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Question
What is the extent of regulatory acceptance of the Triad? What State regulatory agencies have bought into the Triad?
 
Answer

As the case studies contained in the Triad Resource Center demonstrate, the Triad approach has been used successfully at sites across the country that involve a wide range of contaminants of concern, and that represent a wide range of regulatory environments. The EPA is constantly working internally with EPA regional offices, as well as other state and federal agencies, to gain regulatory acceptance and understanding of the Triad approach. As an example, the State of New Jersey’s Department of Environmental Protection, with the assistance of EPA, has actively embraced the Triad and is working to integrate the Triad into its regulatory scheme. As with most advances in characterization and remediation technologies/approaches, however, the ultimate regulatory acceptance rests with the individual local, state, or federal agency staff member assigned to oversee work at a site.

As more and more projects are done applying all (i.e., a Triad project) or some (i.e., a Triad-like project) Triad principles, the benefits of the overall approach are becoming more obvious to regulatory programs. It is too early in the transition process to be able to provide detailed "how-to" instructions that would be appropriate to different federal and state cleanup programs. However, regulatory programs are signaling their acceptance of Triad projects by documenting successful projects and providing overview documentation of general concepts.

For example, EPA’s Superfund program has developed a document entitled "Using Dynamic Field Activities for On-Site Decision Making: A Guide for Project Managers." This document discusses the use of dynamic work strategies and of field methods in a dynamic context and demonstrates EPA’s acceptance of dynamic approaches to Superfund project management. Case study examples of Superfund projects using dynamic work strategies in the 1990s are covered in Chapter V, with more detailed case study discussions available as separate documents. The guidance and case studies can be accessed through the Superfund Dynamic Field Activities homepage at http://www.epa.gov/superfund/programs/dfa/index.htm.

In addition, the Interstate Technology and Regulatory Council (ITRC) has prepared a document entitled, “Technical and Regulatory Guidance for the Triad Approach: A New Paradigm for Environmental Project Management,” which was released January 2004. This document is designed to acquaint state regulators with key Triad concepts and benefits, and address some expected State regulator concerns. It is available in paper and electronic forms through the ITRC website at http://www.itrcweb.org. Choose “Guidance Documents” from the main menu, then click the “Sampling, Characterization, and Monitoring” button.