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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C, 20460
July 23, 1993
OFFICE OF THE ADMINISTRATOR
EPA-SAB-EEC.LTR-93-QG9 ***** ADVISORYSOARD
Honorable Carol M, Browner
Administrator
U.S. Environmental Protection Agency
401 M St., S.W.
Washington, DC 20460
RE: SAB Review of OSWER/Office of Emergency and Remedial Response's
draft Strategic Plan for Ground-Water Remediation at Snperfund Sites
Dear Ms, Browner:
On March 3, 1993, the Superfund Ground Water Remediation Subcommittee
of the Science Advisory Board's Environmental Engineering Committee reviewed
the January 22, 1993, draft Strategic. Plan for Ground- Water Remediation at
Superfund Sites of the Office of Solid Waste and Emergency Response's Office of
Emergency and Remedial Response (OERR),
While the Subcommittee commends OERR for undertaking this critical effort,
it is reluctant to refer to the document as a "strategic plan" because it does not
contain all the elements commonly contained in a strategic plan: a vision, an
assessment of the current state of knowledge, and a pathway for moving from the
current state to realization of the vision. Strategic planning processes can be
flexible, but some of the basic tenets cannot be violated or the goals of the strategic
planning process will not be met. Because such problems are often found in EPA
strategic plans, the Environmental Engineering Committee is considering
development of a separate commentary to address strategic planning generically.
The EPA should focus on why it developed the strategic plan and tailor the
goal and objectives accordingly. It appeared to the Committee that the EPA
collapsed issues and projects currently being acted on into the plan, and the
Committee questions whether the plan is responsive to changes in the Superfund
program, particularly SACM. There is a need to identify problems and their
solutions within the program and it is suitable that this be an internal EPA action
or planning process.
The Committee notes one additional difficulty with the strategy-the coupling
of technology and policy in attempting to set priorities may frustrate the effort and
weaken its credibility. While technical decisions may be altered by policy, it would
seem prudent to separate these two issues to allow development of independent
decisions, compare the outcomes, and then attempt some resolution,
PHtetd on pap*f ihat aamku
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The Subcommittee does agree with what it believes to be the main thrust of
the document-that of encouraging development of methods suitable to a variety of
clean-up scenarios. The plan recognizes that clean-up goals depend upon the
human health and ecological risks included, technical treatability, costs, and values
of various resources affected. The Subcommittee's response to the three questions
of the charge follows,
Question JL Will the four objectives of the Strategic Plan, given in Section II. lead
to the stated goal of_"improvmg the Superfund program's overall technical and
policy approach to ground-water remediation and risk management?"
The Subcommittee believes that the objectives, as presented, are a good start
for developing a plan, however, it may be appropriate to change them if the plan
goal is restated in the process of developing a true strategic plan. As suggested
above, such changes would separate policy and technical objectives while
incorporating language that would reflect CEECLA and the National Contingency
Plan. The goal should include a need for review and improvement of EPA's
existing technical and policy guidelines to ensure that sites will be remediated in a
timely and cost effective manner.
The Subcommittee notes that the second objective, "Improve communication
of remedial objectives and progress, and increase program responsiveness to
customers, including the public," is the least clear, appears to have the least
commitment from the EPA, in terms of issue or project identification in the plan,
and is an area of poor historical performance in the application of the program.
Additionally, the Subcommittee suggests dispensing with the listing of issues by
objective because allocation to a single objective is inappropriate for some issues and
many projects address more than one objective. Finally, the Subcommittee suggests
that EPA recognize the need to minimize delays in development of technical policy
and guidance because some questions, such as technical impracticability, are being
interpreted and applied at sites.
Question 2. Are there^addjtional technical issues related to remediation of ground
water that have not been identified in Section II of the plan?
The Subcommittee suggests that EPA provide a short explanatory paragraph
for each issue that summarizes its implications, why it is considered to be a
problem, and what are the likely solutions. The present list is merely a shorthand
notation which is difficult to decipher by those unfamiliar with the EPA's plans or
projects. It is also difficult to guess the intent of the EPA or the extent of the
listed projects lacking specific descriptions. The Subcommittee believes that much
research is needed in subsurface remediation-specifically, nonaqueous phase liquids
(NAPL) and basic groundwater "purge and treat" technology problem areas in the
Superfund Program.
The EPA document identified research issues for each of its four objectives.
The Subcommittee both comments on and suggests some refinements to those issues
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identfiei by EPA. For some objectives, the Subcommittee also suggests some
additional issues, as follows.
a) Objective 1: Improve decisions for clean-up and risk management of
contaminated ground water.
Identification and availability of reliable methods for evaluating and selecting
the best/applicable remedy for a site is a very important issue. Selection of
an appropriate remedy for a given site should include evaluation of "natural
attenuation (passive restoration)" versus "active restoration" technologies. No
additional issues are suggested for this objective.
b) Objective 2; Improve communication of remedial objectives and
progress, and increase program responsiveness to customers, especially
the public.
As stated above, this objective and its issues are the least clear and appear to
have the least commitment from the EPA in issue and project development. The
EPA should develop better guidelines for the negotiations among potentially
responsible parties (PRPs) and the EPA so that the differences can be reconciled
and there can still be scientifically sound, technically adequate, cost-effective
characterization and remediation plans. Although the Subcommittee suggests that
the issues be clarified, it does not, at this time, suggest any additional issues for
this objective,
c) Objective 3; Improve site characterizations and risk assessments, and
better integrate investigations
The EPA needs to define more clearly easy-to-use criteria for choosing
remediation technology on a site-specific basis. The Subcommittee suggests EPA
consider some additional issues;
1) How can appropriate statistical methods be considered in data
evaluation to minimize costs in site characterization?
