vxEPA
United States
Environmental Protection
Agency
Solid Waste and
Emergency Response
(5102G)
EPA 542-B-00-003
March 2000
www.epa.gov/tio
clu-in.org
An Analysis of Barriers to Innovative Treatment
Technologies: Summary of Existing Studies and
Current Initiatives
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NOTICE
This document was prepared for the U.S. Environmental Protection Agency's (EPA) Technology
Innovation Office (TIO) by Tetra Tech EM Inc. under EPA Contract Number 68-W-99-003. Mention of
trade names or commercial products does not constitute endorsement or recommendation for use.
The document may be obtained from EPA's web site at or at
. A limited number of hard copies of this document are available free of charge by
mail from EPA's National Service Center for Environmental Publications (NSCEP), at
, or at the following address (please allow 4-6 weeks for mail delivery):
EPA/National Service Center for Environmental Publications
P.O. Box 42419
Cincinnati, OH 45242
Telephone: (513) 489-8190 or (800) 490-9198
Fax: (513)489-8695
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CONTENTS
Section Page
EXECUTIVE SUMMARY ES-1
1.0 INTRODUCTION 1
2.0 IDENTIFICATION AND ANALYSIS OF BARRIERS 4
2.1 ANALYSIS OF BARRIERS BY CATEGORY 4
2.2 ANALYSIS OF BARRIERS BY AUTHOR 9
2.3 TREND ANALYSIS OF BARRIERS OVER TIME 13
2.4 ANALYSIS OF BARRIERS BY STAGE OF ITT DEVELOPMENT 20
2.5 AUTHORS' AGREEMENT ON SPECIFIC BARRIERS BY CATEGORY 22
2.5.1 Institutional Barriers 22
2.5.2 Regulatory and Legislative Barriers 22
2.5.3 Technical Barriers 23
2.5.4 Economic and Financial Barriers 23
3.0 INITIATIVES CITED IN SOURCE DOCUMENT'S TO MITIGATE BARRIERS 24
3.1 INITIATIVES TO MITIGATE INSTITUTIONAL BARRIERS 24
3.2 INITIATIVES TO MITIGATE REGULATORY AND LEGISLATIVE BARRIERS . 25
3.3 INITIATIVES TO MITIGATE TECHNICAL BARRIERS 26
3.4 INITIATIVES TO MITIGATE ECONOMIC AND FINANCIAL BARRIERS 27
4.0 INITIATIVES CITED IN EPA DEVELOPER'S GUIDE TO MITIGATE BARRIERS 29
Appendices
A SUMMARY OF TEN DOCUMENTS USED FOR THIS STUDY A-l
B LIST OF OTHER DOCUMENTS REVIEWED FOR THIS STUDY B-l
C LIMITATIONS OF THE STUDY AND ANALYSIS C-l
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TABLES
Table Page
1-1 DOCUMENTS USED FOR THE STUDY 2
2-1 BARRIERS TO ITTs BY CATEGORY 4
2-2 CATEGORIES OF BARRIERS IDENTIFIED 7
2-3 AUTHOR GROUPS 9
2-4 STAGES OF ITT DEVELOPMENT 20
4-1 INITIATIVES FROM EPA'S DEVELOPER'S GUIDE CROSS ARRAYED WITH
BARRIER CATEGORIES 30
4-2 BARRIERS TO ITTs CROSS-REFERENCED BY INITIATIVES 44
FIGURES
Figure Page
2-1 COMPARISON OF SIMPLE AND WEIGHTED PERCENTAGE OF BARRIERS BY
CATEGORY 9
2-2 PERCENTAGE OF ALL 42 BARRIERS IDENTIFIED BY AUTHOR GROUP 10
2-3 PERCENTAGE OF BARRIERS IN EACH CATEGORY IDENTIFIED BY
VARIOUS TYPES OF AUTHOR GROUP 11
2-4 CATEGORY OF BARRIER AS A PERCENTAGE OF THE TOTAL NUMBER
OF BARRIERS IDENTIFIED BY AUTHOR GROUP 12
2-5 AVERAGE NUMBER OF BARRIERS IDENTIFIED BY CATEGORY PER REPORT
FROM 1985 - 1998 15
in
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FOREWORD
Over the last 15 years several studies have been performed to identify barriers to innovative treatment
technologies (ITT). The purpose of this study is to examine the reports of those studies to identify
categories of barriers, to identify barriers that are identified consistently over time and by different
authors, and to determine whether there are trends in the number or types of barriers cited over time. The
study also examines those barriers that may have been addressed by the various federal, state, nonprofit,
and private-sector initiatives being implemented to address such barriers. This type of analysis assists in
understanding how barriers affect the development and use of ITTs and can help focus the efforts of
stakeholders on coordinated initiatives to remove or reduce barriers.
IV
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EXECUTIVE SUMMARY
From 1985 through 1998, a number of studies and reports were prepared about barriers to the
development and use of innovative treatment technologies (ITT) to remediate hazardous waste sites. The
U.S. Environmental Protection Agency's (EPA) Technology Innovation Office (TIO) commissioned a
study to analyze the barriers presented in those reports and to develop findings about the barriers related
to ITTs. For the analysis, 10 source documents were selected from more than 30 documents. The 10
documents contained information specifically dealing with barriers to ITTs. The remaining documents
contained only general information or very little information directly related to development and use of
ITTs. The 10 source document evaluated for the analysis identified 42 barriers.
The 42 barriers identified in the source documents were grouped into the following four general
categories:
Institutional (16 barriers)
Regulatory and legislative (7 barriers)
Technical (6 barriers)
Economic and financial (13 barriers)
Three distinct author groups were identified: (1) technology advocates, (2) technology users and
developers, and (3) government and nongovernment third-party evaluators.
The types of analyses performed on the barriers included: (1) identification of key barriers, defined as
those barriers identified consistently by the individual authors; (2) evaluation of the barriers by author
group to determine whether an individual author group emphasized a particular category of barrier over
others; (3) evaluation of trends overtime, including examination of any changes in the types and number
of barriers faced by ITTs over three time periods: 1985 through 1990 (early); 1993 through 1995
(middle); and 1997 through 1998 (recent); and (4) identification of the barriers affecting the stages of the
technology development process from bench-scale through full-scale application.
Key findings from these analyses indicate:
There was consistent agreement in identifying two barriers among all authors. Those barriers are:
"Permitting processes for ITTs are inconsistent, involve numerous levels, and are time- and resource-
intensive," and "Government and private-sector funding for the development and demonstration of ITTs
is insufficient" Two additional barriers, "Economic incentives are lacking for those who might wish to
develop or use ITTs," and "Cost and performance data for specific ITTs are limited," were consistently
mentioned by four of five authors.
Almost 75 percent of the barriers have been cited consistently over time. Over half of the barriers
have been consistently cited in all three time frames. Seventy-three percent of barriers were identified
in at least two time periods (early, 1985 to 1990; middle, 1993 to 1995; and recent, 1997 to 1998), each
barrier being identified in the most recent time period. Approximately 57 percent of the total number of
barriers have been identified in at least one report in all three time periods.
ES-1
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There is no evidence that the total number of barriers to ITTs is changing over time. However,
there is a shift in the types of barriers that ITT providers face today. Although there is no
significant change in the total number of barriers cited overtime, the average number of institutional
barriers identified by the source documents over each time period has decreased, while the average
number of economic and financial barriers identified has increased overtime.
Only seven percent of the barriers (three barriers) all economic and financial were identified
in the past three years alone and are potentially considered new. The barriers are financial incentives
to delay remediation, the reluctance of firms to develop ITTs because of limited applicability, and the
effects on employment security when using an ITT.
Nineteen percent of the barriers identified (eight barriers) have not been cited in the two
documents published since 1995. Seven of those barriers (17 percent overall) may have been
addressed or are no longer perceived as relevant by the author groups. Of the eight barriers that
have not been cited since 1995, four are institutional, three are economic and financial, and one is
technical. Seven of those barriers may have been addressed or no longer are perceived as relevant by
virtue of the fact that they were cited at one time by one author but were not cited again in subsequent
reports published by that same author.
All three author groups identified a majority of the technical barriers, indicating that there is
agreement among the author groups about technical barriers to development and use of ITTs.
Both the technology advocate and technology user and developer author groups identified 100 percent of
the technical barriers, and the third-party evaluators author group identified 83 percent of the technical
barriers. In the other three categories, there was more variation among the three author groups in the
barriers identified.
Most barriers affect technologies at the full-scale stage of development. Of the 23 barriers analyzed,
19 (or 83 percent) affect the full-scale stage of development. Only nine barriers (or 39 percent) affect the
bench- and pilot-scale stages. That trend is common to barriers in all categories.
Barriers most often affecting technologies in the bench- and pilot-scale stages of development were
primarily institutional and economic and financial. Specifically, institutional barriers that are related
to the coordination of research and development efforts affect the bench- and pilot-scale technologies.
Economic and financial barriers, such as insufficient incentives for developers and lack of funding from
government and private-sector venture capitalists, also affect most technologies in the bench- and pilot-
scale stages.
ES-2
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1.0 INTRODUCTION
The Technology Innovation Office (TIO) of the U.S. Environmental Protection Agency (EPA) was
established in 1990 to promote the use of innovative technologies for the assessment and cleanup of
contaminated sites. As part of its mission, TIO seeks to identify and address barriers that may inhibit the
development and use of innovative treatment technologies (ITT). ITTs are newly developed technologies
that lack sufficient full-scale application data to ensure their routine consideration for site remediation.
To further its ITT efforts, TIO sponsored this study to examine barriers to the development and use of
ITTs through a review of existing documents. The objective of this analysis was to determine whether
there were notable trends and to identify any initiatives undertaken to overcome the barriers from both
the source documents and other resources.
In total, 10 documents were selected from among 33 original studies performed and reports prepared
between 1985 and 1998 about the institutional, regulatory and legislative, technical, and economic and
financial barriers to the development and commercialization of ITTs. Table 1-1 identifies the 10
documents used for this analysis. Only barriers identified in the source documents are included in this
study.
Barriers identified and discussed in the source documents were grouped by the following:
Barriers identified over three periods: 1985 through 1990 (early); 1993 through 1995
(middle); 1997 through 1998 (recent) to identify trends
Barriers identified by authors (or report sponsors) grouped as technology advocates (the
EPA and the National Environmental Technology Applications Center [NETAC]);
technology developers and users (the U.S. Department of Energy [DOE] and the
Hazardous Waste Action Coalition [HWAC]); and government and nongovernment
third-party evaluators (the U.S. Office of Technology Assessment [OTA], the U.S.
General Accounting Office [GAO], and the National Research Council [NRC])
Barriers that affect various stages of technology development, including: bench- and
pilot-scale testing and demonstration, full-scale testing and demonstration, and full-scale
implementation
The barriers were examined further to conduct a more detailed trend analysis. The trend analysis shows
how the barriers are distributed over time and by author to determine which barriers are persistent,
addressed, or newly identified. Also, barriers that were mentioned consistently by different authors over
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the study period were identified. Consistent mention of particular barriers also provides an indication of
their persistence and the importance of those barriers as hindrances to the development and use of ITTs.
TABLE 1-1. DOCUMENTS USED FOR THE STUDY
No.
1
2
3
4
5
6
7
8
9
10
Title
Superfund Strategy
Coming Clean - Superfund Problems Can
Be Solved
Workshop on Developing an Action
Agenda for the Use of Innovative
Remediation Technologies by Consulting
Engineers
Superfund: EPA Needs to Better Focus
Cleanup Technology Development
NET AC, the EPA Model for Encouraging
Private Investment in the DOE
Environmental Market
Management Changes Needed to Expand
Use of Innovative Cleanup Technologies
(concerning DOE)
Progress in Reducing Impediments to the
Use of Innovative Remediation
Technology
Forum on Eliminating Barriers to
Innovative Technology Implementation
Innovations in Groundwater and Soil
Cleanup: From Concept to
Commercialization
Impediments to Deploying Technologies at
DOE Sites and Their Solutions
Primary Author/
Sponsoring Entity
OTA
OTA
EPA (OSWER/TIO)
GAO
EPA ORD/ University of
Pittsburgh Applied
Research Center
GAO
EPA (OSWER/TIO)
DOE and HWAC
NRC
DOE (Office of
Environmental
Restoration)
Types of
Sites
Discussed
Public and
private sites
Public and
private sites
Public and
private sites
Public and
private sites
DOE sites
DOE sites
Public and
private sites
DOE sites
Public and
private sites
DOE sites
Date
Published
April 1985
October
1989
October
1990
April 1993
September
1993
August
1994
June 1995
June 1995
1997
1998
Key:
DOE
EPA
GAO
HWAC
NETAC
U.S. Department of Energy
U.S. Environmental Protection Agency
U.S. General Accounting Office
Hazardous Waste Action Coalition
National Environmental Technology
Technology Applications Center
NRC National Research Council
OS WER Office of Solid Waste and Emergency Response
ORD Office of Research and Development
OTA U.S. Office of Technology Assessment
TIO Technology Innovation Office
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Information about initiatives or programs that reduce or remove barriers is also presented. The initiatives
were identified from the 10 source documents used for the analysis and are not considered to be
comprehensive. In addition, a summary of the recently completed document, Innovative Treatment
Technology Developer's Guide to Support Services (Fourth Edition), is included to show the broad array
of resources that have been developed to overcome barriers to ITTs.
Section 2.0 of this study identifies the barriers and presents the analysis. Section 3.0 presents initiatives
and programs to reduce or remove barriers.
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2.0 IDENTIFICATION AND ANALYSIS OF BARRIERS
Analysis of barriers assists in understanding how barriers affect development and use of ITTs and can
help focus the efforts of stakeholders to coordinate initiatives to remove or reduce barriers. The
following sections present the analyses of barriers by category, author, overtime, and technology scale.
The sections also discuss findings regarding trends.
2.1 ANALYSIS OF BARRIERS BY CATEGORY
A total of 42 barriers were identified in the 10 reports listed in Table 1-1 and were grouped into four
categories for this study institutional, regulatory and legislative, technical, and economic and
financial. Table 2-1 lists the individual barriers within each category. The categories exemplify the
range of hurdles ITT developers must overcome and the breadth of expertise they must be able to tap into
to successfully commercialize a technology.
TABLE 2-1. BARRIERS TO ITTs BY CATEGORY
INSTITUTIONAL BARRIERS
1-1
Actions undertaken by federal and state agencies to promote and regulate the development and use of ITTs
are not well coordinated.
1-2
Rigid management hierarchies and government bureaucracy tend to perpetuate the use of 'status quo'
technologies.
1-3
Schedules imposed by regulatory agencies often do not allow sufficient time to investigate the feasibility of
using ITTs.
1-4
Regulators often adopt rigid approaches to applications of ITTs.
1-5
Level of communication that takes place among the various developers of environmental technologies is not
adequate to promote the development of ITTs.
1-6
In general, a lack of communication exists between the developers of ITTs and the potential users of those
ITTs.
1-7
EPA has not assessed Superfund site cleanup needs systematically and has had difficulty in matching ITTs
with the requirements of specific sites.
1-8
Parties involved with cleanups have conflicting priorities.
1-9
Regulators may lack knowledge about ITTs.
1-10
Technology experts are not included in the formal decision-making process during which technologies are
selected.
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TABLE 2-1. BARRIERS TO ITTs BY CATEGORY (continued)
INSTITUTIONAL BARRIERS (continued)
1-11
Government agencies rely too heavily on the support of contractors, some of whom have financial interests
in conventional technologies, to assist in selecting cleanup remedies.
1-12
Appropriations and procurement processes create uncertainty about the levels and timing of funding that will
be available to manage environmental problems at individual DOE sites.
1-13
Enforcement of regulations that govern cleanup activities is inconsistent and too strict.
1-14
Cycles of government appropriations are not coordinated with the cycles of research and development for
ITTs, causing gaps in funding.
1-15
Regulators are reluctant to appear lenient in dealing with responsible parties.
1-16
Communities often are not supportive of the use of ITTs because they are unwilling to assume risks
associated with the testing and use of ITTs in their neighborhoods.
REGULATORY AND PERMITTING BARRIERS
R-l
Permitting processes for ITTs are inconsistent, involve numerous levels, and are time- and resource-
intensive.
R-2
Permitting and manifesting requirements under the Resource Conservation and Recovery Act (RCRA) often
inhibit the development of ITTs.
R-3
Users of environmental technologies are concerned about liabilities they might incur through the use of
ITTs.
R-4
Entities that develop and use ITTs are concerned about liabilities they might incur through the licensing and
transfer of ITTs.
R-5
Regulatory structures do not consider market forces and therefore do not provide incentives for cleanup
contractors and site managers to use ITTs.
R-6
Tendency of regulations to evolve over time discourages the development and use of certain ITTs.
R-7
Obtaining authentic waste materials or site access needed to test ITTs can be difficult and costly and can
expose the developer of the technology to uncertain liabilities.
TECHNICAL BARRIERS
T-l
Cost and performance data for specific ITTs are limited.
T-2
Performance criteria and cleanup standards often are ill-defined and inconsistent.
T-3
No coordinated program for formally verifying the performance of ITTs.
T-4
Often difficult to apply ITTs at numerous sites because the characteristics of the sites differ.
T-5
Difficult to extrapolate information gained from testing an ITT at one site to other sites.
T-6
ITTs often are not considered until after the data collection phase of the remedial investigation, thereby
leaving critical gaps in data required to evaluate the effectiveness of potentially applicable ITTs.
