*» EPA
U.S. Environmental
Protection Agency
Washington, DC
EPA-SAB-EEC-90-022
Report of the Risk Reduction
Subcommittee of the Environmental
Engineering Committee
Review of the ORD Risk
Reduction Core Research Strategy
A SCIENCE ADVISORY BOARD REPORT
September 1990
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
EPA-SAB-EEC-90-022
©FFIC6 OF
THC ADMINISTRATOR
September 6, 1990
Honorable William K. Reilly
Administrator
U.S. Environmental Protection Agency
401 M Street, S,W*
Washington, D.C. 20460
Dear Mr. Reilly?
The Science Advisory Board (SAB) has completed its review of
the Office of Research and Development's (ORD) Risk Seduction Core
Research Strategy. The review was based on selected materials
provided to us in March of 1990 and from briefing materials and
discussions with staff in a review meeting conducted on April 11-
12, 1990 by the Risk Reduction Subcommittee (RRS) of the
Environmental Engineering Committee (EEC). Our review was one of
three SAB reviews which took place in April. The other two reviews
involved examination of the Ecology Core Research and the Health
Core Research.
The Subcommittee (IRS) was charged to review the core research
program strategy for risk reduction and was requested to examine
the conceptual strategy, appropriateness, rationale, and need for
each proposed major area and sub-elements. The Subcommittee also
was asked to review the strategy, to identify missing or
inappropriately listed areas, and to comment on the clarity of the
proposed core research plans, as well as the completeness and
credibility of their justification.
The Subcommittee is very pleased with the speed of response
to the SAB's prior recommendation for a core research program and
with the level of care, detail and planning that has gone into
current documents pertaining to the proposed risk reduction core
research strategy. The ORD has selected many appropriate topics
on which to focus in a core research risk reduction program. The
following major findings and recommendations are made with a view
toward improving this excellent beginning to the core research
program.
The Agency must institute more effective mechanisms for
recruiting and sustaining talented researchers oriented toward the
-------
solution of long-term environmental problems. This will require
the development and maintenance of a sufficient human resources
pool, both within the Agency and in the complementary public and
private sectors. This entails supporting environmental education
in the universities and creating a research environment within EPA
that attracts innovative new research staff, as well as retains
talented senior personnel. The absence of attention to the
education and training of professionals weakens the viability of
the whole core research agenda.
With regard to pollution prevention, the ORD summary in the
core research reflects incorporation of most of the SAB's prior
recommendations with one important exception, namely research on
criteria and methods for measuring progress in achieving pollution
prevention objectives. Also, the Agency should take the leadership
role to coordinate the related research efforts of other Federal
agencies.
The emerging and future issues topic areas are well chosen,
in that they represent long-term problems with far-reaching
consequences, and together offer broad coverage of air, water and
land problems. The Subcommittee emphasized, however, that
attending to already recognized environmental problems should not
be allowed to distract from the equally important task of antici-
pating future issues. In fact, in the SAB's Future Risk Report
(SAB-EC-88-040), the SAB criticized the Agency's past research
posture for its exclusive devotion to the "definition, assessment,
and control of existing problems."
The Subcoraittee noted, in the course of their review, that two
of the high risk areas identified by the SAB Relative Risk
Reduction strategy Committee were not addressed by the core
research program. The areas were habitat alteration and worker
exposure to chemicals. The Subcommittee also urges the Agency to
pay due attention to core research on contaminant transport and
fate processes.
One void in the core research area is containment, While
continued research in combustion processes is certainly warranted,
the areas of biodegradation and land disposal, including
containment are equally important. Land disposal options are a
central need for the nation for municipal and industrial wastes,
and will obviously remain a very important and needed waste
management option, despite the fact that the nation is moving
toward preventing waste generation and encouraging recycling and.
treatment of wastes. The core research program for land disposal
should not wait for five years.
With regard to information and communications, attention
should be given to collaborative efforts between the social
scientists and environmental scientists. This link is essential
2
-------
I
-------
for timely anticipation of future risks, as well as for effective
information dissemination.
Clearly, "core" and "short term, routine or programmatic"
research need better distinction, so that the integrity of the core
initiative can be preserved. The Agency's process of assigning
priorities, at least in the past, has seemed to overemphasize
short-term marketability which jeopardized the viability of
balanced, long-term non-programmatic research.
It appears that OMB, the Congress and the Agency all need to
be better educated and informed as to the need for core research
and how it will better help us to achieve environmental protection
goals in the long-range view of things. In fact, the implemen-
tation strategy should stress the Agency's need to develop a
culture that recognizes the values and benefits of sustained long-
term basic research.
We appreciate the opportunity to provide advice to the Office
of Research and Development with regard to their core research
proposals for risk reduction. We are pleased to have had the
opportunity to be of service to the Agency, and look forward to
your response to this report.
Sincerely,
Raymond C. Loehj?-f--CEa irraan
Executive Committee
Science Advisory Board
Richard A. Conway, ©hairman
Environmental Engineering committee
Science Advisory Board
Paul V, Roberts, Chairman
Risk Reduction Subcommittee
Science Advisory Board
3
-------
NOTICE
This report has been written as a part of the activities of the
Science Advisory Board, a public advisory group providing
extramural scientific information and advice to the Administrator
and other officials of the Environmental Protection Agency. The
Board is structured to provide a balanced, expert assessment of
scientific matters related to problems facing the Agency. This
report has not been reviewed for approval by the Agency; hence, the
comments of this report do not necessarily represent the views and
policies of the Environmental Protection Agency or of other Federal
agencies. Any mention of trade names or commercial products does
not constitute endorsement or recommendation for use.
-------
ABSTRACT
The Risk Reduction Subcommittee (RRS) of the Environmental
Engineering Committee (EEC) of the EPA Science advisory Board (SAB)
has prepared a report on the Agency's proposed Risk Reduction Core
Research Strategy. The Subcommittee examined issues within the
core research proposal for risk reduction and answered the issues
posed by the EPA's Office of Research and Development (ORD)
relating to clarity of conceptual strategy, appropriateness of
major areas for research, the appropriateness and completeness of
research proposed within each of the sub-elements, and the
rationale and need for each sub-element.
The Subcommittee examined five major topical areas related to
the core research program for risk reduction; pollution
prevention, pollution control, emerging and future issues,
information and communication, and the implementation strategy.
