United States Science Advisory Board EPA-SAB-EEC-98-005
Environmental Washington, DC February 1998
Protection Agency
SEPA A REVIEW OF THE WASTE
RESEARCH STRATEGY OF
THE OFFICE OF RESEARCH
AND DEVELOPMENT
PREPARED BY THE
ENVIRONMENTAL ENGINEERING
COMMITTEE (EEC)
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February 27, 1998
EPA-SAB-EEC-98-005
Honorable Carol M. Browner
Administrator
U.S. Environmental Protection Agency
401 M Street, SW
Washington, DC 20460
Subject: Review of the Waste Research Strategy of the Office of Research and
Development
Dear Ms. Browner:
The Office of Research and Development (ORD) requested that the Science Advisory
Board (SAB) review research strategies developed by ORD research coordination teams in
consultation with the program offices. The Environmental Engineering Committee (EEC) and a
specially established multi-disciplinary Subcommittee reviewed the Waste Research Strategy at a
public meeting held June 30-July 3, 1997 at the National Risk Management Research Laboratory
in Cincinnati, Ohio.
The EEC was charged to consider whether the strategy clearly captured the environmental
problems associated with wastes; identified the high priority topics and applied appropriate
emphasis; proposed research activities addressing the highest priority research needs; established
clear and reasonable criteria and processes to filter and select the highest priority research; and;
clearly identified future directions that are reasonable and appropriate.
General Comments Before addressing the particulars of this strategy, the EEC wishes to
note that the existence of a Waste Research Strategy is, in itself, commendable progress. Three
years ago, the EEC's strategic research planning commentary (EPA-SAB-EEC-COM-94-004)
recommended development of a vision statement; a definition of a mission; an assessment of
strengths, weaknesses, external opportunities, and threats; and identification of strategic initiatives
and metrics of success. The Subcommittee will now recommend two advancements to the
process of research strategy development—the involvement of external organizations in the
planning process and transparent documentation of decisions. The Subcommittee also notes
ORD's decision to develop a research strategy for waste, while not completely addressing the
Committee's concern (EPA-SAB-EEC-97-011) over EPA's decreased emphasis on waste
management research, is a positive step.
The Subcommittee commends ORD for its adoption of risk reduction as the cornerstone
of its waste research strategy. The risk reduction approach is an improvement over earlier
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approaches. If this approach is implemented properly, the effectiveness and impact of ORD's
research programs will improve significantly.
The waste research strategy has strengths in some areas and needs improvement in others.
In general, implementation of the strategy is likely to produce results that will improve the
Agency's capacity to address waste management problems and reduce risks to human health and
the environment.
Within the universe of research opportunities considered in the strategy, the programs and
projects highlighted are reasonable and largely justifiable. Strategic planning for waste
management, however, is a dynamic process that may need revision as new information becomes
available.
Specific Findings & Recommendations Major findings and recommendations based on
detailed review of the ORD waste research strategy are summarized below:
a) The Subcommittee finds that the set of waste research issues identified by ORD for
coverage in the strategy is appropriate and important. However, ORD needs to
involve representatives of external organizations in the planning process. External
expertise should be drawn from stakeholder sectors such as the academic
community, non-profit organizations, other public agencies and the private sector.
b) The risk reduction methodology used in screening waste research issues and topics
is adequate but its application process is not clear. The prioritization scheme for
research topics should be made more transparent. Lack of transparency may
compromise the credibility of an otherwise useful waste research prioritization
scheme. The scheme can be made more transparent by documenting how and why
specific research topics were assigned various priority levels. The ranks assigned
to topics should reflect the hierarchy and criticality of the needs that were
identified earlier in the process.
c) It is necessary for ORD to establish linkages between the waste research strategy
and parallel efforts within and outside the Agency. Such linkages are expressed in
ORD documents only in global terms. If such linkages exist at specific project
levels, it may be possible to avoid duplication of efforts or neglect of important
issues. Examples of risk reduction efforts outside the Agency are the Risk-Based
Corrective Action (RBCA) programs operated by Environmental Protection
Agencies of various states; waste management programs of the Department of
Energy; and natural hazards mitigation programs of the Federal Emergency
Management Agency (FEMA), U.S. Geological Surveys of the National Institute
for Standards and Technology (NIST).
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d) ORD should include information on current and projected budgets in its research
strategy. Budget information is useful for assessing the relative merit of
performing research on some waste issues within or outside the Agency.
e) ORD should develop a means of utilizing the results of extramural research in
intramural research planning.
f) Considering the large volume of wastes generated each year and the existence of
thousands of contaminated sites, better balance between research on risk
characterization and technologies for site remediation and waste management
should be attained in the strategy.
g) While technical support is extremely important and deserving of much attention, it
should not be a major research focus of the strategy. ORD should acknowledge
the importance of technical support on waste issues in the Strategy and work with
other organizations of the Agency toward its implementation.
The EEC and the Waste Research Strategy Subcommittee appreciate the opportunity to
review this strategy and thank ORD personnel for the information they provided during the
review process. The SAB looks forward to a written response from the Assistant Administrator
for ORD.
Sincerely,
/signed/
Dr. Joan Daisey, Chair
Executive Committee
/signed/
Dr. Ishwar P. Murarka, Chair
Environmental Engineering Committee
/signed/
Dr. Hilary I. Inyang, Chair
Waste Research Strategy Subcommittee
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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
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.
