EPA-SAB-EEC92-026
Unted SutM Sctanc* Advisory EPA-SAB-CEC-92-026
Environmental Board (A-101) September 1992
Protection Agency
vvEPA AN SAB REPORT: REVIEW
OF BIOREMEDIATION
RESEARCH PROGRAM
^K!nS'TRATEGY
AGENCY
DALLAS. TEXAS
THE OFFICE OF
RESEARCH AND
DEVELOPMENT'S
BIOREMEDIATION RESEARCH
PROGRAM STRATEGY
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON D.C. 20460
September 9, 1992
OFFICE OF
THE ADMINISTRATOR
SCIENCE ADVISORY BOARD
EPA-SAB-EEC-92-026
Honorable William K. Reilly
Administrator
U.S. Environmental Protection Agency
401 M Street, SW
Washington, D.C. 20460
Subject: Science Advisory Board Report on Review of ORD's
Draft "Bioremediation Research Program Strategy"
Dear Mr. Reilly:
The Science Advisory Board (SAB) has completed its review of the Office of
Research and Development's (ORD) "Bioremediation Research Program Strategy"
(December 1991 Draft) and is pleased to submit this report. On February 10 and 11, 1992,
the Bioremediation Research Review Subcommittee (BRRS) of the SAB's Environmental
Engineering Committee reviewed the draft document, received extensive briefings from
research managers and scientists who developed the document, debated technical arguments,
and offered advice to ORD on this promising remediation technology.
Our findings and recommendations are aimed at improving the current Bioremediation
Research Program Strategy document (hereafter referred to as the Strategy Document). We
are pleased to see the broad Agency and inter-laboratory participation in this research
planning effort, which led to the development of a comprehensive document that clearly
contains the considered thoughts of a talented group of scientists and engineers. We draw
your attention and look forward to a response in particular on the following highlighted
findings and recommendations:
1) The BRRS found that the strategy presented in the draft document, which is
interactively driven by actual assessment of site conditions and knowledge
gaps, to be useful and basically sound in concept and commend the Agency on
the team approach used to address the topic. This site-directed approach is
fundamental to development of all bioremediation strategies and will help
determine whether any generic approaches are feasible.
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2) The BRRS stressed that, while the strategy has many good features, the draft
document and the entire bioremediation research program could benefit greatly
from a more explicit treatment of the strategic planning process. To be
specific, the Strategy Document should be more sharply focused and integrated
by employment of a rigorous strategic planning process. A clear vision
statement of EPA's role in bioremediation, combined with critical assessment
of the state-of-the-science and technology, would lead to a more defined
concept of the research program needed to further the Agency's mission in this
important field. The Administrator may wish to provide such guidance to
others in the Agency for development of their strategic plans.
3) A sharpened focus for the program should lead to development of better
mechanisms of program outreach, inter-agency coordination, and leveraging to
maximize the benefits of EPA's resources in the bioremediation field. The
EPA bioremediation strategy needs to recognize other EPA research, as well
as have an "open windows policy" to reach out to and keep abreast of new
developments in the field. In particular, there is a need to coordinate with
other governmental agencies, as well as with the private sector regarding the
critical engineering aspects of bioremediation.
4) The Strategy Document should include information which pays attention to the
current regulatory framework in which the technology must be used and
applied. Regulatory roadblocks can preclude bioremediation as a technology
of choice, and need some attention in the document. This information would
be helpful both to the Agency and the regulated community.
5) The Strategy Document should include greater attention and progressive effort
to meet the needs of the user community — those that apply bioremediation
for environmental cleanup.
6) Bioavailability is a major factor limiting wide-scale application of
bioremediation technologies. There is a need to conduct research to
understand the physical-chemical changes that affect bioavailability of chemical
pollutants including mixtures, in order to develop more effective
bioremediation technologies.
7) A clearer identification of waste types as to contained chemicals will improve
the understanding of the Strategy Document and how the actions relate to
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existing problems. It is exposure to the chemicals in the wastes that cause the
adverse effect to human health and the environment.
8) Budget information is included in the Strategy Document, but the BRRS
believes that funding available is inadequate to support effective
implementations of the proposed Bioremediation Research Program Strategy.
It is therefore essential for EPA to pursue both Agency-wide and government-
wide planning and coordination in this important area of bioremediation
research and technology development.
9) Concepts related to performance evaluation of an on-going bioremediation field
project should be expanded; and toxicity issues associated with bioremediation
should be focused on real-world pilot and field situations and not on possible
secondary by-products that may not occur or may occur only in special
situations or exceptions.
10) Specific criteria to measure progress and success of bioremediation research
and technology development are needed.
The SAB has offered a series of broad-ranging and specific programmatic
recommendations to enhance the quality and usefulness of the Strategic Document. We are
pleased to have had this opportunity to be of service to the Agency. We trust that these
comments will help in your guidance of this important program and look forward to your
response.
Sincerely,
Dr.*Raymond C. Loehr, Chair Mr. Richard A. Conway, Chair^
Executive Committee Environmental Engineering Committee
Science Advisory Board Science Advisory Board
Dr. C. H. Ward, Chair
Bioremediation Research Review
Subcommittee
Environmental Engineering Committee
Science Advisory Board
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NOTICE
This report has been written as a part of the activities of the Science Advisory Board,
a public advisory group providing extramural scientific information and advice to the
Administrator and other officials of the Environmental Protection Agency. The Board is
structured to provide a balanced, expert assessment of scientific matters related to problems
facing the Agency. This report has not been reviewed for approval by the Agency; hence,
the comments of this report do not necessarily represent the views and policies of the
Environmental Protection Agency or of other federal agencies. Any mention of trade names
or commercial products does not constitute endorsement or recommendation for use.
