Green Remediation or Sustainable Remediation: Moving From Dialogue to Common Practice

REMEDIATION Spring 2015

Green Remediation or SustainableRemediation: Moving From Dialogueto Common Practice

Paul W. Hadley

Melissa Harclerode

Different points of view have emerged concerning how to best consider and address the largely un-

examined ancillary environmental impacts, and more particularly the social and economic impacts,

of remediation activities. These views are generally categorized as “green remediation” and “sus-

tainable remediation.” This article dissects the commonalities and differences between “green”

and “sustainable” remediation approaches. Several key obstacles to the broader implementation

of sustainable remediation practices are identified. Similarities identified among the two concepts

offer a common ground and areas of collaboration. The objective of this article is to support matu-

ration of the remediation industry by addressing the opposition to and supporting the implementa-

tion of sustainable remediation practices, including offering recommendations for a path forward.c ⃝ 2015 Wiley Periodicals, Inc.

INTRODUCTION

During the past two decades, there has been a worldwide concern that anthropogenicsocietal and industrial emissions of carbon dioxide and other greenhouse gases arecontributing to a trend of global climate change. In addition, nonrenewable resources aredecreasing in availability. As a result, virtually every segment of society has worked toalleviate atmospheric impacts and reduce the consumption of natural resources, thusfunctioning more sustainably. Simply reading the environmentally friendly claims on thepackaging for food and durable goods demonstrate how sustainability principles andpractices have been integrated into everyday life. These and other examples highlight theimportance sustainability principles and practices have achieved in modern culture.

In the midst of such widespread interest in sustainability, the site remediation industryhas been considering the environmental impacts resulting from cleanups. This conceptcame to prominence in 2010 when the United States Environmental Protection Agency(USEPA, 2010) issued the final draft of their Superfund Green Remediation Strategy. Theremediation industry is unique in that its main activity—cleanup—is conducted toaddress environmental contamination from historic practices and processes conducted at asite. In addition, the environmental agencies that mandate or oversee cleanups developrules, regulations, and guidance that often specify preferred or required approaches.

c ⃝ 2015 Wiley Periodicals, Inc.Published online in Wiley Online Library (wileyonlinelibrary.com). DOI: 10.1002/rem.21427 95

Green or Sustainable Remediation: Moving From Dialogue to Common Practice

In fact, early guidance andexamples of green reme-diation focused almostexclusively on substitutingbiodiesel for conventionaldiesel fuel, and lookingfor opportunities to utilizealternative sources ofelectricity—particularlyphotovoltaic panels andwind turbines—to powerremedial systems.

Professionals throughout the remediation industry recognize the often contentiousand litigious nature of the cleanup process and the resulting challenges that have hamperedinnovations of all kinds. Not surprisingly, different points of view have emergedconcerning how to best consider and address the heretofore largely unexamined ancillaryenvironmental impacts, and more presently the social and economic impacts, ofremediation activities. These views are manifest most evidently as a preference for either“green remediation” or “sustainable remediation.” Although there are differences inpreferred nomenclature and overall approach, both parties are interested in obtainingsimilar goals for maximizing the overall benefit of a cleanup. Still there are somesignificant differences between “green” and “sustainable” remediation approaches, andobstacles to broader implementation of such practices. There is also common ground andareas of collaboration among the two approaches that should provide a path forward.

GREEN REMEDIATION OR SUSTAINABLE REMEDIATION?

Green remediation can generally be described as the practice of implementing remedialactions in a more environmentally friendly way, such as utilizing renewable energy sourceswherever possible. In fact, early guidance and examples of green remediation focusedalmost exclusively on substituting biodiesel for conventional diesel fuel, and looking foropportunities to utilize alternative sources of electricity—particularly photovoltaic panelsand wind turbines—to power remedial systems. Historically “greening” the remedy hasneither influenced the basic remedy design nor considered whether the selected remedialaction produces either a significant net benefit to, or negative impact on, the environment.Perhaps this is in part because many remedies were already in place long before the adventof either green remediation or sustainable remediation practices. However, recentguidance for green remediation allows for green practices and options in the remedyselection phase of a cleanup (ASTM, 2013).

On the other hand, sustainable remediation can generally be described as taking abroader, more holistic view of remediation’s impacts and benefits. Sustainable remediationtackles the challenge of balancing the economic, societal, and environmental impacts andbenefits (i.e., the triple bottom line of sustainability) of remedial actions as a matter ofprinciple. Note that the triple bottom line is nearly universally incorporated whenaddressing sustainability in other sectors.

Under sustainable remediation not only are “green” opportunities (e.g., use ofenvironmentally preferable energy sources) to be considered, but design andimplementation of remedial actions are undertaken to produce cleanups that are cognizantof societal and economic impacts than would have occurred otherwise. In some regards,this is analogous to conducting an integrated impact assessment or a strategicenvironmental assessment (Pope et al., 2004) in parallel with the remedy selection anddesign, in order to make a more informed decision to promote overall benefit to the triplebottom line of sustainability. To the extent this occurs, one might say the sustainabilityassessment conducted for the cleanup project has been integrated into the remedyselection and design process. This is a clear difference from the current common approachfor implementing green remediation. However, under sustainable remediation, theprinciples and practices of green remediation can also be incorporated into the remedyselection and design process.

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CURRENT STATE OF PRACTICE

Environmental regulatory agencies become involved in remediation projects through anumber of different programs, including traditional Superfund-style cleanups, correctiveactions at operating and closing permitted facilities, leaking underground fuel tanks,voluntary cleanups, and brownfield cleanup and redevelopment projects. While theseprograms vary in goals and approaches, all involve some form of enforcement activity orenforceable agreement. The legal position of regulatory agencies might be considered animpediment to implementing innovations of all kinds during remedial activities. However,there are still quite a few good examples of both green and sustainable approaches beingintegrated into cleanups.

