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June 2k, 1987
REGULATORY APPLICATIONS
OF
SEDIMENT CRITERIA
U.S. Environmental P-ot.-otion
Region 5, Library (Di'L-16)
230 5. Doaiborn Street, Room 1670
Chicago, IL 60604
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FINAL REPORT
REGULATORY APPLICATIONS
OF
SEDIMENT CRITERIA
Prepared for:
U.S. Environmental Protection Agency
Criteria and Standards Division
401 H Street S.W.
Washington, DC 20460
June 23, 1987
Prepared by:
Battelle Ocean Sciences
397 Washington Street
Duxbury, HA 02332
(617) 934-0571
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TABLE OF CONTENTS
Page
ABSTRACT i
1.0 INTRODUCTION 1
2.0 BACKGROUND 2
3.0 OBJECTIVES 3
4.0 OVERVIEW OF DEVELOPMENT AND IMPLEMENTATION OF
SEDIMENT CRITERIA 5
5.0 APPROPRIATE APPLICATIONS 7
5.1 Summary of the Major Regulatory Programs of
EPA for Which Sediment Criteria Could be
Helpful 7
5.2 Recommendation of Appropriate Uses of
Sediment Criteria 13
5.2.1 Conceptual Considerations 13
5.2.2 Specific Applications 15
5.2.2.1 Disposal Site Designation 15
5.2.2.2 Permit Evaluation for Dumping
and Discharges 18
5.2.2.3 Disposal Site Monitoring 18
5.2.2.4 Site Cleanup and Restoration... 19
5.2.2.5 Environmental Impact
Statements (EIS's) 20
5.3 Outlook on Sediment Criteria Development 21
6 . 0 SUMMARY AND RECOMMENDATIONS 21
7.0 REFERENCES 24
APPENDIX A Discussion of a Survey of Needs and Uses
for Sediment Criteria A-l
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TABLE OF CONTENTS
(Continued)
LIST OF TABLES
Table 1. Seme of the Major Laws and the Sections
Within These Laws to Which Sediment
Criteria May Be Relevant 8
Table 2. Summary of Applications of Sediment Criteria
in Implementing Key Sections of Some Major
Envi ronmental Laws 16
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ABSTRACT
This report briefly describes the development of sediment
criteria, discusses their utility and appropriate regulatory
applications, and recommends steps to enhance the acceptance of
sediment criteria by the regulatory and regulated communities.
The report is based on the collective thoughts of the chemists,
biologists, and aquatic toxicologists on the EPA Sediment
Criteria Technical Steering Committee, and the results of a
survey of the regulatory and regulated communities interested in
sediment criteria.
The first criteria values developed will be useful to help
identify problem and potential problem areas and, in some cases,
the need for more specific studies to determine the likelihood of
adverse impacts. As developmental studies progress and data
supporting the developed criteria improve, the utility of the
criteria will increase. (^Sediment criteria will be useful in
implementing a number of laws, primarily those involving siting,
permitting, or monitoring of waste disposal; identification or
cleanup of contaminated areas, and preparation of environmental
impact statements. )The development of sediment criteria is a new
effort and the exact role of these criteria in environmental
protection is in the earliest stages of development. As under-
standing of contaminated sediments improves and the role of
sediment criteria becomes better defined, it is important that
this progress be communicated to all who are interested.
Continuing scientific review of the process of criteria
development is essential.
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FINAL REPORT
REGULATORY APPLICATIONS
OF
SEDIMENT CRITERIA
Prepared for:
U.S. Environmental Protection Agency
Criteria and Standards Division
401 M Street S.W.
Washington, DC 20460
June 23, 1987
Prepared by:
Battelle Ocean Sciences
397 Washington Street
Duxbury, MA 02332
1.0 INTRODUCTION
Sediment quality has been of interest to scientists for years
because contaminants in the aquatic environment often accumulate
to higher concentrations in sediments than in the overlying
water. Contaminated sediments may, in turn, act as a source from
which these contaminants can be released into the overlying
waters. To better accomplish their environmental protection
missions, regulatory agencies have continually sought a scien-
tific basis for regulating these contaminants in sediments.
Because sediments play a key role in contaminant interactions
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with the aquatic environment, they are of great interest in a
large and growing number of regulatory programs. The differing
objectives and priorities of these programs result in a variety
of potential applications for sediment criteria. This report
summarizes the applications and recommends appropriate uses and
limitations for sediment criteria. The report will help give EPA
a strong basis for adding sediment criteria to the available
regulatory tools.
2.0 BACKGROUND
The development of water quality criteria (EPA, 1980) has been
one of the major continuing efforts in protection of the aquatic
environment. These criteria address the potential impacts of
dissolved contaminants in the water column. It has long been
recognized that dissolved chemicals become associated with, and
accumulate in, sediments. Although this raised environmental
concerns, techniques were not available for developing nationally
applicable sediment criteria. Numerical guidance based on the
presence of elevated concentrations of chemicals in the sediment
was developed in some areas (Engler, 1980). However, sediment
criteria based on the relationship of contaminant concentrations
to biological effects were not developed, because of inadequate
scientific understanding of the complex ways the many possible
combinations of mineral and organic constituents in sediment
interact to influence the biogeochemical behavior, and thus
effects, of contaminants. In the absence of effects-based
sediment criteria, a variety of approaches have been used to
evaluate potential environmental effects of contaminated sedi-
ments. Many of these approaches have emphasized the presence of
contaminants in sediments, rather than the biological effects of
those contaminants. Examples of such approaches (reviewed by
Engler, 1980) include physical characterizations, sanitary
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engineering measurements (e.g., biological oxygen demand), and
bulk or total sediment chemistry. A more effects-oriented
approach came into use with the analysis of sediment elutriates
and the interpretation of results by comparison to effects-based
water quality criteria (EPA, 1975). Bioassays and bioaccumulation
tests have only recently been widely used to directly evaluate
the potential environmental effects of contaminated sediments
(EPA/CE, 1977).
All the approaches mentioned above, as well as many variations,
had specific characteristics that made them more suitable for
some applications than for others, and almost as many sediment
evaluation techniques were developed as there were sediment
programs. These evaluation techniques were of little use for
evaluating sediments on a national basis because the results from
one sediment could not be extrapolated to other sediments, and
thus the evaluation had to be repeated for every sediment of
concern. Over the past dozen years, scientific advances in a
number of fields have combined to improve the understanding of
the environmental behavior of several classes of contaminants in
sediments enough to allow development of effects-based sediment
criteria that are applicable to a range of sediments.
3.0 OBJECTIVES
The objectives of this report are to
• Identify the regulatory programs of EPA in which
sediment criteria could be most helpful,
• Recommend appropriate present and potential uses of
sediment criteria by EPA,
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Evaluate the utility, including both appropriate
applications and limitations, of sediment criteria
to major regulatory programs.