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ABSTRACT
The Bioremediation Research Review Subcommittee (BRRS) of the Environmental
Engineering Committee (EEC) of the EPA Science Advisory Board (SAB) has reviewed the
Office of Research and Development's (ORD's) "Bioremediation Research Program
Strategy," December 1991 draft. The BRRS found that the strategy presented in the draft
report, which is driven by actual site conditions and knowledge gaps, to be useful and
basically sound in concept. The BRRS commends the Agency on the team approach used to
address the topic, but recognized that the authors need to clarify concepts and terminology
related to the term, "site-directed approach." The BRRS believes that, while the strategy has
many good features, the draft document and the entire bioremediation research program
could benefit greatly from a more explicit treatment of the strategic planning process.
Additional recommendations are as follows: Bioavailability is a major factor limiting
wide-scale application of bioremediation technologies. There is a need to conduct research to
understand the physical-chemical changes that affect bioavailability of chemical pollutants
including mixtures in order to develop more effective bioremediation technologies; there is a
need to coordinate with other governmental agencies, as well as with the private sector; the
EPA bioremediation strategy needs to recognize other EPA research, as well as an "open
windows policy" to reach out and keep abreast of new developments in the field; and specific
criteria to measure success are needed. A number of other recommendations were made
with the aim of improving both the draft strategy document and the Agency's, overall
bioremediation research program.
Key Words: Bioremediation, Bioremediation Research, Bioremediation Research Program
Strategy
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Science Advisory Board
Environmental Engineering Committee
Bioremediation Research Review Subcommittee
Chair
Dr. C. H. Ward, Professor and Chairman, Department of Environmental Science and
Engineering, Rice University, Houston, TX
Members and Consultants
Dr. Martin Alexander, Professor, Department of Soil, Crop and Atmospheric Sciences,
Cornell University, Ithaca, NY
Mr. Richard A. Conway, Senior Corporate Fellow, Union Carbide Corporation, So.
Charleston, WV
Dr. Wayne M. Kachel, Technical Advisor, Pilko & Associates, Inc., Houston, TX
Dr. Raymond C. Loehr, Professor and H. M. Alharthy Centennial Chair in Civil
Engineering, University of Texas, Austin, TX
Dr. Ishwar P. Murarka, Senior Program Manager, Electric Power Research Institute, Palo
Alto, CA
Dr. Frederic K. Pfaender, Professor, Department of Environmental Sciences and
Engineering, University of North Carolina, Chapel Hill, NC
Dr. George E. Pierce, Manager, Bioremediation Technology Development, American
Cyanamid, Linden, NJ
Dr. Frederick G. Pohland, Professor and Edward R. Weidlein Chair of Environmental
Engineering, University of Pittsburgh, Pittsburgh, PA
Science Advisory Board Staff
Dr. K. Jack Kooyoomjian, Designated Federal Official, U.S. EPA, Science Advisory Board
(A-101F), 401 M Street, Washington, DC 20460
Mrs. Diana L. Pozun, Staff Secretary, Environmental Engineering Committee
Dr. Donald G. Barnes, Staff Director, Science Advisory Board
111
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TABLE OF CONTENTS
1. EXECUTIVE SUMMARY 1
2. INTRODUCTION 4
3. KEY FINDINGS AND RECOMMENDATIONS ON THE DRAFT
BIOREMEDIATION RESEARCH PROGRAM STRATEGY . . . 6
4. SPECIFIC TECHNICAL SUGGESTIONS ON EPA BIOREMEDIATION
RESEARCH 12
5. COMMENTS ON DOCUMENT PRESENTATION 17
APPENDIX A - GLOSSARY OF TERMS AND ACRONYMS A-l
DISTRIBUTION LIST
IV
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1. EXECUTIVE SUMMARY
This report presents the Science Advisory Board's (SAB) review of the Office of
Research and Development's (ORD) "Bioremediation Research Program Strategy"
(December, 1991 Draft). On February 10 and 11, 1992, the Bioremediation Research
Review Subcommittee (BRRS) of the SAB's Environmental Engineering Committee (EEC)
reviewed the draft document, received extensive briefings from research managers and
scientists who developed the document, debated technical arguments, and offered advice to
ORD on this promising remediation technology. Additional review occurred in mail
correspondence with the BRRS and the EEC. The EEC conducted public reviews on the
various draft reports at the EEC meetings of March 4 and 5, 1992 and July 7 and 8, 1992.
Throughout the process, the BRRS offered additional commentary to refine the
recommendations contained herein.
Our findings and recommendations are aimed at improving the current Bioremediation
Research Program Strategy document (hereafter referred to as the Strategy Document). The
following highlights key findings and recommendations:
1) The BRRS found that the strategy presented in the draft document, which is
driven by actual site conditions and knowledge gaps, to be useful and basically
sound in concept and commends the Agency on the team approach used to
address the topic.
2) The SAB believes that the site-directed approach used to develop the Strategy
Document is appropriate and basically sound. However, the BRRS suggests
that the authors need to clarify concepts and terminology related to the term,
"site-directed approach."
3) The BRRS believes that, while the strategy has many good features, the draft
document and the entire bioremediation research program could benefit greatly
from a more explicit treatment of the strategic planning process.
4) A sharpened focus for the program should lead to development of better
mechanisms of program outreach, inter-agency coordination, and leveraging to
maximize the benefits of EPA's resources in the bioremediation field.
5) The Strategy Document should include information which pays attention to the
regulatory framework in which the technology must be used and applied.
Regulatory roadblocks can preclude bioremediation as a technology of choice,
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and need some attention in the document. This information would be helpful
both to the Agency and the regulated community.
