United States
             Environmental Protection
             Office Of Water
EPA 823-R-94-001
August 1994
EPA's Contaminated Sediment
Management Strategy


EPA's Contaminated Sediment Management Strategy
                     U.S. Environmental Protection Agency
                         Washington! D.C.  20460
                             August 1994
                                                     Printed w«h,Soy/Canola Ink on paper that
                                                     contains at loast 50% recycled fiber



                       WASHINGTON, D.C. 20460
                                                         OFFICE OF
Dear Reader:

     Based on your expressed irterest in the Environmental
Protection Agency's (EPA) Contaminated Sediment Management
Strategy, I am sending you a co'py of the document.  The Strategy
describes specific actions that EPA will take to reduce environ-
mental and human health risks associated with contaminated
sediment.  The Strategy does no|t propose new regulations.  EPA is
acting under existing statutory and regulatory authority to
implement policies developed to assess, prevent, and remediate
contaminated sediment.

     The Strategy describes the cross-program policy framework in
which EPA intends to promote consideration and reduction of
ecological and human health risks posed by sediment contamina-
tion.  The goals of the Strategy are:  1) to develop consistent
methodologies for assessing contaminated sediments; 2) to prevent
ongoing contamination of sediments that may cause unacceptable
ecological or human health risk's; 3) to clean-up existing
sediment contamination that causes significant effects on human
health or the environment; and 4) to ensure that sediment
dredging and the disposal of dredged material continue to be
managed in an environmentally sound manner.

      EPA will accept written comments on the Strategy for 60
days after publication of an Executive Summary and a notice of
availability in the Federal Register.  Comments may be mailed or
delivered to: Contaminated Sediment Strategy Clerk, Water Docket
MC-4101, Room L102, Environmental Protection Agency, 401 M
Street, S.W., Washington, D.C.
to submit any references cited
20460.  Commenters are requested
in their comments.  Commenters are
also requested to submit an original and  3 copies  of their
written comments and enclosures.  Commenters who want  receipt  of
their comments acknowledged should  include a self-addressed,
stamped envelope.

     Thank you for your interest in this important effort,  if
you have any questions, please feel free to contact Tudor T.
Davies, Director, Office of Science and Technology, at
(202) 260-5400."

                              Robert Perciasepe
                              Assistant Administrator

      This document was prepared by the U.S.(Environmental Protection Agency's Sediment
Steering Committee and its staff workgroups. The Steering Committee was chaired by the Deputy
Assistant Administrator for Water, Martha G. Prothro.
      The cover art is an adaptation of an illustration from Life in the Chesapeake Bay, a book by
Alice Jane and Robert Lippson, published by Johns Hopkins University Press, 701 West 40th Street,
Baltimore, MD 21211.


                                     Executive Summary
EPA's Contaminated Sediment Management Strat
   - Reinventing Government to Streamline
       Contaminated sediment poses ecological and human health risks in many watersheds
throughout the United States.  In these watersheds, sediment serves as a contaminant reservoir from
which fish and bottom dwelling organisms can accumulate toxic compounds and pass them up the
food chain.  Sediment contaminants can be passed
accumulate to levels that may be toxic to humans.
to larger fish, birds, and mammals until they
 Toxic chemicals in sediment come from discharges
of industrial waste and sewage; stormwater runoffjfrom waste dumps, city streets and farms, and air
pollutants contained in rainwater.  The magnitude of the sediment contamination problem in the
United States is evidenced in more than 1,200 State advisories that have been issued against
consuming fish that have accumulated toxic bioaccumulative sediment contaminants.
        More than ten Federal statutes provide authority to many EPA program offices to address the
problem of contaminated sediment.  This has resulted in fragmented, and in some cases duplicative,
efforts to complete the necessary research, technology development, and pollution control activities
required to effectively manage contaminated sediment.  Often it has been difficult for EPA programs
to agree even upon the fundamental question of whether sediment at a particular site poses ecological
or human health risks. EPA's Contaminated Sediment Management Strategy was developed to
 streamline decision-making within and among the
Agency's program offices by promoting and
 ensuring: the use of consistent sediment assessment practices, consistent consideration of risks posed
 bv contaminated sediment, the use of consistent approaches to management of contaminated sediment
  J                                          I
 risks, and the wise use of scarce resources for research and technology development.
 Goals of the Contaminated Sediment Management Strategy

        EPA's Contaminated Sediment Management Strategy describes actions that the Agency will
 take to accomplish the following four strategic gcals: 1) Prevent further sediment contamination that
 may cause unacceptable ecological or human health risks; 2) When practical, clean up existing
 sediment contamination that adversely affects the Nation's waterbodies or their uses, or that causes

 other significant effects on human health or the environment; 3) Ensure that sediment dredging and
 dredged material disposal continue to be managed in an environmentally sound manner; 4) Develop
 and consistently apply methodologies for analyzing contaminated sediments.

 What the Strategy Does

        The Contaminated Sediment Management Strategy is comprised of six component sections:
 assessment, prevention, remediation, dredged material management, research, and outreach. In each
 section, EPA describes actions that the Agency will take to accomplish the four broad strategic goals.

        In the assessment section of the Strategy EPA proposes that Agency program offices all use
 standard sediment toxicity test methods and chemical-specific sediment quality criteria to determine
 whether sediments are contaminated. Actions that EPA will take to develop a national inventory of
 sites and sources of sediment contamination (the National Sediment Inventory) are described in the
 assessment section of the Strategy.  The National Sediment Inventory will be used by EPA to target
 sites for contaminated sediment assessment, prevention, and remediation.  These assessment actions
 will enable EPA to focus on cleaning up the most contaminated waterbodies, and ensuring that further
 sediment contamination is prevented.

        EPA's plan to stop sediment contaminants from reaching the environment is described in the
 prevention section of the Strategy.  In order to regulate the use of pesticides and toxic substances that
 accumulate in sediment, EPA proposes the use of acute sediment toxicity tests to support registration
 of chemicals under the Federal Insecticide, Fungicide, and Rodenticide Act and the Toxic Substances
 Control Act.  In the  prevention section of the Strategy EPA also proposes: developing effluent
 guidelines for industries that discharge sediment contaminants; using pollution prevention policies to
 reduce or eliminate sediment contamination resulting from noncompliance with permits; the
 development of guidelines for design of new chemicals to reduce bioavailability and partitioning of
 toxic chemicals to  sediment; and implementation of point and nonpoint source controls that will
protect sediment quality.  EPA's prevention actions will stop further contamination of sediment and
reduce ecological and human health risks.

        In the remediation section of the Strateg^ EPA proposes using multiple statutes to require
 contaminated sediment remediation by parties responsible for pollution. These statutes include the
 Comprehensive Emergency Response, Compensation, and Liability Act (CERCLA), the Resource
 Conservation and Recovery Act (RCRA), the Clean Water Act (CWA), the Toxic Substances Control
 Act (TSCA), the Rivers and Harbors Act, and the Oil Pollution Act.  EPA states in the Strategy,
 however, that the Agency will not proceed with a clean-up if a combination of pollution prevention
 and source controls will allow the sediments to recover naturally in an acceptable period of time.
EPA's remediation actions will clean up existing
Nation's waterbodies.
sediment contamination that adversely affects the
        In the dredged material management section of the Strategy, EPA discusses the development
of technical guidance regarding dredged material
testing, dredged material disposal site selection, and
disposal alternatives.  EPA actions described in ttie Strategy will ensure continued disposal of dredged
material in an environmentally sound manner.

         In the research section of the Strategy, EPA proposes a program of investigative research
that is needed to: develop and validate new chemical-specific sediment criteria and other sediment
assessment methods; improve EPA's understanding of the transfer of sediment contaminants through
the food chain; and develop and evaluate a range of technologies for remediating contaminated
sediments. EPA's proposed research program will support improved assessment, prevention, and
remediation of contaminated sediment.

        The outreach section of the Strategy describes actions that EPA will take to demonstrate,
through public involvement, the Agency's commitment to, and accountability for, sediment
management efforts. EPA will produce, and make available to the public, regular status reports on
sediment management activities.

Next Steps Toward Implementation of a Federal Agency Contaminated Sediment Management

        EPA will begin to track activities of the Agency's program offices as they implement the
Contaminated Sediment Management Strategy.  However, EPA envisions that this internal strategy

will also be the keystone of a much larger Federal government strategy for the management of
contaminated sediment. The Water Resources Development Act of 1992 (WRDA 92) establishes a
National Contaminated Sediment Task Force to advise the Federal government on the extent and
severity of sediment contamination; sediment restoration methods and technologies; prevention and
source control measures; and long-term disposal sites for contaminated dredged material.  EPA and
the U.S. Army Corps of Engineers will convene the Task Force and  submit the Agency's Strategy to
the Task Force for use hi developing a Federal agency contaminated  sediment management strategy.
The Task Force can build upon EPA's coordinated research program and the research of the U.S.
Army Corps of Engineers, the U.S. Fish and Wildlife Service, the National Oceanic and Atmospheric
Administration, and other Federal agencies to improve methodologies for measuring ecological and
human health risks from contaminated sediment.
       EPA's National Sediment Inventory is a repository of sediment monitoring data generated by
Federal agencies to identify contaminated sediment sites.  This data base can be used by Federal,
State, and local agencies to focus their pollution prevention and remediation efforts on the worst sites
of sediment contamination.

       EPA's Contaminated Sediment Management Strategy will promote EPA and U.S. Army
Corps of Engineers research to develop technologies for remediation of contaminated sediment under
authority of the CWA, CERCLA and WRDA. In addition, the Strategy will provide guidance for
coordinating EPA Regional and Headquarters roles in the management of dredged material, and set
forth ongoing EPA and Headquarters regulatory development activities related to dredged material

        Guidance provided in the Strategy will facilitate the coordination of dredged material
management  activities among Federal agencies and nongovernmental organizations.  Coordination of
dredged material management activities has been called for in the May 1994 options paper drafted by
the Federal Interagency Working Group on the Dredging Process.  The Working Group was
convened by the Secretary of Transportation in the Fall of 1993. The Group has held a series of
outreach sessions throughout the country to solicit ideas on improving the dredging process. The
Working Group identified important activities needed to improve the dredging process. These
activities include: enhanced research and monitoring to improve dredged material disposal decision

describes a plan for research on interpretation of
making, identification of opportunities to control s ources of sediment contaminants, and effective
education and communication with the public on t le risks and impacts associated with dredged
material disposal.  The Contaminated Sediment Management Strategy addresses all of these issues. It
loaccumulation and chronic toxicity tests and
dredged material disposal site assessment.  It provides a plan for identification and control of sources
of sediment contaminants. It also proposes effect ve ways of interacting with the public.

Listing of Actions Identified in EPA's Contaminated Sediment Management Strategy
       EPA's Contaminated Sediment Management Strategy proposes that Agency program offices
take the following actions.

       All EPA program offices will use standard sediment testing methods to determine whether
sediments are contaminated. The Office of Water will use standard sediment toxicity and
bioaccumulation test methods for monitoring, inte pretation of narrative water quality standards, and
dredged material disposal testing. The Office of Pesticide Programs and the Office of Pollution
Prevention and Toxics will use standard sediment
toxicity tests to assess the toxicity of pesticides and
chemicals when registering or reregistering these chemicals for manufacture and use.  The Office of
Emergency and Remedial Response will use standard sediment toxicity and bioaccumulation test
methods for Superfund Remedial Investigation/Feasibility studies.  The Office of Solid Waste will use
biological sediment toxicity test methods for assessing and monitoring hazardous waste facilities.

        EPA program offices will use sediment qv ality criteria, when they are promulgated, to assess
contaminated sediment sites.  All EPA programs
 mducting sediment monitoring will use the criteria
to interpret sediment chemistry data. Upon promulgation, the criteria may be adopted as State wateir
quality standards and used to set National Pollution Discharge Elimination System (NPDES) permit
limits. The criteria will also be used with other information to make site-specific decisions
concerning corrective action at hazardous waste facilities, and to assess Superfund sites.  EPA has not
yet determined how sediment quality criteria will be used in dredged material testing. In FY95, the
Agency will develop a more detailed Sediment Quality Criteria User's Manual describing how the
Agency's programs will use these criteria.

       The National Sediment Inventory will be used by EPA program offices as an assessment tool.
The inventory will be used to: identify contaminated sediment sites for consideration for remedial
action; target facilities for possible injunctive relief or supplemental enforcement projects; identify
problem pesticides and toxic substances that may require further regulation or be  targeted for
enforcement action; identify impaired waters for National Water Quality Inventory reports or
development of Total Maximum Daily Loads; target watersheds for nonpoint source management
practices; and to help select industries for effluent guidelines development.
       In order to regulate the use of pesticides that may accumulate to toxic levels in sediment, EPA
intends to propose that acute sediment toxicity tests be included in procedures required to support
registration, jreregistration, and special review of pesticides likely to sorb to sediment.  In fiscal year
1995, EPA will propose incorporating acute toxicity bioassays and spiking protocols into the
Agency's pesticide assessment guidelines (40 CFR Part 158).  To prevent other toxic substances from
accumulating in sediment, EPA will also propose incorporating acute sediment toxicity tests and
sediment bioaccumulation tests into routine chemical review processes required under the Toxic
Substances Control Act.  In addition, EPA intends to call for the development of EPA guidelines for
design of new chemicals to reduce bioavailability and partitioning of toxic chemicals to sediment.

       EPA's Office of Enforcement and Compliance Assurance will take action to prevent sediment
contamination by negotiating, in cases of noncompliance with permits, enforceable settlement
agreements to require source recycling and source reduction activities.  The Office of Enforcement
will also monitor the progress of Federal facilities toward the  goal of halving toxic emissions by the
year 1999, and will monitor the reporting of toxic releases to  the public.

       EPA's Office of Water, and other EPA program offices, will work with nongovernmental.
organizations and the States to prevent point and nonpoint source contaminants from accumulating in
sediments. EPA will: 1) promulgate new and revised best available technology effluent guidelines for
industries that discharge sediment contaminants; 2) encourage the States to use biological sediment
test methods to interpret water quality standards, and to adopt sediment quality criteria as water
quality standards; 3) encourage the States to develop Total Maximum Daily Loads for impaired
watersheds specifying point and nonpoint source load reductions necessary to protect sediment quality;

 4) use the National Sediment Inventory to target
                                             active point sources of sediment contaminants for
 permit compliance tracking, 5) ensure that discharges from CERCLA sites and RCRA facilities
 subject to  NPDES permits comply with permit requirements that protect sediment quality; 6) use the
 National Sediment Inventory to target watersheds where technical assistance and grants would
 effectively be used to reduce nonpoint source loads of sediment contaminants.
        The National Sediment Inventory will be
                                        of Soli
                                             used by EPA's Office of Water, Office of
Emergency and Remedial Response, Office of Solid Waste, and Office of Enforcement to help target
Sites for enforcement action requiring contaminated sediment remediation. EPA's standard sediment
toxicity and bioaccumulation tests will be used tc identify sites for remediation, assist in determining
clean-up goals for contaminated sites, and to monitor the effectiveness of remedial actions.

Dredged Material Management
       The U.S. Army Corps of Engineers estimates that a small percentage of the total volume of
sediment dredged for navigational channel maintenance requires special handling due to the presence
of toxics. The National Sediment Inventory will
                                             be used to identify sites where dredged material may
be contaminated.  EPA standard sediment toxicity and bioaccumulation tests are now used in dredged
material testing.
       EPA's Office Of Research and Developm
                                             :nt, through its Environmental Monitoring and
Assessment Program, will continue to collect new chemical and biological data on sediment quality.
These data will be included in the Agency's National Sediment Inventory. EPA's Office of Research
and Development will also develop: new biological methods to assess the ecological and human health
effects of sediment contaminants, chemical-specific sediment quality criteria, methods to conduct
sediment toxicity identification evaluations, dredged material disposal fate and transport models,
sediment wasteload allocation models, and technc logics for remediation of contaminated sediment.
       EPA will undertake a program of outreach
about contaminated sediment risk management.
                                              and technology transfer to educate target audiences
                                             'arget audiences will include: other Federal

agencies, State and Local agencies, the regulated community, the scientific community, environmental
advocacy groups, the news media, and the general public. Technical and nontechnical information
will be provided to these audiences by developing a range of outreach products.  The National
Contaminated Sediment Task Force will monitor implementation of EPA's Contaminated Sediment
Management Strategy and development of a federal Strategy.

                                   OF CONTENTS
Executive Summary
Table of Contents .
Table of Acronyms
1.1    Purpose of the Strategy  . . .
1.2    Definition of Contaminated Sediments
1.3    Background	
       1.3.1 Statement of the Problem
       1.3.2 Extent and Severity of the Problem
1.4    Goals and Principles of the Stra :egy
Coordination of Strategy Implementation
3.1    Interagency Coordination  ..
3.2    Agency Coordination	
3.3    States' Role	
Policy Framework for Strategy
4.1 '   Background	
4.2    Forums  	
4.3    Written Comments   . .
Strategy for Assessing Sediment Contamination
5.1    Consistent Sediment Testing Methods . ,
Why EPA Needs an Agency-Wide Strategy for Managing Contaminated Sediments
2.1    Cross-Program Coordination
2.2    Client Demand	
2.3    Congressional Interest ....
              5.1.1 Agency-wide Use of Consistent Test Methods	
              5.1.2 Establishment of an Agency-wide Sediment Tiered Testing Committee
.  .  i
.   ix
.   1
.   1
.   1
.   3
.   2
.   4
.   6

.  11
.  11
.  12
.  12

.  16
.  16
.  17
.  17

.  18
.  18
.  19
.  21

.  22
.  22
.  22
.  23

              5.1.3 Selection of Sediment Toxicity Tests for Agency-wide Use Within the Tiered
              Testing Framework	 23
              5.1.4 Supplemental Specific Assessment Methods	;	25
       5.2    Sediment Quality Criteria	;	25
       5.3    National Inventory of Sites with Sediment Contamination  	30
              5.3.1 Purpose of the Site Inventory	,30
              5.3.2 Scope of the Site Inventory	30
              5.3.3 EPA Program Office Uses of the Site Inventory	31
              5.3.4 Evaluation of Data Included in the Site Inventory   	;.	35
       5.4    National Inventory of Sources of Sediment Contamination	',	36
              5.4.1 Approach to Developing the Source Inventory  	>	37
              5.4.2 Uses of the Source Inventory .	38
       5.5    Increase hi Sediment Monitoring in Water Quality Monitoring Programs . ;.	42
       5.6    Assessment of Atmospheric Deposition of Sediment Contaminants	43
       5.7    Coordination of Assessment Activities with Other Federal Agencies	44

6.     Strategy for Preventing Sediment Contamination	.	45
       6.1    Office of Pesticide Programs Actions	»	45
              6.1.1 Control of Sediment Contaminants Regulated Under FIFRA	45
              6.1.2 OPP Use of the Site Inventory	,  ..... 45
              6.1.3 Memorandum of Agreement with USGS	46
              6.1.4 Pesticide Incident Reports	:	46
              6.1.5 Development of Technical Guidance Documents for Evaluation of Pesticide
              Risks	47
              6.1.6 Aquatic Effects Dialogue Group Recommendations  	I.	47
       6.2    Office of Pollution Prevention and Toxics Actions	49
       6.3    Office of Enforcement Actions	53

7.     Strategy for Abating and Controlling Sources of Sediment Contamination	\	55
       7.1    Technology-Based Controls for Point Sources	55
       7.2    Water Quality-Based Controls for Point Sources	57
       7.3    Controls for Nonpoint Sources	;	61

       7.4    Coordination with Other Agencies	65
Strategy for Remediation and Enforcement  	.66
       8.1    CERCLA Remediation and Enforcement	69
       8.2    RCRA Remediation and Enforcement	73
       8.3    CWA Remediation and Enforcement  	75
       8.4    TSCA Enforcement		77
       8.5    Rivers and Harbors Act Enforcement	78
       8.6    Oil Pollution Act Enforcement  .   	78
       8.7    Related Legislation	79
       8.8    Coordination with Other Agencies	80

9.     Strategy for Dredged Material Management	82
       9.1    Dredged Material Assessment Un er MPRSA	83
       9.2    Dredged Material Assessment Under CWA	85
       9.3    Dredged Material Management Alternatives Document	86
       9.4    Ocean Disposal Site Management and  Monitoring Guidance     	87
       9.5    Relationship of CERCLA, TSCA, and RCRA  	88
       9.6    Coordination with Other Agencies and States	.  . 90

10.    Research Strategy	92
       10.1   Collection of Chemical and Biological Data on Sediment Quality in the EMAP
              Program	92
       10.2   Development and Validation of Sediment Quality Criteria	93
              10.2.1 Development of Freshwater and Marine Sediment Quality Criteria	93
              10.2.2 Chemical Data for Development of Sediment Quality Criteria	93
              10.2.3 Field Validation Studies for Sediment Quality Criteria	94
       10.3   Contaminated Sediment Assessment Methods	94
              10.3.1 Biogeochemical and Transport  Processes Influencing Metals
              Bioavailability	94
              10.3.2 Exposure Assessment Modeling for Aquatic Disposal of Dredged
              Materials  	95

              10.3.3 Contaminated Sediment Toxicity Identification Evaluation  	'	95
              10.3.4 TMDL/Wasteload Allocation Modeling to Evaluate Contaminated Sediments
              and Source Control Options	 .	96
              10.3.5 Chemical Analytical Methods Development	96
              10.3.6 Development and Validation of Acute and Chronic Test Protocols  	97
              10.3.7 Development and Field Validation of Bioaccumulation Test Methods	97
              10.3.8 Unavailability and Trophic Transfer of Sediment-Associated
              Contaminants	98
              10.3.9 Development of Tissue Residue Thresholds	99
              10.3.10 Routes of Biological Exposure		99
       10.4   Remediation Methods	  100
              10.4.1 Remediation Methods for Contaminated Sediments  	100
              10.4.2 Resiliency  and Natural Recovery of Aquatic Benthic Ecosystems	101
       10.5   Completion of Research and Technology Transfer	101
              10.5.1 ORD  Clients  	,	  101
              10.5.2 Technology Transfer	102

11.    Outreach Strategy	  103
       11.1   Communication Themes  .	  103
       11.2   Interagency Coordination and Alliances with Other Agencies, Industry, and the
              Public	:	  104
       11.3   Target Audiences	.••••!	  105
       11.4   Outreach Activities	  106
              11.4.1 Regulatory Actions and Guidance Documents	106
              11.4.2 Outreach Publications	109
              11.4.3 Advisory Groups, Databases, Clearinghouses, and Other Activities	109
       11.5   Outreach Principles	110

12.    Case Studies	  113
       12.1   Case Studies of Human Health Risks	113
              12.1.1 Quincy Bay  and New Bedford Harbor, Massachusetts	114
              12.1.2 Puget Sound, Washington	116

12.1.3 Los Angeles-Long Beach Harbor, California
12.1.4 Lake Michigan  .....!
12.1.5 New York	
12.1.6 Pago Pago, American Samoa
Case Studies of Ecological Effects/Risks
12.2.1 Elizabeth River, Virginia
12.2.2 Commencement Bay, Washington
12.2.3 Great Lakes	
13.     References


                                TABLE OF ACRONYMS

AEDG	  Aquatic Effects Dialogue Group

ARCS	Assessment and Remediation of Contaminated Sediments

AVS	  Acid Volatile Siulfides

AWPD  	Assessment and Watershed Protection Division

BAT	  Best Available Technology

BCT	 Best Conventional Technology

BIOS	  Bio-STORET; the portion of STORET containing biological data

BLM	  United States Bureau of Land Management

CAA	  Clean Air Act (1970)1

CCMP	Comprehensive Conservation and Management Plan

CDF	  Confined Disposal Facility

CERCLA	Comprehensive Emergency  Response, Compensation,

                                                                 and Liability Act (1980)1

CFR	  Code of Federal Regulations

COE	  United States  Army Corps of Engineers

CWA  	: .  Clean Water Act (1977)1

CZARA	 Coastal Zone Act Reauthorization Amendments of 1990

CZMA	Coastal Zone Management Act (1972)1

DAIS  	  Dredged Analysis Information System

DMATS	  Dredged  Material Tracking System

DOD	United States Department of Defense

DOE	   United States Department of Energy

'Date of original enactment

                                          xiv                               I

DOJ  .

DOT  .


EAB  .

EBR  .


EPA  .

EqP  .
	 United States Department of Justice

	United States Department of Transportation

	Division of Water Enforcement

	Exposure Assessment Branch

	  Exposure Based Review

Environmental Monitoring and Assessment Program

. .  United States Environmental Protection Agency

	  Equilibrium Partitioning
FIFRA	Federal Insecticide, Fungicide, and Rodenticide Act (1972)1



HRS  . .  ,

HWIR .  .