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TABLE 2-1. BARRIERS TO ITTs BY CATEGORY (continued)
ECONOMIC AND FINANCIAL BARRIERS
E-l
Economic incentives are lacking for those who might wish to develop or use ITTs.
E-2
Government and private-sector funding for the development and demonstration of ITTs is insufficient.
E-3
Information available to characterize potential markets for ITTs is limited.
E-4
Venture capitalists perceive the environmental management market as a high financial risk.
E-5
Technology selection decision-makers are concerned with protection of their agencies' budgets, so there is a
reluctance to use technologies developed by other agencies.
E-6
Only a small portion of the entire life cycle of a project may be taken into consideration when the costs of
remediation alternatives are compared.
E-7
Numerous financial incentives to delay remediation and few incentives to carry out remediation in a timely
manner.
E-8
Market for environmental remediation technologies is fragmented.
E-9
Use of fixed-price contracts to procure remediation services discourages the use of ITTs.
E-10
Under the Federal Acquisition Regulation (FAR), contractors that test ITTs during cleanup design would be
precluded from bidding on construction work at the site.
E-ll
Lack of adequate mix of entrepreneurial, technical, and business management skills in small environmental
technology companies to facilitate development of a market-driven technology.
E-12
Firms are reluctant to develop ITTs with limited applications.
E-13
Concern that use of an ITT may have adverse effects on employment in the agency that uses that technology.
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Table 2-2 defines each category and shows the number and percentage of barriers identified in each
category.
TABLE 2-2. CATEGORIES OF BARRIERS IDENTIFIED
Barrier
Category
Institutional
Regulatory
and
Legislative
Technical
Economic and
Financial
Definition
Barriers that stem from the internal workings or
functions of entities that seek to regulate, develop, or
select ITTs for use in cleaning up hazardous waste
sites or from the interaction of such entities
Barriers that are imposed by legislatures and
government agencies through specific statutes,
regulations, policies, and programs
Barriers associated with the ITTs themselves,
including lack of information about cost and
performance
Barriers that tend to reduce or eliminate financial
incentives to entities that develop, use, or market ITTs
TOTAL
Number of
Barriers
16
7
6
13
42
Percentage of
Total
38%
17%
14%
31%
100%
Finding No. 1:
Institutional and economic and financial barriers represented almost 70
percent of the barriers cited. Technical barriers were the least often cited
category of barriers at 14 percent.
Table 2-2 shows, institutional and economic and financial categories account for 38 and 31 percent of the
distribution, respectively. The two barrier categories represent almost 70 percent of all the barriers
identified. This finding indicates that institutional and economic and financial barriers were cited
approximately twice as often as either technical or regulatory and legislative barriers. Conversely,
technical barriers represented only 14 percent of all barriers cited. Therefore, ITTs appear to face a
greater number and variety of institutional and economic and financial barriers than either technical or
regulatory and legislative barriers. However, no one category of barriers dominated or represented more
than 50 percent of all the barriers cited.
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Although technical barriers were cited least frequently (14 percent), there may be more consensus among
the individual authors about the specific barriers within that category versus specific barriers in other
categories, such as institutional barriers. For example, 50 percent of the technical barriers (three of six)
identified were cited in six or more documents (at least 60 percent of the documents). In contrast, only
two institutional barriers of a total of 16 (less than 13 percent) were cited in six or more documents.
Because some barriers were cited more frequently than others, a weighted percentage for each barrier
category was calculated. The weighted percentage for each barrier category can be viewed as a measure
of the relative level of agreement regarding barriers within that category, compared with other categories.
The weighted percentage was based on the number of times a specific barrier was cited. For example,
the methodology assigns a higher weight to a barrier that was cited in 8 of 10 source documents versus a
barrier that was cited in 3 of the 10 source documents.1 Figure 2-1 compares the simple percentage with
the weighted percentage. As Figure 2-1 shows, the weighted percentages for institutional and economic
and financial barrier categories decreased slightly, while the percentages for technical and regulatory and
legislative barrier categories increased. Although institutional and economic and financial barrier
categories still represent the majority of barriers identified (approximately 60 percent), the technical and
regulatory and legislative barrier categories now represent 40 percent of the barriers identified.
This weighted frequency analysis provides an indication of those barriers for which there is greater
consensus. For example, if a majority of reports mention the same technical barriers, while at the same
time presenting a variety of institutional barriers (some of which are identified in only one or two
reports), that may indicate that the technical barriers are better understood or merit more attention than
some of the institutional barriers that are identified less often. Finding No. 3 in Section 2.2 of this study
presents a more thorough examination of this point.
1 Weighted percentages for each category were calculated as follows: if two reports listed
the same barrier, it was counted twice or as two "hits." The number of hits for each of
the 42 barriers was counted and divided by the total number of hits (164) to derive a
weighted percentage. The barriers then were grouped into the four categories, and the
percentages were recalculated by category.
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FIGURE 2-1. COMPARISON OF SIMPLE AND WEIGHTED
PERCENTAGE OF BARRIERS BY CATEGORY
Percentage
40% T~
35%
30%
25%
20%
Simple Percentage
^Weighted Percentage
15%
10%
0%
Institutional Economic & Financial Regulatory & Legislative
Barrier Category
Technical
2.2 ANALYSIS OF BARRIERS BY AUTHOR
The 10 source documents reviewed for this study were written by five authors: (1) OTA, (2) GAO, (3)
EPA or EPA jointly with another entity, (4) DOE or DOE jointly with another entity, and (5) NRC.
Barriers were analyzed by author to determine whether various authors recognize similar barriers or
whether some barriers reflect the perspectives of specific groups. As Table 2-3 shows, the authors were
grouped to represent the following three perspectives on technology development and use.
TABLE 2-3. AUTHOR GROUPS
Author
EPA/NETAC
EPA, DOE/ HWAC
OTA, GAO, NRC
Group
Technology advocates
Technology users and developers
Government and nongovernment third-party evaluators
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Finding No. 2
Each author group has a comprehensive view of barriers, identifying at
least two-thirds or more of the barriers. However, the specific barriers
cited within each category differ from author group to author group.
Of the 42 barriers, the technology advocate author group identified 67 percent (28 barriers), the
technology user and developers identified 79 percent (33 barriers), and the third-party evaluators
identified 76 percent (32 barriers). Figure 2-2 shows the percentage of barriers identified by each author
group. No author group identified 100 percent of the 42 barriers. However, different authors identified
different barriers within each category. For example, the technology advocate group identified 9 of the
16 institutional barriers identified by all authors. The third-party author group identified 12 of the 16
institutional barriers. The two groups agreed only on six barriers.
FIGURE 2-2. PERCENTAGE OF ALL 42 BARRIERS IDENTIFIED BY
AUTHOR GROUP
100%
75%
Percentage
of the
42 Barriers
Identified
50%
25%
76%
Technology Advocates
Technology Users and
Developers
Author Group
Third-Party Evaluators
10
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Finding No. 3
All three author groups identified a majority of the technical barriers,
indicating that there is agreement among the author groups about the
technical barriers to development and use of ITTs.
Figure 2-3 shows the percentage of barriers identified in each barrier category by author group. Within
each barrier category, all three author groups identified 50 percent or more of the barriers. Within the
technical barrier category, the technology advocate and technology user and developer author groups
identified 100 percent of the technical barriers, and the third-party author group identified 83 percent of
the technical barriers, indicating general agreement among the three author groups regarding specific
technical barriers. There was greater variation among author groups in the other three categories of
barriers. For example, within the regulatory and legislative barrier category, the technology advocate and
third-party author groups identified approximately 86 percent of the barriers, while the technology user
and developer author group identified 57 percent. Result indicates that there is a higher degree of
consensus among the various authors groups about the technical barriers and relatively less agreement
about the institutional barriers.
FIGURE 2-3. PERCENTAGE OF BARRIERS IN EACH CATEGORY
IDENTIFIED BY VARIOUS TYPES OF AUTHOR GROUP
100% 100%
Percentage of
Barriers
in Each
Category
100% -i
90%
80%
70%
60%
D Technology Advocates
Technology Users and
Developers
D Third-Partv Evaluators
50%
10%
0%
Institutional Regulatory & Legislative Technical
Barrier Category
Economic & Financial
Note: The numbers above represent the percentages of the total number of barriers listed in all reports (42) that were identified by each
author group in each barrier category. For example, of the 16 institutional barriers identified in all reports, technology advocates
identified nine, or 56 percent.
11
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Finding No. 4 The most common category of barrier identified by each author group was
institutional barriers, followed by economic and financial barriers.
However, the authors do not concur regarding specific barriers in the
barrier categories.
Figure 2-4 shows the percentage of barriers by category identified by author group. Although there were
some differences among the three author groups about specific institutional barriers (as illustrated in
Figure 2-3), institutional barriers were the most commonly identified barrier category. The prevalence of
institutional barriers indicates the relative importance of institutional barriers among the author groups.
However, the individual institutional barriers identified by each author group varied. This finding
indicates a lack of agreement among author groups about specific institutional barriers and illustrates
how the perspectives of the various stakeholders differ. The differences in perspectives among
stakeholders in turn may lead to problems in addressing institutional barriers.
FIGURE 2-4. CATEGORY OF BARRIER AS A PERCENTAGE OF THE
TOTAL NUMBER OF BARRIERS IDENTIFIED BY AUTHOR GROUP
Percentage
of the
Total Number
of Barriers
Institutional
Regulatory & Legislative
U Technical
Q Economic & Financial
Technology Advocates
Technology Users and
Developers
Author Group
Third-Party Evaluators
Note: The numbers above represent the percentages of the total number of barriers identified by specific author type in each category. For
example, technology advocates identified a total of 28 barriers, nine of which were institutional. Therefore, 32 percent of the barriers
identified by technology advocates were institutional. The percentages may not add to 100 percent as a result of rounding.
12
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Finding No. 5 Only two barriers appeared in reports by all authors.
Of the 42 barriers, only two were discussed by all authors. Those barriers were the regulatory and
legislative barrier, "Permitting processes for ITTs are inconsistent, involve numerous levels, and are
time- and resource-intensive" and the economic and financial barrier, "Government and private-sector
funding for the development and demonstration of ITTs is insufficient." The economic and financial
barrier, "Economic incentives are lacking for those who might wish to develop or use ITTs" and the
technical barrier, "Cost and performance data for specific ITTs are limited" were cited by four of five
authors.
2.3 TREND ANALYSIS OF BARRIERS OVER TIME
The 10 reports reviewed for this study were published in 1985, 1989, 1990, 1993, 1994, 1995, 1997, and
1998. To review trends overtime, the reports were grouped by publication date into three time periods:
1985 through 1990 (early), 1993 through 1995 (middle), and 1997 through 1998 (recent).
The analysis of barriers over time assumes that discussion of a barrier in a report indicates that the barrier
existed at the time the report was published. For example, barriers discussed in the DOE report
published in 1995 are assumed to have been relevant in the middle time period (1994 through 1995).
Since none of the studies had purposely set out to identify barriers that had been eliminated or addressed,
the analysis relies on the publication time periods (early, middle, recent) in which a barrier was cited to
determine whether a barrier has persisted over time and whether it still is considered a barrier. A review
of trends over time provides insight into how barriers may have evolved and determines whether (1)
certain barriers have been mitigated to the extent that they no longer impede the development and use of
ITTs, (2) certain barriers persist over time and require continued mitigation efforts, or (3) new barriers
have been identified. The review of trends over time also may indicate the authors' perspectives of the
importance of the barrier at a given time.
13
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Finding No. 6 There is no evidence that the total number of barriers to ITTs is changing
over time. However, there is a shift in the types of barriers that ITTs face
today.
In the early years from 1985 through 1990, the number of barriers cited in two OTA reports and one EPA
report were 14, 18, and 19, respectively. More recently, in 1997 and 1998, the number of barriers cited
by NRC and DOE were 17 and 27, respectively. Although the most recent DOE report cited 27 barriers,
a number significantly higher than that in any report published during the early years, three of those
barriers cited by DOE appear to be specific to DOE only. Further, since the recent NRC report cited
fewer barriers (17) than the 1990 report (19), it does not appear that the total number of barriers is
decreasing or increasing. A closer examination by barrier category over time reveals some interesting
results.
Because more reports were published during the middle time frame than during the early or recent time
frames (five compared with three and two) a count of the total number of barriers identified in each
category for each time frame would give unequal weight to the middle time frame. Therefore, the
numbers of barriers in each category were averaged on a per report basis within each time frame. Figure
2-5 shows the results.
As shown in Figure 2-5, there has been a shift in the type of barriers identified from the early to the
recent time periods. The average number of institutional barriers identified from the early time frame to
the recent time frame has decreased steadily. However, the average number of economic and financial
barriers cited over the same time frame has increased. In addition, the average number of regulatory and
legislative barriers has decreased slightly, and the average number of technical barriers has increased
slightly. However, those changes are not as great as those in the numbers of institutional and economic
and financial barriers.
The increase in the number of economic and financial barriers may indicate a greater awareness on the
part on the authors of the financial incentives and wherewithal needed to successfully commercialize
ITTs. The decrease in the number of institutional barriers may indicate the success of policies, programs,
and initiatives on the part of EPA, DOE, other federal agencies, and state governments to address or
remove those barriers.
14
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Average
Number
of Barriers
Per Report
FIGURE 2-5. AVERAGE NUMBER OF BARRIERS IDENTIFIED BY
CATEGORY PER REPORT FROM 1985 -1998
Institutional
-s- -Regulatory & Legislative
ATechnical
- -X- - Financial & Economic
1985-1990 (Early)
1993-1995 (Middle)
Year
1997-1998 (Recent)
Note: The numbers shown represent the average number of barriers on a per report basis identified in each barrier category for the time
frames shown. For example, in the 1985-1990 time frame, three reports were published. The average number of institutional barriers
identified in those reports was six.
Finding No. 7
Almost 75 percent of the barriers have been cited consistently over time.
Over half of the barriers have been consistently cited in all three time
frames.
Data indicate that 73 percent of the barriers (31 of 42) have persisted over time and continue to affect the
development and use of ITTs. Barriers were defined as persistent if they appeared in documents from at
least two time periods, including the most recent time period. Nearly three-quarters of the barriers
identified in either the early or the middle time frame continue to exist today. That finding indicates that
ITTs still face a significant number of barriers that have been known to exist for some time.
Approximately 24 of those 31 barriers (57 percent of the total number of barriers) have been identified in
at least one report in all three time periods, indicating that more than half the barriers that were identified
in the early years are perceived to continue to exist in the middle and recent time frames. Although
initiatives, programs, and policies developed to address those barriers have achieved some success, the
persistence of some barriers over time is evidence that more efforts may be required.
15
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Finding No. 8 Only three potential new barriers have been identified since 1997 - all
economic and financial barriers. However, at least two of those barriers
may be unique to DOE sites.
The three potential new barriers are:
"Numerous financial incentives to delay remediation and few incentives to carry out
remediation in a timely manner."
"Concern that use of an ITT may have adverse effects on employment in the agency that
uses that technology."
"Firms are reluctant to develop ITTs with limited applications."
Only one barrier, "Numerous financial incentives to delay remediation and few incentives to carry out
remediation in a timely manner," was identified in both reports from the recent time frame (1997 to
1998). Although it is possible that the barrier existed before 1997, the fact that it was identified only
recently illustrates a change in focus on the part of the authors from what may be considered more
obvious institutional, regulatory and legislative, or technical barriers to a more subtle in-depth
examination of the incentives for the technology user or site owner to use ITTs. Such an approach
represents a new perspective, by which barriers are examined not only from a "technology push"
viewpoint, but also from a demand-side "pull," or market-based, viewpoint.
It is possible that two barriers, "Numerous financial incentives to delay remediation and few incentives to
carry out remediation in a timely manner," and "Concern that use of an ITT may have adverse effects on
employment in the agency that uses that technology," which were identified only by DOE, are unique to
DOE. There is a lack of financial incentives within DOE to conduct timely cleanups because the
appropriations process creates significant uncertainty about the timing and level of funding available for
the management of environmental problems at DOE sites. Further, because DOE is the owner of a large
number of sites, it is likely that there is concern about the use of ITTs that might reduce the number of
personnel of the DOE facilities needed to install, operate, and maintain the ITTs.
The third barrier identified above, "Firms are reluctant to develop ITTs with limited applications," also
may be unique to DOE. Wastes at DOE sites are unique (radioactive waste), and the market for treating
such wastes may be limited to DOE (on the other hand, DOE itself might be considered a large market
16
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because DOE's problems are extensive). In addition, the limited application barrier may be a reference
to "niche" markets for ITTs that continue to lack good solutions.
Finding No. 9 Eight barriers are not identified in the two documents published since 1995.
Four of those barriers are institutional, three are economic and financial,
and one is technical.
The four institutional barriers that have not been cited since 1995 are: "Government agencies rely too
heavily on the support of contractors, some of whom have financial interests in conventional
technologies, to assist in selecting cleanup remedies;" "Technology experts are not included in the formal
decision-making process during which technologies are selected;" "Communities often are not supportive
of the use of ITTs because they are unwilling to assume risks associated with the testing and use of ITTs
in their neighborhoods;" and "EPA has not assessed Superfund site cleanup needs systematically and has
had difficulty matching ITTs with the requirements of specific sites."
The three economic and financial barriers that have not been cited since 1995 are: "Use of fixed-price
contracts to procure remediation services discourages the use of ITTs;" "Under the Federal Acquisition
Regulation (FAR), contractors that test ITTs during cleanup design would be precluded from bidding on
construction work at the site;" and "Lack of adequate mix of entrepreneurial, technical, and business
management skills in small environmental technology companies to facilitate development of a market-
driven technology."