6) The Strategy Document should include greater attention and progressive effort
to meet the needs of the user-community — those that apply bioremediation
for environmental cleanup.
7) Bioavailability is a major factor limiting wide-scale application of
bioremediation technologies. There is a need to conduct research to
understand the physical-chemical changes that effect bioavailability of chemical
pollutants including mixtures, in order to develop more effective
bioremediation technologies.
8) The title of the document should be changed to more clearly reflect the nature
of the strategy. As now written, there is no clear, succinct statement about the
strategy focus.
9) Bioremediation opportunities at source generator sites need to be more
explicitly recognized in the strategy document.
10) A clearer identification of waste types as to contained chemicals will improve
the understanding of the Strategy Document and how the actions relate to
existing problems. It is exposure to the chemicals in the wastes that cause the
adverse effect to human health and the environment. The EPA bioremediation
strategy needs to recognize other EPA research, as well as an "open windows
policy" to reach out and keep abreast of new developments in the field.
11) Budget information is included in the Strategy Document, but the BRRS
believes that funding available is inadequate to support effective
implementation of the proposed Bioremediation Research Program Strategy. It
is therefore essential for EPA to pursue both Agency-wide and government-
wide planning and coordination in this important area.
12) Concepts related to performance evaluation of an on-going bioremediation field
project should be expanded and toxicity issues associated with bioremediation
should be focused on real-world pilot and field situations and not on possible
secondary by-products that may not occur or may occur only in special
situations or exceptions.
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13) Specific criteria to measure progress and success of bioremediation research
and technology development are needed.
A number of other recommendations are made in the report with the aim of
improving both the draft document and the Agency's overall bioremediation research
program.
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2. INTRODUCTION
The Biosystems Technology Development Steering Committee of ORD prepared a
draft document entitled "Bioremediation Research Program Strategy," (hereafter referred to
as the Strategy Document).1 The Bioremediation Research Review Subcommittee (BRRS) of
the Environmental Engineering Committee (EEC) of the EPA Science Advisory Board
(SAB), reviewed the draft Strategy Document, dated December 1991, at a meeting on
February 10 and 11, 1992. On those dates, the BRRS also received extensive briefings from
research managers and scientists who developed the document, debated technical arguments,
and offered informal advice to ORD on this promising remediation technology. The Strategy
Document review was attended by many of the Agency's personnel who actually participate
in bioremediation research. Additional review occurred by mail correspondence with the
BRRS and the EEC. The EEC conducted public reviews on the various draft reports at the
EEC meetings of March 4 and 5, 1992 and July 7 and 8, 1992. Throughout the process, the
BRRS offered additional commentary to refine the recommendations contained herein.
The BRRS was given a charge which focused on a strategy review, rather than a
detailed program review.2 The Subcommittee was asked to specifically focus on strategic
directions articulated in the draft document. The major questions asked of the BRRS are as
follows (Please note that table and figure numbers cited below refer to tables in the Strategy
Document):
1) Is a site-directed approach appropriate for focusing the Agency's
bioremediation research program? Will it adequately address application
problems that limit its use in the field?
2) Are the waste types and site matrices targeted in the strategy as priority site
categories (Table 2) the most appropriate for focusing research efforts?
3) Do the major scientific and engineering gaps identified in Table 3 adequately
cover the problems associated with applying bioremediation?
4) Are the consensus knowledge level rankings identified in Tables 4, 5, and 9
reasonable? Is this an appropriate means of identifying research emphasis
U.S. EPA, BJoremediation Research Program Strategy, prepared by the BioeyMems Technology Development Steering
Committee, Office of Research and Development, December 1991.
2 Memortndum from E. Timothy Oppelt, Director, RREL-Cincianati, Ohio to K. J«ck Kooyoomjian, Designated Federal Official
of the SAB/EEC, January 8, 1992.
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(i.e., process, pilot, field research, etc.) shown in Table 10 for the priority site
categories?
5) Will the research framework with its associated feedback mechanism (Figure
2) enable ORD to achieve and refine the program objectives?
6) Are the research outputs (Tables 6, 7, 8) adequate to provide guidance to
regional Superfund staff, remediation contractors, and the bioremediation
industry that will result in the effective and appropriate use of bioremediation
in the field? Are there other outputs that would be effective in achieving this
goal?, and
7) Given the identified budget constraints, do the funding distributions depicted in
Figures 3, 4, and 5 provide the proper mix of process and pilot/field research
to support both fundamental understanding and engineering development of
bioremediation?
The following Subcommittee findings and recommendations deal with the Strategy
Document and are aimed at improving it. The findings and recommendations of the BRRS
have been distilled from the dialogue which occurred at the February 10 and 11, 1992
meeting, and from subsequent deliberations on the topic by the BRRS and its parent
Committee, the EEC. The BRRS has attempted to specifically address the issues and
questions posed by ORD and also offers wider-ranging guidance to strengthen and focus the
Strategy Document.
This review has been organized into the following sections: 1) Key Findings and
Recommendations on the Draft Bioremediation Research Program Strategy, 2) Specific
Technical Suggestions on EPA Bioremediation Research, and 3) Comments on Document
Presentation.
