Theme: 03. Green and Sustainable Remediation

Topic Area: 3d. Aligning Remediation Goals with Environmental, Social, and Governance (ESG) Considerations

Formatted Title:

Sustainability and Remediation: The Hidden Cost of Going too Far

Background/Objectives:

The Unites States has always been a world leader in environmental protection, from comprehensive laws designed to preserve our natural resources and protect the health of citizens, to laws and guidance to adequately restore those resources if they become contaminated, to a high caliber environmental restoration industry always evolving toward better approaches to site investigation, risk assessment, and remediation.

But in the face of more modern problems such as climate change, energy shortages, air pollution, and related concerns, all of which remediation efforts impact, have we gone too far? Have we been too conservative in continuing to clean up sites that pose very little threat to citizens or the environment before they attenuate on their own. While regulations are developed with the intent to provide the greatest degree of safety to the public, with sometimes extreme factors of safety, the conditions under which those regulations must be met are infinitely variable, risk assessments heavily subject to assumptions and complex speculations, creating expectations for remediation strategies to achieve cleanups that are sometimes unachievable in our lifetime.

For example, a stable contaminant plume may exist in tight soil formations beneath active commercial properties where groundwater is not impacted, and human exposure is unlikely. In such a case, the negative environmental impact of a remediation system, which often uses significant amounts of electricity, propane, and diesel fuel to operate, outweigh the benefit of the relatively minor removal of contaminant from soil. In the case of petroleum, this is carbon already sequestered in the ground, which is now pulled out, burned, and carbon and a regulated amount of petroleum is released to the atmosphere. This is on top of the carbon footprint of the remediation system equipment. Alternatively, excavation and removal of impacted soil and relocation to a landfill, in addition to the carbon footprint of the heavy construction equipment involved, disposal of a valuable resource (soil) as waste, may also by being brought to the surface, create more opportunity for human exposure to chemicals of concern, all the while consuming limited landfill space already in crisis (Thomas, 2018). Thus, to clean up a speculated risk of contamination in the ground, a real and quantifiable impact to the environment is realized. A 2023 study conducted by NielsenIQ found that 78 percent of U.S. consumers say that a sustainable lifestyle is important to them. It follows then that the remediation industry and corresponding regulatory bodies operating in sustainable ways, limiting carbon footprint, conserving resources, reducing air pollution, are likewise important to citizenry.

Approach/Activities:

This presentation will summarize the environmental impact of four actual remediation programs executed within the past several years that were performed with the intent to meet regulatory requirements. The retrospective evaluation of the carbon footprint, resource consumption, and general environmental impact of those programs will be compared to the efficacy and impact of the program itself had on plume reduction. The comparison will be used to evaluate if the remediation program ultimately had greater value to the public than a strategy of cleaning up all the contamination technically possible, or even leaving the contaminated media in place, subject to natural degradation processes.

Results/Lessons Learned:

While some remediation programs provide clear and unequivocal benefit to public health and safety, there are some instances where the greatest interest of the public can be met by being less conservative in our risk assumptions and, in some cases, leaving existing contamination in place in the interest of preventing or limiting the collateral impact of cleanup or extended cleanup. Sustainability evaluations, including collateral environmental impact assessments, should be an integral part of remediation feasibility studies and strategy selection presented to regulatory agencies. Such an holistic approach is more likely to achieve the highest common goal for citizenry, the overarching goal of regulatory agencies, responsible parties, and consultants: public health and safety delivered in the most sustainable way possible.

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David Jenkins