V-/EPA
United States
Environmental Protection
Agency
Office of
Solid Waste and
Emergency Response
Publication 9345.0-051
September1991
ECO Update
Office of Emergency and Remedial Response
Hazardous Site Evaluation Division (OS-230)
Intermittent Bulletin
Volume 1, NumbeM
The Role of BTAGs in Ecological Assessment
Most EPA Regions have established groups of scientists to
advise and assist site managers with ecological studies pro-
duced in conjunction with Remedial Investigations and
Feasibility Studies (Rl/FSs) andRemoval Actions at Superfund
sites. In general, these groups are known as Biological Tech-
nical Assistance Groups or BTAGs, although some Regions
use different names. This Bulletin summarizes the BTAG
structure and function in the Superfund process. Its purpose
is to help site managers understand how BTAGs can assist
with the collection and evaluation of site information and
ensure that ecological effects are properly considered.
Why BTAGs?
The Comprehensive Environmental Restoration, Compen-
sation, and Liability Act (CERCLA), and the National Oil and
Hazardous Materials Contingency Plan (NCP) mandate that re-
medial actions at hazardous waste sites protect both human health
and the environment. In December 1988, the Directors of EPA's
Office of Emergency and Remedial Response (OERR) and Office
of Waste Programs Enforcement (OWPE) issued a memorandum
directing Regional Offices to perform "thorough and consistent"
ecological assessments at all Superfund sites. The memorandum
also encouraged the Regions to establish BTAGs, and EPA
Headquarters policy continues to support the BTAG process as a
means of ensuring quality ecological assessments.
Every site presents a unique combination of biological,
hydrological, geological, and chemical characteristics. Site man-
agers are responsible for overseeing a wide range of activities and
cannot be expected to have expertise in all the necessary scientific
areas. BTAGs serve a valuable function in providing the necessary
advice and-review of ecological information.
The Superfund Environmental Evaluation Manual,1 issued in
1989, was intended specifically to be used in conjunction with a
consultative framework such as that provided by BTAGs. It was
designed to provide an overview of the scientific and regulatory
basis for conducting ecological assessments, and to direct site
managers to Regional specialists (i.e., BTAGs) for assistance in
planning, designing, and conducting specific studies.
'U.S. Environmental Protection Agency, Risk Assessment
Guidance for Superfund, Volume II: Environmental Evaluation
Manual (EPA/540-1-89/001), 1989.
IN THIS BULLETIN
Why BTAGs? 1
The BTAG Coordinator: 2
Who Is on the BTAG? 2
What Does the BTAG Do? 2
What the BTAG Will Not Do 4
How to Work with the BTAG .,4
ECO Update is a Bulletin series on ecological assessment of Superfund sites. These Bulletins serve as supplements to Risk Assessment Guidance
for Superfund, Volume II: Environmental Evaluation Manual (EPA/540-1-89/001). The information presented is intended as guidance to EPA and
other government employees. It does not constitute rulemaking by the Agency, and may not be relied on to create a substantive or procedural right
enforceable by any other person. The Government may take action that is at variance with these Bulletins.
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The BTAG Coordinator
The BTAG Coordinator is a person within EPA Regional
staff that maintains the logistics of the BTAG. In some Regions,
this responsibility is shared by more than one individual.
Coordinators maintain regular contact with BTAG members,
provide necessary documentation to members prior to upcoming
reviews, and work directly with site managers. BTAG Coordinators
also maintain frequent communication with their Regional coun-
terparts to share techniques and ideas.
In some instances, Coordinators screen sites to determine the
need and/or extent of BTAG involvement. Sites requiring no
ecological assessmentwill not be brought before the group, thereby
saving review time by focusing the membership, on those sites
requiring their attention.
Who Is on the BTAG?
BTAGs represent a variety of disciplines, including wildlife
biology, fisheries, soil science, aquatic toxicology, ecology, geol-
ogy, hydrology, risk assessment, and wetlands science. The spe-
cific composition of each BTAG varies from Region to Region.
The core of the BTAG membership usually includes the BTAG
Coordinator, plus staff from the Regional Environmental Services
Division who specialize in environmental monitoring, surveillance,
and assessment.
Several BTAGs typically include the National Environmen-
tal Policy Act (NEPA) coordinator, a member of the OERR's
Environmental Response Team or Toxics Integration Branch, and
biologists from other EPA Program Offices such as Wetlands,
Water, and Air. Other Federal agencies frequently represented on
BTAGs include the National Oceanic and Atmospheric Admin-
istration, the U.S. Department of the Interior, the U.S. Fish and
Wildlife Service, the U.S. Geological Survey, and the USDA
Forest Service. Some BTAGs may include representatives from
State agencies.