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3. KEY FINDINGS AND RECOMMENDATIONS ON THE DRAFT
BIOREMEDIATION RESEARCH PROGRAM STRATEGY
The BRRS is strongly supportive of the Agency's role in bioremediation research and
technology development, and believes that the Strategy Document for the program should
clearly explain its current status and plans for future directions. The Subcommittee also
believes that the Strategy Document should serve to explain the program's objectives, focus,
structure, operations, budget requirements and relative place in EPA research and
development activities. Hence, key findings and recommendations are directed toward
providing guidance to improve and strengthen the programmatic and management value of
the document. The key findings and recommendations are as follows:
1) A Site-Directed Approach to the Research Strategy Development is
Appropriate and Basically Sound in Concept. Based on review of the draft
document, as supplemented by verbal explanation, the SAB found the
Bioremediation Research Program Strategy, which is driven by actual site
conditions and knowledge gaps, to be useful and basically sound in concept. It
identifies and focuses on many important issues, has feedback from field
findings to basic research as well as feed forward, recognizes the need for
various types of technology transfer in and out of the program, and provides
seldom-included budget estimates. The EPA personnel who prepared the
Strategy Document should be commended. It is a focused summary that
allowed it to be reviewed as a strategy rather than a compilation of individual
projects. In addition, the material was presented well, thus allowing the
Subcommittee to identify the key elements and gaps.
2) A Team Approach to the Research Strategy Development is Productive. We
commend the Agency on the team approach used to address the topic. The
various ORD laboratories obviously worked together to address this Agency-
wide program, rather than handle it on an individual laboratory basis. The
team approach which has led to this program plan and strategy should be
continued and encouraged, and used as a model for other EPA research
programs. However, while the bioremediation program plan has benefitted
significantly from inter-laboratory participation, the strategic planning process
should be strengthened.
3) A More Explicit Treatment of the Strategic Planning Process is Needed to
Guide EP/\ Fegearch on Bioremediation. While the strategy has many good
features, the draft document and the entire bioremediation research program
could benefit greatly from a more explicit treatment of the strategic planning
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process. The process should consist of: a) establishing a vision, b) assessing
the current state of research, and c) selecting the most appropriate pathway
from the present to the vision.
The vision provides a clear, unified direction for the research. As
currently formulated, each individual researcher has his or her own vision of
where the research effort should go within the bounds of research interests of
the individual researcher. Though individual's visions may be worthwhile,
they may not be appropriately focused or prioritized for this research effort to
be fully successful. Embarking on the strategic planning process is consistent
with the SAB's advice 3'4 and with the Agency's stated strategic direction of
"providing leadership in the nation's environmental science, research and
assessment efforts."5>6 The mission should address the extent to which
bioremediation fits into our nation's program with its rather strict goals.
With regard to the current state of bioremediation research, little
mention has been given to what has gone before. Bioremediation is not a new
concept. Clearly, a sound basis already exists upon which bioremediation
advances should be pursued. With the vision and current assessment in place,
the most appropriate path can be selected from this logical reference
framework. The EEC notes that these issues related to strategic planning and
the need for a vision statement have come up before. For all strategic plans,
including this one, the Agency should rigorously implement a basic three-step
process: a) establish a vision, b) determine the current state of the issue, and
c) prepare a plan to achieve the vision.
4) Regulatory Constraints Need Attention. The Strategy Document should
include information which pays attention to the regulatory framework within
which the technology must be used and applied. There are many opportunities
in the Strategy Document to show how bioremediation could be used in
treating RCRA, CERCLA and UST sites. Technically speaking,
3 U.S. EPA/SAB.FutureRUfc: ReiMtch Strategic! for the 1990't. Science Advuory Bowl, EPA-SAB-EC-88-040, September 1988.
4 U.S. EPA/SAB, ftfffVMBf PifV ***1in« Prioritiet and Strategic* for Environment! Protection. Science Adviaory Board,
EPA-SAB-EC-9O421, September 1990.
'EPA...Preserving our Future Today,' Stntefic Direction for the U.S. Environmental Protection Agency, dated April 1991.
6 'EPA...Preserving our Future Today,' U.S. Environmental Protection Agency Strategic Plan, Draft Ob, October 17, 1991.
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bioremediation may be the most appropriate remedial option for a particular
application. If, however, regulatory constraints prevent its application, then
the value of the research is greatly lessened. In fact, existing regulations and
regulatory agency resistance can preclude bioremediation as a technology of
choice. Some attention must be given in the document to identify these
regulatory constraints which could limit implementation of the technology.
Technical discussions to aid in overcoming these constraints should be
included, as well as acknowledgement that information gaps and practical
shortcomings of the state-of-the-art currently limit broad applications of
bioremediation technology. This would be helpful information for both the
Agency and the regulated community. The SAB Executive Committee
observed that there are differences in the acceptance of bioremediation in
Europe, as compared to the United States context, noting that the regulatory
atmosphere in Europe is more conducive to such applications.
5) Defining Resource Needs and Timeliness of Outputs. Resource needs and
timeliness of outputs should relate to the strategic planning process in the
Strategy Document and particularly to question #7 in the charge to the SAB's
BRRS (See introduction and reference #2). The resource information in the
Strategy Document implies that adequate resource allocation has already been
made to carry out the bioremediation research program. However, on
examining the needs for research, development and demonstration covered in
the Strategy Document and EPA staff responses to questions asked during the
SAB's BRRS review, it appears that the adequacy of budget projections should
be reevaluated, particularly from the viewpoint of assuring timely delivery of
outputs envisioned in the strategy. The Subcommittee finds that the existing
budget is too small. It is further suggested that the Agency should focus the
Strategy Document on a realistic discussion of what the Agency can expect to
achieve with the available resources versus what the Agency actually needs to
accomplish with the stated goals and additional resources.
6) The Site-Directed Approach Needs Further Clarification and Description. The
Subcommittee believes that significant confusion exists in the report about the
"Site-Directed Approach" used in the planning process. Within the BRRS,
there were several different interpretations of what is meant by the concepts
and terminology related to the "Site-Directed Approach." Further, the
Subcommittee asks that the Agency clarify and define the meaning of "site
generic categories." The authors of the strategy need to clarify whether sites
are considered as generic categories, as well as clarify the terminology dealing
with environmental compartments, specific field locations, locations where
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specific wastes are found, or combinations of the above. What assumptions
are being made about common contamination and environmental settings of
sites in particular categories? Until this is clarified, it is difficult to fully
appreciate and evaluate the appropriateness of this organizational approach for
the Bioremediation Research Program Strategy.
