This page contains PDF documents that need Acrobat Reader for viewing

P2/S-Remediation
Toolkit for Enhanced Opportunities for P2 and Sustainable Activities at Remediation Sites

Welcome to the Toolkit for Enhanced Opportunities for P2 and Sustainable Activities at Remediation Sites. Minnesota regulatory staff and stakeholders have created this Internet-based interactive toolkit to promote P2 and sustainable activities (P2/S) at remediation sites. The Toolkit is designed to streamline the process of selecting potential site-appropriate P2 and sustainable activities. For greatest success, apply the Toolkit as early as possible in the site characterization process and during cleanup as conditions at the site change. Being familiar with the possibilities, MPCA staff or regulatory program customers can make sure data is collected during the site investigation to enable incorporation of P2 and sustainable activities into site response actions, or business operations and redevelopment plans.

Toolkit includes: Option Decision Tree Terminology List of P2/S Options Disclaimers Policy Checklist Performance Tracking: Measures, Database Tracking Fields, & Responsibilities Awards and Recognition Option Detail Sheets Resource Index Index of Case Studies

The definition of P2 used for this project goes beyond source reduction, reuse, and recycling to include any activity that results in sustainable or enhanced environmental outcomes. MPCA staff and stakeholders identified 18 options related to cleanup site activity according to three specific remediation scenarios. The three scenarios distinguish sites with redevelopment or renovation plans, ongoing or new business operations or remediation plans only. Some sites may involve more than one of these scenarios.

The MPCA hopes to impact four main areas with the Toolkit for Enhanced Opportunities for Pollution Prevention and Sustainable Activities at Remediation Sites:

• Voluntary enhanced environmental outcomes;
• Regional economic and environmental strategies, such as smart growth and community master planning;
• Complementary regulatory tools, and
• Environmental performance tracking.

Components of the Toolkit include:

• A Decision Tree to guide you to potential options suitable to the specific site;
• Definitions of P2 and sustainable activities;
• An explanation of three remediation scenarios to which P2/sustainability activities can be linked;
• Disclaimers and a checklist of factors to consider before pursuing these opportunities; and
• Points of implementation, including performance measures, tracking progress and recognition.

MPCA cleanup programs included in this initiative are the Voluntary Investigation and Cleanup (VIC) Program, the Superfund Program and the Resource Conservation and Recovery Act (RCRA) Corrective Action Program. Although this initiative was not developed with petroleum tank release sites or closed landfill sites in mind, some of the guidelines are applicable. A majority of the options also apply to uncontaminated sites.

The Steps to Selecting, Developing and Implementing P2 or Sustainable Options for Your Site

Step 1: Select the Most Promising Option(s) for Your Site. Step 2: Things to Keep in Mind before Pursuing an Option. Step 3: Implement the Options, Track the Progress and Document and Promote Lessons Learned and Success Stories. Step 4: Awards and Recognition for Implementation Efforts. For assistance with using the Toolkit, contact: Cindy Hilmoe, 651-296-7783, cynthia.hilmoe@pca.state.mn.us

The Toolkit for Enhanced Opportunity for Pollution Prevention and Sustainable Activity at Remediation Sites (Toolkit) targets eighteen options that relate to activity at cleanup sites according to three remediation scenarios. The remediation scenarios are:

• A site that involves a redevelopment or renovation plan;
• A site that includes an ongoing or new business operation; and
• A site that involves nothing other than cleanup of contaminated media.

MPCA staff and stakeholders chose the options based on feasibility and the potential for enhanced environmental outcomes at remediation sites. The list is not exhaustive, and, in fact, a site may correspond with more than one scenario.

A link is provided below to an Option Decision Tree that is designed to let you create a short list of options for your specific site and to access additional information to help determine which options to pursue. The additional information is contained in 18 Option Detail Sheets that are accessed by links within the Decision Tree.

The Option Detail Sheets, in turn, provide links to annotated indexes of resources and case studies that can help you decide if a particular option is suitable to your site:

• The annotated Resource Index describes resources available to help design and implement P2 and sustainable projects at remediation sites.
• An Index of Case Studies provides project examples that may help voluntary or responsible parties or owners decide if a similar project may work at their specific site. Contact information contained in the case studies may serve as additional resources.

