SEPA
United States
Environmental Protection
Agency
Office of Solid Waste and Emergency Response (5203P)
EPA 542-F-13-001
March 2013
                                                                     Engineering Issue
         Sustainable Materials Management in Site Cleanup

                               Technical Support Project Engineering Forum
                 Table of Contents
  1.   Introduction
  2.   Overview
  3.   Benefits
  4.   Materials and Opportunities
  5.   Health and Safety Considerations
  6.   Examples  of Materials Management at
      Cleanup Sites
  7.   Best Management Practices for Site
      Assessment and Planning
  8.   Best Management Practices for
      Construction
  9.   Best Management Practices for Operation
      and Maintenance
  10.  Tools and  Resources
  References
1.  Introduction

The U.S. Environmental Protection Agency (EPA) defines
green remediation as the practice of considering all
environmental effects of remedy implementation and
incorporating options to minimize the environmental
footprint of cleanup actions. EPA developed a methodology
to provide quantitative information about the footprint
reductions gained by applying green remediation best
management practices (BMPs) (U.S. EPA; 2012). The BMPs
address five core elements of a greener cleanup:

• Energy requirements
• Air emissions
• Impacts on water
• Impacts on land and ecosystems
• Material consumption and waste generation.

The BMPs can be used for removal or cleanup activities at
contaminated sites  under Superfund, Resource
Conservation and Recovery Act (RCRA), underground
storage tank, and brownfields cleanup  programs.
                                       2.  Overview

                                       In 2006, the management of materials accounted for 42%
                                       of the United States' greenhouse gas (GHG) emissions,
                                       based on a systems analysis (U.S. EPA; 2009). The systems
                                       view of materials management represents U.S. emissions
                                       related to the goods and services we create through
                                       extraction, harvesting, processing, production, transport,
                                       and final disposition. Sites undergoing cleanup provide
                                       many opportunities for waste reduction and materials
                                       diversion through safe reuse and recycling. These
                                       opportunities apply to materials found or generated during
                                       the site remediation process and materials purchased for
                                       remedy construction and site redevelopment.

                                       Cleanup projects can generate different types of materials
                                       including industrial materials such as construction and
                                       demolition debris, organic matter such as wood and plants,
                                       and other types of solid  wastes from project management
                                       oversight. When safely reused and recycled, industrial
                                       materials salvaged from demolition  activities can be
                                       appropriately diverted from landfills for use in new building
                                       and transportation construction, water infrastructure, and
                                       agriculture. Organic materials can be reused for site design
                                       and remediation, and other solid wastes like paper, plastic,
                                       metals, and glass can be recycled by waste management
                                       and material  recovery facilities into the same markets.

                                       Materials have a large impact on the environment when a
                                       systems view of the life  cycle of materials is taken (Exhibit
                                       1). The life cycle typically comprises  of resource extraction,
                                       material processing, product design  and manufacturing,
                                       product use, collection,  and disposal. Sustainable materials
                                       management is an important part of conserving natural
                                       resources,  reducing waste, and minimizing our footprint on
                                       the environment. It describes  a collection of integrated
                                       strategies that use resources most productively and
                                       sustainably throughout their life cycles. Reusing and
                                       recycling materials to more sustainably manage them can
                                       have significant environmental benefits.

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              Renew
    Recycle
Exhibit 1. The Life Cycle of Materials

     Remanufacture         Reuse
         Composting
       Energy,
       Water
       Inputs
Energy,
Water
Inputs
       Resource
       Extraction
 Material
Processing
                      Energy,
                      Water
                      Inputs
 Energy,
 Water
 Inputs
                       Product
                        Use
Collection/
Processing


 *
.  Energy,
  Water
I  Inputs
  Disposal
                                                                       m
                                                                 m
                                          Emissions to Air, Water, and Land
                                           Diagram adapted from Sustainable Materials Management: The Road Ahead (U.S. EPA; 2009)
  This diagram represents the life cycle of a material from extraction through processing, design, manufacture, use, and
  ultimate disposition, which may include recovery. Every step in the life cycle consumes energy and resources, and every
  step results in environmental releases to air, water, and land. In addition, materials and products require transport
  throughout their life cycle. Transportation uses more energy, consumes more fuel, and results in more emissions to the
  environment. Thus, the flow of materials contributes to a wide range of environmental impacts. Diverting materials
  from disposal through reuse, recycling, or composting conserves resources and intercepts environmental pollution
  along the life cycle of materials, thus contributing to a wide range of environmental impact reductions. Environmental
  savings from the resource extraction and manufacturing processes are usually greatest, since spent materials offset the
  extraction and  manufacture of natural (virgin) resources (U.S. EPA, 2003; U.S. EPA, 2009).
3.  Benefits

Sustainable materials management can have numerous
benefits. Detailed examples of the benefits gained at
brownfield, Superfund, and other sites are provided
throughout this issue paper and in literature cited in closing
references.
Environmental Benefits:
• Conserves natural resources
• Reduces energy consumption
• Conserves landfill space
• Reduces environmental impacts across the life cycle by
  decreasing the demand for virgin products (i.e. reduces
  the need to extract and process natural resources, and
  subsequently transport them for manufacturing or other
  uses).
Economic Benefits:
• Reduces disposal costs and may reduce material hauling
  costs, thereby reducing overall  project costs
• Can reduce purchasing costs since non-virgin materials
  are often less expensive than virgin resources
• Can enable contractors to be more competitive with
  their bids given the reduced costs
• Creates employment opportunities and economic
  activities in the reuse and recycling industries.
                                  Performance Benefits:
                                  • Materials reclaimed, salvaged, or otherwise reused can
                                    perform as well as or better than virgin products in many
                                    applications.
                                    Menomonee Valley Industrial Center and Community
                                    Park Project - Brownfields Site
                                    The 1,200- acre Menomonee Valley revitalization is
                                    the largest brownfields cleanup in Wisconsin history.
                                    The revitalization leveraged $700 million, created
                                    4,000 new jobs, and built 60 acres of park space and 4
                                    miles of trails. This project used crushed concrete for
                                    building foundations and roadway subgrade, and
                                    broken concrete for subsurface transmissive layer
                                    within the stormwater management infrastructure.
                                    The Industrial Center and Community Park Project was
                                    the redevelopment of a 140-acre brownfields site
                                    within the Valley. Various types of locally available
                                    industrial materials were used in the redevelopment,
                                    including foundry sand from the neighboring Falk
                                    foundry and nearly 900,000 cubic yards of fill from the
                                    reconstruction of the adjacent freeway.
                                                                   www. renewthevalle y. orq