7) Coordination with Other Governmental Agencies is Needed. The Strategy
document gives no indication of any integration of planning with other
governmental agencies; ( e.g., DOE, DOD, and the individual military
branches) and possibly NSF, or initiatives outside of these established
organizations in a global perspective. The Subcommittee recognizes that
individual EPA scientists and engineers have meaningful contacts with
colleagues in other governmental agencies. Nevertheless, these do not
represent a substantive coordination in a holistic way, nor does the Strategy
Document represent a strategic method for joint planning. The budget for
EPA's bioremediation research is small relative to the resources perceived by
the Subcommittee as needed. In fact, relative to Other Federal agencies, the
EPA budget currently and in the future to support bioremediation research is
not adequate. It is therefore essential for EPA to pursue both Agency-wide and
government-wide planning and coordination in this important area.
EPA should embark on a senior staff level coordination effort with
other Federal agencies, rather than rely on individual project level contacts.
The establishment of a mechanism for joint government-wide planning would
require action by senior personnel in all relevant agencies.
EPA's science-oriented bioremediation program is appropriate for the
Agency. But it is critically important that this science-based program be
coordinated with the technology-based programs being conducted by other
agencies and industry. This is essential, because materials handling, especially
contact between contaminants, bacteria, and growth support parameters, is the
critical issue. The Agency needs to help build mechanisms for joint planning
and coordination within its organization and between Agencies, as well as
between government and industry.
EPA is in fact proposing to include: a) identifying developments that
are part of the EPA Hazardous Substance Research Centers (HSRCs), b) all-
investigator symposia, c) workshops on bioremediation, and d) specific
conferences on relevant topics. All of these activities will help, but will fall
short of the actual effort needed to fully keep abreast of developments. To
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generate significant coordination, EPA needs an "open windows policy* to
reach out with the Strategy Document (See Reference # 1, pg. 3) with the goal
of keeping abreast of new developments in the field, such as those occurring in
the EPA HSRCs.
As described above, there are many exciting and state-of-the-art
bioremediation research efforts underway that are not funded by EPA and
therefore will not be recognized and integrated by the approaches indicated in
the Strategy Document. EPA should undertake an active program to identify
such research, to have "open windows* to acquire such information to reach
QUi to joint involvement with such research. Such research is being done in
many industry laboratories,(e.g., major petroleum firms), as part of the
investigations conducted for other governmental agencies, (e.g., DOD and
DOE), by universities (e.g., University of Texas and University of Michigan)
and independent contract laboratories, and in other countries.
The recent EPA report, "Safeguarding the Future: Credible
Science, Credible Decisions,"7 calls for EPA to place its scientific
goals and achievements before the public, as well as to draw on the
expertise of other organizations to obtain the best scientific information
possible. While SAB reviews, such as this, place the Agency's
achievements before the public, EPA currently lacks adequate
mechanisms for successfully utilizing expertise of other organizations
and to acquire such information from the broader scientific and
engineering community. A stronger, broader effort is needed than that
indicated in the Bioremediation Research Program Strategy document.
Specifically in this research area, EPA should have an active program
that reaches out to non-EPA researchers in all organizations and encourages
them to share their knowledge. This can include: a) focused efforts to find out
who is doing relevant bioremediation research and the objectives of that
research; b) specific invitations to such individuals to participate in workshops,
symposia, and planning meetings; c) the possibility of joint planning of
research so as to take advantage of other efforts and of sharing the results of
such research; and d) exploring possibilities of rotational assignments that
allow scientists from other organizations to work in EPA science programs and
EPA scientists to participate in research at non-EPA locations. This latter
11 g EPA, fo (failing the Future: Credible Science. Credible Petition. The Report of Ifae Expert Panel on fee Role of Science
at EPA, EPA-600-9-91-050, March 1992, page* 18-19.
10
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approach on rotational assignments is a specific recommendation of the
"Safeguarding the Future" report, and is especially important in the
bioremediation area which is clearly an inter-agency effort.
In summary, a positive, active program is needed to reach out and
involve efforts of the broad scientific and engineering community involved in
bioremediation research. The program identified in the bioremediation
Strategy Document is a beginning but an inadequate overall effort.
8) Coordination and Involvement with the Private Sector is Encouraged. Much
of the knowledge on factors limiting bioremediation, problems with technology
implementation, and research and development on bioremediation technology
resides in the private sector. Large chemical, petroleum and engineering
companies, as well as smaller private firms, have information and knowledge
that can be useful to the development and implementation of the EPA
bioremediation research strategy. Therefore, a system should be devised to
obtain regular advice from scientists and engineers from the private sector on
the priorities, approaches and needs for EPA's bioremediation program. This
could be implemented in a number of ways, such as with planning workshops,
symposia and innovative coordination and support activities. However, the
EEC notes that the issue of barriers to technological information transfer, such
as proprietary issues, need to be examined. EPA's participation and
leadership in the Bioremediation Action Committee is a positive, but only a
modest start in the right direction.
9) EPA Bioremediation Strategy Needs to Recognize Other Related EPA
Research. Biological research within EPA that is relevant to the Biosystems
Technology Development Steering Committee's Bioremediation Research
Program Strategy, but not currently included in it, should be listed and
described in a table or appendix. Expectations from that research and ways by
which that research will be accessed (not directed) should be added to the
Strategy Document. Programs of particular interest include the oil spill
bioremediation research program, research in the UST program which has led
to the development of the "LOCI" model, research sponsored by the
exploratory research center program, and specific research projects supported
by EPA's competitive grants program.
