March 16, 1999

EPA-SAB-EEC-CON-99-003

Honorable Carol M. Browner
Administrator
U.S. Environmental Protection Agency
401 M Street, SW
Washington, DC 20460

             Subject:      Notification of a Consultation on the Advantages and
                          Disadvantages of Average or "Not to Exceed" Concentrations in
                          the Development of Cleanup Goals at Waste Sites.
Dear Ms. Browner:

       The Statistical Consultation Subcommittee of the Environmental Engineering Committee
(EEC) of the Science Advisory Board (SAB), met on March 16,  1999 to conduct a consultation
with staff from the Office of Solid Waste and Emergency Response (OSWER) on the Advantages
and Disadvantages of Average or "Not to Exceed" Concentrations in the Development of
Cleanup Goals at Waste Sites.  The SAB has developed the consultation as a mechanism to advise
the Agency on technical issues that should be considered in the development of regulations,
guidelines, or technical guidance before the Agency has taken a position. A consultation is
conducted under the normal requirements of the Federal Advisory Committee Act, which include
advance notice of the public meeting in the Federal Register.

       As is our customary practice, there will be no formal report from the SAB as a result of
this consultation, nor do we expect any formal response from the Agency.

                                 Sincerely,
                    /s/                               /signed/
       Dr. John P. Maney, Chair                 Dr. Hilary I. Inyang, Chair
       Statistical Consultation Subcommittee      Environmental Engineering Committee
       Environmental Engineering Committee     Science Advisory Board
                                      /signed/
                             Dr. Joan M. Daisey, Chair
                             Science Advisory Board

-------
             U.S. ENVIRONMENTAL PROTECTION AGENCY
                            Science Advisory Board
                    Environmental Engineering Committee
                     Statistical Consultation Subcommittee
CHAIR
Dr. John P. Maney, Environmental Measurement Assessment, Hamilton, MA

MEMBER
Dr. Domenico Grasso, Department of Civil and Environmental Engineering, University of
      Connecticut, Storrs, CT

CONSULTANTS
Dr. Richard O. Gilbert; Battelle Washington Office, Washington, DC

Dr. Barabara L. Harper,Environmental Restoration, Yakima Indian Nation, Richland, WA

Mr. Stuart G. Harris, Department of Natural Resources, Confederated Tribes of the Umatilla
      Indian Reservation, Pendleton, OR

Dr. James R.  Rocco,BP Exploration and Oil Inc. Cleveland, OH

Dr. Douglas Splitstone, Splitstone & Associates, Murrysville, PA

Dr. Nga Tran, Johns Hopkins University, School of Public Health, Baltimore, MD

FEDERAL LIAISON
Dr. Charles Land, National Cancer Institute, Bethesda, MD

SCIENCE ADVISORY BOARD STAFF
Kathleen W. Conway, Designated Federal Officer, U.S. EPA, Science Advisory Board (1400),
      401 M Street, SW, Washington, DC

Mary L. Winston,  Management Assistant,U.S. EPA, Science Advisory Board (1400), 401 M
      Street, SW, Washington, DC

-------
             U.S. ENVIRONMENTAL PROTECTION AGENCY
                            Science Advisory Board
                 Environmental Engineering Committee (FY99)


CHAIR
Dr. Hilary I. Inyang, Director, Center for Environmental Engineering and
      Science Technologies (CEEST), University of Massachusetts, Lowell, MA

MEMBERS
Dr. Edgar Berkey, Vice President and Chief Science Officer, Concurrent Technologies
      Corporation, Pittsburgh, PA

Dr. Calvin C. Chien, Senior, Environmental Fellow, E. I. DuPont Company, Wilmington, DE

Mr. Terry Foecke, President, Waste Reduction Institute, St. Paul, MN

Dr. Nina Bergan French, President, SKY+, Oakland, CA

Dr. Domenico Grasso,Head of Department of Civil and Environmental Engineering,
      Environmental Research Institute, University of Connecticut, Storrs, CT

Dr. JoAnn Slama Lighty Associate Dean for Academic Affairs, Associate Professor of
      Chemical Engineering, University of Utah, Salt Lake City, UT

Dr. John P. Maney, President, Environmental Measurements  Assessment, 5 Whipple Road,
      Hamilton, MA

Dr. Michael J. McFarland, Associate Professor, Utah State University, 130 South 1000 East,
      River Heights, UT

Ms. Lynne M. Preslo, Senior Vice President, Technical Programs, Earth Tech, Long Beach, CA

SCIENCE ADVISORY BOARD STAFF
Kathleen W. Conway Designated Federal Officer, U.S. EPA, Science Advisory Board (1400),
      401 M Street, SW, Washington, DC

Mary L. Winston, Management Assistant,U.S. EPA, Science Advisory Board (1400), 401 M
      Street,  SW, Washington, DC

-------
                                       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
balanced expert assessment of scientific matters related to problems faced by the Agency. This
report has not been reviewed for approval by the Agency; and hence, the contents of this report
do not necessarily represent the views and policies of the Environmental Protection Agency or
other agencies in the Federal government.  Mention of trade names or commercial products does
not constitute a recommendation for use.
                                           in

-------
                       DISTRIBUTION LIST
Administrator
Deputy Administrator
Assistant Administrators
EPA Regional Administrators
EPA Laboratory Directors
EPA Headquarters Library
EPA Regional Libraries
EPA Laboratory Libraries
Library of Congress
National Technical Information Service
Office of Technology Assessment
Congressional Research Service

-------