IRIS  . .
ITFM  	Intergovernmental Task Force on Monitoring Water Quality

                                     Concx ntration of contaminant (lethal dose) which will result

                                                     hi mortality of 50% of exposed organisms



'Date of original enactment
           . .  Great Lakes Critical Programs Act

           .  Great Lakes National Program Office

            Great Lakes Water Quality Agreement

           	  Hazard Ranking System

           .   Hazardous Waste Identification Rule

           . .  Integrated Risk Information System
       United States Minerals Management Service

       	  Memorandum of Understanding
MPRSA	Marine Protection, Research, and Sanctuaries Act (1972)1
   	National Water Quality Assessment

   National Corrective Action Prioritization System

NEP	National Estuary Program

NEPA	  National Environmental Policy Act (1969)1

NOAA	National Oceanic and Atmospheric Administration

NPDES	National Pollutant Discharge Elimination System

NPL	National Priorities List

NRC	  National Research Council

NS&T	...-.,..	  National Status and Trends

OCPD	  Oceans and Coastal Protection Division

ODES	Ocean Data Evaluation S5'stem

OECA	Office of Enforcement and Compliance Assurance

OEER	Office of Emergency and Remedial Response

OFA	  Office of Federal Activities

OPP	 Office of Pesticide Programs

OPPE	Office of Policy, Planning and Evaluation

OPPT  	Office of Pollution Prevention ;and Toxics

OPPTS  	  Office of Prevention, Pesticides  and Toxic Substances

ORD	  Office of Research and Development

OST	Office of Science and Technology

OSW	Office of $olid Waste

OW	-.	  Office of Water

OWPE	  Office of Waste Programs Enforcement

OWM	              Office of Wastewater Management

OWOW	  Office of Wetlands, Oceans, and Watersheds

'Date  of original enactment


PAHs  .

ppm  . .


PRP  . .




RFA  .
ROD ........		

SAB	 .  ...-'.	

SARA . . . .	  Sup



STORET . . . .  . ; . . i .  .	

TCLP	.  , . .	



 TVA  . < .  .	


 'Date of original enactment
 	  Polycyclic Aromatic Hydrocarbons

, ,	Polychlorinated Biphenyls

	parts per million

	Publicly Owned Treatment Works

	Potentially Responsible Party

	Quality Assurance/Quality Control

	  Risk Assessment Guidance for Superfund

.   Resource Conservation and Recovery Act (1976)1

	   RCRA Facility Assessment

	  RCRA Facility Investigation

	  Record of Decision

	  Science Advisory Board

rfund Amendments and Reauthorization Act of 1986

	  Soil Conservation Service

....  Superfund Innovative Technology Evaluation

EPA Office of Water's Storage and Retrieval System

  ....  Toxicity Characteristic Leaching Procedure

  	  Toxicity Identification Evaluation

  	 Total Maximum Daily Load

  		  Total Organic Carbon

  	Toxic Substances Control Act (1976)1

  	Tennessee Valley Authority

  	United States Coast Guard






. .  United States Department of Agriculture

United States Food and Drug Administration

	  United States Forest Service

. .  United States Fish and Wildlife Service

	  United States Geological Survey

 Water Resources Development Act of 1992

                                    1. INTRODUCTION
       The purpose of the Environmental Protec tion Agency's (EPA's) Contaminated Sediment

Management Strategy is: to describe EPA's understanding of the extent and severity of sediment

contamination, including uncertainties about the dimension of the problem; to describe the cross-

program policy framework hi which EPA intend!  to promote consideration and reduction of

ecological and human health risks posed by sediment contamination; and to describe actions EPA

believes are needed to bring about consideration and reduction of risks posed by contaminated

       This Strategy is being issued hi support

Agency guidance only.  This document does not

not establish a binding norm and is not finally

decisions in any particular case will be made by

specific facts.
  EPA's regulatory and policy initiatives, and is

 sstablish or affect legal rights or obligations. It does

  irminative of the issues addressed.  Agency

applying the law and regulations on the basis of the
       Contaminated sediments are soils, sand,

accumulate on the bottom of a water body, and contain

adversely affect human health or the environment
  organic matter, or minerals that wash from land and

      in toxic or hazardous materials that may

   (U.S.  EPA, 1993a).  For the purposes of this

Strategy, EPA defines contaminated sediments as those which contain chemical substances at

concentrations that pose a known or suspected threat to aquatic life, wildlife, or human health.


1.3.1  Statement of the Problem

       The contamination of sediments in waterbodies of the United States has emerged in recent

years as an ecological and human health issue of national proportions.  Contaminated sediments can

have an impact on aquatic life by making areas uninhabitable for benthic organisms, and they can

affect fish and wildlife by contributing to the bioaccumulation of contaminants in the food chain.

Documented adverse ecological effects from contaminated sediments include fin rot, increased tunaor

frequency, and reproductive toxicity in fish as well as decreased biodiversity in aquatic ecosystems.

Contaminated sediments can also pose a threat to human health when pollutants in sediments

bioaccumulate in edible fish tissue.  There are numerous examples of cases where fish consumption

advisories or bans have been issued for pollutants such as polychlorinated biphenyls, mercury,

dioxins, and kepone because of the transfer of the pollutants into the food chain (U.S. EPA, no date).

       The presence of contaminated sediments also introduces significant ecological and human

health considerations into the decision of whether and how to dredge and dispose of sediments to

maintain navigational channels.  Where contaminated sediments exist, dredging can result in

resuspension of contaminated material which may then become more available to aquatic organisms.

Special control techniques may be necessary to prevent this.  Contamination can also limit the

disposal options available for dredged sediments.  Disposal of contaminated dredged material requires

locating a secure site, either on land or offshore,

be safely contained.  Sediment contamination can

cost of dredging navigational channels to levels

commercial/private shipping interests.
                                              where large amounts of contaminated material can

                                               also affect commerce, most notably by raising the

                                                 cannot be borne by local sponsors or
       While sediment contamination has been recognized as a serious problem for some time,

limited success has been demonstrated in niitigatir g the problem.  One reason is the general lack of
                                               various pollutants in sediments cause adverse

                                               iblems have been defined primarily on the basis of
national guidelines for determining what levels of

ecological and human health effects.  To date, pn

observed effects oh aquatic life hi the field, such as the presence of pollution-tolerant species or

diseased fish or the absence of certain benthic organisms.  Since 1977, EPA and the U.S. Army

Corps of Engineers, however, have been using a wide range of biological and chemical assessment

techniques in the dredged material program for the evaluation of both water-column and benthic

impacts of potentially contaminated sediment. In some instances EPA Regional or State guidelines,

including sediment standards and regionally appropriate bioassays, have also been used effectively for

problem definition.   ,

       The expense associated with the remediation of contaminated sediments also contributes to the

extent of the problem. Not only are specialized dredging techniques and disposal sites sometimes

needed, but the sediments often must be dewatere 1 or otherwise treated before disposal can occur.

Other complicating factors are the high concentrations of contaminants that sometimes underlie

surface sediments, and the difficulty in identifying a responsible party to pay for the clean-up,

particularly when old sediments or multiple sourc ;s are involved. Frequently, sediment contamination

is the result of historical discharges of pollutants before the National Pollutant Discharge Elimination

System regulatory program was established.

1.3.2  Extent and Severity of the Problem

       In surveys conducted in 1985 and 1987 (U.S. EPA, 1985 and 1988a), the Office of Water

(OW) of EPA first began to document the extent and severity of sediment contamination.  Most of the

information hi the surveys described areas in the Northeast, along the Coast of the Atlantic Ocean and

Gulf of Mexico, and hi the Great Lakes region.  The surveys found that heavy rnetals and metalloids

(e.g., arsenic), polychlorinated biphenyls, pesticides, and polycyclic aromatic hydrocarbons are the

most frequently reported contaminants in sediments. Significant ecological impacts were often
reported at contaminated sediment sites, including impairment of reproductive capacity, and impacts

to the structure and health of benthic and other aquatic communities.  Potential human health impacts

were noted at a number of sites where fish consumption advisories or bans were issued (U.S. EPA,

1988). In 1989, a study by the National Academy of Sciences entitled Contaminated Marine

Sediments - Assessment and Remediation (National Academy of Sciences, 1989), also identified the

potential for far-reaching health and ecological effects from contaminated sediments.       |
       Many potential sources of contaminants to sediments are identified in the reports cited above.

These sources include: municipal sewage treatment plants; combined sewer overflows; stormwater

discharges from municipal and industrial facilities; direct industrial discharges of process waste;

runoff and leachate from hazardous and solid waste sites; agricultural runoff; runoff from rnining

operations; runoff from industrial manufacturing and storage sites; and atmospheric deposition of


        Many of the sediment data used in the E ?A studies were collected prior to regular analysis for

such parameters as grain size, total organic carbon, or acid volatile sulfides.  Such data are needed to

                                              s. Rarely is such information available for historical
determine bioavailability of sediment co
sediment data.  EPA believes that better data on

chemical concentrations in edible fish tissue,  are
                                              sediment quality, as well as direct measurements of

                                              needed. Large quantities of both published and
unpublished data on sediment quality have not been placed in accessible or usable form, and many

locations in the country have not been adequately sampled.  Several recent national and regional
sediment monitoring programs, including EPA's

and the National Oceanic and Atmospheric Agem
                                              Environmental Monitoring and Assessment Program

                                              :y's National Status and Trends Program, are
currently collecting data on physical and chemical characteristics of sediments, parameters describing

bioavailability of contaminants, contaminant residues hi aquatic organism tissues, and biological

community structures.

       It is evident from the best data currently ivailable that sediments in many waterbodies across

the country are contaminated to levels that harm jenthic and aquatic communities and that may

contribute to increased cancer and noncancer diseases for consumers of contaminated fish and
shellfish.  EPA believes that the effects of sediment contamination have been documented sufficiently
to confirm their significance as a widespread national problem.  To further define the extent of

contamination, EPA, under the authority of Section 503 of the Water Resources Development Act of

1992, is developing the first biennial national inv ;ntory of contaminated sediment sites for submission

to Congress in late 1994.


       The goals of EPA's Contaminated Sediment Management Strategy are: 1) to prevent further

contamination of sediments that may cause unacceptable ecological or human health risks; 2) when

practical, to clean up existing sediment contamination that adversely affects the Nation's waterbodies

or their uses, or that causes other significant effects on human health or the environment; 3) to ensure

that sediment dredging and the disposal of dredged material continue to be managed in an

environmentally sound manner; and 4) to develop methodologies for analyzing contaminated

sediments.                                                                          ;

       The Strategy is designed  around the following principles:

       1.      EPA programs with authority to address sediment contamination operate under the

               mandate of many statutory provisions.  Therefore, regulatory decisions must be based

               on requirements that are not always consistent among EPA programs.  EPA programs

               should respond to the risks of sediment contamination as consistently as possible,

               taking into account statutory requirements and the need for programs to address other

               problems that pose similar or higher risks.
        2.      In assessing and managing contaminated sediments, EPA will continue to improve

               coordination of research and regulatory activities among other Federal agencies, State

               agencies, international organizations, and private parties.

EPA will continue to develop and

sediments.  These methods include

biological testing methods.
Assessment of sediment contamination

to reduce risks should be based oh

unavailable, the Agency will utilize
 improve methods for identifying contaminated

  numerical sediment quality criteria and unproved
     and any subsequent steps taken by the Agency

 sound science.  Where scientific information is

  conservative scientific assumptions.
To better assess the extent and severity of sediment contamination, the Agency will

conduct a national inventory of se diment quality and improve its monitoring of

sediment contamination.  The-Agency will identify a list of chemicals of concern

based on their toxicity, persistence, and propensity to bind to sediment particles, and

will identify sources of these chemicals.
6.      To ensure that data gathered by EPA programs are comparable, EPA will develop
        standard sampling, analytical, anc
        numerical sediment quality criteria, to assess sediment contamination and its effects.
Where sediment quality is sufficient

uses of a waterbody, the Agency

pollution prevention measures anc

appropriate level of sediment qua
                                statistical methods, including the application of
   to support, or could support, the full designated

will use appropriate means to ensure that existing

 source controls will maintain, or achieve, the


8.     Where sediments are contaminated, the Agency will implement pollution prevention

       measures and source controls to limit/control further contamination.  This is a critical

       step: 1) to ensure the long-term success of any remedial activity for the site; 2) to

       rninimize the long-term costs of navigational dredging; and 3) to increase

       opportunities for beneficial reuse of dredged material.

9.     Where short-term risks and effects can be tolerated, and statutes or international

       agreements do not require remediation or establish other preferences (e.g., preference

       for treatment under the Superfund Amendments and Reauthorization Act of 1986), the

       preferred treatment of a contaminated sediment site is to implement pollution

       prevention measures  and source controls, and to allow natural processes such as

       biodegradation, chemical degradation, and the deposition of clean sediments to

       diminish risks associated with the site. Selection of the appropriate remedial option

       should, however, be undertaken on a case-by-case basis after careful consideration of

       the risks posed by the contaminants, the benefits of remediation,  and the costs of

       remediation.  In cases where EPA has chosen to allow natural processes to diminish

       risks, the Agency may still seek restitution for damages to natural resources in

       coordination with other Federal and State agencies.
10.     Remediation of contaminated sediment sites will be undertaken first to limit serious

        risks to human health and the environment, and then to restore sites to a degree

        sufficient to support existing and designated uses of the waterbody, including potential

        uses of the sediment, whenever such restorations are practicable, attainable and cost



11.    EPA will not proceed with a clean-up of a contaminated sediment site when

       implementing the remedial alternative would cause more environmental harm than

       leaving the contaminants in place.
At sites where pollution preventio i, source control, and natural processes will not

reduce risks and adverse effects ir  an acceptable time frame, EPA will assign highest

priority to remediating contaminated sediment: 1) that is contributing to the most

                        tial risks to aquatic life, wildlife, and human health; 2)

                                t in the spread of contaminants into other areas that
       severe effects and substantial
       where continued delay would resu
       were previously unaffected; and 3) where remediation is cost effective.
The cost of sediment remediation

State, and local governments.  Appropriate

encourage voluntary clean-ups or

contaminated by their activities and

                                cannot be borne solely or substantially by Federal,,

                                        statutory authority will be used to

                                o compel responsible parties to clean up sediments

                                 to seek restitution for damages of natural
EPA will continue to work with

that dredged materials continue to

Physical, chemical, and biologica

disposal and management decisions

published by EPA, and EPA has
uncertainties will be interpreted, t

methods, to guide disposal and
    U.S. Army Corps of Engineers (COE) to ensure

   be managed in an environmentally sound manner.

   test methods will continue to be used to guide

   . After sediment quality criteria have been

  i ssued guidance describing how criteria values and

     criteria will be used, along with biological test

management decisions.  Interpretation of results to

meet program-specific goals will be maintained, and management alternatives will

remain consistent with the requirements of the applicable statutes.


                             CONTAMINATED SEDIMENTS
       EPA needs an Agency-wide strategy for

ensure consistent consideration of risks posed by

n anaging contaminated sediments to promote and

 contaminated sediments.
       EPA has the authority under numerous statutes to address contaminated sediments.  These

statutes include: the National Environmental Policy Act; the Clean Air Act; the Coastal Zone

Management Act; the Federal Insecticide, Fungicide, and Rodenticide Act; the Marine Protection,

Research, and Sanctuaries Act; the Resource Conservation and Recovery Act; the Toxic Substances

Control Act; the Clean Water Act; the Great Lakes Water Quality Agreement of 1978, as amended by

protocol signed on November 18, 1987; the Comprehensive Emergency Response, Compensation, and

Liability Act; and the Great Lakes Critical Programs Act of 1990.  A complete summary of EPA
authorities for addressing sediment contamination

Statutes and EPA Program Activities (U.S. EPA,
  is provided in Contaminated Sediments - Relevant

       Many EPA offices implement these statutory authorities or coordinate implementation in

 specific geographic areas, such as through the Chesapeake Bay Program, the Great Lakes National

 Program, and the Gulf of Mexico Program.  Depending on statute and program structure, EPA's
 Regional offices and the States may also exercise

 quality and impacts.
  wide latitude in their determination of sediment

        Implementation of these programs by different EPA program offices under a wide range of

statutory authorities has created inconsistencies in procedures for assessing the relative risks posed by

contaminated sediments and has increased the potential for duplication in the areas of research,

technology development, and field activities. EPA must strive to coordinate activities among the

Agency's program offices to promote and ensure consistent sediment assessment practices, consistent

consideration of risks posed by contaminated sediments, consistent decision-making in managing these

risks, and wise use of scarce resources for research, technology development, and field activities.


        In March 1990, a formal request, in the form of proposed legislation, was made to EPA

Administrator William Reilly to create a national program to address contaminated sediments.  The

request was made by the National Contaminated Sediments Working Group, a coalition of 13

environmental advocacy groups, and was endorsed by 235 Federal, State, and local public interest

groups, including labor unions, health organizations, and fishing, sporting, citizen, and environmental

groups. Several EPA Regional offices and States have also identified as a high priority the need for

technical guidance on assessing sediment quality.                                     i

       Congressional interest in issues related to contaminated sediments has been expressed

repeatedly over the past 5 to 10 years. In Section 118(c)(3) of the 1987 Clean Water Act (CWA)

amendments, EPA's Great Lakes National Program Office (GLNPO) was authorized to coordinate

and conduct a 5-year study and demonstration project relating to the control and removal of toxic


pollutants in the Great Lakes, with emphasis on the

sediments.  To fulfill the requirements of the Act,

of Contaminated Sediments (ARCS) program. The

1990 extended the ARCS program by one year and
       Since 1990, EPA has presented testimony
  removal of toxic pollutants from bottom

 GLNPO initiated the Assessment and Remediation

  Great Lakes Critical Programs Act (GLCPA) of

  specified completion dates for interim activities.
concerning contaminated sediments at dozens of
Congressional hearings before the House Commit ee on Merchant Marine and Fisheries, the House

Committee on Public Works and Transportation, and the Senate Committee on Governmental Affairs.
Members of Congress have also expressed interest in addressing sediment contamination in CWA


       The most recent legislation addressing contaminated sediments is the Water Resources

Development Act of 1992 (WRDA).  Title V of WRDA, the "National Contaminated Sediment

Assessment and Management Act," calls for the establishment of a National Contaminated Sediment

Task Force to be co-chaired by the EPA Administrator and the Secretary of the Army. Members of

this WRDA Task Force will include representatives from the National Oceanic and Atmospheric
Administration (NOAA), U.S. Fish and Wildlife

U.S. Department of Agriculture, States, ports, a
Service (USFWS), U.S. Geological Survey (USGS),

ricultural and manufacturing interests, and public
 interest organizations. Under WRDA Section 502, the WRDA Task Force is charged with advising

 the Administrator and the Secretary in the implementation of Title V by: 1) reviewing and

 commenting on reports concerning sediment qual ty and the extent and severity of sediment

 contamination throughout the Nation; 2) reviewing and commenting on programs for the research and

 development of sediment restoration methods, practices, and technologies; 3) reviewing and

 commenting on the selection of pollutants for development of sediment criteria and the schedule for


the development of such criteria; 4) advising appropriate officials in the development of guidelines for

restoration of contaminated sediments; 5) making recommendations to appropriate officials concerning

practices and measures to prevent the contamination of sediments and to control sources of sediment

contamination; and 6) reviewing and assessing the means and methods for locating and constructing

permanent and cost-effective disposal sites for the long-term disposal of dredged material that is not

suitable for ocean dumping, as determined under the Marine Protection, Research, and Sanctuaries


       WRDA Section 503 requires the EPA Administrator, in consultation with the Administrator of

NOAA and the Secretary of the Army, to conduct a comprehensive national survey of data  regarding

sediment quality in the United States. EPA is required to compile all existing information on the

quantity, chemical and physical composition, and geographic location of pollutants hi sediments,

including the probable sources of such pollutants.  A report to Congress is due in November, 1994.

       WRDA Section 503 further requires  that EPA conduct, in consultation with NOAA and the

COE, a comprehensive and continuing program to assess sediment quality which shall at a minimum:

1) identify the location of pollutants hi sediments; 2) identify the extent of pollutants in sediments

determined to be contaminated;  3) establish methods and protocols for monitoring the effects of

contaminated sediments and the pollutants therein; 4) develop a system for the management, storage,

and dissemination of data concerning sediment quality; 5) provide an assessment of sediment quality

trends over tune; 6) identify locations where pollutants in sediments may pose a threat to the quality

of drinking water supplies, fisheries resources, and marine habitats; and 7) establish a clearinghouse

for information on technology, methods, and practices  available for the remediation, decontamination,

and control of sediment contamination. The results will be reported to Congress biennially, starting

four years from the date of enactment.



       Interagency coordination is paramount to successful implementation of the Contaminated

Sediment Management Strategy.  There are numerous recent examples of successful coordination

among agencies, including: 1) the Intergovernmental Task Force on Monitoring Water Quality which

is composed of members from EPA, USGS, eight other Federal agencies, and ten State agencies and

whose mission is to more effectively collect and present water quality data by formulating national

monitoring protocols, quality assurance/quality control (QA/QC) procedures, and data collection and

sharing systems; 2) the Federal Interagency Sedimentation Project, which includes representatives

from the USGS, the COE, the United States Bureau of Land Management (BLM), the United States

Forest Service (USFS), the Tennessee Valley Authority (TVA), and the U.S. Department of

Agriculture (USDA), and whose mission is to study physical properties of sediments to determines

both the degree to which sediments trap contaminants and the timeframe for biodegradation, chemical

degradation, or burial of contaminants; 3) the National Water Quality Assessment Program formed by

members of the USGS, USDA, EPA, and  USFWS to measure baseline conditions at 60 sites

nationwide and monitor conditions over time to define trends; and 4) the U.S. Department of Energy

(DOE) Environmental Restoration Program, through which DOE has entered into agreements with

several States and EPA to coordinate implementation of remedial actions at DOE facilities.
       There are also a number of ongoing staff-level activities which have been successfully

coordinated. As an example, EPA and the COE regularly hold jointly administered Ocean Dumping

Coordinators and CWA Section 404 Coordinators meetings.  At these meetings, issues related to


implementation of the dredged material management

the State of Florida and NOAA have collaborated

along Florida's shoreline at over 700 sites (MacDonald
       The EPA's Contaminated Sediment

build on established cooperative activities among

addressing contaminated sediment issues, as

Through the WRDA Task Force, EPA will also

strategy for contaminated sediment management.


       The Office of Science and Technology within OW has coordinated development of the
Contaminated Sediment Management Strategy anc
        programs are discussed.  As another example,

      on a survey of sediment and biological conditions

          , 1993).
Management Strategy and the WRDA Task Force will

     igencies to promote and maintain consistency hi

 described in subsequent Sections of this document.

    propose the development of a national Federal
      will continue to coordinate implementation of the
Strategy with the relevant program and regional offices. Oversight for coordination of Strategy

implementation will be provided by the Agency-wide Sediment Steering Committee.
       States will play a central role in Strategy
     implementation.  States may, for example,
promulgate sediment quality standards that are pr rtective of sediment quality.  Insofar as possible, the

Strategy will be consistent with regional and State policies and will not impede State and local
management and prevention measures. Strategy implementation will include State training and
information dissemination as described in Section
      11, Outreach Strategy.

                       4. POLICY FRAMEWORK FOR STRATEGY


       In 1989, EPA Administrator Lee Thomas formed an Agency-wide Sediment Steering

Committee to address the problem of contaminated sediments on a national scale. The committee,

chaired by the OW's Assistant Administrator, is composed of senior managers from all program

offices with the authority to address contaminated sediments, and a representative from each of EPA's

ten Regional offices.  A Sediment Technical Committee composed of staff members from each

program and EPA Regional office was also established in 1989.  The Sediment Technical Committee

provides technical input to the Sediment Steering Committee.  The regular meetings of the Sediment

Technical  Committee provide an EPA forum for exchanging information on research, progfam, and

field activities.

       In January 1990, the Sediment Steering Committee decided to prepare an Agency-wide

Contaminated Sediment Management Strategy to coordinate and focus the Agency's resources on

contaminated sediment problems. Four workgroups were established to prepare option papers on how

to improve the Agency's efforts to assess,  prevent, remediate, and manage the disposal of

contaminated sediments. The option papers were distributed to other Federal agencies including the

COE, USGS, the United States Food and Drug Administration (USFDA), NOAA, the USFWS, U.S.

Minerals Management Service (MMS), U.S. Department of Justice, U.S. Coast Guard (USCG), U.S.

Navy, U.S. Army, and representatives of 11 State governments with active contaminated sediment

management programs. The views of these Federal and State officials were presented to the Sediment

Steering Committee in May 1991, when preliminary options were selected to form the basis of a draft

Contaminated Sediment Management Strategy.
       In September 1991, EPA's Deputy Administrator Hank Habicht was briefed on the options

selected for developing the Strategy.  He suggested that EPA distribute the document in outline form

as a proposal for discussion to solicit public comments.  Since March 5, 1992, EPA has distributed

over 2000 copies of the draft outline to Federal, State, and local environmental and public health

agencies, industry and industry coalition groups, national, State,  and local environmental advocacy

groups, law firms, consulting firms, academia, and other interested parties. To further the outreach

effort, OW's Risk Assessment and Management E ranch, at the Deputy Administrator's request,

sponsored a series of three public forums to solicit feedback on the draft outline.


