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Question
How can I convince my State and Regional regulators of the value of a Triad approach?
 
Answer

The existing documentation mentioned in Questions 54 and 55 can be shown to regulators to demonstrate that the ideas and strategies used by the Triad approach are not brand new or untried at the level of federal or state waste programs. However, from a regulator’s perspective, the value of the Triad for any particular project will rest in its ability to improve decision-making quality with the same level of resource investment. This means simply that it is less likely that residual contamination that would pose a human or ecological concern will remain at a site once characterization and remediation is complete. Among the primary stumbling blocks preventing regulatory acceptance are questions about the performance and utility of proposed real-time analytical techniques, and the quality of decisions that will be made within a dynamic work strategy. The Triad Resource Center contains case studies that demonstrate the benefit of these types of techniques within a Triad approach, and that set precedent for their use in a variety of settings. Lingering site-specific concerns can be addressed using demonstrations of method applicability, and through the design and implementation of proper QA/QC programs. Another primary stumbling block that is more difficult to address is the adversarial nature of cleanup activities at some sites, and the mistrust bred under such circumstances. In these cases static work plans developed under a more traditional approach provide some assurance to regulators about what exactly will be done. Dynamic work strategies can raise concerns about the responsible party making inappropriate decisions during the course of field activities. In this situation, a Triad core team comprised of regulators, technical support staff as appropriate, and project management that is fully engaged with planning and implementation activities is critical to ensuring a transparent work effort and consensual, technically-based, defensible decision-making.