EPA
                           United States
                           Environmental
                           Protection
                           Agency
                    Office of
                    Solid Waste and
                    Emergency Response
Publication 9345.0-051
September 1991
ECO   Update
Office of Emergency and Remedial Response
Hazardous Site Evaluation Division (OS-230)
                                                          Intermittent Bulletin
                                                         Volume 1, Number 1
The Role of BTAGs  in Ecological Assessment
Most EPA Regions have established groups of scientists to
advise and assist site  managers  with ecological studies
produced in conjunction with Remedial Investigations and
Feasibility  Studies (RI/FSs) and Removal Actions at
Superfund sites.  In general, these groups are known as
Biological  Technical  Assistance Groups  of  BTAGs,
although some Regions use different names. This Bulletin
summarizes the  BTAG  structure and function in the
Superfund process. Its purpose is to help site managers
understand how BTAGs can assist with the collection and
evaluation of site information and ensure that ecological
effects are properly considered.
Why BTAGs?

   The  Comprehensive  Environmental   Restoration,
Compensation,  and  Liability Act (CERCLA),  and  the
National Oil and Hazardous Materials Contingency Plan
(NCP) mandate that remedial actions at hazardous waste
sites protect both human health and the environment.  In
December  1988,  the  Directors  of EPA's Office  of
Emergency and Remedial Response (OERR) and Office of
Waste  Programs   Enforcement  (OWPE)  issued  a
memorandum directing Regional  Offices  to  perform
"thorough and  consistent" ecological assessments at all
Superfund sites. The memorandum also encouraged  the
Regions to  establish BTAGs,  and EPA  Headquarters
policy continues to support the BTAG process as a means
of ensuring quality ecological assessments.

   Every site presents a unique combination of biological,
hydrological, geological,  and chemical characteristics.
Site managers are responsible for overseeing a wide range
of activities and cannot be expected to have expertise in all
the necessary scientific areas. BTAGs serve a  valuable
function in providing the necessary advice and review of
ecological information.
                                 The Superfund Environmental  Evaluation Manual,1
                              issued in 1989, was intended specifically to be used in
                              conjunction with a consultative framework  such as that
                              provided by BTAGs.   It was designed to  provide an
                              overview of  the  scientific  and regulatory basis  for
                              conducting  ecological  assessments,  and to direct  site
                              managers  to  Regional  specialists  (i.e.,  BTAGs)  for
                              assistance in planning, designing, and conducting specific
                              studies.

                              The BTAG Coordinator

                                 The BTAG  Coordinator is  a  person  within EPA
                              Regional staff that maintains the logistics of the BTAG.  In
                              some Regions, this responsibility is shared by more than
                              one individual.

                                 Coordinators  maintain regular contact  with BTAG
                              members, provide necessary  documentation to members
                              prior to upcoming reviews, and work directly with site
                                          IN THIS BULLETIN
                              Why BTAGs?	1
                              The BTAG Coordinator  	2
                              Who Is on the BTAG	2
                              What Does the BTAG Do?	2
                              What the BTAG Will Not Do	4
                              How to Work with the  BTAG	4
                                 1 U.S. Environmental Protection Agency, Risk Assessment Guidance
                              for  Superfund,  Volume  II:  Environmental  Evaluation Manual
                              (EPA/540/1-89/001), 1989.
   ECO Update is a Bulletin series on ecological risk assessment of Superfund sites. These Bulletins serve as supplements to Risk Assessment Guidance for
Superfund, Volume II: Environmental Evaluation Manual (EPA/540-1-89/001). The information presented is intended as guidance to EPA and other government
employees. It does not constitute rulemaking by the Agency, and may not be relied on to create a substantive or procedural right enforceable by any other person. The
Government may take action that is at variance with these Bulletins

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managers.  BTAG Coordinators also  maintain frequent
communication with their Regional counterparts to share
techniques and ideas.

   In  some  instances,  Coordinators  screen  sites  to
determine the need and/or extent of BTAG involvement.
Sites  requiring no  ecological assessment will  not be
brought before the group, thereby saving review time by
focusing the membership  on those sites  requiring their
attention.

Who Is on the BTAG?

   BTAGs represent a variety of disciplines, including
wildlife biology, fisheries, soil science, aquatic toxicology,
ecology, geology,  hydrology,   risk  assessment,  and
wetlands science.  The specific composition of each BTAG
varies from Region to Region.  The core of the  BTAG
membership usually includes the BTAG Coordinator, plus
staff from the Regional Environmental Services Division
who specialize in  environmental monitoring, surveillance,
and assessment.

   Several   BTAGs   typically   include  the  National
Environmental Policy Act (NEPA) coordinator, a member
of the OERR's Environmental Response Team or  Toxics
Integration  Branch,  and  biologists  from other EPA
Program Offices such as Wetlands, Water, and Air. Other
Federal agencies frequently represented on BTAGs include
the National Oceanic and Atmospheric Administration, the
U.S. Department of the Interior, the U.S. Fish and Wildlife
Service, the U.S. Geological Survey, and the USDA Forest
Service.  Some BTAGs may include representatives from
State agencies.