This report is based on the contributions of persons with
knowledge of the biological, chemical, and legislative issues
relevant to sediment criteria. The report also reflects perspec-
tives and insights gained through the EPA Sediment Criteria
Technical Steering Committee. In addition, a survey of the
regulating and regulated communities was conducted to verify the
needs and potential uses of sediment criteria in specific
programs. A total of 29 respondents were selected to participate
in the surveys based on their involvement with sediment-related
environmental regulations. The survey used a questionnaire
designed to direct respondents through a discussion of three
major topics (1) the need for sediment criteria, (2) the
characteristics that would make the criteria suitable for their
applications (including legislative applicability), and (3) the
specific chemicals for which sediment criteria are needed.
Detailed questions on each topic encouraged full consideration of
each subject to provide an accurate characterization of need.
Interviews were conducted with respondents from eight EPA
Regional Office, three EPA Environmental Research Laboratories,
five EPA Headquarters Offices, two offices of the National
Oceanic and Atmospheric Administration (NOAA), five offices of
the Army Corps of Engineers, three state regulatory offices, two
academic institutions, and one public utility environmental
affairs office. A complete description of the survey and a
discussion of the results are presented in Appendix A.
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4.0 OVERVIEW OF DEVELOPMENT AND IMPLEMENTATION
OF SEDIMENT CRITERIA
The first step in the development of sediment criteria was to
conceptualize approaches by which sediment criteria might be
derived. The most promising of these approaches provides the
basis for sediment criteria that relate sediment contaminant
concentrations to potential for biological effects. This
approach is built on practical applications of the concepts of
,11) fugacity (Mackay, 1979; Mackay and Paterson, 1981, 1982), the
tendency of a chemical to move from one medium to another, and
X2) equilibrium partitioning (Pavlou, 1984), the desorption of a
chemical from sediment into the water, and vice versa, until a
steady state is reached. The approach utilizes the concepts of
fugacity and equilibrium partitioning to calculate movement of
the compound from the sediment to the water, and uses chronic
water quality criteria to indicate the potential biological
effects of the chemical in the water. Thus, the concentration of
chemicals in the sediment can be related to biological effects on
aquatic organisms. Using this approach, tentative criteria for a
few chemicals were developed (Pavlou and Weston, 1984). These
criteria provided an initial test of the concept of equilibrium
partitioning as the basis for sediment criteria.
Testing is under way at Battelle, EPA Laboratories, and several
universities to develop empirical support for key aspects of the
equilibrium partitioning approach that are presently supported by
theory or data from other contexts, but have not been demon-
strated in the context of sediment criteria. Within the next
year or so, these developmental efforts will produce sediment
criteria supported by sufficient data to be used in certain
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applications for the nonpolar organic chemicals for which there
are chronic or continuous exposure water quality criteria.
The first sediment criteria developed will have a limited
database, but it will be sufficient to make the criteria useful
in many applications. For example, sediment criteria could
delineate three groups of sediments: those with contaminant
concentrations above, below, or near the sediment criteria. In
many cases, regulatory decisions based on the potential adverse
impacts of sediments in the first and second groups could be made
without further testing. In some applications regulatory
decisions concerning sediments in the third group might require
more specific chemical and biological testing to help determine
the risk of adverse impact. Statistical uncertainty analyses are
being performed to provide objective guidance on choosing
confidence limits around the criteria appropriate for differen-
tiating the groups of sediments for various purposes. Sediment
criteria used in conjunction with uncertainty analysis will
provide a practical means of making and supporting regulatory
decisions.
At present these chemicals are
Freshwater Saltwater
chlorpyrifos dieldrin
dieldrin DDT
DDT endrin
endrin methoxychlor
lindane mirex
methoxychlor
mirex
parathion
Chronic water quality criteria also exist for chlordane, endo-
sulfan, heptachlor, toxaphene, and total PCB, but these chemicals
are mixtures of many different compounds having a range of
partitioning behaviors, and thus partitioning values sufficiently
representative to use in sediment criteria calculations are not
available.
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Sediment criteria can soon be offered for some nonpolar organic
chemicals. As chronic or continuous exposure water quality
criteria become available for more nonpolar organics, sediment
criteria could be developed for these chemicals. In the absence
of chronic water quality criteria, lowest observed effects levels
or water quality advisories might be used to calculate sediment
values useful for some applications. However, there would be
less confidence in these values than in sediment criteria based
on chronic water quality criteria. The desirability of using a
basis other than chronic water quality criteria for sediment
criteria calculations should be carefully evaluated. The
equilibrium partitioning approach is theoretically as applicable
to metals as to nonpolar organics, and research is currently
underway to make this a reality.
Just as water quality criteria development procedures are
constantly being reviewed and improved, methods used in the
development of sediment criteria should undergo similar review
and improvement efforts. This would result in a progressively
broader range of uses for sediment criteria.
5.0 APPROPRIATE APPLICATIONS
5.1 Summary of the Major Regulatory Programs of EPA
for Which Sediment Criteria Could Be Helpful.
The Clean Water Act of 1977 gives the U.S. Environmental
Protection Agency (EPA) regulatory authority to develop sediment
criteria, as does other legislation (Table 1). Under the Clean
Water Act, EPA has the responsibility for protecting the
chemical, physical, and biological integrity of the Nation's
waters. Section 104 of the Act authorizes EPA to establish
national programs for prevention, reduction, and elimination of
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TABLE 1. SOME OF THE MAJOR LAWS AND THE SECTIONS WITHIN THESE LAWS
TO WHICH SEDIMENT CRITERIA MAY BE RELEVANT.
LAW
PURPOSE
Clean Water Act
of 1977
Section 115
Section 301
301(b)
301(h)
Section 402
Section 404
Establishes authority to restore and
maintain the chemical, physical, and
biological integrity of the Nation's
waters.
Provides authority to identify the location
of in-place pollutants with emphasis on
toxic pollutants in harbors and navigable
waterways.
Establishes effluent limitations.
Provides for effluent limitations for
priority pollutants from point sources,
other than publicly owned treatment works.
Modifies discharge permits for discharge
from publicly owned treatment works.
Authorizes the National Pollution Discharge
Elimination System (NPDES) for regulating
the discharge of pollutants from point
sources.
Establishes permits for discharge of
dredged or fill material into navigable
waters of the U.S.
Clean Water Act
of 1987
Section 104
Section 118
Establishes authority to protect the
chemical, physical, and biological
integrity of the Nation's waters.
Establishes national programs for the
prevention, reduction, and elimination of
pollution through research, experiments,
and demonstrations.
Requires annual reports on the status of
pollutants in sediments of the Great Lakes,
and removal of sediments with toxic
pollutants.
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TABLE 1. (Continued)
LAW
PURPOSE
Section 304(a
Authorizes development and publication of
criteria reflecting the scientific
knowledge on the environmental effects of
pollutants.
Marine Protection,
Research, and
Sanctuaries Act
of 1972
Section 102
Section 103
Provides authority to regulate the
transportation for dumping and the dumping
of material into ocean waters.
Authorizes dumping permits for
sludge and industrial wastes.
sewage
Authorizes permits for transportation of
dredged material for the purpose of dumping
into ocean waters.