The one technical barrier that has not been cited since 1995 is: "ITTs often are not considered until after
the data collection phase of the remedial investigation, thereby leaving critical gaps in data required to
evaluate the effectiveness of potentially applicable ITTs."
Finding No. 10 Of the eight barriers that are not identified in the two documents published
since 1995, seven may have been addressed or no longer are perceived as
relevant.
Seven barriers may have been addressed or no longer are perceived as relevant as by virtue of the fact
that they were cited at one time by one author but were not cited again in subsequent reports published by
that same author. The eighth barrier was cited by two authors in their first reports as well as in their
subsequent reports.
17
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The four institutional barriers that do not appear after 1995 are:
"Government agencies rely too heavily on the support of contractors, some of whom
have financial interests in conventional technologies, to assist in selecting cleanup
remedies."
"Technology experts are not included in the formal decision-making process during
which technologies are selected."
"Communities often are not supportive of the use of ITTs because they are unwilling to
assume risks associated with the testing and use of ITTs in their neighborhoods."
"EPA has not assessed Superfund site cleanup needs systematically and has had
difficulty in matching ITTs with the requirements of specific sites."
The first institutional barrier listed above was identified by EPA in 1990 and by DOE in 1995, but was
not identified again in the more recent reports published by either author. Therefore, from the
perspective of EPA and DOE, this barrier may have been addressed or is less relevant than previously
thought. The second institutional barrier listed above was identified by OTA in 1989, GAO in 1994, and
DOE in 1995. DOE did not identify the barrier again in its 1998 study, and neither OTA nor GAO has
published a subsequent study. Therefore, from the perspective of DOE, it may have been addressed or is
no longer relevant, but, from the perspective of OTA and GAO it is difficult to determine whether the
issue remains a barrier. The third institutional barrier listed above was identified by EPA in 1990 and
DOE in 1995, but was not identified again in more recent reports by either author. It is possible that the
barrier has been addressed. Under the Superfund reforms, community stakeholders have been included
in the decision-making process and extensive efforts have been made to educate citizen groups and the
general public about ITTs. Communities may be more comfortable with the use of ITTs and better
understand the risks associated with them. The fourth institutional barrier listed above was identified by
OTA and GAO. Both authors identified it as a barrier in their first reports and their subsequent reports.
Consequently, when their second reports were published, the authors still considered it a barrier.
Therefore, a conclusion that it has been addressed can not be made. However, because no other author
group identified it as a barrier, it may not be as relevant as previously thought, or it may be an artifact of
the unique perspective of the authors. Reports published by OTA and GAO focused more closely on
program evaluation than those prepared by DOE or EPA. Lack of mention by other authors also may
indicate that efforts undertaken by EPA have been successful in decreasing the impact of this barrier.
18
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The one technical barrier that was mentioned before 1995 was "ITTs often are not considered until after
the data collection phase of the remedial investigation, thereby leaving critical gaps in data required to
evaluate the effectiveness of potentially applicable ITTs." EPA cited that barrier in 1990, and DOE cited
it in 1995, but it was not cited in the more recent reports published by either EPA or DOE or by other
authors. It is likely that the barrier has been addressed or is of less concern than in the past.
Three economic and financial barriers, "Use of fixed-price contracts to procure remediation services
discourages the use of ITTs;" "Under the Federal Acquisition Regulation (FAR), contractors that test
ITTs during cleanup design would be precluded from bidding on construction work at the site;" and
"Lack of adequate mix of entrepreneurial, technical, and business management skills in small
environmental technology companies to facilitate development of a market-driven technology," were
mentioned in only one report each and may not have been considered relevant or important by other
authors. The fact that they were not mentioned again in later reports by the same authors, in conjunction
with the fact that no other authors mentioned them, may indicate that they were less important or less
relevant than other barriers.
Finding No. 11 Five barriers related to government business operations and developers'
market position were identified by one individual author at a single point in
time after 1990 and were not identified in any other source document.
The five barriers, all economic and financial, that were mentioned by only one author, at one point in
time, and were not identified in any other documents included in this study are:
"Use of fixed-price contracts to procure remediation services discourages the use of
ITTs," mentioned in 1990 by EPA TIO
"Under the Federal Acquisition Regulation (FAR), contractors that test ITTs during
cleanup design would be precluded from bidding on construction work at the site,"
mentioned in 1993 by GAO
"Lack of adequate mix of entrepreneurial, technical, and business management skills in
small environmental technology companies to facilitate development of a market-driven
technology," mentioned in 1993 by EPA and NETAC
"Firms are reluctant to develop ITTs with limited applications," mentioned in 1998 by
DOE
"Concern that use of an ITT may have adverse effects on employment in the agency that
uses that technology," mentioned in 1998 by DOE
19
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The fact that the first three barriers (above) were not identified in subsequent reports by the same authors
indicates that they may have been addressed or they may no longer be considered relevant. The last two
barriers were identified only in the most recent DOE report and therefore may be considered new or
unique to DOE sites. See Finding No. 8 in Section 2.3 of this report for further discussion of those two
barriers.
2.4 ANALYSIS OF BARRIERS BY STAGE OF ITT DEVELOPMENT
An analysis was performed to determine the degree to which barriers identified inhibit the development
or use of ITTs at various stages of development. The analysis was based on the information obtained
from the source documents, as well as the professional judgment of the analysts in determining the
relative effect of a given barrier on the various stages of development, as defined in Table 2-4.
TABLE 2-4. STAGES OF ITT DEVELOPMENT
Stage of
Development
Definition
Bench-scale
The bench-scale is that stage of development at which an ITT has been shown to be
feasible using laboratory equipment but for which insufficient data are available to attempt
to test or implement the technology at full-scale.
Pilot-scale
The pilot-scale is that stage of development at which sufficient data have been obtained
about an ITT to demonstrate that the technology may be feasible at full-scale and for
which sufficient data are available to establish the design and operating conditions needed
to test the ITT at full-scale.
Full-scale testing
and demonstration
The full-scale testing stage is that stage of development at which an ITT is tested outside
the laboratory and in a manner that demonstrates the technology's potential usefulness in
the implementation of large-scale cleanups at hazardous waste sites.
Full-scale
implementation
The full-scale implementation stage is that stage of development at which an ITT has been
tested and proven feasible for use at hazardous waste sites, but still lacks cost and
performance data adequate to facilitate the use of the technology on a large-scale,
commercial basis.
Bench- and pilot-scale stages of development are grouped together for this analysis because they
constitute the 'formative' period of the process of developing ITTs. Further, to eliminate any bias
resulting from 'outlier' barriers and to help focus the analysis, only those barriers mentioned in four or
more of the 10 source documents were included in the analysis. The resulting data set includes only 23
of the 42 barriers. Findings from this analysis are presented below.
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Finding No. 12 Six barriers related to the lack of coordination and consistency among
various programs and procedures, limited availability of market
information, and inadequate economic incentives to develop and use ITTs
affect all stages of development.
The six barriers that affect all stages of development are related to the lack of coordination and
consistency among various programs and procedures, limited availability of market information, and
inadequate economic incentives to develop and use ITTs. The six barriers two institutional, one
regulatory and legislative, one technical, and two economic and financial are:
"Actions undertaken by federal and state agencies to promote and regulate the
development and use of ITTs are not well coordinated"
"The level of communication that takes place among the various developers of
environmental technologies is not adequate to promote the development of ITTs"
"Permitting processes for ITTs are inconsistent, involve numerous levels, and are time-
and resource-intensive"
"Performance criteria and cleanup standards often are ill-defined and inconsistent"
"Economic incentives are lacking for those who might wish to develop or use ITTs"
"Information available to characterize potential markets for ITTs is limited"
Finding No. 13 Nearly 80 percent of barriers mentioned in four or more documents
primarily affect ITTs at the full-scale testing and full-scale implementation
stages. Barriers that affect the development and use of ITTs at the bench-
and pilot-scale stages were primarily institutional and economic and
financial.
Of the 23 barriers analyzed, 19 (or 83 percent) affect the full-scale implementation stage, and 18 (or 78
percent) affect the full-scale testing stage. Only nine barriers (or 39 percent) affect the bench- and pilot-
scale stages of development. That trend is common to barriers in all categories.
Bench- and pilot-scale technologies appear to be affected primarily by institutional and economic and
financial barriers. Institutional barriers arise from a lack of communication and coordination among the
parties involved in developing and using ITTs. Economic considerations, such as financial incentives for
developers and information about future market opportunities for their technologies also play a
significant role in bench- and pilot-scale development and testing. The barriers at the bench- and pilot-
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scale stages are crucial because such barriers can affect the potential number of ITTs available at the full-
scale stage.
This finding is consistent with the prevailing belief that technology developers encounter more barriers at
the full-scale testing and implementation stages because of the numerous parties involved and the
complexities of full-scale cleanup.
2.5 AUTHORS' AGREEMENT ON SPECIFIC BARRIERS BY CATEGORY
For this analysis, agreement by the authors on a specific barrier was determined to exist if the barrier was
consistently mentioned. A barrier was defined as consistently mentioned if it was cited in more than six
documents over the three periods (early, 1985 to 1990; middle, 1990 to 1995; and recent, 1997 to 1998),
and by at least one member of each group of authors. This section presents the most consistently
mentioned barriers in each of the four categories.
2.5.1 Institutional Barriers
Finding No. 14 Of the 16 institutional barriers, two that are related to agency coordination
and government hierarchies were mentioned consistently in the 10 source
documents.
Of the 16 institutional barriers, two were mentioned consistently:
"Actions undertaken by federal and state agencies to promote and regulate the
development and use of ITTs are not well coordinated"
"Rigid management hierarchies and government bureaucracy tend to perpetuate the use
of'status quo' technologies"
2.5.2 Regulatory and Legislative Barriers
Finding No. 15 Of the seven regulatory and legislative barriers, three barriers that are
related to the permitting process, manifesting requirements, and liabilities
of users, were mentioned consistently.
22
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The three consistently mentioned barriers in this category are:
"Permitting processes for ITTs are inconsistent, involve numerous levels, and are time-
and resource-intensive"
"Permitting and manifesting requirements under the Resource Conservation and
Recovery Act (RCRA) often inhibit the development of ITTs"
"Users of environmental technologies are concerned about liabilities they might incur
through the use of ITTs"
2.5.3 Technical Barriers
Finding No. 16 Of the six technical barriers, three that are related to limited cost and
performance data, inconsistent cleanup standards, and lack of formal,
coordinated verification programs were mentioned consistently.
Of the six technical barriers, three were consistently mentioned are:
"Cost and performance data for specific ITTs are limited"
"Performance criteria and cleanup standards often are ill-defined and inconsistent"
"No coordinated program for formally verifying the performance of ITTs"
2.5.4 Economic and Financial Barriers
Finding No. 17 Of the 13 economic and financial barriers, three barriers that are related to
lack of economic incentives, insufficient funding for development and
demonstration, and limited market information, were mentioned
consistently.
Of the 13 economic and financial barriers, the three mentioned consistently are:
"Economic incentives are lacking for those who might wish to develop or use ITTs"
"Government and private-sector funding for the development and demonstration of ITTs
is insufficient"
"Information available to characterize potential markets for ITTs is limited"
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3.0 INITIATIVES CITED IN SOURCE DOCUMENT'S TO MITIGATE BARRIERS
Information presented in the 10 source documents indicates that a number of initiatives have been
undertaken to help mitigate the effects of barriers. The list of initiatives presented below is not
comprehensive, but includes only efforts the authors identified in their source documents.
3.1 INITIATIVES TO MITIGATE INSTITUTIONAL BARRIERS
Initiatives discussed in the 10 documents include those that focus on facilitating communication, sharing
information, and coordinating in and among government agencies, technology developers, and users.
The Federal Remediation Technologies Roundtable (FRTR) was established in 1991 as an
interagency committee. The purpose of the FRTR is to facilitate the exchange of information
and provide a forum for joint action in the area of development and demonstration of ITTs for
the remediation of hazardous waste. Member agencies include the U.S. Department of Defense
(DoD), the U.S. Army, the U.S. Army Corps of Engineers (USAGE), the U.S. Navy, the U.S. Air
Force, DOE, the U.S. Department of the Interior (Dol), and EPA.
The FRTR addresses the consistently mentioned barrier "Actions undertaken by federal and state
agencies to promote and regulate the development and use of ITTs are not well coordinated."
The Remediation Technology Development Forum (RTDF) was organized by EPA's TIO and
ORD in 1992 to enhance cooperation and information-sharing among EPA, DOE, DoD, state
governments, private-sector technology companies, and public interest groups. The RTDF
encourage collaboration among those entities in defining, setting priorities among, and funding
innovative concepts for cleanup technologies. The RTDF seeks to combine the financial and
intellectual resources of members of the forum to promote coordination of research and reduce
duplication in research and development efforts.
The RTDF addresses two barriers "In general, a lack of communication exists between the developers of
ITTs and the potential users of those ITTs" and "Parties involved with cleanups have conflicting
priorities."
The Office of Technology Development (OTD) program was restructured in January 1994 by
DOE to address difficulties in coordination among DOE offices. The technology development
program combined activities of the DOE Office of Waste Management and the Office of
Environmental Restoration for increased coordination.
24
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The DOE initiative addresses the consistently mentioned barrier, "Rigid management hierarchies and
government bureaucracy tend to perpetuate the use of 'status quo' technologies."
The Six-State Partnership for Environmental Technology is developing a process for facilitating
the reciprocal evaluation, acceptance, and approval of environmental technologies. Development
of the process began in 1995 as a cooperative effort of EPA and the states of California, Illinois,
Massachusetts, New Jersey, New York, and Pennsylvania to promote verification of the
performance of ITTs. Further, in an attempt to help interested parties overcome certain
bureaucratic burdens that hinder the development and use of ITTs, DOE initiated the
Environmental Restoration and Waste Management Program. That program supports measures
taken to comply with federal, state, and local requirements governing cleanups at DOE sites.
These initiatives address two consistently mentioned barriers, "Actions undertaken by federal and state
agencies to promote and regulate the development and use of ITTs are not well coordinated" and "Rigid
management hierarchies and government bureaucracy tend to perpetuate the use of 'status quo'
technologies." The Six-State Partnership and the DOE initiative also address two other barriers,
"Regulators often adopt rigid approaches to applications of ITTs" and "Enforcement of regulations that
govern cleanup activities is inconsistent and too strict."
3.2 INITIATIVES TO MITIGATE REGULATORY AND LEGISLATIVE BARRIERS
Information presented in the 10 source documents indicates that a number of initiatives have been
undertaken to help overcome regulatory and legislative barriers. A number of initiatives have been
undertaken within EPA, DOE, and several states to reduce the regulatory burdens that affect the
development and use of ITTs. Examples include:
Since 1992, EPA has been granting states the authority to implement the Treatability Exclusion
Rule; the Research, Development, and Demonstration Permit Program; and the Subpart X Permit
Program. Those authorities are granted to states to simplify the approval process for
technologies and to allow more flexibility in testing and demonstrating ITTs.
The initiative addresses the consistently mentioned barriers, "Permitting processes for ITTs are
inconsistent, involve numerous levels, and are time-and resource-intensive" and "Permitting and
manifesting requirements under the Resource Conservation and Recovery Act (RCRA) often inhibit the
development of ITTs."
25
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In 1993, EPA issued the Superfund Response Action Contractor Indemnification Rule (58
Federal Register [F.R.] 5972). The rule was designed to help contractors that use ITTs obtain
lower deductibles under their liability insurance.
The initiative addresses the consistently mentioned barriers, "Users of environmental technologies are
concerned about liabilities they might incur through the use of ITTs," and "Entities that develop and use
ITTs are concerned about liabilities they might incur through the licensing and transfer of ITTs."
In 1994, EPA revised the Treatability Study Sample Exclusion Rule (59 F.R. 8362). The rule
was revised to exclude contaminated media used in testing ITTs from certain permitting and
manifesting requirements under RCRA.
The initiative addresses the barrier, "Obtaining authentic waste materials or site access needed to test
ITTs can be difficult and costly and can expose the developer of the technology to uncertain liabilities."
3.3 INITIATIVES TO MITIGATE TECHNICAL BARRIERS
Information presented in the source documents indicates that a number of initiatives have been
undertaken to help mitigate the effects of the technical barriers identified in this report. Examples of
those initiatives, which focus on the development and verification of cost and performance data, are
described below:
EPA's Superfund Innovative Technology Evaluation (SITE) program was established in 1986 to
help accelerate the development of ITTs. To address the lack of cost and performance data, field
demonstrations of certain ITTs are conducted under the program. The program then publishes
data on the cost, performance, reliability, and applicability of those ITTs. In addition to
remediation technologies, new site characterization technologies also are tested under the SITE
program.
The program addresses the consistently mentioned barriers, "Cost and performance data for specific ITTs
are limited" and "No coordinated program for formally verifying the performance of ITTs."
DoD, in partnership with EPA, launched the DoD National Environmental Technology
Demonstration Program (NETDP) in 1993. The program conducts pilot-scale demonstrations of
technologies at a large number of sites throughout the nation. The program focuses on the
testing and demonstration of technologies that are used to remediate media contaminated with
fuel hydrocarbons, heavy metals, and solvents and on those technologies that integrate biological
and physiochemical remediation processes.
