reduction do you need to achieve your objectives?

384
00:54:12.000 --> 00:54:17.000
If it's 90, that's that's probably gonna be something that's doable.

385
00:54:17.000 --> 00:54:24.000
But that's that's 1 9. If you have 2 nines, 99% reduction, 2 orders of magnitude more difficult.

386
00:54:24.000 --> 00:54:33.000
And then if you have 3 more difficult than 4, just gets more and more difficult to to for our mediation technologies, to get down to those super low concentrations.

387
00:54:33.000 --> 00:54:39.000
So high, medium, low, high, would be up there at 90%, and the low would be down there in the red.

388
00:54:39.000 --> 00:54:48.000
Okay, let's do the last one on this particular slide. Do the key side constituents really attenuate relative to the travel time of the receptors.

389
00:54:48.000 --> 00:55:01.000
So a lot of stuff going in here. But then that on a high level we give some examples related to degradation, and if you have this and this happens to be one of my favorite groundwater molecules of all time.

390
00:55:01.000 --> 00:55:14.000
This is toiling, and this is the one that just goes away like handy, that there's this big Usgs research site, Midiji, Minnesota, that they have big release in the mid seventies of crude oil.

391
00:55:14.000 --> 00:55:21.000
And you go now. 40 years later, It's it's a thing that will go quickly by.

392
00:55:21.000 --> 00:55:25.000
Asked Now, if you have this stuff, and some of you may recognize what this is.

393
00:55:25.000 --> 00:55:28.000
These are these pcbs. Much less degradation.

394
00:55:28.000 --> 00:55:37.000
So so then that might might say that the toiling would be a high, and then these Pcbs might be low, and there's different compounds in the middle about.

395
00:55:37.000 --> 00:55:45.000
Do they attenuate relative to the travel time, to the receptors at your particular site, Then last, you have any difficult removal.

396
00:55:45.000 --> 00:55:55.000
Masks exist at the site, and this is all about what I call matrix diffusion, and as a chemical engineer, I call this the revenge of the geologist.

397
00:55:55.000 --> 00:56:00.000
We originally thought the the subsurface, or I thought, was more or less a sandbox.

398
00:56:00.000 --> 00:56:04.000
Just get my chemicals in there, and the chemical reactions are going to make it happen.

399
00:56:04.000 --> 00:56:17.000
But no it's it's it's a it And there are some sites like this where there's sandboxes, and in that case you'd call this a high, But as I learned it's really this this this geologic heterogeneity, causes.

400
00:56:17.000 --> 00:56:35.000
This matrix diffusion. And this is it I don't know if you've seen this classic lab study this 3 min video done by land Donor and Tom Sale, And here they put this dye in here for 26 days and it goes into those layers those are clay layers and

401
00:56:35.000 --> 00:56:40.000
then for 100 days later, this guy is still coming out. The die diffused into the clear layers.

402
00:56:40.000 --> 00:56:57.000
As David, was talking about. Then it comes back out and so then if you have a site with a lot of geologic heterogeneity, a lot of this layering between transmissive and low probability zones, then that's gonna be this low it's gonna be more difficult to get there I think Now just a good

403
00:56:57.000 --> 00:57:00.000
point for the first 6. Just talk a little bit about this example.

404
00:57:00.000 --> 00:57:04.000
Site Paduca, Kentucky. This is talked about in the document itself.

405
00:57:04.000 --> 00:57:08.000
There's some, do we reports, and this is stylized in some ways.

406
00:57:08.000 --> 00:57:12.000
But if you're talking about this case, study in these first 6 questions, what do you get?

407
00:57:12.000 --> 00:57:24.000
Well, surface access. There's a building in the way, but you can sort of drill through it and maybe that's a moderate, You know a medium We're doing this high meet medium low stuff drilling difficulty.

408
00:57:24.000 --> 00:57:27.000
And you gotta go down to 90 feet. There's some gravel in there. Direct.

409
00:57:27.000 --> 00:57:32.000
Push is probably gonna work. Maybe that would get you more on the lower side.

410
00:57:32.000 --> 00:57:35.000
We're just looking at similar or the scale of the source of the plume.

411
00:57:35.000 --> 00:57:40.000
The plume is pretty long. In this case it's not quite a mile, but pretty It's several 1,000 feet.

412
00:57:40.000 --> 00:57:46.000
So we're gonna call that low. That that means implies a lower likelihood.

413
00:57:46.000 --> 00:57:51.000
You're gonna achieve those objectives just because it's so damn big in concentration reduction.

414
00:57:51.000 --> 00:57:55.000
I think at this point we had to do about 4 orders of magnitude.

415
00:57:55.000 --> 00:57:58.000
Those 99 point, 9% that's gonna make it a low cause.

416
00:57:58.000 --> 00:58:02.000
There's some you know, Dean Apple in here Then there's aenuation.

417
00:58:02.000 --> 00:58:08.000
We have a little bit. This is chlorinated solvent, so we'd say, that's maybe a medium and then we've got difficult to remove mass.

418
00:58:08.000 --> 00:58:12.000
Yeah, It's here that we got this heterogeneity at the site.

419
00:58:12.000 --> 00:58:16.000
Very luvial system. So we're gonna call that a low.

420
00:58:16.000 --> 00:58:33.000
So just give you this idea of for the first 6 how you're doing what this, what this thing looks like, and you can either focus on the source or you focus on the plume when you're doing this type of analysis, but then, looking at this, you have some that are are highs and some that are low and you're gonna do a weight

421
00:58:33.000 --> 00:58:40.000
of evidence in the end, to see how it all works. Okay, but let's keep going Not gonna do to to go to the last questions.

422
00:58:40.000 --> 00:58:45.000
And this one was, what's the predicted performance for available remediation technologies?

423
00:58:45.000 --> 00:58:48.000
And this is there Are these these different papers, a lot of them.

424
00:58:48.000 --> 00:58:56.000
This is one of them thing I've done in my practice is trying to compile results of what happened when people actually did institute remedies.

425
00:58:56.000 --> 00:59:02.000
And there's some documents from 2,011 that talked about performance of these things.

426
00:59:02.000 --> 00:59:06.000
Here's some papers from 2,012, and then this 2,015.

427
00:59:06.000 --> 00:59:09.000
We call that last one. That's 235 site studies.

428
00:59:09.000 --> 00:59:27.000
But it basically says that last report is on average, if you do thermal remediation or institute by degradation or chemical oxidation, trying to treat a source zone, you roughly get about a 90% reduction in concentration, by variance between the different sites some of them are down

429
00:59:27.000 --> 00:59:31.000
to 4. Oh, some of them are 0 homes. But the median one was about 1 1.

430
00:59:31.000 --> 00:59:36.000
Oh! So then your high medium low is talking about for your particular system.

431
00:59:36.000 --> 00:59:40.000
How far, how what type of room reduction can you get?

432
00:59:40.000 --> 00:59:49.000
And then you would to classify those as high medium or low, And then finally, the last question to look into the sole your site. What's this predicted?

433
00:59:49.000 --> 00:59:52.000
Timeframe for tea together and site objectives.

434
00:59:52.000 --> 00:59:59.000
we're looking at potentially using some some simple models or extrapolating site data out there.

435
00:59:59.000 --> 01:00:14.000
but this graph would show that if you got a system with not a lot of diffusion into the matrix, these green lines, that this particular model that's presented in this national research Council report, hey, it cleans up pretty fast So you'd say, maybe that's a that's a high or maybe

436
01:00:14.000 --> 01:00:27.000
that's a medium but if it's a limestone, or if it's a it's a mudstone, or something where you have that that, that there's there's primary porosity that that's in that matrix, itself you can have a lot of this nature's diffusion it's

437
01:00:27.000 --> 01:00:31.000
a lot longer that's in there. So in here, we talk about different models.

438
01:00:31.000 --> 01:00:34.000
You can use to do this where there's a Rem core and a new version. Ram floor.

439
01:00:34.000 --> 01:00:40.000
Md: that's out that can help you understand? And try to get some of these estimates that are in there.

440
01:00:40.000 --> 01:00:44.000
So Those are the 8. Questions and then, finally, what do you do with all this stuff?

441
01:00:44.000 --> 01:00:52.000
So the next slide we're going to talk about. Here's just an example where you're gonna evaluate each criteria's high monitor. Low.