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4.  Materials and Opportunities

Industrial materials likely present the best opportunities for
reuse and recycling at cleanup sites. These materials are
the byproducts from industry that can be used in
construction and land remediation applications in place of
newly processed/manufactured products that rely on the
extraction of natural resources. Industrial materials may
include construction and demolition materials; coal
combustion products; iron, steel, and aluminum foundry
sands; steel slag; and scrap tires. Construction and
demolition materials can contain brick, concrete, masonry,
lumber, paving materials, shingles, glass, plastics,
aluminum (including siding), steel, drywall, insulation,
asphalt roofing materials, electrical components, plumbing
fixtures, siding, corrugated cardboard, and land clearing
debris (soil, rocks, trees, etc.).  Many of these items can be
cut to new sizes or refinished and reused, or they can be
reprocessed into new products. For example, bricks can be
cleaned up for reuse, or metals can be screened out for
recycling. Waste consisting of organic matter such as wood
and plants may also be generated onsite and used as
compost, mulch, and fill materials.

There are many opportunities to safely reuse and recycle
various materials at sites being remediated. Sites can have
abandoned or unwanted buildings that need demolition.
Clean materials salvaged during demolition can be reused
onsite, sold through local markets, donated to reuse
centers, or recycled offsite. In general, materials should be
reused onsite whenever possible. Onsite reuse will offset
the need to haul the materials offsite and to purchase
other products, thereby reducing costs and environmental
impacts from  transportation and avoiding upstream
impacts from  using raw resources and new manufacturing.

Materials that cannot be used onsite should be sent offsite
for recycling wherever markets are available within a
reasonable distance, so that environmental benefits would
not be fully offset by the environmental impacts from
transportation. Cleanup sites are often located in urban
areas near transportation hubs. Transportation corridors
allow site personnel to use current infrastructure and
provide easy access to potential  markets for materials.

In addition, new construction or renovation provides
opportunities to buy recycled content products for
buildings and  roadways; return, sell, or donate unused
materials; and send others
for recycling. Some industrial
materials can  even be
utilized to assist with a site
remedy; for example,
ground up stumps can be
reused for a mulch-based
permeable reactive barrier.
  Worcester, Massachusetts - Brownfields Site
  EPA awarded Main South Community Development
  Corporation (CDC) in Worcester, Massachusetts, a
  $200,000 brownfields cleanup grant to address
  contamination discovered on 7.8 acres of the
  Gardner-Kilby-Hammond neighborhood project. To
  help keep soil- and building-cleanup costs within Main
  South CDC's budget, multiple materials from
  construction and demolition (C&D) were recovered
  from the abandoned industrial buildings, including:
  10,000 cubic feet of concrete, 200 tons of steel,
  50,000 board feet of hard yellow pine, and several
  hundred tons of brick and granite. Salvaged materials
  were sold through local and global  markets, reused
  onsite for new construction, or recycled,
  strengthening the local market for C&D materials.
          www.epa.Qov/brownfields/success/worcester050108.pdf
  Project managers must check with applicable state
  environmental agencies and local authorities for
  authorized uses of industrial materials and clean C&D
  materials. The Construction Industry Compliance
  Assistance Center offers an online tool to help find
  C&D-related regulatory information for specific states.
                     htto://www.cicacenter.ora/solidreas.html
5.  Health and Safety Considerations

Various state and local statutes, in addition to federal
statutes and regulatory programs (such as the
Comprehensive Environmental Response, Compensation,
and Liability Act (CERCLA), Oil Pollution Act, National
Contingency Plan, RCRA Corrective Action Program, and
Land Disposal Restrictions Program) apply to contaminated
sites. To prevent environmental problems and/or address
any possible liability under CERCLA, it is necessary to
coordinate the applicable statutory cleanup requirements
and reuse of onsite industrial materials. Thus, it is
imperative to ensure (a) compliance with all regulations, (b)
that businesses used to manage wastes and materials are
approved and in full compliance with all federal and state
regulations, and (c) that state and local authorities are
consulted for approved beneficial uses.

Materials on cleanup sites can be contaminated, and in
those cases, it is necessary to separate hazardous wastes
from non-hazardous solid wastes. To determine whether
waste is hazardous, a remedial project manager may
review the history of the site to identify whether listed
hazardous wastes may be present, or conduct an
assessment of whether materials express a hazardous
characteristic - using for example, the EPA's Toxicity
Characteristic Leaching Procedure (Method 1311). Other
hazardous waste characteristics to evaluate when

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separating wastes include ignitability, corrosivity, and
reactivity. Hazardous wastes must be disposed of according
to federal and state regulations. Many communities offer
recycling of certain waste characterized as hazardous.