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The program addresses the consistently mentioned barriers, "cost and performance data for specific ITTs
are limited" and "No coordinated program for formally verifying the performance of ITTs."
The FRTR, which was established in 1991 as an interagency committee to exchange information
and to provide a forum for joint action on the development and demonstration of ITTs, produced
a guide that specifies how cost and performance data should be documented at federal sites,
along with more than 150 case studies of completed projects.
The initiative addresses the consistently mentioned barriers, "Cost and performance data for specific
ITTs are limited" and "Often difficult to apply ITTs at numerous sites because the characteristics of the
sites differ."
TIO developed the EPA REmediation And CHaracterization Innovative Technologies (EPA
REACH IT) system in 1998 to provide accessible information on innovative treatment and
characterization technologies to environmental professionals through the Internet. The system
contains searchable data on approximately 1,300 innovative remediation and 150
characterization technologies and 750 service providers that offer those technologies. The
system provides information submitted by technology firms about the performance and
capabilities of specific ITTs and information submitted by EPA, DoD, DOE, and state project
managers about sites at which ITTs are deployed.
The initiative was designed to address the consistently mentioned barriers, "Cost and performance data
for specific ITTs are limited" and "Difficult to extrapolate information gained from testing an ITT at one
site to other sites."
3.4 INITIATIVES TO MITIGATE ECONOMIC AND FINANCIAL BARRIERS
The source documents present a number of recommendations to help mitigate the effects of certain
economic and financial barriers. The source documents did not list initiatives or programs that had been
established to address economic and financial barriers. The recommendations focus primarily on (1)
reducing uncertainties in the ITT market that tend to make the market less attractive than other markets to
venture capitalists and (2) providing more financial incentives to those entities that might wish to invest
in the development of ITTs. The recommendations include:
DOE should guarantee payment to technology firms on specified schedules. Implementing the
recommendation could help improve the reliability of streams of revenues for those technology
firms that market ITTs to DOE.
27
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The recommendation addresses the consistently mentioned barrier, "Economic incentives are lacking for
those who might wish to develop or use ITTs."
The government should require accounting procedures that would require publicly held firms to
report on their balance sheets with greater accuracy the full costs of environmental liabilities.
Implementing the recommendation also could encourage publicly held firms to conduct cleanups
in a timely manner.
The recommendation addresses the barrier, "Only a small portion of the entire life cycle of a project may
be taken into consideration when the costs of remediation alternatives are compared."
28
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4.0 INITIATIVES CITED IN EPA DEVELOPER'S GUIDE TO MITIGATE BARRIERS
In addition to initiatives found in the 10 source documents used for this study, many other initiatives to
reduce or remove barriers to ITT commercialization have begun. Table 4-1 summarizes the initiatives
described in detail in The Innovative Treatment Technology Developer's Guide to Support Services,
Fourth Edition, which is available online at . The table cross references the initiative
with a barrier category or categories and identifies the commercialization stage of technology
development to which the initiative is directed. Table 4-2 cross referenced each barrier category and
specific barrier against the programs or initiatives that might address that barrier. It also identifies the
source document for each barrier. In Table 4-2, the barriers listed above the double lines are consistently
mentioned barriers.
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Table 4-1. Initiatives from EPA's
Developer's Guide Cross Referenced
with Barrier Categories
COMMERCIALIZATION STAGES FROM EPA'S DEVELOPER'S GUIDE
Proof of Concept
Demonstrating Your Technology
Setting the Work
BARRIERS TO
Getting Paid
Administrative
INITIATIVES
1 Advanced Technology Program, U.S. Department of
Commerce
Web: www.atp.nist.gov
2 Air Force Center for Environmental Excellence
(AFCEE) Innovative Technology Program
Web: www.afcee. brooks, af.mil/er/orgert. htm
3 Air Force Center for Environmental Excellence
(AFCEE) Business Opportunities
Web: www.afcee.brooks.af.mil/business.htm
4 Air Force Small Business Environmental Database
(AFSBED)
Web: www.brooks-smallbusiness.com
5 America's Business Funding Directory
Web: www.businessfunding.net
6 Angel Capital Electronic Network (ACE-Net)
Web: www.ace-net. sr. unh. edu/home. html
7 Argonne National Laboratory, Argonne, IL
E-mail: gborland@anl.gov
8 Business Assistance Center, U.S. EPA
Region 3
Web: www.epa.gov/region3/sbac
9 Business Communications Center, U.S. Department
of Energy
Web: www.pr.doe.gov/prbus.html
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Table 4-1. Initiatives from EPA's
Developer's Guide Cross Referenced
with Barrier Categories
COMMERCIALIZATION STAGES FROM EPA'S DEVELOPER'S GUIDE
Proof of Concept
Demonstrating Your Technology
Setting the Work
BARRIERS TO
Getting Paid
Administrative
INITIATIVES
10 California Environmental Technology Certification
Program, California EPA
Web: www. calepa. ca.gov/programs/envirotech/
encertpg.htm
11 California Environmental Technology Export Program
E-mait: togbum@commerce.ca.gov
12 California Remedial Technology Assessment
Phone: (916) 322-3294
13 Capital Network
Web: www, thecapitalnetwork. com/overview, html
14 Carnegie Mellon University, Pittsburgh, PA
E-mail: minkley@andrew.cmu.edu
15 Center for Environmental Industry and Technology
E-mail: kilbride.carol@epa.gov
16 Commerce Business Daily (CBD), U.S. Department
of Commerce
Web: http://cbdnet. access. gpo. gov/
17 Data Merge Venture Capital Database
Web: www, datamerge, com/indexcentral, html
18 Doing Business with EPA, EPA Office of Acquisition
Management
Web: www.epa.gov/oam
19 Envirobiz Market Research
Web: www. envimbiz. com/butions/remhome. htm
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Table 4-1. Initiatives from EPA's
Developer's Guide Cross Referenced
with Barrier Categories
COMMERCIALIZATION STAGES FROM EPA'S DEVELOPER'S GUIDE
Proof of Concept
Demonstrating Your Technology
Setting the Work
BARRIERS TO
Getting Paid
Administrative
INITIATIVES
20 Environment in Asia, Asia Environmental Trading,
Ltd.
Web: www.asianenviro.com
21 Environmental Business Council Resources
Web: http:ffclu-in.org
22 Environmental Capital Network
Web: http://bizserve.com/Environmental. Capital.
Network/
23 Environ mental Export Council
Web: www.eec.org
24 Environmental Security Technology Certification
Program (ESTCP), U.S. Department of Defense
Web: www.estcp.org
25 Enviro-Tech Center
Web: www.envirotechcenter.org
26 Environmental Technology Networks, U.S. Agency for
International Development Global Technology
Network
Web: www.usgtn.org/pages/energy.html
27 Environmental Technology Verification (ETV)
Program, Site Characterization and Monitoring
Technologies Pilot
Web: www. epa. gov/etv/02/02_main. htm
28 EPA Hazardous Waste Clean-up Information (CLU-
Web: http://clu-in.org
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Table 4-1. Initiatives from EPA's
Developer's Guide Cross Referenced
with Barrier Categories
COMMERCIALIZATION STAGES FROM EPA'S DEVELOPER'S GUIDE
Proof of Concept
Demonstrating Your Technology
Setting the Work
BARRIERS TO
Getting Paid
Administrative
INITIATIVES
29 EPA REmediation And CHaracterization Innovative
Technologies (EPA REACH IT)
Web: www.epareachit.org
30 EPA-WASTE Listserve; All Hazardous and Solid
Waste and Comprehensive Environmental Response,
Compensation, and Liability Act Federal Registers
Web: www. epa. gov/epaoswer/hotline/listsrv.htm
31 eWeb
Web: www.slu-edu/eweb
32 Export-Import Bank of the United States
Web: www.exim.gov
33 Federal Remediation Technologies Roundtable
(FRTR)
Web: www.FRTR.gov
34 Federal Technology Transfer Act Program, U.S. EPA
Web: www. nalusda.gov/ttic/guide. htm and
www.etc2.org
35 Foresight Science and Technology, Inc.
Web: www.seeport.com
36 Globaltechs
Web: www.gtobaltechs.com
37 Global Network of Environment & Technology
(GNET) Contracting Opportunities
Web: www.gnet.org/filecomponent/2501.html
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Table 4-1. Initiatives from EPA's
Developer's Guide Cross Referenced
with Barrier Categories
COMMERCIALIZATION STAGES FROM EPA'S DEVELOPER'S GUIDE
Proof of Concept
Demonstrating Your Technology
Setting the Work
BARRIERS TO
Getting Paid
Administrative
INITIATIVES
38 Great Lakes and Mid-Atlantic Hazardous Substances
Research Center
Web: www. engin. umich. edu/dept/cee/research/
HSRC/index.html
39 Great Plains-Rocky Mountain Hazardous Substance
Research Center
Web: www.ensg.kBU.edu/HSRC
40 Ground Water Remediation Field Laboratory, Dover
Air Force Base, DE
Phone: (302) 678-8284
41 Ground-Water Remediation Technologies Analysis
Center (GWRTAC)
Web: www.gwrtac.org
42 Gulf Coast Hazardous Substance Research Center
E-mail: curlessjh@hal. lamar. edu
43 Hazen Research, Inc.
Web: www.Hazenusa.com
44 Idaho National Engineering Laboratory, Idaho Falls,
ID
E-mail: hainke@inel.gov
45 III Research Institute (IITRI), Chicago, IL
Web: www.iitri.org
46 Illinois Pollution Prevention and Technical Assistance
Program
Web: www.wmrc.uiuc.edu
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Table 4-1. Initiatives from EPA's
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with Barrier Categories
COMMERCIALIZATION STAGES FROM EPA'S DEVELOPER'S GUIDE
Proof of Concept
Demonstrating Your Technology
Setting the Work
BARRIERS TO
Getting Paid
Administrative
INITIATIVES
47 Illinois Waste Management and Research Center
E-mail: Gwelde@wmrc. hazard, uiuc. edu
48 Innovative Treatment Remediation Demonstration
(ITRD) Program
E-mail: mmhigMQsandia.gov
49 International Buyer Program, U.S. Department of
Commerce
Web: www.ita.doc.gov/uscs/uscsibp.html
50 International Trade Administration (ITA),
U.S. Department of Commerce
Web: www.ita.doc.gov
51 International Venture Capital Institute
Phone: (203)323-3143
52 Interstate Technology and Regulatory Cooperation
(ITRC) Working Group
Web: www.itrcweb.org
53 Market Access and Compliance (MAC)
On-Line, U.S. Department of Commerce
Web: www.mac.doc.gov
54 MBI International's Center for Biotechnology
E-mail: windishQmbi.org
55 McClellan Air Force Base, Sacramento, CA
E-mail: lu.jim@mcclellan. af.mil
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Table 4-1. Initiatives from EPA's
Developer's Guide Cross Referenced
with Barrier Categories
COMMERCIALIZATION STAGES FROM EPA'S DEVELOPER'S GUIDE
Proof of Concept
Demonstrating Your Technology
Setting the Work
BARRIERS TO
Getting Paid
Administrative
INITIATIVES
56 Michael D. Dingman Center for Entrepreneurship,
University of Maryland
Web: www.bmgt.umd.edu/Dingman
57 National Business Incubation Association
Web: www.nbia.org
58 National Center for Ground Water Research
E-mail: wardch@rice.edu
59 National Center for Integrated Bioremediation
Research and Development
Web: http://ncibrd. engin. umich. edu
60 National Defense Center for Environmental
Excellence
Web: www. ndcee. etc. com/index, htm
61 National Environmental Technology Demonstration
Program, U.S. Department of Defense
62 National Environmental Technology Test Sites
(NETTS) Program
Web: www.hgl.com/serdp/netts/default.html
63 National Environmental Waste Technology Testing
E-mail: maryanhbQmse-ta.com
64 National Technology Transfer Center (NTTC)
Web: www.nttc.edu
65 Naval Construction Battalion Center, Port Hueneme,
CA
E-mail: elory@nsesc.navy.mil
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Table 4-1. Initiatives from EPA's
Developer's Guide Cross Referenced
with Barrier Categories
COMMERCIALIZATION STAGES FROM EPA'S DEVELOPER'S GUIDE
Proof of Concept
Demonstrating Your Technology
Setting the Work
BARRIERS TO
Getting Paid
Administrative
INITIATIVES
66 Naval Environmental Leadership Program (NELP)
Web: www.nelp.navy.mil
67 New Jersey Commission on Science and Technology
E-mait; scitechQscitech.state.nj.us
68 New Jersey Institute of Technology - Otto H. York
Center for Environmental Engineering and Science
Phone: (973) 802-1946
69 New Mexico State University
E-mail: wercQnmsu.edu
70 Northeast Hazardous Substance Research Center
Web: www.cees.njit.edu/nhsrc
71 Oak Ridge Subsurface Weirs, Oak Ridge, TN
E-mait: jardinepm@ornl.gov
72 Office of Environmental Restoration and Waste
Management, U.S. Department of Energy
Web: www.em.doe.gov/er
73 Office of Environmental Technologies Exports, U.S.
Department of Commerce
Web; www.ita.doc.gov/
74 Office of International Trade, U.S. Small Business
Administration
Web: www.sba.gov/OIT
75 Office of Science and Technology, U.S. Department
of Energy
Web: http://em-SO.em.doe.gov
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Table 4-1. Initiatives from EPA's
Developer's Guide Cross Referenced
with Barrier Categories
COMMERCIALIZATION STAGES FROM EPA'S DEVELOPER'S GUIDE
Proof of Concept
Demonstrating Your Technology
Setting the Work
BARRIERS TO
Getting Paid
Administrative
INITIATIVES
76 Olympic Venture Partners
E-mail: info@ovp.com
77 Ontario Centre for Environmental Technology
Advancement
Web: www.oceta.on.ca
78 Overseas Private Investment Corporation
Web: www.opic.gov
79 Program Research and Development
Announcements (PRDA) and Research Opportunity
Announcements (ROA), U.S. Department of Energy
Web: cbdnet.access.gpo.gov
80 Remediation Information Management System
(RIMS)
Web: www.remedial.com
81 Remediation Technologies Development Forum
Web: www.rtdf.org
82 Research Triangle Institute
Web: www.rti.org/genjnfo.html
83 Resource Conservation and Recovery Act (RCRA),
Superfund, and Emergency Planning and Community
Right-to-Know Act (EPCRA) Hotline
Web: www. epa. gov/epaoswer/hotlineftndex. htm
84 Sandia National Laboratories
Web: www.sandia.gov
85 Savannah River Research Campus
Phone: (803) 652-7772
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Table 4-1. Initiatives from EPA's
