**From:** John Petura \[jpetura@aem-inc.com\]

**Sent:** Friday, August 29, 2003 1:53 PM

**To:** Holland, Michael J.

**Subject:** Subcommittee -Research Business Models review - research in
remedation and waste

management

Mr. Holland,

The OSTP subcommittee effort to \"improve the performance and management
of federally sponsored scientific and engineering research\" review has
just come to my attention through the 8/26 issue of Hazardous
Waste/Superfund Week. p. 334. The article asks for feedback on (A)
accountability; (B) inconsistencies of policies and practices among
federal agencies; (C) inconsistencies of policies and practices among
universities; (D) state and institutional requirements; (E) regulatory
requirements; (F) research support; (G) multidisciplinary/collaborative
research; (H) research infrastructure; (I) information technology; and
(J) technology transfer optimization.

Before continuing, you need to know that I have no vested interest nor
potential for financial gain in the subject initiative because my firm,
Applied Environmental Management, Inc., has done none in the past, nor
expects to do any work for the federal government in the foreseeable
future. My interest is in **[raising the bar]{.underline}** so that the
American taxpayer gets a better bargain for \$\$ and efforts expended in
the name of **[scientific and engineering research]{.underline}** in the
fields of **[remediation and waste management]{.underline}**, in which I
have invested my career (see below for thumbnail).

I applaud the objectives of this effort, but have one major criticism of
the above feedback categories from the perspective of improving the
quality and cost-effectiveness of the funds expended and efforts exerted
in the name of engineering research. I offer this perspective as a
practicing professional engineer who routinely reviews project work
scopes, data quality, draft study summaries, technical manuscripts, and
completed remediation reports, both at the research phase and after full
scale implementation.

My criticism is this. In far too many cases \[chapter and verse can be
cited on numerous recent or current cases {without naming names}\], the
quality of the work performed fails to meet expectations, is excessive
in cost, or covers ground that has already been trod because the
**[qualifications and experience]{.underline}** of the persons leading
the effort are **[deficient]{.underline}** with regard to their
comprehension of the study design, the findings of the study, or the
\"big picture\" applicability of the proposed remediation technology.
Two subsets of this observation are \"scientific defensibility\" and
\"engineering feasibility\". The former of these is generally discussed
in the lay media as \"good science\". The latter rarely gets any press
at all, because the definition and practice of engineering are not
understood by the lay media.

For any review program of the Business Model to be complete, it needs to
have a component that addresses the qualifications and experience of the
basic or applied researchers who request grant funding for the proposed
studies, including a review component that asks such questions as \"Has
this technology or a variation on a theme been studied before?\", \"Has
a clear set of objectives been set to determine whether the technology
performs successfully, not in a test tube or column study, but in real
site settings?\", and \"Will the unit cost \[\$/cubic yard or \$/ton or
\$/acre\] for application be determined based on consideration of all
applicable capital and operating costs over the life of a project?\"
This last item relates to the term **[feasibility]{.underline}**, as
defined in the National Contingency Plan, which is supposed to be the
oversight guideline for Superfund site remediation assessments.

As an example of my concern, I have been approached occasionally by the
National Academy of Sciences to review research proposals on topics for
which I have extensive knowledge and practical experience. Several of
these were grant requests for over \$400,000, which were seriously
flawed or deficient, and I was compelled to recommend against their
implementation. Unfortunately, I am aware of other grants of like and
large magnitude that have been provided to universities by state and
federal agencies that continued to completion to develop and endorse
proposed technologies that resulted in technology transfer reports that
overstate the capabilities of the technologies and substantially
understate the cost for its full scale application. This is not an
infrequent occurrence, yet those in charge of such programs as the USEPA
SITE program, as an example, do not have the expertise to recognize this
continuing problem.  Suffice it to say that there are dozens of
published Technology Transfer reports on innovative remedial
technologies in the archives of USEPA and elsewhere that have never been
implemented in full scale because the technology is not performance or
cost-effective when taken to the field for full scale application. The
time frame of my observation spans from the late 1970s to the present,
so the issue of my concern has been around for a long time, but it is
rarely considered a significant criterion by reviewers in the research
grant selection process, not because of their intentions, but because
they themselves lack the expertise to assess the value of a technology
research proposal.

To not prolong my expression of concern, if you are not the person to
whom to address this policy issue, or if there is no flexibility to
include this major issue within the framework of the Business Model
review. please advise me by return email, and I shall cease my
involvement in this matter. If you would like further input on this
topic, I can be contacted by phone or email as indicated below. I would
appreciate a response from you under either circumstance.

As you do not \"know me from Adam\", I am graduate chemical engineer
(B.S. 1968) and environmental engineer (M.S. 1973) and a practicing
professional environmental engineer of 35 years, registered professional
engineer (PE) in 9 states, engineering consulting firm founder (1988)
and CEO, a Diplomate Environmental Engineer (DEE) in Hazardous Waste
Management certified by the American Academy of Environmental Engineers
(AAEE), and a Qualified Environmental Professional (QEP) certified by
the Institute of Professional Environmental Practice (IPEP). My firm's
forté is site remediation investigation and characterization, technology
and scenario alternatives evaluation, and remedial construction
oversight. I have authored and co-authored numerous peer-reviewed
publications and continue to serve as a peer-reviewed for journals such
as *Environmental Science and Technology,* and have testified as an
expert witness on subjects relating to hazardous waste management
issues. I am a past-president of the IPEP
([www.ipep.org](http://www.ipep.org/)) Board of Trustees and have been
on the Board for 7 years, and am the current president of the Council
for Engineering and Scientific Specialty Boards
([www.cesb.org](http://www.cesb.org/)), which is a national accrediting
body for certification boards in engineering and related scientific
disciplines. CESB members include the American Board of Certified
Industrial Hygiene (CIH certification), the Board of Certified Safety
Professionals (BCSP), the Institute of Certified Hazardous Materials
Management (IHMM), American Board of Health Physics (ABHP), Board of
Environmental, Health & Safety Auditor Certifications (BEAC), and
others.

For more detail on my background, you may visit
[www.aem-inc.com](http://www.aem/).

Respectfully submitted,

John C . Petura, P.E., DEE, QEP\
President\
Council of Engineering and Scientific Specialties Boards\
[www.cesb.org](http://www.cesb.org/)

President\
Applied Environmental Management, Inc.\
16 Chester County Commons\
Malvern, PA 19355\
610-251-0450\
610-251-0711 fx\
<jpetura@aem-inc.com>