United States Environmental
Protection Agency
Office of Policy
(1807T)
November 2011
EPA-100-R-11-009
?/EPA
Evaluation of
Implementation of the
Superfund Green
Remediation Strategy
Final Report
Promoting Environmental Results
i >
Through Evaluation
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ACKNOWLEDGEMENTS
This report, Evaluation of Implementation of the Superfund Green Remediation Strategy,
was developed for the U.S. Environmental Protection Agency's Office of Policy (OP)
under Contract EP-W-10-002 between EPA and Industrial Economics, Inc. (IEc) of
Cambridge, MA. The IEc evaluation team included Cynthia Manson, Fauna Samuel, and
Yeshaya Dobrusin.
Carlos Pachon, Suzanne Wells, and Ellen Treimel of EPA's Office of Solid Waste and
Emergency Response, Office of Superfund Remediation and Technology Innovation
(OSRTI) provided critical assistance and background information on the Superfund
Green Remediation Strategy program. John Heffelfinger and Shari Grossarth of OP's
Evaluation Support Division (ESD) provided technical support and advice for the
evaluation. Special thanks go to EPA staff at Headquarters and the Regions who shared
thoughtful reflections, recommendations, and critiques during the conduct of this
evaluation.
This evaluation was funded jointly by OSRTI and ESD, and was selected under the
Program Evaluation Competition, sponsored annually by EPA's Office of Policy.
Program evaluation is one of the performance management tools that EPA uses to assure
itself, the public, and other interested stakeholders that EPA programs are protecting
human health and the environment effectively and efficiently. The information obtained
through program evaluations can shed light on whether EPA programs are meeting their
goals and objectives, provide the evidence and road map needed to replicate successes,
and identify those aspects of EPA programs needing improvement. To access copies of
this or other EPA program evaluations, please go to EPA's Evaluation Support Division
website at http://www.epa.gov/evaluate.
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TABLE OF CONTENTS
EXECUTIVE SUMMARY
CHAPTER 1 | INTRODUCTION AND PURPOSE
I. I 0\ en ie\\ of the Superfund (irccn Rcsnalknion Siniic^v 2
1.2 Siiperfund (irccn Re/ucJituio/i Sirmc^v Logic Model 5
i .3 H\aluation Questions and Purposes 7
1.4 Report Organization 8
CHAPTER 2 | METHODOLOGY
2.1 l:\aluation Design 9
2.2 Steps in Conducting the l:\aluation 14
CHAPTER 3 | FINDINGS
3,1 L\a!nation Purpose I: Assess LPA I!\penences to Date in Implementing the
(iR Strategy 22
3.2 L\aination Purpose 2: Determine a Baseline Against Which to Measure LPA
Progress in Implementing the (iR Sirt//c^v 44
3.3 H\aluation Purpose 3: Determine the Best Metrics for Measuring the Program's
Success in Implementing (iR Practices 48
3.4 Synthesis of Key l:\aluation Findings 62
CHAPTER 4 | CONCLUSIONS AND SUGGESTED NEXT STEPS
4,1 L\a!nation Purpose I: Assess LPA I!\penences to Date in Implementing the
(iR Stniic^y 65
4.2 L\aiiiation I- - - !' - , - ist Which to Measure LPA
Progress in , , : 67
4.3 H\aluation ' ', ' : for Measuring the Program's
Success in I , 11' I- : 68
APPENDIX A: LIST OF INTERVIEWEES
APPENDIX B: INTERVIEW GUIDES
APPENDIX C: REGIONAL SURVEY AND TRACKING DATA
APPENDIX D: EPA CLU-IN USE DATA
APPENDIX E: LIST OF REFERENCES
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EXECUTIVE SUMMARY
The Superfund program is working to advance greener cleanups at Superfund sites. Green
remediation (GR) is defined as the practice of considering all environmental effects of
remedy implementation and incorporating options to minimize the environmental
footprint of remedies. Central to this effort is the Superfund Green Remediation Strategy,
which was published in final form in September, 2010. The strategy outlines 40 action
items across three main areas with the ultimate goal of reducing the environmental
footprint of cleaning up contaminated sites.
As part of the Strategy, the Superfund program is evaluating the implementation of the
Strategy itself. The chosen approach is to conduct a "formative" evaluation of the
national-level effort. The purpose of the evaluation is to document the Strategy's
effectiveness in advancing greener cleanups. This evaluation was guided by nine
questions organized under three key purposes:
Evaluation Purpose 1: Assess EPA experiences to date in implementing the GR
Strategy
1. 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)!
2. Which initial activities or initiatives from the GR Strategy have been most effective in
increasing awareness, adoption and/or implementation of GR strategies?
3. How do Remedial Project Managers (RPMs) factor the GR Strategy into their
approach to planning site cleanup?
What GR practices are being implemented?
What percentage of RPMs are implementing specific GR practices?
What do RPMs know about the energy usage at the sites they manage?
What information do RPMs track on other GR core elements?
4. What effect has the GR Strategy had on the practice of using green remediation
techniques at Superfund sites?
5. What lessons have been learned as a result of implementing the GR Strategy at sites?
What factors affect the ability to implement the GR Strategy at sites? (e.g.,
technical issues, cost issues, legal issues, management support, contract
provisions, or contractor capabilities)
How is integration of the GR Strategy priorities (e.g., policy guidance, training,
and tools) affected by the above factors and experiences to date?
ES-1
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Evaluation Purpose 2: Determine a baseline against which to measure EPA
progress in implementing the GR Strategy
6. What options can we identify for developing a baseline?
What has changed since the implementation of the GR Strategy!
When did green remediation become important to site cleanup?
What options are available for quantifying the environmental footprint at sites?
Evaluation Purpose 3: Determine the best metrics for measuring the program's
success in implementing GR practices
7. What performance measures are appropriate for measuring the effectiveness of the GR
Strategy in achieving intended outcomes at a regional or national level?
8. What are the best means for measuring the effectiveness of the GR Strategy in
reducing the environmental footprint at sites that have implemented GR practices with
respect to the five core elements ofGR Strategy?
What options exist for using qualitative or quantitative measures to assess the
five core elements of GR Strategy!
9. Where are the primary data gaps and limitations that inhibit a better understanding of
the results of implementing the GR Strategy!
PROGRAM LOGIC MODEL
An initial step in the evaluation was the development of a program logic model (Exhibit
ES-1) to illustrate the various components of the Superfund Green Remediation Strategy
and to inform development of specific evaluation questions. For this evaluation, the logic
model focuses on the outcomes that are most relevant to the Superfund Green
Remediation Strategy and the ability to measure its progress. The logic model activities
are organized to reflect the three main categories of actions in the GR Strategy, including
policy and guidance development, resource development and program implementation,
and program evaluation.
EVALUATION METHODOLOGY
As discussed in Chapter 2 of this report, this evaluation uses a range of data sources and
analytic techniques. First lEc conducted a review of existing published background
documents available online and provided by EPA. In addition, lEc reviewed, as relevant,
site specific data (e.g., to identify available data to support specific metrics for
documenting progress under the GR Strategy on the core elements). Finally, this
evaluation relies primarily on data collected directly from EPA personnel who are
currently involved in the implementation of the GR Strategy. lEc employs a combination
of targeted interviews, literature review, and review of existing survey and site data to
ensure high quality data collection and analysis. Exhibit ES-2 summarizes the methods
and data sources used to address the evaluation questions.
ES-2
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EXHIBIT ES-1.
SUPERFUND GREEN REMEDIATION STRATEGY LOGIC MODEL
KCIVICUIM i \\jn S>IKAI t(jY
OUTCOMES
RESOURCES
J_L
ACTIVITIES
Funding
EPA Staff
OSRTI
GR Workgroup
10 Regional
Coordinators
Policy
Resources
EO 13514
OSWER
Principles for
Greener
Cleanups
GR Practices at
State &
Regional level
Peer Network
(developed
through
implementation)
Policy and Guidance
Development
Evaluate potential
ARARs
Resource
Development
Modify contract
language to include GR
practices
Define and refine
BMPs as appropriate
Briefing contractors
and POs
Establish mechanisms
for financing GR
Define footprint
methodology
OUTPUTS
Program
Implementation
Deliver GR trainings
(NARPM)
Communication with
RPMs, DDs.and PRPs
through briefings,
meetings and calls
Program Evaluation
Establish program
baseline
Measure footprint
Identify additional
GR information
resources
REG Purchase
Agreement
Statement
Issue policy on GR
remedy selection
Define and refine
BMPs
Standard contract
language
Contracting tool kit
Footprint
methodology
Communications
outputs
Fact sheets
Checklists
Qs & As
Clu-in website
Case studies
Research
Advertising/
outreach
Baseline & reports
on environmental
footprint reductions
SHORT-TERM
Contextual
Factors
Cannot be too specific with how to implement GR methods because it limits cleanup options
Regional access to different GR methods is not equal
Greener cleanup methods are sometimes more costly than less green methods
INTERMEDIATE
LONG-TERM
Assess consistency
with Regional
Strategies
Power purchase
from local utility
Greater awareness
of GR Strategy and
BMPs
Adopt integrated GR
BMPs for each of 5
Awareness of
authority (well
defined)
Enforcement
Legal
Contract
Provide site-specific
assistances.
assistance
mechanisms
Greater awareness
of Resources
Clu-in
' -Technical
knowhow (skills)
/
>*
Project managers
communicating to
stakeholders
1
GR reflected in
ROD, where
appropriate
Consistent
phrasing
t
Use of contracting
tool kit
Contractor
notification
RPM request
contractor to
incorporate GR
Greater awareness
of status of
environmental
footprint &
opportunities to
improve (5 core
elements)
Specify., adopt
performance goals,
objectives and
measures
Full integration of
GR Strategy
Energy
Use of
renewables
and energy
efficiency
Air
Reduced
emissions
Water
Reduced
consumption/
increased
protection
Land/eco-
systems
Minimize harm
and protect
land for future
use
Materials/
waste
Reduce
material
consumption
and waste
generation
_J
ES-3
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ES-2. EVALUATION QUESTIONS AND DATA SOURCES FOR FORMATIVE EVALUATION OF THE CR STRATEGY
EVALUATION QUESTION
PRIMARY DATA AND METHODS
SECONDARY DATA AND METHODS
EVALUATION PURPOSE 1 : ASSESS EPA EXPERIENCES TO DATE IN IMPLEMENTING THE CR STRATEGY
1 . 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)?
2. Which initial activities or initiatives from the
GR Strategy have been most effective in increasing
awareness, adoption and/or implementation of the
GR Strategy?
Interviews:
Regional Coordinators
Outside-EPA staff
Interviews:
Regional Coordinators
Data Review:
Atlanta Meeting survey
State and regional strategies
Interviews:
Regional attorneys
Front line managers
Data Review:
GR Strategy
Interviews:
Regional attorneys
Front line managers
Data Review:
GR Strategy
3. How do Remedial Project Managers (RPMs) factor the GR Strategy into their approach to planning site cleanup?
3a) What GR practices are being implemented?
3b) What percentage of RPMs are implementing
specific GR practices?
3c) What do RPMs know about the energy usage at
the sites they manage?
3d) What information do RPMs track on other GR core
elements?
4. What effect has the GR Strategy had on the
practice of using green remediation techniques at
Superfund sites?
Interviews:
Regional Coordinators
Data Review:
Atlanta Meeting and regional surveys
State and regional strategies
Interviews:
Regional Coordinators
Interviews:
Regional attorneys
Front line managers
Data Review:
GR Strategy
Data Review:
GR Strategy
CLU-IN case study site profiles
Regional surveys
State and regional strategies
5. What lessons have been learned as a result of implementing the GR Strategy at sites?
5a) What factors affect the ability to implement the
GR Strategy at sites (e.g., technical issues, cost
issues, legal issues, management support, contract
provisions, or contractor capabilities)?
5a) How is integration of the GR Strategy priorities
(e.g., policy guidance, training, and tools) affected
by the above factors and experiences to date?
Interviews:
Regional Coordinators
Interviews:
Regional attorneys
Front line managers
Outside-EPA staff
Data Review:
CLU-IN website use data
ES-4
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EVALUATION QUESTION
PRIMARY DATA AND METHODS
SECONDARY DATA AND METHODS
EVALUATION PURPOSE 2: DETERMINE A BASELINE AGAINST WHICH TO MEASURE EPA PROGRESS IN IMPLEMENTING THE CR STRATEGY
6. What options can we identify for developing a baseline?
6a) What has changed since the implementation of
the CR Strategy?
6b) When did green remediation become important
to site cleanup?
6d) What options are available for quantifying the
environmental footprint at sites?
Data Review:
GR Strategy
Footprint methodology
Published studies
CLU-IN case studies
Interviews:
Regional coordinators
Measurement specialists
Outside-EPA staff
Data Review:
Regional tracking data
EVALUATION PURPOSE 3: DETERMINE THE BEST METRICS FOR MEASURING THE PROGRAM'S SUCCESS IN IMPLEMENTING GR PRACTICES
7. What performance measures are appropriate
for measuring the effectiveness of the GR Strategy
in achieving intended outcomes at a regional or
national level?
Data Review:
Footprint methodology
Published studies
Regional tracking data
Atlanta meeting and regional surveys
Interviews:
Regional coordinators
Measurement specialists
Outside-EPA staff
8. What are the best means for measuring the effectiveness of the GR Strategy in reducing the environmental footprint at sites that have
implemented GR practices with respect to the five core elements of the GR Strategy?
8a) What options exist for using qualitative or
quantitative measures to assess the five core
elements of the GR Strategy?
9. Where are the primary data gaps and
limitations that inhibit a better understanding of
the results of implementing the GR Strategy?
Data Review:
Published studies
CLU-IN website use data and case studies
Interviews:
Regional coordinators
Measurement specialists
Data Review:
Published studies
Interviews:
Regional coordinators
Data Review:
Atlanta meeting and regional surveys
Regional tracking data
Footprint analyses and tools
Data Review:
Footprint analyses and tools
ES-5
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EVALUATION FINDINGS
Chapter 3 presents the evaluation findings, organized by the evaluation purposes and then
the evaluation questions. We provide a short summary below:
Evaluation Purpose 1: Assess EPA experiences to date in
implementing the CR Strategy
Overall, interview respondents were uniformly positive in their opinions of the GR
Strategy structure and purpose, though responses identified some differences of opinion
in how best to present "goals" and objectives. Several respondents noted that a more
precise goal statement could be useful both in increasing awareness and focusing further
implementation of the GR Strategy.
In the strongest finding, EPA and non-EPA interviewees had very positive views of
several key products of the GR Strategy, and felt that these tools and products have been
a key driver in facilitating an expansion of GR activities. Respondents felt that awareness
of the GR Strategy document was more limited, though publication of the GR Strategy
has facilitated the use of GR by raising the national profile of GR.
Interview responses from the regions indicate that RPMs typically do not use the GR
Strategy directly in their decision-making for GR implementation, though it is clear they
use many of the tools and products developed to support the GR Strategy. The GR
Strategy document was identified to be a more important tool for managers than for
RPMs.
It is difficult to assess the distinct contributions of either the national strategy or regional
policies separately, since they influence each other. A few regional policies informed the
GR Strategy, while others many not have been released without the national focus on GR.
Examination of regional data from surveys provides a snapshot of activities underway,
and it is apparent that regions have increased emphasis on GR training and outreach as
the GR Strategy has emerged.
A range of challenges face the broader implementation of the GR Strategy, with key
concerns including the level of funding and support for GR Strategy personnel and
project efforts. Other hurdles include a concern about policy and liability uncertainty,
and limited participation from managers and other key staff.
Evaluation Purpose 2: Determine a baseline against which to
measure EPA progress in implementing the CR Strategy
Interview responses from the regions indicated that most have not focused to date on
developing a baseline. Overall most of the regions (eight often) identified that their
current practices represent a fairly accurate baseline before the GR Strategy was released
because the implementation of GR efforts is just beginning. A complexity of the GR
Strategy is that it has been implemented as a unifying approach encompassing some
existing efforts, and in some cases it clearly post-dates regional activities (e.g., Region 2
and 9). Moreover, a key goal of the program is awareness, and in some cases people are
"doing" GR without calling it GR. The findings from this evaluation suggest that EPA
ES-6
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consider whether one baseline is adequate to support the program. If EPA wishes to
document contribution of the GR Strategy generally then a single date-driven baseline
may be appropriate. To document attribution, however, use of different regional baselines
for site-specific action may be necessary.
Evaluation Purpose 3: Determine the best metrics for measuring the
program's success in implementing GR practices
A review of the logic model associated with the GR Strategy suggests that a suite of
appropriate performance measures for program performance would directly assess the
short-term (changes in awareness), intermediate term (changes in behavior), and long-
term (changes in site practice and impacts) outcomes of the GR Strategy. Metrics for each
type of outcome would also allow EPA to assess the extent to which the GR Strategy is
effectively implemented and successful in integrating GR principles throughout the
remediation process. Successful metrics will also likely require only limited data
collection and analysis.
Review of existing and emerging tools for calculating environmental footprint suggest
EPA's efforts to craft and test a footprint methodology to support GR activities at sites
provides a comprehensive set of metrics that map to four of the five GR Strategy core
elements (excluding land and ecosystems). Several metrics listed in the footprint
methodology appear consistent with other sources and may be able to be adopted with
limited additional effort. The most successful metrics may be those that HQ can estimate
using standardized values and limited regional data.
Interview responses suggest that a number of key challenges exist for understanding the
impacts of GR. As was noted in Evaluation Purpose 1, a larger issue that arose from the
interview process is the identification of the need for policy-level clarity of the GR
Strategy. The lack of clear direction from EPA providing legal and policy justification for
incorporating GR techniques at sites seems to have decreased momentum for moving GR
forward in some regions. Other limitations that inhibit a better understanding of the
results of implementing the GR Strategy include concerns about resource constraints
(e.g., time, funding, manpower), concerns that clear legal authority for requiring GR
practices is not well defined, and reluctance on the part of EPA staff in many regions to
use the methodology to conduct footprint analyses.
EVALUATION CONCLUSIONS AND SUGGESTED NEXT STEPS
Chapter 4 of this report provides conclusions and suggested recommendations for the
future implementation of the Superfund Green Remediation Strategy. In summary, they
include recommendations 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."
ES-7
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Consider the following as a starting point for establishing two baselines:
o A region-specific baseline for documenting site-level changes (core
elements) 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.
ES-8
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CHAPTER 1 | INTRODUCTION AND PURPOSE
Under the Comprehensive Environmental Response, Compensation, and Liability Act
(CERCLA), commonly known as Superfund, the U.S. Environmental Protection Agency
(EPA) has, since 1980, investigated and assessed contaminated hazardous waste sites, and
undertaken enforcement and remediation activities to ensure protection of human health
and the environment. Hazardous waste site investigation and remediation uses resources
such as energy, water, and materials, and also creates a physical environmental
"footprint" at the site and any related disposal areas. In recent years, EPA has focused on
identifying and employing "green remediation" techniques at Superfund sites. Green
remediation (GR) is defined as the practice of considering all environmental effects of
remedy implementation and incorporating options to minimize the environmental
footprint of remedies. A centerpiece of this effort is EPA's Superfund Green Remediation
Strategy (the GR Strategy), which was published in draft form in 2009 and in final form
in September, 2010. The strategy outlines 40 action items across three main areas: policy
and guidance development; resource development and program implementation; and
program evaluation. The central goal of the strategy is to reduce the environmental
footprint of cleaning up contaminated sites by focusing on five core elements:
Energy requirements of the treatment system;
Air emissions;
Water requirements and impacts on water resources;
Material consumption and waste generation; and
Land and ecosystem impacts.
In addition to the Superfund Green Remediation Strategy, EPA's Office of Superfund
Remediation and Technology Innovation (OSRTI) in the Office of Solid Waste and
Emergency Response (OSWER) has published a number of fact sheets and a technology
primer, Green Remediation: Incorporating Sustainable Environmental Practices into
Remediation of Contaminated Sites, to help guide decision-makers about the options that
are most appropriate for specific site circumstances. Moreover, the Superfund site
remediation programs in the ten EPA regions have begun to integrate GR practices at
some sites. In some cases regional focus on GRpre-dates the publication of the GR
Strategy. As EPA begins to incorporate GR more broadly, it is important to ensure that
the GR Strategy and related efforts are appropriately focused, widely understood and
applied where appropriate, and able to demonstrate and measure key impacts related to
the five core elements.
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As part of pursuing the GR Strategy, the Superfund program is evaluating the
implementation of the strategy itself. Industrial Economics, Incorporated (IEc), with the
support of EPA's Evaluation Support Division (ESD) in the Office of Policy, is
conducting a "formative" evaluation of the national-level effort. A formative evaluation is
conducted early in implementation of the program to assess how program activities and
priorities are being implemented, and to ensure that program design and objectives are
well-aligned. The purpose of the evaluation is to help focus the GR Strategy's future
efforts to advance greener cleanups by examining three main parameters:
Insights from EPA experiences to date in implementing the GR Strategy;
Options for developing a baseline against which to measure EPA progress in
implementing the GR Strategy;
Options to assist OSRTI in developing the best metrics for measuring the
program's successes in implementing GR practices.
Nine evaluation questions address different aspects of these evaluation parameters. The
evaluation is designed to shed light on cross-cutting issues in implementing the GR
Strategy, and to inform future efforts undertaken by OSRTI to integrate GR and reduce
environmental footprints at National Priorities List (NPL) sites. As a formative
evaluation, this effort does not focus on "performance" in achieving long-term "program"
(i.e., GR Strategy) goals. Therefore, we do not attempt to quantify environmental
footprint reductions at sites.
The Superfund program envisions the eventual integration of GR as standard business
practice in site remediation, and anticipates a future evaluation that will assess the impact
of the strategy. To further this effort, IEc has assisted EPA in developing a
comprehensive logic model that identifies the key data needed to support related
activities, outputs, and outcomes of the GR Strategy implementation efforts.
1.1 OVERVIEW OF THE SUPERFUND GREEN REMEDIATION STRATEGY
In September 2009, EPA issued its first formal strategy on green remediation for public
review. In September 2010, EPA revised and reissued the strategy, after incorporating
comments from the public review. The final GR Strategy outlines nine key actions,
which describe 40 specific activities that the program intends to implement to promote
green remediation. The actions are separated into three categories:
Policy and guidance development;
Resource development and program implementation; and
Program evaluation.
One long-term goal of the GR Strategy is the eventual integration of GR as standard
business practice in site remediation. The ultimate goal is to establish a process that
routinely ensures that the environmental footprints of site cleanup actions are minimized
to the extent practical. OSRTI plans to treat the Superfund Green Remediation Strategy as
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a "living" document and update the GR Strategy as Agency policy progresses, as
activities are modified within the key actions and, as green remediation practices develop.
A GR Strategy Activity Tracking Chart, published in February 2011, provides an update
documenting the implementation of the components of the GR Strategy. Exhibit 1-1
summarizes the 40 activities and their status as of February 2011.
EXHIBIT 1-1. SUPERFUND GREEN REMEDIATION STRATEGY OVERVIEW
SUPERFUND GR STRATEGY: SUMMARY OF STRATEGIC ACTIONS (AS OF FEBRUARY 201 1 )
POLICY AND GUIDANCE DEVELOPMENT
Key Action #1 : Clarify the role of green remediation in remedy selection and
implementation
1.1
1.2
Develop OSWER policy on green remediation in remedy selection for remedial
and non-time critical removal actions
Evaluate potentially applicable or relevant and appropriate requirements (ARARs)
Status
Under Development
Under Development
RESOURCE DEVELOPMENT AND PROGRAM IMPLEMENTATION
Key Action #2: Develop a compendium of protocols and tools to help project and
program managers integrate green remediation practices
2.1
2.2
2.3
2.4
2.5
2.6
2.7
Identify green remediation resource needs
Identify additional green remediation information resources
Develop technology-specific assessment tools and fact sheets
Develop green remediation Q&A's
Produce green remediation checklists
Deliver or host green remediation training through the Technology Innovation and
Field Services Division's training infrastructure
Provide site-specific assistance and assistance mechanisms
Key Action #3: Identify options that enable use of green remediation practices
3.1
3.2
3.3
3.4
3.5
3.6
3.7
Identify methods to maximize use of renewable energy with a goal of using 100%
renewable energy to power site operations
Identify methods for increasing energy efficiency
Develop a better understanding of the costs or savings associated with use of
green remediation strategies and practices
Develop a fact sheet on using green power for site cleanup
Identify methods to increase use of renewable energy generated onsite for site
remediation at remote locations
Explore and/or establish funding mechanisms to finance green remediation
research, development, and demonstration (RD&D) and initial deployment efforts
at Superfund sites
Participate in development of a national standards and certification process
Key Action #4: Address air pollutant emissions
4.1
4.2
4.3
Key Acti
applicat
5.1
5.2
Develop a fact sheet on clean fuel and emission technologies
Develop cleanup contract requirements for incorporating clean fuel and emission
technologies
Identify opportunities for recovering and using methane gas emitted from
landfills on Superfund sites
on #5: Develop pilot projects to evaluate and demonstrate green remediation
ons
Develop a database of innovative green remediation pilot projects
Develop and pilot test a green remediation analysis template to help collect
information during various phases of the remediation process at any site
Status
Implemented
Implemented
Implemented
Under Development
Under Development
Implemented
Implemented
Status
Under Development
Under Development
Under Development
Implemented
Under Development
Under Development
Under Development
Status
Implemented
Under Development
Under Development
Status
Under Development
Implemented
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SUPERFUND CR STRATEGY: SUMMARY OF STRATEGIC ACTIONS (AS OF FEBRUARY 201 1 )
5.3
5.4
Incorporate green remediation factors into remedy optimization evaluations
Support the Re-Powering America's Land Initiative by identifying Superfund sites
with outstanding or superb renewable energy potential
Key Action #6: Establish opportunities in contracts and assistance agreements to
identify green remediation practices in selected remedies
6.1
6.2
6.3
6.4
6.5
6.6
Modify EPA contract language to include green remediation practices
Modify contract language to require reporting of selected activities
Develop and periodically update a green remediation contracting tool kit
Develop model terms and conditions for assistance agreements and lAs
concerning site cleanup
Explore additional opportunities to use existing federal agreements and establish
new agreements
Explore and promote opportunities to use local expertise in green cleanups
Key Action #7: Communicate and share success stories and lessons learned among
"implementers" across the Program and the public
7.1
7.2
7.3
7.4
Develop a communication plan
Conduct outreach to contractors and industry
Partner with other federal agencies and state organizations to promote national
use of green remediation strategies
Engage local communities in assessing and implementing green remediation
options
Implemented
Implemented
Status
Under Development
Under Development
Implemented
Under Development
Under Development
Under Development
Status
Under Development
Under Development
Implemented
To Be Initiated
PROGRAM EVALUATION
Key Action #8: Establish a roadmap for evaluating the environmental footprint of a
cleanup at a project level
8.1
8.2
8.3
Analyze existing methods and software tools for evaluating the environmental
footprint of a cleanup
Develop an Agency methodology for evaluating the environmental footprint of a
cleanup
Develop evaluation modules for green remediation strategies
Key Action #9: Evaluate the environmental footprints of Superfund cleanups at a
programmatic level
9.1
9.2
9.3
9.4
Estimate a Program baseline for the environmental footprints of Superfund
cleanups
Establish performance goals, objectives, and measures for the Superfund Green
Remediation Strategy
Develop options for addressing possible gaps in measures or metrics
Characterize the state of practice and implications of life cycle assessment on
Program operations
Status
Implemented
Under Development
Under Development
Status
Under Development
Under Development
Under Development
Under Development
EPA Regions, Headquarters, and external stakeholders have issued a number of other
green remediation policy and guidance documents both prior to the first draft of the GR
Strategy that was released in September of 2009, and since the final GR Strategy has been
published. Exhibit 1-2 provides a timeline noting publication of some of the key green
remediation policy documents that form the broader context of GR efforts. One focus of
this evaluation will be examining the extent to which the GR Strategy builds on, supports,
and aligns with existing efforts.