Because of their scientific expertise, representatives of Natu-
ral Resource Trustee agencies typically are included on the BTAG.
These individuals are serving in a technical advisory capacity and
BTAG consultation does not constitute Trustee notification as
required by CERCLA. Site managers must still notify all au-
thorities who may be Trustees, in accordance with the law.
Who Is on the BTAG and
What Do They Do?
Possible Members:
EPA-HWD/ESD, Wetlands, Water, NEPA
Coordinator
U.S Fish and Wildlife Service
National Oceanic and Atmospheric Administration
State Agencies
Others
Responsibilities:
Advise RPM on all aspects of ecological assessment
Define scope
Review Work Plan
Review Draft Rl and FS
Help select alternatives
Review RD/RA Plans
Provide Expert Testimony
What Does the BTAG Do?
Figure 1 summarizes the role of the BTAG in relation to the
site manager and contractor. The BTAG functions primarily in an
advisory and review capacity, although individual BTAG mem-
bers, or the agency they represent, may provide additional services
to support the ecological activities.
Most BTAGs meet monthly, usually for a period of one to two
days. Meeting agendas vary from month to month, depending upon
the number of sites to review, individual site status, and time of
year (e.g., field season). Generally, 10 to 20 people participate in
BTAG meetings.
In some Regions, the BTAG operates within the formal
framework of a charter statement of purpose. Some of the advan-
tages noted by members of formal BTAGs include increased
efficiency of communication, an easily accessible record of meet-
ing events, and the assignment of specific roles and responsibili-
ties. In most cases, however, BTAG meetings remain informal or
semi-formal, depending on Regional operating policy.
The BTAG serves an advisory role; it functions to assist site
managers with the collection and evaluation of information needed
to assess ecological effects at Superfund sites. By performing this
advisory function, BTAGs help toensure that CERCLA mandates
are met with regard to protection of the environment.
The BTAG permits a peer review of ecological studies,
reaching consensus on recommendations made to site managers.
Without consultation of these experts as a group, solicitation of
input would be prohibitively time-consuming, and the quality of
ecological assessments might not meet CERCLA mandates.
Continued on page 3
September 1991 Vol. l.No.l
ECO Update
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Who Does What?
Figure 1
DIRECTS
ADVISES
[ ECOLOGICAL STUDY* [
T t
REVIEWS
EPA CONTRACTOR
CONDUCTS
and
PREPARES
I
* Ecological Study Includes ecological assessments as pan" of the baseline risk assessment, ecological studies such as
toxicity tests and field studies, evaluation of remedial alternatives, ecological portions of RODs, and ecological plans.
BTAGs serve several essential functions to ensure adequate
consideration of ecological issues at Superfund sites. These include:
Initial site review,
Assistance in developing a work scope,
Review of contractor qualifications and performance,
Review of interim and final products,
Evaluation of remedial alternatives, and
Advice on remedial decisions, remedial design,
and remedial actions.
Initial Site Review
BTAGs can facilitate the early stages of the remedial process
by screening initial site data from such sources as the Preliminary
Assessment and Site Investigation to determine the nature and
extent of an ecological assessment. BTAG screening of initial site
data can help streamline the remedial process by ensuring that
ecological investigations are pertinent to remedial objectives. For
example, based on a review of environmental concentrations of
site contaminants in various media, the BTAG will only recom-
mend relevant exposure pathways for further study.
Assistance in Developing a Work Scope
An important role for the BTAG membership involves assist-
ing the site manager with scoping the ecological assessment effort.
BTAG involvement in the preparation, review, and approval of
work plans ensures that ecological work is focused, performed in
a timely manner, and technically correct. Specifically, BTAGs can
recommend study objectives, field and laboratory protocols, QA/
QC requirements, and other elements of a work plan. Because of
their direct experience, the BTAG members may also help identify
qualified investigators to perform ecological assessment.
The BTAG also can assist in the initial identification of
ecological Applicable or Relevant and Appropriate Requirements
(ARARs).
Review of Contractor Qualifications and
Performance
BTAGs can assist the site manager by reviewing and com-
menting on contractor qualifications and performance. Product
quality depends not only on the company performing or overseeing
the activity but on the experience of the personnel within that
company responsible for the product BTAG involvement can help
ensure adequate contractor performance beginning early in the
process. For example, an inadequately prepared work plan may
indicate that the contractor does not have the necessary expertise
available to carry out the requisite ecological investigations. If
contractor expertise is lacking, the BTAG may be able to identify
resources to carry out the needed work. BTAG consultation also
can facilitate communication-fee^tween the site manager and the
contractor.