   Because of their scientific expertise, representatives of
Natural Resource  Trustee agencies typically are included
on the BTAG.  These individuals are serving in a technical
advisory capacity and  BTAG  consultation  does  not
constitute Trustee notification as required by CERCLA.
Site managers must still notify all authorities who may be
Trustees, in accordance with the law.

  Who Is on the BTAG and What do they
                        do?

Possible Members:
   •   EPA-HWD/ESD,   Wetlands,   Water,   NEPA
       Coordinator

   •   U.S. Fish and Wildlife Service

   •   National Oceanic and Atmospheric Administration

   •   State Agencies

   •   Others

Responsibilities:
   Advise RPM on all aspects of ecological assessment

   •   Define scope
   •   Review Work Plan

   •   Review Draft RI and FS

   •   Help select alternatives

   •   Review RD/RA Plans

   •   Provide Expert Testimony

What Does the BTAG Do?

   Figure 1 summarizes the role of the BTAG in relation
to the site manager and contractor. The BTAG functions
primarily in an advisory  and review capacity,  although
individual BTAG members, or the agency they represent,
may provide additional services to support the ecological
activities.

   Most BTAGs meet monthly, usually for a period of one
to two days.  Meeting agendas vary from month to month,
depending upon the  number of sites to review, individual
site status, and time of year (e.g., field season). Generally,
10 to 20 people participate in BTAG meetings.

   In some Regions, the BTAG operates within the formal
framework of a charter statement of purpose.  Some of the
advantages noted by members of formal  BTAGs include
increased  efficiency  of  communication,   an  easily
accessible record of meeting events, and the assignment of
specific roles and responsibilities.  In most cases, however,
BTAG  meetings    remain  informal  or   semi-formal,
depending on Regional operating policy.

   The BTAG serves an advisory role; it  functions  to
assist site  managers  with the collection and evaluation of
information  needed to   assess   ecological  effects  at
Superfund sites.   By performing this advisory function,
BTAGs help to ensure that CERCLA mandates  are met
with regard to protection of the environment.

   The BTAG permits a peer review of ecological studies,
reaching  consensus  on recommendations made to site
managers.  Without consultation  of these experts  as  a
group, solicitation of input would be prohibitively  time-
consuming, and the quality of  ecological  assessments
might not meet CERCLA mandates.

   BTAGs serve  several  essential  functions to  ensure
adequate  consideration of ecological  issues at Superfund
sites. These include:

   •   Initial site review,

   •   Assistance in developing a work scope,

   •   Review   of  contractor   qualifications   and
       performance,

   •   Review of interim and final products,

   •   Evaluation of remedial alternatives, and

   •   Advice  on remedial decisions, remedial design,
       and remedial actions.
September 1991 • Vol. 1, No. 1
                                        ECO Update

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Initial Site Review
   BTAGs can facilitate the early stages of the remedial
process by screening initial site data from such sources as
the Preliminary  Assessment and  Site Investigation to
determine   the  nature  and  extent  of  an  ecological
assessment. BTAG screening of initial site data can help
streamline the remedial process by ensuring that ecological
investigations are pertinent to remedial objectives.  For
example,  based   on  a   review  of  environmental
concentrations of site contaminants in various media, the
BTAG will only  recommend relevant exposure pathways
for further study.

Assistance in Developing a Work Scope
   An important  role for the BTAG membership involves
assisting the  site manager with scoping the ecological
assessment effort.  BTAG involvement in the preparation,
review, and approval of work plans ensures that ecological
work  is focused, performed in a timely  manner,  and
technically correct. Specifically, BTAGs can recommend
study  objectives,  field and laboratory protocols, QA/QC
requirements,  and other elements of a work plan. Because
of their direct experience, the BTAG members  may also
help identify qualified investigators to perform ecological
assessment.
   The BTAG also can assist in the initial identification of
ecological  Applicable  or  Relevant and   Appropriate
Requirements (ARARs).

Review of Contractor Qualifications and
Performance
   BTAGs can assist the site manager by reviewing and
commenting on contractor qualifications and performance.

                Who Does What?
                Figure 1
                        DIRECTS
             Product  quality  depends  not  only  on  the  company
             performing or overseeing the activity but on the experience
             of the personnel within that company responsible for the
             product.   BTAG involvement can help ensure adequate
             contractor performance beginning early in the process. For
             example, an inadequately prepared work plan may indicate
             that the contractor does not have the necessary expertise
             available   to   carry   out  the  requisite   ecological
             investigations.    If  contractor expertise is lacking,  the
             BTAG may be able to identify resources to carry out the
             needed work.    BTAG  consultation  also  can facilitate
             communication  between  the   site  manager  and  the
             contractor.

             Review of  Interim and Final  Products

                Site managers can use  the BTAG  to review and
             evaluate interim products that include ecological studies.
             Based on the  data in such  a product, the BTAG may
             recommend modifications to the original work scope.  This
             kind of "mid-course correction" can save  a project time
             and money.