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EXHIBIT 1-2. GREEN REMEDIATION STRATEGIES
YEAR
Apr 2008
Mar 2009
Aug 2009
Aug 2009
Aug 2009
Summer 2009
Sept 2009
Sept 2009
Sept 2009
Sept 2009
Nov 2009
Jan 2010
Feb2010
Feb2010
Sept 2010
Feb 201 1
SOURCE
OSWER
Region 2
OSWER
Region 8
Region 10
Sustainable Remediation
Forum(SURF)
OSWER/OSRTI
Region 6
Region 7
Region 9
Region 5
Region 3
Region 1
Region 4
OSWER/OSRTI
OSWER
GREEN REMEDIATION POLICIES
Green Remediation Primer: Incorporating Sustainable Environmental
Practices into Remediation of Contaminated Sites
Clean and Green Policy
Principles for Greener Cleanups
Green Remediation Policy
Clean and Green Policy
SURF White Paper Integrating Sustainable Principles, Practices,
and Metrics Into Remediation Projects
Superfund Green Remediation Strategy, Public Review Draft
Clean and Green Policy
Interim Green Cleanup Policy
Greener Cleanups Policy
Greener Cleanup Interim Policy
Greener Cleanup and Sustainable Reuse Policy
Clean and Green Policy for Contaminated Sites
Clean and Green Policy
Superfund Green Remediation Strategy
Superfund Green Remediation Strategy, Activity Tracking Chart
1.2 SUPERFUND GREEN REMEDIATION STRATEGY LOGIC MODEL
To illustrate the various components of the Superfund Green Remediation Strategy and to
inform development of specific evaluation questions, EPA has developed a logic model
(i.e., a graphical representation of the relationships between program inputs, outputs, and
intended outcomes). A logic model synthesizes the key activities of a program into a
picture of how it is expected to work. A program logic model helps determine the degree
to which a program's activities and other related inputs affect the expected outcomes. In
addition, the logic model's outputs and outcomes can help identify potential indicators or
measures of performance. As shown in Exhibit 1-3, the key components of the model
include:
Resources: basic inputs of funds, staffing and knowledge dedicated to the
program.
Activities: the specific procedures or processes used to achieve program goals.
Outputs: the immediate products that result from activities and are often used to
measure short-term progress.
Audience: the groups that the program seeks to influence.
Short-Term Outcomes: the changes in awareness, attitudes, understanding,
knowledge, and skills resulting from program outputs.
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EXHIBIT 1-3. SUPERFUND GREEN REMEDIATION STRATEGY LOGIC MODEL
KCIVICUIM I IUN £> I KM I CO T
OUTCOMES
ACTIVITIES
Funding
EPA Staff
OSRTI
GR Workgroup
10 Regional
Coordinators
Policy
Resources
EO 13514
OSWER
Principles for
Greener
Cleanups
GR Practices at
State &
Regional level
Peer Network
(developed
through
implementation)
Policy and Guidance
Development
Evaluate potential
ARARs
Resource
Development
Modify contract
language to include GR
practices
Define and refine
BMPs as appropriate
Briefing contractors
and PCs
Establish mechanisms
for financing GR
Define footprint
methodology
OUTPUTS
Program
Implementation
Deliver GR trainings
(NARPM)
Communication with
RPMs, DDs, and PRPs
through briefings,
meetings and calls
Program Evaluation
Establish program
baseline
Measure footprint
Identify additional
GR information
resources
REC Purchase
Ag reement
Statement
Issue policy on GR
remedy selection
Define and refine
BMPs
Standard contract
language
Contracting tool kit
Footprint
methodology
Communications
outputs
Fact sheets
Checklists
Qs & As
Clu-in website
Case studies
Research
Advertising/
outreach
Baseline & reports
on environmental
footprint reductions
SHORT-TERM
INTERMEDIATE
LONG-TERM
Contextual
Factors
Cannot be too specific with how to implement GR methods because it limits cleanup options
Regional access to different GR methods is not equal
Greener cleanup methods are sometimes more costlythan less green methods
Assess consistency
with Regional
Strategies
Power purchase
from local utility
Greater awareness
of GR Strategy and
, BMPs
Awareness of
authority (well
defined)
Enforcement
Legal
Contract
Provide site-specific
assistances
assistance
mechanisms
Greater awareness
of Resources
Clu-in
' -Technical
knowhow (skills)
j
-*
^
Adopt integ rated GR
BMPs for each of 5
core areas
Project managers
communicating to
stakeholders
I
GR reflected in
ROD, where
appropriate
Consistent
phrasing
t
Use of contracting
tool kit
Contractor
notification
RPM req uest
contractorto
incorporate GR
Greater awareness
of status of
environmental
footprint &
opportunities to
improve (5 core
elements)
Specify/adopt
performance goals,
objectives and
measures
Full integration of
GR Strategy
Energy
Use of
renewables
and energy
efficiency
Air
Reduced
emissions
Water
Reduced
consumption/'
increased
protection
Land/eco-
systems
Minimize harm
and protect
land for future
use
Materials/
waste
Reduce
material
consumption
and waste
generation
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Intermediate Outcomes: the changes in behavior that are broader in scope than
short-term outcomes. Intermediate outcomes often build upon the progress
achieved in the short-term.
Long-Term Outcomes: the outcomes that demonstrate the GR Strategy's overall
capability to be effective as well as the overall environmental improvements made
through the strategy.
For this evaluation, the logic model focuses on the outputs that are most relevant to the
Superfund Green Remediation Strategy and the ability to measure its progress. The logic
model activities are organized to reflect the three main categories of actions in the GR
Strategy, including policy and guidance development, resource development and program
implementation, and program evaluation. The resource development and program
implementation category was divided into two sections to allow for easier tracking of
outputs and intended audiences. The last column of the logic model outlines the two
parallel long-term goals of the GR Strategy: 1) measurable reductions in the
environmental footprints of site cleanup actions, and 2) the full integration of the GR
Strategy itself into EPA decision-making during Superfund site cleanup.
1.3 EVALUATION QUESTIONS AND PURPOSES
lEc conducted an initial data and document review, and coordinated with EPA to finalize
the following evaluation purposes and questions:
1.3.1 Evaluation Purpose 1: Assess EPA experiences to date in
implementing the CR Strategy
1. 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)!
2. Which initial activities or initiatives from the GR Strategy have been most effective
in increasing awareness, adoption and/or implementation of GR strategies?
3. How do Remedial Project Managers (RPMs) factor the GR Strategy into their
approach to planning site cleanup?
What GR practices are being implemented?
What percentage of RPMs are implementing specific GR practices?
What do RPMs know about the energy usage at the sites they manage?
What information do RPMs track on other GR core elements?
4. What effect has the GR Strategy had on the practice of using green remediation
techniques at Superfund sites?
5. What lessons have been learned as a result of implementing the GR Strategy at sites?
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What factors affect the ability to implement the GR Strategy at sites? (e.g.,
technical issues, cost issues, legal issues, management support, contract
provisions, or contractor capabilities)
How is integration of the GR Strategy priorities (e.g., policy guidance, training,
and tools) affected by the above factors and experiences to date?
1.3.2 Evaluation Purpose 2: Determine a baseline against which to
measure EPA progress in implementing the CR Strategy
6. What options can we identify for developing a baseline?
What has changed since the implementation of the GR Strategy!
When did green remediation become important to site cleanup?
What options are available for quantifying the environmental footprint at sites?
1.3.3 Evaluation Purpose 3: Determine the best metrics for measuring the
program's success in implementing CR practices
7. What performance measures are appropriate for measuring the effectiveness of the GR
Strategy in achieving intended outcomes at a regional or national level?
8. What are the best means for measuring the effectiveness of the GR Strategy in
reducing the environmental footprint at sites that have implemented GR practices with
respect to the five core elements ofGR Strategy?
What options exist for using qualitative or quantitative measures to assess the five
core elements of GR Strategy!
9. Where are the primary data gaps and limitations that inhibit a better understanding of
the results of implementing the GR Strategy!
1.4 REPORT ORGANIZATION
This evaluation report is organized as follows:
Chapter 2 presents the methodology used in this evaluation.
Chapter 3 presents the evaluation findings, organized by the evaluation purpose
and evaluation question. The chapter concludes with a summary of key findings.
Chapter 4 presents conclusions and recommendations to ensure the continued
success of the GR Strategy.
This report also includes appendices with copies of interview guides, regional survey
data, CLU-IN website use data, and list of references.
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CHAPTER 2 | METHODOLOGY
2.1 EVALUATION DESIGN
This evaluation seeks to synthesize available information on the implementation of the
Superfund Green Remediation Strategy. As a formative evaluation of the national-level
effort, this evaluation is primarily a qualitative assessment of how well the GR Strategy
program activities and priorities are being implemented, based on information gathered
from the early phases of implementation of the GR Strategy.
The information needed to support the evaluation reflects a variety of sources, including:
The Superfund Green Remediation Strategy (draft, final and update to the final
GR Strategy);
EPA national and regional data such as surveys conducted during the GR Strategy
development, data on website and document access, regional policies and data,
and methods and case studies for calculating environmental footprints;
Published studies and external data including existing GR literature, State GR
strategies, and private sector efforts such as the Sustainable Remediation Forum
(SuRF) White Paper;
Superfund records, including site profiles; and
Interviews with EPA and non-EPA staff involved in green remediation
implementation efforts.
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. Our evaluation design relies principally on new data
collection through interviews with key EPA personnel involved in implementing GR
techniques and the GR Strategy (e.g., OSRTI staff, Superfund GR Regional Coordinators,
the GR Workgroup participants, RPMs, regional managers and attorneys, other Agency
representatives), and other federal agency and state government officials. In addition, lEc
reviewed 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 also to resolve issues that arose during the interviews.
Exhibit 2-1 on the next page provides a summary of the evaluation questions as they link
to the key objectives (purpose) of the evaluation. Exhibit 2-1 also includes a brief map of
the key data sources that lEc employed in answering each of the questions.
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EXHIBIT 2-1. EVALUATION QUESTIONS AND DATA SOURCES FOR FORMATIVE EVALUATION OF THE CR STRATEGY
EVALUATION QUESTION
DATA SOURCES
SUPERFUND GR
STRATEGY
EPA REGIONAL
STRATEGIES,
SURVEYS AND
TRACKING DATA
PUBLISHED
STUDIES AND
EXTERNAL
DATA
CLU-IN WEB
USE DATA AND
CASE STUDY
SITE PROFILES
INTERVIEWS
NOTES ON DATA SOURCE(S):
EVALUATION PURPOSE 1 : ASSESS EPA EXPERIENCES TO DATE IN IMPLEMENTING THE CR STRATEGY
1 . 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)?
X
X
Interviews with Regional
Coordinators, non-EPA staff,
evaluation of CR Strategy
2. Which initial activities or initiatives from the GR Strategy have been most effective in increasing awareness, adoption and/or implementation
of the GR Strategy?
X
X
X
Interviews with Regional
Coordinators, regional attorneys,
front line managers, and non-EPA
staff, Atlanta meeting survey, state
and regional strategies
3. How do Remedial Project Managers (RPMs) factor the GR Strategy into their approach to planning site cleanup?
3a) What GR practices are
being implemented?
3b) What percentage of RPMs
are implementing specific GR
practices?
X
X
X
X
X
X
Interviews with Regional
Coordinators (including some
RPMs), evaluation of CR Strategy
(and Update), Region 3 and 4
surveys, Region 9 tracking list,
Atlanta meeting survey, state and
regional strategies, site profiles,
website use data
Interviews with Regional
Coordinators, Region 3 and 4
survey, Atlanta meeting survey
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EVALUATION QUESTION
3c) What do RPMs know about
the energy usage at the sites
they manage?
3d) What information do RPMs
track on other GR core
elements?
DATA SOURCES
SUPERFUND GR
STRATEGY
EPA REGIONAL
STRATEGIES,
SURVEYS AND
TRACKING DATA
X
X
PUBLISHED
STUDIES AND
EXTERNAL
DATA
CLU-IN WEB
USE DATA AND
CASE STUDY
SITE PROFILES
INTERVIEWS
X
X
NOTES ON DATA SOURCE(S):
Interviews with Regional
Coordinators, Region 3 and 4
surveys, Region 2 tracking
database, and Atlanta meeting
survey
Interviews with Regional
Coordinators, Region 3 and 4
surveys, Region 2 tracking
database, and Atlanta meeting
survey
4. What effect has the GR Strategy had on the practice of using green remediation techniques at Superfund sites?
X
X
X
Interviews with Regional
Coordinators , Superfund records,
Region 3 and 4 surveys, and state
and regional strategies
5. What lessons have been learned as a result of implementing the GR Strategy at sites?
5a) What factors affect the
ability to implement the GR
Strategy at sites (e.g.,
technical issues, cost issues,
legal issues, management
support, contract provisions,
or contractor capabilities)?
5a) How is integration of the
GR Strategy priorities (e.g.,
policy guidance, training, and
tools) affected by the above
factors and experiences to
date?
X
X
X
X
X
X
Interviews with RPMs, Regional
Coordinators, regional attorneys,
front line managers, non-EPA staff,
Contract Specialists, and website
use data
Interviews with Regional
Coordinators (Region 2 and Region
9), regional attorneys, front line
managers, non-EPA staff, and
website use data
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EVALUATION QUESTION
DATA SOURCES
SUPERFUND CR
STRATEGY
EPA REGIONAL
STRATEGIES,
SURVEYS AND
TRACKING DATA
PUBLISHED
STUDIES AND
EXTERNAL
DATA
CLU-IN WEB
USE DATA AND
CASE STUDY
SITE PROFILES
INTERVIEWS
NOTES ON DATA SOURCE(S):
EVALUATION PURPOSE 2: DETERMINE A BASELINE AGAINST WHICH TO MEASURE EPA PROGRESS IN IMPLEMENTING THE CR STRATEGY
6. What options can we identify for developing a baseline?
6a) What has changed since
the implementation of the GR
Strategy?
6b) When did green
remediation become
important to site cleanup?
6d) What options are available
for quantifying the
environmental footprint at
sites?
X
X
X
X
X
X
X
Interviews with Regional
Coordinators, measurement
specialists, evaluation of GR Strategy
(and Update)
Interviews with Regional
Coordinators, measurement
specialists, evaluation of GR Strategy,
and the SURF White Paper
Interviews with Regional
Coordinators, measurement
specialists, Footprint Measurement
Methodology (Tetra Tech), Region 2
Metrics, Region 9, and Case Studies
EVALUATION PURPOSE 3: DETERMINE THE BEST METRICS FOR MEASURING THE PROGRAM'S SUCCESS IN IMPLEMENTING GR PRACTICES
7. What performance measures are appropriate for measuring the effectiveness of the GR Strategy in achieving intended outcomes at regional or
national level?
X
X
X
Interviews with Regional
Coordinators, measurement
specialists, SURF White Paper, Region
3 and 4 survey, Region 2 tracking
database, Atlanta meeting survey,
and Case Studies
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EVALUATION QUESTION
DATA SOURCES
SUPERFUND GR
STRATEGY
EPA REGIONAL
STRATEGIES,
SURVEYS AND
TRACKING DATA
PUBLISHED
STUDIES AND
EXTERNAL
DATA
CLU-IN WEB
USE DATA AND
CASE STUDY
SITE PROFILES
INTERVIEWS
NOTES ON DATA SOURCE(S):
8. What are the best means for measuring the effectiveness of the GR Strategy in reducing the environmental footprint at sites that have
implemented GR practices with respect to the five core elements of the GR Strategy?
8a) What options exist for
using qualitative or
quantitative measures to
assess the five core elements
of GR Strategy?
X
X
X
X
Interviews with Regional
Coordinators, SURF White Paper,
Region 3 and 4 survey, Region 2
tracking database, Atlanta meeting
survey, footprint analyses and tools,
and Case Studies
9. Where are the primary data gaps and limitations that inhibit a better understanding of the results of implementing the GR Strategy?
X
X
X
Interviews with Regional
Coordinators, measurement
specialists, SURF White Paper,
footprint analyses and tools
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2.2 STEPS IN CONDUCTING THE EVALUATION
Consistent with the purpose of formative evaluations, this effort was designed to be
exploratory, and we did not develop a quantitative analysis of measuring progress or
assessing effectiveness. In addition, the purpose of this evaluation is to capture a range of
insights and ideas to guide next steps for the program. Therefore, we did not implement a
statistically robust survey methodology with random sampling and analysis of statistical
significance of results. Instead, our approach uses qualitative assessment methods and
integrates data sources as follows:
The five broad steps for this evaluation are:
1. Conduct an initial review of existing survey data regarding implementation of
the GR Strategy;
2. Conduct in-depth interviews with EPA regional staff who are actively involved
in implementing the GR Strategy, including all regional GR coordinators;
3. Validate and expand on interview responses, assess data from regional surveys,
tracking efforts, and footprint methods and EPA's Profiles of Green Remediation
case studies;
4. Resolve questions raised and obtain detailed technical information to inform
questions, conduct a second round of targeted interviews focusing on specific
skill areas, issues, and perspectives (including non-EPA individuals, non-Federal
organizations, and regional attorneys and managers); and
5. Report results.
In assessing the results of interviews, we used descriptive statistics as appropriate. We
also verify the strength of key conclusions by using multiple data sources, with a
particular focus on any areas where initial data collection efforts and verification steps
appear to provide conflicting results. The remainder of this Chapter describes the
approach in more detail.
2.2.1 COLLECTION OF DATA FROM EXISTING DATA SOURCES
Evaluation Purpose 1 is informed primarily through new data collected in interviews of
key EPA personnel and individuals familiar with GR practices. Evaluation Purposes 2
and 3, however, rely on published literature as well as interviewee input. Additional data
sources also support the issues and perspectives identified in the interviews with EPA
personnel for Evaluation Purpose 1. These additional sources are organized into the
following four categories: Existing Surveys and Tracking Efforts, Footprint Analyses,
CLU-IN web use data, and Literature and EPA Publications. The subsections below
describe these categories of data sources in more detail.
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Analysis of Existing Surveys and Tracking Efforts
lEc analyzed the following EPA surveys and tracking efforts:
Region 3 Green Remediation 2009 Questionnaire:
The survey, which included 46 RPMs managing a total of 190 Region 3
Superfund sites, was conducted in 2009 prior to the release of the final GR
Strategy in September, 2010.1 Responses to the questionnaire provide information
on current GR practices being implemented at Superfund sites in Region 3 in
2009, and included:
o General GR status question for each RPM: Do you manage a site that
is using green remediation?
o Technical questions linked to specific topics (including some of the
GR Strategy's five core elements)
Stormwater control;
Wetlands;
Land use;
Recycling;
Energy; and,
Long-term stewardship.
Region 4 2010 Superfund Greener Cleanup Survey:
The survey, which included responses from 31 Region 4 RPMs, was conducted in
early 2010 and the summary of results was released in May 2011. The survey
goal was to identify what Greener Cleanup (using OSWER policy language)
activities are occurring in the region and what actions could be taken to help
personnel further implement Greener Cleanup techniques (e.g., trainings). The
survey responses provide a snapshot of the type of GR activities occurring in
Region 4 and which of the five core elements are being addressed. The survey's
questions were categorized by five "Principles for Greener Cleanup" that are
identical to the Strategy's five core elements. Questions under each element
included:
o Have you implemented this principle? (not verbatim)
o Reason for implementing principle?
o Did the principle play a role in the selection of a remedy?
o Did the principle affect the way the remedy was implemented?
o Did the principle affect post construction activities?
Additional questions at the end of the survey included:
1 A draft GR Strategy was released in September, 2009, and development of the final GR Strategy was ongoing and may have
influenced the Region 3 survey results.
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o Are you familiar with the EPA Region 4 Clean and Green Policy?
o Are you familiar with the Superfund Green Remediation Strategy!
Region 9 List of GR Activities: The Region 9 list reports GR activities taking
place at 21 sites in Region 9.2 The list does not address a specified time frame, but
the Region 9 respondent indicated that it was originally developed during 2010
and was updated prior to being sent to lEc in August 2011. The regional contact
noted that the table may not contain the most current activities occurring in the
region and that some of the sites are part of the Brownfields program. However,
the table provides information on the type of activities occurring in the region and
which of the five core elements are being addressed. The elements that appear to
be covered by the listed activities are:
o Air Emissions;
o Energy, and;
o Material Consumption and Waste Generation.
Additionally, the list notes two sites that have begun footprint/life cycle analyses.
2010 EPA Green Remediation Coordination Atlanta Workshop Surveys: The
October 19th-20th, 2010 workshop was intended to ensure consistency and
collaboration across all GR efforts (i.e., program specific and regional efforts).
EPA conducted two surveys in relation to this workshop in October 2010. The
first survey, dated October 15th, polled EPA Cleanup Program representatives
from programs and offices implementing GR strategies at contaminated sites (i.e.,
Superfund, RCRA, Brownfields) for their opinions, status, and suggestions on GR
in general. The second survey, dated October 27th, polled EPA regional
representatives (a majority from the Superfund program). The surveys included
questions such as:
Survey of Program Representatives
o Is there anything in your program that could be leveraged to help
move GR forward?
o Are there aspects of your program that could be obstacles to moving
GR forward?
o Do you have a GR training program?
Survey of Regional Representatives
o What is your region doing as part of implementing its regional "clean
and green" policy?
2 There are 22 activities listed in the table, but only 21 sites are included.
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o Does your region have a GR implementation plan?
o Is your region collecting any measures data?
o Are any of your project managers using any of the environmental
footprint calculator tools?
o Has your region implemented or conducted any kind of GR training?
The findings from these surveys and tracking efforts primarily support the analysis for
Evaluation Questions 1 through 5.
Footprint Analyses
lEc reviewed the following EPA footprint resources:
EPA's Footprint Methodology: EPA's "Methodology for Understanding and
Reducing a Project's Environmental Footprint" was released for public comment
on September 16, 2011. The document outlines specific guidelines and required
metrics for performing a footprint analysis at a contaminated site. The document
is organized by core element as identified in the GR Strategy. The methodology
acknowledges that there are other footprint analysis guidelines and tools that can
be used and also does not require RPMs to conduct a footprint analysis on all or
any sites. The methodology simply provides suggested guidelines and metrics to
use if applicable at a site.
Footprint Methodology Webinar: The "Greener Cleanups - EPA's Methodology
for Understanding and Reducing a Project's Environmental Footprint" webinar
was held on August 10, 2011. The primary purpose of the webinar was to update
the remediation community and other interested parties on the progress and intent
of the Footprint Methodology. The webinar discussed how EPA envisioned the
methodology would be used and clarified that it was not intended to be applied to
all contaminated sites. The presenters continued to walk through specific
examples for quantifying metrics on site and how to use the methodology as a set
of guidelines rather than a template or tool.
Case Studies: EPA has been developing 28 case studies of contaminated sites
where a footprint analysis, or part of a footprint analysis, has been implemented.
These case studies, titled "Profiles of Green Remediation" were last updated in
July 2011 and include basic information for which core elements were included in
the footprint analysis at each site. All of the 28 contaminated sites are not
specifically Superfund sites, but provide references for footprint analysis
implementation.
The findings from these resources were used to evaluate the overall progress of the GR
Strategy's footprint initiative and to identify potential metrics that could be used to assess
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the success of the GR Strategy. lEc used these resources primarily to support the analysis
for Evaluation Questions 6 through 9.
CLU-IN Web Use Data
lEc reviewed CLU-IN Web Use Data provided by EPA in September 2011. The data
included download statistics for specific GR Strategy resources (e.g., BMP Fact Sheets or
Greener Cleanups Contracting and Administrative Toolkit), attendance statistics for
trainings sessions and webinars, and general monthly access statistics for the GR CLU-IN
homepage ranging from September 2009 to August 2011. The findings from the CLU-IN
data primarily support the analysis for Evaluation Questions 1 through 5.
Literature and EPA Publications
Because implementation of the GR Strategy is ongoing, it was helpful to examine how
the Strategy has evolved from the draft issued in September of 2009 to the final GR
Strategy in September of 2010, through the updated Activity Tracking Chart released in
February of 2011. lEc collected and evaluated these documents to better understand how
the GR Strategy has progressed over this time period.
2.2.2 NEW DATA COLLECTION
After the initial review of key existing program survey data and the GR Strategy, lEc
conducted a number of telephone interviews to support this evaluation. lEc used the
interviews in two ways: 1) to provide central information on specific evaluation questions
(e.g., Questions 1 through 6); and 2) to investigate specific data questions from the
qualitative analysis of existing survey data.
The initial interviewees were selected through a targeted consultation process with key
OSRTI personnel. This approach ensured that key "thought leaders" and subject matter
experts across EPA regions were captured in the initial data collection. To gain an
understanding of current issues related to implementation of the GR Strategy, and to
begin the identification process for potential interviewees, lEc attended the 2011 National
Association of Remedial Project Managers (NARPM) Training Program held in Kansas
City, Missouri. While at NARPM, lEc solicited input from key EPA representatives to
make recommendations for interview candidates for the evaluation.
In total, lEc interviewed 28 individuals during the conduct of 24 separate interview
sessions (some sessions had multiple participants). lEc used survey data and program
information to craft the initial interviews with Regional GR Coordinators, and also to
identify data gaps, anomalies, and inconsistencies among responses which became the
focus of follow-on interviews. lEc conducted 10 interviews with GR Coordinators at the
regional level, and approximately four interviews with key GR Workgroup members. We
then conducted eight follow-on interviews. A list of the interviewees and copies of the
interview guides are provided in Appendices A and B, respectively.
The interviews were focused roughly as follows:
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EPA Staff
Superfund Green Remediation Regional Coordinators
o Interviews were conducted with at least one GR coordinator from
each region; with several respondents from Region 2 and Region 9.
o Interviews with GR Regional Coordinators addressed many facets of
GR Strategy implementation but focused primarily on Evaluation
Questions 1 through 6.
Subject Matter Experts and Key Regional Staff
o Five interviews targeted EPA staff and other contacts with specific
areas of expertise in implementing the GR Strategy. Specifically,
lEc interviewed two measurement specialists (one from Region 9
and a private sector contractor), one contract specialist from
Headquarters, one regional attorney, and one regional front line
manager. These interviews inform Evaluation Questions 5 through
9.
Green Remediation Workgroup Participants
o Four interviews with GR Workgroup participants were used to
follow-up and verify findings from analysis of existing survey data
and interviews of the GR Regional Coordinators, particularly to
inform Evaluation Questions 1 through 6.
Non-EPA Contacts
Other Federal Contacts
o One representative from the Army Corps of Engineers that partners
with EPA in GR efforts was interviewed, primarily to provide
insights into the extent to which the GR Strategy has been raising
awareness and changing practices outside the Agency (e.g.,
Evaluation Questions 1, 2, 4, and 5).
State Officials
o Two state officials were interviewed to supplement data collection
efforts for the Evaluation Questions 1 through 6, where data gaps
exist. Specifically, these interviews focused on the extent to which
the GR Strategy is supporting state GR efforts.
2.2.3 REVIEW OF PUBLISHED STUDIES AND EXTERNAL DATA
In addition to the interview effort, lEc relied on existing data and published studies as the
secondary sources of information to inform responses to several of the evaluation
questions. Specifically, Evaluation Questions 6, 7, 8, and 9 required the review of data
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related to baseline assessments and footprint analysis to draw conclusions about the
current focus of the GR Strategy. In addition, development of responses to a number of
other questions involved validating or expanding on data collected in interviews by
reviewing external, published information about GR activities. Below we outline a
number of key existing data sources and note the evaluation questions that they inform.
