Research Otitlook 1982
h Report of the Executive. Committee
of the
Science Advisory Board
U.S* Environmental•Protection Agency
September 21, 1982
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
September 21t 1982
OFFICE OF
THE ADMINISTRATOR
Mrs. Anne M» Gorsueh
Administrator
U.S. Environmental Protection Agency
401 M Street, S.w.
Washington, D.C. 20460
Dear Mrs. Gorsueht
The Executive Committee of the Science Advisory Board
has recently completed its report on the Agency's five-year
plan for research 'and' development entitled Research Outlook
1982. In carrying out its review the Committee made a number
of recommendations for improving both the scientific adequacy
of the document as well as enhancing its usefulness as a
strategic planning tool. I hope that the Science Advisory
Board's comments prove useful to you and the Office of Research
and Development.
Verv/^ruly yours,
airman
:ee
Board
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EPA HOTICE
This report has been written as a part of the activities
of the Agency's Science Advisory Board, a public advisory
group providing extramural scientific information 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 ha© not been reviewed
for approval by the Agencyf and -hence, its contents do not
represent the views and policies- of the Environmental Protection
Agency, nor does mention of trade names or commercial products
constitute endorsement or recommendation for use.
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Contents
Page
Executive Committee Review
Roster ........ — ». .......iv
Executive Summary . ..1
I. Overview of Research Outlook 1982 ».... ...,.*.,3
II. Chapter by Chapter Review of
Research Outlook 1982 . *.. „. 6
1. Energy 6
2 . Hazardous Air Pollutants ..................... 8
3 * Oases and Particles .* 9
4. Oxidante ..................10
5. Mobile Sources .,...12
6. Radiation .. ...12
7. Pesticides ...................................14
8. Toxic Chemical Testing and Assessment ........14
9. Hazardous Wastes ....16
10. Superfund .16
11. Drinking Water 17
12, Water Quality -.17
13. Industrial Wastewater ..18
14. Municipal Wastewater .............. — ........19
III* Findings and Recommendations on the Process
for the Preparation of Research Outlook 20
iii
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HOSIER FOR EXECUTIVE ODMMPECEE
Dr. Earnest F. Gleyna (Chaizman)
Dean,' College of Engineering
Codcrell Hall, 10.310
University ^f Tessas' at Jtostin
Austin, Texas 78712
Dr. Terry P. Yosie
Acting Director
Science Advisory Board
Soon U45W, Waterside Mall
Washington, D.C. 20*60
Mesitsers
Dr. Eileen G. Brennan
Departfflent of Plant
Codk College
Rutgers, The State University , •
New Brunswick, New Jersey 03809
Dr. John E. Cantlcn
Vice President
Research and Graduate Studies
Aandnistration Building
Michigan State lOniversity
East leasing, Michigan 48824
Dr. Sheldon K. Friedlander
Vice Chairman of Qiemical Engineering
Department of Chemical, Nuclear and
Thermal Engineering
School of Engineering and %jplied
Science
Univ. of California at las ingeles
Los Jtageles, California 90024 ^
Dr. Julius E. Jdhnscn
1111 Knollwood Court
Midland, Michigan 48640
Dr. John M. Neuhold
Department of Wildlife Sciences
College of Natural Resources . ,
Utah State University
Logan, Utah 84322
Dr. Gerard A. Rohlich
Department of Civil Engineering
University of Texas at Austin
Austin, Texas 78712
Dr* Sidney Weinhouse
Pels Research Institute
Tenple University School of Medicine
Ehiladelpliia, Pennsylvania 19140
Grateful ackncwledpetnent is also made to Dr. Morton Itippnenn, New York University,
Dr. Sblcnon Micnaelson, University of Rochester, and Dr. J. William Schull,
University of Texas Health Science Center in Etawston, for their cxintoijations in
£he review of this document.
•Dr. Jolm Cairns, Jr.
Center for lasdicttiental Studies
Virginia foiytedhnic Institute
and State University
Blacfcsborg, Virginia 24061
Dr. Herman E. Collier
Moravian College
Bethlehem, Pennsylvania 18018
Dr. Leonard Greenfield
8241 S.W. - 204th Street
Miami, Florida 33189
Dr. Roger 0, 'MeClellan
Director of Inhalation
Toxicology Sesearen Institute
Lovelace Bionedical and
Environmental Research Institute
P.O. Box 5890
Albuquerque, Mew Mexico 87185
Dr. Ruth A* Beck
General Motors Research. Laboratory
DepartTOEnt of Hiysies
General Motors Corporation
Warren, Michigan 48090
Dr. Winona B. Vernberg
School of Public Health
University of South Carolina
Columbia, South Carolina 29208
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Executive Summary
* For the' most part, • the research needs cited in the
Research Outlook 1982 are important. The document 'reflects the
Office of Research and Development's efforts to develop
scientific data bases in support of the program requirements
of EPA regulatory offices. However, it floes not appear that
the resources available to ORD will fund any but a small
fraction of the needs mentioned,
• There is little or no identification of long-term
exploratory research ^needs, and the reader is left to infer
that such research has little if any'priority within the
Agency. Rather than acknowledge new needs in this area, the
document is directed toward a defense of the status gnuo-
* Future Research Outlook documents should present a
statement of research needs that is not subordinate to the
research budget. Such budgetary scenarios, extrapolated
into future fiscal'years, have been frequently unrealistic,
and the need to defend' a particular set of resource forecasts
has inhibited a truly candid discussion by the Agency of
future research needs when those needs appear,to exceed
available resources. A more realistic alternative is for -the
Agency to strive.'to prepare a 'five-year plan which, when
submitted to Congress at the same time as the Administration's
budgetary proposals, does ,not.contain specific resource •
projections* Congress could then continue to use the Outlook
as a planning guide in authorizing and appropriating EPA's
research and development (R&P) budget.