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ABSTRACT
The Environmental Engineering Committee of the EPA Science Advisory Board reviewed
the Waste Research Strategy prepared by the EPA Office of Research and Development. The
Committee commends EPA for developing the Strategy, which responds to previous SAB advice
(EPA-SAB-EEC-COM-94-004) and decisions (EPA-SAB-EEC-97-011). The Committee also
commends ORD for adopting risk reduction as the cornerstone of the Strategy. If this approach
is implemented properly, the effectiveness and impact of ORD's research programs will improve
significantly. The Committee finds the Strategy has strengths and opportunities for improvement.
In general, implementation of the Strategy is likely to improve the EPA's capacity to address
waste management problems and reduce risks to human health and the environment.
The Committee now recommends two advancements to the process of research strategy
development — the involvement of external organizations in the planning process and transparent
documentation.
Establishing and documenting linkages between the ORD waste research strategy and
related efforts within and outside the Agency, will strengthen the strategy. Such description
indicates the authors know the field and it reduces the likelihood that efforts will be duplicated or
important issues neglected. Examples of such organizations are Risk-Based Corrective Action
(RBCA); programs operated by state agencies concerned with environmental protection; the
waste management programs of the Department of Energy; and natural hazards mitigation
programs of the Federal Emergency Management Agency (FEMA), U.S. Geological Surveys of
the National Institute for Standards and Technology (NIST).
The final Strategy should describe how and why specific research topics were assigned
various priority levels so clearly that a stranger to the process could pick up the Strategy and
understand how each decision was made.
Keywords: waste, research, research planning
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U.S. Environmental Protection Agency
Science Advisory Board (SAB)
Environmental Engineering Committee (EEC)
Waste Research Strategy Subcommittee
Chair
Dr. Hilary I. Inyang, Center for Environmental Engineering, University of Massachusetts,
Lowell, MA.
Members
Dr. Stephen L. Brown, R2C2 Risks of Radiation and Chemical Compounds, Oakland, CA
Dr. Barry Dellinger, Environmental Sciences and Engineering, University of Dayton Research
Institute, Dayton, OH
Mr. Terry Foecke, Waste Reduction Institute, St. Paul, MN
Dr. James H. Johnson, Jr., College of Engineering, Architecture and Computer Sciences,
Howard University, Washington, DC
Dr. Richard Kimerle, Consultant, St. Louis, MO
Dr. Ishwar Murarka, Land and Groundwater Protection and Remediation, Environmental
Group, Palo Alto, CA
Dr. Frederick Pohland, Dept. of Civil and Environmental Engineering, University of Pittsburgh,
Pittsburgh, PA
Ms. Lynne Preslo, Technical Programs, Earth Tech, Long Beach, CA
Dr. William Randall Seeker, Energy and Environmental Research Corp., Irvine, CA
Dr. Lauren Zeise, Office of Environmental Health Assessment, California Environmental
Protection Agency, Berkeley, CA
Science Advisory Board Staff
Kathleen W. Conway, Designated Federal Officer, Science Advisor Board, U.S. Environmental
Protection Agency, Washington, DC
Dorothy Clark, Staff Secretary, Science Advisor Board, U.S. Environmental Protection Agency,
Washington, DC
in
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TABLE OF CONTENTS
1. EXECUTIVE SUMMARY 1
2. INTRODUCTION 4
3. RESPONSES TO SPECIFIC CHARGE QUESTIONS 7
3.1 Charge 1: Coverage of Environmental Problems Associated with Wastes 7
3.1.1 "Waste Research" as a Misnomer for Issues Covered 7
3.1.2 Research Needs Identification Process 7
3.1.3 Implications and Adequacy of the Research Issue Classification 7
3.2 Charge 2: Identification of High Priority Areas 7
3.2.1 Agency Program Office Research Preferences versus National Waste
Research Needs 7
3.2.2 Non-utility of Research Area Prioritization 8
3.2.3 Balance of Risk Characterization with Risk Mitigation 8
3.2.4 Linkages among Parallel Programs 9
3.3 Charge 3: Utility of Selected Research Topics 9
3.3.1 Topics on Ecological Issues 9
3.3.2 Topics on Human Health and Exposure Issues 9
3.3.3 Topics on Soil and Groundwater Issues 10
3.3.4 Topics on Active Waste Management Facilities 11
3.3.5 Topics on Waste Combustion 11
3.3.6 Inclusion of Technical Support in Waste Research 13
3.4 Charge 4: Appropriateness and Implementation of Research Topic
Prioritization Scheme 13
3.4.1 Use of the Risk Paradigm 13
3.4.2 Transparency of the Process 13
3.4.3 Utilization of Gathered Information 13
3.4.4 Weighting of Criteria as a Reflection of Critical Needs 14
3.4.5 Identification of Alternative Funding for Non-covered High
Priority Areas 14
3.5 Charge 5: Clarity of Future Research Directions 14
3.5.1 Use of Research Products as Input to the Next Planning Process 14
3.5.2 Intramural versus Extramural Research Programs 14
3.5.3 Intramural Research Personnel Issues 15
3.5.4 Budget Estimates as an Index of Research Strategy and Schedule .... 15
Appendix A - Glossary A-l
Appendix B - EPA Documents Provided for Review B-l
REFERENCES R - 1
IV
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1. EXECUTIVE SUMMARY
The Subcommittee commends the Agency for its effort on the development of a
comprehensive strategy for conducting waste-related research. This strategic plan is an
improvement over earlier plans because a methodology was developed for application to the
problem of research issue screening so that intramural research can be focused on critical needs.
