Att_15_GSP_Interim_Guidance.pdf

Interim Guidance 10-01 5 March 2010

ENVIRONMENTAL QUALITY

DECISION FRAMEWORK FOR INCORPORATION

OF GREEN AND SUSTAINABLE PRACTICES

INTO ENVIRONMENTAL REMEDIATION

PROJECTS

Groundwater recirculation well powered by a wind turbine at the Former Nebraska Ordance Plant Superfund Site, Mead, NE. Photo by Ernie Guitierrez and used with permission of Curt Elmore, Missouri University of Science and Technology

Environmental and Munitions Center of Expertise Interim Guidance

AVAILABILITY

Electronic copies of this and other U.S. Army Corps of Engineers Environmental and Munitions Interim Guidance Documents are available on the Internet at http://www.environmental.usace.army.mil/corpguide.htm.

Publications are provided in portable document format (PDF).

Printed on Recycled Paper http://www.environmental.usace.army.mil/corpguide.htm

REPLY TO

ATTENTION OF

CEHNC-CX-EG

DEPARTMENT OF THE ARMY

HUNTSVILLE CENTER, CORPS OF ENGINEERS

P.O. BOX 1600

HUNTSVILLE, ALABAMA 35807-4301

'5 March 2010

MEMORANDUM FOR SEE DISTRIBUTION

SUBJECT: Decision Framework for Incorporation of Green and Sustainable Practices into Environmental Remediation Projects, Environmental and Munitions Center of Expertise Interim Guidance Document (IGD) 10-01

1. PURPOSE: Interim Guidance Document 10-01 (enclosed) describes the general principles, concepts, and considerations that can be used to incorporate green and sustainable practices into Formerly Used Defense Sites (FUDS) envirori"mental remediation projects. The document describes a decision framework whereby Project Delivery Teams can consider and implement, wherever appropriate, green and sustainable practices throughout the life cycle of a project.

2. APPLICABILITY: This guidance is applicable to FUDS environmental remediation projects executed and managed by the U.S. Army Corps of Engineers (USACE). It may also be applicable to environmental remediation projects managed or implemented by USACE for Army installations and the Environmental Protection Agency. subject to the needs and desires of the customer.

3. EFFECTIVE DATES: The information presented in this interim guidance can be used immediately. The interim guidance will , remain in effect indefinitely, unless superseded by other guidance or policy.

4. DISTRIBUTION: This guidance is approved for public release and unlimited distribution.

5. POINT OF CONTACT: For additiona1 information or to submit suggestions for improvements to this guidance, please contact Dr. Carol Dona at (402)-697-2582 or caroLJ.dona@usace.army.mil.

Enc1 as Director, USACE Enviro

Munitions Center of Experose Dire:ctorate

IG 10-01 03_05_10.doc

TABLE OF CONTENTS

1. Introduction

1.1. Purpose and Scope

1.2. Authorities and Relevant Policies

2. Structure to Incorporate Green and Sustainable Practices into Environmental Remediation

3. Decision Framework to Incorporate Green and Sustainable Practices into the Environmental Project Lifestyle

4. Path Forward

5. References

Tables and Figures Table 1. Methodologies for Incorporating Green and Sustainable Practices into Activities in the CERCLA Cleanup Life Cycle Table 2. Output of Quantitative Sustainability Tools Table A-1. Potential Green and Sustainable Practices Incorporation into USACE Contracts..........................................................................................................................A-3 Table A-2 Examples of Sustainable Practices for Site Assessment that Incorporate Innovative Technologies................................................................................................A-10 Table A-3 Connection Between Sustainability Factors and CERCLA Evaluation Criteria...........................................................................................................................A-14 Figure 1. Decision Flow Chart for Incorporating Green and Sustainable Principles into the Life Cycle of USACE Environmental Remediation Projects

Appendices Appendix A. Step-by-Step Walk-Through of Green and Sustainable Practices Flow Chart ......................................................................................................................A-1 Attachment A-1. Possible Sustainability Contract Language Tailored to Federal Acquisition Regulations (FAR) Section 15.204-1 Uniform Contract Format (FAR 2009)....................................................................................................................A-26 Attachment A-2. Independent Review Checklist for EPA Fund Lead Remedial Design Projects Draft Final............................................................................................A-31 Appendix B. Acronyms...................................................................................................B-1 Appendix C. Case Studies ...............................................................................................C-1 i

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Typewritten Text

1. Introduction

Consistent with Executive Order 13423 — Strengthening Federal Environmental, Energy, and Transportation Management (EO 2007), the Department of Defense (DoD) has directed DoD Components to “…consider and implement green and sustainable remediation opportunities when and where they make sense” (DoD 2009). Green and sustainable environmental remediation practices are ones that:

Use natural resources and energy efficiently;

Reduce negative impacts on the environment;

Minimize or eliminate pollution at its source;

Protect and benefit the community at large; and Reduce waste to the greatest extent possible (DoD 2009).