442
01:00:52.000 --> 01:01:04.000
You can do special things. And hey, question number 3, We're gonna put double weight on it, but just the plain vanilla approach is, you could do this, and if you wanted to, you could then do a semi quantitative you, add up.

443
01:01:04.000 --> 01:01:20.000
The check marks, and in this case there so a let's say it's there's 4 that are high, 2 that a moderate 2 that are low and you'd say, Yeah, this is a higher likelihood of achieving remediation, objectives adaptive site management, well, maybe helpful it's

444
01:01:20.000 --> 01:01:25.000
really not a an essential part of how you should try to manage this site.

445
01:01:25.000 --> 01:01:30.000
On the other hand, if you got this where you know, access is moderate, you're just going down.

446
01:01:30.000 --> 01:01:37.000
This is based on your understanding of your conceptual site. Model people are looking at reports when you're going through these questions and trying to just wait these things.

447
01:01:37.000 --> 01:01:43.000
Can we get out? There The feasibility? The drilling is pretty good Yeah, in terms of you know.

448
01:01:43.000 --> 01:01:50.000
It's maybe it's shallow. Maybe it's a moderate for scale, but then we have a long way to go miles to go before we sleep.

449
01:01:50.000 --> 01:01:53.000
You know, to get to those low concentration goals.

450
01:01:53.000 --> 01:02:00.000
Maybe it's 3 orders of magnitude, little bit of attenuation here but there's a lot of this difficult to remove mass in the form of this.

451
01:02:00.000 --> 01:02:05.000
Some you know, matrix, diffusion, technology performance probably can't get it very.

452
01:02:05.000 --> 01:02:11.000
It's hard to get it out of those clays and those silks Intermediation Time frame model says it's a long time.

453
01:02:11.000 --> 01:02:18.000
So in this one, there's 1 point for high. There's there's the re for moderate for way of evidence, would say.

454
01:02:18.000 --> 01:02:28.000
Oh, I'm in the low category here, a low, likelihood of achieving these objectives, businesses was not gonna work.

455
01:02:28.000 --> 01:02:33.000
You gotta do this adaptive site manager? Okay, just a couple of wrap up slides.

456
01:02:33.000 --> 01:02:39.000
What if you're not actually starting at site? But you've been working the site for a while, Well, there's some different framing of some of this.

457
01:02:39.000 --> 01:02:49.000
Stuff. A lot of it's it's same if you're just at a new site where you're trying to decide How am I gonna approach stuff versus one that's been in business a long time.

458
01:02:49.000 --> 01:02:55.000
But there's some key questions. If you've been working the site for a long time, Has the existing remedy been effectively operated and maintained? You?

459
01:02:55.000 --> 01:02:58.000
Gotta You're gonna say we're gonna you know.

460
01:02:58.000 --> 01:03:07.000
Go to adaptive site management. This would be some key information to know is it's just what that existing remedy, What What's it been working on?

461
01:03:07.000 --> 01:03:12.000
How's it been working? Are they offer conditions? Or contaminant sources adequately characterized?

462
01:03:12.000 --> 01:03:30.000
Had they changed, and do we we really, as you say, for example, matrix fusion, part of our conceptual site model, or the concentration reductions occurring at a rate anticipated if you did a remediation at this site where this remediation that was started you have a glide path is

463
01:03:30.000 --> 01:03:33.000
the glide path through the meeting expectations or something change.

464
01:03:33.000 --> 01:03:39.000
Something's different, and then did the selected remedy adequately address all the contaminants, you know.

465
01:03:39.000 --> 01:03:41.000
Are there any new contaminants? We got to worry, you know.

466
01:03:41.000 --> 01:03:47.000
Worry about. You know I don't know, or any sort of new hydrogelogic conditions that are.

467
01:03:47.000 --> 01:03:53.000
We're starting to become aware with and the last question is, can interim or or site objectives.

468
01:03:53.000 --> 01:03:57.000
be met with other technologies, with the original timeframe.

469
01:03:57.000 --> 01:04:02.000
So this is the twist. If you're already been working a site, there's already been some remediation done at it.

470
01:04:02.000 --> 01:04:06.000
How you would apply this particular remediation potential assessment.

471
01:04:06.000 --> 01:04:09.000
So to wrap this up. Hey, This is a screening tool.

472
01:04:09.000 --> 01:04:13.000
It's a valuable process. It doesn't always produce a default decision.

473
01:04:13.000 --> 01:04:25.000
You answer these 8 technical questions and use this weight of evidence approach to assess if the site's likely to achieve the remediation of objective allows flexibility and site specific input editor process and the goal.

474
01:04:25.000 --> 01:04:32.000
Again, the German upside objectives are likely tainable, or hey, the remediation potential is low.

475
01:04:32.000 --> 01:04:48.000
I've got to really understand. We in a group our stakeholders.

476
01:04:48.000 --> 01:04:55.000
alright. Thank you, Chuck. At this time we'll open our first question to answer portion of the training today.

477
01:04:55.000 --> 01:04:59.000
Again, at any time, feel free to put any questions or any technical issues that you encounter.

478
01:04:59.000 --> 01:05:05.000
In the Q. And A. Pod, and we will address them. So right now, we don't have anything in the Q.

479
01:05:05.000 --> 01:05:10.000
A. Pod. I'll pause here for a moment or 2, and see if we get any questions submitted.

480
01:05:10.000 --> 01:05:14.000
if not, we can move right onto our next section, and we will have another Q.

481
01:05:14.000 --> 01:05:21.000
A portion at the end of the training. After after John wraps us up at the end.

482
01:05:21.000 --> 01:05:35.000
So with that I'll pause here and see if we get any questions for our trainers.

483
01:05:35.000 --> 01:05:36.000
Alright. We have a few questions coming in, so I'll read those off.

484
01:05:36.000 --> 01:05:51.000
We should start thinking about that adaptive site management, and that'll be important. I think. With that we're gonna go to question and answer, break

485
01:05:51.000 --> 01:05:55.000
this is Chuck. I guess I can try to take that one.

486
01:05:55.000 --> 01:06:00.000
So this was about all about permafrost, And so that's something that that I don't.

487
01:06:00.000 --> 01:06:05.000
I'm not worked on very much in terms of trying to think about how you would do this.

488
01:06:05.000 --> 01:06:22.000
I I can see sort of the essence of the question is that or you know, if you're gonna try to to do some of these amendments, you know, trying to inject something in there that might be pretty difficult because because that's a that's a very unusual media and then, it's like thermal treatment, of course.

489
01:06:22.000 --> 01:06:27.000
that that would do something where it would change it quite a bit, you know, melting all this stuff.

490
01:06:27.000 --> 01:06:41.000
So so in the end I would I I have the sense that that's a That's a more difficult approach, and if you went through the 8 questions, then you would say, it has difficult to remove mass and things of that nature.

491
01:06:41.000 --> 01:06:53.000
If you at some point you would get maybe more to the scored dates scale of it being, you know, a lower probability of achieving its mediation objectives, in which case you go down this adapter site management approach Maybe you.

492
01:06:53.000 --> 01:06:58.000
Try some of these different clean up the technologies, or maybe a special one.

493
01:06:58.000 --> 01:07:04.000
That might be appropriate, you know, but but in the end you're really trying to make sure that job one is protecting human health.

494
01:07:04.000 --> 01:07:16.000
The environment, and that that you're trying to keep these these different contaminants, you know, from entering, getting into any water supply systems or or things of that nature.

495
01:07:16.000 --> 01:07:24.000
Well, top my head, that's my answer to the person.

496
01:07:24.000 --> 01:07:25.000
great. Thank you, Chuck. Pause here. In case any other traders have anything to add, or if we get any other questions in the chat, If not, we'll move on to our next section

497
01:07:25.000 --> 01:07:55.000
Question umhm

498
01:07:57.000 --> 01:08:12.000
Oh, so so I've got one that just in general is is, this is is the the new contaminant story, and I'm I'm I'm thinking of some of these corn and solving sites that had more of this trichlorate thing That's in

499
01:08:12.000 --> 01:08:16.000
there, and so can manage that. We've got this diagnosed.

500
01:08:16.000 --> 01:08:30.000
But then there was this this, this discovery, that as many of these things that had the stabilizer, this one for dioxide in there, and all of a sudden that changed some of the the complexion, of that I think it, turns out my colleague Dave adams wrote some

501
01:08:30.000 --> 01:08:37.000
papers about Doc saying, and the original thought was the Docsane plumes were going to be much longer than the chloride solvent plum.