        The forums were designed to include participants representing all parties responsible for
addressing contaminated sediments at the Federal

Extent and Severity of Contaminated Sediments,"
(U.S. EPA, 1992a). The forum consisted of panel discussions on three topics of concern: 1) the
extent of sediment contamination; 2) the severity

effects; and 3) the severity of contamination with
of contamination with respect to human health

respect to ecological effects. Forum participants
 State, and locaLlevels,  The first forum,  "The

was held April 21 and 22, 1992, in Chicago, IL
 concluded that contaminated sediments are a natk nal problem, and that both human health effects and

 ecological effects have been documented at a nunber of sites.

       The second forum, "Building Alliances Among Federal, State, and Local Agencies to Address

the National Problem of Contaminated Sediments," was held May 27 and 28, 1992, in Washington,

DC (U.S. EPA, 1992a). The forum was conducted in three parts corresponding to the assessment,

prevention, and remediation elements of the draft Strategy. Forum participants concluded that: 1)

EPA should expedite development and implementation of the Strategy; 2) development of a national

inventory of contaminated sediment sites was a high priority; 3) all represented agencies would

provide data for the national inventory; 4) more attention should be devoted to nonpoint sources of

contaminants in the Strategy; 5) the addition of sediment toxicity and bioaccumulation tests to

requirements for chemical registration under the Federal Insecticide, Fungicide, and Rodenticide Act

(FIFRA) and the Toxic Substances Control Act was a high priority to prevent point and nonpoint

source contamination of sediments; and 6) consideration should be given to developing an integrated

Federal agency strategy for managing contaminated sediments.                          ,

       The third forum, "Outreach and Public Awareness," was held June 16, 1992, in Washington,

DC (U.S. EPA, 1992a). The forum provided recommendations for effective public outreach from

four perspectives: 1) State government, 2) the regulated community, 3) environmental advocacy

groups, and 4) a public awareness group.  Forum participants agreed that EPA should engage in

active dialogue with the public and be responsive to public concerns.

       Proceedings of the EPA's Contaminated Sediment Management Strategy Forums (U.S. EPA,

1992a) was published in September 1992. The document includes summaries of all presentations and

discussions held at the three forums as well as appendices containing the draft outline of the

Contaminated Sediment Management Strategy; a plan entitled "Proposed Outreach Activities to

Support Implementation of EPA's Contaminated Sediment Management Strategy"; agendas from the

three forums; and address lists for forum participants and speakers. Over 1000 copies of the

document have been distributed.


       In the March 1992 transmittal letter releasing the draft Contaminated Sediment Management

Strategy outline and announcing the three forums, EPA solicited written comments on the Strategy to

be submitted by July 15, 1992. The Agency actually received comments until August 31, 1992.

Comments were submitted by 11 Federal agencies, 17 State agencies, 4 municipal agencies,  13

business, trade, and industry organizations, 2 em ironmental consulting companies, 1 environmental

coalition representing 12 organizations, 1 govern nent coalition, and 1  law firm. The areas that

received the most comments were implementation of sediment quality criteria, consistent minimum

testing, and point versus nonpoint source control.


       To implement effective pollution abatement and control programs for contaminants that are

accumulating in sediments, and to take appropriate remedial action at sites with identified sediment

contamination, EPA has developed a strategy for assessing the extent and severity of sediment

contamination.  The assessment strategy outlines actions that EPA will take to generate and interpret

the environmental data needed to: 1) consistently assess the ecological and human health risks of

sediment contaminants and take appropriate regulatory action under the Agency's existing statutory

authorities; and 2) identify sites where contaminated sediment remediation is needed, and rank those

sites according to the extent and severity of contamination as well as associated ecological and human

health risks.                              •• -—"-'•'


5.1.1 Agency-wide Use of Consistent Test Methods

        All EPA program offices have committed to using consistent chemical and biological test

methods to determine whether  sediments are contaminated.  Standard test methods will be developed

and used to provide high quality  data in support of regulatory and enforcement actions for pollution

prevention, contaminated sediment remediation, and the management of dredged material disposal.

Test methods will be available to address a variety of situations ranging from screening to relatively

definitive tests of the effects of contaminated sediments on biological organisms. Test methods will

be tiered in order to promote efficient use of resources and screening of sites. EPA's Office of

Science and Technology (OST) within OW will

of sediment monitoring, from sample collection
develop a methods manual that will cover all aspects

  analytical methods to assessment techniques.
program offices.  These methods will also includ
Sediment Tiered Testing Committee will also
5.1.2 Establishment of an Agency-wide Sediment Tiered Testing Committee

       An Agency-wide Sediment Tiered Testing Committee, chaired by OST, has been established

to select chemical and biological sediment test methods to be standardized and used by all Agency
 ; guidance on statistical analysis of test results.  The
 elop a tiered testing framework; this framework will
identify a consistent set of tests that provides a complete assessment of sediment contamination within
each tier.  The EPA Science Advisory Board wit

methods will be proposed by the Sediment Tierec

wide use within the testing framework.
       Each EPA program office will develop guidance

tiered framework.  Although the standard sedime it

each office may not always need to perform all o
  review the tiered testing framework, and test
  Testing Committee to be standardized for
      :e for interpreting the tests conducted within the

   test methods will be used by all program offices,

  the tests included in a particular tier.
5.1.3  Selection of Sediment Toxicity Tests for Agency-wide Use Within the Tiered Testing

       The following solid phase acute sediment

selected by the Sediment Tiered Testing Committee
 toxicity tests and bioaccumulation tests have been

    for Agency-wide use within the tiered testing

framework.  These test methods will be published as EPA standard methods for adoption and use by

all Agency program offices in conducting contaminated sediment assessments:

       1.     Ten day freshwater acute toxicity tests using Hyalella azteca (amphipod or scud) and

              Chironomus tentans (midge).

       2.     Twenty-eight day freshwater bioaccumulation tests using Lumbriculus variegatus

              (freshwater oligochaete worm).


       3.     Ten day marine and estuarine acute toxicity tests using the amphipods Ampelisca

              abdita. Rhepoxvnius abronius. Hyalella azteca. Eohaustorius estuarius. and

              Leptocheirus plumulosus.

       4.     Twenty-eight day marine bioaccumulation tests using Macoma nasuta (clam) and

              Neries spp (polychaete worm).
       These test species and methods were selected for standardization on the basis of consensus

reached at an Agency-wide workshop on tiered testing issues for freshwater and marine sediments

held September 16 to 18, 1992 (U.S. EPA, 1992b).  Test method protocols for Agency-wide use,

including QA/QC requirements, have been published for these species (U.S. EPA, 1994a; U.S. EPA,

1994b). Protocols for sediment spiking, collection, handling, and manipulation will also be published

in fiscal year 1994.  The final protocols will be reviewed by the Agency's Environmental Monitoring

Management Council before publication by the Office of Research and Development as EPA Manuals.

All OW programs will use the sediment test protocols immediately.  The Office of Prevention,


Pesticides and Toxic Substances will develop test
   rules using these methods, and the Office of
Pesticide Programs will incorporate these tests into the Agency's test guidelines for pesticide

registration and reregistration.  The Superfund Contract Lab Program will not use the protocols at this

tune, although the Office of Emergency and Remedial Response will consider whether to include the

standardized sediment bioassays in the Contract L ab Program in the future.  The Regional

Environmental Services Division laboratories, however, which perform much of the testing for the
Superfund program, plan to use these methods as
       During fiscal years 1994-1996, EPA will

protocols and toxicity identification evaluation
   soon as they are available hi fiscal year 1994.  As
additional test methods are developed, they may be considered by the Tiered Testing Committee for

Agency-wide use.
   develop standard chronic sediment toxicity test

methods for sediment assessment.
5.1.4 Supplemental Specific Assessment Methods

       In addition to the consistent set of standard sediment assessment methods included in the

Tiered Testing Framework, each EPA program office may select and use supplemental program
specific assessment methods.  Each program will
   develop its own guidance describing specific
regulatory actions to be taken on the basis of resi Us derived from the consistent set of standard tests,

and any supplemental methods used in tiered testing.

       Pursuant to Sections 304(a)(l) and 118(c)(7)(C) of CWA, EPA is developing sediment quality

criteria for the protection of benthic organisms. These criteria are designed to be applied |where total

organic carbon (TOC) equals or exceeds 0.2% of the sediment dry weight, the primary route of

exposure is direct contact with the sediment, and the sediments are continually submerged; or there is

information indicating that equilibrium has been established between water and sediments.,

Documents presenting proposed criteria for five chemicals have been made available for public

review; EPA will publish the documents in final form after considering public comments.; The

documents present sediment quality criteria for the nonionic organic compounds acenaphthene,

dieldrin, endrin, fluoranthene, and phenanthrene. EPA will develop sediment quality criteria for

additional nonionic organic compounds using a methodology called the Equilibrium Partitioning

Approach (EqP).  EPA selected this method after considering a variety of approaches that could be

used to assess sediment contamination. A technical review of the criteria and supporting science was

conducted by the Science Advisory Board (SAB) (U.S. EPA, 1992c).  EPA will be presenting a

methodology for developing sediment quality criteria for metals to SAB in fiscal year 1995. EPA

will prepare sediment quality criteria for metals once the SAB review comments on the methodology

have been addressed.                                                                          .
       The SAB has concluded that sediment quality criteria can be used to support regulatory

decisions when the uncertainty associated with the EqP methodology is addressed.  The SAB

subcommittee reviewing the sediment criteria recommended that "these criteria not be used as a stand-

alone, pass-fail value for all applications" (U.S.EPA, 1992c).  Therefore, the Agency expects that

remediation programs will not use the criteria as mandatory clean-up levels, but rather as a means to/,

identify potential contamination problems and to provide focus and continuity to remediatipn efforts.

To clarify the role of sediment criteria hi a regulatory context, OST and the program offices will


develop a users manual that fully describes how

interpreted within the context of each regulatory

use the criteria as described below.  Public comment

management will be requested in the Preamble of

Rule is being revised to address requirements in

Federation v. Costle, 629 F 2nd 118 (D.C. Cir., :

fiscal year 1994 under the authority of the Marine

(MPRSA, 33 USC Sec. 1401 et seq.).  In addition

criteria users manual, which will describe how sec

program, will be requested as the appendices are completed.
        Great Lakes Program.  The Great Lakes
   sediment criteria values and uncertainty will be

   p ogram.  Generally,' however, program offices will-

       on the uses of criteria in dredged material

     he Ocean Dumping Rule. The Ocean Dumping

   response to a 1980 lawsuit, National Wildlife

     980); The rule will be proposed by EPA in late

     Protection, Research, and Sanctuaries Act     '

     , public comment on the appendices of the sediment

     iment quality criteria will be applied within each
     States and EPA Regions will use the sediment
criteria to assist in the ranking of contaminated se liment sites needing further assessment, to target

hot spots within an area for remediation, and to serve as a partial basis for the development of State

sediment quality standards. The Great Lakes program will also use the criteria to assist in selecting

methods for contaminated sediment remediation and determining whether a contaminated sediment site

should be added or removed from its list of designated Areas of Concern.
        EPA Monitoring Programs.  All EPA

 will use sediment quality criteria to evaluate

 toxicity bioassays and bioaccumulation tests will

   programs conducting sediment monitoring activities

sediment contamination at sites. Acute and chronic

        be used to evaluate ecological and human health

        National Pollutant Discharge Elimination System (NPDES).  State and Federal:permit

writers currently have the authority to establish water quality-based effluent limits in NPDES permits

for the protection of aquatic resources.  NPDES permit limits are currently derived from State water

quality standards, which in turn are derived from EPA's water quality criteria.  With the availability

of sediment quality criteria, State water quality standards and the resulting permit limits can be

derived taking into consideration either sediment or ambient water quality criteria.  Site and chemical-

specific variables will be factored into the calculation of permit limits along with applicable criteria.

As State sediment quality criteria are promulgated as standards, the Office of Wastewater

Enforcement and Compliance will continue to work closely with OST to develop models that can be

used to calculate NPDES permit limits from State water quality standards.
       Dredged Material Regulatory Programs. Sediment quality criteria can be integrated into

existing regulatory programs administered under MPRSA and CWA.  The criteria can be Used in the

tiered testing framework established for these programs.  The testing guidelines are developed by

EPA in consultation with the COE.  Both agencies have agreed that EPA's sediment quality criteria,

when published, can be included in the second tier (Tier n) of required tests, when chemical analyses

are performed on dredged material.  Both agencies have also agreed that any dredged material that

exhibits contaminant concentrations less than or equal to EPA's sediment quality criteria will be

required to undergo additional applicable chemical, biological, and other evaluation procedures before

a decision on disposal can be made. Additional testing of this material will be required to determine

the possible synergistic effects of contaminants present.  EPA and the COE are presently developing

an approach to managing sediments that exceed EPA's sediment quality criteria.  Such cases will

generally result in a more detailed assessment and may include additional sampling. As part of the

ongoing Ocean Dumping regulation revision, OW's Ocean Dumping Program plans to solicit


comments on options for use of sediment quality criteria in the dredged material regulatory program.

A second, draft regulation revision, which will propose a specific option, will be published at a later

date.  EPA has suggested that the equilibrium partitioning methodology could be used to calculate the

bioavailable fraction of contaminant in sediment al a reference site and in the dredged material itself.

Under this approach, if the bioavailable fraction o F contaminant in the dredged material is less than or

equal to the reference area concentration, the mate rial will pass the sediment quality criteria portion of

the evaluation. If the bioavailable fraction exceeds the reference area concentration, the material will

not be disposed of without special management pnctices such as capping.
        OST, the Office of Policy, Planning and Evaluation (OPPE), and the COE are conducting a
study of the benefits and costs associated with the

the COE's navigation dredging program. A goal
                                               use of EPA's sediment quality criteria guidance in

                                               of the study is to provide the best estimate of the
benefits and costs of applying sediment quality criteria to dredged material decision-making in a tiered

testing framework, both as strict pass/fail numbers and as decision criteria to be used within

established statistical confidence limits.
       Resource Conservation and Recovery

RCRA Corrective Action Program will use the

specific decisions about remediation at hazardous

proposed Corrective Action regulation which lists

trigger a study of remedial alternatives. In sel

standards.  At some facilities, technical feasibilitj

alternatives could result in clean-up levels that di
     (RCRA) Corrective Action Program. The

sediment criteria as one of the factors in making site-

  waste facilities.  The Office of Solid Waste has a

   action levels of contaminants that may be used to

     remedies, the action levels may become clean-up

   and long- and short- term effectiveness of

     from the action levels.  If the final corrective

 action regulations define specific action levels, sediment criteria will be one of the factors used in

 setting action levels for remediation projects.

        Superfund (CERCLA) Program.  The Superfund program intends to use sediment quality

 criteria as one of the factors to assess CERCLA sites that have contaminated sediments if there is

 reason to suspect potentially significant contamination of sediments at the Remedial Investigation stage

 of analysis.  The assessment is used to set clean-up targets for remediation pursued under the

 authority of CERCLA and the Superfund Amendments and Reauthorization Act of 1986 (SARA).


       In accordance with the requirements of Title V of WRDA, OST will conduct a comprehensive
 national survey of data regarding sediment quality in the United States, hereafter referred to as the
 Site Inventory.  OST will compile all available information currently contained in national and

 regional computer databases on the quantity, chemical and physical composition, and geographic

 location of pollutants in sediment.  OST will complete a report to Congress  on the Site Inventory in

 1995.  The Site Inventory will be maintained and updated on a regular basis by OST so that it can be

used to assess trends hi both sediment quality and the effectiveness of existing regulatory programs  at

the Federal,  State, and local levels.  The design of the Site Inventory is described in Framework for

the Development of the National Sediment Inventory  (U.S. EPA,  1994).

5.3.1 Purpose of the Site Inventory

                                               obtain the best possible current assessment of the

                                               sediments nationwide; 2) distinguish those areas

                                                  from those that are not contaminated; and 3)

                                               effects to human health or the environment.  Once

                                               ill target them for appropriate action.
       EPA is developing the Site Inventory to: 1

extent and severity of the problem of contaminated

that may be contaminated and need further assessment

identify areas that are causing high risks or severe

hese areas are identified, Agency program offices

5.3.2 Scope of the Site Inventory
       The Site Inventory developed by EPA wil contain detailed sediment quality data from both

freshwater and marine ecosystems nationwide.  Tl e Site Inventory will be developed in two phases.

During the first two year phase, EPA will compile and evaluate a database that will include as much

data as possible from existing national and regional computer-readable databases. The inventory will

include available data on contaminant concentrations in all types of sediments, including those from

rivers, lakes, and estuaries, and from all geographical areas. During the second phase of inventory

                                          die, and
development, EPA will actively solicit, compile

contaminated sediment sites.
                                                 1 evaluate detailed State data describing
5.3.3 EPA Program Office Uses of the Site Inventory

        The following EPA program offices intend to use data contained in the Site Inventory for the

assessment, pollution prevention, remediation, and dredged material management activities identified


        Office of Air and Radiation (OAR). Atmospheric deposition may be an important source of

sediment contamination.  OAR intends to use the Site Inventory to evaluate the contribution of

atmospheric deposition to sediment quality problems.  The Clean Air Act (CAA) Amendments of

1990 include specific sections to increase protection of aquatic systems from the  impacts of

atmospheric deposition. Section 112(c)(6)  requires EPA to list source categories accounting for 90%

of the aggregate emissions of each of seven critical pollutants by 1995. The seven pollutants are

alkylated lead compounds, polycyclic organic matter, hexachlorobenzene, mercury, polychlorinated

biphenyls, 2,3,7,8-TCDD, and 2,3,7,8-TCDF. Emissions standards are to be promulgated^for the

listed categories by the year 2000, assuring regulation of these sources of atmospheric contamination

of waterbodies.

        Section 112(m) requires EPA, hi cooperation with NOAA, to conduct extensive monitoring

and research to identify and assess the extent of atmospheric deposition of hazardous air pollutants for

the Great Lakes, Chesapeake Bay, Lake Champlain, and coastal waters.  A report to Congress was

required by November 1993 and biennially thereafter to include, for those waters, an assessment of

the relative atmospheric contribution to  total loadings, an assessment of the environmental and human

health effects attributable to atmospheric deposition, and a description of any regulatory revisions

necessary to assure adequate protection.  Additional regulations found to be necessary are to be

promulgated by November 1995.                                                     •
       Once atmospheric pollutants have been identified as sources of sediment contaminants present

in the Site Inventory, these data will be referred to the Great Waters Core Project Management

Group, which was formed to develop the implementation plan for Section 112(m).  The Core Group

will review the existing CAA regulations to evaluate their adequacy for control of atmospherically


deposited sediment contaminants.  Further emissions standards or control measures will be

promulgated as necessary and appropriate.

       Office of Emergency and Remedial Response (OERR).  OERR intends to identify sites with
contaminated sediments so that they can be added

contamination sites identified in the inventory can
                                              :o the Site Inventory. In turn, high priority

                                              become candidates for assessment under CERGLA.
This assessment may include evaluation with the I [azard Ranking System, which is used to identify

sites that may warrant long-term (and often high cost) clean-up under the Superfund program.
       Office of Enforcement (OE). OE intends to use the Site Inventory to target areas and

industries for inspection, development of injunctive relief, and supplemental enforcement projects.
The Site Inventory can also be used to target sites
                                              where known sources of sediment contamination
can be linked with ecological and human health effects.  Where possible, enforcement actions will be
initiated to remediate severely contaminated sites.
remediation of contaminated sediments is described in detail in Section 8.
       Office of Federal Activities (OFA).  OFA

Source Inventory (discussed in Section 5.4), and

target issues addressed during environmental reviews

Policy Act (NEPA) process.  OFA will use the Si

quality and potential environmental issues associated

areas requiring programmatic, long-term and/or
                                               Available statutory authority for enforcement and
, within OE, intends to use the Site Inventory,

   available data on sediment contamination to

  conducted as part of the National Environmental

 Inventory to evaluate the status of sediment

 with current Federal projects, and to identify

 i-agency NEPA analysis.

       Office of Pesticide Programs (OPP).  OPP intends to use the Site Inventory to identify

currently registered pesticides that are present in high concentrations at sites nationwide. OPP will

evaluate whether special review of these pesticides should be undertaken, whether sediment toxicity

testing must be required to support registration of additional uses or formulations of these chemicals,

and whether special labeling or use restrictions should be required.                       i

       Office of Pollution Prevention and Toxics (OPPT).  OPPT intends to use the Site! Inventory

to identify existing chemicals regulated under the Toxic Substances Control Act (TSCA) that occur in

areas of sediment contamination. OPPT will evaluate these chemicals for further testing.  OPPT will

also use the Site Inventory to identify possible violations of TSCA regulations.  OPPT will investigate

the sources of contaminants occurring at inventory sites and determine whether enforcement actions

should be initiated.

       Office of Science and Technology (OST). OST intends to use the Site Inventory to target

chemicals of concern for sediment criteria development and to evaluate the effectiveness of i


technology-based effluent guidelines, water quality-based permit limits, and total maximum daily


       Office of Waste Programs Enforcement (OWPE).  OWPE intends to use the Site Inventory

to identify sites where hazardous waste facilities may be contributing contaminants to sediment.  The

information in the inventory will be used to augment current approaches for identifying sites for

investigation and possible remediation.

        Office of Wastewater Management (O
OWM intends to use the Site Inventory to
assess the extent and severity of sediment contamination caused by point source discharges and to

identify the pollutants causing sediment toxicity.  This analysis will contribute to the identification of
watersheds where permitting and enforcement efforts to protect sediment quality will be focused. In
some cases, the Site Inventory and modelling may
limits are causing an impact on the sediment or th it there is a need to develop additional permit limits
specifically for the purpose of protecting sediment
   show that violations of water quality-based permit
        Office of Wetlands, Oceans, and Watersheds (OWOW).  OWOW intends to use the Site

Inventory data to help support its programs in nor point source control, estuarine management, and

dredged material management.  OWOW's Assessment and Watershed Protection Division (AWPD)

intends to use the Site Inventory to help identify impaired waters for the National Water Quality
Inventory 305(b) reports.  States intend to use the
for development of Total Maximum Daily Loads (TMDLs), and for evaluation of TMDL
effectiveness.  AWPD also intends to use the Site
  Inventory to assist State nonpoint source control
programs in updating their lists of waterbodies in iced of NFS management practices, including
control of sediment contaminants entering surface
  Site Inventory to assist in developing a list of sites
  waters from nonpoint sources.
       The Oceans and Goastal Protection Division (OCPD) intends to use the Site Inventory in

evaluating the extent and severity of sediment contamination in the Nation's estuaries.  If the Site

Inventory includes contaminated sites located in estuaries that are part of the National Estuary

Program (NEP), during review of NEP deliverables, OCPD will recommend that Comprehensive

Conservation and Management Plans (CCMPs) for those estuaries include action plans for addressing

contaminated sediment.

       The Site Inventory may also be used by OCPD, the Wetlands Division, and the EPA Regions
to implement the disposal program for dredged material hi association with the COE.  The Site

Inventory may be used to supplement information gathered for Tier I dredged material evaluations to

determine whether additional chemical, physical, and biological testing is necessary.  The Site

Inventory may also be used to help identify possible chemicals of concern in dredged material and to

provide data for the development of disposal site monitoring plans. The Site Inventory could be used
to generate information on the impact of sediment contamination on wetlands functions as well.

                                                           4                      ;
5.3.4 Evaluation of Data Included in the Site Inventory

       EPA intends to develop a "weight-of-evidence" approach based on sediment chemistry and

biological effects data for evaluating sites described hi the inventory.  OST will use this approach to

rank all sites in the inventory as having known or suspected contamination problems.  To be

identified as a site of known contamination, biological effects of contaminants at the site must be

documented.  Depending on the availability of data,  the weight-of-evidence approach will employ one

or a combination of the following assessment methods to determine whether identified threshold

chemical concentration levels or biological effects levels are exceeded at a site: sediment quality

criteria using equilibrium partitioning, sediment quality triad, apparent effects threshold, effects

ranges derived by Long and Morgan (1990), or Threshold Effects Level or Probable Effects Level

(MacDonald, 1993).