* From the standpoint of articulating a strategic
research plan, it would be advisable to emphasize that risk
abatement and 'the prevention of hazards are major goals.
• The productivity of EPA's research and development
program in the next five years will depend critically on many
factors which receive little or no discussion in Research
Outlook 1982. Among these are the management, coordination,
and allocation of•resources among the various components of
the intramural and extramural research program and the
investigator-initiated Peer Review Grants Program.
* A review of the research needs identified in Research
Outlook indicates that EPA's 'research mandate frequently
overlaps that of' other 'Federal agencies. It "would be useful
if the Outlook would compare EPA's definition of its research
needs in the context of what research is being carried out
by other agencies, the private sector, and other levels of
government.
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• The preparation o'f the Research Outlook should be
closely tied to the development • of research strategy documents
within the Office' of Research and•Development (QRD), and the
conceptualization of both sets of documents should be subject
to early Science Advisory Board review.
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I. Overview of Research Outlook 1982
As-a whole. Research Outlook 1982 provides a brief
overview of the major areas of research and development
activity planned by the Agency for the* next- five years. It
presents these' plans in general terms, and the lack of
specifics makes it difficult to evaluate its scientific and
technical adequacy or its adequacy as a research planning
tool* The report does not articulate an overall Agency
strategy for conducting its research and development program.
In the absence of such a clearly stated strategy, the reader
is left with the impression that the program is a collection
of tasks rather than an integrated program managed to achieve
well-stated objectives.
For the most part, the research needs cited in the Outlook
are important. The document reflects the Office of Research
and Development * s efforts to develop scientific data•bases in
support of the program requirements•of EPA regulatory offices.
However, it does not appear -that the resources available will
fund any but a small fraction of the needs mentioned. For
example, to validate stream models or other models for rapid
evaluation of environmental toxieity would require an enormous
effort. It is unclear from reading the Outlook how this would
be done and with what resources.
There is little or no' identification of long-term
exploratory research needs in 'Research Outlook 1982, and the
reader is left to infer that such research has little if any
priority within the Agency. Rather than acknowledge new
needs in this area, the document is directed toward a defense
of the status quo*
The ORD investigator-initiated. Peer Review Grants
Program is the only EPA effort that supports researcher-
initiated studies that are not tied to short-term regulatory
needs- This program meets the scientific community's accepted
definition of long-term exploratory research anfl has enlisted
the talents of an extremely broad and highly qualified segment
of the nation's scientific community. The investigator-
initiated grants program may not fit the organisational framework
of the Research Outlook document very well, but it still needs
to be accommodated within the Agency's plans. It provides an
opportunity for new ideas and fresh approaches•to be developed
that, in the long run* can significantly assist the .Agency in
fulfilling its mission in a cost-effective manner- Unfortunately,
this program is not even mentioned in Research Outlook 1982.
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From the standpoint of articulating a strategic research
plan, risk abatement and the prevention of hazards should be
emphasized as major goals. Although these concepts are implied
in many of the activities described in the Outlook, they are
not mentioned explieity enough to indicate that they are goals
of particularly 'high priority* A related issue is whether there
.is a relationship between R&D expenditures and the degree of
risk reduction. If such a. relationship exists, it should be
stated.
The productivity-of SPA's program for research and
development in the • next • five years trill depend critically on
factors Which are not addressed at all in Research Outlook
1982* Among these are the management of the research
budget and its allocation among the different types of
research areas and research organizations. The program should
have short-term (1 yr 31 intermediate (1-3 yrs), and long-term
(3-5 yrs3 components.
In the past, the Agency has used several approaches for
the conduct of research including 1} in-house operations by
EPA employees, 2} operations carried out under task-order
contracts,; 3) inter-agency agreements, and 4) grants to
universities and other institutions. In the face of reduced
financial resources, it would be of interest to know if changes
in research management and the relative use of the various
approaches noted above are contemplated to yield a more cost-
effective an<3 productive research program*
The Research Outlook document should more, explicitly
address the issue of management, coordination, and allocation
among the various components of -the intramural and extramural
research program. Such background information would greatly
assist reviewers and other interested parties in assessing
the quality of the program and its prospects 'for successful
implementation. Inclusion of a statement oil the process used
for preparation of the document woulel promote understanding
of the relationship between the five-year plan and the research
and development program in general. This information would,
in -turn, facilitate the development of a clearer statement of
of purpose as to what role this relationship serves,for R&D
managers within the Agency.