Resource Conservation
and Recovery Act
of 1976
Section 301
Authorizes efforts to promote the
protection of health and environment and to
conserve valuable material and energy
resources by regulating the treatment,
storage, and transportation of hazardous
wastes that have adverse effects on health
and the environment.
Establishes criteria for identification
listing of hazardous waste.
and
Toxic Substances
Control Act
Section 4(a)
Authorizes regulation of chemical
substances and mixtures that present an
unreasonable risk of injury to health or
the environment.
Authorizes development of testing methods
including toxicity testing.
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TABLE 1. (Continued)
LAW PURPOSE
Section 4(e) Authorizes development of priority list for
promulgation of procedures under Section
4(a).
The Federal Gives authority to protect health and
Insecticide, environment against unreasonable adverse
Fungicide, and effects from application of insecticides,
Rodenticide Act fungicides, and rodenticides.
National Ocean Confers authority to coordinate pollution
Program Act programs amongst the federal agencies
involved in marine research, monitoring,
and regulations.
10
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pollution through research, experiments, and demonstrations.
Section 104(n)(l) specifically provides for the study of the
effects of pollution, including sedimentation, on aquatic life in
estuaries. Section 304(a)(l) directs EPA to develop and publish
criteria for water quality that reflect the latest scientific
knowledge on the environmental effects of pollutants, including
factors affecting organic and inorganic sedimentation, in various
types of receiving waters. Section 404 authorizes the develop-
ment of approaches to prevent unacceptable adverse impacts of
discharges of dredged or fill material into waters of the United
States. Section 103 of the Marine Protection, Research and
Sanctuaries Act of 1972 (MPRSA or Ocean Dumping Act) also pro-
vides for the development of approaches to evaluate and regulate
the environmental effects of discharges, including dredged
material, into the ocean. Table 1 summarizes the major legis-
lation which provides explicit or implicit authority for EPA to
develop and implement sediment criteria.
The various offices and programs concerned with contaminated
sediments have different regulatory mandates and continue to have
different needs and applications for sediment criteria. For
example, under Section 402 of the Clean Water Act, the National
Pollution Discharge Elimination (NPDES) program could use
sediment criteria to assist in evaluating the need for modified
restrictions on discharges. A possible use in implementing
Section 404 of.the Clean Water Act is for evaluating sediments
proposed for dredging and disposal at an aquatic disposal site.
The Superfund program could use sediment criteria in determining
the degree of cleanup required at a site.
11
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Because each regulatory need is different, criteria developed
specifically to meet the needs of one office or program may have
to be implemented in a different manner to meet the needs of
another office or program. For example, sediment criteria appro-
priate for evaluating impacts of contaminated sediments in an
aquatic system would not provide a scientifically sound evalua-
tion of the effects of that same sediment if it were dredged and
disposed at a site on land where the biogeochemistry of the
disposal sediment would change as it dried.
Because of the variety of offices and programs interested in
sediment criteria and the different needs and potential appli-
cations, the criteria may be used in implementing several
different laws and many different EPA regulations. Seventy-six
percent of those interviewed in our survey cited the Ocean
Dumping Act and the Clean Water Act as mandates for regulating
contaminated sediments. Other respondents cited mandates under
the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA)
and the Toxic Substances Control Act (TSCA), which establish
regulations for chemicals being registered or re-registered,
Superfund, Great Lakes Sediment Quality Guidelines, and the NPDES
Program. In addition, other Federal agencies will probably use
EPA's sediment criteria in their own environmental regulations.
States are also likely to use any sediment criteria developed by
EPA as a basis for State standards. The potential impact of
sediment criteria on other agencies and states, as well as EPA,
must be recognized and considered when these criteria are
developed and implemented.
Because development of sediment criteria is a new undertaking and
supporting data are still being generated, procedures currently
under development will require modification in the future,
resulting in improved criteria values and changes in the ap-
propriate applications of the criteria. Therefore, it is
12
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important that each new criteria development and promulgation
document explain the degree of environmental protection
' /
associated with the criteria values and the confidence to be
f
placed in the criteria. This will minimize the chances of
misapplication of the criteria. In order to minimize the
occurrence of misapplication, survey respondents considered it
very important to clearly describe the appropriate applications
of the sediment criteria, the defined level of protection, and
the specific effects at which the criteria are aimed.
5.2 Recommendation of Appropriate Uses of
Sediment Criteria.
5.2.1 Conceptual Considerations
Technically sound use of sediment criteria derived by a single
method will require that the criteria be used in different ways
for different purposes. For example, a criterion developed to
indicate a "no effect" concentration might be very useful in
monitoring of disposal sites, but might have to be used with some
sort of application factor to be administratively acceptable as a
target concentration in the cleanup of a waste site. Otherwise,"
the no effect value could be so low relative to the concentra-
tions at the waste site and the size of the site that achieving
such a goal would be out of the question environmentally,
technologically, and financially.
There will also be limits beyond which sediment criteria
developed by a single method will not be technically applicable.
For example, sediment criteria now being developed using equilib-
rium partitioning and chronic water quality criteria will be
useful for evaluating the potential impacts of sediments in
water. However, these sediment criteria will not be technically
applicable to evaluating the potential impacts of those same
13
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sediments if they were dredged and disposed out of the water at
an upland site where they would dry. Such disposal would change
the geochemical conditions of the sediment, altering the
bioavailability of associated contaminants and thus their
environmental effects. In such cases, impact, evaluation would
have to be based on multi-media assessments.
Environmental interactions and effects of sediment-associated
contaminants are complex, variable, and not completely under-
stood. Therefore, it has long been common wisdom that no single
test can be relied upon to provide a complete characterization of
potential problems in all circumstances. This need for multiple
tests will also be true for some applications of sediment cri-
teria, at least until they become well established. Site-
specific information can be incorporated into sediment
evaluations as appropriate.
Survey respondents expressed several perspectives on the idea
that sediment criteria would have to be applied differently to
meet different needs. Some were concerned that sediment criteria
appropriate for use in clean areas would not be usable in highly
contaminated areas, or where high concentrations of chemicals
occur naturally. Cases of very high contamination levels were
another concern of several respondents. One respondent was
afraid that several harbors would never be below the effect
levels for PCBs. Several respondents suggested that sediment
criteria be established on a site-specific basis. Many survey
respondents saw utility for sediment criteria as a key step in a
tiered or stepwise evaluative approach. In such an application,
sediment contaminant concentrations less than the sediment
criteria would not be of concern. Concentrations near the
criteria might indicate the need for more detailed chemical or
biological studies to determine the potential for adverse
impacts. Sediment contaminant concentrations exceeding the
14
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sediment criteria could be considered to pose a risk of adverse
environmental impact without further evaluation. As the sediment
criteria development process is refined, the ability to evaluate
concentrations near the criteria will increase. Because sediment
criteria developed for one purpose may not be directly applicable
in other contexts, it is important to identify intended uses when
a derivation method is selected, and to describe appropriate
applications for sediment criteria developed by that method and
for that purpose.