       In fiscal year 1994, OST will develop an
where sediment contamination may occur at leve

undertake sediment monitoring at those sites; 2)
 inventory of sources of sediment contamination,
hereafter referred to as the Source Inventory.  T. le Source Inventory will be useful to: 1) identify sites
s adverse to human health and the environment and
arget pollution prevention and source control
activities by identifying industrial categories contributing sediment contaminants to surface waters; 3)

select industries for the development of effluent guidelines on the basis of quantities of toxic sediment

contaminants discharged; and 4) target NPDES permitting and enforcement actions to protect

sediment quality.  The Source Inventory, used in conjunction with the Site Inventory and in some

cases additional monitoring data, should allow determinations to be made about whether sites are
problematic due to past environmental abuses or

update the Source Inventory every two years.
as the result of ongoing contamination.  OST will
5.4.1 Approach to Developing the Source Inventory

       EPA intends to undertake the following t isks to develop the Source Inventory:

       1.     Search databases containing the results of sediment monitoring studies to develop a list

              of contaminants found in sedimei t.  The following databases will be used to compile

              the initial list of sediment contaminants: 1) 1987 EPA Sediment Quality Study (Lyman

              et al., 1987); 2) EPA Region IV/VI Coastal Contaminated Sediment Site Inventory

              (U.S. EPA, 1992d and 1993c); 3p NOAA National Status and Trends (NS&T)
              monitoring data; 4) Puget Sound
Study data; 5) STORET (OW's Storage and
              Retrieval system) sediment observations; 6) Ocean Data Evaluation System (ODES)

       sediment observations; 7) EPA. Region IX Dredged Material Tracking System

       (DMATS); and 8) EPA Region X Dredged Analysis Information System (DAIS).

2.     Identify databases containing information on the sources of the contaminants and

       amounts discharged. The following databases will be used to compile the initial list of

       sources of sediment contaminants:  1) EPA Effluent Guidelines Industry Status Sheets

       database; 2) NPDES Permit Compliance System; 3) Toxics  Release Inventory; 4)

       National Urban Runoff data in STORET; 5)  atmospheric deposition data; and 6)

       pesticides data.

3.     Identify those contaminants that can be linked to sources and that are likely to be

       found in sediments.

4.     Determine loadings of identified sediment contaminants according to standard

       industrial classification codes (Office of Management and Budget, 1987).

5.     Evaluate potential contaminants of concern using a fate/toxicity index.   The index will

       be calculated on the basis of: 1) contaminant propensity to bind to sediment; 2)

       contaminant persistence in the environment;  3) aquatic life toxicity assessed using

       NOAA effects ranges, apparent effects thresholds, or aquatic life sediment;criteria
       derived using the equilibrium partitioning method; and 4) human health toxicity

       (systemic toxicity and  carcinogenicity) assessed using current Integrated Risk

       Information System (IRIS) reference doses, IRIS cancer potency slopes, orj

               mammalian LD^ (lethal dose) data

               normalized using the fate/toxicity
               identify waterbodies potentially ai
                                :.  Quantities of contaminants released will be

Identify point and nonpoint sourc ;s of the contaminants (where data are available) and

evaluate to determine chemicals, geographic areas, and industrial categories of

concern based on the potential for  sediment contamination. EPA also intends to
                                risk from sediment contamination by calculating the
               sum of normalized quantities of contaminants released into each waterbody.
5.4.1. EPA anticipates the likelihood that signifi
5.4.2  Uses of the Source Inventory
       Monitoring.  The methodology used to develop the Source Inventory is described in Section
                               ;ant sediment contaminant sources will be located
where no ambient sediment quality data exist. The Source Inventory can be used to provide

information to target sites for sediment monitoring. Knowledge of existing sources of sediment

contamination can help distinguish between sites that have been contaminated by historical sources
and sites that are currently being contaminated by

when identifying sources of impairment to rivers,
reports.  This information can also assist EPA an 1 the States in determining appropriate remediation

activities. The presence of contaminated sediments at sites without current or historical sources

nearby may indicate potential illegal dumping activities.
                                active sources.  This information is useful to States

                                lakes, and estuaries for their CWA Section 305(b)

       Pollution Prevention. OPPT intends to use the Source Inventory to identify reductions in

sediment contaminant discharge that can be achieved through the voluntary 33/50 Program, which

encourages industries to reduce the generation of toxic wastes.

       Effluent Guidelines Development. Under Sections 301, 304, 306, and 307 of the CWA,

OST promulgates technology-based national effluent limitations guidelines that control the discharge

of toxic chemicals and other pollutants by categories of industrial dischargers. OST selects industries

for promulgation of new and revised effluent limitations guidelines based on environmental factors
and utility to states and POTWs. OST will include the Source Inventory among the environmental

data sources it will use in the selection process.  Accordingly, degradation of the sediment

environment may be considered in the selection of industries for the development of new or revised
effluent limitations guidelines. The effluent limitations guidelines process involves developing and

evaluating treatment options reflecting the Best Available Technology Economically Achievable

(BAT), Best Conventional Technology (BCT), and New Source Performance Standards and

Pretreatment Standards for indirect dischargers.  The Source Inventory can be used in technology

option development and selection by providing information on chemicals causing the greatest risk to

aquatic life and human health. In addition, the Source Inventory data can be used in the

environmental assessment of regulatory options.
       Total Maximum Daily Loads. Section 303(d) of CWA establishes the TMDL program to

allow for water quality-based controls to be implemented when technology-based controls are

inadequate to meet water quality standards. State and EPA authorities begin the TMDL process by

selecting waterbodies which are water quality limited, targeting high priority waterbodies for TMDL

development, and assessing pollutant sources. The Source Inventory can provide EPA and States with

                                              40                                  !

a screening tool to identify contaminant sources and possibly distinguish between point source and
nonpoint source loadings. Additionally, when set
standards, the Source Inventory, in conjunction with the Site Inventory, can be used to identify
waterbodies which may not attain these standards
guidance can be used hi TMDL studies to derive
iment quality standards exist in State water quality
  State authorities could then target these
waterbodies for further assessment and possible 1MDL development.  Sediment quality criteria and
oading targets for nonpoint sources that are
protective of sediment quality.  In some waterbodies, sediment contamination has been caused by

contaminated sediment washing into the waterbody. EPA will encourage, but cannot require, States

to modify or develop their own erosion and sediment control legislation to include consideration of


       Permitting.  Through the NPDES permit ing program, administered by OWM, EPA and

State regulatory authorities establish water quality-based pollutant concentration limits on the effluent

of individual discharge facilities and monitor to ensure compliance with those limits.  The Source

Inventory will be used, in conjunction with the Site Inventory, as a screening tool to identify current

point and nonpoint sources of contaminants nearby or upstream from sediment  with elevated pollutant
levels.  Permit issuing authorities can then target

assessment and possibly for development of watei

EPA headquarters may also use the Source and S
watersheds and specific facilities for further

 quality-based permit limits to protect the sediment.

ite Inventories to identify facilities where procedures
for developing water quality-based permit limits for sediment quality could be demonstrated, to

identify pollutants contributing to sediment quality problems nationwide, and to evaluate whether

current point source permit limits are sufficiently protective of human health and the environment.

       Enforcement.  The Division of Water Enforcement (DWE) within OE is currently planning a

water quality initiative to identify sources contributing pollutants to waterbodies for which a State has

issued water quality advisories against fish consumption or swimming because of excess loadings of

the pollutants.  Frequently, the advisories are a result of sediment contamination. The Source

Inventory can assist DWE by providing information on nearby or upstream dischargers of potential

sediment contaminants.  The Source Inventory could be used to develop the initial list of likely
pollutant sources for a given watershed. Further, the inventory can provide data on specific

chemicals most likely to cause adverse  environmental impact.  This could provide DWE with
information necessary to identify the discharges or industrial activities that are contributing to the

water quality advisory. This information in turn could support enforcement actions that wpuld

compel a facility to cease its damaging  activities.

       Other Potential Uses.  Additional program offices within OW may  use the Source Inventory

to support their activities.  For example, OWOW identifies priority watersheds for nonpoiht source

control strategies and manages the NEP.  OCPD, within OWOW, can target waterbodies where

sediment is contaminated for management under its program.  Knowledge of current sources of

sediment contaminants could help both  the States and EPA to determine point source and nonpoint

source pollutant contributions to waterbodies and to identify potentially significant contaminant

sources.  The Source Inventory could help OST identify chemicals that are potentially most toxic and

are discharged in the greatest amounts, and thus guide the development of sediment quality criteria.

assess aquatic sediment quality.  EPA will comply


       Section 503 of WRDA requires EPA to establish a comprehensive and continuing program to
                              with this requirement by increasing sediment
monitoring in the Agency's water quality monitoring programs.  EPA intends to takethe following

actions to establish the Agency's sediment monitoring program.
       1.     The Office of Research and Develbpment

              Program (EMAP) intends to gathei

              quality at EMAP sampling stations
       2.     OW intends to develop a sediment
                                    's Environmental Monitoring and Assessment

                               chemical and biological data describing sediment
                              monitoring program to be implemented as part of
              its overall monitoring program framework.  The monitoring framework describes how
             'monitoring programs conducted by

              Agencies will be coordinated.
OW intends to include provisions

framework which will be

Monitoring Water Quality (ITFM)

reached with other Federal, State,

sediment monitoring protocols,

appropriate information system liri
                               EPA Headquarters*, EPA Regions, and State
        or sediment monitoring in the national monitoring

develope i by the Intergovernmental Task Force on

         Through this framework agreements should be

        and local agencies concerning incorporation of

     sediment monitoring QA/QC procedures, and

        cages into monitoring programs.

       4.     OW and the Office of Information Resources Management shall assure that the

              capability to store and use sediment data is enhanced as part of the ongoing

              modernization of the Agency's water quality data systems (STORET, BIOS, and

              ODES).  OW intends to work with the EPA Regions to ensure that Regional databases

              developed for the purpose of archiving and analyzing sediment information are

              compatible with the Agency's national databases.

       5.     EPA intends to allocate additional resources for the purpose of sediment monitoring if

              funds are appropriated for monitoring activities authorized under WRDA ;of CWA.


CONTAMINANTS                                                             i

       As described above in this strategy document, under Section 112(m) of the CAA, EPA is

undertaking a program to assess the effects of hazardous air pollutants on the Great Lakes, Lake

Champlain, the Chesapeake Bay, and near-coastal waters.  This program is referred to as the "Great

Water Bodies Study."  As part of this study, EPA will monitor the air deposition of toxics, monitor

tissue levels of airborne toxics in aquatic organisms, and develop models of contaminant transport.

An initial report to Congress on this program was completed hi May 1994.  Subsequent reports to

Congress on the Great Water Bodies Program are required every two years thereafter.  The reports

will address contribution of air pollutants to water pollution, sources of pollutants, and whether they

contribute to violations of water quality standards.  OST will incorporate these results into the Source

and Site Inventories.



      EPA will coordinate its sediment assessment activities with the USGS and other Federal and

State agencies through the ITFM.  EPA will also coordinate its sediment assessment activities with the

USGS, COB, BLM, USFS, TVA, USDA, and other agencies participating in the Federal Interagency

Sedimentation Project through the National Contaminated Sediment Task Force required under



        Implementation of an effective program to prevent sediment contamination from occurring is

 the most environmentally protective and, in most cases, cost-effective way to address the problem.

 EPA's current statutory and regulatory authority is adequate to prevent many sediment contaminants

 from being released to the environment.  The strategy for preventing sediment contamination

 describes the actions that EPA program offices will take under a number of different statutes,

 including EDFRA, TSCA, RCRA, CAA, and CWA to prevent sediment contamination.



 6.1.1   Control of Sediment Contaminants Regulated Under FIFRA

        FIFRA gives EPA the authority to ban or restrict the use of pesticides that have the potential

 to contaminate sediments, if the risks to nontarget organisms are judged to be unreasonably.  In

 making decisions on pesticides, FIFRA requires EPA to consider economic, social, and environmental

 costs and benefits. Sediment toxicity is not currently addressed in routine test procedures and risk

 assessments for pesticide registration, reregistration, and special review.                ;

 6.1.2 OPP Use of the Site Inventory
       OPP intends to use the Site Inventory developed by OW to develop a list of pesticides that are

posing risks or causing harmful effects on a national scale. OPP intends to evaluate these pesticides

to determine whether appropriate regulatory action should be taken.                    •


6.1.3 Memorandum of Agreement with USGS
                                              ;ement between OPP and the USGS's National

                                              The NAWQA program is integrating with other

                                              river basins and aquifer systems.  Information will

                                              .t the start of this program, data collection is

                                              OPP has played an active part in the USGS

                                               had technical input, and is currently working on
 requires information from registrants on adverse

 of finalizing a rule concerning collection of these

 of FIFRA).  OPP has set up a special process foi
       There is currently a Memorandum of Agn

Water Quality Assessment (NAWQA) Program.

programs the results from monitoring most major

be provided at the regional and national scales.  /

focusing on pesticides and nutrients in sediment.

NAWQA Program Federal Advisory Council, has

several joint USGS/OPP publications.

6.1.4 Pesticide Incident Reports
        OPP uses voluntary pesticide incident reports made by citizens, farmers, and pesticide

 registrants to obtain information on use, misuse, md problems associated with pesticides.  OPP also
                                              rffects of pesticides.  OPP is currently in the process

                                              adverse effect data (required under Section 6(a)(2)

                                               cataloging, sorting, processing, and using both the
 voluntary reports and the required registrant adverse effects reports hi the regulatory program.  OPP

 will continue to investigate information concerning sediment contamination in these incident reports

 on a case-by-case basis. If convincing cause-effect

 ecological or human health effects are available,
                                              then special review of the chemicals causing the

 adverse effects, or other appropriate regulatory action, may be undertaken by OPP.
                                               : data on pesticides in sediment and adverse

 6.1.5 Development of Technical Guidance Documents for Evaluation of Pesticide Risks

        OPP intends to continue work to develop technical guidance documents on the evaluation of

 pesticide risks, and evaluation of pesticides to determine their potential to run off into surface waiters,

 leach into surface waters, or accumulate in sediment.

 6.1.6  Aquatic Effects Dialogue Group Recommendations                           !

        In 1990, the Conservation Foundation's program on Environmental Dispute Resolution made

 recommendations on aquatic issues for the Agency's consideration. One topic of the discussions of

 the Aquatic Effects Dialogue Group (AEDG) was the evaluation of sediment toxicity. AEDG

 recommended that tests of sediment toxicity to aquatic organisms be considered for pesticides that are

 likely to sorb to sediment. The following scheme, proposed for EPA consideration, integrated

 sediment testing with FIFRA testing tiers (World Wildlife Fund,  1992):

 Tier I:         Equilibrium partitioning calculations to estimate chemical concentrations in porewater

               and sediment.

 Tier It:        Acute porewater and whole sediment toxicity tests with spiked sediment.

 Tier HI:        Chronic whole sediment toxicity tests with spiked sediment.

 Tier IV:        Benthic community structure, colonization rate, laboratory toxicity tests with field

               collected sediment, and in-situ sediment toxicity testing within a mesocosm.
       Although sediment toxicity testing can be required as a special test pesticides do not routinely

address potential ecological and human health effects of sediment contamination. OPP therefore

intends to develop a strategy to systematically eva uate

the registration and use of pesticides.  OPP intends

strategy for evaluating the potential for pesticide
                                     the risk of sediment contamination posed by

                                s to propose the following actions as part of its

                               contamination of sediments.
        1.      OPP intends to revise both the regulatory requirements for registration of pesticides at
               40 CFR Part 158 and Subdivision
               incorporate the EPA standard acui
                                E of the Pesticide Assessment Guidelines to
                               ite wh
                                 whole sediment bioassay methods and spiking

protocols developed by the Agency-wide Sediment Tiered Testing Committee.  OPP

intends to develop Standard Evalu ition Procedures for the sediment toxicity tests and
               submit them for Science Advisory
                                Panel review. OW will provide OPP with
supporting information regarding sensitivity of species and appropriateness of life

stages used.

When chronic sediment toxicity tests are developed by the Agency-wide Sediment

Tiered Testing Committee, OPP intends to revise both 40 CFR Part 158 and

Subdivision E of the Pesticide Assessment Guidelines to incorporate these methods
               and protocols. OPP intends to de
               and submit them to the Science Advisory Panel for review.

       3.      OPP intends to routinely require aquatic fate tests to support many terrestrial uses of

               pesticides that persist or bioaccumulate.
       4.      OPP is evaluating the feasibility 01

               Guidelines a new test requirement
                                elop Standard Evaluation Procedures for these tests
                                 integrating into the Pesticide Assessment

                                that combines protocols for two existing tests, the


              water column monitoring test ("Aquatic Field Dissipation Test") and the aquatic life

              tissue monitoring study ("Accumulation in Aquatic Non-Target Organisms").

              Regulatory requirements for routinely conducting this new test will be proposed.

       5.     OPP intends to develop better information for distribution to the public on brop

              management practices and Integrated Pest Management practices that will most

              effectively reduce the levels of toxic pesticide contaminants in sediment. OPP will

              work with OW's nonpoint source program to reduce the levels of toxic peslicides in

              sediment by providing information on best management practices and integrated pest

              management to fanners.

       6.     OPP intends to develop criteria for pesticide residues in sediments to be usjed as one

              of several screening tools for the determination of "Reduced Risks" (i.e., ''Safer")

              pesticides. This would allow for expedited registration of chemicals that fit into die

              category and possibly displace use of pesticides that are more harmful to human and

              ecological health.

       7.     OPP intends to investigate the feasibility of using the OPPT screening method that

              uses parameters such as chemical properties, environmental fate, hazard, and exposure

              for identifying those chemicals which pose a greater risk.


       EPA has authority under TSCA to regula e new and existing chemicals that have the potential

to contaminate sediments, if the resulting ecological or human health risks are judged to be
unreasonable.  The Office of Prevention, Pesticid
5 of TSCA, assessment of environmental fate and
                               is and Toxic Substances (OPPTS) is committed to a
program that will incorporate into routine chemic il review processes, performed under Sections 4 and
                                effects of toxic chemicals that could potentially
contribute to sediment contamination.  EPA believes that OPPT can contribute most significantly to

the management of contaminated sediment through its pollution prevention efforts.  OPPT therefore

intends to take the following actions to prevent sediment contamination:
OPPT intends to incorporate the «

sediment bioaccumulation test methods

into the OPPTS test guidelines.

developed by the Tiered Testing

OPPTS test guidelines as well.
acute whole sediment toxicity test methods and

      developed by the Tiered Testing Committee

When chronic whole sediment test methods are

Committee, OPPT will incorporate them into the
OPPT intends to use the Site Inventory and the Source Inventory to select chemicals

for review.  OPPT intends to devslop, and update on a regular basis, a list of

sediment contaminants to be evaluated for review. This list will include all chemicals

regulated under TSCA that have been identified to exceed toxic threshold

concentration levels at locations included in the Site Inventory.  As additional sites are
               included in the inventory, the list
                               of chemicals for review will be updated. OPPT
               intends to use the Source Inventory database (compilations of the Toxic Releases
               Inventory database, the Office of
                               Water Effluent Guidelines database, and the Office

       of Water Permit Compliance System database) to evaluate the sources of contaminants

       on the list of chemicals for review.

3.     Through the New Chemicals Program, OPPT can ban or otherwise regulate !the

       production of chemicals that could contribute to sediment contamination and!result in

       unreasonable risk to human health or the environment.  OPPT can and has prevented

       pollution from occurring.  OPPT intends to use the New Chemicals Program to
       engage the chemical industry in dialogues on the redesign of chemicals to reduce both

       bioavailability and partitioning of toxic chemicals to sediment.  OPPT intends to draft

       guidelines and implement a policy encouraging the design of new chemicals |having

       the following characteristics: molecular weight greater than 1000 grams per imole  to

       prevent adsorption through biological membranes; large cross-sectional diameters  to

       prevent movement through cell membranes; functional groups embedded within the

       molecule to enhance rapid transformation to low toxicity products; and log ^w

       (octanol-water partition coefficient) values greater than 8 to prevent effects at

       saturation or less than 3.5 to avoid partitioning to sediment.

 4.     OPPT is working on an assessment of a cluster of chemicals that may be persistent

       bioaccumulators.  Chemicals that are persistent bioaccumulators are also likely to

        accumulate in sediments. To the extent that this cluster, or elements thereof, appear

        to pose an unreasonable risk to human health or the environment, OPPT intends to
        engage industry hi discussions to mitigate this risk through voluntary pollution

        prevention measures.

Under the New Chemicals Program, OPPT has developed an exposure based review

(EBR) policy. In this program environmental fate and effects tests (e.g., sediment
        toxicity tests) may be triggered i
                               certain criteria are met in OPPT's initial review.
Data gathered in this way will ir iprove the OPPT risk evaluation and management

processes.  OPPT intends to revise this policy to include criteria triggering

requirements for sediment toxici y testing.

Staff in OPPT's Exposure Asses iment Branch (EAB) have worked with EPA's Region

V office to develop a testing strategy to assess the environmental risks associated with

biocides used to prevent zebra Brussels from fouling water pipes. While the final

report of this project is not available, it has been determined that some biocides do not
       degrade well and therefore can
                               :rsist in sediment. Region V plans to severely
       restrict the use of this group of chemical biocides.  Some other chemicals used as

       surfactants or wetting agents in biocides have been identified as potential risk

       concerns.  Region V intends to propose language for paper mill permits limiting the
       amount of these chemicals used.
       plans for the use of different surfactants that will degrade in the environment.
7.     OPPT is working with a number
                               IE addition, permitees may be required to submit
                               of industry trade associations to provide product
       toxicity testing information and guidance to their member companies.  OPPT and

       other program offices are assisting members of the Ecological and Toxicological

       Association of the Dyestuffs Manufacturing Industry in developing a pollution
       prevention program to record po
                               lution prevention achievements, further reduce waste
       generation, and continue to realize the benefits of pollution prevention in the dye

              industry.  As part of this pollution prevention program, OPPT intends to specifically

              document the actions that the dye industry can take to reduce the generation of waste

              products that concentrate in sediment.  The Site and Source Inventories may be used
              to produce an initial list of toxic waste products that may be present in sediment.

       8.     Li evaluating new chemical registrations, OPPT intends to use the Site and Source

              Inventories to assist in identifying geographical areas where additional chemical

              discharges may lead to unacceptable levels of sediment contamination.



       OECA has issued two policies related to the use of pollution prevention conditions in EPA

enforcement settlements.  These two policies are: 1) the Policy on the Use of Supplemental

Enforcement Projects hi EPA Settlements (issued February 12, 1991); and 2) the Policy on the

Inclusion of Pollution Prevention Conditions in Enforcement Settlements (issued February 25, 1991).

These policies are designed to help reduce or  eliminate root causes of noncompliance with permits by

commuting penalties, through enforceable agreements, if appropriate source recycling and source

reduction activities are undertaken. OECA will aggressively apply both of these policies to negotiate

settlements that will reduce sediment contamination. All settlements will emphasize reductions over

and above what is required to return to compliance with the requirements of law. Settlements will

also emphasize actions which will enhance the prospects  for long-term or continuous compliance.

OECA intends to take the following actions to implement programs to reduce sources of sediment


1.-..-,  OE intends to continue to implement pollution prevent*

       Office of Air Quality Planning and

2.     Under these initiatives the OE intends

       teams to identify and evaluate the

       to reduce sediment contamination,
3.     OE intends to also monitor respondent

       assure compliance with all settlement

4.     OE intends to evaluate and report

       conditions related to sediment contaminants
5.    ; OE intends tQ develop technical

       the EPA Regions in enforcement

                    ion initiatives with the OPPTS,

   Standards, NPDES, and RCRA compliance
      to provide technical support to EPA negotiation

  feasibility of specific pollution prevention conditions
      or defendant activities in cases pursued and

     conditions related to prevention of sediment
  on the effectiveness of the pollution prevention

           that are obtained in the settlements.
pollution prevention guidance that can be used to train

 actions that can be taken to reduce sediment
6.     An executive order signed on Aujust 3, 1993 requires Federal facilities to halve their

       toxic emissions by 1999 and to begin reporting to the public any release of toxic

       pollutants. EPA will monitor compliance with the executive order.


                                     CONTAMINATION                         \

       The goal of CWA is to restore and maintain the chemical, physical, and biological integrity of

the Nation's waters. NPDES permits are the primary means for preventing the discharge of

pollutants into water from point sources.  Under Sections 301, 304, 306, and 307 of CWA, EPA has

set minimum, technology-based requirements for municipal dischargers (e.g., primary and secondary

treatment standards) and sets similar requirements for industrial dischargers (e.g., best available

technology economically achievable and pretreatment standards for existing sources).  Under Section

301 of CWA, NPDES permits must also include additional limits as necessary to achieve applicable

water quality standards.

       To date EPA has promulgated best available technology (BAT) effluent guidelines for 40

industrial categories. Over one billion pounds of the 126 priority pollutants are removed Annually as

a result of these requirements.  EPA has not directly considered sediment contamination in developing

these guidelines; however, the program has reduced loadings of toxicants to both water arid sediment.
In addition to developing these nationally applicable effluent limitations, EPA sets technology-based

limitations in permits on a site-specific basis using Best Professional Judgment. Effluent guidelines

are also the basis for local pretreatment programs, which require toxics controls on industries

discharging into municipal sewage treatment plants.  In 1986, it was estimated that 37 percent of the

toxic industrial compounds that entered surface waters had passed through sewage treatment plants.

