&EPA
           United States
           Environmental Protection
           Agency
             Office of Research and
             Development
             Washington DC 20460
EPA/600/K-96/003
February 1997
Updated September 1997
Environmental Technology
Verification Program

Verification Strategy

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EPA/600/K-96/003
February 1997
Updated September 1997
Environmental Technology
Verification Program

Verification Strategy
Office of Research and Development
U.S. Environmental Protection Agency
Washington, DC 20460
                                              Printed on Recycled Paper

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ETV
                                   UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                                                 WASHINGTON, D.C. 20460

                                                     MAR 18
                                                                                         TlEADWNISTRATOH
                   Honorable Albert Gore, Jr.
                   The Vice President of the
                    United States
                   Washington, DC 20501

                   Dear Vice President Gore:

                         Within the next few days I will send the enclosed document. Environmental Technology
                   Verification Strategy, to the Chairmen and Ranking Minority Members of the House and Senate
                   Appropriations Subcommittees on Veterans Affairs, Housing and Urban Development, and
                   Independent Agencies. This document explains the goals, operating principals and program
                   criteria being used to implement tie EPA Environmental Technology Verification Program
                   (ETV).

                         ETV fulfills commitments made by the Agency in the National Pe rformancs Review to
                   establish a broad-based environmental technology verification program.  It executes an initiative
                   in the President's National Environmental Technology Strategy, Bridge to a Svs, nimble Future.
                   It also is designed to carry out the intent of Congress as expressed in both the FY96 and FY97
                   appropriation legislation. I believe the Environmental Technology Verification Strategy will
                   assist the public and the Congress to understand better the efforts being made by EPA to cany
                   out this program.

                         We have made substantial progress in our first year of operation. The program wiU soon
                   cover all environmental technology areas: Several hundred stakeholders are involved and the first
                   technology verification statements were issued by EPA two weeks ago. We continue to befievc
                   that EPA performance verification of innovative technologies can make a major contribution to
                   more rapid protection of the world's environment at reasonable costs.

                                                                 Sincerely,
                    Enclosure
Verification Strategy

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Foreword

      The U.S. Environmental Protection Agency's (EPA) Office of
Research and Development (ORD) is publishing this document,
Verification Strategy, to report the goals, operating principles, and future
plans of the newly created Environmental Technology Verification
Program (ETV). ETV is intended to expand the environmental technology
choices of public and private decision makers, both in our country and
abroad. The use of new technologies will allow faster and more thorough
pollution prevention, control, cleanup, and monitoring, while bringing the
overall cost of regulatory compliance down.

      Evaluations of promising new technologies by ETV should be
useful to a broad array of organizations:

    • Buyers of technology, and the consulting engineering community
      that advises them, who need an objective source of data to make
      informed purchasing decisions.

    • Permitters at state, local and federal level who must decide on
      which technologies to allow into use.

    • The financial community that must determine the level of risk
      involved in supporting innovative technology developers.

    • Vendors who want to market their products on a level
      playing field of objectively acquired data.

      The challenges  of the next three years will be substantial as we
produce and broadly distribute credible data that are products of ETV.
Meeting these challenges will ensure that the environment, the economy,
and the marketplace benefit from the steady stream of scientific and
technological innovation this program will  encourage.

                              Mr. Henry L. Longest II
                              Acting Assistant Administrator
                              Office of Research and Development
                              U.S. Environmental Protection Agency
                                                   Verification Strategy                 iii

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Contents

                                                             Page
Foreword	iii
Background	 1
Important Definitions	2
Operating  Principles	3
ETV Pilot Process	7
Selection Criteria for ETV Pilot Projects	9
2001 Report to Congress	 11
ETV Program Vision and Projected Development Scenario	 11
ETV Web Site Information	 14
                                                  Verification Strategy                 iv

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Environmental  Technology Verification Program


Verification Strategy


Background

      Throughout its history, the U.S. Environmental Protection Agency
(EPA) has evaluated technologies to determine their effectiveness in
monitoring, preventing, controlling, and cleaning up pollution. Since the
early 1990s, however, numerous government and private groups have
identified the lack of an organized and ongoing program to produce
independent, credible performance data as a major impediment to the
development and use of innovative environmental technology. Such data
are needed by technology buyers and permitters both at home and abroad
to make informed technology decisions.  Because of this broad input, the
President's environmental technology strategy, Bridge to a Sustainable
Future, and the Vice President's  National Performance Review, contain
initiatives for an EPA program to accelerate the development of
environmental technology through objective verification and reporting  of
technology performance. In 1994, EPA's Office of Research and Develop-
ment formed a workgroup to plan the implementation of the Environmental
Technology Verification Program (ETV). The workgroup produced a
Verification White Paper that guided the initial stages of the program. This
document, Verification Strategy, updates the earlier paper based upon the
evolution of the program over the last two years. It outlines the operating
principles and implementation activities that are shaping the program, as
well as the challenges that are emerging and the decisions that must be
addressed in the future. ETV will  continue to  be modified through input
from all parties having a stake in environmental technology, through further
operational experience, and through formal evaluation of the program.