5.2.2. Specific Applications
Potential applications of sediment criteria can be found in a
number of laws. The specific applications under these laws
differ, but fall into several distinct categories. The primary
categories of applications in some of the major laws are
summarized in Table 2, which is intended to be illustrative
rather than exhaustive. The utility and limitations of sediment
criteria would be very similar within each category of applica-
tion, regardless of the law involved. That is, sediment criteria
would be used for site designation in much the same way under any
law involving site designation.
5.2.2.1 Disposal Site Designation
Dumpsites. Sediment criteria could be useful for designating
dumpsites under several laws (Table 2). For example, in dumpsite
designation under Section 102 of the Ocean Dumping Act, sediment
transport patterns predicted for the site by field studies or
model calculations should be evaluated to determine their impli-
cations for environmental impact. This evaluation could be
accomplished by combining transport predictions with sediment
contamination data interpreted in comparison to sediment cri-
teria. The use of sediment criteria in this context would help
15
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evaluate the potential for impact in the surrounding area as a
result of sediment-associated contaminants being transported from
the site. Sediment criteria could also be useful in evaluating
the potential impact of contaminants that are transported away
from the site in dissolved or microparticulate form and are
predicted to later accumulate in sediments away from the disposal
site. Such information is important in evaluating the accepta-
bility of candidate dumpsites under a number of laws (Table 2).
An advantage of sediment criteria in this context is that they
would add objectivity and consistency to the evaluation of the
potential impact of sediment-associated contaminants. They would
also assist in reliably distinguishing potential problem sites
from those for which there is little cause for concern. However,
to be most useful in these contexts, sediment criteria would have
to be available for all the major contaminants of concern, and
would have to have undergone sufficient scientific and public
review to make them acceptable to the regulating and regulated
communities.
Discharge Sites. The application of sediment criteria to the
siting of outfalls or discharges (Table 2) would be similar to
the application of criteria in the dumpsite designation process.
For example, in outfall siting under Section 301 of the Clean
water Act, models or field data could be used to predict the
accumulation of dissolved and particulate-bound contaminants in
the sediment. Sediment criteria could then be used to help
determine whether those accumulations would constitute a
potential for unacceptable adverse impact. Discharge siting
under several other laws (Table 2) could use sediment siting in a
similar way. Advantages and limitations of sediment criteria for
discharge siting would be similar to those mentioned above in
relation to dumpsite designation.
17
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5.2.2.2 Permit Evaluation for Dumping and Discharges
Once a disposal or discharge site was designated, sediment
criteria could be used in the permitting process. For example,
in evaluating a discharge permit under Section 402 of the Clean
Water Act, sediment criteria could be used to help evaluate the
potential impact of contaminants that would be expected to
accumulate in the sediments. These might be dissolved or
associated with micro-particulates, and could accumulate in
sediments at some distance from the site, or contaminants might
occur in the discharged material in solid forms that would settle
rapidly to the bottom near the site. In either case, sediment
criteria could be used to help evaluate the potential impact of
such contaminants in permit evaluations under several laws (Table
2).
Sediment criteria would help in permit evaluation by increasing
the objectivity and consistency of the evaluation of potential
contaminant impacts. Many survey respondents believed that in
order to be useful in permit evaluations there would have to be
sediment criteria for many different chemicals. Many respondents
also thought use in permit evaluations, even for purposes, would
require extensive review of the derivation process and the
criteria values by the scientific community and public. Use in
permit evaluation would also require criteria for many chemicals.
5.2.2.3 Disposal Site Monitoring
Disposal site monitoring implies that some action will be taken
if the data exceed some level indicating a problem is imminent.
Sediment criteria could be the basis for determining whether
contaminants were accumulating in sediment to the extent that a
potential effects threshold was being approached or exceeded.
For example, in monitoring a discharge under Section 301 of the
18
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Clean Water Act, contaminants would be analyzed in the sediments
around the discharge. The values could be compared to sediment
criteria to help determine the likelihood of impact. Sediment
criteria could be used in monitoring disposal sites and dumpsites
under several laws (Table 2).
Sediment criteria could be particularly valuable in site monitor-
ing applications, where sediment contaminant concentrations
gradually approaching the criteria over time could be a reliable
early warning of upcoming problems. Such a warning would provide
an opportunity to take corrective action before adverse impacts
occurred. Sediment criteria would have to be available for a
large number of chemicals to be most useful in site monitoring.
5.2.2.4 Site Cleanup and Restoration
Because many contaminants sorb to sediments, sediment criteria
could be helpful in evaluating the potential environmental risk
posed by in-place pollutants. For example, under Section 303 of
the Clean Water Act, sediment criteria could be used as a point
of comparison to help determine whether an area might benefit
environmentally from cleanup activities. Under this and other
laws (Table 2) sediment criteria could be used to help (1)
determine the need for cleanup, (2) set a goal for cleanup,
thereby helping to determine the size of the area to be addressed
and thus the cost of the cleanup, and (3) assess the degree of
benefit to be realized by cleaning up an area to meet the
criteria.
In the context of hazardous waste sites or highly contaminated
areas (Table 2), sediment criteria developed to indicate no
effect concentrations might have to be used with some sort of
19
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application factor. Sediment criteria could prove to be of value
in assessing the benefit and cost of complete cleanup and perhaps
in setting different cleanup goals for portions of sites with
different degrees of contamination.
Evaluation of in-place pollutants in aquatic sediments could be
one of the most appropriate applications of sediment criteria.
The administrative ease of having established numbers for
comparison could tend to encourage overreliance on the criteria.
However, identification of candidate areas for cleanup is likely
to be viewed as a less precise process than issuing or denying a
permit, and one in which there would be less incentive to adhere
rigidly to a fixed number. The utility of sediment criteria in
evaluating candidate areas for cleanup would increase if criteria
were available for a large number of chemicals.
5.2.2.5 Environmental Impact Statements (EISs)
Sediment criteria could be helpful in evaluating alternatives in
the preparation of EISs (Table 2) under the National Environ-
mental Policy Act. In this context, sediment criteria could
provide a quantitative (although partial) basis for comparing the
environmental benefits or consequences of various alternatives,
including the no-action alternative, to the proposed action. The
use of sediment criteria in this context would require field or
model data to predict the accumulation of contaminants in sedi-
ments as a result of the proposed action and each of the
alternatives. Sediment criteria could then be used to help
evaluate the potential for unacceptable adverse impacts
associated with each of the alternatives.
20
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5.3 Outlook on Sediment Criteria Development
The comments of some survey respondents indicate that everyone
interested in sediment criteria may not be fully familiar with
the process by which the criteria are being derived.
