Time to Look at the Whole Picture
 

Brownfield Renewal

Time to Look at the Whole Picture

Everyone wants to be green these days. Turn on the TV and you see commercials about oil companies building windmills. Thanks to the efforts of the U.S. Green Building Council’s LEED certification program, the term “green building” no longer needs explanation. Even the ultimate brownfield prize, the Phoenix Award, includes green design among its evaluation criteria.

Current sustainable brownfield redevelopment practices integrate green building and landscape design into their project scope. While this is laudable, it only enhances the reuse part of a project. This year, EPA Region 3 embarked on a pilot with DuPont to see if it is feasible to factor a shade of green into the cleanup portion of a redevelopment project. It’s the part of the picture you don’t see.

The site selected for the pilot is a former nylon manufacturing facility that DuPont would like to see reused. The cleanup is taking place under RCRA Corrective Action authority. (See page 12 for more information about this pilot.)

The Corrective Action program goals call for remedies to meet three threshold criteria: protect human health and the environment; meet cleanup objectives; and control sources to the extent practicable. Remedies that meet the threshold criteria are evaluated against balancing factors such as long-term protectiveness, short-term risks, cost, and community acceptance. A pilot objective was to develop a sustainability balancing factor to compare remediation alternatives that passed the three threshold criteria.

DuPont proposed a matrix of quantifiable inputs using a credit and debit approach to measure the sustainability of potential cleanup options. While these components continue to evolve, they include energy (kWh), carbon output (CO2 equivalents), soil and solid material use (tons), land use (acres), and water use (gallons). For example, reuse of soil is a credit, while off-site disposal of soil is a debit.

The most complicated input to calculate is CO2, which is estimated through a life cycle analysis. In general terms, the CO2 estimate includes debits for the carbon output from fuel and consumables used to build and maintain the remedy and credits for activities that sequester CO2 over the life of the remedy. Credits for sequestration could be achieved through activities such as planting of trees or the destruction of contaminants with global warming potential.

Credit for contaminant destruction would promote more aggressive cleanup technologies and less long-term maintenance, which is more sustainable. This approach aligns with the EPA’s “preference for treatment policy” in the cleanup programs. Looking ahead, if a developer could receive carbon credits for contaminant treatment, some upside down properties might turn right side up.

The EPA and DuPont jointly developed a list of potential cleanup options for the pilot site that were screened against the threshold criteria noted above. Through the credit and debit approach, DuPont calculated the potential net environmental impact of the various options under consideration for each cleanup area. Surprisingly, these calculations showed that CO2 output varied over an order of magnitude across the different cleanup options outlined in the matrix.

This is the first time I’ve seen a quantitative evaluation of remedy alternatives. Typically, cleanup programs compare technologies qualitatively. The pilot produced a better understanding of the total environmental impact associated with the various cleanup options, and it is leading EPA and DuPont to innovative options that would never have been considered.

This is not to suggest that every cleanup warrants the quantitative approach, but companies should consider options to make their cleanups greener. Examples include using low-sulfur diesel to operate construction equipment, using renewable energy (wind and solar) to power a remedial system, recycling material, and increasing site vegetation.

So where do we go from here? One idea is to encourage green cleanups using the LEED certification model, which promotes recycling of materials, efficient use of water re-sources, optimizing energy efficiency, and innovation in design. These same types of considerations could be applied to the cleanup portion of a brownfield project and advanced through a similar third-party certification system.

Development of a rating system to capture cleanup efficiency could guide and stimulate efficient, cost-effective, low-impact site remediation by encouraging property owners, developers and communities to go beyond state and federal requirements in their remediation and revitalization projects. On your next redevelopment project, maximize the net environmental benefits by looking at the whole picture. Put a green building on a green cleanup.

Deborah Goldblum is Region 3’s RCRA Corrective Action Revitalization Coordinator. Any views expressed in this article are those of the author and do not necessarily represent the views of the U.S. EPA.


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