PUBLIC REVIEW VERSION
Superfund Green Remediation Strategy
August 2009
       \     U.S. Environmental Protection Agency
  \ ^         Office of Solid Waste and Emergency Response
   \,tp o^/     Office of Superfund Remediation and Technology Innovation

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Acknowledgments
This Strategy was prepared by the Superfund Green Remediation Workgroup under the
direction of James Woolford, Director of the Office of Superfund Remediation and Technology
Innovation. The Workgroup is chaired by Branch Chiefs Dan Powell and Suzanne Wells, Office
of Superfund Remediation and Technology Innovation, and includes:
Michael Adam, Office of Superfund Remediation and Technology Innovation
Robin Anderson, Office of Superfund Remediation and Technology Innovation
Sairam Appaji, Region 6
Harold Ball, Region 9
Brad Bradley, Region 5
Steve Chang, Office of Superfund Remediation and Technology Innovation
Harry Compton, Office of Superfund Remediation and Technology Innovation
Chris Corbett, Region 3
Jeff Dhont, Region 9
Nicoletta Diforte, Region 2
Art Flaks, Office of Superfund Remediation and Technology Innovation
Elisabeth Freed, Office of Site Remediation Enforcement
Amanda Gallagher, Region 2
Michael Gill, Region 9
Anne Marie Hoffman, Federal Facilities Restoration and Reuse Office
Jennifer Hovis, Office of Superfund Remediation and Technology Innovation
Steven Krauser, Region 2
Ginny Lombardo, Region 1
Jill Lowe, Region 3
Shahid Mahmud, Office of Superfund Remediation and Technology Innovation
Barbara McDonough, Office of Superfund Remediation and Technology Innovation
Nat Miullo, Region 8
Matthew Monsees,  Region 4
Charles Openchowski, Office of General Counsel
Carlos Pachon, Office of Superfund Remediation and Technology Innovation
John Peterson, Region 5
John Podgurski, Region 1
Joseph Rauscher, Office of Superfund Remediation and Technology Innovation
Tim Rehder, Region 8
Fernando Rosado,  Region 2
William Ross, Office of Superfund Remediation and Technology  Innovation
Charles Sands, Office of Superfund Remediation and Technology Innovation
Julie Santiago-Ocasio, Region 4
Sean Sheldrake, Region 10
Craig Smith, Region 7
Larry Zaragoza, Office of Superfund Remediation and Technology Innovation

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Disclaimer
This document contains information designed to be useful and helpful to governments, the
public, and the regulated community. This document does not impose legally binding
requirements, nor does it confer legal rights, impose legal obligations, or implement any
statutory or regulatory provisions. This document does not change or substitute for any statutory
or regulatory provisions. This document presents technical information based on EPA's current
understanding of the link between hazardous waste site cleanup activities and potential risks to
human health and the environment. Finally, this is a living document that may be revised
periodically without public notice. EPA welcomes public comments on this document at any time
and will consider those comments in any future revisions of this document.

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Table of Contents
Executive Summary                                                               i

1.0  Introduction                                                                 1
     1.1      Background                                                          1
     1.2      Green Remediation and Superfund                                       2
     1.3      Green Remediation and Other Waste Programs                            3
     1.4      Incorporating Green Remediation into Site Sustainability                     4
     1.5      Federal and State Statutes and Executive Orders Promoting Energy          4
             and Water Conservation

2.0  Superfund Remedial Program's Green Remediation Goals and Key Action Items   5
     2.1      Policy and Guidance Development                                       7
     2.2      Resource Development and Program Implementation                       8
     2.3      Program Evaluation                                                   15

3.0  Implementation of the Superfund Green Remediation Strategy                   18

Appendix A:   Abbreviations and Acronyms                                           19
Appendix B:   References                                                          20
Office of Superfund Remediation and Technology Innovation
U.S. Environmental Protection Agency

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Executive Summary
As part of its mission to protect human health and the environment, the U.S. Environmental
Protection Agency (EPA, or "the Agency") and its partners manage and implement the Superfund
Remedial Program ("the Program"), which is dedicated to the cleanup of the nation's
uncontrolled hazardous waste sites. Since its inception in 1980, the Program (which includes the
Office of Superfund Remediation and Technology Innovation (OSRTI), the Federal Facilities
Restoration and Reuse Office (FFRRO), the Federal Facilities Enforcement Office (FFEO), the
Office of Site Remediation Enforcement (OSRE), the Office of Emergency Management (OEM),
and EPA regional Superfund offices) has made considerable progress toward cleaning up
hazardous waste sites and responding to emergencies involving hazardous substances. Site
remediation involves a wide variety of approaches and technologies to address contamination in
soil, ground water, surface water, and sediment. This Superfund Green Remediation Strategy
("the Strategy") sets out current plans of the Superfund Remedial Program to reduce greenhouse
gas (GHG) emissions and other negative environmental impacts that might occur during
remediation of a hazardous waste site or non-time critical removal actions.

Today, we recognize that the activities associated with
investigation and remediation of hazardous  waste sites      Green remediation is the
may be sources of GHGs, diesel emissions, air pollutants,   practice of considering all
and other emissions. For example, treatment remedies,     environmental effects of remedy
such as pump and treatment systems for contaminated      implementation and
ground water, may use energy from fossil fuel powered      incorporating options to
utilities for many years. Similarly, heavy-duty equipment     minimize the environmental
used during site remediation is usually powered by diesel    footprints of cleanup actions.
fuel, which typically emits a complex mixture of air
pollutants. At many sites, we are recognizing that much
can be done to reduce the energy use and improve  the environmental performance of Superfund
activities, while at the same time fulfilling our mission to protect human health and the
environment.

In September 2008, OSRTI formed a workgroup of headquarters  and  regional staff to develop a
green remediation strategy. This current version of the Strategy is the culmination of workgroup
discussions regarding ways that the Superfund Remedial Program may reduce the
environmental "footprint" of response actions taken at private and federal sites, while at the same
time protecting human health and the environment. This Strategy is not intended to be a
comprehensive document; rather, we expect it will change over time as we learn more about how
we can improve our cleanup activities and receive input from others.

This current version of the Strategy outlines ten key action items and recommends related
activities to promote green remediation. Action items fall into three overarching categories:

  • Policy and guidance development;
  • Resource development and program implementation; and

  • Program evaluation.
Office of Superfund Remediation and Technology Innovation
U.S. Environmental Protection Agency

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Recommended Key Actions
Key Action Description
Policy and Guidance Development
Key Action #1
Clarify the role of green remediation in remedy selection and
implementation
Resource Development and Program Implementation
Key Action #2
Key Action #3
Key Action #4
Key Action #5
Key Action #6
Key Action #7
Develop a compendium of protocols and tools to help project and
Program managers integrate green remediation practices
Identify options that enable use of green remediation practices
Address air pollutants and diesel emissions
Develop pilot projects to evaluate and demonstrate green
remediation applications
Establish opportunities in contracts and assistance agreements to
identify green remediation practices in selected remedies
Communicate and share success stories and lessons learned
among "implementers" across the Program and the public
Program Evaluation
Key Action #8
Key Action #9
Key Action #10
Evaluate green remediation application at the site level
Develop Program evaluation measures
Evaluate the Superfund Green Remediation Strategy
Office of Superfund Remediation and Technology Innovation
U.S. Environmental Protection Agency

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In developing these action items, the workgroup highlighted several needs that are important for
their implementation:

  • Clarify how green remediation practices fit within the Comprehensive Environmental
   Response, Compensation, and Liability Act (CERCLA) and the National Oil and Hazardous
   Substances Pollution Contingency Plan (NCP);

  • Improve our understanding of potential resource and energy demands for many Superfund
   remedies; and

  • Develop a consensus on metrics that can be used to measure and evaluate green
   remediation actions.

This  Strategy contains recommendations to develop white papers that clarify major issues such
as the extent to which OSRTI, FFRRO, FFEO, OSRE, and Superfund regional programs can
incorporate green remediation practices under existing laws and regulations. The Strategy also
includes a recommendation to pursue follow-on directives that help foster greater use of green
remediation practices at Fund-lead (i.e., sites where cleanup is funded by the Agency and led by
EPA), state-lead, potentially responsible party (PRP)-lead, and federal facility sites.