502
01:08:37.000 --> 01:08:53.000
He said that wasn't the case. At most of those sites, but but it is at some of them, and so maybe that's I don't have a specific example, but that's one example of, that's sort of a change of conditions.

503
01:08:53.000 --> 01:09:00.000
I can. I can mention simpler examples as well where the goals change over time.

504
01:09:00.000 --> 01:09:12.000
Maybe there's a release of of crude oil, or whatever, and the initial goals are to simply get that oil out of the ground, and people are happy when you don't see that oil in the wells anymore.

505
01:09:12.000 --> 01:09:31.000
But as time goes on, maybe people realize that there's other problems such as dissolve phase B techs and and and it triggers and use approach just to state a simple example.

506
01:09:31.000 --> 01:09:37.000
alright. Thank you. Chuck and David. All right. So we have one last question in the Q. A. P.

507
01:09:37.000 --> 01:09:38.000
That I'll read out loud, and then we can move on to our next section.

508
01:09:38.000 --> 01:09:56.000
That's in there.

509
01:09:56.000 --> 01:10:14.000
So this is chuck. So the the timeframe for doing these assessments, I think I'm not sure I'm answering the the question specifically, but I think when like a lot of the original legislation was written you know many years ago, superfunded retro that

510
01:10:14.000 --> 01:10:29.000
there, was this this this this you do, this immediately investigation, and you do this feasibility study, and then your your and they sort of thought This would be done in a couple of years, and it turns out, that, laying, up these sites is a lot more difficult.

511
01:10:29.000 --> 01:10:36.000
Than anyone imagined. I think back then it's due to the geology, new contaminants coming.

512
01:10:36.000 --> 01:10:40.000
Online Come with me, you know more stringent remediation criteria.

513
01:10:40.000 --> 01:10:50.000
And so it's it's just doing every a characterization in one staff, say, you know, and in a year one mobilization or whatever.

514
01:10:50.000 --> 01:11:00.000
And then figuring out the the right. So the right radiation, you know, approach or the what you're gonna do about this.

515
01:11:00.000 --> 01:11:14.000
it's it takes much longer. And so at some of these complex sites, it's it's over years and over decades, even in terms of we're we're trying to manage this trying to understand this, we're working on separate.

516
01:11:14.000 --> 01:11:17.000
That's maybe some separate issues on there. But the bottom line.

517
01:11:17.000 --> 01:11:47.000
It can be a long time, and then you definitely in the year time, years of work to to do, do, an a mediation assessment and try to get that data and do this feasibility.

518
01:11:48.000 --> 01:11:59.000
wait good morning, everyone! Good afternoon, and where you are. I'm gonna be presenting the next section of the training here, which is focused really on adaptive remedy selection.

519
01:11:59.000 --> 01:12:12.000
And So at this point we would have completed the remediation potential assessment that chopped just walk through, and perhaps determine that our site has low remediation potential and could therefore benefit from adaptive site.

520
01:12:12.000 --> 01:12:26.000
Management So the first stage in that whole process, then, would be adaptive remedy, selection, the content that I'm presenting here today is really summarized in Chapter 4 I the guidance document.

521
01:12:26.000 --> 01:12:37.000
And then the main learning objective for this section of the training is understanding and applying these adaptive site management principles during the process of remedy selection.

522
01:12:37.000 --> 01:12:42.000
We can take a closer look at that through the adaptive site management process.

523
01:12:42.000 --> 01:12:47.000
in this flow chart that you have in a training handout is also in the guidance.

524
01:12:47.000 --> 01:13:12.000
Stop and others on this training have already introduced. So just as a close up here or trigger, happy with the slides just zooming in on a portion of that full chart, which is figure one in our guidance, document these 3 steps in light blue really describe this process and

525
01:13:12.000 --> 01:13:24.000
So the those steps include refining the conceptual site, model setting or visiting site objectives and then developing internet objectives in the adaptive or video strategy.

526
01:13:24.000 --> 01:13:28.000
And I do have a poll question for you. I think that popped up on the screen.

527
01:13:28.000 --> 01:13:35.000
I'm curious to know people working in the audience today on you have experience at complex sites.

528
01:13:35.000 --> 01:13:43.000
How many of you are approaching this, you know, with the initial recognition that this is a call, website or maybe coming.

529
01:13:43.000 --> 01:13:47.000
This is looking at some of these more legacy sites that Chuck was just describing the Q. A.

530
01:13:47.000 --> 01:13:50.000
Session, and needing to revisit the remedy.

531
01:13:50.000 --> 01:13:57.000
So if if you did need to revisit a site, remedy what actions were taken, you can just select all that that apply.

532
01:13:57.000 --> 01:14:12.000
There. They'll get people a minute to complete them. Poll, While you're doing that, I just want to point out that in our flow chart we do accommodate that process, so that shoulds shown by the the arrow that goes to the right hand side.

533
01:14:12.000 --> 01:14:17.000
Decision, documents that the point, maybe to a need to reevaluate the remedy process.

534
01:14:17.000 --> 01:14:36.000
And you'd be going through these things steps again. So it looks like we full question or full results back, and results are showing that most of our audience either has some experience already with revisiting a remedy, or they think that they may need to in the future so the take the way.

535
01:14:36.000 --> 01:14:40.000
Here. Is, if there is a need to reevaluate the remedy.

536
01:14:40.000 --> 01:14:47.000
You basically, he going back and repeating these 3 steps, which makes it, you know, iterative or adaptive process.

537
01:14:47.000 --> 01:14:55.000
And the next couple of slides I'm gonna be walking through each of these

538
01:14:55.000 --> 01:15:01.000
So the first would be We're finding a conceptual site model.

539
01:15:01.000 --> 01:15:11.000
So the conceptual site model would need to be updated to describe the site challenges and those key uncertainties that David walked through already.

540
01:15:11.000 --> 01:15:20.000
And you know, if we've implemented a remedy and we're approaching this from the perspective of So we've tried something, and it's failed to meet our performance expectations.

541
01:15:20.000 --> 01:15:28.000
And we probably learn something that we can use now to go back and improve our conceptual site model and adjust those expectations.

542
01:15:28.000 --> 01:15:37.000
We might have learned what has inhibited our remedial progress, what previous assumptions did we make before that have changed?

543
01:15:37.000 --> 01:15:53.000
And you know what data gaps may remain. So So that's consistent with the understanding or the description of conceptual site model.

544
01:15:53.000 --> 01:16:12.000
In other it. Rc Guidance, documents, and certainly by Epa that really describe the site conceptual model as dynamic and the importance of updating that before you're making key decisions at your site, You might also want to consider some of the tools, for remedy evaluation that

545
01:16:12.000 --> 01:16:33.000
we've compile appendix B of our guidance document as well as some of the other Itrc resources, such as a document that was published in 2,015 on an integrated site. Characterization approach that could also help you in updating a conceptual side

546
01:16:33.000 --> 01:16:39.000
So here's an example of one such tool that was used to improve a conceptual site.

547
01:16:39.000 --> 01:16:48.000
Model This is a 14 compartment model, and it was applied at one of our detailed case 3 sites, which is yeah industrial site located in Australia.

548
01:16:48.000 --> 01:16:58.000
And had chlorinated solvents according to hydrocarbon present in fractured basalt aquifer, and also kind of it.

549
01:16:58.000 --> 01:17:04.000
It traveled along underground. So it's 2 lines for several kilometers as well, and the site managers.

550
01:17:04.000 --> 01:17:13.000
There used a 14 compartment model to estimate the amount of mass contamination that was present in different media.

551
01:17:13.000 --> 01:17:23.000
So in swell vapor, in great water, or absorbed, and they looked at that in both transmissive as well as low permeability.

552
01:17:23.000 --> 01:17:26.000
Zones. Considering the source zone, and then the plume.

553
01:17:26.000 --> 01:17:29.000
In this case they consider the off-site phone separately.

554
01:17:29.000 --> 01:17:33.000
So actually add adds up to 20 compartment model account.

555
01:17:33.000 --> 01:17:51.000
The boxes, not to distract you. With that the I think importance of this really was when you're using this type of model, it can present more of a holistic view of the problem, and it can promote awareness if you're working with a broader group of stakeholders of which which compartments.

556
01:17:51.000 --> 01:17:59.000
of contamination are are going to be addressed by various remedial technologies

557
01:17:59.000 --> 01:18:08.000
So, after updating the conceptual site model the next step in the process is to set or revisit site objective.