Developer's Guide Cross Referenced
with Barrier Categories
COMMERCIALIZATION STAGES FROM EPA'S DEVELOPER'S GUIDE
Proof of Concept
Demonstrating Your Technology
Setting the Work
BARRIERS TO
Getting Paid
Administrative
INITIATIVES
86 Service Corps of Retired Executives (SCORE)
Web: www.score.org
87 Small Business and Contracting Opportunities, U.S.
Department of Defense
Web: www.acq.osd mit/sadbu
88 Small Business Development Center Program, U.S.
Small Business Administration
Web: www.sba.gov
89 Small Business Guide to Federal R8D Funding
Opportunities
Web: www, seeport, com/manuals/r&dbook/
rdguide.htm
90 Small Business Innovative Research Program, U.S.
Small Business Administration
Web: www.sba.gov/SBIR/sbir.html
91 Small Business Technology Transfer Program, U.S.
Department of Energy
Web: http://sttr.er.doe.gov/sttr
92 Smithville Phase IV Bedrock Remediation Program
Phone: (905) 957-4077
93 Solution Quest
Web: www.sotquest.com
94 South and Southwest Hazardous Substance
Research Center
Web: www. hsrc. org/hsrc/html/south. html
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Table 4-1. Initiatives from EPA's
Developer's Guide Cross Referenced
with Barrier Categories
COMMERCIALIZATION STAGES FROM EPA'S DEVELOPER'S GUIDE
Proof of Concept
Demonstrating Your Technology
Setting the Work
BARRIERS TO
Getting Paid
Administrative
INITIATIVES
95 Southern Technology Applications Center (STAC)
Web: www.state.fl.us/stac
96 State Science and Technology Institute (SSTI)
Web; www.ssff.org
97 State Sources of Commercialization Assistance
Web: h ttp://clu-in. org/products/ebc/ebcrpt. h tm
98 State University of New York at Buffalo
Web; httpJ/wings, buffalo, edu/hazwaste
99 Superfund Innovative Technology Evaluation (SITE)
Web: www.epa.gov/ORD/SITE/index.html
100 Superfund Technical Liaison Program, U.S. EPA
Phone: (202)260-7667
101 Sustainable Business Network
Web: h ttp://sbn. en virolink. org/busopps/index. h tml
102 TechCon
Web: htipJ/web. ead. anl. gov/techconl
103 TechKnow
Web: www.fec/i/cnow.org
104 Technology Transfer Society
Web: www.f2s.org
105 Tennessee Technology Foundation
Phone: (423) 220-8832 or (615) 253-1946
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40
-------
Table 4-1. Initiatives from EPA's
Developer's Guide Cross Referenced
with Barrier Categories
COMMERCIALIZATION STAGES FROM EPA'S DEVELOPER'S GUIDE
Proof of Concept
Demonstrating Your Technology
Setting the Work
BARRIERS TO
Getting Paid
Administrative
INITIATIVES
106 Toxic Substances Control Act (TSCA) Assistance
Information Service, U.S. EPA
E-mail: tsca-hotlineQepa.gov
107 Trade Information Center, U.S. Department of
Commerce
Web: www.ita.doc.gov/tic
108 UNISPHERE
Web: www.unisphere.com
109 U.S. Army Corps of Engineers (USAGE)
Environmental Programs Contracting Opportunities
Web: www.environmental.usace.army.mil/hq/tools/
opportunity/opportunity.html
110 U.S. Business Advisor: Laws and Regulations
Web: www.business.gov
111 U.S. EPA Laws and Regulations
Web: www. epa. gov/epahome/rules. html
112 U.S. EPA National Exposure Research Laboratory -
Environmental Sciences Division (NERL-ESD)
Web: www.epa.gov/crdlvweb
113 U.S. EPA National Risk Management Research
Web: www.epa.gov/ORD/NRMRL
1 14 U.S. EPA Test and Evaluation Facility
Phone: (513)569-7051
115 U.S. Small Business Administration
Web: www.sba.gov
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41
-------
Table 4-1. Initiatives from EPA's
Developer's Guide Cross Referenced
with Barrier Categories
COMMERCIALIZATION STAGES FROM EPA'S DEVELOPER'S GUIDE
Proof of Concept
Demonstrating Your Technology
Setting the Work
BARRIERS TO
Getting Paid
Administrative
INITIATIVES
116 University of California, Los Angeles
Web: http://cct. seas. ucla. edu/cct. home.html
117 University of Cincinnati
Phone: (513) 556-3738
118 University of Florida
Web: www.floridacenter.org
119 U n iversity of Tennessee
Phone: (423) 974-8080
120 University of Waterloo
Phone: (519)885-1211, ext. 2189
121 University of Wyoming Center for Environmental
Simulation Studies
E-mail: qskinnerQuwyl.edu
122 Virginia's Center for Innovative Technology
Web: http://cit.org
123 Volunteer Army Ammunition Plant, Chattanooga, TN
Web: www. volunteersite. com/volsite. htm
124 Waterways Experiment Station Hazardous Waste
Web: www.wes.army.mil/el/hwrc
125 Western New York Technology Development Center
Web: wings.buffalo.edu/wnytdc
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42
-------
Table 4-1. Initiatives from EPA's
Developer's Guide Cross Referenced
with Barrier Categories
COMMERCIALIZATION STAGES FROM EPA'S DEVELOPER'S GUIDE
Proof of Concept
Demonstrating Your Technology
Setting the Work
BARRIERS TO
Getting Paid
Administrative
INITIATIVES
126 Western Region Hazardous Substance Research
Center
Web: www-seep-server. start ford. edu/SEEP Web/
wrhsrc
127 SR-Superfund Reforms, Round 1, Round 2, and
Round 3
Web: www. epa. gov/superfund/programs/reforms/
byround.htm
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43
-------
Table 4-2. Barriers to ITTs Cross Referenced by Initiatives
SOURCE DOCUMENTS
THIRD PARTY
INITIATIVES
UNDERWAY
Cross
Reference to
Table 4-1
to
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1-1
I-2
I-3
I-4
I-5
I-6
I-7
I-8
Actions undertaken by federal and state agencies to promote and regulate the development
and use of ITTs are not well coordinated.
Rigid management hierarchies and government bureaucracy tend to perpetuate the use of
status quo technologies.
Schedules imposed by regulatory agencies often do not allow sufficient time to investigate the
feasibility of using ITTs.
Regulators often adopt rigid approaches to applications of ITTs.
The level of communication that takes place among the various developers of environmental
technologies is not adequate to promote the development of ITTs.
In general, a lack of communication exists between the developers of ITTs and the potential
users of those ITTs.
EPA has not assessed Superfund site cleanup needs systematically and has had difficulty in
matching ITTs with the requirements of specific sites.
Parties involved with cleanups have conflicting priorities.
27, 33, 48, 52,
61,81
2, 10, 12, 15,
24, 27, 34, 48,
52,61,72,75,
79,81,99
27, 29, 33, 43,
52,100,114
10, 27, 52
20,21,26,28,
49,51,56,74,
81,86,88,95,
104, 105, 108,
122
12, 19, 24, 26,
28, 29, 37, 49,
54, 64, 73, 80,
87, 103, 105,
107, 108
12,99,100,
102
*
+
+
*
+
+
+
+
*
+
+
+
*
*
No specific initiative addressing this barrier was identified in the source documents or EPA s The Innovative Treatment Technologies Developers Guide to Support Services, Fourth Edition
reviewed in preparing this table. It is important to note that this list is not comprehensive and initiatives or policies may exist that address these barriers.
44
-------
Table 4-2. Barriers to ITTs Cross Referenced by Initiatives
SOURCE DOCUMENTS
THIRD PARTY
INITIATIVES
UNDERWAY
Cross
Reference to
Table 4-1
to
s
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I-9
1-10
1-11
1-12
1-13
1-14
1-15
1-16
Regulators may lack knowledge about ITTs.
Technology experts are not included in the formal decision-making process during which
technologies are selected.
Government agencies rely too heavily on the support of contractors, some of whom have
financial interests in conventional technologies, to assist in selecting cleanup remedies.
Appropriations and procurement processes create uncertainty about the levels and timing of
funding that will be available to manage environmental problems at individual DOE sites.
Enforcement of regulations that govern cleanup activities is inconsistent and too strict.
Cycles of government appropriations are not coordinated with the cycles of research and
development for ITTs, causing gaps in funding.
Regulators are reluctant to appear lenient in dealing with responsible parties.
Communities often are not supportive of the use of ITTs because they are unwilling to
assume risks associated with the testing and use of ITTs in their neighborhoods.
TOTALS
10,12,24,27,
28,29,36,41,
42, 52, 58, 59,
61,64,66,68,
75,80,81,94,
99,103,113,
116,118,120,
124
66, 100
24, 27, 28, 29
9,37,102
8,10,52,110
110
10,27
2. 24, 27, 28,
29,36,38,41,
42,52,61,64,
66,68,80,81,
92, 99, 103,
113
4-
6
*
3
4
+
+
8
+
+
11
4
+
8
2
+
9
+
2
No specific initiative addressing this barrier was identified in the source documents or EPA s The Innovative Treatment Technologies Developers Guide to Support Services, Fourth Edition
reviewed in preparing this table. It is important to note that this list is not comprehensive and initiatives or policies may exist that address these barriers.
45
-------
Table 4-2. Barriers to ITTs Cross Referenced by Initiatives
SOURCE DOCUMENTS
THIRD PARTY
INITIATIVES
UNDERWAY
Cross
Reference to
Table 4-1
to
s
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R-1
R-2
R-3
R-4
R-5
R-6
R-7
Permitting processes for ITTs are inconsistent, involve numerous levels, and are time- and
resource-intensive.
Permitting and manifesting requirements under the Resource Conservation and Recovery Act
(RCRA) often inhibit the development of ITTs.
Users of environmental technologies are concerned about liabilities they might incur through
the use of ITTs.
Entities that develop and use ITTs are concerned about liabilities they might incur through the
licensing and transfer of ITTs.
Regulatory structures do not consider market forces and therefore do not provide incentives
for cleanup contractors and site managers to use ITTs.
Tendency of regulations to evolve over time discourages the development and use of certain
ITTs.
Obtaining authentic waste materials or site access needed to test ITTs can be difficult and
costly and can expose the developer of the technology to uncertain liabilities.
TOTALS
10,27,52
*
*
34,54
*
A
2,7,12,15,24,
25, 40, 44, 48,
55, 59, 62, 63,
65, 66, 69, 70,
71,81,92,99,
123
+
+
4
+
3
*
*
3
3
+
+
4
+
4
*
5
3
2
+
3
T-1
T-2
Cost and performance data for specific ITTs are limited.
Performance criteria and cleanup standards often are ill-defined and inconsistent.
2, 24, 27, 28,
29,33,41,48,
50, 60, 66, 68,
80,81,99,103
*
*
*
*
* No specific initiative addressing this barrier was identified in the source documents or EPA s The Innovative Treatment Technologies Developers Guide to Support Services, Fourth Edition
reviewed in preparing this table. It is important to note that this list is not comprehensive and initiatives or policies may exist that address these barriers.
46
-------
Table 4-2. Barriers to ITTs Cross Referenced by Initiatives
SOURCE DOCUMENTS
THIRD PARTY
INITIATIVES
UNDERWAY
Cross
Reference to
Table 4-1
to
s
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T-3
T-4
T-5
T-6
EA
- \
E-2
E-3
E-4
No coordinated program for formally verifying the performance of ITTs.
Often difficult to apply ITTs at numerous sites because the characteristics of the sites differ.
Difficult to extrapolate information gained from testing an ITT at one site to other sites.
ITTs often are not considered until after the data collection phase of the remedial
investigation, thereby leaving critical gaps in data required to evaluate the effectiveness of
potentially applicable ITTs.
TOTALS
. . . . .
economic incentives are lacking Tor those who might wish to develop or use Ills.
Government and private-sector funding for the development and demonstration of ITTs is
insufficient.
Information available to characterize potential markets for ITTs is limited.
Venture capitalists perceive the environmental management market as a high financial risk.
10,27,48,55,
75,81,99
38, 40, 59, 60,
62, 121, 123
2, 24, 27, 28,
29,33,41,48,
50, 60, 66, 68,
80,81,99,103
10, 12, 27, 28,
29,33
*
1,5,6,12,13,
15, 17, 22, 32,
35,47,51,54,
56, 57, 67, 70,
72, 74, 78, 79,
89,90,91,101,
105,107,115
19,20,26,53,
73,93,107
5,6,13,15,17,
22,31,51,54,
56, 57, 76, 77,
101,108
+
+
6
+
2
*
2
+
+
*
5
*
4
*
2
*
+
2
1
*
1
+
5
*
*
No specific initiative addressing this barrier was identified in the source documents or EPA s The Innovative Treatment Technologies Developers Guide to Support Services, Fourth Edition
reviewed in preparing this table. It is important to note that this list is not comprehensive and initiatives or policies may exist that address these barriers.
47
-------
Table 4-2. Barriers to ITTs Cross Referenced by Initiatives
SOURCE DOCUMENTS
THIRD PARTY
INITIATIVES
UNDERWAY
Cross
Reference to
Table 4-1
to
s
O
t;
a.
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E-5
E-6
E-7
E-8
E-9
E-10
E-11
E-12
E-13
Technology selection decision-makers are concerned with protection of their agencies'
budgets, so there is a reluctance to use technologies developed by other agencies.
Only a small portion of the entire life cycle of a project may be taken into consideration when
the costs of remediation alternatives are compared.
Numerous financial incentives to delay remediation and few incentives to carry out
remediation in a timely manner.
Market for environmental remediation technologies is fragmented.
Use of fixed-price contracts to procure remediation services discourages the use of ITTs.
Under the Federal Acquisition Regulation (FAR), contractors that test ITTs during cleanup
design would be precluded from bidding on construction work at the site.
Lack of adequate mix of entrepreneurial, technical, and business management skills in small
environmental technology companies to facilitate development of a market-driven technology.
Firms are reluctant to develop ITTs with limited applications.
Concern that use of an ITT may have adverse effects on employment in the agency that uses
that technology.
TOTALS
*
*
*
3,19,28,37
*
*
5,21,25,31,
57, 76, 85, 86,
88,93,115
44, 72, 75, 79
*
3
6
2
+
6
+
+
8
4
+
3
2
0
+
+
7
No specific initiative addressing this barrier was identified in the source documents or EPA s The Innovative Treatment Technologies Developers Guide to Support Services, Fourth Edition
reviewed in preparing this table. It is important to note that this list is not comprehensive and initiatives or policies may exist that address these barriers.
48
-------
APPENDICES
A SUMMARY OF TEN DOCUMENTS USED FOR THIS STUDY A-l
B LIST OF OTHER DOCUMENTS REVIEWED FOR THIS STUDY B-l
C LIMITATIONS OF THE STUDY AND ANALYSIS C-l
-------
APPENDIX A
SUMMARY OF TEN DOCUMENTS USED FOR THIS STUDY
A comprehensive literature review of documents related to barriers of innovative treatment technologies
(ITT) identified an initial list of 33 documents. A preliminary review of the 33 documents was
performed to select documents that provide the most useful information in which to articulate the barriers
to acceptance of ITTs. A review of those documents was performed, and the documents were classified
as follows:
Nine of the documents provided little or no information about barriers to the
development and use of ITTs and therefore were determined not to be useful to this
study.
Twelve of the documents discussed barriers to the use of innovative environmental
technologies in general, including pollution prevention technologies, but did not provide
information about barriers that specifically affected the development, selection, and use
of ITTs. Therefore, these documents were determined not to be useful to this study.
Twelve of the documents were determined to contain relevant information about barriers
to the development and use of ITTs. However, two of these documents were reviews of
other studies and therefore were eliminated from the study.
Based on this review, and at the direction of the U.S. Environmental Protection Agency (EPA) work
assignment manager (WAM), 10 documents that held the most value for further detailed analysis were
selected for use in this study. These documents contain information that is sufficient to develop a general
understanding of the barriers to ITTs; however, they do not necessarily contain as comprehensive a
discussion, or explore as many facets of barriers as that found in the documents related to "innovative
environmental technologies." These documents served as the basis for the analysis of barriers to ITTs.
This appendix presents a summary of each of these 10 documents. The remaining 23 documents are
listed in Appendix B.
A-l
-------
Document No.: 1
Title: Super fund Strategy
Author/Sponsor: Congress of the United States, Office of Technology Assessment (OTA)
Publication Date: 1985
Overview:
EPA estimates of the number of Superfund sites is very low, and existing resources are not sufficient to
permanently cleanup even that very low number of sites (one-fifth of OTA's estimate). Although, at
many sites responses have been limited, they usually consist of moving the waste to land disposal sites or
leaving the waste in the ground. The public has begun to demand permanently effective cleanups, that is,
cleanups that minimize the likelihood that further action will be necessary in the future to address the
same sites or wastes for the same sites. To achieve such permanent cleanups, waste and contaminated
materials must be treated, rather than merely moved. But little progress has been made in accomplishing
permanent cleanups, particularly in the case of the expensive, difficult, and uncertain task of cleaning up
contaminated groundwater. Moreover, detailed goals for permanent cleanups remain unclear; without
such goals, it is difficult to select cost-effective cleanup technologies and evaluate their performance.
Statement of Problem:
Cleanup has focused on containment strategies adopted by the construction industry. Minimal thought
has been given to the development and application of ITTs specifically designed to deal with the unique
problems encountered at hazardous waste sites. With increasing evidence that containment strategies are
ineffective in the long term and that it might be necessary to take further remediation action at a site or
on a waste, and as the dimensions of groundwater problems at sites become increasingly clear,
technologies designed to destroy the toxic component of hazardous wastes are being developed by the
private sector. However, institutional, regulatory and legislative, and economic and financial barriers
hamper the adoption of ITTs by the Superfund program.
Barriers Identified in the Report:
The document identifies the following barriers to the adoption of ITTs:
Policy uncertainties create market uncertainties: Because Superfund is viewed as a short-term
program, market support for long-term development of ITTs is weak. Uncertainties about the
ultimate size of the Superfund program and the type of cleanup effort it will encompass create
market uncertainties. Uncertainties also arise because technology is at an advanced stage than
A-2
-------
the regulatory process. There is no clear-cut way to objectively judge the effectiveness of ITTs
or to compare them with traditional technologies.
Access to financing for research and development (R&D): Without adequate funding for R&D
and demonstration, no technology will reach the stage at which it can demonstrate an acceptable
level of reliability and effectiveness under field conditions. The crucial and expensive
demonstration period is preceded by bench and pilot-test stages that often must be funded
without guarantees that a commercial product will result.
Institutional practices and regulatory effects: Cleanup standards are not consistent and valid
waste materials for testing are difficult to acquire. That circumstance raises the cost of, or even
prevents, demonstrations and creates inconsistencies in the information available about ITTs.
There is no established procedure for collecting and disseminating the information that is
generated. Institutional and regulatory and legislative barriers include:
Permitting requirements are expensive and time-consuming: There is duplication of
procedures between the states and the federal government and even among EPA regions.
- Testing that will result in applicable and valid data requires the use of real material
rather than synthetically produced wastes. Valid waste for testing is difficult to obtain.
- Policy uncertainties, the lack of regulations, or uncertainties about new regulations can
have negative effects on technology development: Existing regulations also affect
adoption of technologies because of: (1) duplication in the permitting requirements of
federal, state, and local agencies; (2) differences between various states and EPA
regions; and (3) the preemption of other applicable or relevant environmental
regulations.
There is a regulatory bias toward the 'status quo' or existing technology: Regulations (including
the National Contingency Plan [NCP]) and guidance including, EPA's "Guidance on the
Preparation of Feasibility Studies " encourage a bias toward containment and, to a lesser extent,
traditional incineration technologies. A predilection for short-term costing and a reluctance to
reach beyond comfortable, traditional technology favor the 'status quo.'
Document No.: 2
Title: Coming Clean - Super fund Problems Can Be Solved
Author/Sponsor: Congress of the United States, OTA
Publication Date: 1989
Overview:
Superfund began in 1980 as a short-term emergency clean up effort. By 1985, when Congress debated
reauthorizing Superfund for a second five year period, the program had become controversial and
confrontational. Among other things, Superfund at the time lacked a unified national infrastructure of
education, training, databases, research, and development. In addition, OTA found that as many as 75
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percent of cleanups were unlikely to be effective over the long term. The report responds to a request
from the House Committee on Public Works and Transportation and the House Committee on Energy
and Commerce for an examination of the implementation of the Superfund Amendments and
Reauthorization Act of 1986 (SARA).