The Strategy recommends a series of initiatives that may be implemented in the near term to
expedite consideration and use of green remediation practices:
  • Launching a pilot  project to test incorporating green remediation considerations into remedy
   optimization evaluations by fiscal year 2010;

  • Considering ways to reduce the  use of natural resources and energy during remedial actions
   and when developing cleanup alternatives;

  • Integrating clean,  renewable, and innovative energy sources and advanced diesel
   technologies (such as diesel particulate filters and alternative fuels) and encouraging
   operational practices (such as engine idle reduction practices) to minimize total emissions;

  • Including language in statements of work for Fund-lead remedial and removal action and
   PRP-lead remedial design and remedial action contracts that specifies use of green
   remediation practices and requires separate reports for energy/fuel usage and costs; and
  • Helping communities establish networks and training programs that enable local workers
   (including minority and low-income populations) to gain proficiency in expertise needed for
   green cleanups, such as energy efficiency auditing and renewable energy applications.

Finally, the Strategy includes  the recommendation to establish a process for quantifying
achievements regarding the Program's commitment to reduce the demands that site cleanups
place on the environment. Regional  summaries, site-specific data, and trend information can be
collected and used to establish a solid baseline on the environmental demands made prior to
Strategy implementation. Using this  baseline, the Program could aim toward specific targets
such as reducing energy consumption by 20%, increasing use of alternative fuels/renewable
energy by  15%, and reducing diesel equipment emission of particulate matter by 10% by 2015,
to the extent consistent with selecting responses under the NCP.

As a "living" document, OSRTI will update this Strategy to reflect refined Agency policy, modified
activities within the key actions, and other developments as green remediation matures. EPA is
seeking input from Superfund "stakeholders" (including affected communities, state and local
governments, tribal governments, other federal agencies, cleanup contractors, PRPs, and
developers). The Agency will  conduct specific outreach activities to solicit and promote input on
further refining this Strategy and focusing this effort. The Strategy's next version will include
aspects specific to the Agency's Emergency Response/Removal  Program.

Office of Superfund Remediation  and Technology Innovation                                      ill
U.S. Environmental Protection Agency

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1.0   Introduction
The EPA Superfund remedial offices managing the long-term cleanup of Superfund sites are
dedicated to the broader goal of the Agency's mission to protect human health and the
environment. These offices strive to clean up hazardous waste sites in ways that use natural
resources and energy efficiently and reduce negative impacts on human health and the
environment in accordance with existing authorities. This Superfund Green Remediation Strategy
sets out the Program's current plans to respond to the need to reduce GHG and other air
emissions and minimize other negative impacts on  the environment and surrounding community
that might occur during  remediation of a hazardous waste site, while continuing to protect human
health and the environment.


1.1    Background
Site cleanup is inherently green; however, cleanup  activities use energy, water, and materials
resources to achieve cleanup objectives. The process of cleanup therefore creates an
environmental "footprint" of its own. For purposes of this Strategy, EPA defines green
remediation as the practice of considering all environmental effects of remedy implementation
and incorporating options to minimize the environmental footprints of cleanup  actions.1

Green remediation is intended to reduce the demand placed on the environment during cleanup
actions and to conserve natural resources.  Each stage of the remedial process (discovery,
assessment, characterization, design and construction activities, operation of treatment and
containment remedies,  monitoring and  maintenance of remedies, etc.) produces  an
environmental footprint. Combined, the footprint can be significant when considering the nearly
10,000 sites yet to reach a final assessment decision along with  the approximately 1,600 final
and deleted sites on the National Priorities List (NPL). The impacts to the environment and  to
communities from cleanup activities, including fossil fuel consumption, emission of GHG and air
pollutants, disruption to water cycle balances, and soil erosion, need to be considered.

Opportunities to reduce environmental footprints at contaminated sites exist beyond cleanup
activities. When green remediation techniques are linked to  careful site reuse  planning and
sustainable development practices, such as applying smart growth principles and green building
methods, additional opportunities are often  created to reduce the environmental footprint of both
remediation and reuse projects. The combined planning and practices provide a basis for a
greener approach to land revitalization  and  help ensure that all socioeconomic groups of affected
communities can benefit from the improved environmental outcome of site cleanup.

Green remediation generally is recognized as a major step in improving the sustainability of
contaminated land cleanup.2 EPA's Office of Solid Waste and Emergency Response (OSWER)
identified five core elements of green remediation:
   •   Energy: Many Superfund cleanups  involve energy intensive technologies. Green
       approaches focus on opportunities to improve energy efficiency and use renewable
       energy sources.
1 Extensive background information is provided in EPA's technology primer, Incorporating Sustainable Environmental
Practices into Remediation of Contaminates Sites (USEPA, 2008c).
2 In accordance with Executive Order 13423, sustainability is defined as the capacity 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.

Office of Superfund Remediation and Technology Innovation                                       1
U.S. Environmental Protection Agency

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   .   Air: Many Superfund cleanups involve onsite and offsite emissions of GHGs and air
       pollutants from activities such as treatment processes, operation of heavy machinery, and
       transportation of routine vehicles and cargo trucks. These emissions can be reduced by
       applying the most appropriate advanced technologies and practices.
   •   Water: Superfund cleanups may also involve consumption of significant amounts of
       water for treatment processes and typically require management of surface water. Green
       approaches focus on reducing water consumption, reusing treated water, and using
       efficient techniques to manage and protect surface water and ground water.
   •   Land and ecosystems: Superfund sites often involve degraded onsite and offsite
       ecosystems and may have conditions that make the site unsafe for human or other use.
       Green remediation strategies focus on remedial actions that minimize further harm to the
       area, protect land resources and ecosystems at or near the site, and foster the return of
       sites to ecological, economic, social, or other uses.
   •   Materials and waste: Site remediation generally uses          Materials
       significant amounts of raw materials and sometimes            & Waste
       generates its own hazardous and non-hazardous wastes,
       including materials and debris that often are shipped
       offsite. Green strategies offer opportunities to reduce         Land&  Elements   ^
       material consumption and waste generation, use recycled   Ecosystems
       and indigenous materials and spent products, and
       purchase environmentally preferred products.


1.2    Green Remediation and Superfund

Green remediation aligns with goals and processes outlined in CERCLA (P.L. 96-510, 1980) as
well as the NCR (40 CFR 300, Title 40). One of the primary purposes of CERCLA, as amended
by the Superfund Amendments and Reauthorization Act of 1986 and the Small Business Liability
Relief and Brownfields Revitalization Act of 2002, is to protect human health and the
environment from uncontrolled hazardous waste sites. As the basic blueprint for carrying out
Superfund response actions, the NCR describes expectations for response actions and  includes
remedy selection considerations such as "the nine criteria" to evaluate alternatives. Green
remediation strategies as addressed in this document may also be useful in non-time critical
removal actions, including preparation of engineering evaluation/cost analyses (EE/CAs), but
may have less applicability in time critical removals, especially emergency response situations.

Opportunities to decrease the environmental footprint of cleanup activities and maximize a
cleanup project's total environmental benefit exist throughout a project life, extending from site
investigation through development of cleanup  alternatives and remedy design, construction,
operation, and monitoring. A number of EPA regional offices have initiated efforts to apply green
remediation practices during site cleanups.3 These opportunities are enhanced by recent
developments such as advances in cleanup technologies and growing awareness of the links
between site cleanup and revitalization. Concerns  about fluctuations in energy costs and the
growing quantity of GHG emissions have highlighted the need for a smaller environmental
footprint. Given these trends, green remediation strategies offer significant potential for
increasing the total benefit of a cleanup, potentially saving project costs, and returning sites to
productive reuse that is consistent with cleanup goals.
3 For example, see Region 2's "Clean & Green" Policy (USEPA, 2009b) and Region 9's Cleanup-Clean Air Initiative
(USEPA, n.d.1).

Office of Superfund Remediation and Technology Innovation
U.S. Environmental Protection Agency

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Green remediation strategies take precaution to protect areas that surround contaminated sites
and help ensure environmental, human health, and economic benefits to those areas.
Construction and operation activities associated with the cleanup of private and federal
hazardous waste sites are often sources of GHG and other air pollutants. Many treatment
technologies, such as ground water pump and treat systems, use energy from fossil fuel
powered utilities for many years and in some cases decades. Heavy equipment used during site
remediation is usually powered by diesel engines, which emit a complex mixture of air pollutants
including both solid and gaseous materials that have serious human and environmental impacts.
Diesel emissions pose particular concern in non-attainment areas and additional problems in
environmental justice communities that face disproportionate burdens of potential exposure to
environmental hazards. Opportunities to reduce these impacts exist through innovative
approaches, treatment system optimization,  and use of more sustainable practices and
technologies such as renewable energy sources, more efficient treatment equipment, and clean
diesel technologies.