As a result of this finding, EPA identified the 1500 municipal sewage treatment plants that handle the

     plants to develop and enforce appropriate

 system.  An estimated 12,000 significant industrial

   or more of the effluent guideline categorical
majority of industrial wastewater.  EPA required

effluent limits for industries discharging into then-

users in pretreatment cities are required to meet

       Under Section 304(m) of CWA, EPA is required to publish a biennial Plan that establishes a

schedule for the annual review and revision of pro nulgated effluent guidelines and identifies
categories of sources discharging toxic and nonconventional pollutants for which guidelines have not

yet been published. Following publication of the first such Effluent Guidelines Plan in 1990, the

Natural Resources Defense Council and Public Citizen Inc. filed suit, claiming that the Plan did not

fulfill the requirements of Section 304(m).  In a Consent Decree dated January 31, 1992, EPA agreed
to promulgate 19 new and revised effluent limitati
                                                ms guidelines over an 11 year period.  Twelve of
the industries for rulemaking have been selected based on need and potential for risk reduction.  The

remaining 9 must be selected beginning in 1995.  The Agency agreed to study these industries in the

intervening tune and to evaluate the need and risks involved before making the selections.
        EPA's effluent guidelines program has evaluated risk as one criterion used to select industrial
categories for guidelines development. In the next
  Effluent Guidelines Plan, the Agency intends to
propose adding sediment contamination as a specific factor in the selection of these industrial

categories.  The Source Inventory would be used for this purpose. The inclusion of sediment

contamination as a specific evaluation factor would increase the potential for industries discharging
sediment contaminants to be the subject of new or
 revised effluent limitations guidelines.  This would
ensure that the Agency will consider sediment con aminants in establishing guidelines in the future.

Once an industry has been selected for development or revision of guidelines, it will take a minimum


of 5 years to promulgate the rule.  Guidelines are not self-implementing, but only become binding

when implemented hi permits, so 5 to 10 years is the minimum tune period to be expected for

implementation of new technology-based NPDES permit limitations.                    ;


       Although in many cases past discharges are partly responsible for today's contaminated

sediment problem, sediment quality problems are not solely the legacy of past discharges.i Monitoring

and assessment data compiled by Federal, State, local, and private sources  indicate that currently

discharging sources do contribute to sediment contamination.  On the States' CWA Section 304(1) lists

of waterbodies that will not meet water quality standards for toxics because of point source

discharges, 11 waterbodies were listed because an active point source was entirely or substantially

contributing to or causing  sediment contamination and hence impairing uses of the waters. The point

sources of sediment contaminants identified by States under Section 304(1) included Publicly Owned

Treatment Works (POTWs), power plant Outfalls, and industrial discharges.  EPA studies shave

documented additional cases of sediment contamination from stormwater discharges, combined sewer

overflows, metal finishing industries, pulp and paper mills, and oil storage  terminals.  Furthermore,

preliminary data from the Source Inventory indicate that active point source discharges are

contributing to sediment contamination.
       EPA has published water quality criteria identifying the concentrations of specific :chemicals in

the water column that should not be exceeded in order to protect aquatic life and human health.    -;

These criteria are often used by the States as the basis for adoption of legally enforceable water

quality standards for waterbodies.  Every 3 years, States are required under CWA to review their

                                              58                                  [

water quality standards to determine if they meet the requirements of the Act, and standards are to be
revised as necessary.  In 1987, Congress amended
States had met this requirement.  EPA initiated ac

toxic pollutants applicable to those States that had
 CWA to require States to adopt numeric toxics
criteria in their water quality standards as necessary to support designated uses.  By early 1990 only 6
ion to promulgate Federal water quality criteria for

failed to comply fully with the Act.  On December
22, 1992, EPA promulgated criteria for toxic poll itants for the jurisdictions that had not yet complied

with the Act.  Because numeric water quality crite ria for toxics are now in place in all 57 States and

territories, numeric water quality-based NPDES p ;rmit effluent limits for toxics will eventually be

developed in all States. Due to the lack of chemical-specific sediment quality criteria and sediment

bioassay methods, however, most NPDES permits do not contain limits specifically developed to

protect sediment quality.  Once EPA has developed a standard set of chemical and biological sediment

test methods, EPA and the States will be able to use these methods in the process of developing water

quality-based permit limits to protect sediment quility for targeted discharges.  Toxicity bioassays

may be used to confirm whether point source con lamination of sediments causes or contributes to
 aquatic life toxicity.  Sediment toxicity identificat

 chemicals causing the toxicity.  For human health
;on evaluations can be performed to identify the

 and wildlife protection, bioaccumulation bioassays
 can be used to confirm that the chemicals discharged are bioconcentrating in the food chain.
        CWA also includes requirements in Section

 Under recently revised regulations, every two years

 meet water quality standards (including designated

 rank the waters in priority order; and 3) develop

 specify the particular source reductions necessary

 source reductions are implemented through NPDES
  303(d) for comprehensive water quality planning.

   States must: 1) identify all waters that do not

 uses and sediment criteria) or are threatened; 2)

TMDLs according to the priority ranking.  TMDLs

 to attain and maintain water quality standards.  The

   permit limits and through State nonpoint source

 programs,  TMDLs are especially valuable when there are multiple sources or when loadings to

 threatened waters that may not yet exceed water quality criteria need to be allocated to point source

 discharges. If chemical-specific sediment quality criteria and standards are available, TMDL

 modeling can be used to establish effluent limits that meet those criteria.  If sediment criteria are not

 available for problem pollutants, a permit writer may develop sediment toxicity and bioaccumulation

 limits in NPDES permits, based on a State's narrative water quality standards, in order to .protect

 sediment quality.

        OW's Permits Division is field-testing an EPA model that predicts water and sediment

 concentrations based on receiving water conditions and effluent loadings.  The model can be used to

 calculate wasteload allocations based on compliance with sediment quality criteria.  If the model is

 satisfactory, the Permits Division intends to prepare a users manual on how to use the model to derive

 wasteload allocations and permit limits to protect sediment quality.  The Office of Research and

 Development (ORD) is investigating methods to link contaminated sediments to point sources.  These

 methods include toxicity identification evaluations to identify the chemicals causing toxicity;

 contaminated sediment gradient assessment,  in which contaminant concentrations are measured as &

 function of proximity to a pipe; and fingerprinting, which examines the correlation betweeh the

 specific chemicals produced by a company and the chemicals found in nearby sediments.  These

 methods may be incorporated into the OW guidance as they become available.
       Once EPA publishes sediment quality criteria and the accompanying users manual, the States

can adopt criteria as necessary to protect sediment quality during their triennial review propess. (Note

that States are required under CWA Section 303 to promulgate criteria to protect designated uses; if a

specific pollutant is not likely to be present in waterbodies at levels sufficient to impair those uses,

                                               60                                   :

then a State is not required to adopt criteria for that pollutant.)  States can also develop criteria less
protective than EPA's criteria guidance, provided
uses nevertheless will be protected. NPDES pern its generally are written for a 5-year term so as

many as 8 years may pass after EPA promulgation of sediment quality criteria guidance before
permits are issued with water quality-based limits
                                              that the State can show that the relevant designated
                                              specifically to protect sediment quality. Additional
time may be allowed for compliance with these lii lits, if the inclusion of compliance schedules in

permits is explicitly allowed by State water quality standards or implementation procedures.
        The 1987 amendments to CWA also require EPA and the States to develop permits for

discharges from all municipal separate storm sewer

100,000, and to issue permits for stormwater disc
                                                systems that serve populations of more than
                                               tiarges associated with industrial activity as well.

The stormwater rule promulgated in October 1990 provides wide-reaching authority that can be used
                                               ;as, and some authority to control stormwater
contaminants from point sources.  OW intends to

geographic areas that have the greatest likelihood
to prevent contamination of sediments in urban ar

discharges from silvicultural and mining sources.
        The Source Inventory is the first comprehensive evaluation of ongoing discharges of sediment
                                              use the Source and Site Inventories to screen for

                                              of experiencing adverse aquatic life and human
health risks due to sediment contaminants. In ad( ition, OW intends to use the inventories to help

identify the active point sources and pollutants most responsible for causing such risks.  OW also

intends to use the inventories to target industrial stormwater discharges, discharges from municipal

separate storm sewer systems, and combined sewer overflows that are known to contribute to

contaminated sediment.  These dischargers will b 5 required to prepare  a pollution prevention plan
 which includes measures to prevent the discharge
                                               of sediment contaminants and the occurrence of

sediment toxicity.  EPA will develop guidance on how to identify and control sources of sediment

contamination that discharge to these sewers. Because these sewer systems receive a large volume of

nonpoint source runoff, compliance with end-of-pipe limitations may result in local implementation of

nonpoint source runoff controls and practices.

       Point source discharges are also addressed through CERCLA and RCRA.  Discharges from

CERCLA sites and RCRA facilities subject to NPDES permits must comply with requirements in the

permit that are protective of sediment quality.  As with other NPDES permits, these permits do not

currently contain limitations specifically developed to achieve sediment quality.  Both on-site and off-

site direct discharges from CERCLA sites are required to meet the substantive requirements of

NPDES permits.   (On-site actions are exempt from actually acquiring the permit.)  Under RCRA.,

hazardous waste facilities that have point source discharges are not exempt from NPDES permit

requirements.  Run-on and run-off controls are also required at active facilities to control nonpoint

source contributions to surface waters.  EPA is currently evaluating the need to control nonpoint

source contributions from "interim status" facilities that have been shut down, but are still

contaminating sediments through stormwater runoff or leaching.                   •   .  ,       .

       Section 319 of CWA provides an overall framework for States to prevent and manage all

nonpoint sources of water pollution.  Under Section 319, States are required to complete a

comprehensive assessment of their navigable waters and evaluate the effects of all categories and

sources of nonpoint pollutants. In its Nonpoint Source Guidance (U.S. EPA,  1987a), EPA

encouraged States to provide information regarding those waters not meeting beneficial uses,


funds totaled $38 million in fiscal year 1990, $51
including those not meeting designated uses due tc contaminated sediments.  The guidance classified

contaminated sediments as a nonpoint source polli tion category.  EPA's Section 319 grant guidance

makes contaminated sediment prevention and, in some limited instances, remediation efforts eligible '

for funding.  Section 319 gives EPA authority to  iward grant funds to States as  an incentive for

nonpoint source control, including control of sour :es of sediment contamination. Section 319 grant
       million hi fiscal year 1991, $52.5 million in fiscal
year 1992, and $50 million in fiscal year 1993.  Section 319 does not provide any Federal authority

to regulate nonpoint sources, however.  State nonpoint source management programs are to  include

plans for preventing and managing nonpoint sources of pollution by encouraging, assisting, or
requiring the implementation of best management
       practices (BMPs).  At their own discretion, States
can enact legislation or regulations for control of nonpoint sources.  The development of TMDLs

under Section 303 of CWA is a regulatory tool fcr addressing nonpoint sources as well as point

sources; States are increasingly including nonpoii t sources in their TMDLs.
        In 1992, EPA set aside $800,000 to fund
       demonstration of urban and agricultural BMPs
 specifically designed to remove sediment contaminants in stormwater runoff.  Once the results of

 these demonstration projects are available, EPA will publicize their effectiveness. When EPA

 develops the Site Inventory, the nonpoint source jrogram can work with the States to target sites for
 grants and technical assistance to prevent further
       sediment contamination.
        Other EPA programs contribute signi

 Section 314 of CWA, the Clean Lakes Program

 assessment, study and restoration of lakes.  EPA

 Agreements with participating States.  Many
ignificahtly to the control of nonpoint sources.  Under

       >rovides grants to States for the classification,

       has entered into over 400 Clean Lakes Cooperative

           agreements have funded nonpoint source
of these

 controls to prevent pollutants originating in the watershed from entering lakes. Several projects have

 used storm water retrofitting to control urban runoff, and others have used wetlands to buffer and

 filter pollutants from agricultural and silvicultural areas.  The Implementation Memorandum for the

 fiscal year 1990 Clean Lakes Program encourages States to integrate their Clean Lakes projects with

 Section 319 nonpoint source programs for targeted watershed demonstration projects. This guidance

 memorandum also mentions that USDA PL 83-566 projects may offer assistance in watersheds

 significantly affected by agricultural nonpoint source pollution.  As in the case of the Section 319

 program, EPA's Site Inventory will be used to target watersheds for Clean Lakes grants to prevent

 further sediment contamination. Funding for BMPs effective in removing sediment contaminants can

 be provided to these Clean Lakes sites.

       EPA's NEP, authorized under CWA Section 320, is a national demonstration program that

 uses a comprehensive watershed management approach to address water quality and habitat problems

 in designated estuaries on the Atlantic, Gulf, and Pacific coasts and in the Caribbean. Under the Act,

 management conferences,  consisting of Federal, State, and local agencies, scientists, citizens,

 industry, and environmental groups, develop Comprehensive Conservation and Management  Plans

 (CCMPs) within five years of NEP designation.  These plans address toxic and pathogen

contamination, nutrient overenrichment, habitat loss or alteration, impacts to living resources, and

other problems from point and nonpoint source pollution and physical alterations (e.g., dredging and

construction).  A number of the NEP watersheds have identified contaminated sediments as a problem

and are developing action  plans to reduce or eliminate the problem through point and nonpoint source


       EPA expects States to use the Site Invent >ry to assist in identifying both estuaries that should

be nominated for NEP designation and controls for nonpoint sources of contamination to sediments.

The inventory may also provide information to determine whether already designated estuaries should

have more attention focused on nonpoint or point source controls for contaminated sediments. If EPA

determines that additional NEP management conferences are to be convened, OW's OCPD intends to
advise States that nomination packages for new p
•ograms should include identification of sites that are
included in the Site Inventory. EPA will also advise States that the Agency intends to use this

information in evaluating the nominations.

        Another important nonpoint source control program is the coastal nonpoint source control

program established by the Coastal Zone Act Rez uthorization Amendments of 1990 (CZARA).

Under CZARA, States must implement programs in conformity with EPA guidance.  EPA's guidance

specifies management measures for nonpoint sou 'ce categories located within the coastal area. These

management measures are considered best available technology for agricultural, silvicultural, urban,
hydromodification, and marina nonpoint sources.
 In addition, CZARA requires States to adopt
legally enforceable policies and mechanisms for controlling nonpoint sources in those coastal areas.

Failure by the States to adopt approvable prograiis by the 1995 statutory deadline will result in

reductions in Coastal Zone Management Act (CZMA) and CWA grants to violating States, beginning

in 1996.  As data become available, OW will pu )licize the measures that are found to be most

effective for controlling sediment contaminants a id will try to ensure that these measures are

incorporated into States' coastal nonpoint source programs as part of EPA's and NOAA's approval



        States play a key role in controlling point and nonpoint source pollution. In order for controls

to be focused on sediment quality, the States can, as necessary, adopt sediment quality criteria as part

of their water quality standards or use EPA's sediment bioassays to interpret their narrative standards

of "no toxics in toxic amounts."  Most States are authorized to issue NPDES permits to control point

sources, so EPA will work closely with the States to ensure implementation of water quality-based

limits to protect sediment quality. Guidance will be developed and workshops will be held! to train

States how to use EPA-consistent sediment testing methods, how to develop permit limits to protect

sediment quality,  and how to monitor for compliance with these limits.

        In the nonpoint source area, EPA will encourage the States to modify the Model St^te Act for

erosion and sediment control to include consideration of toxics.  This Act, developed for the Council

of State Governments, is currently directed only at "clean sediment"  problems.  EPA will also

encourage the States  to develop their own legislation, based on the Model State Act, for preventing

sediment contamination. EPA's nonpoint source program will continue to coordinate with USDA,

USFS, and Bureau of Reclamation as in the past, and will include consideration of contaminated

sediment as well as clean sediment issues.  EPA will also seek to ensure that coordination With

Mexico and Canada to control point and nonpoint sources of pollution will address prevention of

contaminated sediment.  An important means  of coordinating with Canada will be through revising

the Great Lakes Water Quality Agreement (GLWQA).

the Rivers and Harbors Act, TSGA, and the Oil I

contaminated to levels that cause ecological harm

       EPA may take actions directed at remedu tion of contaminated sediments under the

Comprehensive Emergency Response, Compensa ion and Liability Act (CERCLA), RCRA, CWA,
                                              'ollution Act of 1990. Where sediments are
                                              or pose a risk to human health, EPA will strive to

implement whatever remediation strategy will mo 5t effectively reduce the risk.  In certain

circumstances, the best strategy will be to implen exit pollution prevention measures as well as point

and nonpoint source controls to allow natural recovery processes such as biodegradation, chemical

degradation, and the deposition of clean sediment; to diminish risks associated with the sites.  In other

cases, active remediation may be necessary.  EP/ L will not proceed with an active clean-up, however,

when implementation of the remedial alternative would cause more environmental harm than leaving

the contaminants in place.

       EPA will develop criteria for deciding wl ether natural recovery is  the preferred remedial

alternative on a site-specific basis, using such factors as: the specific contaminants present and their

associated risks; the designated uses unpaired during recovery; the size of the affected area;  the

feasibility of remediation; site hydrodynamics, including the extent of downstream transport; the time

required for natural recovery; and the liability ass ociated with active remediation.  The specific

contaminants present in sediment affect the type (ecological versus human health) and severity (acute

versus chronic toxicity) of the impact.  Natural recovery is not acceptable where contamination poses

severe and substantial risks to aquatic life, wildlife, and human health.  In  addition, natural recovery

may not be the method of choice for contaminants that biodegrade or transform into more persistent,

toxic compounds.

       Identification of the designated uses impaired by sediment contamination will allow the risk.

manager to evaluate the tradeoffs involved with short-term, active remediation compared to long-term,

natural recovery. The size of the contaminated area is a key parameter to be considered.

Widespread,  low levels of contaminants favor natural recovery while geographically limited areas

containing high levels of contaminants favor active remediation.  Technology also plays a part in the

use of natural recovery.  If it is technically impractical to remediate a site, then natural recovery is

the only option.  Site hydrodynamics affect the decision because sediments must be stable for clean
          :                                                                           I
sediment burial to be effective.  If contaminated sediments are continually being transported into more

critical habitats or being spread over a wider area where remediation is no longer technically or

economically feasible,  active remediation should be performed.  In some situations, combinations of

active remediation and natural recovery may be possible. For example, if fairly discrete areas of

contamination are removed, the rest of a site may be left alone for natural recoveiy.  Alternatively,

limited capping of contaminated sediment with clean material may be done in anticipation of further

natural deposition of clean sediment. Before initiating any remediation, active or natural, it is

important that point and nonpoint sources of contamination be controlled.                ;

        The amount of time needed for natural recovery will vary from site to site, but will generally

be on the order of one or more decades if clean sediment burial, biodegradation, and chemical

degradation proceed at average rates.  Natural recovery times will obviously be shortened if the area

of contamination is small in size, sediment burial rates are high, and all the major sources of

contamination are controlled.  However, natural resource damage provisions in various environmental

statutes may discourage the use of strategies employing natural recovery.  The lengthier processes of

natural recovery increase the number of years over which damage to natural resources can occur,

thereby making immediate clean-up a more attrac tive alternative.  Responsible parties may wish to
solve the problem immediately rather than be liable for additional years of resource damages.

        The goal of all natural recovery and actrve remediation projects is to achieve sediments that

pose no acute or chronic toxicity to aquatic life a id no significant risk to wildlife and human
consumers of fish.  It should be noted, however,

standards for remediation projects. The decision

must incorporate a number of site-specific factors

waterbody, the ecology, geology, and hydrology
                                               that the Strategy does not mandate specific clean-up

                                               on an appropriate clean-up level for any project
                                                 These include the beneficial uses of the
methodology for listing sites in priority order for
                                              of the site, technical feasibility, risks that may be

posed by the various treatment or disposal options, the benefits of remediation, and economic


       The ranking system being developed for the Site Inventory will provide an analytical
                                               remediation and pollution prevention, and will play
a significant role in targeting sites for source com rols to protect sediment quality.  Each remediation

program will then set its own priorities for the sites in the Site Inventory based on statutory and
regulatory constraints.  A program decision to se

site will require the detailed data gathered during
                                              ect natural recovery or active remediation for any

                                              a remedial investigation/feasibility study of the
environmental impacts, cost-effectiveness, and technical achievability of remedial alternatives.
       EPA is committed to using all potential enforcement authorities to obtain sediment

remediation. CERCLA, RCRA, CWA, the Rivers and Harbors Act of 1899, TSCA, and the Oil

Pollution Act of 1990 contain provisions that, unc er the appropriate circumstances, can compel
responsible parties to contribute to the clean-up o
                                              : contaminated sediments.  Depending on the

particular statute, EPA can use these authorities to: (1) compel parties to clean up the sites jthey have

contaminated; (2) recover costs from responsible parties for EPA-performed clean-ups; and (3)

coordinate with natural resource trustees to seek restitution from responsible parties for natural

resource damages. The Agency's ability to obtain sediment remediation within a reasonable time

frame may be enhanced through the coordinated use of contractor listing (40 CFR Part 15);

debarment and suspension (40 CFR Part 32), State or local laws and regulations, and the Agency's

criminal enforcement authority.

        To date EPA has successfully used only Section 309(b) of CWA and Section 106 of CERCLA

in conjunction with its violating facility listing authority to require clean-ups at contaminated sediment

sites. In addition, settlements of CWA unauthorized discharge enforcement cases have incorporated

sediment clean-up as part of the injunctive relief.  Under this Contaminated Sediment Management

Strategy, EPA intends to use these statutes and the other authorities described  in this section to

require sediment remediation by responsible parties.  Once EPA develops the Site and Source

Inventories, this information will assist in the targeting -of enforcement actions for sediment

remediation. The Agency-wide consistent tests will be used to identify areas needing remediation and

to help provide clean-up goals for enforcement-based remediation. The following sections describe

the EPA remedial and enforcement programs that will be used for contaminated sediment clean-up.

        Under CERCLA, OERR has established a comprehensive program for identifying,

 investigating, and remediating hazardous waste sites.  Unless focused clean-up activities that require

 immediate attention take place under CERCLA's removal program, sites must be placed on the

                                              70                                   !

National Priorities List (NPL) to be eligible for remedial funding. The CERCLA process for

assessing sites involves a tiered system for evaluation that is used to screen out sites that do not

warrant placement on the NPL.  Before a site is Jdded to the NPL, it is evaluated using the Hazard

                                         at least 28.5 is
Ranking System (HRS); a resultant score of

range between 0 and 100).
        Local governments, States, and EPA Reg

evaluated for threats to public health and the environment

sediments will be added to the Site Inventory.  Si

and that are not currently under the jurisdiction ol

for evaluation under CERCLA.             ;
site to human health and the environment, and th<
is needed to support listing (HRS scores
                                             onal offices typically identify sites that should be

                                                    .  Superfund sites with contaminated

                                             es that are already identified in the Site Inventory

                                             " another program (e.g., RCRA) may be appropriate
       Under CERCLA, EPA carries out a detal ed analysis of risks posed by contaminants at the
                                              feasibility of various response action alternatives to
reduce risk. The Risk Assessment Guidance for Superfund (RAGS), (U.S. EPA, 1989a) provides a

framework for the assessment of human health and environmental impacts. Various EPA

publications, including guidance in RAGS, Ecological Updates, and fact sheets, are used to develop

assessments that are presented as a part of the Remedial Investigation/Feasibility Study of a CERCLA

site. The process is not designed specifically for sediments, but rather for the purpose of assessing all

exposure routes from contamination at CERCLA sites.
       The CERCLA program intends to use the

Tiered Testing Framework in the Remedial Invest

intends to provide guidance on the use of the testing
                                             EPA-consistent sediment testing methods of the

                                             :gation/Feasibility Study stage of analysis. OERR

                                               methods to promote consistency of these methods

within the CERCLA process. Within one year after the EPA standard protocols for acute sediment

toxicity testing are completed, the CERCLA program will develop guidance describing the iuse of the

EPA sediment testing methods.  CERCLA program guidance on the use of sediment quality criteria

will be issued following completion of the users manual for the criteria.

       An evaluation of all CERCLA Record of Decisions (RODs) from 1982 through 1992

identified 335 sites where contaminated sediments were reported.  Of these sites, less than half were

addressed through remediation.  Given that there are approximately 1300 sites for which R0Ds have

been written, this finding indicates that sediment contamination might be reported, even if it is minor,

for approximately 30% of the sites evaluated.
        CERCLA provides one of the most comprehensive authorities available to EPA to obtain

sediment clean-up, reimbursement of EPA clean-up costs, and compensation to natural resource

trustees for damages to natural resources affected by contaminated sediments.  Once EPA determines

that there is a release, or substantial threat of a release, of hazardous substances to the environment,

EPA may undertake response action necessary to protect public health and the environment and, if

there is imminent and substantial endangerment to public health or welfare or the environment,

compel the potentially responsible parties (PRPs) to undertake the clean-up.  Liability under CERCLA

is "strict," meaning the responsible parties are liable without fault, often "joint and several," meaning

that they are collectively responsible for the entire cost of the clean-up, and "retroactive," meaning

that liability exists for disposal that occurred prior to CERCLA's enactment.  If the contamination

resulted from a Federally permitted release, cost recovery is not available. CERCLA defines

 "hazardous substances" and lists those substances covered by the statute.  Removal actions and

enforcement actions can be brought at both National Priority List (NPL) and non-NPL sites.