This decision framework outlines the process through which these and other green and sustainable practices can be undertaken across the life cycle of Formerly Used Defense Site (FUDS) program projects executed by the US Army Corps of Engineers (USACE).

1.1. Purpose and Scope

The purpose of this document is to provide a process for incorporating green and sustainable practices into environmental remediation consistent with DoD policy (DoD 2009) and the Army Environmental Cleanup Strategic Plan (US Army 2009) during USACE execution of the FUDS program. The scope of the document is to provide these processes for the entire environmental remediation lifecycle, from project inception through site closeout. The framework is readily adaptable to the FUDS Installation Restoration Program (IRP), the Military Munitions Response Program (MMRP), and the Building Demolition and Debris Removal (BD/DR) Program.

1.2. Authorities and Relevant Policies

The FUDS program was established under authority of the Defense Environmental Restoration Program (10 USC §2701) to address those locations described under 10 USC §2701(c) as: “Each facility or site which was under the jurisdiction of the Secretary and owned by, leased to, or otherwise possessed by the United States….” The FUDS program is managed and executed by the USACE, under authority delegated to the Secretary of the Army by Department of Defense Instruction (DoDI 4715.7). Due to the relationship of authorities between DERP and the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), USACE preference is to conduct all FUDS environmental response actions in accordance with CERCLA and the National Oil and Substances Pollution Contingency Plan (NCP) (CFR Title 40 Part 300) when appropriate. Consequently, consideration and implementation of green and sustainable practices will typically take place within the existing CERCLA response framework but should not be limited to CERCLA response actions.

Incorporation of sustainable practices in US Federal agencies has been directed by a series of Executive Orders [EO 13101 (EO 1998), EO 13123 (EO 1999b), EO 13134 (EO 1999a), and EO 13148 (EO 2000)], which were consolidated in and superseded by EO 13423 “Strengthening Federal Environmental, Energy, and Transportation Management” (EO 2007). The EO states that to be sustainable “…means to create and maintain conditions, under which humans and nature can exist in productive harmony, that permit fulfilling the social, economic, and other requirements of present and future generations of Americans.” It further calls on federal agencies to “…conduct their environmental...and energy-related activities...in an environmentally, economically, and fiscally sound, integrated, continuously improving, efficient, and sustainable manner.” DoD’s policy memorandum, Consideration of Green and Sustainable Remediation Practices in the Defense Environmental Restoration Program, lays out the requirements for DoD Components to carry out their environmental restoration activities consistent with EO 13423 (DoD 2009). Recently, EO 13514 (EO 2009) was also issued, laying out additional requirements and expanding upon the goals established in EO 13423.

In compliance with EO 13423, the Army has also outlined its approach to green and sustainable remediation in the FY 2010-2011 Army Environmental Cleanup Strategic Plan (Army 2009). The Plan states, “the Army’s approach to “green remediation” seeks to preserve our natural resources, minimize energy use, minimize carbon dioxide emissions, maximize recycling and reuse of materials, and minimize the Army’s environmental footprint.” The approach encourages “project managers to seek opportunities to incorporate options for minimizing the impact on the environment of cleanup actions undertaken at Army installations.” The Plan also contains the specific objective for the FUDS program to consider “green remediation approaches to existing and future remedies.” In addition, the Plan outlines a SMART (Sustainable Management of Available Resources and Technologies) cleanup approach that promotes sustainability through greater flexibility in the reuse of contaminated land, recommending consideration of future reuse of a contaminated site early during development of the site remediation strategy.