      The goal of  ETV, which remains unchanged, is to  verify the
environmental performance characteristics of commercial-ready tech-
nology through the evaluation of objective and quality assured data, so that
potential purchasers and permitters are  provided with an independent and
credible assessment of what they are buying and permitting.
                                                Verification Strategy

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Important Definitions

      A clear definition of the words "evaluate" and "verify", along with the
word "certify", is important to establish at the outset of the program. The
technology development community, the regulated community, and those
charged with executing environmental standards at all levels of
government  require a precise understanding of what EPA means and does
not mean by the activities to be undertaken through ETV.
EPA intends to sponsor the evaluation of environmental technologies
through adequate testing and verify that they perform at the levels reported.
By evaluate and verify we mean:

Evaluate/Evaluation
       To carefully examine and judge the efficacy of a technology; to
       submit technologies for testing under conditions of observation and
       analysis; syn., measure, estimate, classify, test.

Verify / Verification
       To establish or prove the truth of the performance of a technology
       under specific, predetermined criteria or protocols and adequate
       data quality assurance procedures; syn., confirm, corroborate,
       substantiate, validate.

       EPA does not intend to certify that a technology will always, or
under circumstances other than those used in testing, operate at the levels
verified. By certify we mean:

Certify / Certification
      To guarantee a technology as meeting a standard or performance
      criteria into the future; syn., ensure, warrant, guarantee.

      EPA understands that the word certify can have a variety of
meanings, but the Agency believes that the above definition is the one
most commonly understood. Misuse of the term could cause confusion
among the public.
Verification Strategy

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Operating Principles

      Several important operating principles have defined the basic ETV
program structure and remain fundamental to its operation. These are
briefly outlined below.


1. Performance Evaluation Goal
   Under ETV, environmental technologies are evaluated to ascertain and
   report their performance characteristics. EPA and its partners will not
   seek to determine regulatory compliance; will not rank technologies or
   compare their performance;  will not label or list technologies as
   acceptable or unacceptable; and will not seek to determine "best
   available technology" in any form. In general, the Agency will avoid  all
   potential pathways to picking "winners and losers". The goal of the
   program  is to make objective performance information available to all of
   the actors in the environmental marketplace for their consideration and
   decision  making.

2. Commercial-ReadyTechnologies
   The ETV program is a service of EPA to the domestic and international
   marketplace in order to encourage rapid acceptance and
   implementation of improved  environmental technology.  ETV, therefore,
   focuses its resources on technologies that are either in, or ready for,
   full-scale commercialization. The program does not evaluate
   technologies at the pilot or bench scale and does not conduct or
   support research. Participation in ETV is completely voluntary.

3. Third-PartyVerification Organizations
   ETV leverages the capacity, expertise, and existing facilities of others
   through third-party partnerships in order to achieve universal coverage
   for all technology types as rapidly as possible. Third-party verification
   organizations are chosen from the both the public and private sector,
                                                   Verification Strategy

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   including states, universities, associations, business consortia, private
   testing firms, and federal laboratories. EPA designs and conducts
   auditing and oversight procedures of these organizations, as
   appropriate, to assure the credibility of the process and data. In order to
   determine if EPA participation is important to the commercialization
   process, ETV is testing the option of one totally unstructured and
   independent, private sector pilot in which EPA's  role will be solely
   fiduciary. In addition, the Agency will continue to  publish the results of
   commercial-ready technology evaluations that it conducts in the normal
   course of its business.

4. PilotPhase
   The program will begin with a five year pilot phase to test a wide range
   of partner and procedural alternatives, as well as the true market
   demand for and response to such a program. Throughout the pilot
   period, EPA and its partners will operate in a flexible and creative
   manner in order to  identify new and efficient methods to verify
   environmental  technologies, while maintaining the highest credibility
   standards. The operational objective will be to actively look for ways to
   optimize procedures without compromising quality. The ultimate
   objective of the pilot phase is to design and implement a permanent
   verification capacity and program within EPA, should the evaluation of
   the effectiveness of the program warrant it.