                                              72                                 ;

       Section 106 of CERCLA authorizes the U.S. Attorney General to secure such relief as is

necessary to abate an imminent and substantial th -eat to the public health or welfare,  or the

environment, because of an actual or threatened release of a hazardous substance.  A judicial action

or issuance of an order under Section 106 to compel responsible parties to perform clean-ups may be

appropriate.  Failure or  refusal to comply with the Section 106 order, without sufficient cause,
subjects responsible parties to treble damages and
 penalties up to $25,000 a day.
       Section 107 of CERCLA provides that the U.S. may recover all costs of CERCLA response

actions, when not inconsistent with the National Contingency Plan, as well as damages for injury to
natural resources and costs of health assessments.
facilities from which there is a release or threatened release, or who were involved with disposal,
treatment, or transport of hazardous substances.
 Liable parties are persons who owned or operated
Section 107(j) provides that EPA cannot recover
response costs or damages resulting from a Fedeially permitted release under Section 107. CERCLA

Federally permitted releases include three types of releases from point sources with NPDES permits,

as set out in Section 101(10)(A)-(C).  Natural resource damages resulting from sediment

contamination may be recovered only by the U.Sl, State, local and foreign governments, and Indian

tribes and their members, as provided hi CERCIJA Section 101(16).  Natural resource trustees are

routinely notified of any CERCLA clean-up activity, pursuant to Section 122(j) of CERCLA, and are

encouraged to participate in negotiations where natural resources under their trust may be affected.

The natural resources trustees' participation in setlement negotiations is important to PRPs seeking

release from liability. The natural resource trustees can grant a "covenant not to sue" if the PRP
agrees to undertake appropriate actions to protect
 and restore the damaged natural resources.

       Section 122 of CERCLA authorizes EPA to enter into settlements with responsible parties to

perform response actions. Settlements negotiated under this authority generally will reflect the

strength of evidence of liability, the strength of responsible party defenses, and public interest and

considerations. Settlements may include compensation for, or remediation of, natural resources

damages if the Department of Interior, the State, or another designated natural resources trustee is a

party to the settlement.


       Subtitle C of RCRA provides EPA with the authority to assess whether releases from a

hazardous waste treatment, storage, or .disposal facility have contaminated sediments and to require

corrective action, including possible remediation, if contamination is discovered.  RCRA corrective

action authorities apply to all releases of hazardous waste or constituents from any solid waste

management unit, regardless of when the waste was placed in the unit (Section 3004(u)).  EPA

assesses hazardous waste facilities that have RCRA permits.  These assessments are called "RCRA

facility assessments" (RFAs).  If an RFA suggests that a release has occurred, hazardous waste permit

writers can prepare permit conditions or enforcement orders requiring facility operators or owners to

conduct extensive RCRA facility investigations (RFIs) to determine the extent of any contamination.

If the RFI indicates that solid waste management units at the facility caused contamination, the permit

can be modified to require sediment remediation.  EPA also has enforcement authority to, order

owners and operators of "interim status" facilities to conduct corrective action, including sediment

remediation.  "Interim status" facilities are those that qualified to handle hazardous waste'prior to the

issuance of a final permit.

       Section 3004(v) of RCRA authorizes EPA
      to establish standards requiring corrective action
for releases from a facility that have migrated beyond the boundaries of a facility (e.g., offsite

sediments), where necessary, to protect human health or the environment, unless the facility's owner

or operator demonstrates that he was unable to obtain access to the contaminated areas.
       Section 3008(h) of RCRA authorizes EPA

take corrective action, or such other response measures

the environment from a release of hazardous wast
       To date several facilities have been

to consent orders entered into under 3008(h) and
        Section 7003 of RCRA authorizes EPA to
      to issue orders requiring interim status facilities to

           that are necessary, to protect human health or
required to investigate contaminated sediments, pursuant

      )ermit conditions issued under 3004(u) and 3004(v).
      bring suit against persons who contributed to past
or present handling, storage, treatment, transportation, or disposal of any solid or hazardous waste

that may present an imminent and substantial threat to human health or the environment.  EPA may

further order such persons to take other actions as; may be necessary to mitigate the threat;  This

authority has already been used to enter into consent orders whereby the facility has agreed to

investigate contaminated sediments.

        The Office of Solid Waste (OSW) and OWPE currently use the RCRA National Corrective

Action Prioritization System (NCAPS) to prioritise facilities for corrective action. They will use the

information in the Site Inventory to supplement the information used for prioritization.  For facilities

which have not yet been ranked with NCAPS, and where it is clear that releases from a RCRA

facility have caused the sediment contamination identified in the Site Inventory, such contamination


will be scored as an "observed release" for the surface water route under the NCAPS.  An observed

release score will often lead to the classification of a facility as high priority for corrective action.

For facilities that have already received an NCAPS score, the information from the Site Inventory can

be used to elevate their overall priority.

       In fiscal year 1994, when the sediment bioassays and chemical criteria for Agency-wide use

become available, OSW has also agreed to include them as an addendum to the RFI guidance.  At

present, the RFI guidance warns about potential sediment quality problems but does not recommend

specific tests to evaluate the ecological and human health risks posed by contaminated sediments.

       As a benchmark for the scope and magnitude of the above-described action items| RCRA

remediation applies to several thousand sites across the country.


       Section 115 of CWA directs EPA to identify the location of in-place pollutants with an

emphasis on toxic pollutants in harbors and navigable  waterways.  EPA is authorized, acting through

the COE, to make arrangements for the removal and disposal of such materials from critical port and

harbor areas.  The $15 million authorized by this Section has only been appropriated once, and all the

funds were spent in the 1970s.
       If new appropriations are made for Section 115, EPA will target the top priority harbors in

the Site Inventory for Section 115 remediation. The Agency-wide consistent sediment tests will be

used to select clean-up goals and monitor the effectiveness of remedial actions.  Section il5 funds


will be effectively used by "piggybacking" the

maintenance projects.  "Piggybacking" projects wi

and demobilization and possibly with some sediment

between EPA and the COE will be required to
                                           remediation project onto the COE's navigation

                                               1 save the costs associated with dredge mobilization

                                                 testing. A formalized system of coordination

                                            fac litate Section 115 and "piggybacking" projects.
                                             of a
       Section 309 of CWA authorizes EPA to

including permanent or temporary injunction, for

violation of permit limits. Given establishment

contaminated sediment, both Administrative orders

of the removal of illegally discharged pollutants.

undertake sediment pollution removal as an envi

penalty.  Environmentally beneficial expenditures

economic benefit penalties.  Even if the sediment

the facility may be willing to clean up in mitigatiojn

possible liability under the other statutes
        Wastewater discharges are typically regulated by

 wastewater discharges and nonpoint source runoff that

 however, are regulated under Section 311, except

 CWA authorizes the President to act to remove, or

 discharge of oil or hazardous substances into navigable

 contiguous zone, or that may affect natural resources

 address many of the pollutants which have accumulated
    commence civil action for appropriate relief,

     e]numerated violations, including any discharges in

        link between the unpermitted discharge and the

       and civil suits can require remediation in the form

       iiforcement actions can also encourage polluters to

environmentally beneficial expenditure in lieu of a civil

      nay be used in conjunction with, but not hi lieu of,

      xmtamination is the result of permitted discharges,

        of a portion of the civil penalties or to limit
                                                      Section 402 of CWA. Pollutants found in

                                                   have been designated as hazardous substances;,

                                               for Federally permitted discharges. Section 311 of

                                                 arrange for the removal of, an actual or threatened

                                               jable waters, adjoining shorelines or waters of the

                                                   of the U.S.  Section 311 can be utilized to

                                                     in sediments.

       Section 504 provides a possibility for injunctive relief if it can be shown that polluted

sediments present an imminent and substantial endangerment to the health of persons, or the

livelihoods of persons, whose employment might be affected by contaminated sediments.

Enforcement actions under Section 504 can compel responsible parties to clean up contaminated

sediment even if the contamination resulted from permitted discharges.

       OW has developed guidance on how to use CWA enforcement authorities to obtain sediment

remediation.  Training workshops are also being held in the Regional EPA offices to teach

enforcement staffs how to pursue cases of their own.                                  ,


       Unlike CERCLA and RCRA, which require clean-up of hazardous releases no matter when

they occurred, TSCA does not explicitly require clean-up of regulated substances other than

polychlorinated biphenyls (PCBs) if they were discharged before the effective date of the TSCA.

regulations requiring such clean-up.  Regardless of the date of contamination, any party that removes

or handles sediments containing TSCA-regulated substances must  follow the regulations promulgated

under TSCA for the handling of these substances.

       PCB spills that occurred before the effective date of TSCA are subject to regulation under

TSCA.  The current draft Agency position would allow EPA Regional Administrators discretion on a

case-by-case basis to assert TSCA authority over such sites.  EPA Regional Administrators can

approve alternatives to incineration or disposal in

contaminated with PCBs if the disposal is adequately
       The Rivers and Harbors Act of 1899 i

Department of Justice (DOJ), may use to bring

contamination.  First, the Act provides for criminal

responsible for obstructing the navigable capacity

condition of the channel of such waterway. Second

relief in response to discharges of "refuse matter

water. Courts have broadly interpreted this Act

with a permit under CWA.  The injunctive relief

the removal of the obstruction or the refuse.
        Under CWA Section 311, as amended by
  'SCA-approved facilities for sediments

    protective of human health and the environment.
includes two provisions which the U.S., through the

  enforcement actions to address sediment

      and injunctive relief against anyone who is

    of any water of the U.S. and for altering the

      , the Act provides for criminal and injunctive

     into any navigable water or tributary of a navigable

      prohibit discharges other than those hi compliance

    ivailable under the Act includes the ability to  order
 the Oil Pollution Act of 1990, EPA may require
 responsible parties to clean up contaminated sedir lents resulting from oil spills and discharges. EPA

 may use this authority to obtain sediment remediation whenever appropriate circumstances exist.


       As part of the 1987 amendments to CWA, Section 118(c) established the ARCS prpgram to

assess the extent of sediment contamination hi the Great Lakes and to demonstrate bench- and pilot-

scale treatment technologies for contaminated sediment. The Great Lakes Critical Programs Act of

1990 extended the ARCS program from 5 to 6 years, requiring a report to Congress in December

1993.  The ARCS program is the only EPA effort specifically directed at developing innovative

treatment technologies for contaminated sediment. The Superfund Innovative Technology Evaluation

(SITE) program does some investigations into sediment remedial techniques, but its  resources must be

used to evaluate clean-up techniques for all contaminated media.

       WRDA requires EPA and the Department of the Army to establish a National Contaminated

Sediment Task Force with Federal, State, and private and public interest groups represented. This

WRDA Task Force is charged with a number of responsibilities, including: (1) developing guidelines

for the restoration of contaminated sediment; and (2) evaluating the research and development of

sediment restoration methods, practices, and technologies. This WRDA  Task Force will provide an

excellent mechanism for promoting the use of innovative technologies in all Federal, State and private

remediation projects. Through the WRDA Task Force, EPA can share the results of the ARCS and

SITE programs with other interested parties and can learn about the remedial technology research

performed by the other groups.
       The WRDA Task Force also can assist remediation programs by reviewing and assessing the

means and methods for locating and constructing permanent, cost-effective, long-term disposal sites

for contaminated dredged material, as required by the statute.  At the present time, one of the most


economical ways to remediate contaminated sediment is to dredge it and dispose of it in confined

disposal facilities (CDFs).  As current CDFs are tjeing filled to capacity, new, long- term disposal

sites are needed by both remediation programs and navigational channel maintenance programs.
       Facilities of the Department of Defense (DOD) and DOE have on-site sediments contaminated

with radionuclides, PCBs, metals, and other toxics. As part of this Strategy, EPA will work with

these agencies on assessing their sediment quality problems and remediating the sites to appropriate

clean-up levels.  DOE has already entered into "Federal facility agreements" with several States and

EPA to coordinate implementation of remedial act ons at their facilities.
       EPA will also coordinate with the Federal
Interagency Sedimentation Project.  Under this
project, USGS, the COE, BLM, USFS, TVA, and USDA have initiated a joint effort to investigate

the physical properties of sediments. These agencies are conducting research to determine the degree

to which sediments trap contaminants and the tuiKiframe for natural recovery.

       EPA will continue to coordinate closely with the COE on remediation. Prior to passage of

the Water Resources Development Act of 1990, the COE did not have authority to remediate

contaminated sediments on its own initiative. Thioughout the 1980's, however, the COE was

involved in many clean-up efforts under interagenW agreements with EPA (New Bedford Harbor,

Commencement Bay, Waukegan Harbor, Sheboygan Harbor, Marathon Battery Site, Upper Hudson

River, and others).  WRDA authorized the COE to initiate "clean-up" dredging adjacent to and
outside authorized Federal navigation channels as
long as the projects are cost-shared with a non-

Federal sponsor. The Federal Facilities Compliance Act requires government agencies, including the

COE, to meet the same standards for their hazardous waste management as nongovernmental

owners/operators.  The COE is therefore concerned about implementing this new authority because of

questions of liability.  The COE does not want to dredge contaminated sediments outside of

navigational boundaries without having identified responsible parties for cost recovery. EPA and the

WRDA Contaminated Sediment Task Force intend to examine liability issues in sediment remediation

and try to identify ways that the COE can implement remedial actions without assuming total liability

for the clean-up.

       Approximately 400 million cubic yards of

and waterways each year (Lee, 1992).  Of this

material is disposed in the ocean at sites regulated

dredged material is discharged in open water sites,

uses regulated under CWA, as well as upland (Lee
    sediment are dredged from the Nation's harbors

 ampunt, some 60 million cubic yards of dredged

    under MPRSA (Lee,  1992).  The remaining

     at confined disposal facilities, and for beneficial

    , 1992).
       The COE, as the Federal agency designated to maintain navigable waters, conducts a majority

of this dredging and disposal under its Congressionally authorized civil works program (Moore and

Wilson, 1992). The balance of the dredging and disposal is conducted by a number of local public
and private entities.  In either case, the disposal is
     subject to a regulatory program administered by
the COE under the above statutes.  EPA shares the responsibility of managing dredged material,

principally in the development of the environmental criteria by which disposal sites are selected and

proposed discharges are evaluated, and in the exercise of its environmental oversight authority.

Dredged material management activities are also subject to NEPA, as well as a number of other laws,

executive orders, and State and  local regulations.
        Estimates by the COE indicate that a sma 1

 material disposed, approximately three to 12 mi

 handling and/or treatment is required (Lee,  1992)

 EPA and COE efforts affect the assessment and

 otherwise.  The dredged material management portion
     percentage of the total annual volume of dredged

million cubic yards, is contaminated such that special

    .  A number of ongoing and recently completed

   management of dredged material, contaminated and

         of this Strategy outlines the actions of OW, in

cooperation with the COB, to continue consistent implementation of the various statutes and

regulations governing dredged material management in an environmentally sound manner.


       MPRSA is the primary Federal statute governing the transportation of dredged material to the

ocean for the purpose of disposal. Section 102 of MPRSA requires EPA, in consultation with the

COE, to develop environmental criteria that must be met before any proposed ocean disposal activity

is allowed to proceed (40 CFR 227).  In 1991, EPA and the COE published a revised guidzince

document entitled Evaluation of Dredged Material Proposed for Ocean Disposal - Testing Manual

(U.S. EPA and COE, 1991), known as the Green Book or the Ocean Testing Manual, which

describes the technical procedures for determining the potential ecological impacts of dredged material

disposal in the ocean.  The 1991 publication, which revises  and replaces the 1977 edition, describes

sample collection, handling and storage, physical and chemical  characterization methodologies for

sediment and water, and acute bioassay and bioaccumulation test procedures.  Tests are conducted in

a tiered-testing framework: each successive tier provides increasing investigative intensity until a

determination of environmental suitability of material proposed for disposal can be made.

       The Ocean Testing Manual and associated regional implementation manuals reflect  the

significant improvements hi the state-of-the-practice of toxicology and environmental assessment since

publication of the 1977 version. The manual calls for the use of more appropriate and sensitive

organisms for toxicity and bioaccumulation testing to assess effects resulting from the complex

mixture of chemicals present in most dredged material.  An unproved numerical mixing model for

predicting water quality compliance at the disposal site is also included in the manual.

                                              84                                   :

        A recent review of the 1991 Ocean Testing Manual by SAB indicated that a number of further
improvements should be incorporated into the manual (U.S. EPA, 1992e).  Among these were the
recommendations that EPA should:  1) revise the
  tiered testing approach to further emphasize reducing
uncertainty as the level of tiered testing increases; 2) provide improved guidance on the interpretation

of the bioaccumulation test results; 3) clarify how sediment quality criteria will be incorporated into

the tiered-testing approach; 4) require testing of ippropriately sensitive species; and 5) include

appropriately sensitive test species measures of chronic sublethal effects.

        EPA and the COE continue to conduct intensive research and development programs to

further improve the assessment capability and address concerns of the SAB.  The EPA consistent
sediment testing methods are already being used
  in the dredged material testing programs. Additional
guidance is also being developed on the translation of tissue residue information into ecological and

human health risks.  As described in the Assessment Section, the approach for using sediment quality

criteria in Tier II will also be decided upon and included in revisions of the Ocean Dumping Rule and

will be included as appropriate hi future revisions of the Ocean Testing Manual.  Likewise, improved
QA/QC guidance for sample collection, storage,
  and manipulation of sediments for chemical analyses
and bioassays is being developed and will accompany the dredged material testing manuals for bom

ocean and inland waters.
       EPA will also improve a number of aspects

process.  EPA, in consultation with the COE, is

regarding the transportation and disposal of dredged

technical and procedural aspects to reflect program

the Site and Source Inventories, under development
     of the dredged material disposal decision-making

  currently in the process of revising regulations

     material in the ocean in order to update its

     experience since the last revisions.  In addition,

     as a part of this Strategy, may be useful in Tier I

(evaluation of existing information) of the Ocean Testing Manual to help identify potential areas of

contamination and chemicals of concern to evaluate. EPA is also developing guidance regarding the

use of sediment quality criteria in dredged material evaluations conducted under MPRSA.


       Section 404 of CWA is the primary statute governing the discharge of dredged material into

waters of the United States.  The Section 404(b)(l) Guidelines (40 CFR 230) are the substantive

environmental criteria by which these proposed discharges are evaluated.  EPA and the COE are

currently developing a document entitled Evaluation of Dredged Material Proposed for Discharge in

Inland and Near Coastal Waters - Testing Manual (known as the Inland Testing Manual), (U.S. EPA

and the COE, 1993).  The document will provide national guidance on evaluating potential

contaminant-related environmental impacts of proposed discharges of dredged material into waters of

the United States.  The Inland Testing Manual will utilize a tiered testing approach similar;to that

employed in the Ocean Testing Manual and will incorporate both the SAB recommendations for

improvements to the Ocean Testing Manual and additional comments provided by SAB after its

review of the draft Inland Testing Manual. The Inland Testing Manual describes the procedures for

evaluating dredged material  required by the Guidelines, the tests to implement them,  collection and

preservation procedures, statistical procedures, interpretive guidance, and supporting references.
        To the extent practicable, OW and the COE will maintain consistency between the testing

 procedures and manuals used under CWA and MPRSA to facilitate the evaluation of dredged material

 disposal alternatives. The draft Inland Testing Manual revises and updates with a number of technical

 improvements the COE's 1976 interim testing manual for inland waters.  As with ocean dumping


activities under MPRSA, the Site and Source Inventories may also be useful in Tier I (evaluation of

existing information) of the Inland Testing Mamu 1 to help identify potential areas of contamination
and chemicals of concern to evaluate. OW will a
                                             so develop guidance regarding the use of sediment
quality criteria in dredged material evaluations conducted under CWA.  EPA expects to publish both

the Inland Testing Manual and the guidance on the use of sediment quality criteria in dredged material

evaluations in 1994.
       OW is also developing a proposed rule to
                                             revise the testing provisions of the Guidelines by
providing for comparisons between dredged material proposed for discharge and reference sediment

(U.S. EPA, 1993d).  Through these revisions, EPA hopes to make a technical improvement in the

testing provisions and to make dredged material testing more consistent with that conducted under

MPRSA, which currently employs a reference sediment approach.

       In 1992, OW, OFA, and the COE published a guidance document entitled Evaluating

Environmental Effects of Dredged Material Management Alternatives - A Technical Framework (U.S.
                                           ides euic
EPA and the COE, 1992). The document provides guidance for all appropriate testing, evaluation,

and management activities.  It is a framework for evaluating the potential environmental effects of

proposed discharges of dredged material in open water and in confined disposal sites, as well as the

possibility of using dredged material for beneficial purposes, such as beach enrichment. The

document is designed to facilitate environmental evaluations that meet the substantive and procedural
requirements of NEPA, MPRSA, and CWA, and
                                             to enhance interagency coordination and consistency

in evaluating management alternatives. The document incorporates the concepts of, and makes

references to the details in, the dredged material assessment manuals discussed above.

       Specifically, this Framework Document discusses the regulatory requirements of applicable

statutes, the equipment and techniques employed in dredging and disposal, the general framework in

which alternatives are evaluated, and the more detailed assessments for evaluating open water and

confined disposal site options and beneficial use alternatives. The analysis of each of these major

alternatives includes a discussion of site characteristics, physical effects or suitability of dredged

material, site capacity, contaminant pathways of concern or site suitability, and management actions

and contaminant control measures.  The Framework Document also contains a brief section on the

selection of dredged material management alternatives, which both agencies plan to expand in a

future, Phase n, guidance document.  EPA and the COE expect the Phase II guidance document to

discuss approaches for comparing economic and environmental cost and benefits among

environmentally acceptable alternatives, and to present a number of different authorities that could be

used to fund more costly, environmentally preferable alternatives.

        OW and the COE are developing a comprehensive ocean disposal site designation,

 management, and monitoring guidance document.  Although there are a number of reference

 documents on the three topics, the joint EPA and COE guidance will integrate and update all aspects

 of site selection and management. WRDA directs that all ocean disposal sites designated [prior to

 January 1, 1995 shall have site management plans in place by 1997, and that no site shall be

 designated after January 1, 1995 without such management plans.



       CERCLA, TSCA, and RCRA may all affect the management of dredged material, as

discussed below.
       CERCLA's program of identifying and

dredged material management if contaminated sediments

Contaminated sediment remedial actions conducted

of the U.S. within the CERCLA site do not requi

but must nonetheless meet the substantive environmental

Starfield, 1990; Edgar, 1985).
                                          remediating hazardous substance sites may affect

                                                  are present at the site (40 CFR 302.4).

                                             under CERCLA that involve discharges to waters

                                            re CWA Section 404 or any other Federal permit,

                                                  standards of the applicable laws (Winer and
       TSCA includes special management provisions for handling material containing PCBs (40

CFR 721).  TSCA prescribes disposal by
placement in an approved chemical waste landfill.

Regional Administrator if contaminated sediments
ion that complies with 40 CFR §761.70 and
                                             or by an alternate method that is approved by a

                                             containing PCB concentrations of 50 ppm or
greater were to be dredged.  Sediments containing PCBs hi these concentrations are typically not

dredged for navigational purposes (Engler, 1992),
       Some concern has been raised with regarc
                                             to the potential regulation of dredged sediments as
hazardous waste. Hazardous waste management requirements under RCRA Subtitle C apply to "solid

wastes" (i.e., materials that are, or intended to be, discarded) that are listed as hazardous in EPA

regulations or exhibit any of the four hazardous waste characteristics identified in EPA regulations
(RCRA Section 10004(27); 40 CFR § 261.3).  The person who generates a solid waste is responsible

for determining whether it is listed as a hazardous waste, and for determining whether it exhibits a

characteristic, either by using knowledge of the waste or by testing (40 CFR § 262.22). The

knowledge requirement involves applying knowledge of the waste in light of the materials or the

processes used.  The Agency has specified, by regulation, test methods for the four characteristics.

The test for the toxicity characteristic is the Toxicity Characteristic Leaching Procedure (TCLP) (§


       The COE took the position in an April, 1988 Federal Register notice that dredged material

was not a solid waste and therefore not subject to RCRA authorities.  The COE also contended that

the TCLP is technically inappropriate for use on dredged material.  Furthermore, the COE believes

that MPRSA  and CWA provide the appropriate regulatory regimes  for dredged material.

