Standard Guide for Integrating Sustainable Objectives into Cleanup
Importancia y uso:
4.1 Flexibility—Users may desire to incorporate sustainable aspects within the scalable framework throughout any or all phases of the cleanup, or any size of site.
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 The spirit and intent of the guide promotes improvements in cleanup through integration of sustainable objectives.
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.
4.10.2 The cleanup program should be consistent with reasonably anticipated future use of the site.
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.
4.12.1 The user is encouraged to consider long-term benefits and financial savings in addition to short- and long-term costs associated with cleanups performed using this guide.
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.
4.12.4 This guide is intended to use environmental and community resources efficiently and to increase the short- and long-term benefits of a cleanup to its environment and community. This guide is not intended to justify the avoidance of regulatory requirements or any applicable cleanup standards.
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.
4.14 This standard does not purport to address all of the safety concerns, if any, associated with its use. It is the responsibility of the user of this standard to establish appropriate safety and health practices and determine the applicability of regulatory limitations prior to use.
Subcomité:
E50.04
Referida por:
E2348-24, E3033-16, E2091-24, E3210-20, E3361-22, E2893-16E01, E3240-20, E2893-16E01
Volúmen:
11.05
Número ICS:
13.080.01 (Soil quality in general)
$ 1,551
Norma
E2876
Versión
13(2020)
Estatus
Active
Clasificación
Guide
Fecha aprobación
2020-11-01