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4. SPECIFIC TECHNICAL SUGGESTIONS ON EPA
BIOREMEDIATION RESEARCH
Establishment of a clear vision and well defined objectives for the EPA
bioremediation research program will provide focus for specific research initiatives and
guidance for the Agency's niche in this important area. The Subcommittee review of the
draft Strategy Document has lead to a series of specific suggestions which should be
considered in the research planning process. The Subcommittee has also attempted to
identify specific areas of research which appear to be inadequately emphasized in the draft
document.
1) Specific Criteria to Measure Success of Bioremediation Projects are Needed.
The Subcommittee suggests that the strategy contain explicit criteria to follow
progress of bioremediation in the field and to measure success and
accomplishment of research outputs. For example, Technical Resource
Documents (TRDs) are expected to be clear, concise and easy-to-use products
that will enable the intended users to apply them for "real-time" decisions.
The Subcommittee suggests that while a TRD is a document which only
provides technical guidance and, as such, cannot set up a system to measure
success, the TRDs should give clear guidance on ways to measure success and
progress of bioremediation Meld studies. Whenever possible, differentiation
should be made between what would have happened naturally, without
intervention and how intervention changed the course of bioremediation.
2) Concepts Related to Performance Evaluation Should be Expanded. The
purpose of bioremediation is to degrade, detoxify and immobilize constituents
that may pose a threat to human health and the environment. Thus, it is
appropriate that toxicity issues associated with bioremediation be addressed.
However, the toxicity research should be focused on real-world possibilities
and not on elucidation of secondary by-products that may not occur or may
occur only in special situations or exceptions. Rather, an early effort of the
proposed bioremediation toxicity research should be investigations of on-going
pilot and field scale situations.
Large-scale bioremediation efforts are underway at many locations in
the U.S. Samples from these sites could be obtained and the relative toxicity
changes monitored and related back to the degradation and changes in
chemical constituents. Samples from a few such sites have indicated that the
relative toxicity is likely to decrease at the same rate or faster than the loss of
specific chemicals. Such a real-world comparison would: a) provide a reality
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check for the toxicity generation assumptions being made and b) more closely
tie toxicity changes to actual bioremediation process performance. Only if
there is clear evidence that there are relative toxicity increases would there be
a need to identify possible intermediate by-products, causes for the toxicity
increase, and methods to cause the increase not to occur.
To pursue the identified bioremediation toxicity research efforts as
described in the Strategy Document may be to evaluate a potential problem
which is in reality a non-problem. By tying the toxicity research into actual
bioremediation laboratory, pilot and field studies, a reality check will be
included and more meaningful performance evaluation data will be obtained.
In a like manner, the immobilization question also should be part of
any bioremediation process performance. Information from laboratory and
field studies indicates that as bioremediation proceeds, the remaining
constituents become less soluble, less available for leaching and therefore less
mobile. Thus throughout a bioremediation study, samples should be evaluated
for the relative mobility of constituents. This can be done by standardized
leaching procedures such as the Toxicity Characteristic Leaching Procedure
(TCLP) or others that may be more appropriate.
By relating changes in mobility of constituents to degradation and
chemical loss by bioremediation, the overall performance of the bioremediation
process can be better evaluated. Judgements on the technical and
environmental feasibility of bioremediation will be made on more than just loss
of specific chemicals or on degradation rates.
In terms of performance evaluations, it is not clear how the information
acquired will be related to design relationships and parameters that feed into
ultimate use of bioremediation processes and specifically into the Technical
Resource Documents (TRDs). Without this connection, it is possible that very
good scientific data will result, but unfortunately will not be able to be
included in engineering design. An example would be to provide a link
between the microbial characterization data and process performance so that
chemical loss rates ultimately can be calculated in terms of mass of chemical
lost per unit time per mass of active organisms. Wherever possible, the
experiments should be planned to obtain chemical loss rate data and the effects
of environmental parameters or management options on such rate data.
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3) Categorizations of Waste Type Should Reflect the Logic of the Strategy
Categorization of waste type in the Strategy Document is awkward and
interferes with a quick understanding of the logic involved. The waste types
include chemicals (solvents, halogenated aromatic hydrocarbons or HAHs, and
pesticides) and industries (wood preserving and munitions). While these are
items common to Superfund sites, it would be better and less confusing if there
were more commonality such as using categories that are all chemicals. Thus
for wood preserving, the category could be polycyclic aromatic hydrocarbons
(PAH) as a chemical class of concern and for munitions waste, it could be
metals or specific organics.
The current waste type categorization makes it appear that there are not
other major industries causing Superfund or RCRA corrective action problems,
whereas there clearly are. For instance the petroleum refining and
petrochemical industries contribute waste to both Superfund and RCRA
corrective action sites. The BRRS was told that constituents of such industries
are understood to be included in the wood preserving category. However, the
Strategy Document does not make this clear. Similarly, UST problems include
petroleum and petroleum products that are different from the usual solvents,
yet apparently are included in the solvent category. A clearer identification of
waste types as to contained chemicals will improve the understanding of the
Strategy Document and how the actions relate to existing problems. It is
exposure to the chemicals in the wastes that cause the adverse effect to human
health and the environment.
4) The Title of the Strategy Document does not Reflect Content. The title of the
Strategy Document should be changed to more clearly reflect the nature of the
strategy. In addition, early in the Executive Summary and the Introduction,
the primary focus of the strategy should be clearly stated. As now written,
there is no clear, succinct statement about the strategy focus. Rather, the
focus is scattered throughout several paragraphs.