Statement of Problem:
OTA recognized several problems involving "...our technological capabilities to manage hazardous waste
and cleanups...". Three types of problems plagued the Superfund program; they were related to workers
and technology. Long-term support on the part of the government for basic research and R&D on critical
problems was deemed necessary. The potentially enormous size of the cleanup business initiated R&D,
and hundreds of new companies offered advanced cleanup technologies. Use of better, and often more
expensive, technologies was limited by decision makers who were overly cautious, had available only
inadequate information, or were interested primarily in minimizing front-end costs. Although almost
everyone working in the Superfund system understood the congressional intent to shift to permanently
effective cleanup technologies and to acknowledge the public's support for that policy, a number of
factors resulted in slow and uneven implementation.
Barriers Identified in the Report:
The document identifies the following barriers to the adoption of ITTs:
Because data on cost and operational history are limited, ITTs historically have been screened
out early in the evaluation process: Certain elements of the evaluation process create a bias
against the use of ITTs. For example, because of liability for damages resulting from failure of a
technology, contractors, potentially responsible parties, and government alike are reluctant to
recommend the use of ITTs that have not been demonstrated fully.
There are significant delays between R&D and demonstration and between demonstration and
full-scale application: The delays in adopting new ITTs, in turn, create a delay between market
expectations and market returns on R&D investments. The existence of such delays tends to
influence the expanding national cleanup effort to depend on older technologies, rather than
assume the risk and uncertainty, but the chance for bigger gains, offered by newer technologies.
Further, the public may have little patience with delays in Superfund cleanups. Insecurities about
the Superfund system and pressures from outside delay the adoption of ITTs, even as the need for
them increases.
Few incentives to select improved cleanup technologies have been built into the Superfund
program: There are far more penalties than rewards for choosing new solutions over older ones,
even though the older approaches may not offer reliable, permanent, long-term protection. Those
who bear the responsibility for paying for cleanups see ITTs as more expensive in the near term
than conventional containment or land disposal and monitoring. Engineering companies have
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strong concerns about liability for ineffective work or work that is judged later by standards that
differ from those that governed the conduct of the work. There is less risk in using 'standard'
off-the-shelf technologies than in adopting new and innovative ones. Engineers who use
unproven technologies in their designs are gambling with their clients' money. If the gamble
backfires, the engineering firm might be held liable. Engineers, therefore, are not likely to use
unproven technologies in remedial designs because of potential liability; the result is an impasse:
engineers do not want to use ITTs, but technologies cannot reach commercial status unless they
are used.
There is pressure on those in government to complete reports and records of decision (ROD):
Such pressure impedes the use of ITTs because the selection process for such technologies is
likely to be more lengthy and costly than that for conventional approaches. There are a few
exceptions, mostly on the part of responsible parties that are aware that the use of a new
technology will reduce costs, compared with the cost of older technologies. Such parties also
tend to consider the use of ITTs as a means of reducing future liability. As a rule, parties that
give weight to such considerations tend to select permanent remedies, including ITTs.
Another disincentive to the use of ITTs is the need to obtain a regulatory delisting of the residue
of a treatment operation if the material is to be sent off site after treatment: The Resource
Conservation and Recovery Act (RCRA) regulatory program is plagued with considerable
inefficiencies. If delisting cannot be obtained quickly, the cost of using a treatment technology
escalates, because a residue automatically is considered hazardous unless found to be otherwise
through the delisting process. Uncertainty about delisting and the potentially high cost of
managing residue can block the adoption of an effective treatment technology.
The technology development pipeline is clogged: R&D efforts are moving forward, buoyed by
continued optimism about the number of cleanups, the availability of cleanup funds from
government entities, and the availability of venture capital. But the cleanup market rarely meets
the expectations of technology developers. The rapid growth of Superfund and public pressures
on the government to produce more cleanups faster do not necessarily promote adoption of ITTs.
One company that had developed a new form of thermal destruction, which had garnered much
attention and been applied successfully in several site demonstrations, went bankrupt.
Competition increases constantly so that available business and opportunities for site
demonstrations are distributed among a growing number of technology companies. Small market
share can limit both the success of a company and its ability to continue its technology
development efforts. The Superfund Innovative Technology Evaluation (SITE) program has had
mixed results. Analytical contractors have provided inadequate services. The SITE program
tends to overemphasize positive results and to discount negative results. Of crucial concern as
well, the SITE program never has focused on true ITTs that would represent breakthroughs in
particulary difficult cleanup applications and technologies for which prior R&D has justified
field demonstration. Some of the technologies in EPA's SITE program are variations of well-
known, commercial technologies that have been demonstrated several times or even have been
applied in an actual cleanup. Because the SITE program information is widely distributed, it
appears to become a public relations opportunity for companies. Months or even years pass
before results from SITE demonstrations are made available to the public. Such long delays in
obtaining proof from a SITE demonstration might serve only to prolong the stigma attached to a
technology that continues to be considered innovative and unproven through such a delay.
No clear rules establish what constitutes proof of effectiveness of cleanup for ITTs: There is no
clear understanding of the amount and type of information that is considered reasonable proof of
effectiveness and reliability. The engineering aspect of technology selection can obscure
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fundamental goals for environmental protection, resulting in the rejection of ITTs that are
environmentally more effective than the approaches selected. The key problem is how to bridge
the gap among technology selection decisions and laboratory results.
Information about newer technologies is disseminated poorly: The latest technical information
about generic and specific cleanup technologies, their costs, and their performance and
implementation at sites is not well distributed. Therefore, the considerable experience gained
through private, state, and RCRA corrective action cleanups, as well as cleanups performed by
federal agencies other than the EPA may go untapped. The expanding reservoir of cleanup-
related R&D, including university work, is not shared effectively, as well. Transfer of
information and communication are key problems. For both the general public and individuals in
the Superfund workforce, it is difficult to cope with the flood of scientific and technological data
and details, which are increasing at a rapid rate as more vendors enter the market. But
technology development and the selection of technologies are crucial in making Superfund work
more effectively and efficiently.
Loyalty to existing technologies and inexperience in the workforce reduce the number of ITTs
selected for use in cleanups: Superfund contractors, their parent companies, or their
subsidiaries, often own cleanup equipment and technologies. Such a contractor may have a stake
in the adoption of a particular technology. EPA's remedial division, which should be performing
cleanups as dictated by the principles of the SARA, appears so wedded to architecture and
engineering (A&E) firms in developing RODs that it appears virtually impossible to get an ITT
accepted within any reasonable length of time.
Document No.: 3
Title: Workshop on Developing an Action Agenda for the Use of Innovative Remedial
Technologies by Consulting Engineers
Author/Sponsor: EPA
Publication Date: October 1990
Overview:
In October 1990, EPA's Technology Innovation Office (TIO), in conjunction with the National Advisory
Council on Environmental Policy and Technology (NACEPT), sponsored a workshop to develop an
action plan for addressing barriers that impede the use of ITTs to remediate soils and groundwater that
have been contaminated with hazardous waste. Participants in the workshop suggested actions that the
public and the private sectors can undertake to overcome barriers associated with availability of
information, training, professional development, regulatory uncertainty, and liability.
Statement of Problem:
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The lack of descriptive information and of data on the performance and cost of ITTs impedes the use of
those technologies. The R&D costs of bringing a technology from bench-scale to pilot-scale can be
prohibitive. The inconsistent and inconstant nature of regulations that govern the use of ITTs is a
disincentive to development. In the absence of cleanup standards, consulting engineers are reluctant to
use unproven ITTs because of liability considerations.
Barriers Identified in this Report:
The document identifies the following barriers to the adoption of ITTs:
It is difficult to extrapolate the applicability of the technology: Information obtained by testing a
technology at one site cannot be used easily at other sites because the combinations of wastes
and characteristics of sites vary significantly. There is a need to collect standardized data on
technologies and sites.
Data on technologies are unreliable: Consulting engineers are unwilling to assume the liability
associated with reliance on bench-scale data. Vendor data typically are based on tests conducted
under synthetic, and therefore unrealistic, conditions.
ITTs often are not considered until after the data collection phase of the remedial investigation,
leaving crucial gaps in the data necessary to evaluate the potential effectiveness of the
technology.
Schedules imposed by regulatory agencies do not allow the time necessary to investigate ITTs;
further, the preselection of remedial alternatives by agencies is a disincentive to such
investigation.
Communication among technology developers is not adequate to promote the development of
ITTs.
There is a shortage of available and accessible information about the full-scale implementation of
remediation projects: Data associated with the full-scale implementation of remediation technologies
often are not published because such information often cannot successfully pass through the peer
review process and because proprietary cost and performance data often are considered confidential.
The number of personnel qualified to develop and implement ITTs is inadequate: Universities
find it difficult to locate specific sites for conducting hazardous waste research projects, without
raising concern about liability.
The financial burden of conducting R&D necessary to bring an ITT to the pilot-scale stage can
be prohibitive: Under the SITE program, the entrepreneur waits too long to realize a return on
the investment in a technology.
It can be prohibitively time-consuming to meet regulatory requirements, and changes in
regulations discourage investment in specific technologies: The RCRA and Comprehensive
Environmental Response, Compensation, and Liability Act (CERCLA) programs take different
approaches to solving the same hazardous waste remediation problem. The new land disposal
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restrictions (LDR) are hampering cleanup activities. Current laws and regulations are inflexible
and impractical and do not promote the most effective remediation solutions.
In the absence of cleanup standards, consulting engineers are reluctant to use unproven ITTs
because of liability considerations: ITTs are by definition unproven, so there is a built-in bias to
prefer established technologies. Because there are no standard practices that guide risk
assessment and site remediation, engineers find it difficult to defend themselves against lawsuits
and prove to the public that they have met cleanup standards.
The fixed-price procurement process is inappropriate for the development of ITTs because the
technologies often require redesign: Costs associated with the uncertainty of technology are
magnified by the liability issue.
Activities to Address Existing Barriers:
The document identifies the following activities that are being or should be undertaken to address
barriers to the adoption of ITTs:
Develop a site classification program based on industrial activities, contaminants, and remedial
technologies, so that data on the performance of ITTs can be extrapolated more easily. Identify a
panel of experts for each type of technology to define the specific parameters to be used in
evaluating ITTs.
To alleviate the risk of depending on bench-scale data, evaluate tax incentives that reward the
client for taking risks by adopting innovative approaches. Establish independent organizations
responsible for setting criteria for judging the validity of data. Provide a facility at which
vendors of ITTs can perform pilot-scale tests to obtain data under any numerous but standard
conditions at a nominal cost.
Consider ITTs early in the remedial investigation stage when the data collection plan is
developed.
Provide incentives to make the release of information profitable to its owner. Start the peer
review process earlier in the remediation process.
Increase collaboration between universities and research institutes and consulting engineering
firms.
Take a more flexible approach to regulation by allowing the selection of a technology at different
stages of the remediation process and in the absence of a ROD.
The government should share in the exposure to liability arising from use of new and improved
technologies.
Document No.: 4
Title: Superfund: EPA Needs to Better Focus Cleanup Technology Development
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Author/Sponsor: U.S. General Accounting Office (GAO)
Publication Date: April 1993
Overview:
EPA established the SITE program in response to SARA, which required that the agency accelerate the
development of ITTs. ITTs are defined in SARA as treatment technologies for which adequate cost and
efficacy data are not yet available. The four components of the SITE program are:
The Demonstration Program, which publishes data on the cost, performance, reliability, and
applicability of selected ITTs after field demonstrations have been conducted
The Emerging Technologies Program, which provides financial assistance to developers of new
technologies that are undergoing laboratory tests
The Monitoring and Measurement Program, which tests new technologies to assess the nature
and extent of contamination at a site
The Technology Transfer Effort, which disseminates information gathered through the three
SITE programs to EPA regions, states, PRP, and Superfund contractors
Implementation figures indicate that there are 109 ITTs in the SITE program for which the program has
planned 117 field demonstrations. To date, SITE has initiated 74 field demonstrations. The number of
field demonstrations conducted each year has increased from three in 1987 to 32 in 1992.
EPA established TIO to increase the use of ITTs at contaminated sites by both government and industry.
TIO promotes increased flexibility in policies, permit requirements, state grants, and contracting
procedures. TIO also helps vendors of ITTs prepare cost and performance data for their technologies, as
well as disseminate information about those technologies.
TIO reports that ITTs have been selected for use in 228 remedial or removal cleanup actions, with the
annual number increasing from three in fiscal year (FY) 1984 to 68 in FY 1991. As of 1993, only 11
such remedial cleanup actions and 14 removal actions or 11 percent of the cleanup actions identified had
been completed.
This GAO study evaluates the effectiveness of the SITE and TIO initiatives.
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General Statement of Problem:
EPA has yet to develop a plan that sets priorities among cleanup needs. The agency's efforts fail to
target solicitation of technology development to meet needs in specific areas.
This GAO study evaluates the effectiveness of the SITE and TIO initiatives.
Barriers Identified in this Report:
The document identifies the following barriers to the adoption of ITTs:
EPA has not assessed systematically Superfund site cleanup needs and has had difficulty in
matching new technologies to the requirements of specific sites: EPA does not have an
automated cleanup remedy database that provides information about remedies by medium, cost,
and efficacy. Because systematic information about technologies used at Superfund sites is
lacking, EPA cannot inform potential developers or users fully, nor can the agency assess
effectively which technology needs should be addressed to reduce risks to human health or the
environment. When the SITE program attempts to solicit new technologies from developers and
vendors, its guidance is vague and does not identify specific needs. Therefore, solicitations are
not targeted to specific cleanup needs, thereby creating potential problems in selecting
technologies with a defined need. For example, EPA accepts technologies in search of an
application, rather than seeking solutions to site-specific problems (applications seeking
technologies). Under the SITE program, therefore, it is difficult to match technologies with sites
for field demonstration.
Lack of reliable data on the cost and efficacy of ITTs has led parties involved in cleanup to avoid
the use of such technologies to avoid the possible risks associated with those technologies: EPA
officials, PRPs, and potential investors all tend to be risk-averse in situations in which complete
information is not available. There are not always guarantees that ITTs will work effectively,
within the required schedule for meeting milestones, and be cost-competitive with currently
proven technologies. Although EPA has undertaken efforts to improve data on cost and efficacy
under the SITE program, the availability of substantive data remains limited. After a
demonstration has been completed, an average of 19 months passes before cost and performance
reports are published. It has been recommended that, to accelerate the process, EPA initiate
demonstrations that test more than one technology at a time and develop incentives that will lead
project managers to allow the use of their sites for such demonstrations.
Requirements for issuing permits, as well as regulations and agency policies, are barriers to the
development and use of ITTs: Regulations that are intended to protect human health and the
environment can preclude the use of promising new technologies for site cleanup by requiring a
permit application that includes data on performance and risk that have not yet been developed.
The time and cost associated with obtaining a testing permit (under RCRA) also is identified as a
barrier. Inconsistencies among guidance and regulations of federal, state, and local authorities
often increase the number of hurdles a developer of ITTs must overcome. Approval by one state
may not translate into acceptance by another state. The Federal Acquisition Regulation (FAR)
can discourage contractors from testing ITTs by prohibiting the contractors' subsequent
involvement in cleanup activities at the site at which the test was conducted. A contractor that
has tested a technology for EPA usually is prohibited for three years from working for the
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responsible parties. EPA is working to amend requirements under the FAR to allow exemptions
for the demonstration of ITTs. EPA has made, and will continue to make, reforms in regulations
and policies that will encourage parties to increase their research and development activities.
Further, a number of multiple federal facility sites and government research facilities will be
made available for the testing and evaluation of ITTs. Therefore, developers will be able to
conduct tests without obtaining the permits that would be necessary for activities conducted at
private property.
Activities EPA is Undertaking to Address Existing Barriers:
Efforts by TIO target the assessment of cleanup needs, the development and dissemination of data on
cost and efficacy, and the reduction or removal of barriers that arise from permit requirements and
regulatory procedures. But the report found that to date, efforts have been piecemeal, and a systematic
plan and strategy have been lacking.
Recommendations made in the report include the suggestion that TIO take a more systemic approach to
identify problems at sites, set priorities among cleanup technologies and research needs, and solicit the
development of specific technologies.
Conclusions:
The efforts of both TIO and the SITE program have contributed to increased development and selection
of ITTs. However, ITTs still cannot fulfill cleanup expectations reliably and cost-effectively. EPA could
take more steps to stimulate R&D, as well as the acceptance of new cleanup technologies on the part of
site managers and parties responsible for site cleanup.
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Document No.: 5
Title: National Environmental Technology Applications Center, The EPA Model for
Encouraging Private Investment in the DOE Environmental Market: A
Summary Report to the U.S. Department of Energy
Author/Sponsor: U.S. Environmental Protection Agency (EPA) and National Environmental
Technology Applications Center (NETAC)
Publication Date: September 1993
Overview:
Through an interagency agreement, DOE and EPA conducted a project under which they defined a model
for determining how private sector funds can be invested in cost-sharing agreements with DOE to
accelerate the development of technologies that have strong commercial potential in the DOE
environmental market. The primary impetus for the project was the need for safe, efficient, and cost-
effective technologies to clean up DOE's nuclear weapons complex. EPA's participation was motivated
by its interest in working cooperatively with DOE to facilitate site cleanups in a timely and
environmentally acceptable manner. DOE is endeavoring to establish even closer ties with other federal
agencies, Congress, state and local governments, universities, and other organizations, such as the
venture capital and financial community, that can help DOE achieve its cleanup objectives.