5. PilotTechnologyAreas
   ETV has begun with pilots in narrow technology areas in each of the
   major environmental media and will expand as appropriate, based on
   market forces,  availability of resources, and the willingness of the
   marketplace to pay for third-party verification.  For example, the drinking
   water technology pilot has started with a focus on microbial and
   particulate contaminants, and disinfection byproducts in small systems
   (less than 3300 users), an obvious and very large domestic and
   international market with pressing environmental problems. In future
   years, the program will be expanded to the wider area of nitrates and
   synthetic organic chemicals and pesticides in all drinking water
   systems. Success in particular technology areas will allow the program
   to have a "pump-priming" effect to bring new technologies to the
   marketplace. Selection criteria for ETV pilot programs and other
   verification focus areas are discussed in a subsequent section of this
   paper.
Verification Strategy

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6. Stakeholder Groups
   ETV is guided and shaped by using the expertise of appropriate
   stakeholder groups in all aspects of the program. These groups consist
   of representatives of all verification customer groups: buyers and users
   of technology, developers and vendors, and, most importantly,
   technology "enablers", i.e., the consulting engineering community that
   recommends technology alternatives to purchasers, and the state
   permitters and regulators who allow it to be used. Stakeholder groups
   must be unique to each technology area in order to capture the
   important individual aspects of the different environmental media and to
   get buy-in from affected groups. For example, state drinking water
   permitters are necessary to participate in development of testing
   protocols for cryptosporidium; air pollution regulators are needed to
   evaluate innovative compliance monitoring devices; metal production
   parts manufacturers need to help design testing procedures for new
   coating compounds. In general, the role of stakeholders will be to assist
   in the development of procedures and protocols, prioritize types of
   technologies to be verified,  review all important documents emerging
   from the pilot, assist in defining and conducting outreach activities
   appropriate to the particular area, and, finally, to serve as  information
   conduits to the particular constituencies that they represent. As of
   September 1997, over 180  individuals are serving in the six
   stakeholder groups formed to date.

7. Private Sector Funding
   Over the five year pilot phase of the program, the costs of verifying
   technologies in many pilots will move from a primarily government
   funded effort to a primarily private sector funded effort. At least two
   pilots will be vendor supported from the beginning. The original goal, as
   articulated in the 1994 strategy, called for complete private sector
   sponsorship within three years. A recent review (1995) of the program
   by a distinguished panel of outside experts convened by the EPA
   Science Advisory Board (SAB) concluded that such a goal was
   probably not achievable in so short a time-frame (they suggested five to
   eight years) and that some level of government support (10 to 20% of
   ongoing costs) would remain necessary to keep the activity viable.
   Conclusions on this issue will be reached as data emerge on the
   economic value-added of the program and the level of cost that the
   private sector is willing to bear in the various technology sectors.
                                                   Verification Strategy

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8. Pilot Evaluation and Program Decisions
   The Agency will collect data on operational parameters, e.g., number of
   participants; cost and time required to perform tests and report results,
   and on outcomes, e.g., use of data by the states and public; sales
   reported by vendors, in order to evaluate all aspects of the program.
   EPA will use this information to make long-term recommendations to
   the Congress on the future and shape of the program in 2001. Among
   the choices at that time will be the formulation of a permanent, broad
   scale program; the narrowing of efforts to certain areas in which ETV
   appears to be effective; or the discontinuance of verification efforts. The
   latter conclusion could be reached either because state regulators/
   permit writers and the technology innovation industry are not assisted
   by ETV or because the cost of verification proves to be prohibitive.

9. Outreach and Information Diffusion
   As was pointed out by the SAB in its 1995 review of ETV, verification
   alone will not  move better, cheaper, faster technologies to success in
   the marketplace. In particular, substantive and substantial interface with
   the permitters of environmental technology (primarily at the state level)
   will be  necessary to have any chance of rapidly implementing
   innovative approaches. To date, the outreach activities of the program
   have been limited to assuring substantial state representation on the
   Stakeholder Groups that are designing the protocols and procedures
   for each pilot; developing informational fact sheets about the program;
   and placing a Web page  on the Internet. In 1998, the Agency intends to
   develop an overarching outreach strategy through consultation with all
   affected groups and with the help of major organizations in the
   technology area, e.g., National Governors Association, Western
   Governors Association, Environmental Council of the States, National
   Pollution Prevention Roundtable, appropriate corporations, and others.