Review of Interim and Final Products
Site managers can use the BTAG to review and evaluate
interim products that include ecological studies. Based on the data
in such a product, the BTAG may recommend modifications to the
original work scope. This kind of "mid-course correction" can
save a project time and money.
Continued on page 4
ECO Update
September 1991 Vol. l,No.l
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The BTAG can litiake recommendations for additional data
following the initial review. If the initial data are incomplete, the
BTAG can recommend the types of biological data (e.g., field
studies, toxicity tests) needed to characterize the ecological risks
posed by the site. For example, the BTAG may recommend
collection of more data on site chemistry, habitat identification, or
other information that will allow them to determine the need for,
and extent of, biological data.
The BTAG should review the draft and final ecological
assessment to ensure that this portion of the Remedial Investiga-
tion has been completed in an acceptable manner. Because eco-
logical assessment has no\ standardized methods for evaluating
risk, informed professional Judgment is necessary to determine if
the weight of evidence supports a particular set of conclusions.
BTAG endorsement of the final ecological assessment will indi-
cate to approving authorities that ecological concerns have been
adequately addressed.
Evaluation of Remedial Alternatives
BTAG involvement in the evaluation of remedial alternatives
ensures the protection of environmental receptors. The collective
expertise of the BTAG can be used to assess the adequacy of the
ecological-effects evaluation for each alternative. BTAG review
of alternatives also can ensure that ecologically related AR ARs are
addressed.
Advice on Remedial Decisions, Remedial
Design, and Remedial Actions
BTAG involvement continues to be important during the
remedial design (RD) and remedial action (RA) phases. The
BTAG can evaluate the quality and completeness of work plans,
and advise on remediation and monitoring activities. BTAG par-
ticipation in this phase ensures that ROD and CERCL A mandates
are met.
For example, the ROD for a site recently undergoing RD
required creation of a new wetland. Within the body of the ROD
and associated documents were specific guidelines as to the
wetland design, plant species required, methods required to plant
vegetation to ensure desired growth, etc. However, BTAG review
of thecontractor's workplan showed that very few of the necessary
ecological requirements were addressed: plant species were not
specified, proper planting methods were missing, etc. Further-
more, the plan did not include the participation of a wetland
scientist The BTAG recommended that the specific requirements
of the ROD be achieved by inclusion of a qualified wetland
scientist to ensure that the remedial objectives would be achieved.
In at least two Regions, the Superfund Division Director will
not sign a Record of Decision (ROD) unless the BTAG has
reviewed the site. In other Regions, RPMs are expected, but not
necessarily required, to obtain BTAG review before submitting
RODs for approval.
Finally, the BTAG can assist with the development of plans
to monitor ecological effects as sites move into the post-remedial
monitoring stage. Regular review of monitoring data by the BTAG
will help the RPM continue to see that ROD requirements are met.
What the BTAG Will Not Do
The BTAG functions in an advisory capacity; as such it does
not, as a group, provide direct field or laboratory services. In
specific cases, it may be possible to make arrangements (such as
inter-agency agreements in the case of non-EPA staff) for individual
BTAG members to become directly involved in conducting por-
tions of the investigation.
- The BTAG does not normally communicate directly with
responsibleparties or their contractors. Advice isprovided directly
to the site managers.
The BTAG does not write work plans and protocols, nor does
it conduct risk assessments. As an advisory group, the BTAG
functions to assist the site management process by reviewing and
commenting on sampling and analysis plans, ecological risk
assessments, and ecological implications of remedial decisions.
The BTAG focuses resources on site-specific requirements by
performing a quality assurance/quality control function on a
continuing basis.
How to Work with the BTAG
Consultation with the BTAG should follow-the phased ap-
proach of site management At appropriate stages throughout the
RI/FS process, the site manager should use BTAG assistance and
advice to coordinate and monitor ecological studies. This consul-
tation allows for periodic re-assessment of goals and objectives,
and ensures a focused and high-quality investigation.
The first line of communication is the BTAG Coordinator,
who can convene meetings and help the site manager select
appropriate data for BTAG review. When the BTAG initially
considers a site, the site manager should provide a brief oral
presentation of the site history. Before the meeting, members
should be provided copies of relevant documents and reports.
Without exception, the quality of BTAG help is directly related to
their timely receipt of site data. D
This Bulletin has described in general terms how the BTAG can ensure that ecological concerns are
properly addressed in the Superfund process. To be certain that CERCLA mandates regarding protection
of the environment are met, site managers should consult their Regional BTAG Coordinator at the earliest
possible stage of the site assessment.
September 1991 Vol. l.No.l
ECO Update
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