In addition to the 2009 DoD policy and the Army Environmental Cleanup Strategic Plan, other policies or positions taken by DoD or its Components with respect to incorporation of green and/or sustainable practices include:

Use of best management practices for achievement of environmental protection through the establishment of Environmental Management Systems (EMSs) on Army facilities as outlined in the ISO 14001 EMS standard (ISO 2004) and EMS policy and guidance (US Army 2006c);

Incorporation of sustainable design and development into vertical construction, policy and associated guidance (US Army 2006a, and US Army 2007);

Minimization/diversion of deconstruction/demolition waste (US Army, 2006a), DoD being a signatory to the Federal Leadership in High Performance and

Sustainable Buildings Memorandum of Understanding (EPA 2006b);

The Army Strategy for the Environment (the Army Strategy) in 2004 (US Army

2004), which outlines a vision as the Army “simultaneously meets current as well as future mission requirements world-wide, safeguards human health, improves quality of life, and enhances the natural environment”; and

The Department of Navy, Naval Facilities Engineering Command, Sustainable Environmental Remediation (SER) Fact Sheet (Navy 2009), which outlines a general approach to applying green and sustainable environmental remediation to a site, including the choice of green and sustainable elements and metrics, methodologies to quantify the metrics, and use of the results to reduce the environmental footprint of the site remediation.

Existing Federal laws and regulations also contain elements that encourage green and sustainable practices. The Energy Independence and Security Act (EISA) of 2007 (EISA 2007), Section 438, includes storm water runoff requirements for development or redevelopment projects involving Federal facilities with footprints exceeding 5000 square feet. In addition, the Federal Acquisition Regulation (FAR), 48 Code of Federal Regulations (CFR) “Environment, Energy and Water Efficiency, Renewable Energy, Occupational Safety, and Drug-Free Workplace,” includes the Government’s policy to “acquire supplies and services that promote energy and water efficiency, advance the use of renewable energy products, and help foster markets for emerging technologies” [23.202 Policy] (FAR 2009).

The US Environmental Protection Agency (EPA) has provided several information documents on incorporation of green and sustainable practices into environmental remediation. These include the Green Remediation Technology Primer (EPA 2008d), which provides topical information on how to incorporate green and sustainable environmental practices into remediation of contaminated sites, and “Principles for Greener Cleanups,” (EPA 2009b), which updates the elements from the Primer to be considered within an environmental remediation project to potentially make the cleanup more green and sustainable. In addition, EPA has issued a ruling that determined six greenhouse gases (carbon dioxide, methane, nitrous oxide, hydrofluorocarbons, perfluorocarbons, and sulfur hexafluoride) “endanger the public health and welfare of current and future generations” (EPA 2009a). However, no regulatory emission requirements on the greenhouse gases have been established.

Several EPA regions have also issued policies, including:

Region 2 (http://www.epa.gov/region02/superfund/green_remediation/);

Region 9 (http://www.clu-in.org/greenremediation/); and Region 10 (http://yosemite.epa.gov/R10/extaff.nsf/programs/greencleanups).

http://www.epa.gov/region02/superfund/green_remediation/ http://www.clu-in.org/greenremediation/ http://yosemite.epa.gov/R10/extaff.nsf/programs/greencleanups

These policies are Region-specific but generally include recommendations for use of renewable energy sources, greener materials, cleaner (lower emission) fuels, water conservation, reduced greenhouse gas emissions, and waste and material recycling and reuse.

Despite the existing authorities and policies discussed above, the incorporation of green and sustainable practices into environmental remediation is presently limited by the following:

No DoD/Department of Army indicator or measure of success;

The current lack of regulatory requirements mandating incorporation of green and sustainable practices at federal facility sites;

Concerns within the regulatory community that the CERCLA statutory criteria will be overshadowed by incorporation of green and sustainable practices;

The difficulty in quantifying the impact of some green and sustainable practices, such as preservation of green space and other ecologically friendly practices, which have aesthetic benefits but do not necessarily lead to site-related risk reduction or result in cost savings; and

Lack of a current framework to consistently consider site-related impacts that extend beyond the boundaries of the site, affecting, for example, air quality or regional water supplies, which can lead to underestimating the benefits of green and sustainable practices.

Because of these limitations and the fact that green and sustainable remediation has only recently emerged, there is no “industry-standard” structure for incorporating green and sustainable practices into environmental remediation. Section 2 describes the structure used in this decision framework.

2. Structure to Incorporate Green and Sustainable Practices into Environmental Remediation

The impetus behind this decision framework is the need to provide a process whereby USACE project teams can consider, implement, and document incorporation of green and sustainable practices into environmental remediation consistent with the existing FUDS regulatory framework, DoD policy, and the Army Environmental Cleanup Strategic Plan.