A review of the research needs and projects discussed in
individual chapters indicates that EP&'s research mandates
frequently overlap those of other Federal agencies. For
example, EPA sponsors.'research for pesticides, criteria and
hazardous air pollutants, acidic deposition, and various
toxic substances. It would be helpful if the Outlook would
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compare the research needs that are identified by EPA in the
context of what research is being carried out by other
agencies. In addition, research initiatives undertaken by
the private sector and other levels of government should be
discussed.
It is clear that EPA cannot be the primary sponsor of
research in all•of the areas of research and development
embraced by its regulatory mandate. Choices must be made -to
define in what fields of research EPA should have a primary
role, a shared or contributory role, or no role. An example
of a primary role for EPA should be the fields of environmental
transformation, fate and ecology, and municipal wastewater.
In the case of chemical processing technology in manufacturing
plants, including synfuels plants, other organizations may be
"better qualified than EPA to be' a primary sponsor of research
and development. This years"s Outlook provides little or no
scientific rationale (as contrasted with a legislative rationale)
for the inclusion or exclusion of specific research activities.
Research Outlook 1982 does not provide a clear statement
of how the Agency's research budget will be allocated. A
better explanation of the terms high, moderate* and low
growth would also be helpful to the reader.
The need for health effects research is mentioned in
several places in the document. For example, the Outlook
states (p.33) that "Epidemiological studies germane to air
quality are left to health agencies such as the National
Institutes of Health (NIH) and academic institutions." This
statement is inappropriate for an Agency whose mission is to
protect the public health from environmental hazards*
In health-oriented sections of the document, reference
is made repeatedly to the development, use, and validation of
short-term tests for predicting the toxicity of various materials,
In most cases, the implication is that short-term tests can be
used to predict latent health'effects. If'this is the objective
and if it is to be attained, validation will require a well-
developed strategy. Such a strategy should include the conduct
of long-term animal studies? yet such studies receive limited
attention in the document*
The major milestones cited throughout the document for
individual research projects do not, for the most part, extend
past 1984. This is inconsistent for a document that is
supposed to be a five-year plan.
The report could be improved if it included an Executive
Summary highlighting the most important conclusions and
contents. In the absence of such a Summary, it is difficult
to identify those research issues that are considered' most
significant by the Agency's scientists and policy makers.
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II. Chapter by Chapter Review of Research Outlook 1982
Comments on Chapter Is ENERGY
I introduction
—Given the extent to which other agencies, such as
the Department of Energy, have major research efforts
underway in this area, the report should clearly
identify how the EPA effort will complement the research
sponsored toy these agencies. In addition, there should
toe additional discussion of how EPA set its own energy
research.priorities..
—Long term energy research is confined to a narrow part
of EPA's discussion of its energy research mandate.
Not represented are (1) long-term effects of acid
deposition and {2} long-term effects of waste disposal
from energy technologies,
Acid Deposition
—Transport and transformation of acidic deposition pre-
t cursers should'toe emphasized* More discussion is needed
on the scale of acid deposition impacts, research on the
trend of the impact, or the relationship toetween the
tractability of the problem and the scientific capability
for abatement. The Outlook does not address in sufficient
detail acidic deposition mitigation methods such as liming.
—Since many significant gaps exist in our understanding
of dry deposition, there should be more discussion of
this part of the -research program.
--EPA should provide its estimate of how long it will
take to establish reliable trend data in the pH of
precipitation samples {page 4).
—The impact of acidic deposition on construction materials
may be less than the impact on the overall structure's
integrity, life span, etc. The document should, therefore,
include a discussion of impacts on riveted and welded
joints, concrete-to-steel interfaces, etc. (page 6,
paragraph 2).
—The research strategy for acid deposition discusses
fishery resource losses, aquatic assessment models,
fate, and additional priority for development of criteria
to judge sensitivity of soils to acid deposition. If
there is a single major factor interrelating the acid
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deposition strategies to the solid state intermedia,
it is the ion exchange capacity of soils* The proposed
• strategies seem either to lead up to or to s"kirt this
problem, when indications are that it may be the
central point of an integrated assessment.
Combustion Technology
The rationale for the NO^ program needs to be further
developed, since in very few regions of the country are
the 'Standards exceeded.
—Partieulate control technology is discussed under the
heading of Combusjlon Technology (page 7), This is not
the appropriate category in which to review this subject,
because air pollution control technology is not a
branch of combustion technology. The title of the
section should be changed to Air Pollution Control
Technology * There is also no discussion of the control
of fugitive or non-ducted sources. EPA is the natural
sponsor for support of this type of research, and a
significant level of research activity, should toe
maintained. Are all o£ the technologies relating to
NOX, SOX, and particulate emissions to be given
equal emphasis, or is NOX given priority because
"it is the only class of major air pollutants to have
increased over the past decades"? Is there any plan
to test an ammonia scrubber to reduce NOX?