It is important to recognize that the development of sediment
criteria is a new process and many issues related to criteria
derivation processes, data requirements, important chemicals,
appropriate uses, application procedures, etc., are being
addressed as they arise. Sediment criteria development is in the
early stages of a multi-year process. Although the criteria now
being developed will be useful in many applications, the number
of criteria and their utility will increase with time as the
derivation process becomes better established and sediment
criteria gain acceptance by the scientific and regulatory
communities. Because the development of sediment criteria is
new, there is a considerable interest in the process and
uncertainty about appropriate applications of the criteria. The
efforts to keep all interested parties informed of the sediment
criteria process have increased awareness of the criteria.
Progress in sediment criteria development will be enhanced by the
increasing involvement of regulators and scientists in decisions
regarding future directions of the sediment criteria effort.
This involvement will be encouraged by the continuing effort to
make sediment criteria information available to all interested
parties.
6.0 SUMMARY AND RECOMMENDATIONS
The greatest utility of sediment criteria is likely to be in a
variety of applications to identify existing and potential
problem areas. The first sediment criteria that are developed
21
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may best be used to confirm the potential impact of highly
contaminated sediments. With less contaminated sediments the
criteria may best be used as a screening tool. As sediment
criteria derivation processes are refined, the criteria will
have greater applicability to sites with a greater range of
sediment contaminant concentrations.
Implementation of many laws and regulations can be improved or
made easier with sediment criteria. These laws and regula-
lations have to do mainly with siting, permitting, and
monitoring of discharges and dump sites; identification and
cleanup of contaminated areas; and preparation of environ-
mental impact statements.
Both the regulatory and regulated communities need to continue
to have access to all information and documentation developed
in support of this effort. As progress is made on sediment
criteria development, the dissemination of information becomes
more critical to minimize unnecessary concerns and misdirec-
tions. Readily available information on the status, progress,
and direction of sediment criteria development is the key to
ensuring unnecessary uneasiness or concerns are kept to a
minimum. It has been the practice in the past to ensure that
any person with an interest in sediment criteria development
will be able to obtain copies of all documents and work plans
generated in support of this effort. This practice should
continue and become more pro-active to make people aware of
the existence of key documents.
The scientific and administrative review underway and planned
for the sediment criteria now being developed should be widely
publicized. All those concerned with sediment criteria
development should be made aware of the scientific oversight
22
-------
of the developmental work by the Sediment Criteria Technical
Steering Committee, the past and planned presentations of work
at national scientific meetings such as the Society for
Environmental Toxicology and Chemistry (SETAC), and the
planned review of the developmental process and the criteria
by the EPA Science Advisory Board (SAB).
A technical workshop to allow the scientific community to
critique the sediment criteria development process should be
scheduled before the process is finalized. This should be a
much larger and more diverse group than the Technical Steering
Committee. The group should be provided with the physical/
chemical model for sediment-contaminant-water interactions,
and the protocols for chemical and biological tests, to be
used in developing sediment criteria. The workshop should be
followed by a Technical Steering Committee meeting to review
and revise the criteria development process as appropriate in
consideration of the results of the workshop.
Sediment criteria should be developed for as many chemicals as
possible. Sediment criteria will be of limited use until they
are available for most of the metals and organic compounds
commonly of concern in sediments. Ongoing research should
provide a method for developing sediment criteria for metals.
The paucity of chronic water quality criteria for nonpolar
organic compounds is the major limitation on developing
sediment criteria for organic compounds. Coordination between
the water quality criteria and sediment criteria programs to
increase the number of nonpolar organic compounds for which
chronic or continuous exposure water quality criteria are
being developed would result in a one-for-one increase in the
number of sediment criteria available.
23
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7.0 REFERENCES
Engler, R.M. 1980. Prediction of Pollution Potential Through
Geochemical and Biological Procedures: Development of
Regulatory Guidelines and Criteria for the Discharge of
Dredged and Fill Material. R.A. Baker (ed.)
Contaminants and Sediments. Ann Arbor Science, Ann
Arbor, Mich.
EPA, 1975. Navigable Waters: Discharge of Dredged or Fill
Material. Federal Register 40 (173), September 5,
1975.
EPA. 1980. Water Quality Criteria Documents; Availability.
Federal Register 45(231), November 28, 1980.
EPA/CE. 1977. Ecological Evaluation of Proposed Discharge of
Dredged Material into Ocean Waters; Implementation
Manual for Section 103 of Public Law 92-532 (Marine
Protection, Research, and Sanctuaries Act of 1972).
July, 1977 (second printing April 1978), Waterways
Experiment Station, Vicksburg, Miss.
Mackay, D. 1979. Finding fugacity feasible. Environ. Sci.
Technol. 13(10:1218-1223.
Mackay, D. and S. Paterson. 1981. Calculating fugacity.
Environ. Sci. Technol. 15(9):1006-1014.
Mackay, D. and S. Paterson. 1982. Fugacity revisited. Environ.
Sci. Technol. 16(12):654A-660A, 1982.
24
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APPENDIX A
A-l
-------
APPENDIX A
DISCUSSION OF A SURVEY OF NEEDS AND USES FOR SEDIMENT
CRITERIA
1.0 INTRODUCTION
To supplement the technical expertise and regulatory knowledge of
the sediment criteria development team and review group, it was
desirable to contact the regulatory and regulated communities to
confirm the characteristics and potential uses of sediment
criteria for a variety of applications. Therefore, discussions
were held with key personnel in EPA offices and programs as well
others that have potential uses for sediment criteria. This
appendix reports the results of these discussions.
2.0 METHODS
2.1 Identification of Key Personnel
The original list of interview candidates was compiled by Drs.
Richard Peddicord, James Fava, Christina Cowan, and H. Suzanne
Bolton. An attempt was made to contact representative EPA
offices in each coastal or Great Lakes region that has expressed
an interest in sediment criteria. Additional contacts were
solicited at the conclusion of each interview. Ultimately, the
list of interview candidates increased to over 100, reflecting
the wide interest which exists in sediment criteria.
A-2
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2.2 The Interview Process
A questionnaire was designed for use during telephone discussions
which directed participants through a three-tiered examination of
their need for sediment criteria, the characteristics which would
make the criteria suitable for their applications, and the
specific chemicals for which sediment criteria are needed. The
questionnaire was carefully planned to minimize the possibility
of influencing the responses by the phrasing or context of the
questions. The questionnaire (Table A-l) was approved by the
Work Assignment Leader and the program office prior to the
interview process. The interview format began with a descriptive
introduction of the purpose of the survey, explaining that
Battelle was conducting the study for EPA Criteria and Standards
Division. The stated purpose of the interview was to assess the
need, the potential applications, and the desired scientific
characteristics of sediment criteria. The interview was
conducted in a conversational tone using follow-up questions to
clearly identify the candidate's position on each topic. Because
responses were not biased by limits imposed by a particular
question, an accurate characterization could be made in the final
evaluation of the survey results.