Green remediation also provides a useful perspective for considering other issues,  such as
materials and resources used in the remediation process, potential  impacts on land and water
resources and ecosystems, and ultimate reuse and stewardship of a site. Green remediation
involves understanding and addressing the effects of selected  response actions, from the early
assessment phases through remedy selection and implementation to long-term operation,
maintenance, and project closeout. Green remediation provides a basis for ensuring that
remedies are designed and operated in a manner that not only minimizes negative  impacts on
the environment but also may result in cost savings.

The Agency's 2006-2011 Strategic Plan includes a number of goals and objectives that can be
advanced by green remediation. Goal 5 ("Compliance and Environmental Stewardship") of the
Strategic Plan specifies that stewards of the environment recycle wastes to the greatest extent
possible, minimize or eliminate pollution at its source, conserve natural resources, and use
energy efficiently to prevent harm to the environment or human health (USEPA, 2006). Under
sub-objective 3.2.2  ("Clean Up and Revitalize Contaminated Land"), the Agency commits to
ensuring that substantial  numbers of NPL  sites are ready for site-wide reuse.


1.3    Green Remediation and Other Waste Programs

Promoting clean energy and mitigating climate change are top priorities for EPA. Superfund's
green remediation efforts are intended to intersect a variety of initiatives in other waste programs
across EPA, states, and other federal agencies that are addressing sustainability and climate
change issues. OSWER also is working to maximize community benefits of the various waste
programs,  including site remediation under Superfund.

OSRTI is working with other OSWER cleanup offices to ensure consistency in green remediation
concepts and implementation approaches. This Strategy was developed primarily with the
Superfund Remedial Program in mind, and other Agency cleanup programs are anticipated to
find information and recommendations in the Strategy to be useful.  Other federal and state
cleanup programs also may adopt some of the implementation steps and evaluation activities to
address sustainability and climate change issues. Implementation of the Strategy will involve a
dynamic interchange of ideas, data, and practices within and outside of the Superfund Remedial
Program. The Agency also expects to exchange "lessons learned" with  our partners in cleanup
as efforts evolve over time.
Office of Superfund Remediation and Technology Innovation
U.S. Environmental Protection Agency

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1.4    Incorporating Green Remediation into Site Sustainability

Green remediation strategies help reduce the environmental footprint of cleanup activities.
Greater site sustainability can be achieved by incorporating greener approaches and practices in
all phases of a cleanup and redevelopment project. An integrated approach can include:
   •   Deconstructing a site's buildings and infrastructure and reusing the materials on site;
   •   Designing cleanups such that mixed use and smart-growth land reuse opportunities can
       be maximized;
   •   Employing green building design and construction practices; and
   •   Planning long-term remedy operations and reuse activities that are less environmentally
       intensive and pose minimal adverse impacts (such as diesel emissions and fugitive dust)
       on local communities.

Encouraging an overall "green" view of project life cycles will help ensure that green  remediation
techniques and redevelopment practices are incorporated and become opportunities for meeting
long-term health, environmental, social, and economic goals within a community.


1.5    Federal  and State Statutes and Executive Orders Promoting
       Energy and Water Conservation

Green remediation strategies involve concepts of numerous executive orders and federal or state
statutes and regulations that specifically address reductions in energy and water consumption,
increased use of renewable energy,  and conservation of other natural resources. In particular,
the Energy Policy Act of 2005 promotes energy conservation nationwide. The Energy
Independence and Security Act of 2007 builds on the Energy Policy Act by setting additional
goals for energy consumption and associated GHG emissions, including increased use of
alternative fuels for vehicles and accelerated research and development of alternative energy
resources. Executive Order (EO) 13423, Strengthening Federal Environmental, Energy, and
Transportation Management, builds on these mandates, stating that it is the policy of the United
States that federal agencies conduct their environmental, transportation, and energy-related
activities under the law in support of their respective missions  in an environmentally,
economically, and fiscally sound, integrated, continuously improving, efficient, and sustainable
manner (EO, 2007).

Beyond federal efforts, many states are adopting climate legislation and policies, creating climate
action plans, and providing incentives to create renewable energy projects.4 A majority of states
and the District of Columbia have implemented policies for renewable portfolio standards that
require electricity providers to obtain a minimum percentage of their power from renewable
energy resources by a certain date.
4 See information on state energy policies and incentives in: Database of State Incentives for Renewables & Efficiency
(North Carolina Solar Center/Interstate Renewable Energy Council, n.d.) and U.S. States & Regions (Pew Center on
Global Climate Change, n.d.).

Office of Superfund Remediation and Technology Innovation                                      4
U.S. Environmental Protection Agency

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2.0   Superfund Remedial Program's  Green Remediation
       Goals and Key Action Items
The NCR is the blueprint for Superfund cleanups. It addresses response actions for oil spills as
well as hazardous substances, pollutants, and contaminants. Under CERCLA and the NCR,
remedial response actions may involve a number of steps including site assessment, remedial
investigation, feasibility study, remedy selection, remedy implementation, and a five-year review
for a site where waste is left on site. Employing green remediation practices fits within the
statutory and regulatory framework of the Superfund  Remedial Program.

Green remediation comprises a range of best practices that can be applied throughout the
Superfund cleanup process, beginning with site assessment and investigation and extending
through remedy operations. The practices provide means to improve waste management;
conserve or preserve energy,  fuel, water, and other natural resources; reduce GHG emissions;
promote sustainable long-term stewardship; and reduce adverse impacts on local communities
during and after remediation activities. Green remediation can also complement efforts to return
brownfields and private or federal Superfund sites to  productive use in a sustainable manner,
such as utility-scale production of renewable energy.

Green remediation activities are within the scope of a Superfund response and  can help ensure
a protective remedy. For sites where the remedy has already been selected, it often will be
possible to implement the remedy in a way that is more sustainable and has lesser long-term
negative effects on the environment. At sites with operating remedies, green remediation
practices can be used to upgrade or optimize treatment systems.

Green remediation options should be  evaluated under
CERCLA requirements and relevant NCR provisions  as a       Green remediation  is viewed
means to help ensure protectiveness  of human health and      as a  means to  enhance
the environment. Since the enactment of CERCLA and         remedy protectiveness, not as
promulgation of the NCR, EPA has undertaken various          a disincentive to active
initiatives that may provide a platform for consideration and     remediation processes or an
implementation of green remediation, such as the Ground      approach that reduces remedy
Water Optimization Initiative5 and the  Superfund               protectiveness.
Redevelopment Initiative (SRI).6

In addition,  the Environmentally Responsible Redevelopment and  Reuse (ER3) Initiative7
encourages developers and property owners to implement sustainable practices during
redevelopment of contaminated sites. The ER3 Initiative complements EPA's efforts to clean up
5 OSWER initiated optimization of Superfund-financed ground water remedies as part of the FY2000-FY2001
Superfund Reforms Strategy (OSWER 9200.0-33; July 7, 2000). Remedy optimization is designed to facilitate
systematic review and modification of remedies to promote continuous improvement and enhance overall remedy and
cost effectiveness (USEPA, n.d.8). In the Superfund Program, optimization evaluations generally use the remediation
system evaluation (RSE) process, a tool developed by the U.S. Army Corps of Engineers. RSEs can be conducted for
Superfund remedies involving one or more technologies used for ground water, soil, and/or sediment treatment
[USEPA, n.d.2).
 The SRI Initiative helps communities return some of the nation's worst hazardous waste sites to safe and productive
uses. In addition to cleaning up Superfund sites and making them protective of human health and the environment,
EPA is working with communities and other partners by considering reasonably anticipated future land use in the
cleanup process. The Agency also is working with PRPs and communities at sites that have already been cleaned up
to ensure that long-term stewardship of cleanups will support anticipated reuse (USEPA, n.d.7).
7 EPA's ER3 Initiative uses enforcement incentives to encourage developers, property owners, and other parties to
implement sustainable practices during cleanup, redevelopment, and reuse of contaminated sites (USEPA, n.d.3).

Office of Superfund Remediation and Technology Innovation                                       5
U.S. Environmental Protection Agency

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contaminated sites. Through OSRE's partnership with OSRTI, the ER3 Initiative also includes
green remediation as part of its efforts to promote sustainable cleanup of contaminated sites.

