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Stakeholder Involvement

Stakeholder participation plays a particularly important role in a Triad approach.

While stakeholder participation is necessary for all hazardous waste site remediation and closure efforts, it plays a particularly important role in the Triad approach. This is because of the Triad's reliance on what may be non-standard analyses to support real-time decision-making, and its use of dynamic work strategies that often defer significant decisions to the field during data collection, remediation, or monitoring. Successful deployment of a Triad approach requires stakeholder participation not just in concurring with strategies and work plans, but also potentially with decisions that are made in the field in response to conditions/real-time results as they are encountered. This level of participation can have a positive impact on the ultimate outcome of a characterization or remediation program, since stakeholder issues with data or activity performance can be addressed while field work is underway. However, it also requires a different form of interaction with stakeholders than has traditionally been the case.

From a manager's perspective, Triad-specific linkages with stakeholders (regulators as well as others) include:

CSM Development. The CSM captures the primary and secondary decisions that must be made, organizes site understanding in a fashion that will support those decisions, identifies the level and nature of uncertainty present in the CSM, and develops strategies for managing that uncertainty. Collecting additional information will likely be a part of those strategies. Stakeholder "buy-in" with a site CSM is critical to Triad success. If there is fundamental disagreement with CSM components, or with the level of certainty/uncertainty embodied by the CSM, then there will be stakeholder disagreement over work plans, uncertainty management strategies, and ultimately site decisions that flow from the CSM.

Analytical Technique Selection. Triad-based data collection programs will typically rely on a variety of data collection techniques and analytical methods to achieve the desired level of decision-making certainty. These methods will certainly include analyses that are considered standard in their description, methodology, and associated quality control. There will also be methods whose application may be considered non-standard. These may be technologies that truly are innovative and different. There may also be technologies whose base technique has been standardized, but whose standard operating procedures are modified to meet site-specific needs. For these techniques, regulatory and stakeholder acceptance will be critical to their successful deployment.

Real-Time Decision-Making. Stakeholder acceptance of real-time decision-making based on real-time data occurs at two levels. The first level is concurrence with the decision-logic (if-then scenarios and contingency plans) embodied in the dynamic work strategy and captured in subsequent work planning documents. The second is concurrence with significant real-time decisions that are made while work is underway, particularly when those decisions are in response to unexpected conditions, or deviate from the original decision-logic. A prime example is the alteration of an analytical method, or substitution of a different analytical method, in response to performance problems encountered during field work.

One way to obtain this form of stakeholder involvement is through the use of a core team that guides Triad implementation. The core team would include representatives of the responsible party, regulatory agencies, local groups or organizations, and technical expertise resources. The purpose of the core team is to reach concurrence at key decision points as work progresses, and to be on-call if critical decisions are required unexpectedly during field activities. The intent of the core team is to support consensus-based decision-making, and streamline the cycle of document preparation, submittal, review, comment, comment response, etc. For core teams to be successful, participants must be committed to work through technical issues in a non-adversarial manner, and to be available and engaged on an as-needed basis. Successful core teams are also ones where there is membership continuity over the life-cycle of a project, since the team will embody a collective understanding of the technical and political basis for work done to date, and work proposed for the future.

There is also the assumption that core team members can speak for their respective agencies and organizations, minimizing the possibility that formal approval by agencies of proposed plans and strategies would not be obtained. The use of a core team, however, does not supercede the roles regulatory and oversight agencies play, nor does it completely eliminate the potential for an impasse to develop among stakeholders that must be resolved via more traditional mechanisms.