A Tiered Approach for Evaluating the Sustainability of Remediation Activities at Rail Sites

Remediation of environmental sites is of concern across the rail industry. Impacted sites may result from releases of chemicals to the environment along active rail lines or in rail yards; historical activities; or through acquisition of impacted property. Management of these liabilities may require investigation, planning, design, and remediation to reduce risks to human health and the environment and meet regulatory requirements. However, these investigation and remediation activities may generate unintended environmental, community, or economic impacts. To address these impacts, many organizations are focusing on the incorporation of sustainability concepts into the remediation paradigm. Sustainable remediation is defined as the use of sustainable practices during the investigation, construction, redevelopment, and monitoring of remediation sites, with the objective of balancing economic viability, conservation of natural resources and biodiversity, and the enhancement of the quality of life in surrounding communities (Sustainable Remediation Forum [SURF]). Benefits of considering and implementing measures to balance the three pillars of sustainability (i.e., society, economics, and environment) may include lower project implementation costs, reduced cleanup timeframes, and maximizing beneficial while alleviating detrimental impacts to surrounding communities. Sustainable remediation has evolved from discussions of environmental impacts of cleanups (with considerable greenwashing), to quantifying and minimizing the environmental footprint and subsequent long-term global impacts of a remedy, and currently, incorporating strategies to address all three components of sustainability — environmental, social, and economic. As organizations expand their use of more sustainable approaches to site cleanup, it is beneficial to establish consistent objectives and metrics that will guide implementation across a portfolio of sites. Sustainable remediation objectives should be consistent with corporate sustainability goals for environmental performance (e.g., greenhouse gas emissions, resource consumption, or waste generation), economic improvements (i.e., reduction of long term liability), and community engagement. In the last decade, there have been several Executive Orders (13423, 13514, 13693) that provide incrementally advanced protocols for achieving sustainability in government agency and corporate programs. Resources for remediation practitioners are available to assist in developing sustainable approaches, including SURF’s 2009 White Paper and subsequent issue papers, ITRC’s Green and Sustainable Remediation: State of the Science and Practice (GSR-1) and A Practical Framework (GSR-2), and ASTM’s Standard Guide for Greener Cleanups (E2893-16) and Standard Guide for Integrating Sustainable Objectives into Cleanup (E2876-13). These documents discuss frameworks that may be applied to projects of any size and during any phase of the remediation life cycle, and many provide best management practices (BMPs) that may be implemented to improve the environmental, social, or economic aspects of a project. Many of these frameworks encourage a tiered approach that matches the complexity of a sustainability assessment to the cost and scope of the remediation. For small remediation sites, a sustainability program may include the selection, implementation, or tracking of BMPs. A medium sized remediation site may warrant the quantification of environmental impacts (e.g., air emissions, waste generation, etc.) during the evaluation and selection of remedial alternatives. Often, only large and costly remediation sites demand detailed quantitative assessment of environmental impacts (e.g., life cycle assessment), economic modeling, or extensive community or stakeholder outreach. However, if a tiered approach is adopted by an organization, components of each of these assessments can be incorporated into projects where it makes sense to meet the needs of the stakeholders.