Exhibit 1 provides an example of organizations involved in either green remediationor sustainable remediation practices. As can be seen, most of the organizations areassociated with government, though some notable exceptions are apparent. Most of theregulatory agencies identified in Exhibit 1 tend to be more closely aligned with greenremediation than with sustainable remediation. Professional organizations and federalagencies external to the regulatory jurisdiction are the main advocates for incorporatingsustainability principles and practices into environmental remediation.

An extensive compilation and discussion of green remediation and sustainableremediation policies and guidance issued by federal and nonfederal organizations at aninternational level is provided in The Horinko Group’s The Rise and Future of Green andSustainable Remediation (Horinko Group, 2014).

Few would suggest that reducing the ancillary environmental footprint of aremediation project—particularly at a large remediation project deploying anenergy-intensive cleanup technology—is not desirable. However, the approach to achievethat goal and to what degree it should be considered, compared with other factors are asignificant part of the current dialogue between the proponents of green remediation andthe proponents of sustainable remediation.

IMPLEMENTATION OBSTACLES

There are several obstacles to the broader implementation of sustainable remediationprinciples and practices. Five key implementation obstacles have been discussedpreviously, including health and safety; incorporation of the triple-bottom-line concept;timing (i.e., applied at the remedy selection vs. implementation stage); concernsurrounding the limited success of many groundwater remediation projects, particularlythose involving source control or treatment; and potential impact of litigation onsustainability principles implemented on remediation projects (Hadley & Woodward,2010). These obstacles also tend to divide proponents of green remediation fromproponents of sustainable remediation.

Health and Safety

In remediation, health and safety concerns—for onsite workers as well as surroundingcommunities—are of paramount importance. The practitioners of sustainableremediation advocate evaluating health and safety aspects of remedial approaches during

The legal position ofregulatory agencies mightbe considered an imped-iment to implementinginnovations of all kindsduring remedial activities.However, there are stillquite a few good exam-ples of both green andsustainable approachesbeing integrated intocleanups.

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Exhibit 1. Organizations involved in green or sustainable remediation

OrganizationComposition,Constituents Practices References, Links, Comments

USEPA Federal environmentalregulatory agency

Provide guidance documents, otherinstructional materials, trainingmodules, evaluation tools, and haveconducted a number of outreachactivities on green remediation

http://www.clu-in.org/greenremediation/

Wisconsin Departmentof Natural Resources(DNR)

Federal environmentalregulatory agency

Green and sustainable remediationmanual

http://dnr.wi.gov/files/PDF/pubs/rr/RR911.pdf

Illinois EPA State environmentalregulatory agency

Prominent representative on nationalefforts for green remediation; havedeveloped a series of tools forenabling greener cleanups

http://www.epa.state.il.us/land/greener-cleanups/

New York Departmentof EnvironmentalConservation (DEC)

State environmentalregulatory agency

Developed a policy on the approach toreducing the environmental footprintof cleanups (i.e., green remediation)

http://www.dec.ny.gov/docs/remediation_hudson_pdf/der31.pdf

Massachusetts DEP State environmentalregulatory agency

Developed a greener cleanups policysupporting green remediationpractices, however encouragessustainable remediation

http://www.mass.gov/eea/agencies/massdep/cleanup/regulations/sustainable-remediation-faqs.html

Minnesota PollutionControl Agency (PCA)


Active participant and leader in nationalefforts at green and sustainableremediation; internally has madeefforts in fuel tank cleanups alongwith other types of cleanups

http://www.astswmo.org/Files/Policies_and_Publications/Sustainability/Greener_Cleanups/MN-Green-and-Sustainable-Remediation-and-Redevelopment-0911.pdf

California Departmentof Toxic SubstancesControl (DTSC)


Conducted a symposium on green andsustainable remediation, prepared adocument, excel spreadsheet forqualitative assessment; the DTSC GreenRemediation Team is currently“inactive”

Interim advisory document ongreen remediation, excelspreadsheet for qualitativeassessment, and materialsfrom the February 2009symposium are available at:http://www.dtsc.ca.gov/OMF/Grn_Remediation.cfm

U.S. Dept. of Energy Federal agency carryingout environmentalcleanups

Promotes the use of green andsustainable remediation practices

http://www1.eere.energy.gov/sustainability/pdfs/doe_sspp_2011.pdf

Association of Stateand Territorial WasteManagement Officials(ASTSWMO)

An organization for statewaste managementprograms to coordinate,collaborate, and worktogether on matters ofmutual interest

Has carried the “Greener CleanupsInitiative,” which involves a number ofstates

http://www.astswmo.org/Pages/Policies_and_Publications/Sustainability/Greener_Cleanups.html





















http://www.dtsc.ca.gov/OMF/Grn_Remediation.cfm

http://www.dtsc.ca.gov/OMF/Grn_Remediation.cfm









Exhibit 1. Continued


ASTM International Organization for thedevelopment anddelivery of voluntaryinternational standards

Produced two separate guides forintegrating sustainability objectivesinto cleanups, one addresses greenremediation while the other speaks tosustainable remediation

Green remediation:http://www.astm.org/Standards/E2893.htm

Sustainable remediation:http://www.astm.org/Standards/E2876.htm

ASTM E2893–13 standard guide forgreener cleanups

ASTM E2876–13 standard guide forintegrating sustainable objectives intocleanup

Interstate Technology& Regulatory Council(ITRC)

State-led coalition thatincludes industry,academia, federalagency staff, andcommunity stakeholders

Created two guidance documents, ongreen and sustainable remediation;produced one Internet-based trainingmodule

Guidance documents and linksto the training are availableat: http://www.itrcweb.org/Team/Public?teamID=7

SustainableRemediation Forum(SURF)

Nonprofit organizationwith mission foreducation onsustainableremediation;membership open toall, but membership isprimarily from theprivate sector

Published a series of documents onsustainable remediation; outreachefforts through professionalconferences