The Subcommittee's findings and recommendations for long-term
sustained risk reduction core research address the need to develop
a culture that recognizes the values and benefits of sustained
long-term core research as contrasted to the short-term
marketability of programmatic research. The Subcommittee stresses
the need to institute more effective mechanisms for recruiting and
sustaining talented researchers oriented toward long-term
environmental problems and for the maintenance of a sufficient
human resources pool at all skill levels, both with the Agency and
in the complementary public and private sectors* The Subcommittee
also urges ORD to 1) develop criteria on methods for measuring
progress in the area of pollution prevention initiatives, 2)
recognize land disposal for municipal and industrial wastes as a
disposal option of continuing importance, and 3) incorporate a
substantial element of contaminant transport and fate research into
the core research plan.
KEY words: Core Research, Risk Reduction, Pollution Prevention,
Pollution Control, Public Information and Communication
ii
-------
RISK REDUCTION SUBCOMMITTEE
ENVIRONMENTAL ENGINEERING COMMITTEE
Of the
SCIENCE ADVISORY BOARD
Chairman
Dr. Paul V. Roberts
Professor of Environmental Engineering
Stanford University
Stanford, California
Dr. Joan Berkowitz
President
Farkas Berkowitz & Company
Washington, D-C,
Mr- Richard A, Conway
Senior Corporate Fellow
Union Carbide Corporation
South Charleston, West Virginia
Dr. Ben B. Ewing
Professor of Environmental Engineering
University of Utah
Salt Lake City, Utah
Dr. Wayne Kaehel
Senior Water Quality Engineer
Pilko & Associates, Inc.
Houston, Texas
Dr. Joseph T* Ling
vice President (Retired)
3M Company
St. Paul, Minnesota
Dr. Raymond C. Loehr
H.M. Alharthy Centennial Chair
in Civil Engineering
University of Texas
Austin, Texas
Dr. Charles R. O'Melia
Professor of Environmental Engineering
Department of Geography and
Environmental Engineering
The John Hopkins University
Baltimore, Maryland
iii
-------
Dr. Frederick G. Pohland
Weidlein Chair of Environmental Engineering
University of Pittsburgh
Pittsburgh, Pennsylvania
Dr. Paul Slovic
Decision Research
Eugene, Oregon
Dr. Mitchell J, Small
Department of Civil Engineering
Carnegie-Mellon University
Pittsburgh, Pennsylvania
Designated Federal Official
Dr. K. Jack Kooyoomj ian
Staff Secretary
Ms. Marey Jolly
Director. Science Advisory Board
Dr. Donald G. Barnes
Science Advisory Board (A1Q1)
U.S. Environmental Protection Agency
401 M Street S.W.
Washington, D.C. 20460
iv
-------
TABLE OF CONTENTS
1. 0 EXECUTIVE SUMMARY 1
2 , 0 INTRODUCTION AND BACKGROUND. 5
3,0 RISK REDUCTION CORE RESEARCH
STRATEGY AREAS ADDRESSED IN REVIEW 6
3.1 Overall Comments on the Core Research Program..6
3.2 Pollution Prevention .6
3.2.1 Clarification of Research Objectives....?
3.2.2 Modifications to Program Elements 8
3.2.3 Additions and Refinements to the
Research Plan 10
3.3 Pollution Control n
3.4 Emerging and Future Issues. 13
3.4.1 General Comments on Emerging Issues 13
3.4.2 General Comments on Future Issues 15
3.5 Information and Communication 16
3 . 6 Implementation Strategy. 18
APPENDIX A - REQUEST FOR SAB REVIEW. 20
APPENDIX B - GLOSSARY OF TERMS AND ACRONYMS 2 3
APPENDIX C - RESOURCE MATERIAL AND REFERENCES CITED
C-l Background Articles, Briefings and
Materials Provided to the SAB by ORD.....24
C-2 Reports Cited............................ 25
v
-------
1.0 EXECUTIVE Sy^HAPY
This report presents the EPA Science Advisory Board's (SAB)
review of the Office of Research and Development's (ORD) proposed
risk reduction core research strategy. This review is based upon
the working draft Risk Reduction Core Research Report, published
on March 12, 1990 and information obtained in briefings and
presentations by the ORD staff to the Risk Reduction Subcommittee
(RRS) at a meeting on April 11-12, 1990.
The following highlights of the findings and recommendations
for the Agency's risk reduction core research are made with the
view toward improving this excellent beginning to the core research
program:
1) ORD should distinguish more clearly between long-term,
sustained "Core" research aimed at anticipatory future
challenges and short-term programmatic research
required to deal with immediate environmental problems,
so that the integrity of the core initiative can be
preserved. The Agency needs to develop a culture that
recognizes and supports the long term contributions of
sustained, anticipatory research,
2) More attention must be paid to developing and sustaining
a sufficient human resources pool, not only within the
Agency, but also in the complementary public and private
sectors. The lack of emphasis on the education and
training of professionals weakens the viability of the
whole agenda.
3) With regard to pollution prevention, the ORD summary in
the core research reflects incorporation of most of the
SAB's recommendations (See Appendix c-2, reference #12}
with one important exceptions research is needed on
criteria and methods for measuring progress in achieving
pollution prevention objectives. It would be valuable to
develop "criteria" for socially and environmentally
preferable products. This would encourage and guide the
development of such products in the private sector.
Further, the Agency should take the leadership role to
coordinate the related research efforts of other Federal
agencies. In our review, we also observed that the plan
for core research in pollution control clearly reflects
far greater Agency experience than that proposed for
pollution prevention. We caution the Agency not to treat
the pollution prevention paradigm simply as a new slogan,
while falling back to the more familiar pollution control
initiatives.
1
-------
4) Continued and innovative research is warranted in the
areas of combustion, biodegradation and land disposal,
including those features such as containment and control
systems. Land disposal, and particularly landfilling,
will remain a very important and requisite waste manage-
ment option for wastes of both municipal and industrial
origin, despite the recent emphasis on source reduction
and recycle. Funding for the existing land disposal
research program should be increased significantly, and
the core research element on that topic should not be
delayed for five years.