3.0 RESULTS AND DISCUSSION
A total of 29 interviews were conducted between March 4 and May
8, 1987. The scope of contacts included eight EPA Regional
Offices, three EPA Environmental Research Laboratories, five EPA
Headquarters offices, two National Oceanic and Atmospheric
Administration (NOAA) offices, five Army Corps of Engineers
offices, three state regulatory offices, two members of the
academic community, and a public utility (Figure A-l). The
discussion that follows is based on the results of these
A-3
-------
TABLE A-l. QUEMILSKMRS USED DURING TELEPHONE COIfVERSATIOKS CUBLUWLHG SEUlJgJTl OUTEULA DEVrLOPHEWT AID USE.
D»te: ltam»: Organisation: __ Phoae:
00 TOD HAVE A MEED FOB SKDDBTT QUALITT OUTDIA7
Is your office concerned (involved) with environmental effects of contaminated sediment? Soil?
In your opinion, what is the regulatory mandate of your office for sediment protection? under what existing laws or
regulations would you use sediment criteria?
[ ) Clean Water Act I ) Ocean Dumping [ ] ItEPA [ J EIS Other:
In your opinion, are new, enabling regulations needed in order for your office to regulate sediment contamination using
sediment quality criteria?
Mhat approaches are you now using to determine whether or not sediment may be considered a problem (contaminated)?
In your opinion, how would the development of SQC improve the way your office presently deals with contaminated sediments?
(Compared to whatever guidelines you working with now?)
Would you envision a Sediment Quality Criteria (SQC) as possibly becoming the basis of state regulatory requirements?
DO TDD BED TO BHOUHK POTOTTAL EWTMOMBZAL IMPACTS OT CCeTEMtDBaK
Two conceptual approaches have been identified for using SQC. One approach would present a single value or a tingle
value with uncertainty to be used as a pass-fail regulation, the second approach would present the SC as the first-cut
in sequence of tiered steps. Which type of approach would be most useful to you in regulating sediments: Pass-fail
Sequence of tiered steps
If p«*s—fail, which would probably be most useful to your office:
A single value or a single value with uncertainty ? Discussion.
If a sequence of tiered steps), which would be most useful to your office?
A technique such as bioassay which could be used as a first-cut flag or as base for litigation?
or a sequence of tiered steps similar to that presently used in developing water quality criteria? Discussion.
What level of scientific strength do you feel you need for SQC compared, for instance, with water quality criteria?
In your opinion, does the derivation procedure need to go through formal rule-making like water quality criteria?
WAT ABE m WjTOK CHEMICALS OF ' ' T1 II Kff IB SZBDBRS?
For what classes of chemicals would SQC be useful to you?
( 1 PCBs | ] Dioxin I 1 Metals: [ J chlorinated Pesticides
Other Specific Chemicals of Concern:
Other Comments:
Can you recommend other people who you think I should contact about this subject:
A-4
-------
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interviews and is intended to be illustrative rather than a
quantitative sampling of opinions. Responses are those of the
individual interviewee, and do not represent any consensus of
views in the respondents' organization or area. The results of
the survey, summarized in Table A-2, are discussed in the
following section.
3.1 Mandate for Regulatory Sediment Contamination
Of the 29 individuals contacted, 97% were concerned with the
environmental effects of contaminated sediments. The Ocean
Dumping Act and the Clean Water Act are the primary regulatory
mandates cited by those involved with sediment contamination,
representing 41 and 31%, respectively, of those interviewed.
Eighteen percent of those surveyed were involved with the
registration of chemicals, including pesticides, herbicides, and
new formulations. Eighteen percent were involved in Superfund
or Resource Conservation and Recovery Act (RCRA) cleanup issues,
and 17% evaluated sediments under National Environmental Policy
Act (NEPA) regulations.
3.2 Present Approaches Used in Sediment Contamination Regulation
In the absence of centralized guidelines, a variety of approaches
have been adopted. In many cases, no single method has been
adopted by similar offices or within regions. The approach taken
seems to be driven, at least in part, by the perceived magnitude
of the problems and the backlog of sites awaiting evaluation.
The two general approaches used to assess contaminated sediments
are case-by-case evaluations (59%) and mandatory bioassays (38%).
Where the case-by-case approach is used, historical data, bulk
chemical analyses, and bioassays are usually part of a sequence
of tiered decision-making steps. Results of bioassays are used
A-6
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TABU A-2. SUH9XI OF A TELCPBDKE SURVEY COHDUCTED BETWO3I KARCB 4 MID KM 8, 1987 WITH IHDIVIDUALS SELECTED FOR THE IS
IKVOLVEMBR WITH SEDDOBIT CJU'fUtlA DBVELOPMElfT AHD USE.
Hespoodent Categories
B C - D I
Percent of
Bespoodents
Number of Respondents:
N/A
It your office concerned with environmental
•ff»ctg of contaminated sediments?
Yes
No
Not Yet
100 100 100 100 100 80
20
97
3
In your opinion, what is (are) the regulatory
mandate!s) of your office for cedinent protection?
(More than one choice possible).
Ocean Dumping
Clean Water
FIFRA, TSCA
RICRA, Super fund
NEPA
SRPA
N/A
What approaches are you now using to determine
sediment contamination?
Case by Case Tiered Approach
Manditory Bioassays
N/A
How would the development of SQC improve the
way your office presently regulates contaminated
sediments? (Here than one choice).
Additional Weight in Decision-making
Provide Cutoff Number vs
Best professional Judgement
Eliminate Manditory Bioassays
No Effect (Would not use)
Would a sequence of tiered steps or a pass-fail
approach be most useful to you in regulating the
potential environmental impact of contaminated
sediments?
Tiered Steps
Pass - fail
Combination of Tiered Steps t Pass-Fail
Neither
60 75 33 67 - 20
60 25 33 67 20 20
20 - 66 60
20 12 33 33 20
20 37 - 33 -
- 12 - - -
33 - 80
40 50 - 100 100 60
60 50 100 20
_____ 3
40 25 33 67 60 60
40 38 - 40 40
12 33
20 25 33 33
80 62 100 67 100 60
12
- 12 - 33 - 20
20 12 20
41
31
18
18
17
4
7
59
38
3
45
34
10
17
76
4
10
10
A « Corpe of Engineers B - EPA tegional Offices C
I - Miscellaneous, P - EPA Headquarters Offices.
EPA Enviro
atal Research L*bortorieg, D - State Regulators,
-------
TABLE A-2. (Continued).
How would you use SC in decision-making?
First-cut Screening
Added Weight
TSCA Approach (cut-off effects criteria)
None of Above
Won't Use
What level scientific strength do sediment
criteria need to be useful and enforceable
for your office? (More than one choice).
Very Strong
Legally Defensible
More Research Needed
Advisory or Quidance
Peer Review
Need Specific Chemicals
Are new, enabling regulations needed in order
for your office to regulate sediment contamination
using sediment quality criteria?
fes
No
Maybe
N/A
Irrelevant
In your opinion, does the derivation procedure
need to go through formal rule-making like
water criteria?
Yes
No
Hope Not
Doesn't Care
Not Yet
N/A
Would you envision a Sediment Quality Criteria
becoming the basis of state regulatory requirements?