Further, project managers need to check state
environmental agency requirements for authorized safe
beneficial uses of materials, and contact local authorities
for any restrictions on the use of materials in specific
applications. A recommended approach for getting started
is to contact your EPA regional industrial materials recycling
coordinator, who will have knowledge of state contacts and
solid waste programs that typically review and approve
industrial materials management.
  Fort Ord, California - Former Military Base
  The preliminary building assessment revealed
  asbestos in the vinyl tile flooring and lead-based paint
  on the exterior siding and some interior finish
  materials. Contaminated materials were removed and
  isolated before full-scale deconstruction began.
  • Contaminant-free materials: sold onsite at public
    sale or donated to Goodwill Industries
  • Hazardous materials: asbestos-containing materials
    disposed of by certified contractor at approved site;
    high-value Douglas fir siding warehoused for further
    research in removal of lead-based paint
  • Other: unpainted drywall composted;
    representative pieces of dimensional lumber re-
    graded and strength-tested.
                  www.huduser.org/Publications/PDF/decon.odf
6.  Examples of Materials Management at Cleanup
    Sites

The following examples illustrate some of the opportunities
for the diversion of various materials from landfilling. The
materials may be found at cleanup sites, or used on
cleanup sites. The examples illustrate reuse of onsite
materials, reuse or recycling of materials offsite, and
procurement of construction and other materials
containing recycled content.1 To be protective of human
health and the environment, materials should be evaluated
for safety (i.e., compared to relevant benchmarks and
performance criteria) prior to use, and project managers
should check with applicable state environmental agencies
and local authorities regarding proposed uses.

• Crushed concrete can  be used onsite as a construction
  aggregate for road base, pipe bedding, or landscaping
Clean demolition materials can be shipped offsite to used
building material resale stores, which sell donated
supplies to the general public at reduced prices
Clean concrete can be shipped offsite for use as
aggregate in ready mix concrete
Concrete that is made with coal fly ash or ground
granulated blast furnace slag to displace a portion of
traditional Portland cement can be procured for
construction purposes. One example is the use of fly ash
containing concrete for the construction of the structural
elements of a treatment plant
Reclaimed asphalt pavement can  be used as a granular
base for new roads
Shredded scrap tires, crushed  concrete, and other onsite
clean hard materials can be used  in place of borrow for
fills
Iron and steel foundry sands, dry  wall, flue gas
desulfurization (FGD) gypsum, and compost can be used
for soil amendments and manufactured soils
Reclaimed asphalt pavement,  asphalt roofing shingles,
glass, and scrap tire rubber can be recycled into asphalt
pavements
Uncontaminated and pest- or  disease-free organic debris
like wood can be salvaged for  use as infill, mulch, or
compost
Compost can be used for stormwater management, to
prevent soil erosion and  for landscaping
Composting contaminated soils may provide a less costly
alternative to conventional methods of remediating
certain contaminants in soil (Unified Facilities Guide
Specifications; 2012)
FGD gypsum can be used for mitigation of phosphorous
transport to surface and  groundwater.
1 Additional ideas, material uses, and any applicable performance benefits
can be obtained from the available resources referenced at the end of this
issue paper.
 Barksdale Air Force Base, Louisiana
 Containment of 25 acres of construction debris and
 hazardous waste in an onsite landfill included
 salvaging 1,000 tons of concrete. The concrete was
 sorted by aggregate size for use in onsite road
 construction and stormwater runoff controls.
 Approximately 700 tons of woody material that was
 removed during installation of the landfill's cover also
 was salvaged for beneficial  use.
              www.cluin.orQ/Qreenremediation/subtab d!7.cfm

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The Oregon Army National Guard's Camp
Withycombe - Brownfields Site
The Oregon Army National Guard's Camp Withycombe
won the fiscal year 2009 Secretary of the Army award
for environmental restoration efforts by completing
the remediation of six former training ranges in
preparation for a major Oregon Department of
Transportation highway development project. The
former ranges accumulated lead bullets during their
use for approximately 100 years. With freeway
construction set to begin, the National Guard
immediately began planning to design a sustainable
cleanup that would use green remediation strategies.

The soil treatment system used a dry particle
separation and wet gravity separation process to
remove bullets and fragments from  30,000 tons of
contaminated soil. The system was implemented at a
cost of $5.9 million, a cost avoidance of more than $5
million. Nearly 300 tons, or approximately 25,205,000
bullets, were sifted out and reclaimed for recycling.
Revenue generated by lead recycling was reinvested
into restoration.
More than 50% of the contaminated soil was cleaned
and ready to be used in reforestation to refill a
mountain. The soil treatment system used a closed
loop water system that filtered and  recycled its own
water, reducing demand and preventing the discharge
of contaminated water. The system  also boasted a
stormwater collection component, which collected
and directed it into the closed  loop system as process
water. Upon completion of soil washing, the system
treated the process water so it could be recycled for
irrigation during natural resources restoration.
    http://www.army.mil/artide/36028/camp-withycombe-qreen-
        remediation-techniciues-result-in-5-million-cost-avoidance
7.  Best Management Practices for Site
    Assessment and Planning

Material management goals should be integrated into
existing site-specific planning processes to evaluate
opportunities and document decisions. The following BMPs
are recommended during remedial site assessment and
planning phases:

