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

jody.klassen@ec.gc.ca