State and Regional Strategies
Many states and Regions have begun to integrate GR practices at some sitesin some
cases regional focus on GRpre-dates the publication of the Strategy. lEc collected and
analyzed state and regional strategies to better understand how EPA Regions are
implementing GR approaches and to understand the role that the GR Strategy is playing
in continuing these efforts. The data collected informs Evaluation Questions 2, 3 and 4.
SURF White Paper
In late 2007, the Sustainable Remediation Forum (SURF) initiated a study to collect,
clarify and express the experiences of SURF members on the incorporation of GR
principles. The white paper on "Integrating Sustainable Principles, Practices, and Metrics
into Remediation Projects" was published in the summer of 2009. Data collected from
this report informs Evaluation Questions 6 through 9. Because SURF membership is
primarily composed of corporate members in the United States, evaluation of this report
provides a private-sector perspective on GR practices.
Footprint Methodology and Case Studies
OSRTI has already undertaken a number of activities related to measurement of the
impact of GR on site footprints. The most comprehensive effort is the development of a
methodology for performing footprint analyses at NPL sites. The methodology was
released for public comment in September 2011, and is accompanied by 28 case study
sites with comprehensive or partial footprint analyses. lEc uses OSRTFs Footprint
Methodology and EPA's "Profiles of Green Remediation" case studies as primary data
sources to answer Evaluation Questions 6, 7, 8, and 9, coupled with information from the
life cycle assessment (LCA) literature and other published approaches to assessing site
footprints.
EPA Website Use Data
OSRTI currently tracks a number of website use indicators related to the CLU-IN website
and specific GR Strategy documents. lEc worked with EPA to review these data. EPA
website use data provides external validation for the interviews and primarily informed
Evaluation Questions 3 and 5.
Additional Data Resources: Site Profiles, etc.
lEc also performed a targeted review of other existing data sources (e.g., site profiles, and
footprint analyses and tools) that interviews indicated would be helpful to the evaluation.
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2.2.4 ANALYSIS AND INTEGRATION OF DATA COLLECTION EFFORTS
After collecting all of the data and information described above, lEc went through a
process to validate findings across multiple sources. The following bullet points outline
the data integration process used for each of the three Evaluation Purposes.
Evaluation Purpose 1:
o Collect primary data - Interviews with Regional GR Coordinators
o Review external data sources to refine, expand, and validate
findings from the primary data collection.
o Develop verified findings that integrate multiple data sources.
Evaluation Purposes 2 and 3:
o Review existing literature and program information.
o Interview subject matter experts based on information from
literature review and responses from the primary data collection.
o Validate and expand findings with information from Evaluation
Purpose 1.
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CHAPTER 3 | FINDINGS
This evaluation aims to explore the GR Strategy's progress to date in advancing greener
cleanup and to inform the program's priorities going forward. The evaluation considers
three main parameters: assessing EPA experiences to date in implementing the GR
Strategy; determining a baseline against which to measure EPA progress in implementing
the GR Strategy; and determining the best metrics for measuring the program's success in
implementing GR practices. As a formative evaluation of the national-level effort, this
evaluation is primarily a qualitative assessment of how well the GR Strategy program
activities and priorities are being implemented, based on information gathered from the
early phases of implementation of the GR Strategy.
This chapter summarizes the results of our analyses as outlined in Chapter 2. We organize
our results first by evaluation purpose, and then by the individual evaluation questions
pertaining to that evaluation purpose. For each evaluation question, we briefly note key
data sources and analytical approaches that are discussed in more detail in Chapter 2. We
follow the description of data sources with a discussion and tabulation of our findings
related to the question. The chapter concludes with a brief summary of general findings
for each of the three evaluation purposes.
3.1 EVALUATION PURPOSE 1: ASSESS EPA EXPERIENCES TO DATE IN
IMPLEMENTING THE CR STRATEGY
To assess EPA's experiences in implementing the GR Strategy, lEc relies on data
collected through interviews and other sources focusing on different aspects of the
implementation and integration of the GR Strategy across EPA and in the 10 Regions.
lEc designed this data collection effort around the following five evaluation questions:
Evaluation Question 1: 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)!
Evaluation Question 2: Which initial activities or initiatives from the GR
Strategy have been most effective in increasing awareness, adoption and/or
implementation of the GR Strategy!
Evaluation Question 3: How do Remedial Project Managers (RPMs) factor the
GR Strategy into their approach to planning site cleanup?
Evaluation Question 4: What effect has the GR Strategy had on the practice of
using green remediation techniques at Superfund sites?
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Evaluation Question 5: What lessons have been learned as a result of
implementing the GR Strategy at sites?
As described in more detail in Chapter 2 - Methodology, the primary findings for this
purpose reflect insights collected directly from designated GR coordinators and other
staff actively focusing on implementation of GR in each of EPA's ten regions. These
contacts represent the staff most clearly aware of the GR Strategy and its use. To verify
and expand on the initial findings for each question, we present relevant information
obtained from additional interviews with EPA managers, legal staff, and other contacts
specializing in certain areas of GR implementation, as well as data tracking the use of the
CLU-IN website, several surveys, and a site characteristic tracking database being
developed by Region 2.3
3.1.1 SUMMARY OF FINDINGS
Overarching findings related to Evaluation Purpose 1 are as follows:
Respondents are generally positive about the GR Strategy structure and purpose,
though some difference of opinion exists on how best to present "goals" and
objectives. Several respondents feel that a more clearly defined statement of goals
could be useful both in increasing awareness of the GR Strategy and in focusing
GR Strategy implementation. A key interest is ensuring that GR efforts maintain
momentum in the implementation phase.
Interview respondents have strong, positive views of many key products of the GR
Strategy, and feel that these tools and products have been important in facilitating
an expansion of GR activities. Respondents are less able to connect the Strategy
itself to site-level actions, and report a limited awareness of the document.
However, respondents agree that the release of the GR Strategy has reached many
decision-makers and has facilitated GR by raising its national profile.
RPMs typically do not use the GR Strategy directly in GR implementation, though
they document use of many of the tools associated with the CLU-IN web site and
other GR Strategy products. Respondents consider the GR Strategy document
itself as a more important tool for managers than for RPMs.
It is difficult to identify specific changes in practice associated directly with the
GR Strategy, due in part to the limited time that has elapsed since publication, and
in part to the fact that other factors such as regional strategies and costs savings
also contribute to GR efforts. The national GR Strategy and regional policies
(e.g., "clean and green") influence each other, and it is therefore difficult to
attribute influence to each separately. However, regional data from surveys does
provide a snapshot of activities underway, and suggests regions have increased
emphasis on GR training and outreach as the GR Strategy has emerged.
5 Data were provided by Environmental Management Support (EMS) on August 18, 2011.
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A range of challenges face the broader implementation of the GR Strategy, with
key concerns including the level of funding and support for GR Strategy personnel
and project efforts. Other broader hurdles include a concern about policy and
liability uncertainty, and limited participation from managers and other key staff.
One overall concern raised in different contexts is the need for momentum and
Headquarters signaling about commitment to GRto ensure that progress
continues.
Below we document the more detailed findings for each of the five questions contributing
to Evaluation Purpose 1.
3.1.2 Evaluation Question 1: Does EPA have clearly defined goals and
objectives for the CR Strategy? Should they be refined and improved
to enhance usefulness (e.g., for management decision making,
planning and budgeting, EPA's Strateg/c Plan)?
This general question presented a challenge for interview respondents because the GR
Strategy is organized around three purposes (policy and guidance development, resource
development, and program implementation). Within those purposes are nine key actions
and 40 specific actions, but the GR Strategy does not present a separate, specific set of
goals. In addition, interview participants preferred different definitions of the term "goal"
- with some focusing on measurable, timed objectives and others focusing more broadly
on strategic priorities.
To encourage open-ended input in the interviews, lEc did not provide a specific definition
of GR Strategy goals and objectives for the respondents, but discussed respondents'
perceptions of the Strategy's overall goals in the context of the purposes and key actions.
The following are brief summations of respondents' answers to the general question of
whether EPA has clearly defined goals and objectives for the GR Strategy:
Respondents in four of nine Regions that addressed this question find the GR
Strategy goals and objectives to be fairly well-defined. However, three of these
respondents voiced concerns about the inclusion of aspirational and unachievable
goals, and all of these cited the target of 100 percent renewable energy (RE) on
Superfund sites as an example of an aspirational goal.4 One regional respondent
expressed concern with the purchase of renewable energy credits (RECs) as a way
to achieve this goal and noted that it can be difficult to ensure the quality of the
RECs being purchased. These respondents explained that aspirational goals,
which they believe are clearly unattainable, could deter from the overall
4 EPA's Office of Solid Waste and Emergency Response (OSWER) is in the process of making a national bulk REC purchase to
achieve the goal of powering site operations with 100 percent renewable energy. A REC is a certificate that represents the
generation of one megawatt-hour (MWh) of electricity from an eligible source of renewable energy. The purchase of RECs
facilitates the development of the renewable energy market. OSWER believes a bulk REC purchase to be the most
immediate and cost-effective way to power all Superfund sites with renewable energy.
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implementation and integration of the Strategy and GR in general. Respondents
indicate that there is some difference of opinion whether RECs are equivalent to
installation of renewable energy projects at specific sites.
Respondents from two regions stated that while the GR Strategy goals and
objectives are somewhat well defined, most regional staff, including RPMs and
front line managers, are not aware of the goals. One respondent suggested that
EPA HQ should focus on spreading awareness and educating regional staff on the
goals and objectives of the GR Strategy.
Finally, respondents in three regions felt that the goals and objectives of the GR
Strategy should be more clearly indicated and defined. When the question was
posed, these respondents were unable to answer with confidence that they were
aware of or could clearly identify the goals and objectives of the GR Strategy. All
of these respondents felt that this might indicate a challenge for ensuring that the
Strategy would be implemented, and that an effort to identify goals and objectives
could provide momentum to the program.
In addition, some respondents provided the following insights and suggestions for
improvement to the GR Strategy goals and objectives:
Two respondents noted that their lack of familiarity with the goals and status of
the GR Strategy is a result of their relatively "low profile" in contributing to GR
Strategy activities since the publication of the document. Both noted that the
general purpose of the GR Strategy and the key actions are well crafted, but they
had not remained informed about progress in implementing key actions. They
focused their comments on the difficulty in maintaining momentum to implement
changes after milestones like GR Strategy publication.
One respondent suggested that EPA HQ should provide a summary document
(fact sheet) laying out the goals and objectives of the GR Strategy in a more
concise manner. They felt that people would be more willing to become familiar
with a short concise document rather than a long document. Summarizing key
goals and objectives in a more manageable format could help meet a broader
method to ensure effective outreach and education. Two respondents felt that EPA
should reconsider and restructure the goals and objectives. Primarily, EPA should
reduce the number of unachievable goals and replace them with more realistic
objectives. Goals cited most often as particular examples of this are the aim to
provide 100 percent renewable energy (RE) on all Superfund sites, and an aim to
reduce impacts on land use and ecosystems.
To complement the input from the regional coordinators, lEc reviewed written documents
on GR Strategy implementation and survey responses from Regions 3 and 4. We also
asked technical expert interviewees for feedback on this question. However, only the
regional coordinators had any specific knowledge of or insights into GR Strategy goals.
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Most respondents, including the regional coordinators, did say that the general focus of
the Strategy and the key actions identified were appropriate and well-designed. Overall,
the lack of awareness of goals does not appear to indicate any negative impressions of the
GR Strategy itself but instead appears to suggest a challenge in implementation.
Additionally, an underlying theme identified in responses to Evaluation Question 1 is the
need for more momentum surrounding the GR program and GR Strategy specifically.
Respondents explained that Headquarters clearly defining the goals of the GR Strategy
could reenergize the program and benefit the Strategy's integration into Superfund
Program site cleanup culture.
3.1.3 Evaluation Question 2: Which initial activities or initiatives from the
CR Strategy have been most effective in increasing awareness,
adoption and/or implementation of the CR Strategy?
Key respondents to this question were the Superfund GR Regional Coordinators. While
not asked directly, interviews of non-EPA contacts provided verification of regional
responses to this question. Data on participation in training sessions and on use of
resources on the CLU-IN web site also provided a second important source of
information.
An initial finding of significance is that Regional GR Coordinators focus on different
aspects of "awareness" as it relates to the GR Strategy. To some, the question considers
visibility of specific products that have been developed through implementation of the
GR Strategy (i.e., CLU-IN website and BMP fact sheets). Others focused on awareness of
the GR Strategy as a document and policy implementation exercise. Finally, one
respondent discussed the success of the initial development of the GR Strategy as an
exercise that increases awareness. Detailed insights include:
Key Products
All respondents stated that the most visible and successful manifestation of the GR
Strategy is the set of products presented on the CLU-IN web site. Respondents noted five
specific products in identifying effective activities that facilitated GR implementation:
BMP Fact Sheets
NARPM Trainings
Case Studies (any examples of success are helpful)
CLU-IN Website as a total resource
"Doughnut of Remedy Implementation" (as referred to by respondent)5
5 The "Doughnut of Remedy Implementation" refers to the graphic of the OSWER five core elements presented on p.2 of the
GR Strategy document.
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Exhibit 3-1 below summarizes graphically, the number of regional respondents that cited
each product as being useful to GR awareness and implementation in their region.
It is noteworthy that the interview questions did not include or prompt a specific
discussion of GR Strategy products. Respondents readily and quickly identified the set of
products as a critical resource in expanding the use of GR approaches, and expressed very
positive opinions of the quality and focus of the BMPs in particular.
We were unable to confirm these responses with the CLU-IN Website use data due to
limited available data.6 However, the CLU-IN use data do indicate that the website and
products of the GR Strategy are referenced and used by EPA, other government
organizations, and third party individuals/companies.7 We summarize the EPA CLU-IN
use data in the Exhibit 3-2 below:
EXHIBIT 3-1. PRODUCTS IDENTIFIED AS USEFUL IN FURTHERING ADOPTION OF GR PRACTICES
Useful GR Strategy Products
E
Q.
§3
01
l/l
cc
(3
BMP Fact Sheets
NARPM Trainings
Case Studies
Cluln Website
Remedy Implementation Doughnut
0123456789
Number of Regions Citing Product
6 EPA's contractor for documenting CLU-IN use, has explained that the download data do not account for copies of the
documents distributed via email or hard copy distribution. Additionally, the EPA training data may not fully capture all
participants for online trainings because multiple users could access the training via a single user ID.
7 Non-EPA interview responses confirm this.
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EXHIBIT 3-2. CLU-IN WEBSITE DOWNLOAD AND PARTICIPATION STATISTICS 8'9
o
£
QC
Use of GR Products on CLU-IN Website
Total NARPM Training Attendance
O
gj> Total BMP Fact Sheet Downloads
Total Contracting Toolkit Downloads
k. Average NARPM Training Attendance
(Average per Training)
Average Downloads of Each BMP Fact
Sheet (Average per Fact Sheet)
D Other(Non-EPA
Participants
EPA
0 100 200 300 400
Number of Participants or Downloads
EPA also provided data on downloads of the BMP Fact Sheets' release schedule
("Upcoming Topics" PDF on CLU-IN website). The data is as follows:
EPA: 14 Downloads
Other Government: 5 Downloads
Non-Government: 413 Downloads
These data suggest that individuals maintain interest in the other topics that will be
covered by future BMP Fact Sheets and actively check the proposed release schedule.
In addition to the NARPM trainings, as presented above, EPA provided participation
statistics for CLU-IN web seminars and "On-Scene Coordinator (OSC) Readiness"
training sessions. Although the data do not support definitive conclusions about total use
ofGR Strategy materials, the information does demonstrate that EPA staff are actively
participating and seeking out GR Strategy-based information. The most heavily EPA
attended CLU-IN web seminars were:
8The "total" values in the table are all inclusive (i.e., Total NARPM Training Attendance is the total attendance for all
NARPM trainings).
9 For NARPM trainings, the "EPA" category represents only RPMs and the "Other" category represents all other participants
at the trainings including either EPA staff and non-EPA government and private sector staff.
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"Your Role in Green Remediation Implementation and Case Studies in Green
Remediation - This Year's Models and Tools"10 - Specifically the first of three
sessions held on December 8, 2010 (EPA had 80 identified participants).
"Green Remediation: Applying Strategies in the Field"11 - Specifically the first of
three sessions held on October 8, 2009 (EPA had 53 identified participants).
The data for NARPM trainings show that the first three GR NARPM trainings had the
best in-person RPM attendance. These trainings are:
"Green Remediation: Opening the Door to Field Use." July 9, 2008 - 43 RPMs
were identified at this training.
"Green Remediation - What's Next." June 3, 2009 - 30 RPMs were identified at
this training.
"Your Role in Green Remediation Implementation and Case Studies in Green
Remediation: This Year's Models and Tools." May 26, 2010 - 35 RPMs were
identified at this training.
Although the trend in NARPM attendance does not necessarily suggest a decrease in GR
momentum, the CLU-IN use data does not show big growth in NARPM attendance that
would demonstrate a clear expansion of interest and awareness. The lack of growth in
NARPM attendance is difficult to interpret: it could be indicative of increased regional
trainings, an increased saturation of trained RPMs, or that interest in GR is stabilizing.
Additionally we note that these values may understate participation at these events
because multiple users can register/view a webinar training presentation under a single
ID. Regional respondents noted that that some regions held NARPM training webinar
sessions in-house and therefore may have used only one registration ID.
EPA has not to date tracked use statistics for the 28 case studies (Profiles of Green
Remediation) listed on the Superfund GR CLU-IN website, but this could be tracked in
the future.
Finally, although not a target audience, non-EPA individuals have expressed a positive
reaction to the GR Strategy's products. These respondents cited several of the same
resources have been useful in informing their organizations' GR initiatives and staff.
Awareness of GR Strategy
While GR Strategy products are well-known, respondents in three regions noted that the
GR Strategy itself is not well known or used by regional staff such as RPMs. Several
respondents also noted that regional policies (i.e., GR, Greener Cleanup, or Clean and
Green) appear to have higher profiles in triggering individual staff interest in exploring
greener cleanups.
This was a follow-up web seminar to a 2010 NARPM GR session.
1 This was a follow-up web seminar to a 2009 NARPM GR session.
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In a related finding, respondents in all regions emphasized that "awareness" of GR as an
option is complicated because GR is often "common sense," and many RPMs would
likely implement cost saving actions at their sites even without the national GR Strategy
(and possibly without regional policies). However, respondents felt that the publication
of the GR Strategy has generally raised the national profile of GR and contributed to
interest in the subject.
Interviews with front line managers confirmed these findings and noted that during the
development of the GR Strategy, they observed a growing interest in learning to
implement GR. However, the managers noted that after the release of the final document,
they witnessed a clear decrease in "buzz" surrounding the initiative.
Data on the number of visits to the Superfund GR CLU-IN webpage generally confirm
the insights shared by front line managers. The data span the time frame from September
2009 to August 2011. The following charts (Exhibits 3-3 and 3-4) present trends in the
monthly data. Exhibit 3-3 depicts the number of estimated visits per month, while Exhibit
3-4 depicts the percentage of visitors making repeat visits. Both charts include a line of
best fit to depict the general trend over time. In Exhibit 3-3, the spike in monthly visits in
October 2010 corresponds with the release of the final GR Strategy document. Other
spikes in the data typically correspond with the release of the different BMP fact sheets.
Currently the data do not allow examination of trends of unique visits or visitors over
time.12
EXHIBIT 3-3. CLU-IN WEBSITE MONTHLY ESTIMATED VISITS
Estimated Visits
12 EPA does not track data by individual, which currently limits the use of this analysis. However, if desired, it may be
possible to implement tracking by individual in the future, assuming that no policy or legal restrictions exist.
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EXIBIT 3-4.
CLU-IN WEBSITE MONTHLY VISITOR REPEAT RATE
Visitor Repeat Rate (%)
jS> $> ^ ^
Exhibit 3-3 indicates an overall downward trend in monthly visits to the CLU-IN website
implying that the website is getting used less over time. This observation echoes the
concern raised by interview respondents that the GR Strategy implementation could
potentially lose momentum. However, Exhibit 3-4 shows that the estimated monthly
visitor repeat rate is trending upward over time. This suggests:
The population of prior users is increasing over time as GR is more broadly
considered, and;
Individuals that have previously viewed the CLU-IN website are returning to
the website, which may imply that it is a valuable resource to users.
One caveat of the EPA CLU-IN Website Use Data is that it may not accurately report
EPA staff awareness of the GR Strategy and its products (i.e, trainings and BMP Fact
Sheets) because the web site is not the only source of information. EPA's Intranet website
contains some of the same information found on the CLU-IN website, and the GR
workgroup regularly distributes products by e-mail. Although not conclusive in and of
itself, the downward trend in monthly CLU-IN website visits, as depicted in Exhibit 3-3,
echoes insights from the interviews with Regional GR Coordinators and other EPA staff
that a general need for more focus on the program's objectives and goals might help
increase GR awareness and momentum.
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3.1.4 Evaluation Question 3: How do Remedial Project Managers (RPMs)
factor the CR Strategy into their approach to planning site cleanup?
To answer this question lEc relies principally on responses from GR Regional
Coordinators, and supplements and verifies that information with data from regional
surveys. In general, responses to this question were consistent. Key themes are:
RPMs do not typically use GR Strategy. Respondents from eight regions
explained that RPMs do not specifically consider the GR Strategy in their
approach to planning a site cleanup. Respondents noted that this is not equivalent
to saying that RPMs do not consider GR in their cleanups. Instead, RPMs often
use regional green cleanup policies as a guide to implement GR techniques rather
than the GR Strategy itself. Respondents believe that RPMs, at most, only have a
general familiarity with the GR Strategy, unless they were involved it its
development through the Superfund GR Workgroup.
GR Strategy is and should be more of a tool for management. Respondents also
noted that they do not expect RPMs to take time to consult the GR Strategy during
the remediation process. Additionally, three respondents specifically noted that
they view the GR Strategy as a guide for management and do not think that RPMs
need to be familiar with the document itself. This sentiment was also shared by
non-EPA GR specialists. Respondents explained that the GR Strategy document is
very helpful, but as an internal strategy. They felt that the document was too
technical and prescriptive to be used as a site-level resource for implementing GR
practices.
GR Strategy has been successful in raising general awareness among RPMs.
Although respondents do not feel RPMs are factoring the GR Strategy directly
into their site cleanup plans, they do believe that the GR Strategy publication has
increased overall awareness and interest in GR among RPMs. These respondents
believe that the development of the GR Strategy, at the least, has resulted in more
RPMs considering GR in the remediation process. All respondents said that their
regions have facilitated some form of training in connection to the GR Strategy.
Although the EPA CLU-IN data cannot inform whether GR activities and
techniques are being implemented and used by RPMs, it does confirm that RPMs
and EPA employees have been actively participating in trainings and downloading
materials from the CLU-IN website, as discussed in Evaluation Question 2. Based
on the NARPM attendance data, it seems that RPMs have been most interested in
learning about basic integration of the GR Strategy and more specifically
information on "Pump and Treat" technologies.
Responses to Evaluation Question 3 noted that it is still relatively early in the
implementation and integration of the GR Strategy. Although RPMs may be currently
involved in GR activities, it is not always the case that they classify their efforts as GR.
This suggests that awareness of GR practices is increasing, but as respondents explained,
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individuals are referencing multiple GR resources aside from the GR Strategy and its
products. The following sub questions provide further insight into RPMs current level of
GR awareness and the type of GR activities currently occurring:
What GR practices are being implemented?
Interview Data
While six, of the nine respondents that addressed this question, were able to
provide one or two examples of specific green remediation activities currently
occurring at sites in their regions, these respondents indicated that GR practices
are not tracked formally. Several respondents cited specific projects that
identified energy or material savings opportunities, but noted that these activities
are attributable to one or more factors other than the GR Strategy (e.g., regional
policies, individuals' interest in GR and site optimization, or cost reduction).
While most respondents answered this question at the site level, interview
responses on other questions revealed that all regions are considering or
implementing at least one program-level change to encourage GR, with activities
such as training and implementation of contract language specifying GR.
In the remaining three regions, some GR activity tracking effort is currently
underway. Each tracking effort varies in period of time and level of detail. The
results of these tracking efforts are summarized below.
Region 4 2010 Survey Data
Early 2010 survey results (released in May 2011) of RPMs in Region 4 provide a
snapshot of the activities in use at sites in that region, and reveal that GR-related
activities are not uncommon. However, survey responses echo interview
responses in noting that the specific role of the GR Strategy is not always clear. A
majority of respondents in Region 4 that reported implementing GR activities at
their sites did not feel that explicit consideration of the five core elements had a
significant role in selecting or implementing a remedy. However, 90 percent of
the RPMs that responded to the Region 4 survey were familiar with the GR
Strategy.13
Although not attributed to the Strategy or the five core elements, some activities
that can be considered GR and are being implemented in Region 4 include:
o Total Energy Use and Renewable Energy Reuse:
(12 of 31 respondents, or 39 percent)
Consider use of optimized passive-energy technology
Look for energy efficient equipment
5 Note that self-selection bias may be significant here, if only interested RPMs chose to respond to the survey.
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Maintain equipment at peak performance
Consider installing renewable energy systems
o Air Pollutants and GHG Emissions:
(14 of 31 respondents, or 45 percent)
Minimize use of heavy equipment
Use cleaner fuel
Minimize dust export of contaminants
o Water Use and Impacts to Water Resources:
(17 of 31 respondents, or 55 percent)
Minimize fresh water consumption
Maximize water reuse
Prevent impacts to water quality of nearby water bodies
Erosion prevention
o Materials Management and Waste Reduction:
(19 of 31 respondents, or 56 percent)
Use technologies to minimize waste generation
Reuse materials
Recycle waste materials
o Land Management and Ecosystem Protection:
(16 of 31 respondents, or 52 percent)
Use minimally invasive technologies
Use passive energy technologies
Minimize habitat disturbance
Region 3 2009 Survey Data
The survey responses were from 46 RPMs from Region 3 about activities at 190
sites in that region, and only 2 RPMs reported using GR techniques at some of
their sites. However, some techniques reportedly being used by RPMs could be
considered GR even if the RPM did not classify it as such. These activities
include, but are not limited to:
o Stormwater Control - about 50 sites reported some form of
stormwater control with 23 percent using vegetative swales;
o Minimize Water Use - about 10 percent of sites reported
minimizing water use; and
o In-Situ Technology - 39 to 45 percent of sites with a ground water
component reported using In-Situ technology rather than traditional
pump and treat.
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Region 9 List of CR Activities
The Region 9 list of GR activities reports the activities for 21 sites in the
Region.14 The list does not include dates, but provides a brief description and the
current status of each activity. Exhibit 3-5 below summarizes the information
reported in the Region 9 list.
EXHIBIT 3-5. SUMMARY OF REGION 9 LIST OF GR ACTIVITIES
GR ACTIVITY
CATEGORY
Renewable Energy
Footprint/Life Cycle
Analysis
Clean Diesel/Bio-
Diesel
Burning Landfill Gas
Other
GR STRATEGY COKE
ELEMENT
Energy
N/A
Air Emissions
Material Reuse and
Waste Generation
N/A
NUMBER OF
SITES
15
3
1
1
2
STATUS OF ACTIVITIES
8 - In Process
7 - Operational
1 - Planning/Not
Feasible
In Process
Completed
Operational
Operational
Overall, responses and survey data reveal that most regions have some GR activities
occurring. During interviews, however, only two regional respondents (Region 2 and
Region 9) identified use of GR as routinely implemented. Additionally, Regions 3 and 4
survey data reveal a high level of GR activity taking place, as well. However, the
majority of RPMs in these regions are not considering their activities as GR. In the
remaining regions GR activities are in developmental stages, and it does not appear that
RPMs specifically incorporate the GR Strategy itself into decision-making, though they
appear to access materials and projects.
