Significance and Use
4.1.1 For simplicity the term cleanup is used in the guide when referring to any of the cleanup phases, for example site assessment, remedy selection, remedy design and implementation, remedy optimization, operation, maintenance and monitoring, and closure.
4.1.2 Implementation of the guide is site-specific. The user may choose to customize the implementation of the guide for particular types of sites, for example, UST sites, dry cleaner sites, or particular phases of cleanup. Customization may be particularly relevant for groups of small, non-complex sites.
4.2 Considerations—The information provided in this guide provides a framework to evaluate sustainable aspects in the context of site cleanup. The guide helps users identify factors and activities they may want to consider in cleanup projects, while protecting human health and the environment.
4.3 Sustainable Performance Criterion—Based on the sustainable objectives identified for the site, users should implement one or more best management practices that substantially benefit each of the sustainable aspects (environmental, social and economic), see Section 6 for details. The user should demonstrate these benefits through publicly available documentation. Substantial benefits must be over and above those achieved by existing regulatory requirements, unless a regulatory agency adopts this guide for cleanup sites. In that case the regulatory agency will determine what constitutes substantial benefits under its own regulations.
4.4 Transparency Goal—The user should document the activities and evaluations performed while using this guide. The documentation is needed to demonstrate the sustainable benefits through public disclosure and transparency. See Section 8 for more information.
4.5 Stakeholder Involvement—The user should engage stakeholders as early as possible in the cleanup process. The planning and scoping phase of the project should identify the perspectives and values of the stakeholders and use that information to inform decision-making (see Guide E2348). Users should consider the input of different stakeholders, including the community, and implement BMPs favored by community members wherever possible. Consideration may include review of and integration into the community’s approved Master Plan.
4.6 Elimination of Uncertainty—Professional judgment, interpretation, and some uncertainty are inherent in the process, even when exercised in accordance with objective scientific principles. In addition, new concepts and methods for integrating sustainable objectives into cleanup results will develop in the future.
4.7 Not every property will warrant the same level of evaluation of alternatives or approaches for integrating sustainable objectives in cleanup. The appropriate level of assessment and evaluation should be guided by the complexity of the cleanup project, the extent of impacts, the relative costs and benefits of various cleanup options and sustainable improvements, the potential limitation of resources for the cleanup, the future use of the site, other considerations associated with the site and affected community, and the regulatory requirements.
4.8 Worker health and safety issues are one of many considerations in the site cleanup decision-making process. If two approaches are equally protective of human health and the environment and fully meet regulatory requirements, then the one that is expected to provide greater worker safety should generally be preferred. Worker health and safety should not be used as a rationale for avoiding cleanup at sites.
4.9 The guide is divided into various sections for ease of use. See Fig. 1.
4.9.1 Section 5 includes information for the user about planning and scoping of the cleanup project to integrate sustainable objectives.
4.9.2 Section 6 of the guide includes steps to identify, evaluate, select and implement BMPs for a particular site.
4.9.3 Section 7 presents the evaluation and measurement of improvements for selected BMPs.
4.9.4 Section 8 presents information about documenting the activities conducted while implementing the guide.
4.9.5 Appendices include example BMPs (Appendix X1), example documentation forms (Appendix X2), and Additional Resources (Appendix X3). The example BMP list in Appendix X1 is not intended to be comprehensive, but rather to serve as a starting point for the user. This list may be added to or modified in the future as more experience is gained. The user is encouraged to consult other resources for additional BMPs that may be appropriate for a site. See also 6.2.1.
4.10.1 A cleanup program, developed in conjunction with implementing BMPs following this guide, should fulfill regulatory cleanup requirements and timelines. The user should consider only cleanup approaches that will not result in unreasonable delay of cleanup.
4.11 The user should consider the over-all affect of site cleanup in a holistic manner, including the adverse impacts of the cleanup and the consequences for the community. In order to accomplish this, during cleanup planning, the user should consider the sustainable core elements to provide direction and help define actions.
4.12 Cost Considerations—As with all projects, costs are an important factor. It is the prerogative of the user to determine how to evaluate and accommodate the financial implications of using the guide (see Guide E2137). The economic well-being of persons neighboring a cleanup and others within the community should be considered in the evaluation. The user should document the cost considerations. See Section 8 for information about documentation.
4.12.2 The user should consider advancing the benefits of persons not yet born as an alternative to those who enjoy current day, status quo benefits. Conventional economic efficiency assessment favors the latter persons. (Bromley, 1999) (7).
