A Clean, Green Remediation

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A Clean, Green Remediation How Green Remediation can make hazardous waste cleanup more eco-friendly, from beginning to end and at the same time help the bottom line By Robert J. Young, PG Vice President, TechLaw, Inc. Chicago, Illinois And Rich Howard Regional Manager, TechLaw, Inc. Sacramento, California Over the last few years, much of the globe has been swept up in a rising tide of awareness and dialogue about the environment, in general, and in specific about issues such as sustainability, recycling, greenhouse gas emissions and going green. From the cars we drive, to the napkins we use, more people are taking a keen interest in how products are made, how services are delivered and how it all impacts the environment. Thus, it is somewhat ironic that one such specific issue that is just beginning to spark discussion deals with the very way that the country s most toxic places are restored. In other words: Do we have an environmentally friendly way to clean the environment? With that in mind, the chief federal agency that oversees the clean-up of many polluted sites, the U.S. Environmental Protection Agency (EPA), has added another phrase to today s environmental lexicon: Green Remediation. The EPA defines Green Remediation as, the practice of considering all environmental effects of remedy implementation and incorporating options to maximize net environmental benefit of cleanup actions. 1 For property owners and the contracting firms that work to clean up contaminated locales, it means using the agency s recommended practices to minimize impacts on human health and the environment during site remediation activities, while integrating sustainable practices for long-term stewardship. But as many consumers have discovered, going green often comes at a price. Buying that hybrid vehicle or those dye-free, recycled napkins often carries a premium that makes it more costly compared to similar products and services. In today s cost-conscious economy, the tremendous progress made in raising environmental awareness and responding to the threat of ecological harm is in danger of stagnating or slipping. 1 U.S. EPA, Office of Solid Waste and Emergency Response, Green Remediation: Incorporating Sustainable Environmental Practices into Remediation of Contaminated Sites, EPA 542-R-08-022, April 2008

For those reasons, the concept of Green Remediation stands out as a desirable and viable solution for U.S. companies, non-profit agencies and organizations who want to do well by the environment, despite the potentially huge costs associated with environmental cleanups. TechLaw, Inc, found that this concept can be successfully brought to reality when we partnered with Habitat for Humanity at a large-scale cleanup-turnedhousing renewal project at a former hazardous waste site in California. The words and ideas of John Elkington, an author and expert in corporate responsibility and the environment, weren t far from our minds as we approached the Habitat for Humanity East Bay project Oakland, Calif., in 2005. It was Elkington who coined the phrase Triple Bottom Line in 1994, to describe what it would take for sustainability and other environmental concepts to become part of a company s way of business. The three concepts of economic, environmental and social responsibility were all necessary for success, he said. For those considering the Triple Bottom Line in addressing the need to clean up properties contaminated with chemicals or radiological materials, the environmental and social rewards of Green Remediation are obvious. Reductions in greenhouse gas (GHG) emissions, the elimination of wastes generated by longterm cleanup remedies and the establishment of viable ecological habitats are a few of the environmental and social benefits. And as demonstrated by TechLaw and Habitat for Humanity East Bay, the economic rewards of Green Remediation while not so obvious at first were found to be a welcome benefit and a key reason for the project s success. Our experiences showed that all three legs of the Triple Bottom Line stool can sturdily stand up to the Green Remediation process, and that it deserves a seat at the table whenever environmental cleanup is discussed and debated. We also discovered that there is indeed a green path that can be taken that features awareness Habitat for Humanity East Bay Site Before Green Remediation and stewardship when restoring the environment, from a project s uncertain beginning to its rewarding end.

Getting a start on Green Remediation Since it was formed in 1983, TechLaw has provided consulting services on more than 2,000 projects involving the remediation of chemical and radiological contamination. For the last few years, we have requested that our site remediation managers and technical support staff strongly examine Green Remediation options when proposing or evaluating site remediation. We targeted our support to EPA on Superfund and the Resource Conservation and Recovery Act (RCRA) Corrective Action Program projects across the country as a way to integrate Green Remediation into our thinking. Now, we are helping EPA and industry apply Green Remediation in the planning and implementation of cleanup activities at a wide range of contaminated sites. This includes everything from simple underground storage tank (USTs) removals, to complex tasks at industrial facilities with dozens of contaminated waste areas. The goal of any contaminated site cleanup project is to reduce the level of risk that existing chemicals pose to humans and the environment. Green Remediation is a process designed to Habitat for Humanity East Bay Site Removal of UST reach this goal, while also including an emphasis on reducing the demand placed on the environment during and after cleanup activities. Consideration of green methodologies for purchasing materials and selecting remedial technologies needs to start at the initiation of project planning activities. If considered early in the planning process, the potential for cost savings is greatly increased. How a Green Remediation approach helped the bottom line TechLaw recently assisted Habitat for Humanity East Bay (HHEB) with preparing a 1.8-acre former industrial property for residential redevelopment in Oakland, Calif., under a project overseen by the California Department of Toxic Substances Control. The planned construction of 28 single-family homes was the second phase of a 54-home construction project known as the Edes Avenue Development. The development is located on property that was formerly home to a plant nursery, an auto salvage yard and a brick recycling facility. In the planning stages, TechLaw considered Green Remediation processes to address site contamination and the social, environmental and economic aspects of the cleanup project. The social rewards of this project affordable housing in an urban area were noteworthy. Potential environmental and economic benefits were targeted during the planning stages of the project. The goals of the project were driven by the need to mitigate the potential health risks posed by contaminated soils found on the HHEB property, while at the same time reducing the carbon footprint left by the remedial actions. This is how these goals were met:

TechLaw first conducted a human health risk assessment of the property, which indicated that soil containing elevated concentrations of polynuclear aromatic hydrocarbons (PAHs), lead and petroleum hydrocarbons could pose a health risk to future residents if remediation was not performed. Due to the contaminants present, it was determined that contaminated soil removal was the most effective long-term remedy. In evaluating Green Remediation options, TechLaw weighed the need to remove soils posing potential health risks against the environmental impacts of the heavy equipment needed to perform soil excavation, trucks needed to transport contaminated soils off-site, and the disposal and long-term management of contaminated soils in a landfill. The solution? TechLaw s risk assessors developed a health-protective cleanup goal for PAHs that was approved by regulatory agencies and substantially reduced the volume of soil to be excavated and disposed of by 50 percent overall. The health of the future residents was further ensured through a comprehensive confirmatory sampling plan. Greenhouse gas (GHG) generation during the cleanup was minimized, tracked, and then offset by a certified offset provider. Overall, it was determined that the project GHG emissions were reduced by 47 percent, with a 35.4 metric ton carbon dioxide offset for the remaining GHG production. These were real, achievable environmental benefits. Economic benefits were also realized by initially targeting the reduction of the carbon footprint left by the remedial actions. The reduction in heavy equipment and transportation vehicle usage resulted in significant savings, along with cost savings associated with reduced disposal costs due to the smaller volume of soils removed from the site. Through the 50 percent reduction in the volume of waste materials requiring Habitat for Humanity East Bay Site-After Green Remediation excavation and disposal, TechLaw estimated that the overall cost of the site cleanup was reduced by about 40 percent, trimming more than $75,000 in disposal costs from the project. This was a real, achievable economic benefit. In sum, the project was completed on time, greenhouse gas emissions were significantly reduced and money was saved. Most importantly, several families now occupy homes on a former hazardous waste site that was once considered uninhabitable.

Other projects where Green Remediation can result in cost savings For many years, the accepted practice for contaminated site cleanup was the removal and treatment of chemically-impacted materials, followed by disposal or incineration of the treated material. Many of these projects involved ongoing treatment of contaminated media and the generation of wastes that had to be managed in an environmentally safe manner. This was especially true of sites with contaminated groundwater. These projects are now being evaluated through the lens of Green Remediation by measuring the overall sustainability of the remedial actions. Among the questions being asked in the evaluation: What are the impacts on the environment of the treatment methods and byproducts of the processes? To what extent are natural resources being used to sustain the treatment and disposal procedures? How is the disposal of the treated materials impacting the environment? TechLaw advocates focused evaluations of control and treatment technologies that do not generate waste products during the treatment process. For example, under our nationwide EPA contracts, TechLaw has evaluated innovative technologies involving in-situ, or onsite, remediation at more than 50 facilities. These technologies are considered green because they do not generate wastes that would otherwise need to be managed to prevent adverse effects on human and ecological receptors. These technologies also conserve natural resources that would be required to implement more conventional methods of removal, treatment and disposal. Technologies that have been evaluated in favor of excavation and extraction/treatment systems include: surfactant-enhanced subsurface remediation, in-situ chemical oxidation of soil and groundwater, and six-phase heating to treat a site with dense non-aqueous phase liquids (DNAPL). In general, recent technology evaluations and field implementation have proven the long-term environmental benefits of the in-situ remedial measures. Another significant benefit has also been realized: These in-situ technologies are often more cost-effective than the more conventional contaminant removal/treatment/disposal methods. Consider evaluating Green Remediation for your next site cleanup project Implementation of green methodologies for purchasing materials and selecting remedial technologies will almost assuredly result in a site cleanup action that will show social and environmental benefits. The economic benefits of this approach, however, should not be buried. In fact, they should contribute greatly to achieving the ecological, social and financial goals of environmental restoration that benefits commerce and society at a reasonable cost. And if momentum is maintained and successful projects such as the Edes Avenue Development showcase what can be done with Green Remediation, chances are good that the restoration approach taken by Habitant for Humanity East Bay with TechLaw s assistance will likely become a more significant part of environmental cleanup in the future.