• Survey onsite buildings and infrastructure to determine
  the potential to reuse existing structures and equipment;
  if structures or their portions cannot be reused as is,
  determine individual material components and
  approximate quantities that could be reused or recycled
• Include a requirement or demonstrated performance
  level for reuse and recycling of all uncontaminated C&D
  material in contract  documents such as requests for
  proposals, bid specifications, and subcontracts and in
  administrative documents such as corrective action plans
  or grants; the requirement/level should align with
  existing state and local requirements or
  recommendations
• Structure incentives that reward diversion of materials
  away from landfills beyond a minimum goal of 50%, and
  establish a construction waste management plan that
  includes materials tracking and documentation
• Consult EPA's C&D materials recycling web page for tools
  and resources for project managers and contractors
  (www.epa.gov/cdmaterials)
• Contact local recyclers and waste haulers to determine
  what materials can be recycled
• Check with applicable state environmental agencies and
  local authorities for authorized  uses of industrial
  materials
• Evaluate onsite  reuse and/or recycling opportunities
  versus shipment offsite for reuse and/or recycling
• Communicate with contractors about how they will track
  and report the amount of waste that is recycled, reused,
  or disposed. If needed, provide tracking forms to project
  managers and haulers to make data reporting easier
• Design new construction to utilize standard material
  sizes and minimize cut-offs2
• Design new construction for future deconstruction3
• Evaluate opportunities for the purchase and use of
  recycled content products for onsite construction
• Designate the use of products with recycled content
  during the design process for onsite construction and
  conduct environmentally preferable purchasing
• Contract with suppliers that will take back scraps and
  whose products meet performance specifications,
  whenever the cost of their products is reasonable and
  the products are available within a reasonable time or
  distance.
2 Cut-offs are excess material that is generated when materials of standard
production sizes are cut down to fit custom design dimensions.
3 Deconstruction means the selective disassembly of buildings to facilitate
the reuse or recycling of valuable materials.

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  Fort Worth Post Office, Texas
  Environmentally preferred products used by the
  United States Postal Service to construct the 8th
  Avenue Station in Forth Worth included:
  • 20% recycled-content concrete with fly ash
  • Recycled-content gypsum board and ceiling tiles
  • 90% post-consumer recycled-content steel
  • Recycled-content dock bumpers and floor mats
    (contains recycled tires)
  • Recycled-content plastic toilet partitions, tree
    grates, and workroom bumpers.
                      vjww.eoa.gov/eoo/oubs/case/usos2.htm
8.0   Best Management Practices for Construction

The following BMPs are recommended during construction
and remedy implementation, which may include
demolition of pre-existing structures:

• Implement deconstruction techniques, preserve usable
  portions of existing structures but dismantle unusable
  parts, and recover clean materials for reuse and/or
  recycling
• When construction site parameters allow, encourage
  contractors to require and incentivize workers to sort
  uncontaminated materials for reuse or recycling as they
  are removed or debris is produced. This practice results
  in greater diversion but may depend on site conditions
  such as storage space. Materials may need to be
  consolidated prior to collection by a recycler who then
  separates them offsite (if this option is available). Source
  segregation can reduce costs because recycling and
  waste management companies often charge less for pre-
  sorted versus comingled materials. Source segregation
  can also provide a safer working environment and
  increase recyclability/reuse potential of materials
• Use signs to designate collection points for recyclables
• Salvage  uncontaminated materials with potential recycle,
  resale, donation, or onsite infrastructure value
• Link a deconstruction project with a construction or
  renovation project to facilitate reuse of clean salvaged
  materials
• Divert at least 50% (by weight) of the uncontaminated
  C&D materials generated  onsite and include this goal in
  the site  waste management plan; for example, the U.S.
  Department of Defense, including the U.S. Army Corps of
  Engineers, specifies that all defense installations/military
  projects must divert at least 50% (by weight) of C&D
  materials from disposal or incineration according to their
  Integrated (Non-Hazardous) Solid Waste Management
  Policy.
• Optimize product ordering to prevent excess supplies
  from arriving  at the site
If materials are reused, specify that contractors ensure
that state and local engineering performance standards
are met for material end uses. These standards often
include or specify national standards for performance,
such as those from ASTM International and the American
Association of State  Highway and Transportation Officials
Return durable packaging and unused goods from
construction to suppliers or manufacturers.
Upper Arkansas River, Colorado -Superfund Site
Historic mining near Leadville, Colorado, occurred at
the headwaters of the Arkansas River. Releases of
mine waste, and contaminated water and sediments
with elevated levels of metals have impaired
productivity of agricultural land adjacent to the river.
Low pH and enriched metal concentrations resulted in
large areas of phytotoxicity, evident by barren and
sparsely vegetated areas. The contaminated
floodplain and irrigated meadows are designated as
Operable Unit 11 of the California Gulch Superfund
Site.

Impacted soil areas were treated with soil
amendments that beneficially used industrial
byproducts. Soil treatment included the use of
biosolids, lime, woody materials for compost, and high
rates of phosphorous fertilizer.
• Lime  amendment was procured from a sugar beet
  processing facility  near  Longmont and  transported
  to  the  site; the  lime  was mixed with  organic
  amendments (biosolids compost or cow  manure
  compost)  to  reduce   soil   acidity,   supporting
  increased plant viability and metal insolubility
• Composted  organic matter was transported from a
  feedlot source and incorporated along  with woody
  materials as additional plant nutrients
• Wood chips  were   added  to  reduce  nitrogen
  (nutrient)  leaching  and  increase  water  holding
  capacity
The remedy resulted in
reduced bioavailability
of zinc and other
metals, neutralized soil
to support healthier
ecosystems, reduced
erosion and river
channel degradation,
and re-established
vegetation, including
native plants.
                                                               http://www.epa.ciov/reciion8/superfund/co/calciulch/mdex.Mml
                                                                    http://www. clu-in. ora/areenremediation/subtab d!3. cfm

