By Collin Linebach
I am, by far, not the most seasoned veteran of RCRA in our office. Heck, most of the guys here are old enough to remember when RCRA was passed into law by Congress! Recently, however, I attended the EPA Region 4 RCRA Facility Investigation Remedy Selection Track (FIRST) training in Atlanta. As a consultant, the principles employed through the FIRST technique (communication, flexibility, and a desire to solve problems) are nothing new. The EPA, on the other hand, doesn’t have to attract or retain clients, so the need for improved communication and techniques to keep the process moving had to be recognized, desired, designed and implemented. I am convinced that the RCRA FIRST process will improve the RCRA Facility Investigation and Remedy Selection process the same way good client communications, flexibility and a desire to solve problems keeps LFI’s clients satisfied (hopefully!)
EPA Regions 3 and 7 identified three primary causes of delay in the RFI and remedy selection process: no common or upfront understanding on investigation or remedy selection objectives (communication), competing objectives among parties (impassable disagreements), and overall strategies are not discussed early in the process (communication, again).
The RCRA FIRST process hits the ground running with a well-informed, structured meeting between the facility, their consultant and the EPA designed to generate a plan of attack for the Facility Investigation. Then, FIRST fills in the gaps in and around a RCRA Facility Investigation and the approval of Remedy Selection with more communication, meetings as necessary, and a more streamlined approach to plan and remedy approvals. And, for those times when industry and regulators just cannot see eye to eye, the process will no longer come to a screeching halt. That’s right, no more waiting it out for a new regulator, or retirement. The crown jewel in the FIRST Toolbox is the new elevation tool. Write down the seemingly unresolvable issue, send it upstairs, move forward with the meeting. The resolution will come, but this time it will come without the bruised egos and prolonged process.
The RCRA FIRST Toolbox for Corrective Action aims to reduce the average RCRA Facility Investigation and Remedy Selection process from over 19 years to about 5 years. The RCRA FIRST process reduces the number of hand-offs, reviews, approvals, loopbacks, resubmissions, re-dos and decision points to the tune of approximately 80% higher efficiency in remedy selection. And that is not all! The RCRA FIRST approach should also:
• Reduce time and costs needed to complete the facility investigation and remedy selection;
• Accelerate positive environmental results for affected communities;
• Provide a roadmap with process metrics to drive continuous improvements;
• Enhance communication throughout the process;
• Ensure all stakeholders have a clear understanding of the steps to select a remedy and complete construction.
Region 4 received the third RCRA FIRST Toolbox Training nationwide, after Regions 3 and 7, in January 2016 at the EPA Regional Office in Atlanta, Georgia. This training brought together Region 4 states, RCRA project managers, facility representatives, and consultants to learn about opportunities to improve corrective action using the FIRST approach. LFI is excited to have been a part of the third ever RCRA FIRST training, and we are ready to bring our expertise to your project.