Synthetic Fuels
—There should be a discussion of the pace of development
of the synthetic fuels industry and ite inipact on the
research program described in the Qutloolc* The Agency
should maintain a continuing capability to assess the
environmental effects of this industry, paying particular
attention to existing or developing synthetic fuels
projects.
—The synfuels research strategy indicates that a signif-
icant amount of environmental research has already
been done. This document should clarify which are
the principal pollutants and the principal environmental
problems associated with this industry, in addition, the
statement "risk-benefit assessments will be limited to
utilizing existing data and addressing major research
endpoints" (page 10, paragraph 1»" line 2} needs to be
explained.
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Envj, r onment a 1 'Effects
—Neither cold climate studies nor pollutant transport
modeling can actually be classified as aa environmental
effect. The former is discussed in the context of
monitoring CO concentrations in Alaska and the latter
with tracking pollutants in terrains complicated by
mountains, ridges, etc. There way be a more appropriate
title for this section of the document (pages 10-11).
Long-term Research
—There seem to be no plans for supporting long-term acid
deposition research. Instead, short-tenm effects/
mitigation studies are planned. In addition, based upon
experience in arctic research, it is not clear how the
statement, "In support of the cold-climate research.*.for
permafrost and tundra ecosystems" (page 11, paragraph
2, line 7), relates to energy-driven environmental
effects, or why it warrants a high priority for scarce•
long-?range funds.
Comments on Chapter 2; HAZARDOUS AIR POLLUTM3TS
General Comments
—This chapter should present and discuss the criteria for
the selection of pollutants identified for research
funding .
— More information is needed on the interaction of complex
mixtures of pollutants, including whether such mixtures
act synergistically or through other mechanisms.
Health Effects Research
scope of the effort outlined in this section defines
two major objectives? "(1) the screening and identifi-
cation of biologically active compounds so that appropri-
ate candidate substances are prioritized for further
analyses, and (2) the conduct of detailed assessments of
selected substances in support of regulatory decisions*
(page 17, paragraph 3). The research dollars budgeted
are insufficient to carry out these ambitious tasks.
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Comments on Chapter 3s GASES AND PARTICLES
General Comments
—In this chapter and in Chapter 4, Oxidants, there
is discussion of research -strategies for oxides of
nitrogen and sulfur. More discussion of the
relationships between the NQjj and the gases and
particles program is needed.
Agency has expressed considerable interest in -the
use of the "Bubble" concept for controlling emissions
from an entire industry rather than on an individual
process or equipment item basis, this may simplify
pollution control efforts and reduce costs* The use-
fulness of the "Bubble" approach could be enhanced if
the Agency sponsored further research of this concept.
Such research could be initiated through the Peer Review
Grants Program at an early date.
E nvi ronmenta 1 Processes and Effects
— Inasmuch as gaseous SC>2 and acid deposition will be
evaluated together for their impact on Materials, one
might expect a similar 'Integrated approach in regard
to vegetation.
Health Effects
—A discussion of any plans to test combinations of lead
and gaseous pollutants would be useful.
—Since the National Ambient Air Quality Standards (NAAQS)
, are to be reexamined at five-year intervals, there is
a continuing need to develop better indices of particu-
late air quality than the non-specific mass concentra-
tions used for TSP, PM^o, or fine parti culates, because
particulate mass concentrations, even when specified by
size range, remain crude indices of air quality.
— There is relatively sparse discussion about specific re-
search projects in this chapter, malting it difficult to
evaluate the prospects for effective implementation
of this section of Research Outlook 1982. 'Where
specific projects are stated, they sometimes raise
concerns about the criteria and judgment used in
their selection. For example, oa page 33, lines 6-7,
the three chemicals identified for specific study are
ammonium sulfate, iron oxide, and kaolin clay. Ammonium
sulfate is the most innocuous chemical in the series
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SOg, 803, H2SO4, NH4HSQ4, and (^£[4) 3 804. Iron oxide
is one of the least likely metal oxides to have adverse
' effects, by itself. It is less active as a catalyst
than many other metal oxides and other particles,
' such as•carbon. It is also difficult to understand
the selection of kaolin, a relatively innocuous silicate,
as a research.priority.
—-The focus of the planned human studies (page 33, para-
graph 2) will involve exposures to sulfate and nitrate
aerosols alone and in combination with 03, M>2» *n&
SO2* *t is difficult, to see how much useful informa-
tion can come from additional studies of this type.
These kinds of studies, using the most sensitive available
methods and having excellent quality control, have
been carried out recently.
Resource Options
—it is difficult to understand the emphasis on human
exposures in view of the limited range of important
questions that can be addressed by clinical exposure
studies compared to the versatility and economy of animal
models for screening chemicals, characterizing particle
size influences, and adding to our understanding of
chronic exposures'and persistent effects.