Documents and other materialsavailable at:http://www.sustainableremediation.org/library/

U.S. Air Force CivilEngineer Center(AFCEC)

Federal agency carryingout environmentalcleanups

Developed the Sustainable RemediationTool (SRTTM); incorporates green andsustainable remediation practices inremediation approaches

http://www.afcec.af.mil/environment/technicalsupportdivision/environmentalrestorationtechnicalsupportbranch/restorationsystemsandstrategies.asp

U.S. Department ofDefense (DOD)

Federal agency carryingout environmentalcleanups

Promotes the use of green andsustainable remediation practices;Consideration of Green and SustainableRemediation Practices in the DefenseEnvironmental Restoration Program(August 2009)

http://www.smithcollaboration.com/wp-content/uploads/2012/09/DoD-Green-and-Sustainable-Remediation-Policy.pdf


http://www.astm.org/Standards/E2893.htm




http://www.itrcweb.org/Team/Public?teamID=7

http://www.itrcweb.org/Team/Public?teamID=7

http://www.sustainableremediation.org/library/

http://www.sustainableremediation.org/library/















U.S. Army Corps ofEngineers (USACE)

Federal agency carryingout a large share of theenvironmental cleanupwork being performedby other Federalagencies

Developed a decision frameworkdocument for incorporating green andsustainable practices into cleanups.USACE Decision Framework forIncorporation of Green and SustainablePractices into EnvironmentalRemediation Projects (March 2010).

http://employee.uxb.com/Publications/USACE/IGD%2010-01.pdf

U.S. Navy Federal agency, theDepartment of NavyEnvironmentalRestoration (ER)Program

Incorporates green and sustainableremediation practices in passive andactive remedial approaches.Department of Navy Guidance on Greenand Sustainable Remediation (April2012)

https://www.navfac.navy.mil/navfac_worldwide/specialty_centers/exwc/products_and_services/ev/erb/gsr.html

USEPA regional offices Federal environmentalregulatory agencyregional offices

Region-specific green remediationpolicies are available for all USEPAregions; additional materials availableon a region-by-region basis

http://www.clu-in.org/greenremediation/regions/index.cfm

remedy selection. This perspective of sustainable remediation is occasionally not shared byadvocates of green remediation. In the authors’ own experiences, the notion that workerhealth and safety should be considered in selecting a remedy has been rejected by someregulators. Arguments offered against regulatory agencies overseeing remediation beingdirectly involved with worker health and safety include that those concerns are overseenby other agencies (e.g., Occupational Safety and Health Administration—OSHA), andthat the dangerous activities often associated with remediation—trucking, drilling,dredging, and others—would be ongoing in commerce anyway, and so the remediationdoes not “create” a unique danger or hazard.

Concurrently, the authors have experience with other regulators pointing out thathealth and safety concerns should be considered under the evaluation of the short-termeffectiveness of a remedy. In addition, these same regulators have described projects wherecertain remedial alternatives were no longer considered based on health and safetyconcerns. Addressing health and safety concerns is discussed as a part of remediation riskmanagement in a relatively recent state regulatory agency–oriented guidance document(ITRC, 2011c).

The key issue surrounding this obstacle seems not to be the principle that health andsafety should be considered—no matter the overarching framework—but rather that adiscussion of health and safety concerns can force an uncomfortable visible decision wherethe merits of remediation are weighed against the likelihood of injury, or even death, frompotentially hazardous remediation activities. This dilemma is quite apparent in consideringdredging projects, but also arises wherever the miles traveled and the hours worked on aparticular project become excessive.













The Triple Bottom Line

Regulatory programs operate under the authorities vested in them. Sustainability is notspecifically called out as a consideration in enabling legislation and regulations that governcleanups. Indeed, neither green remediation nor sustainable remediation is specificallyreferenced among the National Contingency Plan’s (NCP’s) nine criteria for environmentalcleanup. Requiring that sustainability analyses be conducted, or that sustainabilityprinciples be put into practice, is not as common or as high of a priority as the basicregulatory requirements in enforcement-oriented cleanups. Nonetheless, examples existof green remediation and sustainable remediation interests being included in remediationorders or state regulatory policies (J. A. Simon, personal communication, 2014).

The regulatory criteria for evaluating remedies are for the most partqualitative—only the cost estimate of a remedy is quantitative. By contrast, practitionersof sustainable remediation strive to provide as quantitative an estimate as possible for boththe undesirable and beneficial impacts of remedial alternatives. These impacts can bequantified using industry-endorsed tools (i.e., life-cycle assessment and environmentalfootprint analysis) and innovative methodologies (i.e., cost–benefit analysis ofsocioeconomic impacts and community surveys). By doing so, not only should unintendedconsequences of remediation be more likely to be revealed, but alternative remedies canalso be compared against each other, both more quantitatively and more confidently. Thus,a more informed decision can be made when choosing the selected remedy for cleanup.The dilemma that develops is that a more sustainable remedy—though perhaps defensibly“better” than other options—might not be considered as such by those reviewing theremedy proposal since, strictly speaking, there is no regulatory requirement to do so.

Analogous situations are apparent in other areas of the remediation industry. Forexample, innovative field analytical methods (e.g., portable gas chromatograph) and in situcharacterization tools (e.g., membrane interface probe [MIP] and ultraviolet opticalscreening tool [UVOST]) are available to provide more streamlined and, occasionally,more reproducible results than conventional laboratory analytical methods. In fact, evenUSEPA has spent considerable time and energy in moving “better” analytical methods intocommon use. Resistance to use such methods has often been due to inappropriateoverreliance on SW 846 laboratory methods, as well as to longstanding institutionalpreferences and habits that have precluded all other non-SW 846 methods. Significanteffort has been expended by USEPA and others to overcome institutional preferencesagainst new and innovative analytical and characterization methods and to put non-SW846 methods into more frequent use and acceptance (ITRC, 2007; USEPA, 1997, 2005).