5) The emerging and future issues topic areas are well
chosen, in that they represent long-term problems with
far-reaching consequences, and together offer broad
coverage of air, water and land problems. The
Subcommittee emphasized, however, that attending to
already recognized environmental problems should not be
allowed to distract from the equally important task of
anticipating future issues. In fact, in the SAB's Future
Risk Report (SAB-EC-88-040), the SAB criticized the
Agency's past research posture for its exclusive devotion
to the "definition, assessment, and control of existing
problems." Additional findings and recommendations are
as follows;
a) Current Agency strategy for Municipal Solid Waste
(MSW) (i.e., source reduction, recycle, reuse,
incineration and land-filling residual ash) is
reflected in the proposed program. However, much
of the proposed program should be covered in the
pollution prevention and pollution control area,
rather than under the emerging issues,
b) Other aspects of municipal solid waste management
should be included, such as 1) anaerobic fermentation
or chemical processing for alcohol or gasoline
recovery, and 2) system performance (particulary for
landfills) as well as (3) risk reduction effectiveness
and cost effectiveness studies,
c) The global climate core research area as described is
an innovative and appropriate niche for contributions
by EPA to a much broader Federal research effort on
global climate change,
d) The water supply core research area appears to have
properly identified the significant unresolved
issues requiring attention,
2
-------
e) Alternative fuels research should be subsumed under
the pollution prevention category,
f) The oil spills research should address fresh water
and river systems, as well as the marine environment
and should be expanded to encompass chemical spills,
g) The non-point source research appears to involve
considerable risk assessment, rather than direct
risk reduction, and
h) The indoor air quality research section is well
developed, with proper balance between risk
assessment and risk reduction,
6) The proposed program for anticipating future risks is
weak, in that it relies almost entirely on environmental
monitoring and data analysis. Moreover, the proposed
core research program for environmental monitoring and
data analysis neglects the need to improve knowledge of
the phenomena that control contaminant transport and fate.
Detailed findings and recommendations are as follows:
a) without basic research on contaminant behavior in the
environment, environmental monitoring and data
analysis will remain a crude tool, regardless of the
quality of data and the kinds of statistical analyses
applied,* transport and fate research is a requisite
for early anticipation of emerging and future issues.
Although this type of research logically belongs in
the realm of ecological research, it is apparently
completely neglected in the core research program
proposed for that area, as well as in the risk
reduction core program, ord should redress
this oversight by building on transport and fate
research,
b) To better anticipate future risks ORD should
also explore innovative means of identifying future
problems and their prospective solutions by 1)
analyzing social/economic/technological trends, and
2) using expert scientific vision on a continual
basis, and
7) The development of methods to control and mitigate
habitat alteration and worker exposure should be
considered as part of the research program for risk
reduction, in conjunction with other agencies
currently responsible for addressing these issues.
3
-------
8) The information and communications chapter raises many
broad issues which require greater public understanding
and participation; new core research initiatives in this
domain are welcomed. However, the planned initial fund-
ing level is far too low. Also, the chapter could be
strengthened with examples of what might be achieved
through the research.
Attention should be given to collaborative efforts between
social and environmental scientists. This link is
essential for understanding human response to environ-
mental risks, and for effective information dissemination
concerning environmental problems.
9) The implementation strategy should stress the Agency's
need to develop a culture that recognizes the value and
benefits of sustained long-term basic research. The
Agency's process of assigning priorities, at least in the
past, has seemed to have overemphasized short-term
marketability to the detriment of a balanced, long-term
non-programmatic research program. Additional findings
and recommendations relative to the implementation
strategy are as follows:
a) The implementation strategy focuses on budgetary
priorities and staging, without making explicit
proposals. The apparent emphasis on near-term
payback, although understandable as a means of
gaining support, is at odds with the spirit of the
SAB's previous advice,
b) The Agency must institute more effective mechanisms
for recruiting and sustaining talented researchers
oriented toward long-term environmental problems.
This entails supporting environmental education in
the universities and creating a research environment
within EPA that attracts innovative new research as
well as retains talented senior personnel~ This
approach would encourage a proactive attitude toward
anticipating future problems, as well as provide
continuity in the research program, and
c) We recommend that the ORD review the combined
implementation plan from the standpoint of balance and
comprehensiveness, including the human resources and
institutional aspects, as well as the interfaces
among risk reduction, environmental effects, and
health effects.
4
-------
2.0 INTRODUCTION AND BACKaKOtlND
In March, 1990, the Office of Research and Development (ORD)
provided the Risk Reduction Subcommittee (EES) of the Science
Advisory Board (SAB) with a working draft report of the Risk
Reduction Core Research strategy (See Appendix A and Appendix c-2,
reference #4). This report is a product of earlier SAB suggestions
to establish a core research program for risk reduction (See
Appendix C-2, references 1, 8, 9 & 10),
The SAB was asked to review the Risk Reduction Core Research
Strategy and assigned the review to the Environmental Engineering
Committee (EEC) . The EEC established a Risk Reduction Subcommittee
(RRS), members of which are listed in this report.
The Subcommittee (RRS) was charged to review the core research
program strategy for risk reduction and was requested to examine
the following:
1) Is the conceptual strategy clear?
2) Do we have the appropriate major areas for research? Have
we asked the right questions?
3) Within each of the major topics, do we have the proper sub-
elements? What's missing? What doesn't belong?
4) Is the rationale and need for each sub-element clear and
convincing?
5) Are the types of research proposed within the sub-elements
appropriate?
The Subcommittee met on April 11-12, 1990, in Washington,
D.C., to hear presentations and discuss the report with the ORD
staff. During the meeting, the RRS was provided with briefing
materials and formal presentations on the first day- The second
day of the meeting was dedicated largely to report writing activity
by the RRS, but sufficient time was allowed to convey verbally to
the ORD staff the details of the RRS findings and recommendations,
so that they would be in a position to immediately rewrite their
draft report.
5
-------
3.0 RISK REDUCTION CORE RESEARCH
STRATEGY AREAS ADDRESSED IN REVIEW
3.1 Overall Comments on the Core Research Program
These comments relate to the material in the working draft of
the EPA-ORD Risk Reduction Core Research Strategy dated March 12,
1990.
In 1988, the SAB issued a report, Future Risk: Research
Strategies for the 1990's, (see references 7, 8, 9 & 10) that
provided advice to 1PA on ways to improve strategic research
planning at EPA. One of the ten major recommendations was that EPA
should plan, implement, and sustain a long-term, core research
program in areas where it has unique responsibilities and
capabilities. The EPA office of Research and Development (ORD) has
responded to this recommendation by developing a core strategy for
EPA that will generate knowledge essential to all areas of
environmental decision-making, as well as for the immediate
regulatory needs of EPA's program offices. This core research
program will strengthen and expand existing efforts and initiate
substantial new efforts in critical areas.
This Risk Reduction Subcommittee is very pleased with the
speed of response to the SAB recommendation for a core research
program and with the level of care, detail, and planning that has
gone into current documents. Continuing careful thought, resolve
for such a program, as well a marshalling of resources will be
necessary to make the program the keystone of long-term EPA success
in protecting human health and the environment. It is imperative
that this initial resolve and action be continued and that adequate
resources be provided for the directions and topics that have been
identified and recommended. If the resolve is diverted or the
resources not provided, ORD will have lost an important opportunity
to provide the long-term leadership and knowledge needed by the
Agency.