As stated by EPA personnel in the discussions, the Bioremediation
Research Program Strategy is to meet the needs of EPA and other individuals
involved in Superfund, RCRA corrective action, and UST remediation and
clean-up efforts. A reader of the Strategy Document must go through many
paragraphs and sometimes pages before this focus finally sinks in. Someone
looking at the title could infer that the Strategy Document addresses much
more, such as non-hazardous industrial wastes and even the use of
bioremediation for municipal wastewaters, and sludges. Thus, it would be
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appropriate to consider a more descriptive title to the document such as,
"Hazardous Waste, Superfund and UST Bioremediation Research Strategy"
and more clearly define this focus in the opening paragraphs of the Executive
Summary and the Introduction.
5) The Strategy Document Should Support the Development of
Technology Decision Support Systems. Proper application of
bioremediation technology at present is an inexact science, even
in the hands of the limited number of highly skilled
technologists in the field. Other more mature fields of
technology have developed Decision Support Systems (DSSs) to
aid in the training of new personnel. These DSSs eventually
take the form of computer programs into which is placed a
synthesis of the accumulated knowledge of those individuals
most skilled and experienced in the technology. Timely
development of DSSs will enhance the usefulness of the TRDs
and promote the most appropriate and cost-effective wide-spread
use of bioremediation technology.
The Subcommittee suggests that DSSs, or "simple decision
software* be discussed in the Strategy Document as possible products
that will increase the value and use of the TRDs. Of course, the term,
"simple decision software", needs to be defined. There are pros and
cons as to whether such systems are sufficiently developed to support
this recommendation. In fact, such systems could serve to limit
further development in the field, or at least limit remediation options.
Some of the BRRS members and consultants suggested that software is
useful when decisions on applications are being done by inexperienced
persons or non-experts. In this case, however, decisions should be
made by experienced persons where such guidance is less necessary.
At a minimum, the Agency might consider a discussion of the pros and
cons, as well as a definition, of DSSs or "simple decision software" in
the Strategy Document.
6) Suggestions for Specific Research Topics to be Included in the
Strategy. The authors of the Bioremediation Research Program
Strategy are to be commended for preparing a comprehensive
list of scientific and engineering knowledge gaps (Table 3). The
Subcommittee has identified several additional knowledge gaps
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and research areas that should be considered by the Biosystems
Technology Development Steering Committee:
a) There is minimal information on the dynamics of biodegradation of
mixed materials containing multiple contaminants, other than petroleum
hydrocarbons. The Strategy Document should include research needed
to address the nature of stimulatory, inhibitory or complementary
interactions that are possible.
b) No apparent attention has been given to integrated process technologies
for waste remediation. These integrated techniques usually involve
combinations of physical, chemical and biological processes. There is
significant work underway on a variety of potentially useful
combinations that need to become part of the bioremediation strategy.
A specific example could include surfactant or co-solvent enhanced
product recovery from the vadose zone, followed by vacuum extraction
for further residuals removal and bioventirig for "polishing."
Numerous other integrated methodologies are needed for application in
a "treatment train" concept.
c) There is a need to conduct research to understand the physical -
chemical changes that affect bioavailability of chemical pollutants and
mixtures in order to develop more effective bioremediation
technologies. Bioavailability of parent and aged chemical complexes is
one of the factors most widely recognized as limiting the efficacy and
wide-scale application of bioremediation. Chemical aging (weathering)
should be a major thrust of the Strategy Document.
d) The Strategy Document does not recognize the bioremediation
potential at existing source generators, such as landfills, and
other land disposal facilities as bioreactors. Clearly, the
application of bioremediation to these facilities is not outside the
purview of the initiative. In situ bioremediation, while different
for landfills and other land disposal facilities is often a reality
which would moderate the potential migration and environmental
effects of residuals and conversion products from these sources,
as well as direct the requirement and extent of possible post-
transport relating to external bioremediation decisions and
efforts.
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5. COMMENTS ON DOCUMENT PRESENTATION
The intent of the Subcommittee's comments on document presentation is to help 1)
clarify some of the language and terms used in the draft document, 2) ensure that the needs
of the users of bioremediation technology receive appropriate attention, and 3) provide focus
to communication and technology transfer activities, such as program symposia and
workshops on bioremediation. The following comments are intended to focus on improving
presentation within the Strategy Document.
1) Greater Consideration of Technology Transfer to the User Community
(Process Engineer) is Needed. Success ultimately will be judged by the
knowledgeable application of bioremediation. It is critical that the user
community (i.e., engineer/remediation managers) be supplied with engineering
data and information which will support effective decisions regarding the
application of bioremediation. A clearly defined technology transfer activity
which provides this required information should be incorporated into the
Strategy Document. Additionally, it is suggested fhat a serious discussion on
science versus engineering/technical development needs of the various
segments of the user community would be most helpful in the Strategy
Document.
2) The Process Used in Preparing the Tables of Information Presented in the
Strategy Document Should be Explained and Disclosed. To a large extent, the
description and direction of the program strategy is based on various types of
information contained in tables in the report. These tables appear to have been
prepared in a subjective manner on the basis of input provided by various
Agency bioremediation experts. It would be very helpful to explain the
process used in preparing the tables and how the rankings were established.
Additionally, since these tables provide direction, it would be worthwhile to
explain who was involved in the ranking process, as well as the backgrounds
and affiliations of all participants. This material could be provided in an
Appendix or integrated into the text. By disclosing the process more fully, the
reader could gain an appreciation for the nature, origin and hence the validity
of the process and the information in the tables. The reader can then more
appropriately focus on the more substantive issues within the strategy.
3) Knowledge Gaps Need Prioritization and Major Gaps Need to be Identified.