In addition to general green remediation steps that parties can take throughout the cleanup life
cycle, such as minimizing travel to and from sites, decision makers can integrate relevant
practices of green remediation into all  phases of the remedial process:
   •   Preliminary Assessment and Site Investigation (PA/SI): Project managers should
       consider more efficient, streamlined approaches that minimize field mobilizations,
       materials and natural resource consumption, and waste generation during a preliminary
       assessment and site investigation.
   •   Remedial Investigation and Feasibility Study (RI/FS): More  intensive site
       characterization activities including sampling can benefit by employing the same
       practices mentioned above. In  addition, when developing options for remedial actions that
       are consistent with remedial action objectives, project managers should consider
       alternatives that include opportunities for reducing the environmental footprint of remedial
       design and construction activities.
   •   Remedial Design (RD): Opportunities to integrate green remediation strategies into a
       remedy can be taken when:
       °   Designing a new remedy, or

       °   Updating an existing remedy to ensure remedy protectiveness, based on new
          information or changes in science and technology.
   •   Remedial Action (RA): The construction  phase as well as the  operational phase of a
       remedial action provides significant opportunities to reduce onsite and offsite footprints of
       a cleanup. Best practices introduced during construction can continue during remedy
       operation; practices include using clean fuels and renewable energy sources for vehicles
       and equipment, substituting diesel trucks with railroads for material and waste transport,
       retrofitting diesel machinery and vehicles for improved emission controls, reusing
       construction and routine operational materials, reclaiming demolition or processing waste,
       and installing  maximum controls for stormwater runoff.
   •   Short- and Long-Term Remedy Operations and Five-Year Reviews: Periodic reviews
       are required at sites where contaminants remaining on site after a  cleanup action do not
       allow for unrestricted use or unlimited exposure. The five-year review serves to ensure
       that the remedy remains protective and offers opportunities for  project managers to
       consider whether green remediation practices can  be integrated into remedy operation
       and maintenance.

EPA considers reasonably anticipated future land use throughout the remedy selection  and
implementation process to help ensure that response actions will remain protective in light of the
anticipated  reuse of remediated sites.  Green remediation strategies can complement anticipated
site reuse involving sustainable activities or property development in accordance with
community-level  smart growth principles and green building practices.  Integrated planning of
cleanup and reuse projects also facilitates sharing of site infrastructure components such as
stormwater controls, waste recycling networks, or small-scale renewable energy systems.

The following sections describe the key actions that have been identified to implement green
remediation practices in the Superfund Remedial Program. At the end  of each action item, the
phrase "under development," "to be initiated," or "already implemented" is included to inform
readers of the progress to date at implementing the action item.
Office of Superfund Remediation and Technology Innovation
U.S. Environmental Protection Agency

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2.1    Policy and Guidance Development

Goal:

Provide policy and guidance to achieve greater consideration and use of green remediation
practices throughout the Superfund remedial cleanup process (consistent with CERCLA and
NCR requirements) that will provide a clear, legally defensible foundation for facilitating green
remediation.

Introduction:

Key actions in this section are intended to integrate green remediation within the Program and
provide an overall context for green remediation to be used to the maximum extent practicable.
As such, a policy statement should be developed to clarify what green remediation is within the
sphere of Superfund remedial activities and how it fits within the various phases of the Program,
and to encourage EPA regions and others to work collaboratively to effectively implement
Superfund cleanups in as sustainable a manner as practicable.

The action items in this section are intended to integrate green remediation concepts into
Superfund response actions that are consistent with the Statute and the implementing
regulations. EPA regions may wish to adapt or tailor the action items and concepts for
incorporation into region-specific policies. As the national framework for green remediation
evolves, these key action items may need to be revised.
 Key Action #1:  Clarify the role of green remediation in remedy selection and
                  implementation
The goals of green remediation are consistent with objectives and processes specified in
CERCLA and the NCP. The NCP provides detailed expectations and criteria to follow in  selecting
and implementing cleanup remedies. This action area describes efforts that would be undertaken
to ensure that green remediation efforts can be effectively considered and integrated into
Superfund response actions, while adhering to NCP requirements and requirements of other
related statutes. The following actions will be taken:
   1.1  Develop a Superfund Remedial Program white paper on green remediation:
        Prepare a white paper to: (a) examine how green remediation may be considered within
        the existing CERCLA and NCP framework for response actions, and (b) evaluate ways
        to integrate green remediation throughout response actions and within technical
        assistance contracts as well as assistance agreements and interagency agreements
        (lAs). [underdevelopment]
   1.2  Develop OSWER policy on green remediation in remedy selection for remedial
        and non-time critical removal  actions: OSRTI is working with FFRRO and other
        OSWER offices (the Office of Brownfields and Land Revitalization, Office of
        Underground Storage Tanks, Office of Resource Conservation and Recovery, and
        Center for Policy Analysis) and other Agency offices to develop a consistent green
        remediation approach. This policy will address how to evaluate green remediation and
        sustainable activity in the context of the Superfund Program. It would likely clarify how
        green remediation can be factored into the nine  evaluation criteria and the evaluation
        criteria for non-time critical removal actions (involving the EE/CA process) within the
        overall remedy selection framework. Any policy  recommendations would address the
        importance of key statutory requirements and NCP provisions, [under development]
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   1.3  Evaluate potentially applicable or relevant and appropriate requirements
        (ARARs): Analyze and summarize existing state and federal regulations and policies
        that may pertain to green remediation (such as state renewable energy portfolio
        standards) to determine their potential to serve as site-specific ARARs under CERCLA.
        This analysis could assist regions in developing and implementing remedies that
        address new ARARs while meeting goals of green remediation. Summary information
        would be distributed to EPA  regions and posted on OSRTI's cross-program "Green
        Remediation" page of the "CLU-IN" Web platform.8 [to be initiated]


2.2    Resource Development and Program Implementation

Goal:

Develop a compendium of green remediation practices and resources to help on-scene
coordinators (OSCs) and remedial project managers (RPMs) ensure that green remediation is
considered throughout the response process and in meeting remedial goals.

Introduction:

Throughout the Superfund cleanup process (including site assessment and characterization,
removal, design, construction, operation and maintenance, monitoring, closeout,  and
revitalization), there are opportunities  to increase the total benefit of a cleanup and contribute to
site sustainability. As cleanup technologies continue to advance and related options evolve,
green remediation strategies may offer significant potential for reducing project costs while
meeting the selected remedy's remedial action objectives. The goal of these key actions is to
research and evaluate existing or evolving green remediation resources such as  technical
information, new technologies, internal and external knowledge, funding, contracts, and grants,
and to develop new tools and resources, as needed.
  Key Action #2:  Develop a compendium of practices and tools to help project
                  and Program managers integrate green remediation practices
The compendium would be designed to facilitate understanding and implementation of green
remediation efforts by consolidating available tools and resources in a central location to be
organized by cleanup phase (i.e., site discovery through post-construction). Quality
assurance/quality control procedures would be established to minimize duplicative/excessive
information, ensure efficiencies, and provide user-friendly navigation.

Updates to the tools and compendium will be developed as needed to reflect evolving cleanup or
auxiliary technologies and new practices. The following are some of the expected actions to be
taken when developing the compendium:
   2.1   Identify green remediation resource needs: Research and evaluate existing green
        remediation tools and frameworks available on CLU-IN as well as materials such as
        checklists, fact sheets, and outlines issued by regional or other program offices, to
        identify resource needs, [under development]
   2.2  Identify additional green remediation information resources: Reach out to
        communities, contractors, technology vendors, states, other EPA workgroups, and non-
        governmental organizations for green remediation evaluations, case studies, fact
 Cross-program technical materials, federal and state policies, and background information are available on the
Green Remediation Web site at: http://CLU-IN.org/greenremediation (USEPA, n.d.4).