What percentage of RPMs are implementing specific GR practices?
Regional responses to this question ranged across regions, with respondents estimating
that as few as 10 percent to as high as 90 percent of RPMs are aware of GR practices and
implement them where they can.15 However, most responses were concentrated at the
lower end of this range, indicating that awareness and use of GR practices is still limited
in many regions.
The 2009 Region 3 survey results show that four percent of the respondents are
implementing GR. Note that these results only reflect activities that the respondent
considered GR at the time of the survey. Survey results from Region 4 do not lend
M One site is listed twice for two separate GR activities.
15 Not all sites have opportunities for GR and there may by RPMs that cannot conduct GR because of that.
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themselves to this computation. However, the "principle" with the highest activity
percentage was "Materials Management and Waste Reduction" with approximately 60
percent of respondents conducting some related activity in Region 4.
Some of the variability across regions could be attributed to respondents' interpretation of
GR practices. This issue is prevalent in the Region 3 survey results. As discussed in the
prior sub-question, only two RPMs (managing 3 sites) out of 46 (190 total sites) reported
implementing GR techniques. However, although RPMs did not classify their
remediation activities as such, several reported activities could be considered GR.16
It also appears that regional responses could be significantly influenced by the existence
of regional green cleanup policies prior to the release of the GR Strategy, and by regional
specific characteristics such as the level of senior management involvement in GR. lEc's
analysis of the interview data reveals that regions with Greener Cleanup or GR policies
established before the national GR Strategy typically reported higher percentage of RPMs
involved with GR activities.
What do RPMs know about the energy usage at the sites they manage?
All respondents agreed that information on energy use is available for Fund-lead sites,
though it is not routinely collected and tracked, except in Region 2. However, for other
categories of sites, a majority of regions explained that the availability of information
varies by site and the RPM in charge of the site. Respondents from six regions noted that
tracking energy use is becoming more important, and several also noted that the national
REC purchase policy has increased the profile of energy use. Specifically, some RPMs
are voluntarily trying to track their consumption of energy to assist the national effort.
At the regional level, interviews for this evaluation and the 2010 Survey of EPA Regional
Representatives following the Atlanta GR Coordination Workshop confirm that only one
region routinely tracks and measures energy consumption. However, Region 2 has
received funding from HQ to develop a tracking database that could then be used by all
RPMs to track energy consumption and the other core elements at their sites.17 The
database would require RPMs to report sites' monthly energy usage. If implemented
broadly, the database could provide information for national tracking.
What information do RPMs track on other GR core elements?
Respondents from nine of the regions report having the ability to track some information
on the other core elements identified in the GR Strategy. However, for the most part, very
little is currently tracked and quantified. RPMs most often track energy consumption, as
16 Another factor limiting the use of GR is the limited number of sites that are at appropriate stages of remediation for
considering GR. This was noted by several respondents but is not directly linked to the GR Strategy itself.
17 The database was created to collect and compile data in Region 2 related to the implementation of the regional Clean and
Green Policy and not the national GR Strategy. The Region 2 Clean and Green touchstone practices only address three of
the five core elements of the GR Strategy (energy, air emissions, materials and waste).
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mentioned above, as well as material use and recycling, waste management, and air
emissions. Only one respondent mentioned that the region tracks water use metrics.
Respondents noted that not all sites have opportunities for using GR practices, so limited
opportunities exist for tracking implementation at sites.
The Region 2 database that is currently under development would track metrics related to
the Region 2's 2010 Clean and Green Policy. Although the database, in its current state,
does not require RPMs to report information on all five core elements, several site
specific data will be available. More specifically, in addition to energy use, the database
will require RPMs to report the following information for their sites:
Clean Diesel:
o Type of Equipment being used on site
o Fuel Volume of total fleet of equipment
o Total number and type of retrofits on equipment
o Usage rate of equipment
Material Reuse, Reduction, and Recycling:18
o Amount of materials reused
o Amount of materials reduced
o Amount of materials recycled
o Amount of materials landfilled
o Amount of materials combusted
o Amount of materials composted
Respondents to the 2010 Survey of EPA Regional Representatives following the Atlanta
Workshop confirmed that the database was designed to address four core elements, and
did not include the land and ecosystems core element.
In responding to these subquestions and other evaluation questions, two cross-cutting
themes from the interviews emerged. First, respondents from all regions expressed
concern that any significant requirements to track GR impacts could potentially reduce
interest among RPMs. As discussed in more detail in Question 5, limited resources (e.g.,
time, manpower) represent a significant challenge in GR implementation. As an example
of this, one respondent emphasized that RPMs do not require metrics to do their job
successfully and therefore it is more difficult to get people to track these sorts of metrics.
Respondents recommended developing a simplified universal system to assist the metric
tracking effort, which could also be tied to performance reviews.
8 Note that this information will be reported by material type (i.e., aluminum cans, glass, food scraps etc.'
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In addition, a review across regional responses reveals that many regions appear to focus
on one aspect of the GR Strategy at one time. One respondent remarked that taking this
approach to implementation would allow the Strategy to move further without spending
time "reinventing the wheel." Respondents from different regions noted identifying and
implementing renewable energy efforts (either through the REC purchase or generation
on site), waste reduction and management, and reduction of air emissions through the use
of newer technology and clean diesel as specific regional areas of interest. This practice
may be important in considering national-level tracking options and coordination efforts,
and may limit the practicality of tracking multiple indicators at all sites.
3.1.5 Evaluation Question 4: What effect has the CR Strategy had on the
practice of using green remediation techniques at Superfund sites?
Consistent with Question 2 responses, most respondents across regions could not identify
or attribute specific changes in regional practice to the GR Strategy. In general,
respondents thought that the GR Strategy has been most successful in refocusing and
defining GR. They explained that it has provided some momentum to the GR effort and
has assisted in spreading awareness of GR, but they noted three factors that complicate
the identification of specific activities with the GR Strategy:
Not enough time has elapsed: Respondents generally felt that it is "too soon" to
see significant impacts of the GR Strategy. They believe it has had a general
positive impact, but ongoing site efforts typically started before its publication.19
Focus on regional policies: Regions that have a GR policy stated that their
RPMs refer to these regional policies rather than the GR Strategy. The BMP fact
sheets and CLU-IN website, rather than the GR Strategy itself, have been useful
guides for RPMs when attempting to implement GR principals. Respondents from
three regions also asserted that the GR Strategy has not impacted regional practice
because the region was involved in GR activities prior to the final GR Strategy.
Attribution poses challenges: Two respondents felt that GR is generally common
sense, and it is difficult to attribute any changes in activities to the GR Strategy or
to regional strategies because some RPMs would be implementing or exploring
GR activities and opportunities even without the policies in place.
The surveys conducted in Region 3 and 4 in 2009 and 2010, respectively, are consistent
with these responses.20 As discussed in Evaluation Question 3, very few RPMs in Region
3 report that they are implementing GR activities in the survey responses. However, the
19 Due to limited tracking of GR practices within regions it is difficult to assess which activities were implemented prior to,
during, and after the development of the draft and final GR Strategy.
20 The Region 2 database and Region 9 list of GR activities do not report the reason (i.e., regional policy or national strategy)
for implementing specific GR techniques at sites, but Region 2 states specifically that the database is intended to track
data related to the series of touchstone practices outlined in their regional Clean and Green Policy. Region 9 does not
provide such a distinction.
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Region 3 survey was completed prior to the publication of the GR Strategy and therefore
does not specifically address the role of the Strategy. Similarly, a majority of Region 4's
respondents who are implementing GR activities do not attribute those activities to the
GR Strategy or its five core elements. Again, because the survey was completed several
months prior to publication of the final GR Strategy, it is not unexpected that impacts
would be limited.
Responses to the 2010 Survey of Regional Representatives following the GR
Coordination Workshop did identify several activities underway to implement GR in their
regions. Although the survey responses do not specifically link activities with the GR
Strategy, these activities represent an increased awareness and interest in GR practices at
the time of publication. Key examples of the activities identified include:
GR Trainings;
Focus on site-specific opportunities for renewable energy development;
Development of RPM guidance documents and checklists;
Development of websites with links to resources and contact information for
experts; and,
Added GR language to contracts.
The CLU-IN website use data generally confirms the statement that the GR Strategy has
been successful in increasing overall GR awareness and providing momentum to GR
efforts. As was discussed in Evaluation Question 2, a large (over 20 percent) increase in
CLU-IN site visits in October 2010 corresponded with the release of the final GR
Strategy document. However, this level of activity later dropped back to the August level
of visits, which suggests a decrease in momentum.
Training and Awareness
Interview respondents echoed the Region 4 2010 survey results in the key area of
training. While most respondents did not attribute specific changes in practice to the GR
Strategy, all regions report taking part in or delivering some form of GR training and/or
GR outreach. Regional GR training is a key action under the GR Strategy, and represents
a change in regional practice. The trainings and outreach identified by regions include:
Development of a regional GR Website
Brownfields conference
Regional facilitated GR trainings
GR sessions and speakers during regional meetings and green seminars
CLU-IN web seminars: (3,863 participants across 22 sessions, including 623 EPA
participants and 1,013 Other Government participants)
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NARPM webinars and trainings: (323 total participants across six sessions,
including 157 RPM participants)
OSC readiness trainings: (105 total participants across three sessions, including 45
OSC participants)
Although data do not document trends in participation or overall RPM or OSC
participation percentages, participation and interest among EPA staff continues.
3.1.6 Evaluation Question 5: What lessons have been learned as a result of
implementing the CR Strategy at sites?
This question had two distinct themes. Respondents were asked to discuss the general
themes and lessons that they've gained from their experiences with GR and specifically
with the implementation of the GR Strategy. They were also asked a specific set of sub-
questions related to challenges and opportunities in connection to the GR Strategy.
Notably, respondents had difficulty drawing broad conclusions from their experiences
implementing the GR Strategy. Specifically, seven often respondents could not cite
specific lessons learned from implementation. This limitation appears to reflect the fact
that some regions are in the early stages of implementing GR into site and regional
practices. The insight in Evaluation Questions 3 and 4 that it is too early to document GR
Strategy impacts is consistent with the reticence in identifying broad lessons.
Three respondents with broad insights about GR implementation shared the following:
GR is not always more expensive;
What may work at one site may not work at every site; and,
Working through the challenges and limiting factors has been a learning
experience.
These insights are echoed and expanded in an Association of State and Territorial Solid
Waste Management Officials (ASTSWMO) document that explained state experiences
implementing GR.21 The document provides a short summary of seven common
misperceptions about green remediation, along with a rebuttal for each, including: 1) GR
is an additional regulatory burden that agencies will have to impose on projects and
responsible parties; 2) GR will divert resources from our primary responsibility of
protecting human health and the environment from releases of petroleum and hazardous
substances; 3) cleanup is already green. There is no need to change our approach; 4) GR
will cost more; 5) the benefits or trade-offs of different GR approaches are too difficult to
assess; 6) responsible parties will use GRto argue for doing no remediation at all; and, 7)
we don't have the authority to do green remediation.
21 In September 2009 as the draft GR Strategy was released for public comment, the Greener Cleanups Task Force of the
Association of State and Territorial Solid Waste Management Officials (ASTSWMO) Sustainability Subcommittee released the
Green Remediation: Getting Started by Debunking Some Myths document noting a number of lessons learned and popular
challenges related to green remediation.
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In response to the specific questions about issues or factors affecting the implementation
and integration of the GR Strategy, and GR in general, in their regions, respondents had
much more to discuss. The responses are organized by sub-question below.
What factors affect the ability to implement the GR Strategy at sites (e.g.,
technical issues, cost issues, legal issues, management support, contract
provisions, or contractor capabilities)?
Each regional respondent cited a different mix of factors affecting their ability to
implement the GR Strategy or GR in general. Key factors included limited resources,
limited staff time (including lack of dedicated staff time), costs associated with assessing
sites, concerns about legal authority, lack of clear policy addressing some circumstances,
and limited support from management, legal staff, and contractors.
Exhibit 3-6 below identifies the key factors (challenges) mentioned by respondents and
the number of respondents that cited each factor.
EXHIBIT 3-6. KEY CHALLENGES TO IMPLEMENTATION OF THE GR STRATEGY
Challenges Facing GR Strategy
01
OB
01
15
.c
u
Time
Legal
Policy
Resources
Costs
Technical
Attitudes/Education
Contracts
Management Support
1234
Number of Regions Citing Challenge
How is integration of the GR Strategy priorities (e.g., policy guidance, training,
and tools) affected by the above factors and experiences to date?
Interview responses describing each of the factors identified provide some additional
insights.
Time and resources - Respondents noted that GR efforts in most regions do not involve
dedicated staff. Many respondents expressed concern that RPMs, and regional Superfund
programs as a whole, are "stretched too thin," and thus GR becomes a "second-tier
priority." Several respondents felt that additional resources would be necessary to fully
implement and integrate GR techniques into the regional remediation process.
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Costs - Separate from resources, respondents noted that the cost of GR itself is difficult
to justify if it exceeds the cost of other options. This is true both for analysis and
implementation of GR practices, and a key concern is the ability to justify GR when
demanding cost recovery from PRPs. Respondents suggested that HQ and regions
improve RPM and front-line manager education about the costs of GR, to ensure that
staff accurately measure both short- and long-term costs and benefits and can identify
situations where GR is not more expensive than alternatives.
Legal authority - Several regional respondents discussed challenges in convincing PRPs
to pursue GR. Respondents noted a lack of clear legal justification and broader
Headquarters support for promoting GR activities during remedy selection and design.
Separately, respondents also noted that third party liability concerns limit the interest of
some renewable energy developers in using Superfund sites for renewable energy (RE)
generation.
Front line managers also focused specifically on the challenge of addressing third party
liability. They discussed recent efforts to clarify operator liability and encourage third
party operators to implement GR projects.
Policy direction - In response to this question, three respondents directly identified
limited available policy direction as a hurdle to implementing GR. Specifically,
respondents noted that many managers and RPMs are unwilling to undertake GR efforts
without clear indication that HQ will support these actions.
More broadly, several regional respondents noted that the policy direction and
information is "lagging" somewhat compared with the high-quality technical materials
associated with the GR Strategy. Respondents noted that draft policy statements related
to GR in remedial design have been circulated but expressed a desire for a more visible
role by HQ in reaffirming support for GR by clarifying policy where possible. While this
issue was most clearly articulated in the responses to this evaluation question, the interest
in more evident HQ support emerged in response to several questions.
Interviews with other regional staff (attorneys and front line managers) and non-EPA
individuals involved in other GR initiatives confirmed that the lack of policy or explicit
direction from EPA HQ limits the implementation of the GR Strategy. However,
respondents cite some individuals who have successfully implemented GR techniques
without explicit direction, in part through direct negotiation with PRPs and contractors to
incorporate GR practices. Many respondents noted that some PRPs can see the value in
GR without it being a matter of law, though legal clarity is critical in the event of
litigation.
Both regional and HQ staff noted that GR should not become a separate "tenth criteria" in
considering remedial design, and several respondents noted that HQ should be cautious in
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providing policy direction to avoid being too prescriptive.22 However, clear input from
HQ, including completion of the policy portions of the GR Strategy, will assist in the
integration of the GR Strategy into regional culture and will provide a key signal that HQ
regards GR as a priority. Both regional and HQ respondents agreed that HQ is a critical
driver of momentum to ensure the success of the GR Strategy. In addition to specific
policy clarification, respondents suggested other HQ actions such as inclusion of GR
targets in performance agreements and other incentives. Overall, the importance of HQ
involvement in GR is a key theme that emerges across questions.
In addition to these main issues, respondents identified the following hurdles:
Obtaining legal support - some attorneys hesitate to pursue GR in the absence of
clear legal authority. This is separate from concerns about development of clear
policy, but respondents agreed that attorney hesitation could reflect limited policy
direction and lack of clear EPA HQ support for the GR Strategy.
Management support and direction - One respondent noted that GR will not
happen if management doesn't state it as a priority. Efforts to work with regional
managers to pursue GR may therefore be a key part of expanding implementation.
Contractors - Two respondents noted that contractors may resist suggestions
from RPMs to consider GR. Introduction of clear and concise policies related to
contracting on the regional and national level could potentially address this issue.
Technical ability - One respondent noted that an aggregated source of
information and training on GR technologies could help RPMs identify and
compare GR technologies with traditional approaches. This would support efforts
to work with contractors and PRPs.
In addition to the obstacles mentioned during the interviews, according to the 2010
Survey of EPA Program Representatives, the Superfund representative(s) felt that there
was not enough awareness of the goals and objectives of GR; this result provides
independent corroboration for the responses to Evaluation Question 1.
Also, although somewhat outside the scope of this evaluation, one non-EPA interviewee
expressed interest in having more coordination of GR efforts across EPA Offices (i.e.,
RCRA and Superfund). The respondent explained that EPA and non-EPA organizations
alike would benefit from seeing an EPA-wide GR policy and a single web-based portal
consolidating program efforts. Currently GR resources are spread across programs and
are difficult to locate.
22 This references the Nine National Contingency Plan Evaluation Criteria under CERCLA.
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3.2 EVALUATION PURPOSE 2: DETERMINE A BASELINE AGAINST WHICH TO
MEASURE EPA PROGRESS IN IMPLEMENTING THE CR STRATEGY
This evaluation purpose is to create a starting point for measuring the performance of the
GR Strategy implementation. Consistent with the purpose of a formative evaluation, EPA
is currently considering options for the development of an appropriate baseline against
which to measure progress in implementing the GR Strategy. Evaluation Question 6
directly addresses this purpose, and includes three sub-questions:
Evaluation Question 6: What options can we identify for developing a baseline?
o What has changed since the implementation of the GR Strategy!
o When did green remediation become important to site cleanup?
o What options are available for quantifying the environmental footprint at
sites?
To determine a baseline for the GR Strategy, lEc first interviewed the designated GR
Regional Coordinators and RPMs actively attempting to implement GR in the 10 EPA
regional offices. In addition, lEc interviewed key measurement specialists that have been
involved in the development of the Draft Footprint Analysis for Environmental Cleanup
document. Based on this input and a review of pertinent literature, we provide an initial
set of options for considering baselines.
3.2.1 Evaluation Question 6: What Options Can We Identify For Developing
A Baseline?
Developing a clear baseline is an important step in effectively measuring outcomes of the
GR Strategy. A number of factors are important to consider when developing a baseline.
Ideally a program or strategy has clear initial data and a unique set of activities and
metrics that are readily tracked.
A complexity of the GR Strategy is that it has been implemented as a unifying approach
encompassing some existing efforts, and in some cases it clearly post-dates regional
activities. Moreover, a key goal of the program is awareness, and in some cases people
are "doing" GR without calling it GR. Therefore, in evaluating responses to this question,
we consider:
Timing: Have regions begun to implement GR practices (and when)? Many GR
activities implemented in Region 2 and Region 9 pre-date the GR Strategy, while
some other regions have not yet formally implemented GR practices, and still
others are in early stages of implementation at a limited number of sites. The
progress of implementing GR practices may be affected by the stage at which site
cleanup is in the "Superfund pipeline" (e.g., Remedial Investigation, Record of
Decision (ROD) development, remedial design (RD), remedial action (RA),
O&M, or five-year review). Incorporating GR activities into the ROD allows for
greatest opportunities for footprint reductions, because the RD/RA phases are
based on specifications described in the ROD. Opportunities to optimize the
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remediation through GR practices may not be available again until the five-year
review period.23
Multiple baselines: As multiple types of outcomes (awareness, behavior, and
condition) are associated with the program, is it helpful to think about different
baselines? Are different baselines appropriate for measuring awareness and site
activities? Regional respondents noted that a number of current GR activities are
not called "GR," suggesting that awareness of GR is at a different level than site
activities.
Tracking: Another factor in identifying a clear baseline is collecting data on
current GR activities. It is therefore important to assess the data that regions
currently and routinely collect and identify data that regions could collect.
Regional respondents provided three different suggestions for determining a baseline for
the GR Strategy.
Date-dependent Baseline: In general, responses indicated that most regions have
not yet focused on developing a baseline. Respondents from eight regions stated
that current practices represent a fairly accurate "before GR" baseline, because
they are just beginning to implement green remediation efforts. They noted that
the GR Strategy and accompanying regional efforts are the driving force behind
all identified GR activities from this time forward. While some uncertainty would
accompany these estimates (e.g., if projects have been underway), the respondents
felt the total impact on metrics would be negligible.
In Regions 2 and 9, however, it is clear that significant GR activities pre-date the
GR Strategy, and it would be difficult to attribute all future activity to the
Strategy.
Based on these insights, one option for a baseline is to exclude these regions
(Regions 2 and 9) when measuring site-level activities related to the GR Strategy,
except for specific activities that are clearly connected with the GR Strategy (e.g.,
energy purchase policies or contract implementation).
A second option is to consider all site-level GR activities as related to the GR
Strategy, at least indirectly, but stop short of "attributing" the impacts of these
activities to the GR Strategy. This approach would consider "contribution" and
assume that the Strategy contributes to all activities, without asserting that the
Strategy is solely responsible.
23 The purpose of a five-year review is to evaluate the implementation and performance of a remedy (on a site-by-site basis)
in order to determine if the remedy is or will be protective of human health and the environment. Five-year reviews should
be conducted either to meet the statutory mandate under CERCLA §121 (c) or as a matter of EPA policy. In general, five-
year reviews are required whenever a remedial action results in hazardous substances, pollutants, or contaminants
remaining on site.
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Three Separate Baselines (Multiple Baselines): A respondent from another
region offered three distinct scenarios to describe the current state of GR practices
in the regions. If a baseline were to be measured at the present time each of the
regions would fall into one of three categories including,
o Date is prior to all GR activity. Regions in this category have
integrated little to no GR practices at sites. Eight of the ten regions
generally fall into this category;
o Region is in the "opportunistic phase" when GR starts to be
considered in site cleanup. Regions in this category have integrated
energy and cost saving practices, but are not referring to them as
GR. An accurate baseline measurement of GR practices due to the
GR Strategy would include these practices since they are not
attributable to the GR Strategy. This scenario relays the importance
of determining a baseline for changes in awareness and a separate
baseline for changes in behavior. At least one region potentially falls
into this category, and;
o GR is main stream. Regions in this category already widely
practice GR techniques and had policies in place to address GR
prior to the release of the national GR Strategy. Two regions fall
into this category.
This would provide an accurate and informative assessment of different GR
Strategy priorities, including integration of GR throughout the remediation
process, but requires significant data collection, and could lead to potential
confusion as regions transition from one category to another.
Results from the tracking database: Finally, Region 2 has been implementing
GR since before the GR Strategy was developed. In this situation, current
measurements may not accurately capture the region's baseline. However, Region
2 has received funding to develop a metric tracking database and it may be
possible to identify specific activities associated with the GR Strategy using the
data from this effort.24
Exhibit 3-7 summarizes the number of regions that fall into each of the three categories of
baseline measurement as discussed above and provides a summary of responses to the
three sub-questions under Evaluation Question 6.
24 The database is intended to track data related to the series of touchstone practices of the Region 2 Clean and Green
Policy, which addresses the energy, air emissions, and materials and waste, but does not address water, or land and
ecosystems core elements.
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EXHIBIT 3-7. OVERVIEW OF FINDINGS RELATED TO BASELINE MEASUREMENT
EVALUATION
QUESTION 6 SUB-
QUESTIONS
Number of Regions
Providing this Answer
What has changed
since the
implementation of
the CR Strategy?
When did green
remediation become
important to site
cleanup?
What options are
available for
quantifying the
environmental
footprint at sites?
REGIONAL INSIGHTS ON BASELINE DEFINITION
SINGLE DATE-
DEPENDENT BASELINE:
ASSUME ALL ACTIVITY
AFTER SPECIFIC DATE IS
RELATED TO THE CR
STRATEGY
Eight
Respondents noted that
little has changed "yet"
at the site level since
publication of the
Strategy.
GR activities currently
being implemented
would likely have been
implemented absent
the CR Strategy, but
new activities reflect
increasing awareness.
Responses included
considering, as a
starting point, the
development of the
Strategy in 2009, the
2010 release of the
Strategy, and assertions
that "it is still not
considered important."
Respondents felt that
limited baseline data on
footprints exists, with
the exception of Fund-
lead site energy use.
Survey results from
Regions 3 and 4
generally corroborate
this; data are collected
at specific sites but
footprint data are not
collected in any
standardized way that
would support broad
baseline development.
ESTABLISH THREE
BASELINES FOR REGIONS
DEPENDING ON GR
STATUS AND ASSUME
DIFFERENT GR STRATEGY
IMPACT LEVELS
One
The respondent
explained that current
projects reflect
opportunistic actions,
and felt that the CR
Strategy should identify
time frames for
different types of
impacts in each region
as GR efforts evolve.
Respondent explained
that it was difficult to
pinpoint an exact time
because each effort
evolved differently.
The respondent did not
have any suggestions for
quantifying the
environmental footprint.
TRACK SITE-
SPECIFIC GR
STRATEGY
ACTIVITIES USING
TRACKING
DATABASE
One
The respondent
did not address
this question.
The respondent
did not address
this question, but
the regional GR
policy predates
the CR Strategy.
The respondent
did not have
suggestions for
quantifying site
footprints.
However, the
region is
developing a
metric tracking
database, and
may have
suggestions when
the database is
complete.
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Overall, the interview responses to this question and the data review suggest the
following:
Site-level outcomes may require two baselines to clarify attribution. For site-
level activities, a single uniform baseline across regions may not be as robust as a
dual baseline if EPA wishes to attribute activities specifically to the GR Strategy.
This baseline would assume that eight regions are "new" at GR (and all GR
activities from this time on can be linked to the GR Strategy), and the remaining
two regions can only be considered responding to the GR Strategy if they report
significant and specific changes in activity. If EPA considers only a more general
"contribution" approach, then a single baseline of 2009 or 2010 might be an
appropriate starting point.
Program-level outcomes may use single date-driven baseline. For broader
changes in awareness and integration of GR tools and techniques throughout the
Agency, a single national baseline is more feasible. While interview and survey
respondents report undertaking activities that are "GR," the responses to this
question and prior questions suggest that broad awareness of GR as a concept and
practical approach are clearly linked to the development of the GR Strategy.
Regions have not collected baseline footprint data. Because very little
information about GR activities is currently tracked across regions, identifying a
broad and reliable baseline "site footprint" is difficult. It is possible to measure the
environmental effects (for four of the five core elements) at each site, but
resources (e.g., time, manpower) for conducting measurements are scarce and no
standard method for tracking such data currently exists. The exception to this may
be the documentation of typical energy use, because data from Fund-lead sites
could provide a basis for estimation. However, a measured baseline footprint
might be unnecessary if EPA can develop reliable metrics that quantify "typical
footprint impacts" associated with specific GR practices (see Evaluation Question
8 below).
3.3 EVALUATION PURPOSE 3: DETERMINE THE BEST METRICS FOR
MEASURING THE PROGRAM'S SUCCESS IN IMPLEMENTING GR PRACTICES
To examine the best metrics for measuring the program's success in implementing GR
practices, lEc evaluated a number of existing data sources, and supplemented and
corroborated these with interview responses from relevant parties working on GR. To
review the metrics for measuring program success, lEc investigated the following
questions:
Evaluation Question 7: What performance measures are appropriate for
measuring the effectiveness of the GR Strategy in achieving intended outcomes at
a regional or national level?
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Evaluation Question 8: What are the best means for measuring the effectiveness
of the GR Strategy in reducing the environmental footprint at sites that have
implemented GR practices with respect to the five core elements of the GR
Strategy!
