Win-Win Regulatory Strategies in Idaho - 19241
During the course of any waste management or environmental remediation project, the earliest goals must include the creation and maintenance of mutual trust, respect, and cooperation with regulatory agencies and stakeholders. The heavy equipment and treatment systems remain idled until bounding characterization and risk analysis is complete, technical and functional requirements are identified, required controls and limits are established, and the proper permits and approvals are issued. Once a project receives approval to start up or break ground, the regulatory process has only just begun. Process modifications and improvements, as well as unexpected events, will continue to necessitate further reviews, discussions, and approvals. Building healthy professional relationships with the regulatory community and consistently meeting or exceeding their expectations, while operating within controls, is a cornerstone to jointly finding cost-effective solutions to complex issues, and streamlining the path to success. Navigating the optimal routes to compliance through the myriad regulatory waypoints is essential to avoiding schedule delays, staying within budget, and keeping clients continuously satisfied and delighted. Two complex case studies from the Idaho Cleanup Project Core will examine regulatory communication and integration strategies that have proven effective to date in obtaining timely approvals and maintaining compliance: (1) conducting Decontamination and Decommissioning as non-time critical removal actions (NTCRA) under CERCLA, and (2) preparing the integrated documentation necessary to obtain DOE, EPA, DEQ, and NRC approvals to close calcine storage units at the Idaho Nuclear Technology and Engineering Center (INTEC). (author)