Interviews were conducted with more than 90 private investors, and discussions were held with investors
who participated in the Project Steering Committee that served the effort. The top five barriers to the
development and implementation of ITTs from the investors' perspective are identified.
Statement of Problem:
Private investors have shied away from the environmental technology market.
Barriers Identified in the Report:
The document identifies the following barriers to the adoption of ITTs:
The pathway to commercialization of environmental technologies is unpredictable: Investors
cannot predict project revenues for an environmental technology company because of uncertainty
in the marketplace. In the DOE marketplace, that uncertainty is increased further by a lack of
adequate and meaningful information from DOE (for example, information about planned
procurement outlays for environmental efforts at sites and timing of such efforts). Investors rely
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on such information to make informed investment decisions. In addition, there is a procurement
bias in favor of "tried and true" methods (rather than new methods). Technology users and
regulators prefer proven technologies even if they cost more than new technologies to
address environmental needs.
There is a pronounced lack of entrepreneurial management in small environmental technology
companies: Such companies generally have strong technical expertise but few business or
marketing skills that can facilitate development of a market-driven technology.
Inconsistent, multilevel permitting contributes to the unpredictability of the commercialization
pathway for environmental technologies: Requirements for multilevel approvals not only create
time-consuming and costly delays for technology companies and their investors, they also
fragment the market, creating numerous local markets another factor that has negative effects
on the ability of investors to project a company's revenue flow and capital needs. The regulatory
and permitting requirements, customer bases, and technology needs of the various local markets
may differ.
Potential liability (that is, strict liability) in the environmental industry, especially in the area of
site restoration and remediation, is of concern for the private sector: Strict liability, as defined
under CERCLA, is of concern. Another such concern is related to licensing and technology
transfer of internally developed technologies by large companies. As investors pointed out,
Fortune 100 corporations have developed numerous pollution control technologies primarily for
internal use. Those technologies may be useful solutions that can be marketed externally.
However, large corporations hesitate to license such technologies. Corporations fear potential
liability if harm or damage results from the use of a developed technology, since the corporation
may be perceived as a "deep pocket" source of funds to support the remediation of such
problems.
Performance data are incomplete and the criteria used to determine the success of a technology
are ill-defined: Technology developers usually have difficulty in obtaining access to
demonstration sites. If demonstrations are not conducted, developers, investors, regulators, and
potential users lack adequate data to evaluate a technology's real performance and economics. In
addition, to properly evaluate a technology, the criteria that define success must be established
and agreed upon up front.
Activities to Address Existing Barriers:
DOE developed a model, a six-step, market-driven process based on incentives, to encourage private
investment in the development, demonstration, testing, and commercialization of solutions that meet
DOE's environmental needs. The model is a mechanism for creating a predictable commercialization
pathway (that is, prediction of revenue flow) for private investment in environmental technology
companies. The six steps are:
Step 1: Identification of performance requirements
Step 2: Preparation of a request for proposal (RFP) for team technology demonstrations
Step 3: Formation of market-driven teams
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Step 4: Selection of teams
Step 5: Phased development, demonstration, and testing of teams' systems
Step 6: Award of DOE performance contracts to successful teams
Conclusions:
The document makes the following conclusions with respect to the barriers to the adoption of ITTs:
A pilot program must be implemented to validate and refine the model. The model complements
initiatives currently underway that could serve as opportunities to validate the model:
DOE's integrated demonstrations (ID)
DOE's environmental restoration management contracts (ERMC)
- Memorandum of agreement (MOU) with the Western Governors' Association
The model recommends that DOE continue to streamline and accelerate its procurement
processes.
The model recommends that an independent study be conducted to identify private-sector market
opportunities in the DOE environmental market.
The model recommends industry-driven conferences and publications to communicate DOE's
environmental needs and EPA's participation in cooperatively working with DOE to clean up its
sites.
The time frame for Step 5 under the model ~ three to three and one-half years - appears to favor
technologies in the later stages of development.
The model encourages the market-driven identification of commercially viable technologies for
the DOE environmental market. The model motivates the private sector to identify those
technologies and technology companies that offer safe, efficient, and cost-effective solutions.
Those benefits extend to all environmental technology companies that participate in
implementation of the model.
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Document No.: 6
Title: Management Changes Needed to Expand Use of Innovative Cleanup Technologies
(for DOE)
Author/Sponsor: GAO
Publication Date: August 1994
Overview:
Over the past 40 years, DOE and its predecessor agency disposed of more than one billion cubic feet of
hazardous or radioactive material at facilities around the country. Contamination of soil and groundwater
is now widespread, and more than 5,700 individual contaminated plumes have been identified on DOE
lands. In 1989, DOE established the Office of Technology Development (OTD), with the goal of
ensuring that cleanup technology is developed to the stage at which it can be commercialized and,
therefore be made available in the private sector. OTD's mission is to fund a variety of projects that
demonstrate the potential of new and improved approaches to cleanup problems. OTD supports work in
the Office of Environmental Management, which in turn works with EPA to identify and select the most
appropriate technologies and to set milestones for completing cleanup work.
Statement of Problem:
Although OTD has conducted several demonstration projects to show the effectiveness of innovative
approaches to cleanup, new technologies are not being considered seriously for use in cleaning up DOE
sites. DOE has received $23 billion for environmental management since 1989; yet, little cleanup has
been completed. Only about six percent of DOE's contaminated sites have been cleaned up or closed.
Barriers Identified in this Report:
The document identifies the following barriers to the adoption of ITTs:
Local officials fear that the use of new technologies may cause projects to miss milestones,
should the technology fail: DOE is under pressure to meet its scheduled milestones and the
expected cleanup pace is set to accelerate over the next few years. Public frustration often
results when regulators allow DOE to miss cleanup milestones. However, regulators also note
that their hesitancy to appear too lenient with DOE may not be as widespread as perceived. They
point to several regulatory options that would allow the agency to use ITTs in combination with
conventional techniques to meet milestones effectively. For example, in January 1994, EPA
published the guidance Technology Innovation Strategy (EPA 543-K-93-002), which was
designed to stimulate the adoption of new technologies by streamlining incentives for innovation
and reducing barriers in the regulatory framework.
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Conflicting priorities among stakeholders tend to prevent the approval of innovative approaches
to site cleanup: For example, local governments may place a high priority on economic
development and job creation and view faster cleanup as a threat to local economies. The public
is primarily concerned about risks associated with the cleanup process. Therefore, the various
stakeholders tend to view innovative approaches differently. Accordingly, DOE must balance
the interests of those diverse stakeholder groups.
Field officials, as well as local stakeholders, may not be familiar with newer technologies that
might be appropriate for their sites: If there is no incentive to innovate, field officials believe
that there is no need to increase the uncertainty related to the performance and cost of a remedy
by adopting an innovative technology. Stakeholders might associate the newer technologies with
an unacceptable level of risk; they might be said to be risk-averse. (The report refers to the GAO
report Superfund: EPA Needs to Better Focus Cleanup Technology Development)
Field officials often rely on the recommendations ofon-site contractors at the site who may favor
particular technologies because of their own experience with them and investments in them:
DOE long has been criticized for its extensive reliance on contractors for technical decision-
making. Contractors also tend to favor established technologies, in part because of the additional
capital costs associated with the use of a new technology.
Program officers do not always work together effectively: Lack of internal coordination has
prevented the agency from maximizing investments in ITTs. Individual DOE offices have not
worked together as a well-coordinated and integrated unit to overcome resistance to the use of
new technology, nor have offices worked together to develop a comprehensive assessment of
technology needs. DOE explained that OTD develops technologies for problems that are
common within the DOE complex, while program offices develop technologies that address
problems at specific sites. The analysis revealed no clear distinctions among projects and little
coordination among offices regarding the scope and objectives of projects.
DOE does not have a comprehensive needs assessment through which technology development
projects can be ranked and funded in the most effective way: An initial description of needs
completed in 1991 did not indicate specific needs for technology development. In many
locations, DOE field officials are studying specific cleanup needs for their particular site.
Therefore, field offices may not be developing technologies that can be considered most
appropriate from an agency-wide perspective.
OTD's technical experts do not play a role in the formal decision-making process through which
technology choices are made: For example, OTD does not have a role in negotiating agreements
for cleanup milestones. In the absence of OTD's involvement at such key points, the full range
of technology choices is not likely to be evaluated throughly.
Activities DOE is Undertaking to Address Existing Barriers:
The document identifies the following activities that are being or should be undertaken to address the
barriers to the adoption of ITTs:
In January 1994, DOE began restructuring its technology development program. The activities
related to the technology development program conducted by the Offices of Waste Management,
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Environmental Restoration, and Technology Development were to be managed centrally and
directed by OTD.
Five priorities for technology development have been established: remediation of tanks
containing high-level waste; characterization, treatment, and disposal of mixed waste; cleanup of
contaminated plumes; stabilization of landfills; and decommissioning and final disposition of
DOE facilities. Implementation teams are being established for the five priorities to facilitate the
use of ITTs. The teams will be made up of representatives of headquarters, selected regulators,
and field users.
The DOE peer review process and performance measurement criteria are being modified to
reflect the five priority areas.
In a July 1993 policy statement, DOE's Office of Environmental Restoration directed its field
staff to consider new and ITTs early in the process of selecting cleanup procedures.
DOE also is expanding research outreach to help ensure that the technology development efforts
of agencies are coordinated closely to maximize benefits and reduce costs.
Conclusions:
Although DOE's new strategy should help correct coordination problems, insufficient emphasis is placed
on ensuring that parties at all levels are aware of innovations in remediation technology. The roles of
stakeholders must be clarified, so that more new technologies can be selected. The strategy also fails to
link technology experts with field decision makers. DOE's new approach does not overcome
contractors' resistance to recommending technologies with which they are unfamiliar.
Document No.: 7
Title: Progress in Reducing Impediments to the Use of Innovative Remediation
Technology
Author/Sponsor: EPA
Publication Date: June 1995
Overview:
TIO was created in April 1990 to act as an advocate for new treatment technologies. Because of its small
size, TIO has relied on cooperative ventures with partners both within and outside EPA, to maximize the
impact of available resources to enhance the state of remediation technology.
The report identifies changes EPA and TIO have made to advance or promote information sharing about
and the demonstration and actual use of ITTs. The report identifies four categories of efforts and lists 54
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actions that EPA has taken to change its approach to the development of ITTs. The four major
categories, as well as examples of the steps taken, are listed below:
Policy and regulatory improvements: For example, the Revision to the Treatability Study
Sample Exclusion Rule (59 Federal Register [F.R.] 8362), promulgated in February 1994, is
intended to increase the limits on the quantities of contaminated media used in treatability studies
that may be conditionally exempt from permitting and manifest requirements under RCRA so
that large-scale demonstration testing may be conducted. Another example of policy and
regulatory improvements is OSWER Directive 9380.017FS, issued in August 1991, which
encourages reasonable risk-taking in selecting treatment technologies, requires that ITTs be
considered routinely as treatment options, and establishes incentives for more frequent use of
ITTs.
Improvements in research, development, and demonstration: For example, TIO worked with
EPA's Office of Research and Development (ORD) to organize the Remedial Technologies
Development Forum (RTDF), which encourages collaboration among companies, public interest
groups, states, universities, DOE, and the U.S. Department of Defense (DoD) in defining, setting
priorities among, and funding new, untried concepts for cleanup technologies to promote
coordination and eliminate duplicative research and development. Another EPA effort to
promote improvements in research, development, and demonstration was the establishment of a
Groundwater Remediation Technologies Analysis Center (GWRTAC), which tracks ongoing
groundwater research and development, promotes coordination of the activities of public and
private research groups, and encourages the demonstration of promising remediation
technologies.
Improvements in information-sharing: For example, OSWER published 37 case study reports of
cleanups. These reports were prepared by the Federal Remediation Technologies Roundtable
(FRTR) in a four-volume publication. In another example, OSWER developed and maintained
the Vendor Information System for Innovative Treatment Technologies (VISITT), which
provides current information about vendors of ITTs, their products, and their capabilities. As of
1994, the VISITT database included information about 277 technologies offered by 171
developers and vendors, and the system had been accessed by more than 10,000 users in more
than 60 countries. OSWER also developed and enhanced EPA's Clean-Up Information (CLU-
IN) electronic bulletin board to provide up-to-date information on ITTs to hazardous waste
professionals.
Improvements in training: For example, TIO developed and continues to operate the CERCLA
Education Center (CEC), a unique training forum that provides basic and advanced training on
the laws, regulations, and processes that make up the Superfund program to on-scene
coordinators, remedial project managers, site assessment managers, and other Superfund staff.
Conclusions:
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TIO recognizes that there are significant barriers that impede the proliferation of ITTs. TIO continues to
strive to overcome those barriers to promote the supply of technologies and information to the market to
expedite the cleanup of the nation's waste sites.
Document No.: 8
Title: Forum on Eliminating Barriers to Innovative Technology Implementation
Author/Sponsor: DOE and the Hazardous Waste Action Coalition (HWAC)
Publication Date: June 1995
Overview:
The Joint Forum on Eliminating Barriers to Technical Innovation in Remediation first convened on June
14, 1995. The forum was sponsored jointly by DOE and the HWAC, an association that represents the
community of engineering and science firms that have expertise in the cleanup of hazardous and nuclear
waste. The primary purpose of the forum was to convene key stakeholders to identify specific barriers to
technical innovation and develop approaches to address those barriers.
The forum focused on efforts to:
Assess and set priorities among barriers to innovation previously identified in earlier forums and
pre-workshop activities
Identify short-term action plans to address specific barriers to innovation
Barriers Identified in the Report:
The document identifies the following barriers to the adoption of ITTs:
Absence of verified and validated information for ITTs: There is no overall system for
addressing the absence of validated cost and performance data for technical issues relevant to a
specific remediation project. There is a need for validated cost and performance data for specific
technologies. Experiences of entities other than DOE are relevant to the effort to overcome the
general lack of technology verification and validation. Data obtained by the effort would prove
valuable in technology verification and validation.
Environmental restoration, relative to other construction activities, is perceived to be risky from
a financial and liability perspective, and results are considered unpredictable. Technologies
that involve less risk to environmental restoration projects are inherently more attractive than
ITTs. ITTs for which there are no established and documented performance histories therefore
are not widely utilized.
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Developers oflTTs and potential users of such technologies do not communicate well. The
respective needs of technology developers and users differ significantly. Developers need
opportunities and funding to apply their solutions without incurring unacceptable risks to
themselves, yet maintain their proprietary rights. Users must achieve tangible results with
predictable cost and performance in a very risky environment.
Activities to Address Existing Barriers:
DOE has made a commitment to innovative remediation and has recognized the need for cooperation and
the development of partnerships between DOE and its stakeholders to promote technical innovation in
remediation.
Conclusions:
The document makes the following conclusions or recommendations with respect to the barriers to the
adoption of ITTs:
Develop a strategic approach to technology validation and verification that is based upon an
existing state model (California).
Adopt a systematic, program-wide strategic approach to innovative remediation that specifies
development of local plans to clearly identify issues related to risk in operation effectiveness,
stakeholder concerns, logistics, and economics.
Modify contracting practices to permit multi-site and other contracting mechanisms to apply
successful ITTs to numerous DOE sites under the same contract.
Modify the 'risk' provisions of contracts to provide incentives to apply ITTs, and remove or
reduce contractual disincentives to innovation.
Increase awareness within the DOE community of the regulatory flexibility currently exhibited
by EPA.
Increase the use of performance-based RODs and interim response actions to reduce the
uncertainty associated with cleanups before adopting an ITT.
Document No.: 9
Title: Innovations in Groundwater and Soil Cleanup: From Concept to
Commercialization
Author/Sponsor: National Research Council (NRC)
Publication Date: 1997
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Overview:
During the 1990s, as the limitations of conventional subsurface remediation technologies have become
increasingly clear, the use of ITTs has become increasingly common in the cleanup of contaminated soil
and of leaking underground storage tanks that contain petroleum products. However, ITTs are used only
rarely for cleaning up groundwater at major contaminated sites regulated by the Superfund and RCRA
programs.
Statement of Problem:
Since the late 1980s, reports prepared by a number of organizations have indicated that there are
significant barriers to the development of remediation technologies for commercial markets. Barriers to
the use of ITTs are complex and range from the inherent variability of the subsurface environment to
regulatory obstacles, conservatism on the part of owners of hazardous waste sites and their consultants,
and lack of reliable data on technology performance.
Much of this report focuses on developing credible data sets that can be used to compare ITTs with
conventional ones and to transfer technology used at one site to another site without repeating all
elements of testing performed for the site at which the technology was applied.
Barriers Identified in the Report:
The document identifies the following barriers to the adoption of ITTs:
The remediation technology market is fragmented by client type and by site type: Clients can be
grouped into two categories: (1) the private sector, including companies representing a broad
range of types and sizes, and (2) the public sector, including federal agencies. Within the private
sector market, there is wide variation by type of client and size of site. Similarly, the
characteristics of the public-sector market vary because of the significant differences among the
agencies responsible for contaminated sites. Further complicating matters, clients usually are
represented by consultants that may have their own concerns about the performance of ITTs. A
much more difficult problem for remediation technology vendors is the fragmentation of the
remediation market according to type of site. A technology that works well for cleaning up a
particular contaminant in a particular geologic setting may not work at all when applied to the
same contaminant in a different geologic setting. When a new technology is offered to the client,
it must be accompanied by technical expertise on applying the system in the setting of the
particular client's site of concern.