Evaluation Question 9: Where are the primary data gaps and limitations that
inhibit a better understanding of the results of implementing the GR Strategy!
The findings for this evaluation purpose are based primarily on evaluation of the
following existing data sources: surveys from Region 3 and Region 4, the survey
following the Atlanta Green Remediation Meeting held in October 2010, the Region 2
database, the Region 9 GR activity tracking list, the Sustainable Remediation Forum
(SURF) White Paper on Integrating Sustainable Principles, Practices and Metrics into
Remediation Projects, the draft Footprint Analysis for Environmental Cleanup, and other
footprint analyses and tools.
In addition, the review of existing data was supplemented with information gathered in a
first round of interviews with RPMs and GR Regional Coordinators active in promoting
GR practices in each of the 10 EPA Regions, along with a second round of interviews
with measurement specialists familiar with metrics and measurement techniques. The
second round of interviews also includes other non-EPA professionals working in state or
other federal agencies on GR activities.
3.3.1 SUMMARY OF FINDINGS
Overarching findings related to this evaluation purpose are as follows:
Identification of performance measures for the GR Strategy: The logic model
associated with the GR Strategy (Exhibit 1-3) suggests that a suite of appropriate
performance measures (metrics) for program performance would include: 1)
specific metrics identifying awareness (near-term outcomes), changes in behavior
(medium-term outcomes) and changes in site practice and impacts (long-term
outcomes) and 2) metrics for each type of outcome that allow EPA to assess the
extent to which the GR Strategy is effectively implemented and successful in
integrating GR principles throughout the remediation process. Another key
feature of successful metrics is ease of data collection and analysis. A detailed list
of possible metrics is presented in the results for Question 7.
Identification of metrics for assessing site footprints: EPA's efforts to craft
and test a footprint methodology to support GR activities at sites provides a
comprehensive set of metrics that map to four of the five GR Strategy core
elements. A number of these metrics appear consistent with other sources and
may be able to be adopted with limited additional effort. In other areas,
particularly in the area of land and ecosystem protection, practical options may be
limited to basic process metrics (e.g., reviewing sites for critical or sensitive
habitats) or qualitative descriptions.
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Key data gaps and challenges: Direct responses to this question were very
limited, but a number of themes emerged in both data reviews and interview
responses to other questions. One concern was the reluctance of EPA staff in
many regions to conduct footprint analyses. While some interview responses
noted that resources for conducting the analyses were an issue, a broader concern
appears to be uncertainty about the defensibility of using these analyses in
negotiations.
A related, key concern noted by several regional respondents is the need for more
clear policy guidance on implementation of GR practices, to serve as both a guide
and a "signal" from Headquarters to reticent regional staff. Interviewees,
including two subject-matter experts, also noted HQ policy guidance is
constrained by the statutory authority that is available to require GR practices in
cleanups, and by the need to ensure appropriate flexibility for regions to
implement the program as they see fit. Given the constraints, it appears unlikely
that HQ will issue guidance as prescriptive as some regional respondents
suggested. The challenge for HQ is to determine how to provide information that
will continue to enable and motivate regions to implement GR practices at site
cleanup, and will provide assurance that HQ continues to consider GR a high
priority.
It appears that the GR Strategy has been successful in both raising general awareness of
GR and in providing specific practical information and tools for implementation, but it
has been more difficult to provide information on the appropriate contexts and
approaches for different types of GR activities.
Below we document the more detailed findings for each of the three questions
contributing to this Evaluation Purpose.
3.3.2 Evaluation Question 7: What performance measures are appropriate
for measuring the effectiveness of the CR Strategy in achieving
intended outcomes at a regional or national level?
To determine the best metrics for measuring the program's success in implementing the
GR Strategy, lEc used two different approaches, including the collection of new data
through interviews and review of existing program evaluation literature and other data
sources identifying specific GR metrics. Consistent with the focus of a formative
evaluation, we consider a range of outcome (performance) measures that could measure
progress toward goals.25
As an initial step, lEc reviewed the GR Strategy logic model to identify activities and
outcomes that EPA is seeking to measure, and examined literature to identify criteria that
would help describe appropriate metrics.
25 Handbook of Practical Program Evaluation p. 101.
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To generate potential metrics for consideration, lEc interviewed the Region GR
coordinators, as well as key measurement specialists that have been involved in the
development of the draft Footprint Analysis for Environmental Cleanup.
lEc then used the Handbook of Practical Program Evaluation to assess each of the
metrics listed below. Aside from threshold requirements of validity and reliability, the
Handbook describes five other criteria for identifying appropriate measures:26
Meaningful and Understandable Measures - Measures focus clearly on the
goals and objectives of the evaluated program. Additionally, the program's
intended audience should be able to easily understand the suggested metrics.
Timely and Actionable Measures - Measures should be actionable, focus on
results that decision makers can have leverage over, and present dimensions that
are directly affected by the program's elements. Additionally, measures should be
based on fresh data and provide results in a timely manner.
Practical Considerations and Cost - Measures should be cost-effective to
document. Metrics that require new data collection systems and procedures may
be less optimal.
Balanced and Comprehensive Measures - As a group, measures should provide
a balanced and comprehensive picture of the evaluated program.
Goal Displacement - Measures should not cause managers to alter or sacrifice
the program's goals (e.g., by focusing on "bean counting" at the expense of best
practices).
The metrics identified in Exhibit 3-8 below consider the first three criteria described.
Potential challenges for measuring these metrics are highlighted in the last column of the
table. The last two criteria represent considerations in identifying an appropriate suite of
several metrics. These should be considered throughout the metric selection process and
evaluated once all available data are collected.
Insights from interview responses: In general, the regional respondents considered this
to be a "difficult question" and could not offer many suggestions for appropriate
performance measures to assess the effectiveness of the GR Strategy in achieving national
or regional level outcomes. One regional respondent suggests avoiding "green beans" or
"counting" green activities as the sole metric to evaluate program success without
encouraging the actions with the most impacts.27
Responses from the measurement specialists echoed the difficulty in measuring program
success. One respondent stressed that tracking the use of the footprint methodology is one
Handbook of Practical Program Evaluation p. 110-111.
27 Under a system focused on counting green beans, people may be motivated to do as many "green" activities as possible,
which may hinder the overall goal of site remediation and protection of human health and the environment.
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metric that could be used to assess implementation of the GR Strategy, but that
quantifiable reductions in environmental footprint is the key metric. All respondents
remarked that it would be interesting to track the number of sites that complete an
environmental footprint analysis and the number that use the Footprint Methodology
outlined in the Footprint Analysis for Environmental Cleanup document in order to assess
the implementation of the GR Strategy.
Insights from literature: The Sustainable Remediation Forum (SURF) White Paper
provides a framework to achieve sustainable remediation, which outlines activities in the
following three categories: technical resource integration, cooperative communication,
and outreach and recognition. Under each category the paper provides examples of
metrics that could be used to assess performance. Technical resource integration includes
the development and acceptance of a sustainability framework, technical and regulatory
guidance documents, pilot studies and research, lessons learned and case studies, and
technical stewardship.
These resources track well with the intended outputs and outcomes of the GR Strategy.
Cooperative communication at the project and Agency levels can include BMPs, fact
sheets and other publications, meetings and trainings, as well as dedicated attention to
stakeholder questions and concerns. Finally, the paper notes that outreach and recognition
activities will provide momentum for green remediation activities. Examples include
publications, participation at conferences, maintenance of a central Web site as a
repository for green remediation activities, and the establishment of awards for creative
and sustainable projects. Analogous to the metrics included in the SURF White Paper,
Exhibit 3-9 contains a list of GR Strategy-related measures that may be used to assess
performance.
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EXHIBIT 3-8. IDENTIFICATION AND REVIEW OF POTENTIAL PERFORMANCE MEASURES
OUTCOMES
LOGIC MODEL
OUTCOMES
Status of regional
policies
POTENTIAL
METRIC
DATA
SOURCES
DATA COLLECTION
REQUIREMENTS
Measure of n . .
. Review and
,. . . Comparison Medium (Would be
coPn°sisCtenc of a" easy to do' but
with the
Strategy over
time
Development of
regional
implementation
plans
Regional
policies and
the Strategy
Regions
Use of CLU-IN
Website and EMS CLU-IN
only goal)
Medium (requires
data collection
form regions)
downloads of Website Use Low; data available
specific Data
materials
Attendance at EMS CLU-IN
NARPM and Website Use Low; data available
other Trainings
Awareness of CR RPM survey
Data
Strategy & BMPs responses
Short-Term: regarding Regional High (would require
Changes in awareness of RPM Surveys survey)
Awareness and
Attitudes
Strategy over
time
Number of CR
Strategy
actions/product HO
s completed
and published
to web
Use of CLU-IN
Website and
Posted Strategy
Products
Attendance at
EMS CLU-IN
Website Use
Data
EMS CLU-IN
Low; data available
but not direct
indicator of
awareness
Low; data available
NARPM and Website Use Low; data available
Awareness of other Trainings Data
resources and
site specific Number of
ass/stance
phone calls Qr (Depends
placed to .. 3 .. v ., .....
.,. . other on the availability
'^about^S '"formation of a call log or if
.,. on amount the information is
speci ic Q<: requestecj tracked some other
. . assistance way)
and /or "
resources
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OUTCOMES
LOGIC MODEL
OUTCOMES
Awareness of
footprint
Interest in GR
POTENTIAL
METRIC
DATA
SOURCES
Use of Pilot
Studies and EMSCLU-IN
DATA COLLECTION
REQUIREMENTS
Footprint Website Use Low; data available
Assessment
CLU-IN Pages
Number of
participants and
Data
organizations
attending CLU-IN List
Footprint of
Methodology Participants
Webinar and
subsequent
trainings
Number of
Case
Studies,
Low; data available
"footprinted" technical Low; data available
sites
GR Workgroup
.-all
experts in
R9
Hn
Coordination .""".- "^
participation
Low, but not direct
awareness indicator
High (Current
Intermediate:
Changes in
Behavior
Adopt BMPs for
GR reflected in
ROD
Use of Contracting
Tool Kit
Number of
times BMPs are
used on sites
Number of RODs
with GR
language
Use or number
of views of the
Contracting
Tool Kit
Regional
Surveys or
interviews
with RPMs
Does CLU-IN
surveys do not ask
about BMPs.
Surveys and
interviews can be
difficult to
coordinate.)
Medium (If there is
,av*j.a . a feedback section,
ee. . ac those results may
... ...... inform this
the BMP
, question.)
page?
Regional
review and
count of
RODs
EMSCLU-IN
Website Use
Data
Number of Review/
Regional master count of
High; requires
review of RODs
Low; data available
contracts that Regional Medium
contain GR master
language I contracts
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OUTCOMES
Long-Term:
Changes in
Condition
LOGIC MODEL
OUTCOMES
Specify and adopt
performance goals
Formalize GR
positions in regions
Full integration of
the GR Strategy
Reductions in
environmental
footprint
POTENTIAL
METRIC
Number of
published
implementation
plans and "hard
targets" in
Regional
policies
Changes to
more
permanent
staffing of GR
positions
Number of sites
with completed
footprint
analyses.
Agreement on
integration of
GR in different
pipeline stages
Number of
"non-G/?
Strategy
specific"
webinars and
NARPM trainings
that include GR
in curricula
Inclusion of GR
practices and
targets in
management
and
performance
requirements
Integration of
cross- program
and cross-
Agency GR
strategies
DATA
SOURCES
Regions
Regions
Regions
HQ, Regions
HQ
Regions
HQ, work
group
DATA COLLECTION
REQUIREMENTS
Medium (requires
data collection
from regions)
Low; data available
High; though this
could be a difficult
metric to measure
Low, but requires
significant work to
achieve and
document success
Low- medium; data
collection reviews
of NARPM materials
Medium; would
require data
collection from
Regions
Low, but difficult
to achieve
Refer to Evaluation Question 8 for a more detailed
discussion on available footprint metrics.
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3.3.3 EXAMPLE: USE OF CLU-IN WEB DATA
To examine the feasibility of one data set for supporting GR Strategy metrics, lEc
reviewed a preliminary subset of the CLU-IN Website use data that track the number of
participants for CLU-IN web seminars. Exhibit 3-9 tracks the number of CLU-IN web
seminars and the number of participants from 2008 to 2011.28
EXHIBIT 3-9. REVIEW OF PARTICIPATION IN CLU-IN WEB SEMINARS
Number of Web Seminar Conferences
Average Number of Participants per Conference
Number of EPA Participants
Number of Other Government Participants
Number of Non-Government Participants
Total Number of Participants
YEAR OF CLU-IN WEB SEMINARS
2008
5
186
93
332
507
932
2009
8
173
254
338
795
1387
2010
4
142
110
142
314
566
2011
5
196
166
201
611
978
Exhibit 3-9 shows that the two years with the most participants per seminar were 2008
and 2011, coinciding with the beginning of the GR Strategy development in 2008 and the
period following publication of the final version of the GR Strategy in September 2010.
However, the largest number of seminars took place in 2009, during GR Strategy
development. These data do not account for the content of the seminars or outreach
leading up to each seminar but continued high participation in future years would indicate
awareness of GR.
It is also interesting to note that the number of non-government participants were
consistently higher than the number of EPA and other government participants. This
result may reflect a larger population and audience of non-government participants than
government, but it may also suggest that EPA's GR Strategy is achieving awareness of
GR outside the Agency. Data on the different categories of non-EPA participants might
provide insights on the extent to which EPA is reaching targeted audiences.
3.3.4 Evaluation Question 8: What are the best means for measuring the
effectiveness of the CR Strategy in reducing the environmental
footprint at sites that have implemented GR practices with respect to
the five core elements of the CR Strategy?
To determine the best means for measuring the effectiveness of the GR Strategy in
reducing the environmental footprint at sites, lEc first evaluated the Footprint Analysis
for Environmental Cleanups document, which was recently released in draft form by
! lEc also examined data on NARPM training and annual OSC Readiness training, but we do not separately discuss results.
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EPA's Office of Superfund Remediation and Technology Innovation GR Team in
September 2011. The document is a robust starting place to evaluate the best means for
measuring the GR Strategy's ability to reduce the environmental footprint at sites. The
document lists a set of established parameters (metrics) to be quantified and a
straightforward methodology for quantifying those metrics for four of the five core
elements of the GR Strategy (materials & waste, water, energy, and air quality).29
To identify other possible metrics to measure the environmental footprint at sites, lEc
mined site case studies (Profiles of Green Remediation), surveys, regional databases,
regional metrics, interview responses, literature and other sources, and compared the
findings with the metrics list provided by the Footprint Analysis for Environmental
Cleanups30 Exhibit 3-10 arrays the possible metrics that were identified by this review.
As one source of data, we found that the use of the footprint methodology is not
widespread throughout EPA regional offices since it was only recently released
(September 2011). However, Superfund GR Workgroup members developed best
management practices (BMPs) for minimizing the environmental footprint of site
activities and have implemented at least one of them at 28 case study sites. These BMPs
are in place under a range of cleanup programs including Superfund, RCRA, federal
facility, brownfield, and state voluntary actions. A table of 28 Profiles of Green
Remediation case studies available on the CLU-IN website summarizes the use of these
BMPs.
An analysis of the case studies shows that the most frequently used BMPs are related to
air emissions. Over 82 percent of the 28 sites utilized report reducing fossil fuel use over
the course of the cleanup to achieve reductions in GHGs and air pollutants. Energy-
focused BMPs (i.e., energy efficiency and renewable energy use) have been documented
at 68 percent of the 28 sites. Over 64 percent of case study sites employed recycling or
beneficial use BMPs to manage materials and waste generated on site. Just under half (12
sites) of the profiles identify strategies to conserve and reuse water treated at sites.
Finally, nine sites include land and ecosystems BMPs, though no formal metrics for such
activities were outlined in the footprint methodology.
29 The metrics are used to quantify the total environmental effects of a remedy by core element (e.g., total energy use, total
air emissions, total water use, total waste generation/material consumption). In this way one or more potential remedy
options can be compared across either the total environmental footprint or by a specific core element. The document does
not provide guidance on quantitative metrics or a methodology for evaluating land and ecosystems, but rather stated that
this core element would be evaluated through qualitative analysis. The details of this type of analysis are under
development.
30 Specific existing data sources include: Region 3 Green Remediation 2009 Questionnaire, Region 4 2011 Superfund Greener
Cleanup Survey, results from the Atlanta Green Remediation Coordination Meeting in October 2010, the SURF White Paper,
Region 2 metrics and database of GR practices, the 28 Profiles of Green Remediation case studies available on the CLU-IN
Web site, a table of RPM activities that include GR practices from Region 9, and other footprint analyses and tools (e.g.,
SiteWise, Sustainable Remediation Tool, Greener Cleanups Matrix, Green Remediation Evaluation Matrix).
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Exhibit 3-10 reflects the results of this data collection effort by identifying potential
metrics and the data sources that report their use. The exhibit includes metrics that are
currently being tracked or have the potential to be tracked. The exhibit includes interview
responses indicating the availability of metric information summarized at core element
level. Overall, our analysis identifies some metrics that are currently in use and other
metrics that could be tracked rather easily. Other metrics cited in the footprint
methodology appear less common or may be more difficult to track.
EXHIBIT 3-10. REVIEW OF POTENTIAL METRICS FOR CORE ELEMENTS OF THE CR STRATEGY
CORE
ELEMENT
Materials &
Waste
Water
Energy
Air Quality
Land &
Ecosystems
METRICS
Refined materials used (Ibs)
Percent of refined materials from
recycled or waste material
Unrefined materials used (tons)
Percent of unrefined materials from
recycled or waste material
Hazardous waste generated (tons)
Non-hazardous waste generated (tons)
Percent of total potential waste
diverted from landfill disposal
On-site water used, including source,
use, and fate of the used water (gal)
Off-site water used (gal)
Drawdown of the water table 1 00 feet
from pumping location (feet)
Percent reduction in stormwater runoff
Total energy used (MMBtu)
Percent of total energy use from
renewable resources
Scope 1 Criteria Pollutant emissions
(pounds)
Scope 1 HAP emissions (Ibs)
Total greenhouse gas emissions (Ibs)
CO2e)
Total Criteria Pollutant emissions (Ibs)
Total HAP emissions (Ibs)
Number of applications of clean diesel
applied and amount of ULSD used
(convert to CAP emissions reduced)
No metrics. Qualitative analysis.
Percentage of land reforested for
carbon sequestration
Percentage of land used for community
and utility scale solar
FP'
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
CASE
STUDIES2
x(8
Super-
fund, 10
others)
x(6
Super-
fund, 6
others)
x (12
Super-
fund, 7
others)
x(14
Super-
fund, 9
others)
x(3
Super-
fund, 6
others)
SURVEYS a
DATABASES3
a, b, c
a, c
a, b, c
b
b
b
a, c
a, c
a, b, c
d
d
d
d
INTERVIEWS4
(* OF REGIONS)
x(2)
x(1)
x(6)
x(3)
OTHER
SOURCES5
j, k
k
j, k
k
j
j
i, J
i, j, k, I
i, j, I
g, k
i, k, I
i, k
j
i
i, j, I
j, I
k
i
h
h
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CORE
ELEMENT
METRICS
Percentage of land used for community
and utility scale wind
FP'
CASE
STUDIES2
SURVEYS a
DATABASES3
INTERVIEWS4
(* OF REGIONS)
OTHER
SOURCES5
h
1 Footprint Analysis for Environmental Cleanups Draft, May 2011
2 Profiles of Green Remediation available online at
3 This column includes the following sources. If a source is not listed in the table above it indicates that we have reviewed the source and identified
no relevant information.
1 Region 2 database (not publically available) and list of recommended metrics (available online at
http:/ /www. epo.gov/reg/on02/superfund/green remediation /metrics, html)
b Region 3 Green Remediation 2009 Questionnaire
c Atlanta Green Remediation Coordination Meeting in October 2010 survey
d Region 4 2011 Superfund Greener Cleanup Survey. The survey asks respondents if "calculator used?" for each principle (core element). If
there were any "Yes" responses recorded, we assume that some metrics corresponding to the specified principle were measured and used in
some form of analysis. Note that the survey does not provide specific metrics under each principle. Therefore we can only match Region 4's
Survey to footprint methodology metrics at the categorical level.
6 Region 9 list of RPM activities
4 This column reports the number of regions that noted, during interviews with lEc, that they currently track or could easily track the categories of
core elements of the OR Strategy. The interviewees did not cite the specific metrics within each category and therefore we report the results at the
categorical level. Interviews were conducted with Regional GR coordinators and RPMs actively attempting GR in the 10 EPA regional offices.
5The following sources constitute the "Other" Category. If a source is not listed in the table above it indicates that we have reviewed the source and
identified no relevant information.
' SURF White Paper, 2009
g EPA Brownfields, Air and Water Quality Impacts of Brown fields Redevelopment, April 2011
h EPA OSWER, Opportunities to Reduce GHG Emissions through Material and Land Management Practices, Sept 2009
The following sources are other publicly available footprint analysis tools. We did our best matching the metrics listed in the following tools
to the metrics included in the table above. However, the metrics in the following tools do not perfectly sync with the EPA's footprint
methodology.
' SiteWise available at
' California DTSC Green Remediation Evaluation Matrix available at
k Illinois EPA Greener Cleanups Matrix available at
. The Illinois EPA's Greener Cleanups Matrix is more of a check list of
activities than a footprint analysis tool or template and does not require specific metrics to be measured. However, we assume, based on our
review of the document, that the metrics indicated in the table above would be available if the matrix, and activities outlined in the matrix,
are implemented.
'Air Force Center for Engineering and the Environment(AFCEE) Sustainable Remediation Tool (SRT) available at
The review of metrics proposed by the Footprint Analysis for Environmental Cleanups
draft documents shows that other sources typically highlight and track a subset of these
markers. This suggests that the Footprint Analysis metrics list is generally
comprehensive and highlights some of the more commonly used metrics that may be
most appropriate for program-level examination. Below we briefly provide additional
insights from the interview and data collection process, organized by sub-question.
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What options exist for using qualitative or quantitative measures to assess the
five core elements of CR Strategy?
OSRTFs metrics outlined in the Footprint Analysis for Environmental Cleanups draft
document represent a clear set of quantitative options for direct measurement of
reductions in the environmental footprint at sites. Review of additional sources and
practices failed to identify any additional quantitative metrics that would be broadly
useful.
In implementing these metrics, respondents to the GR Regional Coordinator interviews in
nine regions noted that they may have some information or have the ability to track at
least one core element (usually energy). However, no consistent method is currently used
to track success across regions or even across sites. The most common elements tracked
or for which some information is available are energy use, air emissions and waste
management.
Respondents noted that the methods exist to track all four of the core elements outlined in
the Footprint Analysis for Environmental Cleanups draft document, but resources
necessary to conduct measurements are scarce. Respondents expressed concern about
adding tracking requirements to RPM workloadsone regional respondent noted that
RPMs do not need metrics to "do their jobs." Several respondents noted a centralized and
simplified tracking system would be important in ensuring participation.
One option may be to document "typical sites" and "typical activities" based on case
study and other existing data sources, and use these data to estimate reductions in
environmental footprint resulting from specific GR practices. This option addresses the
concern of limited resource availability for data collection and analysis efforts noted in
several interviews. Under this scenario HQ could develop standard values for typical
footprint reductions associated with specific activities and assess regional activities with
limited regional data tracking. For example, with sufficient data it may be possible to
estimate the average energy savings between two different pump-and-treat systems. In
this case it would only be necessary to identify the number of sites that use such systems
to calculate total savings.
3.3.5 Evaluation Question 9: Where are the primary data gaps and
limitations that inhibit a better understanding of the results of
implementing the CR Strategy?
A key source for the response to this evaluation question was lEc's interviews with
regional EPA staff, HQ staff, and outside-EPA contacts. Direct responses to this question
were very limited, and typically focused on difficulties developing defensible footprint
analyses. However, a brief review of insights in response to other questions (e.g.,
Evaluation Question 5's assessment of barriers) indicates three fundamental areas that
affect the ability of EPA to fully integrate GR into the remediation process.
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Concerns about use of the footprint methodology.
While agreeing that the core elements are well-focused and the quantitative measure of
changes in site operation would be an ideal way to document GR success, respondents in
several regions expressed concern about both the cost of conducting footprint analyses,
and also the potential consequences if the data and methods are challenged by PRPs.
Specific insights included:
The challenge of finding additional resources to undertake (or contract) the
analysis.
A need for support and guidance in "triaging" sites to decide when and how to
apply the analysis to ensure that results are not able to be misused (e.g., encourage
PRPs to argue for selecting a less-prescriptive remedy because it is the "greener"
option).31
Clarity about how best to respond to PRPs with "competing analyses."
Weed for policy guidance before implementation.
A broader concern expressed by respondents in several regions is the need for HQ to
reaffirm the GR priorities. This issue arose in responses to Evaluation Purpose 1
questions, and was again stressed in response to this question as a "lack of information."
Specifically, several respondents noted that a perceived "lack of guidance" confirming
the statutory basis for GR is often cited by Regional staff who are tentative about using
GR. Two respondents specifically stated that the GR Strategy has provided many useful
and practical tools for implementation, but without more specific guidance addressing
legal and policy questions, many RPMs and regional managers are reluctant to make
significant efforts to implement GR. The forthcoming HQ guidance on GR in remedy
selection may address this need to some extent, but a broader reaffirmation of HQ's focus
on GR might also be helpful as part of any forward-looking effort to increase momentum.
Weed to "revitalize" communication to ensure GR Strategy implementation.
Respondents from three regions also noted that the incentives to stay engaged in the GR
implementation process are reduced after significant achievements such as the publication
of the GR Strategy, and they are not always aware of what aspects of the Strategy are
progressing. The respondents noted that the quality of their own participation was an
issue, and emphasized that without dedicated funding for GR staff in the regions, the GR
Strategy effort is by definition something that is addressed after other required
responsibilities are met.
To supplement these insights, lEc examined the green remediation literature to see what
other approaches had been addressed. The Sustainable Remediation Forum (SURF)
31 These respondents had not yet reviewed the current Footprint Analysis for Environmental Cleanups draft document; some
of these concerns may be resolved.
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White Paper, specifically, identified a number of barriers preventing a broad
implementation of green remediation practices. These barriers are not specific to a better
understanding of the results of implementing GR practices or the GR Strategy, but they
echo several issues raised by EPA interviews. These general barriers include a lack of
regulatory guidance, insufficiently defined frameworks and metrics, few financial or
other incentives [for PRPs to participate in GR efforts], and the lack of regulatory
requirements for the incorporation of green remediation practices in remediation
assessments. The SURF White Paper also notes that consensus has not yet been reached
on specific remedial approaches and tools at sites.
3.4 SYNTHESIS OF KEY EVALUATION FINDINGS
This section provides a synthesis of the key findings of this evaluation organized by
evaluation purpose.
Consistent with the general objective of the evaluation, we have explored the GR
Strategy's progress to date in advancing greener cleanup and to inform the program
priorities going forward. The evaluation considers three main parameters: assessing EPA
experiences to date in implementing the GR Strategy; determining a baseline against
which to measure EPA progress in implementing the GR Strategy; and determining the
best metrics for measuring the program's success in implementing GR practices.
3.4.1 Evaluation Purpose 1: Assess EPA experiences to date in
implementing the CR Strategy
Overall, interview respondents were uniformly positive in their opinions of the GR
Strategy structure and purpose, though responses identified some differences of opinion
in how best to present "goals" and objectives. Several respondents noted that a more
precise goal statement could be useful both in increasing awareness and focusing further
implementation of the GR Strategy.