It is particularly noteworthy that some elements of the Risk Reduction Methodology that is being
developed by a diverse panel of the Science Advisory Board have been applied in the development
of the ORD waste research strategy. If this effort is sustained within the Agency, the
effectiveness of the Agency's internal risk reduction research will be significantly improved.
However, it should be recognized that strategic planning for attainment of environmental goals is
a dynamic process. As more information becomes available, the plan will need to be revised
accordingly.
The Subcommittee found that the waste research strategy has merit in some areas, while it
needs significant improvement in others. A brief summary of findings by the Subcommittee on
each of the charge questions is presented. Details on these findings and relevant
recommendations are provided in various sections of this report.
Charge Question #1 — Has ORD clearly captured and presented the environmental problems
associated with wastes?
Response: Yes. ORD has identified significant environmental problems from releases of
contaminant by numerous solid waste management units, oil spills, proliferation of human
and ecosystem exposure pathways (for contaminants), and existence of thousands of
contaminated sites. The effort made by ORD to compile and update this information is
commendable.
Charge Question #2 — Has ORD identified the high priority topics that need to be addressed?
Has too much or too little emphasis been placed on one or another of the topic areas? Do any
other major topic areas need to be added?
Response: Yes. Within the universe of research opportunities considered in the strategy,
the programs and projects highlighted are reasonable and largely justifiable. However, the
Agency appears to have focused only on its internal customers. If external customers had
been involved in the identification and prioritization of research needs, the research
priorities might have been different. The Subcommittee recommends that ORD seek input
from other stakeholders such as consultants, members of the academic community, non-
profit organizations, and private companies so that both internal and external views could
be embraced.
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The Subcommittee observes that the research strategy emphasizes the study of wastes and
contaminated sites before treatment. Considering the fact that the need for waste
management and improvement of remediation technologies for contaminated sites is still
high, remediation research should not be de-emphasized in the ORD waste research
strategy. Technical support is a necessary component of ORD research programs but it
should not be ranked with the same criteria that ORD has applied to research topics.
The ORD research strategy is media-focused: groundwater, soils/vadose zone, air
(emissions) and active waste management facilities. The Subcommittee believes that some
elements of the media-focused approach are important but the cross-media approach is
better-suited to ORD's efforts at developing solutions to real-world problems.
Charge Question #3 - Are the research activities proposed within each topic area addressing the
highest priority research needs? Has too much or too little emphasis been placed on one or
another of the research activities (topics)? Do any other major research activities (topics) need to
be added?
Response: In the groundwater and soils research area of the research strategy, natural
attenuation, biotreatment, contaminant fate and transport modeling and site
characterization/field screening justifiably, rank highly. Too little emphasis has been
placed on waste containment research and potentially useful physico-chemical treatment
techniques such as vitrification and stabilization. Additional important topics that are not
covered by the strategy are technologies for 'Brownfields' site decontamination and
redevelopment; natural hazards effects on waste containment, utilization of wastes; low-
level radioactive waste-contaminated sites; and naturally occurring radioactive materials
(NORM).
The research topics selected in the waste combustion area have adequately cover research
needs on emissions from hazardous waste incinerators, municipal solid waste incinerators,
cement kilns, industrial furnaces and medical waste incinerators. Emissions from other
types of combustors need to be included. Examples are sewage sludge incinerators and
thermal treatment technologies.
The topics listed for current and future research focus in the active waste management
research area relate mostly to waste toxicity, modeling of fate and transport processes and
waste characterization. These topics are too generic and tend to overlap with the same
suite of topics that are categorized under the soils and groundwater areas. In order to
improve the effectiveness of control measures for present and future releases of
contaminants from active waste management facilities, the Subcommittee recommends
that the following research issues be considered for inclusion in the research strategy:
contaminant teachability from utilized wastes; long term performance of facilities such as
surface impoundments, waste piles and confined disposal facilities (CDSs); and leak
control and monitoring technologies.
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The topics on ecological, human health and exposure issues are appropriate. They are
consistent with some of the recommendations made during ongoing critical review of
EPA's exposure and risk assessment methods by the Science Advisory Board. More
detailed information about specific research topics are needed to assess the extent to
which the projects will reduce uncertainties in the factors needed to address human health
and exposure issues.
Charge Question #4 — Are criteria and processes used to filter and select the highest priority
research clear and reasonable?
Response: ORD has significantly improved its methodology for prioritizing its program
activities. The waste research strategy is conceptually consistent with ORD's strategic
plan. Information presented to the Subcommittee confirms that risk reduction potential
was considered as a screening tool in the prioritization of waste research topics.
However, although the methodology and criteria are structurally reasonable, their
application is not sufficiently transparent. More detailed information on how and why
specific research topics were assigned various priority levels would have been useful.
Such information could help ORD in the demonstration of the extent to which the ranks
assigned to research topics reflect the hierarchy and criticality of the needs identified
earlier in the process. The Subcommittee recommends that alternative and/or future
funding sources be identified for high priority topics that are not covered in the current
research strategy.