4.12.3 The user, when applicable, should evaluate short-term and long-term costs and implement appropriate financing strategies. An activity under this guide may have higher up-front capital costs (for example installation of solar panels or energy efficient insulation) but the overall long-term net costs associated with reduced energy use may result in a significantly less net cost compared to an alternative which relies on higher annual energy use.
4.13 Regulatory Context—Regulatory contexts where this guide is applicable include voluntary cleanups, brownfields cleanups performed in compliance with state voluntary cleanup programs, or brownfield initiatives, state-led enforcement cleanups, for example, most underground storage tank corrective actions by states paid through the American Recovery and Reinvestment Act of 2009, CERCLA removal and remedial actions, and other corrective actions required under RCRA. Users should, however, determine the regulatory context for each site and comply with all applicable laws, regulations and guidance (for example, environmental laws under CERCLA, RCRA, TSCA), including health and safety requirements under the OSHA and parallel state statutes and regulations.
4.13.1 Current state and federal cleanup processes already incorporate some greener cleanup principles or sustainable objectives (see NAS 2011) (8). This guide expands the evaluation and consideration of these aspects for interested users.
4.13.2 This guide provides ideas and options within a broad range of actions that integrate sustainable objectives throughout all phases of the cleanup. The guide is not, however, a stand-alone document and does not provide all the information needed to complete the cleanup process. In addition, when implementing this guide, the user must comply with all applicable state and local professional licensing requirements.
4.13.3 The use of this guide does not ensure compliance with any regulatory requirements. Additionally, users are cautioned that environmental regulators may not review or evaluate any particular aspect or results from using this guide as part of the cleanup approval process and the regulatory program.
1.1 This guide presents a framework that allows and encourages the user to address sustainable aspects (environmental, economic and social) within cleanup projects. The user may implement this guide to integrate sustainable objectives into cleanup while working within applicable regulatory criteria.
1.2 The guide provides an overarching, consistent, transparent and scalable framework that helps the user identify and incorporate sustainable best management practices (BMPs) into site cleanup (which includes assessment and remediation), and enables the user to perform measurement of BMPs during the cleanup process. See Appendix X1 for example BMPs.
1.3 The guide is intended to encourage incremental steps to incorporate sustainable elements into cleanup projects. The user chooses whether to pursue BMP implementation alone (Section 6) or to also measure the benefits of the implemented BMPs (Sections 6 and 7). The user also chooses the phases of the cleanup to which they apply the guide.
1.4 The guide should be implemented within the existing site assessment and remediation process. The approach described in this guide should be used with other existing technical tools and policy to encourage the consideration of a more holistic approach with a broader range of cleanup options and activities than traditionally employed (NICOLE 2012(1))2.
1.5 BMPs implemented under this guide should address all three aspects of sustainability: environmental, economic and social, while assuring that human health and safety as well as ecological risks are addressed. The goal of implementing BMPs is to take actions to address the sustainable objectives identified for the site.
1.6 3.1.17 defines sustainable objectives; 184.108.40.206 defines sustainable aspects; 5.3 provides detail about core elements; and Section 6 describes a process to identify, evaluate, select, and implement BMPs.
1.7 While the guide specifically applies to the cleanup phases of a project (which includes assessment and remediation phases), decisions made in the cleanup may influence reuse activities. The anticipated reuse of the site may influence cleanup activities.
1.9 The guide is composed of the following sections: Section 2 Referenced Documents, Section 3 Terminology, Section 4 Significance and Use, Section 5 Planning and Scoping; Section 6 Selection and Implementation of best management practices (BMPs); Section 7 Quantifying Site-Specific results from BMPs; and Section 8 Documentation. Fig. 1 Using the guide is provided to assist the user in navigating the guide.
1.9.2 The environmental portions of the guide align with the Greener Cleanup Principles released by USEPA in August 2009 (2).
1.10 The guide is intended to provide an overarching framework for integrating sustainable objectives in cleanup projects. The user may choose to consider the ASTM Work Item WK 35161 for greener cleanups along with this guide to more fully address the environmental elements of a project.
1.11 When implementing this guide, the user must comply with all applicable federal, state, and local statutes and regulations requiring or relating to protection of human health and the environment. This includes, but is not limited to, laws and regulations relating to health and safety, of the surrounding community, or on-site workers. No action taken in connection with implementing this guide should generate unacceptable human health or ecological risks.
1.11.2 Most sites fall under specific regulatory programs that include provisions for health and safety plans following OSHA regulations. For more information see OSHA FAQ (3).