MassDEP’s Bureau of Waste Site Cleanup Greener Cleanup Guidance AEHS Foundation Soils, Sediments, Water, and Energy Conference Amherst | 21 October 2014 Thomas M. Potter Clean Energy Development Coordinator

WHY Greener Cleanups in MA? Administration Mandates & Goals Clean Energy Results Program (CERP) BWSC CERP Goals 10/21/20142

Massachusetts Clean Energy Mandates 2007 Top Priority for Patrick Administration 2008 Green Communities Act (GCA) – Supports Development of Clean Energy Resources – Expands Efforts to Promote Energy Efficiency – Increased the Renewable Energy Portfolio Standard (RPS) to 1% per year Global Warming Solutions Act – Comprehensive Program -> Climate Change – Goal 25 % Below 1990 GHG levels by /21/20143

Through CERP, MassDEP: Supports DOER and MassCEC in Achieving Commonwealth Clean Energy Goals Promotes Clean and Efficient Sources of Energy at MassDEP Regulated Sites (where we have authority or control) Maximizes MassDEP’s Unique Expertise to Overcome Permitting & Siting Obstacles Addresses Public Health Concerns Using Sound Science 10/21/20144

Commissioner’s BWSC Specific Goals 2.Promote the use of Green Remediation/Greener Cleanups at state and federally regulated contaminated sites 10/21/20145

Promoting Greener Cleanups Focus on Energy Efficiency and Renewable Opportunities (RPS eligible projects)

Green Remediation in the States 0* = State with Statute/Law 2 = State with Regulation (MA, NJ) 8 = States with Policies (NY, IL, IN, MN, CA, OR, WI, WY) 40 = NA * Based on 2012/2013 GCW Survey 710/21/2014

Green Remediation A Sub-Set of Sustainable Remediation Green Remediation maximizes the net environmental benefit of cleanup utilizing approaches and technologies that address the 5 Core Elements. Core Elements – key elements for potentially reducing the environmental footprint of a cleanup. 810/21/2014

5 CORE ELEMENTS (helps reduce net environmental footprint) 1.Minimizing total energy use and maximizing renewable energy use; 2.Minimizing air pollutants and greenhouse gas emissions ; 3.Minimizing water use and impacts to water resources; 4.Reducing, reusing and recycling of materials and waste reduction; 5.Protecting land and ecosystems. 10/21/20149

2014 MassDEP Efforts APRIL - Regulatory Amendments include provisions to address “core elements” in support of Commonwealth’s energy and emission reduction mandates of – Found in RAPS and Remedy Selection MAY - DRAFT Greener Cleanups “Policy” posted online – Policy advocates use of ASTM Standard Guide for Greener Cleanups (E , November 2013) – Comments due July 2014 SEPTEMBER – Greener Cleanups Workgroup – Meeting since 2012 OCTOBER - FINAL Greener Cleanups Guidance posted (available as of 10/20/14) 10/21/201410

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310 CMR Response Action Performance Standard (RAPs) (3) The application of RAPS shall be protective of health, safety, public welfare and the environment and shall include, without limitation, in the context of meeting the requirements of this Contingency Plan, consideration of the following: – (e) eliminating or reducing, to the extent practicable and consistent with response action requirements and objectives, total energy use, air pollutant emissions, greenhouse gases, water use, materials consumption, and ecosystem and water resources impacts resulting from the performance of response actions through energy efficiency, renewable energy use, materials management, waste reduction, land management, and ecosystem protection. 10/21/201412

310 CMR Detailed Evaluation Criteria (for Remedy Selection) the remedial action alternatives identified by the initial screening shall be evaluated using the following criteria: – (4) The comparative costs of the alternatives, including: (b) costs of environmental restoration, potential damages to natural resources, including consideration of impacts to surface waters, wetlands, wildlife, fish and shellfish habitat; and (c) the relative total consumption of energy resources in the implementation and operation of the alternatives, and externalities associated with the use of those resources, including greenhouse gases and other air pollutants. 10/21/201413

2014 Greener Cleanups Guidance Promotion of greener cleanups consistent with Commonwealth’s mandates to improve energy efficiency, reduce emissions and expand the use of renewable energy resources where practicable. Voluntary consideration. The includes addressing five core elements or factors for reducing the environmental footprint of a cleanup. Greener cleanup considerations may not be used to override any requirement to implement a remedy to achieve the timely elimination, mitigation or prevention of such conditions. Users determine specific cleanup phase/response action for application. MassDEP advocates for the use of the ASTM Standard Guide for Greener Cleanups in addition to other available resources. 10/21/201414

2013 USEPA Memo of Encouragement Assistant Administrator OSWER “[I]n the Agency’s pursuit of a cleaner, safer environment, I recommend that the regions and OSWER programs facilitate and encourage use of ASTM’s Standard Guide for Greener Cleanups in your efforts to implement greener cleanup practices.” 1510/21/2014