—-Given the levels of funding as projected for 1983-1986,
the allocation of a major portion of the budget to high
cost clinical studies would leave other critical areas
of investigation unfunded.
Comments on Chapter 4; OXIDJINTS
General Comments
—The objectives and strategies in this chapter clearly
complement each other. Specific problems and their
solutions are explicitly stated, especially in relation
to health effects and air quality models. As a minimal
program, the chapter represents a well-designed and
well-balanced effort.
Exposure and Effects
—With respect 'to the discussion of important 03 health
effects, there is inadequate attention to the cumula-
tive effects of chronic, low level exposures. These
exposures may contribute to cellular changes in the
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small airways and alveoli which, with continued periodic
exposures, may cause cumulative and irreversible
adverse changes to human respiratory systems. Exam-
ination of lung sections of humans whose residential
and occupational histories can be determined will be
expensive and will take at least several years to
perform. It is unlikely that they will be performed
without EPA's support and encouragement. More chronic
low level inhalation exposure studies in laboratory
animals are needed to guide and complement studies on
human lung tissue.
—Greater discussion is needed on why the assumption is
made that there is a threshold for 03 in normal subjects
(page 40).
—The issue of the effect of repeated exposures to peak
concentrations of NC>2 "has not been adequately addressed.
A focused program of animal studies of the effects of
periodic peak HC>2 exposures on lung defense functions
should have a high priority.
—Recent reviews by the scientific community indicate
that there are critical gaps in (1) health effects
research on HOX to justify more stringent control,
and (2) epidemiology studies relative to KfOx and 03.
Air Quality Models
—This chapter has not sufficiently emphasized the issue
of model validation as a research priority, even though
there are large uncertainties in the current state-of-
the-art of the precision of models. There should also
be greater emphasis on developing a method for measuring
hydrocarbons.
—It is appropriate that peroxyacetylnitrate (PAN) be
evaluated for its role in photochemistry of the atmosphere
and for its possible health effects* PAN shoulo" also
be evaluated as a .contributor to acidic deposition.
—It may be overly optimistic to promise a dispersion model
for PAN, HM>3, etc. for 1984.
—More justification is needed as to why biogenic emissions
are considered to be an important research priority (page
42, paragraph 1),
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Control Technology
—-EPA should determine the extent to which private industry-
is sponsoring control technology research for volatile
organics, and, in light of this information, the Agency
should assess its own research needs and'degree of
support *
Comments on Chapter 5s MOBILE SOURCES
General Comments •
— There is no reference in this chapter to the role of
the Health Effects institute, jointly funded toy EPA
and the automobile industry* It would be appropriate
to discuss the Institute's program and how it relates
to or differs from the rest of the EPA mobile source
program.
— Some research issues outlined in this chapter are
too broad to be critically evaluated. For example,
on page 50, paragraph 1, it is indicated that variotas
animal tests would be performed comparing diesel soot
and several known carcinogens and that the results
would provide a basis for performing human risk
assessments on diesel exhaust samples. The Outlook
needs to address* the merits of this* testing approach
and identify methodological weaknesses or problems.
Further, it is unclear what is meant by the statement
that in vitro tests might be used for. "cancer-based
regulation of engine systems and fuels and fuel add-
itives."
important issue of research on aerosol sampling
techniques for exhaust particles . has been overlooked
(page 51, paragraph 6).
Comments on Chapter 6j RADIATION
General Comments
--This chapter seems deficient in at least two respects.
First, given the plethora of governmental agencies
which address some aspect of the health effects of ion-
izing radiation {DQD, DOE, EPA, N1H-NCI, ...) / it
is not clear how EPA's effort compares with that of the
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others. Is it truly unique, and if so, how? How do
these activitiest in turn, relate to recommendations by
such organizations as the National Council on Radiation
Protection? Second, there seems to be no aspect of the
program on non-ionizing radiation devoted to the possible
health effects of extremely low frequency radiation
(50-75 Hz) as geomagnetic waves. Are studies of this
kind underway in some other agency?
—Most of the research strategies proposed and the
milestones developed in this chapter focus on
experimental animals. What support exists for
epidemiological investigations? Some further studies
on human health may help to inform the public better
as to either the presence or absence of radiation hazards,
Research Strategy
—Too much emphasis is placed on the mammalian nervous
system with no mention of immunology or growth and
development. The importance of the study of mechanisms
within the health effects program is appropriate.
The focus on the effects on growth and function of
bacterial and other unicellular organisms at specific
frequencies is unclear. What is the relevance of
these studies, and how can one extrapolate their results
to man in the face of other more extenuating problettts
such as immunology, reproduction, growth, an
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—It would be helpful to have a discussion of the relation-
ship between the National Research Council study by
Robinette and the sixth research milestone identified on
page 58 which states, "Final report on mortality,
cause of death, and morbidity in a population exposed
to radar 40 years ago - 1984."
Comments on Chapter 7s PESTICIDES
General Comments
—Research needs for Pesticides should be.discussed
in the context of what research is being sponsored
by other agencies and by the industrial sector.
