Incorporating sustainability: federal contaminated sites decision-making framework

Appendix A: incorporating sustainability in contaminated sites management

Table of Contents

1   Introduction

The main objectives of the Federal Contaminated Sites Action Plan (FCSAP) are to reduce the human health and environmental risks and the financial liabilities associated with federal contaminated sites. One of the priorities under the program is to strengthen consideration of the environmental and socio-economic effects of contaminated sites management at these sites. Furthermore, the Treasury Board Policy on Management of Real Property, which outlines the requirements associated with federal contaminated site management, states that the objective of the policy is “to ensure real property is managed in a sustainable and financially responsible manner, throughout its life cycle, to support the cost-effective and efficient delivery of government programs.”

The FCSAP Secretariat has developed tools, guidance and training to encourage the use of sustainable approaches when managing federal contaminated sites, including the addition of sustainability considerations into the FCSAP Decision-Making Framework (DMF). This appendix provides additional resources to help custodians implement sustainable practices listed in the steps of the DMF. The sections below present general information on sustainable contaminated site management, the benefits associated with incorporating sustainable approaches, the best management practices associated with implementing those approaches, as well as a number of references for guidance documents and case studies that further describe these approaches and best management practices.

2  Principles of Sustainable Contaminated Site Management

Sustainable contaminated site management includes the analysis of the “environmental, social and economic impacts of a project to ensure an optimal outcome, while being protective of human and environmental health, both at a local level and for the larger community” (extracted from Sustainable Remediation Forum (SuRF) Canada, 2012 definition of sustainable remediation).

Sustainable contaminated site management considers implementing sustainable approaches throughout each of the following project phases:

By integrating sustainable approaches and activities throughout the FCSAP 10-step approach (i.e., planning through monitoring as listed above), the environmental footprint for each stage can be reduced. Site managers can choose approaches that not only manage or eliminate the contamination risks but also maximize the overall environmental, social and economic benefits associated with those approaches.

3  Benefits of Sustainable Contaminated Site Management

Incorporating sustainability into contaminated sites management can have many benefits, including:

In many cases, site challenges can be overcome by, or be drivers for, the use of sustainable approaches. For example, sites with large areas of contamination or in sensitive ecosystems, remote and northern locations and/or with lack of access to electrical power can benefit from sustainable approaches such as:

4  Best Management Practices for Implementing Sustainable Approaches

The sustainability approaches identified in the DMF flowcharts are described in more detail in the “Sustainability Summary Tables” presented in the sections below. Various best management practices (BMPs) are presented to assist site managers to implement the sustainability approaches into their projects.

10steps

Figure 4 1: Alignment of Sustainability Best Management Practice Sections with FCSAP 10-Step Process

Figure 4 1 shows the alignment between the FCSAP 10-Steps described in the DMF and the sections in this document with the best management practices for those steps.

The BMPs proposed have varying degrees of complexity. Some of them can be easily applied with minimal time and resources, while others take planning and require additional resources in order to make them more feasible for larger, more complex sites.  To assist with the selection of BMPs that are commensurate with the complexity of a site, in the tables below, each BMP is assigned a level as follows:

Within each Sustainability Summary Table, there are links to the reference sections listing guidance documents and, where available, case studies related to the best management practices presented in the Tables.

5  Preliminary Project Planning (DMF Steps 1 and 2)

5.1  Sustainable Best Management Practices

Preliminary Project Planning (DMF Steps 1 and 2)

Sustainable Best Management Practices

LEVEL 1* LEVEL 2*

5.1.1 Preliminary Sustainability Plan Development

(References)

Develop a Preliminary Sustainability Plan that includes the general requirements set out in the Federal Sustainable Development Strategy and specifically outlines the requirements for the project related activities outlined below. 

The plan should also require any consultants and contractors working on the project to have the following elements incorporated into their work plans and their company’s Environmental Management Systems:

X X

5.1.2 On-site / office waste reduction activities

(References)

  • Reduce water use, waste generation and reuse and recycle wastes (e.g., office waste, demolition waste) generated on site.
X X
  • Recycle paper and other materials
X X
  • Use recycled paper
X X
  • Avoid printing when possible
X X
  • Use reusable cups
X X

5.1.3 Transportation related activities

(References)

  • Avoid idling vehicles
X X
  • Use alternative worker transport methods (e.g., carpooling, cycling)
  X
  • Use fuel efficient or hybrid vehicles
  X
  • Use alternative fuel (i.e., biofuels)
  X

5.1.4 On-site equipment activities

(References)

  • Avoid idling equipment
X X
  • Optimize and maintain equipment regularly
X X
  • Use energy-efficient equipment
  X
  • Use alternative fuel sources (i.e., biofuels) to power equipment
  X
  • Incorporate renewable energy sources (e.g.,  wind , solar)
  X
  • Use equipment with low air emissions and / or enhanced emission controls
  X

5.1.5 Evaluate Sustainability Options for the Project

(References)