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        sheets, etc. Engage and partner with other federal agencies to document and share
        tools and best practices, [under development]
   2.3  Develop a Superfund Remedial Program framework outlining key concepts in
        green remediation: Draft the framework and circulate the product throughout OSRTI,
        OSRE, other OSWER program offices, and the regions for review and comment. After
        revising, share the framework with other Superfund stakeholders for review and
        comment. Finalize this framework to provide a clear, unified overview of the
        components of green remediation, [under development]
   2.4  Develop technology-specific assessment tools and fact sheets: Continue
        developing fact sheets that demonstrate best management practices of green
        remediation.9  Fact sheets will address specific technologies as well as particular
        remedies or crosscutting topics. One example is a fact sheet illustrating site-specific
        application, unique considerations, and  operating procedures associated with green
        remediation practices in pump and treat remedies. Evaluate and provide tools that help
        assess the environmental  footprint of specific technologies. Examples of tool topics
        include conducting  life cycle assessment of remedial actions, information on the use of
        liquid fuels during site operations, and evaluation of energy and water consumption and
        GHG emissions,  [underdevelopment]
   2.5  Develop green remediation "Q&A's": Develop "Questions & Answers" and "Myths
        vs. Facts" summaries to foster better understanding of green remediation. Topics  may
        include the methodologies for evaluating potential remedy implementation strategies
        (as described under Key Action #8) and assessing public health enhancements
        resulting from use of green remediation strategies, [to be initiated]
   2.6  Produce green remediation checklists: Develop checklists for existing Superfund
        processes (PA/SI, RI/FS, and RD/RA) and long-term response actions. Checklists
        would include the Agency's Remedy Update Reform RSEs and five-year reviews, which
        can be used to foster recommendations for green remediation practices that take
        advantage of advances in  science and technology. Headquarters will work with existing
        checklists developed through regional or cross-program initiatives to the extent possible
        (e.g., Region 2's  "Green Site Assessments and Remediation Checklist for the
        Superfund RI/FS," Region 3's green cleanup standards and certification efforts
        (USEPA, 2009c), and the  Engineering Forum's checklist for energy conservation and
        production (USEPA, 2004)) and issue national checklists, [under development]
   2.7  Develop an on-line application and an electronic notebook encompassing the
        compendium for use by  RPMs/OSCs and others to search the latest green
        remediation tools, incentives, and other information: The electronic notebook will
        serve as an automated, quick-reference guide and a resource for in-depth research. It
        will be organized and cross-referenced to help identify green options according to
        cleanup phase, find information on a particular technology's performance, and obtain
        additional assistance, [to be initiated]
   2.8  Establish a green  remediation page on the Agency's Superfund Web site: Add a
        "Superfund & Green Remediation" page to OSRTI's Superfund Web site in order to
        increase awareness about green remediation specific to the Superfund Program, and
        update the page with future products developed under this Strategy.10 [already
        implemented]
 Such as: Green Remediation: Best Management Practices for Excavation and Surface Restoration (USEPA, 2008b).
10 See Superfund & Green Remediation at: http://www.epa.gov/superfund/greenremediation (USEPA, n.d.6).

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   2.9  Deliver or host green remediation training through the Technology Innovation
        and Field Services Division's training infrastructure: Training generally will be co-
        located with other venues such as annual National Association of Remedial Project
        Managers (NARPM) conferences, OSC Readiness training, and North American
        Commission for Environmental Cooperation meetings. Internet seminars on CLU-IN
        also will be  held periodically, [already implemented]
   2.10 Provide site-specific assistance and assistance mechanisms: Headquarters will
        assist regional staff in reviewing green remediation options during the investigation and
        selection process and in optimizing and retrofitting existing systems. This assistance
        includes direct technical support from experts in Agency program offices and groups
        such as the Technical Support Project's Green Remediation Committee. OSWER also
        could collaborate with the Office of Research and Development's National Risk
        Management Research Laboratory (NRMRL) through: (a) NRMRL's Materials
        Management and Remediation Center operating under the Environmental Technology
        Verification Program, and (b) workings of the Superfund technical  liaisons.  Site-specific
        assistance  mechanisms would include OSWER lAs with missions to support green
        remediation, [already implemented]
  Key Action #3:  Identify options that enable use of green remediation practices
The Superfund Remedial Program needs to examine whether additional options are needed to
incorporate green remediation consistent with the NCP. Such options may be designed to
complement activities developed independently by EPA regions, other agencies, states, and
local communities. Potential actions include:

