The Triad changes the timing of regulatory participation, which in turn requires modifying the way cleanup work typically gets done.
A key difference between the Triad approach and more traditional remedial projects centers on the temporal distribution of regulatory participation. Traditional projects tend to be "back-end loaded" with little regulatory participation early in the process and heavy participation in the review of data reports, alternative analyses, remedial decision documents, and closure reports. Because the Triad emphasizes systematic planning from the inception of a project, regulatory involvement occurs much earlier and topics are engaged as part of the project planning processes that are often deferred under more traditional approaches. A primary contribution regulators make by engaging early is to clarify key criteria that project decision-makers must understand to manage the project's decision uncertainty. Issues with regulatory dimensions that can be addressed early in the systematic planning process include:
future land use;
exposure assumptions;
the process for determining contaminants of potential concern (COPCs);
ARARs and other decision criteria;
QA/QC procedures;
groundwater classification;
statistical protocols, and
approaches for handling background contaminant level estimation.
Ideally under the Triad, the life-cycle level of effort for regulators and other project staff is reduced over the lifetime of the project by moving the planning concerning these types of decisions to the front-end of the project. The reason is that it is much more efficient to develop decision statements and design data collection programs when the specifications are clear and agreed upon by the regulators and responsible parties. Because project protocols have been fully developed and verified by the regulators and it is clear what the data analysis means when the results are available, much less time is required for regulatory review and the likelihood and duration of additional remobilizations to further characterize the site are greatly reduced.