In the strongest finding, EPA and non-EPA interviewees had very positive views of
several key products of the GR Strategy, and felt that these tools and products have been
a key driver in facilitating an expansion of GR activities. Respondents felt that awareness
of the GR Strategy document was more limited, though publication of the GR Strategy
has facilitated the use of GR by raising the national profile of GR.
Interview responses from the regions indicate that RPMs typically do not use the GR
Strategy directly in their decision-making for GR implementation, though it is clear they
use many of the tools and products developed to support the GR Strategy. The GR
Strategy document was identified to be a more important tool for managers than for
RPMs.
It is difficult to assess the distinct contributions of either the national strategy or regional
policies separately, since they influence each other. A few regional policies informed the
GR Strategy, while others may not have been released without the national focus on GR.
Examination of regional data from surveys provides a snapshot of activities underway,
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and it is apparent that regions have increased emphasis on GR training and outreach as
the GR Strategy has emerged.
A range of challenges face the broader implementation of the GR Strategy, with key
concerns including the level of funding and support for GR Strategy personnel and
project efforts. Other hurdles include a concern about policy and liability uncertainty,
and limited participation from managers and other key staff.
3.4.2 Evaluation Purpose 2: Determine a baseline against which to
measure EPA progress in implementing the CR Strategy
Interview responses from the regions indicated that most have not focused to date on
developing a baseline. Overall most of the regions (eight often) identified that their
current practices represent a fairly accurate baseline before the GR Strategy was released
because the implementation of GR efforts is just beginning. A complexity of the GR
Strategy is that it has been implemented as a unifying approach encompassing some
existing efforts, and in some cases it clearly post-dates regional activities (e.g., Region 2
and 9). Moreover, a key goal of the program is awareness, and in some cases people are
"doing" GR without calling it GR. The findings from this evaluation suggest that EPA
consider whether one baseline is adequate to support the program. If EPA wishes to
document contribution of the GR Strategy generally, then a single date-driven baseline
may be appropriate. To document attribution, however, use of different regional baselines
for site-specific action may be necessary.
3.4.3 Evaluation Purpose 3: Determine the best metrics for measuring the
program's success in implementing GR practices
A review of the logic model associated with the GR Strategy suggests that a suite of
appropriate performance measures for program performance would directly assess the
short-term (changes in awareness), intermediate term (changes in behavior), and long-
term (changes in site practice and impacts) outcomes of the GR Strategy. Metrics for each
type of outcome would also allow EPA to assess the extent to which the GR Strategy is
effectively implemented and successful in integrating GR principles throughout the
remediation process. Successful metrics will also likely require only limited data
collection and analysis.
Review of existing and emerging tools for calculating environmental footprint suggest
EPA's efforts to craft and test a footprint methodology to support GR activities at sites
provides a comprehensive set of metrics that map four of the five GR Strategy core
elements (excluding land and ecosystems). Several metrics listed in the footprint
methodology appear consistent with other sources and may be able to be adopted with
limited additional effort. The most successful metrics may be those that HQ can estimate
using standardized values and limited regional data.
Interview responses suggest that a number of key challenges exist for understanding the
impacts of GR. As was noted in Evaluation Purpose 1, a larger issue that arose from the
interview process is the identification of the need for policy-level clarity of the GR
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Strategy. The lack of clear direction from EPA providing legal and policy justification for
incorporating GR techniques at sites seems to have decreased momentum for moving GR
forward in some regions. Other limitations that inhibit a better understanding of the
results of implementing the GR Strategy include concerns about resource constraints
(e.g., time, funding, manpower), concerns that clear legal authority for requiring GR
practices is not well defined, and reluctance on the part of EPA staff in many regions to
use the methodology to conduct footprint analyses.
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CHAPTER 4 | CONCLUSIONS AND SUGGESTED NEXT STEPS
Based on our analysis of data collected from interviews and from published and EPA
internal sources, lEc's evaluation team offers the following conclusions and suggested
next steps for consideration. We believe that implementing these suggested next steps
could ensure continued momentum for implementation of the Superfund GR Strategy and
help ensure the continued integration of GR principles into OSRTI activities.
We note that overall feedback from the interviews about experiences with the GR
Strategy has been consistently positive, and available data generally support and confirm
interview responses. Therefore, lEc's suggested next steps focus on how EPA may be
able to strengthen the GR Strategy and its products to support the successful integration
and implementation of the Strategy.
4.1 EVALUATION PURPOSE 1: ASSESS EPA EXPERIENCES TO DATE IN
IMPLEMENTING THE CR STRATEGY
Based on findings from interviews, regional data, and CLU-IN website materials and use
data, lEc concludes that the development and publication of the GR Strategy has had
some initial success in spreading general awareness about GR concepts and best
practices, educating EPA staff, providing tools for implementation of GR practices, and
supporting Agency interest for incorporating GR techniques into site cleanups and
remedial plans. However, interview responses suggest that the GR Strategy is at an
important transitional point, with a need for clear focus to ensure its continued longevity
and success. The timing of this formative evaluation is appropriate because the results can
be used to help EPA to focus on next steps for the GR Strategy, to ensure that the
momentum that was built during the development of the GR Strategy can be maintained
to ensure implementation of GR practices. Specifically, we note the following:
Even among GR Regional Coordinators and other active EPA participants in GR,
the general conclusion is that GR Strategy could benefit from more clearly defined
goals and objectives. While current documents focus on actions, it is difficult to
quickly identify clear and concise goals that could guide implementation.
Users have a very positive reaction to the range of practical tools and products for
GR implementation that have been developed as part of the GR Strategy (e.g.,
BMP Fact Sheets and the Contracting Tool Kit). These products are regarded as
user friendly, practical, and well-focused on common issues faced by RPMs. In
contrast, the GR Strategy document is not regularly referenced during site cleanup
or remedial design and selection, but is viewed as an internal document from and
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for management that acts as a high-level guide for developing an implementation
plan for GR at Superfund sites.
To date, the GR Strategy has been most successful in refocusing, defining, and
raising awareness for GR in general. Changes in practice due specifically to the
GR Strategy are still limited since less than a year has passed since publication.
Additionally, since regions also have developed separate GR guidance or policies,
it is difficult to clearly attribute practice changes wholly to the GR Strategy.
However, interviews and data suggest that, assuming momentum and interest are
maintained, changes in practice should become more measurable over time, and
will likely reflect use of the various GR Strategy-related implementation tools.
Key factors limiting the implementation of GR practices include limited resources
for dedicated GR staff at the regional level, and concerns about ensuring that GR
approaches are also cost-saving or cost-neutral. However, the most widely-noted
limitation of the current GR Strategy is the absence of published direction or
information from HQ addressing several key policy and legal questions facing
practitioners who are attempting to incorporate GR techniques at sites. It appears
that clarification could provide both practical information and a continued
indication of HQ support for GR. Moreover, it appears that other limiting factors
identified, such as RPM interest and management support, may be able to be
addressed in part by more policy-level information from HQ.
4.1.1 NEXT STEPS
The key conclusions above suggest that a number of near-term actions by EPA could
improve the direction and effectiveness of the GR Strategy as implementation continues.
Focus on clarity of goals and implementation objectives. EPA may want to
establish a near-term focus on concrete goal setting to ensure implementation of
GR Strategy key actions. At a minimum, this could involve clearly identifying
and defining the overarching goals and objectives of the GR Strategy in a concise
user-friendly document that can be widely used to promote GR principles. In
addition, EPA could provide new structure and focus for the GR Regional
Coordinators and other key GR participants by considering a more specific
implementation plan for key actions. These actions would address the internal
need for continued momentum to support GR, and could facilitate broader efforts
to expand awareness and acceptance of GR among regional staff and managers.
Continue emphasis on practical tools for GR implementation. A continued
focus on development of high-quality, practical products and resources for using
GR techniques, especially those with site-specific applicability, will help further
implementation of GR practices. Moreover, use of these products provides a clear
indication of changes in awareness of GR and implementation of GR practices.
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Increase focus on policy and legal information and tools, or on other HQ
"signaling." As a complement to the well-received practical implementation
tools, EPA may be able to support integration of GR practices by developing
materials that address key policy and legal questions. This may include, but is not
limited to, completion of the Considering Green Remediation Measures in the
Remedy Selection Process Q&A document currently underway. In concert with
other goal-setting priorities, an increased focus on practical assistance for
addressing policy questions may be useful both in overcoming regional concerns
about both specific policy issues and in reaffirming the general commitment to
GR. Finally, expressions of HQ support for GR as a priority represent signals that
are important to many front-line regional staff.
4.2 EVALUATION PURPOSE 2: DETERMINE A BASELINE AGAINST WHICH TO
MEASURE EPA PROGRESS IN IMPLEMENTING THE CR STRATEGY
Development of a clear baseline is a critical step for a new program focusing on
measuring its success. In the context of the effort to implement GR practices, the recent
publication of the GR Strategy itself provides one possible starting point for measuring
future changes. However, because the GR Strategy was developed over several years and
involved several concurrent regional efforts, it is important to distinguish between "new"
activities and those that were under development. Moreover, the GR Strategy has a dual
purpose to both physically reduce the environmental footprints at sites, and improve
awareness and integration of GR principles throughout the Superfund program. This dual
purpose adds complexity to baseline development process. Below we summarize the
conclusions for this evaluation purpose and discuss suggested next steps.
Regional interviews confirm that most regions do not currently track GR activities
across sites in any way that could be used to develop a reliable baseline "site
footprint." With the exception of energy use, little information related to the five
core elements is tracked consistently across sites.
In the absence of existing baseline information, a time-defined baseline is likely to
be most appropriate if attribution is a goal. However, to capture site-level
activities, a dual baseline may be more robust than a single uniform baseline
across regions. In eight of the ten regions, GR activities appear to be in beginning
stages, and one approach that appears reasonable is to consider all future GR
activity as an outcome of the GR Strategy. The remaining two regions, however,
have pursued GR implementation since before the development of the GR
Strategy; site-level activities in this regions would only be included if they report
specific and significant changes that are directly attributable to the Strategy. If
EPA prefers to measure the total change in GR activity without considering the
specific role of the GR Strategy (a contribution analysis) then a national time-
defined baseline is appropriate, and likely more feasible to implement.
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A single national baseline could be used to capture broader changes in awareness
and integration of GR tools and techniques throughout EPA. While many regions
report undertaking GR without calling it GR, the findings of this evaluation
suggest that broad awareness of GR as a concept are clearly linked to the
development of the GR Strategy.
4.2.1 NEXT STEPS
As EPA considers appropriate metrics for measuring program performance, it will
likely be necessary to employ two baselines. We suggest that EPA consider the
following as a starting point for establishing baselines, assuming that attribution of
impacts to the GR Strategy is a focus:
o A region-specific baseline for documenting site-level changes
(core elements) and attributing change to the GR Strategy: This
baseline would assume that all reductions in site footprints
associated with GR activities since 2010 are related to the GR
Strategy in all regions except Regions 2 and 9, where established
GR efforts pre-dated the GR Strategy development. Specific
decisions about attribution could include methods for considering
the impact of specific GR Strategy achievements in Regions 2 and 9,
and could also consider the impacts of separate regional efforts in
the remaining regions. Documenting attribution is challenging, and
would also require correcting for other potential influences such as
specific regional strategies, PRP initiatives, or other state or federal
programs.
o A national baseline for documenting integration of GR
practices into EPA cleanup culture: This baseline would support
measurement of changes in awareness and the integration of GR
policy throughout the EPA cleanup community and among other
audiences, and would assume that all measured changes in
awareness and practice (e.g., use of training opportunities and
implementation of changes such as contracting language) since
September 2010 are related to the GR Strategy.
4.3 EVALUATION PURPOSE 3: DETERMINE THE BEST METRICS FOR
MEASURING THE PROGRAM'S SUCCESS IN IMPLEMENTING GR PRACTICES
After careful review of the findings of the evaluation we conclude that a number of strong
data sources and methodologies exist for measuring the program's success in
implementing GR practices. The CLU-IN Website use data can be used to track
awareness of the GR Strategy and related products (e.g., BMPs, Contracting Tool Kit). In
addition, the footprint methodology developed by EPA appears to be a promising tool for
measuring site-level impacts of GR activities and Region 2 has developed a Clean and
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Green Policy Metrics Tracking Tool database for compiling site-level data, though it is
still in the testing phase. Below we summarize the conclusions for this evaluation purpose
and discuss suggested next steps.
To address the goal of the GR Strategy of reducing the environmental footprint of
cleanup activities, EPA must identify a method for measuring footprint reductions
resulting from implementing GR practices. We conclude that it will be necessary
for EPA to either directly measure the environmental gains at each site or develop
a set of standardized "average" site-level effects for common GR activities that
can be used to estimate national effects. One limitation of using site-level data is
that it may be necessary to establish a centralized system for tracking data, which
could be very resource intensive to manage, especially across a large number of
sites. Alternatively, if EPA uses case study and other data to develop estimates of
average site-level effects for specific GR techniques, the data collection would
require only that regions identify the number of sites employing those techniques.
The footprint methodology developed by EPA represents a clear set of
quantitative options directly measuring site performance, but interview responses
suggest that the methodology is too resource-intensive to use at every site. Review
of an array of emerging tools for calculating environmental footprint did not
identify any additional metrics or methods that would be more useful than those in
EPA's footprint methodology. We conclude that EPA's tool is appropriate for
directly measuring site-level gains for four core elements. However, to address
resource concerns among regional staff, EPA should examine options for
developing average values for specific GR activities that can be used to estimate
site progress without direct data collection and measurement.
The Superfund Green Remediation Strategy Logic Model (Exhibit 1-3) suggests a
number of measures that could be used to assess the success of the program.
Given that the GR Strategy was created to be a "living" document that is
constantly evolving, EPA will have to consider metrics that best align with current
objectives of the GR Strategy. While EPA must ultimately select metrics, the
selection should include a balanced suite that directly assesses the short-term,
intermediate term, and long-term out outcomes of the GR Strategy. Other criteria
of the best metrics could include that they: 1) track data that are readily available
and easy to collect, 2) clearly address the goals of the program (clearly linked to
logic model), 3) are resource- and cost-effective, 4) are easy to understand, and 5)
are meaningful to the intended audiences of the GR Strategy.
Respondents identified a number of key data gaps and challenges related to
measuring program success. Many of the challenges focused on the use of the
EPA footprint methodology. Many regions noted the reluctance of EPA staff in
their regions to conduct footprint analyses, the difficulty of implementing
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footprint analyses without clear policy direction, and the limited resources
available for conducting such analyses.
4.3.1 Next Steps
We recommend that EPA work with regions and develop guidance on how and
when to conduct footprint analyses and to examine the potential for utilizing such
tools to quantify environmental impacts at sites.
EPA may want to 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 that can be used to estimate national impacts
based on simple data collection from regions on GR activities underway.
We recommend that EPA select metrics to measure program success based upon
the proposed criteria listed above.
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APPENDICES
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APPENDIX A: LIST OF INTERVIEWEES
We would like to thank the individuals who provided information for this evaluation.
NAME
Carol Donna
Robin Anderson
Barbara
McDonough
Ellen Treimel
Carlos Pachon
Suzanne Wells
Ginny Lombardo
John Podgurski
Nicoletta Diforte
Kristin Giacalone
Stephanie Vaughn
Hillary Thorton
Candice Jackson
Don Rigger
Brad Bradley
Raji Josiam
POSITION
Chemical Engineer and Primary
Author of Interim Guidance
Incorporating GR into
Environmental Remediation
Writing Policy Piece for GR
Strategy
Chief of Contracts Management
Branch and Oversees Grants and
Inter-Agency Agreements
Program Analyst, Member of ASTM
Greener Cleanup Standard
Workgroup
Superfund Green Remediation
National Coordinator
Branch Chief
Superfund GR Regional Co-
Coordinator and RPM
Superfund GR Regional Co-
Coordinator
Superfund GR Regional
Coordinator and RPM
Chair of Regional GR Workgroup
and Regional Superfund
Enforcement Coordinator
RPM and member of GR workgroup
and energy forum
RPM and Presenter/Moderator at
NARPM
New Superfund GR Regional
Coordinator and RPM
Branch Chief
Superfund GR Regional
Coordinator and Brownfields
Project Officers' Assessment and
Cleanup Coordinator
Superfund GR Regional
Coordinator, RPM, Co-Lead
National Engineering
Subcommittee on GR, and On-
Scene Coordinator
ORGANIZATION
Army Corps of
Engineers
EPA OSWER
EPA OSWER
EPA OSWER
EPA OSWER
EPA OSWER
EPA Region 1
EPA Region 1
EPA Region 2
EPA Region 2
EPA Region 2
EPA Region 3
EPA Region 4
EPA Region 4
EPA Region 5
EPA Region 6
DATE
INTERVIEWED
September 1 6,
2011
September 28,
2011
August 30, 201 1
September 29,
2011
September 27,
2011
May 17- 18, 2011
July 14, 2011
July 14, 2011
July 11, 2011
July 11, 2011
July 11, 2011
July 12, 2011
July 18, 2011
September 23,
2011
July 11, 2011
July 13, 2011
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NAME
Clint Sperry
Timothy Rehder
Andria Benner
Rusty Harris-
Bishop
Jeff Dhont
Karen
Scheuermann
Julie Santiago-
Ocasio
Beth Sheldrake
Clifford Villa
Heather NiFong
Kevin Carpenter
Doug Sutton
POSITION
RPM and Co-Chair of Federal
Facilities Forum
Superfund GR Regional
Coordinator and Associate with
Super Fund Brown Fields
RPM
Former Superfund GR Regional
Coordinator (Currently
Communication Coordinator,
Liaison to OPA)
Superfund GR Regional
Coordinator
Author of Superfund GR Strategy
Activity Tracking Chart, Key Action
lead (Also Considered an
Environmental Engineer in Region
9 RCRA)
Former Superfund GR Regional
Coordinator and
Presenter/Moderator at NARPM
Superfund GR Regional
Coordinator and Superfund
Regional Program Management
Unit Manager
Assistant Regional Counsel and
Unit Manager for Staff Attorneys
Program Advisor
Member of Green Standards Work
Group and ASTM Greener
Sustainable Cleanup Team,
ASTSWMO
Technology Staff for the Division
of Environmental Remediation
EPA Consultant (assisted in the
development of the Footprint
Methodology and performs site
optimization analyses)
ORGANIZATION
EPA Region 7
EPA Region 8
EPA Region 9
EPA Region 9
EPA Region 9
EPA Region 9
EPA Region 9
(Formerly at EPA
Region 4)
EPA Region 10
EPA Region 10
Illinois EPA
New York State
Department of
Environmental
Conservation
Tetratech
DATE
INTERVIEWED
July 29, 2011
July 12, 2011
July 19, 2011
July 19, 2011
August 1 , 201 1
August 1 1 , 201 1
July 18, 2011
July 15, 2011
September 9,
2011
August 1 7, 201 1
September 20,
2011
August 8, 201 1
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APPENDIX B: INTERVIEW GUIDES
Each interview guide was sent to interviewees with the following cover letter.
Superfund Green Remediation Strategy: Implementation Evaluation
CONTACT INFORMATION
Name:
Title:
Email:
Phone number:
INTRODUCTION
Thank you for participating in this interview process. As you are aware, the Superfund
program is working to advance greener cleanups at Superfund sites. Central to this effort
is the Superfund Green Remediation (GR) Strategy, which was published in final form in
September, 2010. With the support of Industrial Economics, Inc. (IEc) and EPA's
Evaluation Support Division (ESD) in the Office of Policy, EPA's Office of Superfund
Remediation and Technology Innovation (OSRTI) is evaluating the implementation of
the GR Strategy. The evaluation is jointly funded by OSRTI and ESD, and was selected
under OP's Program Evaluation Competition, a long-term effort to build capacity for
program evaluation among headquarters and regional offices.
As part of the GR Strategy, the Superfund program is evaluating the implementation of
the GR Strategy itself. The chosen approach is to conduct a "formative" evaluation of the
national-level effort. The purpose of the evaluation is to document the GR Strategy's
effectiveness in advancing greener cleanups based on three main parameters:
Assessing EPA experiences to date in implementing the GR Strategy;
Determining a baseline against which to measure EPA progress in implementing
the GR Strategy;
Determining the best metrics for measuring the program's successes in
implementing GR practices.
Throughout the interview, we would like to know about the processes with which you are
most familiar. We also encourage you to raise any items or topics you think are important
to our evaluation. Information shared during the interviews will be anonymous and
summarized thematically, and will not be attributed to specific individuals in the
evaluation report. In presenting findings from the interviews, IEc may attribute findings
to groups of interviewees, (e.g., a regional staffer), but we will not attribute findings or
quotes to individuals without first obtaining permission from the respective interviewees.
The following interview questions are intended to serve as a guide for our conversation
and are provided in advance to spur your thinking and responses. Where possible, please
be prepared to provide specific examples. Your responses are important, and we look
forward to speaking with you. If you have any questions or would like to provide any
additional feedback or information, please contact:
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Cynthia Manson, Industrial Economics, Inc.
cj m(g),indecon .com
617-354-0074
Interview Guide for Regional GR Coordinators and RPMs
INTERVIEW QUESTIONS
Implementation of Superfund Green Remediation Strategy
General Information:
Please briefly describe your position at Region 7.
What is your role in implementing the GR Strategy!
How do you use the GR Strategy!
Evaluation Questions:
1. Which initial activities or initiatives from the GR Strategy have been most
effective in increasing awareness, adoption and/or implementation of GR
activities in your Region?
How well is the GR Strategy getting used?
Which activities have been least effective?
How successful has the GR Strategy been at helping to implement GR
practices?
What are the main challenges in advancing GR?
Which audiences have been most easily reached by the GR Strategy!
Which audiences have been more challenging or have not yet been
reached?
2. How do Remedial Project Managers (RPMs) in your Region factor the GR
Strategy into their approach to planning site cleanup?
Has your region conducted a survey of GR practices in your Region? If
so, to whom?
What GR practices are being implemented?
What percentage of RPMs are implementing specific GR practices?
What do RPMs know about the energy usage at the sites they manage?
What information do RPMs track on other GR core elements?
3. What effect has the GR Strategy had on the practice of using green remediation
techniques at Superfund sites in your region?
What practices/activities have you changed as a result of the GR
Strategy?
Does your region have a GR implementation plan?
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What other policies/strategies do you use for implementing GR
practices?
Are there other regional programs helping to move GR forward?
4. What lessons have been learned as a result of implementing the GR Strategy at
sites?
What successes have you had?
What factors affect the ability to implement the GR Strategy at sites?
i. Technical issues
ii. Cost issues
iii. Legal issues
iv. Management support
v. Contract provisions
vi. Contractor capabilities
vii. Other?
How is integration of the GR Strategy priorities (e.g., policy guidance,
training, and tools) affected by the above factors and experiences to date?
Has your region implemented or conducted any kind of GR training?
Strategic Implementation
5. Review of GR Strategy goals and objectives
Please tell us how your work has used or focused on GR Strategy goals
and objectives.
In your opinion, does EPA have clearly defined goals and objectives for
the GR Strategy!
Are these objectives and goals well aligned for different uses?
i. Management decision-making
ii. Planning and budgeting
iii. Strategic planning?
Do you have suggestions for refining goals or objectives?
Baseline Development
6. What options can we identify for developing a baseline?
What has changed since the implementation of the GR Strategy in your
Region?
When did green remediation become important to site cleanup?
What options are available for quantifying the environmental footprint at
sites?
THE FOCUS OF THIS INTERVIEW IS ON THE SIX QUESTIONS LISTED ABOVE, BUT
ANOTHER PURPOSE OF OUR EVALUATION AIMS AT EVALUATING THE BEST METRICS
FOR MEASURING THE PROGRAM'S SUCCESS IN IMPLEMENTING GR PRACTICES.
PLEASE LET US KNOW IF YOU HAVE THOUGHTS ON THE FOLLOWING THREE
QUESTIONS RELATED TO THAT TOPIC.
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Metrics for Measuring Progam Success
7. What performance measures do you think could be used for measuring the
effectiveness of the GR Strategy in achieving intended outcomes at a regional or
national level?
8. What approaches are useful for measuring the effectiveness of the GR Strategy in
reducing the environmental footprint at sites that have implemented GR practices
with respect to the five core elements ofGR Strategy!
What options exist for using qualitative or quantitative measures to
assess the five core elements of GR Strategy!
Is your region collecting any measurement data related to the use of GR?
What type?
9. Where are the primary data gaps and limitations that inhibit a better
understanding of the results of implementing the GR Strategy!
Additional Information
10. Please discuss any other issues affecting the efficiency or effectiveness of the GR
Strategy. Do you have any other suggestions to improve the GR Strategy, from
either the perspective of EPA or the intended audiences?
Interview Guide for Regional Attorneys
INTERVIEW QUESTIONS
1. Please briefly describe your position in your Region.
2. Do you work on green remediation (GR) issues?
Where in your work have you encountered GR?
3. What is your impression of GR?
What seems most promising?
What seems most troubling?
4. In your opinion, what are the challenges for implementing GR practices?
What factors affect the ability to implement the GR Strategy at sites?
Technical issues
Cost issues
Hi. Legal issues
iv. Management support
v. Contract provisions
vi. Contractor capabilities
vii. Other?
Is there currently sufficient policy or legal justification for the legal
department in your Region to support GR activities? Does the legal
department support RPMs' requests/orders to contractors or PRPs to
consider GR activities?
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5. What experience have you had with Superfund Green Remediation (GR)
Strategy?
In your experience, what aspects of the GR Strategy work well?
What aspects don't work well?
Do you have suggestions for improvements to the GR Strategy?
6. What effect has the GR Strategy had on the practice of using GR techniques at
Superfund sites in your region?
In what way has the GR Strategy shaped policy in your Region?
How has the GR Strategy been helpful to your work?
How has the GR Strategy made your job more difficult?
1. How do you coordinate with Headquarters in your GR work?
Is there anything that HQ could provide to make your work with GR
easier?
Are there specific people that you work with frequently?
Which topics do you typically address?
Are there other people or resources you consult with outside ofHQ?
8. Please discuss any other issues affecting the efficiency or effectiveness of the
GR Strategy. Do you have any other suggestions to improve the GR Strategy?
Interview Guide for Regional Supervisors
INTERVIEW QUESTIONS
1. Please briefly describe your position in your Region.
2. Do you work on green remediation (GR) issues?
How do you encounter GR?
Where in your work do you use GR?
3. What experience have you had with Superfund Green Remediation (GR)
Strategy?
In your experience, what aspects of the GR Strategy work well?
What aspects don't work well?
Do you have suggestions for improvements to the GR Strategy?
4. In your opinion, what are the challenges for implementing GR practices?
What factors affect the ability to implement the GR Strategy at sites?
i. Technical issues
ii. Cost issues
Hi. Legal issues
iv. Management support
v. Contract provisions
vi. Contractor capabilities
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vii. Other?
What effect has the GR Strategy had on the practice of using GR techniques at
Superfund sites in your region?
Has the GR Strategy been helpful to this effort?
Please discuss any other issues affecting the efficiency or effectiveness of the GR
Strategy. Do you have any other suggestions to improve the GR Strategy?
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Interview Guide for EPA Contract Specialists
INTERVIEW QUESTIONS
1. Please briefly describe your position as it relates to the Green Remediation
Strategy.
How are you involved with the GR Strategy?
In what capacity does your work promote the GR Strategy?
2. Please briefly describe the process of incorporating GR clauses into Superfund
contracts.
What does your work entail?
How does putting GR into a contract work?
Which types of contracts have GR clauses been incorporated into?
/'. Removal action
ii. Remedial response
Hi. Support services
iv. Technical enforcement support
v. Policy, program management, and administrative services
vi. Other contract venues
Are the GR clauses in contracts sufficient to promote GR practices?
i. Are they followed or ignored?
