UNITED STATES ENVIRONMENTAL PROTECTION AGENCY	fTT^
REGION VIII (8HWM-SM)	jT7Ttfj
999 18th STREET - SUITE 500	I^T~n
DENVER, COLORADO 80202-2466
Region VIM
Region 8 Superfund Technical Guidance
No. ER-01: ETAG for Region 8	September 1994
Ecological Risk ( Short Title / Key Words)
TITLE:
authors:
approvals:
(initials)
Hazardous Waste Management Division, Superfund Management Branch, Technical Section
SUMMARY
This Regional guidance is intended to outline the general formation and
operation of Region VIII ETAGs (Ecological Technical Assistant Groups) for Superfund
ecological risk assessments (ERAs). ETAGs (or alternatively, BTAGs, Biological TAGs)
have recently been created throughout EPA at Regional levels to establish an available
team of ecologically relevant professionals for consultation and review of EPA
ecotoxicological activities. The ETAGs are expected to help EPA achieve better ERAs
through consideration of broad-based professional inputs on field sampling designs,
population and habitat characterizations, selection of important assessment and
measurement endpoints, and interpretations of results. Functional ETAGs should be
operated efficiently and should help provide greater scientific credibility, consistency
and comparability for EPA ecological risk assessments.
Operation of the ETAG (Ecological Technical Assistance
Group) for EPA Region VIII Ecological Risk Assessments
Region 8 Toxicologists	contact: Dr. Gerry Henningsen
ph: 303-294=7656-
8M	\ h/s/tj
Chief, TS / dale	Chief, SM / dale	DirectedWM {date '
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Region 8, U.S. EPA
Technical Guidance
SOP# 8ER-01
September 1994
ETAG for Region VIII
PURPOSE
The purpose of the ETAG (Ecological
Technical Assistance Group) is to assist
EPA remedial project managers (RPMs) in
adequately addressing scientific aspects of
environmental impacts at hazardous waste
sites. It is noi intended to serve as a
forum through which state and federal
agencies formally transmit their concerns
or recommendations regarding natural
resource trustee (governmental land
owners or overseers) issues.
Interactions by RPMs or by other
officials with the ETAG do not constitute
formal notification to natural resource
trustees or the identification of Applicable
or Relevant and Appropriate Requirements
(ARARs) as required by CERCLA.
Separate processes exist for these
purposes. However, early involvement
and coordination with the trustee agencies
by the RPMs, usually through the Regional
ETAG, will enhance the efficiency of the
remedial process by minimizing repetitious
or unnecessary sampling and analysis.
ORGANIZATIONAL FRAMEWORK
ETAG participants can represent a
variety of disciplines: wildlife and aquatic
biology, toxicology, fisheries, ecology,
wetlands, botany, soil science, geology,
and hydrology. The Regional ETAGs are
usually comprised of representatives from
several state and federal agencies as
relevant to an EPA site, including: U.S.
EPA offices of Superfund and Water or
Wetlands and RCRA, U.S. Fish and Wildlife
Service and/or U.S. Biological Survey
(D.O.I.), Bureau of Land Management,
U.S. Geological Service, U.S. Forest
Service, State Department of Health, and
State Division of Wildlife.
EPA will chair and otherwise
manage the ETAG groups, which are
planned to be established on a state by
state basis as needed in Region 8. The
EPA Chair will usually be the Regional
Superfund ecotoxicologist or the ETAG
Coordinator (if such a position is filled) in
the absence of the Chair. Other technical
advisors with special expertise may be
called upon to participate in scientific
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Region 8. U.S. EPA
Technical Guidance
SOP# 8ER-01
September 1994
discussions at the discretion of the core
ETAG workgroup.
REVIEW AND MEETING PROCESSES
As much as possible ETAG members
will only be consulted for pertinent stages
of document reviews and to discuss and
help resolve key ecotoxicological risk
issues. The EPA Regional ETAG
Coordinator, or the Chair, will be the
contact point for all requests and
interactions between RPMs and the ETAG.
To make best use of professionals'
limited time for ETAG work, the
Coordinator will serve as the interface
between RPMs and ETAG members to
screen and help prioritize requests for
critical reviews. ETAG members should
only be involved in productive work that
takes advantage of their expertise on items
that actually need their professional review
and iinput. Much of that work should be
able to be handled through mailings with
acceptable timeliness.
The Coordinator will help ensure
that reviews are focused on specific
critical issues, that the appropriate ETAG
members receive complete materials, and
that lollow-up occurs to get timely receipt
of comments. The Coordinator will work
closely with (or at times may fill-in as) the
ETAG Chair to manage the ecological
activities in a manner that complies with
EPA guidance and serves the RPMs.
The ETAG Chair is expected to
serve as a liaison with the Regional human
health toxicologists on comprehensive risk
assessments, ensuring that data sampling
and analyses are coordinated between
human health and ecological needs
(averting redundant or unnecessary
sampling and analyses). The ETAG Chair
can also assist the RPMs and human
health toxicologists place the ERA and
BRA into proper balance and perspective
for later RI/FS and ROD activities.
