Green Remediation Strategy from EPA Aims to Limit Impact
Recognizing that site cleanup activities have their own environmental impact, the U.S. Environmental Protection Agency ("EPA") released for public comment its Superfund Green Remediation Strategy ("Strategy") on September 8, 2009. Through the action items set forth in the Strategy, which is not a regulation, EPA hopes to clarify how green remediation practices fit within the regulated cleanup process, improve an understanding of the potential resource and energy demands of remedial measures; and to establish metrics that can be used to measure and evaluate green remediation activities. EPA defines green remediation as "the practice of considering all environmental effects of remedy implementation and incorporating options to minimize the environmental footprints of cleanup actions."
Manko, Gold, Katcher & Fox, LLP, has historically counseled clients on many of the elements of green remediation now being promoted by EPA. These elements include: reduced waste generation and material consumption; improved energy efficiency and use of renewable energy; reduction of onsite and offsite emissions of greenhouse gases and air pollutants from treatment processes, operation of heavy machinery and transportation; and reduction of water usage in treatment processes through water reuse and improved efficiency.
EPA Regions 2, 9, and 10 have already implemented their own green remediation policies. Moving forward, EPA is likely to continue to look for ways to reduce the environmental impacts of cleanup activities. EPA's efforts to ensure that cleanup remedies minimize environmental impacts also provide opportunities to maximize land reuse and to reduce project costs.