558
01:18:08.000 --> 01:18:18.000
The sign Objectives are the overall remedial folds, and those would be based on regulatory expectations and requirements.

559
01:18:18.000 --> 01:18:22.000
You're so setting site objectives, you might want to recognize.

560
01:18:22.000 --> 01:18:39.000
You could have different objectives for different units of the site, either it's a hydrogen logic unit, or perhaps an operable unit, and call those site segments in the guidance document I mean what you really want to achieve is consensus that those site objectives are appropriate they're

561
01:18:39.000 --> 01:18:46.000
achievable within a reasonable timeframe. Otherwise, you know, you may need to be revisiting them.

562
01:18:46.000 --> 01:18:55.000
Yeah, And if you're already visiting them again, agree that they are achievable with the timeframe, and they are.

563
01:18:55.000 --> 01:19:15.000
Excuse me. So on the next slide. Let's just talk about what are some typical site objectives And if we're looking at that question for a super fun site, the the answer is that all final remedies at super fun sites need to be protective of human health in the environment, and they

564
01:19:15.000 --> 01:19:29.000
also must comply with applicable or relevant and appropriate requirements, or or meet very specific criteria for and those criteria are listed here on the slide.

565
01:19:29.000 --> 01:19:39.000
I won't go through each one of them. But just to point out a few, for example, for if you have an interim measure in place at a surface site that does not need to meet.

566
01:19:39.000 --> 01:19:45.000
but and since that's temporary, because sites would need to select a final remedy.

567
01:19:45.000 --> 01:19:52.000
However, there are a lot of complex sites. Circle program. Yeah, still.

568
01:19:52.000 --> 01:19:57.000
Have interim room remedies in place, perhaps due to that complexities.

569
01:19:57.000 --> 01:20:03.000
And then the second to last one on greater risk on aver could be waved.

570
01:20:03.000 --> 01:20:23.000
If compliance with that April would result in a greater risk to human health and the environment than not complying; and we have seen that language described in a couple, I would say, like 50 these are in general, very rare to see in for meal you know records of decision and other decision

571
01:20:23.000 --> 01:20:29.000
documents, But I have seen this language used in a few sites.

572
01:20:29.000 --> 01:20:52.000
For example, if dredging sediment, for example, Mike cos no harm to the ecological environment, then, leaving that contamination in place, and then this last option of technical impracticability, or ti waivers these have been used again, very rarely but maybe, hundreds of super fun

573
01:20:52.000 --> 01:21:00.000
sites, over the past. You know throughout the history of the program, over 30 30 years of the program.

574
01:21:00.000 --> 01:21:09.000
So I do have one whole question for you here, and that is, you know how many of you have have needed to look at the applicability of an air or waiver.

575
01:21:09.000 --> 01:21:33.000
And if so, what approach is ultimately selected? Looks like, most people have not which is consistent with the idea that these are pretty rarely used, and considered, so of you have have looked at it or have looked at it and decided that you did not need to implement I do have an example sorry

576
01:21:33.000 --> 01:21:34.000
Hey, Elizabeth! Just real quick. I wanted to let you know that.

577
01:21:34.000 --> 01:21:40.000
Let me just go back one

578
01:21:40.000 --> 01:21:45.000
Okay, Great. Thank you. I'll give people another minute to complete that.

579
01:21:45.000 --> 01:21:51.000
So the full questions, asking what approach was selected. Following the evaluation What's an error where we're ultimately selected?

580
01:21:51.000 --> 01:21:59.000
Or, after looking at it in more detail, some other approach

581
01:21:59.000 --> 01:22:11.000
So I'll give people a minute to complete that, pulling your attention and multiple different places

582
01:22:11.000 --> 01:22:15.000
Good, so yes, so again, not applicable for most of the audience.

583
01:22:15.000 --> 01:22:20.000
Given that these are rare, and have not been used The majority of the sites.

584
01:22:20.000 --> 01:22:30.000
It's like that did look at it. Maybe the majority of those selected another approach

585
01:22:30.000 --> 01:22:38.000
Slide, presents a case Study of an era waiver that was granted, based on technical impracticability.

586
01:22:38.000 --> 01:22:52.000
The copper coppers, Oralville would treatment facility in Northern California, and it's a site that has Dna will prey so pentagonal and bioxins and fans from the wood treatment.

587
01:22:52.000 --> 01:23:02.000
Process, the remedy was amended to include technical and practical ability for the source area So basically, like a 4 acre area that was defined in the rod.

588
01:23:02.000 --> 01:23:09.000
And by setting that up and essentially change the goal within that area from restoration to containment.

589
01:23:09.000 --> 01:23:15.000
And it was a decision that was made like following a pretty significant effort to identify technology.

590
01:23:15.000 --> 01:23:23.000
They could use to meet cleanup goals at the time they've done a number of pre ability studies using institute by remediation.

591
01:23:23.000 --> 01:23:37.000
they tried excavation soil, washing, chemical fixation, tapping, and ultimately their what their remedy called for was some excavation, creation of an onsite landfill, and then an industrial deed.

592
01:23:37.000 --> 01:23:45.000
Use restriction that was granted in addition to the technical impractic ability

593
01:23:45.000 --> 01:23:53.000
so I mentioned. That is a pretty rare process. We included in our guidance document, just because we've gotten a lot of questions about it.

594
01:23:53.000 --> 01:24:01.000
same with this next remedy like when you're setting and revisiting site objectives. And you're thinking about.

595
01:24:01.000 --> 01:24:04.000
What could you do? That could be appropriate goal at this site?

596
01:24:04.000 --> 01:24:09.000
If you're working with the site. So this is it is also authorized.

597
01:24:09.000 --> 01:24:15.000
The use of ultimate concentration limit to acls under very specific conditions.

598
01:24:15.000 --> 01:24:35.000
I've listed those out here, so if groundwater is discharging the surface water, not seeing a statistically statistically significant increase in concentrations and surface water downstream at that point of discharge and there's not exposure to the off-site contaminate from or prior to

599
01:24:35.000 --> 01:24:47.000
the discharge. It's essentially almost like a a mixing zone or a dilution argument of having different values, applying to realm or given that the receptor is surface water.

600
01:24:47.000 --> 01:24:54.000
And it is not an issue, you know, in surface water We know this in our guidance, and we talk about it.

601
01:24:54.000 --> 01:25:11.000
But we also say, you know, there haven't really been any circle sites that need to identify that have used this since 2,000, and 5 to our knowledge, I would say it's been included for the the just for complete mistake

602
01:25:11.000 --> 01:25:17.000
Well, what about in repra so or other State cleanup programs?

603
01:25:17.000 --> 01:25:24.000
The resource conservation, the the site so records are typically administered by State programs.

604
01:25:24.000 --> 01:25:35.000
We also included brown fields, underground storage tank programs, or voluntary and and it's a little harder to find comprehensive information out.

605
01:25:35.000 --> 01:25:47.000
About. You know what remedies have been selected at these sites, because it's typically administered by the State and require a lot of research to dig into the various state databases.

606
01:25:47.000 --> 01:25:56.000
So Itrc: though, because we work with States directly early on in the front process of this team surveyed the state points of contact.

607
01:25:56.000 --> 01:26:02.000
We got responses back from about 40 different states. We ask them 2 different questions.

608
01:26:02.000 --> 01:26:16.000
We ask, Is your State allow the following for meeting site objectives, and listed out about 25 different approaches, including yes, institutional controls and designated points of compliance, low threat closure.

609
01:26:16.000 --> 01:26:24.000
These types of approaches, and we have the full list of all the approaches in Appendix a of the guidance.

610
01:26:24.000 --> 01:26:30.000
And it's also summarized in a few figures in in the text of Chapter 4.

611
01:26:30.000 --> 01:26:48.000
So we ask States if they use those approaches as a primary means, as well as if the original remedy was failing to meet site objective in a few states indicated that they had more flexibility to adjust the site objectives after a remedy.

612
01:26:48.000 --> 01:26:54.000
Had been tried, and had not met expectations. But here's some of the results.

613
01:26:54.000 --> 01:27:15.000
So the bar graph here is just showing the number of states that indicated that they did use this approach in their peanut program, and it we found that it was fairly common for States to be using risk-based site specific the space criteria institutional controls for managing exposure designated

614
01:27:15.000 --> 01:27:28.000
points of compliance, but in contrast only about half of the survey respondents indicated that they're stick peanut programs allowed for site objectives to be adjusted. Using.