You are listed as a contributor to the Greener Cleanups Contracting and
Administrative Toolkit. Do you participate in the periodic updates of this
document?
i. Who else is involved?
ii. How are updates communicated to the intended audiences?
3. With whom do you work in the Regions? At HQ?
What level of staff do you work with in the Regions?
Do you work with Regional Coordinators or RPMs directly?
4. What are your goals for incorporating GR in Superfund contracts?
Are there metrics that you track related to GR in contracts?
i. If not, what could be tracked?
ii. Do you have a list of all contracts that incorporate GR?
How would you measure the success of what your work is trying to
accomplish?
/'. What successes have you had?
What challenges have you faced in incorporating GR into contracts?
/'. What factors affect the ability to incorporate GR into contracts?
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5. Please discuss any other issues affecting your work as it relates to the GR
Strategy. Do you have any other suggestions to improve the GR Strategy, from
either the perspective of EPA or the intended audiences?
Interview Guide for EPA GR Strategy Evaluation Work Group
Members
INTERVIEW QUESTIONS
1. What do you see as the next steps for the strategy?
What things are you working on now?
2. What type of feedback have you received about the strategy?
What type of feedback from EPA HQ?
What type of feedback from regional staff (e.g., RPMs, front line
managers, attorneys)?
3. What do you see as areas of the strategy that need the most work/attention?
Which areas are most pressing?
4. What do you see as the next steps for the footprint methodology?
Are you planning to issue any further guidance on using the
methodology?
5. What are the challenges facing the integration and implementation of the
strategy?
6. What is the status of the Region 2 database for tracking site level data?
Is that something that is intended to be shared with all the regions?
7. How do you intend to use EMS and their data in the future?
In addition to what has been tracked and collected, are there other metrics
you have or will request?
8. We received feedback that EPA should be more coordinated with other programs.
Are there any plans to do this in the future?
How would this happen?
For outside EPA contacts what do you think the coordination with EPA
on GR should be?
Interview Guide for EPA GR Strategy Policy Expert
INTERVIEW QUESTIONS
1. What is your role in the GR Strategy?
2. Tell us about the current piece you are working on.
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3. What is next for you?
4. What are the next steps for the GR Strategy as a whole?
What are the most pressing?
5. What other policy guidance to you see coming in the future?
What else is in the works?
Interview Guide for Non-EPA Federal Agencies
INTERVIEW QUESTIONS
1. Please briefly describe your position as it relates to green remediation.
2. What experience have you had with the Superfund Green Remediation (GR)
Strategy?
In your experience, what aspects of the GR Strategy work well?
What aspects don't work well?
Do you have suggestions for improvements to the GR Strategy?
3. How does the GR Strategy help with your green remediation efforts?
Does the GR Strategy create any problems?
How does the GR Strategy effort differ from yours? Is it complementary?
4. How do you coordinate with the Regional and national (Headquarters) EPA
offices in your green remediation work?
5. How does your coordination with EPA compare with your coordination with
other federal agencies?
6. Has the GR Strategy had any effect on the practice of using green remediation
techniques at remediation sites in your Agency?
What practices/activities have you changed as a result of the GR
Strategy?
What other policies/strategies do you use for implementing GR
practices?
1. Please discuss any other issues affecting the efficiency or effectiveness of the GR
Strategy. Do you have any other suggestions to improve the GR Strategy!
Interview Guide for State Programs
INTERVIEW QUESTIONS
1. Please briefly describe your position as it relates to green remediation.
2. What experience have you had with the Superfund Green Remediation (GR)
Strategy?
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In your experience, what aspects of the GR Strategy work well?
What aspects don't work well?
Do you have suggestions for improvements to the GR Strategy?
3. How does the GR Strategy help with your state-level green remediation efforts?
Does the GR Strategy create any problems?
How does the GR Strategy effort differ from yours? Is it complementary?
4. How do you coordinate with the Regional and national (Headquarters) EPA
offices in your green remediation work?
5. How does your coordination with EPA compare with your coordination with
other federal agencies?
6. Has the GR Strategy had any effect on the practice of using green remediation
techniques at Superfund sites in your state?
What practices/activities have you changed as a result of the GR
Strategy?
What other policies/strategies do you use for implementing GR
practices?
7. Please discuss any other issues affecting the efficiency or effectiveness of the GR
Strategy. Do you have any other suggestions to improve the GR Strategy!
Interview Guide for Measurement Specialists
INTERVIEW QUESTIONS
1. Please briefly describe your position as it relates to the Green Remediation
Strategy.
How are you involved with the GR Strategy?
In what capacity does your work promote the GR Strategy?
2. Please give us an update of the status of the footprint methodology.
How will this be rolled out and integrated in the Regions?
What are your plans for how people will use this?
i. Will there be guidance on how Regions can overcome some of
the limiting factors mentioned in the first round interview s? (i.e.,
time, money, resources, availability of a universal measurement
system, and educating contractors on the methodology)
How will it be determined which sites to footprint?
i. Will the EPA eventually want the analysis conducted on every
Superfund site?
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Who will provide the resources and funding to conduct the footprint
analysis?
Some Regions raised the issue of PRPs coming back with competing
analyses. How is the footprint methodology designed to limit this
problem?
How does the footprint methodology address land use?
Baseline Development
3. What ideas do you have for measuring a baseline?
What options are available for quantifying the environmental footprint at
sites?
Metrics for Measuring Progam Success
4. What performance measures do you think could be used for measuring the
effectiveness of the GR Strategy in achieving intended outcomes at a regional
or national level?
5. What approaches are useful for measuring the effectiveness of the GR Strategy
in reducing the environmental footprint at sites that have implemented GR
practices with respect to the five core elements of GR Strategy!
What options exist for using qualitative or quantitative measures to
assess the five core elements of GR Strategy!
What types of measurement data are being collected related to the use of
GR in the Regions?
6. Where are the primary data gaps and limitations that inhibit a better
understanding of the results of implementing the GR Strategy!
Additional Information
7. Please discuss any other issues affecting the efficiency or effectiveness of the
GR Strategy. Do you have any other suggestions to improve the GR Strategy,
from either the perspective of EPA or the intended audiences?
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APPENDIX C: REGIONAL SURVEY AND TRACKING DATA
REGION 3 GREEN REMEDIATION 2009 QUESTIONNAIRE:
The Region 3 Green Remediation 2009 Questionnaire results could not be formatted
effectively to include in the appendices. Instead, we include the actual questionnaire that
was sent to RPMs in the region to offer some context for the information available in the
results.
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Green Remediation 2009 Questionnaire
Site Name Location:
QPrivate QArmy QNavy QAir Force
List RPM of the site Name
WATER
Stortnwater Management:
1) Have vim installed any
of the following landscape features to control stormwater:
A) bioretention cells
B) vegetative swales
C) porous pavement/stones
D) trees
E) biosocks
F) coconut logs
la) What is the area?
Water Usage:
2) Did vou minimize water use on site?
2a) How?
3) Did you store site generated water or storm water for reuse on site?
(i.e. rainwater for dust suppression)
3a) How is the water stored and how much?
4) Did you recycle water for use on site?
4a) How is it used?
5) Have you created open space Q to filter water Q other explain:
I | storm water control
1 1 create wetlands
B\es no
ves no
{_ yes no
[_| \ es no
, D yes _ no
LJ \esL no
D >cs [H no
tU yes D no
[ D yes D no
Wetlands as water management features :
6) Have you constructed wetlands for:
a) Stormwater control
b) act as a filter before entering surface water
c) treat contaminants
d) enhancement
e) replacement
D yes D no
O yes O no
n yes D no
D yes D no
O yes E] no
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6a) How many acres? I f not known
where could we find this
information?
Green (Jrountlwater remedy:
7) Is there a groundwater or surface water component at your site?
a) monitoring only
b) pump and treat
c) in-situ treatment:
d) Was the in-situ treatment part of a pump and treat optimization?
e) other
Explain
Q yes [H no
D yes D no
O yes d no
n yes G no
n yes n no
8) What was the reagent used to treat the groundwater contaminant(s):
C] molasses Q vegetable oil [D chemical compound like potassium permanganate Q other
9) Have you installed a permeable reactive barrier as a remedy rather than
groundwater pump and treat system?
O yes LJno
1
9a) Was this part of the original remedy or a post- j %) If post-ROD why?
ROD modification?
10) Have you performed an optimization study on your site? What were the results?
yes LJ no
Is the site currently_being_reu3cd?
1 la) When did you start planning for reuse?
D Pre ROD d_ROD__ D Post ROD
lib) What was the type of re-use;
j yes I I no
nercial d ecological Q residential d municipal d other explain
12) What type of revegctation did you perform at your
site?
Qflandfill cover O replacement
O wetland
d enhance existing land
D other:
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12a) What type of species
1 2b) How many acres were planted?
O native gr
O trees/shr
Q_wctland
Dothe
13) What was the purpose of the revegetation on your site?
a) Stormwater control
b) Create, enhance, or preserve wetlands
c) Treatment of contaminants
d) Reduce green house gases
e) Enhance ecological habitat
f) Replacement of destroyed vegetation
Explain:
14) Did the remedy include plants or trees (phytoremediation) to remediate
contamination?
yes
yes
yes
CD yes IU no
[H yes Z] no
D yes Q no
no
] no
no
Soil Q yes D no
Ground water
CD yes CD no
Surface Water/Springs
n yes n no
14a) What type of plants were
used, how many acres were planted or
number of plants?
IS) Did you reduce or minimize
destruction of ecologically
significant habitats?
[JyesLjno
Amount:
Explain:
SCML:
16) Did you treat contaminated soils on-site and reuse the soils for cover or fill rather
than dig/haul contaminated soils for off-site disposal?
J yes LJ no
1?) Did you minimize off-site disposal via onsitc containment and/or treatment?
[~] yes M no
17a) How much soil,
sediment, other waste?
Describe materials and
quantify.
USoil
I | Sediment
Q Other waste
Total:
Explain:
18) Were any amendments and/or plants used to improve soil quality?
18a) What type of amendment? Example: pine bark, bio-solid
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1
18h) What quantity of soils were treated?
1 8c) Do you have information about the impacts of soil amendments have on |_J yes |_| no
sequestering green house gasses?
RECYCLING
I 19) Were recycled materials used to construct anything on site i.e. buildings, roads,
parking lots or pavement?
i Explain:
20) Did you separate materials for re-use or recycling at your site?
20a) What type of material?
D soil for cover Q wood Q metal D oil D other: D tire D Construction &
Demolition Debris
[ | green concrete
20b) How did you reuse on-site materials?
Amount:
Explain:
21) How did you minimize waste generation at the site? Explain.
Secondary Questions:
22) Did you use waste streams from other sources in your remedy? For example,
biosolids for a cover, pickle liquor for groundwatcr treatment.
22a) What type of waste?
LJyeslLJno
ENERGY
Priot
23) Do any of the components of your remedy uses low energy?
(i.e. monitoringgroundwater)
LJ yes U
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Did you design the treatment system with optimum efficiency?
24a) Did you perform an optimization study of the groundwater pump and treat
system and as a result did you find energy efficiency and/or cost savings?
IDyesDno
i n yes n no
study, how did you alter the
groundwater pump and treat system?
24c) Have you tracked your energy usage
or cost over time? What figures do you
have? Where are they reported?
24d) Are you using energy efficient equipment (pumps, lights) at your site?
24e) Are you using Energy Star equipment like computers at your site?
25) Is the power used at the site from a renewable energy source?
a) Are you using solar energy, hydro energy or wind power for energy at your site?
b) Has methane gas from a landfill at your site been used for energy?
c) Did you purchase energy from a renewable energy source?
26) Did you use field techniques to minimize energy used? (i.e. XRF, TAGA Van,
TRIAD)** of samples
O Yes [Jno
yes no
es [I] no
LJ yes LJ no
J yes I | no
27) Did you use low energy remedy such as bioremediation, reactive barrier or
phytoremediation?
AIR QUALITY AND GREEN HOUSE GASSES
Priority Questions
28) Did you minimize the generation of air emissions and greenhouse gases? i.e. reduce
equipment and transportation usage
28a) If so, how?
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28b) Did you include additional treatment on an air stripper to reduce air emissions?
29) Have you used or plan to use alternative fuels such as biodiesel, electricity, ethanol,
hydrogen, natural gas, propane in the equipment on the site?
29a) Did you try to reduce the
usage of equipment i.e.
hand excavate?
29b) Did you repair an existing
engine or equipment to
make it more efficient?
Q yes Q no
D yes D n°
i
LJyesLjno Explain: ;
CD yes O no Explain:
29c) Did you install emission reduction 1 LJ yes (_j no Explain:
technology on equipment such as
clean diesel equipment?
30) Are plans in place to reduce truck EH yes [jTno Explain: j
transport either to dispose of waste or bring i
supplies to the site?
LONG TERM STEWARD
Priority Questions
31) Have you evaluated operation and maintenance procedures in order to increase
efficiency or reduce energy usage?
3 la) For example, did you reduce monitoring frequency (number of wells,
contaminants) while still gathering sufficient data to monitor the remedy?
If yes, explain.
31b) For example, have you modified landfill vegetation so there is less maintenance?
If yes, explain.
3 Ic) For example, have you looked at composite sampling versus discrete sampling or
different levels of validation for sampling? If yes, explain.
32) Have you installed a new technology to make the remedy more efficient?
LJ yes LJ no
LJ >'es LJ no
O yes Lj] no
D yes D no
n yes n no
32a) For example, have you installed a computer based monitoring system? | | yes | | no
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32b) For example, have you installed energy efficient equipment for the operating Q yes O no
systems?
CLOSING QUESTIONS
33) What training or resources would
help you use green remediation?
34) What are the greenest aspects of your
remedy? Or planned green remedy?
Can any other KI'M's who had the site
elaborate on green aspects of the
remedy?
35) What type of documentation do you
have on the green component of the
remedy including reasons why it was
implemented and cost and where could
we find this information?
36) Would you be interested in attending
the Green Cleanup Symposium
scheduled for February lO11* & II1*,
2010? Or present a case study at the
Green Cleanup Symposium?
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REGION 4 2010 GREENER CLEANUP SURVEY:
MEMORANDUM
United States Environmental Protection Agency B&V Project 049049
TO 49 - Green Remediation May 26, 2011
To: Julie Santiago-Ocasio, U.S. Environmental Protection Agency
Subject: Greener Cleanup Survey Summary Memorandum
Document Control Number 49049-0872-02-E-00833RO
This memorandum summarizes the results of the U.S. Environmental Protection Agency (EPA)
Region 4 Superfund Greener Cleanup Survey. Region 4 conducted this survey to assess progress
in implementing Greener Cleanup practices at Superfund sites across Region 4. The information
obtained through this survey will help to identify training needs and opportunities to aid personnel
in implementing Greener Cleanup practices at their sites. This information will also be utilized to
develop tools and case studies to help Remedial Project Managers (RPMs) learn from successes
and/or failures of the implementation process.
This memorandum has been prepared by Black & Veatch Special Projects Corp. (Black & Veatch)
under Contract Number EP-S4-09-02 with EPA Region 4 and under specific authorization of EPA
Region 4 through the Task Order (TO) Number 049.
The results of the survey are presented below. For reference, the definitions of the five Principles
for Greener Cleanups are included.
Principle 1: Total Energy Use and Renewable Energy Use
Minimize energy consumption (e.g. use energy efficient equipment).
Power cleanup equipment through onsite renewable energy sources.
Purchase commercial energy from renewable resources.
Principle 2: Air Pollutants and Greenhouse Gas Emissions
Minimize the generation of greenhouse gases.
Minimize generation and transport of airborne contaminants and dust.
Use heavy equipment efficiently (e.g. diesel emission reduction plan).
Maximize use of machinery equipped with advanced emission controls.
Use cleaner fuels to power machinery and auxiliary equipment.
Principle 3: Water Use and Impacts to Water Resources
Minimize water use and depletion of natural water resources.
Capture, reclaim and store water for reuse (i.e., recharge aquifer, drinking water
irrigation).
Minimize water demand for revegetation (i.e., native species).
Employ best management practices for stormwater.
Principle 4: Materials Management and Waste Reduction
Minimize consumption of virgin materials.
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Minimize waste generation.
Use recycled products and local materials.
Beneficially reuse waste materials (e.g., concrete made with coal combustion products
replacing a portion of the Portland cement).
Segregate and reuse, or recycle materials, products, and infrastructure (e.g. soil,
construction and demolition debris, buildings).
Principle 5: Land Management and Ecosystem Protection
Minimize areas requiring activity or use limitations (e.g., destroy or remove contaminant
sources).
Minimize unnecessary soil and habitat disturbance or destruction.
Use native species to support habitat.
Minimize noise and lighting disturbance.
General
The Greener Cleanup Survey was sent to 63 EPA Remedial Project Managers (RPMs). A total of
34 RPMs, or 54%, responded to the survey; however, only 31 respondents answered all of the
questions. The following is a list of all EPA RPMs who participated in the study:
Femi Akindele Bill Denman Leigh Lattimore Michael Taylor
Cathy Amoroso Carl Froede Jr. Lila Llamas Michelle Thornton
Jim Barksdale Rachel Hall McKenzie Mallary Peter Thorpe
Martha Berry Corey Hendrix Keriema Newman Samantha Urquhart-Foster
Jon Bornholm Ralph Howard Rob Pope Debbie Vaughn-Wright
Randy Bryant Candice Jackson Jon Richards Tim Woolheater
Carolyn Callihan Constance Jones Carmen Santiago-Ocasio Craig Zeller
Loften Carr Yvonne Jones Pam Scully
Peter Dao Rusty Kestle Erik Spalvins
Type of Site
Superfund - 20
Superfund with Federal Facilities Sites - 13
Both Superfund & Superfund with Federal Facilities Sites - 1
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Number of sites managed by each of the responding RPMs
Number of Sites
1
2
o
J
4
5
6
7
8
9
10
11
15
20
Number of RPMs
8
5
1
3
3
4
3
1
1
2
1
1
1
Principles for Greener Cleanups
Principle 1: Total Energy Use and Renewable Energy Use
12 RPMs, or 35% of the respondents, have implemented this principle.
Specific elements include:
o Consider use of optimized passive-energy technologies (with little or no
demand for external utility power) that enable all or part of the
remediation objectives to be met - 8
o Look for energy efficient equipment and maintain equipment at peak
performance to maximize efficiency - 6
o Periodically evaluate and optimize energy efficiency of equipment with
high energy demands - 2
o Consider installing renewable energy systems to replace or offset
electricity requirements otherwise met by the utility (i.e., solar powered
sampling devices) - 5
o Other - solar powered surface water monitoring system
Reason for implementing the principle
o Technical -10
o Financial - 5
o To comply with Region 4 Clean and Green Policy - 3
o To comply with Greener Cleanup language added in an enforcement
document - 0
o Other: No onsite power source.
Did the principle play a role in the selection of a remedy?
o Yes -1
o No -10
Did the principle affect the way the remedy was implemented?
o Yes - 3
o No - 6
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o Not applicable - 2
Did the principle affect post construction activities?
o Yes - 3
o No-5
o Not applicable - 3
Sites where Principle 1 has been implemented
Site Name
Marshall Space Flight Center
P Area OU 94
Landia Chemical
Savannah River Site
Sanford Gasification
M Area OU
Cape Fear
Savannah River Site
Barite Hill
Nevada Goldfields
Redstone
Oak Ridge Reservation
East TN Technology Park
Calculator
Used?
No
No
Yes
No
No
No
No
No
No
No
No
No
No
Phase
Investigation, Remedy Selection,
Remedial Design, and Implementation
Remedy Implementation
Remedy Implementation
Remedy Implementation
Remedy Implementation
Remedy Implementation
Post-Construction Complete
Remedy Implementation
Investigation
Investigation
Investigation
Remedial Design and Implementation
Remedial Design and Implementation
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Principle 2: Air Pollutants and Greenhouse Gas Emissions
14 RPMs, or 41% of the respondents, have implemented this principle.
Specific elements include:
o Minimize use of heavy equipment requiring high volumes of fuel - 4
o Use cleaner fuels and retrofit diesel engines to operate heavy
equipment, when possible - 2
o Reduce atmospheric release of toxic or priority pollutants (ozone,
paniculate matter, carbon monoxide, nitrogen dioxide, sulfur dioxide,
and lead) (i.e., use of anti-idling policies) - 6
o Minimize dust export of contaminants -12
o Other - minimization of personnel traveling to the site
Reason for implementing the principle
o Technical -10
o Financial - 2
o To comply with Region 4 Clean and Green Policy - 3
o To comply with Greener Cleanup language added in an enforcement
document - 0
o Other - This is a standard operating procedure at SRS, To control
fugitive dust emissions, Generally good practice.
Did the principle play a role in the selection of a remedy?
o Yes - 2
o No-11
Did the principle affect the way the remedy was implemented?
o Yes - 3
o No-9
o Not applicable -1
Did the principle affect post construction activities?
o Yes - 0
o No-8
o Not applicable - 5
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Sites where Principle 2 has been implemented
Site Name
East TN Technology Park
Oak Ridge National Lab
Savannah River Site
Landia Chemical
Aqua Tech
T Area OU
Sanford Gasification
TVA Kingston
Cape Fear
Barber Orchard
Barite Hill
NAS Jacksonville
Redstone Arsenal
Oak Ridge Reservation
East TN Technology Park
Smokey Mountain Smelters
Sprague Electric
Calculator
Used?
No
No
No
Yes
No
No
Yes
Yes
No
No
No
No
No
No
No
No
No
Phase
Treatability Study
Remedy Implementation
Remedy Implementation
Remedy Implementation
Remedy Implementation
Post-Construction Complete
Remedy Implementation
Remedy Implementation
Post-Construction Complete
Remedy Implementation
Investigation
Investigation, Remedy Selection,
Implementation, and Post-Construction
Complete
Investigation, Remedy Selection,
Remedial Design, and Implementation
Remedy Implementation
Remedy Implementation
Investigation & time critical remedy
Remedial Design
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Principle 3: Water Use and Impacts to Water Resources
17 RPMs, or 50% of the respondents, have implemented this principle.
Specific elements include:
o Minimize fresh water consumption and maximize water reuse during
daily operations and treatment processes - 6
o Reclaim treated water for beneficial use such as irrigation - 3
o Use native vegetation requiring little or no irrigation - 7
o Prevent impacts such as nutrient loading on water quality in nearby
water bodies (i.e., erosion prevention methods like silt fences) -14
o Other - Recycling treated groundwater - 2 and using straw to retain
water in soils being revegetated
Reason for implementing the principle
o Technical -14
o Financial - 7
o To comply with Region 4 Clean and Green Policy - 2
o To comply with Greener Cleanup language added in an enforcement
document - 0
o Other - Standard DOE policy, Request of FWS, Common sense,
Generally good practice
Did the principle play a role in the selection of a remedy?
o Yes - 4
o No -12
Did the principle affect the way the remedy was implemented?
o Yes - 4
o No-9
o Not applicable - 3
Did the principle affect post construction activities?
o Yes - 4
o No-7
o Not applicable - 5
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Sites where Principle 3 has been implemented
Site Name
Oak Ridge National Lab
Anniston PCB
Marshall Space Flight Center
Savannah River Site
Escambia Treating Company
Landia Chemical
Aqua Tech
Lexington County Landfill
Holtrachem
Reasor Chemical
Shuron
Sanford Gasification
TVA Kingston
Cape Fear
Geigy Chemical
Redstone Arsenal
Site 12 Jericho Island
Site 3 Causeway Island
Site 45 Former Drycleaner
ET Cover
Oak Ridge Reservation
East TN Technology Park
Sprague Electric
Gurley Pesticide
Stauffer Chemical Tarpon Springs
Calculator
Used?
No
No
No
No
No
Yes
No
No
No
No
No
Yes
Yes
No
No
No
No
No
No
No
No
No
No
No
No
Phase
Remedy Implementation
Remedy Selection/Feasibility Study
Investigation, Remedy Selection,
Remedial Design, and Implementation
Post-Construction Complete
Remedy Implementation
Remedy Implementation
Remedy Implementation
Remedy Implementation and Post-
Construction Complete
Investigation
Post-Construction Complete
Remedy Implementation
Remedy Implementation
Remedy Implementation
Post-Construction Complete
Post-Construction Complete
Remedy Implementation
Post-Construction Complete
Post-Construction Complete
Remedy Selection/Feasibility Study
and Maintenance Action
Post-Construction Complete
Remedy Implementation
Remedy Implementation
Remedial Design
Soil Remedial Action Complete
Remedy Implementation
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Principle 4: Materials Management and Waste Reduction
19 RPMs, or 56% of the respondents, have implemented this principle.
Specific elements include:
o Use technologies designed to minimize waste generation - 8
o Reuse materials whenever possible -10
o Recycle materials generated at or removed from the site whenever
possible -15
o Minimize natural resource extraction and disposal - 2
o Use passive sampling devices producing minimal waste, where feasible
(i.e., use of baroball, remote controlled sampling devices, etc.) - 7
o Other - autonomous sampling and monitoring system reduces the
generation of waste, use of local products, resale/salvage/re-use of SVE
blower unit
Reason for implementing the principle
o Technical -14
o Financial -13
o To comply with Region 4 Clean and Green Policy - 3
o To comply with Greener Cleanup language added in an enforcement
document - 0
o Other - Because it's smart to recycle, Generally good practice
Did the principle play a role in the selection of a remedy?
o Yes - 0
o No -19
Did the principle affect the way the remedy was implemented?
o Yes - 8
o No-7
o Not applicable - 4
Did the principle affect post construction activities?
o Yes - 5
o No - 10
o Not applicable - 4
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Sites where Principle 4 has been implemented
Site Name
American Creosote Works
National Southwire Aluminum
Marshall Space Flight Center
National Electric Coil
Savannah River Site
Escambia Treating Company
ITT Thompson Institute
Solitron Microwave
Solitron Devices
Aqua Tech
Lexington County Landfill
Medley Farm Drum Dump
Staley PCE
Sheet Metal Restoration
Holtrachem
Oak Ridge
Sanford Gasification
Aberdeen Pesticide Dump
Barber Orchard
Blue Ridge Plating
Cape Fear
Chemtronics
National Stach & Chemical Co
Savannah River Site - T Area GW
-EOS
Barite Hill
Nevada Goldfields
Redstone Arsenal
Calculator
Used?
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
Yes
No
No
No
No
No
No
No
No
No
No
Phase
Post-Construction Complete
Post-Construction Complete
Investigation, Remedy Selection,
Remedial Design, and Implementation
Post-Construction Complete
Remedy Implementation
Remedy Implementation
Remedy Implementation
Post-Construction Complete
Post-Construction Complete
Remedy Implementation
Remedy Implementation and Post-
Construction Complete
Remedy Implementation
Investigation
Investigation
Investigation
Remedial Design and Implementation
Remedy Implementation
Post-Construction Complete
Remedy Implementation
Post-Construction Complete
Post-Construction Complete
Remedy Selection/Feasibility Study
and Post-Construction Complete
Post-Construction Complete
Remedy Implementation
Investigation
Investigation
Remedy Implementation
C-18
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Site 12 Jericho Island
ET Cover
Oak Ridge Reservation
East TN Technology Park
Smokey Mountain Smelters
No
No
No
No
No
Post-Construction Complete
Post-Construction Complete
Remedy Implementation
Remedy Implementation
Time critical removal action
Principle 5: Land Management and Ecosystem Protection
16 RPMs, or 47% of the respondents, have implemented this principle.
Specific elements include:
o Use minimally invasive in situ technologies - 7
o Use passive energy technologies such as bioremediation and
phytoremediation as primary remedies or "finishing steps," where
possible and effective - 7
o Minimize soil and habitat disturbance -13
o Minimize bioavailability of contaminants through adequate source
control/containment - 8
o Reduce noise and lighting disturbance - 4
o Other - Use of native plants where new planting was required - 2 and
early soil source removal
Reason for implementing the principle
o Technical -13
o Financial - 6
o To comply with Region 4 Clean and Green Policy - 2
o To comply with Greener Cleanup language added in an enforcement
document - 0
o Other - Better for the environment, To keep citizens happy, Good
practice - especially for the site environment
Did the principle play a role in the selection of a remedy?
o Yes - 5
o No-11
Did the principle affect the way the remedy was implemented?
o Yes - 5
o No-11
o Not applicable - 0
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Did the principle affect post construction activities?
o Yes - 3
o No-5
o Not applicable - 8
Sites where Principle 5 has been implemented
Site Name
Oak Ridge National Lab
National Southwire Aluminum
Marshall Space Flight Center
Savannah River Site
Escambia Treating Company
ITT Thompson Institute
GMH Electronics
Murray Ohio Dump
M Area OU
Cape Fear
Savannah River Site
Barite Hill
Nevada Goldfields
Redstone Arsenal
M Area OU
Aberdeen Pesticide Dump
Barber Orchard
Blue Ridge Plating
Cape Fear
Chemtronics
National Stach & Chemical Co
Geigy Chemical
Redstone Arsenal
Site 1 Incenirator
Calculator
Used?