When looked at it in the light of “is this remedy better or worse”—much in the wayan optometrist gives two options in an eye exam—most people will invariably choose the“better” option. So perhaps, just as it has taken quite some time for better and innovativemeasurement techniques to find broader acceptance, it might be that sustainabilityassessments of remedies will need some time to demonstrate their advantages to regulatorsand others. Sustainability assessments have already been recognized for their potential toproduce “better” remedies by some significant industrial interests with cleanup obligations(Butler et al., 2011; Favara et al., 2011; Holland et al., 2011; SURF, 2009). In addition,regulators have in several instances reviewed and accepted remedies that integratedsustainability analyses. This increase in acceptance is simply supported by the issuance ofgreen and sustainable remediation guidance by federal agencies and regulatory councils, as

Requiring that sus-tainability analyses beconducted, or that sus-tainability principles beput into practice, is notas common or as highof a priority as the basicregulatory requirementsin enforcement-orientedcleanups.



All techniques and tech-nologies must overcomethe variety of contami-nant transport processesthat move and spreadcontaminants through-out aquifers, as wellas those physical andchemical processes thathold contaminants inaquifer matrix materials,and therefore impedecontaminant removal ordestruction.

well as the development of environmental footprint analysis tools (e.g., SiteWiseTM andSRTTM), which include health and safety and other socioeconomic metrics.

So perhaps like many other “new” ideas introduced into the remediation industry, asignificant amount of time is still required to educate the work force on sustainabilityprinciples and practices built around the triple bottom line before they are accepted andimplemented as business as usual.

Timing

There is generally a difference of opinion between advocates of green remediation andadvocates of sustainable remediation about just when sustainability principles should beconsidered. Advocates of green remediation usually consider incorporation of suchprinciples after a remedy is selected. As such “green” practices will only have after-the-factimpacts on the sustainability of a remedy. It should be noted that under sustainableremediation approaches, green remediation principles could be considered at any point ina contaminated site’s life cycle. By contrast to the norm of the green remediationapproach, advocates of sustainable remediation argue that sustainability principles beconsidered throughout a contaminated site’s life cycle, even offering analyses of therelative “sustainability” of various site assessment and cleanup alternatives. By integratingsustainability analysis early on in the remedial alternative development/design process,the most significant changes and improvements can be made to alleviate undesirableimpacts and promote beneficial ones.

Recently, advocates of green remediation have recognized that integratingsustainability principles and practices into remediation projects can produce a betterremedy (Harclerode et al., 2013; Watt et al., 2010). To that end, there is at least tacitrecognition from some advocates of green remediation that integrating sustainability intothe remedial design and selection process has merit, with most of the objection being overthe prescribed regulatory approach not specifically identifying sustainability as a significantfactor to consider when evaluating a remedy. An opportunity to revise the currentregulatory approach is USEPA’s recently released Strategic Plan 2014–2018. USEPA’sStrategic Plan “stresses the importance of sustainability assessments in pursuing the majorgoals of the organization” (NRC, 2014). Recent guidance from ASTM (2013) mayencourage broader consideration of both green remediation and sustainable remediationopportunities earlier in the cleanup process, where benefits can be more significant thanpostremedy selection.

Ineffectiveness of Remedies, Particularly for Source Control

Inherent in the notion of “sustainability” is the concept of effectiveness. Clearly, a moreeffective approach to any activity would be viewed almost universally as more desirableand successful. Moreover, a more effective approach is invariably more sustainable.

In the context of “effective” groundwater remediation, many techniques andtechnologies have been applied for cleanup of contaminated aquifers. All techniques andtechnologies must overcome the variety of contaminant transport processes that move andspread contaminants throughout aquifers, as well as those physical and chemical processesthat hold contaminants in aquifer matrix materials, and therefore impede contaminantremoval or destruction. Several studies have looked at the shortcomings—and poor



performance—of groundwater remediation technologies, particularly those aimed atdense nonaqueous-phase liquid (DNAPL) sources and chlorinated solvent plumes (ITRC,2011b). At least some studies have shown that remediation of sources often did notproduce any significant improvement (Geosyntec Consultants, 2004; McGuire et al.,2006; Newell et al., 2006).

Exhibit 2 presents a number of documents and publications covering a period ofapproximately 25 years dealing with the performance of various remedial technologies forgroundwater contamination. None of the publications indicate that the “MCLseverywhere” remediation goal is achievable, and some provide caution as well as evidencethat it is essentially unattainable through remedial technologies (ITRC, 2011b; NRC,2013). More recent research has shown that diffusion into the aquifer matrix materials isone such chemical process that has been underappreciated in its significance, and that itexplains the relatively poor performance of many groundwater remediation systems(Hadley & Newell, 2012).

It should seem apparent that when site conditions are anticipated to be almostunresponsive to active remediation, the merits of active remediation should bequestioned, particularly in light of ancillary environmental impacts associated with themore common energy-intensive cleanup technologies. At present that is generally not thecase, and remediation systems are often required without significant consideration ofexpected performance and SMART (specific, measurable, achievable, relevant, andtime-bound) remedial objectives focused on risk-based cleanups (ITRC, 2011b). At thesame time, there has been an ongoing debate for well over a decade about the merits ofsource zone remediation, particularly where only partial mass removal can be effected(Kavanaugh et al., 2003). Despite a mounting body of research and practical experiencequestioning, if not challenging, the concept and practice, source zone remediation remainsa default presumption of many remedies (ITRC, 2011b). Fortunately, the development ofinnovative technologies (e.g., in situ chemical oxidation, bioremediation, and thermaltreatment) has increased the effectiveness of source zone remediation.

Both green remediation and sustainable remediation principles can play a role inaddressing effectiveness of active and passive source zone and groundwater remediation byproviding best management practices (BMPs) and tools to facilitate stakeholders in makinga more informed decision when considering cleanup approaches.