       EPA  has historically taken the position that contaminated sediments are not exempt from the

definition of solid waste (or from the need to determine if the sediments must be managed as

hazardous waste).  The most common  concern has been whether sediments exhibit the toxicity

characteristic as determined by the TCLP. Although current regulations specify the TCLP to be used

as the test for the toxicity characteristic, EPA agrees that the Agency should investigate other test

methods.  OSW is reviewing alternative testing procedures for evaluating sediments. The Agency

believes that it is important to recognize that sediments which were found to be toxic under CWA or

MPRSA testing, have not failed the TCLP in most cases.  Regions should be aware of this when

deciding whether dredged materials need TCLP testing.
        The Agency is also working on a Hazardous Waste Identification Rule (HWIR) which will

address management standards for contaminated media, including sediments. In this rulemaking the

Agency will evaluate, as one proposal, whether adequate Federal oversight of dredged material exists

under CWA and MPRSA such that further management under RCRA is unnecessary to be protective

of human health and the environment.


       EPA and the COE have jointly administer :d the dredged material disposal provisions of CWA

and MPRSA for over 20 years. During that period the two agencies have developed and revised

numerous dredged material management measures, including many of the assessment procedures EPA

is considering for consistent Agency-wide use as a part of this Strategy. EPA is committed to

maintaining this coordination on issues such as dredged material testing and assessment, evaluation of

sediment management alternatives, monitoring of disposal sites, training of field staff, and research

and development activities, in order to continue to ensure that dredged material is managed in an

environmentally sound manner.
        EPA also has a number of Memoranda oi

 define each agency's respective roles and respo
                                   I responsi
 Understanding (MOU) with the'COE: These MOU

ibilities in administering the dredged material
 management programs and outline coordination procedures.  Topics covered by these MOU include

 ocean disposal site management and procedures for handling elevations and enforcement cases under

 CWA. EPA will work with the COE to update existing or develop additional MOU as necessary.
        Likewise, EPA is committed to a dredged material management process, through established

 regulatory mechanisms, that coordinates effectively with other Federal agencies, including USFWS,

                                             Oceanic and Atmospheric Administration, as well as
National Marine Fisheries Service, and National

States.  Consultation requirements, State certification requirements, and public notice procedures are a

few of the dredged material management mechanisms that are available.

prevention strategies. The contaminated sediment
                               10. RESEARCH STRATEGY

       ORD is committed to a comprehensive, ccordinated program of research that will identify

relationships between sediment contaminants and the viability and sustainability of benthic ecosystems,

and ultimately will clarify how such information cm be used to direct source control and pollution
                                            research strategy describes how ORD intends to
support the EPA program offices by undertaking lesearch to develop: 1) methods to assess the

ecological and human health effects of sediment contaminants; 2) chemical-specific sediment quality

criteria; 3) sediment pollution source allocation methods; and 4) sediment clean-up methods for sites

where natural recovery is not appropriate. To complete this research, ORD intends to conduct the

projects discussed below as part of sediment quali y research initiatives in the budgets for fiscal years

1994 and beyond.


       EMAP gathers chemical and biological

EMAP sampling design is based on probability

estimates of resource conditions.  EMAP will con

to report national and regional trends in concentrations

contaminants, sediment toxicity, and macrobenthic
  on sediment quality on a regional scale.  The

 covers a well-defined grid to provide unbiased

inue to gather sediment data from its sites in order

    of organic and inorganic sediment

 community composition and abundance.


10.2.1 Development of Freshwater and Marine Sediment Quality Criteria

       ORD intends to develop and validate techniques for the derivation of numerical sediment

quality criteria for both marine and freshwater systems. Short-term goals include the validation of

equilibrium partitioning as an approach for developing sediment quality criteria for nonionic organic

chemicals.  Longer-term goals include the development of tissue residue-based sediment quality

criteria, sediment quality criteria for metals,  and sediment quality criteria based upon human health

considerations.  Field and laboratory studies  will be conducted with both spiked and field-collected

contaminated sediments to validate equilibrium partitioning and associated tissue residue approaches

for deriving sediment quality criteria for nonionic organic compounds.  Similar types of studies will

be performed to determine physical and chemical factors in sediments which mediate the  ;

bioavailability and toxicity of metals.  Research  will also be conducted to develop aquatic food chain

models to predict the exposure of humans to contaminants associated with sediments.     :

10.2.2 Chemical Data for Development of Sediment Quality Criteria
       ORD intends to determine octanol/water partition coefficients (K,jws) for hy^rophobic organic

compounds selected for development of numerical criteria.  Sorption-desorption kinetics of

hydrophobic organic pollutants to and from sediments will also be investigated.  This work will

permit comparisons between field and laboratory toxicological data used in the development and

assessment of sediment quality criteria.  In addition, ORD intends to investigate mechanisms by which

ionic organics absorb to sediment, and develop an approach to modelling the binding of metals to

                                             94                                 '.

sediments.  These investigations will provide the

ionic organics and metals.
                                              )asis for developing sediment quality criteria for
10.2.3 Field Validation Studies for Sediment Quality Criteria
       ORD has selected a variety of field sites i o verify sediment criteria and other sediment

assessment methods. At selected sites,  contaminant concentrations, sediment toxicity,

                                     lie communities will be ii
bioaccumulation, and alterations of benthic'

gradients.  Levels of sediment contamination wil

where adverse ecological effects would be predic
             investigated along sediment pollution

be compared with sediment criteria to identify sites

ed by the criteria.  The actual condition of the
benthic community, degree of sediment toxicity and bioaccumulation, and partitioning of contaminants

among phases will then be compared with predici ed conditions.  Efficacy of sediment criteria in the

field will also be verified through spiking experiments that simulate field observations under

controlled laboratory conditions.


10.3.1 Biogeochemical and Transport Process js Influencing Metals Bioavailability

       ORD intends to develop a prototype biogeochemical transport model for assessing porewater
biological exposure to metals in sediments. This

sediment quality criteria for metals.  The current
                                              model is needed to facilitate the development of

                                              acid volatile sulfide (AVS) approach for assessing
 potential toxicity caused by sediment-associated metals is applicable to mature, quiescent sediments.

 An understanding of the migration of contaminants in sedimentary porewaters, however, is necessary


 to decrease the uncertainty associated with use of the AVS procedure.  This research will identify

 those situations where application of the existing AVS procedure is appropriate.

 10.3.2  Exposure Assessment Modeling for Aquatic Disposal of Dredged Materials

        ORD intends to conduct research to improve, verify, and expand the scope of existing models

 which are used for ocean disposal scenarios.  ORD intends to also develop far-field models which

 define the movement of dredged material participates and their associated contaminants.  The models

 developed would provide information on water circulation, particulate movement, and contaminant

 transport and transformation under a variety of conditions. This information will enhance the

 technical basis for ocean disposal site selection and improve permitting and monitoring decisions

 based on site-specific physical processes.

 10.3.3  Contaminated Sediment Toxicity Identification Evaluation

        ORD intends to develop Toxicity Identification Evaluation (TIE) procedures for sediment

contaminants.  Through these procedures, interstitial water will be used as a test fraction  for direct

identification of chemicals responsible for acute toxicity to aquatic organisms.  TIE would help guide

the selection of appropriate contaminated sediment remediation strategies and augment post1

remediation monitoring.

10.3.4 TMDL/Wasteload AUocation Modeling 1

       Control Options
o Evaluate Contaminated Sediments and Source
       ORD intends to conduct research to develop TMDL and wasteload allocation models capable

of predicting the partitioning of metals, ionic organic chemicals, and hydrophobic organic chemicals

to sediments.  A series of models ranging from simplified spreadsheets to complex mass balance

models will be designed to relate contaminant con :entrations among sediment, the water column, fish,

wildlife, and humans.  This should allow a better interpretation and comparison of various criteria,

including water quality criteria, U.S. Food and Dug Administration fish tissue action levels, region-

specific fish tissue action levels, Superfund site-specific sediment clean-up levels, and sediment

criteria derived by using various  methods.  As previously mentioned, OW has also undertaken

projects to identify TMDL/wasteload allocation models to protect sediment quality.

10.3.5 Chemical Analytical Methods Development

       ORD intends to develop sensitive, low cost, analytical methods to detect sediment

contaminants at concentrations compatible with F« deral and State water quality criteria. ORD intends
to develop methods for measurement of sediment

chemicals in sediments.  Methods would also be i
characteristics that control biological availability of

eveloped to minimize or eliminate the use of
hazardous solvents and reagents, thereby both reducing the exposure of laboratory workers to these

chemicals and minimizing waste which must be disposed of in accordance with RCRA regulations.

Research will also be completed to develop sensitive chemical methods for analyzing metals and

organics in suspended sediments.  Such research may be of particular use in the NPDES permitting



10.3.6 Development and Validation of Acute and Chronic Test Protocols


       In consultation with EPA's Tiered Testing Committee, ORD intends to develop state-of-tlhe-

science standardized protocols for assessing potential impacts of contaminated sediments on aquatic

ecosystems.  As noted above, the development of these tests is essential to the success of the tiered

testing approach adopted by EPA as part of this Strategy.  ORD will work with the EPA program

offices to develop standard test protocols which can be used in a hierarchical tiered testing approach

which proceeds from simple acute toxicity assessments to chronic and sublethal test endpoints.

Standard culture, acute toxicity, and chronic toxicity protocols will be developed and validated for a

variety of appropriately sensitive freshwater and marine benthic species.  The initial group lof acute

whole sediment toxicity tests that are to be standardized for Agency-wide use are described in Section

5. Methods should be validated by comparing laboratory test results to in-situ impacts. Freshwater

species selected for testing include benthic amphipods, chironomids, and oligochaetes, and water

column cladocerans and fish species. Marine species include at least six species of marine!and

estuarine amphipods. Representative bivalves and polychaetes will also be considered for test method


10.3.7 Development and Field Validation of Bioaccumulation Test Methods
       Demersal (bottom-dwelling) fishes and some benthic taxa, typically molluscs and pblychaetes,

have a relatively high tolerance to sediment contaminants and are able to survive in very polluted

habitats.  Unfortunately, such species often accumulate a high body burden of various toxic chemicals

in their tissues.  In consultation with the Sediment Tiered Testing Committee, ORD intends to

develop standard laboratory procedures for determining the bioaccumulation potential for sediment


contaminants, and validate these methods through
the use of field studies. The initial bioaccumulation
tests to be developed and validated are described in Section 5.
       Existing solid phase bioaccumulation protocols

test species expanded to be more representative o

validated by comparing tissue residues measured in

residue concentrations measured in transplanted on

same sediments in controlled laboratory exposure;

analytical laboratories will be compared.
     must be rigorously validated and the array of

r local species at risk.  Test protocols should be field

  organisms collected from selected sites with

•ganisms as well as in organisms exposed to the

.  To evaluate precision, results from a variety of
10.3.8 Unavailability and Trophic Transfer of Sediment- Associated Contaminants
        Sediment-associated contaminants may pose a direct risk to wildlife and human health through

the direct consumption of contaminated benthic organisms such as clams and lobsters, or an indirect
risk through the trophic transfer of contaminants

conduct research on the bioavailability and trophi

emphasis on residue levels in shellfish and highei

relationships between contaminant concentrations
ip the food chain into edible fish. ORD intends to

: transfer of contaminants in sediments with special

 trophic level aquatic species.  Information on

in sediments and higher trophic level and .
commercially important aquatic species will be developed.  This information will help determine the

classes of compounds and the conditions which warrant the generation of sediment criteria protective

of human health.

10.3.9 Development of Tissue Residue Thresholds

       One of the major uncertainties in assessing the effects of sediment-associated contaminants is

the ecological significance of bioaccumulated compounds.  ORD intends to undertake research to

determine the tissue residue levels of contaminants in fish and invertebrates which result in both death

and sublethal effects such as reproductive impairment. Because they rely on internal doses;rather than

external pollutant concentrations, tissue residue thresholds avoid the errors  inherent in predicting the

bioavailable fractions of sediment contaminants. Tissue residue threshold levels would be used to

identify the toxic agents in sediments with multiple contaminants, derive wasteload allocations based

on existing tissue residues, and generate insight into  pollutant interactions.
Routes of Biological Exposure
        All methods of generating sediment quality criteria require assumptions about the routes of

biological exposure and their relative importance in relation to equilibrium conditions. ORD intends

to undertake research to evaluate the importance of different routes of exposure in relation to

biological variables such as feeding and burrowing behavior of organisms, chemical partitioning

behavior, and sediment characteristics.  It is expected that this research will produce techniques for

incorporating various routes of sediment contaminant uptake by benthic organisms into the derivation

of sediment quality criteria.


 10.4.1  Remediation Methods for Contaminated Sediments

        ORD intends to develop and evaluate a r inge of methods for the remediation of contaminated

 sediments. Methods developed should provide c >st-effective solutions to the problem of sediment

 contamination.  ORD intends to evaluate the following remediation approaches: in-situ containment,

 biological treatment, and metals treatment.  Research into in-situ containment will focus on the
capping or armoring of sediments.  The mobility
of contaminants through caps of differing materials
will be measured in the laboratory, and hydrodynamic situations where capping or armoring is
applicable will be identified.  ORD also intends

disposal facilities as large bioreactors to degrade

directed toward the development of technologies
o investigate the modification and use of confined

contaminants.  Research into in-situ treatment will be
for the removal of metals from sediments.  Particular
emphasis will be given to processes that allow recovery and eventual reuse of metals.
       The National Research Council's (NRC)
Commission on Engineering and Technical Systems
has convened a Committee on Contaminated Maiine Sediments.  The committee will assess the

Nation's capability for cleaning up and remediati ig or managing contaminated marine sediments.  A

public NRC report on this subject will be prepand by May 31, 1995.  It is expected that the NRC

report will: 1) provide additional information to define and describe the nature of problems associated

with contaminated sediments; 2) establish categoiies of contaminated sites for remedial investigation;

3) discuss relevant regulatory frameworks for contaminated sediments; 4) review state of the art of

identifying and assessing sites;  5) review remediation technologies currently in use, or likely to be
available in the near future; and 6) develop a decision model for one category of remediation problem

sites.  EPA will carefully consider the findings of the NRC report as the Contaminated Sediment

Management Strategy is implemented.

10.4.2 Resiliency and Natural Recovery of Aquatic Benthic Ecosystems

       As stated in this strategy document, the preferred remediation technique for many

contaminated sediment sites is implementation of source controls allowing natural recovery to occur.

To assist the EPA program offices hi developing criteria for determining when natural recovery is the

appropriate remedial alternative, ORD intends to conduct research to determine the rates of recovery

of benthic communities under different environmental conditions and stresses.  Factors which control

recovery rates would be identified (e.g., community type, physical factors, and types of stress).

Intact benthic communities would be studied in microcosms receiving uncontaminated water; research

would also include monitoring rates of recovery at selected field sites.


10.5.1 ORD Clients
        In completing the research described in this Strategy, ORD will work closely with; its clients

to ensure that the methods, tests, and models it develops are useful to EPA program offices and other

identified users of research products.  ORD will draw upon the technical expertise available in other

government agencies, academia, and industry.  Major clients who will use ORD research products

include: the EPA program offices, EPA Regional offices, the Great Lakes National Program Office,

the Gulf of Mexico Program Office, National Estuary Program Management Conferences,; the

                                             102                                l

Chesapeake Bay Program, and State and local regulatory agencies.  In addition, other Federal

agencies including the COE, NOAA, USFWS, U 5GS, and the United States Soil Conservation

Service (SCS) will use ORD research results. OIJD will coordinate its research programs with the

ongoing activities of these clients.

10.5.2  Technology Transfer
       ORD intends to take the following actions

sediment research programs are available to users
                                to ensure that the results of its contaminated
       1.      ORD intends to sponsor, and cost onsor with the EPA program offices, workshops
               and training sessions on such topics as remediating contaminated sediments, use of
                                              ' various sediment contaminant transport and
sediment bioassays, and the use o:

partitioning models.
ORD intends to publish research results in peer reviewed scientific, technical, and

engineering journals.
       3.     ORD scientists and engineers intend to present research results at platform and poster

              sessions at major national and international conferences and at workshops.
       4.     ORD intends to work with OST tc  provide regulatory agencies and the regulated

              community with methods and protocols for assessing and remediating contaminated


                                11.  OUTREACH STRATEGY                    ;

       Outreach is a critical component of the EPA's Contaminated Sediment Management Strategy.

Public understanding of the ecological and human health risks associated with sediment

contamination, and of solutions to the problem, is key to successful implementation of this Strategy.

OST therefore intends to initiate an outreach program in support of Strategy objectives.  In

implementing the outreach program, EPA will draw upon the experiences of successful outreach

efforts in the Chesapeake Bay Program, the Great Lakes Program, the Gulf of Mexico Program, the

NEP, EPA public-private partnership programs, and the RCRA public outreach program.

       The primary goal of EPA's outreach program for this Strategy is to educate key audiences

about the risks, extent, and severity of contaminated sediments, the role of the Strategy in solving

contaminated sediment problems  and the way in which stakeholders will be involved in Strategy

implementation. The outreach program described below has four key elements: 1) defining key

Strategy themes or messages; 2)  identifying target audiences and needs;  3) developing appropriate

materials such as guidance documents, brochures, and videos; and 4) providing channels to facilitate

two-way communication on Strategy issues.

        Four themes of the Strategy, closely linked to the Strategy's goals, will be conveyed by EPA

 to target audiences through outreach activities described below.  The first theme is that sediment

 contamination comes from many sources, which must be identified, and that source control options

 must be evaluated according to risk reduction potential and effectiveness.  The second theme is that


sediment contamination poses threats to human health and the environment.  The risks must be

identified and effectively communicated to the public. Third, sediment contamination can be

effectively managed through assessment, prevention, and remediation. And fourth, EPA's strategy

for managing contaminated sediment relies on interagency coordination and building alliances with

other agencies, industry, and the public.


       Communication with other Federal, State,

important part of EPA's outreach program. EPA

all agencies effectively characterize the risks

sediment testing methods are applied; consistent

levels; and optimal use of financial and technical
                                            and local agencies and industry will be an

                                            s outreach program will be designed to ensure that:

                                       of sediment contaminants; consistent assessment and

                                          decisions are made at the Federal, State, and local
                                           resources occurs.
       In accordance with the requirements of WRDA 1992, EPA will convene and co-chair, with

the Department of the Army, the National Contaminated Sediment Task Force. Through this Task

Force, EPA will coordinate its assessment activities with the following agencies: NOAA, USGS,

COE, USFWS, and the States. Through the Task Force, EPA will also propose the development of a

                               linated sediment
national Federal strategy for contaminate
       EPA will also work with other Federal agencies to promote remediation and prevention
practices consistent with the Contaminated Sediment Management Strategy.  These agencies will

include USDA, U.S. Department of Transportation (DOT), DOD, and DOE.  EPA will develop

memoranda of understanding and agreement with these and other agencies to promote these practices.

       To effectively implement the outreach plan, EPA will seek to communicate with large and

highly diverse audiences, educate and involve the general public in EPA's decision-making processes,

and target information to both broad audiences as well as subgroups within those audiences.  In

designing and targeting its outreach messages, EPA will determine the information needs of each

audience by assessing the extent of its knowledge about the topic. The positions and concerns of the

audience about the topic will be determined as well as the audience's level of interest, and methods to

increase interest and attention will be developed. It will be necessary to determine whether the

primary purpose of EPA's message is to inform the audience, change its attitude, or to encourage the

audience to take action.

       The audiences that EPA will target to receive its outreach materials and messages are be

categorized as follows:

       1.     The general public.

       2.     Environmental and public interest groups.

       3.     The scientific community,  including academia, laboratories, and professional societies.

       4.     Congressional representatives and government groups.
       5.     Federal agencies, including the COE

              whose policies and operations direc
 , DOE, DOD, DOT, USDA, and other agencies

 ly contribute to the Strategy or affect its goals.
       6.     State and local agencies.
       7.     EPA Regional and Headquarters personnel.
       8.     The regulated community, including businesses and industrial trade associations.

       9.     News media, including printed med a, television, radio, trade and industry journals,

              and environmental magazines.

       Outreach activities to support implementation

will include actions taken by a number of different
11.4.1 Regulatory Actions and Guidance Documents
       EPA intends to prepare guidance document!

and Eionregulatory requirements for contaminated si
  of the Strategy will be coordinated by OST, but

'. iPA program offices.
 and reports in support of the Agency's regulatory

 liment assessment, prevention, and remediation.
Guidance documents and reports will focus on issues such as sediment quality assessment

methodologies, sediment toxicity testing methods, use of sediment quality criteria, and assessment of

human health and ecological risks of sediment contamination. EPA's initial outreach efforts will

focus on preparation of the following guidance documents and reports:

        1.      OST and ORD intend to prepare guidance documents on methods to be used by all

               EPA program offices in conducting standardized sediment toxicity tests. Such

               guidance will address acute and chronic bioassays and bioaccumulation tests.

       2.      OST will prepare guidance documents on evaluating and selecting techniques for

               remediation of contaminated sediment.  ORD and other EPA offices intend to develop

               guidance documents on technologies for contaminated sediment remediation.

       3.      OWM intends to develop guidance for deriving NPDES permits that protect sediment


       4.      OST intends to prepare guidance for development of mixing zones for NPDES point

               sources to protect sediment quality.

       5.      EPA intends to develop guidance for nonpoint source controls to help prevent

               sediment contamination from nonpoint sources of pollution.
       6,      OW, in conjunction with the COE, intends to develop national guidance on testing of

               dredged materials for disposal in inland waters, and will revise existing guidance on

               testing of dredged materials for ocean disposal.


 7.      EPA intends to develop guidance

        address contaminated sediment
on regulatory and associated enforcement actions to

    control and remediation.
 8.      OST intends to develop guidance on designing and implementing monitoring programs

        for sediment contaminants.

 9.      EPA intends to develop guidance for trade associations on pollution prevention issues,

        including the contamination of sediments from point and nonpoint sources of


 10.     EPA will produce a Report to Con ;ress on the Site and Source Inventories as required

        by WRDA 1992.

 11.     EPA will produce a Report to Congress on the Great Water Bodies Study on the
       effects of hazardous air pollutants.

       effects of air pollutants on sedimen
 This report will include information on the known

12.    EPA will produce a Report to Congress on the activities of the National Contaminated

       Sediment Task Force required by WRDA 1992.

11.4.2 Outreach Publications                                                      '

       EPA intends to prepare outreach publications and support other agencies in developing their

own technical and general audience publications on sediment contamination.  EPA intends to develop

journal articles, pamphlets, brochures, fact sheets, slide shows, and other multimedia materials to

inform a variety of technical and nontechnical audiences about issues and problem solutions related to

sediment contamination.  These materials would be distributed through advertising in bulletins such as

the Contaminated Sediments News or at public meetings, workshops, and national conferences on

pollution prevention or contaminated sediment.

11.4.3 Advisory Groups, Databases, Clearinghouses, and Other Activities

        EPA intends to take the following actions to establish advisory groups, databases, clearing

houses and other programs hi support of the Contaminated Sediment Management Strategy:

        1.     EPA intends to maintain the Sediment Steering Committee to oversee implementation

               of the Agency's Contaminated Sediment Management Strategy.  In this role the

               Committee will track and monitor all aspects of strategy implementation.  A report

               will be developed to document Agency-wide activities and will be distributed to the

               public on a regular basis.
        2.      As described hi this strategy document, EPA intends to prepare both Site and Source

                Inventories for contaminated sediments.  These data will be made available to the

                public and reports to Congress will be prepared on a biennial basis.


       3.      EPA intends to regularly sponsor
                             conferences on contaminated sediments.
       4.      EPA intends to hold a series of workshops for the public to educate them about the

              risks of sediment contamination.

       5.      EPA intends to submit scientific J nd technical guidance and related materials to the

              SAB for review.  SAB reviews wjll be announced in the Federal Register as well as

              other relevant EPA publications.

       EPA recognizes that implementation of the

must be a partnership among many organizations

implement its contaminated sediment managemen
       1.     EPA will involve the public, i

              as early as possible in the strategy

                               Contaminated Sediment Management Strategy

                               EPA will therefore adopt a number of principles to

                              ; outreach program.
                          including the private sector as well as the general public,

                               planning process.  Community participation will be
       2.      EPA will clearly state its expectations for sediment clean-up efforts at the outset of

               program implementation. Issues such as cost, the time frame for clean-up, and how

local situations compare to
               in the initial planning stages of c
clean-up efforts nationwide will all be addressed
                              ean-up efforts.

 3.     EPA will focus on "keeping the momentum" going with respect to citizen

        involvement. Short term goals will be created to highlight accomplishments.

 4.     Wherever possible, EPA will tie the issue of sediment contamination to tangible

        effects such as fish consumption advisories.

 5.     EPA will demonstrate the Agency's commitment and accountability to sediment

        management efforts through consistent involvement of the public in reviewing major

        actions under the Strategy.

 6.      EPA will utilize existing information networks and communication systems as

        mechanisms for public involvement and information dissemination.