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
Phase
Remedy Implementation
Post-Construction Complete
Investigation, Remedy Selection,
Remedial Design, and Implementation
Remedy Implementation
Remedy Implementation
Remedy Implementation
Remedy Selection/Feasibility Study
and Remedy Implementation
Remedial Design
Remedy Implementation
Post-Construction Complete
Remedy Implementation
Investigation
Investigation
Investigation
Remedy Implementation
Post-Construction Complete
Remedy Implementation
Post-Construction Complete
Post-Construction Complete
Remedy Selection/Feasibility Study
and Post-Construction Complete
Post-Construction Complete
Post-Construction Complete
Remedy Implementation
Post-Construction Complete
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Site 5 Jericho Causeway Landfill
Site 45 Former Drycleaner
ET Cover
Oak Ridge Reservation
East TN Technology Park
Sprague Electric
No
No
No
No
No
No
Post-Construction Complete
Remedy Selection/Feasibility Study
and Maintenance Action
Post-Construction Complete
Remedy Implementation
Remedy Implementation
Remedial Design
Other Greener Cleanup Practices
PRP Lead Sites
Do you have any PRP-Lead sites?
22-YES
9-NO
Is there an enforcement agreement in place for any of your PRP-Lead sites?
20-YES
2-NO
Was there Greener Cleanup Language in any of the agreements?
0-YES
20-NO
Did you have any PRPs that were willing to incorporate aspects of your regional Clean and Green
policy or other Greener Cleanup elements or best management practices?
16-YES
6-NO
Did any PRPs perform actions above and beyond the minimum Greener Cleanup requirements?
4-YES
6-NO
11 - Not applicable
Additional Questions
Are you familiar with the EPA Region 4 Clean and Green policy?
26-YES
5-NO
Are you familiar with the Superfund Green Remediation Strategy?
28 - YES 3 - NO
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REGION 9 LIST OF GR ACTIVITIES:
Region 9 Superfund Green Remediation Projects
Site
Aerojet
Apache Powder
Camp Pendelton
Marine Base
Del Amo
Frontier Fertilizer
Frontier Fertilizer
Iron Mountain Mine
Lawrence
Livermore Lab
Leviathan
McColl
Newmark
Ohlone
College/Newark
Center
Pemaco
Selma Treating
Company
Stringfellow
Alameda NAS
Travis AFB
Tucson
International
Airport
Apache Powder
McKinley Mine,
Navajo Nation
Nineteenth Avenue
Landfill
Operating Industries
Type
Superfund
Superfund
Superfund
Superfund
Superfund
Superfund
Superfund
Superfund
Superfund
Superfund
Superfund
Brownfields
Superfund
Superfund
Superfund
Superfund
Superfund
Superfund
Superfund
(none -closed
coal mine-no
substantive
EPA program)
Superfund
Superfund
Project
3.6MWPV
Wind and 1.4 KW PV system for constructed wetlands
to conduct bioremediation
Clean diesel/biodiesel/DPF for non-road equipment
during earthmoving operation
Oxygen injection to reduce time (and energy use) of
soil vapor extraction system
5.7 KW PV system for groundwater treatment
500 KW PV system for in-ground heating
Ran transmission line to use local hydro power instead
on on-site diesel generators
PV to power groundwater treatment
NREL renewable energy evaluation
PV panel to power sump pump
PV powered monitoring equipment at 50 wells
600 KW PV system 45% of campus electricity need
3.4KWPVsystem
Molasses injection into groundwater plume reduced
cleanup time 30-50 years/energy use
NREL renewable energy evaluation
Life Cycle Analysis
Life Cycle Analysis
Life Cycle Analysis (HQ support)
Technical support for solar farm development
Technical support for renewable energy development
Support for Phoenix and ADEQ for possible solar
development
Six-70 KW microturbines burn landfill gas
Status
Operational;
additional 2.4
MW in planning
Operational
Completed
Operational
Operational
Planning/not
feasible
Operational
Operational
In process
Operational
Operational
Operational
Operational
Operational
In process
In process
In process
In process
In process
In process
In process
Operational
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APPENDIX D: EPA CLU-IN USE DATA
GR Focus Stats
E«tract«d from monthly CUMN rtports;
23,4 133
Total Requests for GR Focus Pages
ss sss * ss
Direct Vlsltofs (%)
Estimated Visits
>v >w sss sss *
Average Visit Length (min)
s^s^r
Visitor Repeat Rate (%)
ss sss * ss sss
Total User Hours
Notable
rnethodology d
methodology- a
UST fact sheet
mtrofactsheet(>4>datB)
reri«wable enera- Fact sheet
contracting toolkit
Superfurd GR Strategy
dean fuels/emissions fact sheet
SVE&«fact sheet
biorernedation
P&T
site invesogaCiorr
excavation 8. restoration
September 16, 2011
^uly 7, 2011
June M, 2011
tutey 3A20U
Ap-il 13, 2011
February 1, 2011
September 2ft 2010
August 31. 2010
March 24 2010
March 24, 2010
January 18, 2010
Ifirn.lr,- I :, ;-- -M
January 23, 2009
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Superfund Green Remediation Strategy: strategic action progress based on use of online products and training
Detailed CLU-INGR Focus slots as of August 1, 2011, unless noted otherwise
Action 2.3 Develop technology-specific assessment tools and fact sheets
An Introduction (May 11, 2011, update * original); http://www.duin.crg/greenremedi3tiw/dccs/GR_Quick_Ref_FS_lntro.pdf
Excavation and Surface Restoration (EPA 542-F-08-012, December 2008);
http^/www. cluin.org/grpenremediati on/doc s/GRJ3uick_Ref_FS_exc_rest.pdf
Site Investigation {£PA 542-F-09-OD4, December 2009); http://www.cluin.org/greenremediation/docs/GR_Fact_Sheet_SI_12-31-20Q9.pdf
Pump and Treat Technologies (EPA 542-F-09-C05, December 2009J; http://www.cluin.org/greenremed!ation/docs/GR_Fact_Sheet_P&T_12-31-
2009.pdf
Bioremediation (EPA542-F-10-006, March 2010);httpv'/www.cluin.CTB/greenremediation/docs/QR_fact^eet_biorem_B2410.pdf
Soil Vapor Extraction & Air Sparging (EPA 542-F-10-007, March 2010);
http;//www. cluin.org/greenremedJati on/doc s/GR_factsheet_SVE_AS_032410.pdf
Sfteswith Leaking Underground Storage Tank Systems (EPA 542-F-ll-QOS, June 2011);
http://www.duin.orB/greenremediati on/docs/ US T_GR_fact_sheet.pdf
Total
S of Views
EPA other gov non gov ft of Downloads EPA otliei gov non gov
280
2,659
1,190
2,120
1,842
430
10,238
0
10
31
37
24
0
US
3
8
33
31
47
112
350
272
2,641
1,126
2,052
1,771
318
9,760
Action 2.6 Deliver or host green remediation training through the Technology Innovation and Field Services Division's Training
Infrastructure (as of August 17,2011)
CLU IN Web Seminars (open to the public)
Greener Cleanups - EPA's Methodology for Understanding and Reducing a Project's Environmental Footprint. August 10, 2011.
NARPM Presents: Ecological Revitalization: Turning Contaminated Propertiesfnto Communfty Assets. March 15, 2011.
US and EU Perspectives on Green and Sustainable Remediation (Part 2 of ConSoil 2010 follow-up). March 15, 2011.
Your Rote in Green Remediation Implementation and Case Studies In Green Remediation - This Year's Models and Tools (2010 NARPM green
remediation session follow-on Webinar series )
Session 1; Decembers, 2010
Session 2; January 11, 2011
Session 3; February 10, 2011
Identifying & Evaluating Ecosystem Services at Contaminated Sites Prior to Remediation. August IS, 2010.
US and EU Perspectives on Green and Sustainable Remediation. July 12, 2010.
Energy for the Future: Exploring Methane Gas-to-Energy Projects at Superfund Sites- May 6, 2010.
Green Remediatfon: Applying Strategies in the Field {2009 NARPM green remediation session foltlow-on Webinar series}
Session 1; October 8, 2009
Session 2; November 12, 2009
Session 3; December 15, 2009
Understanding Life Cycle Assessment: Applications for OSWEffs Land and Materials Management September 23, 2009.
Solar Energy on Closed Landfills: Regulatory and Technical Considerations. September 9, 2009.
Tackling the Carbon Footprint at Pump and Treat Projects: A Case Study in Energy Efficiency. March 10, 2009.
Green Remediation Voluntary Standards Initiatfve. March 4, 2009
Green Remediation: Opening the Door to Field Use (2OO8 NARPM gresn remediation sessianfolltow-on Webinar series}
Introduction and Carbon Calculus: A RCRA Case Study. Session A: November 24, 2008
Green Remediation Toolsand Examples. Session B: December 16, 2008
Green Remediation Toolsand Examples. Session C: January 13, 2009
USEPA-ILEPA Green Remediation Update. Decembers, 2008
ConSoil 2008Speci3l Session: Green Remediation. June 5, 2008
Earth Day 200S Green Remediation Panel Session; green remediation, soil amendments for impaired lands, and renewable energy on
contaminated lands. April 2008.
Total
Training Courses (in-person sessions open to the public, based on OSRTI tally of August 10, 2011)
Best Management Practices for Green Remediation Footprint Reduction; August 29, 2011; Westin New Orleans Canal Place, New Orleans, LA
Best Management Practices for Green Remedfation Footprint Reduction; November 15, 2011; U.S. EPA Region 2, New York, NY
S of Participants
359
76
125
199
200
218
119
174
74
]"-
160
157
in?
191
202
190
200
205
189
267
28
232
3,863
near future
near future
1 IV
40
24
13
80
45
45
9
4
17
53
36
26
33
M
17
>.i
32
29
45
12
3
17
-I-.
\ IV,
olliei gov
37
19
1"
39
33
43
44
49
10
.-,i
35
24
A':
,,u
41
40
43
37
48
179
4
69
1,013
ortiei gov
non gov
232
33
94
80
122
130
66
121
47
100
89
107
31
: 'is
144
120
125
as
96
76
21
146
2,227
rion gov
Hours
2
2
2
2
2
2.25
2.25
1.5
2
2
2
2
2
1.5
1
1
2
2
2
2
2
1.5
39.00
8
.-:
D-2
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Total
Total number of participants and training hours in public venues
Annual N AH I'M Training Conference (based on OSRTI tally of August 10,2011)
ISth; Green Remediation: Opening the Door to Field Use. July 9, 2008
19th: Green Remediation - What's Next. June 3, 2009
20th: Your Role in Green Remediation Implementation and Case Studies in Green Remediation: This Year's Models and Tools. May 26, 2010
21st: Greener Cleanups
An RPM's Primer. May 17, 2011
Case Studies and Discussion. May 18, 2011
Addressing Your Project's Environmental Footprint Theory and Practice. May 18, 2011
Total
Annual OSC Readiness (based on OSRTI tally of August 10,2011)
12th: Greening Response Actions I. February 12, 2009
13th: Greening Response Actions II. February 1, 2010
14th: Greening Response Actions III. January 31, 2011
Total
Total number of RPMs/OSCs trained and training hours delivered
Total number of others trained at NARPM and OSC Readiness
Action 3.4 Develop a fact sheet on using green power for site cleanup
Using input from RPMs experienced in applying onsite renewable energy, OSRTI issued a fact sheet entitled: Green Remediation Best
Management Practices: integrating Renewable Energy into Site Cleanup (EPA S42-F-11-006) in March 2011,
nttp://www.c lu in. o i g/gieenremetl ia lion/docs/I ntegrating_RE_into_site_cleanup_factsheet.pdf
Action 4.1 Develop a fact sheet on dean fuel and emission technologies
With input from OTAQ and regional offices, OSRTI issued a fact sheet entitled: Green Remediation Best Management Practices: Clean Fuel &
Emission Technologies for Site Cleanup (EPA 542-F-10-008) in August 2010.
http^/www.cluin.org/greenremediation/doc5/dean_Fuel Emis_GR_fact_sheet_S-31-10.pdf
Action 4.3 Identify opportunities for recovering and using methane gas emitted from landfills on Superfund sites
Using a screening tool developed by OSRTI, the Agency evaluated feasibility of methane recovery at six NPL sites, as described in the Superfund
Landfill Merhane-to-Energy Pilot Project (OSWER 9200.081, December 2010) released in June 2011.
http-y/www.cluin.org/greenremediation/docVLand fill_Methane_Rnal_Report_051031.pdf
Action 5.2 Develop and pilot test a green remediation analysis template to help collect information during various phases of the
remediation process at any site
Ronnie Environmental Technologies Corporation facility in Palo Alto, CA; http^/www.cluin.org/greenremediation/romic/index.cfm,'
hftp^/www.cluin.org/greenremediation/romic/docs/r omic_report_rev_051110.pdf
Former BP Products North America, Inc. Facility in Wood River, IL; http://www.cluin.org/greenremediation/bpwoodriver/Index.cfm;
httpy/www.cluin.org/6reenremediat(on/bpwoodrIver/docs/final_8P_report_111510.pdf
Travis Air Force Base
Total
Action 5.3 Incorporate green remediation factors Into remedy optimization evaluations
As part of remedy optimization studies at Superfund sites, OSRTI has evaluated various options for reducing the environmental footprint of cleanup
at Shepley's Hill Landfill in Devens, MA. http://www.clu-
in.org/greenremediation/docs/Rnal%20Shepleys%20Hill%20Landfiliyo20RSEyo20082109.pdf
Action 6.3 Develop and periodically update a green remediation contracting toolkit
In June 2009, OSRTI initially released the Green Response and Remedial Action Contracting and Administrative Toolkit, which was updated in
October 2010. Injanuary 2011, OSRTI issued the (re-titled) document, Greener Cleanups Contracting and AdminhtratMe Toolkit,http://www.clu-
in.org/gfeenremediathn/docs/Greener__Cleanups_Contracting_and_Adminhtrative_Tootkit,pdf
Action 8.1 Analyze existing methods and software tools for evaluating the environmental footprint of a cleanup
M 16
3,863 623 1,013 2,227 55.00
tt of Partipcants
85
55
H
47
S3
46
123
31
46
is
105
202
zje
RPMs
43
v
'.'.
17
13
19
157
other
42
25
22
.'i
20
27
166
OSCs other
10 21
22 24
13 15
45 60
Hours
S
:-,
:-:
4
4
4
4
4
4
48
S of Views EPA other gov non gov ft of Downloads EPA other gov non gov
332 0 5 327
tt of Views EPA other gov non gov It of Downloads EPA other gov non gov
347 4 6 337
tt of Views EPA other gov non gov tt of Downloads EPA other gov non gov
46 0 0 46
0 of Views EPA other gov non gov tt of Downloads EPA other gov non gov
1,037 96 10 931 146 14 2 130
50 3 0 47
196
tt of Views EPA other gov non gov tt of Downloads EPA other gov non gov
270 19 2 249
unava'lable 8/1
1,307
268 S 3 257
tt of Views EPA other gov non gov tt of Downloads EPA other gov non gov
1,227 71 21 1,135
ttofViews EPA other gov nongov tt of Downloads EPA other gov non gov
D-3
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OSRTI has identified more than 50 Web-based calculators, software models, and other tools that can help quantify environmental outcomes
associated with one or more core element of green remediation. Four additional, no-cost online tool shave been developed by other federal
agencies or states to specifically address green and sustainable site cleanup. http://www.clu-m.crg/greenremediation/subtabj33.cfrn 543 276 121 151
Action 8.2 Develop an Agency methodology for evaluating the environmental footprint of a cleanup 8 of Views EPA other gov nongov # of Downloads EPA other gov non gov
OSRTI released Footprint Analysis foi Environmental Cleanups near future
Footprint Assessment: Methodology [www.cluin.org/greenremediation/rnethodologypage to be activated Septembers] near future
Footprint Analysis for Environmental Cleanups [PDF to be posted September Son "metnodolcgy" page]
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APPENDIX E: LIST OF REFERENCES
2010 Green Remediation Coordination Meeting Surveys. Oct. 2010. Atlanta, GA.
Air Force Center for Engineering and Environment. "Sustainable Remediation Tool
(SRT)."
(http://www.afcee.af.mil/resources/technologytransfer/programsandinitiatives/sus
tainableremediation/srt/index.asp).
Association of State and Territorial Solid Waste Management Officials (ASTSWMO).
"Greener Cleanups Task Force (GCTF) Incentives for Greener Cleanups." June
2009..(http://www.astswmo.org/Files/Policies_and_Publications/Sustainability/G
reener_Cleanups/GCTF_Incentives_Paper_6-25 -09 .pdf).
ASTSWMO. "Green Remediation: Getting Started by Debunking Some Myths." August
2009.
(http://www.astswmo.org/Files/Policies_and_Publications/Sustainability/Greener
_Cleanups/Green-Remediation-Myth-Busters_August-2009 .pdf).
California EPA Department Toxic Substances Control (DTSC). "DTSC's Interim
Advisory for Green Remediation." December 2009.
(http://www.dtsc.ca.gov/OMF/Grn_Remediation.cfm).
California EPA DTSC. "Green Remediation Evaluation Matrix (GREM)."
(http://www.dtsc.ca.gov/OMF/Grn_Remediation.cfm)
EMS (an EPA contractor). U.S. EPA Superfund CLU-IN Website Use and Download
Data. August-September 2011.
Illinois EPA Greener Cleanups Webpage (http://www.epa.state.il.us/land/greener-
cleanups/)
Illinois EPA. "Greener Cleanups: How to Maximize the Environmental Benefits of Site
Remediation (Greener Cleanups Matrix)."
(http://www.epa.state.il.us/land/greener-cleanups/matrix.pdf).
GeoTrans, Inc. "Environmental Footprint Analysis of Three Potential Remedies: BP
Wood River, Wood River, IL." November 15, 2010. (http://www.clu-
in.org/greenremediation/bpwoodriver/index.cfm).
GeoTrans, Inc. "Environmental Footprint Analysis of Three Potential Remedies: Former
Romic Environmental Technologies Corporation Facility, East Palo Alto,
California." May 11, 2011. (http://www.clu-
in.org/greenremediation/romic/index.cfm).
Geo Trans, Inc. "Shepley's Hill Landfill RSE & GR Evaluation." August 21, 2009.
(http://www.clu-in.org/greenremediation/subtab_b3.cfm).
Massachusetts Department of Environmental Protection (MassDEP). "Sustainable
Remediation - FAQs."
(http://www.mass.gov/dep/cleanup/priorities/susrem.htm).
Minnesota Pollution Control Agency. "Greener Practices for Business, Site Development,
and Site Cleanups: A Toolkit." Last modified April 2010.
(http://www.pca.state.mn.us/index.php/topics/preventing-waste-and-
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pollution/sustainability/greener-practices-toolkit/greener-practices-for-business-
site-development-and-site-cleanups-a-toolkit.html).
National Association of Remedial Project Managers (NARPM). "The 21st Annual
NARPM Training Program." Kansas City, MO. May 16-20, 2011.
(http://www.epanarpm.org/2011/).
National Association of Remedial Project Managers (NARPM). "The 20th Annual
NARPM Training Program." Arlington, VA. May 24-28 , 2010.
(http://www.ttregistration.com/narpm2010/conference/index.cfm).
National Association of Remedial Project Managers (NARPM). "2009 NARPM Annual
Training Conference." Atlanta, GA. June 2-5, 2009.
(http://www.epanarpm.org/2009/home.htm).
New York State Department of Environmental Conservation (NYSDEC). "DER-
3 I/Green Remediation." Revised January 2011.
(http://www.dec.ny.gov/docs/remediation hudson_pdf/der31 .pdf).
Oregon Department of Environmental Quality (DEQ). "Draft DEQ Green Remediation
Policy." October 2010. (http://www.deq.state.or.us/lq/cu/greenremediation.htm).
Sustainable Remediation Forum (SURF)."Sustainable Remediation White Paper
Integrating Sustainable Principles, Practices, and Metrics Into Remediation
Projects." September 2009. (http://www.sustainableremediation.org/librarv/issue-
papers/).
Tetra Tech GEO (formerly GeoTrans, Inc.) "Environmental Footprint Analysis of Four
Potential Remedies: Site DP039, Travis Air Force Base, Fairfield, California."
July 15, 2001. (http://www.clu-in.org/greenremediation/travis/index.cfm).
U.S. Department of Defense, Office of the Under Secretary of Defense. "Consideration of
Green and Sustainable Remediation Practices in the Defense Environmental
Restoration Program." August 10, 2009.
U.S. EPA CLU-IN Internet Seminar. "Greener Cleanups - EPA's Methodology for
Understanding and Reducing a Project's Environmental Footprint." August 10,
2011. (http://www.clu-in.org/greenremediation/).
U.S. EPA. "Superfund & Green Remediation." US Environmental Protection Agency.
Last updated September 22, 2011.
(http://www.epa.gov/superfund/greenremediation/).
U.S. EPA Office of Solid Waste and Emergency Response. "Green Remediation:
Incorporating Sustainable Environmental Practices into Remediation of
Contaminated Sites (EPA 542-R-08-002)." April 2008. (http://www.clu-
in.org/greenremediation/docs/Green-Remediation-Primer.pdf).
U.S. EPA Office of Solid Waste and Emergency Response. "Green Remediation Best
Management Practices (BMP) Fact Sheet." September 2011. (http://www.clu-
in.org/greenremediation/docs/GRfactsheet topics update.pdf).
U.S. EPA Office of Solid Waste and Emergency Response. "Principles for Greener
Cleanups." August 27, 2009.
(http://www.epa.gov/oswer/greencleanups/pdfs/oswerjgreencleanup_principles.p
df).
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U.S. EPA Office of Solid Waste and Emergency Response. "Superfund Green
Remediation Strategy Activity Tracking Chart." February 16, 2011.
U.S. EPA Office of Solid Waste and Emergency Response - Office of Superfund
Remediation and Technology Innovation. "Contaminated Site Cleanup
Information (CLU-IN)." Last updated September 18, 2011. (http://www.clu-
in. org/greenremediation/).
U.S. EPA Office of Solid Waste and Emergency Response - Office of Superfund
Remediation and Technology Innovation. "Greener Cleanups Contracting and
Administrative Toolkit, (Update)." January 2011.
(http://www.cluin.org/greenremediation/docs/Greener_Cleanups_Contracting_an
d_Administrative_Toolkit.pdf).
U.S. EPA Office of Solid Waste and Emergency Response - Office of Superfund
Remediation and Technology Innovation. "Methodology for Understanding and
Reducing a Project's Environmental Footprint." September 16, 2011.
(http://www.clu-
in.org/greenremediation/methodology/docs/GC draft EPA Footprint Methodol
ogy 091611.pdf).
U.S. EPA Office of Solid Waste and Emergency Response - Office of Superfund
Remediation and Technology Innovation. "Profiles of Green Remediation." Last
updated July 12, 2011. (http://www.cluin.org/greenremediation/tab_d.cfm).
U.S. EPA Office of Solid Waste and Emergency Response - Office of Superfund
Remediation and Technology Innovation. "Superfund Green Remediation
Strategy." September 2010. (http://www.epa.gov/superfund/greenremediation/sf-
gr-strategy.pdf).
U.S. EPA Office of Superfund Remediation and Technology Innovation. "Energy
Consumption and Carbon Dioxide Emissions at Superfund Cleanups." May 2008.
(http://clu-in.org/greenremediation/docs/SF Energy Carbon Footprint.pdf).
U.S. EPA Region 1 Clean and Green Policy for Contaminated Sites. February 2010.
(http://www.epa.gov/regionl/brownfields/pdfs/CleanGreenPolicy.pdf).
U.S. EPA Region 2 Clean and Green Policy. March 2009.
(http://epa.gov/region2/superfund/green remediation/clean and green_policy.pd
f).
U.S. EPA Region 2 Superfund. "Green Remediation Measurements/Evaluation Subgroup
- Metrics." Last updated October 5, 2010.
(http://www.epa.gov/region02/superfund/green_remediation/metrics.html).
U.S. EPA Region 2 Metric Tracking Database. (Not publicly available)
U.S. EPA Region 3 Greener Cleanup and Sustainable Reuse Policy. January 2010.
(http://www.epa.gov/reg3hscd/bf-
Ir/whatsnew/EPA R3 Greener Cleanup Sustainable Reuse%20Policy.PDF).
U.S. EPA Region 3 Green Remediation 2009 Questionnaire.
U.S. EPA Region 4 Clean and Green Policy. February 2010. (http://clu-
in.org/greenremediation/docs/R4GRPolicy.pdf).
U.S. EPA Region 4 Greener Cleanups Survey Data, January 2010.
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U.S. EPA Region 5 Interim Greener Cleanup Policy. November 2009.
(http://www.epa.gov/r5brownfields/pdf/gcinterimpolicyr05signedcopvll09.pdf).
U.S. EPA Region 6 Clean and Green Policy. September 2009 .(http://clu-
in.org/greenremediation/docs/R6GRPolicy.pdf).
U.S. EPA Region 7 Interim Green Cleanup Policy. September 2009.
(http://www.epa.gov/region7/cleanup/pdf/r7 green cleanup_policy.pdf).
U.S. EPA Region 8 Green Remediation Policy. August 2009. (http://clu-
in.org/greenremediation/docs/R8GRPolicv revl.pdf).
U.S. EPA Region 9 Greener Cleanups Policy. September 2009.
(http://www.epa.gov/region9/climatechange/pdfs/greener-cleanups-policy.pdf).
U.S. EPA Region 9 List of Green Remediation Activities.
U.S. EPA Region 10 Clean and Green Policy. August 2009.
(http://vosemite.epa.gOv/R10/EXTAFF.NSF/0/bee5cf8b41felfdl8825761c006bb
9fb/$FILE/ATTBM7LK/clean and green policv%20R10%208%2013%2009.pd
f).
U.S. Navy. "SiteWise GSR Tool." (http://www.ert2.org/t2gsrportal/SiteWise.aspx).
Wisconsin Department of Natural Resources (DNR). "Wisconsin's Initiative for
Sustainable Remediation and Redevelopment (WISRR) (formerly known as
WISC)." (http://ua.dnr.wi.gov/org/aw/rr/cleanup/wisc.htm).
Wholey, Joseph S., Harry P. Hatry, and Kathryn E. Newcomer. Handbook of Practical
Program Evaluation. Second ed. San Francisco, CA: Jossey-Bass, 2004.
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