Yes
Maybe
Hope Not
No
N/A
20
40
-
-
40
60
-
60
20
20
-
20
60
-
-
20
-
20
20
20
20
20
20
20
20
-
40
Respondent Categories
38 33 67 40
50 67 33 60 20
- 60
- - - - 20
12
62 - 33 100 80
25 - 20 20
25 67 67 20
50 - 33 40 20
25 33 67 40 40
67 - 20
38 33 - 40 20
50 33 67 - 60
12 33 - - 20
60
33
25 33 - 60 80
12 33 33 20 20
25 - 33
_
25 - 33 20
12 33 - -
50 67 33 60 40
25 33 33 40 20
12 - 33 -
12
- 40
Percent of
m««nr«irWit
31
45
10
4
10
62
14
34
31
34
10
24
48
7
10
7
34
21
14
4
17
10
45
28
10
4
14
Sew previous page.
A-8
-------
either as for further work (chemical analyses or bioaccumulation
tests) or are, themselves, the endpoint used for decision-making.
In cases where bioassays are mandatory, these other parameters
may or may not be examined as part of the decision-making
process.
3.3 Applications and Advantages of Sediment Criteria
3.3.1 Immediate Applications
In general, many respondents (76%) envisioned using sediment
criteria as part of the tiered decision process they now use.
One respondent suggested: "Sediment chemistry values would be
compared to the sediment criteria. If sediment concentrations
were well below the criteria value, no bioassays would be
required and a permit would be issued. If sediment concentra-
tions were well above the sediment criteria values, bioassays and
more specific analytical chemistry would be mandatory. If
sediment concentrations were close to the sediment criteria
values, the amount and kind of future testing and analysis would
be determined by evaluation of the available data based on best
professional judgment."
3.3.2 Long-Range Applications
Most respondents are eager for some .type of sediment criteria and
readily suggested potential applications for sediment criteria.
In general, applications fall into three categories: prediction
and planning, baseline establishment, and expediting decision
making. In all these applications the desire for numbers based
on scientifically rigorous testing (i.e., lab and field verifi-
ication of the values) was universal. The regulation of
municipal and industrial discharges involves not only the types
of decisions required in dumping permits, but also long-range
A-9
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planning, since discharges represent what is essentially chronic
exposure. Sediment criteria would be useful in the planning,
prediction, and decision-making required in discharge permits.
3.3.2.1 Prediction and Planning
Dumping. There is a widespread desire for the ability to predict
both the potential short-term impact of the disposal process
itself and the long-term effects of dumping on the dumpsite
before regulating decisions are finalized. Sediment criteria
could help evaluate potential effects of contaminants
accumulating in sediments from various dumping activities.
Discharges. Sediment criteria could be used to help evaluate
trends in transport of contaminants from point and non-point
sources. They could be incorporated into software inventories
that would track present discharge levels from point sources, and
predict whether contaminant accumulation rates from all sources
would require action. Used in conjunction with effluent testing,
estimates of storm water run-off and other non-point source
contributions, and hydrologic models for specific water bodies,
sediment criteria could help evaluate the environmental
importance of dispersal, settling and accumulation of
contaminated sediments. Sediment criteria could be incorporated
into environmental fate and effects models to help assess the
potential for unacceptable adverse impact. Such predictive
models would require both lab and field testing before they could
be used with assurance.
Planning. Many states recognize the need to plan the use of
waterways and to anticipate the cumulative effects of many point
and non-point sources of pollution. Some states are in the
process of developing master plans for the use and protection of
A-10
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lakes, rivers, harbors and estuaries. Sediment criteria could be
incorporated into long-term planning as clean-up targets, or as
average maximum allowable levels.
3.3.2.2 Baseline Establishment
The need for baseline data is a common theme among respondents.
Most areas have no baseline or historical data which can be used
to help determine what is clean and what is contaminated.
Sediment criteria could help provide a target number for cleanup,
a comparative baseline for dredging and dumping decisions, and a
benchmark number for examination of the cumulative effects of
outfalls. Sediment criteria could be used in sediment surveys to
create contamination maps, noting trends of contamination spread
and patchiness, which could be used as indicators of the overall
condition of water bodies.
3.3.2.3 Decision-making
Sediment criteria would permit respondents to streamline the
permitting process. The crisis that many face is typified by the
respondent who said "I'm so backlogged with NPDES permits that I
don't even have time to think about sediments." While this is an
extreme case, the backlog of permits and decision making is
universal. This backload is created not only by the volume of
applicants but by the approach used by most offices in making
decisions on a case-by-case basis. In many cases the same
information is recreated with each application.
Dumping. Sediment criteria based on bioavailability could be
used to help determine whether additional testing were needed and
if so, what types of testing would be appropriate for a specific
site. One survey respondent thought "Sediment criteria might do
away with need for bioassays if the bulk chemistry analysis could
-------
litigation if the numbers are not "scientifically defensible...
rigorous...with strong teeth... hard...real..." Almost 34% of
respondents desired to see sediment criteria developed as the
water quality criteria were developed: with multispecies, round
robin testing, peer review, public scrutiny, and finally, Federal
Register publication. Some feel that both field and laboratory
testing are necessary to support the sediment criteria. Many
survey respondents recognized that this process could take 5 to
10 years, and suggested that sediment criteria advisories or
guidance documents be published in .the interim. On the other
hand, sediment criteria will require much less testing and
validation for the 31% of respondents who said they will use the
values only as guidance. In these cases, the values must only be
supported by "a good database that supports the criteria
derivation process."
In either case, most respondents believed that sediment criteria
should consider the interrelationships between sediment
contamination, bioaccumulation, and toxicity.
3.5 Legislation
3.5.1 Need For Formal Rulemaking
The mandate to regulate the contamination of sediments and to
remediate sediment contamination is contained explicitly or
implicitly within the framework of existing legislation. In
some cases, the decision-making criteria are contained in the
legislation itself. In order for sediment criteria to be
implemented in these cases, new legislation may be required.
Where the decision-making process is loosely defined and left to
the regulating office, it is unlikely that new legislation will
be required.
A-13
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Under its present mandate, the U.S. Army Corps of Engineers would
not use sediment criteria, alone, as specific cut-off numbers.
Because their mandate requires that decisions include other
considerations in addition to potential environmental impact,
sediment criteria would not, in themselves, drive the decision.
Because the Corps has no requirement to use sediment criteria
values, many Corps respondents (60%) feel that there is no need
for new regulations. In addition, sediment criteria could be
used as guidance within the context of present regulations.
Many respondents either were unsure or disagreed on whether new
legislation would be required in order for them to use sediment
criteria: 48% felt that no new regulations would be needed, but
31% thought that new legislation was possibly or definitely
required. In general, acceptance depended upon the specific
application for which sediment criteria will be used. If used as
a technical device, sediment criteria would not require new
enabling legislation because published technical documents become
articles of practice or support documentation for many regulating
offices. In fact, as one respondent said: "Sediment criteria
presented in guidance documents will be of more use to a wider
audience: formal structure loses application." On the other
hand, 34% felt that the sediment criteria should go through the
same formal rulemaking and review as did the water quality
criteria: 21% felt that formal rulemaking is not necessary and
another 17% felt that it is not desirable at this time. The
rulemaking process would provide the exposure to and comment from
the scientific community needed if sediment criteria are to be
used in litigation. One respondent stated, "If sediment criteria
do not go through the same rigor as the water quality criteria
they will be second-class citizens."
