sustainability in the federal contaminated sites action plan · 2013. 6. 24. · halifax, ns june...
TRANSCRIPT
Jody Klassen, Environment Canada Real Property Institute of Canada
Regional Workshop
HALIFAX, NS June 19-20, 2013
Sustainability in the Federal Contaminated Sites Action Plan
Context of Sustainability in FCSAP • FCSAP activities are to employ sustainable
principles – principles embedded in the Federal Sustainable
Development Strategy and the Federal Sustainable Development Act (2008)
– The Treasury Board of Canada Policy on Management of Real Property refers to sustainable management of real property (6.1.11)
– Phase II of FCSAP (2011-16) – developing new tools to apply accepted sustainability principles to federal contaminated sites
What have we been doing? • 2012- “Considerations for Development of the
FCSAP Sustainability Strategy and Implementation Plan” (2012, Mpunt & TLomasJylha)
1. Review of sustainability frameworks in other
organizations (SuRF US / UK and EPA) 2. Consultation with FCSAP program partners, EPA and
private industry 3. Identification of ‘Barriers and Issues’ related to
implementing sustainable practices at federal sites 4. Recommended proposed activities and identified
considerations for their implementation
Results to date • 4 Broad Elements (Federal Direction,
Decision-Making Framework, Communications and Performance Measurement) broken down into key actions and strategic initiatives
E.g., Key Action: ‘clarifying the federal direction with respect to the use of sustainable approaches at federal contaminated sites’
Strategic Initiative: ‘clarify funding eligibility for feasibility studies’
2012-13: began work on key actions and strategic initiatives
20 strategic initiatives
6 key actions
4 categories
Strategic Initiatives (2012-13) 1. ‘Value Proposition’ / Flyer 2. Examination of Federal Policies
Document with Q&As document 3. Overlay / layer for DMF that incorporates
sustainability – Outline (flowchart) for where to add
sustainability considerations to existing DMF – Table with references to BMPs at each step
4. Training plan for 2013-14 (suggested)
1. Value Proposition / Flyer – Plain Language communication piece to
highlight the positives of sustainability at FCSAP sites, including case studies.
– Multiple links to FCSAP policy docs, tools (like the PWGSC SD Tool), National Master Specification (PWGSC), EPA, ITRC, SuRF Canada, etc.
• What is sustainable contaminated sites management?
– Not limited to sustainable remediation
– Considers implementing sustainable approaches
throughout each of the steps of the FCSAP 10-step process (and therefore expands application of sustainable management to assessment, planning, remediation and long term monitoring)
Incorporating sustainable approaches makes good
business sense
1. Value Proposition / Flyer
Benefits of Sustainable Site Management Potential Outcome
Protection and restoration of ecosystems, biodiversity and habitat
Improved stakeholders relations and public involvement Use of renewable energy use Cost savings and aligned timelines Use of local services and service providers Local jobs and other employment opportunities Capacity-building and educational opportunities for FCSAP
expert support, custodians, consultants and contractors Site closure certainty within a reasonable timeframe Northern and remote sites become cost effective viable projects Public confidence by demonstrating commitment to sustainable
development / corporate responsibility
Reduce: Risks to human
health and the environment associated with contamination
Energy consumption
Emissions Material
consumption Waste
generation Water use Dust, noise and
vehicle congestion
Source; Value Proposition Document, FCSAP 2013
Some key drivers for sustainable site management
• High cost for site management • Long timelines • Severe climate / remote locations • Lack of electrical power • Equipment mobilization • Need to reduce excavation volume • Ecologically sensitive areas • Conventional approaches otherwise not
feasible…
Policy Examination Q&A Q: Do Treasury Board Policies and FCSAP Eligible Cost Guidance rules restrict us from using sustainable approaches? A: costs related to sustainable management ARE eligible for FCSAP funding (provided other eligibility requirements are met) Q: Do sustainable activities have to be recorded as a liability? A: Not necessarily; although some sustainable activities, such as recycling or long term management are not to be recorded in liability estimates, liability estimates should be based on the BEST (most appropriate and cost effective) approach
Eligible costs for sustainable activities
Risk Management Sustainable or Green Remediation Selection of sustainable approaches using
tools such as the Sustainable Decision Tool
Feasibility Studies Waste Recycling Long Term Monitoring*
Example 1: Risk Management and LTM • Biopiling and MNA is selected to address a PHC plume in
a remote area where it would otherwise cost too much to remove the waste to a landfill. When PHCs reach a site-specific target level, the site will be monitored to ensure the approach was successful (and this is noted as part of the RAP).
