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

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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. US Contaminated Site Programs: We Still Have a Lot of Remediation Work to Do. - PowerPoint PPT Presentation
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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
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Page 1: John Simon, ASTM Task Group Lead, Gnarus Advisors LLC Carlos Pachon, EPA HQ Superfund

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

Page 2: John Simon, ASTM Task Group Lead, Gnarus Advisors LLC Carlos Pachon, EPA HQ Superfund

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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Page 3: John Simon, ASTM Task Group Lead, Gnarus Advisors LLC Carlos Pachon, EPA HQ Superfund

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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Page 4: John Simon, ASTM Task Group Lead, Gnarus Advisors LLC Carlos Pachon, EPA HQ Superfund

“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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Page 5: John Simon, ASTM Task Group Lead, Gnarus Advisors LLC Carlos Pachon, EPA HQ Superfund

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Page 6: John Simon, ASTM Task Group Lead, Gnarus Advisors LLC Carlos Pachon, EPA HQ Superfund

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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Page 7: John Simon, ASTM Task Group Lead, Gnarus Advisors LLC Carlos Pachon, EPA HQ Superfund

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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Page 8: John Simon, ASTM Task Group Lead, Gnarus Advisors LLC Carlos Pachon, EPA HQ Superfund

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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Page 9: John Simon, ASTM Task Group Lead, Gnarus Advisors LLC Carlos Pachon, EPA HQ Superfund

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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Page 10: John Simon, ASTM Task Group Lead, Gnarus Advisors LLC Carlos Pachon, EPA HQ Superfund

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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Page 11: John Simon, ASTM Task Group Lead, Gnarus Advisors LLC Carlos Pachon, EPA HQ Superfund

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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Page 12: John Simon, ASTM Task Group Lead, Gnarus Advisors LLC Carlos Pachon, EPA HQ Superfund

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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Page 13: John Simon, ASTM Task Group Lead, Gnarus Advisors LLC Carlos Pachon, EPA HQ Superfund

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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Page 14: John Simon, ASTM Task Group Lead, Gnarus Advisors LLC Carlos Pachon, EPA HQ Superfund

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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Page 15: John Simon, ASTM Task Group Lead, Gnarus Advisors LLC Carlos Pachon, EPA HQ Superfund

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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Page 16: John Simon, ASTM Task Group Lead, Gnarus Advisors LLC Carlos Pachon, EPA HQ Superfund

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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Page 17: John Simon, ASTM Task Group Lead, Gnarus Advisors LLC Carlos Pachon, EPA HQ Superfund

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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Page 18: John Simon, ASTM Task Group Lead, Gnarus Advisors LLC Carlos Pachon, EPA HQ Superfund

ASTM BMP Table

Page 19: John Simon, ASTM Task Group Lead, Gnarus Advisors LLC Carlos Pachon, EPA HQ Superfund

Example Selection from BMP Table

Page 20: John Simon, ASTM Task Group Lead, Gnarus Advisors LLC Carlos Pachon, EPA HQ Superfund

BMP Step 2 - Prioritization

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Page 21: John Simon, ASTM Task Group Lead, Gnarus Advisors LLC Carlos Pachon, EPA HQ Superfund

BMP Step 3 - Selection

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Page 22: John Simon, ASTM Task Group Lead, Gnarus Advisors LLC Carlos Pachon, EPA HQ Superfund

BMP Step 4 - Implementation

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Page 23: John Simon, ASTM Task Group Lead, Gnarus Advisors LLC Carlos Pachon, EPA HQ Superfund

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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Page 24: John Simon, ASTM Task Group Lead, Gnarus Advisors LLC Carlos Pachon, EPA HQ Superfund

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

Page 25: John Simon, ASTM Task Group Lead, Gnarus Advisors LLC Carlos Pachon, EPA HQ Superfund

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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Page 26: John Simon, ASTM Task Group Lead, Gnarus Advisors LLC Carlos Pachon, EPA HQ Superfund

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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Page 27: John Simon, ASTM Task Group Lead, Gnarus Advisors LLC Carlos Pachon, EPA HQ Superfund

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

Page 28: John Simon, ASTM Task Group Lead, Gnarus Advisors LLC Carlos Pachon, EPA HQ Superfund

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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Page 29: John Simon, ASTM Task Group Lead, Gnarus Advisors LLC Carlos Pachon, EPA HQ Superfund

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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Page 30: John Simon, ASTM Task Group Lead, Gnarus Advisors LLC Carlos Pachon, EPA HQ Superfund

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:

[email protected]

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Page 31: John Simon, ASTM Task Group Lead, Gnarus Advisors LLC Carlos Pachon, EPA HQ Superfund

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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Page 32: John Simon, ASTM Task Group Lead, Gnarus Advisors LLC Carlos Pachon, EPA HQ Superfund

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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Page 33: John Simon, ASTM Task Group Lead, Gnarus Advisors LLC Carlos Pachon, EPA HQ Superfund

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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Page 34: John Simon, ASTM Task Group Lead, Gnarus Advisors LLC Carlos Pachon, EPA HQ Superfund

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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Page 35: John Simon, ASTM Task Group Lead, Gnarus Advisors LLC Carlos Pachon, EPA HQ Superfund

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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Page 36: John Simon, ASTM Task Group Lead, Gnarus Advisors LLC Carlos Pachon, EPA HQ Superfund

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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Page 37: John Simon, ASTM Task Group Lead, Gnarus Advisors LLC Carlos Pachon, EPA HQ Superfund

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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