3.2 Pollution Prevention
In March 1990, EPA's Office of Research and Development
transmitted its Pollution Prevention Research Plan as a Report to
Congress. The pollution prevention component of the risk reduction
core research strategy is derived from the Report to Congress,
which was previously reviewed in draft by the SAB (See Appendix C-
2, reference #12). Most of the recommendations by the SAB made in
that review have been incorporated into the pollution prevention
core research program. This program is comprehensive, broadly
conceived, and supportive of a shift in focus of the Agency's
environmental protection strategy from end-of-pipe controls to
preventing pollution at the source.
6
-------
The SAB has endorsed pollution prevention as one of the most
important risk reduction initiatives that EPA can take in the next
decade. We consider it appropriate, therefore, to include the
critical elements of pollution prevention research in the overall
risk reduction core research strategy, provided that the central
role of pollution prevention in reducing future risk is not lost.
In its review of the Report to Congress on pollution prevention
research, the SAB cautioned the Agency to steer clear of the normal
tendency to build incrementally on existing (i.e., known and
comfortable) programs in early years. In this review of the
Agency's integrated core pollution prevention and pollution control
research strategy, the Subcommittee cautions against too great an
emphasis on incremental improvements in pollution control, where
the EPA has had years of experience, to the detriment of the bold
new steps needed to support a shift toward a pollution prevention
paradign. The Subcommittee's specific recommendations relate to:
1) Clarification of research objectives,
2) Modifications to program elements, and
3) Additions and refinements to the research plan,
3,2,1* Clarification of Research Objectives
All of the research objectives should be stated so
that a determination can be made as the program progresses of
whether or not they have been met. Such a determination is
virtually impossible for objectives stated in terms of "encourage"
or "stimulate." As examples, how will the Agency determine whether
or not;
1) Its product research has "encouraged" private sector
development of environmentally preferable products?
2) Its process research has "stimulated" cross-industry
application?
3) Its reuse/recycling research has "stimulated" additional
capacity for using recycled materials?
4) Its technology transfer and technical assistance program
has "stimulated" pollution prevention opportunity assess-
ments?
Objectives stated in terms of "establish", "identify", and
"demonstrate", "develop", "conduct", or "quantify" have much
clearer, measurable end points and are greatly to be preferred.
7
-------
3.2.2. Modifications to Program Elements
The following recommendations are offered to clarify
or strengthen the various program elements:
1) The pollution prevention chapter as a whole could be
improved by incorporation of a few specific examples
within each program element.
2) Product and Process Research:
a) Product Research is proposed on methods for
conducting assessments, identifying opportunities» and
developing/using "preferable" products. The research
would be enhanced by also including applications -
perhaps a series of ORD reports on the life cycle of
specific products or product classes, the impacts on
the environment at each stage, and pollution
prevention opportunities,
b) It should be recognized that few new products can be
completely harmless to the environment. The plan
should note, therefore, that "environmentally
preferable products" are those that place less burden
on the environment, and research in the area should
reflect this perspective,
c) The Agency could provide a valuable service to
industry and the public by establishing criteria
for identifying environmentally preferable products.
The criteria should include disposal as well as
production and use,
d) The Agency should evaluate its own past experience in
pollution prevention, e.g. assess the efficacy of its
pollution prevention activities in the broad sense,
including product formulation, (such as is undertaken
under the Toxic Substances Control Act (TSCA), and
e) Available information from numerous activities
already in progress in industry should be collected
and utilized in the early part of the program,
including the data bases being compiled under the
auspices of SARA Title III.
3. Socioeconomic and Institutional Research;
a) The research plan should include identification of
both incentives and barriers, including statutory
and regulatory barriers.
8
-------
4. Technology Transfer and Technical Assistance:
a) The information obtained from socioeconomic,
institutional, and anticipatory research should be
dissseminated, as well as that for product, process,
and recycling/reuse research, and
b) It would be more appropriate to call this activity
Information Transfer rather than Technology Transfer.
5. Anticipatory Research:
a) In reviewing pollution prevention, as a stand-alone
research program, the SAB endorsed Anticipatory
Research as an important component. Within the
integrated core research program, anticipatory
research in pollution prevention should be incor-
porated into the overall research effort in Emerging
and Future Issues, and should be the first approach
considered in addressing those issues as they are
identified, and
b) Several of the areas discussed under Emerging and
Future Issues are excellent examples of pollution
prevention research that might be undertaken.
Specifically:
1) Municipal Solid Waste; strategic planning
source reduction, recycling,
2) Global Climate Change: development of CFC
substitutes, identification of barriers, and
incentives for switching,
3) Stratospheric Ozone Depletion: the example cited
of a cooperative effort in recycling mobile air-
conditioning refrigerant is a fine example of a
technically-oriented pollution prevention
project,
4) Nonpoint Source Pollutants: controlling the
amount, timing, arid manner of agricultural
chemical application to within the limits of the
assimilative capacity of the environment, and
5) VOCs and HAFs: substitutes, alternative feed-
stocks and processes, recovery/reclamation/reuse.
9
-------
3.2.3. Additions and Refinements to the Research Plan
The following materials separately reviewed by the SAB
would be valuable additions to the report:
a) The charts on risk reduction research budget and
initiated priorities among pollution prevention
research program elements, similar to what was
presented to the Subcommittee in the April 11-12,
1990 review meeting,
b) The "Next Steps" Addendum to the pollution prevention
chapter, with "Results Expected", specified in terms
which would allow objective evaluation of whether or
not they were achieved,
c) One area of research recommended by the SAB in its
review of the Report to Congress on pollution
prevention is not reflected in the current document.
This is research on criteria and methods for measuring
progress in pollution prevention. It is important
because:
1) Most of the published work in the field has been
anecdotal* While many of the available case
examples demonstrate spectacular successes in
reducing waste generation at the source, with
relatively short pay-back periods, the impact on
total waste generation has been too small to be
measurable,
2) Many of the State Capacity Assurance Plans assume
very significant reductions in the quantities of
hazardous waste seeking off-site treatment and
disposal. Yet no state provides substantive data
on the degree of reduction possible or how it is
to be achieved, and
3) No tested and validated methodology exists to even
begin to assemble information that could
eventually lead to the establishment of measurable
objectives.
d) The Pollution Prevention Research Branch Current
Projects Summary, dated February 1990, proposes a
project on "Methodology for Measuring Pollution
Prevention". The project is well conceived and
appropriately funded at $300 thousand over a two year
period. A principal investigator had not been
selected at the time of publication of the report,
10
-------
e) An additional role recommended for EPA is coordination
of related pollution prevention research efforts by
other Federal agencies such as DOD, DOE, USDA, Dot,
etc. Such coordination is needed to eliminate
duplication and achieve better cooperative efforts,
and
f) Finally, the Subcommittee recommends additional
funding for anticipatory research in FY91. The
results for anticipatory and socioeconomic and
institutional research could serve as the "guiding
light" to point the direction of needed industrial and
social behavior changes. It may take a long time to
gain valuable information from anticipatory research
and the current funding is inadequate.