The regulatory structure for implementing hazardous waste cleanups, especially at Superfund
and RCRA sites, has added to the inherent difficulties that vendors of ITTs face in bringing new
products to the market: The two programs rely on regulatory push rather than market pull to
create demand. The process of technology selection is regulated strictly and the penalties for
failing to initiate remediation promptly are insufficient.
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In many cases, it is less costly to a company to delay remediation through litigation than to
select a technology and begin cleanup: The incentive to delay, rather than begin, cleanup
reduces market demand for remediation technologies, including ITTs. Economic incentives for
carrying out remediation are lacking under current policies. Companies perceive remediation as
a tax on earnings and a bottom line deduction, rather than as an activity undertaken in the
company's economic self interest. Companies frequently do not report liabilities related to
environmental cleanup on their corporate balance sheets; therefore, there is no economic
incentive to improve remediation. If a company were to assess voluntarily all its future
remediation costs and post the total on its balance sheet, the value of the company would be
reduced, creating a disadvantage relative to companies that do not report such liability.
The time line for selecting and installing a remediation technology can be very long and can
vary unpredictably from site to site: This circumstance is caused by the incentives to delay
remediation and in part by the long series of regulatory steps involved in selecting a cleanup
remedy for a site. Because of unpredictable time delays technology developers and investors
find it difficult to forecast cash flow, resulting in serious financial difficulties for technology
providers that are of great concern to investors.
Private-sector companies can be hesitant to share information about their contaminated sites:
Because of this lack of information-sharing, technology vendors find it difficult to predict the
potential size of the market for their product and to establish sites to which they can refer future
clients for evidence of the technology's performance.
Conclusions:
The document makes the following conclusions with respect to the barriers to the adoption of ITTs:
Economic incentives for remediation must be created. If customers derived financial value and
economic differentiation from improved remediation and accelerated cleanup, they would
perceive remediation as an activity worth pursuing in part based on their own self-interest.
Enforcement of regulations must be more consistent. It is imperative to have a predictable,
known, and consistent enforcement mechanisms, accompanied by severe penalties. Lacking
sufficient enforcement and penalties for noncompliance, the system rewards those who delay.
The regulatory process for selecting cleanup goals and remediation technologies should be more
predictable. For example, the detailed steps in selecting remedies for two different sites that
have similar geophysical characteristics and contaminants should be similar, regardless of the
regulatory program under which the sites are being cleaned up or the EPA office responsible for
overseeing the cleanup. EPA should conduct a detailed review of remedy selection procedures at
Superfund and RCRA sites in its 10 regions. Using the results of that review, EPA should
identify the degree to which the procedures vary and should recommend steps for making the
process more consistent. EPA also should consider whether the establishment of national
cleanup standards for groundwater and soil would enhance the cleanup process by providing
greater consistency. In addition, EPA should develop guidelines that would establish tentative
time lines for reaching the various regulatory milestones at sites of various degrees of
complexity. Such guidelines would assist technology developers in anticipating with greater
certainty how long they might have to wait before they receive a job contract.
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Customers must have the freedom to choose any remediation technology or group of
technologies they desire to meet the required cleanup standards. Regulators should be indifferent
about how a company or federal agency cleans up a site, as long as the regulatory requirements
for risk reduction are met. Current regulatory preapproval of remediation technologies should be
curtailed. GAO should examine the program of the state of Massachusetts under which licensed
site professionals select remediation technologies on behalf of environmental regulators and
should recommend whether such a program should be implemented nationwide.
Complete information about the size and nature of all sectors of the remediation market must be
made available. Companies, as well as government agencies, should be required to disclose fully
information about all contaminated sites that exceed a given size or pose a risk greater than an
established level. EPA could use such information to develop a national registry of contaminated
sites.
More opportunities should be created to test ITTs and verify their performance. Programs that
encourage the testing of ITTs should be given high priority. Further, a coordinated program is
needed for formally verifying remediation technology performance. Official, federally-
sanctioned verification of the performance of technologies provides customers with assurance
that performance data on new technologies are valid and representative of the expected
performance of the technology. Verification of performance also could reduce regulatory
barriers, expedite the entry of technologies into the market, and facilitate the raising of capital
needed to commercialize new technologies.
Document No.: 10
Title: Impediments to Deploying Technologies at DOE Sites and Their Solutions,
Getting the "Right Technology at the Right Site at the Right Time "
Author/Sponsor: DOE
Publication Date: 1998
Overview:
This report examines problems and commonly proposed solutions related to barriers to implementing
improved technologies in the DOE Environmental Management program. The problems discussed in the
report were identified over the four years preceding its publication. Many of the barriers are being
addressed by recently instituted initiatives in the Office of Environmental Restoration and the Office of
Science and Technology.
Statement of Problem:
DOE's technology problems related to remediation technologies arose because the agency lacked a well-
coordinated and fully integrated technology development and deployment program. The agency's
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technology needs have not been comprehensively identified to support prudent decisions about research,
nor have the various environmental management program offices in headquarters and in the field worked
together effectively to identify and evaluate all the possible technology solutions available. Further,
internal decision-making processes have prevented a full discussion of opportunities for the application
of new and promising technologies in environmental cleanup and waste management activities.
Barriers Identified in the Report:
The document identifies the following categories of barriers to the adoption of ITTs:
Attitudinal barriers: The federal budget process discourages rapid cleanup efforts because
funding allocated to sites decreases as cleanup progresses. There is little incentive to complete
projects as quickly and cost-effectively as might be possible. Adverse effects of new
technologies on employment are perceived by many as a disincentive to their use. A significant
disincentive is the "not invented here" attitude toward outside technologies, which is evident
within DOE and reflected in resource allocations.
Management barriers: Rigid management hierarchy and bureaucracy tend to encourage
continuation of the 'status quo.' Flexibility of senior management and acceptance of
responsibility on the part of lower management and staff are crucial to the implementation of
new ideas and procedures and to the reduction of impediments to the deployment of innovative
and improved technologies at DOE sites.
Technical barriers: The lack of a third-party process for the verification and validation of data
on performance and cost of specific applications is a perceived limit on DOE's ability to
implement new technologies.
Lack of teamwork and coordination: Two significant disincentives to the development and
implementation of ITTs are the lack of cooperation by regulatory agencies and the lack of
acceptance on the part of stakeholders:
The lack of uniform interstate regulatory acceptance results in increased costs and delays
during the process of developing and implementing ITTs. In the absence of a national
process, technologies must be demonstrated repeatedly, and requirements vary from
demonstration to demonstration. Further, regulators in each state must scrutinize the
details of performance claims carefully before they approve each proposed
implementation.
Lack of acceptance on the part of stakeholders slows both the development and the
implementation of ITTs.
Lack of communication: Knowledge is not shared within the DOE complex, among DOE
organizations, among DOE and industry, or among DOE and regulators.
Perception of the environmental market as a high risk market: A leading disincentive is the
perception of high risk associated with uncertainties in the environmental management market.
The perception of high risk is found throughout the environmental market and has brought about
the widely discussed lower-than-expected investment in the development and commercialization
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of new technologies. Factors that contribute to the perception include: (1) the lack of definition
of the environmental management market and its submarkets, (2) the lack of specific
performance requirements, and (3) the lack of award incentives based on early competition in
production design.
Procurement barriers: Two significant obstacles prevent procurement and large-scale use of the
services of technology providers by DOE: (1) lack of such service providers and (2) lack of
economic incentives. There are other barriers, as well, including:
- It is difficult to entice vendors to develop technologies that have limited applicability
outside DOE
- Contracts do not provide incentives or reward risk-taking
- States and other stakeholders are reluctant to turn over some efforts to private industry
- The DOE procurement process is time- and resource-intensive
- It is difficult to identify contract opportunities with DOE, particularly for smaller
companies
Budget process barriers: Only a very small portion of the entire life cycle of a project is taken
into consideration when remediation alternatives are compared. The R&D cycle, which may take
5 to 10 years, is not aligned with the appropriations cycle for DOE R&D programs. The
appropriations process creates significant uncertainty about the timing and level of funding
available for the management of environmental problems at individual DOE sites. Therefore,
even though the technology base may have been developed on schedule to enable cleanup on
time and within projected limits, adequate funds may not be appropriated. This disincentive
combines with inefficiencies in procurement to create significant additional uncertainties that
increase investors perception of risk in the DOE market.
Regulatory Barriers: While it may be the policy of regulators to promote the use of ITTs, the
practice is perceived by the regulated community to be quite different. The requirements that
technology providers and DOE perform a full demonstration in each state in which a technology
is under consideration is a financial disincentive to the use of the technology. In addition, the
inconsistent, multi-level permitting and regulatory process, from state to state and from regulator
to regulator, and inconsistent regulatory enforcement preclude large-scale implementation of
ITTs. Inability or reluctance to use the full flexibility of environmental statutes limits the ability
to use performance-based contracting to identify the best remediation strategy. Because of strict
liability under CERCLA, responsible parties are very selective about cleanup technologies, often
opting for more proven methods even if those methods are more costly. Other barriers include
regulators' lack of knowledge about new technologies, conflicting perceptions on the part of
regulators, lack of urgent regulatory requirements or drivers, excessive cost of compliance with
DOE orders, issues related to allocation of liability and indemnification, and the reluctance of
regulators to appear too lenient with DOE.
Conclusions:
Although over the past few years, ITTs have been incorporated into the remedy selection process, very
few such technologies have been selected as cleanup options. To promote the evaluation and selection of
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ITTs, incentives must be provided. DOE's Office of Environmental Restoration has initiated an effort to
work with industry to identify incentives, as well as candidate sites for application of ITTs.
Regulators and stakeholders often do not accept an innovative technology as the chosen remedy because
detailed documentation is not available to certify and validate its cost and performance. Therefore, it is
important that cost and performance information about ITTs be collected and published.
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APPENDIX B
LIST OF OTHER DOCUMENTS REVIEWED FOR THIS STUDY
Documents that discuss innovative environmental technologies ~ Of the 33 documents subjected to
preliminary reviews for this study, 12 discuss the barriers to innovative environmental technologies. For
the most part, these documents address issues related to a wide variety of environmental technologies.
Some mention of the innovative treatment technologies (ITT) market can be found, but ITTs are not
necessarily the main focus of the documents. The 12 documents are listed below:
Barriers to Environmental Technology Innovation and Use; Research Report; Funded by the Joyce
Foundation and the U.S. Environmental Protection Agency (Cooperative Agreement); Prepared by the
Environmental Law Institute; January 1998.
Bridge to a Sustainable Future: National Environmental Technology Strategy; National Science and
Technology Council; April 1995.
Bridging the Valley of Death: Financing Technology for a Sustainable Future; Funded by and Prepared
for the U.S. Environmental Protection Agency (Interagency Agreement); Prepared by the U.S. Small
Business Administration; December 1994.
Environmental Technology Initiative: FY 1994 - FY 1995 Projects, Removing Barriers to Innovations
That Protect Public Health and the Environment (EPA 238-R-96-001); U.S. Environmental Protection
Agency and Innovative Technology Council; July 1997.
Improving Technology Diffusion for Environmental Protection, Report and Recommendations of the
Technology Innovation and Economics Committee; Prepared for the U.S. Environmental Protection
Agency; Prepared by the National Advisory Council for Environmental Policy and Technology
(NACEPT); October 1992.
Incentives and Barriers to Commercializing Environmental Technologies, Results of an Environmental
Technology Market Needs Assessment; Prepared for the U.S. Environmental Protection Agency, Office
of Research and Development; Prepared by the National Environmental Technology Applications
Corporation, University of Pittsburgh Trust, Pittsburgh, Pennsylvania; March 1990.
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National Environmental Technology Strategy: Status & Action; 3rd Annual Private Enterprise
Government Interaction (PEGI) Roundtable Conference; PEGI Task Group Committee on Environment
and Natural Resources; Rosslyn, Virginia; November 7, 1995.
Report on Barriers to Pollution Prevention; Minnesota Office of Waste Management; March 1991.
Stakeholder Attitudes on the Barriers to Innovative Environmental Technologies; Funded by the U.S.
Environmental Protection Agency (Cooperative Agreement); Prepared by Abt Associates, Inc. with the
collaboration of the Environmental Law Institute; January 1998.
Technology for a Sustainable Future: A Framework for Action; National Science and Technology
Council.
Transforming Environmental Permitting and Compliance Policies to Promote Pollution Prevention,
Removing Barriers and Providing Incentives to Foster Technology Innovation, Economic Productivity,
and Environmental Protection; Prepared for the U.S. Environmental Protection Agency; Prepared by
NACEPT's Technology Innovation and Economics Committee; April 1993.
White House Conference on Environmental Technology (working papers); Washington, B.C.; December
11-13, 1994.
Documents or information sources that contained little or no information about barriers to
innovative environmental technologies or ITTs ~ Nine of the 33 documents contained general
information on barriers to innovative environmental technologies and ITTs, but minimal information
directly related to barriers to their development and use. The nine documents and web sites are listed
below:
Cleaning Up the Nation's Waste Sites: Markets and Technology Trends, 1996 Edition (EPA 542-R-96-
005); U.S. Environmental Protection Agency, Office of Solid Waste and Emergency Response; April
1997.
Environmental Technology Verification Program Verification Strategy (EPA/600/K-96/003); U.S.
Environmental Protection Agency, Office of Research and Development; February 1997.
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Regulatory Barriers to Pollution Prevention: A Position Paper of the Implementation Council of the
American Institute for Pollution Prevention; Prepared for the U.S. Environmental Protection Agency,
Risk Reduction Engineering Laboratory, Cincinnati, Ohio; Prepared by the Aluminum Company of
America; 1991.
Summary of Treatment Technology Effectiveness for Contaminated Soil (9355.4-06); U.S. Environmental
Protection Agency, Office of Solid Waste and Emergency Response; June 1990.
Environmental Technology Initiative; http://www.gnet.org/eti/abouteti.htm
National Environmental Technology Test Sites (NETTS) Program;
http://www.serdp.gov/netts/default.html
Reinvention for ITTs (ReflT); http://www.wpi.org/epa/refit/
Resolving Barriers to Soil Treatment: Session Output and Analysis; Concurrent Session, 7th National
TIE Workshop; April 1995; http://www.em.doe.gov/tie/sum955a.html
White House Conference on Environmental Technology; http://es.epa.gov/program/exec/techconf.html
Document that summarized "barrier studies" ~ Two documents presented a review of other studies
on barriers to ITTs, but provided little new information on the subject. These documents were:
Summary of Barrier Studies and Examples of Technology Programs for Development of Innovative
Remedial Technologies; Miljostyrelsen (National Environmental Protection Agency, Denmark); May
1997.
Hard Times for Innovative Cleanup Technology; Environmental Science and Technology (ES&T);
December 1997.
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APPENDIX C
LIMITATIONS OF THE STUDY AND ANALYSIS
While each of the documents used for this report describes specific barriers to the development and use
of innovative treatment technologies (ITT), the documents do not establish priorities among those
barriers in terms of the significance of their effects on the development and use of ITTs. Most of the
documents reviewed for this report do not provide insight into which of the barriers might be easiest to
resolve. Some of the documents, however, do identify or recommend potential approaches to the
removal or reduction of the barriers identified. Such recommendations are provided throughout this
report, but are not subjected to detailed analysis.
Of the 10 documents reviewed for this report, four pertain specifically to the use of ITTs in the U.S.
Department of Energy (DOE) environmental remediation market segment. However, the types of
barriers encountered in using ITTs in the DOE environmental market largely are relevant to the use of
ITTs in other market segments. In fact, in its report for DOE, Management Changes Needed to Expand
Use of Innovative Cleanup Technologies, the U.S. General Accounting Office (GAO) states that those
barriers identified that pertain to DOE are similar to those that inhibit the use of ITTs by other
government agencies, and particularly by EPA.
The analyses presented in this report are subject to the following limitations:
1) Of the 10 documents reviewed for the study, five pertain specifically to the use of ITTs in the
U.S. Department of Energy (DOE) environmental remediation market. The types of barriers
encountered in using ITTs in the DOE environmental market also may be relevant to the use of
ITTs in other markets. Nevertheless, because of the number of the documents reviewed that
address the DOE market, the findings presented in this study might be biased toward the
identification of barriers that pertain to that market.
2) No analysis at the state level could be performed for the study because none of the documents
used for the study address barriers that are unique to individual states. Because state agencies
frequently determine whether ITTs meet performance and cleanup standards, the absence of a
comparative analysis of barriers introduced by the various regulations and standards imposed by
state agencies is a limitation to this study.
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3) The barriers identified in the study are grouped in four categories: institutional; regulatory and
legislative; technical; and economic and financial. Each barrier was assigned to only one
category. However, because the categories are broad and at times may overlap, it is likely that
certain barriers easily could fit into more than one category.
4) Because this report was written based on information obtained from other sources, access to the
original data was not possible. Therefore, it is assumed that publication dates (ranging from
1985 to 1998) of the sources used indicate that the barriers which the publications discuss were
in fact barriers to developing and using ITTs at the time of publication.
5) For some barriers, no specific initiative addressing them was identified in the source documents
or developers' guide reviewed for this analysis. It is important to note that the list of initiatives
and programs provided in Table 4-1 is not comprehensive and initiatives or policies may exist
that address these barriers.
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