Some respondents thought that the Clean Water Act, the Ocean
Dumping Act, and Superfund may have to be modified in order to
_1 A
-------
use sediment criteria for some applications. Some feel that the
mandate to use sediment criteria may exist implicitly in water
quality criteria and that if sediment criteria are as environ-
mentally protective as water,quality criteria, there will be no
need for additional legislation. In freshwater applications,
some felt "it will be difficult to link discharges to elevated
contamination levels down-stream" in remediation efforts based on
sediment criteria without new legislation.
3.5.2 Legislation at the State Level
Based on the results of this study, 45% felt that sediment
criteria would become the basis of state regulations and another
28% saw a potential for this use. While there is a great need
for numerical guidance, 10% of the respondents at either Federal
or Regional offices expressed concern that numerical values
published by EPA would probably be written into state legislation
without full understanding of the intent and proper application
of the numbers. Therefore, legally and technically defensible
sediment criteria values are essential and would require both
public scrutiny and peer review through publication in the
refereed scientific literature.
Many states are creating and promulgating sediment criteria for
their own use. Both Washington and Wisconsin are developing
state-wide sediment criteria at present. Federal sediment
criteria and the methodology developed to derive these criteria
should augment the State efforts and provide a basis for meeting
multistate needs in interstate waterways.
3.6 Chemicals of Widest Concern
The specific chemicals for which sediment criteria are needed are
determined by the regulations and permits implementing the
-------
environmental laws. Some permits require testing of the full
suite of priority pollutants. Others require bulk analysis of
specific classes of chemicals or target individual chemicals. At
the state level, additional specific chemical analyses may be
requi red.
The six major classes of chemicals for which sediment criteria
are most needed according to the respondents are the heavy metals
(72%), followed by PCBs (59%), PAHs (41%), chlorinated pesticides
(34%), dioxins (24%), and "persistent compounds" (17%) (Table
A-3).
3.7 Examination of Major Concerns
Only 7% of those interviewed expressed no concern over the
present sediment criteria development strategy as they understood
it. All others voiced a variety of opinions about the need to
modify the development process. Over 50% expressed the opinion
that the present sediment criteria development is not sufficient-
ly effects-based. They felt that the criteria should include
risk assessment for a defined level of protection and should
include an assessment of the effects of bioaccumulation. Eighty
percent expressed some concern for the chemical methodology,
questioning the validity of extrapolating sediment criteria
derived from single-chemical testing to complex mixtures and a
variety of geochemical parameters, and the inadequacy of the
present state of the science to sample and measure contaminant
concentrations consistently. Forty-one percent expressed concern
about the potential for over- or under-protecting sediments, the
misuse of sediment criteria values by the states, or overly rapid
development of sediment criteria. These misunderstandings can be
addressed if the long-range plans for sediment criteria
development and implementation are described. Open communication
A-16
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TABLE A-3.
CHEMICALS NAMED BY SURVEY RESPONDENTS AS ONES FOR WHICH
SEDIMENT CRITERIA WOULD BE USEFUL. RESULTS ARE REPORTED AS
THE PERCENT OF RESPONDENTS IN EACH CATEGORY AND AS THE
PERCENT OF THE TOTAL NUMBER INTERVIEWED.
Chemical Type
Heavy metals
PCBs
PAH
Chlorinated Pesticides
Dioxin
Persistent compounds
Carcinogens
Chlorinated hydrocarbons
Total organics
Priority Pollutants
Oil & Grease
Furans
DDT
Neutral hydrophobics
Bioaccumulatable cmpds.
Charged Organics
Total Phosphorus
Volatile Organics
Organic Nitrogen, Carbon
Organophosphate
Incineration Products
Nutrients
Organic Distillates
Total Dissolved Sulfides.
Total Organic Carbon
A
100
100
60
40
80
20
-
20
-
-
-
20
20
-
-
-
-
-
-
-
-
20
20
-
-
Respondent
B C
88 67
88 33
38 33
25
25
33
67
-
25
25
25
33
12
-
-
-
12
12
12
-
33
-
-
12
12
Category
D E
67 60
33 40
100 40
33 40
-
33 20
33
67
20
33
- -
-
- -
-
33
-
-
-
- -
-
-
-
-
-
- -
Percent
of Total
P Respondent
40 72
20 59
41
60 34
20 24
20 17
10
10
10
10
7
7
7
20 4
4
20 4
4
4
4
20 4
4
4
4
4
4
A-17
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with respondents will be the crucial factor in the recognition
and acceptance of sediment criteria. A sampling of respondent
thoughts and concerns is presented in Table A-4.
A-18
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U.S. Environmental Protection Agency
Region 5, Library (5PL-16)
230 S. Dearborn St-eet, Boon 1670
Chicago, IL 60604
-------
TABLE A-4. REPRESENTATIVE COMMENTS FROM RESPONDENTS TO THE TELEPHONE
INTERVIEWS.
"If sediment criteria were based on good data, they could be used as part
of the assessment for whether or not testing was necessary." Corps of
Engineers
"Walk carefully. Nontechnical people want an easy number. This usually
results in overregulating or underregulating." Corps of Engineers
"Once there's a baseline, maybe we won't have to do analysis every time."
Corps of Engineers
"I like the partitioning-based idea of sediment criteria for hydrophobic
organics combined with field testing." Corps of Engineers
"If sediment criteria are related to bioaccumulation and toxicity they
would provide numerical criteria which could be used with bioassays." EPA
Region 1
"Sediment criteria should be commensurate with water quality advisories,
not criteria." EPA Region 1
"The present analytical methods aren't good enough for a certified
document. Sediment criteria should be issued in a guidance document."
EPA Region 2
"I basically doubt that a good baseline can be developed." EPA Region 2
"Sediment criteria would legitimize the decision to forego
bioassays...sediment criteria might provide a relaxation of the bioassay
requirement, which is very costly." EPA Region 4
"Pilot them. Try them in real-life situations." EPA Region 5
"Sediment criteria would be a parameter factored into the assessment of
dredging- or construction-generated sediments for disposal; a target for
sediment loading or contamination." EPA Region 9
"Strong scientific strength would be nice but right now it's seat-of-
the-pants anyway. Sediment criteria would give us a place to start." EPA
Region 9
"Sediment criteria would be a number to go by just like water quality
criteria to be used for enforcement vs best professional judgement. They
must be site specific and compared with a reference site, and must take
into account naturally occurring high values." EPA Region 9
"Sediment criteria must have more than a theoretical base. They must
incorporate field data and biological fate information, and must be
predictive." EPA Region 10
A-19
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