Charge Question #5 — Are the future directions for research in the program clearly identified
in the plan and are they reasonable and appropriate?
Response: The future direction of research areas has been clearly identified in the plan.
The reasonableness and appropriateness of the future directions of research could not be
credibly evaluated by the Subcommittee because it lacked information on the availability of
the "critical mass" of the internal ORD experts and projected budgets for the future.
The Subcommittee recommends that ORD integrate information on core competencies
from its overall Strategic Research Plan into its waste research strategy. A system should
be developed for utilizing the results of extramural research in intramural research
planning.
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2. INTRODUCTION
The Office of Research and Development (ORD) of the U.S. Environmental Protection
Agency developed a research strategy to address waste-related environmental problems through
fiscal year 2000. The research strategy was presented to the Environmental Engineering
Committee (EEC) of the Science Advisory Board (SAB) for review. Several documents listed in
Chapter 5 of this report were provided to the EEC members prior to the July 1, 1997 review
meeting at U.S. EPA's National Risk Management Research Laboratory (NRMRL) in Cincinnati,
Ohio. In preparation for the July 1, 1997 meeting, a telephone conference call was held on June
13, 1997, during which U.S. EPA senior personnel presented elements of the waste research
strategy and responded to inquiries by EEC members and consultants. More detailed
presentations were made by ORD staff in Cincinnati. This report has been prepared to
communicate the consensus comments in response to the five-point charge given to the
Subcommittee.
In general, the primary objective of the waste research strategy is to apply ORD's strategic
planning principles, goals and ranking criteria to its internally-driven effort toward establishing
priorities for waste-related research. As expressly stated in the Executive Summary of the
research strategy document, ORD will use this strategy to select and focus on the most important
research areas. ORD also hopes that stakeholders outside ORD can use this strategy to identify
research needs and priorities. Following its internal screening process, during which some
research topic areas were filtered out, ORD decided to group its waste research projects into five
categories:
a) Contaminated sites - groundwater
b) Contaminated sites - soils/vadose zone
c) Emissions from waste combustion facilities
d) Active waste management facilities
e) Technical support
Thirty nine (39) research projects were initially identified. Among the parameters stated
by ORD as being included in the criteria for ranking these projects were uncertainty in risk
assessment, efficacy and cost-effectiveness of risk management technologies, and the broad
applicability of methods and models. The non-science criteria included administrative priority,
Program Office priority, regulatory or legal mandates, priorities within the Agency, Congressional
directives, FY 98 area for new funding and Committee on Environment and Natural Resources
(CENR) research priority. Table 1 provides the research project topics or task areas within the
five program (topic) areas and their overall rankings.
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ORD requested a review of the waste research strategy by the EEC. The Waste Research
Subcommittee has herein provided responses to the following five-point charge:
a) Has ORD clearly captured and presented the environmental problems associated
with wastes?
b) Has ORD identified the high priority topics that need to be addressed? Has too
much or too little emphasis been placed on one or another of the topic areas? Do
any other major topic areas need to be added?
c) Are the research activities proposed within each topic addressing the highest
priority research needs? Has too much or too little emphasis been placed on one
or another of the research activities? Do any other major research activities need
to be added?
d) Are criteria and processes used to filter and select the highest priority research
clear and reasonable?
e) Are the future directions for research in the program clearly identified in the plan
and are they reasonable and appropriate?
The Subcommittee considers it appropriate to provide a written evaluation of both the
waste research strategy development process and the topics selected. To the extent possible,
comments are provided as recommendations which ORD may consider in its on-going effort to
develop and refine its waste research strategy.
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Table 1. Selected ORD Waste Research Program Research Activities
Research Topic
Areas
(In Priority Order)
Contaminated Sites -
Ground Water
Contaminated Sites -
Soils / Vadose Zone
Emissions from
Waste Combustion
Facilities
Active Waste
Management
Facilities
RESEARCH ACTIVITIES BY RISK PARADIGM CATEGORIES
Risk Assessment
Exposure
Assessment
- Environmental Fate
and Transport
Modeling (7)*
- GW Exposure
Factors / Pathways
(21)
- Estimating Human
Exposure &
Delivered Dose (1)
- Estimating Soil
Intake and Dose
-Wildlife Species
(3)
- Indirect Exposure
Characterization/
Modeling (13)
- Indirect Pathway
Risk Assessment
Methods (11)
- Multimedia,
Multipathway
Exposure Modeling
(14)
- Environmental Fate
and Transport;
Physical Estimation
(25)
Toxicity Assessment
- Mixtures Toxicology
(26)
- Ecological Risk
Assessment Methods
(38)
- Human Dose-Response
Models for Mixtures
(3)
- Ecological Screening
Tests to Measure the
Effectiveness of
Treatment (18)
- Mixtures Toxicology
(34)
- Movement of
Bioaccumulative
Chemicals in Food
Webs (33)
- Dose-Response of Key
Contaminants (24)
- Developing Provisional
Toxicity Values for
Contaminants (18)
Risk
Characterization
Risk Management
Remediation &
Restoration
- Natural Attenuation (2)
- Abiotic Treatment of GW
(9)
- Biotreatment of GW (16)
- Containment of GW ( 17)
- Demonstration/
Verification of Innovative
Remediation
Technologies (27)
- Biotreatment of Soils (3)
- Containment of Soils (18)
- Demonstration/
Verification of Innovative
Remediation
Technologies (27)
- Abiotic Treatment of
Soils (31)
- Oil Spills (36)
Control
- Emissions
Prevention
and Control
(12)
- Waste
Management
(36)
Monitoring
- Subsurface Characterization
(6)
- Field and Screening
Analytical Methods for GW
(5)
- Demonstration/ Verification
of Field Monitoring
Technologies (27)
- Field Sampling Methods
(8)
- Field and Screening
Analytical Methods for
Soils (9)
- Sampling Design (22)
- Demonstration/ Verification
of Field Monitoring
Technologies (27)
- Continuous Emissions
Monitoring (CEMs)
Methods (23)
- Waste Characterization and
Sampling (32)
* Equals the ordinal rank of each research activity across the entire Waste Research Program based on the science plus ranking factors.