10. Market Gap Definition
   Lastly,  EPA will track applications and expressions of interest on the
   part of technology developers who come to all parts of  the Agency that
   do not fit into the present suite of verification activities.  This universe
   will be characterized during the initial stages of the pilot period and a
   strategy to address gaps will be developed.
Verification Strategy

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ETV Pilot Process

       Although a wide degree of flexibility will characterize the pilot
projects (see above), each ETV pilot generally will go through two periods
of development: an organizational phase and an operational phase (see
Figure 1).
Figure 1. ETV Pilot Process
      Organization Phase
  Operations Phase
       Verification Organization (VO)
               Selected
                (EPA)
                I
    Open Solicitation
         (VO)
      Stakeholder Groups Formulated
               (EPA/VO)
Generic/Tailored Test Plans
     (Developer/VO)
         Technologies Prioritized
                 and
       Generic Protocols Developed
         (EPA/VO/Stakeholders)
     Testing byVO
         OR
  Testing by Developer
   (With VO Oversight)
                                                        I
                                                     QA Evaluation
                                                       (EPA/VO)
                                               Verification Report/Statement
                                                       (EPA/VO)
                                                  Information Diffusion
                                                   (EPA/Stakeholders)
                                                          Verification Strategy

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Organizational Phase
    During the organizational phase, EPA will select one or more partner
    organizations to oversee and conduct verification activities. This
    important step will usually occur through an open solicitation process,
    although some exceptions will be appropriate. All partner proposals will
    be peer reviewed. EPA and its partner(s) will then select approximately
    25 appropriate participants for the Stakeholder Group (see #6) that will
    guide the progress of the program. EPA may formulate the
    Stakeholders Group prior to selecting the partner organization if the
    procurement process is protracted. Stakeholder Groups will then begin
    the important process of establishing priorities and defining procedures
    and protocols appropriate  to that particular type of environmental
    technology and customer group.

Operational Phase
    Once the basic building blocks of the program are in place, actual
    verification activities begin (these steps will not always be strictly
    sequential). Verification activities in each technology area will be
    announced in the Commerce Business Daily and other appropriate
    publications to encourage maximal participation by technology
    developers, and to assure a level playing field. Test plans will be
    developed with the participation of developers and tests conducted by
    independent third parties (either the verification organization or other
    testing organizations approved by the verification organization).
    Appropriate quality assurance procedures  will be incorporated into all
    aspects of the project and reports will be peer reviewed. Verification
    statements of three to five  pages, based on the performance data
    contained in the reports, will be issued by EPA and appear on the ETV
    Internet Web page. Other outreach activities, as defined by the
    Stakeholder Group, such as state permitter training, will be conducted.
Verification Strategy

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Selection Criteria for ETV Pilot Projects

      The appropriate selection of verification pilot programs and other
ETV verification activities to be carried out under the program is critical to
its ultimate success. The ETV pilot programs are designed to meet the
needs of the many stakeholders in environmental technology, while
allowing EPA to experiment with a variety of procedures and partnership
arrangements to determine the optimal form of program implementation.
The following criteria have been used to choose ETV verification pilots
and other verification activities. The first three criteria are applied in
cascading order, i.e., each pilot passes the previous criterion in order to go
on to the next.

1. AddressImportantEnvironmental Needs
   All programs conducted by the EPA have environmental improvement
   and  protection as their ultimate objective. It is particularly important
   that  this program, which is designed to assist the environmental
   technology industry, select pilot verification activities that have clear
   and  positive environmental benefits. Such  benefits may improve the
   environment by achieving higher levels of pollution reduction or by
   accelerating the rate of technology implementation through  lower cost
   or simplified operation.

2. Present Substantial Business Opportunities for the Private
   Sector
   Pilot areas selected have clear market niches, both domestically and
   internationally, that present the potential for a substantial increase in
   technology sales and use. Although voluntary environmental
   improvement technologies, e.g., indoor air filtration systems, and
   existing regulatory program technologies, e.g., hazardous waste
   monitoring devices, are of interest to the program, particular attention
   will be paid to technology areas that stress the Agency's commitment to
   pollution prevention or address upcoming regulatory requirements and
                                                   Verification Strategy

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                      deadlines that present obvious and major opportunities for innovation
                      and increased economic activity.

                   3.  Involve Multiple Developers andVendors
                      To clearly demonstrate the potential of a successful verification
                      program, the ETV pilots must benefit the largest possible number of
                      technology developers and users.  Pilot programs will focus on areas in
                      which a number of technologies and companies are active.

                      The last two criteria are programmatic and allow the Agency to test
                   operating program parameters in the pilot phase.

                   4.  Address the Full Range of Environmental Media
                      Assuring that all major environmental media and program areas are
                      included in the pilots will allow ETV to begin interaction with interested
                      parties, e.g., technology developers, technology buyers, regulation
                      writers and state permitters, across a broad range of environmental
                      areas. This will assist the program to identify particularly fruitful
                      technology focus areas for the future,  spread the word about the EPA
                      verification function widely, identify regulatory barriers that inhibit the
                      use of verified technologies, and assist developers across a wide
                      spectrum of technology.