Given the preference of the USACE to use the CERCLA framework for the FUDS program, this decision framework uses the sequential CERCLA site cleanup process as the basic structure with which to frame incorporation of green and sustainable practices.

Certain methodologies are conducive to the incorporation of green and sustainable practices.

Use of these methodologies in the different activities associated with CERCLA remediation can achieve significant green and sustainable benefits. Table 1 summarizes the methodologies that are recommended for use in each activity, along with specific applications and examples of incorporation of green and sustainable practices within each methodology. Table 1 also includes locations in Appendix A where instruction in using the methodologies is included.

Table 1. Methodologies for Incorporating Green and Sustainable Practices into Activities in the CERCLA Cleanup Life Cycle

Activity Methodology Specific Applications of Methodologies

Potential Green and Sustainable

Practices Incorporation

Additional Information Location in Appendix A

Planning (all phases)

Systematic planning (included in all phases)

USACE Technical Project Planning (USACE, 1998) Data Quality Objectives (DQOs) (EPA, 2006a)

Early involvement of stakeholders and concerns, efficient, long-range (to site close-out) project planning

Steps 1-3

Investigative Dynamic work strategies, real-time measurement, field-based investigation

Performance-Based Management (AFCEE, 2004)

TRIAD (ITRC 2003)

Less waste generation, efficient use of resources

Step 5

Remedy development and evaluation

Standard, systematic development and comparison of remedial options on the basis of multiple decision-making criteria

CERCLA Feasibility Study (EPA, 1988)

Balanced decision-making over range of different criteria;

same structure serves as a template for considering green and sustainable practices

Steps 7-8

Remedy selection

Stakeholder involvement

Record of Decision (EPA, 1999) Inclusion of public and support agency concerns

Step 9

Remedy implementation

Independent design review and construction best management practices

Independent Design Review Checklists and Value Engineering Studies (EPA, 2008b) State of Illinois: Green Remediation Best Management Practices (State of Illinois EPA, 2008)

Waste minimization and efficient use of resources;

recycling/reuse of equipment/materials

Steps 10-11

Activity Methodology Specific Applications of Methodologies

Potential Green and Sustainable

Practices Incorporation

Additional Information Location in Appendix A

Operations and maintenance

Optimization of remedial system operations and maintenance

Remediation System Evaluation (USACE, 2009) Long Term Monitoring Optimization (EPA and USACE, 2005b)

Reduced resources through shorter remediation times and through optimization of O&M activities and/or monitoring networks

Steps 13-17

Closeout Maximization of site reuse, materials, and resources

Principles in waste minimization policy (US Army, 2006a) Low Impact Development Storm Water Practices (EPA 2007a) Planning and Promoting Ecological Land Reuse of Remediated Sites (ITRC, 2006) Carbon Sequestration in Agriculture and Forestry (EPA, http://www.epa.gov/sequestration/practices.html)

Recycling/reuse of equipment/materials, beneficial public or ecological site reuse, carbon sequestration

Step 18

In addition to general methodologies, it is necessary to establish a secondary structure through which green and sustainable principles and practices specific to environmental remediation can be identified, considered, implemented, and documented. The first step in developing this structure is selection of green and sustainable remediation elements.

Consistent with EO 13423 (EO 2007), EPA proposed in the Green Remediation Primer (EPA 2008d) that the core elements of green and sustainable remediation be 1) air, 2) water, 3) land and ecosystems, 4) materials and waste, 5) energy, and 6) stewardship. These elements have been further refined in the EPA Greener Cleanup Principles (EPA 2009b) to 1) total energy use (and renewable energy use), 2) air pollutants and greenhouse gas emissions, 3) water use and impact to water resources, 4) materials management and waste reduction, and

5) land management and ecosystem protection. In addition to the elements identified by EPA, the Navy (Navy 2009) and the Air Force (AFCEE 2009) have also identified worker safety as a green and sustainable remediation element. The USACE and Army have not established recommendations for elements. However, the goals in the Army Environmental Cleanup Strategic Plan (Army 2009) can be encompassed by the elements defined by the Navy (Navy 2009), so it is recommended that project teams adopt the Navy recommendations as initial elements on USACE environmental remediation projects. It is expected that the final choice of elements will be project-specific and made by the project team.