3,3 Pollution control
The pollution control research program reflects the Agency's
extensive experience in pollution control research endeavors, and
thus comprises a mature, low-risk proposal. The subcommittee
generally supports the core research agenda proposed in this area,
but urges the Agency to define priorities and identify a unifying
theme for core research. specific findings and recommendations
relating to pollution control strategy are as follows?
1) The overall core research agenda is very ambitious, with
quantum changes in funding levels however prioritized.
If such support materialises, "core" research and short-
term regulation-oriented research need better distinction
so that the integrity of the core initiative can be
preserved. There is a lack of a unifying theme for the
core research program. The Subcommittee had some
difficulty in distinguishing the elements of the core
initiative from the regulation-oriented research. The
terms "keystone" and "cornerstone" research are not
clearly defined and consistently used in the report. The
unifying theme is needed to keep the core research in
balance and prevent it from becoming lost by intermingling
with the regulation-oriented research.
2) There appears not to be adequate attention given to the
development and maintenance of a sufficient human
resources pool, both within the Agency and in the
complementary public and private sectors. Beyond the
attempts to suggest technology transfer (information
transfer) and public education programs, the absence of
attention on the education of professionals weakens the
viability of the whole research agenda. If innovative,
competent personnel are lacking, the additional funds
devoted to future core research will likely be ill-spent.
11
-------
3) The Agency's perception of needs and priorities does not
necessarily reflect attitudes outside the Agency. The
chapter tended to treat everything as if there is a need
to do core research. Several of the processes being
proposed for core research have been an integral part of
past research initiatives. There is the outside
perception that the Agency may not have performed any
fundamental or core research in these areas. EPA does not
give itself adequate credit for the success of their
earlier efforts-
4) The pollution control chapter tends to view processes, or
controls, as separate entities without sufficient emphasis
on the "integrated systems" approach. The chapter was
very specific in discussing certain technologies, while
other technologies were essentially neglected,
5) The Subcommittee recommends several changes in priorities.
Although continued research is warranted in the combustion
area, the areas of residuals management, biodegradation,
and land disposal/containment are of equal or greater
importance. Many treatment residues will ultimately be
landfilled. Hence, this area of land disposal research
needs immediate attention. The environment as an
appropriate and necessary ultimate receptor of residuals
should be recognized? environmental assimilative capacity
needs to be integrated into the overall technological
perspective. It is recommended that work in disposal of
residuals be elevated in priority, with greater emphasis
on the overall performance of land disposal systems and
the integrity of their structural elements.
6) Containment technologies use various forms of barriers,
such as liners, to separate harmful materials from the
environment. The core research should address the
question of how effective these barriers are in protecting
the environment from landfilled waste. The strategy
document also notes that "an information gap still exists
on aspects of the performance, reliability and cost of
many of the control technologies" now being used to reduce
risk. These are appropriate topics on which to focus a
core research program.
7) Research to address the performance of system components
is discussed, but the overall performance of land disposal
systems is of equal or greater importance. Better
knowledge about the performance of existing systems is
important for both technical guidance and regulatory
decisions. The performance-related research that is
needed includes procedures for determining facility
performance and use of these procedures for determination
of the performance of both older and modern MSW landfills,
12
-------
including those employing emerging innovative
technologies.
8) The technical and regulatory changes that have been
implemented have been made to reduce the risk to human
health and the environment. However, the extent to which
the actual risks have been reduced has not been
documented.
9) Another important aspect of the core research program
should be to evaluate the costs of existing and planned
land disposal systems. The capital and operating costs
of land disposal facilities are increasing due largely to
mandated technical and regulatory requirements. Cost
evaluation can be used with the risk evaluation
information discussed above to better identify the costs
and benefits of additional controls that may be needed to
better protect human health and the environment.
10) Emphasis on "non-point" sources should also include
agricultural areas (pp. 3-17) , as well as the control of
fugitive emissions of hazardous air pollutants.
3.4 Emerging and Future Issues
To improve understanding of this section , ORD should strive
for a clearer distinction between 1) issues that have only recently
emerged as pressing problems, or are anticipated in the future, and
2) widely recognized, but neglected, issues.
3-4.1 General Comments on Emerging Issues
Eleven emerging issues are specified as needing greater
attention, namely: municipal solid waste; global climate?
stratospheric ozone? medical wastes? indoor air; non-point sources;
volatile organics; water supply? alternative fuels; environmental
infrastructure; and oil spills, with some exceptions, these topic
areas are well chosen, in that they represent long-term problems
with far-reaching consequences and together offer broad coverage
of air, water, and land problems.
This section outlines in part new research programs to be
founded in support of regulatory development in areas where the
needs for regulation of existing problems appear imminent. This
emphasis is understandable in the context of SFA's regulatory
mission, yet diverges from the spirit of the SAB's advice to the
Agency in "Future Risk..." (See Appendix C-2, reference #7,
recommendation #4 in SAB-EC-88-040 which criticizes the Agency's
past research posture for its exclusive devotion to the
"definition, assessment, and control of existing problems"). It
is certainly proper for EPA to assign high priority to these
emerging concerns; however, the attention given to these already
13
-------
perceived environmental problems should not be allowed to distract
from the equally important task of anticipating future issues
(i.e., those not yet perceived) in a more timely fashion than
heretofore. There is an implicit danger that the emerging issues
will crowd out the future issues in research budget allocation
decisions, by virtue of being more imminent, and hence more subject
to pressure for regulation.
The Subcommittee finds that several of the core research
emerging issues are especially well chosen, and believes them
worthy of priority support,
1) The global climate core research area is an inno-
vative and appropriate niche for contributions by
EPA to a much broader Federal research effort on
global climate change,
2) The water treatment core research area appears to have
properly identified significant unresolved issues
requiring attention, and
3) The indoor air quality research section is well
developed, with proper balance between risk
assessment and risk reduction.
However, there are several emerging issues included that seem
to be out of place in this portion of the core research program.
Medical wastes do not seem to possess a strong need for continuing
research, and what research is needed can be conducted in relation
to combustion studies. Volatile organic compounds (VOCs) and
hazardous air pollutants (HAPs) , may be able to be covered
adequately under pollution prevention and other pollution control
studies, but the data from the SARA Title III Surveys should be
evaluated systematically to assess VOC's/HAPs as an emerging issue.