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3. RESPONSES TO SPECIFIC CHARGE QUESTIONS
3.1 Charge 1: Coverage of Environmental Problems Associated with Wastes
3.1.1 "Waste Research" as a Misnomer for Issues Covered
The title of the program, "waste research" is a misnomer, considering the issues covered.
The broad areas of research covered are contaminated sites (groundwater and soils), emissions
from waste combustion facilities, and active waste management facilities. "Waste and Site
Remediation Research" is considered a more appropriate title than "Waste Research" for the
suite of environmental issues covered.
3.1.2 Research Needs Identification Process
In the oral presentations and the research strategy documents, ORD identified several
significant environmental problems relevant to "waste research" programs. Among these
problems are releases of contaminants by numerous solid waste management units, oil spills,
proliferation of human and ecosystem exposure pathways (for contaminants), and existence of
thousands of contaminated sites. The effort made to compile and update these data is
commendable. However, the involvement of non-EPA personnel in the research needs
identification process was lacking. Moreover, the needs discussed were not strongly linked to
the reduction of risks or waste management problems discussed.
3.1.3 Implications and Adequacy of the Research Issue Classification
The titles used to classify research issues broadly should reflect those issues; otherwise
research inventory takers may erroneously assume (using the titles) that specific issues have
been covered by ORD's strategy. The classification system used by ORD is largely media-
focused: groundwater, soils/vadose zone and air (emissions). Although elements of this
approach are important, focus on issues and/or techniques across various media seems more
consistent with an approach directed at finding solutions, e.g., "improvement of containment
systems for waste." The latter may involve consideration of cross-media pollution problems
such as contaminant releases to the atmosphere, groundwater and vadose zone.
3.2 Charge 2: Identification of High Priority Areas
3.2.1 Agency Program Office Research Preferences versus National Waste
Research Needs
Within the universe of research opportunities considered in the strategy, the programs and
projects highlighted are reasonable and the justifications are adequate. However, ORD appears
to have focused only on internal customers. If representatives of external customers such as the
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general public, engineering firms and the regulated community had been involved in the
prioritization of research needs, the research priorities might have been different. For example,
"Brownfields" characterization is an issue for which these external stakeholders frequently seek
technical support. In the waste research strategy, there should be better communication of the
linkage between ORD/Agency Program Office research preferences and the identified national
waste research needs. Then, it would be possible to evaluate the effects of implementation of
the agency-preferred research tasks on national waste management problems.
3.2.2 Non-utility of Research Area Prioritization
ORD has identified four groupings of research issues which it refers to as research topic
areas. Ranking of the categories is less useful than ranking of the specific research projects that
constitute the categories. It is difficult and perhaps meaningless to establish the importance of
groundwater contamination research relative to soil contamination research on a national basis.
If both problems are desegregated into various aspects, it may be easier to weigh them relative
to one another. In this regard, the issue ranking approach adopted by ORD is superior to the
category ranking approach.
3.2.3 Balance of Risk Characterization with Risk Mitigation
Figure 1 is a representation of the risk control scheme favored by ORD. An analysis of
how the research issues that rank highly in Table 1 fit into Figure 1 indicates overemphasis on
Statutory and Legal
Considerations
Dose-Response
Assessment
Public Health
Considerations
Hazard
Identification
Risk
Management
Decision
Risk
haracterizati
Exposure
Assessment
Risk
Management
Options
Political
Considerations
Compliance
Approaches &
Monitoring
Figure 1. Conceptual risk control scheme adopted by U.S. EPA's Office of Research
and Development (ORD)
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risk characterization. Few of the highly ranked issues can be regarded as risk mitigation. The
current strategy emphasizes the study of wastes and contaminated sites before treatment.
Considering that in many cases, the decision has already been made to remediate pollution at
contaminated sites, and that characterization alone is not the solution, research on technologies
for site cleanup should not be de-emphasized within ORD programs.
3.2.4 Linkages among Parallel Programs
There should be more linkages among ORD research issue plans and with research of other
agencies. For example, the National Institute of Environmental Health Sciences (NIEHS)
performs basic toxicology work for the Superfund office. In addition, the EPA Hazardous
Substance Research Centers perform several aspects of site characterization and cleanup
research. Although it is mentioned that these and other programs were considered, it is not
clear why specific research topic areas that appear to fit those programs were also ranked highly
in ORD's Waste Research Program.
3.3 Charge 3: Utility of Selected Research Topics
3.3.1 Topics on Ecological Issues
The aspects of research included in the strategy on ecological issues are appropriate.
