John Simon, ASTM Task Group Lead, Gnarus Advisors LLC Carlos Pachon, EPA HQ Superfund

1. ASTM Standard Guide for Greener Cleanups E2893 John Simon, ASTM Task Group Lead, Gnarus Advisors LLC Carlos Pachon, EPA HQ Superfund Deb Goldblum, EPA Region 3 RCRA

2. 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. Source: www.clu-in.org/market

3. Challenge: To Lower the Environmental Footprint of Cleanup Projects Greener Cleanups* The practice of considering all environmental effects of remedy implementation and incorporating options to minimize the environmental footprints of cleanup actions. *as defined by US EPA, aka Green Remediation

4. Core Elements for Greener Cleanups “Minimize, Reuse, and Recycle…” “Reduction, Efficiency, and Renewables…” “Conserve, Protect, and Restore…” “Protect Air Quality, Reduce Greenhouse Gases…” “Improve Quality, Decrease Quantity of Use…”

6. 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

7. 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.

8. 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.

9. ASTM Framework for Greener Cleanup • 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

10. 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

11. 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 • Site Assessment • Remedy Selection • Remedy Design and Implementation • Operation, Maintenance and Monitoring • Remedy Optimization

12. Working With Existing Phases BMPs SiteAssessment Quantitative Evaluation RemedySelection Quantitative Evaluation with BMPs BMPs Remedy Design/ Implementation Remedy Modification Quantitative Evaluation with BMPs BMPs Operation, Maintenance and Monitoring Remedy Optimization Remedy Optimization or Modification No Further Cleanup

13. ASTM Greener Cleanups Standard Sections Scope Referenced Documents Terminology Significance and Use Planning and Scoping BMP Process Quantitative Evaluation Documentation and Reporting

14. 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

15. 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

16. 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

17. 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

18. ASTM BMP Table

19. Example Selection from BMP Table

20. BMP Step 2 - Prioritization • Supplement P&T system with plant based extraction • Use variable frequency drives • Operate system in off-peak hours • Install amp meters to evaluate consumption rates • Use gravity flow where feasible • Purchase renewable energy credits • Use on-site generated renewable energy • Use excess steam as an energy source

21. BMP Step 3 - Selection • Supplement P&T system with plant based extraction • Use variable frequency drives • Operate system in off-peak hours • Install amp meters to evaluate consumption rates • Use gravity flow where feasible • Purchase renewable energy credits • Use on-site generated renewable energy

22. BMP Step 4 - Implementation • Supplement P&T system with plant based extraction • Development changed and area is now paved eliminating space for plants • Use variable frequency drives • Operate system in off-peak hours • Install amp meters to evaluate consumption rates • Use gravity flow where feasible

23. 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

24. 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

25. 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)

26. Interpreting Results: Targeting Areas for Footprint Reduction As en example: We’ll focus our optimization efforts on particulate matter emissions. Baseline Footprint Key contributor is diesel fuel combustion during truck transport of waste off-site Optimization #1 → no idling during loading Optimization #2 → no idling during loading → use particulate filters

27. Interpreting Results: Targeting Areas for Footprint Reduction continued 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

28. Section 8: Documentation and Reporting Step 1: Document for each phase • BMP 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

29. 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

30. Section 8: Public Availability ASTM will post on website. Contact Kate McClung at: kmcclung@astm.org • Public repository • Post on a website • Submit to a regulatory agency, with prior agency consent

31. Section 8: Timing for Reporting • Based on: • Needs of the user • Requirements or agreements with a regulatory program • Commitments through contractual agreements or with stakeholders • Recommends results be reported after implementation of cleanup activities

32. 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

33. 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.”

34. 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

35. 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)

36. Access to the Standard Guide Individuals Go to: http://www.astm.org/Standards/E2893.htm Subscriptions E-mail: service@astm.org 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

37. 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 • jsimon@gnarusllc.com • Carlos Pachon, EPA HQ Superfund • pachon.carlos@epa.gov • Deb Goldblum, EPA Region 3 RCRA • goldblum.deborah@epa.gov