4) Current Agency strategy for MSW (i.e., source
reduction, recycle, reuse, incineration and land-
filling residual ash) is reflected in the proposed
program. However, much of the proposed program
should be covered in the pollution prevention
categories and in the fundamental research on com-
bustion technology in the pollution control area,
rather than under the emerging issues, and
5) Likewise, alternative fuels research should be subsumed
under the pollution prevention category.
Several of the proposed emerging issues are appropriate as
core research elements, but need to be reformulated,
6) The proposed oil spill research is important, but
should address fresh water and river systems, as well
14
-------
as the marine environment, and should be expanded to
encompass chemical spills, and
7) The non-point source research appears to involve
considerable risk assessment, rather than direct
risk reduction, and should be reoriented toward
source reduction.
two missing programs of high risk to the environment, health,
and/or welfare are habitat alteration and perhaps worker exposure
to chemicals. The draft report of the SAB Relative Risk Reduction
Subcommittee (See Appendix C-2, reference #14) sustantiates the
need for research aimed at lessening these risks.
3.4.2 General Comments on Future Issues
The section on future issues is broad and general, as is
inevitable considering the subject matter, which deals with
anticipating environmental problems that are as yet unforeseen.
The section deals with analyzing environmental trends, acquiring
comprehensive data bases for ambient concentrations, and assessing
new risk reduction technologies. Of these categories, the first
two capture the spirit of anticipating future environmental
problems (See Appendix C-2, reference # 7.Future Risk.
Recommendation #4) , but the last category seems out of place in
this section. That is,'the examples listed under Future Technology
and Products (accelerated application of computer and
telecommunications technology; optimization of the production,
distribution, and use of hydrocarbon resources; integrated biomass
and high-technology energy cycles? and application of solar
photovoltaics) seem to belong under pollution prevention or
pollution control. To be consistent with the priorities issues,
this section should address assessing new technology and products
to identify future problems.
The sections on environmental monitoring and data analysis
recognize the need for improved methods for data acquisition and
statistical analysis, but ignore the need for improved
understanding of the processes governing contaminant behavior in
the relevant environmental compartments. Without adequate
knowledge of the phenomena that control contaminant transport and
fate, environmental monitoring 'and data analysis will remain a
crude tool, regardless of the quantity of data and the kinds of
statistical analysis applied. The effective interpretation of
environmental quality data requires a profound knowledge of
underlying processes and mechanisms, to provide properly formulated
hypotheses to be used in the design of environmental monitoring
programs and the interpretation of their results. The early
identification of atmospheric ozone depletion constitutes a
successful recent example of this synergism.
15
-------
Accordingly, the Agency must recognize the paramount
importance of transport and fate research in foreseeing future
problems, and build it into their program for anticipating future
risks. More data and better statistical methodologies will not
suffice without better process understanding. Ideally, such
research studies should be included in the Ecological Core Research
strategy, such that those concerned with interpreting ambient data
will become more adept in understanding the role of transport and
fate phenomena. Unfortunately, the present version of the
Ecological Core Research Strategy appears not to recognize the
crucial role of transport and fate research in the early
identification of future problems.
The ORD report also neglects the essential task of
synthesizing expert opinion to help identify future issues in an
integrated way in this chapter. Ways to do this can be categorized
as follows; 1) Analyze ambient/ecological/health data for evidence
of nascent problems, 2) Analyze societal/economic/ technological
trends and develop scenarios that would indicate future problems
and possible solutions, and 3} Use expert scientific vision, based
on process understanding on a continuing basis to identify new
potential problems and means to address them. Only the first
approach was addressed. A more complete coverage of future-issue
identification seems appropriate, Such a program is described in
Appendix A of jEa_tj4^g...BlsH (See Appendix C-2, reference #8, pg. 11-
22) and again called for in the SAB's Research Strategy Advisory
Committee's, January '89 review of the ORD's Core Research Area
(See Appendix c-2, reference #10, pg 11). This was agreed to by
Lee Thomas (then Administrator) in a Memorandum dated 26 September
1988. This effort should be combined with the anticipatory part
of The Pollution Prevention Core Program. As recommended in the
documents cited above, a small staff dedicated primarily to this
endeavor should be established,* they would draw upon internal and
external experts, rather than themselves, to address the imposing
task of keeping track of developments of all kinds (technological,
socioeconomic, physiographic) throughout the world that portend
environmental consequences. To facilitate the gathering of
external expertise, twenty (20) or so professional societies could
be asked to participate in a program in which they would nominate
persons to participate in expert workshops in which future problems
would be identified. Perhaps four workshops could be held each
year, so that each organization could be involved every 5 years.
Also EPA could recruit key personnel from investigator-initiated
grants, especially in the health and ecological areas, who could
be asked to participate.
3.5 Information and Communication
The understanding of human response to environmental risks is
critical to the management of environmental issues where individual
decisions affect the levels of pollutants introduced to the
16
-------
environment and the subsequent exposure. Examples include consumer
product choices which affect the quantities of municipal solid
wastes and household hazardous products introduced to the
environment, and indoor air pollution and household water quality
problems, where homeowner decisions to sample and remediate limit
the potential impact of risk reduction efforts.
Proper information dissemination is essential to appropriately
focus limited Agency resources and avoid redundant efforts. The
subcommittee is concerned that, as currently written, the chapter
is weak in comparison to the other chapters and thus does not
adequately convey the importance of the issue. This can be
rectified by the addition of examples of what might be achieved
through the research. Such examples would make the benefits more
tangible and lessen the probability that this area would be the
first to suffer budget cuts in this predominantly hard science
research program.
The Subcommittee is gratified to see the Agency committing
resources to this research area. However, the initial funding
level appears to be so inadequate that it is unlikely that anything
of significance can be accomplished. The initial funding level
should be increased and the long range funding plan should call for
consistent growth. The limited funds can be stretched by means of
leveraged research efforts with other organizations.
Financial resources are not the only resources in limited
supply. Personnel resources in the environmental area are
extremely limited and are expected to become more limited. Without
adequately trained personnel, core research cannot be successfully
conducted. To provide the trained personnel resources, the Agency
should consider resurrecting the traineeship program. This should
be augmented with an effort to promote, environmental education and
awareness at all levels. There is no need for the Agency to
prescribe environmental curriculum. The diversity of curricula
that currently exists in the University system is critical to
providing the many diverse viewpoints that are needed to move us
toward a cleaner environment.