   3.1  Develop a better understanding of the costs or savings associated with use of
        green remediation strategies and practices: Evaluate the costs and savings of
        various green remediation strategies, including greater energy efficiency, by analyzing
        the data available at a sample of green  remediation projects implemented to date. The
        Agency will evaluate and build upon successful internal and external efforts to facilitate
        green remediation. EPA anticipates working with other federal agencies, states, and
        private industry to find independent mechanisms that may include loans or grants,
        expedited permitting processes  used by state or local government agencies, cleanup
        contractor bonuses,  a green cleanup certification system, and/or renewable energy
        certificates (RECs). Findings will be summarized and  made available to the public
        through online CLU-IN seminars and documents posted on OSRTI's green remediation
        Web pages, [under development]
   3.2  Identify opportunities to finance green remediation practices consistent with the
        NCP at Fund-lead sites:  These options may include establishment of headquarters
        and/or regional green remediation funds that can be used to finance green remediation
        activities. The Agency would need to establish the amount of available funding, criteria
        for accessing the fund, and methods for returning any savings to the fund  and/or the
        region. Related lessons and strategies gained at Fund-lead sites may then be applied
        to similar efforts at federal facility, state-lead, and PRP-lead sites, [under development]
   3.3  Analyze issues involved in use of RECs: Options will be examined for purchasing
        RECs at sites without onsite or directly accessible renewable energy sources. Derived
        REC attributes such  as avoided emissions, eligibility for emission reduction credits or
        offsets, and price stability will be integrated into green remediation site-specific and
        program evaluations, [to be initiated]
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   3.4  Explore and/or establish mechanisms to finance green remediation research,
        development, and demonstration (RD&D) and initial deployment at Superfund
        sites: OSRTI and FFRRO should identify existing federal resources (such as U.S.
        Department of Defense, U.S. Department of Energy (DOE), and Small Business
        Innovation Research programs) to support green remediation research and application.
        One sample approach for this action is the Materials Management and Remediation
        pilot project sponsored by the public-private Environmental Technology Verification
        Program.  Finance mechanisms would include use of assistance agreements, lAs, and
        contracts as appropriate (see Key Action #6).  [under development]
   3.5  Identify a Superfund green remediation liaison/coordinator in each region: This
        position is similar to the brownfields coordinator and the Superfund redevelopment
        coordinator. Each liaison/coordinator will foster consideration of green remediation
        within his/her region, serve as a liaison in green remediation issues, coordinate with
        other regional programs, and update stakeholders on potential or actual changes in
        environmental and community impacts as a result of using green remediation
        strategies, [already implemented]
   3.6  Participate in development of a national standards and certification process:
        Superfund will build  on Region 3's current project involving EPA participation in an
        ASTM  International task to develop a national, voluntary standard for green cleanups.11
        The Agency is working with state partners to develop a draft framework that outlines
        desired outcomes for a green cleanup standard and serves as a starting point for the
        consensus-based process used to develop the standard.  In 2009, the Agency's Green
        Cleanup Standards Workgroup will continue developing various options for associated
        certification of voluntary green cleanups, [under development]
  Key Action #4: Address air pollutants and diesel emissions
This key action incorporates the use of diesel emission
reduction practices and clean diesel technologies into
response programs in a manner consistent with CERCLA
and the NCP and while reflecting national priorities and
tradeoffs. Use of clean diesel technologies would be
explored for all contract types, regardless of the cleanup
leads involved.
Diesel emissions pose
significant risks to people -
residents and workers alike
and should therefore be
minimized.
   4.1  Develop an OSWER/OSRTI fact sheet (in coordination with the Office of Air and
        Radiation and EPA regions)  on clean diesel technologies: The fact sheet would
        discuss existing documentation that shows how using clean diesel equipment reduces
        emission of nitrogen oxides, particulate matter, and air toxics, which contribute to
        serious public health problems and adversely affect air quality. The fact sheet would
        target ways to minimize total emissions, covering topics such as operational practices
        (e.g., proper service and maintenance procedures and engine idle reduction plans), use
        of advanced technology (e.g.,  retrofitting machinery for diesel engine emission control
        and exhaust treatment technologies such as particulate filters and oxidation catalysts),
        and the influence of factors such as equipment type or age. The fact sheet also will
        foster a better understanding of the environmental sustainability of various liquid fuels
        such as biodiesel. Information  resources would include technical material such as
        EPA's  Smart Energy Resources Guide (USEPA, 2008e). [to be initiated]
  See periodic updates on EPA's Green Cleanup Standard Initiative (USEPA, 2009c) and related updates from ASTM
International (ASTM International, n.d.).
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   4.2  Develop cleanup contract requirements for incorporating clean diesel
        technologies and fuels: Sample contract language developed under Key Action #6
        would include considerations or requirements regarding air emissions, [under
        development]
 Key Action #5:  Develop pilot projects to evaluate and demonstrate green
                  remediation applications
Pilot projects will help the Program build a collection of data on actual costs and results of green
remediation approaches, operational and administrative lessons learned, and materials for
planned trainings and information sessions. Headquarters could provide regions with funding to
support scoping, planning, or design activities related to green remediation projects.
   5.1  Encourage regions and headquarters to undertake innovative green remediation
        pilot projects: OSRTI and FFRRO would request that each region identify one or more
        pilot projects. The pilots would develop information based on practical field experience
        with green approaches. OSRTI's Technology Innovation and Field Services Division
        and the regions will collect data generated from pilot projects and develop a
        comprehensive database supporting future actions, [under development]
   5.2  Develop and pilot test a green remediation analysis template that will help collect
        information during various phases of the remediation process at any site: The
        template could consist of a series of checklists for compiling baseline information  and
        comparing potential green strategies. Template topics  will include opportunities for
        greater energy efficiency and site suitability for long-term wind farming, solar or thermal
        energy generation, and gas production, [under development]
   5.3  Launch a pilot project incorporating green remediation considerations into all
        remedy optimization evaluations and assessing the feasibility for all
        optimizations by FY 2010: The pilot will include consideration of energy efficiency and
        alternative energy sources, reduction of air emissions,  reduction of waste generated by
        the remedy, minimizing habitat destruction, and other key green  remediation
        considerations relevant to the operating remedies. Experience gained during the pilot
        may result in a revised optimization process to account for potential components of
        green remediation, [already implemented]
   5.4  Support the RE-Powering America's Land Initiative by identifying Superfund sites
        with outstanding or superb renewable energy potential:12 Regions will be
        encouraged to work with  renewable energy developers and other stakeholders to
        assess feasibility of locating renewable energy generation projects on contaminated
        lands and mining sites. Technical assistance to the regions is available through an
        OSWER IA with DOE's National Renewable Energy Laboratory,  [under development]
 Key Action #6:   Establish opportunities in contracts and assistance agreements
                   to identify green remediation practices in selected remedies
Opportunities to modify existing and upcoming contracts, cooperative agreements, grants, and
lAs will be assessed as a means to identify green remediation best management practices
consistent with the remedy selected. Consistent with Federal Acquisition Regulations and
  RE-Powering America's Land products include maps and incentive sheets on potential for community wind energy,
utility-scale wind energy, concentrating solar power, photovoltaic solar energy, and biomass energy (USEPA, n.d.5).
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Executive Order 13423 (EO, 2007), OSWER will work with the Office of Acquisitions
Management to explore the following:
   6.1  Modify contract language to identify green remediation practices consistent with
        remedy selection under the NCR: Identify upcoming solicitations and develop
        language for the statements of work (SOWs) and requests for proposals. Modify SOW
        language in existing remedial and removal contracts (both region-wide and site-specific)
        and work assignments or task orders whenever possible. New and modified contracts
        can include results-based language directing contractors to explore green strategies
        (e.g. reducing energy and fuel usage, incorporating renewable energy sources, and
        increasing material reuse) in all cases with the exception of time critical removals. Use
        regional Remedial Action Contract (RAC) and Emergency and Rapid Response
        Services (ERRS) SOWs  (such as those developed in Regions 2, 9, and 10) to develop
        national model contract language with SOWs that reference Executive Order 13423 or
        other mandates. Inclusion of specifications outlined in Federal Acquisition Regulations
        may be considered, [under development]
   6.2  Modify contract language to require reporting of selected activities: Modify SOW
        language in corresponding remedial and removal contracts (and/or associated work
        assignments or  task orders) to require contractors to annually and/or monthly report on
        headquarters or regional concerns such as energy and fuel usage, separate from  other
        direct costs, [under development]
   6.3  Develop and periodically update a green remediation contracting tool kit:
        Disseminate the Green Response Action Contracting and Administrative Toolkit issued
        in June 2009 to  regional project managers and Superfund contractors (USEPA, 2009e).
        Continue compiling new language adopted by regions or other agencies and
        information on innovative contracting or administrative mechanisms coming into use,
        and make toolkit updates publically available through posting  on OSRTI's green
        remediation Web pages, [already implemented]
   6.4  Develop model terms and conditions for assistance agreements and lAs
        concerning site cleanup: Using regional examples such as Region 2's IA with the
        U.S. Army Corps of Engineers, draft and institutionalize requirements for green
        remediation considerations consistent with the selected remedy in non-contracting
        vehicles such as assistance agreements and lAs.  Develop model outputs/outcomes for
        regions to use in state agreements, [under development]
   6.5  Explore additional opportunities to use existing federal agreements and establish
        new agreements: Use OSWER's memoranda of understanding and/or lAs with the
        National Renewable Energy Laboratory and Argonne National Laboratory to provide
        regions with site-specific technical assistance.  Pursue additional lAs with other
        agencies to further enable green  remediation consistent with NCR response actions.
        [under development]
   6.6  Explore and promote opportunities to use local expertise in green cleanups:
        OSRTI will work with regional community involvement coordinators to engage
        stakeholders in worker training and hiring opportunities applicable to green cleanups.
        For example, regional and local utility businesses will be encouraged to develop
        strategies that develop and retain local workers with expertise in energy optimization
        and renewable energy integration. In addition, local government agencies and
        businesses directly or indirectly involved in cleanups will be encouraged to
        institutionalize service contracts and agreements with clauses that give preference to
        local workers and firms using environmentally preferable practices, [to be initiated]
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 Key Action #7: Communicate and share success stories and lessons learned
                 among "implementers" across the Program and the public
Development of green remediation program-wide and site-level initiatives will depend on shared
activities and information that involve multiple interested parties, disciplines, and federal and
state cleanup programs. A dedicated, well organized communications effort would be needed to:
(a) ensure that all stakeholders have an opportunity to be involved, (b) ensure consistency of
green remediation messages across and within programs, (c) share technical and programmatic
information, and (d) provide options that incorporate green remediation practices. The following
initiatives are expected to address these needs:
   7.1  Develop a communication plan: The communication plan will complement OSWER
        efforts to ensure consistency of green remediation messages across the various
        cleanup programs. Success stories and lessons learned will be shared with
        communities,  EPA regions, other federal agencies, states, local organizations, and
        contractors through use of tools  such as Web sites, regular conference calls with
        regional staff and managers, webinars, and the electronic notebook.  Regular
        communications at events such as OSC Readiness and the annual NARPM training
        conference are an integral aspect of the plan. Communications also will be maintained
        at non-Superfund events such as the National Brownfields Conference, the RCRA
        Corrective Action Conference, and the  National LIST Conference, [under development]
   7.2  Conduct outreach to contractors and industry: This outreach will  facilitate
        information sharing among EPA regions and help define or refine the best management
        practices of green remediation. Target  information includes success stories,
        complications and technical roadblocks, and costs incurred or saved, [under
        development]
   7.3  Partner with other federal agencies and state organizations to promote  national
        use of green remediation strategies: Documents prepared by EPA should be shared
        with other agencies and state organizations for use by their members. Government
        organizations with work teams dedicated to green cleanup issues include the Federal
        Remediation Technologies Roundtable, Interstate Technology and Regulatory Council
        (ITRC), and Association of State and Territorial Solid Waste Management Officials
        (ASTSWMO). OSRTI and  FFRRO will partner with other federal agencies and states to
        compile federal and state publications and information resources on green remediation
        and distribute them to EPA, state,  and other federal agency program and project
        managers, [already implemented]
   7.4  Engage local communities in assessing and implementing green remediation
        options: OSRTI will work with regions  to enhance participation of local stakeholders,
        including minority and low-income populations affected by site cleanup. Mechanisms
        may include the Technical Outreach Services for Communities Program to help
        communities understand technical issues and opportunities posed by green
        remediation options; the Technical Assistance Grant Program to establish information
        networks; and the Superfund Job Training Initiative to help educate local workers in
        specialty fields such as energy efficiency and renewable energy applications,  [to be
        initiated]
   7.5  Develop a series of green remediation "citizen's guides:" Develop several citizen's
        guides that explore specific green remediation approaches and options and encourage
        meaningful participation in remedy selection and remedy design processes, [to be
        initiated]
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2.3    Program Evaluation

Goal:

Identify and make available measures and metrics for evaluating green remediation
implementation at a site level and a Program level as part of a coordinated effort among OSWER
program offices. The resulting measures and metrics can be used to integrate green remediation
goals in the EPA's Strategic Plan and align with Agency budgets.

Introduction:

Evaluation objectives for green remediation are needed at both the site and Program levels to:
(1) identify elements to be measured, (2) evaluate progress resulting from green remediation
practices over time, and (3) report accomplishments at specific sites and within the Program.

In order to frame the evaluation measures to be developed, OSWER will need to establish
criteria for selecting the measures. Criteria can include considerations such as the degree of
resolution acceptable for different parameters; limits to the level of effort required to implement
the measures; the need to align with EPA goals; and the needs of various users such as site
managers, regional offices, and national program managers. The criteria should also address
acceptable approaches and scope for addressing indirect or intangible effects of green
remediation, including how to ensure that local governments and communities weigh disparate
measures such as cost, emissions,  energy use, impacts on local ecosystems, and effects on
communities.