The major knowledge gaps are identified in the Strategy Document (Table 3),
but their significance is diminished by including an extensive listing of factors
related to microbiological degradation in general and not to bioremediation of
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hazardous waste sites in particular. An example is "environmental conditions
(pH, temperature, redox potential, moisture content and organic carbon
content)." One approach to address this issue would be to rank items by
asterisks in Table 3 or separate out in a second table the major or priority
information gaps. In the latter case, Table 3 should be retitled. The
Subcommittee is not suggesting that comprehensiveness be abandoned, but
cautions against the implication that all items are equally important.
4) FY 92/93 Research Program Needs Particular Attention to Performance.
Evaluation and Modeling. Performance evaluation and modeling programs
need particular attention in the FY 92 and FY 93 research program mix
(Tables 12 and 15). For example, sampling would be important in the former
and aerobic processes in the latter. The narrative on performance assessment
(Section 3.1.5) should focus on generic issues such as sampling and
surrogates. Such work is on-going within EPA and needs to be included in the
document.
5) Tables Need Clarification. A subgrouping should be added to indicate projects
by waste categories in Tables 12, 13 and 15 to clarify the presentation.
6) Symposia and Workshops Need More Thought Toward Intended Objectives. It
is uncertain whether the state-of-the-science and technology symposia and
workshops have clearly stated objectives and will contribute to specific
research initiatives, or to broader generic issues. Symposia and workshops
should support the timely delivery of technology resource documents and aid
in the effective implementation of bioremediation processes (Tables 6 and 7).
The impending symposium on reductive dechlorination should be exemplary of
a more specific thrust, however, as officially entitled as "Anaerobic
Processes," the symposium may be too broad to contribute directly to any
work product of the bioremediation research program. Additionally, the
symposia and workshops should be focused to provide inputs to the
development of DSSs for technology application and implementation.
7) Consistency of Terminology Needs Greater Attention. When reviewing the
document, special care should be given to the consistent use and application of
terms. The following specific suggestions deal with terminology:
a) In the draft Strategy Document, there is a question regarding the use
and application of terms such as "site", "treatment", and "in situ! as
applied to technologies. For example, since the term "site" may have
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several meanings, there may be potential for confusion if this term is
not used in a consistent manner.
b) The term "treatment" is used in the text to describe the level of
biodegradation achieved in experimental studies. Because this term has
a defined meaning with in the context of CERCLA, RCRA and UST
activities, its use in a generic sense to convey biodegradation, rather
than achieving a required level of restoration, could be misconstrued.
c) In situ is used throughout the document to describe a variety of
technologies, some of which meet the strict definition of in situ, which
suggests a process that is non-intrusive and non-disturbing. Other
usages may reflect hybrid technologies which combine la sity and fix
situ elements. Furthermore, the preferred spelling of in situ (i.e., in
situ) should be checked throughout the document.
d) There is inconsistency regarding the use of and different meanings of
HAH (Halogenated Aromatic Hydrocarbons) and H & AH in the
document. It would seem that the term, H&AH, is synonyous with
HAH. These terms should be defined, or one of them dropped.
e) Solvent(s) is (are) inappropriately used in the document to include both
chlorinated solvents and petroleum hydrocarbons. "Wood-preserving
wastes" could be grouped under a term such as phenols and PAHs.
8) A Glossary of Terms and Acronyms in the Appendix of the Strategy Document
Would be Helpful for the Reader. There are many terms and acronyms used
throughout the Strategy Document and the Tables. A complete glossary of
acronyms and terms would be most helpful as an attachment or appendix to the
Strategy Document and would facilitate understanding for the general reading
audience. In fact, most Agency documents would do well to make the use of
a glossary of terms and acronyms a standard practice, as is done with the SAB
reports.
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APPENDIX A - GLOSSARY OF TERMS AND ACRONYMS
BRRS
CERCLA
DOD
DOE
DSSs
EEC
EPA
FY
HAH
HSRCs
LOCI
NSF
OEETD
ORD
PAHs
PH
RCRA
SAB
TCLP
TRD
UST
US
BIOREMEDIATION RESEARCH REVIEW SUBCOMMITTEE
(EEC/SAB/EPA) (ALSO REFERRED TO AS THE
SUBCOMMITTEE)
COMPREHENSIVE ENVIRONMENTAL RESPONSE,
COMPENSATION AND LIABILITY ACT (ALSO KNOWN AS
"SUPERFUND")
DEPARTMENT OF DEFENSE
DEPARTMENT OF ENERGY
DECISION SUPPORT SYSTEMS
ENVIRONMENTAL ENGINEERING COMMITTEE (SAB/EPA)
U.S. ENVIRONMENTAL PROTECTION AGENCY (U.S. EPA, or
"THE AGENCY"
FISCAL YEAR
HALOGENATED AROMATIC HYDROCARBONS
HAZARDOUS SUBSTANCES RESEARCH CENTERS
UNDERGROUND STORAGE TANK CONCEPTUAL MODEL
DEVELOPED BY THE U.S. EPA/ORD RISK REDUCTION
ENGINEERING LABORATORY
NATIONAL SCIENCE FOUNDATION
OFFICE OF ENVIRONMENTAL ENGINEERING AND
TECHNOLOGY DEMONSTRATION
OFFICE OF RESEARCH AND DEVELOPMENT, U.S. EPA
POLYCYCLIC AROMATIC HYDROCARBONS
NEGATIVE LOG OF HYDROGEN ION CONCENTRATION
RESOURCE CONSERVATION AND RECOVERY ACT
SCIENCE ADVISORY BOARD (EPA)
TOXICITY CHARACTERISTIC LEACHING PROCEDURE
TECHNICAL RESOURCE DOCUMENT
UNDERGROUND STORAGE TANK
UNITED STATES
A-l
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