With regard to new initiatives, the Subcommittee strongly
supports the Agency's dedication to the commercialization of new
environmental technologies and products. Commercialization is
essential to elevating the quality of available environmental
treatment technologies. An economic study is needed to determine
how the private sector might "internalize the externalities" in
their economic decision-making, such that public-sector benefits
are reflected in the private sector decisions. Such a study would
provide useful perspectives. These efforts, as all efforts in the
information and communication area, could benefit from teamwork
between social and environmental scientists. The link is essential
for understanding human response to risks and for effective
information dissemination concerning environmental problems. To
17
-------
better understand changes in environmental risk perception which
occur over time, there is a need for an improved data base on
consumer and behavioral issues related to risk decisions. The need
is for the equivalent of a social sciences "EMAP".
Finally, on page 5-2 of Reference #4, in Appendix C-2,the
media bullet is too harsh and should be softened to; "Extensive
media reporting of environmental problems,"
3,6 Implementation Strategy
The implementation strategy focuses on budgetary priorities
and staging, without making explicit proposals. The emphasis on
near-term payback, although understandable as a means of gaining
support, is nonetheless at odds with the spirit of the SAB's
previous advice. The Agency's process of assigning priorities
seems to have overemphasized short-term marketability to the
detriment of the viability of a balanced, long-term nonprogrammatic
research program. The Agency needs to develop a culture that
recognizes the long-term contributions of sustained, basic
research, apart from short-term payoffs. This is the essence of
the SAB's message in "Future Risk...." The Subcommittee believes
that ORD is unduly defeatist in abandoning the quest to establish
a constituency for sustained, long-term research at the outset of
the core research planning process. ORD and the Agency must
undertake to convince Congress and OMB of the value of and need for
core research.
The implementation strategy combines existing ("core-like")
and incremental core research. This confuses the issue and
complicates review of the implementation plan. Further, it raises
the spectre that the core research program may be perceived as
competing with existing program-oriented research. ORD should also
describe the interrelationship between the proposed core research
program and the investigator-initiated projects in exploratory
research, avoid unnecessary overlap, and assure communication
between those two research channels.
The implementation strategy neglects the non-budgetary aspects
of initiating and sustaining the core research program. The Agency
must recognize that the success of the core research program
depends critically on human resources, as well as on coordination
with other Agencies and cooperation with other institutions,
including the private sector and the academic community. Such
interactions should be incorporated into the implementation
strategy. The Agency must institute more effective mechanisms for
recruiting and sustaining talented researchers oriented toward
long-term problems in the environmental field, both within EPA and
in other segments of the environmental research community. This
entails supporting environmental education in the universities and
creating a research environment within EPA that attracts creative
new researchers and retains talented senior personnel, provides
13
-------
continuity, and encourages a pro-active attitude toward
anticipating future problems.
Apart from these general considerations, the Subcommittee is
not able to review the implementation strategy in depth owing to
the lack of comprehensive, detailed documentation. We recommend
that the SAB Research Strategies Advisory Committee review ORD's
combined implementation plan from the standpoint of balance
(connection to investigator-initiated grant program and balance
between in-house and extramural research), procedures for future
planning, external input, proactive assessment, and peer review and
comprehensiveness (e.g., the apparent omission of research on
contaminant transport and fate), including the human resources and
institutional aspects.
19
-------
APPENDIX A - REQUEST FOR SAB REVIEW
20
-------
J %
iss/
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON. D.C, 20460
QFPiCE OP
RESEARCH AMD DEVELOPMENT
MEMORANDUM
SUBJECT: SAB Review of Core Risk Reduction Program ^
FROM: Peter W, Preuss, Director /fsfec U) AlMlM
Office of Technology Transfer and Regulatory Support
TO: SAB Environmental Engineering Committee
Enclosed for your review is Risk Reduction Core Research Strategy, the Office
of Research and Development's (ORD's) plan for core research in risk reduction.
Also included for background information is the original core research plan,
Protecting the Environment: A Research Strategy for the 1990s,
In order to provide you with more background for your review, I want to
explain what the document is that you will be reviewing, how your review can
most assist us, and what will happen next with these research plans.
First, let me explain how this document developed and what it represents. In
April, 1989, ORD published its core research plan, Protecting the Environment: A
Research Strategy far the 1990s. This plan was reviewed by the SAB's Research
Strategies Advisory Committee, and outlined 4 areas of emphasis for EPA's
fundamental research program: (1) Ecological Risk Assessment; <2) Health Risk
Assessment; (3) Risk Reduction; and (4) Research Grants, The document we are
asking you to review is a further expansion and refinement of the risk reduction
portion of the overall core program.
Since April, 1989, we have spent our time better defining the three technical
areas. Out of that process have come three documents, one of which, is the risk
reduction document provided to you today. These three documents will be
reviewed by three standing SAB committees. Each document attempts to define the
universe of research we think should be included in a core research program. These
are not research proposals; thus, we have not provided resource estimates.
However, each document does try to give an idea of the size of certain program
areas relative to others and the timing of the research. These documents are what
we call "working drafts'*; they are not final documents.
Second, let me discuss how your review can most assist us as we continue to
-------
plan qui core research program. lit general, we would appreciate your reaction to
this "working draft", and your suggestions on the directions we're going with our
research programs. Some questions you may want to think about as you're
reviewing the document include:
• Is the conceptual strategy clear?
• Do we have the appropriate major areas for research? Have we asked the
right questions?
• Within each of the major topics, do we have the proper sub-elements?
What's missing? What doesn't belong?
• Is the rationale and need for each sub-element clear and convincing?
• Are the types of research proposed within the sub-elements appropriate?
It would be most helpful to us if the review was an interactive one. If you
have questions prior to the meeting, please feel free to contact Darwin Wright of
ORD's Office of Environmental Engineering and Technology Demonstration
(OEETD) at (202) 382-4073. Fred Lindsey, Director of OEETD, Darwin, and other ORD
staff will be available during the meeting on April 11 and 12. We would appreciate
your immediate feedback, either verbal or written, as we need to have this
document, as well as the other documents, complete for the beginning of the budget
process in early summer.
Third, I want to let you know what will happen following SAB review. We
will make revisions to the documents in response to your comments. At the same
time, we will be developing an executive summary that will tie the three parts of
the core program together and that will set some general priorities among the three
areas. The executive summary and the three documents will be sent for review to
the SAB's Research Strategies Advisory Committee, sometime in May, and to the
EPA Research Strategy Council thereafter. Once we get directions from the SAB and
others, we will look at the timing of the research; for example, what research will be
conducted first, what will be second, etc. From this, we will decide what research
should be initiated in FY 92 and in the succeeding years to fulfill these plans.