  • Identify indicators and metrics that will be measured throughout the project in order to monitor and report on the use of sustainable approaches
X X
  • Use qualitative or semi-qualitative tools for evaluating the sustainability of options for managing the contaminated site project.
X X
  • Use quantitative (i.e., life-cycle analysis) tools for evaluating the sustainability of options for managing the contaminated site project.
  X

5.1.6 Other sustainable site management considerations

(References)

   
  • Determine the best and most sustainable potential future uses for the site
X X
  • Ensure habitat and eco-system protection
X X
  • Examine interim use opportunities (i.e., wind or solar energy generation on unused portions of site)
  X
  • Investigate opportunities for local employment and other socio-economic benefits
  X
  • Consider climate change adaptation
  X
  • Engage contractors / stakeholders to obtain their input on implementing sustainable approaches for the specific site
  X

*Notes

Level 1 = Simple sustainable activities and qualitative analyses that can be applied at smaller, less complex sites.

Level 2 = Multifaceted sustainable activities and more robust and defensible quantitative analyses that can be applied at larger or more complex sites.

5.2 References

Preliminary Project Sustainability Plan Development - References (Section 5.1.1, 7.1.2 & 8.1.1)

General Guidance

Case Studies

On-site / Office Waste Reduction Activities - References (Section 5.1.2)

General Guidance

Case Studies

Transportation Related Activities - References (Section 5.1.3)

General Guidance

Case Studies

On-site Equipment Activities - References (Section 5.1.4)

General Guidance

Case Studies

Evaluate Sustainability Options for the Project - References (Section 5.1.5)

(Note: This section provides guidance and references specific to the evaluation of sustainability options for the project as a whole. Section 7.1.1 provides information and references related specifically to remediation technology sustainability evaluation.)

General Guidance

Case Studies

Other Sustainable Site Management Considerations - References (Section 5.1.6)

General Guidance

Case Studies

6 Initial / Detailed Testing Program and Site Assessment (DMF Steps 3 to 6)

6.1 Sustainable Best Management Practices

Initial / Detailed Testing Program - Site Assessment (FCSAP Steps 3 to 6)

Sustainable Best Management Practices

LEVEL 1* LEVEL 2*

6.1.1 Sustainable Site Assessment

(References)

Plan and implement sustainable site assessment methods that reduce energy and waste generation, where possible, while still providing the necessary due diligence. Examples include:
X X
  • Use on-site analytical techniques to avoid long-distance transportation of samples to laboratories,
X X
  • Use passive analytical devices that avoid the need for digging wells and bore holes,
X X
  • If wells / boreholes are required, use drilling / digging techniques that reduce waste generation, such as low flow purge techniques for groundwater sampling,
X X
  • If sampling is required, develop a strategic sampling plan and use statistical methods to avoid over sampling of the site,
  X
  • Use telemetry or remote data collection.
  X

6.1.2 On-site / office waste reduction activities

(References)

Develop and use sustainable contracting clauses as outlined in the Environmental Procedures in Section 01-35-43 of the Public Works and Government Services Canada’s National Master Specification.

X X

*Note

Level 1 = Simple sustainable activities and qualitative analyses that can be applied at smaller, less complex sites.

Level 2 = Multifaceted sustainable activities and more robust and defensible quantitative analyses that can be applied at larger or more complex sites.

6.2 References

Sustainable Site Assessment and Monitoring Activities - References (Section 6.1.1 & 9.1.1)

General Guidance

Sustainable Contracting Methods - References (Section 6.1.2, 7.1.4 & 9.1.2)

General Guidance

Case Study

7 Remediation / Risk Management Strategy Development (DMF Step 7)

7.1 Sustainable Best Management Practices

Develop Remediation / Risk Management Strategy (FCSAP Steps 7)

Sustainable Best Management Practices

LEVEL 1* LEVEL 2*
7.1.1  Sustainable Remediation / Risk Management Selection

(References)

(Note: This section provides guidance and references specific to remediation technology sustainability evaluation. Section 5.1.5 provides information and references related to the evaluation of sustainability options for the project as a whole.)

Consider sustainability when selecting remediation and / or risk management methods:

X X
  • Consider risk management (as opposed to remediation) approaches where appropriate land-use restrictions and human health and environmental protection can be made.
X X
  • Where risk management approaches are not possible, consider the use of in-situ remediation techniques and those that destroy contaminants.
X X
  • Use a qualitative or semi-qualitative (i.e., PSPC’s Sustainable Development (SD) Analysis Tool) approach to evaluate the sustainability of viable remediation or risk management options for the site.
X X
  • Use a quantitative  (i.e., life-cycle analysis) approach to evaluate the sustainability of viable remediation or risk management options for the site.
  X
7.1.2   Update Sustainability Plan

(References)

Update and refine the preliminary sustainability plan developed in FCSAP Step 2 (as described in Section 5.1.1)

X X
7.1.3   Sustainable Remediation Demonstration

(References)

Look for opportunities to demonstrate the feasibility of incorporating sustainable remediation activities.

  X
7.1.4   Sustainable Contracting Methods

(References)

Develop and use sustainable contracting clauses as outlined in the Environmental Procedures in Section 01-35-43 of the Public Works and Government Services Canada’s National Master Specification.