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Emeryville, California - Brownfields Site
The City of Emeryville provided $1,175,000 in EPA brownfields
revolving loan funds to GreenCity LLC to assist with cleanup
costs associated with the GreenCity Lofts property, a former
paint factory. Demolition of the former paint factory and
warehouse buildings was necessary before construction of the
lofts could begin. The project team employed C&D waste
recycling practices including deconstructing (hand dismantling)
the buildings on the former industrial property as an alternative
to traditional demolition. As a result, 94.6% of the demolition
waste was recycled, exceeding the nearby City of Oakland's
legal requirement by 45%.  In addition, 21,569 tons of excavated
soil were diverted from disposal and used as beneficial cover at
a local Class II landfill, reducing project costs by an estimated
$496,708 in eliminated tipping fees.
                                                                 The GreenCity Lofts in Emeryville, California
                                                              www.epa.Qov/brownfields/success/emeryvilleca cd ss final.pdf
Elizabeth Mine, Vermont - Superfund Site
The Elizabeth Mine is an abandoned copper mine located in the
Village of South Strafford within the Town of Strafford, Orange
County, Vermont. Past operations at the property consisted of
mining, copper smelting, and ore  processing. Water resources
have been negatively impacted by acid rock drainage.
The green remediation strategy for this site for materials and
waste included the reuse of onsite materials rather than
importing natural resources for remedy construction and site
restoration, establishing programs for recycling of waste
materials, and initiating a procurement process for
environmentally preferable products.
Results:
• Construction of the soil cap: reused rip-rap that was originally emplaced around an adjacent waste rock excavation
  area (known as "TP-1A"); used approximately 1,000 cubic yards of soil that had been previously used as temporary
  backfill in TP-1A, as well as other borrow materials from the site for cap construction
• Construction materials: recycled construction materials and incorporated a product recycling evaluation into
  procurement sourcing, wherever applicable; approximately 30 cubic yards of geomembrane liner made of recyclable
  high-density polyethylene (HOPE) and 96 HOPE liner cores (each 20 feet in length by 6 inches in width) were recycled
  in 2011
• Erosion control and stormwater quality: emplaced tubular devices ("socks") filled with organic materials such as
  recycled compost on ground surfaces along the TP-1A soil cap perimeter; in one year compared to typical silt fencing,
  this resulted in 50% less surface water runoff, returned more nutrients to the subsurface, and involved  less
  maintenance
• Stabilization of steep slopes: used salvaged onsite wood debris
• Project-wide consumable waste: implemented a recycling program that resulted in the recycling of approximately 40
  cubic feet of cans, 44 cubic feet of paper, 1,800 cubic feet of plastics, and 28 cubic feet of glass during 2011
• Borrow materials:  used a 4.7-acre onsite area to develop borrow materials for the cap system and as-needed
  manufactured topsoil; over one year, the area produced approximately 93,000 cubic yards of earthen fill (including
  over 87,000 cubic yards of till/soil and 4,300 cubic yards of boulders), which avoided nearly 6,200 trucks trips (each
  with a capacity of 15 cubic yards) traveling on local roads in order to import the materials and averted approximately
  945,000 pounds of associated CO2 emissions.
                                                             http://www.du-in.org/areenremediation/subtab d36 12Q322.cfm

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9.0 Best Management Practices for Operation and
    Maintenance

The following BMPs are recommended during site
operation and maintenance (O&M):
• Use regenerated granular activated carbon (GAC) for use
  in carbon beds; if the GAC was pool-regenerated, ensure
  that contaminants on the regenerated GAC are not
  present at unacceptable levels
• In instances in which coconut shell-derived GAC is
  produced within reasonable distance from the project
  site, use it as a more sustainable alternative to coal-
  based activated GAC
• Use products, packing material,  and equipment that can
  be reused or recycled
• Use remediation system evaluations as opportunities to
  incorporate practices that involve reuse and recycling of
  industrial materials and purchasing of products with
  recycled content as a means to maximize resource
  efficiencies while potentially reducing project costs and
  optimizing remedy effectiveness
• Use techniques for continuous process monitoring,
  control, and optimization, to maximize capacity of
  treatment media and minimize frequency of media
  replacement
• Divert waste generated during operation and
  maintenance activities, including C&D materials
  generated during renovation of  structures, from disposal
  in landfills.

Exhibit 2 provides an overview of process flow for
integrating sustainable materials management in site
cleanup projects.
10. Tools and Resources

EPA's "Industrial Materials Recycling Tools & Resources"
document, updated February 2011, brings together many
helpful resources to implement the beneficial use of
industrial materials, some of which are highlighted below.

S Agency and trade organization programs that focus on
   recycling of individual industrial materials
•S State regulatory frameworks
S Risk assessment resources
•S Potential applications of industrial materials with
   relevant case studies
•S Environmental and economic benefits resources
S Performance standard specifications and guidelines
S Industrial materials suppliers.
http://www.epa.gov/wastes/conserve/imr/pdfs/toolsl-09.pdf
                              Disclaimer: The inclusion of
                              non-EPA links and their
                              content does not necessarily
                              reflect the views and policies
                              of the EPA, nor does the
                              mention of trade names,
                              businesses, or commercial
                              products constitute
                              endorsement or
                              recommendation for use.
                              These links are included to
                              maximize the utility the
                              Internet provides and to
                              better fulfill our role as
                              information provider and
                              disseminator. The contents
                              and addresses of websites
                              mentioned herein are subject
                              to change without notice.
"Spent GAC that is sent back for regeneration can be "pooled" into large-
volume batches priorto being regenerated. Since the pooled GAC may
come from multiple industrial and municipal sources, it is possible for
multiple types of contaminants to be present on the spent GAC; it is also
possible for inorganic contaminants to be present.
EPA's Office of Resource
Conservation and Recovery
(ORCR) is developing a
methodology to evaluate
the encapsulated beneficial
uses of products containing
coal combustion residuals
(CCRs), such as coal fly ash
in concrete and the
byproducts of FGD systems
in wallboard. The
methodology aims to enable
users/consumers to
determine if encapsulated
beneficial uses of CCRs are
comparable to analogous
products without the CCRs
or byproducts of FGD systems. In the future, ORCR will also
develop a conceptual model to evaluate the potential risks
from unencapsulated beneficial uses of CCRs.
http://www.epa.gov/epawaste/conserve/imr/

> Resources for Locating C&D Recyclers, Reuse
   Stores, and Material Exchange Networks

When choosing businesses to  manage waste and materials,
it is important to ensure they  are reputable and in full
compliance with state regulations (which may include
licensing or registration) as well as local government
requirements. State and local  authorities must also be
consulted for approved beneficial uses.