Initially, EPA can establish internal baseline  estimates on specific parameters (such as energy
use, fuel consumption, air emissions, and water use) as well as use of the best practices.
Examples of baseline parameters include the extent to which decision makers consider green
options, adopt green approaches, or use best practices as an integral part of  the Superfund
process. Clearly defined measures and metrics  will
expedite subsequent data collection as well as           Internal baselines will provide the
contribute to the use of qualitative measures for         Agency with a starting point from
reporting  progress on attaining green remediation        which to measure related changes
goals while remaining within Agency budgets. EPA will    and quantify related project
work with states through ASTSWMO and the ITRC to     improvements in accordance with
identify measures and metrics that also can be           one or more core elements of green
specified  in assistance agreements and lAs              remediation.
concerning green remediation.

This key action will begin by examining existing  tools developed by Agency program offices,
other federal agencies, states, and private industry for potential application to the program.
Common needs in site and Program evaluations include:
   •   Performance measure benchmarks, which will build upon Agency and other standards
       such  as ASTM International's environmental management series or a  forthcoming green
       cleanup standard, as well as policies and methodologies issued under initiatives such as
       the United Nations Framework on Climate Change (United Nations, 2003). Baselines and
       methodologies pertaining to GHG and associated consumption of fossil fuel energy will
       be derived in part from EPA information such as the Office of Air and  Radiation's April 10,
       2009, proposed rulemaking on reporting of greenhouse gases (USEPA, 2009a) and
       EPA's Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990 - 2007 (USEPA,
       2008d).

   •   Evaluation measures, which must be meaningful and transferable across site and
       Program use levels. Anticipated measures include fuel and energy consumption,

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       contributions from renewable energy sources, GHG and air contaminant emissions, water
       consumption and reuse, and material recycling or reuse.
       A core set of metrics that is practical to apply and poses minimal reporting burdens on
       RPMs and OSCs. Consistent, intuitive metrics will help balance project decision making
       and supply quantitative or qualitative data for measuring changes from green remediation
       baselines. Examples include gallons of fuel, kilowatts of electricity, pounds of carbon
       dioxide equivalents, gallons of water,  and cubic yards of waste.
  Key Action #8: Evaluate green remediation application at the site level
In order to make informed decisions on green remediation practices at a site level, a consistent
approach is needed to quantify cleanup footprints associated with each of the core elements of
green remediation on a site-by-site basis. Many tools exist for evaluating the effects of site
activity on one or more core elements, but none meets the Agency's need to evaluate all core
elements affecting site cleanup. Information gathered from the Program's pilot projects will
generate useful data and lessons to be used in developing a consistent "roadmap" for site-
specific evaluation of green strategies. The green remediation roadmap will maintain consistency
with NCR criteria for remedy evaluation.

RPMs and OSCs can use the roadmap to collect and evaluate information at a site-specific level,
enabling them to focus efforts on reducing potential footprints through innovation, optimization,
and best practices. The roadmap could be applied during remedy selection, design, construction,
operation, and monitoring phases. In all cases,  consideration of the environmental footprint of
remedy alternatives assumes that each adequately addresses a site's remedial objectives.
Collective information gathered under this key action can also contribute to Program evaluation
efforts by Agency management (Key Action #9). Specific actions  may involve:

   8.1  Compile and analyze existing tools with measures and metrics for evaluating
        sustainability: Existing tools for addressing one or more core elements will be
        researched and summarized in terms  of scope that aligns with the core elements and
        applicability to site cleanup. Resulting information will be summarized in a
        comprehensive document made available to RPMs, OSCs, and other stakeholders,  and
        frequently updated to reflect new or expanded tools (USEPA, 2009d). [already
        implemented]

   8.2  Develop criteria for selecting site-specific evaluation measures and metrics:
        Results of EPA green remediation pilot projects, the existing tools for general evaluation
        of core elements, and applicable portions of cleanup evaluation tools developed by
        other agencies or private industry will  be analyzed. The  analysis will be used to
        describe and document tangible/intangible, unique, and composite measures of value
        to decision makers as well as specific criteria for use in choosing suitable measures
        and  metrics at a particular site, [under development]
   8.3  Develop modules for core element evaluation: Methodologies for selecting and
        applying suitable measures and metrics will be developed for each core element of
        green remediation. Each module will delineate an approach for identifying and
        prioritizing constituents  of a footprint, estimating a footprint made by a potential or
        existing remedy, and identifying best practices or innovative solutions to reduce the
        footprint, [under development]
   8.4  Recommend methods for determining total benefit of a cleanup: Existing  guidance
        and  tools will be analyzed to identify methodologies for evaluating and weighing factors
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        that can estimate: (a) the benefits of incorporating green remediation practices at a site,
        and (b) associated total benefit of a cleanup. The Program will compile a limited array
        of potential resources and recommend selected methodologies pertaining to sample
        cleanup scenarios, [to be initiated]
  Key Action #9:  Develop Program evaluation measures
Program management at a regional or national level needs consistent quantitative and qualitative
tools to evaluate program direction. Program evaluations will aggregate the parameters used in
site-level assessments, such as GHG emissions and water and energy use. Efforts can build on
preliminary studies such as OSRTI's estimates regarding energy consumption and carbon
dioxide emissions from frequently used treatment technologies at NPL sites (USEPA, 2008a).
The following efforts would lead to development of a core set of evaluation objectives that may
be applied across the Program and provide information for EPA's Strategic Plan.
   9.1  Develop options for addressing possible gaps in  measures or metrics: This
        activity will  examine and identify gaps in measures and metrics identified through site-
        specific green remediation evaluations or in other strategic activities. Gaps may relate
        to environmental outcomes that are difficult to quantify in terms of cleanup baselines,
        such as changes in sulfur dioxide and nitrogen oxide emissions, while other gaps may
        relate to complex issues such as carbon sequestration. Options for resolving measures
        and metrics gaps may involve application of methods such as present value analysis.
        [to be initiated]

   9.2  Characterize the state of practice and implications of life cycle analysis and net
        carbon footprint analysis on Program operations: Identify and develop tools and
        guidance to explore: (a) upstream and downstream impacts on the environmental
        footprints of remedial actions, (b) methods for aggregating data on disparate metrics to
        inform program-level issues, and (c) approaches for comparing options extending over
        different time periods (e.g., excavation and disposal versus multi-year, onsite
        treatment). Upstream impacts may include offsite activities such as material
        manufacturing that consumes energy and water. Potential downstream contributors
        include activities such as discharge of wastewater to publicly owned treatment works.
        Impact characterization would help direct
        environmental implications of the Program's
        actions overtime, [underdevelopment]
   9.3  Coordinate recommended Program
        performance measures with activities
        supporting green remediation resource
        development and program
        implementation (Actions 2.1 through 7.5):
        The core set of programmatic measures
        should align with strategic Program products
        such as the green remediation compendium
        and pilot projects. This coordination would
        ensure that recommended measures are
        feasible and practical and that they may be
        appropriate for use in developing and
        evaluating Program objectives, [under
        development]
Region 2 intends to measure the cost
differentials and environmental
benefits associated with
implementing its Clean and Green
policy. Examples include tracking
quantities of materials reduced,
reused or recycled; carbon or
greenhouse gas reductions;  and
quantities of water conserved or
replenished.  The Region plans to use
existing progress reporting
requirements in enforcement
instruments,  grants, and contracts to
collect this data.
  Region 2 "Clean and Green" Policy
Office of Superfund Remediation and Technology Innovation
U.S. Environmental Protection Agency
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3.0   Implementation of the Superfund Green Remediation
       Strategy
One of the major challenges in implementing this Strategy is developing a baseline of information
on cleanups using traditional approaches. A baseline is essential for identifying the greatest
opportunities for improving environmental outcomes of cleanups, evaluating the effects of
Strategy implementation, and determining appropriate  Program goals.
  Key Action #10:   Evaluate the Superfund Green Remediation Strategy
This key action involves a formative evaluation of the new approaches related to usage of
energy, water, and other natural resources. Results also may be used to address cross-program
priorities.
    10.1 Estimate environmental outcomes of traditional cleanups: This information would
        be used to determine the current baseline of energy, fuel, and water usage at Fund-
        lead sites prior to Strategy implementation, [under development]

    10.2 Compile site-specific information on resource consumption: Information on
        energy, fuel, and water usage would be collected through other key actions and
        compiled in a comprehensive data set available to regions and program offices, [under
        development]
    10.3 Establish a process for quantifying achievements: The process will establish a
        baseline and assist in  evaluating progress in reducing demands that site cleanups place
        on the environment and communities. Using this baseline, the program could aim
        toward specific targets such as reducing energy consumption by 20% or increasing use
        of alternative fuels/renewable energy by 15%, consistent with selecting and
        implementing responses under the NCR. [under development]

As the Superfund Remedial  Program moves forward with finalizing this Strategy, it is proceeding
with implementing many of the Strategy's specific actions. For example, green remediation
approaches are being considered in optimization evaluations underway this fiscal year, and
green remediation liaisons have been named for each regional office.