--The phrase "biological pest controls" should be
substituted for "biological pesticides." Not all
biological pest controls operate through lethal effects?
some are reproductive inhibitors or repellants, etc-
Environmental Rj.sk Assessment
—There should be a statement in the paragraph on modeling
(pages 63-64) to emphasize the need for verification of
models and the need for repeated comparison of model
predictions with actual performance*
Quality Assurance
—The Outlook should reference worlc carried out by the
National Bureau of Standards and other professional
• organizations concerned with analytical quality assur-
ance*
Comments on Chapter 8s TOXIC CHEMICAL TESTING AND
ASSESSMENT
Health Effects
—A statement' of the criteria usetl to establish research
priorities for this issue should be included.
—It would be helpful to identify more specifically the
participants involved in the validation of predictive
tests (page 72e paragraph 1, line 2).
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Environmenta 1 'Processes and 'Effects
^Environmental fate
—There is not sufficient emphasis on validation of fate
predictions. Is the research to be done on mixtures,
pure chemicals, or both?
Environmental toxicology
--Community level toxicity tests are mentioned but not
described. Will the tests be on community function,
structure, .or both? Why standardize•species and
diets when variability is characteristic of all natural
systems? Recovery time following ecological displac-
ement is not mentioned, and recovery and restoration
should be discussed. 'Most present tests are steady-
state? is pulsed exposure research being considered?
Extrapolation •from the laboratory to the real environment
—There is no major body of evidence to support the as-
sumption in the Outlook that microcosms and model eco-
systems can be used to validate extrapolations from
the laboratory to the real environment. The document
should discuss tlie suitability of funding microcosms
and model ecosystems 'research for this purpose before
spending more money for development of such methods.
The nature of the field validation effort should be
described in more detail to clarify whether validating
predictions will be made with single species tests with
higher levels of biological Organization or at the
same level,
Indirect human exposure
—A statement should be included indicating the fre-
quency of exposures resulting from the consumption of
contaminated plants and animals and providing examples
of such exposures*
Monitoring and Quality Assurance
—This section discusses mainly chemical and physical mon-
itoring, EPA should also provide its analysis of tlie.
role of biological monitoring. Second, since natural
systems are highly variable, conventional statistical
methods may not be suitable, and discussion of the
types of statistical methods to be used for such
situations would be helpful.
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Major Milestones'
—The relationship between the milestones and the
narrative is not clear; for example, where are the
structure-activity models mentioned? It would also be
helpful to indicate what projects have been
diminished, or augmented.
Comments on Chapter 9s HAZARDOUS WASTES
Research Strategies
—On page 81, paragraph 1, line 5, the words *'dispose of"
are not appropriate. More appropriate language would
be to "dispose of, contain, or detoxify."
Spills reBjgpn_se
—Not enough priority is assigned to ecosystem recovery
processes, The clevelopment of guidelines to establish
ecologically acceptable'residual levels of contaminants
where scientific criteria for the extent of clean-up
<3o not exist is a meritorious research endeavor. How-
ever t the Outlook should describe the research efforts
needed to obtain such criteria. In addition, spill
avoidance should, be explicitly identified as a
technology development target*
Lotig-texro research
--In managing hazardous waste disposal sites and spill
areas, there should be better methods for identifying
the point at which waste removal is warranted vs. other
less costly containment steps. EPA probably cannot
make a "determination of. threshold factor for irrevers-
ibility of ecosystem damage" (page 88) unless a
major effort is undertaken, which is currently not the
case.
Comments on Chapter 10s SUPERFDHD
General Comments
—The chapter largely addresses.technical service needs
rather than research needs.
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-More thought should be given to development of a "hazard-
ous spill index," which would be a function of the
degree of hazard based upon the quantity, toxicity,
and media in which the spill occurred. Such an index
could be used in triggering the Superfund reporting
requirement *
-Development of adequate mobile equipment for rapid de-
toxification of liquid wastes, as well as collection
and storage of hazardous solid wastes, should be under-
written. Mobile treatment equipment should include
carbon treatment techniques, chemical neutralization,
and/or chemical oxidation or detoxification* Also,
the addition of solidification constituents available
on a mobile basis should be researched.
-Scientific guidelines for the restoration of affected
areas should be formulated with emphasis on assessing
waste impacts on topsoil, vegetation, and, particularly,
groundwater. For example, a protocol could be estab-
lished for immediately installing observation wells
in and around an affected area.
Comments on Chapter 11: DRIHKIMG WATER
General Comments
—The Outlook should emphasize low cost testing procedures
as a research priority. In addition, development of
tests for specific pathogens is going to be far more'
valuable than previous gross testing for eoliform
organisms, especially since pathogens may come from
varied sources.
—The emphasis being placed on subsurface contaminant de-
tection is commendable.
—An index, showing where various aquifers and storage
areas are located regionally and 'the current status
of their chemistry, would be extremely valuable to the
drinking water control laboratories.
