ASTM Announces Guide for Greener Cleanups
Submitted by Nancy Zikmanis
In recent years, the EPA has included an evaluation of the green options in their Brownfield grants and RCRA/CERCLA clean-ups. EPA’s guidance has been varied and did not provide an in-depth guidance on what actions a consultant, applicant, or responsible party should take to meet this element of the program. In 2009, the EPA drafted a green strategy document, required public and State input, and issued the Superfund Green Remediation Strategy document in 2010. EPA also issued guidance called Green Remediation – Best Management Practices, and offered training through coordination with Clu-In. Several of the Regional offices and State Environmental Protection offices also have attempted to develop guidance on Green Remediation which considered various aspects of sustainability and remedial opportunities.
These documents varied widely and did not provide a clear and overarching perspective of green remediation and its best management practices from a global viewpoint. ASTM took on the challenge first as a Sustainability Guidance and found the task daunting so it was divided into two different standards for better understanding and use. Green remediation moved off into its own path to document the opportunities for green practices in environmental remediation with a diverse group of committee members and so the Guide to Greener Cleanups (E2893) was born.
The document took shape as a standard of green remediation best management practices to try to cover all sizes and shapes of projects. The guide was designed to ‘work well with the framework of the proposed Standard Guide for Integrating Sustainable Objectives into Cleanup (E2876-13)’, which also integrated social and economic aspects along with the environmental objectives. The guide was developed to ‘incorporate practices, processes, and technologies into cleanup activities with the goal of minimizing impacts to the environment through reduced demands on natural resources and decreased emissions to the environment’. Remember also that this document has been developed as a guide and not a standard practice due to the complexity of the subject.
The guide provides for tools to evaluate, assess, implement, and document remedial activities that reduce the environmental footprint of a cleanup by incorporating EPA’s core elements into cleanups with the goal of reducing the environmental footprint of remedies. These core elements include:
- Minimize Air Pollutants and Greenhouse Gas Emissions;
- Minimize Total Energy Use and Maximize Use of Renewable Energy;
- Minimize Water Use and Impacts to Water Resources;
- Reduce, Reuse, and Recycle Material and Waste; and
- Protect Land and Ecosystems.
The guide encourages professional judgment in balancing the greener alternatives with regulatory requirements and client needs to ensure protection of human health and the environment. The guide has two parts – use of Best Management Practices (BMPs) and incorporation of a quantitative evaluation which focuses on a Life Cycle Analysis (LCA) or footprint analysis for the greener demonstration, an optional evaluation to compliment the BMPs. The document includes supporting appendices, forms, and a BMP table to help the user as they navigate through the planning process and on to the final reporting.
The guide also acknowledges the various scenarios that a user may be utilizing to complete their projects, such as regulatory oversight; land use; size of the property; types and concentrations of contaminants; budget and time; and stakeholder interaction. These two processes can both be applied to the entire cleanup process. The idea behind two pieces of the greener puzzle is to allow users to either quickly define the BMPs which suit their project and move forward or allow for additional evaluation to find more reductions, as needed or desired, for a project. Often, size and contaminant levels limit projects from applying many green best management practices; this guide will help users still reap the rewards of greener cleanups by providing multiple alternatives and opportunities for small to complex projects.
The guide is flexible in its application to all project phases from site assessment through remedy selection, remedial design, operation and maintenance, and finally to remedial optimization. Each has their own characteristics and opportunities to embrace greener cleanups. BMPs fit well in times of action, such as during design, construction, and operation and maintenance. Quantitative Evaluation is best instituted during the phases following site assessment as the assessment stage it is typically too early in the process to benefit from the quantitative evaluation expense and effort. Both processes allow users to identify, evaluate, prioritize, implement, and document the best alternatives for greener cleanups.