John Simon, ASTM Task Group Lead, Gnarus Advisors LLC
Carlos Pachon, EPA HQ Superfund
Deb Goldblum, EPA Region 3 RCRA
ASTM Standard Guide for Greener Cleanups E2893
Source: www.clu-in.org/market Source: www.clu-in.org/market
US Contaminated Site Programs: We Still Have a Lot of Remediation Work to Do
♦ We have made great progress cleaning up contaminated sites…
♦ Going forward we will invest significant resources cleaning up contaminated sites in all programs
» Superfund» RCRA Corrective Action» Underground Storage Tanks» Brownfields» Federal Facilities
♦ We have an opportunity to take lessons learned over the past decades, and apply the innovations and best management practices to future sites.
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Challenge: To Lower the Environmental Footprint of Cleanup Projects
*as defined by US EPA, aka Green Remediation
The practice of considering all
environmental effects of remedy
implementation and incorporating
options to minimize the environmental
footprints of cleanup actions.
Greener Cleanups*
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“Reduction, Efficiency, and Renewables…”
“Protect Air Quality, Reduce Greenhouse
Gases…”
“Minimize, Reuse, and Recycle…”
“Conserve, Protect,
and Restore…”
“Improve Quality, Decrease Quantity of Use…”
Core Elements for Greener Cleanups
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Why A Standard?
Codify best practices Define a process for reducing environmental
footprint Provide a protocol for contracting purposes Provides “brand recognition” for greener
cleanups Results in a transparent documented process
that is reported publicly
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ASTM Guide Origins In 2008, the EPA recognized a lack of guidance on how to
implement green remediation.
Consistent with Federal requirements the Agency researched the option of using voluntary standard development organizations.
ASTM International, Inc. responded and agreed to initiate the development a Standard, which evolved to a Standard Guide.
ASTM established a task group, comprised of professionals from consulting firms, regulatory agencies, law firms, and industry, and initiated the standard writing process in October 2009.
Over the next 4 years the Task Group wrote the standard and took it through ASTM’s consensus-based approval process.
In November 2013, ASTM published ASTM E2893-13 Standard Guide for Greener Cleanups.
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Important Notice
The ASTM Standard Guide for Greener Cleanup does not affect or supersede existing regulations and guidance issued pursuant to federal cleanup statutes, including for example, the CERCLA remedy selection process provided for in the National Contingency Plan (40 CFR part 300) and associated EPA Superfund guidance.
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Greener Cleanup is a Process, not a Technology Greener cleanup principles should be
integrated into cleanup projects Applied on a phase-by-phase basis Is not just about remedy selection
and green technologies “Only is green if it works”
Focus on how to incorporate BMPs into projects
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The Basics
Provides a step-by-step approach Flexible, with qualitative and quantitative
options Includes reporting expectations Documentation must be publicly available
(inhibits “green washing”) Environmental professional must lead the
team and sign attestation that the standard was followed
Designed to be the industry standard; particularly if adopted by regulatory agencies
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ASTM Standard Guide Overview
Fundamental core is selecting BMPs Flexible evaluation process Qualitative evaluation (BMP selection) Quantitative evaluation (numerical) Standard is applied on a phase-by-phase basis
1. Site Assessment2. Remedy Selection3. Remedy Design and Implementation4. Operation, Maintenance and Monitoring5. Remedy Optimization
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Remedy Selection
Site Assessment
Remedy Design/ Implementation
No Further Cleanup
Operation, Maintenance and
Monitoring
BMPs
Quantitative Evaluation
Re
me
dy
Mo
dific
atio
nR
em
ed
y O
pti
miz
ati
on
Quantitative Evaluation with BMPs
Quantitative Evaluation with BMPs
BMPs
Remedy Optimization or
Modification
BMPs
Working With Existing Phases
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ASTM Greener Cleanups Standard Sections
1. Scope
2. Referenced Documents
3. Terminology
4. Significance and Use
5. Planning and Scoping
6. BMP Process
7. Quantitative Evaluation
8. Documentation and Reporting
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Standard Management Practices are not Best Management Practices Standard Management Practice (not included because routine)
Considered industry standards and are truly basic in nature Recycling office waste Using compact fluorescent light bulbs Minimizing paper use with electronic filing systems
Best Management Practice Activity that reduces the environmental footprint of a remedy ASTM developed a comprehensive list BMPs
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Best Management Practices
BMPs drive environmental footprint reduction
BMPs are organized on a technology or activity basis, but are applied based on the phase of the project
BMPs assigned to EPA’s five core elements
Energy
Air Emissions
Water Impacts
Material and Waste
Land and Ecosystem
ASTM considered establishing a “bar” for the minimum number of BMPs that need to be incorporated into a project in order for it to be considered Green; realized this was arbitrary, not defensible and partial to larger projects
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BMP Process“Five Steps to Greening Cleanups”
1. Opportunity Assessment Review master list of BMPs and retains those that warrant further consideration. Consider BMPs not on the master list Should be a pretty straightforward exercise
2. BMP Prioritization Identify BMPs with the greatest potential for reducing the environmental footprint and
prepare prioritized list
3. BMP Selection Unless a compelling reason to do otherwise, select each BMP from Step 2 for
implementation What is a “compelling reason to do otherwise”? Substantive issues associated with applicability, implementation, impracticability and
cost
4. BMP Implementation Document BMPs that can not be implemented and why