Once the elements are identified, it is necessary to define metrics that allow quantitative and/or qualitative representation of the elements. The Navy used the core EPA elements from the Green Remediation Primer to develop the following metrics: 1) energy consumption, 2) green house gas and criteria pollutant emissions, 3) water impacts, 4) ecological impacts, 5) resource consumption, and 6) community impacts (Navy 2009). The Navy has also included worker accident and fatality risk as a metric for the additional element of worker safety (Navy 2009). As with elements, the USACE and Army do not currently have core metric recommendations; however, the goals in the Army Environmental Cleanup Strategic Plan (Army 2009) can be encompassed by the metrics defined by the Navy. Therefore, it is recommended that the Navy recommendations for metrics also be used as initial metrics for USACE projects, with the final choice of metrics made by the project team based on project-specific needs.

Once the elements and metrics have been selected, green and sustainable practices can be identified that can reduce the overall environmental footprint. Tools to help in this process generally fall into two general categories: 1) tools that identify green and sustainable best management practices (BMPs) and 2) tools that quantify the green and sustainable aspects of different remedial options based on a defined set of metrics.

In using tools that identify BMPs, the BMP is often selected based on applicability to the project conditions, and the elements and metrics through which the BMP achieves green and sustainable benefits are then documented. For example, passive sampling devices may be chosen, with reduction of the environmental footprint attributed to the reduction in waste generated (no investigation-derived waste), and reduced energy use (no need to pump water from wells to collect samples). The tools that quantify green and sustainable aspects through use of metrics are useful when comparing different remedial options, to both determine and document the impact on environmental footprint. One advantage of these latter tools is that they can quantify the overall sustainability of the life cycle of a process. For example, for a particular project, pursuing the BMP of grey water use might require an expanded conveyance system to deliver the water. The overall environmental footprint resulting from conservation of water and pipeline construction and installation (with associated energy use and greenhouse gas emissions) could be evaluated. In some instances, simply following a BMP may not be the most green and sustainable approach.

Examples of some of the tools currently being used are provided in Table 2 below (from SURF 2009) and the EPA Green Remediation Toolbox: Decision Tools (http://www.clu-in.org/greenremediation/subtab_b3.cfm). An example of a tool that identifies green and sustainable BMPs is the State of Illinois Greener Cleanup Matrix (State of Illinois 2007). An example of a tool that quantifies green and sustainable aspects through metrics is the Air Force Sustainable Remediation Tool (SRT) (AFCEE 2009).

It is expected that the decision as to tool use again will be made by the individual project teams based on the specific project requirements and the resources available. However, the USACE is evaluating two tools, the Air Force SRT (AFCEE 2009) and the Battelle SiteWise™ SER tool (Battelle 2009), which are or will be available to the public. An initial version of the Air Force SRT with four remedial technologies (excavation, soil vapor extraction, pump and treat, and in-situ bioremediation) is currently publicly available (http://www.afcee.af.mil/resources/technologytransfer/programsandinitiatives/sustainablerem ediation/srt/index.asp), with an expanded technology suite (reactive walls, in-situ thermal, in-situ chemical oxidation, and long-term monitoring/monitored natural attenuation) expected in early 2010. The SiteWise™ SER tool, which is based on configuring remedial options through a series of activity modules, has been applied to several USACE/Army and Navy sites. The USACE and Navy have contracted with Battelle for further development and purchase of their SiteWise™ SER tool, with expected public availability of the tool in spring 2010. Application of these tools is described in more detail in Appendix A, with examples of application of the SiteWise™ tool to remedy selection and remedy optimization in Steps 8 and 15, respectively, in Appendix A. Detailed instructions on use of these tools is not included in this decision framework; rather, training is being planned on use of the tools and the process by which the tools can be used in an overall green and sustainable remediation evaluation, when the tools are complete and publicly available. Details on training will be communicated separately from this decision framework (see also Section 4).

One additional tool within the systematic planning methodology is sample language specifically for incorporating green and sustainable practices into remediation contracts.