                The BTAG can make recommendations for additional
             data following the initial review.  If the initial data are
             incomplete,  the BTAG can recommend  the  types  of
             biological data (e.g., field studies, toxicity tests) needed to
             characterize the ecological risks posed by the site.  For
             example, the BTAG may recommend collection of more
             data on  site chemistry, habitat identification,  or  other
             information that will allow them to determine the need for,
             and extent of, biological data.

                The BTAG should review the draft and final ecological
             assessment to  ensure that this portion of  the Remedial
             Investigation has been completed in an acceptable manner.
             Because   ecological  assessment has  no  standardized
APPROVES
ADVISES
                                           ECOLOGICAL STUDY*
                                               CONDUCTS
                                                   and
                                               PREPARES
                 REVIEWS
                   EPA CONTRACTOR
                'Ecological Study-Includes ecological assessment as part of the baseline risk assessment, ecological studies such as
                toxicity test and field studies, evaluation of remedial alternatives, ecological portions of RODS, and ecological plans.
September 1991 • Vol. 1, No. 1
                                                    ECO Update

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methods  for  evaluating  risk,  informed  professional
judgement  is necessary to  determine  if the weight  of
evidence supports a particular set of conclusions. BTAG
endorsement  of the  final  ecological  assessment  will
indicate to  approving authorities that ecological concerns
have been adequately addressed.

Evaluation of Remedial Alternatives

   BTAG  involvement in  the evaluation  of  remedial
alternatives  ensures  the protection  of  environmental
receptors.  The  collective expertise  of the BTAG can be
used  to  assess  the adequacy  of the  ecological-effects
evaluation  for  each  alternative.   BTAG  review  of
alternatives  also  can  ensure  that ecologically related
ARARs are addressed.

Advice on Remedial Decisions, Remedial
Design,  and Remedial Actions

   BTAG involvement continues to be  important during
the remedial design (RD) and remedial action (RA) phases.
The BTAG can evaluate the quality and completeness  of
work plans, and advise on remediation and monitoring
activities. BTAG participation  in this phase ensures that
ROD and CERCLA mandates are met.

   For example, the ROD for a site recently undergoing
RD required creation of a new wetland.  Within the body
of the ROD and  associated  documents were  specific
guidelines as to the wetland design, plant species required,
methods  required to plant vegetation to ensure desired,
methods  required to  plant  vegetation to ensure desired
growth, etc.  However, BTAG  review of the contractor's
work plan  showed  that very few  of  the  necessary
ecological  requirements were  addressed: plant species
were not specified, proper planting methods were missing,
etc. Furthermore, the plan did not include the participation
of a wetland scientist.  The BTAG recommended that the
specific requirements of the ROD be achieved by inclusion
of a qualified wetland scientist to ensure that the remedial
objectives would be achieved.

   In  at least  two  Regions,  the Superfund  Division
Director will not sign a Record  of Decision (ROD) unless
the BTAG has reviewed the  site. In other Regions, RPMs
are expected, but not necessarily required, to obtain BTAG
review before submitting RODs  for approval.

   Finally,  the BTAG can assist with the development  of
plans to monitor ecological  efforts as sites move into the
post-remedial monitoring  stage.   Regular  review  of
monitoring  data by the BTAG will help the RPM continue
to see that ROD  requirements are met.
What the BTAG Will Not Do

   The BTAG functions in an advisory capacity; as such it
does not, as a group, provide  direct  field or laboratory
services.  In specific cases, it may be possible to  make
arrangements (such as inter-agency agreements in the case
of non-EPA  staff)  for  individual BTAG  members to
become  directly involved in conducting portions of the
investigation.

   The BTAG does not normally communicate directly
with responsible parties  or their contractors.  Advice is
provided directly to the site managers.

   The BTAG does not  write work plans and protocols,
nor does it conduct risk assessments.  As an advisory
group, the BTAG functions to assist the site management
process by reviewing and commenting on sampling and
analysis plans, ecological risk assessments, and ecological
implications of remedial decisions. The BTAG focuses
resources on  site-specific requirements by performing a
quality assurance/quality  control function on a continuing
basis.

How to Work with  the BTAG

   Consultation with the BTAG should follow the phased
approach of  site  management.    At  appropriate stages
throughout the RI/FS process, the site manager should use
BTAG assistance and advice to coordinate and  monitor
ecological studies.  This consultation allows for periodic
re-assessment of goals  and objectives,  and ensures  a
focused and high-quality investigation.

   The  first  line   of communication is  the  BTAG
Coordinator, who can convene meetings and help the site
manager select appropriate data for BTAG review When
the BTAG  initially considers  a  site,  the site  manager
should provide a brief oral presentation of the site history.
Before the meeting, members should be provided copies of
relevant documents and reports.  Without exception, the
quality of BTAG help is directly  related to their timely
receipt of site data.
This Bulletin has described in general terms  how the
BTAG can ensure that ecological concerns are properly
addressed in the Superfund process.   To be certain that
CERCLA  mandates   regarding   protection   of  the
environment are met, site managers should consult their
Regional BTAG Coordinator at the earliest possible stage
of the site assessment.
September 1991 • Vol. 1, No. 1
                                        ECO Update

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