By responding to the series of if/then statements in the Decision Tree, you will create a short-list of options to consider for a specific site. Because the options are grouped according to remediation scenario, the Decision Tree allows you to skip entire sets of questions that don't relate to the site. Information in the linked Option Detail Sheets can then be used to cull the short-list of options by answering questions like:

• Does the aim of the option fit the conditions and plans for the site?
• Do site-specific circumstances favor implementation of this option?
• Do case studies indicate a good fit between the option and site plans or suggest resources useful to the development or implementation of the P2 or sustainable activity at the site?
• Do the referenced regulatory, business and technical resources complement the ability of the voluntary/responsible party or owner to develop or implement a project?
• In what ways could the remediation staff or other regulatory staff assist?

Go to the Option Decision Tree

MPCA Staff Assistance

• Need help using the Decision Tree and Option Detail sheet?
• Need help identifying the most useful resource referrals and case studies?
• Uncertain about how regulatory staff or other resources can help you develop your idea?
• Contact: Cindy Hilmoe, 651-296-7783, cynthia.hilmoe@pca.state.mn.us

Before pursuing opportunities for pollution prevention or sustainable activities (P2/S) at a remediation site, refer to the following information and policy.

Terminology: How are "pollution prevention" and "sustainable activities" defined?

List of Remediation Scenarios and Targeted Options: Targeted options are grouped and related to cleanup site activity according to three remediation scenarios. This document provides explanations of the scenarios. P2/S can be important during response actions, to prevent future releases from on-site business operations, and in redevelopment plans.

Disclaimers: Qualifications of the Toolkit are summarized.

Policy Checklist: Implementation of P2/S projects is subject to the listed considerations.

Step 3: Implement the Options, Track the Progress and Document and Promote Lessons Learned and Success Stories

Voluntary Implementation:
Options that suit the site conditions can be implemented when the regulatory program user volunteers. MPCA regulatory staff may assist an interested program user to evaluate the options for the site. The MPCA staff will consider including the voluntary action in an MPCA record of decision, corrective measure study approval, response action plan approval or assurance letter only if the program user gives consent. Inclusion in these decision documents may result in greater success at tracking the progress of implementation of the P2 or sustainable activity (P2/S). However, voluntary implementation of P2/S at remediation sites can be abandoned at any time at the discretion of the program user as long as the MPCA staff has approved any necessary alternate actions. These conditions will be made clear in the language of the MPCA decision documents. Mandatory implementation of P2 or sustainable activities at a remediation site would occur only as part of a negotiated enforcement action (for example, a Supplemental Environmental Project) or as an option for preventing a threatened release. Mandatory activities may require collaboration between MPCA remediation and enforcement staff.

Tracking Progress using the MPCA Remediation Program Database:
The MPCA is obligated to measure performance of this initiative, which is aimed at enhancing opportunities for P2 and sustainable activities (P2/S) at remediation sites. During implementation of the P2 or sustainable activity, MPCA staff is encouraged to work with program users to gather information for inclusion in the MPCA Remediation Program Database. MPCA staff will enter the P2/S activity in the Events Log of the Database. This information will be of interest to MPCA managers, the Minnesota legislature, other states and the EPA; and may be used to develop case studies to promote P2/S projects at other sites.

An expanded tracking system that has been proposed for MPCA managers' approval:
Performance Tracking: Measures, Database Tracking Fields and Responsibilities (Draft)

Document and Promote Lessons Learned and Success Stories
The MPCA site team, voluntary or responsible parties and owners may submit names of projects implemented, projects successfully completed or projects offering important "lessons learned" to MPCA pollution prevention and sustainability (P2/S) staff in the Policy and Planning (P&P) Division for development of case studies or progress reports. P2/S staff may periodically search the Remediation Program Database for sites with P2/S activity for information suitable for publishing in MPCA material and reports, regional profile indexes, trade organization publications, neighborhood newspapers and other public information. MPCA staff involved in preparation of legislative and other agency wide progress reports may also review and publish P2 and sustainable activities.

MPCA Staff Assistance

• Uncertain about how regulatory staff or other resources can help implement your idea?
• Uncertain about how to track results?
• Uncertain about the implications of including implementation as part of an approved action?
• Contact: Cindy Hilmoe, 651-296-7783, cynthia.hilmoe@pca.state.mn.us

The MPCA site team, voluntary or responsible parties may nominate projects for awards or seek recognition by providing information to be developed into case studies for various publications as described in Step 3. If appropriate, P&P or remediation staff may be able to assist with applications for awards and recognition.

Awards and Recognition: A list of Web links to opportunities for awards and recognition.

Toolkit
Minnesota Pollution Control Agency
Enhancing Opportunities for P2 and Sustainable Activities at Remediation Sites