615
01:27:28.000 --> 01:27:33.000
You know alternate concentration limits or technical impracticability.

616
01:27:33.000 --> 01:27:37.000
Provisions will fit, go correct, closure, criteria, etc.

617
01:27:37.000 --> 01:27:41.000
In our guidance document. We talk more about each of these approaches.

618
01:27:41.000 --> 01:27:47.000
we do include some examples and and details on state program.

619
01:27:47.000 --> 01:27:54.000
Cleanup

620
01:27:54.000 --> 01:28:02.000
Hello! Moving on, now that's kind of a summary of the guidance content on setting and revisiting site objectives.

621
01:28:02.000 --> 01:28:09.000
Next step is developing interim objectives and adaptive remedial strategy.

622
01:28:09.000 --> 01:28:13.000
So I talked about site objectives. What about interim objectives?

623
01:28:13.000 --> 01:28:21.000
Interim objectives are really designed to be a step or a milestone for achieving that overall site.

624
01:28:21.000 --> 01:28:31.000
Objective. So you might be specific technology or an area of the site, and Then, once you've achieved that, that would lead you to the next phase of the mediation.

625
01:28:31.000 --> 01:28:38.000
so the pull question we're just asking you, Yeah, for example, restoring brown water for beneficial use.

626
01:28:38.000 --> 01:28:43.000
Is that an example of the hi objective or an interim objective?

627
01:28:43.000 --> 01:28:46.000
Give people a minute, and I believe we have a second full question also.

628
01:28:46.000 --> 01:28:59.000
Nicole just as it a second example to see if we should spend a little more time discussing those concepts or not.

629
01:28:59.000 --> 01:29:05.000
So. Most people believe that a site objective would be restoring ground.

630
01:29:05.000 --> 01:29:13.000
More beneficial uses that's consistent with providing stuff as well

631
01:29:13.000 --> 01:29:21.000
And then the second 1 s call would be, What about reducing mass Flux offsite by 50% within 5 years?

632
01:29:21.000 --> 01:29:47.000
So the Hydraulic Controller no longer site, objective or Internet.

633
01:29:47.000 --> 01:29:55.000
cool question, Full results back here, and most people would agree. This is an example, and yes, that's absolutely right.

634
01:29:55.000 --> 01:30:01.000
So I think that most people get this again. The idea is interim.

635
01:30:01.000 --> 01:30:22.000
Objectives, or set to be milestones that are achievable in the short term as stepping stone to reaching our overall goal, and ultimately those would be sketched out as smart objectives so specific measurable attainable relevant time bound ideally and that those objectives might correspond to

636
01:30:22.000 --> 01:30:29.000
one area of the site, or one type of contaminated media, or a specific technology that you're using.

637
01:30:29.000 --> 01:30:41.000
And those interim objectives having those in place provided with a basis for assessing remedy, performance.

638
01:30:41.000 --> 01:30:46.000
before, I guess before you're finalizing these interim objectives.

639
01:30:46.000 --> 01:30:49.000
It's almost like you're working in parallel to build.

640
01:30:49.000 --> 01:30:52.000
What is your remedy, and what are your objectives?

641
01:30:52.000 --> 01:31:00.000
At the same time, because some of you, if the interim objectives are going to be specific to the technology into the approach that you're selecting.

642
01:31:00.000 --> 01:31:06.000
So just take a step back and thinking about what you're adaptive or medial strategy would be a certain site.

643
01:31:06.000 --> 01:31:29.000
we well, you know we we can include kind of a general table of various renewal technologies, and then provide references so that people can reference that table and just kind of ask what are the tools in our toolbox if there's something that strikes them as helpful for their site and then that's worth

644
01:31:29.000 --> 01:31:43.000
including. So this is just a short example of the entries in a much larger table or documenting table, 10 more more complete listing.

645
01:31:43.000 --> 01:31:52.000
The next step would be comparing remedial approaches, so you would then follow the regulatory process for that so it's circle sites.

646
01:31:52.000 --> 01:32:03.000
You'd be using the 9 criteria, you know, feasibility setting process, and it requires you might be using the threshold criteria and balancing criteria.

647
01:32:03.000 --> 01:32:07.000
So again following the regulatory process. But keep in mind.

648
01:32:07.000 --> 01:32:28.000
There might be other considerations that you want to think about at complex sites, and I have a slide that summarizes some of those additional considerations, including level of confidence and the ability to implement the remedy which does get basically feasibility and practicability, but understanding that that may be a real

649
01:32:28.000 --> 01:32:39.000
consideration, for a lot of these complex sites soonergy of a particular technology with other technologies or approaches that are going to be used again.

650
01:32:39.000 --> 01:32:46.000
Recognizing that it complex sites You're not typically selecting one technology or one approach, but you're working with treatment trains.

651
01:32:46.000 --> 01:32:56.000
You're working with, you know, different approach, several different technologies over time and over space adaptability over time.

652
01:32:56.000 --> 01:33:02.000
If there's information that you're gonna learn during the first year of operation, you know, can the system be exposed?

653
01:33:02.000 --> 01:33:31.000
Or somehow refined to improve performance as well as you know, does implementing this technology provide us with additional information that we can use to improve decision making at the site robustness of design including interim objectives, metrics and performance monitoring data and then other such as I know some sites.

654
01:33:31.000 --> 01:33:43.000
You know, looking at sustainability is a a key driver. Whether one approaches need more breeding sustainable to another.

655
01:33:43.000 --> 01:33:51.000
And then I guess during either remedy, evaluation, or selection, you could prepare a matrix of the site objectives.

656
01:33:51.000 --> 01:33:57.000
The remedies that you're working with, and the different areas of the site of source.

657
01:33:57.000 --> 01:34:07.000
And phone. Here in this conceptual model, and just see how each of the technologies is aligning with the site objectives for the remedy that's ultimately selected.

658
01:34:07.000 --> 01:34:24.000
You could have another call on here. That specifies what the interim objectives are, as well, such as source removal or treatment or containment, exposure, control maybe returning some some portions of the site to beneficial use

659
01:34:24.000 --> 01:34:32.000
One of the case studies in our document is Rocky Mount Arsenal in Colorado, and I just wanted to think through.

660
01:34:32.000 --> 01:34:50.000
We don't have a lot of case studies where they say you know, we were using adaptive site management when we approached this whole process of remedy selection, So what we've done is state is kind of gone back and looked at the decision making at some complex sites kind of fit that into this

661
01:34:50.000 --> 01:34:54.000
framework, so you can see if this thinking was done.

662
01:34:54.000 --> 01:34:58.000
All upfront, and they had that information. What would it look like?

663
01:34:58.000 --> 01:35:03.000
So Rocky Mountain Arsenal is an example of a site that we we looked at from Remy selection.

664
01:35:03.000 --> 01:35:13.000
This is a former chemical weapons, Manufacturing facilities used to support World War 2, and then continued operations in the 19 fifties.

665
01:35:13.000 --> 01:35:18.000
And then today, it's one of the largest urban wildlife refugees in the United States.

666
01:35:18.000 --> 01:35:26.000
or 12,000 acres, or 51 square kilometers, and what they have in place is basically land.

667
01:35:26.000 --> 01:35:46.000
Use restrictions, restrict any type of residential use of development as well as agricultural use and human consumption of fishing game from rocky mountain Arsenal, and then access is also limited to Captain and covered area so the onsite area has been capped following pretty

668
01:35:46.000 --> 01:35:55.000
extensive excavation of the top fee. And there's also some boundary pumping treat systems operating.

669
01:35:55.000 --> 01:36:02.000
So in this table again, just thinking conceptually, and going back to the previous slide.

670
01:36:02.000 --> 01:36:10.000
This shows how the various infirm and final remedy components mapped to the site objectives for rocking out more so.

671
01:36:10.000 --> 01:36:14.000
and you can see some common remedies in terms of containment.

672
01:36:14.000 --> 01:36:21.000
Source treatment and removal, but also some more unique elements, like a medical monitoring program.

673
01:36:21.000 --> 01:36:26.000
that's true fund that was set up. 2 provide for long term operation.

674
01:36:26.000 --> 01:36:38.000
Maintenance costs, and then portable water supply and distribution

675
01:36:38.000 --> 01:36:43.000
For the final step in this whole process is basically documenting the medial approach.