Litigation

The remediation industry is known not only for the visible presence of enforcement fromregulatory agencies, but also for the existence or possibility of legal pressures beingbrought to bear by individuals, organizations, or other entities such as through third-partylawsuits. Despite the apparent merits and advantages of a more sustainable remedy, it maynot be acceptable to the parties engaged in litigation.

At this time, the authors are unaware of any remediation project being rejectedbecause of legal objections directed at sustainability principles and practices incorporatedinto the remedy. However, it seems likely that sustainability principles and practices maybe excluded from consideration where litigation is ongoing, threatened, or pending. At thisjuncture, it is important to pay attention to how the legal community views and respondsto the prospect of sustainability principles and practices being incorporated into remedies.

Both green remediationand sustainable reme-diation principles canplay a role in addressingeffectiveness of active andpassive source zone andgroundwater remediationby providing best man-agement practices (BMPs)and tools to facilitatestakeholders in making amore informed decisionwhen considering cleanupapproaches.



Exhibit 2. Documents concerning performance of remediation technologies

Authors Title of Publication Key Points

Mackay and Cherry(1989)

Groundwater contamination: Pump-and-treatremediation.

Detailed consideration of why pump and treat wasnot working

Travis and Doty (1990) Can contaminated aquifers at Superfund sites beremediated?

Pump and treat probably would not meetexpectations

Rice et al. (1995a,1995b)

Two volumes collectively referred to as the“Lawrence Livermore Report of LUFT Sites.”

Fuel sites are not a significant problem forCalifornia’s water resources; intrinsicbiodegradation at fuel sites is preferred toenergy-intensive remedial technologies

Kavanaugh et al.(2003)

The DNAPL remediation challenge: Is there a casefor source depletion?

Is there a case for source removal?

Geosyntec (2004) Assessing the feasibility of DNAPL source zoneremediation: Review of case studies.

Source treatment is often poorly planned, evenwithout objectives

NRC (2004) Contaminants in the subsurface: Source zoneassessment and remediation.

Need new models, approaches for cleanups

McGuire et al. (2006) Performance of DNAPL source depletiontechnologies at 59 chlorinated solvent-impactsites.

Source treatment is not accomplishing desiredgoals

Newell et al. (2006) Multiyear temporal changes in chlorinated solventconcentrations at 23 MNA sites.

Natural attenuation can be as effective asremedial technologies, though over more time

Muegge and Hadley(2009)

An evaluation of permeable reactive barrierprojects in California.

Back diffusion and other factors would lead toprolonged periods just to verify cleanup, muchless achieve it

ITRC (2011b) Integrated DNAPL site strategytechnology/regulatory guidance.

Cleanup is a daunting challenge—achieving the“MCLs everywhere” objective is unlikely

Hadley and Newell(2012)

Groundwater remediation: The next 30 years. Future approaches to groundwater remediationhave much to learn from the shortcomings ofthe past

NRC (2013) Alternatives for managing the nation’s complexcontaminated groundwater sites.

For large, complex sites current technologies willnot achieve the unrestricted use/unrestrictedaccess goals typically specified

Siegel (2014) On the effectiveness of remediating groundwatercontamination: Waiting for the black swan.

Groundwater remediation as practiced is servingthe public poorly, and accepting the real limitsof what can be accomplished would be verymuch of an improvement

Summary of Implementation Obstacles

The general viewpoint of both green remediation advocates and sustainable remediationadvocates concerning the implementation obstacles just discussed is summarized inExhibit 3.



Exhibit 3. Relative perspectives on the five implementation obstacles

Topic Green Point of View Sustainability Point of View Comment

Health and safety Not applicable since workersare covered by otheragencies (OSHA), andworkers accept the risks oftheir work.

Incurring potential humaninjury or loss when weighedagainst the hypothetical(often exaggerated) risksfrom a site seems tocontradict the intent ofcleanup in the first place;“risks” also can extend tothe community, as withexcessive truck traffic.

Worker (and community) healthand safety are logicallyconsidered under the “short-termeffectiveness” criterion; toooften this seems to be ignored,but informal examples exist ofregulators not evaluating furthersome obviously dangerousremedies.

Triple bottom line Since it is not a specificelement of the “ninecriteria,” it should not beconsidered in remedyselection at all.

Sustainability analyses(evaluating the triplebottom line) improveremedy design andselection; in many waysintegrating thesustainability analysis intothe remedy selection processessentially accomplishes the“environmental impactassessment” required insome jurisdictions.

Sustainability has been successfullyintegrated into remedyselection; further, examples ofhow and why it can and shouldbe implemented are available(Holland et al., 2011; ITRC,2011a; US ACE, March 2012).

Timing Since “sustainability” is notone of the nine criteria,such practices are oftenconsidered postremedyselection via “greening theremedy.”

Integrating sustainabilityconsiderations into theremedy selection processenables stakeholders tomake better informedcleanup decisions.

Sustainability has been integratedinto cleanup decisions, includingremedy selection (e.g., SURFWhite Paper, SURF 2009).

Source control Generally relies on anincreasingly outdated viewof plumes wherein“sources” continually feeddowngradient parts of aplume; source control isprioritized as a componentof virtually all groundwaterremedies.

Recent research and fieldresults indicate that a newmodel is necessary; the“old” model universallylinking sources and plumeshas resulted in countlessinefficient remedies, and atits heart “sustainability” isa reflection of efficiency.

Along with an increasing body ofresearch, recent state-led effortsfrom ITRC have put forth thejustification for following currentthinking about the importanceof mass flux in cleanups; inaddition, USEPA has used massflux in revisiting a remedy toamend cleanup objectives,discontinue previous remedies,and institute a more robustsource zone treatment approachwith well-defined goals (USEPA,2009).