Although there was a sense that ecological issues should play a larger role in comparison with
human health concerns in the development of waste site remediation standards, the specific
research focus of the ecological aspects included is vague. For instance, on the topic of
chemicals in food webs, what specifically will be done? Will the focus be on plants,
invertebrates, fish, mammals or birds? The Subcommittee would like to encourage the use of
the Agency's Ecological Risk Assessment Guidelines as a template for identifying ecological risk
assessment needs. In addition, the Subcommittee calls to the attention of the waste research
strategy planners a recent study (C & EN, 1997) offish in 25 streams in 31 states by the U.S.
Geological Survey. Several pesticides and phenol compounds in biological tissues were
correlated with estrogen and testosterone in fish. These hormones in fish are significant with
respect to reproductive ability. Some useful information may be gained from this and other
studies by ORD.
It was difficult to follow the path of selection of ecological issues from the broader set of
waste-related problems summarized and the specified criteria. The future directions of
ecological research, generally are appropriate, except that restoration of damaged ecosystem is
not covered.
3.3.2 Topics on Human Health and Exposure Issues
The proposed program in the area of health risks of chemical mixtures could possibly
satisfy the high risk and high uncertainty criteria, but lack of information on specific research
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projects planned within the issues listed makes it difficult to confirm the potential for reduction
of uncertainty.
The future directions of human health and exposure research listed are appropriate. They
are consistent with some of the recommendations made during ongoing critical review of EPA's
exposure and risk assessment methods by the Science Advisory Board.
3.3.3 Topics on Soil and Groundwater Issues
The description of groundwater contamination (pages 27 and 33) in the Strategic Plan
should be expanded to include:
a) the state of groundwater contamination in the United States (with references);
b) discussions of uncertainties with respect to detection and quantification of contaminants
in groundwater and effectiveness of remedial action; and
c) the fact that groundwater may be the slowest resource to recover naturally.
It is not clear how the priorities were assigned to the sub-topics within the groundwater
area. For example, why are subsurface contaminant containment and its associated aspects
ranked below characterization, modeling, field screening methods and biotreatment?
Characterization of dense non-aqueous phase liquids (DNAPLs) is an important research focus,
but improvement of the cost-effectiveness of containment technologies and associated long-term
performance assessments is equally important.
Modeling of fate and transport of contaminants ranks high in the plan, and certainly is an
ORD research strength. However, rather than focus on modeling in general, efforts should be
devoted to developing models for specific media that have not been adequately covered by
existing models. Examples are karst terrain and fractured bedrock. There are numerous fate-
and-transport models for porous media, and consumption of limited resources by research
producing marginal increases in precision and accuracy of porous media models is not justified.
Demonstration and verification of innovative groundwater remediation and monitoring
technologies should be coordinated with other ongoing activities, such as the demonstrations at
Dover and McClellan Air Force Bases, the projects at the University of Waterloo and Rice
University, and other initiatives. It is also considered useful to assess the relationship between
these efforts and the activities that EPA conducts under its SITE program. The criteria and
processes used to filter and select highest research priority topics in the soil and groundwater
area are justified. However, it is difficult to reconcile the final rankings, because the rationale
for assigning scores or ranks to the topics considered is unclear.
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Natural attenuation and biotreatment justifiably rank very high in the strategy. However,
the Subcommittee is concerned that other promising technologies have been overlooked. Are
there other applied research or technical support programs that deal with vitrification,
stabilization, etc., within the Agency? There is general relegation of site (soils and groundwater)
research to lower ranks without adequate explanation. Other issues that are not embraced
include: "Brownfields" site contamination, remediation and control; natural hazards effects on
waste containments; utilization of wastes; low-level radioactive waste-contaminated sites; and
naturally occurring radioactive materials (NORM). The success of the future research focus
areas listed will depend on the specific projects selected. The exclusion of issues, such as those
mentioned above, from both the current and future research plans should be explained.
3.3.4 Topics on Active Waste Management Facilities
It is correctly stated in the waste research strategy document (page 172) that "the current
regulatory approach to the management of hazardous wastes is considered extremely
burdensome and costly to the U.S. economy." It is further stated that relevant "regulations are
considered overly conservative and not well-founded on risk." The research plan presented on
active waste management facilities covers issues that are not specifically targeted at reducing the
problem that has been described. The topics listed for the current and future research focus
mostly relate to waste toxicity, modeling of fate and transport processes, and waste
characterization. It can be argued that all of these topics are only indirectly relevant to a
research plan that would address the control of present and future releases of contaminants from
active waste management facilities. Furthermore, they tend to overlap with the same suite of
topics that were categorized under the soils and groundwater areas.
The types of active waste management facilities that are to be addressed should first be
identified. Are they the thousands of surface impoundments that are known to leak? What
about waste piles from mining wastes? Is the long-term performance of confined disposal
facilities (CDFs) addressed elsewhere? Do holding tanks for liquid wastes at industrial plants
leak? After justifiable selection of the types of waste management facilities and identification of
knowledge gaps in technologies that could control releases and hence reduce risks, ORD could
then select topics with an appropriate focus.
