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Keys to Technology Selection and Acceptance
As described throughout the Road Map, innovative technologies and technology
approaches offer many advantages in the cleanup of brownfields sites.
Stakeholders in such sites, however, first must accept the technology.
Brownfields decision-makers should consider the following elements to
increase the likelihood that the technology will be accepted, thereby
facilitating the cleanup of the site.
1) Focus on the Decisions that Support Site Goals
As discussed in Spotlight 7, The Triad approach,
systematic planning is an important element of all cleanup activities.
Clear and specific planning to meet explicit decision objectives is essential
in managing the process of cleaning up contaminated sites: site assessment,
site investigation, site monitoring, and remedy selection. With good planning,
brownfields decision-makers can establish the cleanup goals for the site,
identify the decisions necessary to achieve those goals, and develop and
implement a strategy for addressing the decision needs. Technology decisions
are made in the context of the requirements for such decisions. All cleanup
activities are driven by the project goals. An explicit statement of the
decisions to be made and the way in which the planned approach supports
the decisions should be included in the work plan.
2) Build Consensus
Investing time, before the site work begins, in developing decisions
that are acceptable to all decision-makers will foster more efficient
site activities and make successful cleanup more likely. Conversely, allowing
work to begin at a site before a common understanding and acceptance of
the decisions have been established increases the likelihood that the
cleanup process will be inefficient, resulting in delays and inefficient
use of time and money. Further, decision-makers must understand that there
is uncertainty in all scientific and technical decisions (see below for
more information about uncertainty). Clearly defining and accepting uncertainty
thresholds before making decisions about the site remedy will build consensus.
Decisions also should be made in the context of applicable regulatory
requirements, political considerations, budget available for the project,
and time constraints.
3) Understand the Technology
A thorough knowledge of a technology’s capabilities and limitations is
necessary to secure its acceptance. All technologies are subject to limitations
in performance. Planning for the strengths and weaknesses of a technology
maximizes understanding of its benefits and its acceptance. “Technology
approvers,” typically regulators, community groups, and financial service
providers are likely to be more receptive of a new approach if the proposer
provides a clear explanation of the rationale for its use and demonstrates
confidence in its applicability to specific site conditions and needs.
This latter point underscores the importance of carefully selecting an
experienced, multidimensional team of professionals who have the expertise
necessary to plan, present, and implement the chosen approach.
4) Allow Flexibility
Streamlining site activities, whether site assessment, site investigation,
removal, treatment, or monitoring, requires a flexible approach. Site-specific
conditions, including various physical conditions, contamination issues,
stakeholder needs, uses of the site, and supporting decisions, require
that all decision-makers understand the need for flexibility. Although
presumptive remedies, standard methods, applications at other sites, and
program guidance can serve as the basis for designing a site-specific
cleanup plan and can help decision-makers avoid “starting from scratch”
at each site, decision-makers should be wary of depending too heavily
on “boilerplate language” and prescriptive methodologies, as well as standard
operating procedures and “accepted” methods. While such tools provide
excellent starting points, they lack the flexibility to meet site-specific
goals. To ensure an efficient and effective cleanup, the actual technology
approach, whether established or innovative, must focus on decisions specific
to the site.
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Managing Uncertainty
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| Managing uncertainty
is the unifying theme of the Triad approach, and it is a crucial aspect
of the effective use of field analytical methods (see Spotlight
7, The Triad Approach). Although not all field analytical technologies
employ screening methodologies (for example, field-portable gas chromatography/mass
spectrometry [GC/MS] is a definitive analytical methodology), many
such technologies (for example, immunoassays) do. In general, data
produced by screening analytical methods will present more analytical
uncertainty than data produced by definitive methods. However, that
fact in itself does not make definitive methods necessarily “better”
than screening methods. Definitive methods are not fool-proof – interferences
or other problems can cause a marked increase in their analytical
uncertainty. On the other hand, a number of strategies can be used
to minimize the analytical uncertainty inherent in screening methods.
Such strategies include the selection of appropriate QA/QC procedures
to ensure that the data are of known and documented quality. Most
important, field analytical technologies offer the unique ability
to cost-effectively manage the largest single source of decision error—sampling
representativeness—an ability that is not available when requirements
to use fixed laboratory methods discourage proactive management of
sampling uncertainty. |
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Sunday, September 7, 2008
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