Topic Green Point of View Sustainability Point of View Comment

Litigation It is difficult to see how“green” remediationpractices are a high-riskproposition. Because“green” remediation hasthe support of USEPA, it isdifficult to see why aresponsible party wouldundertake the cost of alegal objection unless thecost of accommodating thesuggested “green”elements of a remedy wasquite high.

Incorporating sustainability asa component of cleanups isa relatively recentdevelopment. Litigation is arelatively commondevelopment aroundcleanups, and whereobjections to sustainabilitycould strengthen a legalstrategy for litigation itmight be argued overlegally.

A number of corporate andgovernment organizationsundertaking cleanups haveintegrated sustainabilityconsiderations and practices intotheir cleanups. While thisprecedent may not preclude legalaction concerning sustainability,it is certainly a good sign.

COMMON GROUND AND AREAS OF COLLABORATION

Sustainability concepts have been visibly applied to remediation projects, and have thepotential to be eventually incorporated into policy. The following examples and significantpolicy and even legislative developments highlight a common ground and likely areas forcollaboration between advocates of green remediation and sustainable remediation. Inaddition, the examples illustrate how a once unsupported concept, with the appropriateaccompanying data and evaluation, can transform to business as usual and, eventually,policy.

Brownfields

USEPA defines brownfields as “ …real property, the expansion, redevelopment, or reuseof which may be complicated by the presence or potential presence of a hazardoussubstance, pollutant, or contaminant” (USEPA, 2002a). Site assessment and cleanup ofbrownfields explicitly take into consideration balancing of the triple bottom line and,therefore, provide an example of sustainable remediation application. Environmentalconcerns associated with a brownfields site are resolved in the context of financiallimitations (e.g., limited remediation and redevelopment funds available) and socialconsiderations (e.g., property reuse often times increases the quality of life of the localand surrounding communities; Holland et al., 2013).

In addition, the “Brownfields Law” is a relatively new regulatory program thatamended the Comprehensive Environmental Response, Compensation, and Liability Act(CERCLA or Superfund) on January 11, 2002 (USEPA, 2002b). The Brownfieldsmovement was initiated largely by the remediation and redevelopment industry and notregulatory entities, similar to sustainable remediation. Brownfields is an excellent exampleof how a concept, developed and put into practice to better serve the remediationindustry and society, can eventually be enacted successfully as law.



Best Management Practices

Many remediation professionals perceive the practice of sustainable remediation to bemore rigorous, ambitious, and potentially difficult to implement in comparison withgreen remediation, and, therefore, use such a justification for not considering it.Fortunately, this perceived concern has been addressed with recent guidance presentingBMPs that can be implemented to incorporate sustainable remediation into siteassessment and cleanup. Examples of relevant guidance are Standard Guide for IntegratingSustainable Objectives into Cleanup (ASTM, 2013), and Green and Sustainable Remediation: APractical Framework (ITRC, 2011a).

BMPs presented in sustainable remediation guidance are often in parallel with BMPsassociated with green remediation. The repetitiveness and similarities among sustainableremediation and green remediation BMPs are due to interrelations among the three pillarsof the triple bottom line (Pope et al., 2004). For example, benefits of incorporatingenvironmentally preferable energy sources include a reduction in greenhouse gasemissions (an environmental benefit), as well as a reduction of impacts from climatechange on all relevant market and nonmarket sectors, including agriculture, energyproduction, water availability, human health, coastal communities, and biodiversity (socialand economic benefits; United States Government, 2013). In other words, by conductinggreen remediation, one is nonetheless performing sustainable remediation, albeitminimally and inadvertently. Therefore, by focusing solely on incorporating only greenremediation elements into site assessment and cleanup, one is simply not acknowledging,much less taking full advantage of, the benefits and potential cost savings associated withsustainable remediation due to its synergistic effects.

Risk-Based Cleanup: Oil Spills

The relatively recent Deepwater Horizon oil spill garnered as much internationalattention as any other oil spill in modern history. The scope and scale of the event, and itsproximity to the rich fishing and shellfish grounds of the Gulf of Mexico, gave theDeepwater Horizon event unparalleled scrutiny by the media, the public, elected officials,researchers, environmental prosecutors, and, particularly, the stakeholders who maketheir livelihoods from the bounty of the Gulf.

In the midst of the heightened scrutiny and sensitivity that the Deepwater Horizon oilspill generated, there was a clear concern that some types of active cleanups advocated forcould in some cases do more “harm” than “good.” In particular, aquatic and wildliferesources were sometimes considered more vulnerable to the effects of the chosencleanup activities than to the contamination itself. Specifically, disruption of sensitivehabitat was viewed as a reason to not undertake active cleanup of low levels of oil. As aresult, decision criteria were developed and adopted so that low concentrations of oillocated in sensitive breeding grounds would be left unremediated to reduce the risk of realand certain damage to the resident wildlife that would result from remediation.Potentially exposed wildlife populations (subsurface-probing birds and sea turtle eggs andhatchlings) would receive further study and attention (U.S. Coast Guard [USCG], 2011).

Most oil spills are amenable to biodegradation by indigenous microorganisms. Byweighing the potential for damage to an ecosystem, resulting from anthropogenic cleanupactivities against the benefits for simply allowing more time for natural attenuation, a

Oil spills are front pagenews. The larger the spill,the longer the event is onthe front page. Along withsuch notoriety comes theinevitable public pressureto conduct an acceleratedcleanup.



Most oil spills areamenable to biodegra-dation by indigenousmicroorganisms. Byweighing the potential fordamage to an ecosystem,resulting from anthro-pogenic cleanup activitiesagainst the benefits forsimply allowing more timefor natural attenuation,a difficult, but more sus-tainable decision aboutcleanups was available.

difficult, but more sustainable decision about cleanups was available. It would seem thatthis kind of decision making and risk-based cleanup approach—though difficult andcertainly not popular—hold to principles that might serve similar difficult decisions onother types of contamination events (e.g., DNAPL sources and chlorinated solventplumes).