X X

*Notes

Level 1 = Simple sustainable activities and qualitative analyses that can be applied at smaller, less complex sites.

Level 2 = Multifaceted sustainable activities and more robust and defensible quantitative analyses that can be applied at larger or more complex sites.

7.2 References

Sustainable Remediation / Risk Management Selection - References (Section 7.1.1)

General Guidance

(Note: This section provides guidance and references specific to remediation technology sustainability evaluation. Section 5.1.5 provides information and references related specifically to the evaluation of sustainability options for the project as a whole.)

Case Studies

Sustainable Remediation Demonstration - References (Section 7.1.3)

General Guidance

8 Remediation / Risk Management Strategy Implementation (FCSAP Steps 8)

8.1 Sustainable Best Management Practices

Implement Remediation / Risk Management Strategy (FCSAP Steps 8)

Sustainable Best Management Practices

LEVEL 1* LEVEL 2*
8.1.1  Sustainability Plan Implementation

(References)

Implement the sustainability plan developed and identified in Step 7 (as described in Section 7.1.2)

X
X
8.1.2   Sustainable Remediation / Risk Management Implementation

Implement the sustainable remediation / risk management methods selected in Step 7 and as part of the remedial action plan. Sustainable methods related to specific remediation techniques include:

X X
8.1.3  Soil Excavation

(References)

   
  • Reduce excavation and off-site disposal, where possible,
X X
  • Consider use of on-site treatment rather than off-site treatment of soils
   
  • Avoid unnecessary extraction of soil by performing proper delineation of contamination
   
  • Sequence work to minimize double-handling of materials.
  X
  • Make beneficial reuse of excavated soils on-site, where possible,
X X
  • Use renewable energy sources or clean fuels to power equipment and vehicles
   
  • If transport of materials is required, transport to a location as close as possible to the site
   
  • Segregate and recycle or reuse waste, demolition materials (e.g., concrete, rebar),
X X
  • Reduce water use
X X
  • When additional material is required for fill, select local material that is comprised of post-consumer recycled materials, such as crushed concrete,
X X
8.1.4  In-situ Remediation Optimization

(References)

   
  • Optimize systems to reduce reagent volumes, extraction rates and number of injection wells
   
  • Use existing wells as injection points
   
  • Use direct push drilling methods
   
  • Use renewable energy sources to power injection pumps
   
  • Recirculate extracted groundwater for reagent blending
   
  • Use reagents that are waste byproducts from other processes
   
8.1.5 Groundwater Pump and Treat Optimization

(References)

   
  • Optimize systems to reduce number of extraction wells and reagent use
   
  • Reuse extracted water
   
  • Use renewable energy sources to power extraction pumps
   
8.1.6  Sustainable Contracting Methods

(References)

Implement sustainable contracting clauses as outlined in the Environmental Procedures in Section 01-35-43 of the Public Works and Government Services Canada’s National Master Specification.

X X

* Notes

Level 1 = Simple sustainable activities and qualitative analyses that can be applied at smaller, less complex sites.

Level 2 = Multifaceted sustainable activities and more robust and defensible quantitative analyses that can be applied at larger or more complex sites.

8.2 References

Soil Excavation - References (Section 8.1.3)

General Guidance

Case Studies

In-situ Remediation Optimization - References (Section 8.1.4)

General Guidance

Case Studies

Groundwater Pump and Treat Optimization - References (Section 8.1.5)

General Guidance

9 Confirmatory Sampling and Final Reporting / Long-term Monitoring (FCSAP Steps 9 and 10)

9.1 Sustainable Best Management Practices

Confirmatory Sampling and Final Reporting / Long-term Monitoring (FCSAP Steps 9 and 10)

Sustainable Best Management Practices

LEVEL 1* LEVEL 2*
9.1.1      Sustainable Site Confirmatory Sampling / Monitoring

(References)

Plan and implement site monitoring methods that reduce energy and waste generation, where possible, while still providing the necessary due diligence. Sustainable site monitoring methods to consider include:

X X
  • Use on-site analytical techniques to avoid long-distance transportation of samples to laboratories,
X X
  • Use passive analytical devices that avoid the need for digging wells and bore holes,
X X
  • If wells / boreholes are required, use drilling / digging techniques that reduce waste generation, such as low flow purge techniques for groundwater sampling,
X X
  • If sampling is required, develop a strategic sampling plan and use statistical methods to avoid over sampling of the site,
  X
  • Use telemetry or remote data collection.
  X
9.1.2  Sustainable Contracting Methods

(References)

Develop use sustainable contracting clauses as outlined in the Environmental Procedures in Section 01-35-43 of the Public Works and Government Services Canada’s National Master Specification.

X X
9.1.3      Sustainable Approaches Profiling

Report on and profile the use of sustainable approaches at the site.

  X

* Notes

Level 1 = Simple sustainable activities and qualitative analyses that can be applied at smaller, less complex sites

Level 2 = Multifaceted sustainable activities and more robust and defensible quantitative analyses that can be applied at larger or more complex sites.

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