It was estimated (U.S. EPA, 1992) that by the year 2000, the generation rate of municipal
wastes in the United States will be about 222 million tons per year. Society is increasingly faced
with the problem of low toxicity, high volume wastes, some of which have potential as partial
replacement for traditional construction materials. Lack of a knowledge on contaminant
teachability from composite construction materials that contain some of these low toxicity
materials have interfered with potentially beneficial utilization of these materials. Therefore, the
Agency should include this issue in its research plans and relevant technical guidance initiatives.
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3.3.5 Topics on Waste Combustion
If de-emphasis of combustion research is because waste incineration has been relatively
well addressed compared to other types of combustion, an appropriate focus for the current
combustion research component of the strategy should be the characterization of emissions from
a diversity of sources. The plan addresses emissions from hazardous waste incinerators,
municipal solid waste incinerators, cement kilns, industrial furnaces and medical waste
incinerators, but it does not include emissions from other waste combustors such as sewage
sludge incinerators or thermal treatment technologies, including thermal desorbers or oxidizers
for treatment of contaminated soils. Although it would be logical to include these topics in this
strategy, oral discussion indicated that they were not considered in the development of this
research strategy.
The strategy does not go into detail on the issues involved in waste combustion, nor does it
document the importance of the issues with statistics or other metrics. However, it does
correctly identify the research priorities which are, in order of priority; emission prevention and
control, indirect exposure characterization/modeling, indirect pathway risk assessment methods,
continuous emissions monitoring methods, and studies of the movement of bioaccumulative
chemicals in food webs. Although the titles of these subject areas do not adequately describe
the detailed research priorities, the more detailed breakdown included in the strategy provides
some insights and reflects a strong grasp of the subject matter.
The high priority should be characterization of emissions from waste combustors, and
development of a better understanding of how the combustion process leads to formation of
pollutants. While incineration is a highly efficient method of organic waste destruction, it still
represents a source of direct introduction of pollutants into the environment. This residual is
emitted as organic by-products, with only 20-50% of the emissions being chemically
characterized. While this is similar to other combustion sources, characterization of emissions
should be a priority for waste combustors (and other combustion sources). Determining the
origin of these emissions so that they can be prevented and controlled is the logical progression
for the research.
Several tasks were identified that relate to better assessment of exposure and risk. The
results of the WTI risk assessment clearly identified these weaknesses in the risk assessment
procedure. Of these, gas-solid partitioning and local terrain models may be the most important.
Gas-solid partitioning of semi-volatile pollutants controls their uptake into the food chain and
ultimately the route of human exposure.
Development of Continuous Emission Monitors (CEMs) for dioxins and mercury continues
to be a real need, but could be better accommodated by long-term, high-risk research studies
funded through the grants program and/or NSF.
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Major concern with the combustion emissions strategy is lack of definition of which
combustion sources are included. Emissions from hazardous waste, municipal waste, medical
waste, sewage sludge, and contaminated soil thermal treatment technologies should be included.
The data will be more meaningful if they are generated in combination with data from other
combustion sources suspected of emitting toxic combustion by-products. Coordination with
EPA's air toxics program is indicated.
3.3.6 Inclusion of Technical Support in Waste Research
Technical support is a program that should apply to all areas of ORD's research effort. The
same criteria can not be credibly used to rank it along with research areas or topics. Therefore,
it is considered inappropriate to include it as one of the areas of major research focus. While
technical support is extremely important and deserving of much attention, it should not be a
major research focus of the strategy. ORD should acknowledge the importance of technical
support on waste issues in the strategy and work with other organizations of the Agency toward
its implementation.
3.4 Charge 4: Appropriateness and Implementation of Research Topic Prioritization
Scheme
3.4.1 Use of the Risk Paradigm
The ORD has significantly improved its methodology for prioritizing its program activities
and it is commendable that the risk paradigm has been adopted as the foundation for structuring
ORD's research programs. The waste research strategy is conceptually consistent with ORD's
strategic plan. Information presented to the Subcommittee confirms that risk reduction potential
was considered as a screening tool in the prioritization of waste research topics. A refined
research strategy should include an analysis of the areas of the risk paradigm in which USEPA
and external organizations need strengthening. Although, these areas vary from one issue to
another, such variabilities need to be communicated and addressed.
3.4.2 Transparency of the Process
Although the methodology used for waste research prioritization is structurally
appropriate, its implementation is not sufficiently transparent. More detailed information on
how and why specific research topics were assigned various priority levels need to be
documented. To what extent do the rankings assigned reflect the hierarchy and criticality of
needs identified earlier in the process? Others should be able to apply the methodology and
arrive at a reasonably similar set of waste research priorities. The transparency of the
application of the methodology is a determinant of the extent to which ORD can successfully
defend its research priorities.
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3.4.3 Utilization of Gathered Information
ORD presented referenced information, especially on the inventory of waste/contaminated
sites and expressed missions of other agencies. The categories of research performed by other
agencies and other organizations within EPA are identified. However, the utility of these
external research efforts with respect to EPA's research mission was not adequately
communicated. For example, it was mentioned that the Agency for Toxic Substances and
Disease Registry (ATSDR) is involved in toxicological database development, and that one of
its mandates is "to provide EPA with critical health-based information so that clean-up decisions
that are effective and protective to public health can be made." Is there a relationship between
the high ranks assigned by ORD to human exposure and toxicological research and possible
inadequacies also addressed in related to ATSDR research?