Evaluating the Environmental Footprint of Cleanups

Advocates of both green and sustainable remediation approaches recognize andacknowledge that cleanups consume resources and energy, generate atmosphericpollutants, and lead to negative environmental impacts. Identifying those impacts are ofinterest for both green and sustainable remediation practitioners (Scheuermann, 2012;SURF, 2009). However, just how to consider and respond to opportunities to reducethose impacts in the context of developing, designing, and selecting a remedy is a point ofdisagreement. Nonetheless, the acceptance that there are ancillary environmental impactsresulting from remediation and the shared interest in quantifying those impacts, via thedevelopment of agency-specific environmental footprint analysis tools, provide anopportunity for cooperation and collaboration between advocates of green remediationand advocates of sustainable remediation.

SURF’s Water Conservation and Reuse Document

Water scarcity and drought are becoming more and more common throughout at least theWestern United States. Concurrently, ongoing groundwater remediation projects oftendischarge treated water to sanitary sewers, effectively losing all chance for beneficial reuseof the treated water. In some regions, and even for just certain specific projects, there isenough cumulative extraction and treatment of groundwater to meet a significant amountof the local demand for water. A recent document prepared by SURF (2013) considersoptions and opportunities for conservation and reuse of groundwater at remediation sites.Included in that document are 14 case studies, including examples where treatedgroundwater from cleanups was used for public supply. Most of the case studies werelocated in the Western United States.

Presently, the available guidance for reusing treated water from groundwater cleanupprojects is quite limited (USEPA, 2007). Nonetheless, it would seem that advocates ofgreen remediation would have a clear interest in conserving and reusing groundwaterfrom remediation projects—an interest that should be heightened in areas of waterscarcity and drought. With all the potential for meeting some of the increasing demand forwater with reuse of treated groundwater, this would seem to be a logical and likely areafor collaboration between advocates of green remediation and sustainable remediation.

Social Considerations

The triple-bottom-line values social benefits (and costs) equally with economic andenvironmental benefits (and costs). Methodologies to semiquantify and quantifysocioeconomic costs and benefits are maturing. However, social considerations havehistorically been incorporated into assessment and remediation of contaminated sites.Under CERCLA, community acceptance is one of the nine NCP criteria. Many



brownfields cleanups lend themselves to high stakeholder involvement. In addition, thedecision to protect public health itself is viewed as a social consideration. Similar togroundwater conservation and reuse, giving credit to stakeholder engagement andcommunity acceptance as a sustainable practice is another logical and likely area forcollaboration between advocates of green remediation and advocates of sustainableremediation.

A step toward a collaborative effort is EPA Region 7’s development of the LeadingEnvironmentalism and Forwarding Sustainability (L.E.A.F.S.) Award. The award wasestablished to “to recognize those who have supported the Superfund RedevelopmentInitiative through innovative thinking, sustainable practices and environmentalstewardship.” The evaluation criteria for the award include social considerations such as“consideration of and effect on the local community” and “implementation of sustainablepractices.” The CCI Inc. Superfund site was the first project to receive the L.E.A.F.S.Award in 2012. Social benefits from the remediation and redevelopment of the siteconsisted of working with the community to install a pollinator habitat and educationaltrail for monarch butterflies during their pollination season throughout the Midwest. Theredevelopment design included public education regarding the process and importance ofpollination (USEPA, 2014).

From a sustainable remediation perspective, stakeholder engagement and communityacceptance would be incorporated into the decision-making process when evaluatingremedial alternatives for a specific cleanup, rather than postremedy selection. From theauthors’ experience, this scenario is often more prominent under the BrownfieldsProgram, as compared to other CERCLA programs. In addition, considering thesocioeconomic costs of environmental metrics (e.g., monetized damages associated withmitigating the impacts from climate change due to greenhouse gas emissions), along withenvironmental impacts during the remedial alternative evaluation process, enablesstakeholders to make better informed decisions for cleanup and redevelopment.

Cost Effectiveness

With many conventional cleanups predicted to last for centuries, the remediation industryhas ample time to improve its practices. However, funding available to remediateproperties is limited and continues to decrease. One of the components (i.e., spheres) ofthe triple bottom line is the economy. Within the economic sphere, the cost of the cleanupis one of the factors considered when evaluating potential remedial alternatives for a site.Case studies presented at recent conferences and publications (Harclerode et al., 2013;Watt et al., 2010) illustrate significant savings in implementation costs by conductinggreen remediation and/or sustainable remediation practices. For example, Harclerodeet al. (2013) showed a 38 percent reduction in project implementation cost by conductinga phased focused investigation approach utilizing direct imaging screening tools. BMPsimplemented during the phased focused investigation included utilizing the Triadapproach, direct push technology (DPT) drilling methods, and localized laboratorysampling efforts based on direct imaging screening results. These BMPs can be consideredunder both green remediation and sustainable remediation. The common ground ofimplementing green remediation and sustainable remediation practices to reduce projectimplementation cost is an area for collaboration and knowledge sharing.

One of the components(i.e., spheres) of the triplebottom line is the econ-omy. Within the economicsphere, the cost of thecleanup is one of thefactors considered whenevaluating potential re-medial alternatives for asite.



Exhibit 4. Evolution/maturity of the remediation industry (SURF, 2009; reprinted with permission

from SURF)

MOVING FROM DIALOGUE TO COMMON PRACTICE

As mentioned previously, there are many disparate points of view that can come to bear ona remediation project. As such, advances in the remediation industry are often made quiteslowly. Other impediments to progress and innovation are common in the remediationindustry, including limited performance information for many innovative technologies,hesitancy by both regulatory agencies and the public, concerns by responsible parties overcost and performance and the uncertainty of achieving cleanup goals, and a number of riskperceptions held by the various stakeholders in a cleanup project. All of these and otherimpediments can discourage proposals to pursue sustainable remediation principles andpractices in any particular cleanup. At the same time, a vision for sustainable remediationis illustrated in Exhibit 4. As shown therein, sustainable remediation representsadvancement, maturity, and fulfillment of the remediation industry.