The Whole  Building Design Guide's Construction Waste
Management database contains information on companies
that haul, collect, and process recyclable debris from
construction projects. Created in 2002 by the Government
Service Administration's Environmental Strategies and
Safety Division to promote responsible waste disposal, the
database is a free online service for those seeking
companies that recycle construction debris in their area.
The database is searchable by state, zip code, or material(s)
recycled, http://www.wbdg.org/tools/cwm.php

The Construction Materials Recycling Association (CMRA)
website, under the "Find a Recycler" section, provides a list
of C&D recyclers. CMRA  is a 501(c)(3) organization  that
promotes the recycling of construction and demolition
materials, www.cdrecvcling.org/
The Building Materials Reuse Association (BMRA) is a non-
profit educational and research organization whose mission
is to facilitate building deconstruction and the reuse and
recycling of recovered building materials. BMRA's online
directory is a resource for finding reuse stores such as
Habitat for Humanity, deconstruction contractors,
architects and more. The directory is browsable by state
and searchable by zip code, city, state, and keyword.
http://bmra.org/home

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       Exhibit 2. Sustainable Materials Management for Green Remediation: Process Flow
                    Research statutes and regulatory programs that apply to your specific
                        site type, e.g., brownfield, Superfund, RCRA corrective action.
              Refer to this issue paper for background information and a preliminary selection of
          sustainable materials management BMPs applicable to your project's phase/phases (e.g., site
                              assessment and planning, construction, O&M).
         Consult EPA's regional industrial materials recycling coordinator for points of contact within
         your state solid waste programs that review and approve industrial materials management.
Contact your state personnel and collect information on state-specific beneficial use requirements. Inquire about
applicable local authorities to contact about authorized uses of industrial materials and clean C&D materials.
                                             1. Will on site
                                            materials either
                                             be recovered
                                            and used onsite
                                             or shipped for
                                              use off site?
                                                 T
                                  Or
  2. Will non-
  hazardous
  secondary
materials from
offsite locations
be used onsite?
                                                               If the answer to
                                                               both questions is No
                 If the answer to
                 either question is Yes
                                            Are any of these
                                               materials
                                            contaminated?
                                             Yes
                      Separate non-hazardous from hazardous constituents and dispose
                       of hazardous wastes according to federal and state regulations.
                            Proceed with implementation of BMPs and cleanup
                               within constraints of applicable regulation(s).

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The Construction Industry Compliance Assistance Center is
an EPA-funded environmental compliance assistance
website for contractors and builders/developers. The
website contains a C&D materials State Resource Locator,
where contractors can find state and municipal recycling
programs, www.cicacenter.org

Materials and waste exchanges are markets for buying and
selling reusable and recyclable commodities. Some are
physical warehouses that advertise available commodities
through printed catalogs, while others are simply websites
that connect buyers and sellers. Some exchanges are
coordinated by state and local governments. Others are
wholly private, for-profit businesses.
http://www.epa.gov/wastes/conserve/tools/exchange.htm and
http://mxinfo.org/list.cfm

*• Material and Application Specific Information

EPA has established "Criteria for the Safe and
Environmentally Protective Use of Granular Mine Tailings
Known as "Chat"" in transportation construction projects
carried out in whole or in part with federal  funds in the
Oklahoma, Kansas, and Missouri tri-state mining region.
http://www.epa.gov/osw/nonhaz/industrial/special/mining/chat/

"Using Recycled Industrial Materials in Buildings" (2008) is
a fact sheet developed by EPA to provide information
about the use of recycled industrial materials in buildings
as an alternative to virgin materials and building products.
http://www.epa.gov/wastes/conserve/imr/pdfs/recv-bldg.pdf

"Using Recycled Industrial Materials in Roadways" (2009) is
a fact sheet developed by EPA that discusses the use of
industrial materials in roadways and other infrastructure
projects as an alternative to virgin materials and
construction products.
http://www.epa.gov/osw/conserve/imr/pdfs/roadwavs.pdf

The Federal Highway Administration and the Recycled
Materials Resource Center developed User Guidelines for
Waste and By-Product Materials in Pavement Construction
to provide information and guidance on engineering
evaluation requirements, environmental issues, and
economic considerations to determine the  suitability of
using recycled materials in pavement  applications.
http://www.fhwa.dot.gov/publications/research/infrastructure/st
ructures/97148/intro.cfm and
http://rmrc.wisc.edu/user-guidelines-2/

The Use of Soil Amendments for Remediation,
Revitalization, and Reuse (2007) was developed by EPA to
provide information on the use of soil amendments as a
cost-effective in situ process for many types of disturbed or
contaminated landscapes. It focuses on amendments that
are generally residuals from other processes and have
beneficial properties when added to soil, such as municipal
biosolids, animal manures and litters,  sugar beet lime,
wood ash, coal combustion products such as fly ash, log
yard waste, neutralizing lime products, composted
biosolids, and a variety of composted agricultural
byproducts, as well as traditional agricultural fertilizers.
http://clu-in.org/download/remed/epa-542-r-07-013.pdf
EPA also has a website on agricultural and horticultural
applications using industrial materials.
http://www.epa.gov/wastes/conserve/imr/ag.htm

The Northeast Waste Management Officials' Association
(NEWMOA) has developed fact sheets on various
waste/use combinations.
http://www.newmoa.org/solidwaste/bud.cfm