3.4.4 Weighting of Criteria as a Reflection of Critical Needs
The fifth stage of ORD's Waste Research Ranking Scheme illustrated in Figure 2 is the
prioritization of research activities. Ordinal rankings of the activities were developed using three
criteria: uncertainty in risk assessment, efficacy and cost-effectiveness of risk management
technologies, and broad applicability of methods and models. This approach has merit, but the
relative importance of each of the three evaluation criteria should be made explicit. Weighting
of the criteria may produce results that are more reflective of ORD's risk management needs.
Currently, the assumption (which may be justifiable) is that the three criteria have equal weights.
3.4.5 Identification of Alternative Funding for Non-covered High Priority Areas
ORD generally considered funding limitations, in-house expertise and capacity to perform
waste research, although this was done on a rather generic basis. During the vetting process
(especially, the science-plus evaluation), there was the possibility that certain research needs
with high risk reduction potential were eliminated. High utility research issues and associated
activities that "fall off the table" should be addressed in other programs or considered in
subsequent plans for the Waste Research Strategy.
3.5 Charge 5: Clarity of Future Research Directions
3.5.1 Use of Research Products as Input to the Next Planning Process
In each of the four major research focus areas, the connection between the results of the
initial research program and the plan for subsequent research activities should be refined. In the
strategy document, it is difficult to establish the connection. Perhaps some of the issues will be
adequately addressed by a 3-year program but, ORD's projections should be expressed despite
the uncertainties associated with such prediction.
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3.5.2 Intramural versus Extramural Research Programs
The ORD has operated an elaborate extramural research program on issues that overlap, or
at least intersect, those that are covered by this intramural research strategy. In the strategy
document reviewed, it was not clear whether this relationship was considered. How does ORD
decide to classify topics for extramural research? Are the products of the extramural research
effort used in internal research prioritization? The Subcommittee recommends that a system be
developed for utilizing the results of extramural research in intramural research planning.
3.5.3 Intramural Research Personnel Issues
The plan is mostly silent on ORD's capacity to perform intramural research in the areas
selected. The availability of the "critical mass" of internal experts is an important determinant of
the potential success of the program. It would be helpful for ORD to integrate information on
core competencies from its overall strategic research plan into the waste research strategy.
Recently, the National Risk Management Research Laboratory (NRMRL) has advertized
vacancies for post-doctoral researchers, which could augment internal research expertise.
3.5.4 Budget Estimates as an Index of Research Strategy and Schedule
The extent to which the available or projected budget affected the research prioritization
process is not clear. If the scope of essential research tasks is limited by budget constraints,
such tasks should be identified, transferred to a program that can support it, or tagged for
coverage in a subsequent program.
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Needs Input
OSWER
ORD
Regions
CENR Strategy
Identification of
Research Needs
Preliminary Filtering
of Research Needs
Identification of
Research Topic Areas
& Associated
Research Activities
Prioritization of
Research Activities
Final Filtering of
Research Activities
Selection of
Research Activities
Figure 2. ORD's waste research ranking flow chart (EPA 1997c)
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Appendix A - Glossary
ATSDR = Agency for Toxic Substances and Disease Registry
C & EN = Chemical and Engineering News
CDF = Confined Disposal Facility
CEM = Continuous Emission Monitor
CENR = Committee on Environment and Natural Resources
DNAPL = Dense Non-Aqueous Phase Liquid
NIEHS = National Institute of Environmental Health Sciences
NORM = Naturally Occurring Radioactive Material
NRMRL = National Risk Management Research Laboratory
NSF = National Science Foundation
ORD = Office of Research and Development
PM = Particulate Matter
SITE = Superfund Innovative Technology Evaluation
WTI = Waste Technology Institute
A- 1
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Appendix B - EPA Documents Provided for Review
U.S. EPA. 1996. Promoting innovative approaches to environmental protection. A Summary of
Recommendations from the National Advisory Council for Environmental Policies and
Technology. EPA/100/R-96/003. U.S. Environmental Protection Agency, Washington, DC
U.S. EPA. 1997a. Waste research strategy. A Briefing Book for the Science Advisory Board
Review. U.S. Environmental Protection Agency, Washington, DC
U.S. EPA. 1997b. Science to Achieve Results (STAR). Program Description Outline. Office of
Research and Development, U.S. Environmental Protection Agency, Washington, DC
U.S. EPA. 1997c. Waste Research Strategy. External Review Draft. Office of Research and
Development, U.S. Environmental Protection Agency, Washington, DC
U.S. EPA. 1997d. Update to ORD's strategic plan. EPA/600/R-97/015. Office of Research and
Development, U.S. Environmental Protection Agency, Washington, DC
B- 1
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REFERENCES
U.S. EPA. 1986. Municipal solid waste landfill survey. Draft. Office of Solid Waste, U.S.
Environmental Protection Agency, Washington, DC
U.S. EPA. 1992. Characterization of municipal solid waste in the United States: 1992 update.
EPA/530/S-92/019. Office of Solid Waste and Emergency Response, U.S. Environmental
Protection Agency, Washington, DC.
NSTC. 1995. A national R&D strategy for toxic substances and hazardous and solid waste.
Toxic Substances and Hazardous and Solid Waste Subcommittee, Committee on Environmental
and Natural Resources, National Science and Technology Council, Washington, DC.
C&EN. 1997. Endocrine disruption may be occurring in U.S. fish. Chemical and Engineering
News, May 12, pp. 28.
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