In a general sense, without striving for sustainability, the remediation industry wouldinvariably drift toward “unsustainability.” However, like all significant progress in mostsocietal endeavors, sustainable remediation is not without resistance. This resistanceappears to be largely bound by constraints of regulatory processes, protocols, andpreferences focused on the act of remediation rather than its performance and long-termimpacts. After all, most of the metrics of the remediation industry—notably timelines toimplement remedies—are based largely on enforcement objectives. Accordingly, mostregulatory agencies have staff devoted to managing the process of site investigation andcleanup, but relatively few (if any) staff devoted to evaluating the performance ofremediation technologies. Perhaps these situations arise from institutional preferences forcertain remedial approaches and priorities and, therefore, explain in part why most



technology performance surveys are not prepared by regulatory agencies, even thoughregulatory agencies are the central repositories for vast amounts of data.

Like other changes that have come to the remediation industry (e.g., naturalattenuation, in situ bioremediation, risk-based corrective action [RBCA], brownfields, andvoluntary cleanup programs), sustainable remediation has been tasked with addressingmany of the unresolved situations and issues already pervasive throughout this sector.Some of these unresolved situations and issues include identifying verifiable risk versusrisk perception; the need for metrics; the inability of available technology to achieve theelusive “MCLs everywhere” criterion for groundwater remediation; the decision whetherto prioritize enforcement and enforceability or allow flexibility; as well as the inertia ofthe status quo. Considering only the green aspect of remediation is not acknowledging theeffect environmental impacts (as well as benefits) cleanups can have on social andeconomic systems. Moreover, applying a sustainability assessment, whether green orsustainable, post remedy selection does not enable stakeholders to advocate for a remedywith the least impact (or maximum benefit) to the triple bottom line. Sustainableremediation practices implemented at the onset of a project and incorporated throughoutthe entire project life cycle would seem to allow for an improved remedy.

Significant opportunities in implementing sustainable remediation practices include,but are not limited to, developing metrics to evaluate the triple bottom line, increasing thevalue of a cleanup by reusing treated water, reducing the environmental footprint ofremediation, and increasing the social and economic benefits of cleanups. One of the nextsteps toward progress in the maturation of the remediation field, in general, is to identify,discuss, and address the obstacles that hold the remediation sector back in thedecision-making process, what the root cause for reluctance toward maturation really is,and to identify what sustainability has to offer for these shortcomings. The time frame bywhich sustainable remediation reaches a tipping point where it goes from an innovationand intellectual curiosity to a core value in cleanups remains to be seen. Resistance tochange is not an uncommon feature of any progressive idea or movement, regardless ofthe apparent rewards of making a change (Gladwell, 2000).

A potential initial step is to address the lack of quantitative metrics, other than cost, inthe nine criteria of the NCP for determining what makes a “better” remedy. Sustainabilityanalysis offers a semiqualitative to quantitative approach for comparing different remediesfor the same site, and perhaps even comparing remedies from different sites. This has notbeen accomplished with traditional approaches relying only on the nine criteria. However,such sustainability analyses have been conducted and presented at recent conferences andpublications. The remediation industry should continue sharing sustainable remediationcase studies as part of the ongoing dialogue. Case studies will ultimately be a source ofknowledge and guidance for implementing sustainable remediation as “business as usual”(i.e., common practice).

CLOSING THOUGHTS

There are certainly differences between green remediation and sustainable remediationapproaches. However, there seem to be several areas of common interest betweenadvocates of sustainable remediation and of green remediation. If these areas trulyrepresent common ground and shared interests, then there is at least a platform for

Like other changes thathave come to the remedi-ation industry (e.g., naturalattenuation, in situ biore-mediation, risk-basedcorrective action [RBCA],brownfields, and volun-tary cleanup programs),sustainable remediationhas been tasked withaddressing many of theunresolved situations andissues already pervasivethroughout this sector.



establishing communication and progress. The question then would be how to move fromthe current situation of dialogue to common practice. Whether there can ever be aresolution of the implementation obstacles identified earlier seems to be a veryworthwhile but ultimately longer range concern.

So, how can the remediation industry move beyond dialogue concerning sustainableremediation? Inevitably that will require “change.” Whether the change is more in attitudethan in written guidance would seem to be one key question. However, if there can be nochange toward designing and implementing more sustainable remedies, how can there beany other change toward what might be considered better remedies in the first place?Perhaps that is a better question to pursue.

ACKNOWLEDGMENTS

The authors would like to thank Dave Woodward of AECOM for his input and help on anearly draft of this article, as well as Michael Miller of CDM-Smith, Angela Fisher ofGeneral Electric, and Keith Aragona of Haley & Aldrich, for their thoughtful review of alater draft.

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DISCLAIMER

The views and opinions expressed herein are solely those of the authors, and do not reflectthe policies or positions of the DTSC, the California Environmental Protection Agency(Cal/EPA), the ITRC, the SURF, CDM-Smith, Inc., Montclair State University, or anyother organizations with whom either of the authors are affiliated.

Paul W. Hadley is a senior hazardous substances engineer with California’s Department of Toxic Substances

Control. He has been active in SURF since the organization’s inception. Over the last 25 years, he has authored

numerous publications on topics related to risk and remediation, and more recently on sustainable remediation.

Melissa Harclerode is an environmental scientist at CDM Smith, where she specializes in hazardous waste

characterization and remediation, as well as development of sustainable remediation approaches. Related

positions include CDM Smith’s Sustainable Remediation Technical Resource group leader, SURF’s Social As-

pect Initiative cochair, and a doctoral student in the environmental management program at Montclair State

University.