Comments on Chapter 12j WATER QUALITY
Introduction
--There is no mention of regional and seasonal differences
in the assimilative capacity of watercourses, even though
this is an important issue in water pollution control
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decisions. Biological monitoring, which is mentioned
in much of the legislation, is also not specifically
addressed in the Outlook.
Legislated Responsibilities
--Neither short-term nor long-term risks at levels of
biological' organization 'higher than single species
can now be assessed. This was.-the main theme of the
boolc -Seating for Effects of Chemicals on Ecosystems,
prepared'for^ EPA in 1981 by the National Research Cotm-
cil. This book clearly demonstrates that laboratory-
based single, species toxicity tests may not accurately
predict responses in more complex systems. In view
of this information, the statement, "The most significant
constraint on effectively addressing Phase II water
quality impacts is an inability to accurately quantify
the risks' associated with long-term exposure to toxins,"
(page 108} ie questionable.
Research Strategy
—Why should a high priority be given to increasing
sensitivity down to laboratory derived criterion
values unless these have been validated? If they have
been validated, that should be explicitly stated.
—Field evaluation of selected laboratory derived eco-
logical water quality criteria and identification of
field situations in which criteria adaptation protocols
are urgently needed is one of the most important
problems yet to be resolved and deserves more than "a
small effort" (page 111, paragraph 5).
—One of the most important aspects of contamination of
public waters, from point or non-point sources, is the
speed of detection and the determination of gradient
concentration. Unless specific emphasis is given to
these issues the pathology of a sensitive organism or
series of organisms will not be sufficiently understood
or reported.
Comments on Chapter 13s INDUSTRIAL WAST1WATER
General Comments
—Research efforts should be oriented toward cost-effective
and energy-efficient pollution control systems. There
should be greater emphasis on removing organic materials
with low energy-requiring systems*
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"The use. of bioassays to trigger specific analyses of
toxic wastewater materials is conceptually sound, and
.standard 'research- relating the presence of .toxic
materials to existing or new bioassay techniques has
merit and long-range implications for control strategies
-EPA should continue to reassess the capability.of bio-
logical systems (so-called BPT technology) to remove
toxic wastewater constituents to low-level 'Concentra-
tions .
\
Comments on Chapter 14; MUNICIPAL WASTEWATER
General Comments
-Additional research is needed in the area of low cost
treatment of municipal effluents including overland
flow treatment, waste stabilization pond treatment,
and low energy biological systems in selected areas.
-Research into improvement of individual treatment
systems could be advantageous, especially in light of
the proliferation of individual treatment systems on
the market as many municipalities are forced to make
judgments on septic, tank or individual unit treatment
facilities as compared to central system hook-up.
This research could emphasize treatment systems for
individual households, condominium complexes, motels,
etc. This would be particularly useful for develop-
ments located on rocky or impervious surfaces.
-Pretreatment requirements for industries discharging
into Publicly Qwtied Treatment Works (PQTW's) should
not be based on industrial categories, but should be
based on case-by-case analysis. For example, research
could lead to development of a protocol under which
industries would be required to meet pretreatment
quality levels based on a methodology using treatability
studies. Such studies, in which the industrial component
of treatment would be proportioned by flow, could
constitute a rational basis for determining the impact
of industrial discharges on the POTW system. This
information could then be used to establish pretreatment
requirements for particular industrial plants.
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III. Findings and Recommendations on the Process for the
Preparation of Research Outlook
Following its review,of Research Outlook 1982 the 'Science
Advisory Board is convinced that its role"'in reviewing future
five-year plans needs* altering* Discussions with the staff
of the Office of Research and Development at the July 8-9
meeting of the Board indicate similar thinking on their part.
The process for preparing this year's Outlook.has thus proven
to be mutually unsatisfactory. From the Board's perspective,
there are at least several factors reponsible for the poor
quality of this year's document. These includes
* lack of input by the scientific community in the
preparation of research strategy documents which form
the basis for the Research Outlook?
* a paucity of conceptual thinking for translating
general goals into specific research and management
strategies at various levels of fundingj
* the tendency of the document to present a defense of
the near term status quo rather than articulating a
forward looking plan.
The chapter—by-chapter analysis of the Outlook "by the
Science Advisory Board has highlighted flaws in the process
for preparing the document* Simultaneously, the Board's
evaluation has served as the basis for generating new proposals
which will hopefully lead to significant improvements in
the quality of next year's update of the five-year research
and development plan.