676
01:36:43.000 --> 01:36:53.000
You could use a table, which is one that we just described to summarize the technologies and the other video components, and then also interim objectives.

677
01:36:53.000 --> 01:37:00.000
And ultimately conformance metrics, as well in our guidance document, Basically, state.

678
01:37:00.000 --> 01:37:19.000
Please call regulatory guidelines in terms of how and when to Doc the remedial approach again recognizing that complex sites fall under a number of different peanut programs and there's often not a one size fits all approach to to timing and then finally if the remedial

679
01:37:19.000 --> 01:37:29.000
strategy that selected is incorporating multiple technologies, You'd want to describe how and when to transition from one technology to the next.

680
01:37:29.000 --> 01:37:36.000
We have a bit more detail about that in Chapter 5

681
01:37:36.000 --> 01:37:55.000
And then finally just recognizing that throughout this whole process of remedy, selection there's often opportunities to involve stakeholders and tribes. As John talked about our team was really fortunate enough to have multiple stakeholders on the team that had direct experience representing communities who've been

682
01:37:55.000 --> 01:38:06.000
impacted by environmental contamination, and they shared their knowledge, and some examples of how community engagement can benefit the site remedies such as Mvw.

683
01:38:06.000 --> 01:38:26.000
Site that John mentioned, but also just more generally some tips for interested stakeholders and tribal representatives to get more engaged in the whole process of remedy, selection, and access information create forums provided some examples that We included in our guidance about how the community

684
01:38:26.000 --> 01:38:38.000
was able to influence key decisions at complex sites, and they also provided some advice on advisory boards and and technical assistance

685
01:38:38.000 --> 01:38:41.000
And then from the perspective of responsible parties or document.

686
01:38:41.000 --> 01:38:57.000
Also includes some tips for increasing stakeholder, and tribal engagement, and those recommendations are summarized in Chapter 7 of the Guidance document seeking out community Numbers are trusted giving them with tools so they can participate.

687
01:38:57.000 --> 01:39:13.000
Constructively. And then I think people are are aware of, you know, organizing public meetings, technical documents, and information working with media so

688
01:39:13.000 --> 01:39:23.000
No! Just to summarize in this section. We've introduced a couple key principles of adaptive site management, and some takeaway points.

689
01:39:23.000 --> 01:39:32.000
First, it's important to refine the conceptual site, model and revisit the site objective to determine if they're achievable in a reasonable time.

690
01:39:32.000 --> 01:39:40.000
Frame. We learned about several different approaches within regulatory cleanup programs for achieving that.

691
01:39:40.000 --> 01:40:02.000
We also talked about how to build an adaptive or medial strategy, looking at different areas or segments of the site, using multiple technologies and approaches for those areas and and over time and then also the importance of setting interim objectives and performance metrics to kind of guide

692
01:40:02.000 --> 01:40:10.000
remedy Progress over the short term, and then the adaptive part, of course, repeating this process and hopefully we're finding it.

693
01:40:10.000 --> 01:40:15.000
If the remedy is not on track

694
01:40:15.000 --> 01:40:36.000
So that concludes the section on adaptive remote selection, the final section in our training is long term management and this is content That's taken from chapter 5 of the Guy and stuff and Our trainer Sam Brock with a former air force environmental center is not with us

695
01:40:36.000 --> 01:40:56.000
today. So I'm gonna go ahead and walk through this section of the training as well. Basically long term management is the process of operating and monitoring your selected remedial approach. And verifying that we've installed The remy properly and then it's working as expected

696
01:40:56.000 --> 01:41:03.000
No! The first step in that whole process is basically developing in line management plan.

697
01:41:03.000 --> 01:41:22.000
It should be a written performance based plan for adaptive site management. And that would describe the activities that you're going to be taking over over time and the evaluations that you're gonna be doing in order to make those informed and timely decisions about the remedial program

698
01:41:22.000 --> 01:41:26.000
So going back to our flow chart, we're now looking at this section.

699
01:41:26.000 --> 01:41:36.000
It's how colored in dark blue it relates to the long term management process, and again, this is referring back to chapter 5 in the guidance document.

700
01:41:36.000 --> 01:41:56.000
So the key steps of the a long term management plan. We're gonna go through now in the training and then implementing, designing and implementing the site, specific remedy basically I describe that a bit you know, what was kind of high level and for you to chat to 4 for more detail on that and

701
01:41:56.000 --> 01:42:12.000
then monitoring and evaluating performance, and then the decision logic that we walk through to pull together the information we're getting from the monitoring program and make decisions in order to adapt The vanity.

702
01:42:12.000 --> 01:42:21.000
So, starting with a long term manager plan, just wanted to step back and say, What's the benefit of having a plan like this in place?

703
01:42:21.000 --> 01:42:25.000
The plan basically provides the site management team with a framework.

704
01:42:25.000 --> 01:42:30.000
So that if we're learning as we go, we can document that.

705
01:42:30.000 --> 01:42:42.000
And even just in the process of going through and forming a plan, I think will help the stakeholder team or the site management team to identify any week links in the renewal.

706
01:42:42.000 --> 01:42:59.000
Approach. It also helps to inform the decision makers about remedial progress, and to communicate with a variety of different stakeholders basically serves to document the overall site completion strategy it also serves to document the remedy.

707
01:42:59.000 --> 01:43:04.000
Expectations, and describe how progress is going to be evaluated.

708
01:43:04.000 --> 01:43:11.000
And evaluate. I guess the other thing is, you know, if you have a plan upfront, it helps you to make more timely decisions.

709
01:43:11.000 --> 01:43:20.000
If you get to the point in the remediation process, we do need to evaluate a remedy or transition from one phase of the remedy to the next.

710
01:43:20.000 --> 01:43:24.000
Having a plan in place can can help to smooth those transitions.

711
01:43:24.000 --> 01:43:29.000
Yeah.

712
01:43:29.000 --> 01:43:40.000
so in terms of

713
01:43:40.000 --> 01:43:54.000
Yeah.

714
01:43:54.000 --> 01:44:00.000
Okay, Okay, I went the wrong direction. Here we go. So plan components.

715
01:44:00.000 --> 01:44:05.000
So completion strategy. I mentioned that the plan basically provide the description.

716
01:44:05.000 --> 01:44:15.000
The overall site. Completion strategy. That will be deployed at that site So over time and over space, What's the big picture of the remedial approach?

717
01:44:15.000 --> 01:44:19.000
And then it provides a more detailed description of the current phase of remediation.

718
01:44:19.000 --> 01:44:30.000
What's the selected remedy right now, even though we're playing transition Something later on, also would describe the expected remedial performance over time.

719
01:44:30.000 --> 01:44:50.000
that is based on probably a quantitative performance model, and then that would provide a way of assessing remedy, progress over time and how the remedy is projected to reach those interim goals.

720
01:44:50.000 --> 01:45:12.000
your plan would also provide a timeline and criteria for monitoring and periodic evaluations, and it would also describe how that decision logic for making decisions of of how to transition to another remedy describes that transition that decision logic and also I

721
01:45:12.000 --> 01:45:19.000
think, also addresses, how remediation project risks would be mitigated as well.

722
01:45:19.000 --> 01:45:24.000
So on this next slide, basically talking about the complete strategy.

723
01:45:24.000 --> 01:45:30.000
This is the long term picture that describes our overall path to achieve our site objectives.

724
01:45:30.000 --> 01:45:38.000
again, at complex sites. This is likely a collaborative process, and it may be changed over time.

725
01:45:38.000 --> 01:45:47.000
but the strategy, I think in a lot of complex sites often prioritizes land, use and maximizes.

726
01:45:47.000 --> 01:46:00.000
Yeah, land use considers options to do that, and might employ different approaches depending on the expected landing when developing the overall completion strategy.

727
01:46:00.000 --> 01:46:23.000
Again. We just refer you to relevant regulatory and technical regulatory guidance. And We did provide some citations here on on slide 82 for further information on exit strategies and kind of planning remedy components

728
01:46:23.000 --> 01:46:33.000
I mentioned on the previous slide it up Project management risk, and we wanted to highlight that remedial projects, especially at complex sites.

729
01:46:33.000 --> 01:46:41.000
Often you calendar a number of different barriers for satisfactory neo-technology. Performance.

730
01:46:41.000 --> 01:46:46.000
Okay. And there's another a separate Itc team and guidance document called Project Risk Management Site.