The Industrial Resources Council is composed of industry
trade associations representing coal combustion products,
foundry sands, iron and steel slag, wood and pulp
materials, rubber materials, and C&D materials. Their
website contains information about industrial materials
and their applications.
http://www.industrialresourcescouncil.org

"An Innovative Alternative Reclamation Technique to
Stabilize Coal Mine Refuse Using an Alkaline Clay By-
product" is a paper by T. Kovalchuk of the Pennsylvania
Department of Environmental Protection that was
presented at the 32nd Annual National Association of
Abandoned Mine Land Programs Conference in 2010. It
discusses a field trial demonstrating a coal mine refuse
reclamation technique using alkaline clay and compost to
neutralize acidic soils, establish sustainable vegetative
cover, and minimize acidic leachate.
http://www.cl u-in.org/products/tins/tinsone.cfm?num=20562210

> Tools for Contractors

The Contractor Toolkit For Recycling and Using Recycled
Industrial Materials was developed  by EPA, the Associated
General Contractors of America, and the Industrial
Resources Council to provide a collection of resources to
assist contractors who want to recover C&D materials
generated at their job sites, or contractors who want to use
industrial materials in the construction or renovation of a
structure, http://www.agc.org/cs/recvcling toolkit

The U.S. Department of Housing and Urban Development's
"Guide to Deconstruction" provides an overview of
deconstruction with a focus on community development
opportunities. The guide describes project profiles and case
studies that show the components of deconstruction and
its benefits, and presents ways to make it part of a
community revitalization strategy.
http://www.huduser.org/Publications/PDF/decon.pdf
                                                        10

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The Deconstruction Institute's "A Guide to Deconstruction"
provides guidance to deconstruction managers, supervisors
and workers who are planning or who are already
conducting deconstructions. The guide can also be helpful
to resale stores or redistributors of building materials.
http://www.deconstructioninstitute.com/files/learn center/4576
2865 guidebook.pdf

EPA's Office of Superfund Remediation and Technology
Innovation offers the Green Response and Remedial Action
Contracting and Administrative Toolkit to EPA remedial
project managers, on-scene coordinators, and procurement
offices to help prepare contracts and administrative
documents that foster strategies for green response
actions and long-term remediation at contaminated sites.
http://www.cluin.org/greenremediation/docs/Greener Cleanups
 Contracting and Administrative  Toolkit.pdf

*• Guides for Specifying  and Purchasing for
   Contracts and Administrative Documents

Environmentally Preferable Purchasing (EPP) provides
procurement guidance including information about
environmental attributes to look for in construction
products. The Environmentally  Preferable Purchasing
Program helps federal agencies identify and purchase
environmentally preferable products and services.
http://epa.gov/epp/pubs/products/construction.htmffa

U.S. EPA Comprehensive Procurement Guidelines (CPG)
contains information about construction and
transportation products containing recycled content.
Although the CPGs are primarily for federal procuring
agencies, the information is useful to state and local
governments and the private sector. The webpage includes
access to a Product Supplier Database that lists
manufacturers, vendors, and  suppliers for each item and
specifies EPA's recommended recycled-content ranges.
http://www.epa.gov/epawaste/conserve/tools/cpg/index.htm

The Federal Green Construction Guide for Specifiers
provides information about procuring green building
products and construction/renovation services within the
Federal government, including sample specification
language for building deconstruction and salvage. EPA
partnered with the Federal Environmental Executive and
the Whole Building Design Guide to develop this guide.
http://www.wbdg.org/design/greenspec.php

WasteCap Resource Solutions, Inc. provides sample
construction waste management specifications that are
master specifications that can be edited for specific
projects. WasteCap Resource Solutions, Inc. is a nonprofit,
industry supported 501(c)(3)  organization that provides
waste reduction and recycling assistance to businesses.
http://www.wastecapwi.org/services/construction-and-
demolition-specifi cations/
*• Recovering C&D Materials for Land
   Revitalization

EPA created "Recover Your Resources: Reduce, Reuse, and
Recycle Construction and Demolition Materials at Land
Revitalization Projects" (2009) to provide information on
commonly recovered C&D materials at land revitalization
projects, best practices, case studies, and other resources.
http://www.epa.gov/brownfields/tools/cdbrochure.pdf

*• State Program Requirements and Beneficial
   Use Determinations

The National Center for Manufacturing Sciences developed
the State Beneficial Use Program Locator tool that
identifies individual state rules and programs related to
secondary materials use. Users are able to select a state (or
states) of interest and obtain helpful beneficial use
information. This tool was developed under a grant with
EPA's National Compliance Assistance Centers program.
http://www.envcap.org/statetools/brsl/

The Northeast Waste Management Officials' Association
created a Beneficial Use Determinations (BUD) Database to
help states share information and improve the efficiency of
their BUD approval processes. The database  includes over
1,500 BUDs issued by over 25 states. The BUD database is
accessible to state and federal government only, and is
searchable  by material type or use, and provides details
about requirements for approval where available. For more
information and to obtain a  username and password,
please contact Jennifer Griffith at igriffith@newmoa.org.
http://www.newmoa.org/solidwaste/bud.cfm

> Regulatory Information

"RCRA in  Focus: Construction, Demolition, and Renovation"
(2004) provides information about how RCRA applies to the
generation  of construction and demolition materials.
http://www.epa.gov/osw/inforesources/pubs/infocus/rif-cd.pdf

EPA provides resources to aid  in  the process  of identifying
hazardous waste and makes available links to codifications
of rules in the Federal Register, which define solid waste,
identify the types of wastes that are excluded from RCRA,
list the specific wastes that have been determined to be
hazardous,  and define characteristic hazardous wastes.
http://www.epa.gov/osw/hazard/wastetypes/wasteid/index.htm