Sample language for USACE contracts is provided in Appendix A Step 1 and Attachment A-1. The EPA “Green Response and Remedial Action Contracting and Administrative Tool Kit” also provides sample contracting language. http://www.clu-in.org/greenremediation/docs/Green_RR_Action_Contract__Admn_Toolkit_July%202009.p df

Section 3 provides a decision flowchart using the above general structure to incorporate green and sustainable practices into the different remediation phases.

http://www.clu-in.org/greenremediation/subtab_b3.cfm http://www.clu-in.org/greenremediation/subtab_b3.cfm http://www.afcee.af.mil/resources/technologytransfer/programsandinitiatives/sustainableremediation/srt/index.asp http://www.afcee.af.mil/resources/technologytransfer/programsandinitiatives/sustainableremediation/srt/index.asp http://www.cluin.org/greenremediation/subtab_b2.cfm

Name Approach Environmental Social Economic Outputs Outputs Outputs

Life Cycle Assessment (general) Quantitative Impacts of resource consumption, energy use, transportation emmissions, fuel production

Impact of emissions on regional health and globally

AFCEE Restoration Sustainability Tool (GSI Environmental) Quantitative Carbon dioxide (CO2) emissions, total energy consumed, change in resource service Safety /accident Risk Technology cost

Net Environmental Benefit Analysis Quantify and compare ecosystem service impacts

Evaluates existence and aesthetic value of ecosystems, preservation of biodiversity, habitat for threatened/endangered species and human recreational use

Risk reduction Cost and natural resource service benefits and losses

URS/Dupont Spreadsheet Quantitative Assessment of greenhouse gas production, energy usage, resource usage, and utilization of consumable products to determine carbon footprint/tons of CO2 equivalents

90 social outputs

GolderSET-SR-CN Sustainability Tool Hybrid: Semi-quantitative and Qualitative

Assessment of soil, sediment, groundwater, and surface water quality; product removal; water consumption, wildlife and flora conservation; off-site migration prevention, greenhouse gas emissions, energy conservation; solid residual matter management; site contaminant management; and hazardous waste management.

Assessment of impact of local resident safety and quality of life; worker safety; limited duration of work; benefits for contractor staff; beneficial use for local community; employee skill development;

local job creation and diversity; competitive advantage through innovation; response to social sensitivity; and standards, laws, and regulations.

Assessment of initial capital cost moderation; low annual O&M cost;

prevention of potential litigation; potential grants or subsidies; environmental liabilities reduction; train service reliability and performance; donations to the community;

economic advantages fro the local community; reliability (moderate maintenance and repair); economic advantage of more effective techology; and technological uncertainty management.

Minnesota ToolKit Qualitative Assessment of reasonableness of remediation/restoration options through decision tree evaluation and case studies Assessment of community acceptability Technology cost

The REC Decision Support System for Comparing Soil Remediation Alternatives (Dutch Research Programme for In-Situ Bioremediation)

Comparison of soil remediation technologies

Environmental merit Risk reduction Cost

Shell Cost-Benefit Analysis (United Kingdom) Quantitative Impacts of groundwater remediation (monetization of impacts) Monetization of risk/benefits Technology cost

Swedish Hållbar Sanering cost-benefit anlaysis/life-cycle analysis model Quantitative

Primary, secondary, and tertiary effects of contamination/remediation as in resource use, climate change, acidification, eutrophication, ozone formation, human toxicity, and ecotoxicity

Risk/socio-economic cost of secondary emissions (NOx, SO2, VOC, particles and CO2) Cost of clean-up

British Electric National Grid (developing a tool kit that will be available to public) Hybrid Carbon dioxide emissions, waste reuse, levels of noise, dust, vibration, and odor Deaths/injuries Cost

Danish National Railway Agency’s Model to Calculate Environmental Costs and Benefits

Quantitative evaluation of cost/benefit

Consumption of crude oil, hard coal, natural gas, brown coal, aluminum, iron, copper, manganese, nickel, sand/gravel, and water; Potential effects of global warming, ozone depletion, acidification, photochemical ozone formation, nutrient enrichment, persistent toxicity, human toxicity, ecotoxicity, bulk waste, hazardous waste, nuclear waste, slag and ashes Potential environmental benefits: reduction in persistent toxicity, reduction in ecotoxicity

Reduction in human toxicity from air and groundwater

California DTSC Green Remediation Matrix Qualitative matrix 17 items within categories of sustance and thermal releases, resource depletion, and physical disturbances

Ontario Life Cycle Framework Qualititative matrix and LCA

Matrix includes 22 items within pollution, disturbance and depletion categories. Life cycle analysis (LCA) includes GWP, solid waste burden, contaminant fate and toxicity, land use, and residual toxicity

Cadotte LCA study LCA Groundwater protection, ozone depletion, acidification, eutrophication, photochemical smog, ecotoxicity, Human health