731
01:46:46.000 --> 01:46:53.000
Remediation. It can walk you through that framework, and I think a lot of us are familiar with.

732
01:46:53.000 --> 01:47:07.000
You know the whole health and safety, awareness, culture, and tools, that we have developed around building awareness of health and safety idea of stepping back before you start a task identifying what could possibly go wrong?

733
01:47:07.000 --> 01:47:14.000
Here, and what can we do to make sure that if that does happen, we know what our our plan is.

734
01:47:14.000 --> 01:47:17.000
What are we doing to mitigate the possibility of that account?

735
01:47:17.000 --> 01:47:28.000
It's a very similar mindset here, with project Risk management, but you're taking that beyond health and safety and really identifying different events that might prop up to kind of derail.

736
01:47:28.000 --> 01:47:33.000
A project, do you real the progress of your remedial technology?

737
01:47:33.000 --> 01:47:46.000
And again going through that thought process of how do we identify these potential adverse events and develop contingency plans or some type of thinking of how to mitigate.

738
01:47:46.000 --> 01:47:59.000
So this is a great resource. If you're trying to develop a contingency response for unexpected events or some type of stall remedial progress

739
01:47:59.000 --> 01:48:02.000
next step would be basically describing what remedy has been selected.

740
01:48:02.000 --> 01:48:17.000
So what are the actions that you're planning to take in each area of the site and describing kind of how and when each action is is going to be taken to contribute to the overall side objectives

741
01:48:17.000 --> 01:48:23.000
and here he would also be listing out the interim objectives, and as well as performance metrics.

742
01:48:23.000 --> 01:48:46.000
And this will help you to get to what are you actually going to be measuring on a monthly or quarterly or periodic basis to track progress for achieving those objectives as well as any type of from your system maintenance and monitoring requirements to assess technology performance as Well.

743
01:48:46.000 --> 01:49:03.000
and going back to the idea of a simple table that captures the site, objectives, and the remedy components in long term management plan, you would be adding to that information on the interim objectives and then the performance metrics.

744
01:49:03.000 --> 01:49:14.000
So what are you going to be measuring to demonstrate that the demonstrate progress for achieving the interim objectives

745
01:49:14.000 --> 01:49:21.000
And it at many complex sites. This is based on a quantitative performance model So I'm just showing an example here.

746
01:49:21.000 --> 01:49:41.000
It's highly clearoretical in in this scenario, but over several years may be expected to see contaminants, concentrations, decline as for media action, if you are including a quantifiable performance model and performance metrics this would be key to to this

747
01:49:41.000 --> 01:49:45.000
would be what you use basically for assessing progress during the performance.

748
01:49:45.000 --> 01:50:06.000
Evaluation. We do have other itrc guidance on projecting for your performance, and we we included an appendix fee of the Guidance document, number of different tools to kind of help development of that model and then moving then to the monitoring and evaluating

749
01:50:06.000 --> 01:50:13.000
performance stage of of the plan or of implementation of the plan.

750
01:50:13.000 --> 01:50:36.000
You would then be conducting monitoring assess remedial performance relative to the interim objectives or goals. And if I just move on now to the next, slide you can see an example that is in the same next I think as the previous slide

751
01:50:36.000 --> 01:50:41.000
Okay, Yeah, close the poll for now, just get that up with.

752
01:50:41.000 --> 01:50:44.000
So the it this slide on slide 88.

753
01:50:44.000 --> 01:50:56.000
Now we have a hypothetical example that again shows this type of asymptotic removal In this case, maybe we're talking about swell vapor extraction for removing some.

754
01:50:56.000 --> 01:51:01.000
Volatile contaminant from the unsaturated soil.

755
01:51:01.000 --> 01:51:08.000
You can see the margin of the green area here is basically similar to that asymptotic trend that I showed on the previous slide.

756
01:51:08.000 --> 01:51:21.000
This would be the performance model, and you might integrate some type of sensitivity of that to to be a yellow band, maybe one standard deviation away from what you expect to achieve.

757
01:51:21.000 --> 01:51:29.000
and then this kind of yellow zone, maybe you would look at some type of process improvement or optimization, and then the red area?

758
01:51:29.000 --> 01:51:37.000
Would you record representative of unacceptable performance from your remedy?

759
01:51:37.000 --> 01:51:45.000
So in that context, the the black dashed line from time, 0 maybe an example of the actual containment concentration.

760
01:51:45.000 --> 01:51:54.000
So for the first, you and a half be collecting monitoring data and showing us winds up very well with what we anticipated in our model.

761
01:51:54.000 --> 01:52:03.000
But after one and a half years, maybe, we note some reduced performance, and then that could trigger optimization of the remedial system.

762
01:52:03.000 --> 01:52:13.000
And we might see some benefit after optimization, as shown in by the green dashed line, showing how you know again, we're getting some additional containment mask.

763
01:52:13.000 --> 01:52:25.000
But then approaching, asymptotic levels, and at this, at this point we may conclude that we've basically, you know, reach the maximum benefit of this spe technology approach.

764
01:52:25.000 --> 01:52:29.000
And we would think about transitioning to the next phase.

765
01:52:29.000 --> 01:52:39.000
Maybe a natural attenuation of residual contamination, or or whatever that next phase may be.

766
01:52:39.000 --> 01:53:02.000
so I I think that I think that the the proof probably feel like I've been saying this on each in terms of being able to monitor and evaluate performance, but that really is the the gist of of section 5 it's pretty simple conceptually But then of course the doubles and the details and you try to implement it in a

767
01:53:02.000 --> 01:53:24.000
conflict. But as a full question, just to make sure that that's come across we are asking what's the best time to review technology performance in detail, And the choices would be after every monitoring event during a periodic during every periodic evaluation only If your technology is failing

768
01:53:24.000 --> 01:53:30.000
to make progress towards the interim objectives, or after an income objective has been met.

769
01:53:30.000 --> 01:53:34.000
Oh, I'll give people a minute to look at that, and then you can pull up the results.

770
01:53:34.000 --> 01:53:47.000
In a few minutes

771
01:53:47.000 --> 01:53:55.000
I know that in in previous polls there's sometimes some confusion on this, so I just wanna take a minute to respond to. If that's the case.

772
01:53:55.000 --> 01:54:07.000
In this group, then apologies, If I haven't done Sam's content justice here

773
01:54:07.000 --> 01:54:30.000
Okay, So some looking at the results of the poll, a lot of people are saying either after every monitoring event or after every periodic evaluation, And I I do think that it does work and in depth review after so during each periodic evaluation.

774
01:54:30.000 --> 01:54:35.000
And certainly after every monitoring event, you would want to look and see if you're on.

775
01:54:35.000 --> 01:54:43.000
Track I think people get it overall, that after a periodic evaluation, you'd be going in and doing this detail analysis.

776
01:54:43.000 --> 01:54:52.000
seeing if you're on track and that may or may not correspond to every every morning.

777
01:54:52.000 --> 01:55:12.000
No, thank you for participating in that poll I'm gonna move on now to some other tools that are provided in the guidance document for this phase of remediation and long term back monitoring management and that is a remediation evaluation checklist that we provided in the guidance.

778
01:55:12.000 --> 01:55:15.000
document you can use that checklist to help guide troubleshooting.

779
01:55:15.000 --> 01:55:39.000
If your remedial system is under performing. And the the full checklist can be downloaded also and it's in the guidance that can also be downloaded on the website under the links, 2 additional materials and that's really just recognizing that doing this following this performance

780
01:55:39.000 --> 01:55:46.000
model monitoring, and then going back to the decision. Logic It's gonna help you identify unacceptable performance.

781
01:55:46.000 --> 01:55:51.000
Doesn't really help you to understand why the mediation system is under performing.

782
01:55:51.000 --> 01:55:56.000
it's really gets back to the conceptual site model characterization.

783
01:55:56.000 --> 01:56:08.000
And you know we want to recognize that more comprehensive evaluations could be triggered by this process and should be done if needed, in response to something like that.

784
01:56:08.000 --> 01:56:13.000
The checkpoint.

785
01:56:13.000 --> 01:56:18.000
It will find just to address the decision Logic portion.