"Test Methods for Evaluating Solid Waste,
Physical/Chemical Methods," also known asSW-846,
contains the analytical and test methods that EPA has
evaluated and found  to be among those acceptable for
testing under RCRA Subtitle C. This guidance  sets forth
acceptable, but not required, methods for the regulated
and regulatory communities to use to evaluate solid waste.
http://www.epa.gov/epawaste/hazard/testmethods/index.htm
                                                       11

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"Land Disposal Restrictions for Hazardous Wastes" is a
brochure providing a snapshot of the EPA's Land Disposal
Restrictions (LDR) Program. The LDR program ensures that
land disposed waste does not pose a threat to the human
health and the environment by prohibiting land disposal of
hazardous wastes unless the constituent hazardous
chemicals are immobilized or destroyed.
http://www.epa.gov/osw/hazard/tsd/ldr/snapshot.pdf

More about LDR and the applicable treatment standards
can be found in 40 CFR Part 268, as well as in Land Disposal
Restrictions: Summary of Requirements.
http://www.epa.gov/osw/hazard/tsd/ldr/ldr-sum.pdf

*• Quantifying the Environmental  Benefits from
   Materials Diversion

EPA's "Methodology for Understanding  and Reducing a
Project's Environmental Footprint" report presents green
remediation metrics associated with contaminated site
cleanup, and a process to quantify those metrics in order to
achieve a greener cleanup. Use of the methodology can
provide quantitative information about  the footprint
reductions gained from the use of best practices for waste
and materials.
http://www.cluin.org/greenremediation/methodologv/

The Waste Reduction Model (WARM)  calculates and totals
life cycle GHG emissions avoided through alternative waste
management practices (reduced, recycled, combusted, or
composted) in comparison to a baseline scenario
(landfilled) for various materials.
 http://www.epa.gov/warm

The Recycled Content (ReCon)  Tool estimates the life cycle
GHG emissions and energy impacts from purchasing and/or
manufacturing materials with varying  degrees of post-
consumer recycled content.
http://www.epa.gov/climatechange/wycd/waste/calculators/ReC
on home.html

The Greenhouse Gas Equivalencies Calculator expresses
quantities of GHGs in easier to comprehend metrics such as
number of cars, gallons of gasoline, acres of forest, etc.
http://www.epa.gov/cleanenergv/energv-
resources/calcu lator.html

More Jobs, Less Pollution: Growing the Recycling Economy
in the US provides environmental and economic benefits
information for implementing a bold national recycling and
composting strategy in the U.S. The report was prepared by
the Tellus Institute for the Blue Green Alliance, a coalition
of labor unions and environmental groups.
http://www.recvclingworkscampaign.org/2011/ll/more-iobs-
less-pollution/
        The Engineering Forum Greener Cleanup
        Subcommittee offers broad assistance in
  implementing EPA's Principles for Greener Cleanups at
                    Superfund sites:
                       orum/ecs/
References [Web accessed: March 2013]

U.S. EPA (2012). Methodology for Understanding and Reducing a Project's
Environmental Footprint. EPA 542-R-12-002.
http://www.epa.gov/oswer/greenercleanups/pdfs/methodology.pdf

U.S. EPA Region 2 (2011). Clean and Green Policy Technical Primer
Number One- Materials Reuse and Recycling.

U.S. EPA Region 5 (2011). Interim Resource Guide: Greener Cleanups
Through Sustainable Materials Management.
http://www.epa.gov/Region5/waste/cars/remediation/r5interim resourc
e guide0511.pdf

U.S. EPA (2009). Opportunities to Reduce Greenhouse Gas Emissions
through Materials and Land Management Practices. EPA 530-R-09-017.
http://www.epa.gov/oswer/docs/ghg land and materials management.
fidf

U.S. EPA (2009). Recover Your Resources: Reduce, Reuse, and Recycle
Construction and Demolition Materials at Land Revitalization Projects.
EPA-560-F-09-523.
http://www.epa.gov/brownfields/tools/cdbrochure.pdf

U.S. EPA (2009). Sustainable Materials Management: The Road Ahead.
EPA530-R-09-009.
http://www.epa.gov/epawaste/conserve/smm/vision.htm and
http://www.epa.gov/epawaste/conserve/smm/pdf/vision2.pdf

U.S. EPA (2003). Beyond RCRA: Waste and Materials Management in the
Year 2020. EPA530-R-02-009.
http://www.epa.gov/wastes/inforesources/pubs/vision.pdf

U.S. Army Corps of Engineers, Naval Facilities Engineering Command, Air
Force Civil Engineer Support Agency, Air Force Center for Engineering and
the Environment, and the National Aeronautics and Space Administration
(2012). Unified Facilities Guide Specifications, UFGS 02 54 21.
http://www.wbdg.org/ccb/browse cat.php?c=3. See Section 02 54 21,
Bioremediation of Soils Using Windrow Composting,
http://www.wbda.orK/ccb/DOD/UFGS/UFGS%2002%2054%2021.pdf

 For more information about sustainable materials management
                 during site cleanup, contact:
                     Kendra Morrison
        U.S. Environmental Protection Agency Region 8
        Office of Partnerships and Regulatory Assistance
         Resource Conservation and Recovery Program
                 morrison.kendra@epa.gov

                       Ksenija Janjic
            U.S. Environmental Protection Agency
         Office of Resource Conservation and Recovery
        Resource Conservation and Sustainability Division
              Industrial Materials Reuse  Branch
                   ianiic.kseniia(5)epa.gov
                                                                     To learn more about EPA's green remediation
                                                                    strategies, visit Green Remediation Focus online:
                                                                          httD://cluin.ors/sreenremediation
                                                           12

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