Finally, I want to thank you for your help with ORD's research program,
especially the core program, and for taking on this review. I understand how busy
you are and appreciate you rearranging your schedule for this review. If we can
provide you with any additional material, please let me know.
-------
4
APPENDIX B - GLOSSARY OF TERMS AND ACRONYMS
EDAT BEST DEMONSTRATED AVAILABLE TECHNOLOGY
CFC'S CHLORO FLUGRO-CARBONS
ch4 METHANE
CO, CARBON DIOXIDE
DQD DEPARTMENT OF DEFENSE
DOE DEPARTMENT OF ENERGY
DOT DEPARTMENT OF TRANSPORTATION
EEC ENVIRONMENTAL ENGINEERING COMITTEE OF THE SAB
EMAP ENVIRONMENTAL MONITORING ASSESSMENT PROGRAM
EPA ENVIRONMENTAL PROTECTION AGENCY
FY FISCAL YEAR
HAP HAZARDOUS AIR POLLUTANTS
MSW MUNICIPAL SOLID WASTE
NOAA NATIONAL OCEANIC AND ATMOSPHERIC ADMINISTRATION
N,0 NITROUS OXIDE
OMB OFFICE OF MANAGEMENT AND BUDGET
ORD OFFICE OF RESEARCH AND DEVELOPMENT
OTTRS OFFICE OF TECHNOLOGY TRANSFER AND REGULATORY
SUPPORT OF THE ORD OF THE EPA
RREL RISK REDUCTION ENGINEERING LABORATORY OF THE EPA
RRS RISK REDUCTION SUBCOMMITTEE OF THE EEC
(ALSO REFERRED TO AS THE SUBCOMMITTEE)
RSAC RESEARCH STRATEGIES ADVISORY COMMITTEE OF THE SAB
SAB SCIENCE ADVISORY BOARD OF THE U.S. ENVIRONMENTAL
PROTECTION AGENCY
SARA SUPERFUND AMENDMENTS AND REAUTHORIZATION ACT
TSCA TOXIC SUBSTANCES CONTROL ACT
US UNITED STATES
USCG UNITED STATES COAST GUARD
USDA U.S. DEPARTMENT OF AGRICULTURE
U-V ULTRA VIOLET RADIATION
VOC VOLATILE ORGANIC CONTAMINANTS
23
-------
APPENDIX C - RESOURCE MATERIAL AND REFERENCES CITED -
C-l BACKGROUND ARTICLES, BRIEFINGS AND MATERIALS
PROVIDED TO THE SCIENCE ADVISORY BOARD BY THE
OFFICE OF RESEARCH AND DEVELOPMENT OF THE
ENVIRONMENTAL PROTECTION AGENCY
1) American Institute of Pollution Prevention, Us EPA
Brochure, 1989.
2) Background Articles, Briefings and Materials Provided
to the SAB by ORD
3) Bridges, James S., Waste Minimization Assessments at
Selected DOD Facilities, RJREL, US EPA, Cincinnati, Ohio
4) Brown, Lisa M. and Johnny Springer, RREL, US EPA,
Cincinnati, Ohio and Matthew Bower, APS Materials, Inc,
Dayton, Ohio, Chemical Substitution for 1,1,1-
Trichloroethane and Methanol In Manufacturing Operations.
5) Chapter 5t Information and Communication (Briefing),
6} Comments by Darwin R. Wright for SAB Review of ORD's
Risk Reduction Core Research Report - Emerging and
Future Issues, April 11, 1990,
7) Curran, Mary Ann and Kenneth R. Stone, Evaluation of EPA
Waste Minimization Assessment, RREL USEPA, Cincinnati,
Ohio.
8) Howell, S. Garry, A Ten Year Review of Plastics Recycling
RREL, US EPA, Cincinnati, Ohio.
9) ORD FY91 2% Set Aside Projects.
10) Pollution Control (Briefing by Gregory Ondich).
11) Pollution Control — Containment Processor (Briefing
by Gregory Ondich).
12) Pollution Prevention, Research Plan Report to Congress
(Briefing)
13) Relative Risk Reduction Strategy Committee (Draft Report)
(1990)
14) Summary of Projects Funded Through the 2% Set-Aside,
November 14, 1989.
15) US EPA, ORD, ORD FY90 Multimedia Properties by Subject.
24
-------
J
APPENDIX G-2 - REPORTS CITED
1) US EPA, Office of Research and Development, Draft
Pollution Prevention Research Plan Report to Congress.
February 15, 1989.
2) US EPA, Office of Research and Development, Pollution
Prevention Research Plan Report to congress, Feb. 1990.
3) US EPA, Office of Research and Development, Protecting
the Environment: A Research Strategy for the 1990's.
Draft, April 1989, (Also referred to as The Whale Book.
4) US EPA, Office of Research and Development,
Reduction core Research Report, working Draft,
March 12, 1990.
5) US EPA, Office of Research and Development,
Reduction Core Research Strategy Addendum {"Next
Steps" Priority Research Items for Each Research
Area), Working Draft, March 12, 1990,
6) US EPA Office of Research and Development, Risk
Reduction Core Research Strategy Directory, Working
Draft, March 12, 1990.
7) US EPA, Science Advisory Board, Future Risk: Research
Strategies for the 1990*s. SAB-EC-88-040, Sept. 1988.
8) US EPA, Science Advisory Board, Appendix A: Strategies
for Sources, Transport and Fate Research. SAB-EC-88-040A,
September 1988.
9) US EPA, Science Advisory Board, Appendix E: Strategies
for Risk Reduction Research, SAB-EC-88-040E, Sept. 1988,
10) US EPA, Science Advisory Board, Report of the Research
Strategies Advisory Committee, Review of ORD's CORE
Research Areas. EPA-SAB-RSAC-89-013, January 1989,
11) US EPA, Science Advisory Board, Report of the Municipal
Waste Combustion Ash Subcommittee, Review of the ORD
W^ste Combustion ftsfr Solidification/
Stabilization Research Program, EPA-SAB-EEC-90-010,
March 1990.
12) US EPA, Science Advisory Board, Report of the Pollution
Prevention Subcommittee, Review of the ORD Draft
Pollution Prevention Research Plan: Report to Congress,
1PA-SAB-EEC-89-037, September 1989.
25
-------
13) US EPA, Science Advisory Board, Report of the
Environmental Engineering Committee, Resolution on
Use of Mathematical Models by EPA for Regulatory
Assessment and Decision-Making, EPA-SAB-EEC-89-012,
January 1989.
14) US EPA, Science Advisory Board, Relative Risk
Reduction Strategy Committee, Reducing Risk:
Trie Vajug of An Integrated Environmental Policy,
Draft Report, August 12, 1990»
26
------- |