5. BMP Documentation and Reporting Record BMPs implemented If BMPs from Steps 3 & 4 were not implemented, explain why
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BMP - Step 1 Opportunity AssessmentGreener Cleanup BMP Table
Task Group painstakingly compiled table with over 160 BMPs
ASTM intends to provide the table in Excel format as an “Adjunct”
Arranged by category, core element and technology 10 Categories (e.g., power & fuel, materials, vehicles…) 5 Core elements 11 Technologies (e.g., SVE, P&T, excavation…)
User strongly encouraged to add BMPs to the table User can sort the Excel table by technology, core
element or category
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ASTM BMP Table
Example Selection from BMP Table
BMP Step 2 - Prioritization
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BMP Step 3 - Selection
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BMP Step 4 - Implementation
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BMP Step 5 - Documentation
Include tables generated in Steps 1 through 4 Follow requirements in Section 8 and the
example Technical Summary Form outline in Appendix X2
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Section 7: Quantitative Evaluation Overview
Most applicable to large and complex site Types of quantitative evaluation
Footprint Analysis Life Cycle Assessment
Seven step process Uses for quantitative evaluation
Opportunity Evaluation Technology Evaluation Metrics for BMPs
Section 7: Quantitative Evaluation Approach
Define the scope of the assessment and system boundaries Collect and organize input information for analysis Run calculations, for example using EPA’s SEFA* or other tool Conduct a sensitivity analysis, identify target footprint elements Use quantitative evaluation findings to select BMPs (Section 6)
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Interpreting Results: Targeting Areas for Footprint ReductionInterpreting Results: Targeting Areas for Footprint Reduction
Baseline Footprint
Key contributor is diesel fuel combustion during
truck transport of waste off-site
Optimization #1
→ no idling during loading
As en example: We’ll focus our optimization efforts on particulate matter emissions.
Optimization #2
→ no idling during loading→ use particulate filters
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Baseline
→ air stripping with GAC→ discharge to POTW
Optimization #1
→ enhance air stripping→ eliminate GAC
Optimization #2
→ all the above (Opt #1)→ discharge to surface water
Optimization #3
→ all the above (Opt #2)→ install renewable energy
continued
Interpreting Results: Targeting Areas for Footprint ReductionInterpreting Results: Targeting Areas for Footprint Reduction
Section 8: Documentation and Reporting
Step 1: Document for each phaseBMP Summary Tables
List applicable BMPs, prioritized by anticipated environmental benefit
Identify those implemented Include rationale for those not implemented Identify BMPs required by law or regulation
Quantitative Evaluation Report, if applied
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Section 8: Documentation and Reporting
Step 2: Make publicly available Technical Summary (Appendix X2 form)
General Information Environmental Footprint Reductions
BMP Summary Tables and Quantitative Evaluation Report, if applicable (for each phase)Self-Declaration
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Section 8: Public Availability
Public repository Post on a website Submit to a regulatory agency, with prior agency
consent
ASTM will post on website. Contact Kate McClung at:
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Section 8: Timing for Reporting
Based on: Needs of the user Requirements or agreements with a regulatory
program Commitments through contractual agreements
or with stakeholdersRecommends results be reported after
implementation of cleanup activities
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Summary of Key Attributes
Voluntary: Not mandating new cleanup evaluation Flexible: Guide vs. Practice Universal: Program neutrality facilitates implementation Transparent: Public availability of decisions & outcomes Tool: Appendix X3 BMP Table ASTM: Provides brand recognition
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EPA Memo of EncouragementAssistant Administrator OSWER
“[I]n the Agency’s pursuit of a cleaner, safer environment, I recommend that the regions and OSWER programs facilitate and encourage use of ASTM’s Standard Guide for Greener Cleanups in your efforts to implement greener cleanup practices.”
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EPA Regions: Facilitate and Encourage Regions 3 and 6’s Superfund programs are piloting
the BMP Table at select fund-lead sites Region 5 is pursuing insertion of language in its
regional terms and conditions for Brownfield grants stating that grantees will use the ASTM Standard guide for Greener Cleanups to the extent possible
Region 9 is planning to use the Standard Guide during implementation of their updated Greener Cleanup Policy
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States: Facilitate and Encourage Illinois references the Standard Guide on their VCP website Massachusetts is incorporating Greener Cleanup goals (i.e.
evaluation of core elements) into its regulations and referencing the Standard Guide in policy, as way to achieve regulatory requirement
Minnesota will update their Green and Sustainable Remediation Guidance with reference to the Standard Guide in the near future and is piloting the BMP Table in its Green and Sustainable Remediation Evaluation Project
Wisconsin plans to include the standard as a resource for complying with State Cleanup rules (NR 722.09)
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Access to the Standard Guide
Individuals Go to: http://www.astm.org/Standards/E2893.htm
Subscriptions E-mail: [email protected]
EPA Go to: http://portal.astm.org/CUSTOMERS/filtrexx40.cgi?index.frm Type: E2893
States Unique to each State; some have a subscription to ASTM products
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Helpful Links
CLU-IN (technical resources):
www.clu-in.org/greenremediation
EPA Greener Cleanup Standard Initiative:
www.epa.gov/oswer/greenercleanups/standard.html
John Simon, ASTM Task Group Lead, Gnarus Advisors LLC [email protected]
Carlos Pachon, EPA HQ Superfund [email protected]
Deb Goldblum, EPA Region 3 RCRA [email protected]
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