As a guide to formulating specific recommendations for
altering the Research Outlook development process, the Board
offers two general observations. These includes
* The preparation of the Research Outlook should be
closely tied to the development of research strategy
documents within the Office of Research and Development,
and the conceptualization of both sets of documents
shoulct be subject to early Science Advisory Board
review,
* Future Research Outlook plans should present a
statement of research needs that is, not subordinate to
the research budget. Such budgetary scenarios,
extrapolated into future .fiscal years, frequently have
been unrealistic, and the need to defend a particular set
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of resource forecasts lias inhibited a truly candid
Discussion by the Agency of future research needs when
those needs appear to exceed available'resources. As
a result, the Research Outlook has suffered from a
dual identity crisis'—on one hand it is supposed to
represent a scientific statement of EPA's strategic
• research planning needs for a five-year period, and
on the other hand it represents a political statement,
as does any document during any Administration which
addresses resource allocations and the Agency's spending
priorities for environmental research. These two
characteristics of the Outlook have proven to be
mutually incompatible. Perhaps a more realistic
alternative is for the Agency to strive to prepare a
five-year plan which, when submitted to Congress at
the same time as the Administration's budgetary
proposals, does not contain specific resource
projections. Congress could then continue to use the
Outlook as a planning guide in authorising and
appropriating EPA'e research and development budget.
In accordance with .these observations,' the•Science Advisory
Board recommends that the following steps be implemented by
the Office of Research and Development for the preparation of
future Research Outlooks;
1. -There should be a two-tiered set'of guidelines for
drafting research strategies and the research plan. This
would include
a) identification of major research needs that
are important for national environmental protection. At
this stage the information gathering- process would not
specify which research is to be carried out by other
Federal agencies or the private sector, and would be
independent of budgetary constraints.
b) after formulating this comprehensive,research
needs inventory, ORD staff should identify those needs
that are clearly within EPA's legislative mandate and
should command high priority for funding. This
QRD-generated set of priorities would be sent to various
program offices within EPA for review and comment and
possible modification*
2. Following the QHD-program office review phase* ORB
should submit draft strategy documents to a Science Advisory
Board subcommittee for review. The subcommittee's comments
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and recommendations would be forwarded to QRD, the program
offices, and the Deputy Administrator. Figure 1 illustrates
tliis and subsequent steps of the process for the preparation
of the'five-year plan,
3. The results of the preceding process would provide
the basis 'for a draft Research Outlook. Some of the features
of this document would include
a) citations and footnotes to document key
assertions?
b) a matrix comparing each of EPA's major program
areas with a range of research activities ranging from
the toxicology of individual chemicals to technology
development to ecological effects research. Within the
matrix cells would be noted areas in which EPA is carrying
out research and development, research supported by other
Federal agencies, and areas in which EPA expects either
private industry or the states to assume research funding
responsibility. An example of such a matrix is provided
in Figure 2j
c) a scientific as well as a legislative rationale
for the research priorities recommended in the research
strategies and the Research Outlook?
d) approximation of the contribution of each
research priority to abatement of risks to public health
or the environment, perhaps only "high," "medium," and
"low."
4. The Research Outlook would be submitted to the
Executive Committee of. the Science Advisory Board for its
review. The SAB would carry out its review and prepare a
report to the Administrator which would be transmitted to
Congress along with the Research Outlook.
5. The Research Outlook would be revised annually by
repeating the same process. ' However, to assure continued
improvement, copies of each current Outlook would be mailed
to a broad spectrum of outstanding 'environmental researchers
not serving on any EPA advisory committees. Their recommen-
dations for innovative research ideas that might be candidates
for inclusion in EPA's future research strategies would be
solicited. Copies of the Outlook would also be mailed to
other Federal agencies carrying out environmental research
with a request for suggestions that might be considered for
future research strategies. The EPA/ORD staff would analyze
these suggestions and share them with the SAB.
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and recommendations would be forwarded to QRD, the program
offices, and the Deputy Administrator. Figure 1 illustrates
tliis and subsequent steps of the process for the preparation
of the'five-year plan,
3. The results of the preceding process would provide
the basis 'for a draft Research Outlook. Some of the features
of this document would include
a) citations and footnotes to document key
assertions?
b) a matrix comparing each of EPA's major program
areas with a range of research activities ranging from
the toxicology of individual chemicals to technology
development to ecological effects research. Within the
matrix cells would be noted areas in which EPA is carrying
out research and development, research supported by other
Federal agencies, and areas in which EPA expects either
private industry or the states to assume research funding
responsibility. An example of such a matrix is provided
in Figure 2j
c) a scientific as well as a legislative rationale
for the research priorities recommended in the research
strategies and the Research Outlook?
d) approximation of the contribution of each
research priority to abatement of risks to public health
or the environment, perhaps only "high," "medium," and
"low."
4. The Research Outlook would be submitted to the
Executive Committee of. the Science Advisory Board for its
review. The SAB would carry out its review and prepare a
report to the Administrator which would be transmitted to
Congress along with the Research Outlook.
5. The Research Outlook would be revised annually by
repeating the same process. ' However, to assure continued
improvement, copies of each current Outlook would be mailed
to a broad spectrum of outstanding 'environmental researchers
not serving on any EPA advisory committees. Their recommen-
dations for innovative research ideas that might be candidates
for inclusion in EPA's future research strategies would be
solicited. Copies of the Outlook would also be mailed to
other Federal agencies carrying out environmental research
with a request for suggestions that might be considered for
future research strategies. The EPA/ORD staff would analyze
these suggestions and share them with the SAB.
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