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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