 7.      EPA will provide guidance, information, and support to the States but will, where

        possible, allow the States flexibility in making decisions and adapting the outreach

        information to local conditions.

 8.      EPA will prepare written materials and guidance on sediment contamination, but will

        also use workshops and face-to-face contact hi disseminating information.

9.      EPA will provide the public with a balanced risk framework that is understandable

        and includes information about comparative risks.

10.    EPA will provide public information at a level of detail that allows the public to

       formulate decisions.

11.    EPA will work toward building consensus among all of its audiences.
12.    EPA will work toward developing

       be self-sustaining and will carry
  a management framework of institutions that will

he work of sediment management into the future.

                                     12.  CASE STUDIES

       Well-documented cases of human health and ecological effects caused by sediment

contamination have been published in the peer-reviewed literature.  This appendix contains a few case

examples that reflect both human health and ecological effects that may be expected at sites where

severe sediment contamination is evident.


       For the purposes of this Strategy, risk is defined as the probability of harm or likelihood of an

adverse consequence or effect caused by the presence of contaminants hi the environment.  Various

EPA programs have different acceptable risk levels, generally ranging from 10^ to 10"6; therefore

"unacceptable risk" determinations must be made on a program specific basis.
       In 1987, EPA completed a study entitled Unfinished Business: A Comparative Assessment of

Environmental Problems (U.S. EPA, 1987b). Toxic chemicals in sediments, included as a category

of nonpoint source pollution, were ranked as the eleventh most significant environmental problem of

thirty-two identified in the report.  In 1989, EPA Administrator William Reilly asked the SAB to

review "Unfinished Business." The SAB is a public advisory group that provides scientific

information and advice to EPA.  In a report entitled Reducing Risk: Setting Priorities and Strategies

for Environmental Protection. SAB supported EPA's ranking of the human health risks posed by

contaminated sediments (U.S. EPA, 1990b).  In this report, SAB indicated that cancer and non-cancer

illnesses can be caused by bioaccumulation of toxic chemicals from sediments in fish and shellfish

which are then consumed by humans. Both EPA and SAB gave contaminated sediments a medium.


risk score as a causative agent of non-cancer illnesses

fish posed a low cancer risk, but noted that bioaccumulation

sediments was the primary route of human exposure
   .  SAB judged that consumption of contaminated

         in fish of chemicals in contaminated

  to carcinogens in surface waters.
       In comparative risk analyses performed b; r EPA Regions I, n, ffl, V, and X, sediment

contamination was given a medium-high score for cancer risks to consumers of fish and shellfish

(U.S. EPA, 1989b).  Since actual risks may be higher for certain ethnic groups due to fish

consumption patterns, environmental equity concerns have been raised in certain parts of the country.

In 1993, there were 1280 waterbodies with fish consumption advisories in the United States, with

sediments identified as a potential source of contamination at many sites.
12.1.1  Quincy Bay and New Bedford Harbor,
       In June 1988, EPA released a report, completed at the request of Congress, entitled

Assessment of Oulncv Bay: Summary Report (U.S. EPA, 1988b).  The study investigated the types

and concentrations of pollutants hi Quincy Bay, Massachusetts; the incidence of abnormalities in

marine life; and the potential public health implications of consumption of seafood exposed to

contaminated sediments. Study results indicated that levels of PCBs, polycyclic aromatic

hydrocarbons, and metals were elevated in sediments and hi the marine species studied. Whiter

flounder and soft-shelled clams were found to erf ibit an extremely high incidence of conditions

believed to be associated with environmental stress: cancerous lesions; liver, intestinal, and pancreatic

pathologies; and neoplasms.

       The human health risk assessment concluded that regular consumption of tomalley

(hepatopancreas) from Quincy Bay lobsters posed a high cancer risk comparable to risks reported in

the case studies described below for Upper New York Harbor or Lake Michigan.  The maximum

upper bound estimated lifetime cancer risk for the maximally exposed individual consuming a mixed

diet of clams, flounder, lobster meat, and lobster tomalley from Quincy Bay was calculated to be 2.3

x 10"2 (U.S. EPA,  1988b). The lifetime cancer risk of a typical local consumer of the same mixed

diet was calculated to be 1.3 x 10"3 (U.S. EPA, 1988b).

       At the New Bedford Harbor Superfund site in Massachusetts, PCB concentrations in

sediments range from a few parts per million (ppm) to over 100,000 ppm. PCB levels as high as 10

ppm in fish tissue have been measured in certain areas at the site; 10 ppm is five times the  FDA's

action level of 2 ppm for PCBs.  Thousands of acres have been closed to the harvesting of shellfish,

finfish, and lobsters since New Bedford Harbor's appearance on the National Priority List (NPL) in

1982.  Many individuals regularly consumed seafood from the area before the extent of contamination

was known, however, and some  residents still harvest both finfish and shellfish for personal


       A human health risk assessment was conducted for consumption of lobster, flounder, and

clams using an 8 ounce meal size (pers. comm. with G. Carman, 1993).  PCB levels in edible lobster

tissue (including tomalley) of 2.3 ppm produced a lifetime cancer risk of 1 x 10"2 for weekly

consumption (52 meals/year) and 2.5 x 10~3 for monthly consumption (12 meals/year).  PCB levels hi

flounder tissue of 0.37 ppm produced a lifetime cancer risk of 1.7 x 10~3 for weekly consumption and

3.9 x IQ4 for monthly consumption.  The fish were taken from an area of intermediate contamination.

PCB levels in clam tissue of 0.23 ppm produced

consumption and 2.4 x 10"4 for monthly consumpt

12.1.2 Puget Sound, Washington
       Another comprehensive study was comple

Sound (Puget Sound Estuary Program,  1988).  A

and it was determined that 25% of the individuals

during their lifetimes. The health risk assessment

be added to the 2500 cases expected per 10,000 i

(a risk level of 2 x 10"4), and 40 additional cases

10,000 individuals consuming a large quantity

carcinogens identified in this study were PCBs in

                                              lifetime cancer risk of 1.1 x 10* for weekly

                                             ed on consumption of seafood taken from Puget

                                             high background incidence of cancer was observed

                                             in the Puget Sound region would develop cancer

                                             predicted that two additional cases of cancer would

                                            individuals consuming an average quantity of seafood

                                             of cancer would be added to the 2500 expected per

                                          of seafood (a risk level of 4 x 10'3).  The principal

                                             fish and polycyclic aromatic hydrocarbons in
12.1.3 Los Angeles-Long Beach Harbor, California
       Following a risk assessment analysis

of Health Services issued a health advisory

Santa Monica Bay, Palos Verdes Peninsula, and

al., 1989).  Sediments in these areas are

were  discharged in the 1960s and early 1970s.

croaker was particularly contaminated, and that

croaker were significantly higher than levels
                                         of toxic contaminants in fish, the California Department

                                       concerning the consumption of local sport fish from the

                                            Los Angeles-Long Beach Harbor areas (Gossett et

                                     contaminated with PCBs, DDT,  and DDT metabolites which

                                            Analysis showed that the bottom-feeding white

                                           cancer risks to the population consuming white

                                         generally considered to be acceptable (cancer risk levels

on the order of 10"3 to 10"* were calculated).  In the Los Angeles area, significantly higher levels of

DDT and its metabolites were found in the blood serum of local and sport fishermen who ate their

catch than in the blood serum of nonconsumers.

12.1.4 Lake Michigan

       In the mid-1970s, PCB levels as high as 20 ppm were found in fish from Lake Michigan

(Swam, 1992).  Human exposure to PCBs was determined using data from extensive epidemiological

studies of two matched cohorts of exposed individuals (Swain, 1988).  One cohort consisted of sport

anglers and the other cohort consisted of mothers and their newborn infants. These groups were

exposed to significant quantities of PCBs from consumption of contaminated freshwater fish from

Lake Michigan.

       A 1974 study of 178 adult sport anglers showed that the longer the period of time during

which anglers consumed fish from Lake Michigan, the higher their PCB body burdens (Swain, 1988).

A study of 991 adults in 1982 showed that persons consuming fish from Lake Michigan had higher

PCB body burdens than did non-fish eating individuals (Humphrey,  1987).  Risk analyses were not

performed as part of these studies.
       A study of mothers and their newborn infants showed that as the period of time over which

fish was consumed from the lake increased, so did the mothers' body burdens of PCBs (Swain, ,

1988). Exposed mothers were found to have increased levels of PCBs in whole blood serum and

breast milk. The higher the PCB body burdens, the more intense were the effects exhibited by the

infants (Fein et al., 1984; Jacobsen and Fein,  1985). Infants of highly exposed mothers were born at


reduced birth rates and reduced gestational ages; had smaller head circumferences, arid exhibited

neuro-motor effects.

12.1.5 New York

       The New York Department of Environmental Conservation's Clean Water Act Section 304(1)

List states that contaminated sediments cause more than 20% of all river miles in New York to fail to

meet their designated uses under CWA authority.  Many of New York's major rivers are affected,

including the entire 38 mile length of the Niagara River, the entire 109 mile length of the St.

Lawrence River lying in New York, and the entire 180 mile reach of the Hudson River from Fort

Edward iii the Upper Hudson to the Battery at Manhattan.  About 30,000 acres (90%) of New York's

lakes are also a problem for fish consumers, due j rimarily to PCB contamination. Other sediment

contaminants identified include DDT, chlordane, £ nd mercury.  Fish consumption advisories or bans

have been issued for several or all species at each site.

12.1.6 Pago Pago, American Samoa

       In 1991, the American Samoan government issued a public health directive instructing the

public not to eat any fish or shellfish caught in ira er Pago  Pago Harbor.  A ban on the sale of fish

from the inner harbor was also issued. The directive was based on the results of a study which

examined chemical concentrations in water, sediment, and  fish (American Samoa Department of

Health, 1991).  Sediments were reported to be highly contaminated with PCBs', oil and grease, and

heavy metals.

        EPA Region IX analyzed the data for health risks and identified the following risks of greatest

concern: 1) Potential brain damage. If lead contamination alone were considered, lead concentrations

in fish could reach levels that would cause 70% to 80% of children who regularly eat 3 to 4 fish

meals per week to suffer a permanent reduction in intelligence.  2) Increased cancer risk.  Consuming

fish from the inner harbor at a rate of 3 to 4 fish meals per week over a lifetime would significamtly

increase the risk of cancer due to arsenic contamination. 3) Increased non-cancer health risks.  Using

a hazard index hi which non-cancer health risks occur at levels greater than a value of "1", EPA

Region IX calculated the hazard index at 1-3 for adults consuming inner harbor fish and at 2-3 for

children consuming inner harbor fish (Baker, 1993).


       In the SAB and EPA Regional comparative risk studies, contaminated sediments received a

high score for their potential to cause adverse ecological effects on both local and regional scales.

The studies also determined that the "recovery period" for areas with sediment contamination may be

decades or longer. Several documented cases of adverse ecological effects due to contaminated

sediments are presented below.

12.2.1 Elizabeth River, Virginia
       The Elizabeth River is a sub-estuary of the Chesapeake Bay and is heavily contaminated with

a variety of pollutants, particularly polycyclic aromatic hydrocarbons (PAHs).  Sediment gradients of

PAHs were measured in the following studies: Hargis et al., 1984; Bieri et al., 1986; and, O'Connor

and Huggett, 1988. Examination of benthic communities in the Elizabeth River suggests that


contaminated sediments have adverse effects. Up
ake of organic compounds in fish has been
for the observed effects (Van Veld et al.,  1990).
observed by assaying bile from exposed fish. Bic accumulation of PAHs in commercially fished,

resident crabs has also been documented.  In addi ion, the frequency and intensity of neoplasms,

cataracts, enzyme induction, finrot, and other lesions observed in fish populations (mainly Leiostomus

xanthurus. spot) have been correlated with the extent of sediment contamination (Van Veld et al.,

1990).  Laboratory studies have been conducted t > elucidate whether the sediments were responsible
Fish maintained in the laboratory in contact with
sediments taken from the Elizabeth River exhibited several of the symptoms observed among fish

populations in the field. Additional laboratory studies have implicated contaminants from sediments

as causal agents for other effects, such as immune system dysfunction.

12.2.2  Commencement Bay, Washington

        Field and laboratory studies were the basis for a comprehensive assessment of ecological risks

caused by toxic sediments in Commencement Bay (U.S. EPA, 1993e).  Using amphipod and oyster

larvae bioassays, investigators determined that sediments from 24 of 52 stations caused significant

toxicity compared to a reference area. Benthic infauna measurements were also used to determine
 chronic effects.  This investigation was the basis
for one of the case studies reviewed by EPA's
 Ecotoxicity Subcommittee charged by the Agency's Risk Assessment Council with responsibility for

 the development of ecological risk assessment guidelines.

 12.2.3  Great Lakes

        In the Great Lakes, PAH contamination of sediments has been linked to increased incidence of

 tumors  in certain fish (Baumann, 1989).  Brown bullheads from the industrialized Black River in

 Ohio exhibited higher levels of organic contaminants, particularly PAHs, and a higher incidence of

 skin, liver> and lip tumors than bullheads taken from a nearby reference site (Bauitnann et al., 1987).

 By applying criteria established for human epidemiology studies to the data from numerous reports on

 the Black River, a cause and effect relationship can be determined between the presence of PAHs in

 the sediment and the occurrence  of liver cancer in native fish populations (Baumann et al.,  1987).

        Also in the Great Lakes region, organochlorine contaminants have been linked to reproductive

 problems in Forster's tern and to reproductive failure and mortality in mink. The reproductive

 success  of Forster's terns inhabiting contaminated Green Bay on Lake Michigan was significantly

 lower than that of terns inhabiting relatively uncontaminated Lake Poygan in Wisconsin (Kubiak et

 al., 1989). Reproductive failures have been linked to intrinsic factors (e.g., egg viability) and

 extrinsic factors (e.g., parental attentiveness), both of which are affected by sediment contaminants.

Reproductive problems in mink were first reported in the 1960s at mink farms  that fed the mink Great

Lakes fish; high levels  of PCBs in the fish were identified as the cause (Auerlich et al., 1973).  These

two examples are indicative of the risks to fish-eating birds and mammals posed by a PCB-

contaminated food chain, and may provide clues to explain why certain fish-eating birds and

mammals may have disappeared or become rare in ranges where they were historically found.

                                           American Samoa Health Bulletin: Don't Eat the Fisfa
American Samoa Department of Health.  1991.

       in Inner Pago Pago Harbor!  October 29.
Auerlieh, R.J., R.K. Ringer, and S. Iwamoto.  1973.  Reproductive failure and mortality in mink fed
       on Great Lakes fish. J. Reprod. Fertil. Su
                                             jpl. 19:365.
Baker, B.  1993.  Personal communication with EPA Region IX.
 Baumann, P.C.  1989.  PAHs, metabolites, and n

        of Polycyclic Aromatic Hydrocarbons in

        Press, Inc.  Boca Raton, FL.  pp 268-289
 Baumann, P.C., W.D. Smith, and W.K. Parland.
                                             ;oplasia in feral fish populations.  In: Metabolism

                                            the Aquatic Environment.  U. Varansi, ed.  CRC
                                              1987. Tumor frequencies and contaminant
        concentrations in brown bullheads from a i industrialized river and a recreational lake.

        Transactions of the American Fisheries Society  116:79-80.

 Bieri, R. H., C.S. Hein, R.J. Huggett, P.M. Shcu, H.D. Slone, C.L. Smith, and C.-W. Su.  1986.

        Polycyclic aromatic hydrocarbons in surface sediment from the Elizabeth River subestuary.

        Intern. J. Environ. Anal. Chem.  26:97-113.
  Edgar, III, C.E. 1985.  Superfund Projects. U.

         Letter 85-7. July 5.
                                             S. Army Corps of Engineers Regulatory Guidance

 Engler, R,  1992. Personal communication with Office of Wetlands, Oceans and Watersheds staff.

 Fein, G.G., J.L. Jacobsen, S.W. Jacobsen, P.W.  Schwartz, and J.K. Dowler.  1984. Prenatal

        exposure to polychlorinated biphenyls: effects on birth size and gestational age.  Pediatrics


 Carman, Gayle.  1993.  Personal Communication. New Bedford Harbor Regional Project Manager,

        EPA Region I, Boston, MA.

 Gossett, R., G. Wikholm, J. Ljubenkov, and D. Steinman.  1989.  Human serum DDT levels related

        to consumption of fish from the coastal waters of Los Angeles.  Environmental Toxicology

        and Chemistry 8:951-955.

 Hargis, Jr., W.J., M.H. Roberts, Jr., and D.E. Zwerner.  1984. Effects of contaminated sediments

       and sediment-exposed effluent water on an estuarine fish: acute toxicity.  Marine

       Environmental Research 14:337-354.

Humphrey, H.E.B.  1987. The human population-an ultimate receptor for aquatic contaminants.

       Hydrobiologia 149:75-80.

Jacobsen, J.L. and G.G. Fein.  1985. Clusters for the Brazelton scale: an investigation of the

       dimensions of neonatal behavior. Dev. Psychology 20:339-353.

Kubiak, T.J., HJ. Harris, L.M. Smith, T.R. Schwartz, D.L. Stalling, J.A. Trick, L. Sileo, D.E.

       Docherty, and T.C. Erdman.  1989.  Mic rocontaminants and reproductive impairment of the

       Forster's tern on Green Bay, Lake Michigan-1983.  Arch. Environ. Contam. Toxicol.


Lee, C.R.  1992. U.S. Army Corps of Engineer!; National Dredging Program.  Presentation to the

       CSMS Forum on "The Extent and Severity of Contaminated Sediments." In: Proceedings of

       the EPA's Contaminated Sediment Management Strategy Forums.  EPA 823-R-92-007.

       September 1992.
Long, E.R. and L.G. Morgan.  1990.  The

       Contaminants Tested hi the National

       Memorandum NOS OMA 52.  National

Potential for Biological Effects of Sediment-Sorbed

 Status and Trends Program.  NOAA Technical

    Oceanic and Atmospheric Administration.  Seattle,
Lyman, W.J., A.E. Glazer, J.H. Ong, and S.F. Coons.  1987.  An Overview of Sediment Quality in

       the United States. Prepared for the Offic; of Water Regulation and Standards.

MacDonald, D.D.  MacDonald Environmental Sc iences Ltd.  1993.  Development of an Approach to

       the Assessment of Sediment Quality in Fbrida Coastal Waters.  Prepared for the Florida
       Department of Environmental Regulation,

      Tallahassee, FL.  Ladysmith, British Columbia.

Moore, D. and Wilson, J. 1992.  Presentation to the GSMS Forum on "Building Alliances Among

       Federal, State, and Local Agencies to Address the National Problem of Contaminated

       Sediments."  In: Proceedings of the EPA's Contaminated Sediment Management Strategy

       Forums.  EPA 823-R-92-007. September 1992.

National Academy of Sciences.  1989.  Contaminated Marine Sediments-Assessment and

       Remediation.  National Academy Press. Washington, D.C.

O'Connor, J.M. and RJ. Huggett. 1988.  Aquatic pollution problems, North Atlantic coast,

       including Chesapeake Bay.  Aquatic Toxicology 11:163-190.

Office of Management and Budget. 1987.  Standard Industrial Classification Manual.  PB87-100012,

Puget Sound Estuary Program.  1988. Health Risk Assessment of Chemical Contamination in Puget

       Sound Seafood. PTI. Bellevue, WA.

Swain, W.R.  1988.  Human health consequences of consumption of fish contaminated with

       organochlorine compounds. Aquatic Toxicology  11:357-377.

Swain, W.R.  1992.  The Impacts of Contaminated Sediments on Human Health: A Case Study from

       the Great Lakes.  Presentation to the CSMS Forum on "The Extent and Severity of

       Contaminated Sediments." In: Proceedings of the EPA's Contaminated Sediment

       Management Strategy Forums.  EPA 823-R-92-007.  September 1992.

U.S. EPA.  No date.  Fish Consumption Database

       Board. Assessment and Watershed Protection

U.S. EPA. 1985. National Perspective on Sedim

       EPA Contract #68-01-6986 for Office of Water

       Washington, D.C.  July.
  Nonpoint Source Program Electronic Bulletin

ion Division, Office of Wetlands, Oceans and
:nt Quality. Report prepared by Battelle under

    , Criteria and Standards Division.
U.S. EPA. 1987a.  Nonpoint Source Guidance.  Office of Water and Office of Water Regulations

       and Standards. Washington, D.C.  December.

U.S. EPA. 1987b.  Unfinished Business: A Comparative Assessment of Environmental Problems.


U.S. EPA. 1988a.  An Overview of Sediment Quality in the United States. EPA 905/9-88/002.
U.S. EPA.  1988b.  U.S. Environmental Protection

       summary report.  Narragansett, RI: U.S.
  Agency Region 1.  Assessment of Quincy Bay:

3PA Research Laboratory.
 U.S. EPA.  1989a, Risk Assessment Guidance fcr Superfund, Volume II - Environmental Evaluation

       Manual, Interim Final.  EPA 540/1-89/001.                                ;
 U.S. EPA.  1989b.  Comparing Risks and Setting

        Regional Projects.  EPA X9001-0028.
Environmental Priorities.  Overview of Three

U.S. EPA.  1990a.  Contaminated Sediments-Relevant Statutes and EPA Program Activities. EPA


U.S. EPA.  1990b.  Reducing Risk: Setting Priorities and Strategies for Environmental Protection.

       EPA SAB-EC-90-021.

U.S. EPA.  1992a.  Proceedings of the EPA's Contaminated Sediment Management Strategy Forums.

       EPA 823/R-92/007.

U.S. EPA.  1992b.  Tiered Testing Issues for Freshwater and Marine Sediments. Proceedings,

       September 16-18, 1992, Washington, D.C. Office of Water, Office of Science and

       Technology, and Office of Research and Development.

U.S. EPA.  1992c.  An SAB Report: Review of Sediment Criteria Development Methodology for

       Non-Ionic Organics.  Sediment Quality Subcommittee of the Ecological Processes and Effects

       Committee.  EPA-SAB-EPEC-93-002.

U.S. EPA.  1992d.  Evaluation of Region 4's Sediment Quality Inventory. Prepared for Coastal

       Programs, U.S. EPA, Region 4. Atlanta, GA.

U.S. EPA.  1992e.  An SAB Report: Review of a Testing Manual for Evaluation of Dredged

       Material Proposed for Ocean Disposal.  Prepared by the Sediment Criteria Subcommittee of

       the Ecological Processes and Effects Committee.  EPA-SAB-EPEC-92-01.

U.S. EPA.  1993a. Selecting Remediation Techniques for Contaminated Sediment.  EPA


U.S. EPA.  1994. Framework for the Development of the National Sediment Inventory.  EPA 823-

U.S. EPA.  1993c. Gulf of Mexico Toxic Substa ices and Pesticides Characterization Report.

       Produced for Gulf of Mexico Program, Stennis Space Center, MS. DRAFT.
U.S. EPA.  1993d. EPA Regulatory Agenda.  April.
U.S. EPA.  1993e. A review of ecological asses

       perspective.  In: Commencement Bay Ti

       Study.  EPA-630-R-92-005.
   ment case studies from a risk assessment

Tidelands Assessment: Commencement Bay Case
U.S. EPA. 1994a. Methods for Measuring the

       Contaminants with Freshwater Invertebrates
 Tojxicity and Bioaccumulation of Sediment-Associated

     .  EPA 600/R-94/024.
U.S. EPA.  1994b.  Methods for Measuring the

       Contaminants with Estuarine and Marine.
U.S. EPA and the U.S. Army Corps of Engineer!i

       for Ocean Disposal: Testing Manual.  EPA
  Tbxicity of Sediment Toxicity of Sediment-Associated

   \niphipods.  EPA 600/R-94/025.
    .  1991.  Evaluation of Dredged Material Proposed


U.S. EPA and the U.S. Army Corps of Engineers.  1992.  Evaluating Environmental Effects of

       Dredged Material Management Alternatives-A Technical Framework.  EPA 842/H-92/008.

U.S. EPA and the U.S. Army Corps of Engineers.  1993.  Evaluation of Dredged Material Proposed

       for Discharge in Inland and Near Coastal Waters-Testing Manual.  (DRAFT).

Van Veld, P.A., DJ. Westbrook, B.R. Woodin, R.C. Hale, C.L. Smith, R.J. Huggett, and J.J.

       Stegman.  1990. Induced cytochrome P-450 in intestine and liver of spot (Leiostomus

       xanthurus) from a polycyclic aromatic contaminated environment. Aquatic Toxicology  17:

       119-132.                                                                ;

Winer, C. and Starfield, L.  1990.  Effect of Section 404(c) of the Clean Water Act on Remedial

       Action under CERCLA.  EPA Office of General Counsel Memorandum to Robert James.

       July 20.

World Wildlife Fund.  1992. Improving Aquatic Risk Assessment under FIFRA: Report of the

       Aquatic Effects Dialogue Group.  Washington, D.C.