SAB-EEC-86-017
REPORT
on the review of the
SUPERFUND INNOVATIVE TECHNOLOGY EVALUATION (SITE) PROGRAM
DRAFT STRATEGY AND PROGRAM PLAN
prepared by the
Office of Research and Development
and the
Office of Solid Waste and Emergency Response
by the
Environmental Engineering Committee
Science Advisory Board
U. S. Environmental Protection Agency
June, 1986
Washington, DC 20460
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INTRODUCTION |
Background
While most experts agree that there are a number of technologies which are
suitable to prevent or mitigate releases of hazardous substances from Super-
fund sites, by far the most prevalent in practice has been to use some land-
based containment approach. In most cases, this has meant the removal of
contaminated soils from a Superfund site to a permitted RCRA hazardous waste
facility. The public, the engineering community, and the Congress, have all
noted that this approach can result in transferring the problem on a long-
term basis from one site to another, without an ultimate remedy.
In October, 1985, the Environmental Engineering Committee of the Science
Advisory Board expressed its concern, in a resolution to the Administrator
of EPA, that enormous expenditures were being made under Superfund without
an adequate technological data base to support rehabilitation of both public
and private hazardous waste disposal sites. • .
In January, 1986, the Administrator responded to the Science Advisory Board,
stating that he shared the Board's concerns, and noted that the Office of Re-
search and Development and the Office of Emergency and Remedial Response
(OERR) were developing a strategy for a Superfund Innovative Technology Evalu-
ation (SITE) Program to address some of these issues. The goal of this pro-
gram is to enhance the development, demonstration, and use of new or innova-
tive technologies that are effective. The Agency expects to receive authority,
under proposed amendments to CERCLA, to expend Superfund monies on such pro-
jects.
EPA convened an advisory group consisting of representatives from industry,
academia, state and local governments, and other Federal agencies, to identify
how to evaluate impediments to the development and use of alternative techno-
logies, how to remove these impediments or to develop methods to promote ex-
panded use, and how to develop a program to demonstrate and evaluate selected
technologies. Dr. Raymond C. Loehr, who chairs the Environmental Engineer-
ing Committee of the SAB, is a member of this group.
At an October 21-22, 1985, meeting of the Environmental Engineering Committee
Dr. John Skinner, Director, Office of Environmental Engineering and Technology,
ORD, asked the EEC to review the Program, and to advise him on how best to pro-
ceed. The Agency, with the assistance of the advisory group, has produced a
draft SITE Program Strategy and Program Plan, which was referred to the EEC
for review in January, 1986.
This report is the result of that review.
Committee Review Procedures
A Subcommittee of the Environmental Engineering Committee, consisting of
Dr. Davis L. Ford (Chairman), Mr. Richard Conway, Dr. Raymond C. Loehr and
Dr. Mitchell Small, was organized to initiate the review. This Subcommittee
met on the evening of February 12, 1986, and prepared a rough draft of its
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comments. On February 13, 1986, at a regular meeting/jof the Environmental
Engineering Committee, Mr. Alfred Lindsey, OEET, briefed the Committee on
the contents of the draft Strategy and Program Plan. The Committee then
expanded the rough Subcommittee draft, and directed Mr. Torno to complete
the report and to circulate the completed draft to the Committee for their
final approval and subsequent submission to the Agency.
REVIEW OF DRAFT SITE PROGRAM STRATEGY AND PROGRAM PLAN
General
The Agency has produced a draft plan, which incorporates some important com-
ponents necessary to the implementation of an effective research, development
and demonstration program. The document's major strengths include:
A. A clear exposition of the problem, and the goals and objectives of
the Program.
B. A succinct summary of the impediments to the development and use .of
alternative technologies.
C. The emphasis on getting the Program moving, without waiting to be
sure that all problems have first been resolved.
To be effective, the Plan must: (a) have the endorsement of the Administrator
and other senior officials of EPA, (b) be recognized as a long-term (at least
5 years) effort and commitment, (c) be adequately supported with personnel
and funds on a sustained basis and (d) have dedicated EPA persor-^l at Head-
quarters, at specific research laboratories and in the regions. If this is
not clearly understood by senior EPA administrators, the SITE Program will
not achieve the desired success and will result in a waste of scarce resour-
ces, including an unfortunate diversion of EPA personnel.
Specific Comments
A. Liability is a key concern relative to the SITE program. The Com-
mittee recognizes that the CERCLA reauthorization legislation addres-
ses this issue and cannot be finalized at this time. However, the
Committee believes that "hold harmless" clauses or the limitation of
liability to the contractor's insurance coverage will be necessary
before the SITE program can be successfully implemented.
B. The Committee believes that the technology orientation initially will
be in the areas of immobilization and thermal oxidation. The other
candidate technologies, such as chemical or biological removal, would
take longer to evaluate, but should be considered as viable options.
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C. The Committee believes that the institutional -barriers have been re-
cognized in the report and agrees that these barriers should be mini-
mized to the greatest extent possible. The permitting is critical •
and a RCRA ROAD permit may be the most expeditious way of permitting
a demonstration project as compared to the "Part B" route. The Com-
mittee recognizes that the cost effectiveness of emerging or demon-
strated technology would be difficult to assess in the early stages.
It is also noted that time is required before the O&M'costs can be
accurately evaluated.
D". It is critical that delisting of treatment residues be-addressed.
This could be a major impediment or constraint for some of the can-
didate technologies.
E. A thorough review of factors affecting the successes and failures un-
der previous demonstration grant programs should be made in addition
to the review of the 1977 Innovative Technology Program under Title
II. Examples of demonstration technologies previously evaluated in-
clude the UNOX process, the Zimmerman process, and the PACT process.
F. The Committee strongly believes that there should be a singular re-
sponsibility for the demonstration program structure. As presently
outlined, it is not clear who has overall responsibility, ORD or
OSWER.
G. The solicitation for innovative technologies more clearly should in-
clude the regulated community and the engineering consultants. More-
over, it is imperative that the international community be made aware
of this program, as they could have a significant incentive to become
involved from both a technological and commercial basis.
H. The criteria for evaluating technologies are of utmost importance.
Some minor clarifications are required with regard to (a) permanence
of solution if successful, (b) state of technology development (pro-
bability of success), and (c) regulatory compliance.
I. The SITE management in EPA should try to obtain more senior people
from other sources including (but not limited to) the Corps of Engi-
neers, the Navy civil engineering program, retired military, or re-
tired industry personnel, to insure professional management of these
projects (the Committee notes that the Agency already has a program
to use retired individuals - the Senior Environmental Employment
(SEE) Program, which is administered in the Office of Exploratory Re-
search).
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K.
The Program should demonstrate the technical and economic feasibility
of a number of innovative technologies. Limited resources will per-
mit only a few demonstrations {probably less than thirty) during the
life of the Program. To have the greatest impact, particularly in
the early years when it is important to show some successes, the
technologies should be demonstrated at actual CERCLA sites to indicate
the ability of a technology to solve all or part of a real problem.
The Plan should better define "fully proven" - there is a point at
which EPA can (and probably should) say that a specific technology
is acceptable, with all that such a judgement implies.-
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