Volkwein LCA study LCA 16 impact categories Godin LCA study LCA 12 impact categories Toffoletto LCA study LCA 12 impact categories

Lesage LCA model LCA Four combined categories of human health, ecosystem quality, climate change and resources. Human health

Illinois EPA/AECOM Qualitative Identification of benefits of remediation projects in terms of air, water, land and energy; assessment of clean-up options forminimizing pollution

Identifies potential regulatory, administrative, and operational barriers to remediation

Assessment of maximum efficiency of clean-up options

Sustainable Development Principles Worksheet (Chevron Superfund Site) Quantitative Waste minimization, recycling

Assessment of use of land and quality of business environment to enhance economic opportunities

Table 2 [from SURF (2009) Exhibit 3-2: Output of Quantitative Sustainability Tools -- Metrics]

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3. Decision Framework to Incorporate Green and Sustainable Practices into the Environmental Project Lifecycle

Decision Flow Chart

The following decision flow chart (Figure 1) maps out the process for considering the incorporation of green and sustainable practices in the overall project lifecycle based on the CERCLA process, from planning through site closeout. Although the lifecycle is specific to the CERCLA process, it is expected that the procedures provided can be applied to other cleanup programs, such as RCRA, underground storage tanks, state-led sites, BD/DR and Brownfields sites.

A summary of the process is included here; Appendix A provides a step-by-step walk-through of the steps in Figure 1, with details of implementation, examples, and references.

1. Site characterization results from a Preliminary Assessment/Site Inspection indicate further study is necessary. Initiate systematic planning and develop preliminary conceptual site model (CSM)

Figure 1 Decision Flow Chart for Incorporating Green and Sustainable Principles into the Life Cycle of USACE Environmental Remediation Projects

6. Incorporate data and information into a revised CSM and prepare RI report

7. During the evaluation of process options, consider any use or degradation of critical resources, including on-site and off-site resources. Where appropriate for site conditions and contaminants, include in the screening technologies that are by nature more green and sustainable.

8. Complete configuration, screening, and detailed analysis of alternatives within the CERCLA process. Continue to consider green and sustainable technologies and incorporation of green and sustainable practices into alternatives where and when it makes sense for the project and within the traditional CERCLA process. Perform comparative analysis of alternatives with resepect to standard CERCLA criteria and with respect to green and sustainability aspects.

10. Incorporate green and sustainable practices into scopes of work for remedial design-build and remedial operations contracts. Include existing Army guidance on sustainable design and waste minimization in design criteria as appropriate. Consider pre-design and independent review checklists as well as formal Value Engineering studies to optimize the remedy, including consideration of green and sustainable practices that conserve critical resources. Include best management practices in design that will be used in construction.

4. Determine if more data are necessary, including data for evaluation of technologies that are by nature more green and sustainable.

9. Prepare decision documents. Include evaluation of green and sustainable aspects of alternatives. Provide for public and support agency comment. Finalize decision documents.

11. Construct according to design. Monitor construction to ensure operations are consistent with green and sustainable practices.

2. Determine the program and project-specific factors that will influence the consideration and/or implementation of green and sustainable practices

12. Construction complete, document green and sustainable practices in remedial action report.

Remedy Selection, Design and Construction

15. Perform remedial system evaluation (RSE) that incorporates consideration of green and sustainable practices.

Remedy Operation and Maintenance

18. Remedial goals have been met and the site can be closed. Implement green and sustainable practices into the site deconstruction and site reuse process.

Site Closeout/Transfer

17. Establish procedures to periodically evaluate O&M procedures for optimization opportunities, including incorporation of green and sustainable practices.

16. Optimize long-term monitoring, including procedures that would consider and incorporate green and sustainable practices.

3. During systematic planning, consider opportunities throughout the environmental remediation cycle to incorporate green and sustainable practices

5. Collect data to fulfill project objectives.

14. Consider modification of existing O&M procedures from information obtained from the following options.

13. Is there an existing O&M Plan?

No

Yes

The decision process begins when initial site characterization indicates additional investigation is necessary (Step 1). A systematic planning process is recommended to form the project team, consisting of technical staff, customer, regulators, and stakeholders. A preliminary conceptual site model (CSM) is developed, which seeks to identify any constraints on implementation of green and sustainable practices. These constraints could be imposed by site conditions (presence of a sole source aquifer, for example) or community input. Step 2 examines program- and project-specific factors that may influence how and to the degree to which green and sustainable practices are incorporated. Such factors include contractual mechanisms, project scope, schedule and funding, and availability of experienced personnel to perform or oversee incorporation of green and sustainable practices. Included in Appendix A are examples of template contract language that can be used to incorporate green and sustainable practices into different types of environmental remediation contracts.