2) How should each key factor be considered in determining a
proper risk level
3) How can cost-effective field sampling/analysis methods be
adopted or utilized so that both site evaluation and
design/remediation are improved and accelerated?
d) Objective 4: Improve available remedial technologies and develop new
or innovative technologies,
The Subcommittee suggests EPA consider some additional issues:
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1) How can field performance of newly developed/tested remedial
technologies be shared among all stakeholders and be considered
by all remedial programs underway or in planning? (This may
also be considered under Objective 2),
2) Which innovative remedial technologies need pilot testing and
what are the general measurement requirements for their
effectiveness or acceptability?
3) How could the Superfund Innovative Technology Evaluation
(SITE) program application/approval be simplified so that testing
of new remedial technology can be encouraged and brought into
the program in a timely manner?
Question 3. Of the key issues listed under each objective in Section II, including
those added by the SAB, what is the relative importance of each issue (preferably in
numeric order where 1 is the most important)?.
The Subcommittee decided it should not respond to this request to rank the
issues according to the objectives in the plan because it considers this the
responsibility of the EPA. The Subcommittee believes that the criteria used by the
EPA to decide priority may be as important as the final prioritization and that the
criteria should be included in the plan, The following criteria were identified which
might be useful to the EPA in developing criteria and refining its priorities:
a) Needs at each step/stage of a remedial program.
b) Requirements of the regulatory policies (in the order of importance),
c) Health and risk considerations.
d) Cost versus benefit considerations.
e) Result that may be derived from a issue and its level of acMevability,
f) Time constraints on addressing the issue (e.g. schedule for
reauthorization).
g) Proportion of sites affected by issue.
h) Technical or policy implications for the EPA programs (e.g. RCRA
Corrective Action). "
i) Legal implications,
j) Reduction in degree of scientific uncertainty,
k) Effect on reducing ambiguities or inconsistencies in current guidance.
1) Fairness.
m) Improvement in consistent treatment of public risks.
n) Public perception of an issue (is there high public or political
pressure?).
o) Effect on improving timeliness of clean up.
p) Potential for multiple benefits (i.e. addresses more than one objective).
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Another approach might be to look at key issues in terms of groupings such
as those appropriate to technical understanding, policy, or economic considerations
(or others of interest to the EPA). For example, under Objective 1, the technical
understanding group would include issues a, b, and e; for a policy group, issues c
arid f; and for an economic issue group, b. Then it might be possible to rank the
importance of these groupings rather than the issues themselves,
Conclusions
In summary, the Subcommittee is pleased that the EPA has attempted to
develop a strategic plan for a critical national program with great economic impact.
The Subcommittee is also pleased that the draft document incorporated many
suggestions made in the October 1992 consultation and that the overall technical
thrust of the document is appropriate to the complex situation of site cleanup,
While the draft document was not yet a true strategic plan, the problems seen here
are very common ones, and further clarification and refinement are needed. The
Subcommittee has suggested some refinements and improvements which it hopes
OSWEE will incorporate into the revised document. We look forward to a written
response concerning those refinements.
Sincerely yours,
Raymond C. Loehr, Chair Hichard A. Conway, Chair
Science Advisory Board Environmental Engineering Committee
George F, Carpenter, Chairman
Superfund Ground Water Remediation Subcommittee
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U.S, ENVIRONMENTAL PROTECTION AGENCY
Science Advisory Board
Environmental Engineering Committee
Superfund Ground-Water Remediation Subcommittee
Chair
Dr. George F. Carpenter, Michigan Department of Natural Resources,
Environmental Response Division, Superfund Section, Lansing, MI
Members
Dr. Calvin C. Chien, DuPont Corporate Remediation, Wilmington, DE
Dr, Jshwar P. Murarka, Environmental Division, Electric Power Research
Institute, Palo Alto, CA
Dr. Frederick G. Pohland, Department of Civil Engineering, University of
Pittsburgh, Pittsburgh, PA
Dr. Robert B. Pojasek, GEI Consultants, Inc., Winchester, MA
Dr. C. Herb Ward, Department of Environmental Science & Engineering, Rice
University, Houston, Texas
Science Advisory Board Staff
Mrs, Kathleen Conway, Designated Federal Official, Science Advisory Board, U.S.
Environmental Protection Agency (A-101F), 401 M Street, S.W,, Washington,
DC 20460
Dr. K. Jack Kooyoomjian, Designated Federal Official, Science Advisory Board, 0.S.
Environmental Protection Agency (A-101F), 401 M Street, S.W., Washington,
DC 20460
Mrs. Dorothy Clark, Staff Secretary, Science Advisory Board, U.S.
Environmental Protection Agency (A-101F), 401 M Street, S.W., Washington,
DC 20460
Mrs. Diana Pozxm, Staff Secretary, Science Advisory Board, U.S.
Environmental Protection Agency (A-101F), 401 M Street, S.W,, Washington,
DC 20460
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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 a balanced expert assessment of
scientific matters related to problems facing 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 Federal government. Mention of trade names or commercial
products does not constitute a recommendation for use,
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