oEPA
United States Environmental
Protection Agency
Office of Policy
(1807T)
November 2011
EPA-100-F-11-028
Evaluation of Implementation
of the Superfund Green
Remediation Strategy
Summary
Fact Sheet
http://www.epa.gov/evaluate
For more information on
completed evaluations at
EPA or the Evaluation
Support Division, visit the
above link.
Introduction
• EPA's Superfund program is working to advance greener cleanups at Superfund sites.
• Central to this effort is the Superfund Green Remediation Strategy (GR Strategy), which
was published in final form in September, 2010.
• The GR Strategy o\A\mos 40 action items across three main areas with the ultimate goal
of reducing the environmental footprint associated with cleaning up contaminated sites.
• EPA's Office of Superfund Remediation and Technology Innovation (OSRTI) and the
Office of Policy's Evaluation Support Division (ESD) sponsored this program evaluation
to: 1) assess EPA experiences to date in implementing the GR Strategy; 2} determine a
baseline against which to measure EPA progress in implementing the GR Strategy; and
3) determine the best metrics for measuring the program's success in implementing GR
practices.
Evaluation Questions
• Does EPA have clearly defined goals and objectives for the GR Strategy! Should they be
refined and improved to enhance usefulness (e.g., for management decision making,
planning and budgeting, EPA's Strategic Plan)?
• Which initial activities or initiatives from the GR Strategy have been most effective in
increasing awareness, adoption and/or implementation of the GR Strategy!
• How do Remedial Project Managers (RPMs) factor the GR Strategy \n\.o their approach
to planning site cleanup?
• What effect has the GR Strategyhad on the practice of using green remediation
techniques at Superfund sites?
• What lessons have been learned as a result of implementing the GR Strategy at sites?
• What options can we identify for developing a baseline?
• What performance measures are appropriate for measuring the effectiveness of the GR
StrategyIn achieving intended outcomes at a regional or national level?
• What are the best means for measuring the effectiveness of the GR StrategyIn reducing
the environmental footprint at sites that have implemented GR practices with respect to
the five core elements of the GR Strategy!
• Where are the primary data gaps and limitations that inhibit a better understanding of
the results of implementing the GR Strategy!
Evaluation Methods
• The evaluation used several research methods to answer the evaluation questions.
• The analytical approach for this evaluation combines content analysis of interview
responses with examination of data from surveys, studies, literature, and databases to
answer the evaluation questions.
• The evaluation team collected new data through interviews with key EPA personnel
involved in implementing GR techniques and the GR Strategy, other federal agency, and
state government officials.
• The evaluation team also conducted a review of existing data including GR literature,
site-specific data, and documents and publications specific to the GR Strategy prior to
the interviews to inform interview guides and resolve issues that arose during the
interviews.
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Key Findings
Assess EPA experiences to date in implementing the GR Strategy
• Overall, responses were uniformly positive of the GR Strategy structure and purpose, though some differences of
opinion in how best to present "goals" and objectives were identified. Many respondents noted that a more
precise goal statement could be used to increase awareness and focus further implementation of the GR
Strategy.
• In the strongest finding, responses were very positive about several tools and products of the GR Strategy, which
have been a key driver in facilitating an expansion of GR activities. Awareness of the GR Strategy document was
more limited, though the GRStrategy\s facilitating GR implementation by raising its national profile.
• Regional responses indicate that RPMs typically do not use the GR Strategy directly in their decision-making for
GR implementation, though they use many of the tools and products developed as part of the GR Strategy. The
GR Strategy document itself appears to be a more important tool for managers than for RPMs.
• Assessing the distinct contributions of the national GR Strategy and individual regional policies is difficult because
they influence each other, and because limited time has passed since the GR Strategy publication. A snapshot of
GR activities from regional surveys suggests that GR training and outreach has increased as the GR Strategy has
developed.
• GR implementation is challenged by the level of funding and support for GR Strategy personnel and project
efforts, concern about policy and liability uncertainty, and limited participation from managers and other key staff.
Determine a baseline against which to measure EPA progress in implementing the GR Strategy
• Most regions have not yet focused on developing a baseline for GR implementation. Respondents in eight regions
described their GR implementation as just beginning, and feel that current practices still reflect pre-GR Strategy
practices. Complexity arises in the regions where the GR Strategy clearly post-dates regional activities, and in
cases where people are "doing" GR without calling it GR. Findings suggest that a single baseline may be adequate
to capture contribution, but different regional baselines for site-specific actions may be needed for attribution.
Determine the best metrics for measuring the program's success in implementing GR practices
• A review of the GR Strategy logic model suggests that appropriate performance measures should assess changes
in awareness (short-term outcomes), behavior (medium-term outcomes), and site practice/impacts (long-term
outcomes). Metrics should also assess how effectively the GR Strategy \s implemented and integrated throughout
the remediation process. Successful metrics should be easily quantifiable and require limited data collection.
• Review of existing and emerging tools suggests EPA's footprint methodology's metrics are comprehensive and
reasonable. Use of footprint-based metrics for program performance may require that OSRTI estimate typical site
values to minimize data collection from regions.
• Respondents noted key challenges to understanding and implementing GR. These include the need for policy
guidance on legal authority and implementation strategy for GR, concerns about resource constraints to conduct
footprint analyses, and the need to maintain momentum and signal priorities in implementing the GR Strategy.
Recommendations
The evaluation team suggests that EPA:
• Focus on clarity of goals and implementation objectives.
• Continue emphasis on practical tools for GR implementation.
• Increase focus on policy and legal information and tools, or on other HQ "signaling."
• Consider the following as a starting point for establishing two baselines:
o A region-specific baseline for documenting site-level changes and attributing change to the GR Strategy.
o A national baseline for documenting integration of GR practices into EPA cleanup culture.
• Work with regions and develop guidance on how and when to conduct footprint analyses.
• Start a dialogue with each of the regions to agree on the best way to leverage case study and other available
data to develop an estimation tool or "average" values for GR practices.
• Select metrics to measure program success based upon appropriate EPA criteria.
Report Link: http://www.epa.Qov/evaluate/reports.htm
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