PROJECT ASPECT ELIGIBLE FOR FCSAP FUNDING?
Remediation / RM Approach Confirmatory Sampling Long Term Monitoring*
Example 2: Pilot study and recycling • A PERC site under an asphalt pad will be treated
using zero-valent iron and the removed asphalt will be re-purposed as a cap for another portion of the site. A pilot study is conducted to determine the appropriate concentration of ZVI in slurry to treat the plume.
PROJECT ASPECT ELIGIBLE FOR FCSAP FUNDING?
Pilot Study Remediation / RM Approach Removal of Asphalt Pad to Access Plume
Decision Making Framework • Depicts management options and decision points
throughout the 10-step process for managing federal contaminated sites
• Suggested sustainable activities and best management practices (BMPs) now mapped for each step
• Extensive list of references for BMPs at each step • Now available on the Federal Contaminated Sites
Web Portal (ww.federalcontaminatedsites.gc.ca under “Managing the Sites”
• Review findings of Initial testing from Step 3 and classification from Step 4, and develop scope of work for detailed testing
STEP 5
• Is a phase III required?
• Is the site a contaminated site?
MANAGEMENT DECISIONS
• Develop a sustainable procurement plan
• Use on-site analytical techniques
• Strategic sampling plan
SUSTAINABILITY CONSIDERATIONS
DMF & Sustainability • E.g., Assessment phase (Steps 2-5)
Planning Stage
Assessment Stage (steps 2-5) • Use on-site analytical techniques • Use passive analytical devices • Use drilling techniques that reduce waste
generation • Use telemetry or remote data collection • Develop a strategic sampling plan to avoid
over sampling the site • Develop a sustainable procurement plan and
use sustainable contracting clauses (e.g, PWGSC National Master Specification)
Remediation Planning (step 7)
• Consider sustainability when selecting remediation methods – Consider risk management – Consider in-situ techniques and those that
destroy contaminants (not contaminant transfer)
– Use a tool like the SD Tool* or detailed LCIA to evaluate amongst sustainable options
Remediation Method Suggested Sustainable Approaches / Best Management Practices
• In-situ Remediation
• 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
• Groundwater Pump and Treat
• Optimize systems to reduce number of extraction wells and reagent use
• Reuse extracted water
• Use renewable energy sources to power extraction pumps
• Soil Excavation
• Consider use of on-site treatment rather than off-site treatment of disposal of soils
• Avoid unnecessary extraction of soil by performing proper delineation of contamination
• Re-use soils and crush and recycle uncontaminated waste materials for use as fill
• 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
In-project considerations (step 8) • Sustainable material handling approaches:
– Segregate and recycle or reuse waste, demolition materials (e.g., concrete, rebar),
– Sequence work to minimize double-handling of materials,
– Reduce excavation and off-site disposal where possible,
– Make beneficial reuse of excavated soils on-site, were possible‘
– When additional material is required for fill, select local material that is comprised of post-consumer recycled materials, such as crushed concrete.
Sustainable LTM (step 9)
• Plan and implement site monitoring methods that reduce energy and waste generation, where possible, while still providing the necessary due diligence.
• E.g., plan site visits where necessary with other nearby federal sites / other departments to reduce travel
FCSAP partners are already implementing sustainable practices
at federal sites….
Fort Nelson Airport, B.C. – Transport Canada Site • Green Management Plan
– Waste minimization and recycling in field office – Fuel consumption / emission reduction through carpooling,
bicycling, no idling, clean fuel – Incorporation of green policies into contracts – Diligent and consistent metrics tracking – Engagement of contractors and consultants early to gain buy-in
New Aiyansh, British Columbia DFO, PWGSC, New Aiyansh Government Village • Sustainable Management Plan • Incorporated two sustainable remedia3on guiding principles : Remedial
op3on analysis and Remedial approach op3miza3on • Developed sustainable remedia3on tool • Evaluated poten3al remedia3on approaches using
triple bo=om line approach • Incorporated sustainability matrix into planning stages • Limita3ons of poten3al remedial op3ons • Sustainability indicators • Involved First Na3ons as the prime remedia3on contractors • Low environmental impact (reduced GHGs and waste genera3on,
conserved water) with high social benefit and high economic s3mulus to the local community
Questions? http://www.federalcontaminatedsites.gc.ca/index-eng.aspx
www.ec.gc.ca
Jody Klassen
Senior Coordinator Contaminated Sites
Prairie & Northern Region
780-951-8942