Step 3 identifies the information that needs to be collected in order to implement green and sustainable practices across the complete remediation process, and Step 4 identifies the process through which data can be collected for evaluation of remedial technologies that are inherently green and sustainable. Generally, these technologies are ones that mimic a natural process, such as phytoremediation. Ideally, the life cycle of the project will be considered when information and data gaps and needs are identified.

The investigation process is covered in Steps 5 and 6. Implementation of Step 5 involves consideration of investigation and data collection techniques that are green and sustainable.

One approach that lends itself to greater efficiencies during investigation is the use of dynamic work strategies and real-time measurement technologies, including field-generated data. Many green and sustainable BMPs are also listed in Step 5 that can be adopted in an a la carte manner. Updating of the CSM and preparation of the investigation report (Step 6) should clearly lay out conditions that favor implementation of green and sustainable practices and should identify site-specific cleanup levels.

Steps 7-9 examine ways of considering green and sustainable practices through the remedy formulation, evaluation, and selection process. Step 7 takes into consideration any on- or off-site critical resources, such as a regional aquifer or energy supply, in development of the process options and identifies technologies that are inherently more green and sustainable.

Step 8 addresses how to incorporate consideration of green and sustainable practices in the existing regulatory framework for configuration, screening, evaluation and comparison of remedial alternatives, both through incorporation of BMPs and through use of stand-alone sustainability evaluation tools. These tools are summarized in Section 2, with more information in Appendix A. The remedy evaluation process culminates in selection of the preferred remedy in a decision document (Step 9), which provides an opportunity for regulatory and community preference for green and sustainable practices to be offered and considered.

Remedial design (Step 10) and construction (Step 11) present many opportunities to encourage a more green and sustainable remedy, whether through independent design review, BMPs, or adoption of LEED-like building standards as guidelines. Benefits of incorporation of green and sustainable practices are documented in the remedial action report (Step 12).

Steps 13 through 17 address ways of including green and sustainable practices during the operation and maintenance (O&M) phase of a project, through optimization studies or remedial system evaluations. The tools that can be used are summarized in Section 2, with more detail in Appendix A. These tools include ones that quantify different environmental metrics for optimization options, such as greenhouse gas emissions and energy use, and qualitative ones that identify BMPs. Regardless of the structure and tools through which the operations are evaluated for more green and sustainable practices, it is recommended that a schedule for such evaluations be developed and followed. This process is consistent with guidance for identifying opportunities for optimization during periodic reviews of operating remedies.

The final step in the life cycle of a project is achieved when remedial goals have been met and the site can be closed (Step 18). This step emphasizes practices that involve responsible deconstruction and minimization of waste, low impact development approaches, reuse of equipment, beneficial site reuse, and conservation of resources during site restoration.

4. Path Forward

This decision framework captures a snapshot in time of the current practice of incorporating green and sustainable practices into environmental remediation. Considerable incorporation has already occurred (see case study summary from SURF (2009) in Appendix C); it is expected that the number of examples of incorporation of green and sustainable practices into environmental remediation, as well as the tools used for selection of the best green and sustainable practices for any specific project, will continue to grow rapidly. As a follow-up to this framework, the USACE is planning to distribute reports on assessment of the use of the Battelle SiteWise™ and AFCEE SRT tools from the tools’ application on numerous sites.

A training session on both the AFCEE SRT and the Battelle SiteWise™ tools is currently planned for the May 2010 Battelle Remediation of Chlorinated Solvents and Recalcitrant Compound Conference in Monterey, CA. The USACE is also planning training on this decision framework and the Battelle SiteWise™ tool. This training will be offered to USACE districts once the tool development is complete.

We invite you to be part of this process. We welcome your feedback on the decision framework, any examples of incorporation of green and sustainable practices on your sites, your interest in training on the decision framework and/or tools, and your participation in the training that is planned for the future. Please contact Carol Lee Dona of the US Army Corps of Engineers Environmental and Munitions Center of Expertise (EMCX) at carol.l.dona@usace.army.mil with comments, examples, interest, and questions. We will use this information to make any revisions in future versions of this decision framework.

mailto:carol.l.dona@usace.army.mil

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