Available Guidance Resources Several guidance documents and implementing tools that have been developed by outside professional organizations: – United States Environmental Protection Agency (USEPA), August 2009, Principles for Greener Cleanups (US EPA Office of Solid Waste and Emergency Response) – USEPA, August 2014, CLU-IN | Strategies & Initiatives |Green Remediation Focus ( – ASTM International, November 2013, Standard Guide for Greener Cleanups, E – The Interstate Technology and Regulatory Council (ITRC), May 2011, Technology Overview, Green and Sustainable Remediation: State of the Science and Practice (GSR-1) – ITRC, November 2011, Technical/Regulatory Guidance, Green and Sustainable Remediation: A Practical Framework (GSR-2). 10/21/201416

OVERVIEW ASTM Standard Guide for Greener Cleanups  Structure  Only addresses green remediation  Fundamental core is selecting Best Management Practices (BMPs)  Flexible evaluation process A.Qualitative Evaluation – BMP selection B.Quantitative Evaluation (numerical assessment) – Footprint Analysis + BMP, or – Life Cycle Assessment + BMP  Standard is applied on a phase-by-phase basis 1.Site Assessment 2.Remedy Selection 3.Remedy Design and Implementation 4.Operation, Maintenance and Monitoring 5.Remedy Optimization 10/21/201417

Best Management Practices Best Management Practice (BMP) – Activity that reduces the environmental footprint of a cleanup activity – ASTM developed a comprehensive list BMPs NOT... Standard Management Practice (not included because routine - Considered industry standards and are truly basic in nature) Recycling office waste Using compact fluorescent light bulbs Minimizing paper use with electronic filing systems 10/21/201418

SELECTING BMP’s ASTM Guide - BMP Table Task Group compiled table with over 160 BMPs ASTM provides table in Excel format as an “Adjunct” Arranged by category, core element and technology  10 Categories (e.g., power & fuel, materials, vehicles…)  5 Core elements  11 technologies (e.g., SVE, P&T, excavation…) User strongly encouraged to add BMPs to the table (LSPA Tech Practices) User can sort the Excel table by technology, core element or category 10/21/201419

BMP Process “Five Steps to Greening Cleanups” 1. Opportunity Assessment 2. BMP Prioritization 3. BMP Selection 4. BMP Implementation 5. BMP documentation

1. Opportunity Assessment Review master list of BMPs and retains those that warrant further consideration. Consider BMPs not on the master list Should be a pretty straightforward exercise

ASTM BMP Table 2210/21/2014

Example P&T Selection from BMP Table 10/21/201423

2. BMP Prioritization Identify BMPs with the greatest potential for reducing the environmental footprint and prepare prioritized list

BMP Selection – Step 2 Prioritization  Supplement P&T system with plant based extraction  Use variable frequency drives  Operate system in off-peak hours  Install amp meters to evaluate consumption rates  Use gravity flow where feasible  Purchase renewable energy credits  Use on-site generated renewable energy  Use excess steam as an energy source

3. BMP Selection Unless a compelling reason to do otherwise, select each BMP from Step 2 for implementation – Document those that are not selected What is a “compelling reason to do otherwise”? – Substantive issues associated with applicability, implementation, impracticability and cost

BMP Selection – Step 3 Selection & Implementation  Supplement P&T system with plant based extraction  Use variable frequency drives  Operate system in off-peak hours  Install amp meters to evaluate consumption rates  Use gravity flow where feasible  Purchase renewable energy credits  Use on-site generated renewable energy

4. BMP Implementation Again, document BMPs that can not be implemented and why

BMP Selection – Step 4 Implementation  Supplement P&T system with plant based extraction  Development changed and area is now paved eliminating space for plants  Use variable frequency drives  Operate system in off-peak hours  Install amp meters to evaluate consumption rates  Use gravity flow where feasible

5. BMP Documentation Record BMPs implemented Explain why BMPs from Steps 3 & 4 were not implemented (if any)

BMP Case Study No. 1 Future site use not defined Status: Remedy Selection – remedial excavation/backfill with engineered barriers and institutional controls BMP Opportunity Assessment Conducted (no QE) Summary tables prepared: – Potential BMPs – Prioritization of BMPs – Selection of BMPs – No Implementation at this stage 10/16/ SAMPLE

BMP Case Study No. 1 Selected BMPs: – Target Treatment Zones and select appropriate performance standard to minimize volume, tuck trips, emissions, etc. – Use nearby clean backfill – Use local staff/contractors – Use local biodiesel – Implement idle reduction – Establish green requirements for subcontractor selection. 10/16/201332

BMP Case Study No. 1 (cont.) BMP Table Summary 10/16/201333

Why would a PRP, or other property owner want to consider green remediation? Save money Improve community perception Corporate commitment Property value 4/25/14 ASTM Guide Webinar: (External Stakeholders) Q: “What is your driver for implementing the ASTM Guide at site cleanup projects?” A: 43% - Corporate/Agency Policy 10/21/201434

Corporate Policy? 10/21/201435

Green Remediation Incentives Under Consideration DOER & MassCEC Energy Efficiency & Renewable Energy Programs – SREC II, GSHP Grants Public Recognition/Awards for Projects Future Fee “Breaks” Others? – LEED (SAC – 5/22/14) 10/21/201436

Thank You! Thomas M. Potter Clean Energy Development Coordinator MassDEP Bureau of Waste Site Cleanup One Winter Street, 6 th Floor Boston, MA Clean Energy Results Program Website: energy/energy/ 3710/21/2014