786
01:56:18.000 --> 01:56:34.000
You're applying the decision logic that's shown on the flow chart What you're doing is you're comparing the addicted to actual rate of change and you're gonna arrive at one of or possible communication either your remediation is complete you can see that at the

787
01:56:34.000 --> 01:56:50.000
bottom of the flow chart that we're gonna initiate site closure because we've met our objectives, That's always great news or The remediation is on schedule so the problem is acceptable on track of what we predicted with where we would be that should be shown

788
01:56:50.000 --> 01:57:09.000
in the first decision point, or you may get into this this area of optimization being warranted, or a revised approach is needed and that might include implementing a contingency remedy or repeating a site evaluation as described in section 4,

789
01:57:09.000 --> 01:57:15.000
just one quick, case study before I turn back over to John to to wrap up.

790
01:57:15.000 --> 01:57:19.000
this is looking at an actual remediation site in Colorado.

791
01:57:19.000 --> 01:57:25.000
That Sam Brock had experience with, and the remediation was really to address, to recall such an chemicals.

792
01:57:25.000 --> 01:57:36.000
One was Hi Chloroethylene, and the other was in Dma or in my photo present fracture block, about 125 people over ground surface.

793
01:57:36.000 --> 01:57:44.000
There's an interim action enhanced institute by remediation with use, and that was partially successful. For Tcb.

794
01:57:44.000 --> 01:57:52.000
however, asymptotic levels that were above reulatory limits were reached, using bio remediation.

795
01:57:52.000 --> 01:57:59.000
Hilet studies were then initiated or using other technologies that could adjust both chemicals.

796
01:57:59.000 --> 01:58:20.000
those were not successful, and in in the end the record of decision for the site selected, the enhanced Institute by orientation for tce and fractured rock, and included to rebound tests that verified asymptotic levels had them meet in source areas and as a result of

797
01:58:20.000 --> 01:58:39.000
that analysis. In addition, the technical and feasibility waiver was selected for, in my chosen dimethyl, I mean in the proxy racks rock source area based on the pilot study and the site, specific investigation, and then the dissolve face contamination that was present in

798
01:58:39.000 --> 01:59:01.000
the plume portions was addressed, using monitored natural attenuation for both tce and and then, finally, there was an enforceable environmental covenant for both compounds that prevented exposure to surface water receptors, and the decision document specified that the selected remedial

799
01:59:01.000 --> 01:59:14.000
approach will be reevaluated in in 20 to 30 years, which is a timeframe that was based on the predictive contaminant behavior of this site.

800
01:59:14.000 --> 01:59:23.000
Oh, my last slide here, just to summarize. We really wanted to highlight the value and the importance of a written long term management plan.

801
01:59:23.000 --> 01:59:44.000
It went into a bit of detail on components of that plan, and describe some of the considerations for monitoring. The role of scheduled performance evaluation, and how to apply the decision logic to maintain remedial progress and at this point i'd like to hand it back over

802
01:59:44.000 --> 01:59:47.000
thanks, Elizabeth as well as David and Chuck Devin.

803
01:59:47.000 --> 01:59:53.000
I think we've got one more poll. If you want to go ahead and call that up while I I cover this slide.

804
01:59:53.000 --> 01:59:58.000
So we've given you a really quick introduction to 4 elements.

805
01:59:58.000 --> 02:00:17.000
Of our guidance document, first identifying the technical and non-technical challenges at your site, using remediation potential tool that Chuck described as a decision-making tool applying adaptive remedy selection and understanding how to take your site into long-term management again

806
02:00:17.000 --> 02:00:37.000
this is a really quick introduction. So as you get ready to take action, I really encourage you to read the the guidance document as well as the case. Studies that Go along, with, it and devin if that's enough time let's see what everybody said to the Poll results

807
02:00:37.000 --> 02:00:52.000
Wow, that's great. Looks like about 84% of the people are saying they would recommend using this guidance

808
02:00:52.000 --> 02:00:54.000
Hey, devin would you go ahead and fancy slide for me?

809
02:00:54.000 --> 02:00:59.000
I'm not seeing my controls there, so we're back to our roadmap again.

810
02:00:59.000 --> 02:01:17.000
science and technology give us options for these very challenging sites as we've set a robust and iterative conceptual site model is key to our success, and and we talked about consensus-driven interim objectives to help us make Progress consensus driven implies that

811
02:01:17.000 --> 02:01:31.000
you're engaging with your stakeholders throughout the process. And then, if you do that, an adaptive site management process facilitates finding an achievable path to a common goal.

812
02:01:31.000 --> 02:01:36.000
Okay, One more slide, please, Devin: So this is the end of the training.

813
02:01:36.000 --> 02:01:42.000
So again, we want to prepare you to take action. You'll have to flick through these bullets for me, Devin.

814
02:01:42.000 --> 02:01:46.000
We want you to make a difference at at your site.

815
02:01:46.000 --> 02:01:57.000
This training has highlighted the elements of our guidance document, which again, we want you to go ahead and read get familiar with, and we would encourage you to use it, and communicate it to your site owners and responsible parties.

816
02:01:57.000 --> 02:02:05.000
Among regulators and among stakeholders. If you have success stories, we'd like to hear them at Itrc.

817
02:02:05.000 --> 02:02:11.000
Please pry, provide feedback. And again, just to recap the guidance thing.

818
02:02:11.000 --> 02:02:18.000
It. The chapter 2 helped you think about your site challenges which are both technical and non technical.

819
02:02:18.000 --> 02:02:35.000
you using those site challenges apply the remediation potentials tool that Chuck described at your site, using those 8 questions, and you you can get more detail on those in chapter 3 the guidance, and then finally, the key takeaway.

820
02:02:35.000 --> 02:02:45.000
For all of this, I I guess maybe 2 key takeaways is apply adaptive site management principles to your complex site, involving stakeholders throughout the process.

821
02:02:45.000 --> 02:03:05.000
And that includes sending interim objectives or or objectives for site segments, and establishing your performance expectations either for those interim objectives or for those site segments, and then continue to revisit those throughout the process of operating your remedy we hope you'll use

822
02:03:05.000 --> 02:03:14.000
the part of the guidance that talks about stakeholder involvement, both to reach out your stakeholders and to encourage your stakeholders to understand how to be involved with your complex sites.

823
02:03:14.000 --> 02:03:20.000
And Now i'm going to turn it back over to Devin for Q.

824
02:03:20.000 --> 02:03:27.000
alright. Thank you, John, and thank you, Elizabeth, for those 2 parts of our presentation at this time we will open up our second Q.

825
02:03:27.000 --> 02:03:44.000
A portion of the training. Today we have a question in the Q and A. Pond that I'll go ahead and read here.

826
02:03:44.000 --> 02:04:12.000
Yeah, I'll go ahead and start on that. So I do wanna, mention that we did have Epa staff on our team, and if you go through the guidance you'll see extensive references to Epa guidance, and then in the last couple of segments, elizabeth talked about

827
02:04:12.000 --> 02:04:17.000
alright. Thank you, John. So it looks like That's the only question we have.

828
02:04:17.000 --> 02:04:23.000
I will pause here for a moment, and see if anybody has anything else that they want to enter in.

829
02:04:23.000 --> 02:04:28.000
And while I we I will just go over to the the ending logistics here.

830
02:04:28.000 --> 02:04:40.000
So please remember that we do have a feedback form available, and we would love to hear you know your your thing and feedback on how the training went today, So if you could fill that out we would really appreciate it that feedback form.

831
02:04:40.000 --> 02:04:45.000
Is also how you would get a certificate of completion for today's course.

832
02:04:45.000 --> 02:05:02.000
If you fill out that form and check the box that you see here on the screen, that certifies that you participated in E a certificate will be emailed to you afterwards, If, you need any further clarification on any questions or answers or have any additional questions you would like to

833
02:05:02.000 --> 02:05:10.000
ask. You can feel free to email us at Itrc: at Itrc, Web org, and we will follow up with our trainers to get your questions answered.

834
02:05:10.000 --> 02:05:27.000
You are also welcome to follow up with our trainers directly, their emails were listed on Slide Number 5, when I introduce them, and that is included in the in the slides that are on clue in that you are able to download so it looks like we don't have any other

835
02:05:27.000 --> 02:05:30.000
questions that came in. So I'm going to wrap up the training here today.

836
02:05:30.000 --> 02:05:37.000
And I would like to just say thank you to our attendees for being here, and a special thank you to our our trainers, for being here.

837
02:05:37.000 --> 02:05:40.000
We obviously couldn't have done it without either of you.

838
02:05:40.000 --> 02:06:10.000
We really do appreciate it, and we hope to see you in some traditional trainings this coming month.