EPA will periodically set meeting
dates as required to support RPMs' needs,
with consideration of ETAG members'
schedules and availability. Meetings for
the Colorado ETAG will generally be held
at the EPA Region 8 Conference Center in
downtown Denver. ETAGs set up for
other Region 8 States will usually be held
at a convenient location in that State.
An agenda will be sent to the group
members about one to two weeks prior to
a meeting date, along with any site-
specific information requiring ETAG
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Region 8. U.S. EPA
Technical Guidance
review. Members are encouraged to
prepare to discuss review material; if a
member is unable to attend a meeting, an
informal copy of their comments should be
forwarded to the ETAG Coordinator before
the meeting. Comments will be distributed
at the meeting so that input of all
members is considered in the review and
recommendations process by the ETAG.
Site managers will be formally
notified of the inclusion of their sites in an
ETAG meeting, along with the time that
the site will be discussed, approximately
two weeks prior to the meeting. Unless
other sites specifically pertain to their site
(e.g., Arkansas River Superfund sites),
each site RPM is encouraged to stay only
for discussions involving their site.
If the EPA Chair cannot be present
at a ETAG meeting, the Coordinator can be
designated as the acting Chairperson. If
other ETAG members are unable to attend
a meeting, they should notify the ETAG
Coordinator prior to the meeting and try to
arrange for a substitute participant from
their Agency. Minutes of the meetings will
be taken, filed, and distributed by the
ETAG Coordinator or the Chair.
SOP# 8ER-01
September 1994
SITE SELECTION
The RPMs are currently responsible
for contacting the ETAG, normally through
the Coordinator, to request technical
assistance on their site. If it is
unnecessary for the site to be initially
reviewed, because of the nature of the site
and its known contaminants, the
Coordinator may elect to not bring the site
through a formal ETAG review meeting.
However, the names of all new sites
obtained by the Coordinator that have
substantial ecological concerns will be
provided periodically (quarterly) to all the
ETAG core members in the form of status
reports. Any member may request that a
new sites be reviewed by the ETAG at a
subsequent meeting. Status reports will
summarize ERAs by state and the current
stage in the EPA Superfund SA/PI, RI/FS
(including SACM), and ROD process.
REVIEW MATERIAL
The ETAG Coordinator will obtain a
copy of site-specific technical documents/
materials from the RPM and ascertain any
specific needs of the project manager.
The Coordinator will then condense this
material, as needed, by copying and
distributing only the relevant sections. A
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Region 8, U.S. EPA
Technical Guidance
brief overview in a cover letter will be
included to direct the ETAG reviewer,
stating any specific information or needs
that the RPM has requested. Additional
detailed sections of EPA reports and data
or other relevant information may be
requested by contacting the Coordinator.
A brief List of Contents will be included in
the provided package, so that ETAG
members can judge if they have been
given enough information needed to
adequately review the material.
RECOMMENDATIONS PROCESS
The ETAG will provide brief
summaries of consolidated site-specific
technical recommendations and other
comments to the respective EPA project
manager after review and discussion of
documents or issues presented to the
group. If opposing recommendations or
comments are provided on the same issue,
each will be summarized and forwarded to
the RPM with accompanying rationale for
each position.
All ETAG recommendations will be
compiled by the Coordinator and submitted
to the ETAG for a 10-day review before
final submission to EPA's project manager.
Technical recommendations may be
SOP# 8ER-01
September 1994
obtained on any document or issue which
the ETAG is requested to review by a
Regional EPA site manager. Any
recommendations will be from the Region
ETAG only and are based on the collective
technical expertise of the ETAG; they do
NOT constitute "consensus" or individual
Agency's comments or policy. Any
additional recommendations or comments
(especially as they relate to trustee NRDA
issues) that a Trustee Agency wishes to
present should be addressed to the Region
VIII EPA independently from the ETAG.
ETAG recommendations made to
RPMs will be directed to the current needs
of the site. As new information becomes
available or the status of the site
significantly changes, the site should be
reviewed again by the ETAG. The RPM
should consider any recommendations in
the overall technical framework of the
Superfund remedial process. See Figure 1
below on the ETAG process.
REVISION / REVIEW OF GUIDANCE
This guidance, and any other
guidance developed for or by the ETAG,
will be reviewed periodically and updated
as necessary. Changes to ecotoxicological
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Region 8, U.S. EPA
Technical Guidance
SOP# 8ER-01
September 1994
technical guidance will be made after
discussion and approval by the ETAGs.
REFERENCES
1. Framework for Ecological Risk
Assessment, Risk Assessment Forum,
EPA/630/R-92/001, February 1992.
2.	The Role of BTAGs in Ecological
Assessment, ECO Update, OSWER: Pub
9345.0-05I, September 1991.
3.	The Role of Natural Resource Trustees
in the Superfund Process, ECO Update,
OSWER: Pub 9345.0-05I, March 1992.
Who Does What?
* Ecological Study — Includes ecological assessments as part 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.
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