                   5.  Test a Variety of Verification Organization Types
                      As described above, EPA is interested in evaluating all possible
                      verification organization alternatives, including federal government
                      laboratories, state verification programs, universities, industry
                      associations, independent testing  organizations, and developer
                      conducted  testing (with verification organization or EPA oversight).
                      Pilot programs selected are expected to cover all of these alternatives.

                         Having applied the above criteria to a wide variety of potential pilot
                   candidates, the Agency has selected twelve categories as ETV pilots (see
                   Table 1).
10                 Verification Strategy

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Table 1.ETV Pilots
     1.  Site Characterization & Monitoring Technologies
     2.  P2, Recycling & Waste Treatment Technologies
     3.  Drinking Water Systems
     4.  Indoor Air Products
     5.  P2 Innovative Coatings and Coating Equipment
     6.  EvTEC (any technology area)
     7.  Advanced Monitoring Systems (Air and Water)
     8.  Air Pollution Control Technology
     9.  Greenhouse Gas Technology
     10.  Wet Weather Flow Technologies
     11.  Source Water Protection Technologies
     12.  P2 Metal Finishing Technologies
2001 Report to Congress

      ETV will prepare a Report to Congress, to be sumitted in 2001.  The
questions that will be addressed in the Report include:

   1.  Does the environmental marketplace need/value an EPA
       verification program?
   2.  Is the need different from one technology area to another?
   3.  Can we design a credible program that the developer community
       can afford?
   4.  Where is value added from ETV:
       •  Protocol development?
       •  Third party QA oversight?
       •  EPA Verification Statement?

ETV Program Vision and  Projected Development
Scenario

      Figure 2 lays out the projected ten year development scenario for
the ETV Program in which assumptions are made concerning: (1) the
amount of funding received by the program; (2) the number of viable
technology areas (defined as pilots in the early stages) needed; (3) the
number of EPA staff assigned to quality assurance and technical oversight;
and (4) the number of new technologies that come to the program for
verification. All of these assumptions are  projections based upon the
                                                 Verification Strategy
11

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Figure 2. ETV Program Scenario

ou
45 -
40 -
35 -
30 -
25 -
20 -
15 -
10 -
5 -





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1995 1996 1997 1998 1999 2000 2001 2002 2003








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2004








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2005
• Federal $M Per Year n Technology Areas
• # Verified Technologies Per Year n FTE


                    experience of technology verification programs in other fields and the level
                    of resources needed to accomplish the work projected. Changes to any of
                    the assumptions would, of course, change all of the projections.


                    1.  Federal Funding
                       The projected budget moves from $7M in 1995 to $1OM for three years
                       of development and building market acceptance. It then begins a
                       gradual decline as the private sector pays more and more of the costs.
                       By 2005 the steady-state cost of the program for all environmental
                       areas is projected to be $2M.
 12
Verification Strategy

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2.  TechnologyAreas
   Starting in 1995, pilot programs gradually expand to cover all
   appropriate environmental areas (areas defined primarily by customer
   groups). By 1998, twelve areas are defined and implemented and
   remain in place throughout the program, although their technology
   focus can shift over time, based on market forces.

3.  EPA Personnel2
   EPA staff necessary to oversee third-party verifiers and maintain the
   quality and credibility of the program move from 10 in 1995 to as many
   as 30 while the program is in its formative stages. As procedures and
   quality assurance measurers become routinized, staff demands
   gradually lower to a steady state  of 10 FTE by 2003.

4.  VerifiedTechnologies
   Due to a demand backlog, the number of technologies verified rapidly
   rises from five in 1996 to 50 in 2001, and then declines to a steady state
   of about 30 to 35 technologies each year.

      If executed as projected in this scenario, the Environmental
Technology Verification Program could reasonably be expected to verify
the performance of approximately 300  innovative technologies in a
decade.
   2 EPA personnel are assigned to ETV from appropriate media areas (e.g., drinking
     water, advanced air monitors) within ORD's national laboratories and centers
     based upon programmatic requirements. Six EPA staff are assigned to ETV
     directly for management coordination, information dissemination, and oversight.
                                                    Verification Strategy                 13

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               ETVWeb Site Information
                          Accessing  the Latest ETV Information

                    Ongoing information about the progress of the ETV Program,
                 including all published documents and a list of upcoming events, can
                 be downloaded from the ETV Web Site at http://www.epa.gov/etv
14
Verification Strategy

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