A detailed  implementation plan  will be developed for each of the action items contained in the
Strategy. The plan will identify actions to be taken, the persons responsible for each action, and
an associated schedule.
Office of Superfund Remediation and Technology Innovation
U.S. Environmental Protection Agency
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Appendix A: Abbreviations and Acronyms
ARAR        applicable or relevant and appropriate requirement
ASTSWMO   Association of State and Territorial Solid Waste Management Officials
CERCLA     Comprehensive Environmental Response, Compensation, and Liability Act of
             1980, as amended
DOE         U.S. Department of Energy
EE/CA       engineering evaluation/cost analysis
EO          executive order
EPA         U.S. Environmental Protection Agency
ER3         Environmentally Responsible Redevelopment and Reuse Initiative
ERRS        Emergency and Rapid Response Services
FFEO        Federal Facilities Enforcement Office
FFRRO       Federal Facilities Restoration and Reuse Office
GHG         greenhouse gas
IA           interagency agreement
ITRC         Interstate Technology and Regulatory Council
NARPM       National Association  of Remedial Project Managers
NCP         National Oil and Hazardous Substances Pollution Contingency Plan
NPL         National Priorities List
NRMRL       National Risk Management Research Laboratory
OEM         Office of Emergency  Management
OSC         on-scene coordinator
OSRE        Office of Site Remediation Enforcement
OSRTI       Office of Superfund Remediation and Technology Innovation
OSWER      Office of Solid Waste and Emergency Response
PA/SI         preliminary assessment/site investigation
PRP         potentially responsible party
RA          remedial action
RAC         remedial action contract
RD          remedial design
REC         renewable energy certificate
RI/FS         remedial investigation/feasibility study
RPM         remedial project manager
RSE         remediation system evaluation
SOW         statement of work
SRI          Superfund Redevelopment Initiative
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U.S. Environmental Protection Agency
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Appendix B:  References
40 CFR 300. Code of Federal Regulations, Title 40: Protection of Environment, Part 300-
National Oil and Hazardous Substances Pollution Contingency Plan.
http://ecfr.gpoaccess.gov/cg i/t/text/text-idx?c=ecfr&tpl=/ecfrbrowse/Title40/40cfr300_main_02.tpl

ASTM International, (n.d.). New Guide for Green Cleanup at Contaminated Sites. ASTM
WK23495. http://www.astm.org/DATABASE.CART/WORKITEMS/WK23495.htm

Executive Order 13423. 2007. Strengthening Federal Environmental, Energy, and Transportation
Management. 72 FR 3919, January 26, 2007. http://www.ofee.gov/eo/eo13423_main.asp

North Carolina Solar Center/Interstate Renewable Energy Council, (n.d.). Database of State
Incentives for Renewables & Efficiency, http://www.dsireusa.org/ (Accessed: 2009, June 26)

P.L. 96-510, 42 U.S.C. § 9601-9675, December 11, 1980. Comprehensive Environmental
Response, Compensation, and Liability Act.

Pew Center on Global Climate Change, (n.d.). U.S. States & Regions.
http://www.pewclimate.org/states-regions (Accessed: 2009, June 26)

USEPA. 2009a.  40 CFR Parts 86, 87, 89, et al. Mandatory Reporting of Greenhouse Gases;
Proposed Rule. 74 FR 16448, April 10, 2009. U.S. Environmental Protection Agency.
http://www.epa.gov/climatechange/emissions/ghgrulemaking.html

USEPA. 2009b.  Clean and Green Policy. U.S. Environmental Protection Agency, Region 2.
http://epa.gov/region2/superfund/green_remediation/policy.html

USEPA. 2009c.  Green Cleanup Standard Initiative. U.S. Environmental Protection Agency.
http://clu-in.org/greenremediation/subtab_b5.cfm

USEPA. 2009d.  Green Remediation: Footprint Assessment Tools. Office of Superfund and
Remediation Technology. U.S. Environmental Protection Agency.
http://www.duin. org/greenremediation/subtab_b3.cfm

USEPA. 2009e.  Green Response and Remedial Action Contracting and Administrative Toolkit.
U.S. Environmental Protection Agency, Office of Superfund and Technology Innovation.
http://www.duin. org/greenremediation/subtab_b2.cfm

USEPA. 2008a.  Energy Consumption and Carbon Dioxide Emissions at Superfund Cleanups.
U.S. Environmental Protection Agency, Draft prepared for Office of Superfund Remediation and
Technology Innovation.
http://www.duin. org/greenremediation/docs/SF_Energy_Carbon_Footprint.pdf

USEPA. 2008b.  Green Remediation: Best Management Practices for Excavation and Surface
Restoration. EPA 542-F-08-012, U.S. Environmental Protection Agency, Office of Solid Waste
and Emergency  Response.
http://www.duin. org/greenremediation/docs/GR_Quick_Ref_FS_exc_rest.pdf

USEPA. 2008c.  Green Remediation: Incorporating Sustainable Environmental Practices into
Remediation of Contaminated Sites. EPA 542-R-08-002, U.S. Environmental Protection Agency,
Office of Solid Waste and Emergency Response. http://www.cluin.org/download/remed/Green-
Remediation-Primer.pdf  [This resources includes an extensive list of references and resources.]
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USEPA. 2008d. Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990 - 2007 (March 1,
2008, public review draft). U.S. Environmental Protection Agency.
http://epa.gov/climatechange/emissions/usinventoryreport.html

USEPA. 2008e. Smart Energy Resources Guide. EPA 600-R-08-049, U.S. Environmental
Protection Agency, Region 9. http://www.epa.gov/nrmrl/pubs/600r08049/600r08049.htm

USEPA. 2006. 2006-2011 EPA Strategic Plan: Charting Our Course. U.S. Environmental
Protection Agency, EPA 190-R-06-001. http://www.epa.gov/ocfo/plan/2006/entire_report.pdf

USEPA. 2004. Introduction to Energy Conservation and Production at Waste Cleanup Sites.
EPA 542-8-04-001, U.S. Environmental Protection Agency, OSWER  Engineering Forum.
http://www.epa.gov/tio/tsp/download/epa542s04001.pdf

USEPA. (n.d.1). Cleanup-Clean Air Initiative. U.S. Environmental Protection Agency, Region 9.
http://www.epa.gov/region09/cleanup-clean-air/ (Accessed: 2009, June 26)

USEPA. (n.d.2). CLU-IN Technology Focus: Remediation Optimization. U.S.  Environmental
Protection Agency, http://www.clu-
in.org/techfocus/default.focus//sec/Remediation_Optimization/cat/Overview/page/3/ (Accessed:
2009, June  26)

USEPA. (n.d.3). Environmentally Responsible Redevelopment and Reuse (ER3). U.S.
Environmental Protection Agency.
http://www.epa.gov/compliance/cleanup/revitalization/er3/index.html (Accessed: 2009, June 26)

USEPA. (n.d.4). Green Remediation. U.S. Environmental Protection Agency, Office of Superfund
and Remediation Technology. http://CLU-IN.org/greenremediation (Accessed: 2009, June 26)

USEPA. (n.d.5). RE-Powering America's Land: Renewable Energy on Contaminated Land and
Mining Sites. U.S. Environmental Protection Agency.
http://www.epa.gov/renewableenergyland/index.htm (Accessed: 2009, June 26)

USEPA. (n.d.6). Superfund & Green Remediation. U.S. Environmental Protection Agency, Office
of Superfund and Remediation Technology, http://www.epa.gov/superfund/greenremediation

USEPA. (n.d.7). Superfund Redevelopment. U.S. Environmental Protection Agency.
http://www.epa.gov/superfund/programs/recycle/index.html (Accessed:  2009, June 26)

USEPA. (n.d.8). Superfund Remedy Optimization. U.S. Environmental Protection Agency.
http://www.epa.gov/superfund/cleanup/postconstruction/optimize.htm (Accessed: 2009, June 26)

United Nations Framework Convention on Climate Change. 2003. Review of the Implementation
of Commitments and of Other Provisions of the Convention, National Communications:
Greenhouse Gas Inventories from Parties Included in Annex I to the Convention.
FCCC/CP/2002/8. http://unfccc.int/resource/docs/cop8/08.pdf
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